**
 

 

**UNITED STATES**

**SECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

 

 

**FORM 10-K/A**

**(Amendment No. 1)**

 

 

**(Mark One)**
****☒********
**ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2018**

**or**

 
****☐********
**TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from                     to                    **

**333-207132-11**

**(Commission File Number of issuing entity)**

**0001700668**

**(CentralIndex Key Number of issuing entity)**

**Citigroup Commercial Mortgage Trust 2017-P7**

**(Exact name of issuing entity as specified in its charter)**

**333-207132**

**(Commission File Number of depositor)**

**0001258361**

**(CentralIndex Key Number of depositor)**

**Citigroup Commercial Mortgage Securities Inc.**

**(Exact name of depositor as specified in its charter)**

**Citigroup Global Markets Realty Corp.**

**(Central Index Key Number: 0001541001)**

**Citi Real Estate Funding Inc.**

**(Central Index Key Number: 0001701238)**

**Natixis Real Estate Capital LLC**

**(Central Index Key Number: 0001542256)**

**Macquarie US Trading LLC d/b/a Principal Commercial Capital**

**(Central Index Key Number: 0001634437)**

**(Exact name of sponsor as specified in its charter)**

 
**New York** 
**82-1399691**

**82-6259785**

**82-6277304**

**(State or other jurisdiction of**

**organization of the issuing entity)**
 
**(I.R.S. Employer**

**Identification No.)**

**c/o Citibank, N.A.**

**388 Greenwich Street, 14th Floor**

**New York, New York 10013**

**(Address of principal executive offices of issuing entity)**

**(212) 816-5614**

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

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

**None**

**Securitiesregistered pursuant to section 12(g) of the Act:**

**None**

 

 

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the SecuritiesAct.    ☐  Yes    ☒  No 

Indicate by check mark if the registrant is not requiredto file reports pursuant to Section 13 or Section 15(d) of the Act.    ☐  Yes    ☒  No 

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Actof 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past90 days.    ☒  Yes    ☐  No 

Indicate by check mark whether the registranthas submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (orfor such shorter period that the registrant was required to submit such files). 

Not Applicable 

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K (§ 229.405 ofthis chapter) is not contained herein, and will not be contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form10-K or any amendment to this Form 10-K.

Not Applicable

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

 
Large accelerated filer ☐  Accelerated filer ☐Non-accelerated filer ☒  Smaller reporting company ☐   Emerging growth company ☐
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition periodfor complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.  ☐ 

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act).    ☐  Yes    ☒  No 

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at which the common equity was last sold, or the average bid and asked price of such commonequity, as of the last business day of the registrant’s most recently completed second fiscal quarter. 

Not Applicable 

Indicate by check mark whether the registrant has filed all documents and reports required to be filed by Section 12, 13 or 15(d) of the SecuritiesExchange Act of 1934 subsequent to the distribution of securities under a plan confirmed by a court. 

Not Applicable 

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

Not Applicable 

**DOCUMENTSINCORPORATED BY REFERENCE**

List hereunder the following documents if incorporated by reference and the Part of the Form10-K (e.g., Part I, Part II, etc.) into which the document is incorporated: (1) Any annual report to security holders; (2) Any proxy or information statement; and (3) Any prospectus filedpursuant to Rule 424(b) or (c) under the Securities Act of 1933. The listed documents should be clearly described for identification purposes (e.g., annual report to security holders for fiscal year ended December 24, 1980). 

Not Applicable 

**EXPLANATORYNOTES**

The purpose of this Amendment No. 1 (the “Amendment”) to our Annual Report on Form 10-Kfor the fiscal year ended December 31, 2018, as filed with the Securities and Exchange Commission (the “Commission”) on March 29, 2019 under Commission FileNo. 333-207132-11 (the “Original Form 10-K”), is to file with the Commission: (i) a revised report onassessment of compliance with servicing criteria for asset-backed securities of Rialto Capital Advisors, LLC as Exhibits 33.2 and 33.34, as a replacement of the report on assessment of compliance filed as Exhibits 33.2 and 33.34 to the Original Form10-K; and (ii) a revised attestation report on assessment of compliance with servicing criteria for asset-backed securities for Rialto Capital Advisors, LLC as Exhibits 34.2 and 34.34, as a replacement ofthe attestation report on assessment of compliance with servicing criteria for asset-backed securities filed as Exhibits 34.2 and 34.34 to the Original Form 10-K. No other changes have been made to theOriginal Form 10-K other than the changes described above. 

 

 

 
**

**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 forRegistrant’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 of Financial Condition and Results of Operations.**

Omitted.****

**Item 7A. Quantitative and QualitativeDisclosures About 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 Corporate Governance.**

Omitted. 

**Item 11. Executive Compensation.**

Omitted. 

**Item 12. Security Ownership of CertainBeneficial Owners and Management and Related Stockholder Matters.**

Omitted. 

**Item 13. Certain Relationships and Related Transactions, and Director Independence.**

Omitted. 

**Item 14. Principal Accounting Fees andServices.**

Omitted. 

