(logo)CoreLogic

 

 

**Management’sReport on Assessment of Compliance with SEC Regulation AB**

**ServicingCriteria**

 

 

1.     CoreLogicCommercial Real Estate Services, Inc. (the “Company” or “CoreLogic”) is responsiblefor assessing compliance with the servicing criteria applicable to it underparagraph (d) of Item 1122 of Regulation AB as of and for the year endedDecember 31, 2019, (the “specified period”), as set forth in Appendix A hereto.The transactions covered by this report include commercial mortgage loanoutsourcing customers for which CoreLogic acted as the tax service provider(the “Platform”).

 

2.     Except asset forth in paragraph 3 below, CoreLogic used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to assess the compliance with theapplicable servicing criteria.

 

3.     Thecriteria listed in the column titled “Inapplicable Servicing Criteria” inAppendix A hereto are inapplicable to CoreLogic based on the activities itperformed, directly or through its Vendors, with respect to the Platform forthe specified period.

 

4.     CoreLogichas complied, in all material respects, with the applicable servicing criteriafor the specified period with respect to the Platform taken as a whole.

 

5.     GrantThornton LLP, an independent registered public accounting firm, has issued anattestation report on CoreLogic’s assessment of compliance with the applicableservicing criteria for the reporting period.

 

 

CoreLogicCommercial Real Estate Services, Inc.

January31, 2020

 

 

By:/s/ Kirk Randlett,

KirkRandlett, Executive, Operations

 

 

**Appendix A**

** **

| **SERVICING  CRITERIA**                                         | **APPLICABLE SERVICING  CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **INAPPLICABLE  SERVICING**

**CRITERIA**                                      |
|-----------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------|
| ** **

** **

** **

**Reference**               | ** **

** **

** **

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

** **

**Performed  directly**

**by    CoreLogic** | **Performed by  Vendor(s) for which CoreLogic is the    Responsible Party** | **Performed  by subservicer(s) or vendor(s) for which CoreLogic is NOT the Responsible**

**Party** | **NOT**

**performed  by CoreLogic or by      subservicer(s) or vendor(s)  retained********by**

**CoreLogic** |
| **General Servicing  Considerations**                           |
| ** **

1122(d)(1)(i)                                       | Policies and procedures are instituted  to monitor any performance or other triggers and events of default in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                                                           |   |   | ** **

**X** |
| ** **

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

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

1122(d)(1)(iv)                                      | A fidelity bond and errors and omissions  policy is in effect on the party participating in the servicing function throughout  the reporting period in the amount of coverage required by and otherwise in  accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

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

1122(d)(1)(v)                                       | ** **

An assessment is conducted of the conveyance  and mathematical accuracy of data that is aggregated by one party and then  provided to a servicing party.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                           |   |   | ** **

**X** |
| **Cash Collection  and Administration**                         |
| ** **

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

**X** |
| 1122(d)(2)(ii)                                                  | Disbursements made via wire transfer on  behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **X**                                                                          |   |   |   |
| ** **

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

**X** |
| ** **

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

**X** |
| ** **

** **

1122(d)(2)(v)                           | Each custodial account is maintained at a  federally insured depository institution as set forth in the transaction  agreements. For purposes of this criterion, “federally insured depository  institution” with respect to a foreign financial institution means a foreign  financial institution that meets the requirements of § 240.13k-1(b)(1) of  this chapter.                                                                                                                                                                                                                                                                                                                                 | ** **

** **

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

1122(d)(2)(vi)                                      | Unissued checks are safeguarded so as to  prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | ** **

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

** **

** **

** **

1122(d)(2)(vii) | Reconciliations  are prepared on a monthly basis for all asset- backed securities related bank  accounts, including custodial accounts and related bank clearing accounts.  These reconciliations: (A) Are mathematically accurate; (B) Are prepared  within 30 calendar days after the bank statement cutoff date, or such other  number of days specified in the transaction agreements; (C) Are reviewed and  approved by someone other than the person who prepared the reconciliation;  and (D) Contain explanations for reconciling items. These reconciling items  are resolved within 90 calendar days of their original identification, or  such other number of days specified in the transaction agreements. | ** **

