**Management’s Assertion on Compliance with Applicable**

**Regulation AB Servicing Criteria**

** **

 

1. Rialto Capital Advisors, LLC (“Rialto”), the SpecialServicer in the agreements listed on Exhibit 1 (the “Pooling and ServicingAgreements”), is responsible for assessing compliance with the servicingcriteria applicable to it under paragraph (d) of Item 1122 of Regulation AB,for the period from January 1, 2016, up to and including December 31, 2016, orapplicable shorter period there within, (the “Reporting Period”), as set forthin Appendix A hereto.  The transactions covered by this report include thetransactions listed on Exhibit 1 that are commercial mortgage-asset backedsecurities transactions for which Rialto acted as Special Servicer on or afterJanuary 1, 2016, or for the Applicable Certification Period as listed onExhibit 1 (the "Platform"), and were registered after January 1,2006, with the Securities and Exchange Commission pursuant to the SecuritiesAct of 1933.

 

2. Rialto has engaged certain vendors (the “Vendors”) toperform specific, limited, or scripted activities, and Rialto elects to takeresponsibility for assessing compliance with the servicing criteria, or portionof the servicing criteria, applicable to such Vendors’ activities as set forthin Appendix A hereto. Rialto has determined  its Vendors are not“servicers” as defined in Item 1101 (j) of Regulation AB and asserts that ithas policies and procedures in place to provide reasonable assurance that theVendors’ activities comply, in all material respects, with the servicingcriteria applicable to each vendor;

 

3. Except as set forth in paragraph 4 below, Rialto used thecriteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess thecompliance with the applicable servicing criteria;

 

4. The criteria listed in the column titled “InapplicableServicing Criteria” on Appendix A hereto are inapplicable to Rialto based onthe activities it performs, directly or through its Vendors, with respect tothe Platform;

 

5. Rialto has complied, in all material respects, with theapplicable servicing criteria as of December 31, 2016, and for the ReportingPeriod with respect to the Platform taken as a whole.

 

6. Rialto has not identified and is not aware of anymaterial instance of noncompliance by the Vendors with the applicable servicingcriteria as of December 31, 2016, and for the Reporting Period with respect tothe Platform taken as a whole;

 

7. Rialto has not identified any material deficiency in itspolicies and procedures to monitor the compliance by the Vendors with theapplicable servicing criteria as of December 31, 2016, and for the ReportingPeriod with respect to the Platform taken as a whole; and

 

8. NDB Accountants & Consultants, LLP, a registeredpublic accounting firm, has issued an attestation report on Rialto’s assessmentof compliance with the applicable servicing criteria for the Reporting Period.

 

 

Date: March 1, 2017

Name: Adam Singer

Title: Managing Director

 

Signature: /s/ Adam Singer

 

 

**Exhibit 1**

 