**ADDITIONALDISCLOSURE ITEMS REQUIRED BY GENERAL INSTRUCTION J(2)**

**Item 1112(b) of Regulation AB**

No mortgage loan in the pool assets for Citigroup Commercial Mortgage Trust 2017-P7 constitutes a significant obligorwithin the meaning of Item 1101(k)(2) of Regulation AB. 

**Item 1114(b)(2) and Item 1115(b) of Regulation AB**

No entity or group of affiliated entities provides any external credit enhancement, uses any derivative instruments or other support for the certificateswithin this transaction. 

**Item 1117 of Regulation AB**

Disclosure from Citibank, N.A., as Certificate Administrator: 

Citibank, N.A. (“Citibank”) is acting as the Certificate Administrator of this commercial mortgage-backed securities (“CMBS”) transaction.In the ordinary course of business, Citibank is involved in a number of legal proceedings, including in connection with its role as trustee of certain residential mortgage-backed securities (“RMBS”) transactions. Certain of these Citibankas trustee-related matters are disclosed herein. 

On June 18, 2014, a civil action was filed against Citibank in the Supreme Court of the State ofNew York by a group of investors in 48 private-label RMBS trusts for which Citibank allegedly serves or did serve as trustee, asserting claims for purported violations of the Trust Indenture Act of 1939 (the “Trust Indenture Act”), breachof contract, breach of fiduciary duty and negligence based on Citibank’s alleged failure to perform its duties as trustee for the 48 RMBS trusts. On November 24, 2014, plaintiffs sought leave to withdraw this action. On the same day, asmaller subset of similar plaintiff investors in 27 private-label RMBS trusts for which Citibank allegedly serves or did serve as trustee, filed a new civil action against Citibank in the United States District Court for the Southern District of NewYork asserting similar claims as the prior action filed in state court. In January 2015, the court closed plaintiffs’ original state court action. On September 8, 2015, the federal court dismissed all claims as to 24 of the 27 trustsand allowed certain of the claims to proceed as to the other three trusts. Subsequently, plaintiffs voluntarily dismissed all claims with respect to two of the three trusts. On April 7, 2017, Citibank filed a motion for summary judgment.Plaintiffs filed its consolidated opposition brief and cross motion for partial summary judgment on May 22, 2017. Briefing on those motions was completed on August 4, 2017. On March 22, 2018, the court granted Citibank’s motionfor summary judgment in its entirety, denied Plaintiffs’ motion for summary judgment and ordered the clerk to close the case. On April 20, 2018, plaintiffs filed a notice of appeal. Plaintiffs’ opening brief was filed onAugust 3, 2018. Citibank filed its opposition on November 2, 2018. Plaintiffs’ filed their reply on November 16, 2018. 

On November 24, 2015, the same investors that brought the federal case brought a new civil action inthe Supreme Court of the State of New York related to 25 private-label RMBS trusts for which Citibank allegedly serves or did serve as trustee. This case includes the 24 trusts previously dismissed in the federal action, and one additional trust.The investors assert claims for breach of contract, breach of fiduciary duty, breach of duty to avoid conflicts of interest, and violation of New York’s Streit Act (the “Streit Act”). Following oral argument on Citibank’s motionto dismiss, plaintiffs filed an amended complaint on August 5, 2016. On June 27, 2017, the state court issued a decision, dismissing the event of default claims, mortgage-file-related claims, the fiduciary duty claims, and the conflict ofinterest claims. The decision sustained certain breach of contract claims including the claim alleging discovery of breaches of representations and warranties, a claim related to robo-signing, and the implied covenant of good faith claim. Citibankappealed the lower court’s decision, and on January 16, 2018, the Appellate Division, First Department, dismissed the claims related to robo-signing and the implied covenant of good faith, but allowed plaintiffs’ claim allegingdiscovery of breaches of representations and warranties to proceed. 

On August 19, 2015, the Federal Deposit Insurance Corporation (“FDIC”)as receiver for a failed financial institution filed a civil action against Citibank in the Southern District of New York. This action relates to one private-label RMBS trust for which Citibank formerly served as trustee. FDIC asserts claims forbreach of contract, violation of the Streit Act, and violation of the Trust Indenture Act. Citibank jointly briefed a motion to dismiss with The Bank of New York Mellon and U.S. Bank, N.A., entities that have also been sued by FDIC in their capacityas trustee, and these cases have all been consolidated in front of Judge Carter. On September 30, 2016, the court granted the motion to dismiss without prejudice for lack of subject matter jurisdiction. On October 14, 2016, FDIC filed amotion for reargument or relief from judgment from the court’s dismissal order. On July 11, 2017, Judge Carter ruled on the motion for reconsideration regarding his dismissal of the action. He denied reconsideration of his decision onstanding, but granted leave to amend the complaint by October 9, 2017. The FDIC subsequently requested an extension of time to file its amended complaint, which was granted. The FDIC filed its amended complaint on December 8, 2017.Defendants jointly filed a motion to dismiss the amended complaint on March 13, 2018. On April 18, 2018, plaintiff filed its opposition. Defendants filed their joint reply on May 3, 2018. 

