**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****  ANNUAL REPORT PURSUANT TO SECTION13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2022or**

**o**** ****TRANSITIONREPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226486-12**

**Central Index Key Number of the issuing entity:0001797056**

**BANK 2020-BNK25**

**(exact name of the issuing entity as specified in itscharter)**

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, Inc.**

**(exact name of the depositor as specified in itscharter)**

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

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

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

**Central Index Key Number of the sponsor: 0001102113**

**Bank of America, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001577313**

**National Cooperative Bank, N.A.**

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

** **

| **New York****(State or other jurisdiction of  incorporation or organization of**

**the issuing entity)** | **38-4129140**

**38-4129141**

**38-7235663**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|

**c/o Computershare Trust Company, National Association, as agent for**

**Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

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

**(704) 374-6161**

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

| Title of each class | Trading Symbol(s) | Name of each exchange on which registered |
|---------------------|-------------------|-------------------------------------------|
| None                |              |                                      |

 

 

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

Indicate by check mark whether the registrant has submittedelectronically every Interactive Data File required to be submitted pursuant toRule 405 of Regulation S-T (Section 232.405 of this chapter) during thepreceding 12 months (or for such shorter period that the registrant wasrequired to submit such files).

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check if asmaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

Indicate by check mark whether the registrant has filed areport on and attestation to its management’s assessment of the effectivenessof its internal control over financial reporting under Section 404(b) of theSarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firmthat prepared or issued its audit report. o

 

If securities are registered pursuantto Section 12(b) of the Act, indicate by check mark whether the financialstatements of the registrant included in the filing reflect the correction ofan error to previously issued financial statements. o

 

Indicate by check mark whether any of those errorcorrections are restatements that required a recovery analysis ofincentive-based compensation received by any of the registrant’s executiveofficers during the relevant recovery period pursuant to §240.10D-1(b). o

Indicate by check mark whether the registrant is a shellcompany (as defined in Rule 12b-2 of the Act).  o Yes ⌧ No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the following documents if incorporated byreference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) intowhich the document is incorporated: (1) Any annual report to security holders;(2) Any proxy or information statement; and (3) Any prospectus filed pursuantto Rule 424(b) or (c) under the Securities Act of 1933. The listed documentsshould be clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 545 Washington Boulevard Mortgage Loan,which constituted approximately 5.0% of the asset pool of the issuing entity asof its cut-off date, is an asset of the issuing entity and is part of a loancombination that includes the 545 Washington Boulevard Mortgage Loan and threeother *pari passu* loans, which are not assets of the issuing entity. Thisloan combination, including the 545 Washington Boulevard Mortgage Loan, isbeing serviced and administered pursuant to the Pooling and ServicingAgreement, which is incorporated by reference as Exhibit 4.1 to this AnnualReport on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Park Tower at Transbay Mortgage Loan, whichconstituted approximately 3.1% of the asset pool of the issuing entity as ofits cut-off date.  The Park Tower at Transbay Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the ParkTower at Transbay Mortgage Loan and nine other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BANK 2019-BNK21 transaction, Commission FileNumber 333-228375-02 (the “BANK 2019-BNK21 Transaction”). This loancombination, including the Park Tower at Transbay Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe BANK 2019-BNK21 Transaction, which is incorporated by reference as Exhibit4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Jackson Park Mortgage Loan, which constitutedapproximately 4.6% of the asset pool of the issuing entity as of its cut-offdate.  The Jackson Park Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the Jackson Park Mortgage Loan,nine other *pari passu* loans and two subordinate companion loans, whichare not assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Jackson Park Trust 2019-LIC transaction (the“JAX 2019-LIC Transaction”). This loan combination, including theJackson Park Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the JAX 2019-LIC Transaction, which isincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Parklawn Building Mortgage Loan, whichconstituted approximately 4.0% of the asset pool of the issuing entity as ofits cut-off date.  The Parklawn Building Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the ParklawnBuilding Mortgage Loan and four other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Morgan Stanley Capital I Trust 2019-L3transaction, Commission File Number 333-227446-07 (the “MSC 2019-L3Transaction”). This loan combination, including the Parklawn BuildingMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2019-L3 Transaction, which is incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Sacramento Office Portfolio Mortgage Loan,which constituted approximately 0.9% of the asset pool of the issuing entity asof its cut-off date.  The Sacramento Office Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theSacramento Office Portfolio Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. The other *pari passu*portion of the loan combination was securitized in the BANK 2019-BNK23transaction, Commission File Number 333-227446-08 (the “BANK 2019-BNK23Transaction”). This loan combination, including the Sacramento OfficePortfolio Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the BANK 2019-BNK23 Transaction, which isincorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Bellagio Hotel and Casino Mortgage Loan,which constituted approximately 6.1% of the asset pool of the issuing entity asof its cut-off date.  The Bellagio Hotel and Casino Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theBellagio Hotel and Casino Mortgage Loan, twenty-two other *pari passu*loans and nine subordinate companion loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe BX Trust 2019-OC11 transaction (the “BX 2019-OC11 Transaction”).This loan combination, including the Bellagio Hotel and Casino Mortgage Loan,is being serviced and administered pursuant to the trust and servicingagreement for the BX 2019-OC11 Transaction, which is incorporated by referenceas Exhibit 4.6 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 55 Hudson Yards Mortgage Loan, whichconstituted approximately 6.1% of the asset pool of the issuing entity as ofits cut-off date.  The 55 Hudson Yards Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 55 HudsonYards Mortgage Loan, thirty-one other *pari passu* loans and threesubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Hudson Yards2019-55HY Mortgage Trust transaction (the “Hudson Yards 2019-55HYTransaction”). This loan combination, including the 55 Hudson YardsMortgage Loan, is being serviced and administered pursuant to the trust andservicing agreement for the Hudson Yards 2019-55HY Transaction, which isincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the 1412 Broadway Mortgage Loan, which constitutedapproximately 4.3% of the asset pool of the issuing entity as of its cut-offdate.  The 1412 Broadway Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the 1412 Broadway Mortgage Loanand two other *pari passu* loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe BANK 2019-BNK24 transaction, Commission File Number 333-228375-03 (the “BANK2019-BNK24 Transaction”). This loan combination, including the 1412Broadway Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the BANK 2019-BNK24 Transaction, which isincorporated by reference as Exhibit 4.8 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 1633 Broadway Mortgage Loan, whichconstituted approximately 6.1% of the asset pool of the issuing entity as ofits cut-off date.  The 1633 Broadway Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 1633Broadway Mortgage Loan, thirty-two other *pari passu* loans and foursubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the BWAY Trust2019-1633 transaction (the “BWAY 2019-1633 Transaction”). This loancombination, including the 1633 Broadway Mortgage Loan, is being serviced andadministered pursuant to the trust and servicing agreement for the BWAY2019-1633 Transaction, which is incorporated by reference as Exhibit 4.9 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Chroma Apartments Mortgage Loan, whichconstituted approximately 0.9% of the asset pool of the issuing entity as ofits cut-off date.  The Chroma Apartments Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the ChromaApartments Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. The other *pari passu* portion of the loancombination was securitized in the UBS Commercial Mortgage Trust 2019-C18transaction, Commission File Number 333-227784-05 (the “UBS 2019-C18Transaction”). This loan combination, including the Chroma ApartmentsMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the UBS 2019-C18 Transaction, which is incorporated byreference as Exhibit 4.10 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 560 Mission Street Mortgage Loan, whichconstituted approximately 3.1% of the asset pool of the issuing entity as ofits cut-off date.  The 560 Mission Street Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 560 MissionStreet Mortgage Loan and six other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Benchmark 2020-B16 Mortgage Trusttransaction, Commission File Number 333-226943-06 (the “Benchmark 2020-B16Transaction”). This loan combination, including the 560 Mission StreetMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2020-B16 Transaction, which isincorporated by reference as Exhibit 4.11 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Kings Plaza Mortgage Loan, which constitutedapproximately 4.6% of the asset pool of the issuing entity as of its cut-offdate.  The Kings Plaza Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Kings Plaza Mortgage Loan andten other *pari passu* loans, which are not assets of the issuing entity.This loan combination, including the Kings Plaza Mortgage Loan, was servicedunder the pooling and servicing agreement for the Benchmark 2020-B16Transaction prior to the closing of the securitization of a *pari passu*portion of the Kings Plaza loan combination in the Benchmark 2020-B17 MortgageTrust transaction, Commission File Number 333-226123-08 (the “Benchmark2020-B17 Transaction”).  After the closing of the Benchmark 2020-B17Transaction on March 24, 2020, this loan combination, including the Kings PlazaMortgage Loan was, and will continue to be, serviced and administered pursuantto the pooling and servicing agreement with respect to the Benchmark 2020-B17Transaction, which is incorporated by reference as Exhibit 4.12 to this AnnualReport on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the general master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the 55 Hudson Yards Mortgage Loan, the Jackson ParkMortgage Loan, the 1412 Broadway Mortgage Loan, the Park Tower at TransbayMortgage Loan, the Chroma Apartments Mortgage Loan and the Sacramento OfficePortfolio Mortgage Loan. As a result, Wells Fargo Bank, National Association isa “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans that constituted10% or more of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements delivered by Wells FargoBank, National Association in the capacities described above are listed in theExhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the 1633 Broadway Mortgage Loan, the 55 Hudson YardsMortgage Loan, the Bellagio Hotel and Casino Mortgage Loan, the Jackson ParkMortgage Loan, the Kings Plaza Mortgage Loan, the 1412 Broadway Mortgage Loan,the Parklawn Building Mortgage Loan, the 560 Mission Street Mortgage Loan, thePark Tower at Transbay Mortgage Loan, the Chroma Apartments Mortgage Loan andthe Sacramento Office Portfolio Mortgage Loan.  As a result, Wells FargoBank, National Association is a servicing function participant in thecapacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

