**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: 333-206677-15**

**Central Index Key Number of the issuing entity:0001698685**

**BANK 2017-BNK4**

**(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 itscharter)**

** **

**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: 0001102113**

**Bank of America, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001541557**

**Morgan Stanley Mortgage CapitalHoldings 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)** | **38-4032075**

**38-4032076**

**38-7170551**

**(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 pursuantto 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 smallerreporting company, 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 if asmaller reporting company)                          Smaller reporting company                    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 alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes 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 documentsshould be clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The D.C. Office Portfolio Mortgage Loan, theOne West 34th Street Mortgage Loan, the American Greetings HQ Mortgage Loan andthe Ralph’s Food Warehouse Portfolio Mortgage Loan, which constitutedapproximately 6.9%, 6.0%, 3.7% and 2.5%, respectively, of the asset pool of theissuing entity as of its cut-off date, are each an asset of the issuing entityand are each part of a loan combination that includes (a) with respect to theD.C. Office Portfolio Mortgage Loan which is an asset of the issuing entity andone other *pari passu* loan, which is not an asset of the issuing entity,(b) with respect to the One West 34th Street Mortgage Loan which is an asset ofthe issuing entity and two other *pari passu* loans, which are not assetsof the issuing entity, (c) with respect to the American Greetings HQ MortgageLoan which is an asset of the issuing entity and two other *pari passu*loans and one subordinate companion loan, each of which are not assets of theissuing entity and (d) with respect to the Ralph’s Food Warehouse PortfolioMortgage Loan which is an asset of the issuing entity and one other *paripassu* loan, which is not an asset of the issuing entity. These loancombinations, including the D.C. Office Portfolio Mortgage Loan, the One West34th Street Mortgage Loan, the American Greetings HQ Mortgage Loan and theRalph’s Food Warehouse Portfolio Mortgage Loan, are being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 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 Summit Birmingham Mortgage Loan and the JWMarriott Desert Springs Mortgage Loan, which constituted approximately 6.1% and5.4%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Summit Birmingham Mortgage Loan and the JW Marriott DesertSprings Mortgage Loan are each an asset of the issuing entity and are each partof a loan combination that includes (a) with respect to The Summit BirminghamMortgage Loan and three other *pari passu* loans, which are not assets ofthe issuing entity or (b) with respect to the JW Marriott Desert SpringsMortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity. A *pari passu* portion of each loan combination wassecuritized in the Bank of America Merrill Lynch Commercial Mortgage Trust2017-BNK3 transaction, Commission File Number 333-206847-05 (the “BACM2017-BNK3 Transaction”). These loan combinations, including The SummitBirmingham Mortgage Loan and the JW Marriott Desert Springs Mortgage Loan, arebeing serviced and administered pursuant to the pooling and servicing agreementfor the BACM 2017-BNK3 Transaction, which is incorporated by reference asExhibit 4.2 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 Merrill Lynch Drive Mortgage Loan, whichconstituted approximately 4.1% of the asset pool of the issuing entity as ofits cut-off date.  The Merrill Lynch Drive Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the MerrillLynch Drive Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BBCMS Mortgage Trust 2017-C1 transaction, Commission File Number 333-206987-01 (the “BBCMS 2017-C1Transaction”). This loan combination, including the Merrill Lynch DriveMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the BBCMS 2017-C1 Transaction, which is incorporated byreference as 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 Davenport Mortgage Loan, which constitutedapproximately 5.0% of the asset pool of the issuing entity as of its cut-offdate.  The Davenport Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes The Davenport Mortgage Loan and oneother *pari passu* loan, which is not an asset of the issuing entity. Theother *pari passu* portion of the loan combination was securitized in theWells Fargo Commercial Mortgage Trust 2017-RB1 transaction, Commission FileNumber 333-206677-14 (the “WFCM 2017-RB1 Transaction”). This loancombination, including The Davenport Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the WFCM2017-RB1 Transaction, which is incorporated by reference as Exhibit 4.4 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 Key Center Cleveland Mortgage Loan, whichconstituted approximately 4.0% of the asset pool of the issuing entity as ofits cut-off date.  The Key Center Cleveland Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the KeyCenter Cleveland Mortgage Loan and five other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Citigroup Commercial Mortgage Trust 2017-P7transaction, Commission File Number 333-207132-11 (the “CGCMT 2017-P7Transaction”). This loan combination, including the Key Center ClevelandMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the CGCMT 2017-P7 Transaction, which is incorporated byreference as Exhibit 4.5 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 Pentagon Center Mortgage Loan, whichconstituted approximately 5.5% of the asset pool of the issuing entity as ofits cut-off date.  