**Management’s Certification on Compliance withApplicable Servicing Criteria**

 

PGIM Real Estate LoanServices, Inc. (“PGIM RELS”) is responsible for assessing compliance with theservicing criteria applicable to PGIM RELS under paragraph (d) of Item 1122 ofRegulation AB (the “Servicing Criteria”), as of and for the year ended December31, 2023, (the ”Reporting Period”) as set forth in Exhibit A hereto inconnection with all commercial mortgage loans serviced within the Platform, asset forth in Exhibit B, during the applicable period;

 

1.       Exceptas set forth in paragraph 3 and 4 below, the Asserting Parties used thecriteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess thecompliance with the Servicing Criteria;

 

2.       Thecriteria described as not applicable on Exhibit A hereto areinapplicable to the Asserting Parties based on the activities of PGIM RELSperformed with respect to commercial mortgage securities transactions involvingmortgage loans, also PGIM RELS has identified specific servicing criteria forwhich no transaction activity occurred;

 

3.       PGIMRELS has engaged certain vendor(s), which are not deemed to be servicers asdefined in Item 1101(j) of Regulation AB (the “Vendor(s)”), to perform specificand limited activities or activities scripted by PGIM RELS as of and during theReporting Period, and PGIM RELS elects to take responsibility for assessingcompliance with the Servicing Criteria or portion of the Servicing Criteriaapplicable to such Vendor(s), excluding CoreLogic Solutions, LLC (“CoreLogic”)as set forth in Exhibit A hereto (such criteria, the “Applicable VendorServicing Criteria”).

 

PGIM RELS haspolicies and procedures in place designed to provide reasonable assurance thatthe Vendor(s)’ activities comply in all material respects for purposes ofRegulation AB with the Applicable Vendor Servicing Criteria. PGIM RELS (i) hasnot identified and is not aware of any material instance of noncompliance bythe Vendor(s) with the Applicable Vendor Servicing Criteria that would affectPGIM RELS’s compliance and (ii) has not identified any material deficiency inPGIM RELS’s policies and procedures to monitor the compliance by the Vendor(s)with the Applicable Vendor Servicing Criteria as of December 31, 2023 and forthe Reporting Period.

 

4.       PGIMRELS has engaged CoreLogic to perform specific and limited activities as of andduring the Reporting Period. PGIM RELS is relying on CoreLogic’s Management’sReport on Assessment of Compliance with SEC Regulation AB Servicing Criteria,which includes commercial mortgage loan outsourcing customers for which CoreLogicacted as the tax service provider, as issued by Grant Thornton LLP, datedJanuary 31, 2024 with respect to the Applicable Vendor Servicing Criteriaapplicable to CoreLogic.

 

5.       PGIMRELS has complied, in all material respects, with the Servicing Criteria as ofand for the year ending December 31, 2023; and

 

6.       PricewaterhouseCoopersLLP has issued an attestation report with respect to PGIM RELS’s assessment ofcompliance with the Servicing Criteria as of and for the year ended December 31,2023.

 

February 23, 2024

 

PGIM Real Estate Loan Services, Inc.

 

/s/ Joni Brown-Haas

Joni Brown-Haas, President 

 

/s/ Keith Kehlbeck

Keith Kehlbeck, Vice President

 

 

| ** **                                                        | ** **                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | **EXHIBIT A**

** **            |
|-------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------|
| **SERVICING********CRITERIA**

**Reg********AB********Portfolio** | **APPLICABLE  SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | **INAPPLICABLE  SERVICING CRITERIA** |
|  

