AEGON(logo)



| | AEGON USA Realty Advisors,
    LLC                              
| | ----------------------------------------------------------------
| | 6300 C Street SW                                                
| | Cedar Rapids, Iowa 52499-5554 
    specialservicing@aegonusa.com



Report
on Assessment of Compliance with Applicable Servicing Criteria Pursuant to Item 1122(d) of Regulation AB under the Securities
Exchange Act of 1934



AEGON
USA Realty Advisors, LLC (“AEGON”) as special servicer for the commercial mortgage backed securities transactions
in Appendix B (the “Platform”) hereby provides the following report on its assessment of compliance with the applicable
servicing criteria pursuant paragraph (d) of Item 1122 of Regulation AB applicable to it and as described on Appendix A hereto.



| | 1. | AEGON
                                         is responsible for assessing its 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, 2021 (the “Reporting Period”) as noted on the accompanying
                                         Appendix A;
| | -- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 2. | Except
                                         as set forth in paragraph 3 below, AEGON used the criteria set forth in paragraph (d)
                                         of Item
1122 of Regulation AB to assess its compliance with the applicable servicing criteria;
| | -- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 3. | The
                                         criteria listed as “N/A” in the column titled “Performed Directly by
                                         AEGON” on Appendix A hereto are inapplicable to AEGON based on the activities it
                                         performs with respect to the Platform;
| | -- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 4. | AEGON
                                         has complied, in all material respects, with the applicable servicing criteria as of
                                         December 31, 2021 and for the Reporting Period with respect to the Platform taken as
                                         a whole, except as described in Appendix C hereto;
| | -- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 5. | PricewaterhouseCoopers
LLP, a registered public accounting firm, has issued an attestation report on AEGON’s assessment of compliance with the
applicable servicing criteria for the Reporting period.
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | AEGON USA Realty Advisors, LLC
| | ------------------------------
| |                               
| | /s/
     Sarah Swartzendruber 
| | Sarah Swartzendruber          
| | Managing Director             
| |                               
| | February 25, 2022             











AEGON(logo)



Appendix
A – Servicing Criteria Applicable to AEGON



|                | SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                        | APPLICABLESERVICINGCRITERIA   
|--------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------
|Reference       | Criteria                                                                                                                                                                                                                                                                                                                                                                                  | Performed
    Directly byAEGON
|                | 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.                                                                                                                                                                                                                          | X                             
|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.                                                                                                                                                                              | XC                            
|1122(d)(1)(iii) | Any
    requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                     | N/AA                          
|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 the transaction agreements. | X                             
|1122(d)(1)(v)   | Aggregation
    of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                                                                                                                                               | X                             
|                | Cash Collection and Administration                                                                                                                                                                                                                                                                                                                                                        |                               
|1122(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.                                                                                                                                     | XC                            
|1122(d)(2)(ii)  | Disbursements
    made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                 | XB                            
|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.                                                                                                                                                         | XC                            



AAEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v),
1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable
to the activities AEGON performs with respect to the Platform.



BThis servicing activity was not performed during the Reporting Period as there were no loans serviced on the Platform that
would trigger the applicability of this criteria.



CThis servicing activity was not performed during the Reporting Period as there was no activity for serviced loans on the
Platform that would trigger performance of this activity.











AEGON(logo)



Appendix
A (cont.)



|                                                                                                                                                                                                                             | SERVICING
    CRITERIA                                                                                                                                                                                                                                                                                                                                                                          | APPLICABLESERVICINGCRITERIA   
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------
|Reference                                                                                                                                                                                                                    | Criteria                                                                                                                                                                                                                                                                                                                                                                                        | Performed
    Directly byAEGON
|                                                                                                                                                                                                                             | Cash Collection and Administration (continued)                                                                                                                                                                                                                                                                                                                                                  |                               
|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.                                                                                                                                   | XC                            
|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. | XC                            
|1122(d)(2)(vi)                                                                                                                                                                                                               | Unissued
    checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                       | XC                            
|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:                                                                                                                                                                                          | XC                            
|(A)
    Are mathematically accurate;                                                                                                                                                                                        
|(B)
    Are prepared within 30 calendar days after the bank 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.

AAEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v),
1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable
to the activities AEGON performs with respect to the Platform.



