** **

**
**Management’s Assertion on Compliance with Applicable**

**Regulation AB Servicing Criteria**

 

1.

Rialto Capital Advisors, LLC. (the “Asserting Party”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending December 31, 2018 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report, include commercial mortgage-asset-backed securities transactions, as listed on Exhibit 1 hereto, for which the Asserting Party served as special servicer, and that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933 (the “Platform”);

 

2.

The Asserting Party has engaged certain vendors, which are not servicers as defined in Item 1101(j) of Regulation AB (the “Vendors”), to perform specific, limited or scripted activities, and the Asserting Party elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors’ activities as set forth in Appendix A hereto;

 

3.

Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria;

 

4.

The criteria listed in the column titled “Inapplicable Servicing Criteria” on Appendix A hereto are inapplicable to the Asserting Party based on the activities it performs, directly or through its Vendors, with respect to the Platform;

 

5.

The Asserting Party has complied, in all material respects, with the applicable servicing criteria as of December 31, 2018 and for the Reporting Period with respect to the Platform taken as a whole;

 

6.

The Asserting Party has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria as of December 31, 2018 and for the Reporting Period with respect to the Platform taken as a whole;

 

7.

The Asserting Party has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria as of December 31, 2018 and for the Reporting Period with respect to the Platform taken as a whole; and

 

8.

Deloitte & Touche LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party’s assessment of compliance with the applicable servicing criteria for the Reporting Period.

 

 
 
October 18, 2019

 

 

 

Name: Adam Singer

 

Title: Managing Director

 

Signature:

 /s/ Adam Singer

 

 
**

 

  

 

 

**
****Exhibit 1****

 

