**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****  ANNUAL REPORT PURSUANT TO SECTION13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2019or**

**o**** ****TRANSITIONREPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-206677-12**

**Central Index Key Number of the issuing entity:0001688957**

**Wells Fargo Commercial MortgageTrust 2016-C37**

**(exact name of the issuing entity as specified in itscharter)**

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, Inc.**

**(exact name of the depositor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0000312070**

**Barclays Bank PLC**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001541468**

**Ladder Capital Finance LLC**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001624053**

**Silverpeak Real Estate Finance LLC**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001592182**

**LMF Commercial, LLC**

**(exact name of the sponsor as specified in its charter)**

**(formerly known as RialtoMortgage Finance, LLC)**

** **

**Central Index Key Number of the sponsor: 0001541214**

**C-III Commercial Mortgage LLC**

**(exact name of the sponsor as specified in its charter)**

** **

| **New York****(State or other jurisdiction of  incorporation or organization of**

**the issuing entity)** | **38-4014790**

**38-4014791**

**38-7170495**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|

**c/o Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

**Registrant’s telephone number,including area code:**

**(704) 374-6161**

Securities registered pursuant to Section 12(b) of the Act:

| Title of each class | Trading Symbol(s) | Name of each  exchange on which  registered |
|---------------------|-------------------|---------------------------------------------|
| None                |              |                                        |

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

Indicate by check mark whether the registrant has submittedelectronically and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form10-K.   

Not applicable.

Indicate by check mark whether the registrant is a largeaccelerated filer, an accelerated filer, a non-accelerated filer, a smaller reportingcompany, or an emerging growth company. See the definitions of “largeaccelerated filer,” “accelerated filer,” “smaller reporting company,” and“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller reporting company)                          Smaller reportingcompany                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

Indicate by check mark whether the registrant is a shellcompany (as defined in Rule 12b-2 of the Act).  o Yes ⌧ No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed all documentsand reports required to be filed by Section 12, 13 or 15(d) of the SecuritiesExchange Act of 1934 subsequent to the distribution of securities under a planconfirmed by a court.  o Yes oNo

Not applicable.

Indicate the number of shares outstanding of each of theregistrant’s classes of common stock, as of the latest practicable date.

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the following documents if incorporated byreference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) intowhich the document is incorporated: (1) Any annual report to security holders;(2) Any proxy or information statement; and (3) Any prospectus filed pursuantto Rule 424(b) or (c) under the Securities Act of 1933. The listed documents shouldbe clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Quantum Park Mortgage Loan, the 1140Avenue of the Americas Mortgage Loan, the Fremaux Town Center Mortgage Loan,the Midwest Industrial Portfolio Mortgage Loan, the Redwood MHC PortfolioMortgage Loan and the DoubleTree by Hilton Tempe Mortgage Loan, whichconstituted approximately 6.9%, 4.0%, 3.3%, 3.1%, 2.7% and 1.5%, respectively,of the asset pool of the issuing entity as of its cut-off date, are each anasset of the issuing entity and are each part of a loan combination thatincludes (a) with respect to the Quantum Park Mortgage Loan which is an assetof the issuing entity and two other *pari passu* loans, which are notassets of the issuing entity, (b) with respect to the 1140 Avenue of theAmericas Mortgage Loan which is an asset of the issuing entity and three other *paripassu* loans, which are not assets of the issuing entity, (c) with respectto the Fremaux Town Center Mortgage Loan which is an asset of the issuingentity and two other *pari passu* loans, which are not assets of theissuing entity, (d) with respect to the Midwest Industrial Portfolio MortgageLoan which is an asset of the issuing entity and one other *pari passu*loan, which is not an asset of the issuing entity, (e) with respect to theRedwood MHC Portfolio Mortgage Loan which is an asset of the issuing entity andtwo other *pari passu* loans, which are not assets of the issuing entityand (f) with respect to the DoubleTree by Hilton Tempe Mortgage Loan which isan asset of the issuing entity and one other *pari passu* loan, which isnot an asset of the issuing entity. These loan combinations, including the QuantumPark Mortgage Loan, the 1140 Avenue of the Americas Mortgage Loan, the FremauxTown Center Mortgage Loan, the Midwest Industrial Portfolio Mortgage Loan, theRedwood MHC Portfolio Mortgage Loan and the DoubleTree by Hilton Tempe MortgageLoan, are being serviced and administered pursuant to the Pooling and ServicingAgreement, which is incorporated by reference as Exhibit 4.1 to this AnnualReport on Form 10-K. 

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the 80 Park Plaza Mortgage Loan, which constitutedapproximately 2.8% of the asset pool of the issuing entity as of its cut-offdate.  The 80 Park Plaza Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the 80 Park Plaza Mortgage Loanand four other *pari passu* loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe Citigroup Commercial Mortgage Trust 2016-C3 transaction, Commission FileNumber 333-207132-08 (the “CGCMT 2016-C3 Transaction”). This loancombination, including the 80 Park Plaza Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the CGCMT2016-C3 Transaction, which is incorporated by reference as Exhibit 4.2 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Potomac Mills Mortgage Loan, whichconstituted approximately 4.8% of the asset pool of the issuing entity as ofits cut-off date.  The Potomac Mills Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the PotomacMills Mortgage Loan and nine other *pari passu* loans and ten subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the CFCRE 2016-C6 MortgageTrust transaction, Commission File Number 333-207567-03 (the “CFCRE 2016-C6Transaction”). This loan combination, including the Potomac Mills MortgageLoan, is being serviced and administered pursuant to the pooling and servicingagreement for the CFCRE 2016-C6 Transaction, which is incorporated by referenceas Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Hilton Hawaiian Village Mortgage Loan, whichconstituted approximately 7.0% of the asset pool of the issuing entity as ofits cut-off date.  The Hilton Hawaiian Village Mortgage Loan is an assetof the issuing entity and is part of a loan combination that includes theHilton Hawaiian Village Mortgage Loan and fourteen other *pari passu*loans and five subordinate companion loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe Hilton USA Trust 2016-HHV transaction (the “Hilton USA 2016-HHVTransaction”). This loan combination, including the Hilton Hawaiian VillageMortgage Loan, is being serviced and administered pursuant to the trust andservicing agreement for the Hilton USA 2016-HHV Transaction, which isincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Walmart Shadow Anchored Portfolio MortgageLoan, which constituted approximately 5.3% of the asset pool of the issuingentity as of its cut-off date.  The Walmart Shadow Anchored PortfolioMortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Walmart Shadow Anchored Portfolio Mortgage Loanand one other *pari passu* loan, which is not an asset of the issuingentity. The other *pari passu* portion of the loan combination wassecuritized in the Wells Fargo Commercial Mortgage Trust 2016-LC25 transaction,Commission File Number 333-206677-11 (the “WFCM 2016-LC25 Transaction”).This loan combination, including the Walmart Shadow Anchored Portfolio MortgageLoan, is being serviced and administered pursuant to the pooling and servicingagreement for the WFCM 2016-LC25 Transaction, which is incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the Hilton Hawaiian Village Mortgage Loan, the WalmartShadow Anchored Portfolio Mortgage Loan and the Potomac Mills Mortgage Loan. Asa result, Wells Fargo Bank, National Association is a “servicer” as defined inItem 1108(a)(2)(iii) of Regulation AB, in the capacities described above,because it is servicing mortgage loans that constituted 10% or more of theassets of the issuing entity as of its cut-off date. The assessments of compliancewith applicable servicing criteria, accountants’ attestation reports andservicer compliance statements delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theHilton Hawaiian Village Mortgage Loan, the Walmart Shadow Anchored PortfolioMortgage Loan and the Potomac Mills Mortgage Loan.  As a result, Wells FargoBank, National Association is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Trimont Real Estate Advisors, LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement and the80 Park Plaza Mortgage Loan.  As a result, Trimont Real Estate Advisors,LLC is a servicing function participant in the capacities described above,because it is servicing mortgage loans that constituted 5% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Trimont Real Estate Advisors, LLC in the capacitiesdescribed above are listed in the Exhibit Index.

