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Reportof Independent Registered Public Accounting Firm

 

 

BerkeleyPoint Capital LLC

 

Wehave examined management’s assertion, included in the accompanying Management’sAssessment of Compliance with Applicable Servicing Criteria Pursuant to Item1122 of Regulation AB, that Berkeley Point Capital LLC (the “Company”) compliedwith the servicing criteria set forth in Item 1122 (d) of the Securities andExchange Commission’s Regulation AB for the commercial mortgage-backedsecurities transactions platform as of and for the year ended December 31,2021, except for Items 1122(d)(1)(iii), 1122(d)(2)(ii), 1122(d)(2)(iii),1122(d)(3)(i), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(ii),1122(d)(4)(vii), 1122(d)(4)(xv), which the Company has determined are notapplicable to the activities performed by  them with respect to the servicingplatform covered by this report. Refer to Appendix A of Management’s Assessmentof Compliance with Applicable Servicing Criteria Pursuant to Item 1122 ofRegulation AB for the asset backed transactions covered by this platform.Management is responsible for the Company’s compliance with those servicingcriteria. Our responsibility is to express an opinion on management’s assertionabout the Company’s compliance with the servicing criteria based on ourexamination.

 

Ourexamination was conducted in accordance with attestation standards establishedby the American Institute of Certified Public Accountants and the PublicCompany Accounting Oversight Board (United States) and, accordingly, includedexamining, on a test basis, evidence about the Company’s compliance with theapplicable servicing criteria and performing such other procedures as weconsidered necessary in the circumstances.  Our examination includedtesting of less than all of the individual asset backed transactions andsecurities that comprise the platform, testing of less than all of theservicing activities related to the Platform and determining whether theCompany processed those selected transactions and performed those selectedactivities in compliance with the servicing criteria and as permitted byRegulation AB Compliance and Disclosure Interpretations of the Division ofCorporation Finance, Section 200.06, “Vendors Engaged by Servicers” (C&DI200.06).  Furthermore, our procedures were limited to the selectedtransactions and servicing activities performed by the Company during theperiod covered by this report. Our procedures were not designed to determinewhether errors may have occurred either prior to or subsequent to our teststhat may have affected the balances or amounts calculated or reported by theCompany during the period covered by this report for the selected transactionsor any other transactions. Although the Company is responsible for assessingcompliance with items 1122(d)(4)(iii), 1122(d)(4)(vi), 1122(d)(4)(ix) and1122(d)(4)(xiv) of Regulation AB, there were no servicing activities performedby the Company during the year ended December 31, 2021 that required theseservicing criteria to be complied with. We believe that the evidence weobtained is sufficient and appropriate to provide a reasonable basis for ouropinion.

 

Ourexamination does not provide a legal determination on the Company’s compliancewith the servicing criteria.

 

Asdescribed in management’s assertion, for servicing criteria 1122(d)(1)(v),1122(d)(2)(vi) and 1122(d)(2)(vii), the Company has engaged a vendor to performthe activities required by these servicing criteria. The Company has determinedthat this vendor is not considered a “servicer” as defined in Item 1101(j) ofRegulation AB, and the Company has elected to take responsibility for assessingcompliance with the applicable servicing criteria applicable to this vendor aspermitted by C&DI 200.06. As permitted by C&DI 200.06, the Company hasasserted that it has policies and procedures in place designed to providereasonable assurance that the vendor’s activities comply in all materialrespects with servicing criteria applicable to this vendor.  The Companyis solely responsible for determining that it meets the SEC requirements toapply C&DI 200.06 for the vendor and related criteria as described in itsassertion, and we performed no procedures with respect to the Company’seligibility to apply C&DI 200.06.

 

Inour opinion, management’s assertion that the Company complied with theservicing criteria set forth in Item 1122 (d) of the Securities and ExchangeCommission’s Regulation AB, 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 200.06as described above, as of and for the year ended December 31, 2021 for thecommercial mortgage-backed securities transactions platform, is fairly stated,in all material respects.

 

 

/s/Ernst & Young LLP

February22, 2022

 

 

Amember firm of Ernst & Young Global Limited