The Pentagon Center Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the PentagonCenter Mortgage Loan and three other *pari passu* loans, which are notassets of the issuing entity. This loan combination, including the PentagonCenter Mortgage Loan, was serviced under the pooling and servicing agreementfor the GS Mortgage Securities Trust 2017-GS5 transaction prior to the closingof the securitization of a *pari passu* portion of the Pentagon Centerloan combination in the GS Mortgage Securities Trust 2017-GS6 transaction,Commission File Number 333-207677-05 (the “GSMS 2017-GS6 Transaction”). After the closing of the GSMS 2017-GS6 Transaction on May 31, 2017, thisloan combination, including the Pentagon Center Mortgage Loan was, and willcontinue to be, serviced and administered pursuant to the pooling and servicingagreement with respect to the GSMS 2017-GS6 Transaction, which is incorporatedby reference as Exhibit 4.6 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 Summit Birmingham Mortgage Loan, the JW Marriott DesertSprings Mortgage Loan, The Davenport Mortgage Loan, the Merrill Lynch DriveMortgage Loan and the Key Center Cleveland Mortgage Loan. As a result, WellsFargo Bank, National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Wells Fargo Bank, National Association inthe 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, The SummitBirmingham Mortgage Loan, the JW Marriott Desert Springs Mortgage Loan, TheDavenport Mortgage Loan, the Merrill Lynch Drive Mortgage Loan and the PentagonCenter Mortgage Loan.  As a result, Wells Fargo Bank, National Associationis a servicing function participant in the capacities described above, becauseit is servicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byWells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the Merrill Lynch Drive Mortgage Loan and the Key CenterCleveland Mortgage Loan. As a result, Rialto Capital Advisors, LLC is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Rialto Capital Advisors, LLC in the capacities described above are listed inthe Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the special servicer of The SummitBirmingham Mortgage Loan and the JW Marriott Desert Springs Mortgage Loan andthe primary servicer and special servicer of the Pentagon Center Mortgage Loan.As a result, Midland Loan Services, a Division of PNC Bank, NationalAssociation is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB,in the capacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Midland Loan Services, a Division of PNC Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofThe Summit Birmingham Mortgage Loan, the JW Marriott Desert Springs MortgageLoan, the Merrill Lynch Drive Mortgage Loan and the Key Center ClevelandMortgage Loan.  As a result, Park Bridge Lender Services LLC is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPark Bridge Lender Services LLC in the capacities described above are listed inthe Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Pooling andServicing Agreement, the JW Marriott Desert Springs Mortgage Loan, The SummitBirmingham Mortgage Loan, the Merrill Lynch Drive Mortgage Loan and TheDavenport Mortgage Loan.  Pursuant to the Pooling and Servicing Agreement,the pooling and servicing agreement for the BACM 2017-BNK3 Transaction, thepooling and servicing agreement for the BBCMS 2017-C1 Transaction and thepooling and servicing agreement for the WFCM 2017-RB1 Transaction, the trusteeis required to provide an assessment of compliance with applicable servicingcriteria 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 Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable 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 mortgage loans serviced underthe Pooling and Servicing Agreement, the JW Marriott Desert Springs MortgageLoan, The Summit Birmingham Mortgage Loan, the Merrill Lynch Drive MortgageLoan and The Davenport Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(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 JW Marriott Desert Springs Mortgage Loan, The SummitBirmingham Mortgage Loan, the Merrill Lynch Drive Mortgage Loan, The DavenportMortgage Loan and the Key Center Cleveland Mortgage Loan to remit tax paymentsreceived from the escrow accounts of borrowers to local taxing authorities, toreport tax amounts due, to verify tax parcel information, and to verifynon-escrow tax payments. These servicing functions are included within theservicing criteria set forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) ofRegulation AB.  Therefore, under the principles-based definition of“servicer” set forth in Item 1101(j) of Regulation AB that looks to thefunctions that an entity performs, these vendors are “servicers” for thepurposes of Item 1122 of Regulation AB.  *See* Compliance andDisclosure 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 JW Marriott Desert Springs Mortgage Loan, The SummitBirmingham Mortgage Loan, the Merrill Lynch Drive Mortgage Loan, The DavenportMortgage Loan, the Pentagon Center Mortgage Loan and the Key Center ClevelandMortgage Loan listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as the certificate administrator pursuant to the related poolingand servicing agreement or trust and servicing agreement does not perform anyactivities that address servicing criteria with respect to the issuing entityand because they are each not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include The Davenport Mortgage Loan and the Key CenterCleveland Mortgage Loan, (i) the report on assessment of compliance withservicing criteria and attestation report on assessment of compliance withservicing criteria of Deutsche Bank Trust Company Americas as trustee andcustodian of the Key Center Cleveland Mortgage Loan, listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as they are not requiredto be included on this Annual Report on Form 10-K per Instruction 3 to Item1122 of Regulation AB because it is a party performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity;and (ii) the servicer compliance statement of C-III Asset Management LLC asspecial servicer of The Davenport Mortgage Loan, listed on the Exhibit Index isomitted from this Annual Report on Form 10-K as it is not required by Item 1123of Regulation AB to be included on this Annual Report on Form 10-K because itis an unaffiliated party that is not a “servicer” that meets the criteria inItem 1108(a)(2)(i) through (iii) of Regulation 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 no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to Wells Fargo Bank, National Association, as trustee,as certificate administrator and as custodian, and Deutsche Bank Trust CompanyAmericas, as trustee and as custodian.

