**Certification Regarding Compliance with ApplicableServicing Criteria**

** **

**To PricewaterhouseCoopers LLP**

 

1. Prudential Asset Resources, Inc. (the "Servicer")is responsible for assessing compliance by it with the servicing criteriaapplicable to it under paragraph (d) of Item 1122 of Regulation AB (the"Servicing Criteria"), as of and for the year ended December 31,2016, as set forth in Exhibit A hereto in connection withcommercial mortgage securities transactions for the-mortgage loansecuritizations listed in Exhibit C;

 

2. Except as set forth in paragraph 3 below, the Servicerused the criteria set forth in paragraph (d) of Item 1122 of Regulation AB toassess the compliance with the Servicing Criteria;

 

3. The criteria described as not applicable on ExhibitA hereto are inapplicable to the Servicer based on the activities itperforms with respect to commercial mortgage securities transactions involvingmortgage loans, also the Servicer has identified specific servicing criteriafor which no transaction activity occurred;

 

4. The Servicer has engaged certain vendors, which are notdeemed to be servicers as defined in Item 1101(j) of Regulation AB (the"Vendors"), to perform specific and limited activities or activitiesscripted by the Servicer as of and during the Reporting Period, and theServicer elects to take responsibility for assessing compliance with theServicing Criteria or portion of the Servicing Criteria applicable to suchVendors as set forth in Exhibit A hereto (such criteria, the "ApplicableServicing Criteria Performed by Vendor(s)").

 

The Servicer has policies and procedures in place designedto provide reasonable assurance that the Vendor's activities comply in allmaterial respects for purposes of Regulation AB with the Applicable VendorServicing Criteria. The Servicer (i) has not identified and is not aware of anymaterial instance of noncompliance by the Vendors with the Applicable VendorServicing Criteria that would affect the Servicer's compliance and (ii) has notidentified any material deficiency in its policies and procedures to monitorthe compliance by the Vendor with the Applicable Servicing Criteria Performedby Vendor(s) as of December 31, 2016 and for the Reporting Period.

 

5. The Servicer has complied, in all material respects, withthe Servicing Criteria as of and for the year ending December 31, 2016; and

 

6. PricewaterhouseCoopers LLP has issued an attestationreport with respect to the Servicer's assessment of compliance with theServicing Criteria as of and for the year ended December 31, 2016, whichattestation report is included in Exhibit B attached hereto.This Certification is being provided to PricewaterhouseCoopers LLP infulfillment of its requirement for issuance of the final report.

 

February 22, 2017

 

Prudential Asset Resources, Inc.

 

/s/ Timothy E. Steward

Timothy E. Steward, President

 

/s/ Lukshmi A. Subendranathan

Lukshmi A. Subendranathan, Vice President

 

 

**EXHIBIT A**

 

| **SERVICING CRITERIA**

**Reg AB Portfolio** | **APPLICABLE SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | **INAPPLICABLE SERVICING CRITERIA** |                             |
|---------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|----------------------------------|
|  

 

Reference                         |  

 

Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Performed by Servicer     | Performed by Vendor(s) |   |   |
| **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y                                   |                             |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                   |                             |   |   |
| 1122(d)(1)(iii)                                   | Any requirements in the transaction agreements to maintain  a back-up servicer for the mortgage loans are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                |                             | N/A |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Y#1                                 |                             |   |   |
| 1122(d)(1)(v)                                     | Aggregation of information, as applicable,  is mathematically accurate and the information conveyed accurately  reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                   |                             |   |   |
| **Cash Collection and Administration**            |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |
| 1122(d)(2)(i)                                     | Payments on mortgage loans 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                   |                             |   |   |
| 1122(d)(2)(ii)                                    | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                   | Y#2                              |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Y                                   |                             |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                   |                             |   |   |
| 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-l(b)(l)  of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                                                                         | Y                                   |                             |   |   |
| 1122(d)(2)(vi)                                    | Unissued checks are safeguarded so as to prevent unauthorized  access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                   | Y#2                              |   |   |
| 1122(d)(2)(vii)                                   | Reconciliations are prepared on a monthly basis for all  commercial mortgage 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. Thesereconciling items are resolved  within 90 calendar days of their original identification, or such other  number of days specified in the transaction agreements. | Y                                   | Y#3                              |   |   |
| **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 mortgage loans serviced by the Servicer.                                                                                | Y for (A&B)                     |                             | N/A for (C&D) |   |
| 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/A |   |
| 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/A |   |
| 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/A |   |
| **Pool Asset Administration**                     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |
| 1122(d)(4)(i)                                     | Collateral or security on mortgage loans is maintained as  required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Y                                   |                             |   |   |
| 1122(d)(4)(ii)                                    | Mortgage loan and related documents are safeguarded as required  by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Y#4                                 |                             |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Y#5                                 |                             |   |   |
| 1122(d)(4)(iv)                                    | Payments on mortgage loans, including any payoffs, made in  accordance with the related mortgage loan 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   mortgage  loan documents.                                                                                                                                                                                                                                                                                            | Y                                   |                             |   |   |
| 1122(d)(4)(v)                                     | The Servicer's records regarding the mortgage loans agree  with the Servicer's records with respect to an obligor's unpaid principal  balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Y                                   |                             |   |   |
| 1122(d)(4)(vi)                                    | Changes with respect to the terms or status of an obligor's  mortgage loans (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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Y                                   |                             |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y#6                                 |                             |   |
| 1122(d)(4)(viii)                                  | Records documenting collection efforts are maintained  during the period a mortgage loan 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 mortgage loans including, for  example, phone calls, letters and payment rescheduling plans in cases where  delinquency is deemed temporary (e.g., illness or unemployment).                                                                                                                                                                                                                                       | Y                                   |                             |   |
| 1122(d)(4)(ix)                                    | Adjustments to interest rates or rates of return for mortgage  loans with variable rates are computed based on the related mortgage loan  documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Y                                   |                             |   |
| 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 mortgage loan 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 mortgage loan  documents and state laws; and (C) such funds are returned to the obligor  within 30 calendar days of full repayment of the related mortgage loans, or  such other number of days specified in the transaction agreements.                                                                                                                                                      | Y                                   |                             |   |
| 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.                                                                                                                                                                                                                                                                                                                                                             | Y                                   | Y#2                              |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                   | Y#2                              |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Y                                   |                             |   |
| 1122(d)(4)(xiv)                                   | Delinquencies, charge-offs and uncollectible accounts are  recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Y                                   |                             |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                |                             | N/A |
|                                              |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                |                             |   |   |   |   |   |   |   |

 

**Y**=Yes

 

**Y#l** = Fidelity bond and errors and omissions policiesin force for Prudential. In addition, fidelity bond and errors and omissionspolicies are in force for the following vendors: Silverskills ($1MM),NTS ($2MM) and Covius ($1MM).

 

**Y#2** = The only third party vendor to whomthis applies is National Tax Search, LLC (NTS). PAR transferred to the vendorthe process of paying property taxes to the local government taxingauthorities. Payment is made only after review, authorization and transfer offunds is completed by PAR. Policies and procedures are in place to monitor thisvendor.

 

**Y#3** = Silverskills Private Limited(SPL) performs monthly P&I, Tax & Insurance, Reserve, and Suspenseaccount compilations including review and approval of all selfreconciling bank accounts. PAR has procedures in place to review workperformed by SPL.

 

**Y#4** = As outlined in the PSAs, theprimary responsibility for safeguarding all original documents (except Lettersof Credit, which are held by PAR) is with the named Document Custodian. Thenamed Trustee has oversight responsibility for the custodian, not the Servicer.However, to the extent that loans are secured by Letters of Credit or loans aremodified or some other credit action occurs which generates a new or revisedloan document, then Servicer complies with this criteria.

 

**Y#5** = PAR's role related to additions,removals or substitutions to the asset pool only occurs after a decision ismade to so modify the asset pool.  The responsibility and any decisionsrelated to additions, removals or substitutions to the asset poolis with the Trustee, Issuer and related mortgage loan seller. PAR asServicer has not experienced any of these types of actions in its CMBS assetpools.

 

**Y#6** = There are currently no transactions duringthe year that applied to this servicing criteria within the Reg ABwhere PAR was named the special servicer.

 

**N/A** = Not applicable, as the criteria is not theresponsibility of the primary/master servicer or no event has occurred whichtriggered an action by the primary/master servicer.

