February 28, 2024



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, 2023.



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 December 31, 2023 and for the period from January 1, 2023 to December 31, 2023 (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, 2023 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, 2023.














CWCapital Asset Management LLC







|    |                                           |  | Date: February 28, 2024
|--- | ----------------------------------------- |  | -----------------------
|By: | /s/ James P. Shevlin                      |  |                        
|    | James P. Shevlin                          |  |                        
|    | President/Chief Operating Officer         |  |                        
|    |                                           |  |                        
|    |                                           |  | Date: February 28, 2024
|By: | /s/ Bruce Cunningham                      |  |                        
|    | Bruce Cunningham 
Chief Financial Officer |  |                        
|    |                                           |  |                        












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                                                                                                             








|                 | Relevant Servicing Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |               
|---------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------
|Reference        | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | CWCAM         
|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.                                                                                                                                                                                                                                                                                         | Applicable    
|1122(d)(4)(viii) | Records documenting collection efforts are maintained during the period a mortgage loan 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 mortgage loans including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).                                                                           | Applicable    
|1122(d)(4)(ix)   | Adjustments to interest rates or rates of return for mortgage loans with variable rates are computed based on the related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                             | Not Applicable
|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 mortgage loan documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable mortgage loan documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related mortgage loans, or such other number of days specified in the transaction agreements. | Not Applicable
|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.                                                                                                                                                                                                | Not Applicable
|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.                                                                                                                                                                                                                                                                                                                                                            | Not Applicable
|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.                                                                                                                                                                                                                                                                                                                                                                                      | Not Applicable
|1122(d)(4)(xiv)  | Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Not Applicable
|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.                                                                                                                                                                                                                                                                                                                                                                                                                  | Not Applicable








Appendix
B 
Platform



|Aventura 2018-AVM                                                                    | DBJPM 2020-C9                                                                | NOHT 2019-HNLA 
|------------------------------------------------------------------------------------ | ---------------------------------------------------------------------------- | ---------------
|BACM 2007-1                                                                          | DBUBS 2011-LC3                                                               | ONE 2021-PARK  
|BACM 2008-1                                                                          | DCOT 2019-MTC                                                                | OPG 2021-PORT  
|BANCORP 2019-CRE6                                                                    | DROP 2021-FILE                                                               | PKHL 2021-MF   
|BANK 2020-BNK25                                                                      | EQUS 2021-EQAZ                                                               | SMR 2022-IND   
|BANK 2020-BNK27                                                                      | GSMS 2012-GCJ7                                                               | SREIT 2021-FLWR
|BANK 2021-BNK37                                                                      | GSMS 2014-GC22                                                               | SREIT 2021-MFP 
|BANK 2022-BNK40                                                                      | GSMS 2014-GC26                                                               | SREIT 2021-PALM
|BANK5 2023-5YR1                                                                      | GSMS 2015-GC32                                                               | UBS 2017-C1    
|BANK5 2023-5YR2                                                                      | GSMS 2020-GC45                                                               | VNDO 2016-350P 
|BENCHMARK 2018-B4                                                                    | GSMS 2021-ROSS MZ                                                            | WBCMT 2006-C23 
|BENCHMARK 2018-B8                                                                    | GSMS 2021-STAR                                                               | WBCMT 2006-C28 
|BENCHMARK 2021-B23                                                                   | HGI 2022-FL3                                                                 | WBCMT 2007-C33 
|BHMS 2018-ATLS                                                                       | HILT 2016-HHV                                                                | WBCMT 2007-C34 
|BLP 2023-IND                                                                         | Hudson Yards 2019-55HY                                                       | WBHT 2019-WBM  
|BMARK 2018-B2                                                                        | JPMBB 2014-C19                                                               | WFCM 2016-C35  
|BMARK 2019-B12                                                                       | JPMBB 2014-C26                                                               | WFCM 2016-NXS6 
|BMARK 2021-B30                                                                       | JPMBB 2015-C33                                                               | WFCM 2019-JWDR 
|BMO 2022-C1                                                                          | JPMC 2006-CIBC17                                                             | WFCM 2021-C61  
|BPR 2021-NRD                                                                         | JPMC 2006-LDP9                                                               | WFRBS 2013-C11 
|BPR 2022-SSP                                                                         | JPMCC 2008-C2                                                                | WFRBS 2013-C15 
|BSCMS 2007-PWR18                                                                     | JPMCC 2013-C10                                                               | WFRBS 2013-UBS1
|BSCMS 2007-TOP26                                                                     | JPMCC 2017-JP7                                                               | WFRBS 2014-C22 
|BWAY 2015-1740                                                                       | JPMCC 2018-ASH8                                                              | WFRBS 2014-C23 
|BX 2017-CQHP                                                                         | JPMCC 2019-ICON UES                                                          | WFRBS 2014-C25 
|BX 2019-ATL 
CF 2019-CF1 
CFCRE 2016-C3 
CGCMT 2016-P4
CGCMT 2016-P6                 | JPMCC 2020-NNN 
JPMCC 2021-MHC 
JPMDB 2017-C5 
LBUBS 2006-C6
MHC 2021-MHC    |                
|CGCMT 2020-GC46 
COBALT 2007-C2 
COMM 2013-CCRE11 
COMM 2015-CCRE25
COMM 2015-CCRE26 | MHC 2021-MHC2 
MHP 2021-STOR 
MLCFC 2006-1
MLCFC 2007-5
MLMT 2006-C1         |                
|COMM 2016-CCRE28 
COMM 2016-DC2 
COMM 2019-GC44 
COMM 2022-HC
CORE 2019-CORE         | MOFT 2020-ABC 
MSBAM 2013-C12 
MSBAM 2014-C15 
MSBAM 2014-C19
MSBAM 2015-C27 |                
|CPTS 2019-CPT 
CSAIL 2017-CX10 
CSMC 2008-C1
CSMC 2014-USA                           | MSC 2016-UBS11 
MSC 2019-PLND 
MSC 2021-ILP
MSCI 2016-UBS9                   |