Report of Independent Registered Public Accounting Firm



Board of Directors

PentAlpha Surveillance, LLC



We have examined management’s
assertion, included in the accompanying Management’s Report on Assessment of 2019 Compliance
by PentAlpha Surveillance, LLC with Applicable Regulation AB Servicing Criteria (Management’s
Assertion), that PentAlpha Surveillance, LLC (the Company) complied with the servicing criteria set forth in Item 1122(d) of the
Securities and Exchange Commission’s (SEC) Regulation AB for services by the Company
that are encompassed by contractual obligations to perform Regulation AB reporting (Platforms A and B), including only those asset-backed
securities transactions defined below, as of and for the year ended December 31, 2019, excluding the following criteria set forth
in Items 1122(d)(1)(i-v), 1122(d)(2)(i-vii), 1122(d)(3)(ii-iv), 1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv), which management has
determined are not applicable to the activities performed by the Company with respect to Platform A, and excluding the following
criteria set forth in Items 1122(d)(1)(i-v), 1122(d)(2)(i-vii), 1122(d)(3)(i)(C-D), 1122(d)(3)(ii-iv), 1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv),
which management has determined are not applicable to the activities performed by the Company with respect to Platform B covered
by this report. Appendix B to Management’s Assertion identifies the individual asset-backed
transactions defined by management as constituting Platforms A and B. Management is responsible for the Company’s
compliance with the applicable servicing criteria. Our responsibility is to express an opinion on Management’s
Assertion about the Company’s compliance with the applicable servicing criteria based
on our examination.



Our examination was conducted in accordance with
attestation standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on
a test basis, evidence about the Company’s compliance with the applicable servicing
criteria, including tests on a sample basis of the servicing activities related to Platforms A and B, determining whether the Company
performed those activities in compliance with the servicing criteria during the specified period and performing such other procedures
as we considered necessary in the circumstances. Our procedures were limited to selected servicing activities performed by the
Company during the period covered by this report and, accordingly, such samples may not have included servicing activities related
to each asset-backed transaction in Platforms A and B. Further, an examination is not designed to detect noncompliance arising
from errors that may have occurred prior to the period specified above that may have affected the balances or amounts calculated
or reported by the Company during the period covered by this report. We believe that our examination provides a reasonable basis
for our opinion. Our examination does not provide a legal determination on the Company’s
compliance with the servicing criteria.



In our opinion, Management’s
Assertion that PentAlpha Surveillance, LLC complied with the aforementioned applicable servicing criteria as of and for the year
ended December 31, 2019, for Platforms A and B is fairly stated, in all material respects.







Los Angeles, California
February 24, 2020