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches of representationsand warranties, (ii) notify investors of alleged events of default, and (iii)abide by appropriate standards of care following alleged events of default.Relief sought included money damages in an unspecified amount, reimbursement ofexpenses, and equitable relief. In November 2018, Wells Fargo Bank reached anagreement, in which it denied any wrongdoing, to resolve such claims on aclasswide basis for the 271 RMBS trusts at issue.  On May 6, 2019, thecourt entered an order approving the settlement agreement.  Separatelawsuits against Wells Fargo Bank making similar allegations filed by certainother institutional investors concerning several RMBS trusts in New Yorkfederal and state court are not covered by the agreement.  With respect tosuch litigations, Wells Fargo Bank believes plaintiffs' claims are withoutmerit and intends to contest the claims vigorously, but there can be noassurances as to the outcome of the litigations or the possible impact of thelitigations on Wells Fargo Bank or the RMBS trusts.

Deutsche Bank Trust CompanyAmericas (“DBTCA”) and Deutsche Bank National Trust Company (“DBNTC”)have been sued by investors in civil litigation concerning their role astrustees of certain RMBS trusts. 

 

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.  Duringthe course of the litigation, plaintiffs dismissed the case from New York StateSupreme Court and refiled two separate cases, one in the U.S. District Courtfor 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, IKBInternational, S.A. in Liquidation and IKB Deutsche Industriebank A.G.(collectively, “IKB”), as an investor in 37 RMBS trusts, filed a summonswith notice in the Supreme Court of the State of New York, New York County,against DBNTC and DBTCA as trustees of the trusts.  On May 27, 2016, IKBserved its complaint asserting claims for breach of contract, breach offiduciary duty, breach of duty to avoid conflicts of interest, violation of theStreit Act, violation of the TIA, violation of Regulation AB, and violation ofSection 9 of the Uniform Commercial Code.  IKB alleges that DBNTC andDBTCA are liable for over U.S. $268 million in damages.  On October 5,2016, DBNTC and DBTCA, together with several other trustees defending lawsuitsby IKB, filed a joint motion to dismiss.  On January 6, 2017 and June 20,2017, IKB voluntarily dismissed with prejudice all claims as to seventrusts.  As of March 1, 2020, DBNTC and DBTCA’s motion to dismiss has beenbriefed and is awaiting decision by the court.

It is DBTCA’s belief that it has nopending legal proceedings (including, based on DBTCA’s present evaluation, the litigationdisclosed in the foregoing paragraphs) that would materially affect its abilityto perform its duties under the related servicing agreement for thistransaction.

**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 April 19, 2017 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 Zto 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 Summit Birmingham Mortgage Loanand the JW Marriott Desert Springs Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BACM2017-BNK3 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit Z to the pooling and servicing agreement forthe BACM 2017-BNK3 Transaction incorporated by reference as Exhibit 4.2 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the BACM 2017-BNK3 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 Merrill Lynch Drive MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the BBCMS 2017-C1 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 BBCMS 2017-C1 Transaction incorporatedby reference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BBCMS2017-C1 Transaction responsible for each applicable servicing criteria setforth 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 Davenport Mortgage Loan, which isbeing serviced and administered pursuant to the pooling and servicing agreementfor the WFCM 2017-RB1 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the WFCM 2017-RB1 Transaction incorporated by reference asExhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the WFCM 2017-RB1Transaction 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 Key Center Cleveland MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the CGCMT 2017-P7 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit O to thepooling and servicing agreement for the CGCMT 2017-P7 Transaction incorporatedby reference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CGCMT2017-P7 Transaction responsible for each applicable servicing criteria setforth 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 Pentagon Center Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the GSMS 2017-GS6 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the GSMS 2017-GS6 Transaction incorporated by referenceas Exhibit 4.6 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the GSMS 2017-GS6Transaction 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 savedproperly resulting in the prior month's Schedule AL File being submitted forthe given month 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.  Following identification,Midland made staffing changes and additional enhancements and improvements toits processes and procedures to support its Schedule AL reporting obligationsand expects to move to an automated solution for this process.  

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

**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          Poolingand Servicing Agreement, dated as of April 1, 2017, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.1 to the registrant’s Current Report on Form 8-K/A filed on June 6,2017 under Commission File No. 333-206677-15 and incorporated by referenceherein),asamended by Amendment No. 1 to Pooling and Servicing Agreement, dated as of June18, 2018, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand as Asset Representations Reviewer (filed as Exhibit 4.1 to the registrant'sCurrent Report on Form 8-K filed on June 19, 2018 under Commission File No.333-206677-15 and incorporated by reference herein).

4.2          Poolingand Servicing Agreement, dated as of February 1, 2017, by and among Banc ofAmerica Merrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Midland Loan Services, a Division ofPNC Bank, National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 99.4 to theregistrant’s Current Report on Form 8-K filed on April 19, 2017 underCommission File No. 333-206677-15 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of February 1, 2017, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Wells Fargo Bank, National Association,as Master Servicer, Rialto Capital Advisors, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Park Bridge Lender Services LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit99.7 to the registrant’s Current Report on Form 8-K filed on April 19, 2017under Commission File No. 333-206677-15 and incorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of March 1, 2017, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, C-III Asset Management LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Trimont Real EstateAdvisors, LLC, as Operating Advisor and as Asset Representations Reviewer(filed as Exhibit 99.6 to the registrant’s Current Report on Form 8-K filed onApril 19, 2017 under Commission File No. 333-206677-15 and incorporated byreference herein).