| **Pooling and Servicing Agreements**                                                  | **Applicable Certification Period**     |
|---------------------------------------------------------------------------------------|-----------------------------------------|
| WFRBS 2012-C8                                                                         | January 1, 2016 to December 31, 2016    |
| FDIC 2012-C1                                                                          | January 1, 2016 to December 31, 2016    |
| WFCM 2012-LC5                                                                         | January 1, 2016 to December 31, 2016    |
| UBS-Barclays 2012-C3                                                                  | January 1, 2016 to December 31, 2016    |
| UBS-Barclays 2012-C4                                                                  | January 1, 2016 to December 31, 2016    |
| GSMS 2012-GCJ9                                                                        | January 1, 2016 to December 31, 2016    |
| JPMCC 2012-LC9                                                                        | January 1, 2016 to December 31, 2016    |
| COMM 2013-LC6                                                                         | January 1, 2016 to December 31, 2016    |
| WFRBS 2013-C12                                                                        | January 1, 2016 to December 31, 2016    |
| UBS-Barclays 2013-C6                                                                  | January 1, 2016 to December 31, 2016    |
| GSMS 2013-GCJ12                                                                       | January 1, 2016 to December 31, 2016    |
| WFRBS 2013-C14                                                                        | January 1, 2016 to December 31, 2016    |
| WFRBS 2011-C5                                                                         | January 1, 2016 to December 31, 2016    |
| WFCM 2013-LC12                                                                        | January 1, 2016 to December 31, 2016    |
| WFRBS 2011-C2                                                                         | January 1, 2016 to December 31, 2016    |
| WFRBS 2011-C3                                                                         | January 1, 2016 to December 31, 2016    |
| WFRBS 2011-C4                                                                         | January 1, 2016 to December 31, 2016    |
| UBS-Citigroup 2011-C1                                                                 | January 1, 2016 to December 31, 2016    |
| UBS 2012-C1                                                                           | January 1, 2016 to December 31, 2016    |
| WFRBS 2012-C6                                                                         | January 1, 2016 to December 31, 2016    |
| GSMS 2011-GC3                                                                         | January 1, 2016 to December 31, 2016    |
| COMM 2013-LC13                                                                        | January 1, 2016 to December 31, 2016    |
| WFRBS 2013-C16                                                                        | January 1, 2016 to December 31, 2016    |
| GSMS 2013-GCJ16                                                                       | January 1, 2016 to December 31, 2016    |
| WFRBS 2013-C17                                                                        | January 1, 2016 to December 31, 2016    |
| GSMS 2012-GC6                                                                         | January 1, 2016 to December 31, 2016    |
| MSBAM 2013-C13                                                                        | January 1, 2016 to December 31, 2016    |
| COMM 2014-CCRE14                                                                      | January 1, 2016 to December 31, 2016    |
| MSBAM 2014-C14                                                                        | January 1, 2016 to December 31, 2016    |
| WFRBS 2014-LC14                                                                       | January 1, 2016 to December 31, 2016    |
| COMM 2014-LC15                                                                        | January 1, 2016 to December 31, 2016    |
| WFRBS 2014-C20                                                                        | January 1, 2016 to December 31, 2016    |
| COMM 2014-CCRE18                                                                      | January 1, 2016 to December 31, 2016    |
| CGCMT 2014-GC23                                                                       | January 1 , 2016 to December 31, 2016   |
| MSBAM 2014-C17                                                                        | January 1, 2016 to December 31, 2016    |
| COMM 2014-UBS5                                                                        | January 1, 2016 to December 31, 2016    |
| MSBAM 2014-C18                                                                        | January 1, 2016 to December 31, 2016    |
| COMM 2012-CCRE4                                                                       | January 1, 2016 to December 31, 2016    |
| COMM 2012-LC4*                                                                        | January 1, 2016 to December 31, 2016    |
| WFRBS 2014-C24                                                                        | January 1, 2016 to December 31, 2016    |
| JPMBB 2014-C25                                                                        | January 1, 2016 to December 31, 2016    |
| LCCM 2014-909                                                                         | January 1, 2016 to December 31, 2016    |
| MLMI 1998-C3                                                                          | January 1, 2016 to December 31, 2016    |
| WFCM 2014-LC18                                                                        | January 1, 2016 to December 31, 2016    |
| COMM 2015-DC1                                                                         | January 1, 2016 to December 31, 2016    |
| GSMS 2015-GC28                                                                        | January 1, 2016 to December 31, 2016    |
| WFCM 2015-C27                                                                         | January 1, 2016 to December 31, 2016    |
| WFCM 2015-LC20                                                                        | January 1, 2016 to December 31, 2016    |
| WFCM 2015-NXS1                                                                        | January 1, 2016 to December 31, 2016    |
| CSAIL 2015-C2                                                                         | January 1, 2016 to December 31, 2016    |
| WFCM 2015-NXS2                                                                        | January 1, 2016 to December 31, 2016    |
| COMM 2015-PC1                                                                         | January 1, 2016 to December 31, 2016    |
| CSAIL 2015-C3                                                                         | January 1, 2016 to December 31, 2016    |
| WFCM 2015-SG1                                                                         | January 1, 2016 to December 31, 2016    |
| WFCM 2015-LC22                                                                        | January 1, 2016 to December 31, 2016    |
| COMM 2015-CCRE27                                                                      | January 1, 2016 to December 31, 2016    |
| WFCM 2015-NXS4                                                                        | January 1, 2016 to December 31, 2016    |
| MSCI 2015-UBS8                                                                        | January 1, 2016 to December 31, 2016    |
| CSAIL 2016-C5                                                                         | February 9, 2016 to December 31, 2016   |
| WFCM 2016-C32                                                                         | February 18, 2016 to December 31, 2016  |
| WFCM 2016-NXS5                                                                        | February 26, 2016 to December 31, 2016  |
| CGCMT 2015-GC27 (Special Servicer solely for the Boca  Hamptons Plaza Portfolio Loan) | January 1, 2016 to December 31, 2016    |
| WFCM 2016-C33                                                                         | March 31, 2016 to December 31, 2016     |
| MSBAM 2016-C29                                                                        | May 5, 2016 to December 31, 2016        |
| CFCRE 2016-C4                                                                         | May 18, 2016 to December 31, 2016       |
| GSMS 2016-GS2 (Special Servicer solely for the Veritas  Multifamily Pool 2 only)      | May 31, 2016 to December 31, 2016       |
| BACM 2016-UBS10                                                                       | June 7, 2016 to December 31, 2016       |
| SGCMS 2016-C5                                                                         | July 19, 2016 to December 31, 2016      |
| WFCM 2016-BNK1                                                                        | August 18, 2016 to December 31, 2016    |
| CD 2016-CD1                                                                           | August 25, 2016 to December 31, 2016    |
| GSMS 2016-GS3                                                                         | September 30, 2016 to December 31, 2016 |
| MSBAM 2016-C31                                                                        | November 14, 2016 to December 31, 2016  |
| CGCMT 2016-C3                                                                         | November 17, 2016 to December 31, 2016  |
| CFCRE 2016-C6                                                                         | November 22, 2016 to December 31, 2016  |
| CSAIL 2016-C7                                                                         | November 22, 2016 to December 31, 2016  |
| MSC 2016-UBS12                                                                        | December 7, 2016 to December 31, 2016   |