BThis servicing activity was not performed during the Reporting Period as there were no loans serviced on the Platform that
would trigger the applicability of this criteria.



CThis servicing activity was not performed during the Reporting Period as there was no activity for serviced loans on the
Platform that would trigger performance of this activity.











AEGON(logo)



Appendix
A (cont.)



|                                                                                                                                                        | SERVICING
    CRITERIA                                                                                                                                                                                          | APPLICABLE
    SERVICINGCRITERIA
|------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------
|Reference                                                                                                                                               | Criteria                                                                                                                                                                                                        | Performed
    Directly byAEGON  
|                                                                                                                                                        | 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;                                             | X                                                                                                                                                                                                              
|(B)
    Provide information calculated in accordance with the terms specified in the transaction agreements;                                            | XB                                                                                                                                                                                                             
|(C)
    Are filed with the Commission as required by its rules and regulations; and                                                                     | XB                                                                                                                                                                                                             
|(D)
    Agree with investor’s or the trustee’s records as to the total unpaid principal balance and number of pool assets
    serviced by the servicer. | XB                                                                                                                                                                                                             
|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.                                       | N/AA                            
|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.                         | N/AA                            
|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.                                                                 | N/AA                            
|                                                                                                                                                        | Pool Asset Administration                                                                                                                                                                                       |                                 
|1122(d)(4)(i)                                                                                                                                           | Collateral
    or security on pool assets is maintained as required by the transaction agreements or related mortgage loan documents.                                                                           | XC                              
|1122(d)(4)(ii)                                                                                                                                          | Pool
    assets and related documents are safeguarded as required by the transaction agreements.                                                                                                                | XB                              
|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.                             | XC                              

AAEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v),
1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable
to the activities AEGON performs with respect to the Platform.



BThis servicing activity was not performed during the Reporting Period as there were no loans serviced on the Platform that
would trigger the applicability of this criteria.



CThis servicing activity was not performed during the Reporting Period as there was no activity for serviced loans on the
Platform that would trigger performance of this activity.











AEGON(logo)



Appendix
A (cont.)



|                              | SERVICING
    CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | APPLICABLESERVICINGCRITERIA   
|----------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ------------------------------
|Reference                     | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Performed
    Directly byAEGON
|Pool
    Asset Administration
|1122(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.                                                                                                       | XB                            
|1122(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.                                                                                                                                                                                                                                                                                                                                                                              | N/AA                          
|1122(d)(4)(vi)                | Changes
    with respect to the terms or status of an obligor’s pool asset (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.                                                                                                                                                                                                                                                                 | XC                            
|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.                                                                                                                                                                                                             | X                             
|1122(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). | XC                            

AAEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v),
1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable
to the activities AEGON performs with respect to the Platform.



BThis servicing activity was not performed during the Reporting Period as there were no loans serviced on the Platform that
would trigger the applicability of this criteria.



CThis servicing activity was not performed during the Reporting Period as there was no activity for serviced loans on the
Platform that would trigger performance of this activity.











AEGON(logo)



Appendix
A (cont.)



|                                                                                                                                                                                              | SERVICING
    CRITERIA                                                                                                                                                                                                                                                                                                                                                                                      | APPLICABLE

    SERVICINGCRITERIA
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------
|Reference                                                                                                                                                                                     | Criteria                                                                                                                                                                                                                                                                                                                                                                                                    | Performed
    Directly byAEGON   
|Pool
    Asset Administration (continued)                                                                                                                                                    
|1122(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.                                                                                                                                                                                                                                                            | N/AA                             
|1122(d)(4)(x)                                                                                                                                                                                 | Regarding
    any funds held in trust for an obligor (such as escrow accounts):                                                                                                                                                                                                                                                                                                                             | N/AA                             
|(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 asset, or such other
    number of days specified in the transaction agreements.
|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. | N/AA                             
|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.                                                                                                                                                                 | N/AA                             
|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.                                                                                                                                                                                           | N/AA                             
|1122(d)(4)(xiv)                                                                                                                                                                               | Delinquencies,
    charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                        | N/AA                             

AAEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v),
1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable
to the activities AEGON performs with respect to the Platform.