There can be no assurances as to the outcome of litigation or the possible impact of litigation on the trustee or the RMBS trusts. However, Citibank deniesliability and continues to vigorously defend against these litigations. Furthermore, neither the above-disclosed litigations nor any other pending legal proceeding involving Citibank will materially affect Citibank’s ability to perform itsduties as Certificate Administrator under the pooling and servicing agreement for this CMBS transaction. 

Disclosure from Deutsche Bank Trust CompanyAmericas, as Trustee: 

Deutsche Bank Trust Company Americas (“DBTCA”) and Deutsche Bank National Trust Company (“DBNTC”) have beensued by investors in civil litigation concerning their role as trustees of certain residential mortgage-backed securities (“RMBS”) trusts. 

OnJune 18, 2014, a group of investors, including funds managed by Blackrock Advisors, LLC, PIMCO-Advisors, L.P., and others, filed an action against DBNTC and DBTCA in New York State Supreme Court alleging that DBNTC and DBTCA failed to performpurported duties, as trustees for 544 private-label RMBS trusts, to enforce breaches of representations and warranties as to mortgage loans held by the trusts and to enforce breaches by servicers of their mortgage loan servicing obligations for thetrusts. During the course of the litigation, plaintiffs dismissed the case from New York State Supreme Court and refiled two separate cases, one in the U.S. District Court for the Southern District of New York (the “*BlackRock*SDNYCase”) and the other in the Superior Court of California, Orange County (the “*BlackRock*California Case”). Pursuant to a settlement among the parties, the *BlackRock*SDNY Case was dismissed on December 6, 2018 andthe *BlackRock*California Case was dismissed on January 11, 2019. 

On September 27, 2017, DBTCA was added as a defendant to a case broughtby certain special purpose entities including Phoenix Light SF Limited in the U.S. District Court for the Southern District of New York, in which the plaintiffs previously alleged incorrectly that DBNTC served as trustee for all 43 of the trusts atissue. On September 27, 2017, plaintiffs filed a third amended complaint that names DBTCA as a defendant in addition to DBNTC. DBTCA serves as trustee for one of the 43 trusts at issue. DBNTC serves as trustee for the other 42 trusts at issue.Plaintiffs’ third amended complaint brings claims for violation of the U.S. Trust Indenture Act of 1939 (“TIA”); breach of contract; breach of fiduciary duty; negligence and gross negligence; violation of New York’s Streit Act(the “Streit Act”); and breach of the covenant of good faith. However, in the third amended complaint, plaintiffs acknowledge that, before DBTCA was added to the case, the court dismissed plaintiffs’ TIA Act claims, negligence andgross negligence claims, Streit Act claims, claims for breach of the covenant of good faith, and certain theories of plaintiffs’ breach of contract claims, and plaintiffs only include these claims to preserve any rights on appeal. Plaintiffsallege damages of “hundreds of millions of dollars.” On November 13, 2017, DBNTC and DBTCA filed an answer to the third amended complaint. On December 7, 2018, DBNTC and DBTCA filed a motion for summary judgment. Also onDecember 7, 2018, plaintiffs, jointly with Commerzbank AG (*see* description of *Commerzbank* case below), filed a motion for partial summary judgment. 

On November 30, 2017, DBTCA was added as a defendant to a case brought by Commerzbank AG(“Commerzbank”) in the U.S. District Court for the Southern District of New York, in which Commerzbank previously alleged incorrectly that DBNTC served as trustee for all 50 of the trusts at issue. On November 30, 2017, Commerzbankfiled a second amended complaint that names DBTCA as a defendant in addition to DBNTC. DBTCA serves as trustee for one of the 50 trusts at issue. DBNTC serves as trustee for the other 49 trusts at issue. Commerzbank’s second amended complaintbrings claims for violation of the TIA; breach of contract; breach of fiduciary duty; negligence; violation of the Streit Act; and breach of the covenant of good faith. However, in the second amended complaint, Commerzbank acknowledges that, beforeDBTCA was added to the case, the court dismissed Commerzbank’s TIA claims for the trusts governed by pooling and servicing agreements, as well as its Streit Act claims and claims for breach of the covenant of good faith, and Commerzbank onlyincludes these claims to preserve any rights on appeal. The second amended complaint alleges that DBNTC and DBTCA caused Commerzbank to suffer “hundreds of millions of dollars in losses,” but the complaint does not include a demand formoney damages in a sum certain. On January 29, 2018, DBNTC and DBTCA filed an answer to the second amended complaint. On December 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. 

On December 30, 2015, IKB International, S.A. inLiquidation and IKB Deutsche Industriebank A.G. (collectively, “IKB”), as an investor in 37 RMBS trusts, filed a summons with notice in the Supreme Court of the State of New York, New York County, against DBNTC and DBTCA as trustees of thetrusts. On May 27, 2016, IKB served its complaint asserting claims for breach of contract, breach of fiduciary duty, breach of duty to avoid conflicts of interest, violation of the Streit Act, violation of the TIA, violation of Regulation AB,and violation of Section 9 of the Uniform Commercial Code. IKB alleges that DBNTC and DBTCA 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 seven trusts. As of March 1, 2019, DBNTC and DBTCA’s motion to dismiss has been briefed andis awaiting decision by the court. 