****Pooling and Servicing Agreements****

****Reporting Period****

WFRBS 2012-C8

January 1, 2018 to December 31, 2018

WFCM 2012-LC5

January 1, 2018 to December 31, 2018

UBS-Barclays 2012-C3

January 1, 2018 to December 31, 2018

UBS-Barclays 2012-C4

January 1, 2018 to December 31, 2018

GSMS 2012-GCJ9

January 1, 2018 to December 31, 2018

JPMCC 2012-LC9

January 1, 2018 to December 31, 2018

COMM 2013-LC6

January 1, 2018 to December 31, 2018

WFRBS 2013-C12

January 1, 2018 to December 31, 2018

UBS-Barclays 2013-C6

January 1, 2018 to December 31, 2018

GSMS 2013-GCJ12

January 1, 2018 to December 31, 2018

WFRBS 2013-C14

January 1, 2018 to December 31, 2018

WFRBS 2011-C5

January 1, 2018 to December 31, 2018

WFCM 2013-LC12

January 1, 2018 to December 31, 2018

WFRBS 2011-C2

January 1, 2018 to December 31, 2018

WFRBS 2011-C3

January 1, 2018 to December 31, 2018

WFRBS 2011-C4

January 1, 2018 to December 31, 2018

UBS-Citigroup 2011-C1

January 1, 2018 to December 31, 2018

UBS 2012-C1

January 1, 2018 to December 31, 2018

WFRBS 2012-C6

January 1, 2018 to December 31, 2018

GSMS 2011-GC3

January 1, 2018 to December 31, 2018

COMM 2013-LC13

January 1, 2018 to December 31, 2018

WFRBS 2013-C16

January 1, 2018 to December 31, 2018

GSMS 2013-GCJ16

January 1, 2018 to December 31, 2018

WFRBS 2013-C17

January 1, 2018 to December 31, 2018

GSMS 2012-GC6

January 1, 2018 to December 31, 2018

MSBAM 2013-C13

January 1, 2018 to December 31, 2018

COMM 2014-CCRE14

January 1, 2018 to December 31, 2018

MSBAM 2014-C14

January 1, 2018 to December 31, 2018

WFRBS 2014-LC14

January 1, 2018 to December 31, 2018

COMM 2014-LC15

January 1, 2018 to December 31, 2018

WFRBS 2014-C20

January 1, 2018 to December 31, 2018

COMM 2014-CCRE18

January 1, 2018 to December 31, 2018

CGCMT 2014-GC23

January 1, 2018 to December 31, 2018

MSBAM 2014-C17

January 1, 2018 to December 31, 2018

COMM 2014-UBS5

January 1, 2018 to December 31, 2018

MSBAM 2014-C18

January 1, 2018 to December 31, 2018

COMM 2012-CCRE4

January 1, 2018 to December 31, 2018

COMM 2012-LC4

January 1, 2018 to May 31, 2018

WFRBS 2014-C24

January 1, 2018 to December 31, 2018

JPMBB 2014-C25

January 1, 2018 to December 31, 2018

LCCM 2014-909

January 1, 2018 to December 31, 2018

WFCM 2014-LC18

January 1, 2018 to December 31, 2018

COMM 2015-DC1

January 1, 2018 to December 31, 2018

GSMS 2015-GC28

January 1, 2018 to December 31, 2018

WFCM 2015-C27

January 1, 2018 to December 31, 2018

WFCM 2015-LC20

January 1, 2018 to December 31, 2018

WFCM 2015-NXS1

January 1, 2018 to December 31, 2018

CSAIL 2015-C2

January 1, 2018 to December 31, 2018

WFCM 2015-NXS2

January 1, 2018 to December 31, 2018

COMM 2015-PC1

January 1, 2018 to December 31, 2018

CSAIL 2015-C3

January 1, 2018 to December 31, 2018

WFCM 2015-SG1

January 1, 2018 to December 31, 2018

 
**

 

2 
 

 

WFCM 2015-LC22

January 1, 2018 to December 31, 2018

COMM 2015-CCRE27

January 1, 2018 to December 31, 2018

WFCM 2015-NXS4

January 1, 2018 to December 31, 2018

MSCI 2015-UBS8

January 1, 2018 to December 31, 2018

CSAIL 2016-C5

January 1, 2018 to December 31, 2018

WFCM 2016-C32

January 1, 2018 to December 31, 2018

WFCM 2016-NXS5

January 1, 2018 to December 31, 2018

CGCMT 2015-GC27 (Special Servicer solely for the Boca Hamptons Plaza Portfolio Loan prior to July 5, 2018 and named Special Servicer under the applicable Pooling and Servicing Agreement from and after July 5, 2018 through December 31, 2018)

January 1, 2018 to December 31, 2018

WFCM 2016-C33

January 1, 2018 to December 31, 2018

MSBAM 2016-C29

January 1, 2018 to December 31, 2018

CFCRE 2016-C4

January 1, 2018 to December 31, 2018

GSMS 2016-GS2 (Special Servicer solely for the Veritas Multifamily Pool 2 only)

January 1, 2018 to December 31, 2018

BACM 2016-UBS10

January 1, 2018 to December 31, 2018

SGCMS 2016-C5

January 1, 2018 to December 31, 2018

WFCM 2016-BNK1

January 1, 2018 to December 31, 2018

CD 2016-CD1

January 1, 2018 to December 31, 2018

GSMS 2016-GS3

January 1, 2018 to December 31, 2018

MSBAM 2016-C31

January 1, 2018 to December 31, 2018

CGCMT 2016-C3

January 1, 2018 to December 31, 2018

CFCRE 2016-C6

January 1, 2018 to December 31, 2018

CSAIL 2016-C7

January 1, 2018 to December 31, 2018

MSCI 2016-UBS12

January 1, 2018 to December 31, 2018

BBCMS 2017-C1

January 1, 2018 to December 31, 2018

GSMS 2017-GS5

January 1, 2018 to December 31, 2018

CGCMT 2017-P7

January 1, 2018 to December 31, 2018

BANK 2017-BNK4

January 1, 2018 to December 31, 2018

CD 2017-CD4

January 1, 2018 to December 31, 2018

CFCRE 2017-C8

January 1, 2018 to December 31, 2018

JPMCC 2017-JP6

January 1, 2018 to December 31, 2018

CD 2017-CD5

January 1, 2018 to December 31, 2018

GSMS 2017-GS7

January 1, 2018 to December 31, 2018

BANK 2017-BNK7

January 1, 2018 to December 31, 2018

CSAIL 2017-CX9

January 1, 2018 to December 31, 2018

UBS 2017-C4

January 1, 2018 to December 31, 2018

UBS 2017-C6

January 1, 2018 to December 31, 2018

BANK 2017-BNK9

January 1, 2018 to December 31, 2018

GSMS 2018-GS9

March 29, 2018 to December 31, 2018

UBS 2018-C9

March 29, 2018 to December 31, 2018

MSCI 2012-C5

April 13, 2018 to December 31, 2018

WFCM 2018-C44

May 17, 2018 to December 31, 2018

UBS 2018-C10

May 31, 2018 to December 31, 2018

WFCM 2015-C30

July 5, 2018 to December 31, 2018

JPMBB 2014-C23

July 5, 2018 to December 31, 2018

MSBAM 2014-C19

July 5, 2018 to December 31, 2018

COMM 2015-LC21

July 5, 2018 to December 31, 2018

MSBAM 2015-C20

July 5, 2018 to December 31, 2018

JPMBB 2015-C31

July 5, 2018 to December 31, 2018

GSMS 2018-GS10

July 30,2018 to December 31, 2018

CD 2018-CD7

August 24, 2018 to December 31, 2018

GSMS 2018-3PCK

September 27, 2018 to December 31, 2018

BANK 2018-BNK14

September 27, 2018 to December 31, 2018

DBGS 2018-C1

October 30, 2018 to December 31, 2018

CSAIL 2018-C14

November 29, 2018 to December 31, 2018

UBS 2018-C14

December 12, 2018 to December 31, 2018

 

 

3 
 

 

**APPENDIX A**

 

**Servicing Criteria**

** **

** **

**Reference**

**Criteria**

**Performed by Servicer**

**Inapplicable Servicing Criteria**

 

**General Servicing Considerations**

 

 

1122(d)(1)(i)

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.