4.5          Poolingand Servicing Agreement, dated as of April 1, 2017, by and among CitigroupCommercial Mortgage Securities Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Rialto Capital Advisors, LLC, as SpecialServicer, Park Bridge Lender Services LLC, as Operating Advisor and as AssetRepresentations Reviewer, Citibank, N.A., as Certificate Administrator andDeutsche Bank Trust Company Americas, as Trustee (filed as Exhibit 99.8 to theregistrant’s Current Report on Form 8-K filed on April 19, 2017 underCommission File No. 333-206677-15 and incorporated by reference herein).

4.6          Poolingand Servicing Agreement, dated as of May 1, 2017, by and among GS MortgageSecurities Corporation II, as Depositor, Midland Loan Services, a Division ofPNC Bank, National Association, as Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer, Wells FargoBank, National Association, as Certificate Administrator, Wells Fargo Bank,National Association, as Trustee, and Pentalpha Surveillance LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 99.19 to theregistrant’s Current Report on Form 8-K/A filed on June 6, 2017 underCommission File No. 333-206677-15 and incorporated by reference herein).

4.7          AgreementBetween Note Holders, dated as of February 13, 2017, by and between Bank ofAmerica, N.A., as initial note A-1 holder, and Bank of America, N.A., asinitial note A-2 holder (filed as Exhibit 99.9 to the registrant’s CurrentReport on Form 8-K filed on April 19, 2017 under Commission File No.333-206677-15 and incorporated by reference herein).

4.8          AgreementBetween Note Holders, dated as of December 20, 2016, by and between Bank ofAmerica, N.A., as initial note A-1 holder, Bank of America, N.A., as initialnote A-2 holder, Barclays Bank PLC, as initial note A-3 holder, and BarclaysBank PLC, as initial note A-4 holder (filed as Exhibit 99.10 to theregistrant’s Current Report on Form 8-K filed on April 19, 2017 underCommission File No. 333-206677-15 and incorporated by reference herein).

4.9          AgreementBetween Note Holders, dated as of March 15, 2017, by and between Wells FargoBank, National Association, as initial note A-1 holder, Wells Fargo Bank,National Association, as initial note A-2 holder, and Goldman Sachs MortgageCompany, as initial note A-3 holder (filed as Exhibit 99.11 to the registrant’sCurrent Report on Form 8-K filed on April 19, 2017 under Commission File No.333-206677-15 and incorporated by reference herein).

4.10        Co-LenderAgreement, dated as of March 16, 2017, by and between Goldman Sachs MortgageCompany, as initial note A-1 holder and initial note A-2 holder, and MorganStanley Bank, N.A., as initial note A-3 holder, initial note A-4 holder,initial note A-5 holder and initial note A-6 holder (filed as Exhibit 99.12 tothe registrant’s Current Report on Form 8-K filed on April 19, 2017 underCommission File No. 333-206677-15 and incorporated by reference herein).

4.11        AgreementBetween Note Holders, dated as of January 11, 2017, by and between MorganStanley Bank, N.A., as initial note A-1 holder, Morgan Stanley Bank, N.A., asinitial note A-2 holder and Morgan Stanley Bank, N.A. as initial note A-3holder (filed as Exhibit 99.13 to the registrant’s Current Report on Form 8-Kfiled on April 19, 2017 under Commission File No. 333-206677-15 andincorporated by reference herein).

4.12        AgreementBetween Note Holders, dated as of March 30, 2017, by and between Wells FargoBank, National Association, as initial note A-1 holder and Wells Fargo Bank,National Association, as initial note A-2 holder (filed as Exhibit 99.14 to theregistrant’s Current Report on Form 8-K filed on April 19, 2017 underCommission File No. 333-206677-15 and incorporated by reference herein).

4.13        AgreementBetween Note Holders, dated as of January 31, 2017, by and between BarclaysBank PLC, as initial note A-1 holder, Barclays Bank PLC, as initial note A-2holder, and Morgan Stanley Bank, N.A., as initial note A-3 holder (filed asExhibit 99.15 to the registrant’s Current Report on Form 8-K filed on April 19,2017 under Commission File No. 333-206677-15 and incorporated by referenceherein).

4.14        Co-LenderAgreement, dated as of January 31, 2017, by and between Citi Real EstateFunding Inc., as initial note A-1 holder and initial note A-4 holder, Bank ofAmerica, N.A., as initial note A-2 holder and initial note A-5 holder, andDeutsche Bank AG, New York Branch, as initial note A-3 holder and initial noteA-6 holder (filed as Exhibit 99.16 to the registrant’s Current Report on Form8-K filed on April 19, 2017 under Commission File No. 333-206677-15 andincorporated by reference herein).

4.15        AgreementBetween Note Holders, dated as of October 27, 2016, by and between Bank ofAmerica, N.A., as initial note A-1-1 holder, Bank of America, N.A., as initialnote A-1-2 holder and Bank of America, N.A., as initial note A-2 holder (filedas Exhibit 99.17 to the registrant’s Current Report on Form 8-K filed on April19, 2017 under Commission File No. 333-206677-15 and incorporated by referenceherein).

