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#  

# **AEGON USA RealtyAdvisors, LLC**

## 6300 C Street SW

## Cedar Rapids, Iowa52499 

 

 

February 28, 2019

 

**Officer’s Certificate**

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

** **

1.     AEGON is responsible for assessing itscompliance with the servicing criteria applicable to it under paragraph (d) ofItem 1122 of Regulation AB, as of and for the 12-month period ending December31, 2018 (the “Reporting Period”) as noted on the accompanying Appendix A;

 

2.     Except as set forth in paragraph 3 below, AEGONused the criteria set forth in paragraph (d) of Item 1122 of Regulation AB toassess its compliance with the applicable servicing criteria;

 

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

 

4.     AEGON has complied, in all material respects,with the applicable servicing criteria as of and for the Reporting Period withrespect to the Platform taken as a whole;

 

5.     PricewaterhouseCoopers LLP, a registered publicaccounting firm, has issued an attestation report on AEGON’s assessment ofcompliance with the applicable servicing criteria for the Reporting period.

 

AEGON USA Realty Advisors, LLC (“AEGON”) as specialservicer for the commercial mortgage backed securities transactions:

 

•   LB-UBS Commercial Mortgage Trust 2004-C8

•  WFLD 2014-MONTMortgage Trust Commercial MortgagePass-Through Certificates Series 2014 – MONT

•  COMM 2013-300PMortgage Trust, Commercial MortgagePass-Through Certificates

•  BAMLLCommercial Mortgage Securities Trust 2013-WBRK,Commercial Mortgage Pass-Through Certificates, Series 2013-WBRK

•  Morgan StanleyCapital I Trust 2013-WLSR CommercialMortgage Pass-Through Certificates, Series 2013-WLSR

•  Four TimesSquare Trust, Commercial MortgagePass-Through Certificates, Series 2006-4 TS

•   CSMC Trust2015-GLPA

•   CSMC Trust2015-GLPB

•   GS MortgageSecurities Corporation Trust 2015-590M

•   BAMLLCommercial Mortgage Securities Trust 2015-ASTR

•   BAMLLCommercial Mortgage Securities Trust 2015-HAUL

•   BAMLLCommercial Mortgage Securities Trust 2015-200P

•   Morgan StanleyCapital I Trust 2013-ALTM Commercial Mortgage Pass-Through Certificates, Series2013-ALTM

•   Hudson Yards2016-10HY Mortgage Trust Commercial Mortgage Pass-Through Certificates

•   BBCMS 2016-ETCMortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2016-ETC

•   CommercialMortgage Pass-Through Certificates, Series 2016-ISQR

•   Shops atCrystals Trust 2016-CSTL Commercial Mortgage Pass-Through Certificates, Series2016-CSTL

•   GS MortgageSecurities Corporation Trust 2016-RENT MZB Commercial Mezzanine Pass-ThroughCertificates, Series 2016-RENT MZB

•   BANK OF AMERICAMERRILL LYNCH COMMERCIAL MORTGAGE TRUST 2015-UBS7, COMMERCIAL MORTGAGEPASS-THROUGH CERTIFICATES SERIES 2015-UBS7BACM15U7

•   BAMLLCommercial Mortgage Securities Trust 2016-SS1

•   Credit SuisseFirst Boston Mortgage Securities Corp., Commercial Mortgage Pass-ThroughCertificates, Series 2015-C3 (Charles River)

•   COMM 2016-667MMortgage Trust

•   CSMC Trust2016-MFF

•   CFCRE 2016-C6Mortgage Trust (Potomac Mills)

•   GS MortgageSecurities Trust 2016-GS4 (225 Bush Street)

