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**Report of Independent Registered PublicAccounting Firm**

 

Tothe Management of AEGON USA Realty Advisors LLC

 

Wehave examined AEGON USA Realty Advisors LLC’s (“AEGON” or the “Company”)compliance with the servicing criteria set forth in Item 1122(d) of theSecurities and Exchange Commission’s Regulation AB for the commercial mortgagebacked securities transactions (the “Platform”) described in the accompanyingReport on Assessment of Compliance with Applicable Servicing Criteria Pursuantto Item 1122(d) of Regulation AB under the Securities Exchange Act of 1934, asof December 31, 2021 and for the year then ended excluding criteria1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv),1122(d)(4)(v), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii),1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv), which the Company hasdetermined are not applicable to the servicing activities performed by it withresponse to the Platform. Appendix B to management's assertion identifies theindividual asset- backed transactions and securities defined by management asconstituting the Platform. AEGON’s management is responsible for the Company'scompliance with the applicable servicing criteria. Our responsibility is toexpress an opinion on the Company's compliance with the applicable servicingcriteria based on our examination.

 

Ourexamination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants. Those standards require that we plan and perform the examinationto obtain reasonable assurance about whether the Company complied, in allmaterial respects, with the applicable servicing criteria, and, accordingly,included examining, on a test basis, evidence about the Company’s compliance withthe applicable servicing criteria and performing such other procedures as weconsidered necessary in the circumstances. Our examination included testing ofselected asset-backed transactions and securities that comprise the Platform,testing of selected servicing activities related to the Platform, anddetermining whether the Company processed those selected transactions andperformed those selected activities in compliance with the applicable servicingcriteria. Our procedures were limited to the selected transactions andservicing activities performed by the Company during the period covered by thisreport. Our procedures were not designed to detect noncompliance arising fromerrors that may have occurred prior to or subsequent to our tests that may haveaffected the balances or amounts calculated or reported by the Company duringthe period covered by this report. We believe that our examination provides,and that the evidence we obtained is sufficient and appropriate to provide, areasonable basis for our opinion. Our examination does not provide a legaldetermination on the Company’s compliance with the servicing criteria.

 

Ourexamination disclosed the following material noncompliance with the servicingcriteria set forth in Item 1122(d)(3)(i)(A) of Regulation AB applicable to theCompany during year ended December 31, 2021. As required by Item1122(d)(3)(i)(A) of Regulation AB, reports to investors are maintained inaccordance with transaction agreements and applicable Commission requirementsand are prepared in accordance with timeframes and other terms set forth in thetransaction agreements. For the only active special serviced deal subject toItem 1122(d)(3)(i)(A), the report to the investors was not prepared inaccordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021.

 

In our opinion, except for the material noncompliance described inthe preceding paragraph, AEGON complied with the aforementioned applicable servicingcriteria as of and for the year ended December 31, 2021 for the Platform, inall material respects. 

 

 

/s/PricewaterhouseCoopers LLP

Chicago,Illinois

February25, 2022 

 

 

*PricewaterhouseCoopersLLP, One North Wacker Chicago, Illinois 60606*

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