4.16        AgreementBetween Note Holders, dated as of April 13, 2017, by and between Morgan StanleyBank, N.A., as initial note A-1- holder and Morgan Stanley Bank, N.A., asinitial note A-2 holder (filed as Exhibit 99.18 to the registrant’s CurrentReport on Form 8-K filed on April 19, 2017 under Commission File No.333-206677-15 and incorporated by reference 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        Rialto Capital Advisors,LLC, as Special 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        Pentalpha SurveillanceLLC, 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        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the D.C. Office Portfolio Mortgage Loan(see Exhibit 33.1)

33.10      Rialto Capital Advisors,LLC, as Special Servicer of the D.C. Office Portfolio Mortgage Loan (seeExhibit 33.2)

33.11      Wilmington Trust, National Association, as Trustee of the D.C. Office PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.12      Wells Fargo Bank, NationalAssociation, as Custodian of the D.C. Office Portfolio Mortgage Loan (seeExhibit 33.5)

33.13      Pentalpha SurveillanceLLC, as Operating Advisor of the D.C. Office Portfolio Mortgage Loan (seeExhibit 33.6)

33.14      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the D.C. OfficePortfolio Mortgage Loan (see Exhibit 33.7)

33.15      National Tax Search, LLC,as Servicing Function Participant of the D.C. Office Portfolio Mortgage Loan(see Exhibit 33.8)

33.16      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the One West 34th Street Mortgage Loan (seeExhibit 33.1)

33.17      Rialto Capital Advisors,LLC, as Special Servicer of the One West 34th Street Mortgage Loan (see Exhibit33.2)

33.18      Wilmington Trust, National Association, as Trustee of the One West 34th StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.19      Wells Fargo Bank, NationalAssociation, as Custodian of the One West 34th Street Mortgage Loan (seeExhibit 33.5)

33.20      Pentalpha SurveillanceLLC, as Operating Advisor of the One West 34th Street Mortgage Loan (seeExhibit 33.6)

33.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the One West 34thStreet Mortgage Loan (see Exhibit 33.7)

33.22      National Tax Search, LLC,as Servicing Function Participant of the One West 34th Street Mortgage Loan(see Exhibit 33.8)

33.23      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the American Greetings HQ Mortgage Loan(see Exhibit 33.1)

33.24      Rialto Capital Advisors,LLC, as Special Servicer of the American Greetings HQ Mortgage Loan (seeExhibit 33.2)

33.25      Wilmington Trust, National Association, as Trustee of the American Greetings HQMortgage Loan (Omitted. See Explanatory Notes.)

33.26      Wells Fargo Bank, NationalAssociation, as Custodian of the American Greetings HQ Mortgage Loan (seeExhibit 33.5)

33.27      Pentalpha SurveillanceLLC, as Operating Advisor of the American Greetings HQ Mortgage Loan (seeExhibit 33.6)

33.28      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the AmericanGreetings HQ Mortgage Loan (see Exhibit 33.7)

33.29      National Tax Search, LLC,as Servicing Function Participant of the American Greetings HQ Mortgage Loan(see Exhibit 33.8)

33.30      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Ralph’s Food Warehouse PortfolioMortgage Loan (see Exhibit 33.1)

33.31      Rialto Capital Advisors,LLC, as Special Servicer of the Ralph’s Food Warehouse Portfolio Mortgage Loan(see Exhibit 33.2)

33.32      Wilmington Trust, National Association, as Trustee of the Ralph’s FoodWarehouse Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.33      Wells Fargo Bank, NationalAssociation, as Custodian of the Ralph’s Food Warehouse Portfolio Mortgage Loan(see Exhibit 33.5)

33.34      Pentalpha SurveillanceLLC, as Operating Advisor of the Ralph’s Food Warehouse Portfolio Mortgage Loan(see Exhibit 33.6)

33.35      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Ralph’s FoodWarehouse Portfolio Mortgage Loan (see Exhibit 33.7)

33.36      National Tax Search, LLC,as Servicing Function Participant of the Ralph’s Food Warehouse PortfolioMortgage Loan (see Exhibit 33.8)

33.37      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Summit Birmingham Mortgage Loan (seeExhibit 33.1)

33.38      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The SummitBirmingham Mortgage Loan

33.39      Wilmington Trust, National Association, as Trustee of The Summit BirminghamMortgage Loan (Omitted. See Explanatory Notes.)

33.40      Wells Fargo Bank, NationalAssociation, as Custodian of The Summit Birmingham Mortgage Loan (see Exhibit33.5)

33.41      Park Bridge LenderServices LLC, as Operating Advisor of The Summit Birmingham Mortgage Loan

33.42      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The SummitBirmingham Mortgage Loan (see Exhibit 33.7)

33.43      National Tax Search, LLC,as Servicing Function Participant of The Summit Birmingham Mortgage Loan (seeExhibit 33.8)

33.44      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the JW Marriott Desert Springs MortgageLoan (see Exhibit 33.1)

33.45      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the JWMarriott Desert Springs Mortgage Loan (see Exhibit 33.38)

33.46      Wilmington Trust, National Association, as Trustee of the JW Marriott DesertSprings Mortgage Loan (Omitted. See Explanatory Notes.)

