(logo)TRIMONT

 

 

TrimontReal Estate Advisors, LLC

 

 

Management'sReport on Assessment of Compliance with SEC Regulation AB Servicing Criteria

 

 

TrimontReal Estate Advisors, LLC ("the Asserting Party") is responsible for assessingcompliance as of and for the year ended December 31, 2019 ("the ReportingPeriod") with the applicable servicing criteria set forth in Item 1122(d)of the Securities and Exchange Commission's Regulation AB as set forth inExhibit A hereto (the "Applicable Servicing Criteria"). Thetransactions covered by this report are only those transactions processed bythe Asserting Party in capacity as trust, senior trust, or operating advisorfor the asset backed securities transactions listed in Exhibit B hereto (the"Platform").

 

TheAsserting Party has used the servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission's Regulation AB to assess its compliancewith the Applicable Servicing Criteria for the Reporting Period and hasconcluded that the Asserting Party has complied, in all material respects, withthe Applicable Servicing Criteria as of and for the year ended December 31,2019 with respect to the Platform.

 

GrantThornton, LLP, an independent registered public accounting firm, has issued anattestation report on the assessment of compliance with the ApplicableServicing Criteria as of and for the year ended December 31, 2019 as set forthin this assertion.

 

 

TrimontReal Estate Advisors, LLC

February25, 2020

 

 

/s/Glen Peters

GlenPeters

ChiefFinancial Officer

 

 

AMSTERDAM ATLANTA  DALLAS  KANSAS CITY  LONDON  LOS ANGELES  NEWYORK  SYDNEY

 

 

| **Exhibit   A**

** **         |
|-------------------------------------|
| **Regulation   AB Criteria**        | **GSMS 2015-GC30** | **WFCM 2015-C27** | **WFCM 2015-C29** | **WFCM 2015-C31** | **WFCM 2015-LC20** | **WFCM 2015-NXS1** | **WFCM 2015-SG1** | **WFRBS 2014-C25** | **WFRBS 2014-C23** | **WFRBS 2014-C21** | **GSMS 2014-GC20** | **WFRBS 2014-C19** | **WFRBS 2013-C17** | **MSBAM 2013-C12** | **WFRBS 2013-C15** | **GSMS 2013-GC13** | **WFRBS 2013-C13** | **MSBAM 2013-C9** | **WFRBS 2013-C11** | **GSMS 2013-GC10** | **UBS 2012-C4** | **WFCM 2012-LC5** |
| ***Section***                       | ***Description*** | ***Criteria*** | ***Applicable   Criteria*** |
| General Servicing  Considerations   |
| 1122(d)(1)(i)                       | Policies and  Procedures | Policies and procedures  are instituted to monitor any performance or other triggers and events of  default in accordance with the transaction agreement. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(ii)                      | Policies and Procedures  (vendors) | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(iii)                     | Back-up Servicer | Any requirements  in the transaction agreements to maintain a back-up servicer for the pool  assets are maintained. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(iv)                      | Fidelity Bond | 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 agreement. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(v)                       | Accuracy of  Information | Aggregation of information,  as applicable, is mathematically accurate and the information conveyed  accurately reflects the information. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Cash Collection  and Administration |
| 1122(d)(2)(i)                       | 2 Days to deposit  Payments into Custodial Accounts | Payments on pool  assets are deposited into the appropriate custodial bank accounts and related  bank clearing accounts no more than two business days of receipt, or such  other number of days specified in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(ii)                      | Wire Transfers | Disbursements made  via wire transfer on behalf of an obligor or to an investor are made only by  authorized personnel | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(iii)                     | Advances | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(iv)                      | Commingling | The related  accounts for the transaction, such as cash reserve accounts or accounts  established as a form of over collateralization, are separately maintained  (e.g., with respect to commingling of cash) as set forth in the transaction  agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(v)                       | Federally Insured  Institution | 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 §240.13k-1(b)(1) of this chapter.  