Exhibit 35.4

Statement of Compliance

To Midland Loan Services, a Division of PNC Bank, National Association, Master Servicer of the Series of Commercial Mortgage Pass-Through Certificates, referred to on Attachment A:

I, Steven Johnson, in my capacity as Managing Director of Principal Real Estate Investors, LLC and Principal Global Investors, LLC, as a Primary Servicers for mortgage loans securing securities issued in conjunction with the series of Commercial Mortgage Pass-Through Certificates, referred to on Attachment A, hereby state that:

|   | 1. | I am an officer of Principal Real Estate Investors, LLC and Principal Global Investors, LLC; |   |
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|   | 2. | A review of the activities of Principal Real Estate Investors, LLC and Principal Global Investors, LLC in its capacity as Primary Servicers during the calendar year ending December 31, 2019 (the “Reporting Period”); and of its performance under the applicable sub-servicing agreement has been made under my supervision; and |   |
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|   | 3. | To the best of my knowledge, based on such review, Principal Real Estate Investors, LLC and Principal Global Investors, LLC, as Primary Servicers have fulfilled all of their obligations in all material respects under the Primary Servicing Agreements for said Commercial Mortgage Pass-Through Certificates, referred to on Attachment A throughout the above-referenced Reporting Period. |
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Date: February 17, 2020

 

|                                      |
|--------------------------------------|
| /s/ Steven R. Johnson                |
|                                 |
|                                 |
| Steven R. Johnson                    |
| Managing Director                    |
| Principal Real Estate Investors, LLC |
| Principal Global Investors, LLC      |

 

 

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Attachment A

Commercial Mortgage Pass-Through Certificates

 

| Wells Fargo Bank, National Association, as Master Servicer |
|------------------------------------------------------------|
| Series 2004-Top14 dated April 1, 2004                      | Series 2000-PRIN dated September 1, 2000 | Series 2001-Top3 dated July 1, 2001 |
| Series 2004-Top16 dated November 1, 2004                   | Series 2004-Top15 dated July 1, 2004 | Series 2003-Top10 dated April 1, 2003 |
| Series 2005-Top18 dated April 1, 2005                      | Series 2005-Top20 dated October 1, 2005 | Series 2004-Top13 dated February 1, 2004 |
| Series 2005 PWR10 dated December 1, 2005                   | Series 2006-Top21 dated January 1, 2006 | Series 2004-IQ8 dated August 1, 2004 |
| Series 2006-Top22 dated April 1, 2006                      | Series 2006 PWR13 dated September 1, 2006 | Series 2005-Top19 dated July 1, 2005 |
| Series 2006-HQ9 dated August 1, 2006                       | Series 2007 Top25 dated January 30, 2007 | Series 2006-Top23 dated August 1, 2006 |
| Series 2006 PWR14 dated December 1, 2006                   | Series 2011 C-2 dated March 1, 2011 | Series 2006-Top24 dated October 1, 2006 |
| Series 2007 Top26 dated April 18, 2007                     | Series 2011 C-5 dated November 1, 2011 | Series 2007 PWR15 dated March 29, 2007 |
| Series 2011 C-4 dated August 1, 2011                       | Series 2012 C10 dated December 1, 2012 | Series 2007 PWR18 dated December 27, 2007 |
| Series 2012 C-9 dated October 1, 2012                      | Series 2013 C17 dated November 1, 2013 | Series 2011 C-3 dated June 1, 2011 |
| Series 2013 C13 dated May 1, 2013                          | Series 2015 – C27 dated March 1, 2015 | Series 2012 C-8 dated August 1, 2012 |
| Series 2014 – LC14 dated February 1, 2014            | Series 2017 – P7 dated April 1, 2017 | Series 2013 C11 dated February 1, 2013 |
| Series 2014 – C21 dated August 1, 2014               | Series 2016 – P3 dated April 1, 2016 | Series 2014 – C19 dated March 1, 2014 |
| Series 2015 – P2 dated December 1, 2015              | Series 2016 – P4 dated July 1, 2016 | Series 2015 – P1 dated August 1, 2015 |
| Series 2017 – CD6 dated November 1, 2017             | Series 2017 – P8 dated September 1, 2017 | Series 2019 – CD8 dated August 1, 2019 |

 

| Berkadia Commercial Mortgage LLC, as Master Servicer |
|------------------------------------------------------|
| Series 2007 IQ-15 dated 8/23/2007                    | Series 2002 IQ -3 dated 12/01/2002 |   |

 

| Midland Loan Services, a Division of PNC Bank, National Association, as Master Servicer |
|-----------------------------------------------------------------------------------------|
| Series 2016 – P5 dated October 1, 2016                                            | Series 2016 – P6 dated December 1, 2016 |   |