Reference                                                 |  

Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Performed by

Servicer               | Performed by Vendor(s) | Performed by

Other Servicers |   |
| **General********Servicing********Considerations**                |
| 1122(d)(1)(i)                                                     | Policiesandproceduresareinstituted to monitor any performance  or other triggers and events of default in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Y                                    |   |   |   |
| 1122(d)(1)(ii)                                                    | If any material servicing activities are outsourcedtothirdparties,policiesand  proceduresareinstitutedtomonitorthe third party’s performance and  compliance with such servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                    |   |   |   |
| 1122(d)(1)(iii)                                                   | Anyrequirementsinthetransactionag reements to maintain a back-up servicer for the mortgage  loans are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                 |   |   | N/A |
| 1122(d)(1)(iv)                                                    | If a Fidelity bond and errors and omissionspolicyisineffectonthe party participatingintheservicing function throughout the  reporting period in the amount of coverage required by and otherwise in  accordance with the terms of the transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                 | Y#1                                  |   |   |   |
| 1122(d)(1)(v)                                                     | Aggregation of information, as applicable,ismathematicallyaccurate and the information conveyed  accuratelyreflectstheinformation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                    |   |   |   |
| **Cash********Collection********and********Administration**       |
| 1122(d)(2)(i)                                                     | Payments on Pool assets are deposited into  the appropriate custodial bank account and related bank clearing accountsnomorethan2businessdaysof  receipt,orsuchnumberofdaysspecified in the transaction agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Y                                    |   |   |   |
| 1122(d)(2)(ii)                                                    | Disbursementsmadeviawiretransferon behalf of an  obligor or to an investor are made only by authorized personnel                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Y                                    |   | Y#2 |   |
| 1122(d)(2)(iii)                                                   | Advances of funds or guarantees regarding collections,  cash flows or distributions and any interest or other feeschargedforsuchadvancesaremade,  reviewed, and approved as specified in the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Y                                    |   |   |   |
| 1122(d)(2)(iv)                                                    | The related accounts for the transaction, suchascashreserveaccountsoraccounts established as a form of O/C,  are separately maintained as set forth in the transactionagreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                    |   |   |   |
| 1122(d)(2)(v)                                                     | Each  custodial account is maintained at afederallyinsureddepositoryinstitution assetforthinthetransactionagreement. For purposes of this  criterion,‘federally insured  depository institution” with respect to a foreign financial institution meansaforeignfinancialinstitutionthat  meets the requirements of Rule 13K- 1(b)(1)oftheSecuritiesExchange Act.                                                                                                                                                                                                                                                                                                  | Y                                    |   |   |   |
| 1122(d)(2)(vi)                                                    | Unissuedchecksaresafeguardedsoas to prevent unauthorized access                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                    | Y#2a | Y#2 |   |
| 1122(d)(2)(vii)                                                   | Reconciliations are prepared on a monthly basis for all  asset-backed securities related bank accounts, includingcustodialaccountsandrelated bank clearing accounts: (1) Are  mathematically accurate; (2) Are prepared within 30 calendar days after the  bank statement cut-off date, or such other number of days specified in the  transactionagreement;(3)Arereviewed andapprovedbysomeoneotherthanthe person who prepared  the reconciliation; and (4) 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 thetransactionagreements | Y                                    |   |   |   |
| **Investor********Remittances********and********Reporting**       |
| 1122(d)(3)(i)                                                     | i) Reports to investors, including those to be filed  with the Commission, are maintained in accordance with the transaction  agreements and applicable Commissionrequirements.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 withthe terms specified in the transaction  agreements; (C) Are filed with the Commission as requiredbyitsrulesandregulations;(D) Agree with investors' or the  trustee's records as to the total unpaid principal; balance and number of  pool assets servicedbytheservicer.                          | Y#6for (A&B)                     |   |   | N/Afor(C&D) |
| 1122(d)(3)(ii)                                                    | AmountsduetoInvestorsareallocated  and remitted in accordance with timeframes, distribution priority and other  terms set forth in the transaction agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                 |   |   | N/A |
| 1122(d)(3)(iii)                                                   | Disbursements  made to an Investor are posted within 2 business days to the Servicersinvestorrecords,orsuchother number of days specified in the transactionagreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                 |   |   | N/A |
| 1122(d)(3)(iv)                                                    | Amountsremittedtoinvestorsperthe investor reports agree with cancelled checks, or other form of payment,  or custodial bank statement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                 |   |   | N/A |
| **Pool********Asset********Administration**                       |
| 1122(d)(4)(i)                                                     | Collateralorsecurityonmortgageloans is maintained as required by the transaction  agreements or related pool asset documents                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Y                                    |   |   |   |
| 1122(d)(4)(ii)                                                    | Mortgageloanandrelateddocuments are safeguarded as required  by the transaction agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Y#3                                  |   |   |   |
| 1122(d)(4)(iii)                                                   | Anyadditions,removalsorsubstitutions totheassetpoolaremade,reviewedand approved in accordance with any conditionsorrequirements  inthe transaction agreement                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Y#4                                  |   |   |   |
| 1122(d)(4)(iv)                                                    | Payments  on mortgage loans, including any payoffs, made in accordance with the related  mortgage loan asset documents are posted to the applicable servicer's obligor  records maintained no more than 2 business days after receipt, or such other  number of days specified, intransactionagreementandallocatedto Principal, Interest, or other items  in accordance with the related mortgage loan  documents                                                                                                                                                                                                                                                            | Y                                    |   |   |   |
| 1122(d)(4)(v)                                                     | The  Servicer's records regarding the mortgageloansagreewiththeservicer's records with  respect to an obligor's unpaidprincipalbalance                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y                                    |   |   |   |
| 1122(d)(4)(vi)                                                    | Changes with respect to terms or status ofanobligor'smortgageloans(e.g.,loan modifications or re-agings) are made,  reviewed and approved by authorized personnel in accordance with the  transactionagreementsandrelatedpool asset  documents.                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                    |   |   |   |
| 1122(d)(4)(vii)                                                   | Lossmitigationorrecoveryactions(e.g., forbearance plans, modifications and deedinlieuofforeclosure,foreclosures  and repossessions, as applicable) are initiated, conducted and  concluded in accordancewiththetimeframesorother  requirements established by the transactionagreements                                                                                                                                                                                                                                                                                                                                                                                      | Y#5                                  |   |   |   |
| 1122(d)(4)(viii)                                                  | Records  documenting collection efforts are maintained during a period a pool asset is  delinquent in accordance with the transaction agreement. Such records are  maintained on at least a monthly basis, or such other period specified in thetransactionagreements,anddescribe the entity's activities in  monitoring delinquentmortgageloansincluding,for example,  phone calls, letters and payment rescheduling plans in cases wheredelinquencyisdeemedtemporary (e.g.illnessor unemployment).                                                                                                                                                                         | Y                                    |   |   |   |
| 1122(d)(4)(ix)                                                    | Adjustments to interest rate or rates of returnformortgageloanswithvariable ratesarecomputedbasedontherelated  pool asset documents                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Y                                    |   |   |   |
| 1122(d)(4)(x)                                                     | Regarding any funds held in trust for anobligor(suchasescrowaccounts): (A) such funds are analyzed, in accordancewiththeobligor’smortgage loan documents, on at least an annual basis, or such  other period specified in the transaction agreements;(B)interestonsuch  funds is paid, or credited, to obligors in accordance with applicable  mortgage loan documents and state laws; and (C) such funds are returned to the  obligor within 30 calendar days of full repaymentoftherelatedmortgageloans, or  such other number of days specified inthetransaction agreements.                                                                                        | Y                                    |   |   |   |
| 1122(d)(4)(xi)                                                    | Payments  made on behalf of an obligor (such as tax or insurance payments) are made onor beforethe related penalty or expiration dates, as indicated on the  appropriate bills or notices for such payments, provided that such support  hasbeenreceivedbytheserviceratleast  30 calendar days prior to these dates, or suchothernumberofdaysspecifiedin the transaction agreements.                                                                                                                                                                                                                                                                                         | Y                                    |   | Y#2 |   |
| 1122(d)(4)(xii)                                                   | Any late payment penalties inconnectionwithanypaymenttobemade  on behalf ofan obligor arepaid fromthe servicer's funds and not charged to the obligor,unlessthe late paymentwasdue totheobligor'serroror omission                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Y#2b                                 |   |   |   |
| **1122**(d)(4)(xiii)                                              | Disbursementsmadeonbehalfofobligor  are posted within 2 business days to the obligor's records maintained by the  Servicer, or such other number of days specifiedinthetransactionagreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Y                                    |   |   |   |
| 1122(d)(4)(xiv)                                                   | Delinquencies,  charge-offs, and uncollectedaccountsarerecognizedand recorded in  accordance with the transactionagreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Y                                    |   |   |   |
| 1122(d)(4)(xv)                                                    | Any  external enhancement or other support, identified in item 1114(a)(1) through(3)orItem1115ofRegulation  AB, is maintained as set forth in the transagreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                 |   |   | N/A |

