Management’s
Assertion on Compliance with Applicable  Regulation
AB Servicing Criteria  1.Rialto
                                         Capital Advisors, LLC (the “Asserting Party”) is responsible for assessing
                                         compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122
                                         of Regulation AB, as of and for the 12-month period ending December 31, 2023 (the “Reporting
                                         Period”), as set forth in Appendix A hereto. The transactions covered by this report,
                                         include commercial mortgage-asset-backed securities transactions, as listed on Exhibit
                                         1 hereto, for which the Asserting Party served as special servicer, and that were registered
                                         with the Securities and Exchange Commission pursuant to the Securities Act of 1933 (the
                                         “Platform”);  2.The
                                         Asserting Party has engaged certain vendors, which are not servicers as defined in Item
                                         1101(j) of Regulation AB (the “Vendors”), to perform specific, limited or
                                         scripted activities, and the Asserting Party elects to take responsibility for assessing
                                         compliance with the servicing criteria or portion of the servicing criteria applicable
                                         to such Vendors’ activities as set forth in Appendix A hereto;  3.Except
                                         as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in
                                         paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable
                                         servicing criteria;  4.The
                                         criteria listed in the column titled “Inapplicable Servicing Criteria” on
                                         Appendix A hereto are inapplicable to the Asserting Party based on the activities it
                                         performs, directly or through its Vendors, with respect to the Platform;  5.The
                                         Asserting Party has complied, in all material respects, with the applicable servicing
                                         criteria as of December 31, 2023 and for the Reporting Period with respect to the Platform
                                         taken as a whole;  6.The
                                         Asserting Party has not identified and is not aware of any material instance of noncompliance
                                         by the Vendors with the applicable servicing criteria as of December 31, 2023 and for
                                         the Reporting Period with respect to the Platform taken as a whole;  7.The
                                         Asserting Party has not identified any material deficiency in its policies and procedures
                                         to monitor the compliance by the Vendors with the applicable servicing criteria as of
                                         December 31, 2023 and for the Reporting Period with respect to the Platform taken as
                                         a whole; and  8.Deloitte
                                         & Touche LLP, an independent registered public accounting firm, has issued an attestation
                                         report on the Asserting Party’s assessment of compliance with the applicable servicing
                                         criteria for the Reporting Period.  February
14, 2024  Name:
Adam Singer  Title:
Managing Director   Signature:
    /s/
    Adam Singer












APPENDIX
A  SERVICING
    CRITERIAReference
    Criteria
    Performed
    byServicer
    InapplicableServicingCriteriaGeneral
    Servicing Considerations1122(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.
    X1122(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.
    X11122(d)(1)(iii)
    Any
    requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.
    
    X1122(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.
    X1122(d)(1)(v)
    Aggregation
    of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.
    X




2







Cash
    Collection and Administration1122(d)(2)(i)
    Payments
    on pool assets 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.
    X1122(d)(2)(ii)
    Disbursements
    made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.
    X31122(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.
    X31122(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.
    X1122(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.
    X1122(d)(2)(vi)
    Unissued
    checks are safeguarded so as to prevent unauthorized access.
    X1122(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 are (A) mathematically accurate; (B) prepared within 30 calendar days after
    the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) 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.
    X




3







Investor
    Remittances and Reporting1122(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 pool assets serviced
    by the Servicer.
    X41122(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.
    
    X1122(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.
    
    X1122(d)(3)(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 Administration1122(d)(4)(i)
    Collateral
    or security on Pool assets is maintained as required by the transaction agreements or related mortgage loan documents.
    X1122(d)(4)(ii)
    Pool
    asset and related documents are safeguarded as required by the transaction agreements
    X1122(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.
    X31122(d)(4)(iv)
    Payments
    on pool assets, including any payoffs, made in accordance with the related pool asset 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 pool asset documents.
    X21122(d)(4)(v)
    The
    Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s
    unpaid principal balance.
    
    X1122(d)(4)(vi)
    Changes
    with respect to the terms or status of an obligor's pool assets (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.
    X1122(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.
    X1122(d)(4)(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).
    X1122(d)(4)(ix)
    Adjustments
    to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.
    
    X1122(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
    pool asset 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 pool asset documents and state laws; and (C)
    such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other
    number of days specified in the transaction agreements.
    
    X




5







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.
    X51122(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.
    
    X1122(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.
    
    X1122(d)(4)(xiv)
    Delinquencies,
    charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.
    
    X1122(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.
    