It is DBTCA’s belief that it has no pending legal proceedings (including, based on DBTCA’s presentevaluation, the litigation disclosed in the foregoing paragraphs) that would materially affect its ability to perform its duties under the related servicing agreement for this transaction. 

Disclosure from Wells Fargo Bank, National Association, as certificate administrator and as custodian for the 229 West 43rd Street Retail Condo mortgage loanunder the CD 2016-CD2 PSA, the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan, and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA, the 111 Livingston Street mortgage loan andthe Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA, the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA, the UrbanUnion - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA and the QLIC mortgage loan under the WFCM 2016-NXS6 PSA: 

Since June 18, 2014, a group of institutional investors have filed civil complaints in the Supreme Court of the State of New York, New York County, andlater the U.S. District Court for the Southern District of New York against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in its capacity as trustee for certain residential mortgage backed securities (“RMBS”) trusts. Thecomplaints against Wells Fargo Bank alleged that the trustee caused losses to investors and asserted causes of action based upon, among other things, the trustee’s alleged failure to: (i) notify and enforce repurchase obligations ofmortgage loan sellers for purported breaches of representations and warranties, (ii) notify investors of alleged events of default, and (iii) abide by appropriate standards of care following alleged events of default. Relief soughtincluded money damages in an unspecified amount, reimbursement of expenses, and equitable relief. Wells Fargo Bank has reached an agreement, in which it denies any wrongdoing, to resolve these claims on a classwide basis for the 271 RMBS trustscurrently at issue. The settlement agreement is subject to court approval. Separate lawsuits against Wells Fargo Bank making similar allegations filed by certain other institutional investors concerning 57 RMBS trusts in New York federal and statecourt are not covered by the agreement. With respect to the foregoing litigations, Wells Fargo Bank believes plaintiffs’ claims are without merit and intends to contest the claims vigorously, but there can be no assurances as to the outcome ofthe litigations or the possible impact of the litigations on Wells Fargo Bank or the RMBS trusts. 

**Item 1119 of Regulation AB**

Provided previously in the prospectus of the Registrant relating to the issuing entity and filed on April 18, 2017 pursuant to Rule 424(b)(2) of theSecurities Act of 1933, as amended. 

**Item 1122 of Regulation AB**

The reports on assessment of compliance with servicing criteria for asset-backed securities and related attestation reports are attached hereto underItem 15. 

The report on assessment of compliance with applicable servicing criteria furnished pursuant to Item 1122 ofRegulation AB by Midland Loan Services, a Division of PNC Bank National Association (“Midland”), as master servicer and special servicer for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under theCD 2017-CD3 PSA, and as special servicer for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA, discloses thata material instance of noncompliance occurred, as described below: 

Material Instance of Noncompliance 

In certain instances, the Schedule AL Files (Item 1125 of Regulation AB) were not reported in accordance with the terms specified in thetransaction agreements, in conflict with Item 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”. The noncompliance consisted of omitted or inaccurately reported numbers due to the following: (1) theinitial setup files contained information at the asset level, and Midland was required to manually compile the information to present it at the loan level as required by Schedule AL; and (2) certain reporting requirements required manualprocessing by Midland, including the use of various data computation formulas, quality control checks and analysis. 

The identifiedinstances did not involve the servicing of the assets backing the asset-backed securities covered in this Form 10-K report. 

Steps Taken to Remedy the Material Instance of Noncompliance 

Midland is currently remediating the Schedule AL reporting for the CMBS transactions found to be incorrect, and will be making improvements toits systems, processes and procedures to support its Schedule AL reporting obligations. 

**Item 1123 of Regulation AB**

The servicer compliance statements are attached hereto under Item 15. 

**PART IV**

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

 
(a)
List the following documents filed as a part of the report: 

 
 (1)
Not Applicable 

 
 (2)
Not Applicable 

 
 (3)
Exhibits listed below are either included or incorporated by reference as indicated below:

 

**Exhibit**

**Number**
  
**Description**
4.1  Pooling and Servicing Agreement, dated as of April 1, 2017 (the “CGCMT 2017-P7 PSA”), by and among Citigroup Commercial Mortgage Securities Inc., as depositor, Wells Fargo Bank, National Association, as master servicer, Rialto Capital Advisors, LLC, as special servicer, Park Bridge Lender Services LLC, as operating advisor and asset representations reviewer, Citibank, N.A., as certificate administrator, and Deutsche Bank Trust Company Americas, as trustee (filed as Exhibit 4.1 to the registrant’sCurrent Report on Form 8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under Commission File No. 333-207132-11, and is incorporated by reference herein). 4.2  Pooling and Servicing Agreement, dated as of December 1, 2016 (the “CD 2016-CD2 PSA”), by and among Deutsche Mortgage & Asset Receiving Corporation, as depositor, Wells Fargo Bank, National Association, as master servicer, KeyBank National Association, as special servicer, Park Bridge Lender Services LLC, as operating advisor and asset representations reviewer, Wells Fargo Bank, National Association, as certificate administrator, paying agent and custodian, and Wilmington Trust, National Association, as trustee (filed as Exhibit 4.2 to the registrant’s Current Report on Form8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under Commission FileNo. 333-207132-11, and is incorporated by reference herein)1.
 