AEGON USA Realty Advisors, LLC isthe special servicer of the Hilton Hawaiian Village Mortgage Loan prior toNovember 22, 2019 and the Potomac Mills Mortgage Loan. As a result, AEGON USARealty Advisors, LLC is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by AEGON USA Realty Advisors, LLC in the capacities described aboveare listed in the Exhibit Index.

CWCapital Asset Management LLC isthe special servicer of the Hilton Hawaiian Village Mortgage Loan, whichconstituted approximately 7.0% of the asset pool of the issuing entity as ofits cut-off date. In accordance with the Compliance and DisclosureInterpretations, Section 200.03 (Rules 13a-18 and 15d-18, Servicer’s Assessmentof Compliance), this percentage must be reduced *pro rata*because it wasonly acting as special servicer of the Hilton Hawaiian Village Mortgage Loanfrom November 22, 2019 to December 31, 2019. As a result, it falls below the*de minimis* requirements in Item 1122 of Regulation AB and no suchassessment or attestation is required. In addition, CWCapital Asset ManagementLLC is an unaffiliated party that, as a result of such *pro rata*reduction of such percentage, is not a “servicer” that meets the criteria inItem 1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliancestatement is required.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Pooling andServicing Agreement, the Potomac Mills Mortgage Loan, the Hilton HawaiianVillage Mortgage Loan and the Walmart Shadow Anchored Portfolio MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the pooling andservicing agreement for the CFCRE 2016-C6 Transaction, the trust and servicingagreement for the Hilton USA 2016-HHV Transaction and the pooling and servicingagreement for the WFCM 2016-LC25 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed and approvedas specified in the transaction agreements). However, during the reportingperiod, the trustee did not perform any servicing function with respect to theservicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performedthe servicing function identified with respect to Item 1122(d)(2)(iii) ofRegulation AB, and each such party included Item 1122(d)(2)(iii) of RegulationAB in the assessment of compliance with applicable servicing criteria andaccountant’s attestation report for the subject transaction.  As a result,this Annual Report on Form 10-K does not include an assessment of compliancewith applicable servicing criteria of the trustee. One or more other servicersof the mortgage loans serviced under the Pooling and Servicing Agreement, thePotomac Mills Mortgage Loan, the Hilton Hawaiian Village Mortgage Loan and theWalmart Shadow Anchored Portfolio Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Deutsche Bank Trust CompanyAmericas acts as trustee of the 80 Park Plaza Mortgage Loan.  Pursuant tothe pooling and servicing agreement for the CGCMT 2016-C3 Transaction, thetrustee is required to provide an assessment of compliance with applicableservicing criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB(regarding advances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction with respect to the servicing criteria specified in Item 1122(d)(2)(iii)of Regulation AB.  The master servicer or the special servicer, to theextent required, performed the servicing function identified with respect toItem 1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for theSubject Transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the 80 Park Plaza Mortgage Loanhave delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer under the Pooling and Servicing Agreement and theprimary servicer of the Potomac Mills Mortgage Loan, the Hilton HawaiianVillage Mortgage Loan and the Walmart Shadow Anchored Portfolio Mortgage Loanto remit tax payments received from the escrow accounts of borrowers to localtaxing authorities, to report tax amounts due, to verify tax parcelinformation, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, thesevendors are “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Potomac Mills Mortgage Loan, the Hilton Hawaiian VillageMortgage Loan, the Walmart Shadow Anchored Portfolio Mortgage Loan and the 80Park Plaza Mortgage Loan listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as the certificate administrator pursuant to the relatedpooling and servicing agreement or trust and servicing agreement does notperform any activities that address servicing criteria with respect to theissuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combination that includes the 80 Park Plaza Mortgage Loan, the PotomacMills Mortgage Loan and the Hilton Hawaiian Village Mortgage Loan, (i) thereports on assessment of compliance with servicing criteria and attestationreports on assessment of compliance with servicing criteria of Midland LoanServices, a Division of PNC Bank, National Association as primary servicer ofthe 80 Park Plaza Mortgage Loan, Rialto Capital Advisors, LLC as specialservicer of the 80 Park Plaza Mortgage Loan, Deutsche Bank Trust CompanyAmericas as custodian of the 80 Park Plaza Mortgage Loan and Park Bridge LenderServices LLC as operating advisor of the Potomac Mills Mortgage Loan, listed onthe Exhibit Index are omitted from this Annual Report on Form 10-K as they arenot required to be included on this Annual Report on Form 10-K per Instruction3 to Item 1122 of Regulation AB because they are parties performing activitiesthat address servicing criteria relating to 5% or less of the assets of theissuing entity, and the report on assessment of compliance with servicingcriteria and attestation report on assessment of compliance with servicingcriteria of and CWCapital Asset Management LLC as special servicer of theHilton Hawaiian Village Mortgage Loan on and after November 22, 2019 toDecember 31, 2019 listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K for the reasons set forth in the Explanatory Notes above;and (ii) the servicer compliance statements of Midland Loan Services, aDivision of PNC Bank, National Association as primary servicer of the 80 ParkPlaza Mortgage Loan, Rialto Capital Advisors, LLC as special servicer of the 80Park Plaza Mortgage Loan and CWCapital Asset Management LLC as special servicerof the Hilton Hawaiian Village Mortgage Loan on and after November 22, 2019,listed on the Exhibit Index are omitted from this Annual Report on Form 10-K asthey are not required by Item 1123 of Regulation AB to be included on thisAnnual Report on Form 10-K because they are each an unaffiliated party that isnot a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

**Item 1B.  Unresolved Staff Comments.**

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

**Item 5.  Market for Registrant’s Common Equity,Related Stockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

**Item 7.  Management’s Discussion and Analysis ofFinancial Condition and Results of Operations.**

Omitted.

**Item 7A.  Quantitative and Qualitative DisclosuresAbout Market Risk.**

Omitted.