    X  X1-Rialto Capital Advisors, LLC performs the activities pertaining to this
criterion, except for specific, limited activities performed by its third-party property managers relating to REO Property, if
any. Rialto has elected to take responsibility for assessing compliance with these servicing criteria with respect to the activities
of its third-party property managers, as and if applicable.  X2-Primary responsibility for processing borrower payments rests with the
Master Servicer, however, Rialto Capital Advisors, LLC may from time to time receive payments on an exception basis which are
forwarded to the Master Servicer in accordance with such criteria. The criteria is marked applicable as Rialto Capital Advisors,
LLC had instances or activity relating to this criteria for the calendar year of January 1, 2023 to December 31, 2023.  X3-Although Rialto Capital Advisors, LLC is responsible for performing
the activities under this criteria, it is noted no such activities occurred during the calendar year of January 1, 2023 to December
31, 2023.  X4-Only items (A) and (B) of the Servicing Criteria are applicable to Rialto
Capital Advisors, LLC as special servicer. Items (C) and (D) are inapplicable as the responsibility for filing reports with the
Commission and agreeing totals to the Servicer records rests with the Trustee and/or Certificate Administrator, as applicable.  X5-Commencing in the regulatory reporting year 2023, Rialto Capital Advisors
periodically advances certain insurance premium payments on behalf of Obligors to insurance carriers to avoid cancellation of
policies or late payments and penalties. Advances are made in accordance with applicable transaction documents.




6







|Exhibit
    1                       
|------------------------------------
|Pooling
    and Servicing Agreements
|UBSBB
    2012-C2                   
|GSMS
    2011-GC3                   
|WFRBS
    2013-C12                  
|WFCM
    2012-LC5                   
|BACM
    2016-UBS10                 
|BACM
    2017-BNK3                  
|BAMLL
    2022-DKLX                 
|BANK
    2017-BNK4                  
|BANK
    2017-BNK7                  
|BANK
    2017-BNK9                  
|BANK
    2018-BNK14                 
|BANK
    2019-BNK18                 
|BANK
    2019-BNK21                 
|BANK
    2020-BNK29                 
|BANK
    2021-BNK32                 
|BANK
    2021-BNK33                 
|BANK
    2021-BNK36                 
|BANK
    2022-BN41                  
|BBCMS
    2017-C1                   
|BBCMS
    2019-C4                   
|BBCMS
    2020-C7                   
|BBCMS
    2021-C10                  
|BBCMS
    2022-C15                  
|BBCMS
    2022-C18                  
|BMARK
    2019-B11                  
|BMARK
    2020-B19                  
|BMARK
    2020-B22                  
|BMARK
    2021-B25                  
|BMARK
    2021-B31                  
|BMARK
    2022-B37                  
|BMO
    2022-C2                     
|BSST
    2021-1818                  
|BSST
    2022-1700                  
|CD
    2016-CD1                     
|CD
    2017-CD4                     
|CD
    2017-CD5                     











|Pooling
    and Servicing Agreements                                                                           | Applicable
    Certification Period     
|-------------------------------------------------------------------------------------------------------------- | ----------------------------------------
|CD
    2018-CD7                                                                                                | January
    1, 2023 to December 31, 2023
|CFCRE
    2016-C4                                                                                              | January
    1, 2023 to December 31, 2023
|CFCRE
    2016-C6                                                                                              | January
    1, 2023 to December 31, 2023
|CFCRE
    2017-C8                                                                                              | January
    1, 2023 to December 31, 2023
|CGCMT
    2014-GC23                                                                                            | January
    1, 2023 to December 31, 2023
|CGCMT
    2015-GC27                                                                                            | January
    1, 2023 to December 31, 2023
|CGCMT
    2016-C3                                                                                              | January
    1, 2023 to December 31, 2023
|CGCMT
    2017-P7                                                                                              | January
    1, 2023 to December 31, 2023
|CGCMT
    2019-GC41                                                                                            | January
    1, 2023 to December 31, 2023
|CGCMT
    2019-GC43                                                                                            | January
    1, 2023 to December 31, 2023
|CGCMT
    2022-GC48
(RCA
    is special servicer as to the Yorkshire & Lexington Towers loan combination only) | January
    1, 2023 to December 31, 2023
|COMM
    2012-CCRE4                                                                                            | January
    1, 2023 to December 31, 2023
|COMM
    2013-LC13                                                                                             | January
    1, 2023 to December 31, 2023
|COMM
    2013-LC6                                                                                              | January
    1, 2023 to December 31, 2023
|COMM
    2014-CCRE14                                                                                           | January
    1, 2023 to December 31, 2023
|COMM
    2014-CCRE15                                                                                           | January
    1, 2023 to December 31, 2023
|COMM
    2014-CCRE18                                                                                           | January
    1, 2023 to December 31, 2023
|COMM
    2014-LC15                                                                                             | January
    1, 2023 to December 31, 2023
|COMM
    2014-UBS5                                                                                             | January
    1, 2023 to December 31, 2023
|COMM
    2015-CCRE27                                                                                           | January
    1, 2023 to December 31, 2023
|COMM
    2015-DC1                                                                                              | January
    1, 2023 to December 31, 2023
|COMM
    2015-LC21                                                                                             | January
    1, 2023 to December 31, 2023
|COMM
    2015-PC1                                                                                              | January
    1, 2023 to December 31, 2023
|COMM
    2019-GC44                                                                                             | January
    1, 2023 to December 31, 2023
|CSAIL
    2015-C2                                                                                              | January
    1, 2023 to December 31, 2023
|CSAIL
    2015-C3                                                                                              | January
    1, 2023 to December 31, 2023
|CSAIL
    2016-C5                                                                                              | January
    1, 2023 to December 31, 2023
|CSAIL
    2016-C7                                                                                              | January
    1, 2023 to December 31, 2023
|CSAIL
    2017-CX9                                                                                             | January
    1, 2023 to December 31, 2023
|CSAIL
    2018-C14                                                                                             | January
    1, 2023 to December 31, 2023
|CSAIL
    2019-C18                                                                                             | January
    1, 2023 to December 31, 2023
|CSMC
    2020-FACT                                                                                             | January
    1, 2023 to December 31, 2023
|CSMC
    2020-NET                                                                                              | January
    1, 2023 to December 31, 2023
|CSMC
    2021-ADV                                                                                              | January
    1, 2023 to December 31, 2023
|CSMC
    2022-NWPT                                                                                             | January
    1, 2023 to December 31, 2023
|DBGS
    2018-C1                                                                                               | January
    1, 2023 to December 31, 2023
|FSRIA
    2019-FL1                                                                                             | January
    1, 2023 to December 31, 2023











