** **

** **

**  **

**Management’sAssertion on Compliance with Applicable**

**RegulationAB Servicing Criteria**

** **

 

1.       Rialto Capital Advisors, LLC (the“Asserting Party”) is responsible for assessing compliance with the servicing criteriaapplicable to it under paragraph (d) of Item 1122 of Regulation AB, as ofand for the 12-month period ending December 31, 2021 (the“Reporting Period”), as set forth in Appendix A hereto. The transactionscovered by this report, include commercial mortgage-asset-backed securitiestransactions, as listed on Exhibit 1 hereto, for which the Asserting Partyserved as special servicer, and that were registered with the Securities andExchange Commission pursuant to the Securities Act of 1933 (the “Platform”);

 

2.       The Asserting Party has engaged certainvendors, which are not servicers as defined in Item 1101(j) of Regulation AB(the “Vendors”), to perform specific, limited or scripted activities, and theAsserting Party elects to take responsibility for assessing compliance with theservicing criteria or portion of the servicing criteria applicable to suchVendors’ 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 Item1122 of Regulation AB to assess the compliance with the applicable servicingcriteria;

 

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

 

5.       The Asserting Party has complied, in allmaterial respects, with the applicable servicing criteria as ofDecember 31, 2021 and for the Reporting Period with respect to thePlatform taken as a whole;

 

6.       The Asserting Party has not identified andis not aware of any material instance of noncompliance by the Vendors with theapplicable servicing criteria as of December 31, 2021 and for theReporting Period with respect to the Platform taken as a whole;

 

7.       The Asserting Party has not identified anymaterial deficiency in its policies and procedures to monitor the compliance bythe Vendors with the applicable servicing criteria as of December 31, 2021and for the Reporting Period with respect to the Platform taken as a whole; and

 

8.       Deloitte & Touche LLP, anindependent registered public accounting firm, has issued an attestation reporton the Asserting Party’s assessment of compliance with the applicable servicingcriteria for the Reporting Period.

 

February 17, 2022

 

 

Name: AdamSinger

Title: ManagingDirector

 

Signature: /s/ AdamSinger

 

 

