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RSMUS LLP

 

 

**Report ofIndependent Registered Public Accounting Firm**

 

 

ManagementCommittee

GreystoneServicing Company LLC and Subsidiaries

 

 

Wehave examined management’s assertion, included in the accompanying Management’sReport on Assessment of 2021 Compliance with Applicable Regulation AB ServicingCriteria (Management’s Assertion), that Greystone Servicing Company LLC andSubsidiaries (the Company) complied with the servicing criteria set forth inItem 1122(d) of the Securities and Exchange Commission’s (SEC) Regulation ABfor services by the Company that are encompassed by contractual obligations toperform Regulation AB reporting (the Platforms), including only thoseasset-backed securities transactions defined below, as of and for the yearended December 31, 2021, excluding the criteria set forth in Appendix II, whichmanagement has determined are not applicable to the activities performed by theCompany with respect to the Platforms covered by this report. Appendix I toManagement’s Assertion identifies the individual asset-backed transactionsdefined by management as constituting the Platforms. Management is responsiblefor the Company’s compliance with the applicable servicing criteria. Ourresponsibility is to express an opinion on management’s assertion about theCompany’s compliance with the applicable servicing criteria based on ourexamination.

 

Ourexamination was conducted in accordance with attestation standards of thePublic Company Accounting Oversight Board (United States) and, accordingly,included examining, on a test basis, evidence about the Company’s compliancewith the applicable servicing criteria, including tests on a sample basis ofthe servicing activities related to the Platforms, determining whether theCompany performed those activities in compliance with the servicing criteriaduring the specified period and performing such other procedures as weconsidered necessary in the circumstances. Our procedures were limited toselected servicing activities performed by the Company during the periodcovered by this report and, accordingly, such samples may not have includedservicing activities related to each asset- backed transaction in thePlatforms. Further, an examination is not designed to detect noncompliancearising from errors that may have occurred prior to the period specified abovethat may have affected the balances or amounts calculated or reported by theCompany during the period covered by this report. We believe that ourexamination provides a reasonable basis for our opinion. Our examination doesnot provide a legal determination on the Company’s compliance with theservicing criteria.

 

Asdescribed in Management’s Assertion, for servicing criterion 1122 (d)(1)(ii),the Company has engaged vendors to perform certain activities required by thisservicing criterion. The Company has determined that these vendors are notconsidered “servicers” as defined in Item 1101(j) of Regulation AB, and theCompany has elected to take responsibility for assessing compliance with theservicing criterion applicable to these vendors as permitted by Section 200.06of the Compliance and Disclosure Interpretations (Section 200.06). As permittedby Section 200.06, the Company has asserted that it has policies and proceduresin place designed to provide reasonable assurance that the vendor’s activitiescomply in all material respects with the servicing criterion applicable tothese vendors. The Company is solely responsible for determining that it meetsthe SEC requirements to apply Section 200.06 for the vendors and relatedcriterion as described in its assertion, and we performed no procedures withrespect to the Company’s determination of its eligibility to use Section200.06.

 

Inour opinion, management’s assertion that Greystone Servicing Company LLC andSubsidiaries complied with the aforementioned applicable servicing criteria asof and for the year ended December 31, 2021, for the Platforms is fairlystated, in all material respects.

 

 

/s/RSM US LLP

Denver,Colorado 

March1, 2022

 

 

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** **

**Appendix II**

 

**ApplicableServicing Criteria Specified in Paragraph (d) of Item 1122 of Regulation AB forthe Following Platforms**

** **

|                                    | **Platform**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |
|-----------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| **Section**                             | **Regulation AB  Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **A** | **B** | **C** | **D** |
| **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** | ** **

**X** | ** **

**X** | ** **

**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** | ** **

**X** | ** **

**X*** | ** **

**X** |
| 1122(d)(1)(iii)                         | Any  requirements in the transaction agreements to maintain a back-up servicer for  the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                         |   |   |   |   |
| 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** | ** **

** **

**X** | ** **

** **

**X** | ** **

** **

**X** |
| 1122(d)(1)(v)                           | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                   | ** **

**X** | ** **

**X** | ** **

**X** | ** **

**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 of receipt, or  such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                   | ** **

**X** | ** **

**X** | ** **

**X*** | ** **

**X** |
| 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** | **X** | **X*** | **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** | ** **

**X** | ** **

**X*** | ** **

**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** | ** **

** **

**X** | ** **

** **

**X*** | ** **

** **

**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 § 240.13k-1(b) (1) of this chapter.                                                                                                                                      | ** **