**Item 8.  Financial Statements and Supplementary Data.**

Omitted.

**Item 9.  Changes in and Disagreements WithAccountants on Accounting and Financial Disclosure.**

Omitted.

**Item 9A.  Controls and Procedures.**

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

**Item 10.  Directors, Executive Officers and CorporateGovernance.**

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

**Item 12.  Security Ownership of Certain BeneficialOwners and Management and Related Stockholder Matters.**

Omitted.

**Item 13.  Certain Relationships and RelatedTransactions, and Director Independence.**

Omitted.

**Item 14.  Principal Accounting Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

**Item 1112(b) of Regulation AB, Significant ObligorFinancial Information.**

No single obligor represents 10% or more of the pool assetsheld by the issuing entity. 

**Item 1114(b)(2) of Regulation AB, Significant EnhancementProvider Financial Information.**

No entity or group of affiliated entities provides any external creditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

**Item 1115(b) of Regulation AB, Certain DerivativesInstruments (Financial Information).**

No entity or group of affiliated entities provides anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

**Item 1117 of Regulation AB, Legal Proceedings.**

 

The registrant knows of nomaterial pending legal proceeding involving the trust or any party related tothe trust, other than routine litigation incidental to the duties of thoserespective parties, and the following, with respect to Deutsche Bank TrustCompany Americas, as trustee and as custodian, and Wells Fargo Bank, NationalAssociation, as certificate administrator and as custodian.

 

Deutsche Bank Trust Company Americas (“DBTCA”) andDeutsche Bank National Trust Company (“DBNTC”) have been sued byinvestors in civil litigation concerning their role as trustees of certain RMBStrusts. 

 

On June 18, 2014, a group of investors, including fundsmanaged by Blackrock Advisors, LLC, PIMCO-Advisors, L.P., and others, filed anaction against DBNTC and DBTCA in New York State Supreme Court alleging thatDBNTC and DBTCA failed to perform purported duties, as trustees for 544private-label RMBS trusts, to enforce breaches of representations andwarranties as to mortgage loans held by the trusts and to enforce breaches byservicers of their mortgage loan servicing obligations for the trusts. During the course of the litigation, plaintiffs dismissed the case from NewYork State Supreme Court and refiled two separate cases, one in the U.S.District Court for the Southern District of New York (the “*BlackRock*SDNYCase”) and the other in the Superior Court of California, Orange County(the “*BlackRock*California Case”).  Pursuant to asettlement among the parties, the *BlackRock*SDNY Case was dismissed onDecember 6, 2018 and the *BlackRock*California Case was dismissed onJanuary 11, 2019.

 

On September 27, 2017, DBTCA was addedas a defendant to a case brought by certain special purpose entities includingPhoenix Light SF Limited in the U.S. District Court for the Southern Districtof New York, in which the plaintiffs previously alleged incorrectly that DBNTCserved as trustee for all 43 of the trusts at issue.  On September 27,2017, plaintiffs filed a third amended complaint that names DBTCA as adefendant in addition to DBNTC.  DBTCA serves as trustee for one of the 43trusts at issue.  DBNTC serves as trustee for the other 42 trusts atissue.  Plaintiffs’ third amended complaint brings claims for violation ofthe U.S. Trust Indenture Act of 1939 (“TIA”); breach of contract; breachof fiduciary duty; negligence and gross negligence; violation of New York’sStreit Act; and breach of the covenant of good faith.  However, in thethird amended complaint, plaintiffs acknowledge that, before DBTCA was added tothe case, the court dismissed plaintiffs’ TIA Act claims, negligence and grossnegligence claims, Streit Act claims, claims for breach of the covenant of goodfaith, and certain theories of plaintiffs’ breach of contract claims, andplaintiffs only include these claims to preserve any rights on appeal. Plaintiffs allege damages of “hundreds of millions of dollars.”  OnNovember 13, 2017, DBNTC and DBTCA filed an answer to the third amendedcomplaint.  On December 7, 2018, DBNTC and DBTCA filed a motion forsummary judgment.  Also on December 7, 2018, plaintiffs, jointly withCommerzbank AG (*see* description of *Commerzbank* case below), fileda motion for partial summary judgment.  As of March 1, 2020, both motionsfor summary judgment have been briefed and are awaiting decision by the court.

 

On November 30, 2017, DBTCA was added as a defendant to acase brought by Commerzbank AG (“Commerzbank”) in the U.S. DistrictCourt for the Southern District of New York, in which Commerzbank previouslyalleged incorrectly that DBNTC served as trustee for all 50 of the trusts atissue.  On November 30, 2017, Commerzbank filed a second amended complaintthat names DBTCA as a defendant in addition to DBNTC.  DBTCA serves astrustee for 1 of the 50 trusts at issue.  DBNTC serves as trustee for theother 49 trusts at issue.  Commerzbank’s second amended complaint bringsclaims for violation of the TIA; breach of contract; breach of fiduciary duty;negligence; violation of the Streit Act; and breach of the covenant of goodfaith.  However, in the second amended complaint, Commerzbank acknowledgesthat, before DBTCA was added to the case, the court dismissed Commerzbank’s TIAclaims for the trusts governed by pooling and servicing agreements, as well asits Streit Act claims and claims for breach of the covenant of good faith, andCommerzbank only includes these claims to preserve any rights on appeal. The second amended complaint alleges that DBNTC and DBTCA caused Commerzbank tosuffer “hundreds of millions of dollars in losses,” but the complaint does notinclude a demand for money damages in a sum certain.  On January 29, 2018,DBNTC and DBTCA filed an answer to the second amended complaint.  OnDecember 7, 2018, DBNTC and DBTCA filed a motion for summary judgment. Also on December 7, 2018, Commerzbank, jointly with the *Phoenix Light*plaintiffs,filed a motion for partial summary judgment.  As of March 1, 2020, bothmotions for summary judgment have been briefed and are awaiting decision by thecourt.

 

On December 30, 2015, IKB International,S.A. in Liquidation and IKB Deutsche Industriebank A.G. (collectively, “IKB”),as an investor in 37 RMBS trusts, filed a summons with notice in the SupremeCourt of the State of New York, New York County, against DBNTC and DBTCA astrustees of the trusts.  On May 27, 2016, IKB served its complaintasserting claims for breach of contract, breach of fiduciary duty, breach ofduty to avoid conflicts of interest, violation of the Streit Act, violation ofthe TIA, violation of Regulation AB, and violation of Section 9 of the UniformCommercial Code.  IKB alleges that DBNTC and DBTCA are liable for overU.S. $268 million in damages.  On October 5, 2016, DBNTC and DBTCA,together with several other trustees defending lawsuits by IKB, filed a jointmotion to dismiss.  On January 6, 2017 and June 20, 2017, IKB voluntarilydismissed with prejudice all claims as to seven trusts.  As of March 1,2020, DBNTC and DBTCA’s motion to dismiss has been briefed and is awaitingdecision by the court.