** **

| **Exhibit  1**                        |
|---------------------------------------|
| **Pooling  and Servicing Agreements** | **Applicable  Certification Period** |
| WFRBS 2012-C8                         | January 1,  2021 to December 31, 2021 |
| WFCM 2012-LC5                         | January 1,  2021 to December 31, 2021 |
| UBS-Barclays  2012-C3                 | January 1,  2021 to December 31, 2021 |
| UBS-Barclays  2012-C4                 | January 1,  2021 to December 31, 2021 |
| GSMS 2012-GCJ9                        | January 1,  2021 to December 31, 2021 |
| JPMCC 2012-LC9                        | January 1,  2021 to December 31, 2021 |
| COMM 2013-LC6                         | January 1,  2021 to December 31, 2021 |
| WFRBS 2013-C12                        | January 1,  2021 to December 31, 2021 |
| UBS-Barclays  2013-C6                 | January 1,  2021 to December 31, 2021 |
| GSMS  2013-GCJ12                      | January 1,  2021 to December 31, 2021 |
| WFRBS 2013-C14                        | January 1,  2021 to December 31, 2021 |
| WFRBS 2011-C5                         | January 1,  2021 to December 31, 2021 |
| WFCM 2013-LC12                        | January 1,  2021 to December 31, 2021 |
| WFRBS 2011-C2                         | January 1, 2021  to December 31, 2021 |
| WFRBS 2011-C3                         | January 1,  2021 to December 31, 2021 |
| WFRBS 2011-C4                         | January 1,  2021 to December 31, 2021 |
| UBS-Citigroup  2011-C1                | January 1,  2021 to December 31, 2021 |
| UBSCM 2012-C1                         | January 1,  2021 to December 31, 2021 |
| WFRBS 2012-C6                         | January 1,  2021 to December 31, 2021 |
| GSMS 2011-GC3                         | January 1,  2021 to December 31, 2021 |
| COMM 2013-LC13                        | January 1,  2021 to December 31, 2021 |
| WFRBS 2013-C16                        | January 1,  2021 to December 31, 2021 |
| GSMS  2013-GCJ16                      | January 1,  2021 to December 31, 2021 |
| WFRBS 2013-C17                        | January 1,  2021 to December 31, 2021 |
| GSMS 2012-GC6                         | January 1,  2021 to December 31, 2021 |
| MSBAM 2013-C13                        | January 1,  2021 to December 31, 2021 |
| COMM  2014-CCRE14                     | January 1,  2021 to December 31, 2021 |
| MSBAM 2014-C14                        | January 1, 2021  to December 31, 2021 |
| WFRBS  2014-LC14                      | January 1,  2021 to December 31, 2021 |
| COMM 2014-LC15                        | January 1,  2021 to December 31, 2021 |
| WFRBS 2014-C20                        | January 1,  2021 to December 31, 2021 |
| COMM  2014-CCRE18                     | January 1,  2021 to December 31, 2021 |
| CGCMT 2014-GC23                       | January 1,  2021 to December 31, 2021 |
| MSBAM 2014-C17                        | January 1,  2021 to December 31, 2021 |
| COMM 2014-UBS5                        | January 1,  2021 to December 31, 2021 |
| MSBAM 2014-C18                        | January 1,  2021 to December 31, 2021 |
| COMM  2012-CCRE4                      | January 1,  2021 to December 31, 2021 |
| WFRBS 2014-C24                        | January 1,  2021 to December 31, 2021 |
| JPMBB 2014-C25                        | January 1,  2021 to December 31, 2021 |
| LCCM 2014-909                         | January 1,  2021 to December 31, 2021 |
| WFCM 2014-LC18                        | January 1,  2021 to December 31, 2021 |
| COMM 2015-DC1                         | January 1,  2021 to December 31, 2021 |
| GSMS 2015-GC28                        | January 1,  2021 to December 31, 2021 |
| WFCM 2015-C27                         | January 1,  2021 to December 31, 2021 |
| WFCM 2015-LC20                        | January 1,  2021 to December 31, 2021 |
| WFCM 2015-NXS1                        | January 1,  2021 to December 31, 2021 |
| CSAIL 2015-C2                         | January 1, 2021  to December 31, 2021 |
| WFCM 2015-NXS2                        | January 1,  2021 to December 31, 2021 |
| COMM 2015-PC1                         | January 1,  2021 to December 31, 2021 |
| CSAIL 2015-C3                         | January 1,  2021 to December 31, 2021 |
| WFCM 2015-SG1                         | January 1,  2021 to December 31, 2021 |
| WFCM 2015-LC22                        | January 1,  2021 to December 31, 2021 |
| COMM  2015-CCRE27                     | January 1,  2021 to December 31, 2021 |
| WFCM 2015-NXS4                        | January 1,  2021 to December 31, 2021 |
| MSCI 2015-UBS8                        | January 1,  2021 to December 31, 2021 |
| CSAIL 2016-C5                         | January 1,  2021 to December 31, 2021 |
| WFCM 2016-C32                         | January 1,  2021 to December 31, 2021 |
| WFCM 2016-NXS5                        | January 1,  2021 to December 31, 2021 |
| CGCMT  2015-GC27                      | January 1,  2021 to December 31, 2021 |
| WFCM 2016-C33                         | January 1,  2021 to December 31, 2021 |
| MSBAM 2015-C20                        | January 1, 2021  to December 31, 2021 |
| CFCRE 2016-C4                         | January 1,  2021 to December 31, 2021 |
| BACM  2016-UBS10                      | January 1,  2021 to December 31, 2021 |
| SGCMS 2016-C5                         | January 1,  2021 to December 31, 2021 |
| WFCM 2016-BNK1                        | January 1,  2021 to December 31, 2021 |
| CD 2016-CD1                           | January 1,  2021 to December 31, 2021 |
| GSMS 2016-GS3                         | January 1,  2021 to December 31, 2021 |
| MSBAM 2016-C31                        | January 1,  2021 to December 31, 2021 |
| CGCMT 2016-C3                         | January 1,  2021 to December 31, 2021 |
| CFCRE 2016-C6                         | January 1,  2021 to December 31, 2021 |