KeyBank National Association isthe primary servicer of the Bellagio Hotel and Casino Mortgage Loan, the 1633Broadway Mortgage Loan and the Parklawn Building Mortgage Loan and the specialservicer of the mortgage loans serviced under the Pooling and ServicingAgreement prior to December 1, 2022, the 560 Mission Street Mortgage Loan andthe Sacramento Office Portfolio Mortgage Loan. As a result, KeyBank NationalAssociation is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby KeyBank National Association in the capacities described above are listed inthe Exhibit Index.

CWCapital Asset Management LLC isthe special servicer of the mortgage loans serviced under the Pooling andServicing Agreement on and after December 1, 2022 and the 55 Hudson YardsMortgage Loan. As a result, CWCapital Asset Management LLC is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by CWCapital Asset Management LLCin the capacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is theoperating advisor of the mortgage loans serviced under the Pooling andServicing Agreement, the 1633 Broadway Mortgage Loan and the Kings PlazaMortgage Loan.  As a result, Pentalpha Surveillance LLC is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by PentalphaSurveillance LLC in the capacities described above are listed in the ExhibitIndex.

Park Bridge Lender Services LLC isthe operating advisor of the Bellagio Hotel and Casino Mortgage Loan, the 1412Broadway Mortgage Loan, the Parklawn Building Mortgage Loan, the 560 MissionStreet Mortgage Loan, the Park Tower at Transbay Mortgage Loan, the ChromaApartments Mortgage Loan and the Sacramento Office Portfolio MortgageLoan.  As a result, Park Bridge Lender Services LLC is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Park Bridge LenderServices LLC in the capacities described above are listed in the Exhibit Index.

Situs Holdings, LLC is the specialservicer of the Bellagio Hotel and Casino Mortgage Loan, the 1633 BroadwayMortgage Loan and the Jackson Park Mortgage Loan. As a result, Situs Holdings,LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Situs Holdings, LLC in the capacities described above are listed in theExhibit Index.

LNR Partners, LLC is the specialservicer of the Parklawn Building Mortgage Loan and the 1412 Broadway MortgageLoan.  These mortgage loans constitute more than 5%, but less than 10%, ofthe pool assets of the issuing entity.  Therefore, the Depositor includedin this Annual Report on Form 10-K an assessment of compliance with applicableservicing criteria for LNR Partners, LLC and an accountants’ attestation reportpursuant to Item 1122 of Regulation AB because LNR Partners, LLC is servicingmore than 5% of the pool assets.  However, the Depositor is not requiredto include in this Annual Report on Form 10-K a servicer compliance statementpursuant to Item 1123 of Regulation AB of LNR Partners, LLC because LNRPartners, LLC is an unaffiliated servicer servicing less than 10% of poolassets.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the 560 MissionStreet Mortgage Loan and the primary servicer and special servicer of the KingsPlaza Mortgage Loan.  These mortgage loans constitute more than 5%, but lessthan 10%, of the pool assets of the issuing entity.  Therefore, theDepositor included in this Annual Report on Form 10-K an assessment ofcompliance with applicable servicing criteria for Midland Loan Services, aDivision of PNC Bank, National Association and an accountants’ attestationreport pursuant to Item 1122 of Regulation AB because Midland Loan Services, aDivision of PNC Bank, National Association is servicing more than 5% of thepool assets.  However, the Depositor is not required to include in this AnnualReport on Form 10-K a servicer compliance statement pursuant to Item 1123 ofRegulation AB of Midland Loan Services, a Division of PNC Bank, NationalAssociation because Midland Loan Services, a Division of PNC Bank, NationalAssociation is an unaffiliated servicer servicing less than 10% of pool assets.

Wells Fargo Bank, NationalAssociation acts as trustee of the Bellagio Hotel and Casino Mortgage Loan, the1633 Broadway Mortgage Loan, the 560 Mission Street Mortgage Loan and the KingsPlaza Mortgage Loan.  Pursuant to the trust and servicing agreement forthe BX 2019-OC11 Transaction, the trust and servicing agreement for the BWAY2019-1633 Transaction, the pooling and servicing agreement for the Benchmark2020-B16 Transaction and the pooling and servicing agreement for the Benchmark2020-B17 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe Bellagio Hotel and Casino Mortgage Loan, the 1633 Broadway Mortgage Loan,the 560 Mission Street Mortgage Loan and the Kings Plaza Mortgage Loan havedelivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the Park Tower at Transbay Mortgage Loan, the JacksonPark Mortgage Loan, the Parklawn Building Mortgage Loan, the Sacramento OfficePortfolio Mortgage Loan, the 55 Hudson Yards Mortgage Loan, the 1412 BroadwayMortgage Loan and the Chroma Apartments Mortgage Loan.  Pursuant to thePooling and Servicing Agreement, the pooling and servicing agreement for theBANK 2019-BNK21 Transaction, the trust and servicing agreement for the JAX2019-LIC Transaction, the pooling and servicing agreement for the MSC 2019-L3Transaction, the pooling and servicing agreement for the BANK 2019-BNK23Transaction, the trust and servicing agreement for the Hudson Yards 2019-55HYTransaction, the pooling and servicing agreement for the BANK 2019-BNK24Transaction and the pooling and servicing agreement for the UBS 2019-C18Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the ParkTower at Transbay Mortgage Loan, the Jackson Park Mortgage Loan, the ParklawnBuilding Mortgage Loan, the Sacramento Office Portfolio Mortgage Loan, the 55Hudson Yards Mortgage Loan, the 1412 Broadway Mortgage Loan and the ChromaApartments Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC  Thisentity was engaged by the general master servicer under the Pooling andServicing Agreement and the primary servicer of the Park Tower at TransbayMortgage Loan, the Jackson Park Mortgage Loan, the Sacramento Office PortfolioMortgage Loan, the 55 Hudson Yards Mortgage Loan, the 1412 Broadway MortgageLoan and the Chroma Apartments Mortgage Loan to remit tax payments receivedfrom the escrow accounts of borrowers to local taxing authorities, to reporttax amounts due, to verify tax parcel information, and to verify non-escrow taxpayments. These servicing functions are included within the servicing criteriaset forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB. Therefore, under the principles-based definition of “servicer” set forth inItem 1101(j) of Regulation AB that looks to the functions that an entityperforms, this vendor is a “servicer” for the purposes of Item 1122 ofRegulation AB.  *See* Compliance and Disclosure Interpretations,Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) of RegulationAB that looks to the functions that an entity performs, this party is a“servicer” for the purposes of Item 1123 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Park Tower at Transbay Mortgage Loan, the Jackson ParkMortgage Loan, the Parklawn Building Mortgage Loan, the Sacramento Office PortfolioMortgage Loan, the Bellagio Hotel and Casino Mortgage Loan, the 55 Hudson YardsMortgage Loan, the 1412 Broadway Mortgage Loan, the Chroma Apartments MortgageLoan, the 1633 Broadway Mortgage Loan, the 560 Mission Street Mortgage Loan andthe Kings Plaza Mortgage Loan are omitted from this Annual Report on Form 10-Kas the certificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Park Tower at Transbay Mortgage Loan, theChroma Apartments Mortgage Loan, the Parklawn Building Mortgage Loan, the 1412Broadway Mortgage Loan, the 560 Mission Street Mortgage Loan and the KingsPlaza Mortgage Loan, (i) the reports on assessment of compliance with servicingcriteria and attestation reports on assessment of compliance with servicingcriteria of Rialto Capital Advisors, LLC as special servicer of the Park Towerat Transbay Mortgage Loan and the Chroma Apartments Mortgage Loan, listed onthe Exhibit Index are omitted from this Annual Report on Form 10-K as they arenot required to be included on this Annual Report on Form 10-K per Instruction3 to Item 1122 of Regulation AB because it is a party performing activitiesthat address servicing criteria relating to 5% or less of the assets of theissuing entity; and (ii) the servicer compliance statements of Rialto CapitalAdvisors, LLC as special servicer of the Park Tower at Transbay Mortgage Loanand the Chroma Apartments Mortgage Loan, LNR Partners, LLC as special servicerof the Parklawn Building Mortgage Loan and the 1412 Broadway Mortgage Loan andMidland Loan Services, a Division of PNC Bank, National Association as primaryservicer of the 560 Mission Street Mortgage Loan and primary servicer andspecial servicer of the Kings Plaza Mortgage Loan, listed on the Exhibit Indexare omitted from this Annual Report on Form 10-K as they are not required byItem 1123 of Regulation AB to be included on this Annual Report on Form 10-Kbecause they are each an unaffiliated party that is not a “servicer” that meetsthe criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