It is DBTCA’s belief that it has nopending legal proceedings (including, based on DBTCA’s present evaluation, thelitigation disclosed in the foregoing paragraphs) that would materially affectits ability to perform its duties under the related servicing agreement forthis transaction.

 

Beginning on June 18, 2014, agroup of institutional investors filed civil complaints in the Supreme Court ofthe State of New York, New York County, and later the U.S. District Court forthe Southern District of New York, against Wells Fargo Bank, N.A., (“WellsFargo Bank”) in its capacity as trustee for certain residential mortgagebacked securities (“RMBS”) trusts.  The complaints against WellsFargo Bank alleged that the trustee caused losses to investors and assertedcauses of action based upon, among other things, the trustee's alleged failureto: (i) notify and enforce repurchase obligations of mortgage loan sellers forpurported breaches of representations and warranties, (ii) notify investors ofalleged events of default, and (iii) abide by appropriate standards of carefollowing alleged events of default. Relief sought included money damages in anunspecified amount, reimbursement of expenses, and equitable relief. InNovember 2018, Wells Fargo Bank reached an agreement, in which it denied anywrongdoing, to resolve such claims on a classwide basis for the 271 RMBS trustsat issue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the RMBStrusts. 

**Item 1119 of Regulation AB, Affiliations and CertainRelationships and Related Transactions.**

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on December 22, 2016 pursuant to Rule 424(b)(2).

**Item 1122 of Regulation AB, Compliance with ApplicableServicing Criteria.**

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AAto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 80 Park Plaza Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the CGCMT 2016-C3 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit O to the pooling andservicing agreement for the CGCMT 2016-C3 Transaction incorporated by referenceas Exhibit 4.2 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the CGCMT 2016-C3 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on such assessmentsof compliance with respect to the Potomac Mills Mortgage Loan, which is beingserviced and administered pursuant to the pooling and servicing agreement forthe CFCRE 2016-C6 Transaction, are attached hereto under Item 15 to this AnnualReport on Form 10-K. Attached as Schedule II to the pooling and servicingagreement for the CFCRE 2016-C6 Transaction incorporated by reference asExhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the CFCRE 2016-C6Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Hilton Hawaiian Village MortgageLoan, which is being serviced and administered pursuant to the trust andservicing agreement for the Hilton USA Trust 2016-HHV Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Lto the trust and servicing agreement for the Hilton USA Trust 2016-HHVTransaction incorporated by reference as Exhibit 4.4 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the Hilton USA Trust 2016-HHV Transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Walmart Shadow Anchored PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the WFCM 2016-LC25 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2016-LC25 Transaction incorporatedby reference as Exhibit 4.5 to this Annual Report on Form 10-K is a chart identifyingthe entities participating in a servicing function for the WFCM 2016-LC25Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The report on assessment of compliance with applicableservicing criteria furnished pursuant to Item 1122 of Regulation AB by MidlandLoan Services, a Division of PNC Bank National Association (“Midland”)discloses that a material instance of noncompliance occurred, as describedbelow:

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements andapplicable Commission requirements. Specifically, such reports: (A) Areprepared in accordance with timeframes and other terms set forth in thetransaction agreements”.  The noncompliance consisted of omitted orinaccurately reported fields as described in (1) and (2) below.  (1) Inconnection with other enhancements Midland made to its manual Schedule ALprocess, starting in April 2019, Midland developed and implemented new ScheduleAL reporting templates for each applicable CMBS transaction that closed priorto April 2019 and for each applicable CMBS transaction going forward. Related to this, Midland made certain template setup errors, along with relatedand other manual inputting of information errors, and the errors were notidentified prior to submission of the applicable Schedule AL Files in certaincases due to breakdowns in quality control.  (2) In one applicabletransaction, the related Schedule AL File for a given month was not saved properlyresulting in the prior month's Schedule AL File being submitted for the givenmonth instead of the correct Schedule AL File. 

The identified instances did notinvolve the servicing of assets included in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reportingprocess was enhanced in April of 2019, however, the process remained manualthroughout the 2019 calendar year.  Errors relating to certain Schedule ALFiles during 2019 were identified during the related audit.  Followingidentification, Midland made staffing changes and additional enhancements andimprovements to its processes and procedures to support its Schedule ALreporting obligations and expects to move to an automated solution for thisprocess.  

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to beincorrect. 

Report on Assessment of Compliance with Applicable ServicingCriteria Not Included

For the reasons discussed in theExplanatory Notes above, Midland is not a party performing activities thataddress servicing criteria relating to 5% or more of the assets of the issuingentity.  Therefore, the report of assessment of compliance with applicableservicing criteria for Midland has not been included as an exhibit to thisAnnual Report on Form 10-K.

**Item 1123 of Regulation AB, Servicer Compliance Statement.**

The servicer compliance statements are attached as Exhibitsto this Annual Report on Form 10-K.

**PART IV**

**Item 15. Exhibits, Financial Statement Schedules**

(a) The following is a list of documents filed as part ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Pooling and Servicing Agreement, dated as of December 1,2016, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, LNRPartners, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and TriMont Real Estate Advisors, LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 4.1 to the registrant’s CurrentReport on Form 8-K/A filed on January 27, 2017 under Commission File No.333-206677-12 and incorporated by reference herein).

4.2          Pooling and Servicing Agreement, dated as of November 1,2016, by and among Citigroup Commercial Mortgage Securities Inc., as Depositor,Midland Loan Services, a Division of PNC Bank, National Association, as MasterServicer, Rialto Capital Advisors, LLC, as Special Servicer, TriMont RealEstate Advisors, LLC, as Operating Advisor and Asset Representations Reviewer,Citibank, N.A., as Certificate Administrator and Deutsche Bank Trust CompanyAmericas, as Trustee (filed as Exhibit 99.10 to the registrant’s Current Reporton Form 8-K filed on December 22, 2016 under Commission File No. 333-206677-12and incorporated by reference herein).

4.3          Pooling and Servicing Agreement, dated as of November 1,2016, by and among CCRE Commercial Mortgage Securities, L.P., as Depositor,Wells Fargo Bank, National Association, as Master Servicer, Rialto CapitalAdvisors, LLC, as Special Servicer, AEGON USA Realty Advisors, LLC, as Potomac Mills Special Servicer, Wilmington Trust, National Association, asTrustee, Wells Fargo Bank, National Association, as Certificate Administrator,Paying Agent and Custodian, Park Bridge Lender Services LLC, as OperatingAdvisor and Park Bridge Lender Services LLC, as Asset Representations Reviewer(filed as Exhibit 99.9 to the registrant’s Current Report on Form 8-K filed onDecember 22, 2016 under Commission File No. 333-206677-12 and incorporated byreference herein).

4.4          Trust and Servicing Agreement, dated as of November 28,2016, by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, Wells Fargo Bank, National Association, as Servicer, AEGON USARealty Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee (filed as Exhibit 99.7 to the registrant’s CurrentReport on Form 8-K filed on December 22, 2016 under Commission File No.333-206677-12 and incorporated by reference herein).