| CSAIL 2016-C7                         | January 1,  2021 to December 31, 2021 |
| MSCI  2016-UBS12                      | January 1,  2021 to December 31, 2021 |
| BBCMS 2017-C1                         | January 1,  2021 to December 31, 2021 |
| GSMS 2017-GS5                         | January 1,  2021 to December 31, 2021 |
| CGCMT 2017-P7                         | January 1,  2021 to December 31, 2021 |
| BANK 2017-BNK4                        | January 1,  2021 to December 31, 2021 |
| CD 2017-CD4                           | January 1,  2021 to December 31, 2021 |
| CFCRE 2017-C8                         | January 1,  2021 to December 31, 2021 |
| JPMCC 2017-JP6                        | January 1,  2021 to December 31, 2021 |
| CD 2017-CD5                           | January 1,  2021 to December 31, 2021 |
| GSMS 2017-GS7                         | January 1,  2021 to December 31, 2021 |
| BANK 2017-BNK7                        | January 1,  2021 to December 31, 2021 |
| CSAIL 2017-CX9                        | January 1,  2021 to December 31, 2021 |
| UBSCM 2017-C4                         | January 1,  2021 to December 31, 2021 |
| UBSCM 2017-C6                         | January 1, 2021  to December 31, 2021 |
| BANK 2017-BNK9                        | January 1,  2021 to December 31, 2021 |
| GSMS 2018-GS9                         | January 1,  2021 to December 31, 2021 |
| UBSCM 2018-C9                         | January 1,  2021 to December 31, 2021 |
| MSBAM 2012-C5                         | January 1,  2021 to December 31, 2021 |
| WFCM 2018-C44                         | January 1,  2021 to December 31, 2021 |
| UBSCM 2018-C10                        | January 1,  2021 to December 31, 2021 |
| WFCM 2015-C30                         | January 1,  2021 to December 31, 2021 |
| JPMBB 2014-C23                        | January 1,  2021 to December 31, 2021 |
| MSBAM 2014-C19                        | January 1,  2021 to December 31, 2021 |
| COMM 2015-LC21                        | January 1,  2021 to December 31, 2021 |
| MSBAM 2016-C29                        | January 1,  2021 to December 31, 2021 |
| JPMBB 2015-C31                        | January 1,  2021 to December 31, 2021 |
| GSMS 2018-GS10                        | January 1,  2021 to December 31, 2021 |
| CD 2018-CD7                           | January 1, 2021  to December 31, 2021 |
| GSMS 2018-3PCK                        | January 1,  2021 to December 31, 2021 |
| BANK  2018-BNK14                      | January 1,  2021 to December 31, 2021 |
| DBGS 2018-C1                          | January 1,  2021 to December 31, 2021 |
| CSAIL 2018-C14                        | January 1,  2021 to December 31, 2021 |
| UBSCM 2018-C14                        | January 1,  2021 to December 31, 2021 |
| ILPT 2019-SURF                        | January 1,  2021 to December 31, 2021 |
| MSCI 2019-L2                          | January 1,  2021 to December 31, 2021 |
| WFCM 2019-C50                         | January 1,  2021 to December 31, 2021 |
| BANK  2019-BNK18                      | January 1,  2021 to December 31, 2021 |
| WFCM 2015-P2                          | January 1,  2021 to December 31, 2021 |
| BMARK 2019-B11                        | January 1,  2021 to December 31, 2021 |
| CGCMT  2019-GC41                      | January 1,  2021 to December 31, 2021 |
| BBCMS 2019-C4                         | January 1,  2021 to December 31, 2021 |
| COMM  2014-CCRE15                     | January 1, 2021  to December 31, 2021 |
| UBSCM 2019-C17                        | January 1,  2021 to December 31, 2021 |
| BANK  2019-BNK21                      | January 1,  2021 to December 31, 2021 |
| CGCMT  2019-GC43                      | January 1,  2021 to December 31, 2021 |
| CSAIL 2019-C18                        | January 1,  2021 to December 31, 2021 |
| COMM 2019-GC44                        | January 1,  2021 to December 31, 2021 |
| UBSCM 2019-C18                        | January 1,  2021 to December 31, 2021 |
| WFCM 2020-C55                         | January 1,  2021 to December 31, 2021 |
| UBSBB 2012-C2                         | January 1,  2021 to December 31, 2021 |
| BBCMS 2020-C7                         | January 1,  2021 to December 31, 2021 |
| CSMC 2020-NET                         | January 1,  2021 to December 31, 2021 |
| BMARK 2020-B19                        | January 1,  2021 to December 31, 2021 |
| BMARK 2020-B22                        | January 1,  2021 to December 31, 2021 |
| CSMC 2020-FACT                        | January 1,  2021 to December 31, 2021 |
| CLNY 2019-IKPR                        | January 1,  2021 to December 31, 2021 |
| BANK  2020-BNK29                      | January 1,  2021 to December 31, 2021 |
| WFCM 2020-C58                         | January 1,  2021 to December 31, 2021 |
| FSRIA 2019-FL1                        | January 1,  2021 to December 31, 2021 |
| BANK  2021-BNK32                      | March 24, 2021  to December 31, 2021 |
| BSST 2021-1818                        | March 30, 2021  to December 31, 2021 |
| BMARK 2021-B25                        | April 29, 2021  to December 31, 2021 |
| FSRIA 2021-FL2                        | May 5, 2021 to  December 31, 2021 |
| MSC 2007-T27                          | May 19, 2021  to December 31, 2021 |
| BANK  2021-BNK33                      | May 20, 2021  to December 31, 2021 |
| BBCMS 2021-C10                        | July 15, 2021  to December 31, 2021 |
| CSMC 2021-ADV                         | August 5, 2021  to December 31, 2021 |
| BANK  2021-BNK36                      | October 7,  2021 to December 31, 2021 |
| FSRIA 2021-FL3                        | November 4,  2021 to December 31, 2021 |
| BACM 2017-BNK3                        | November 15,  2021 to December 31, 2021 |
| BMARK 2021-B31                        | December 22,  2021 to December 31, 2021 |