1 
The 229 West 43rd Street Retail Condo mortgage loan, which represented approximately 2.9% of the initial poolbalance of the issuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuing entity. The 229 West 43rd Street Retail Condomortgage loan and the related companion loan(s) are serviced pursuant to the CD 2016-CD2 PSA. 

4.3  Pooling and Servicing Agreement, dated as of December 1, 2016 (the “CSMC 2016-NXSR PSA”), by and among Credit Suisse Commercial Mortgage Securities Corp., as depositor, Wells Fargo Bank, National Association, as master servicer, Torchlight Loan Services, LLC, as special servicer, Park Bridge Lender Services LLC, as operating advisor and asset representations reviewer, Wells Fargo Bank, National Association, as certificate administrator, and Wilmington Trust, National Association, as trustee (filed as Exhibit 4.3 to the registrant’sCurrent Report on Form 8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under Commission File No. 333-207132-11, and is incorporated by reference herein)2. 4.4  Pooling and Servicing Agreement, dated as of February 1, 2017 (the “CD 2017-CD3 PSA”), by and among Citigroup Commercial Mortgage Securities Inc., as depositor, Midland Loan Services, a Division of PNC Bank, National Association, as master servicer, Midland Loan Services, a Division of PNC Bank, National Association, as special servicer, Park Bridge Lender Services LLC, as operating advisor and asset representations reviewer, Wells Fargo Bank, National Association, as certificate administrator, andWells Fargo Bank, National Association, as trustee (filed as Exhibit 4.4 to the registrant’s Current Report on Form 8-K dated April 18, 2017, and filed by the registrant onApril 18, 2017 under Commission File No. 333-207132-11, and is incorporated by referenceherein)3. 4.5  Pooling and Servicing Agreement, dated as of October 1, 2016 (the “WFCM 2016-NXS6 PSA”), by and among Wells Fargo Commercial Mortgage Securities, Inc., as depositor, Wells Fargo Bank, National Association, as master servicer, CWCapital Asset Management LLC, as special servicer, Trimont Real Estate Advisors, LLC, as operating advisor and asset representations reviewer, Wells Fargo Bank, National Association, as certificate administrator, and Wilmington Trust, National Association, as trustee (filed as Exhibit 4.5 to the registrant’sCurrent Report on Form 8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under Commission File No. 333-207132-11, and is incorporated by reference herein)4. 4.6  Pooling and Servicing Agreement, dated as of June 1, 2017 (the “CFCRE 2017-C8 PSA”), by and among CCRE Commercial Mortgage Securities, L.P., as depositor, Wells Fargo Bank, National Association, as master servicer, Rialto Capital Advisors, LLC, as special servicer, Park Bridge Lender Services LLC, as operating advisor and asset representations reviewer, Wells Fargo Bank, National Association, as certificate administrator, paying agent and custodian, and Wilmington Trust, National Association, astrustee (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K dated June 8, 2017, and filed by the registrant on June 14, 2017 under Commission File No. 333-207132-11, and is incorporated by reference herein)5.
 
2 
The Greenwich Office Park mortgage loan, which represented approximately 2.9% of the initial pool balance ofthe issuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuing entity. The Novo Nordisk mortgage loan, which representedapproximately 1.5% of the initial pool balance of the issuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuing entity. TheRentar Plaza mortgage loan, which represented approximately 1.2% of the initial pool balance of the issuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s)that are held outside the issuing entity. The Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan, the Rentar Plaza mortgage loan, and each of the related companion loan(s) are serviced pursuant to the CSMC 2016-NXSR PSA.
3 
The 111 Livingston Street mortgage loan, which represented approximately 2.8% of the initial pool balance ofthe issuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuing entity. The Parts Consolidation Center mortgage loan, whichrepresented approximately 1.0% of the initial pool balance of the issuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuingentity. The 111 Livingston Street mortgage loan, the Parts Consolidation Center mortgage loan, and each of the related companion loan(s) are serviced pursuant to the CD 2017-CD3 PSA. 
4 
The QLIC mortgage loan, which represented approximately 2.0% of the initial pool balance of the issuing entity,is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuing entity. The QLIC mortgage loan and the related companion loan(s) are servicedpursuant to the WFCM 2016-NXS6 PSA. 
5 
The Atlanta and Anchorage Hotel Portfolio mortgage loan, which represented approximately 2.7% of the initialpool balance of the issuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuing entity. The Atlanta and Anchorage HotelPortfolio mortgage loan and the related companion loan(s) are serviced pursuant to the CFCRE 2017-C8 PSA. 