** **

** **

** **

**X**                          |   |   |   |
| **Investor  Remittances and Reporting**                         |
| ** **

** **

** **

** **

1122(d)(3)(i)   | Reports to investors, including those to  be filed with the Commission, are maintained in accordance with thetransaction agreements and applicable  Commissionrequirements.  Specifically, such reports: (A) Are prepared in accordance with timeframes  and other terms set forth in the transaction agreements; (B) Provide  information calculated in accordance with the terms specified in the  transaction agreements; (C) Are filed with the Commission as required by its  rulesand

regulations; and  (D) Agree with investors’ or the trustee’s records as to the total unpaid  principal balance and number of pool assets serviced by the servicer.                                             |                                                                           |   |   | ** **

** **

** **

** **

**X** |
| ** **

1122(d)(3)(ii)                                      | Amounts due to investors are allocated  and remitted in accordance with timeframes, distribution priority and other  terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                                           |   |   | ** **

**X** |
| ** **

1122(d)(3)(iii)                                     | Disbursements made to an investor are  posted within two business days to the servicer’s investor records, or such  other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                                           |   |   | ** **

**X** |
| ** **

1122(d)(3)(iv)                                      | Amounts remitted to  investors per the investor reports agree with cancelled checks, or other form  of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                           |   |   | ** **

**X** |
| **Pool Asset  Administration**                                  |
| ** **

1122(d)(4)(i)                                       | Collateral or security on pool assets is  maintained as required by the transaction agreements or related pool asset  documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                                           |   |   | ** **

**X** |
| 1122(d)(4)(ii)                                                  | Pool assets and related documents are  safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                           |   |   | **X** |
| ** **

1122(d)(4)(iii)                                     | Any  additions, removals or substitutions to the asset pool are made, reviewed and  approved in accordance with any conditions or requirements in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                                           |   |   | ** **

**X** |
| ** **

** **

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

** **

**X** |
| ** **

1122(d)(4)(v)                                       | The servicer’s records  regarding the pool assets agree with the servicer’s records with respect to  an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                                           |   |   | ** **

**X** |
| ** **

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

**X** |
| ** **

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

**X** |
| ** **

** **

** **

1122(d)(4)(viii)            | Records  documenting collection efforts are maintained during the period a pool asset  is delinquent in accordance with the transaction agreements. Such records are  maintained on at least a monthly basis, or such other period specified in the

transaction  agreements, and describe the entity’s activities in monitoring delinquent  pool assets including, for example, phone calls, letters and payment rescheduling  plans in cases where delinquency is deemed temporary (e.g., illness or

unemployment).                                                                                                                                                                                            |                                                                           |   |   | ** **

** **

** **

**X** |
| ** **

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

**X** |
| ** **

** **

** **

1122(d)(4)(x)               | Regarding any funds held in trust for an  obligor (such as escrow accounts): (A) Such funds are analyzed, in accordance  with the obligor’s pool asset documents, on at least an annual basis, or such  other period specified in the transaction agreements; (B) Interest on such  funds is paid, or credited, to obligors in accordance with applicable pool  asset documents and state laws; and (C) Such funds are returned to the  obligor within 30 calendar days of full repayment of the related pool asset,  or such other number of days specified in the transaction agreements.                                                                                                                       |                                                                           |   |   | ** **

** **

** **

**X** |
| ** **

** **

1122(d)(4)(xi)                          | Payments made on behalf of an obligor  (such as tax or insurance payments) are made on or before the related penalty  or expiration dates, as indicated on the appropriate bills or notices for  such payments, provided that such support has been received by the servicer  at least 30 calendar days prior to these dates, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                    | ** **

** **

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

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

**X** |
| ** **

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

**X** |
| ** **

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

**X** |
| ** **

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

**X** |