** **

**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**                                                 | ** ** |
| 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**                                                             | ** ** |
| 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** |
| 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**- RialtoCapital Advisors, LLC performs the activities pertaining to this criterion,except for specific, limited activities performed by (a) its third-partyproperty managers relating to REO Property, if any; and (b) RERC, LLC, aSitusAMC Company, pursuant to a Staffing Agreement, in which RERC provides RCAwith real estate consultant and valuation professionals to perform supportfunctions in connection with property appraisals. Rialto has elected to takeresponsibility for assessing compliance with these servicing criteria withrespect to the activities of its third-party property managers and RERC, LLC.

**X2**-Primaryresponsibility for processing borrower payments rests with the Master Servicer,however, Rialto Capital Advisors, LLC may from time to time receive payments onan exception basis which are forwarded to the Master Servicer in accordancewith such criteria. The criteria is marked applicable as Rialto CapitalAdvisors, LLC had instances or activity relating to this criteria for thecalendar year of January 1, 2021 to December 31, 2021. 

**X3**-RialtoCapital Advisors, LLC performs the activities under the criteria, however therelated criteria are marked inapplicable as Rialto did not haveinstances/activity during the calendar year of January 1, 2021 and ending onDecember 31, 2021 relating to the criteria.   

**X4**-Only items(A) and (B) of the Servicing Criteria are applicable to Rialto CapitalAdvisors, LLC as special servicer.  Items (C) and (D) are inapplicable asthe responsibility for filing reports with the Commission and agreeing totalsto the Servicer records rests with the Trustee and/or CertificateAdministrator, as applicable.

** **