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PENTALPHA SURVEILLANCE
 
 i
 
 March 4, 2015
 
 
 Management's Report on Assessment of 2014 Compliance by Pentalpha
 Surveillance, LLC With Applicable Regulation AB Servicing Criteria
 
 
 Pentalpha Surveillance, LLC (the Asserting Party) is responsible for assessing its compliance, as of and for the year
 ended December 31, 2014, with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of
 Federal Regulations.
 
 The assessment concerns the Asserting Party's servicing efforts for its servicing "Platform," which consists of its
 servicing activities encompassed by contractual obligations to perform Regulation AB reporting (see the Exhibit for
 a list of the Asserting Party's Platform of required reporting by the servicing agreements).
 
 The Asserting Party has assessed its compliance with the applicable servicing criteria as of and for the year ended
 December 31, 2014. The Asserting Party used the criteria in Paragraph (d) of Section 1122 of Regulation AB (17
 C.F.R. 229.1122) to assess its compliance.
 
 Based on such assessment, the Asserting Party believes that as of and for the year ended December 31, 2014, the
 Asserting Party has complied in all material respects with the servicing criteria set forth in Item 1122(d) of
 Regulation AB relating to its operational advisor role in the servicing of the Platform, except for servicing criteria
 1122(d)(1)(i-iv), 1122(d)(2)(i-vii), 1122(d)(3)(i)(C-D) 1122(d)(3)(ii-iv), 1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv),
 which the Asserting Party has determined as being inapplicable to the activities it performs with respect to the
 Platform being serviced (the "applicable servicing criteria").
 
 McGladrey LLP, an independent registered public accounting firm, has issued an attestation report on the
 assessment of compliance with the applicable servicing criteria for the reporting period as set forth in this assertion.


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PENTALPHA SURVEILLANCE
 
 2
 Appendix A
 
 
 Regulation AB Reference
 
 Servicing Criterion
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 1122(d)(1)(iii)
 
 Any requirements in the transaction agreements to maintain a
 backup servicer for the pool assets are maintained.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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 of receipt, or such other number of
 days specified in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 1122(d)(2)(ii)
 
 Disbursements made via wire transfer on behalf of an obligor or to
 an investor are made only by authorized personnel.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.


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PENTALPHA SURVEILLANCE
 
 3
 Regulation AB Reference
 
 Servicing Criterion
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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
 §240.13k-1(b)(1) of this chapter.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 1122(d)(2)(vi)
 
 Unissued checks are safeguarded so as to prevent unauthorized
 access.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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: (A) are mathematically accurate; (B) are prepared
 within 30 calendar days after the bank statement cutoff date, or
 such other number of days specified in the transaction agreements;
 (C) are 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 1122(d)(3)(i)(A)
 
 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 are prepared in accordance with time frames and
 other terms set forth in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Applicable.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 1122(d)(3)(i)(B)
 
 
 
 Reports to investors, including those to be filed with the
 Commission, are maintained in accordance with the transaction


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PENTALPHA SURVEILLANCE
 
 4
 Regulation AB Reference
 
 Servicing Criterion
 
 
 
 agreements and applicable Commission requirements. Specifically,
 such reports provide information calculated in accordance with the
 terms specified in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Applicable.
 
 
 
 
 
 
 1122(d)(3)(i)(C)
 
 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 are filed with the Commission as required by its rules
 and regulations.
 
 
 
 Applicability/Compliance:
 
 Not Applicable.
 
 
 
 
 
 
 1122(d)(3)(i)(D)
 
 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 agree with investors' or the trustee's records as to the
 total unpaid principal balance and number of pool assets serviced
 by the servicer.
 
 
 
 Applicability/Compliance:
 
 Not Applicable.
 
 
 
 
 
 
 1122(d)(3)(ii)
 
 Amounts due to investors are allocated and remitted in accordance
 with time frames, distribution priority and other terms set forth in
 the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 1122(d)(3)(iv)
 
 Amounts remitted to investors per the investor reports agree with
 canceled checks, or other form of payment, or custodial bank
 statements.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 
 
 
 
 1122(d)(4)(i)
 
 Collateral or security on pool assets is maintained as required by
 the transaction agreements or related pool asset documents.
 
 
 
 Applicability/Compliance:
 
 Not applicable.


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PENTALPHA SURVEILLANCE
 
 5
 Regulation AB Reference
 
 Servicing Criterion
 
 
 
 
 
 
 
 
 
 1122(d)(4)(ii)
 
 Pool assets and related documents are safeguarded as required
 by the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 1122(d)(4)(iv)
 
 Payments on pool assets, including any payoffs, made in
 accordance with the related pool asset documents are posted to
 the applicable 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 1122(d)(4)(vi)
 
 Changes with respect to the terms or status of an obligor's pool
 
 asset (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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 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 time frames or other
 requirements established by the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Applicable.
 
 
 
 
 
 
 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


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PENTALPHA SURVEILLANCE
 
 6
 Regulation AB Reference
 
 Servicing Criterion
 
 
 
 rescheduling plans in cases where delinquency is deemed
 temporary (e.g., illness or unemployment).
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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 were returned to the obligor within 30 calendar
 days of full repayment of the related pool asset, or such other
 number of days specified in the transaction agreements.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 
 
 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.
 