4.7  Pooling and Servicing Agreement, dated as of June 1, 2017 (the “CSAIL 2017-C8 PSA”), by and among Credit Suisse Commercial Mortgage Securities Corp., as depositor, Wells Fargo Bank, National Association, as master servicer, Midland Loan Services, a Division of PNC Bank, National Association, as special servicer, Park Bridge Lender Services LLC, as operating advisor and asset representations reviewer, Wells Fargo Bank, National Association, as certificate administrator, and Wilmington Trust, NationalAssociation, as trustee (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K dated June 29, 2017, and filed by the registrant on July 6, 2017 under Commission FileNo. 333-207132-11, and is incorporated by reference herein)6. 31  Rule 15d-14(d) Certification 33  Reports on assessment of compliance with servicing criteria for asset-backed securities.733.1  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer (filed as Exhibit 33.1 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and isincorporated by reference herein) 33.2  Report on assessment of compliance with servicing criteria for asset-backed securities, Rialto Capital Advisors, LLC, as special servicer 33.3  Report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor (filed as Exhibit 33.3 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and isincorporated by reference herein) 33.4  Report on assessment of compliance with servicing criteria for asset-backed securities, Citibank, N.A., as certificate administrator (filed as Exhibit 33.4 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and isincorporated by reference herein) 33.5  Report on assessment of compliance with servicing criteria for asset-backed securities, Deutsche Bank Trust Company Americas, as custodian (filedas Exhibit 33.5 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and isincorporated by reference herein) 33.6  Report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant (filed as Exhibit 33.6 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 33.7  Report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant (filed as Exhibit 33.7 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and isincorporated by reference herein) 33.8  Report on assessment of compliance with servicing criteria for asset-backed securities, Principal Real Estate Investors, LLC, as servicing functionparticipant (filed as Exhibit 33.8 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 33.9  Report on assessment of compliance with servicing criteria for asset-backed securities, Berkadia Commercial Mortgage LLC, as servicing function participant (filed as Exhibit 33.9 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 
 
6 
The Urban Union - Amazon mortgage loan, which represented approximately 2.3% of the initial pool balance of theissuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuing entity. The Broadway Portfolio mortgage loan, which representedapproximately 2.0% of the initial pool balance of the issuing entity, is part of a loan combination comprised of the subject mortgage loan included in the issuing entity and one or more companion loan(s) that are held outside the issuing entity. TheUrban Union - Amazon mortgage loan, the Broadway Portfolio mortgage loan, and each of the related companion loan(s) are serviced pursuant to the CSAIL 2017-C8 PSA. 
7 
Pursuant to Instruction 3 to Item 1122 of Regulation AB, the reports on assessment of compliance with servicingcriteria and attestation reports on assessment of compliance with servicing criteria of (i) KeyBank National Association, as special servicer for the 229 West 43rd Street Retail Condo mortgage loan under the CD2016-CD2 PSA, (ii) CWCapital Asset Management LLC, as special servicer for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA and (iii) Trimont Real Estate Advisors, LLC, as operating advisor forthe QLIC mortgage loan under the WFCM 2016-NXS6 PSA, are not included in this report on Form 10-K because each of KeyBank National Association, CWCapital Asset Management LLC and Trimont Real Estate Advisors,LLC performed activities that address the servicing criteria specified in Item 1122(d) of Regulation AB with respect to 5% or less of the pool assets of the issuing entity. 