|Pooling
    and Servicing Agreements | Applicable
    Certification Period     
|------------------------------------ | ----------------------------------------
|FSRIA
    2021-FL2                   | January
    1, 2023 to December 31, 2023
|FSRIA
    2021-FL3                   | January
    1, 2023 to December 31, 2023
|FSRIA
    2022-FL4                   | January
    1, 2023 to December 31, 2023
|FSRIA
    2022-FL5                   | January
    1, 2023 to December 31, 2023
|FSRIA
    2022-FL6                   | January
    1, 2023 to December 31, 2023
|FSRIA
    2022-FL7                   | January
    1, 2023 to December 31, 2023
|GSMS
    2012-GCJ9                   | January
    1, 2023 to December 31, 2023
|GSMS
    2013-GCJ12                  | January
    1, 2023 to December 31, 2023
|GSMS
    2013-GCJ16                  | January
    1, 2023 to December 31, 2023
|GSMS
    2015-GC28                   | January
    1, 2023 to December 31, 2023
|GSMS
    2016-GS3                    | January
    1, 2023 to December 31, 2023
|GSMS
    2017-GS5                    | January
    1, 2023 to December 31, 2023
|GSMS
    2017-GS7                    | January
    1, 2023 to December 31, 2023
|GSMS
    2018-3PCK                   | January
    1, 2023 to December 31, 2023
|GSMS
    2018-GS10                   | January
    1, 2023 to December 31, 2023
|GSMS
    2018-GS9                    | January
    1, 2023 to December 31, 2023
|ILPT
    2019-SURF                   | January
    1, 2023 to December 31, 2023
|JPMBB
    2014-C23                   | January
    1, 2023 to December 31, 2023
|JPMBB
    2014-C25                   | January
    1, 2023 to December 31, 2023
|JPMBB
    2015-C31                   | January
    1, 2023 to December 31, 2023
|JPMCC
    2012-LC9                   | January
    1, 2023 to December 31, 2023
|JPMCC
    2017-JP6                   | January
    1, 2023 to December 31, 2023
|MSBAM
    2012-C5                    | January
    1, 2023 to December 31, 2023
|MSBAM
    2013-C13                   | January
    1, 2023 to December 31, 2023
|MSBAM
    2014-C14                   | January
    1, 2023 to December 31, 2023
|MSBAM
    2014-C17                   | January
    1, 2023 to December 31, 2023
|MSBAM
    2014-C18                   | January
    1, 2023 to December 31, 2023
|MSBAM
    2014-C19                   | January
    1, 2023 to December 31, 2023
|MSBAM
    2015-C20                   | January
    1, 2023 to December 31, 2023
|MSBAM
    2016-C29                   | January
    1, 2023 to December 31, 2023
|MSBAM
    2016-C31                   | January
    1, 2023 to December 31, 2023
|MSCI
    2015-UBS8                   | January
    1, 2023 to December 31, 2023
|MSCI
    2016-UBS12                  | January
    1, 2023 to December 31, 2023
|MSCI
    2019-L2                     | January
    1, 2023 to December 31, 2023
|Rial
    2022-FL8                    | January
    1, 2023 to December 31, 2023
|SGCMS
    2016-C5                    | January
    1, 2023 to December 31, 2023
|SPGN
    2022-TFLM                   | January
    1, 2023 to December 31, 2023
|UBS-Barclays
    2012-C3             | January
    1, 2023 to December 31, 2023











