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

**Regulation AB Servicing Criteria**

** **

** **

1.       Rialto Capital Advisors, LLC (“Rialto”),the Special Servicer in the agreements listed on Exhibit 1 (the “Pooling and ServicingAgreements”), and 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, 2017, up to and including December 31, 2017, 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, 2017, or for the Applicable Certification Period as listed onExhibit 1 (the “Platform”), and were registered after January 1, 2006, with theSecurities and Exchange Commission pursuant to the Securities Act of 1933.

 

2.       Rialto has engaged certain vendors (the“Vendors”) to perform specific, limited, or scripted activities, and Rialtoelects to take responsibility for assessing compliance with the servicingcriteria, or portion of the servicing criteria, applicable to such Vendors’activities as set forth in Appendix A hereto. Rialto has determined  itsVendors are not “servicers” as defined in Item 1101 (j) of Regulation AB andasserts that it has policies and procedures in place to provide reasonableassurance that the Vendors’ activities comply, in all material respects, withthe servicing criteria applicable to each vendor;

 

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

 

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

 

5.       Rialto has complied, in all materialrespects, with the applicable servicing criteria as of December 31, 2017, andfor the Reporting Period with respect to the Platform taken as a whole.

 

6.       Rialto has not identified and is not awareof any material instance of noncompliance by the Vendors with the applicableservicing criteria as of December 31, 2017, and for the Reporting Period withrespect to the Platform taken as a whole;

 

7.       Rialto has not identified any materialdeficiency in its policies and procedures to monitor the compliance by theVendors with the applicable servicing criteria as of December 31, 2017, and forthe Reporting Period with respect to the Platform taken as a whole; and

 

8.       NDB Accountants & Consultants, LLP, aregistered public accounting firm, has issued an attestation report on Rialto’sassessment of compliance with the applicable servicing criteria for theReporting Period.

 

 

Date: March 1, 2018

Name: Adam Singer

Title: Managing Director

 

Signature: /s/ Adam Singer

 

 

**Management’s Assertion onCompliance**

 

 

**Exhibit 1**

 