**Item 1B.  Unresolved Staff Comments.**

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

**Item 5.  Market for Registrant’s Common Equity,Related Stockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.**

[Reserved].

**Item 7.  Management’s Discussion and Analysis ofFinancial Condition and Results of Operations.**

Omitted.

**Item 7A.  Quantitative and Qualitative DisclosuresAbout Market Risk.**

Omitted.

**Item 8.  Financial Statements and Supplementary Data.**

Omitted.

**Item 9.  Changes in and Disagreements WithAccountants on Accounting and Financial Disclosure.**

Omitted.

**Item 9A.  Controls and Procedures.**

Omitted.

**Item 9B.  Other Information.**

None.

**Item 9C.  Disclosure Regarding Foreign Jurisdictionsthat Prevent Inspections.**

None.

**PART III**

**Item 10.  Directors, Executive Officers and CorporateGovernance.**

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

**Item 12.  Security Ownership of Certain BeneficialOwners and Management and Related Stockholder Matters.**

Omitted.

**Item 13.  Certain Relationships and RelatedTransactions, and Director Independence.**

Omitted.

**Item 14.  Principal Accountant Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

**Item 1112(b) of Regulation AB, Significant ObligorFinancial Information.**

No single obligor represents 10% or more of the pool assetsheld by the issuing entity. 

 

**Item 1114(b)(2) of Regulation AB, Significant EnhancementProvider Financial Information.**

No entity or group of affiliated entities provides any external creditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

**Item 1115(b) of Regulation AB, Certain DerivativesInstruments (Financial Information).**

No entity or group of affiliated entities provides anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

**Item 1117 of Regulation AB, Legal Proceedings.**

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to CWCapital Asset Management LLC, as special servicer,and Wells Fargo Bank, National Association, as certificate administrator, astrustee and as custodian.

From time to time, CWCapital Asset Management LLC, a Delawarelimited liability company (“CWCAM”), is a party to lawsuits and other legalproceedings as part of its duties as a special servicer (e.g., enforcement ofloan obligations) and/or arising in the ordinary course of business. Other thanas set forth in the following paragraphs, there are currently no legalproceedings pending, and no legal proceedings known to be contemplated bygovernmental authorities, against CWCAM or of which any of its property is thesubject, that are material to the certificateholders. 

On December 17, 2015, U.S. Bank National Association, thetrustee under five pooling and servicing agreements for (i) Wachovia BankCommercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC CommercialMortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenceda proceeding with the Second Judicial District Court of Ramsey County,Minnesota (the “State Court”) for a declaratory judgment as to the properallocation of certain proceeds (“Disputed Proceeds”) received by CWCAM inconnection with the sale of the Peter Cooper Village and Stuyvesant Townproperty in New York, New York securing loans held by those trusts.  CWCAMwas the special servicer of such property.  The petition requests theState Court to instruct the trustee, the trust beneficiaries, and any otherinterested parties as to the amount of the Disputed Proceeds, if any, thatconstitute penalty interest and/or the amount of the Disputed Proceeds, if any,that constitute gain-on-sale proceeds, with respect to each trust.  OnFebruary 24, 2016, CWCAM made a limited appearance with the State Court to filea motion to dismiss this proceeding based on lack of jurisdiction, mootness,standing and forum non conveniens.  On July 19, 2016, the State Courtdenied CWCAM’s motion to dismiss.  On July 22, 2016, the action wasremoved to federal court in Minnesota (“Federal Court”).  On October 21,2016, the Federal Court held a hearing on the motion to transfer the action tothe United States District Court for the Southern District of New York (“SDNYCourt”), a motion to remand to state court and a motion to hear CWCAM’s requestfor reconsideration of the motion to dismiss.  On March 14, 2017, theFederal Court reserved the determination on the motion to hear CWCAM’s requestfor reconsideration of the motion to dismiss, denied the motion to remand thematter to state court and granted the motion to transfer the proceeding to theSDNY Court.  Cross motions for judgment on the pleadings were filed butthe SDNY Court was unable to decide the case based on the pleadings and theSDNY Court ordered discovery.  All fact discovery was completed inDecember, 2018 and expert discovery was completed on March 15, 2019.  Theparties submitted cross motions for summary judgment, and on March 19, 2020,the SDNY Court entered an opinion and order in which it granted summaryjudgment in CWCAM’s favor and held that CWCAM was entitled to the entire amountof penalty interest and that CWCAM’s determination of Yield Maintenance wascorrect.  In the 127-page opinion, the SDNY Court found for CWCAM on everyissue presented by the trustee’s petition, namely, that the funds in disputeconstitute penalty interest and yield maintenance, not gain-on-sale proceeds,and that the amount of penalty interest and yield maintenance was correctlycalculated. An appeal of the SDNY Court’s decision was taken on April 29,2020.  Oral argument on the appeal occurred on June 21, 2021.  OnJuly 14, 2022, the Second Circuit entered a decision affirming in part andreversing in part the SDNY Court’s decision and remanding to the SDNY Court forfurther proceedings.  The Second Circuit affirmed the SDNY’s Court holdingthat Penalty Interest and Yield Maintenance are paid before Gain-On-SaleProceeds.  The Second Circuit reversed and remanded for furtherproceedings that portion of the SDNY Court’s decision related to approximately$67.2 million in interest on advances.   On January 13, 2023, theparties entered into a settlement agreement, in which (among other things) theyagreed to stipulate that the amount of interest on advances that accrued on orbefore June 3, 2014 is $27.5 million, and that CWCAM would pay that amount intoescrow for distribution to certificateholders upon the entry of an order by theCourt approving the settlement.  U.S. Bank National Association, asTrustee for the trusts, provided notice of the settlement to all parties ininterest via a notice program approved by the Court.  A hearing on thesettlement is scheduled for March 16, 2023.