33.10  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 33.1 to the registrant’s Original Form 10-K under CommissionFile No. 333-207132-11, and is incorporated by reference herein) 33.11  Report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 33.3 to the registrant’s Original Form 10-K under CommissionFile No. 333-207132-11, and is incorporated by reference herein) 33.12  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 33.12 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 33.13  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 33.13 to the registrant’s Original Form 10-K under CommissionFile No. 333-207132-11, and is incorporated by reference herein) 33.14  Report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 33.6 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.15  Report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 33.7 to the registrant’s Original Form 10-K under CommissionFile No. 333-207132-11, and is incorporated by reference herein) 33.16  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 33.1 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 33.17  Report on assessment of compliance with servicing criteria for asset-backed securities, Torchlight Loan Services, LLC, as special servicer for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 33.17 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 33.18  Report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 33.3 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 33.19  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 33.12 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.20  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 33.13 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 33.21  Report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 33.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.22  Report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 33.7 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 
33.23  Report on assessment of compliance with servicing criteria for asset-backed securities, Midland Loan Services, a Division of PNC Bank, National Association, as master servicer for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 33.23 to the registrant’s OriginalForm 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.24  Report on assessment of compliance with servicing criteria for asset-backed securities, Midland Loan Services, a Division of PNC Bank, National Association, as special servicer for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 33.23 to the registrant’sOriginal Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.25  Report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services, LLC, as operating advisor for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 33.3 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.26  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 33.12 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.27  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 33.13 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.28  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 33.1 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.29  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 33.12 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.30  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 33.13 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.31  Report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 33.6 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 33.32  Report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 33.7 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.33  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 33.1 to the registrant’s Original Form 10-K underCommission File No. 333-207132-11, and is incorporated by reference herein) 33.34  Report on assessment of compliance with servicing criteria for asset-backed securities, Rialto Capital Advisors, LLC, as special servicer for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (see Exhibit 33.2) 33.35  Report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 33.3 to the registrant’s Original Form 10-K underCommission File No. 333-207132-11, and is incorporated by reference herein) 33.36  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 33.12 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein)
33.37  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 33.13 to the registrant’s Original Form 10-K underCommission File No. 333-207132-11, and is incorporated by reference herein) 33.38  Report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 33.6 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.39  Report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 33.7 to the registrant’s Original Form 10-K underCommission File No. 333-207132-11, and is incorporated by reference herein) 33.40  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 33.1 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.41  Report on assessment of compliance with servicing criteria for asset-backed securities, Midland Loan Services, a Division of PNC Bank, National Association, as special servicer for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 33.23 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.42  Report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 33.3 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.43  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 33.12 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.44  Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 33.13 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.45  Report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 33.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 33.46  Report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 33.7 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34  Attestation reports on assessment of compliance with servicing criteria for asset-backed securities.34.1  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer (filed as Exhibit 34.1 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 34.2  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Rialto Capital Advisors, LLC, as special servicer 34.3  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor (filed as Exhibit 34.3 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11,and is incorporated by reference herein) 34.4  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Citibank, N.A., as certificate administrator (filed as Exhibit 34.4 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and isincorporated by reference herein) 
34.5  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Deutsche Bank Trust Company Americas, as custodian (filed as Exhibit 34.5 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 34.6  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant (filed as Exhibit 34.6 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 34.7  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing functionparticipant (filed as Exhibit 34.7 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 34.8  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Principal Real Estate Investors, LLC, as servicing function participant (filed as Exhibit 34.8 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 34.9  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Berkadia Commercial Mortgage LLC, as servicing function participant (filed as Exhibit 34.9 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 34.10  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 34.1 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 34.11  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 34.3 to the registrant’s Original Form 10-K underCommission File No. 333-207132-11, and is incorporated by reference herein) 34.12  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 34.12 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.13  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 34.13 to the registrant’s Original Form 10-K underCommission File No. 333-207132-11, and is incorporated by reference herein) 34.14  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 34.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.15  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing functionparticipant for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 34.7 to the registrant’s Original Form 10-K underCommission File No. 333-207132-11, and is incorporated by reference herein) 34.16  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the Greenwich Office Park mortgage loan the Novo Nordisk mortgage loan, and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 34.1 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.17  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Torchlight Loan Services, LLC, as special servicer for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 34.17 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.18  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 34.3 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein)
34.19  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 34.12 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.20  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 34.13 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.21  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 34.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.22  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing functionparticipant for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 34.7 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.23  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Midland Loan Services, a Division of PNC Bank, National Association, as master servicer for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 34.23 to theregistrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by referenceherein) 34.24  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Midland Loan Services, a Division of PNC Bank, National Association, as special servicer for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 34.23 to theregistrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by referenceherein) 34.25  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services, LLC, as operating advisor for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 34.3 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.26  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 34.12 to the registrant’s OriginalForm 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.27  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 34.13 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.28  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 34.1 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.29  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 34.12 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.30  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 34.13 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.31  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 34.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 
34.32  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing functionparticipant for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 34.7 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.33  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 34.1 to the registrant’s Original Form10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.34  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Rialto Capital Advisors, LLC, as special servicer for the Atlanta and Anchorage Hotel Portfolio mortgage loanunder the CFCRE 2017-C8 PSA (see Exhibit 34.2) 34.35  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 34.3 to the registrant’s Original Form 10-K underCommission File No. 333-207132-11, and is incorporated by reference herein) 34.36  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 34.12 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.37  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 34.13 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 34.38  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 34.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.39  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing functionparticipant for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 34.7 to the registrant’s Original Form 10-Kunder Commission File No. 333-207132-11, and is incorporated by reference herein) 34.40  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 34.1 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.41  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Midland Loan Services, a Division of PNC Bank, National Association, as special servicer for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 34.23 to the registrant’sOriginal Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.42  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Park Bridge Lender Services LLC, as operating advisor for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 34.3 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.43  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as certificate administrator for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 34,12 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.44  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as custodian for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 34.13 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein)
34.45  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 34.6 to the registrant’s OriginalForm 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 34.46  Attestation report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing functionparticipant for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 34.7 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35  Servicer compliance statements.835.1  Servicer compliance statement, Wells Fargo Bank, National Association, as master servicer (filed as Exhibit 35.1 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.2  Servicer compliance statement, Rialto Capital Advisors, LLC, as special servicer (filed as Exhibit 35.2 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.3  Servicer compliance statement, Citibank, N.A., as certificate administrator (filed as Exhibit 35.3 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.4  Servicer compliance statement, Principal Real Estate Investors, LLC, as servicing function participant (filed as Exhibit 35.4 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.5  Servicer compliance statement, Wells Fargo Bank, National Association, as master servicer for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 35.5 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.6  Servicer compliance statement, Wells Fargo Bank, National Association, as certificate administrator for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA (filed as Exhibit 35.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.7  Servicer compliance statement, Wells Fargo Bank National Association, as master servicer for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan, and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 35.7 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.8  Servicer compliance statement, Wells Fargo Bank, National Association, as certificate administrator for the Greenwich Office Park mortgage loan,the Novo Nordisk mortgage loan, and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA (filed as Exhibit 35.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.9  Servicer compliance statement, Wells Fargo Bank, National Association, as certificate administrator for the 111 Livingston Street mortgage loanand the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA (filed as Exhibit 35.6 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 35.10  Servicer compliance statement, Wells Fargo Bank, National Association, as master servicer for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 35.10 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, andis incorporated by reference herein) 35.11  Servicer compliance statement, Wells Fargo Bank, National Association, as certificate administrator for the QLIC mortgage loan under the WFCM 2016-NXS6 PSA (filed as Exhibit 35.6 to the registrant’s Original Form 10-K under Commission FileNo. 333-207132-11, and is incorporated by reference herein) 35.12  Servicer compliance statement, Wells Fargo Bank, National Association, as master servicer for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 35.12 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.13  Servicer compliance statement, Rialto Capital Advisors, LLC, as special servicer for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 35.13 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.14  Servicer compliance statement, Wells Fargo Bank, National Association, as certificate administrator for the Atlanta and Anchorage Hotel Portfolio mortgage loan under the CFCRE 2017-C8 PSA (filed as Exhibit 35.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 
 