| **Pooling and Servicing Agreements**                                                  | **Applicable Certification Period**     |
|---------------------------------------------------------------------------------------|-----------------------------------------|
| WFRBS 2012-C8                                                                         | January 1, 2017 to December 31, 2017    |
| FDIC 2012-C1                                                                          | January 1, 2017 to December 31, 2017    |
| WFCM 2012-LC5                                                                         | January 1, 2017 to December 31, 2017    |
| UBS-Barclays 2012-C3                                                                  | January 1, 2017 to December 31, 2017    |
| UBS-Barclays 2012-C4                                                                  | January 1, 2017 to December 31, 2017    |
| GSMS 2012-GCJ9                                                                        | January 1, 2017 to December 31, 2017    |
| JPMCC 2012-LC9                                                                        | January 1, 2017 to December 31, 2017    |
| COMM 2013-LC6                                                                         | January 1, 2017 to December 31, 2017    |
| WFRBS 2013-C12                                                                        | January 1, 2017 to December 31, 2017    |
| UBS-Barclays 2013-C6                                                                  | January 1, 2017 to December 31, 2017    |
| GSMS 2013-GCJ12                                                                       | January 1, 2017 to December 31, 2017    |
| WFRBS 2013-C14                                                                        | January 1, 2017 to December 31, 2017    |
| WFRBS 2011-C5                                                                         | January 1, 2017 to December 31, 2017    |
| WFCM 2013-LC12                                                                        | January 1, 2017 to December 31, 2017    |
| WFRBS 2011-C2                                                                         | January 1, 2017 to December 31, 2017    |
| WFRBS 2011-C3                                                                         | January 1, 2017 to December 31, 2017    |
| WFRBS 2011-C4                                                                         | January 1, 2017 to December 31, 2017    |
| UBS-Citigroup 2011-C1                                                                 | January 1, 2017 to December 31, 2017    |
| UBS 2012-C1                                                                           | January 1, 2017 to December 31, 2017    |
| WFRBS 2012-C6                                                                         | January 1, 2017 to December 31, 2017    |
| GSMS 2011-GC3                                                                         | January 1, 2017 to December 31, 2017    |
| COMM 2013-LC13                                                                        | January 1, 2017 to December 31, 2017    |
| WFRBS 2013-C16                                                                        | January 1, 2017 to December 31, 2017    |
| GSMS 2013-GCJ16                                                                       | January 1, 2017 to December 31, 2017    |
| WFRBS 2013-C17                                                                        | January 1, 2017 to December 31, 2017    |
| GSMS 2012-GC6                                                                         | January 1, 2017 to December 31, 2017    |
| MSBAM 2013-C13                                                                        | January 1, 2017 to December 31, 2017    |
| COMM 2014-CCRE14                                                                      | January 1, 2017 to December 31, 2017    |
| MSBAM 2014-C14                                                                        | January 1, 2017 to December 31, 2017    |
| WFRBS 2014-LC14                                                                       | January 1, 2017 to December 31, 2017    |
| COMM 2014-LC15                                                                        | January 1, 2017 to December 31, 2017    |
| WFRBS 2014-C20                                                                        | January 1, 2017 to December 31, 2017    |
| COMM 2014-CCRE18                                                                      | January 1, 2017 to December 31, 2017    |
| CGCMT 2014-GC23                                                                       | January 1 , 2017 to December 31, 2017   |
| MSBAM 2014-C17                                                                        | January 1, 2017 to December 31, 2017    |
| COMM 2014-UBS5                                                                        | January 1, 2017 to December 31, 2017    |
| MSBAM 2014-C18                                                                        | January 1, 2017 to December 31, 2017    |
| COMM 2012-CCRE4                                                                       | January 1, 2017 to December 31, 2017    |
| COMM 2012-LC4                                                                         | January 1, 2017 to December 31, 2017    |
| WFRBS 2014-C24                                                                        | January 1, 2017 to December 31, 2017    |
| JPMBB 2014-C25                                                                        | January 1, 2017 to December 31, 2017    |
| LCCM 2014-909                                                                         | January 1, 2017 to December 31, 2017    |
| MLMI 1998-C3                                                                          | January 1, 2017 to December 31, 2017    |
| WFCM 2014-LC18                                                                        | January 1, 2017 to December 31, 2017    |
| COMM 2015-DC1                                                                         | January 1, 2017 to December 31, 2017    |
| GSMS 2015-GC28                                                                        | January 1, 2017 to December 31, 2017    |
| WFCM 2015-C27                                                                         | January 1, 2017 to December 31, 2017    |
| WFCM 2015-LC20                                                                        | January 1, 2017 to December 31, 2017    |
| WFCM 2015-NXS1                                                                        | January 1, 2017 to December 31, 2017    |
