February 28, 2022

Management’s Assertion on Compliance with
Regulation AB Criteria

Re:	Assessment of Compliance for services provided pursuant to the
Pooling and Servicing Agreements entered into by CWCapital Asset Management LLC beginning January 1, 2005 and as of and for the 12-month
period ended December 31, 2021.

CWCapital Asset Management LLC (“CWCAM”)
is responsible for assessing compliance with applicable servicing criteria set forth in Item 1122 (d) of Regulation AB of the Securities
and Exchange Commission for the securitizations issued beginning January 1, 2005, as listed on Appendix A (“Applicable Servicing
Criteria”).

CWCAM has assessed its compliance with the applicable
servicing criteria as of and for the 12-month period ended December 31, 2021 (the “Reporting Period”). In making this assessment,
management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB, excluding
the criteria set forth in Item 1122 (d)(1)(iii), (d)(3)(i)(B), (d)(3)(i)(C), (d)(3)(i)(D), (d)(3)(ii), (d)(3)(iii), (d)(3)(iv), (d)(4)(v),
(d)(4)(ix), (d)(4)(x), (d)(4)(xi), (d)(4)(xii), (d)(4)(xiii), (d)(4)(xiv), and (d)(4)(xv) of Regulation AB, which CWCAM has concluded
are not applicable to the activities it performs (collectively, the “Not Applicable Criteria”). With respect to applicable
servicing criteria (d)(1)(ii), (d)(2)(vi), (d)(4)(i), (d)(4)(iii), and (d)(4)(iv), CWCAM has determined that there were no occurrences
of events that would require CWCAM to perform such activities. The securitizations covered by this report include all securitizations
wherein CWCAM is named as the Special Servicer for securitizations issued beginning January 1, 2005, as listed in Appendix B (the “Platform”).

Based on such assessment, management believes, as
of December 31, 2021 and for the Reporting Period, the following:

1)CWCAM has determined that the Not Applicable Criteria are in fact not applicable to the activities it performs with respect to
the Platform.

2)CWCAM has complied in all material respects with the applicable servicing criteria set forth in Item 1122.

CohnReznick LLP, an independent registered
public accounting firm, has issued an attestation report on CWCAM’s management’s assessment of compliance with the Applicable
Servicing Criteria as of and for the 12-month period ended December 31, 2021.










CWCapital Asset Management LLC












Appendix A

Applicable Servicing Criteria



|                | Relevant Servicing Criteria                                                                                                                                                                                                                                                                                                                                                     |               
|--------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------
|Reference       | Criteria                                                                                                                                                                                                                                                                                                                                                                        | CWCAM         
|                | 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.                                                                                                                                                                                                                        | Applicable    
|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.                                                                                                                                                                            | Applicable    
|1122(d)(1)(iii) | Any requirements in the transaction agreements to maintain a back-up servicer for the mortgage loans are maintained.                                                                                                                                                                                                                                                            | Not Applicable
|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.                                                                                                               | Applicable    
|1122(d)(1)(v)   | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                                                                                                                                         | Applicable    
|                | Cash Collection and Administration                                                                                                                                                                                                                                                                                                                                              |               
|1122(d)(2)(i)   | Payments on mortgage loans 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.                                                                                                                                | Applicable    
|1122(d)(2)(ii)  | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                           | Applicable    
|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.                                                                                                                                                       | Applicable    
|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.                                                                                                                           | Applicable    
|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. | Applicable    
|1122(d)(2)(vi)  | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                           | Applicable    
|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; (B) are prepared within 30 calendar days after the bank                                                                                          | Applicable    












|                | Relevant Servicing Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                                                                            
|--------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -----------------------------------------------------------------------------------------------------------
|Reference       | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | CWCAM                                                                                                      
|                | statement cutoff date, or such other number of days specified in the transaction agreements; (C) are 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.                                                                                                                                                                                                                                      |                                                                                                            
|                | 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 mortgage loans serviced by the Servicer. | (A)       Applicable
    (B)       Not Applicable
    (C)       Not Applicable
    (D)       Not Applicable
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Not Applicable                                                                                             
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Not Applicable                                                                                             
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Not Applicable                                                                                             
|                | Pool Asset Administration                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                                                                                            
|1122(d)(4)(i)   | Collateral or security on mortgage loans is maintained as required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Applicable                                                                                                 
|1122(d)(4)(ii)  | Mortgage loan and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Applicable                                                                                                 
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Applicable                                                                                                 
|1122(d)(4)(iv)  | Payments on mortgage loans, including any payoffs, made in accordance with the related mortgage loan 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 mortgage loan documents.                                                                                                                                                                                                                                      | Applicable                                                                                                 
|1122(d)(4)(v)   | The Servicer’s records regarding the mortgage loans agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Not Applicable                                                                                             
|1122(d)(4)(vi)  | Changes with respect to the terms or status of an obligor’s mortgage loans (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.                                                                                                                                                                                                                                                                                                                                                                                                 | Applicable                                                                                                 








|                
|----------------
|                
|Reference       
|1122(d)(4)(vii) 
|1122(d)(4)(viii)
|1122(d)(4)(ix)  
|1122(d)(4)(x)   
|1122(d)(4)(xi)  
|1122(d)(4)(xii) 
|1122(d)(4)(xiii)
|1122(d)(4)(xiv) 
|1122(d)(4)(xv)  