I.3 Each custodial account shall  be maintained at a federally insured depository institution in trust for the  applicable investor. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(vi)                      | Unissued Checks | Unissued checks  are safeguarded so as to prevent unauthorized access. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(vii)                     | Reconciliations | 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:  (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 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Investor  Remittance and Reporting  |
| 1122(d)(3)(i)                       | Reports to the  Investor | 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. | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| 1122(d)(3)(ii)                      | Investor  Remittance | 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 | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(3)(iii)                     | Investor’s  Records | 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 | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(3)(iv)                      | Remittance and  Bank Statements | Amounts remitted  to investors per the investor reports agree with cancelled checks, or other  form of payment, or custodial bank statements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Pool Asset  Administration          |
| 1122(d)(4)(i)                       | Collateral/  Security on Pool Assets | Collateral or  security on pool assets is maintained as required by the transaction  agreements or related pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(ii)                      | Safeguard Pool  Assets | Pool assets and  related documents are safeguarded as required by the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(iii)                     | Changes to the  Pool Assets | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(iv)                      | Obligor’s Payment  Record | Payments on pool  assets, including any payoffs, made in accordance with the related pool asset  documents are posted to the applicable 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(v)                       | Pool Asset  Records Match UPB | The servicers records  regarding the pool assets agree with the servicer’s records with respect to  an obligor’s unpaid principal balance. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
|  1122(d)(4)(vi)                | Loan  Modifications | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(vii)                     | Loss Mitigation  Actions | 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 agreement. | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 |
| 1122(d)(4)(viii)                    | Collection  Efforts Documented | 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). | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(ix)                      | ARMs | Adjustments to  interest rates or rates of return for pool assets with variable rates are computed  based on the related pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(x)                       | Escrow Funds | Regarding any funds  held in trust for an obligor such funds are (a) 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)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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xi)                      | Timely Payments | 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/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xii)                     | Late Payment  Penalties | 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/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xiii)                    | Obligor’s Records | 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/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xiv)                     | Delinquencies,  Charge-offs, and Other Uncollectible Accounts | Delinquencies,  Charge-offs, and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xv)                      | Any External  Enhancement | 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/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |

 

 

| **Exhibit   A**

** **                                                                                                                          |
|------------------------------------------------------------------------------------------------------------------------------------------------------|
| ** **

** **

** **

** **

** **

**Regulation   AB Criteria**

** **

** **

** **

** **

** ** | **WFRBS 2012-C9** | **DBUBS 2011-LC3** | **WFRBS 2011-C5** | **WFCM 2016-NXS6** | **WFCM 2016-LC24** | **WFCM 2016-C37** | **245 Park Ave Trust2017-245P** | **MSC 2017-H1** | **WFCM 2017-C39** | **WFCM 2017-RB1** | **WFCM 2017-C41** | **CFCRE 2011-C2** | **MSC 2011-C3** | **UBS CCMT 2011-C1** | **JPMCC 2012 CIBX** | **UBS 2012-C1** | **WFRBS 2014-LC14** | **CGCMT 2014-GC23** | **CGCMT 2016-C3** | **CGCMT 2017-B1** | **GSMS 2012-GC6** | **WFRBS 2012-C7** |
| ***Section***                                                                                                                                        | ***Description*** | ***Criteria*** | ***Applicable   Criteria*** |
| General Servicing  Considerations                                                                                                                    |
| 1122(d)(1)(i)                                                                                                                                        | Policies and  Procedures | Policies and  procedures are instituted to monitor any performance or other triggers and  events of default in accordance with the transaction agreement. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(ii)                                                                                                                                       | Policies and  Procedures (vendors) | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(iii)                                                                                                                                      | Back-up Servicer | Any requirements  in the transaction agreements to maintain a back-up servicer for the pool  assets are maintained. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(iv)                                                                                                                                       | Fidelity Bond | 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  agreement. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(1)(v)                                                                                                                                        | Accuracy of  Information | Aggregation of information,  as applicable, is mathematically accurate and the information conveyed  accurately reflects the information. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Cash Collection  and Administration                                                                                                                  |
| 1122(d)(2)(i)                                                                                                                                        | 2 Days to deposit  Payments into Custodial Accounts | Payments on pool  assets are deposited into the appropriate custodial bank accounts and related  bank clearing accounts no more than two business days of receipt, or such  other number of days specified in the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(ii)                                                                                                                                       | Wire Transfers | Disbursements made  via wire transfer on behalf of an obligor or to an investor are made only by  authorized personnel | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(iii)                                                                                                                                      | Advances | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(iv)                                                                                                                                       | Commingling | The related  accounts for the transaction, such as cash reserve accounts or accounts  established as a form of over collateralization, are separately maintained  (e.g., with respect to commingling of cash) as set forth in the transaction  agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(v)                                                                                                                                        | Federally Insured  Institution | 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 §240.13k-1(b)(1) of this chapter.  I.3 Each custodial account shall  be maintained at a federally insured depository institution in trust for the  applicable investor. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(vi)                                                                                                                                       | Unissued Checks | Unissued checks  are safeguarded so as to prevent unauthorized access. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(2)(vii)                                                                                                                                      | Reconciliations | 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:  (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 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Investor  Remittance and Reporting                                                                                                                   |
| 1122(d)(3)(i)                                                                                                                                        | Reports to the  Investor | 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. | X1 | X4 | X3 | X1 | X1 | X1 | X5 | X1 | X1 | X1 | X1 | X3 | X4 | X3 | X1 | X1 | X1 | X1 | X1 | X1 | X1 | X1 |
| 1122(d)(3)(ii)                                                                                                                                       | Investor  Remittance | 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 | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(3)(iii)                                                                                                                                      | Investor’s  Records | 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 | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(3)(iv)                                                                                                                                       | Remittance and  Bank Statements | Amounts remitted  to investors per the investor reports agree with cancelled checks, or other  form of payment, or custodial bank statements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Pool Asset  Administration                                                                                                                           |
| 1122(d)(4)(i)                                                                                                                                        | Collateral/  Security on Pool Assets | Collateral or  security on pool assets is maintained as required by the transaction  agreements or related pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(ii)                                                                                                                                       | Safeguard Pool  Assets | Pool assets and  related documents are safeguarded as required by the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(iii)                                                                                                                                      | Changes to the  Pool Assets | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(iv)                                                                                                                                       | Obligor’s Payment  Record | Payments on pool  assets, including any payoffs, made in accordance with the related pool asset  documents are posted to the applicable 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(v)                                                                                                                                        | Pool Asset  Records Match UPB | The servicers records  regarding the pool assets agree with the servicer’s records with respect to  an obligor’s unpaid principal balance. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
|  1122(d)(4)(vi)                                                                                                                                 | Loan  Modifications | 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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(vii)                                                                                                                                      | Loss Mitigation  Actions | 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 agreement. | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 | X2 |
| 1122(d)(4)(viii)                                                                                                                                     | Collection  Efforts Documented | 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). | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(ix)                                                                                                                                       | ARMs | Adjustments to  interest rates or rates of return for pool assets with variable rates are  computed based on the related pool asset documents. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(x)                                                                                                                                        | Escrow Funds | Regarding any  funds held in trust for an obligor such funds are (a) 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)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. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xi)                                                                                                                                       | Timely Payments | 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/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xii)                                                                                                                                      | Late Payment  Penalties | 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/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xiii)                                                                                                                                     | Obligor’s Records | 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/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xiv)                                                                                                                                      | Delinquencies, Charge-offs,  and Other Uncollectible Accounts | Delinquencies,  Charge-offs, and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| 1122(d)(4)(xv)                                                                                                                                       | Any External  Enhancement | 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/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |

 

 

