Management’s
Report on Assessment of Compliance with SEC Regulation AB

Servicing
Criteria as Primary Servicer



Berkadia
Commercial Mortgage LLC (“Berkadia”) is responsible for assessing compliance, as of and for the year ended December
31, 2022 (the “Reporting Period”), with the Servicing Criteria set forth in Item 1122(d) of Regulation AB of the U.S.
Securities and Exchange Commission for asset-backed securities transactions. This assertion includes all commercial mortgage loans
sold in public securitizations from the period January 1, 2022 through December 31, 2022 for which Berkadia served as Primary
servicer (the “Platform”).



Berkadia
has concluded that the criteria are applicable as shown below (indicated by X) to the primary servicing of the loans in the Platform:



|Regulation
    AB Criteria 1122(d) | Applicability
    ofCriteria asthe PrimaryServicer                                                                                                                                                                                                                       
|---------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|(1)                                | General
    servicing considerations.                                                                                                                                                                                                                                    
|(i)                                | Policies
    and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction
    agreements.                                                                                                         
|(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.                                                             
|(iii)                              | Any
    requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                    
|(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.
|(v)                                | Aggregation
    of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                              
|(2)                                | Cash
    collection and administration.                                                                                                                                                                                                                                  
|(i)                                | Payments
    on pool assets are deposited into the 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.                                       
|(ii)                               | Disbursements
    made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                
|(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 transection agreements.                                        
|(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.            











|(v)   | Each
    custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements.
    For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial
    institution means a foreign financial institution that meets the requirements of § 240.13k-1(b)(1) of this chapter.                                                           | X  
|----- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---
|(vi)  | Unissued
    checks are safeguarded to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                     | X  
|(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:                                                                                                                                                                                                                                  | X  
|(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  
|(3)   | Investor
    remittances and reporting.                                                                                                                                                                                                                                                                                                                                                                                                 |    
|(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:                                                                                                                                                                                                                         | X  
|(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;                                                                                                                                                                                                                                                                                                                                | X  
|(C)   | Are
    filed with the Commission as required by its rules and regulations; and                                                                                                                                                                                                                                                                                                                                                         | (1)
|(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  
|(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  
|(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  
|(iv)  | Amounts
    remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                         | X  
|(4)   | Pool
    asset administration.                                                                                                                                                                                                                                                                                                                                                                                                          |    
|(i)   | Collateral
    or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                      | X1 
|(ii)  | Pool
    assets and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                        | (1)
|(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.                                                                                                                                                                                                                                                     | X2 
|(iv)  | Payments
    on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the applicable
    servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified
    in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related
    pool asset documents. | X  
|(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  











|(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  
|------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ---
|(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.                                                                                                                                                                                                             | (1)
|(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  
|(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  
|(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  
|(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.                                                                                                                    | X1 
|(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.                                                                                                                                                                                                                                                                                    | X1 
|(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.                                                                                                                                                                                                                                                                                                              | X1 
|(xiv)  | Delinquencies,
    charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                           | X2 
|(xv)   | Any
    external enhancement or other support, identified in Item 1114(a) (1) through (3) or Item 1115 of this Regulation AB, is maintained
    as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                    | (1)



X Servicer was responsible for these criteria in its role as Primary Servicer.

X1Vendors, for which Berkadia is the Responsible Party, contributes to the servicing activities for these criteria.

X2There was no transaction activity relevant to the servicing criteria as of and for the yead ended December 31, 2022.

(1)
Per servicing and pooling agreements, the criteria does not apply to the role of Primary Servicer.



The
Servicing Criteria, after giving effect to the foregoing exclusions, are referred to as the “Applicable Servicing Criteria.”



For
the Reporting Period, Berkadia has assessed its compliance with the Applicable Servicing Criteria for the Platform and has concluded
that its servicing operation has complied, in all material respects, with the Applicable Servicing Criteria.











Grant
Thornton LLP, an independent registered public accounting firm, has issued an attestation report on management’s assertion
of compliance with the Applicable Servicing Criteria.



Berkadia
Commercial Mortgage LLC



February
15, 2023



Mark
E. McCool



President-Berkadia
Commercial Real Estate Services, Servicing
Berkadia Commercial Mortgage LLC



/s/ Mark E. McCool