MANAGEMENT’S
ASSERTION OF COMPLIANCE



Management
of the Agency and Trust division of Citibank, N.A. (or “Company”) is responsible for assessing compliance with the
servicing criteria set forth in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission.



Management
has determined that the servicing criteria set forth in Item 1122(d) of Regulation AB are applicable in regard to the servicing
platform as of and for the period as follows:



Platform:
Publicly-issued (i.e., transaction-level reporting initially required under the Securities Exchange Act of 1934, as amended)
and certain privately-issued (i.e., for which transaction-level reporting is required pursuant to contractual obligation)
commercial mortgage-backed securities issued on or after January 1, 2011, as listed in Appendix A, for which the Company provides
the following servicing functions (the “Platform”):



| | • | paying
                                         agent, certificate administration and trustee; or
| | - | -------------------------------------------------------------------------------------------------

| | • | certificate
                                         administration and paying agent
| | - | ------------------------------------------------------------------------------------



Applicable
Servicing Criteria: All servicing criteria set forth in Item 1122(d), to the extent required by Item 1122(d) servicing criteria
in regards to the activities performed by the Company with respect to the Platform as to any transaction, except for the following
servicing criteria: 1122(d)(1)(iii), 1122(d)(4)(i)-1122(d)(4)(ii) and 1122(d)(4)(iv)-1122(d)(4)(xv), which management has determined
are not applicable to the activities the Company performs with respect to the Platform (the “Applicable Servicing Criteria”).
Servicing criterion 1122(d)(1)(v) is applicable only to the activities the Company performs related to the mathematically accurate
aggregation of information received from servicers and the accurate conveyance of such information within reports to investors.
Servicing criterion 1122(d)(4)(iii) is applicable to the activities the Company performs with respect to the Platform only as
it relates to the Company’s obligation to report additions, removals or substitutions on reports to investors in accordance
with the transaction agreements. With respect to servicing criteria 1122(d)(2)(iii) and 1122(d)(4)(iii), there were no activities
performed during the twelve months ended December 31, 2019 with respect to the Platform, because there were no occurrences of
events that would require the Company to perform such activities.



Period:
Twelve months ended December 31, 2019 (the “Period”).



With
respect to the Platform as of and for the Period, the Company’s management provides the following assertion of compliance
with respect to the Applicable Servicing Criteria:



| | • | The
                                         Company’s management is responsible for assessing the Company’s compliance
                                         with the Applicable Servicing Criteria.
| | - | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | • | The
                                         Company’s management has assessed compliance with the Applicable Servicing Criteria.
                                         In making this assessment, management used the criteria set forth by the Securities and
                                         Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | • | Based
                                         on such assessment, the Company has complied, in all material respects, with the Applicable
                                         Servicing Criteria.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------





KPMG
LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s assertion
of compliance with the Applicable Servicing Criteria as of and for the Period.















| | CITIBANK, N.A
| | -------------
| |              
| | By:          
| |              
| | Its:         
| |              



Dated:
February 28, 2020











Appendix
A



Mortgage-backed
Transactions and Securities Constituting the Platform





|DEAL
    NAME                 
|------------------------------
|BMARK
    2018-B3             
|BMARK
    2018-B6             
|BMARK
    2019-B12            
|BMARK
    2019-B15            
|BMARK
    2019-B9             
|CCMT
    2015-GC27            
|CCMT16C2                      
|CCMT16GC37                    
|CCMT16P4                      
|CCMT16P6                      
|CD
    2017-CD5 Mortgage Trust
|CF
    2019-CF1 Mortgage Trust
|CF
    2019-CF2 Mortgage Trust
|CFCRE
    2011-C2             
|CGBAM
    2015-SMRT           
|CGCMT
    2012-GC8            
|CGCMT
    2013-375P           
|CGCMT
    2013-GC15           
|CGCMT
    2013-GC17           
|CGCMT
    2013-GCJ11          
|CGCMT
    2014-GC23           
|CGCMT
    2014-GC25           
|CGCMT
    2015-GC29           
|CGCMT
    2015-GC31           
|CGCMT
    2015-GC33           
|CGCMT
    2015-GC35           
|CGCMT
    2015-P1             
|CGCMT
    2016-C1             
|CGCMT
    2016-C3             
|CGCMT
    2016-P3             
|CGCMT
    2016-P5             
|CGCMT
    2017-B1             
|CGCMT
    2017-C4             
|CGCMT
    2017-P7             
|CGCMT
    2017-P8             
|CGCMT
    2018-B2             
|CGCMT
    2018-C5             
|CGCMT
    2018-C6             
|CGCMT
    2019-C7             
|CGCMT
    2019-GC41           
|CGCMT
    2019-GC43           













CGCMT
225 Liberty Street Trust 2016-225L

GSMC 2011-GC3

GSMST-2011GC5

MAD
2019-650M

MSBAM
Trust Series 2014-C17