33.47      Wells Fargo Bank, NationalAssociation, as Custodian of the JW Marriott Desert Springs Mortgage Loan (seeExhibit 33.5)

33.48      Park Bridge LenderServices LLC, as Operating Advisor of the JW Marriott Desert Springs MortgageLoan (see Exhibit 33.41)

33.49      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the JW MarriottDesert Springs Mortgage Loan (see Exhibit 33.7)

33.50      National Tax Search, LLC,as Servicing Function Participant of the JW Marriott Desert Springs MortgageLoan (see Exhibit 33.8)

33.51      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Merrill Lynch Drive Mortgage Loan (seeExhibit 33.1)

33.52      Rialto Capital Advisors,LLC, as Special Servicer of the Merrill Lynch Drive Mortgage Loan (see Exhibit33.2)

33.53      Wilmington Trust, National Association, as Trustee of the Merrill Lynch DriveMortgage Loan (Omitted. See Explanatory Notes.)

33.54      Wells Fargo Bank, NationalAssociation, as Custodian of the Merrill Lynch Drive Mortgage Loan (see Exhibit33.5)

33.55      Park Bridge LenderServices LLC, as Operating Advisor of the Merrill Lynch Drive Mortgage Loan(see Exhibit 33.41)

33.56      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Merrill LynchDrive Mortgage Loan (see Exhibit 33.7)

33.57      National Tax Search, LLC,as Servicing Function Participant of the Merrill Lynch Drive Mortgage Loan (seeExhibit 33.8)

33.58      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Davenport Mortgage Loan (see Exhibit33.1)

33.59      C-III Asset ManagementLLC, as Special Servicer of The Davenport Mortgage Loan

33.60      Wilmington Trust, National Association, as Trustee of The Davenport MortgageLoan (Omitted. See Explanatory Notes.)

33.61      Wells Fargo Bank, NationalAssociation, as Custodian of The Davenport Mortgage Loan (see Exhibit 33.5)

33.62      Trimont Real EstateAdvisors, LLC, as Operating Advisor of The Davenport Mortgage Loan

33.63      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The DavenportMortgage Loan (see Exhibit 33.7)

33.64      National Tax Search, LLC,as Servicing Function Participant of The Davenport Mortgage Loan (see Exhibit33.8)

33.65      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Key Center Cleveland Mortgage Loan (seeExhibit 33.1)

33.66      Rialto Capital Advisors,LLC, as Special Servicer of the Key Center Cleveland Mortgage Loan (see Exhibit33.2)

33.67      Deutsche Bank Trust Company Americas, as Trustee and Custodian of the KeyCenter Cleveland Mortgage Loan (Omitted. See Explanatory Notes.)

33.68      Park Bridge LenderServices LLC, as Operating Advisor of the Key Center Cleveland Mortgage Loan(see Exhibit 33.41)

33.69      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Key CenterCleveland Mortgage Loan (see Exhibit 33.7)

33.70      National Tax Search, LLC,as Servicing Function Participant of the Key Center Cleveland Mortgage Loan(see Exhibit 33.8)

33.71      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PentagonCenter Mortgage Loan (see Exhibit 33.38)

33.72      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PentagonCenter Mortgage Loan (see Exhibit 33.38)

33.73      Wells Fargo Bank, National Association, as Trustee of the Pentagon CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.74      Wells Fargo Bank, NationalAssociation, as Custodian of the Pentagon Center Mortgage Loan (see Exhibit33.5)

33.75      Pentalpha SurveillanceLLC, as Operating Advisor of the Pentagon Center Mortgage Loan (see Exhibit33.6)

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

34.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2        Rialto Capital Advisors,LLC, as Special 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        Pentalpha Surveillance 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        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the D.C. Office Portfolio Mortgage Loan(see Exhibit 34.1)

34.10      Rialto Capital Advisors,LLC, as Special Servicer of the D.C. Office Portfolio Mortgage Loan (seeExhibit 34.2)

34.11      Wilmington Trust, National Association, as Trustee of the D.C. Office PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.12      Wells Fargo Bank, NationalAssociation, as Custodian of the D.C. Office Portfolio Mortgage Loan (seeExhibit 34.5)

34.13      Pentalpha SurveillanceLLC, as Operating Advisor of the D.C. Office Portfolio Mortgage Loan (seeExhibit 34.6)

34.14      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the D.C. OfficePortfolio Mortgage Loan (see Exhibit 34.7)

34.15      National Tax Search, LLC,as Servicing Function Participant of the D.C. Office Portfolio Mortgage Loan(see Exhibit 34.8)

34.16      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the One West 34th Street Mortgage Loan (seeExhibit 34.1)

34.17      Rialto Capital Advisors,LLC, as Special Servicer of the One West 34th Street Mortgage Loan (see Exhibit34.2)

34.18      Wilmington Trust, National Association, as Trustee of the One West 34th StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.19      Wells Fargo Bank, NationalAssociation, as Custodian of the One West 34th Street Mortgage Loan (see Exhibit34.5)

34.20      Pentalpha SurveillanceLLC, as Operating Advisor of the One West 34th Street Mortgage Loan (seeExhibit 34.6)

34.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the One West 34thStreet Mortgage Loan (see Exhibit 34.7)

34.22      National Tax Search, LLC,as Servicing Function Participant of the One West 34th Street Mortgage Loan(see Exhibit 34.8)

34.23      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the American Greetings HQ Mortgage Loan(see Exhibit 34.1)

34.24      Rialto Capital Advisors, LLC,as Special Servicer of the American Greetings HQ Mortgage Loan (see Exhibit34.2)

34.25      Wilmington Trust, National Association, as Trustee of the American Greetings HQMortgage Loan (Omitted. See Explanatory Notes.)