**Key**

 

|  

X1                                                                                                                                                                                                         | With  respect to Item 1122(d)(3)(i), only parts A and B of this criteria are  applicable for the securitization.                                                                                          |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| X2                                                                                                                                                                                                                 | With  respect to Item 1122(d)(4)(vii), there were no Loss mitigation or recovery  actions during the reporting period for the loan(s) that were serviced under  this securitization.                      |
| X3                                                                                                                                                                                                                 | With  respect to Item 1122(d)(3)(i), only parts A, B, and C are applicable. There  were no activities performed during the reporting period for the loan(s) that  were serviced under this securitization |
| X4                                                                                                                                                                                                                 | With  respect to Item 1122(d)(3)(i), there were no activities performed during the  reporting period for the loan(s) that were serviced under this  securitization.                                       |
| X5                                                                                                                                                                                                                 | With  respect to Applicable Servicing Criteria, the securitization was not in scope  based on the transaction agreement.                                                                                  |
| With  respect to Applicable Servicing Criteria cells in Exhibit A that are denoted  with an "N/A", per review of the respective servicing agreement,  the criteria was not in scope for the transaction. |

 

 

**ExhibitB**

** **

| Name                           | Transaction                                                                                                                                               | Period  of Service                     |
|--------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------|
| DBUBS  2011-LC3                | Commercial  Mortgage Pass-Through Certificates, DBUBS 2011-LC3 pursuant to the Pooling and  Servicing Agreement dated August 1, 2011                      | January  1, 2019 -

December  31, 2019 |
| WFRBS  2011-C5                 | Commercial  Mortgage Pass-Through Certificates, WFRBS 2011-C5 pursuant to the Pooling and  Servicing Agreement dated November 1, 2011                     | January  1, 2019 -

December  31, 2019 |
| MSC  2011-C3                   | Commercial  Mortgage Pass-Through Certificates, MSC 2011-C3 pursuant to the Pooling and  Servicing Agreement dated October 1, 2011                        | January  1, 2019 -

December  31, 2019 |
| CFCRE  2011-C2                 | Commercial  Mortgage Pass-Through Certificates, CFCRE 2011-C2 pursuant to the Pooling and  Servicing Agreement dated December 11, 2011                    | January  1, 2019 -

December  31, 2019 |
| UBS  CCMT-2011-C1              | Commercial  Mortgage Pass-Through Certificates, UBS CCMT-2011 pursuant to the Pooling and  Servicing Agreement dated December 1, 2011                     | January  1, 2019 -

December  31, 2019 |
| GSMS  2012-GC6                 | Commercial  Mortgage Pass-Through Certificates, Series 2012-GC6 pursuant to the Pooling  and Servicing Agreement dated February 1, 2012                   | January  1, 2019 -

December  31, 2019 |
| UBS  2012-C1                   | Commercial  Mortgage Pass-Through Certificates, Series 2012-C1 pursuant to the Pooling  and Servicing Agreement dated May 1, 2012                         | January  1, 2019 -

December  31, 2019 |
| JPMCC  2012 - CIBX             | Commercial  Mortgage Pass-Through Certificates, Series 2012-CIBX pursuant to the Pooling  and Servicing Agreement dated June 1, 2012                      | January  1, 2019 -

December  31, 2019 |
| WFRBS  2012-C7                 | Commercial  Mortgage Pass-Through Certificates, Series 2012-C7 pursuant to the Pooling  and Servicing Agreement dated June 1, 2012                        | January  1, 2019 -

December  31, 2019 |
| WFCM  2012-LC5                 | Commercial  Mortgage Pass-Through Certificates, Series 2012-LC5 pursuant to the Pooling  and Servicing Agreement dated September 1, 2012                  | January  1, 2019 -

December  31, 2019 |
| WFRBS  2012-C9                 | Commercial  Mortgage Pass-Through Certificates, Series 2012-C9 pursuant to the Pooling  and Servicing Agreement dated October 1, 2012                     | January  1, 2019 -

