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REPORT
OFINDEPENDENT REGISTERED
PUBLIC ACCOUNTING FIRM



Rialto
Capital Advisors, LLC.





We
have examined management of Rialto
Capital Advisors, LLC’s
assertion, included
in theaccompanyingManagement’s Assertion
on Compliance with Applicable Regulation
AB Servicing Criteria,that Rialto
Capital Advisors, LLC, (the
“Company”) complied with the servicing criteria set forth in
Item 1122(d)of
the Securities and Exchange Commission’s
Regulation AB for the commercial mortgage loan platform (the “Platform”),
excluding
criteria
in Items 1122 (d)(1)(iii),
(d)(2)(ii),
(d)(2)(iii), (d)(3)(i.C), (d)(3)(i.D), (d)(3)(ii), (d)(3)(iii),
(d)(3)(iv), (d)(4)(v), (d)(4)(ix),(d)(4)(x),
(d)(4)(xi), (d)(4)(xii),
(d)(4)(xiii),
(d)(4)(xiv),
and (d)(4)(xv)
(the “servicing
criteria”), as of and for the year endedDecember 31,
2019, which management has determined are not applicable to the activities performed by the Company with respect
to the Platform. Exhibit
1 to management’s assertion identifiesthe
individual asset-backed
transactions defined by
management
as constituting the Platform.
Management is responsible for the
Company’s compliance with the servicing criteria and itsassertion.Ourresponsibilityis
to express an opinion on management’s
assertion about the Company’s
compliancewith
the servicing criteria based on our
examination.



Our
examination was conducted in accordance with the standards of the Public Company Accounting  Oversight Board (United
States) and in accordance with attestation standards established by the American Institute of Certified  Public Accountants.
Those standards require that we plan and perform the examination to obtain  reasonable assurance about whether management’s
assertion about compliance with the servicing criteria is fairly stated, in all material respects, and, accordingly, included
examining, on a test basis, evidence about  the Company’s compliance with the servicing criteria, including tests  on a
sample basis of the servicing activities related to the Platform, determining whether theCompany performed those
selected activities in compliance with the servicing criteria duringthe specified period, and performing such other
procedures as we considered necessary in the circumstances. Our procedures were limited to selected servicing activities
performed by the Company during the period covered by this report and, accordingly, such samples may not have included
servicing activities related to each asset-backed transaction included in the Platform. Further, an examination is not
designed to detect noncompliance arising from errors that may have occurred prior to the period specified above that may have
affected the balances or amounts calculated or reported by the Company during the period covered by this report. We
believe that the evidence we obtained in our examination is sufficient and appropriate to provide a reasonable basis for our
opinion.












As
described in management’s assertion, for servicing criteria Item 1122(d)(1)(ii), the Company has engaged a vendor  to perform
certain activities required by this servicing criteria. The Company has determined that this vendor  is not considered a
“servicer” as defined  in Item 1101(j) of Regulation AB, and the Company  has elected to take responsibility for
assessing compliance with the servicing criteria applicable to this vendor as permitted by the SEC’s Compliance and
Disclosure Interpretation 200.06, Vendors Engaged by Servicers (“C&DI 200.06”). As permitted by C&DI
200.06, the Company has asserted that  it has policies and procedures in place designed to provide reasonableassurance
that the vendor’s activities comply in all material respects with the servicing criteria applicable to this vendor.
The Company is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendor
and related criteria as described in its assertion, and we performed no procedures with respect to the Company’s
determination of its eligibility to apply C&DI 200.06.



Our
examination does not provide a legaldetermination on the Company’scompliancewith the servicing criteria.



Inour opinion,management’s assertion that the
Company complied with theaforementioned
servicing criteria as of and for the year ended
December 31, 2019, forthecommercial
mortgage loan platform,
is fairly stated, in all material respects.





/s/
Deloitte & Touche LLP

February
28, 2020



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