•   Hilton USATrust 2016-HHV

•   VNDO Trust2016-350P

•   DBWF 2016-85TMortgage Trust

•   GS MortgageSecurities Corporation Trust 2017-485L

•   CSMC Trust2017-HD

•   CSMC Trust2017-LSTK

•   245 Park AvenueTrust 2017-245P

•   UBS CommercialMortgage Trust 2017-C1

•   BXP Trust2017-GM

•   HMH Trust2017-NSS

•   IMT Trust2017-APTS

•   CSMC 2017-MOON

•   J.P. MorganChase Commercial Mortgage Securities Trust 2017-MAUI

•   MAD MortgageTrust 2017-330M

•   CGDBBCommercial Mortgage Trust 2017-BIOC

•   BXP Trust2017-CC

•   BBCMS 2017-DELCMortgage Trust

•   GS Mortgage SecuritiesCorporation Trust 2017-375H

•   COMM 2017-DLTAMortgage Trust

•   Great WolfTrust 2017-WOLF

•   UBS CommercialMortgage Trust 2017-C4

•   DBUBS 2017-BRBKMortgage Trust

•   BX Trust2017-CQHP

•   BAMLL CommercialMortgage Securities Trust 2017-SCH

•   GS MortgageSecurities Corporation Trust 2017-FARM

•   Wells FargoCommercial Mortgage Trust 2017-SMP

•   Wells FargoCommercial Mortgage Trust 2017-HSDB

•   Wells FargoCommercial Mortgage Trust 2018-BXI, Commercial Mortgage Pass-ThroughCertificates, Series 2018-BXI

•   CitigroupCommercial Mortgage Trust 2018-TBR, Commercial Mortgage Pass ThroughCertificates, Series 2018-TBR

•   NatixisCommercial Mortgage Securities Trust 2018-ALXA, Commercial MortgagePass-Through Certificates, Series 2018-ALXA

•   UBSCM 2018-NYCHMortgage Trust Commercial Mortgage Pass-Through Certificates

•   BX CommercialMortgage Trust 2018-BIOA, Commercial Mortgage Pass-Through Certificates, Series2018-BIOA

•   CommercialMortgage Pass Through Certificates Series 2018-C9

•   CommercialMortgage Pass-Through Certificates Series 2018-BNK12

•   DBWF 2018-AMXPMortgage Trust Commercial Mortgage Pass-Through Certificates

•   BX Trust2018-GW, Commercial Mortgage Pass-Through Certificates, Series 2018-GW

•   BX Trust2018-BILT, Commercial Mortgage Pass-Through Certificates, Series 2018-BILT

•   COMM 2018-HOMEMortgage Trust Commercial Mortgage Pass-Through Certificates, Series 2018-HOME

•   DBGS 2018-BIODMortgage Trust Commercial Mortgage Pass-Through Certificates

•   IndependencePlaza Trust 2018-INDP Commercial Mortgage Pass-Through Certificates, Series2018-INDP

•   J.P. MorganChase Commercial Mortgage Securities Trust 2018-AON Commercial MortgagePass-Through Certificates, Series 2018-AON

•   CommercialMortgage Pass Through Certificates Series 2018-FL1

•   Wells FargoCommercial Mortgage Trust 2018-1745, Commercial Mortgage Pass-ThroughCertificates, Series 2018-1745

•   Wells FargoCommercial Mortgage Trust 2018-AUS, Commercial Mortgage Pass-ThroughCertificates, Series 2018-AUS

•   Morgan StanleyCapital I Trust 2018-SUN Commercial Mortgage Pass-Through Certificates, Series2018-SUN

•   J.P. MorganChase Commercial Mortgage Securities Trust 2018-PHH, Commercial MortgagePass-Through Certificates, Series 2018-PHH

•   BAMLLCommercial Mortgage Securities Trust 2018-PARK

•   STWD 2018-URBMortgage Trust Commercial Mortgage Pass-Through Certificates, Series 2018-URB

•   BX Trust2018-EXCL, Commercial Mortgage Pass-Through Certificates, Series 2018-EXCL

•   BX CommercialMortgage Trust 2018-IND, Commercial Mortgage Pass Through Certificates, Series2018-IND

 

 

AEGON USA Realty Advisors, LLC

 

/s/ Lara Osterhaus

Lara Osterhaus

Senior Vice President

 