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of the Original Complaint alleged breaches of a contract and fiduciary duties by CWCAM’saffiliate, CWCapital Investments LLC in its capacity as collateral manager forthe collateralized debt obligation transaction involving CWCapital Cobalt Vr,Ltd. In total, there are 14 counts pled in the Original Complaint. Of those 14,5 claims were asserted against CWCAM for aiding and abetting breach offiduciary duty, conversion and unjust enrichment. On May 23, 2018, the OriginalComplaint was dismissed for lack of subject matter jurisdiction.   OnJune 28, 2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaintin the Supreme Court of the State of New York, County of New York styled asCWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No.653277/2018 (the “New Complaint”).  The gravamen of the New Complaint isthe same as the previous complaint filed in the United State District Court forthe Southern District of New York.  In total there are 16 counts pled inthe New Complaint. Of those 16 counts, 5 claims were asserted against CWCAM foraiding and abetting breach of fiduciary duty, conversion and unjust enrichment,1 count seeks a declaratory judgement that the plaintiff has the right toenforce the contracts in question and 1 count seeks an injunction requiring thedefendants to recognize the plaintiff as the directing holder for the trusts inquestion. On January 11, 2019, the plaintiff dismissed with prejudice thedeclaratory judgment and injunction counts.  The New Complaint and relatedsummons was not served on the defendants until July 13, 2018 and July 16,2018.  The plaintiff’s motion for a preliminary injunction was denied bythe court on July 31, 2018.  On August 3, 2018, the defendants, includingCWCAM, filed a motion to dismiss the New Complaint in its entirety. On August20, 2019, the court entered an order granting defendants’ motion almost in itsentirety, dismissing 11 of the 16 counts and partially dismissing 2 additionalcounts.  Of the remaining counts, 2 are asserted against CWCAM for aidingand abetting breach of fiduciary duty and unjust enrichment.  On September19, 2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relating to theAugust 20, 2019 dismissal order and on September 26, 2019, filed an amendedcomplaint against CWCI and CWCAM attempting to address deficiencies relating tocertain of the claims dismissed by the August 20, 2019 order.  CWCI andCWCAM filed its Motion to Dismiss the amended complaint on October 28,2019.  The court heard argument on the Motion to Dismiss the amendedcomplaint on January 22, 2020 and on October 23, 2020, the court granted themotion dismissing the amended claims.  On November 30, 2020, CWCapitalCobalt Vr Ltd filed a notice of appeal relating to the October 23, 2020dismissal order.  On April 27, 2021, the First Department affirmed thedismissal as to claims against CWCAM that were part of the August 20, 2019dismissal, but reversed the dismissal of two counts for breach of theCollateral Management Agreement against CWCI.  CWCI sought leave to filean appeal of the decision. The plaintiff also sought leave to appeal thedismissal of the claims against CWCAM.  Both requests for leave weredenied by the First Department.  On May 15, 2020, CWCI and CWCAM filed amotion to renew its motion to dismiss as to 4 of the remaining counts (includingthe remaining two counts against CWCAM for aiding and abetting breach offiduciary duty and unjust enrichment), based on a decision entered by JudgeFailla in a trust instruction proceeding  in the US District Court for theSouthern District of New York awarding summary judgment in favor ofCWCAM.  On September 7, 2021, the court denied the motion to renew. CWCI and CWCAM filed a notice of appeal, which they perfected by the filing oftheir opening brief on July 1, 2022.  On November 15, 2022, the First Departmentaffirmed the court’s denial of the motion to renew.  On October 1, 2021,CWCI and CWCAM moved to reargue the denial of the motion to renew (oralternatively, the motion to dismiss) with respect to certain of Cobalt’sclaims, including the remaining 2 claims against CWCAM, based on the FirstDepartment’s April 27, 2021 decision.  On March 24, 2022, the court deniedthe relief sought in the motion to reargue.  CWCI and CWCAM have appealedthe court’s decision on the motion to reargue and filed their opening brief onJuly 11, 2022.  The appeal was dismissed as being non-appealable on August30, 2022.  CWCAM believes that it has performed its obligations under therelated pooling and servicing agreements in good faith and the remainingallegations in the New Complaint are without merit.   

In December 2014, Phoenix Light SF Limited (Phoenix Light)and certain related entities filed a complaint in the United States DistrictCourt for the Southern District of New York alleging claims against Wells FargoBank, N.A., in its capacity as trustee for a number of residentialmortgage-backed securities (RMBS) trusts. Complaints raising similarallegations have been filed by Commerzbank AG in the Southern District of NewYork and by IKB International and IKB Deutsche Industriebank in New York statecourt. In each case, the plaintiffs allege that Wells Fargo Bank, N.A., astrustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. In July 2022, the district court dismissed Phoenix Light’s claims andcertain of the claims asserted by Commerzbank AG, and subsequently enteredjudgment in each case in favor of Wells Fargo Bank, N.A. In August 2022,Phoenix Light and Commerzbank AG appealed the district court’s decision to theUnited States Court of Appeals for the Second Circuit. The Company previouslysettled two class actions filed by institutional investors and an action filedby the National Credit Union Administration with similar allegations. Inaddition, Park Royal I LLC and Park Royal II LLC have filed substantiallysimilar lawsuits in New York state court alleging Wells Fargo Bank, N.A., astrustee, failed to take appropriate actions upon learning of defective mortgageloan documentation.

**Item 1119 of Regulation AB, Affiliations and CertainRelationships and Related Transactions.**

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on February 13, 2020 pursuant to Rule 424(b)(2).

**Item 1122 of Regulation AB, Compliance with ApplicableServicing Criteria.**

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AAto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Park Tower at Transbay MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the BANK 2019-BNK21 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thepooling and servicing agreement for the BANK 2019-BNK21 Transactionincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K is achart identifying the entities participating in a servicing function for theBANK 2019-BNK21 Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Jackson Park Mortgage Loan, whichis being serviced and administered pursuant to the trust and servicingagreement for the JAX 2019-LIC Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit K to the trust andservicing agreement for the JAX 2019-LIC Transaction incorporated by referenceas Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the JAX 2019-LIC Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Parklawn Building Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the MSC 2019-L3 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the MSC 2019-L3 Transaction incorporated by referenceas Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the MSC 2019-L3 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Sacramento Office PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the BANK 2019-BNK23 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Zto the pooling and servicing agreement for the BANK 2019-BNK23 Transactionincorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBANK 2019-BNK23 Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Bellagio Hotel and CasinoMortgage Loan, which is being serviced and administered pursuant to the trustand servicing agreement for the BX 2019-OC11 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the BX 2019-OC11 Transaction incorporated byreference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BX2019-OC11 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 55 Hudson Yards Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the Hudson Yards 2019-55HY Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule I to the trustand servicing agreement for the Hudson Yards 2019-55HY Transaction incorporatedby reference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the HudsonYards 2019-55HY Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 1412 Broadway Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2019-BNK24 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the BANK 2019-BNK24 Transaction incorporated byreference as Exhibit 4.8 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BANK2019-BNK24 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 1633 Broadway Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the BWAY 2019-1633 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the BWAY 2019-1633 Transaction incorporated byreference as Exhibit 4.9 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BWAY2019-1633 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicing criteriafor asset-backed securities and related attestation reports on such assessmentsof compliance with respect to the Chroma Apartments Mortgage Loan, which isbeing serviced and administered pursuant to the pooling and servicing agreementfor the UBS 2019-C18 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit Z to the pooling and servicingagreement for the UBS 2019-C18 Transaction incorporated by reference as Exhibit4.10 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the UBS 2019-C18 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 560 Mission Street Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2020-B16 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Schedule II to thepooling and servicing agreement for the Benchmark 2020-B16 Transactionincorporated by reference as Exhibit 4.11 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2020-B16 Transaction responsible for each applicable servicingcriteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Kings Plaza Mortgage Loan, whichis being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2020-B17 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the Benchmark 2020-B17 Transactionincorporated by reference as Exhibit 4.12 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBenchmark 2020-B17 Transaction responsible for each applicable servicingcriteria set forth in Item 1122(d).

The report on assessmentof compliance for the twelve months ended December 31, 2022, furnished pursuantto Item 1122 of Regulation AB by KeyBank National Association (“KeyBank”), asservicer, discloses that the following material instance of noncomplianceoccurred with respect to its platform:

The examination performed by Ernst & Young LLP identifiedan instance of material noncompliance with the servicing criteria set forth inItem 1122(d)(4)(ix) of Regulation AB applicable to KeyBank during the yearended December 31, 2022. During compliance testing, it was discovered, that notall FlexARM loan mortgagors were offered loan rates within 45-60 days beforethe rate change date, as required per the related pool asset documents. Per therelated note, if the holder fails to offer a loan rate within 45-60 days of anychange date a margin of 2.25% is to be used. Given the notification was notmade to the borrowers, a 3% margin was incorrectly applied. The noncompliancein Item 1122 (d)(4)(ix) is related to a servicing portfolio which is wholly ownedby the investor and is not held in a publicly traded security.

The following remediation procedures have been initiated byKeyBank: (i) the impacted mortgage loans are currently in the process of beingidentified, (ii) investor contact has been initiated, (iii) corrective actionsare being considered and will be tracked and monitored by senior management,(iv) procedures will be reviewed and revised, if necessary, to include newtracking and action steps to prevent this situation from recurring in the future,and (v) training will be provided to the relevant staff members to prevent arecurrence.

**Item 1123 of Regulation AB, Servicer Compliance Statement.**

The servicer compliance statements are attached as Exhibitsto this Annual Report on Form 10-K.