 

**Y** = Yes

 

**Y#1** = Fidelity bond and errors and omissions policies inforce for Prudential. In addition, fidelity bond and errors and omissionspolicies are in force for the following servicer: CoreLogic Solutions, LLC(“CoreLogic”) ($2MM).

** **

**Y#2** = PGIM RELS uses Corelogic, a servicer, for theprocess of paying property taxes to the local government taxing authorities.Payment is made only after review, authorization and transfer of funds iscompleted by PGIM RELS. Policies and procedures are in place to monitor thisservicer.

 

**Y#2a** = In 4Q 2021, Fidelity National Information Services,Inc. (“FIS”), an existing Prudential vendor, started printing checks on behalfof PGIM RELS. FIS handles this process on a large scale across multiplePrudential affiliates. As a result, PGIM RELS adopted FIS’s existing Policiesand Procedures.

 

**Y#2b** - To the extent there is a late payment penalty thatis not due to the obligor’s error or omission, such late payment penalty wouldbe paid by PGIM RELS or CoreLogic, depending on the circumstances giving riseto the late payment.

 

**Y#3** = As outlined in the PSAs, the primary responsibilityfor safeguarding all original documents (except Letters of Credit, which areheld by PGIM RELS) is with the named Document Custodian. The named Trustee hasoversight responsibility for the Document Custodian, not the Servicer. However,to the extent that loans are secured by Letters of Credit or loans are modifiedor some other credit action occurs which generates a new or revised loandocument, then Servicer complies with this criterion.

