| (logo)   PNC  REAL ESTATE | MIDLAND  LOAN  SERVICES |
|--------------------------------|-------------------------|

 

 

**Report on Assessment ofCompliance with Regulation AB Servicing Criteria**

 

Midland Loan Services(“Midland”), a division of PNC Bank, National Association, is responsible forassessing compliance with the applicable servicing criteria set forth in Item1122 (d) of Regulation AB of the Securities and Exchange Commission(“Regulation AB”), as set forth in Appendix A.

 

Midland has assessed itscompliance with the applicable servicing criteria as of and for the year endedDecember 31, 2016 (the “Reporting Period”). In making this assessment, Midlandused the criteria set forth by the Securities and Exchange Commission (“SEC”)in Item 1122(d) of Regulation AB. This report covers all transactions servicedon the *Enterprise!* Loan Management System (the “Platform”).

 

Midland engaged certainvendors, which are not servicers as defined in item 1101(j) of Regulation AB(the “Vendors”), to perform specific, limited or scripted activities related toportions of the servicing criteria as set forth in Appendix A.  Midlandelects to take responsibility for assessing compliance with the servicingcriteria or portion of the servicing criteria applicable to such Vendors’activities as set forth in Appendix A. Midland has not identified and is notaware of any material instances of noncompliance by the Vendors with theapplicable servicing criteria as of December 31, 2016 and for the ReportingPeriod with respect to the Platform taken as a whole, nor has it identified anymaterial deficiencies in its policies and procedures to monitor the complianceby the Vendors with the applicable servicing criteria as of December 31, 2016and for the Reporting Period with respect to the Platform taken as a whole.

 

Based on this assessment,Midland believes that, as of and for the year ended December 31, 2016, Midlandhas complied in all material respects with the applicable servicing criteriaset forth in Item 1122(d) of Regulation AB.

 

PricewaterhouseCoopers LLP, anindependent registered public accounting firm, has issued an attestation reporton Midland’s assessment of compliance with the applicable servicing criteria asof and for the year ended December 31, 2016.

 

MIDLAND LOAN SERVICES

a division of PNC Bank,National Association

 

 

/s/ Steven W. Smith

Steven W. Smith

Executive Vice President

 

/s/ Bradley J. Hauger

Bradley J. Hauger

Senior Vice President 

 

Date: February 17, 2017

 

 

**Member of The PNC FinancialServices Group**

10851 Mastin Boulevard •Overland Park, Kansas • 66210 

800-327-8083

www.pnc.com/midland

 

 

**APPENDIX A**

 

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**SERVICING CRITERIA**                                        | **APPLICABLE SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
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**Reference** | ** **

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**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                  | ** **

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**Performed Directly by Midland** | **Performed by Vendor(s)   for which Midland is the Responsible Party** |
| **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

(only with respect to  financial performance activities) |
| 1122(d)(1)(ii)                                                            | If any material servicing activities are outsourced  to third parties, policies and procedures are instituted to monitor the third  party’s performance and compliance with such servicing activities.                                                                                                                                                                                                                                                                                                              | ** **

X |   |
| 1122(d)(1)(iii)                                                           | Any requirements in the transaction agreements to  maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                        | N/A1 |
| 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 the transaction agreements.                                                                                                                                                                                                                                                         | ** **

** **

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

X |   |
| **Cash Collection and Administration**                                    |
| 1122(d)(2)(i)                                                             | Payments on pool assets are deposited into the  appropriate custodial bank accounts and related bank clearing accounts no  more than two business days following receipt, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                          | ** **

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 |   |
| 1122(d)(2)(iii)                                                           | Advances of funds or guarantees regarding  collections, cash flows or distributions, and any interest or other fees  charged for such advances, are made, reviewed and approved as specified in  the transaction agreements.                                                                                                                                                                                                                                                                                              | ** **

X |   |
| 1122(d)(2)(iv)                                                            | The related accounts for the transaction, such as cash  reserve accounts or accounts established as a form of overcollateralization,  are separately maintained (e.g., with respect to commingling of cash) as set  forth in the transaction agreements.                                                                                                                                                                                                                                                                  | ** **

** **

X |   |
| 1122(d)(2)(v)                                                             | Each custodial account is maintained at a federally  insured depository institution as set forth in the transaction agreements.  For purposes of this criterion, “federally insured depository institution”  with respect to a foreign financial institution means a foreign financial  institution that meets the requirements of Rule 13K-1(b)(1) of the Securities  Exchange Act.                                                                                                                          | ** **

** **

X |   |
| 1122(d)(2)(vi)                                                            | Unissued checks are safeguarded so as to prevent  unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | 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:                                                                                                                                                                                                                                                                                                                         |   |   |   |
|                                                                      | (A) Are mathematically accurate;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | X |   |   |
|                                                                      | (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 |   |   |
|                                                                      | (C) Are reviewed and approved by someone other than the  person who prepared the reconciliation; and                                                                                                                                                                                                                                                                                                                                                                                                                      | X |   |   |
|                                                                      | (D) Contain explanations for reconciling items. These  reconciling items are resolved within 90 calendar days of their original identification,  or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                    |  