**PART IV**

**Item 15. Exhibit and Financial Statement Schedules.**

(a) The following is a list of documents filed as part ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Pooling and Servicing Agreement, dated as of February 1,2020, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,KeyBank National Association, as General Special Servicer, National CooperativeBank, N.A., as NCB Master Servicer and as NCB Special Servicer, Wells FargoBank, National Association, as Certificate Administrator, Wilmington Trust,National Association, as Trustee, and Pentalpha Surveillance LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K filed on February 13, 2020 underCommission File No. 333-226486-12 and incorporated by reference herein).

4.2          Pooling and Servicing Agreement, dated as of October 1,2019, by and among Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 99.12 to theregistrant’s Current Report on Form 8-K filed on February 13, 2020 underCommission File No. 333-226486-12 and incorporated by reference herein).

4.3          Trust and Servicing Agreement, dated as of November 15,2019, by and among Banc of America Merrill Lynch Large Loan, Inc., asDepositor, Wells Fargo Bank, National Association, as Servicer, AEGON USARealty Advisors, LLC, as Special Servicer, Wilmington Trust, NationalAssociation, as Trustee, and Wells Fargo Bank, National Association, asCertificate Administrator (filed as Exhibit 99.8 to the registrant’s CurrentReport on Form 8-K filed on February 13, 2020 under Commission File No.333-226486-12 and incorporated by reference herein).

4.4          Pooling and Servicing Agreement, dated as of November 1,2019, by and among Morgan Stanley Capital I Inc., as Depositor, Wells FargoBank, National Association, as Master Servicer, LNR Partners, LLC, as GeneralSpecial Servicer, Situs Holdings, LLC, as ILPT Industrial Portfolio SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and Asset Representations Reviewer (filed asExhibit 99.11 to the registrant’s Current Report on Form 8-K filed on February13, 2020 under Commission File No. 333-226486-12 and incorporated by referenceherein).

4.5          Pooling and Servicing Agreement, dated as of December 1,2019, by and among Morgan Stanley Capital I Inc., as Depositor, Wells FargoBank, National Association, as Master Servicer, KeyBank National Association,as Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.14 to the registrant’s Current Report on Form 8-Kfiled on February 13, 2020 under Commission File No. 333-226486-12 andincorporated by reference herein).

4.6          Trust and Servicing Agreement, dated as of December 1,2019, by and among Morgan Stanley Capital I Inc., as Depositor, KeyBankNational Association, as Servicer, Situs Holdings, LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator, Custodianand Trustee, and Park Bridge Lender Services LLC, as Operating Advisor (filedas Exhibit 99.7 to the registrant’s Current Report on Form 8-K filed onFebruary 13, 2020 under Commission File No. 333-226486-12 and incorporated byreference herein).

4.7          Trust and Servicing Agreement, dated as of December 6,2019, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer,CWCapital Asset Management LLC, as Special Servicer, Wilmington Trust, NationalAssociation, as Trustee, and Wells Fargo Bank, National Association, asCertificate Administrator, as Paying Agent and as Custodian (filed as Exhibit99.5 to the registrant’s Current Report on Form 8-K filed on February 13, 2020under Commission File No. 333-226486-12 and incorporated by reference herein).

4.8          Pooling and Servicing Agreement, dated as of December 1,2019, between Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Midland Loan Services, a Division of PNC Bank, National Association, as GeneralSpecial Servicer, National Cooperative Bank, N.A., as NCB Master Servicer andas NCB Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 99.10 to the registrant’s Current Report on Form 8-Kfiled on February 13, 2020 under Commission File No. 333-226486-12 andincorporated by reference herein).

4.9          Trust and Servicing Agreement, dated as of December 20,2019, among GS Mortgage Securities Corporation II, as Depositor, KeyBankNational Association, as Servicer, Situs Holdings, LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator, Custodianand Trustee, and Pentalpha Surveillance LLC, as Operating Advisor (filed asExhibit 99.6 to the registrant’s Current Report on Form 8-K filed on February13, 2020 under Commission File No. 333-226486-12 and incorporated by referenceherein).

4.10        Pooling and Servicing Agreement, dated as of December 1,2019, among UBS Commercial Mortgage Securitization Corp., as Depositor, WellsFargo Bank, National Association, as Master Servicer, Rialto Capital Advisors,LLC as Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 99.13 to the registrant’s Current Report on Form 8-Kfiled on February 13, 2020 under Commission File No. 333-226486-12 andincorporated by reference herein).

4.11        Pooling and Servicing Agreement, dated as of February 1,2020, by and among Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer, KeyBank National Association, as Special Servicer, WellsFargo Bank, National Association, as Trustee, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Paying Agent and Custodian, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.9 to the registrant’s Current Report on Form 8-Kfiled on February 13, 2020 under Commission File No. 333-226486-12 andincorporated by reference herein).

4.12        Pooling and Servicing Agreement, dated as of March 1,2020, between J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, Midland Loan Services, a Division of PNC Bank, National Association,as Master Servicer, Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wells Fargo Bank, National Association, as Trustee,and Pentalpha Surveillance LLC, as Operating Advisor and as AssetRepresentations Reviewer (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on March 30, 2020 under Commission File No.333-226486-12 and incorporated by reference herein).

31           Rule 13a-14(d)/15d-14(d) Certifications.

33           Reports on assessment of compliance with servicing criteria for asset-backedsecurities.

33.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

33.2        National Cooperative Bank, N.A., as NCB MasterServicer

33.3        KeyBank National Association, as General SpecialServicer prior to December 1, 2022

33.4        CWCapital Asset Management LLC, as General SpecialServicer on and after December 1, 2022

33.5        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 33.2)

33.6        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

33.7        Wells Fargo Bank, National Association, asCertificate Administrator

33.8        Wells Fargo Bank, National Association, as Custodian

33.9        Pentalpha Surveillance LLC, as Operating Advisor

33.10      CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

33.12      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

33.13      Wells Fargo Bank, National Association, as PrimaryServicer of the 545 Washington Boulevard Mortgage Loan (see Exhibit 33.1)

33.14      KeyBank National Association, as Special Servicerof the 545 Washington Boulevard Mortgage Loan prior to December 1, 2022 (seeExhibit 33.3)

33.15      CWCapital Asset Management LLC, as Special Servicerof the 545 Washington Boulevard Mortgage Loan on and after December 1, 2022(see Exhibit 33.4)

33.16      Wilmington Trust, National Association, as Trustee of the 545 WashingtonBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

33.17      Wells Fargo Bank, National Association, asCustodian of the 545 Washington Boulevard Mortgage Loan (see Exhibit 33.8)

33.18      Pentalpha Surveillance LLC, as Operating Advisor ofthe 545 Washington Boulevard Mortgage Loan (see Exhibit 33.9)

33.19      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 545 Washington Boulevard Mortgage Loan (see Exhibit 33.10)

33.20       Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.12)

33.21      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.1)

33.22      Rialto Capital Advisors, LLC, as Special Servicer of the Park Tower at TransbayMortgage Loan (Omitted. See Explanatory Notes.)

33.23      Wilmington Trust, National Association, as Trustee of the Park Tower atTransbay Mortgage Loan (Omitted. See Explanatory Notes.)

33.24      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.8)

33.25      Park Bridge Lender Services LLC, as OperatingAdvisor of the Park Tower at Transbay Mortgage Loan

33.26      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 33.10)

33.27      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.28      Wells Fargo Bank, National Association, as PrimaryServicer of the Jackson Park Mortgage Loan (see Exhibit 33.1)

33.29      Situs Holdings, LLC, as Special Servicer of theJackson Park Mortgage Loan

33.30      Wilmington Trust, National Association, as Trustee of the Jackson Park MortgageLoan (Omitted. See Explanatory Notes.)

33.31      Wells Fargo Bank, National Association, asCustodian of the Jackson Park Mortgage Loan (see Exhibit 33.8)

33.32      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Jackson Park Mortgage Loan (see Exhibit 33.10)

33.33      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.34      KeyBank National Association, as Primary Servicerof the Parklawn Building Mortgage Loan (see Exhibit 33.3)

33.35      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan

33.36      Wilmington Trust, National Association, as Trustee of the Parklawn BuildingMortgage Loan (Omitted. See Explanatory Notes.)