 

 

**EXHIBIT C**

 

**List of Commercial Mortgage-Backed Security Transactions- RegAB Portfolio**

 

 

1. Morgan Stanley Capital I Inc., Commercial MortgagePass-Through Certificates, Series 2006-IQ12 ("MSCI 2006-IQ12")

 

2. Merrill Lynch Mortgage Trust 2006-C2, Commercial MortgagePass-Through Certificates, Series 2006-C2 ("MLMT 2006-C2")

 

3. Bear Steams Commercial Mortgage Securities II Inc.,Commercial Mortgage Pass-Through Certificates, 2006-PWR11("BSCMS 2006-PWR11")

 

4. Bear Steams Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, 2006-PWR12("BSCMS 2006-PWR12")

 

5. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, 2006-PWR 13("BSCMS 2006-PWR13")

 

6. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, 2006-PWR14("BSCMS 2006-PWR14")

 

7. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, 2007-PWR15("BSCMS 2007-PWR15")

 

8. Morgan Stanley Capital I Inc., Commercial MortgagePass-Through Certificates, Series 2007-IQ14 ("MSCI 2007-IQ14")

 

9. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, 2007-PWR16("BSCMS 2007-PWR16")

 

10. Morgan Stanley Capital I Inc., Commercial MortgagePass-Through Certificates, 2007-IQ15 ("MSCI 2007-IQ15")

 

11. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, 2007-PWR17("BSCMS 2007-PWR17")

 

12. Bear Stearns Commercial Mortgage Securities Inc.,Commercial Mortgage Pass-Through Certificates, 2007-PWR18("BSCMS 2007-PWR18")

 

13. WFRBS Commercial Mortgage Trust 2012-C6,Commercial Mortgage Pass-Through Certificates, Series 2012-C6

 

14. WFRBS Commercial Mortgage Trust 2012-C7,Commercial Mortgage Pass-Through Certificates, Series 2012-C7

 

15. WFRBS Commercial Mortgage Trust 2012-C8,Commercial Mortgage Pass-Through Certificates, Series 2012-C8

 

16. RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series 2012-C9

 

17. WFRBS Commercial Mortgage Trust 2012-C10,Commercial Mortgage Pass-Through Certificates, Series 2012-C10

 

18. RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series 2013- C11

 

19. WFRBS Commercial Mortgage Trust 2013-C12,Commercial Mortgage Pass-Through Certificates, Series 2013-C12

 

20. WFRBS Commercial Mortgage Trust 2013-C13,Commercial Mortgage Pass-Through Certificates, Series 2013-C13

 

21. WFRBS Commercial Mortgage Trust 2013-C14,Commercial Mortgage Pass-Through Certificates, Series 2013-C14

 

22. RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series 2013- C15

 

23. WFRBS Commercial Mortgage Trust 2013-C16,Commercial Mortgage Pass-Through Certificates, Series 2013-C16

 

24. WFRBS Commercial Mortgage Trust 2013-C17,Commercial Mortgage Pass-Through Certificates, Series 2013-C17

 

25. WFRBS Commercial Mortgage Trust 2013-C18,Commercial Mortgage Pass-Through Certificates, Series 2013-C18

 

26. COMM 2013-CCRE13 Mortgage Trust Commercial MortgagePass-Through Certificates

 

27. COMM 2014-CCRE14 Mortgage Trust Commercial MortgagePass-Through Certificates

 

28. RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series 2014- C19

 

29. WFRBS Commercial Mortgage Trust 2014- C20,Commercial Mortgage Pass-Through Certificates, Series 2014-C20

 

30. RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series 2014- C21

 

31. WFRBS Commercial Mortgage Trust 2014-C22,Commercial Mortgage Pass-Through Certificates, Series 2014-C22

 

32. RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series 2014- C23

 

33. WFRBS Commercial Mortgage Trust 2014-C24,Commercial Mortgage Pass-Through Certificates, Series 2014-C24

 

34. Wells Fargo Commercial Mortgage Trust 2014-LC18,Commercial Mortgage Pass-Through Certificates, Series 2014-LC18

 

35. RBS Commercial Funding Inc., CommercialMortgage Pass-Through Certificates, Series 2014- C25

 

36. Wells Fargo Commercial Mortgage Trust 2015-C26,Commercial Mortgage Pass-Through Certificates, Series 2015-C26

 

37. Wells Fargo Commercial Mortgage Trust 2015-C27,Commercial Mortgage Pass-Through Certificates, Series 2015-C27

 

38. Wells Fargo Commercial Mortgage Trust 2015-C28,Commercial Mortgage Pass-Through Certificates, Series 2015-C28

 

39. Wells Fargo Commercial Mortgage Trust 2015-SG1,Commercial Mortgage Pass-Through Certificates, Series 2015-SG1

 

40. Wells Fargo Commercial Mortgage Trust 2015-C31,Commercial Mortgage Pass-Through Certificates, Series 2015-C31

 

41. CFCRE 2016-C3 Mortgage Trust, CommercialMortgage Pass-Through Certificates, Series 2016-C3

 

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