**X**

** **

1122(d)(1)(ii)

If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.

** **

**X1**

** **

1122(d)(1)(iii)

Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.

** **

**X**

1122(d)(1)(iv)

A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements.

** **

**X**

** **

** **

1122(d)(i)(v)

Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.

** X**

****

** **

 

**Cash Collection and Administration**

** **

** **

1122(d)(2)(i)

Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the transaction agreements.

** **

****

**X**

 

 

1122(d)(2)(ii)

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

** **

**X3**

1122(d)(2)(iii)

Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.

** **

**X3**

1122(d)(2)(iv)

The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.

**X**

** **

 

 

4 
 

 

**Servicing Criteria**

** **

** **

**Reference**

**Criteria**

**Performed by Servicer**

**Inapplicable Servicing Criteria**

1122(d)(2)(v)

Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.

**X**

** **

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

**X**

** **

1122(d)(2)(vii)

Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; and (D) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements.

** **

** **

** **

** **

** **

**X**

** **

 

**Investor Remittances and Reporting**

** **

** **

1122(d)(3)(i)

Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the Servicer.

**X4**

** **

1122(d)(3)(ii)

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

** **

**X**

1122(d)(3)(iii)

Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.

** **

**X**

1122(d)(3)(iv)

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

** **

**X**

 

**Pool Asset Administration**

** **

** **

1122(d)(4)(i)

Collateral or security on pool assets is maintained as required by the transaction agreements or related mortgage loan documents.

**X**

** **

1122(d)(4)(ii)

pool asset and related documents are safeguarded as required by the transaction agreements

**X**

** **

 

 

5 
 

 

**Servicing Criteria**

** **

** **

**Reference**

**Criteria**

**Performed byServicer**

**Inapplicable Servicing Criteria**

1122(d)(4)(iii)

Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.

**X**

** **

1122(d)(4)(iv)

Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related pool asset documents.

** **

**X2**

1122(d)(4)(v)

The Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.

** **

**X**

1122(d)(4)(vi)

Changes with respect to the terms or status of an obligor’s pool assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.

**X**

** **

1122(d)(4)(vii)

Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.

** **

** **

**X**

** **

1122(d)(4)(viii)

Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).

** **

** **

** **

** **

**X**

** **

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

** **

**X**

1122(d)(4)(x)

Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements.

** **

**X**

 

 

6 
 

 

**Servicing Criteria**

** **

** **

**Reference**

**Criteria**

**Performedby****Servicer**

**Inapplicable Servicing Criteria**

1122(d)(4)(xi)

Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.

** **

**X**

1122(d)(4)(xii)

Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission.

** **

**X**

1122(d)(4)(xiii)

Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the Servicer, or such other number of days specified in the transaction agreements.

** **

**X**

1122(d)(4)(xiv)

Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

 

** **

**X**

****

1122(d)(4)(xv)

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.

** **

**X**

 

 

 

 

**X1**- Rialto Capital Advisors, LLC performs the activities pertaining to this criterion, except for specific, limited activities performed by its third-party property managers relating to REO Property, if any.  Rialto has elected to take responsibility for assessing compliance with these servicing criteria with respect to the activities of its third-party property managers.

 

**X2**-Primary responsibility for processing borrower payments rests with the Master Servicer, however, Rialto Capital Advisors, LLC may from time to time receive payments on an exception basis which are forwarded to the Master Servicer in accordance with such criteria. The criteria is marked inapplicable as Rialto Capital Advisors, LLC had no instances or activity relating to this criteria for the calendar year of January 1, 2018 to December 31, 2018.

 

**X3**-RialtoCapital Advisors, LLC performs the activities under the criteria, however the related criteria are marked inapplicable as Rialtodid not have instances/activity during the calendar year of January 1, 2018 and ending on December 31, 2018 relating to the criteria. 

 

**X4**-Onlyitems (A) and (B) of the Servicing Criteria are applicable to Rialto Capital Advisors, LLC as special servicer.  Items (C)and (D) are inapplicable as the responsibility for filing reports with the Commission and agreeing totals to the Servicer recordsrests with the Trustee and/or Certificate Administrator, as applicable.

 

 

7