 

 

**Appendix A - Servicing Criteria Applicable to AEGON**

 

|  

**SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                               | **APPLICABLE SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|  

**Reference**                                                                                                                                                                                                                                                                                                                                        |  

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **Performed Directly by**

**AEGON** |
| **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.                                                                                                                                                                                                                                                                                                                                                            | XB |
| 1122(d)(1)(ii)                                                                                                                                                                                                                                                                                                                                               | Ifanymaterialservicingactivitiesareoutsourcedtothird parties, policies and procedures  are instituted tomonitor the  third party's performance and compliance with such servicingactivities.                                                                                                                                                                                                                                                                                                                          | XB |
| 1122(d)(1)(iii)                                                                                                                                                                                                                                                                                                                                              | Any requirements in the transaction agreements to  maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                    | N/AA |
| 1122(d)(1)(iv)                                                                                                                                                                                                                                                                                                                                               | A fidelity bond and errors and omissions policy is in  effect on the party participating in the servicing function throughout the  reporting period in the amount of coverage required by and otherwise in  accordance with the terms the transaction agreements.                                                                                                                                                                                                                                                     | X |
| 1122(d)(1)(v)                                                                                                                                                                                                                                                                                                                                                | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                             | XB |
| **Cash Collection and Administration**                                                                                                                                                                                                                                                                                                                       |
| 1122(d)(2)(i)                                                                                                                                                                                                                                                                                                                                                | Paymentsonpoolassetsaredepositedintotheappropriate custodial bank accounts and  related bank clearing accounts no more than two business days following receipt,  or such other number of days specified inthe transaction agreements.                                                                                                                                                                                                                                                                                | XB |
| 1122(d)(2)(ii)                                                                                                                                                                                                                                                                                                                                               | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                | XB |
| 1122(d)(2)(iii)                                                                                                                                                                                                                                                                                                                                              | Advances of funds or  guarantees regarding collections, cash flows or distributions, and any  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                          | XB |
| 1122(d)(2)(iv)                                                                                                                                                                                                                                                                                                                                               | The related accounts for  the transaction, such as cash reserve accounts or accounts established as a  form of overcollateralization,areseparatelymaintained(e.g.,with respect  to commingling of cash) as set forth inthe  transaction agreements.                                                                                                                                                                                                                                                                   | XB |
| 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.                                                                                                                      | XB |
| 1122(d)(2)(vi)                                                                                                                                                                                                                                                                                                                                               | Unissued  checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                | XB |
| 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:                                                                                                                                                                                                                                                                                                                     | XB |
| (A) Are mathematically accurate;                                                                                                                                                                                                                                                                                                                             |
| (B) Are prepared within 30 calendar days after the  bank statement cutoff date, or such other number of days specified in the  transaction agreements;                                                                                                                                                                                                       |
| (C) Are reviewed and approved by  someone other than the person who prepared the reconciliation; and                                                                                                                                                                                                                                                         |
| (D) Contain explanations  for reconcilingitems. These  reconciling items are resolved within 90 calendar days of their original  identification,or such other  number of days specified inthe  transaction agreements.                                                                                                                                       |
| **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:                                                                                                                                                                                                                                                                                                            | N/AA |
| (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 investor's  or the trustee's records as to the total unpaid principal balance and number  of pool assets serviced by the servicer.                                                                                                                                                                                                            |
| 1122(d)(3)(ii)                                                                                                                                                                                                                                                                                                                                               | Amounts due to investors are allocated and remitted  in accordance with timeframes, distribution priority and other terms set forth  in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                   | N/AA |
| 1122(d)(3)(iii)                                                                                                                                                                                                                                                                                                                                              | Disbursements made to an  investor are posted within two business days to the servicer's investor  records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                    | N/AA |