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 1122(d)(4)(xiv)
 
 Delinquencies, charge-offs and uncollectible accounts are
 recognized and recorded in accordance with the transaction


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PENTALPHA SURVEILLANCE
 
 7
 Regulation AB Reference
 
 Servicing Criterion
 
 
 
 agreements.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 
 
 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.
 
 
 
 Applicability/Compliance:
 
 Not applicable.
 
 
 
 
 March 4, 2015
 
 
 
 
 _/s/____James Callahan____________________________
 James Callahan, Executive Director
 
 
 
 
 /s/____Don Simon_________________________________
 Don Simon, Chief Operating Officer


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PENTALPHA SURVEILLANCE
 
 8
 
 Appendix B
 
 
 Issuer
 
 Platform and Public Name of
 Securitization
 
 
 Master Servicer
 
 
 
 UBS Commercial Mortgage
 Securitization Corp.
 UBS-Barclays Commercial
 Mortgage Trust 2012-C2,
 Commercial Mortgage Pass-
 Through Certificates, Series 2012-
 C2
 Wells Fargo Bank, National
 Association
 
 
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2012-
 C8
 Wells Fargo Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities Corp.
 J.P. Morgan Chase Commercial
 Mortgage Securities Trust 2012-C8
 Commercial Mortgage Pass-
 Through Certificates, Series 2012-
 C-8
 Keycorp Real Estate Capital
 Markets, Inc.
 
 
 
 GS Mortgage Securities
 Corporation II
 Commercial Mortgage Pass-
 Through Certificates, Series 2012-
 GCJ9
 Wells Fargo Bank, National
 Association
 
 
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2012-
 C10
 Wells Fargo Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities Corp.
 J.P. Morgan Chase Commercial
 Mortgage Securities Trust 2012-
 LC9 Commercial Mortgage Pass-
 Through Certificates, Series 2012-
 LC9
 Midland Loan Services, a
 division of PNC Bank, National
 Association


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PENTALPHA SURVEILLANCE
 
 9
 
 
 
 
 Issuer
 Platform and Public Name of
 Securitization
 
 Master Servicer
 
 
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C12
 Wells Fargo Bank, National
 Association
 
 
 
 Citigroup Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 GCJ11
 Wells Fargo Bank, National
 Association
 
 
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C14
 Wells Fargo Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 J.P. Morgan Chase Commercial
 Mortgage Securities Trust 2013-
 LC11 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 LC11
 Midland Loan Services, a
 division of PNC Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2013-C12
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C12
 Midland Loan Services, a
 division of PNC Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 J.P. Morgan Chase Commercial
 Mortgage Securities Trust 2013-
 C13 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C13
 Midland Loan Services, a
 division of PNC Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2013-C14
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C14
 Midland Loan Services, a
 division of PNC Bank, National
 Association
 
 
 
 GS Mortgage Securities
 Corporation II
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 GCJ14
 Wells Fargo Bank, National
 Association
 
 
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C16
 Wells Fargo Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2013-C15
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C15
 Wells Fargo Bank, National
 Association
 
 
 
 
 
 
 
 Platform and Public Name of


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PENTALPHA SURVEILLANCE
 
 10
 Issuer
 Securitization
 Master Servicer
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 J.P. Morgan Chase Commercial
 Mortgage Securities Trust 2013-
 C16 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C16
 Wells Fargo Bank, National
 Association
 
 
 
 Citigroup Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 GC17
 Wells Fargo Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2013-C17
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C17
 Wells Fargo Bank, National
 Association
 
 
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2013-
 C18
 Wells Fargo Bank, National
 Association
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2014-C18
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C18
 
 Midland Loan Services, a
 division of PNC Bank, National
 Association
 
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C20
 Wells Fargo Bank, National
 Association
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2014-C19
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C19
 
 KeyBank, National Association
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMCC Commercial Mortgage
 Securities Trust 2014-C20
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C20
 
 Wells Fargo Bank, National
 Association
 
 
 GS Mortgage Securities
 Corporation II
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 GC22
 Wells Fargo Bank, National
 Association
 
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2014-C21
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C21
 Wells Fargo Bank, National
 Association
 
 
 
 
 Issuer
 
 Platform and Public Name of
 Securitization
 
 
 Master Servicer


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PENTALPHA SURVEILLANCE
 
 11
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2014-C22
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C22
 
 Wells Fargo Bank, National
 Association
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2014-C23
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C23
 
 Wells Fargo Bank, National
 Association
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2014-C24
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C24
 
 Wells Fargo Bank, National
 Association
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2014-C25
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C25
 
 Wells Fargo Bank, National
 Association
 
 
 J.P. Morgan Chase
 Commercial Mortgage
 Securities, Corp.
 JPMBB Commercial Mortgage
 Securities Trust 2014-C26
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C26
 
 Midland Loan Services, a
 division of PNC Bank, National
 Association
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C22
 Wells Fargo Bank, National
 Association
 
 
 Wells Fargo Commercial
 Mortgage Securities, Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C24
 Wells Fargo Bank, National
 Association
 
 
 GS Mortgage Securities
 Corporation II
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 GC26
 Wells Fargo Bank, National
 Association
 
 Deutsche Mortgage & Asset
 Receiving Corporation
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 UBS6
 KeyBank, National Association
 
 Morgan Stanley Capital I Inc.
 Commercial Mortgage Pass-
 Through Certificates, Series 2014-
 C17
 Wells Fargo Bank, National
 Association