| |  | Newmark
                                         Knight Frank(logo)                                                                                                                             
| |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| |  |                                                                                                                                                                                                 
| |  | 225
                                         Franklin Street 18th Floor Boston, MA 02110 T 877.526.3562
                                                                                ngkf.com



MANAGEMENT’S
ASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA PURSUANT TO ITEM 1122 OF REGULATION AB



Management
of Berkeley Point Capital LLC d/b/a Newmark Knight Frank (“NKF”) is responsible for assessing compliance with the
applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to
its role in the servicing of commercial mortgage-backed securities transactions conducted by NKF (the “Platform”)
as of and for the year ended December 31, 2019 (the “Reporting Period”). Appendix A identifies the individual
asset-backed transactions and securities defined by management as constituting the Platform.



NKF’s
management has assessed NKF’s compliance with the applicable servicing criteria during the Reporting Period. In making this
assessment, management used the criteria set forth by the Securities and Exchange Commission (“SEC”) in paragraph
(d) of Item 1122 of Regulation AB, excluding the criteria set forth in AppendixB, which management has determined are
not applicable to the servicing activities it performs with respect to the Platform.



With
respect to applicable servicing criteria identified in Appendix C, there were no activities performed for the Reporting
Period with respect to the Platform, because there was no occurrence of events that would require NKF to perform such activities.



With
respect to servicing criteria 1122(d)(l)(v), 1122(d)(2)(vi) and 1122(d)(2)(vii), management has engaged Midland Loan Services,
a division of PNC Bank, National Association (“Midland”) to perform the activities required by these servicing criteria.
NKF’s management has determined that Midland is not a “servicer” as defined in Item 1101(j) of Regulation AB,
and NKF’s management has elected to take responsibility for assessing compliance with the servicing criteria applicable
to Midland as permitted by the SEC’s Compliance and Disclosure Interpretation (“C&DI”) 200.06, Vendors Engaged
by Servicers (C&DI 200.06) (formerly SEC Regulation AB Manual of Publicly Available Telephone Interpretations, 17.06). Management
has policies and procedures in place designed to provide reasonable assurance that Midland’s activities comply in all material
respects with the servicing criteria applicable to Midland. NKF has not identified and is not aware of any material instances
of noncompliance by Midland with the applicable servicing criteria during the Reporting Period, with respect to the Platform taken
as a whole, nor has it identified any material deficiencies in its policies and procedures to monitor the compliance by Midland
with the applicable servicing criteria during the Reporting Period with respect to the Platform taken as a whole. NKF is solely
responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for Midland and the related criteria.



Based
on such assessment, management believes that with respect to the Reporting Period, NKF has complied in all material respects with
the servicing criteria set forth in Item 1122(d) of Regulation AB of the SEC, including servicing criteria 1122(d)(l)(v), 1122(d)(2)(vi)
and 1122(d)(2)(vii) for which compliance is determined based on C&DI 200.06 as described above relating to its role in the
servicing of the Platform.



2019
BPC d/b/a NKF Management Assessment Letter













| |  | Newmark
                                         Knight Frank(logo)
| |  | -------------------------------------------------------------------







Ernst
and Young LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s
assessment of compliance with the applicable servicing criteria with respect to the Reporting Period.



| | By: | Berkeley
                                         Point Capital LLC, 
                                         dba Newmark Knight Frank
| | --- | ---------------------------------------------------------------------------------------------------------------------------------------







| |  | /s/
                                         Ronald Steffenino                                                                                                                                              
| |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| |  | Ronald
                                         Steffenino
                                                                                Senior
                                         Managing Director



| |  | 2/24/2020
| |  | ---------
| |  | Date     





| |  | Mike
                                         Rispoli 
                                         Chief Financial Officer
| |  | -----------------------------------------------------------------------------------------------------------------------





| |  | 2/24/2020
| |  | ---------
| |  | Date     



2019
BPC d/b/a NKF Management Assessment Letter













| |  | Newmark
                                         Knight Frank(logo)
| |  | -------------------------------------------------------------------



Ernst
and Young LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s
assessment of compliance with the applicable servicing criteria with respect to the Reporting Period.



| | By: | Berkeley
                                         Point Capital LLC,
                                                                                dba
                                         Newmark Knight Frank
| | --- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  | Ronald
                                         Steffenino
                                         Senior Managing Director
| |  | ----------------------------------------------------------------------------------------------------------------------------



| |  | 2/24/2020
| |  | ---------
| |  | Date     



| |  | /s/
                                         Mike Rispoli       
| |  | ----------------------------------------------------------------
| |  | Mike
                                         Rispoli           
| |  | Chief
                                         Financial Officer



| |  | 2/24/2020
| |  | ---------
| |  | Date     





2019
BPC d/b/a NKF Management Assessment Letter











| |  | Newmark
                                         Knight Frank(logo)
| |  | -------------------------------------------------------------------





Appendix
A to Management’s Assessment



COMM
2014-CCRE 17 Mortgage Trust Commercial Mortgage Pass-Through Certificates



COMM
2014-UBS4 Mortgage Trust Commercial Mortgage Pass-Through Certificates



COMM
2014-CCRE19 Mortgage Trust Commercial Mortgage Pass-Through Certificates



GS
Mortgage Securities Trust 2014-GC24 Commercial Mortgage Pass-Through Certificates Series 2014-GC24



COMM
2014-CCRE20 Mortgage Trust Commercial Mortgage Pass-Through Certificates



Commercial
Mortgage Pass-Through Certificates Series 2014-FL2



COMM
2015-LC19 Mortgage Trust Commercial Mortgage Pass-Through Certificates



GS
Mortgage Securities Trust 2015-GC28 Commercial Mortgage Pass-Through Certificates Series 2015-GC28