33.37      Wells Fargo Bank, National Association, asCustodian of the Parklawn Building Mortgage Loan (see Exhibit 33.8)

33.38      Park Bridge Lender Services LLC, as OperatingAdvisor of the Parklawn Building Mortgage Loan (see Exhibit 33.25)

33.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.40      Wells Fargo Bank, National Association, as PrimaryServicer of the Sacramento Office Portfolio Mortgage Loan (see Exhibit 33.1)

33.41      KeyBank National Association, as Special Servicerof the Sacramento Office Portfolio Mortgage Loan (see Exhibit 33.3)

33.42      Wilmington Trust, National Association, as Trustee of the Sacramento OfficePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.43      Wells Fargo Bank, National Association, asCustodian of the Sacramento Office Portfolio Mortgage Loan (see Exhibit 33.8)

33.44      Park Bridge Lender Services LLC, as OperatingAdvisor of the Sacramento Office Portfolio Mortgage Loan (see Exhibit 33.25)

33.45      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Sacramento Office Portfolio Mortgage Loan (see Exhibit33.10)

33.46      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.47      KeyBank National Association, as Primary Servicerof the Bellagio Hotel and Casino Mortgage Loan (see Exhibit 33.3)

33.48      Situs Holdings, LLC, as Special Servicer of theBellagio Hotel and Casino Mortgage Loan (see Exhibit 33.29)

33.49      Wells Fargo Bank, National Association, as Trustee of the Bellagio Hotel andCasino Mortgage Loan (Omitted. See Explanatory Notes.)

33.50      Wells Fargo Bank, National Association, asCustodian of the Bellagio Hotel and Casino Mortgage Loan (see Exhibit 33.8)

33.51      Park Bridge Lender Services LLC, as OperatingAdvisor of the Bellagio Hotel and Casino Mortgage Loan (see Exhibit 33.25)

33.52      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.53      Wells Fargo Bank, National Association, as PrimaryServicer of the 55 Hudson Yards Mortgage Loan (see Exhibit 33.1)

33.54      CWCapital Asset Management LLC, as Special Servicerof the 55 Hudson Yards Mortgage Loan (see Exhibit 33.4)

33.55      Wilmington Trust, National Association, as Trustee of the 55 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

33.56      Wells Fargo Bank, National Association, asCustodian of the 55 Hudson Yards Mortgage Loan (see Exhibit 33.8)

33.57      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 55 Hudson Yards Mortgage Loan (see Exhibit 33.10)

33.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.59      Wells Fargo Bank, National Association, as PrimaryServicer of the 1412 Broadway Mortgage Loan (see Exhibit 33.1)

33.60      LNR Partners, LLC, as Special Servicer of the 1412Broadway Mortgage Loan (see Exhibit 33.35)

33.61      Wilmington Trust, National Association, as Trustee of the 1412 BroadwayMortgage Loan (Omitted. See Explanatory Notes.)

33.62      Wells Fargo Bank, National Association, asCustodian of the 1412 Broadway Mortgage Loan (see Exhibit 33.8)

33.63      Park Bridge Lender Services LLC, as OperatingAdvisor of the 1412 Broadway Mortgage Loan (see Exhibit 33.25)

33.64      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 1412 Broadway Mortgage Loan (see Exhibit 33.10)

33.65      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.66      KeyBank National Association, as Primary Servicerof the 1633 Broadway Mortgage Loan (see Exhibit 33.3)

33.67      Situs Holdings, LLC, as Special Servicer of the1633 Broadway Mortgage Loan (see Exhibit 33.29)

33.68      Wells Fargo Bank, National Association, as Trustee of the 1633 BroadwayMortgage Loan (Omitted. See Explanatory Notes.)

33.69      Wells Fargo Bank, National Association, asCustodian of the 1633 Broadway Mortgage Loan (see Exhibit 33.8)

33.70      Pentalpha Surveillance LLC, as Operating Advisor ofthe 1633 Broadway Mortgage Loan (see Exhibit 33.9)

33.71      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.72      Wells Fargo Bank, National Association, as PrimaryServicer of the Chroma Apartments Mortgage Loan (see Exhibit 33.1)

33.73      Rialto Capital Advisors, LLC, as Special Servicer of the Chroma ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

33.74      Wilmington Trust, National Association, as Trustee of the Chroma ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

33.75      Wells Fargo Bank, National Association, asCustodian of the Chroma Apartments Mortgage Loan (see Exhibit 33.8)

33.76      Park Bridge Lender Services LLC, as OperatingAdvisor of the Chroma Apartments Mortgage Loan (see Exhibit 33.25)

33.77      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Chroma Apartments Mortgage Loan (see Exhibit 33.10)

33.78      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.79      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 560 Mission Street MortgageLoan

33.80      KeyBank National Association, as Special Servicerof the 560 Mission Street Mortgage Loan (see Exhibit 33.3)

33.81      Wells Fargo Bank, National Association, as Trustee of the 560 Mission StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.82      Wells Fargo Bank, National Association, asCustodian of the 560 Mission Street Mortgage Loan (see Exhibit 33.8)

33.83      Park Bridge Lender Services LLC, as OperatingAdvisor of the 560 Mission Street Mortgage Loan (see Exhibit 33.25)

33.84      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

33.85      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Kings Plaza Mortgage Loan (seeExhibit 33.79)

33.86      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Kings Plaza Mortgage Loan (seeExhibit 33.79)

33.87      Wells Fargo Bank, National Association, as Trustee of the Kings Plaza MortgageLoan (Omitted. See Explanatory Notes.)

33.88      Wells Fargo Bank, National Association, asCustodian of the Kings Plaza Mortgage Loan (see Exhibit 33.8)

33.89      Pentalpha Surveillance LLC, as Operating Advisor ofthe Kings Plaza Mortgage Loan (see Exhibit 33.9)

33.90      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.12)

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

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

34.2        National Cooperative Bank, N.A., as NCB MasterServicer

34.3        KeyBank National Association, as General SpecialServicer prior to December 1, 2022

34.4        CWCapital Asset Management LLC, as General SpecialServicer on and after December 1, 2022

34.5        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 34.2)

34.6        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

34.7        Wells Fargo Bank, National Association, asCertificate Administrator

34.8        Wells Fargo Bank, National Association, asCustodian

34.9        Pentalpha Surveillance LLC, as Operating Advisor

34.10      CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

34.12      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

34.13      Wells Fargo Bank, National Association, as PrimaryServicer of the 545 Washington Boulevard Mortgage Loan (see Exhibit 34.1)

34.14      KeyBank National Association, as Special Servicer ofthe 545 Washington Boulevard Mortgage Loan prior to December 1, 2022 (seeExhibit 34.3)

34.15      CWCapital Asset Management LLC, as Special Servicerof the 545 Washington Boulevard Mortgage Loan on and after December 1, 2022(see Exhibit 34.4)

34.16      Wilmington Trust, National Association, as Trustee of the 545 WashingtonBoulevard Mortgage Loan (Omitted. See Explanatory Notes.)

34.17      Wells Fargo Bank, National Association, asCustodian of the 545 Washington Boulevard Mortgage Loan (see Exhibit 34.8)

34.18      Pentalpha Surveillance LLC, as Operating Advisor ofthe 545 Washington Boulevard Mortgage Loan (see Exhibit 34.9)

34.19      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 545 Washington Boulevard Mortgage Loan (see Exhibit 34.10)

34.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.21      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.1)

34.22      Rialto Capital Advisors, LLC, as Special Servicer of the Park Tower at TransbayMortgage Loan (Omitted. See Explanatory Notes.)

34.23      Wilmington Trust, National Association, as Trustee of the Park Tower atTransbay Mortgage Loan (Omitted. See Explanatory Notes.)

34.24      Wells Fargo Bank, National Association, asCustodian of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.8)

34.25      Park Bridge Lender Services LLC, as OperatingAdvisor of the Park Tower at Transbay Mortgage Loan

34.26      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Park Tower at Transbay Mortgage Loan (see Exhibit 34.10)

34.27      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.28      Wells Fargo Bank, National Association, as PrimaryServicer of the Jackson Park Mortgage Loan (see Exhibit 34.1)

34.29      Situs Holdings, LLC, as Special Servicer of theJackson Park Mortgage Loan

34.30      Wilmington Trust, National Association, as Trustee of the Jackson Park MortgageLoan (Omitted. See Explanatory Notes.)