| CSAIL 2015-C2                                                                         | January 1, 2017 to December 31, 2017    |
| WFCM 2015-NXS2                                                                        | January 1, 2017 to December 31, 2017    |
| COMM 2015-PC1                                                                         | January 1, 2017 to December 31, 2017    |
| CSAIL 2015-C3                                                                         | January 1, 2017 to December 31, 2017    |
| WFCM 2015-SG1                                                                         | January 1, 2017 to December 31, 2017    |
| WFCM 2015-LC22                                                                        | January 1, 2017 to December 31, 2017    |
| COMM 2015-CCRE27                                                                      | January 1, 2017 to December 31, 2017    |
| WFCM 2015-NXS4                                                                        | January 1, 2017 to December 31, 2017    |
| MSCI 2015-UBS8                                                                        | January 1, 2017 to December 31, 2017    |
| CSAIL 2016-C5                                                                         | January 1, 2017 to December 31, 2017    |
| WFCM 2016-C32                                                                         | January 1, 2017 to December 31, 2017    |
| WFCM 2016-NXS5                                                                        | January 1, 2017 to December 31, 2017    |
| CGCMT 2015-GC27 (Special Servicer solely  for the Boca Hamptons Plaza Portfolio Loan) | January 1, 2017 to December 31, 2017    |
| WFCM 2016-C33                                                                         | January 1, 2017 to December 31, 2017    |
| MSBAM 2016-C29                                                                        | January 1, 2017 to December 31, 2017    |
| CFCRE 2016-C4                                                                         | January 1, 2017 to December 31, 2017    |
| GSMS 2016-GS2 (Special Servicer solely  for the Veritas Multifamily Pool 2 only)      | January 1, 2017 to December 31, 2017    |
| BACM 2016-UBS10                                                                       | January 1, 2017 to December 31, 2017    |
| SGCMS 2016-C5                                                                         | January 1, 2017 to December 31, 2017    |
| WFCM 2016-BNK1                                                                        | January 1, 2017 to December 31, 2017    |
| CD 2016-CD1                                                                           | January 1, 2017 to December 31, 2017    |
| GSMS 2016-GS3                                                                         | January 1, 2017 to December 31, 2017    |
| MSBAM 2016-C31                                                                        | January 1, 2017 to December 31, 2017    |
| CGCMT 2016-C3                                                                         | January 1, 2017 to December 31, 2017    |
| CFCRE 2016-C6                                                                         | January 1, 2017 to December 31, 2017    |
| CSAIL 2016-C7                                                                         | January 1, 2017 to December 31, 2017    |
| MSCI 2016-UBS12                                                                       | January 1, 2017 to December 31, 2017    |
| BBCMS 2017-C1                                                                         | February 27, 2017 to December 31, 2017  |
| GSMS 2017-GS5                                                                         | March 21, 2017 to December 31, 2017     |
| CGCMT 2017-P7                                                                         | April 18, 2017 to December 31, 2017     |
| BANK 2017-BNK4                                                                        | April 19, 2017 to December 31, 2017     |
| CD 2017-CD4                                                                           | May 17, 2017 to December 31, 2017       |
| CFCRE 2017-C8                                                                         | June 8, 2017 to December 31, 2017       |
| JPMCC 2017-JP6                                                                        | June 16, 2017 to December 31, 2017      |
| CD 2017-CD5                                                                           | August 15, 2017 to December 31, 2017    |
| GSMS 2017-GS7                                                                         | August 24, 2017 to December 31, 2017    |
| BANK 2017-BNK7                                                                        | September 28, 2017 to December 31, 2017 |
| CSAIL 2017-CX9                                                                        | September 29, 2017 to December 31, 2017 |
| UBS 2017-C4                                                                           | October 18, 2017 to December 31, 2017   |
| UBS 2017-C6                                                                           | December 13, 2017 to December 31, 2017  |
| BANK 2017-BNK9                                                                        | December 20, 2017 to December 31, 2017  |

 

 

**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 theactivities pertaining to these criteria, except for specific, limitedactivities performed by its third party property managers relating to REOProperty, if any. Rialto has elected to take responsibility for assessingcompliance with these servicing criteria with respect to the activities of itsthird party property managers.

2)      Payment activities areprocessed by Rialto’s Accounts Payable department, however, unissued check stocksare controlled and physically maintained at a different location(the parent/affiliate company, Lennar) and are not accessible toRialto personnel. Althoughthis criteria is addressed by a parent/affiliateorganization, Rialto has accepted responsibility for this criteria.

3)      Only items (A) and (B) of the ServicingCriteria are applicable to Rialto Capital Advisors, LLC as special servicer.Items (C) and (D) are inapplicable as the responsibility for filing reportswith the Commission and agreeing totals to the Servicer records rests with theTrustee and/or Certificate Administrator, as applicable. 

4)      Primary responsibility for processingborrower payments rests with the Master Servicer, however, Rialto CapitalAdvisors, LLC may from time to time receive payments on an exception basiswhich are forwarded to the Master Servicer in accordance with such criterion.

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