**Management’s Assertion onCompliance with Applicable**

**Regulation AB ServicingCriteria**

** **

 

1. Rialto Capital Advisors, LLC(“Rialto”), the Special Servicer in the agreements listed on Exhibit 1 (the“Pooling and Servicing Agreements”), is responsible for assessing compliancewith the servicing criteria applicable to it under paragraph (d) of Item 1122of Regulation AB, for the period from January 1, 2016, up to and includingDecember 31, 2016, or applicable shorter period there within, (the “ReportingPeriod”), as set forth in Appendix A hereto.  The transactions covered bythis report include the transactions listed on Exhibit 1 that are commercialmortgage-asset backed securities transactions for which Rialto acted as SpecialServicer on or after January 1, 2016, or for the Applicable CertificationPeriod as listed on Exhibit 1 (the "Platform"), and were registeredafter January 1, 2006, with the Securities and Exchange Commission pursuant tothe Securities Act of 1933.

 

2. Rialto has engaged certainvendors (the “Vendors”) to perform specific, limited, or scripted activities,and Rialto elects to take responsibility for assessing compliance with theservicing criteria, or portion of the servicing criteria, applicable to suchVendors’ activities as set forth in Appendix A hereto. Rialto hasdetermined  its Vendors are not “servicers” as defined in Item 1101 (j) ofRegulation AB and asserts that it has policies and procedures in place toprovide reasonable assurance that the Vendors’ activities comply, in allmaterial respects, with the servicing criteria applicable to each vendor;

 

3. Except as set forth inparagraph 4 below, Rialto used the criteria set forth in paragraph (d) of Item1122 of Regulation AB to assess the compliance with the applicable servicingcriteria;

 

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

 

5. Rialto has complied, in allmaterial respects, with the applicable servicing criteria as of December 31,2016, and for the Reporting Period with respect to the Platform taken as awhole.

 

6. Rialto has not identifiedand is not aware of any material instance of noncompliance by the Vendors withthe applicable servicing criteria as of December 31, 2016, and for theReporting Period with respect to the Platform taken as a whole;

 

7. Rialto has not identifiedany material deficiency in its policies and procedures to monitor thecompliance by the Vendors with the applicable servicing criteria as of December31, 2016, and for the Reporting Period with respect to the Platform taken as awhole; and

 

8. NDB Accountants &Consultants, LLP, a registered public accounting firm, has issued anattestation report on Rialto’s assessment of compliance with the applicableservicing criteria for the Reporting Period.

 

 

Date: March 1, 2017

Name: Adam Singer

Title: Managing Director

 

Signature: /s/ Adam Singer

 

 

**Exhibit 1**

 

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

 

*Supplemental clarification regarding COMM 2012-LC4:

 

By trustee's notification,dated September 13, 2016, Rialto was advised of its termination as specialservicer of the COMM 2012-LC4 pool and of the appointment of KeyBank, NationalAssociation ("KeyBank") as replacement special servicer, whichtermination and replacement appointment was indicated as being effective as ofSeptember 12, 2016.  On February 9, 2017, Rialto was advised that variousnotices and certain other requirements under the Pooling and ServicingAgreement had not been properly delivered by the Directing Holder, KeyBank andcertain other parties unrelated to Rialto.  Accordingly, the informationprovided in this certification reflects the foregoing by including the COMM2012-LC4 as a pool serviced by Rialto through December 31, 2016.  KeyBankhas advised Rialto that the only action taken by it as purported SpecialServicer of the pool for the period September 12, 2016 through December 31, 2016was a consent to a lease amendment respecting a J.C. Penney Lease relating tothe Plaza de Sol Loan and that no Servicing Transfer Events occurred duringsaid period.  Rialto has been provided with and has reviewed the relevantmaterials applicable to such lease amendment consent and has concurred in theconsent action taken by KeyBank.

 

 

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, LLCperforms the activities pertaining to these criteria, except for specific,limited activities performed by its third party property managers relating toREO Property, if any.  Rialto has elected to take responsibility forassessing compliance with these servicing criteria with respect to theactivities of its third party property managers.

 

2) Payment activities areprocessed by Rialto’s Accounts Payable department, however, unissued checkstocks are controlled and physically maintained at a different location (theparent/affiliate company, Lennar) and are not accessible to Rialtopersonnel.  Although this criteria is addressed by a parent/affiliateorganization, Rialto has accepted responsibility for this criteria.

 

3) Only items (A) and (B) ofthe Servicing Criteria are applicable to Rialto Capital Advisors, LLC asspecial servicer.  Items (C) and (D) are inapplicable as theresponsibility for filing reports with the Commission and agreeing totals tothe Servicer records rests with the Trustee and/or Certificate Administrator,as applicable. 

 

4) Primary responsibility forprocessing borrower payments rests with the Master Servicer, however, RialtoCapital Advisors, LLC may from time to time receive payments on an exceptionbasis which are forwarded to the Master Servicer in accordance with suchcriterion.

 

5) Rialto Capital Advisors,LLC provides the applicable Master Servicer relating to each deal with thefinal recovery determination and data utilized to complete IRS Form 1099C onloans with charge-offs, however, the ultimate responsibility for adjusting theloan record, reporting to the IRS, and delivering 1099C Forms to the borrowerrests with the Master Servicer.

 

 

**Management’s Assertion onCompliance**