 

**Y#4** = PGIM RELS’ role related to additions, removals orsubstitutions to the asset pool only occurs after a decision is made to somodify the asset pool. The responsibility and any decisions related toadditions, removals or substitutions to the asset pool is with the Trustee,Issuer and related mortgage loan seller. PGIM RELS as Servicer has notexperienced any of these types of actions in its CMBS asset pools.

 

**Y#5** = There are currently no transactions during the year thatapplied to this servicing criteria within the Reg AB portfolio where PGIM RELSwas named the special servicer.

 

**Y#6** = PGIM RELS does not report to investors but reportsonly to the master servicer and/or trustee.

 

**N/A** = Not applicable, as the criteria is not theresponsibility of the primary/master servicer or no event has occurred whichtriggered an action by the primary/master servicer.

 

 

**Exhibit B**

 

List of Commercial Mortgage-Backed SecurityTransactions – RegAB Portfolio

 

 

 

1. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2004-PWR3("BSCMS 2004-PWR3")

 

2.  Bear Stearns CommercialMortgage Securities II Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2004-PWR6("BSCMS 2004-PWR6")

 

3. Bear Stearns CommercialMortgage Securities II Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2005-PWR10("BSCMS 2005-PWR10")

 

4. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2007-PWR16("BSCMS 2007-PWR16")

 

5. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-ThroughCertificates, Series 2007-PWR17("BSCMS 2007-PWR17")

 

6. RBS Commercial MortgageTrust 2013-C11, Commercial Mortgage Pass-Through Certificates,Series 2013-C11

 

7. WFRBS CommercialMortgage Trust 2013-C12, Commercial Mortgage Pass-Through Certificates, Series2013-C12

 

8. WFRBS CommercialMortgage Trust 2013-C13, Commercial Mortgage Pass-Through Certificates, Series2013-C13

 

9. WFRBS CommercialMortgage Trust 2013-C14, Commercial Mortgage Pass-Through Certificates, Series2013-C14

 

10. RBS CommercialMortgage Trust 2013-C15, Commercial Mortgage Pass-Through Certificates,Series 2013-C15

 

11. WFRBS CommercialMortgage Trust 2013-C16, Commercial Mortgage Pass-Through Certificates, Series2013-C16

 

12. WFRBS CommercialMortgage Trust 2013-C17, Commercial Mortgage Pass-Through Certificates, Series2013-C17

 

13. WFRBS CommercialMortgage Trust 2012-C10, Commercial Mortgage Pass-Through Certificates, Series2012-C10

 

14. WFRBS CommercialMortgage Trust 2013-C18, Commercial Mortgage Pass-Through Certificates, Series2013-C18

 

15. Commercial MortgageTrust 2013-CCRE13, Commercial Mortgage Pass-Through Certificates,Series 2013-CCRE13

 

16. Commercial MortgageTrust 2014-CCRE14, Commercial Mortgage Pass Through Certificates,Series 2014- CCRE14

 

17. RBS CommercialMortgageTrust 2014-C19, CommercialMortgage Pass Through Certificates,Series2014-C19

 

18. WFRBSCommercialMortgageTrust2014-C20,CommercialMortgagePass-Through Certificates,Series2014-C20

 

19. 20RBS CommercialMortgage Trust-2014-C21, Commercial Mortgage Pass-Through Certificates,Series 2014-C21

 

20. WFRBS CommercialMortgageTrust 2014-C22, CommercialMortgage Pass-Through Certificates, Series 2014-C22

 

21. RBS CommercialMortgage Trust 2014-C23, Commercial Mortgage Pass-Through Certificates,Series 2014-C23

 

22. WFRBS CommercialMortgage Trust 2014-C24, Commercial Mortgage Pass-Through Certificates, Series2014-C24

 

23. WCMF CommercialMortgage Trust 2014-LC18, Commercial Mortgage Pass–Through Certificates, Series2014-LC18

 

24. RBS CommercialMortgage Trust 2014-C25, Commercial Mortgage Pass-Through Certificates,Series 2014-C25

 

25. WFCMCommercialMortgagePass-ThroughCertificates,Series2015-C26

 

26. WFCMCommercialMortgagePass-ThroughCertificates,Series2015-C27

 

27. WFCMCommercialMortgagePass-ThroughCertificates,Series2015-C28

 

28. WFCMCommercialMortgagePass-ThroughCertificates,Series2015-SG1

 

29. WFCMCommercialMortgagePass-ThroughCertificates,Series2015-C31

 

30. CFCRE 2016-C3Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2016-C3

 

31. SG CommercialMortgage Securities Trust 2016-Cs, Commercial Mortgage Pass- ThroughCertificates Series 2016-C5