4.5          Pooling and Servicing Agreement, dated as of December 1,2016, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,CWCapital Asset Management LLC, as General Special Servicer, NationalCooperative Bank, N.A. as NCB Master Servicer and NCB Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and Asset Representations Reviewer (filed as Exhibit 99.8 tothe registrant’s Current Report on Form 8-K filed on December 22, 2016 underCommission File No. 333-206677-12 and incorporated by reference herein).

4.6          Agreement Between Note Holders, dated as of October 21,2016, by and between Barclays Bank PLC, as Initial Note A- 1 Holder, InitialNote A-2 Holder and Initial Note A-3 Holder (filed as Exhibit 99.12 to theregistrant’s Current Report on Form 8-K/A filed on January 27, 2017 underCommission File No. 333-206677-12 and incorporated by reference herein).

4.7          Co-Lender Agreement, dated as of September 29, 2016,between Ladder Capital Finance I LLC, as Note A- 1 Holder, Note A-2 Holder,Note A-3 Holder, and Note A-4 Holder (filed as Exhibit 99.15 to theregistrant’s Current Report on Form 8-K filed on December 22, 2016 underCommission File No. 333-206677-12 and incorporated by reference herein).

4.8          Agreement Between Note Holders, dated as of November 22,2016, by and between Wells Fargo Bank, National Association, asInitial Note A-1 Holder, Initial Note A-2 Holder and Initial Note A-3 Holder(filed as Exhibit 99.16 to the registrant’s Current Report on Form 8-K filed onDecember 22, 2016 under Commission File No. 333-206677-12 and incorporated byreference herein).

4.9          Agreement Between Note Holders, dated as of December 19,2016, by and between Barclays Bank PLC, as Initial Note A- 1 Holder and InitialNote A-2 Holder (filed as Exhibit 99.17 to the registrant’s Current Report onForm 8-K filed on December 22, 2016 under Commission File No. 333-206677-12 andincorporated by reference herein).

4.10        Co-Lender Agreement, dated as of November 22, 2016,between Ladder Capital Finance I LLC for itself to the extent of its interest,and on behalf of Series TRS of Ladder Capital Finance I LLC, and Series TRS OfLadder Capital Finance I LLC, as Note A-1 Holder, Note A-2 Holder and Note A-3Holder (filed as Exhibit 99.19 to the registrant’s Current Report on Form 8-Kfiled on December 22, 2016 under Commission File No. 333-206677-12 andincorporated by reference herein).

4.11        Agreement Between Note Holders, dated as of December 9,2016, by and between Silverpeak Real Estate Finance LLC, as Initial Note A-1Holder andInitial Note A-2 Holder) (filed as Exhibit 99.20 to theregistrant’s Current Report on Form 8-K filed on December 22, 2016  underCommission File No. 333-206677-12 and incorporated by reference herein).

4.12        Amended and Restated Co-Lender Agreement, dated as ofOctober 26, 2016, between Citigroup Global Markets Realty Corp., as Note A-1Holder and Note A-3 Holder and Ladder Capital Finance VI TRS LLC, as  NoteA-2 Holder, Note A-4A Holder And Note A-4B Holder  (filed as Exhibit 99.18to the registrant’s Current Report on Form 8-K filed on December 22, 2016 underCommission File No. 333-206677-12 and incorporated by reference herein).

4.13        Agreement Between Noteholders, dated as of November 17,2016, by and between Société Générale, as Initial Note A-1 Holder, Initial A-2Holder, Initial A-3 Holder, Initial B-1 Holder, Initial B-2 Holder and InitialB-3 Holder, Bank of America, N.A., as Initial Note A-4 Holder, Initial Note A-5Holder, Initial B-4 Holder and Initial B-5 Holder, Cantor Commercial RealEstate Lending, L.P., as Initial Note A-6 Holder, Initial Note A-7 Holder,Initial Note A-8 Holder, Initial B-6 Holder, Initial B-7 Holder and Initial B-8Holder and Barclays Bank PLC, as Initial Note A-9 Holder, Initial Note A-10Holder, Initial B-9 Holder and Initial B-10 Holder (filed as Exhibit 99.14 tothe registrant’s Current Report on Form 8-K filed on December 22, 2016 underCommission File No. 333-206677-12 and incorporated by reference herein).

4.14        Co-Lender Agreement, dated as of November 28, 2016, byand among JPMorgan Chase Bank, National Association, Deutsche Bank Ag, New YorkBranch, Goldman Sachs Mortgage Company, Barclays Bank PLC, Morgan Stanley Bank,N.A. and Cantor Commercial Real Estate Lending, L.P. (filed as Exhibit 99.11 tothe registrant’s Current Report on Form 8-K filed on December 22, 2016 underCommission File No. 333-206677-12 and incorporated by reference herein).

4.15        Co-Lender Agreement, dated as of November 8, 2016,between Ladder Capital Finance I LLC for itself to the extent of its interest,and on behalf of Series TRS of Ladder Capital Finance I LLC, and Series TRS OfLadder Capital Finance I LLC,as Note A-1 Holder and Note A-2 Holder(filed as Exhibit 99.13 to the registrant’s Current Report on Form 8-K filed onDecember 22, 2016 under Commission File No. 333-206677-12 and incorporated byreference herein).

31           Rule 13a-14(d)/15d-14(d)Certifications.

33           Reports on assessment of compliance with servicing criteria for asset-backedsecurities.

33.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

33.2        LNR Partners, LLC, asSpecial Servicer

33.3        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

33.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.5        Wells Fargo Bank, NationalAssociation, as Custodian

33.6        Trimont Real EstateAdvisors, LLC, as Operating Advisor

33.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

33.8        National Tax Search, LLC,as Servicing Function Participant

33.9        Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the 80 Park Plaza Mortgage Loan (Omitted. See Explanatory Notes.)

33.10      Rialto Capital Advisors, LLC, as Special Servicer of the 80 Park Plaza MortgageLoan (Omitted. See Explanatory Notes.)

33.11      Deutsche Bank Trust Company Americas, as Trustee and Custodian of the 80 ParkPlaza Mortgage Loan (Omitted. See Explanatory Notes.)

33.12      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the 80 Park Plaza Mortgage Loan (seeExhibit 33.6)

33.13      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Potomac Mills Mortgage Loan (seeExhibit 33.1)

33.14      AEGON USA RealtyAdvisors, LLC, as Special Servicer of the Potomac Mills Mortgage Loan

33.15      Wilmington Trust, National Association, as Trustee of the Potomac MillsMortgage Loan (Omitted. See Explanatory Notes.)

33.16      Wells Fargo Bank, NationalAssociation, as Custodian of the Potomac Mills Mortgage Loan (see Exhibit 33.5)

33.17      Park Bridge Lender Services LLC, as Operating Advisor of the Potomac MillsMortgage Loan (Omitted. See Explanatory Notes.)