AEGON(logo)



Appendix
A (cont.)



|                                          | SERVICING
    CRITERIA                                                                                                                                                                     | APPLICABLESERVICINGCRITERIA   
|----------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ------------------------------
|Reference                                 | Criteria                                                                                                                                                                                   | Performed
    Directly byAEGON
|Pool
    Asset Administration (continued)
|1122(d)(4)(xv)                            | Any
    external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is maintained
    as set forth in the transaction agreements. | N/AA                          

AAEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v),
1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable
to the activities AEGON performs with respect to the Platform.











AEGON(logo)



Appendix
B – Commercial Mortgage Backed Securities Transactions included in AEGON’s Platform



|Master          |                     |                              
|--------------- | ------------------- | -----------------------------
|Servicer        | Deal
    Name       | Loan
    Specific Name       
|Berkadia        | MSC
    2013-ALTM   |                              
|KeyBank         | COMM
    2013-300P  |                              
|                | SHOPS
    2016-CSTL |                              
|                | COMM
    2016-667M  |                              
|                | CSMC
    2017-LSTK  |                              
|                | CSMC
    2017-MOON  |                              
|                | GSMS
    2017-FARM  |                              
|                | BX
    2018-BIOA    |                              
|                | DBGS
    2018-BIOD  |                              
|                | JPMCC
    2018-AON  |                              
|                | CGDBB
    2017-BIOC |                              
|                | BX
    2019-RP      |                              
|                | COMM
    2016-GCT   |                              
|                | SGCMS
    2019-PREZ |                              
|                | BX
    2019-XL      |                              
|Midland         | PRMA
    CDO-III    |                              
|                | PRMA
    CDO-IV     |                              
|                | BACM
    2015-UBS7  | 200
    Helen St             
|                | CSAIL
    2015-C3   | Charles
    River Plaza North
|                | GSMS
    2017-485L  |                              
|                | CGCMT
    2018-TBR  |                              
|                | UBSCM
    2018-C9   | DreamWorks
    Headquarters  
|                | IPT
    2018-INDP   |                              
|                | BAMLL
    2018-PARK |                              
|                | BAMLL
    2019-BPR  |                              
|USBank          | PRMA
    CDO-VI     |                              
|Wells
    Fargo | GSMS
    2017-375H  |                              
|                | UBSCM
    2017-C4   | Fairmount
    at Brewerytown 
|                | BAMLL
    2013-WBRK |                              
|                | WFLD
    2014-MONT  |                              
|                | BAMLL
    2015-200P |                              
|                | BAMLL
    2015-HAUL |                              
|                | BAMLL
    2015-ASTR |                              
|                | BAMLL
    2016-SS1  |                              
|                | BAMLL
    2016-ISQ  |                              
|                | BBCMS
    2016-ETC  |                              
|                | HY
    2016-10HY    |                              
|                | CFCRE
    2016-C6   | Potomac
    Mills            











AEGON(logo)



| | DBWF
    2016-85T   |                                            
| | ------------------- | -------------------------------------------
| | PRKAV
    2017-245P |                                            
| | BXP
    2017-GM     |                                            
| | IMTT
    2017-APTS  |                                            
| | MAD
    2017-330M   |                                            
| | BXP
    2017-CC     |                                            
| | DBUBS
    2017-BRBK |                                            
| | WFCM
    2017-HSDB  |                                            
| | BAMLL
    2017-SCH  | The
    Sheraton Grand Chicago - Leased Fee
| | WFCM
    2017-SMP   |                                            
| | NCMS
    2018-ALXA  |                                            
| | DBWF
    2018-AMXP  |                                            
| | BANK
    2018-BN12  | Fair
    Oaks Mall                         
| | COMM
    2018-HOME  |                                            
| | WFCM
    2018-1745  |                                            
| | NCMS
    2018-FL1   |                                            
| | WFCM
    2018-AUS   |                                            
| | BX
    2018-EXCL    |                                            
| | BX
    2018-IND     |                                            
| | SGCMS
    2019-787E |                                            
| | JAX
    2019-LIC    |                                            
| | SGCMS
    2020-COVE |                                            











AEGON(logo)



Appendix
C



The
Company has identified an instance of material noncompliance with the following servicing criterion during the Reporting Period
of the Platform:



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.



For
the only active special serviced deal during the reporting period subject to Item 1122(d)(3)(i)(A), the report to the investors
was not prepared in accordance with the timeframes and other terms set forth in the transaction agreements for the period of January
1, 2021 to January, 21, 2021.