December  31, 2019 |
| UBS  2012-C4                   | Commercial  Mortgage Pass-Through Certificates, Series 2012-C4 pursuant to the Pooling  and Servicing Agreement dated December 1, 2012                    | January  1, 2019 -

December  31, 2019 |
| GSMS  2013-GC10                | Commercial  Mortgage Pass-Through Certificates, Series 2013-GC10 pursuant to the Pooling  and Servicing Agreement dated February 1, 2013                  | January  1, 2019 -

December  31, 2019 |
| WFRBS  2013-C11                | Commercial  Mortgage Pass-Through Certificates, Series 2013-C11 pursuant to the Pooling  and Servicing Agreement dated February 1, 2013                   | January  1, 2019 -

December  31, 2019 |
| MSBAM  2013-C9                 | Commercial  Mortgage Pass-Through Certificates, Series 2013-C9 pursuant to the Pooling  and Servicing Agreement dated May 1, 2013                         | January  1, 2019 -

December  31, 2019 |
| WFRBS  2013-C13                | Commercial  Mortgage Pass-Through Certificates, Series 2013-C13 pursuant to the Pooling  and Servicing Agreement dated May 1, 2013                        | January  1, 2019 -

December  31, 2019 |
| GSMS  2013-GC13                | Commercial  Mortgage Pass-Through Certificates, Series 2013-GC13 pursuant to the Pooling  and Servicing Agreement dated July 1, 2013                      | January  1, 2019 -

December  31, 2019 |
| WFRBS  2013-C15                | Commercial  Mortgage Pass-Through Certificates, Series 2013-C15 pursuant to the Pooling  and Servicing Agreement dated August 1, 2013                     | January  1, 2019 -

December  31, 2019 |
| MSBAM  2013-C12                | Commercial  Mortgage Pass-Through Certificates, Series 2013-C12 pursuant to the Pooling  and Servicing Agreement dated October 1, 2013                    | January  1, 2019 -

December  31, 2019 |
| WFRBS  2013-C17                | Commercial  Mortgage Pass-Through Certificates, Series 2013-C17 pursuant to the Pooling  and Servicing Agreement dated August 1, 2013                     | January  1, 2019 -

December  31, 2019 |
| WFRBS  2014-LC14               | Commercial  Mortgage Pass-Through Certificates, Series 2014-LC14 pursuant to the Pooling  and Servicing Agreement dated February 1, 2014                  | January  1, 2019 -

December  31, 2019 |
| WFRBS  2014-C19                | Commercial  Mortgage Pass-Through Certificates, Series 2014-C19 pursuant to the Pooling  and Servicing Agreement dated February 26, 2014                  | January  1, 2019 -

December  31, 2019 |
| GSMS  2014-GC20                | Commercial  Mortgage Pass-Through Certificates, Series 2014-GC20 pursuant to the Pooling  and Servicing Agreement dated April 1, 2014                     | January  1, 2019 -

December  31, 2019 |
| WFRBS  2014-C21                | Commercial  Mortgage Pass-Through Certificates, Series 2014-C21 pursuant to the Pooling  and Servicing Agreement dated August 1, 2014                     | January  1, 2019 -

December  31, 2019 |
| CGCMT  2014-GC23               | Commercial  Mortgage Pass-Through Certificates, Series 2014-GC23 pursuant to the Pooling  and Servicing Agreement dated August 1, 2014                    | January  1, 2019 -

December  31, 2019 |
| WFRBS  2014-C23                | Commercial  Mortgage Pass-Through Certificates, Series 2014-C23 pursuant to the Pooling  and Servicing Agreement dated September 1, 2014                  | January  1, 2019 -

December  31, 2019 |
| WFRBS  2014-C25                | Commercial  Mortgage Pass-Through Certificates, Series 2014-C25 pursuant to the Pooling  and Servicing Agreement dated December 1, 2014                   | January  1, 2019 -