33.18      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Potomac MillsMortgage Loan (see Exhibit 33.7)

33.19      National Tax Search, LLC,as Servicing Function Participant of the Potomac Mills Mortgage Loan (seeExhibit 33.8)

33.20      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Hilton Hawaiian Village Mortgage Loan(see Exhibit 33.1)

33.21      AEGON USA RealtyAdvisors, LLC, as Special Servicer of the Hilton Hawaiian Village Mortgage Loanprior to November 22, 2019 (see Exhibit 33.14)

33.22      CWCapital Asset Management LLC, as Special Servicer of the Hilton HawaiianVillage Mortgage Loan on and after November 22, 2019 (Omitted. See ExplanatoryNotes.)

33.23      Wilmington Trust, National Association, as Trustee of the Hilton HawaiianVillage Mortgage Loan (Omitted. See Explanatory Notes.)

33.24      Wells Fargo Bank, NationalAssociation, as Custodian of the Hilton Hawaiian Village Mortgage Loan (seeExhibit 33.5)

33.25      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Hilton HawaiianVillage Mortgage Loan (see Exhibit 33.7)

33.26      National Tax Search, LLC,as Servicing Function Participant of the Hilton Hawaiian Village Mortgage Loan(see Exhibit 33.8)

33.27      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Walmart Shadow Anchored PortfolioMortgage Loan (see Exhibit 33.1)

33.28      C-III Asset ManagementLLC, as Special Servicer of the Walmart Shadow Anchored Portfolio Mortgage Loan

33.29      Wilmington Trust, National Association, as Trustee of the Walmart ShadowAnchored Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.30      Wells Fargo Bank, NationalAssociation, as Custodian of the Walmart Shadow Anchored Portfolio MortgageLoan (see Exhibit 33.5)

33.31      Pentalpha SurveillanceLLC, as Operating Advisor of the Walmart Shadow Anchored Portfolio MortgageLoan

33.32      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Walmart ShadowAnchored Portfolio Mortgage Loan (see Exhibit 33.7)

33.33      National Tax Search, LLC,as Servicing Function Participant of the Walmart Shadow Anchored PortfolioMortgage Loan (see Exhibit 33.8)

33.34      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Quantum Park Mortgage Loan (see Exhibit33.1)

33.35      LNR Partners, LLC, asSpecial Servicer of the Quantum Park Mortgage Loan (see Exhibit 33.2)

33.36      Wilmington Trust, National Association, as Trustee of the Quantum Park MortgageLoan (Omitted. See Explanatory Notes.)

33.37      Wells Fargo Bank, NationalAssociation, as Custodian of the Quantum Park Mortgage Loan (see Exhibit 33.5)

33.38      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the Quantum Park Mortgage Loan (seeExhibit 33.6)

33.39      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Quantum ParkMortgage Loan (see Exhibit 33.7)

33.40      National Tax Search, LLC,as Servicing Function Participant of the Quantum Park Mortgage Loan (seeExhibit 33.8)

33.41      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 1140 Avenue of the Americas MortgageLoan (see Exhibit 33.1)

33.42      LNR Partners, LLC, asSpecial Servicer of the 1140 Avenue of the Americas Mortgage Loan (see Exhibit33.2)

33.43      Wilmington Trust, National Association, as Trustee of the 1140 Avenue of theAmericas Mortgage Loan (Omitted. See Explanatory Notes.)

33.44      Wells Fargo Bank, NationalAssociation, as Custodian of the 1140 Avenue of the Americas Mortgage Loan (seeExhibit 33.5)

33.45      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the 1140 Avenue of the Americas MortgageLoan (see Exhibit 33.6)

33.46      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 1140 Avenue ofthe Americas Mortgage Loan (see Exhibit 33.7)

33.47      National Tax Search, LLC,as Servicing Function Participant of the 1140 Avenue of the Americas MortgageLoan (see Exhibit 33.8)

33.48      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Fremaux Town Center Mortgage Loan (seeExhibit 33.1)

33.49      LNR Partners, LLC, as SpecialServicer of the Fremaux Town Center Mortgage Loan (see Exhibit 33.2)

33.50      Wilmington Trust, National Association, as Trustee of the Fremaux Town CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.51      Wells Fargo Bank, NationalAssociation, as Custodian of the Fremaux Town Center Mortgage Loan (see Exhibit33.5)

33.52      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the Fremaux Town Center Mortgage Loan(see Exhibit 33.6)

33.53      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Fremaux TownCenter Mortgage Loan (see Exhibit 33.7)

33.54      National Tax Search, LLC,as Servicing Function Participant of the Fremaux Town Center Mortgage Loan (seeExhibit 33.8)

33.55      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Midwest Industrial Portfolio MortgageLoan (see Exhibit 33.1)

33.56      LNR Partners, LLC, asSpecial Servicer of the Midwest Industrial Portfolio Mortgage Loan (see Exhibit33.2)

33.57      Wilmington Trust, National Association, as Trustee of the Midwest IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.58      Wells Fargo Bank, NationalAssociation, as Custodian of the Midwest Industrial Portfolio Mortgage Loan(see Exhibit 33.5)

33.59      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the Midwest Industrial PortfolioMortgage Loan (see Exhibit 33.6)

33.60      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the MidwestIndustrial Portfolio Mortgage Loan (see Exhibit 33.7)

33.61      National Tax Search, LLC,as Servicing Function Participant of the Midwest Industrial Portfolio MortgageLoan (see Exhibit 33.8)

33.62      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Redwood MHC Portfolio Mortgage Loan(see Exhibit 33.1)

33.63      LNR Partners, LLC, asSpecial Servicer of the Redwood MHC Portfolio Mortgage Loan (see Exhibit 33.2)

33.64      Wilmington Trust, National Association, as Trustee of the Redwood MHC PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.65      Wells Fargo Bank, NationalAssociation, as Custodian of the Redwood MHC Portfolio Mortgage Loan (seeExhibit 33.5)

33.66      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the Redwood MHC Portfolio Mortgage Loan(see Exhibit 33.6)

33.67      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Redwood MHCPortfolio Mortgage Loan (see Exhibit 33.7)

33.68      National Tax Search, LLC,as Servicing Function Participant of the Redwood MHC Portfolio Mortgage Loan(see Exhibit 33.8)

33.69      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the DoubleTree by Hilton Tempe MortgageLoan (see Exhibit 33.1)

33.70      LNR Partners, LLC, asSpecial Servicer of the DoubleTree by Hilton Tempe Mortgage Loan (see Exhibit33.2)

33.71      Wilmington Trust, National Association, as Trustee of the DoubleTree by HiltonTempe Mortgage Loan (Omitted. See Explanatory Notes.)

33.72      Wells Fargo Bank, NationalAssociation, as Custodian of the DoubleTree by Hilton Tempe Mortgage Loan (seeExhibit 33.5)

33.73      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the DoubleTree by Hilton Tempe MortgageLoan (see Exhibit 33.6)

33.74      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the DoubleTree byHilton Tempe Mortgage Loan (see Exhibit 33.7)

33.75      National Tax Search, LLC,as Servicing Function Participant of the DoubleTree by Hilton Tempe MortgageLoan (see Exhibit 33.8)

34           Attestationreports on assessment of compliance with servicing criteria for asset-backedsecurities.

34.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2        LNR Partners, LLC, asSpecial Servicer

34.3        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

34.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.5        Wells Fargo Bank, NationalAssociation, as Custodian

34.6        Trimont Real EstateAdvisors, LLC, as Operating Advisor

34.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

34.8        National Tax Search, LLC,as Servicing Function Participant

34.9        Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the 80 Park Plaza Mortgage Loan (Omitted. See Explanatory Notes.)

