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 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 Newmark (the “Platform”) as of and for the year ended December
31, 2021 (the “Reporting Period”). Appendix A identifies the individual asset-backed transactions and securities defined
by management as constituting the Platform.



Newmark’s
management has assessed Newmark’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 Appendix B, 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 Newmark to perform such activities.



With
respect to servicing criteria 1122(d)(1)(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.
Newmark management has determined that Midland is not a “servicer” as defined in Item 1101(j) of Regulation AB, and
Newmark’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. Newmark 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, Newmark 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)(1)(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.



|NEWMARK
    (logo) | 8
    Spring House Innovation Park
    Suite 200
    Lower Gwynedd, PA  19002 
    nmrk.com
|------------------ | -------------------------------------------------------------------------------------------







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                         |  |           | 
|                                    |  |           | 
|/s/ Ronald Steffenino               |  | 2/22/2022 | 
|Ronald Steffenino                   |  | Date      | 
|Vice Chairman                       |  |           | 
|                                    |  |           | 
|/s/ Mike Rispoli                    |  | 2/22/2022 | 
|Mike Rispoli                        |  | Date      | 
|Chief Financial Officer             |  |           | 



|NEWMARK
    (logo) | 8 Spring
    House Innovation Park
    Suite 200
    Lower Gwynedd, PA  19002 
    nmrk.com
|------------------ | -------------------------------------------------------------------------------------------







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



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



CommercialMortgage
Pass-Through Certificates Series 2015-CCRE23



CommercialMortgage
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 MortgageTrust Commercial Mortgage Pass-Through Certificates Series 2015-LC3



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



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 CommercialMortgage 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 MortgageTrust
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



|NEWMARK
    (logo) | 8 Spring
    House Innovation Park
    Suite 200
    Lower Gwynedd, PA  19002 
    nmrk.com
|------------------ | -------------------------------------------------------------------------------------------







Appendix
B to Management’s Assessment

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



|v | 1122(d)(1)(iii)
|- | ---------------
|  |                
|v | 1122(d)(2)(ii) 
|  |                
|v | 1122(d)(2)(iii)
|  |                
|v | 1122(d)(3)(i)  
|  |                
|v | 1122(d)(3)(ii) 
|  |                
|v | 1122(d)(3)(iii)
|  |                
|v | 1122(d)(3)(iv) 
|  |                
|v | 1122(d)(4)(ii) 
|  |                
|v | 1122(d)(4)(vii)
|  |                
|v | 1122(d)(4)(xv) 



|NEWMARK
    (logo) | 8 Spring
    House Innovation Park
    Suite 200
    Lower Gwynedd, PA  19002 
    nmrk.com
|------------------ | -------------------------------------------------------------------------------------------







Appendix
C to Management’s Assessment



Regulation
AB Item 1122(d) criteria that Newmark is under contract to perform the activities required, but for which there were no occurrences
of events for the year ended December 31, 2021 that required them to perform such activities:



|v | 1122(d)(4)(iii)
|- | ---------------
|  |                
|v | 1122(d)(4)(vi) 
|  |                
|v | 1122(d)(4)(ix) 
|  |                
|v | 1122(d)(4)(xiv)



|NEWMARK
    (logo) | 8 Spring
    House Innovation Park
    Suite 200
    Lower Gwynedd, PA  19002 
    nmrk.com
|------------------ | -------------------------------------------------------------------------------------------