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Management’s
Report on Assessment of Compliancewith SEC Regulation AB Servicing Criteria



Midland
Loan Services, a division of PNC Bank, National Association (“Midland” or the “Company”), is responsible
for compliance with the applicable servicing criteria set forth in Item 1122 (d) of Regulation AB of the Securities and Exchange
Commission (“Regulation AB”), as set forth in Appendix A.



Midland
has assessed its compliance with the applicable servicing criteria as of and for the year ended December 31, 2019 (the “Reporting
Period”). In making this assessment, Midland used the criteria set forth by the Securities and Exchange Commission (“SEC”)
in Item 1122(d) of Regulation AB. This report covers all transactions serviced on the Enterprise!Loan Management System
(the “Platform”) during the Reporting Period.



Midland
engaged certain vendors, which are not servicers as defined in item 1101(j) of Regulation AB (the “Vendors”), to perform
specific and limited or scripted activities related to portions of the servicing criteria as set forth in Appendix A. Midland
elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable
to such Vendors’ activities as set forth in Appendix A. Midland has not identified and is not aware of any material instances
of noncompliance by the Vendors with the applicable servicing criteria as of December 31, 2019 and for the Reporting Period with
respect to the Platform taken as a whole, nor has it identified any material deficiencies in its policies and procedures to monitor
the compliance by the Vendors with the applicable servicing criteria as of December 31, 2019 and for the Reporting Period with
respect to the Platform taken as a whole.



Based
on this assessment, Midland concludes that, as of and for the year ended December 31, 2019, Midland has complied in all material
respects with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB, except as described in Appendix B
hereto.



PricewaterhouseCoopers
LLP, an independent registered public accounting firm, has issued an attestation report on Midland’s compliance with the
applicable servicing criteria as of and for the year ended December 31, 2019 for all transactions serviced on the Enterprise!Loan Management System.



Appendix
C entitled Management’s Remediation Plan for the Material Instance of Noncompliance with Regulation AB Criteria is
presented by Midland for information purposes and is not covered by PricewaterhouseCoopers LLP’s attestation report.



MIDLAND
LOAN SERVICES

a
division of PNC Bank, National Association



/s/ Timothy
E. Steward

Timothy
E. Steward

Senior
Vice President



Date:
February 20, 2020



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APPENDIX
A

|                | SERVICING
    CRITERIA                                                                                                                                                                                                                                                      | APPLICABLE
    SERVICING CRITERIA
|--------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------
|Reference       | Criteria                                                                                                                                                                                                                                                                    | Performed
    Directly by Midland
|                | 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.                                                                | X                                
|1122(d)(1)(iii) | Any
    requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                       | N/A1                             
|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 the transaction
    agreements. | X                                
|1122(d)(1)(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.                                                                                                                                                   | X                                
|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.                                           | X                                
|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                                





1 Midland has determined servicing
criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv),
and 1122(d)(4)(xv) to be inapplicable to the activities Midland performs with respect to the Platform.





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|                | SERVICING
    CRITERIA                                                                                                                                                                                                                                                                                                                                                                          | APPLICABLE
    SERVICING CRITERIA
|--------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------
|Reference       | Criteria                                                                                                                                                                                                                                                                                                                                                                                        | Performed
    Directly by Midland
|                | Cash
    Collection and Administration (continued)                                                                                                                                                                                                                                                                                                                                              |                                  
|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:                                                                                                                                                                                          |                                  
|                | (A)
    Are mathematically accurate;                                                                                                                                                                                                                                                                                                                                                            | X                                
|                | (B)
    Are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction
    agreements;                                                                                                                                                                                                                                    | X                                
|                | (C)
    Are reviewed and approved by someone other than the person who prepared the reconciliation; and                                                                                                                                                                                                                                                                                         | X                                
|                | (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;                                                                                                                                                                                                                                                                                     | X                                
|                | (B)
    Provide information calculated in accordance with the terms specified in the transaction agreements;                                                                                                                                                                                                                                                                                    | N/A1                             
|                | (C)
    Are filed with the Commission as required by its rules and regulations; and                                                                                                                                                                                                                                                                                                             | N/A1                             
|                | (D)
    Agree with investor’s or the trustee’s records as to the total unpaid principal balance and number of pool assets
    serviced by the servicer.                                                                                                                                                                                                                                         | N/A1                             
|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.                                                                                                                                                                                                                       | N/A1                             
|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.                                                                                                                                                                                                         | N/A1                             
|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.                                                                                                                                                                                                                                                 | N/A1                             





1 Midland has determined servicing
criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv),
and 1122(d)(4)(xv) to be inapplicable to the activities Midland performs with respect to the Platform.







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|                 | SERVICING
    CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | APPLICABLE
    SERVICING CRITERIA
|---------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ---------------------------------
|Reference        | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Performed
    Directly by Midland
|                 | 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
    assets 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.                                                                                                       | X                                
|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 asset (e.g., loan modifications or re-agings) are made, reviewed
    and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                 | 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                                





1 Midland has determined servicing
criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv),
and 1122(d)(4)(xv) to be inapplicable to the activities Midland performs with respect to the Platform.







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|                 | SERVICING
    CRITERIA                                                                                                                                                                                                                                                                                                                                                                                      | APPLICABLE
    SERVICING CRITERIA
|---------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------
|Reference        | Criteria                                                                                                                                                                                                                                                                                                                                                                                                    | Performed
    Directly by Midland
|                 | Pool
    Asset Administration (continued)                                                                                                                                                                                                                                                                                                                                                                   |                                  
|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;                                                                                                                                                                                                                      | X                                
|                 | (B)
    Interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws;
    and                                                                                                                                                                                                                                                                 | X                                
|                 | (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                                
|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.                                                                                                                                                                                                                       | N/A1                             





1 Midland has determined servicing
criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv),
and 1122(d)(4)(xv) to be inapplicable to the activities Midland performs with respect to the Platform.





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Appendix
B



The
Company has identified an instance of material noncompliance with the following servicing criterion during the Reporting Period
of the Platform:



​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.



​Certain
instances were identified where the Schedule AL Filings (Item 1125 of Regulation AB) were not appropriately reported in accordance
with the terms specified in the transaction agreements.



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Appendix
C - Management’s Remediation Plan for the MaterialInstance of Noncompliance with Regulation AB Criteria



PricewaterhouseCoopers
LLP’s attestation report does not cover Management’s Remediation Plan for the Material Instance of Noncompliance
with Regulation AB Criteria.



The
report on assessment for Midland Loan Services, a division of PNC Bank, National Association (“Midland”) identified
a material instance of noncompliance related to Regulation AB servicing criterion 1122(d)(3)(i)(A) - “Reports to investors,
including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission
requirements. Specifically, such reports: (A) Are prepared in accordance with timeframes and other terms set forth in the transaction
agreements;” which is applicable to all transactions serviced on the Enterprise! Loan Management System (the “Platform”)
during the year ended December 31, 2019.



For
CMBS transactions subject to the reporting requirements of Regulation AB on and after November 23, 2016 (the effective date of
the most recent amendment to Regulation AB), Midland as master servicer of certain of those CMBS transactions became responsible
for Schedule AL (Asset Level) reporting on behalf of the related CMBS trusts. Midland’s Schedule AL reporting process was
enhanced in April of 2019, however, the process remained manual throughout the 2019 calendar year and additional errors during
such year were identified during the related audit. Following identification, Midland made staffing changes and additional improvements
to its processes and procedures to support its Schedule AL reporting obligations and expects to move to an automated solution
for this process.





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