34.10      Rialto Capital Advisors, LLC, as Special Servicer of the 80 Park Plaza MortgageLoan (Omitted. See Explanatory Notes.)

34.11      Deutsche Bank Trust Company Americas, as Trustee and Custodian of the 80 ParkPlaza Mortgage Loan (Omitted. See Explanatory Notes.)

34.12      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the 80 Park Plaza Mortgage Loan (seeExhibit 34.6)

34.13      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Potomac Mills Mortgage Loan (seeExhibit 34.1)

34.14      AEGON USA RealtyAdvisors, LLC, as Special Servicer of the Potomac Mills Mortgage Loan

34.15      Wilmington Trust, National Association, as Trustee of the Potomac MillsMortgage Loan (Omitted. See Explanatory Notes.)

34.16      Wells Fargo Bank, NationalAssociation, as Custodian of the Potomac Mills Mortgage Loan (see Exhibit 34.5)

34.17      Park Bridge Lender Services LLC, as Operating Advisor of the Potomac MillsMortgage Loan (Omitted. See Explanatory Notes.)

34.18      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Potomac MillsMortgage Loan (see Exhibit 34.7)

34.19      National Tax Search, LLC,as Servicing Function Participant of the Potomac Mills Mortgage Loan (seeExhibit 34.8)

34.20      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Hilton Hawaiian Village Mortgage Loan(see Exhibit 34.1)

34.21      AEGON USA RealtyAdvisors, LLC, as Special Servicer of the Hilton Hawaiian Village Mortgage Loanprior to November 22, 2019 (see Exhibit 34.14)

34.22      CWCapital Asset Management LLC, as Special Servicer of the Hilton HawaiianVillage Mortgage Loan on and after November 22, 2019 (Omitted. See ExplanatoryNotes.)

34.23      Wilmington Trust, National Association, as Trustee of the Hilton HawaiianVillage Mortgage Loan (Omitted. See Explanatory Notes.)

34.24      Wells Fargo Bank, NationalAssociation, as Custodian of the Hilton Hawaiian Village Mortgage Loan (seeExhibit 34.5)

34.25      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Hilton HawaiianVillage Mortgage Loan (see Exhibit 34.7)

34.26      National Tax Search, LLC,as Servicing Function Participant of the Hilton Hawaiian Village Mortgage Loan(see Exhibit 34.8)

34.27      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Walmart Shadow Anchored Portfolio MortgageLoan (see Exhibit 34.1)

34.28      C-III Asset ManagementLLC, as Special Servicer of the Walmart Shadow Anchored Portfolio Mortgage Loan

34.29      Wilmington Trust, National Association, as Trustee of the Walmart ShadowAnchored Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.30      Wells Fargo Bank, NationalAssociation, as Custodian of the Walmart Shadow Anchored Portfolio MortgageLoan (see Exhibit 34.5)

34.31      Pentalpha SurveillanceLLC, as Operating Advisor of the Walmart Shadow Anchored Portfolio MortgageLoan

34.32      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Walmart ShadowAnchored Portfolio Mortgage Loan (see Exhibit 34.7)

34.33      National Tax Search, LLC,as Servicing Function Participant of the Walmart Shadow Anchored PortfolioMortgage Loan (see Exhibit 34.8)

34.34      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Quantum Park Mortgage Loan (see Exhibit34.1)

34.35      LNR Partners, LLC, asSpecial Servicer of the Quantum Park Mortgage Loan (see Exhibit 34.2)

34.36      Wilmington Trust, National Association, as Trustee of the Quantum Park MortgageLoan (Omitted. See Explanatory Notes.)

34.37      Wells Fargo Bank, NationalAssociation, as Custodian of the Quantum Park Mortgage Loan (see Exhibit 34.5)

34.38      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the Quantum Park Mortgage Loan (seeExhibit 34.6)

34.39      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Quantum ParkMortgage Loan (see Exhibit 34.7)

34.40      National Tax Search, LLC,as Servicing Function Participant of the Quantum Park Mortgage Loan (seeExhibit 34.8)

34.41      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 1140 Avenue of the Americas MortgageLoan (see Exhibit 34.1)

34.42      LNR Partners, LLC, asSpecial Servicer of the 1140 Avenue of the Americas Mortgage Loan (see Exhibit34.2)

34.43      Wilmington Trust, National Association, as Trustee of the 1140 Avenue of theAmericas Mortgage Loan (Omitted. See Explanatory Notes.)

34.44      Wells Fargo Bank, NationalAssociation, as Custodian of the 1140 Avenue of the Americas Mortgage Loan (seeExhibit 34.5)

34.45      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the 1140 Avenue of the Americas MortgageLoan (see Exhibit 34.6)

34.46      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 1140 Avenue ofthe Americas Mortgage Loan (see Exhibit 34.7)

34.47      National Tax Search, LLC,as Servicing Function Participant of the 1140 Avenue of the Americas MortgageLoan (see Exhibit 34.8)

34.48      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Fremaux Town Center Mortgage Loan (seeExhibit 34.1)

34.49      LNR Partners, LLC, as SpecialServicer of the Fremaux Town Center Mortgage Loan (see Exhibit 34.2)

34.50      Wilmington Trust, National Association, as Trustee of the Fremaux Town CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.51      Wells Fargo Bank, NationalAssociation, as Custodian of the Fremaux Town Center Mortgage Loan (see Exhibit34.5)

34.52      Trimont Real Estate Advisors,LLC, as Operating Advisor of the Fremaux Town Center Mortgage Loan (see Exhibit34.6)

34.53      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Fremaux TownCenter Mortgage Loan (see Exhibit 34.7)

34.54      National Tax Search, LLC,as Servicing Function Participant of the Fremaux Town Center Mortgage Loan (seeExhibit 34.8)

34.55      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Midwest Industrial Portfolio MortgageLoan (see Exhibit 34.1)

34.56      LNR Partners, LLC, asSpecial Servicer of the Midwest Industrial Portfolio Mortgage Loan (see Exhibit34.2)

34.57      Wilmington Trust, National Association, as Trustee of the Midwest IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.58      Wells Fargo Bank, NationalAssociation, as Custodian of the Midwest Industrial Portfolio Mortgage Loan(see Exhibit 34.5)

34.59      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the Midwest Industrial PortfolioMortgage Loan (see Exhibit 34.6)

34.60      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the MidwestIndustrial Portfolio Mortgage Loan (see Exhibit 34.7)

34.61      National Tax Search, LLC, asServicing Function Participant of the Midwest Industrial Portfolio MortgageLoan (see Exhibit 34.8)