34.31      Wells Fargo Bank, National Association, asCustodian of the Jackson Park Mortgage Loan (see Exhibit 34.8)

34.32      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Jackson Park Mortgage Loan (see Exhibit 34.10)

34.33      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.34      KeyBank National Association, as Primary Servicerof the Parklawn Building Mortgage Loan (see Exhibit 34.3)

34.35      LNR Partners, LLC, as Special Servicer of theParklawn Building Mortgage Loan

34.36      Wilmington Trust, National Association, as Trustee of the Parklawn BuildingMortgage Loan (Omitted. See Explanatory Notes.)

34.37      Wells Fargo Bank, National Association, asCustodian of the Parklawn Building Mortgage Loan (see Exhibit 34.8)

34.38      Park Bridge Lender Services LLC, as OperatingAdvisor of the Parklawn Building Mortgage Loan (see Exhibit 34.25)

34.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.40      Wells Fargo Bank, National Association, as PrimaryServicer of the Sacramento Office Portfolio Mortgage Loan (see Exhibit 34.1)

34.41      KeyBank National Association, as Special Servicerof the Sacramento Office Portfolio Mortgage Loan (see Exhibit 34.3)

34.42      Wilmington Trust, National Association, as Trustee of the Sacramento OfficePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.43      Wells Fargo Bank, National Association, asCustodian of the Sacramento Office Portfolio Mortgage Loan (see Exhibit 34.8)

34.44      Park Bridge Lender Services LLC, as OperatingAdvisor of the Sacramento Office Portfolio Mortgage Loan (see Exhibit 34.25)

34.45      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Sacramento Office Portfolio Mortgage Loan (see Exhibit34.10)

34.46      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.47      KeyBank National Association, as Primary Servicerof the Bellagio Hotel and Casino Mortgage Loan (see Exhibit 34.3)

34.48      Situs Holdings, LLC, as Special Servicer of theBellagio Hotel and Casino Mortgage Loan (see Exhibit 34.29)

34.49      Wells Fargo Bank, National Association, as Trustee of the Bellagio Hotel andCasino Mortgage Loan (Omitted. See Explanatory Notes.)

34.50      Wells Fargo Bank, National Association, asCustodian of the Bellagio Hotel and Casino Mortgage Loan (see Exhibit 34.8)

34.51      Park Bridge Lender Services LLC, as OperatingAdvisor of the Bellagio Hotel and Casino Mortgage Loan (see Exhibit 34.25)

34.52      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.53      Wells Fargo Bank, National Association, as PrimaryServicer of the 55 Hudson Yards Mortgage Loan (see Exhibit 34.1)

34.54      CWCapital Asset Management LLC, as Special Servicerof the 55 Hudson Yards Mortgage Loan (see Exhibit 34.4)

34.55      Wilmington Trust, National Association, as Trustee of the 55 Hudson YardsMortgage Loan (Omitted. See Explanatory Notes.)

34.56      Wells Fargo Bank, National Association, asCustodian of the 55 Hudson Yards Mortgage Loan (see Exhibit 34.8)

34.57      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 55 Hudson Yards Mortgage Loan (see Exhibit 34.10)

34.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.59      Wells Fargo Bank, National Association, as PrimaryServicer of the 1412 Broadway Mortgage Loan (see Exhibit 34.1)

34.60      LNR Partners, LLC, as Special Servicer of the 1412Broadway Mortgage Loan (see Exhibit 34.35)

34.61      Wilmington Trust, National Association, as Trustee of the 1412 BroadwayMortgage Loan (Omitted. See Explanatory Notes.)

34.62      Wells Fargo Bank, National Association, asCustodian of the 1412 Broadway Mortgage Loan (see Exhibit 34.8)

34.63      Park Bridge Lender Services LLC, as OperatingAdvisor of the 1412 Broadway Mortgage Loan (see Exhibit 34.25)

34.64      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 1412 Broadway Mortgage Loan (see Exhibit 34.10)

34.65      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.66      KeyBank National Association, as Primary Servicerof the 1633 Broadway Mortgage Loan (see Exhibit 34.3)

34.67      Situs Holdings, LLC, as Special Servicer of the 1633Broadway Mortgage Loan (see Exhibit 34.29)

34.68      Wells Fargo Bank, National Association, as Trustee of the 1633 BroadwayMortgage Loan (Omitted. See Explanatory Notes.)

34.69      Wells Fargo Bank, National Association, asCustodian of the 1633 Broadway Mortgage Loan (see Exhibit 34.8)

34.70      Pentalpha Surveillance LLC, as Operating Advisor ofthe 1633 Broadway Mortgage Loan (see Exhibit 34.9)

34.71      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.72      Wells Fargo Bank, National Association, as PrimaryServicer of the Chroma Apartments Mortgage Loan (see Exhibit 34.1)

34.73      Rialto Capital Advisors, LLC, as Special Servicer of the Chroma ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

34.74      Wilmington Trust, National Association, as Trustee of the Chroma ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

34.75      Wells Fargo Bank, National Association, asCustodian of the Chroma Apartments Mortgage Loan (see Exhibit 34.8)

34.76      Park Bridge Lender Services LLC, as OperatingAdvisor of the Chroma Apartments Mortgage Loan (see Exhibit 34.25)

34.77      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Chroma Apartments Mortgage Loan (see Exhibit 34.10)

34.78      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.79      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the 560 Mission Street MortgageLoan

34.80      KeyBank National Association, as Special Servicerof the 560 Mission Street Mortgage Loan (see Exhibit 34.3)

34.81      Wells Fargo Bank, National Association, as Trustee of the 560 Mission StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.82      Wells Fargo Bank, National Association, as Custodianof the 560 Mission Street Mortgage Loan (see Exhibit 34.8)

34.83      Park Bridge Lender Services LLC, as OperatingAdvisor of the 560 Mission Street Mortgage Loan (see Exhibit 34.25)

34.84      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

34.85      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the Kings Plaza Mortgage Loan (see Exhibit34.79)

34.86      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Kings Plaza Mortgage Loan (seeExhibit 34.79)

34.87      Wells Fargo Bank, National Association, as Trustee of the Kings Plaza MortgageLoan (Omitted. See Explanatory Notes.)

34.88      Wells Fargo Bank, National Association, asCustodian of the Kings Plaza Mortgage Loan (see Exhibit 34.8)

34.89      Pentalpha Surveillance LLC, as Operating Advisor ofthe Kings Plaza Mortgage Loan (see Exhibit 34.9)

34.90      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.12)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

35.2        National Cooperative Bank, N.A., as NCB MasterServicer

35.3        KeyBank National Association, as General SpecialServicer prior to December 1, 2022

35.4        CWCapital Asset Management LLC, as General SpecialServicer on and after December 1, 2022

35.5        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 35.2)

35.6        Wells Fargo Bank, National Association, asCertificate Administrator

35.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

35.8        Wells Fargo Bank, National Association, as PrimaryServicer of the 545 Washington Boulevard Mortgage Loan (see Exhibit 35.1)

35.9        KeyBank National Association, as Special Servicerof the 545 Washington Boulevard Mortgage Loan prior to December 1, 2022 (seeExhibit 35.3)

35.10      CWCapital Asset Management LLC, as Special Servicerof the 545 Washington Boulevard Mortgage Loan on and after December 1, 2022(See Exhibit 35.4)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of the Park Tower at Transbay Mortgage Loan (see Exhibit 35.1)

35.12      Rialto Capital Advisors, LLC, as Special Servicer of the Park Tower at TransbayMortgage Loan (Omitted. See Explanatory Notes.)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the Jackson Park Mortgage Loan (see Exhibit 35.1)

35.14      Situs Holdings, LLC, as Special Servicer of theJackson Park Mortgage Loan

35.15      KeyBank National Association, as Primary Servicerof the Parklawn Building Mortgage Loan (see Exhibit 35.3)

35.16      LNR Partners, LLC, as Special Servicer of the Parklawn Building Mortgage Loan(Omitted. See Explanatory Notes.)