Appendix BPlatform

|Aventura 2018-AVM  | GSMS 2015-GC32      | WFCM 2019-JWDR    
|------------------ | ------------------- | ------------------
|BACM 2007-1        | GSMS 2018-RIVR      | WFRBS 2013-C11    
|BACM 2007-5        | GSMS 2020-GC45      | WFRBS 2013-C15    
|BACM 2008-1        | GSMS 2020-TWN3      | WFRBS 2013-UBS1   
|BANC 2019-CRE6     | HILT 2016-HHV       | WFRBS 2014-C21    
|BANK 2017-BNK5     | HY 2019-55HY        | WFRBS 2014-C22    
|BANK 2020-BNK27    | JPMBB 2015-C33      | WFRBS 2014-C23    
|BMARK 2018-B2      | JPMC 2006-CIBC17    | WFRBS 2014-C25    
|BENCHMARK 2018-B4  | JPMC 2006-LDP9      | BENCHMARK 2021-B23
|BENCHMARK 2018-B8  | JPMCC 2008-C2       | NOHT 2019-HNLA    
|BENCHMARK 2019-B13 | JPMC 2018-LAQ       | ONE 2021-PARK     
|BHMS 2018-ATLS     | JPMCC 2013-C16      | COMM 2021-LBA     
|BSCMS 2007-PWR18   | JPMCC 2017-JP7      | MSBAM 2014-C15    
|BX 2017-CQHP       | JPMCC 2018-ASH8     | JPMCC 2021-MHC    
|BX 2019-ATL        | JPMCC 2019-ICON UES | MHC 2021-MHC      
|CF 2019-MF1        | JPMCC 2020-NNN      | DROP 2021-FILE    
|CFCRE 2016-C3      | JPMDB 2017-C5       | BSCMS 2007-T26    
|CGCMT 2016-P4      | LBUBS 2006-C6       | MHC 2021-MHC2     
|CGCMT 2016-P6      | MLCFC 2006-1        | GSMS 2021-ROSS MZ 
|CGCMT 2020-GC46    | MLCFC 2006-4        | BMARK 2019-B12    
|COBALT 2007-C2     | MLCFC 2007-5        | CF 2019-CF1       
|COBALT 2007-C3     | MLCFC 2007-6        | MSBAM 2013-C12    
|COMM 2013-CR11     | MLMT 2006-C1        | SREIT 2021-FLWR   
|COMM 2015-CCRE23   | MOFT 2020-ABC       | PKHL 2021-MF      
|COMM 2015-CCRE25   | MSBAM 2013-C8       | JPMBB 2014-C19    
|COMM 2015-CCRE26   | MSBAM 2014-C19      | MHP 2021-STOR     
|COMM 2016-CCRE28   | MSBAM 2015-C21      | OPG 2021-PORT     
|COMM 2016-DC2      | MSBAM 2015-C27      | SREIT 2021-PALM   
|COMM 2019-GC44     | MSC 2016-UBS11      | EQUS 2021-EQAZ    
|CPTS 2019-CPT      | MSCI 2016-UBS9      | LUXE 2021-MLBH    
|CSAIL 2017-CX10    | MSC 2019-PLND       | BMARK 2021-B30    
|CSMC 2008-C1       | UBS 2017-C1         | BANK 2021-BNK37   
|CSMC 2014-USA      | VNDO 2016-350P      | MSC 2021-ILP      
|DBJPM 2020-C9      | WBCMT 2006-C23      | SREIT 2021-MFP    
|DCOT 2019-MTC      | WBCMT 2006-C28      | WFCM 2021-C61     
|GRACE 2014-GRCE    | WBCMT 2007-C33      | GSMS 2021-STAR    
|GSMS 2019-BOCA     | WBCMT 2007-C34      | BPR 2021-NRD      
|GSMS 2012-GCJ7     | WBHT 2019-WBM       |                   
|GSMS 2014-GC22     | WFCM 2016-C35       |                   
|GSMS 2014-GC26     | WFCM 2016-NXS6      |