2 Embarcadero C
e
nter
,
Suite
13
00

San Franci
s
co, CA 94111
Phone
:
415
.
374
.
2820

Fa
x:
415
.
374
.
2704





Certification Regarding Compliance with Applicable Servicing Criteria


1.  Situs  Holdings,  LLC  (the  "Company"  or  "Situs"),  is  responsible  for  assessing  compliance
with  the servicing criteria applicable to it under  paragraph (d) of  item  1 122 of  Regulation AB,
as  of    and  for  the    period  January    1,  2015    through    December    31,  201  5    (the  "Reporting
Period"), as  set forth  in Appendix  A  hereto. The transactions covered  by this  report (these
transactions  collectively    referred  to    as    the    "Special    Servicing    Platform")    include    asset-
backed  securities  transactions  for  which  Situs acted as special servicer, involving commercial
mortgage  loans;

2.  Situs  has  engaged    certain  vendors    (the  "Vendors")    to  perform  specific,  limited  or    scripted
activities for  the  Reporting Period,  and Situs  has elected to take responsibility for  assessing
compliance    with  the    servicing  criteria  or    portion  of    the    servicing  criteria  applicable  to  such
Vendors'  activities as set forth in Appendix  A  hereto;


3.  Except as set forth in paragraph 4 below, Situs used the criteria set forth in paragraph (d) of item 1
122 of Regulation AB to assess the compliance with the applicable servicing criteria;


4.  The criteria listed in the column titled "Inapplicable Servicing Criteria" on Appendix A hereto are
inapplicable  to  Situs  based  on  the  activities  it  performed,  directly  or  through  its  Vendors,  with
respect to the Special Servicing Platform for the Reporting Period;


5
.   During the  reporting  period, there  were  no  additions,  removals  or  substitutions  to  the  applicable
asset  pools  for  which  Situs  would  be  required to  review, approve,  and  execute  the  transaction
in  accordance    with  the  transaction    agreements,  therefore    Situs  did  not  perform  and  servicing
activities  related  to  criteria    1122(d)(4)(iii)    as  of    and  for    the    period  January    1,  2015  through
December 31, 2015.


6.  During  the  reporting  period,  there  were  no  delinquencies,  charge-offs  and  uncollectible  account
write-offs for which Situs would be required to recognize and record the transaction in accordance
with  the  transaction  agreements,  therefore  Situs  did  not  perform  any  servicing  activities  related  to
criteria 1122(d)(4)(xiv) as of and for the period January 1, 2015 through December 31, 2015.

7.  Situs    has    complied,  in  all    material    respects,  with  the    applicable    servicing    criteria    as    of
December  31,  201  5    and  for    the    Reporting    Period    with    respect    to    the    Special    Servicing
Platform taken  as  a whole;

8.
Grant  Thornton  LLP,  as  independent  registered  public  accounting  firm,  has  issued  an    attestation
report  on  Situs'  assessment  of  compliance  with  the  applicable  servicing  criteria  for  the  Reporting
Period


Situs Holdings LLC
February 18, 2016

By: /s/ George Wisniewski

George Wisniewski, Executive Managing Director

2 Embarcadero Center, Suite  1300
San Francisco, CA  94111

Phone
:
415
.
374
.
2820

Fa
x:
415
.
374.2704



APPENDIX A




SERVICING CRITERIA

APPLICABLE
SERVICING CRITERIA

INAPPLICABLE SERVICING
CRITERIA




Reference




Criteria



Performed
Directly by
Situs

Performed by
Vendor(s) for
which Situs is
the
Responsible
Party

Performed by
subservicer(s)
or vendor(s)

for which Situs
is NOT the
Responsible
Party

NOT

performed by
Situs or by
subservicer(s)
or vendor(s)
retained by
Situs


General Servicing  Considerations



l 122(d)(l)(i)

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

x






l 122(d)(l)(ii)

I
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.


x





l  122(d)(l)(iii)

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




x




l  122(d)(l)(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







l  122(d)(l)(v)


Requires an assessment  of the conveyance and
mathematical accuracy of data that is
aggregated by one party and then provided to a
servicing  party
.


x





Cash Collection and  Administration




l 122(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
.


x





l 122(d)(2)(ii)

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

x

2 Embarcadero Center, Suite  1300
San Francisco, CA   94111

Phone:
415.374.2820

Fax: 415.374.2704







l 122(d)(2)(iii)



Advances of
fund
s
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
.



x







l 122(d)(2)(iv)

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


x









l 122(d)(2)(v)

Each custodial account
is maintained
at a
federally
insured depository institution
as set
forth
in the
transaction agreements. For
purposes
of
thi
s
criterion, "federally
in
s
ured
depository institution"
with
respect to
a
foreign
financial institution means
a foreign
financial
institution
that meets  the
requirements
of §240.
l
3k-l (b)
(I)
of
this
chapter.



x




l 122(d)(2)(vi)

Unissued checks
are
safeguarded
so
as
to
prevent unauthorized
access
.

x












l 122(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.
Thes
e
r
eco
nciliations
:
(A) Are
mathematically
accurate
;
(B) Are
prepared
within  30 calendar
day
s
after
the bank
state
ment
cutoff
date,
or
s
uch
other number of
day
s
specified
in the
tran
sac
tion
agreements; (C) Are
reviewed
and
approved
by
someone other
than  the per
so
n
who
pr
e
pared the reconciliation
;
and (D)
Contain explanations for
reconciling
items.

These
reconciling items
are
r
eso
lved
within 90
calendar
day
s
of their  original identification
,
or such other
number
of
days
specified
in  th
e
tran
sac
tion
agreements
.





x





Investor Remittance and  Reporting








l 122(d)(3)(i)

Reports to investor
s,
including
those to
b
e
filed
with
the
Commission,

are
maintained  in
accordance with
the tran
sac
tion
agreements
and applicable Commission
requirement
s.

Specifically
,
such
reports:

(A) Are
prepared  in
accordance with
timefram
es
and other
term
s
se
t
forth
in the tran
sac
tion
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
rule
s
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.








x

2 Embarcadero ·center, Suite 1300
San Francisco,
CA
94111

Phone: 415
.
374.2820

Fax
:
415.374
.
2704




l 122(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



l 122(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


l 122(d)(3)(iv)

Amount
s
remitted to investors per the investor
reports agree with c
a
ncelled checks
,
or other
form of payment
,
or custodial bank   statements
.




x


Pool Asset Administration



l 122(d)(4)(i)


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


x






l 122(d)(4)(ii)

Pool assets and related documents are
safeguarded as required by the transaction
agreements
.

x






l 122(d)(4)(iii)

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


x









l 122(d)(4)(iv)

Payment
s
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  agreement
s,
and
allocated  to principal,  interest or other items
(e.g., escrow) in accordance with the related
pool asset documents.






x


l 122(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




l 122(d)(4)(vi)

Changes with respect to the terms or status of
an obligor's mortgage  loans (e
.
g., loan
modifications  or re-aging's) are made,
reviewed and approved by authorized
personnel  in accordance with the transaction
agreements and related  pool as
s
et documents
.


x







l 122(d)(4)(vii)

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


x

2 Embarcadero Center,
Suite
1300
San Francisco, CA   94111

Phone:  415.374.2820

Fax: 415.374.2704








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





l  122(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








l  122(d)(4)(x)

Regarding any funds held in trust for  an
obligor (such as escrow accounts)  See
following: (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 asset, 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






l  122(d)(4)(xv)

Any external enhancement or other support,
identified in Item l 114(a)
(!)
through (3) or
Item 1115 of this Regulation AB, is
maintained as set forth in the transaction
agreements
.





x