| 1122(d)(3)(iv)                                                                                                                                                                                                                                                                                                                                               | Amounts remitted to investors per the investor  reports agree with cancelled checks, or other form of payment, or custodial  bank statements.                                                                                                                                                                                                                                                                                                                                                                         | N/AA |
| **Pool  Asset Administration**                                                                                                                                                                                                                                                                                                                               |
| 1122(d)(4)(i)                                                                                                                                                                                                                                                                                                                                                | Collateral  or security on pool assets is maintained as required by the transaction  agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                   | XB |
| 1122(d)(4)(ii)                                                                                                                                                                                                                                                                                                                                               | Pool assets and related documents are  safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                         | XB |
| 1122(d)(4)(iii)                                                                                                                                                                                                                                                                                                                                              | Any additions,  removals or substitutions to the asset pool are made, reviewed and approved  in accordance with any conditions or requirements in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                        | XB |
| 1122(d)(4)(iv)                                                                                                                                                                                                                                                                                                                                               | Payments on  pool assets, including any payoffs, made in accordance with the related pool  asset documents are posted to the servicer's obligor records maintained no  more than two business days after receipt, or such other number of days  specified in the transaction agreements, and allocated to principal, interest  or other items (e.g., escrow) in accordance with the related pool asset  documents.                                                                                                    | XB |
| 1122(d)(4)(v)                                                                                                                                                                                                                                                                                                                                                | The  servicer's records regarding the pool assets agree with the servicer's  records with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                           | N/AA |
| 1122(d)(4)(vi)                                                                                                                                                                                                                                                                                                                                               | Changes with respect to  the terms or status of an obligor's pool asset (e.g., loan modifications or  re-agings) are made, reviewed and approved by authorized personnel in  accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                             | XB |
| 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.                                                                                                                                                                                                            | XB |
| 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 )east 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). | XB |
| 1122(d)(4)(ix)                                                                                                                                                                                                                                                                                                                                               | Adjustments to interest rates or rates  of return for pool assets with variable rates are computed based on the  related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                        | N/AA |
| 1122(d)(4)(x)                                                                                                                                                                                                                                                                                                                                                | Regarding any funds held in trust for  an obligor (such as escrow accounts):                                                                                                                                                                                                                                                                                                                                                                                                                                          | N/AA |
| (A) Such funds are  analyzed, in accordance with the obligor's pool asset documents, on at least  an annualbasis,orsuchotherperiodspecifiedinthe  transaction agreements;                                                                                                                                                                                    |
| (B) Interest on such funds  is paid, or credited, to obligorsinaccordancewithapplicablepoolasset documents and state laws;and                                                                                                                                                                                                                                |
| (C) Such  funds are returned to the obligor within 30 calendar days of full repayment  of the related pool asset, or such other number of days specified in the  transaction agreements.                                                                                                                                                                     |
| 1122(d)(4)(xi)                                                                                                                                                                                                                                                                                                                                               | Payments made on behalf  of an obligor (such as tax or insurance payments) are made on or before the  related penalty or expiration dates, as indicated on the appropriate bills or  notices for such payments, provided that such support has been received by  the servicer at least 30 calendar days prior to these dates, or such other  number of days specified in the transaction agreements.                                                                                                                  | N/AA |
| 1122(d)(4)(xii)                                                                                                                                                                                                                                                                                                                                              | Any late payment penalties in  connection with any payment to be made on behalf of an obligor are paid from  the servicer's funds and not charged to the obligor, unless the late payment  was due to the obligor's error or omission.                                                                                                                                                                                                                                                                                | N/AA |
| 1122(d)(4)(xiii)                                                                                                                                                                                                                                                                                                                                             | Disbursements  made on behalf of an obligor are posted within two business days to the  obligor's records maintained by the servicer, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                          | N/AA |
| 1122(d)(4)(xiv)                                                                                                                                                                                                                                                                                                                                              | Delinquencies, charge-offs and uncollectible accounts  are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                     | N/AA |
| 1122(d)(4)(xv)                                                                                                                                                                                                                                                                                                                                               | Any external enhancement or other support, identified  in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is  maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                  |  

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

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

                                                                                                                                                                      |