December  31, 2019 |
| GSMS  2015-GC30                | Commercial  Mortgage Pass-Through Certificates, Series 2015-GC30 pursuant to the Pooling  and Servicing Agreement dated May 1, 2015                       | January  1, 2019 -

December  31, 2019 |
| WFCM  2015-C27                 | Commercial  Mortgage Pass-Through Certificates, Series 2015-C27 pursuant to the Pooling  and Servicing Agreement dated March 1, 2015                      | January  1, 2019 -

December  31, 2019 |
| WFCM  2015-C29                 | Commercial  Mortgage Pass-Through Certificates, Series 2015-C29 pursuant to the Pooling  and Servicing Agreement dated June 1, 2015                       | January  1, 2019 -

December  31, 2019 |
| WFCM  2015-C31                 | Commercial  Mortgage Pass-Through Certificates, Series 2015-C31 pursuant to the Pooling  and Servicing Agreement dated November 1, 2015                   | January  1, 2019 -

December  31, 2019 |
| WFCM  2015-LC20                | Commercial  Mortgage Pass-Through Certificates, Series 2015-LC20 pursuant to the Pooling  and Servicing Agreement dated March 1, 2015                     | January  1, 2019 -

December  31, 2019 |
| WFCM  2015-NXS1                | Commercial  Mortgage Pass-Through Certificates, Series 2015-NXS1 pursuant to the Pooling  and Servicing Agreement dated April 1, 2015                     | January  1, 2019 -

December  31, 2019 |
| WFCM  2015-SG1                 | Commercial  Mortgage Pass-Through Certificates, Series 2015-SG1 pursuant to the Pooling  and Servicing Agreement dated August 1, 2015                     | January  1, 2019 -

December  31, 2019 |
| WFCM  2016-C37                 | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2016-C37 pursuant to the  Pooling and Servicing Agreement dated December 1, 2016              | January  1, 2019 -

December  31, 2019 |
| CGCMT  2016-C3                 | Commercial  Mortgage Pass-Through Certificates, Series CGCMT 2016-C3 pursuant to the  Pooling and Servicing Agreement dated November 1, 2016              | January  1, 2019 -

December  31, 2019 |
| WFCM  2016-LC24                | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2016-LC24 pursuant to the  Pooling and Servicing Agreement dated September 1, 2016            | January  1, 2019 -

December  31, 2019 |   |
| WFCM  2016-NXS6                | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2016-NXS6 pursuant to the  Pooling and Servicing Agreement dated October 1, 2016              | January  1, 2019 -

December  31, 2019 |   |
| 245  Park Ave Trust

2017-245P | Commercial  Mortgage Pass-Through Certificates, Series 245 Park Ave Trust 2017-245P  pursuant to

the  Pooling and Servicing Agreement dated May 30, 2017 | January  1, 2019 -

December  31, 2019 |   |
| CGCMT  2017-B1                 | Commercial  Mortgage Pass-Through Certificates, Series CGCMT 2017-B1 pursuant to the  Pooling and

Servicing  Agreement dated August 29, 2017             | January  1, 2019 -

December  31, 2019 |   |
| MSC  2017-H1                   | Commercial  Mortgage Pass-Through Certificates, Series MSC 2017-H1 pursuant to the  Pooling and

Servicing  Agreement dated June 8, 2017                  | January  1, 2019 -

December  31, 2019 |   |
| WFCM  2017-C39                 | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2017-C39 pursuant to the  Pooling and

Servicing  Agreement dated August 22, 2017             | January  1, 2019 -

December  31, 2019 |   |
| WFCM  2017-RB1                 | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2017-RB1 pursuant to the  Pooling and

Servicing  Agreement dated March 1, 2017               | January  1, 2019 -

December  31, 2019 |   |
|  

WFCM  2017-C41         | Commercial  Mortgage Pass-Through Certificates, Series WFCM 2017-RB1 pursuant to the Pooling  and Servicing Agreement dated November 1, 2017              | January  1, 2019 -

December  31, 2019 |   |