34.26      Wells Fargo Bank, NationalAssociation, as Custodian of the American Greetings HQ Mortgage Loan (seeExhibit 34.5)

34.27      Pentalpha SurveillanceLLC, as Operating Advisor of the American Greetings HQ Mortgage Loan (seeExhibit 34.6)

34.28      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the AmericanGreetings HQ Mortgage Loan (see Exhibit 34.7)

34.29      National Tax Search, LLC,as Servicing Function Participant of the American Greetings HQ Mortgage Loan(see Exhibit 34.8)

34.30      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Ralph’s Food Warehouse PortfolioMortgage Loan (see Exhibit 34.1)

34.31      Rialto Capital Advisors,LLC, as Special Servicer of the Ralph’s Food Warehouse Portfolio Mortgage Loan(see Exhibit 34.2)

34.32      Wilmington Trust, National Association, as Trustee of the Ralph’s FoodWarehouse Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.33      Wells Fargo Bank, NationalAssociation, as Custodian of the Ralph’s Food Warehouse Portfolio Mortgage Loan(see Exhibit 34.5)

34.34      Pentalpha SurveillanceLLC, as Operating Advisor of the Ralph’s Food Warehouse Portfolio Mortgage Loan(see Exhibit 34.6)

34.35      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Ralph’s FoodWarehouse Portfolio Mortgage Loan (see Exhibit 34.7)

34.36      National Tax Search, LLC,as Servicing Function Participant of the Ralph’s Food Warehouse PortfolioMortgage Loan (see Exhibit 34.8)

34.37      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Summit Birmingham Mortgage Loan (seeExhibit 34.1)

34.38      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The SummitBirmingham Mortgage Loan

34.39      Wilmington Trust, National Association, as Trustee of The Summit Birmingham MortgageLoan (Omitted. See Explanatory Notes.)

34.40      Wells Fargo Bank, NationalAssociation, as Custodian of The Summit Birmingham Mortgage Loan (see Exhibit34.5)

34.41      Park Bridge LenderServices LLC, as Operating Advisor of The Summit Birmingham Mortgage Loan

34.42      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of The SummitBirmingham Mortgage Loan (see Exhibit 34.7)

34.43      National Tax Search, LLC,as Servicing Function Participant of The Summit Birmingham Mortgage Loan (seeExhibit 34.8)

34.44      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the JW Marriott Desert Springs MortgageLoan (see Exhibit 34.1)

34.45      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the JWMarriott Desert Springs Mortgage Loan (see Exhibit 34.38)

34.46      Wilmington Trust, National Association, as Trustee of the JW Marriott DesertSprings Mortgage Loan (Omitted. See Explanatory Notes.)

34.47      Wells Fargo Bank, NationalAssociation, as Custodian of the JW Marriott Desert Springs Mortgage Loan (seeExhibit 34.5)

34.48      Park Bridge LenderServices LLC, as Operating Advisor of the JW Marriott Desert Springs MortgageLoan (see Exhibit 34.41)

34.49      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the JW MarriottDesert Springs Mortgage Loan (see Exhibit 34.7)

34.50      National Tax Search, LLC,as Servicing Function Participant of the JW Marriott Desert Springs MortgageLoan (see Exhibit 34.8)

34.51      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Merrill Lynch Drive Mortgage Loan (seeExhibit 34.1)

34.52      Rialto Capital Advisors,LLC, as Special Servicer of the Merrill Lynch Drive Mortgage Loan (see Exhibit34.2)

34.53      Wilmington Trust, National Association, as Trustee of the Merrill Lynch DriveMortgage Loan (Omitted. See Explanatory Notes.)

34.54      Wells Fargo Bank, NationalAssociation, as Custodian of the Merrill Lynch Drive Mortgage Loan (see Exhibit34.5)

34.55      Park Bridge LenderServices LLC, as Operating Advisor of the Merrill Lynch Drive Mortgage Loan(see Exhibit 34.41)

34.56      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Merrill LynchDrive Mortgage Loan (see Exhibit 34.7)

34.57      National Tax Search, LLC,as Servicing Function Participant of the Merrill Lynch Drive Mortgage Loan (seeExhibit 34.8)

34.58      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Davenport Mortgage Loan (see Exhibit34.1)

34.59      C-III Asset ManagementLLC, as Special Servicer of The Davenport Mortgage Loan

34.60      Wilmington Trust, National Association, as Trustee of The Davenport MortgageLoan (Omitted. See Explanatory Notes.)