** **

**X** | ** **

** **

**X** | ** **

** **

**X** | ** **

** **

**X** |
| 1122(d)(2)(vi)                          | Unissued  checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **X** | **X** | **X** | **X** |
| 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:                                                                                                                                                                                                                                                                                                                           |   |   |   |   |
| 1122(d)(2)(vii)(A)                      | Are  mathematically accurate.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | **X** | **X** | **X*** | **X** |
| 1122(d)(2)(vii)(B)                      | Are  prepared within 30 calendar days after the bank statement cutoff date, or  such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X** | ** **

**X** | ** **

**X*** | ** **

**X** |
| 1122(d)(2)(vii)(C)                      | Are  reviewed and approved by someone other than the person who prepared the  reconciliation.                                                                                                                                                                                                                                                                                                                                                                                                                               | **X** | **X** | **X*** | **X** |
| 1122(d)(2)(vii)(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** | ** **

**X** | ** **

**X*** | ** **

**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:                                                                                                                                                                                                                                                                                                                |   |   |   |   |
| 1122(d)(3)(i)(A)                        | Are  prepared in accordance with timeframes and other terms set forth in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                       | **X** | **X** | **X** |   |
| 1122(d)(3)(i)(B)                        | Provide  information calculated in accordance with the terms specified in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                      |   | **X** |   |   |
| 1122(d)(3)(i)(C)                        | Are  filed with the Commission as required by its rules and regulations.                                                                                                                                                                                                                                                                                                                                                                                                                                                    |   |   |   |   |
| 1122(d)(3)(i)(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.                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X** | ** **

**X** |   |   |
| 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** |   | ** **

**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** | ** **

**X** |   | ** **

**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** | ** **

**X** |   | ** **

**X** |
| **Pool Asset  Administration**          |
| 1122(d)(4)(i)                           | Collateral  or security on pool assets is maintained as required by the transaction  agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                            | **X** | **X** | **X** | **X** |
| 1122(d)(4)(ii)                          | Pool  assets and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                              | **X** | **X** | **X** | **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** | ** **

**X** | ** **

**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 applicable servicer's obligor records  maintained no more than two business days after receipt, or such other number  of days specified in the transaction agreements, and allocated to principal,  interest or other items (e.g., escrow) in accordance with the related pool asset  documents.                                                                                               | ** **

** **

** **

**X** | ** **

** **

** **

**X** | ** **

** **

** **

**X** | ** **

** **

** **

**X** |
| 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** | ** **

**X** |   | ** **

**X** |
| 1122(d)(4)(vi)                          | Changes  with respect to the terms or status of an obligor's pool asset (e.g., loan  modifications or re-agings) are made, reviewed and approved by authorized  personnel in accordance with the transaction agreements and related pool  asset documents.                                                                                                                                                                                                                                                                  | ** **

**X** | ** **

**X*** | ** **

**X** | ** **

**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** | ** **

** **

**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** | ** **

** **

** **

**X** | ** **

** **

** **

**X** | ** **

** **

** **

**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** | ** **

**X** |   | ** **

**X** |
| 1122(d)(4)(x)                           | Regarding  any funds held in trust for an obligor (such as escrow accounts):                                                                                                                                                                                                                                                                                                                                                                                                                                                |   |   |   |   |
| 1122(d)(4)(x)(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.                                                                                                                                                                                                                                                                                                                                               | ** **

**X** | ** **

**X** |   | ** **

**X** |
| 1122(d)(4)(x)(B)                        | Interest  on such funds is paid, or credited, to obligors in accordance with applicable  pool asset documents and state laws.                                                                                                                                                                                                                                                                                                                                                                                               | **X** | **X** |   | **X*** |
| 1122(d)(4)(x)(C)                        | Such  funds were returned to the obligor within 30 calendar days of full repayment  of the related pool asset, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                       | ** **

**X** | ** **

**X** |   | ** **

**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** | ** **

** **

**X** |   | ** **

** **

**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** | ** **

**X** | ** **

**X*** | ** **

**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** | ** **

**X** |   | ** **

**X** |
| 1122(d)(4)(xiv)                         | Delinquencies,  charge-offs and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                          |   | ** **

**X** | ** **

**X*** | ** **

**X** |
| 1122(d)(4)(xv)                          | Any  external enhancement or other support, identified in Item 1114(a) (1) through  (3) or Item 1115 of this Regulation AB, is maintained as set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                      |   |   |   |   |

 

 

*Therewere no activities performed during the year ended December 31, 2021 with respectto the Platform because there were no occurrences of events that would requirethe Company to perform such activities.