GS
Mortgage Securities Trust 2015-GC30 Commercial Mortgage Pass-Through Certificates Series 2015-GC30



Commercial
Mortgage Pass-Through Certificates Series 2015-CCRE23



Commercial
Mortgage Pass-Through Certificates Series 2015-LC21



COMM
2015-CCRE24 Mortgage Trust Commercial Mortgage Pass-Through Certificates



COMM
2015-CCRE26 Mortgage Trust Commercial Mortgage Pass-Through Certificates



COMM
2015 CCRE27 Mortgage Trust Commercial Mortgage Pass-Through Certificates



GS
Mortgage Securities Trust 2015-GC34 Commercial Mortgage Pass-Through Certificates Series 2015-GC34



COMM
2015-LC23 Mortgage Trust Commercial Mortgage Pass-Through Certificates Series 2015-LC3



CFCRE
2016-C3 Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series 2016-C3



CCRESG
Commercial Mortgage Trust 2016-HEAT Commercial Mortgage Pass-Through Certificates, Series 2016-HEAT



CFCRE
2016-C4 Mortgage Trust Commercial Mortgage Pass-through Certificates, Series 2016-C4



Citigroup
Commercial Mortgage Trust 2016-C1, Commercial Mortgage Pass-through Certificates, Series 2016-C1



SG
Commercial Mortgage Securities Trust 2016-C5 Commercial Mortgage Pass-Through Certificates Series 2016-C5



Citigroup
Commercial Mortgage Trust 2016-C3, Commercial Mortgage Pass-through Certificates, Series 2016-C3



CFCRE
2016-C6 Mortgage Trust Commercial Mortgage Pass-Through Certificates Series 2016-C6



CFCRE
2016-C7 Commercial Mortgage Pass-Through Certificates



CFCRE
2017-C8 Mortgage Trust Commercial Mortgage Pass-Through Certificates, Series 2017-C8



UBS
Commercial Mortgage Trust 2017-C4 Commercial Mortgage Pass-Through Certificates Series 2017-C4



UBS
Commercial Mortgage Trust 2017-C5 Commercial Mortgage Pass-Through Certificates Series 2017-C5



UBS
Commercial Mortgage Trust 2017-C6 Commercial Mortgage Pass-Through Certificates Series 2017-C6



Citigroup
Commercial Mortgage Trust 2017-C4 Commercial Mortgage Pass-Through Certificates Series 2017-C4



CCUBS
Commercial Mortgage Trust 2017-C1 Commercial Mortgage Pass-Through Certificates Series 2017-C1



UBS
Commercial Mortgage Trust 2018-C8 Commercial Mortgage Pass-Through Certificates Series 2018-C8



UBS
Commercial Mortgage Trust 2018-C9 Commercial Mortgage Pass-Through Certificates, Series 2018-C9



Benchmark
2018-B3 commercial Mortgage Pass-Through Certificates Series 2018-B3



UBS
Commercial Mortgage Trust 2018-C10 Commercial Mortgage Pass-through Certificates, Series 2018-C10



UBS
Commercial Mortgage Trust 2018-C12 Commercial Mortgage Pass-Through Certificates, Series 2018-C12



Morgan
Stanley Capital I Trust 2018-L1 Commercial Mortgage Pass-Through Certificates, Series 2018-L1



UBS
Commercial Mortgage Trust 2018-C14 Commercial Mortgage Pass-Through Certificates Series 2018 C14



Citigroup
Commercial Mortgage Trust 2018-C6 Commercial Mortgage Pass-Through Certificates Series 2018-C6



BBCMS
Mortgage Trust 2018 C2 Commercial Mortgage Pass-Through Certificates, Series 2018-C2



Morgan
Stanley Capital I Trust 2018 H4 Commercial Mortgage Pass-Through Series 2018 H4



Morgan
Stanley Capital I Trust 2019 L2 Commercial Mortgage Pass-Through Certificates Series 2019-L2



CF
2019 CF1 Mortgage Trust Commercial Mortgage Pass-Through Certificates Series 2019-CF1



2019
BPC d/b/a NKF Management Assessment Letter











| |  | Newmark
                                         Knight Frank(logo)
| |  | -------------------------------------------------------------------



Appendix
B to Management’s Assessment



Regulation
AB Item 1122(d) criteria determined to be not applicable:



| | ● | 1122(d)(l)(iii)
| | - | ---------------



| | ● | 1122(d)(2)(ii)
| | - | --------------



| | ● | 1122(d)(2)(iii)
| | - | ---------------



| | ● | 1122(d)(3)(i)
| | - | -------------



| | ● | 1122(d)(3)(ii)
| | - | --------------



| | ● | 1122(d)(3)(iv)
| | - | --------------



| | ● | 1122(d)(4)(ii)
| | - | --------------



| | ● | 1122(d)(4)(vii)
| | - | ---------------



| | ● | 1122(d)(4)(xv)
| | - | --------------



2019
BPC d/b/a NKF Management Assessment Letter













| |  | Newmark
                                         Knight Frank(logo)
| |  | -------------------------------------------------------------------



Appendix
C to Management’s Assessment



Regulation
AB Item 1122(d) criteria that NKF is under contract to perform the activities required, but for which there were no occurrences
of events for the year ended December 31, 2019 that required them to perform such activities:



| | ● | 1122(d)(4)(i)
| | - | -------------



| | ● | 1122(d)(4)(iii)
| | - | ---------------



| | ● | 1122(d)(4)(vi)
| | - | --------------



| | ● | 1122(d)(4)(viii)
| | - | ----------------



| | ● | 1122(d)(4)(xii)
| | - | ---------------



| | ● | 1122(d)(4)(xiv)
| | - | ---------------



2019
BPC d/b/a NKF Management Assessment Letter