 

*Supplemental clarification regarding COMM2012-LC4:

 

By trustee's notification, dated September 13, 2016, Rialtowas advised of its termination as special servicer of the COMM 2012-LC4 pooland of the appointment of KeyBank, National Association ("KeyBank")as replacement special servicer, which termination and replacement appointmentwas indicated as being effective as of September 12, 2016.  On February 9,2017, Rialto was advised that various notices and certain other requirementsunder the Pooling and Servicing Agreement had not been properly delivered bythe Directing Holder, KeyBank and certain other parties unrelated toRialto.  Accordingly, the information provided in this certificationreflects the foregoing by including the COMM 2012-LC4 as a pool serviced byRialto through December 31, 2016.  KeyBank has advised Rialto that theonly action taken by it as purported Special Servicer of the pool for theperiod September 12, 2016 through December 31, 2016 was a consent to a leaseamendment respecting a J.C. Penney Lease relating to the Plaza de Sol Loan andthat no Servicing Transfer Events occurred during said period.  Rialto hasbeen provided with and has reviewed the relevant materials applicable to suchlease amendment consent and has concurred in the consent action taken byKeyBank.

 

 

APPENDIX A

 

| **SERVICING CRITERIA** | ** **                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **                                                        |
|------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------|
| **Reference**          | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **Performed by Servicer**                                         | **Inapplicable    Servicing Criteria** |   |
|                   | **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | ** **

**X**                                                 | ** ** |   |
| 1122(d)(1)(iii)        | Any requirements in the transaction agreements to maintain  a back-up servicer for the [pool assets] are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **                                                        | **X** |   |
| 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 of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**

** **                                     | ** ** |   |
| 1122(d)(i)(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                            | **X1**

** **                                                | ** ** |   |
| 1122(d)(2)(ii)         | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | **X**

** **                                                 | ** ** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X**

** **                                                 | ** ** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **X**                                                             | ** ** |   |
| 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.                                                                                                                                                                                                                                                                                                              | **X**                                                             | ** ** |   |
| 1122(d)(2)(vi)         | Unissued checks are safeguarded so as to prevent  unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | **X2**                                                            | ** ** |   |
| 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 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** | ** ** |   |
|                   | **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; (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.                                 | **X3**                                                            | ** ** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **                                                        | **X** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | ** **                                                        | **X** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **                                                        | **X** |   |
|                   | **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | **X**                                                             | ** ** |   |
| 1122(d)(4)(ii)         | [pool asset] and related documents are safeguarded as  required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | **X**                                                             | ** ** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | **X**                                                             | ** ** |   |
| 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.                                                                                                                                                                                                                                                                                 | ** **                                                        | **X4** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **                                                        | **X** |   |
| 1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X**                                                             | ** ** |   |
| 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).                                                                                                                                                                               | ** **

** **

** **

** **

**X**             | ** ** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **                                                        | **X** |   |
| 1122(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** |   |
| 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.                                                                                                                                                                                                                                                                                                          | ** **                                                        | **X** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **                                                        | **X** |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | ** **                                                        | **X** |   |
| 1122(d)(4)(xiv)        | Delinquencies, charge-offs and uncollectible accounts are  recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

** **                                                | **X5**

** ** |   |
| 1122(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** |   |
|                   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                              |   |   |   |

 

1) Rialto Capital Advisors, LLC performs the activitiespertaining to these criteria, except for specific, limited activities performedby its third party property managers relating to REO Property, if any. Rialto has elected to take responsibility for assessing compliance with theseservicing criteria with respect to the activities of its third party propertymanagers.

 

2) Payment activities are processed by Rialto’s AccountsPayable department, however, unissued check stocks are controlled andphysically maintained at a different location (the parent/affiliate company,Lennar) and are not accessible to Rialto personnel.  Although this criteria isaddressed by a parent/affiliate organization, Rialto has acceptedresponsibility for this criteria.

 

3) Only items (A) and (B) of the Servicing Criteria areapplicable to Rialto Capital Advisors, LLC as special servicer.  Items (C)and (D) are inapplicable as the responsibility for filing reports with theCommission and agreeing totals to the Servicer records rests with the Trusteeand/or Certificate Administrator, as applicable.

 

4) Primary responsibility for processing borrower paymentsrests with the Master Servicer, however, Rialto Capital Advisors, LLC may fromtime to time receive payments on an exception basis which are forwarded to theMaster Servicer in accordance with such criterion.

 

5) Rialto Capital Advisors, LLC provides the applicableMaster Servicer relating to each deal with the final recovery determination anddata utilized to complete IRS Form 1099C on loans with charge-offs, however,the ultimate responsibility for adjusting the loan record, reporting to theIRS, and delivering 1099C Forms to the borrower rests with the Master Servicer.

 

 

**Management’s Assertion on Compliance**