X |   |   |
| **Investor Remittances and Reporting**                                    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
| 1122(d)(3)(i)                                                             | Reports to investors, including those to be filed with  the Commission, are maintained in accordance with the transaction agreements  and applicable Commission requirements. Specifically, such reports:                                                                                                                                                                                                                                                                                                                 |   |   |   |
|                                                                      | (A) Are prepared in accordance with timeframes and other  terms set forth in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                  | X |   |   |
|                                                                      | (B) Provide information calculated in accordance with  the terms specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                 | N/A1 |   |
|                                                                      | (C) Are filed with the Commission as required by its rules  and regulations; and                                                                                                                                                                                                                                                                                                                                                                                                                                          | N/A1 |   |
|                                                                      | (D) Agree with investor’s or the trustee’s records as  to the total unpaid principal balance and number of pool assets serviced by  the servicer.                                                                                                                                                                                                                                                                                                                                                             |  

N/A1 |   |
| 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.                                                                                                                                                                                                                                                                                                                                                       |  

N/A1 |   |
| 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.                                                                                                                                                                                                                                                                                                                                   |  

N/A1 |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                             |  

N/A1 |   |
| **Pool Asset Administration**                                             |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
| 1122(d)(4)(i)                                                             | Collateral or security on pool assets is  maintained as required by the transaction agreements or related mortgage loan  documents.                                                                                                                                                                                                                                                                                                                                                                                       |  

 

X | X

(only with respect to  removal from pools and loan assumptions) |   |
| 1122(d)(4)(ii)                                                            | Pool assets and related documents are safeguarded as  required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                             | X |   |   |
| 1122(d)(4)(iii)                                                           | Any additions, removals or substitutions to the asset  pool are made, reviewed and approved in accordance with any conditions or  requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                             |  

X | X

(only with respect to  removal from pools) |   |
| 1122(d)(4)(iv)                                                            | Payments on pool assets, including any payoffs, made  in accordance with the related pool asset documents are posted to the  servicer’s obligor records maintained no more than two business days after  receipt, or such other number of days specified in the transaction  agreements, and allocated to principal, interest or other items (e.g.,  escrow) in accordance with the related pool asset documents.                                                                                                   |  

 

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 |   |   |
| 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

(only with respect to loan  assumptions) |   |
| 1122(d)(4)(vii)                                                           | Loss mitigation or recovery actions (e.g.,  forbearance plans, modifications and deeds in lieu of foreclosure,  foreclosures and repossessions, as applicable) are initiated, conducted and concluded  in accordance with the timeframes or other requirements established by the  transaction agreements.                                                                                                                                                                                                                |  

 

X |   |   |
| 1122(d)(4)(viii)                                                          | Records documenting collection efforts are maintained  during the period a pool asset is delinquent in accordance with the  transaction agreements. Such records are maintained on at least a monthly  basis, or such other period specified in thetransaction agreements, and describe the entity’s activities in monitoring  delinquent pool assets including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or unemployment). |  

 

 

X |   |   |
| 1122(d)(4)(ix)                                                            | Adjustments to interest rates or rates of return for  pool assets with variable rates are computed based on the related pool asset  documents.                                                                                                                                                                                                                                                                                                                                                                            |  

X |   |   |
| 1122(d)(4)(x)                                                             | Regarding any funds held in trust for an  obligor (such as escrow accounts):                                                                                                                                                                                                                                                                                                                                                                                                                                              |   |   |   |
|                                                                      | (A) Such funds are analyzed, in accordance with the  obligor’s pool asset documents, on at least an annual basis, or such other  period specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                    |  

X |   |   |
|                                                                      | (B) Interest on such funds is paid, or credited, to  obligors in accordance with applicable pool asset documents and state laws;  and                                                                                                                                                                                                                                                                                                                                                                                     |  

X |   |   |
|                                                                      | (C) Such funds are 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 |   |   |
| 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

(with respect to insurance  and tax related activities) |   |
| 1122(d)(4)(xii)                                                           | Any late payment penalties in connection with any  payment to be made on behalf of an obligor are paid from the servicer’s funds  and not charged to the obligor, unless the late payment was due to the  obligor’s error or omission.                                                                                                                                                                                                                                                                        |  

X |   |   |
| 1122(d)(4)(xiii)                                                          | Disbursements made on behalf of an obligor are posted  within two business days to the obligor’s records maintained by the servicer,  or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                         |  

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

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.                                                                                                                                                                                                                                                                                                                                      |  

N/A1 |   |
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1 Midland has determined servicing criteria1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D),1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), and 1122(d)(4)(xv) to beinapplicable to the activities Midland performs with respect to the Platform.