34.62      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Redwood MHC Portfolio Mortgage Loan(see Exhibit 34.1)

34.63      LNR Partners, LLC, asSpecial Servicer of the Redwood MHC Portfolio Mortgage Loan (see Exhibit 34.2)

34.64      Wilmington Trust, National Association, as Trustee of the Redwood MHC PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.65      Wells Fargo Bank, NationalAssociation, as Custodian of the Redwood MHC Portfolio Mortgage Loan (seeExhibit 34.5)

34.66      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the Redwood MHC Portfolio Mortgage Loan(see Exhibit 34.6)

34.67      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Redwood MHCPortfolio Mortgage Loan (see Exhibit 34.7)

34.68      National Tax Search, LLC,as Servicing Function Participant of the Redwood MHC Portfolio Mortgage Loan(see Exhibit 34.8)

34.69      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the DoubleTree by Hilton Tempe MortgageLoan (see Exhibit 34.1)

34.70      LNR Partners, LLC, asSpecial Servicer of the DoubleTree by Hilton Tempe Mortgage Loan (see Exhibit34.2)

34.71      Wilmington Trust, National Association, as Trustee of the DoubleTree by HiltonTempe Mortgage Loan (Omitted. See Explanatory Notes.)

34.72      Wells Fargo Bank, NationalAssociation, as Custodian of the DoubleTree by Hilton Tempe Mortgage Loan (seeExhibit 34.5)

34.73      Trimont Real EstateAdvisors, LLC, as Operating Advisor of the DoubleTree by Hilton Tempe MortgageLoan (see Exhibit 34.6)

34.74      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the DoubleTree byHilton Tempe Mortgage Loan (see Exhibit 34.7)

34.75      National Tax Search, LLC,as Servicing Function Participant of the DoubleTree by Hilton Tempe MortgageLoan (see Exhibit 34.8)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2        LNR Partners, LLC, asSpecial Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the 80 Park Plaza Mortgage Loan (Omitted. See Explanatory Notes.)

35.5        Rialto Capital Advisors, LLC, as Special Servicer of the 80 Park Plaza MortgageLoan (Omitted. See Explanatory Notes.)

35.6        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Potomac Mills Mortgage Loan (seeExhibit 35.1)

35.7        AEGON USA Realty Advisors,LLC, as Special Servicer of the Potomac Mills Mortgage Loan

35.8        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Hilton Hawaiian Village Mortgage Loan(see Exhibit 35.1)

35.9        AEGON USA Realty Advisors,LLC, as Special Servicer of the Hilton Hawaiian Village Mortgage Loan prior toNovember 22, 2019 (see Exhibit 35.7)

35.10      CWCapital Asset Management LLC, as Special Servicer of the Hilton HawaiianVillage Mortgage Loan on and after November 22, 2019 (Omitted. See ExplanatoryNotes.)

35.11      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Walmart Shadow Anchored PortfolioMortgage Loan (see Exhibit 35.1)

35.12      C-III Asset ManagementLLC, as Special Servicer of the Walmart Shadow Anchored Portfolio Mortgage Loan

35.13      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Quantum Park Mortgage Loan (see Exhibit35.1)

35.14      LNR Partners, LLC, asSpecial Servicer of the Quantum Park Mortgage Loan (see Exhibit 35.2)

35.15      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 1140 Avenue of the Americas MortgageLoan (see Exhibit 35.1)

35.16      LNR Partners, LLC, asSpecial Servicer of the 1140 Avenue of the Americas Mortgage Loan (see Exhibit35.2)

35.17      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Fremaux Town Center Mortgage Loan (seeExhibit 35.1)

35.18      LNR Partners, LLC, asSpecial Servicer of the Fremaux Town Center Mortgage Loan (see Exhibit 35.2)

35.19      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Midwest Industrial Portfolio MortgageLoan (see Exhibit 35.1)

35.20      LNR Partners, LLC, asSpecial Servicer of the Midwest Industrial Portfolio Mortgage Loan (see Exhibit35.2)

35.21      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Redwood MHC Portfolio Mortgage Loan(see Exhibit 35.1)

35.22      LNR Partners, LLC, asSpecial Servicer of the Redwood MHC Portfolio Mortgage Loan (see Exhibit 35.2)

35.23      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the DoubleTree by Hilton Tempe MortgageLoan (see Exhibit 35.1)

35.24      LNR Partners, LLC, asSpecial Servicer of the DoubleTree by Hilton Tempe Mortgage Loan (see Exhibit35.2)

99.1        Mortgage Loan Purchase Agreement, dated as of December 9,2016, between Wells Fargo Commercial Mortgage Securities, Inc. and Wells FargoBank, National Association (filed as Exhibit 99.3 to the registrant’s CurrentReport on Form 8-K/A filed on January 27, 2017 under Commission File No.333-206677-12 and incorporated by reference herein)

99.2        Mortgage Loan Purchase Agreement, dated as of December 9,2016, between Wells Fargo Commercial Mortgage Securities, Inc. and BarclaysBank PLC (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K/A filed on January 27, 2017 under Commission File No. 333-206677-12 andincorporated by reference herein)

99.3        Mortgage Loan Purchase Agreement, dated as of December 9,2016, among Wells Fargo Commercial Mortgage Securities, Inc., Ladder CapitalFinance LLC and Ladder Capital Finance Holdings LLLP, Series REIT of LadderCapital Finance Holdings LLLP, Series TRS of Ladder Capital Finance HoldingsLLLP (filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K/Afiled on January 27, 2017 under Commission File No. 333-206677-12 andincorporated by reference herein)

99.4        Mortgage Loan Purchase Agreement, dated as of December 9,2016, between Wells Fargo Commercial Mortgage Securities, Inc. and SilverpeakReal Estate Finance LLC (filed as Exhibit 99.4 to the registrant’s CurrentReport on Form 8-K/A filed on January 27, 2017 under Commission File No.333-206677-12 and incorporated by reference herein)

99.5        Mortgage Loan Purchase Agreement, dated as of December 9,2016, between Wells Fargo Commercial Mortgage Securities, Inc. and RialtoMortgage Finance, LLC (filed as Exhibit 99.5 to the registrant’s Current Reporton Form 8-K/A filed on January 27, 2017 under Commission File No. 333-206677-12and incorporated by reference herein)

99.6        Mortgage Loan Purchase Agreement, dated as of December 9,2016, between Wells Fargo Commercial Mortgage Securities, Inc. and C-IIICommercial Mortgage LLC (filed as Exhibit 99.6 to the registrant’s CurrentReport on Form 8-K/A filed on January 27, 2017 under Commission File No. 333-206677-12and incorporated by reference herein)

(b)  The exhibits required to be filed by the Registrant pursuant to Item 601 ofRegulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

Pursuant to the requirements of Section 13 or 15(d) of theSecurities Exchange Act of 1934, the registrant has duly caused this report tobe signed on its behalf by the undersigned, thereunto duly authorized.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 23, 2020