|Pooling
    and Servicing Agreements | Applicable
    Certification Period     
|------------------------------------ | ----------------------------------------
|UBS-Barclays
    2012-C4             | January
    1, 2023 to December 31, 2023
|UBS-Barclays
    2013-C6             | January
    1, 2023 to December 31, 2023
|UBS-Citigroup
    2011-C1            | January
    1, 2023 to December 31, 2023
|UBSCM
    2012-C1                    | January
    1, 2023 to December 31, 2023
|UBSCM
    2017-C4                    | January
    1, 2023 to December 31, 2023
|UBSCM
    2017-C6                    | January
    1, 2023 to December 31, 2023
|UBSCM
    2018-C10                   | January
    1, 2023 to December 31, 2023
|UBSCM
    2018-C14                   | January
    1, 2023 to December 31, 2023
|UBSCM
    2018-C9                    | January
    1, 2023 to December 31, 2023
|UBSCM
    2019-C17                   | January
    1, 2023 to December 31, 2023
|UBSCM
    2019-C18                   | January
    1, 2023 to December 31, 2023
|WFCM
    2013-LC12                   | January
    1, 2023 to December 31, 2023
|WFCM
    2014-LC18                   | January
    1, 2023 to December 31, 2023
|WFCM
    2015-C27                    | January
    1, 2023 to December 31, 2023
|WFCM
    2015-C30                    | January
    1, 2023 to December 31, 2023
|WFCM
    2015-LC20                   | January
    1, 2023 to December 31, 2023
|WFCM
    2015-LC22                   | January
    1, 2023 to December 31, 2023
|WFCM
    2015-NXS1                   | January
    1, 2023 to December 31, 2023
|WFCM
    2015-NXS2                   | January
    1, 2023 to December 31, 2023
|WFCM
    2015-NXS4                   | January
    1, 2023 to December 31, 2023
|WFCM
    2015-P2                     | January
    1, 2023 to December 31, 2023
|WFCM
    2015-SG1                    | January
    1, 2023 to December 31, 2023
|WFCM
    2016-BNK1                   | January
    1, 2023 to December 31, 2023
|WFCM
    2016-C32                    | January
    1, 2023 to December 31, 2023
|WFCM
    2016-C33                    | January
    1, 2023 to December 31, 2023
|WFCM
    2016-NXS5                   | January
    1, 2023 to December 31, 2023
|WFCM
    2018-C44                    | January
    1, 2023 to December 31, 2023
|WFCM
    2019-C50                    | January
    1, 2023 to December 31, 2023
|WFCM
    2020-C55                    | January
    1, 2023 to December 31, 2023
|WFCM
    2020-C58                    | January
    1, 2023 to December 31, 2023
|WFRBS
    2011-C2                    | January
    1, 2023 to December 31, 2023
|WFRBS
    2011-C3                    | January
    1, 2023 to December 31, 2023
|WFRBS
    2011-C4                    | January
    1, 2023 to December 31, 2023
|WFRBS
    2011-C5                    | January
    1, 2023 to December 31, 2023
|WFRBS
    2013-C14                   | January
    1, 2023 to December 31, 2023
|WFRBS
    2013-C16                   | January
    1, 2023 to December 31, 2023
|WFRBS
    2013-C17                   | January
    1, 2023 to December 31, 2023
|WFRBS
    2014-C20                   | January
    1, 2023 to December 31, 2023











|Pooling
    and Servicing Agreements | Applicable
    Certification Period       
|------------------------------------ | ------------------------------------------
|WFRBS
    2014-C24                   | January
    1, 2023 to December 31, 2023  
|WFRBS
    2014-LC14                  | January
    1, 2023 to December 31, 2023  
|UBSCM
    2017-C1                    | January
    5, 2023 to December 31, 2023  
|BMO
    2023-C5                      | June
    21, 2023 to December 31, 2023    
|BMO
    2023-C6                      | August
    30, 2023 to December 31, 2023  
|BBCMS
    2023-C22                   | November
    1, 2023 to December 31, 2023 
|TMSQ
    2014-1500                   | November
    2, 2023 to December 31, 2023 
|SCG
    2023-NASH                    | November
    29, 2023 to December 31, 2023
|DTP
    2023-STE2                    | December
    28, 2023 to December 31, 2023