8 
This annual report on Form 10-K does not include the servicercompliance statements of (i) KeyBank National Association, as special servicer for the 229 West 43rd Street Retail Condo mortgage loan under the CD 2016-CD2 PSA, (ii) Torchlight Loan Services, LLC,as special servicer for the Greenwich Office Park mortgage loan, the Novo Nordisk mortgage loan, and the Rentar Plaza mortgage loan under the CSMC 2016-NXSR PSA, (iii) Midland Loan Services, a Division of PNC Bank, National Association, asmaster servicer and as special servicer for the 111 Livingston Street mortgage loan and the Parts Consolidation Center mortgage loan under the CD 2017-CD3 PSA and as special servicer for the Urban Union-Amazon mortgage loan and the Broadway Portfolio Mortgage loan under the CSAIL 2017-C8 PSA and (iv) CWCapital Asset Management LLC, as special servicer for the QLICmortgage loan under the WFCM 2016-NXS6 PSA, because each of KeyBank National Association, Torchlight Loan Services, LLC, Midland Loan Services, a Division of PNC Bank, National Association and CWCapital Asset Management LLC is an unaffiliated partythat services less than 10% of the pool assets of the issuing entity, and therefore is not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB. 

35.15  Servicer compliance statement, Wells Fargo Bank, National Association, as master servicer for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 35.15 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 35.16  Servicer compliance statement, Wells Fargo Bank, National Association, as certificate administrator for the Urban Union - Amazon mortgage loan and the Broadway Portfolio mortgage loan under the CSAIL 2017-C8 PSA (filed as Exhibit 35.6 to the registrant’s Original Form 10-K under Commission File No. 333-207132-11, and is incorporated by reference herein) 99.1  Mortgage Loan Purchase Agreement, dated as of April 1, 2017, between Citigroup Global Markets Realty Corp. and Citigroup Commercial Mortgage Securities Inc., pursuant to which Citigroup Global Markets Realty Corp. sold certain mortgage loans to Citigroup Commercial Mortgage Securities Inc. (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under Commission File No. 333-207132-11, and is incorporated by reference herein). 99.2  Mortgage Loan Purchase Agreement, dated as of April 1, 2017, between Citi Real Estate Funding Inc. and Citigroup Commercial Mortgage Securities Inc., pursuant to which Citi Real Estate Funding Inc. sold certain mortgage loans to Citigroup Commercial Mortgage Securities Inc. (filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under Commission File No. 333-207132-11, and is incorporated by reference herein). 99.3  Mortgage Loan Purchase Agreement, dated as of April 1, 2017, between Natixis Real Estate Capital LLC and Citigroup Commercial Mortgage Securities Inc., pursuant to which Natixis Real Estate Capital LLC sold certain mortgage loans to Citigroup Commercial Mortgage Securities Inc. (filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under Commission File No. 333-207132-11, and is incorporated by reference herein). 99.4  Mortgage Loan Purchase Agreement, dated as of April 1, 2017, between Macquarie US Trading LLC d/b/a Principal Commercial Capital and Citigroup Commercial Mortgage Securities Inc., pursuant to which Macquarie US Trading LLC d/b/a Principal Commercial Capital sold certain mortgage loans to Citigroup Commercial Mortgage Securities Inc. (filed as Exhibit 99.4 to the registrant’s Current Report on Form 8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under CommissionFile No. 333-207132-11, and is incorporated by reference herein). 99.5  Sub-Servicing Agreement, dated as of April 1, 2017, between Wells Fargo Bank, National Association, as master servicer, and Principal Real Estate Investors, LLC, as sub-servicer (filed as Exhibit 99.5 to the registrant’s Current Report on Form 8-K dated April 18, 2017, and filed by the registrant on April 18, 2017 under Commission File No. 333-207132-11, and is incorporated by reference herein). 
 
(b)
The exhibits required to be filed by Registrant pursuant to Item 601 of Regulation S-K are listed above. 

 
(c)
Not Applicable 

**SIGNATURES**

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

Date: November 27, 2019 

 

Citigroup Commercial Mortgage Securities Inc.

(Depositor)

/s/ Richard Simpson
Richard Simpson, President