34.61      Wells Fargo Bank, NationalAssociation, as Custodian of The Davenport Mortgage Loan (see Exhibit 34.5)

34.62      Trimont Real EstateAdvisors, LLC, as Operating Advisor of The Davenport Mortgage Loan

34.63      CoreLogic Commercial Real EstateServices, Inc., as Servicing Function Participant of The Davenport MortgageLoan (see Exhibit 34.7)

34.64      National Tax Search, LLC,as Servicing Function Participant of The Davenport Mortgage Loan (see Exhibit34.8)

34.65      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Key Center Cleveland Mortgage Loan (seeExhibit 34.1)

34.66      Rialto Capital Advisors,LLC, as Special Servicer of the Key Center Cleveland Mortgage Loan (see Exhibit34.2)

34.67      Deutsche Bank Trust Company Americas, as Trustee and Custodian of the KeyCenter Cleveland Mortgage Loan (Omitted. See Explanatory Notes.)

34.68      Park Bridge LenderServices LLC, as Operating Advisor of the Key Center Cleveland Mortgage Loan(see Exhibit 34.41)

34.69      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Key CenterCleveland Mortgage Loan (see Exhibit 34.7)

34.70      National Tax Search, LLC,as Servicing Function Participant of the Key Center Cleveland Mortgage Loan(see Exhibit 34.8)

34.71      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PentagonCenter Mortgage Loan (see Exhibit 34.38)

34.72      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PentagonCenter Mortgage Loan (see Exhibit 34.38)

34.73      Wells Fargo Bank, National Association, as Trustee of the Pentagon CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.74      Wells Fargo Bank, NationalAssociation, as Custodian of the Pentagon Center Mortgage Loan (see Exhibit34.5)

34.75      Pentalpha SurveillanceLLC, as Operating Advisor of the Pentagon Center Mortgage Loan (see Exhibit34.6)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2        Rialto Capital Advisors,LLC, as Special Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the D.C. Office Portfolio Mortgage Loan(see Exhibit 35.1)

35.5        Rialto Capital Advisors,LLC, as Special Servicer of the D.C. Office Portfolio Mortgage Loan (seeExhibit 35.2)

35.6        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the One West 34th Street Mortgage Loan (seeExhibit 35.1)

35.7        Rialto Capital Advisors,LLC, as Special Servicer of the One West 34th Street Mortgage Loan (see Exhibit35.2)

35.8        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the American Greetings HQ Mortgage Loan(see Exhibit 35.1)

35.9        Rialto Capital Advisors,LLC, as Special Servicer of the American Greetings HQ Mortgage Loan (seeExhibit 35.2)

35.10      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Ralph’s Food Warehouse PortfolioMortgage Loan (see Exhibit 35.1)

35.11      Rialto Capital Advisors,LLC, as Special Servicer of the Ralph’s Food Warehouse Portfolio Mortgage Loan(see Exhibit 35.2)

35.12      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Summit Birmingham Mortgage Loan (seeExhibit 35.1)

35.13      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of The SummitBirmingham Mortgage Loan

35.14      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the JW Marriott Desert Springs MortgageLoan (see Exhibit 35.1)

35.15      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the JWMarriott Desert Springs Mortgage Loan (see Exhibit 35.13)

35.16      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Merrill Lynch Drive Mortgage Loan (seeExhibit 35.1)

35.17      Rialto Capital Advisors,LLC, as Special Servicer of the Merrill Lynch Drive Mortgage Loan (see Exhibit35.2)

35.18      Wells Fargo Bank, NationalAssociation, as Primary Servicer of The Davenport Mortgage Loan (see Exhibit35.1)

35.19      C-III Asset Management LLC, as Special Servicer of The Davenport Mortgage Loan (Omitted.See Explanatory Notes.)

35.20      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Key Center Cleveland Mortgage Loan (seeExhibit 35.1)

35.21      Rialto Capital Advisors,LLC, as Special Servicer of the Key Center Cleveland Mortgage Loan (see Exhibit35.2)

35.22      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PentagonCenter Mortgage Loan (see Exhibit 35.13)

35.23      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PentagonCenter Mortgage Loan (see Exhibit 35.13)

99.1        MortgageLoan Purchase Agreement, dated as of April 5, 2017, between Wells Fargo Bank,National Association, as seller, and Wells Fargo Commercial Mortgage Securities,Inc., as purchaser (filed as Exhibit 99.3 to the registrant’s Current Report onForm 8-K/A filed on June 6, 2017 under Commission File No. 333-206677-15 andincorporated by reference herein)

99.2        MortgageLoan Purchase Agreement, dated as of April 5, 2017, between Bank of America,National Association, as seller, and Wells Fargo Commercial MortgageSecurities, Inc., as purchaser (filed as Exhibit 99.1 to the registrant’sCurrent Report on Form 8-K/A filed on June 6, 2017 under Commission File No.333-206677-15 and incorporated by reference herein)

99.3        MortgageLoan Purchase Agreement, dated as of April 5, 2017, between Morgan StanleyMortgage Capital Holdings LLC, as seller, and Wells Fargo Commercial MortgageSecurities, Inc., as purchaser (filed as Exhibit 99.2 to the registrant’s CurrentReport on Form 8-K/A filed on June 6, 2017 under Commission File No.333-206677-15 and 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 20, 2020