35.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Sacramento Office Portfolio Mortgage Loan (see Exhibit 35.1)

35.18      KeyBank National Association, as Special Servicerof the Sacramento Office Portfolio Mortgage Loan (see Exhibit 35.3)

35.19      KeyBank National Association, as Primary Servicerof the Bellagio Hotel and Casino Mortgage Loan (see Exhibit 35.3)

35.20      Situs Holdings, LLC, as Special Servicer of theBellagio Hotel and Casino Mortgage Loan (see Exhibit 35.14)

35.21      Wells Fargo Bank, National Association, as PrimaryServicer of the 55 Hudson Yards Mortgage Loan (see Exhibit 35.1)

35.22      CWCapital Asset Management LLC, as Special Servicerof the 55 Hudson Yards Mortgage Loan (see Exhibit 35.4)

35.23      Wells Fargo Bank, National Association, as PrimaryServicer of the 1412 Broadway Mortgage Loan (see Exhibit 35.1)

35.24      LNR Partners, LLC, as Special Servicer of the 1412 Broadway Mortgage Loan(Omitted. See Explanatory Notes.)

35.25      KeyBank National Association, as Primary Servicerof the 1633 Broadway Mortgage Loan (see Exhibit 35.3)

35.26      Situs Holdings, LLC, as Special Servicer of the1633 Broadway Mortgage Loan (see Exhibit 35.14)

35.27      Wells Fargo Bank, National Association, as PrimaryServicer of the Chroma Apartments Mortgage Loan (see Exhibit 35.1)

35.28      Rialto Capital Advisors, LLC, as Special Servicer of the Chroma ApartmentsMortgage Loan (Omitted. See Explanatory Notes.)

35.29      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the 560 Mission Street Mortgage Loan (Omitted. See ExplanatoryNotes.) 

35.30      KeyBank National Association, as Special Servicerof the 560 Mission Street Mortgage Loan (see Exhibit 35.3)

35.31      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Kings Plaza Mortgage Loan (Omitted. See Explanatory Notes.) 

35.32      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Kings Plaza Mortgage Loan (Omitted. See Explanatory Notes.)

99.1        Mortgage Loan Purchase Agreement, dated as of January 27,2020, between Wells Fargo Commercial Mortgage Securities, Inc. and Wells FargoBank, National Association (filed as Exhibit 99.3 to the registrant’s CurrentReport on Form 8-K filed on February 13, 2020 under Commission File No.333-226486-12 and incorporated by reference herein).

99.2        Mortgage Loan Purchase Agreement, dated as of January 27,2020, between Wells Fargo Commercial Mortgage Securities, Inc. and MorganStanley Mortgage Capital Holdings LLC (filed as Exhibit 99.1 to theregistrant’s Current Report on Form 8-K filed on February 13, 2020 underCommission File No. 333-226486-12 and incorporated by reference herein).

99.3        Mortgage Loan Purchase Agreement, dated as of January 27,2020, between Wells Fargo Commercial Mortgage Securities, Inc. and Bank ofAmerica, National Association (filed as Exhibit 99.2 to the registrant’sCurrent Report on Form 8-K filed on February 13, 2020 under Commission File No.333-226486-12 and incorporated by reference herein).

99.4        Mortgage Loan Purchase Agreement, dated as of January 27,2020, between Wells Fargo Commercial Mortgage Securities, Inc. and NationalCooperative Bank, N.A. (filed as Exhibit 99.4 to the registrant’s CurrentReport on Form 8-K filed on February 13, 2020 under Commission File No.333-226486-12 and incorporated by reference herein).

99.5        Co-Lender Agreement, dated as of November 21, 2019, byand between Wells Fargo Bank, National Association, as an Initial Note AHolder, DBR Investments Co. Limited, as an Initial Note A Holder, Morgan StanleyBank, National Association, as an Initial Note A Holder, Wells Fargo Bank,National Association, as Initial Note B-1 Holder, DBR Investments Co. Limited,as Initial B-2 Holder, and Morgan Stanley Bank, National Association, asInitial Note B-3 Holder (filed as Exhibit 99.15 to the registrant’s CurrentReport on Form 8-K filed on February 13, 2020 under Commission File No.333-226486-12 and incorporated by reference herein).

99.6        Co-Lender Agreement, dated as of December 20, 2019, byand among Goldman Sachs Bank USA, as Initial Note A-1-S-1 Holder, Initial NoteA-1-C-1 Holder, Initial Note A-1-C-2 Holder, Initial Note A-1-C-3 Holder, InitialNote A-1-C-4 Holder, Initial Note A-1-C-5 Holder, Initial Note A-1-C-6 Holder,Initial Note A-1-C-7 Holder and Initial Note B-1 Holder, DBR Investments Co.Limited, as Initial Note A-2-S-1 Holder, Initial Note A-2-C-1 Holder, InitialNote A-2-C-2 Holder, Initial Note A-2-C-3 Holder, Initial Note A-2-C-4 Holder,Initial Note A-2-C-5 Holder, Initial Note A-2-C-6 Holder, Initial Note A-2-C-7Holder and Initial Note B-2 Holder, JPMorgan Chase Bank, National Association,as Initial Note A-3-S-1 Holder, Initial Note A-3-C-1 Holder, Initial NoteA-3-C-2 Holder, Initial Note A-3-C-3 Holder, Initial Note A-3-C-4 Holder,Initial Note A-3-C-5 Holder, Initial Note A-3-C-6 Holder, Initial Note A-3-C-7Holder and Initial Note B-3 Holder, Wells Fargo Bank, National Association, asInitial Note A-4-S-1 Holder, Initial Note A-4-C-1 Holder, Initial Note A-4-C-2Holder, Initial Note A-4-C-3 Holder, Initial Note A-4-C-4 Holder, Initial NoteA-4-C-5 Holder, Initial Note A-4-C-6 Holder, Initial Note A-4-C-7 Holder and InitialNote B-4 Holder (filed as Exhibit 99.16 to the registrant’s Current Report onForm 8-K filed on February 13, 2020 under Commission File No. 333-226486-12 andincorporated by reference herein).

99.7        Agreement Between Note Holders, dated as of December 9,2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1-S1 Holder,Note A-1-S2 Holder, Note A-1-RL Holder, Initial Note A-1-C1 Holder, InitialNote A-1-C2 Holder, Initial Note A-1-C3 Holder, Initial Note A-1-C4 Holder,Initial Note A-1-C5 Holder, Initial Note B-1-S1 Holder, Initial Note B-1-RLHolder and Initial Note C-1-S Holder, Citi Real Estate Funding, Inc., asInitial Note A-2-S1 Holder, Initial Note A-2-S2 Holder, Initial Note A-2-RLHolder, Initial Note A-2-C1 Holder, Initial Note A-2-C2 Holder, Initial NoteA-2-C3 Holder, Initial Note A-2-C4 Holder, Initial Note A-2-C5 Holder, InitialNote B-2-S1 Holder, Initial Note B-2-RL Holder and Initial Note C-2-S Holder,JPMorgan Chase Bank, National Association, as Initial Note A-3-S1 Holder,Initial Note A-3-S2 Holder, Initial Note A-3-RL Holder, Initial Note A-3-C1Holder, Initial Note A-3-C2 Holder, Initial Note A-3-C3 Holder, Initial NoteA-3-C4 Holder, Initial Note A-3-C5 Holder, Initial Note B-3-S1 Holder, InitialNote B-3-RL Holder and Initial Note C-3-S Holder (filed as Exhibit 99.17 to theregistrant’s Current Report on Form 8-K filed on February 13, 2020 underCommission File No. 333-226486-12 and incorporated by reference herein).

99.8        Agreement Between Note Holders, dated as of January 23,2020, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank,N.A., as Initial Note A-3 Holder, Barclays Capital Real Estate Inc., as InitialNote A-4 Holder, and Morgan Stanley Mortgage Capital Holdings LLC, as InitialAgent (filed as Exhibit 99.18 to the registrant’s Current Report on Form 8-Kfiled on February 13, 2020 under Commission File No. 333-226486-12 andincorporated by reference herein).

99.9        Co-Lender Agreement, dated as of September 27, 2019, byand between Bank of America, N.A., as Initial Note A-1 Holder, Initial Note A-3Holder, Initial Note A-5 Holder, Initial Note A-7 Holder, Initial Note A-9Holder and Initial Note B-1 Holder, and Wells Fargo Bank, National Association,as Initial Note A-2 Holder, Initial Note A-4 Holder, Initial Note A-6 Holder,Initial Note A-8 Holder, Initial Note A-10 Holder and Initial Note B-2 Holder(filed as Exhibit 99.19 to the registrant’s Current Report on Form 8-K filed onFebruary 13, 2020 under Commission File No. 333-226486-12 and incorporated byreference herein).

99.10      Co-Lender Agreement, dated as of December 3, 2019, by andamong JPMorgan Chase Bank, Nation Association, as Initial Note 1 Holder andInitial Agent, Societe Generale Financial Corporation, as Initial Note 2Holder, Wells Fargo Bank, National Association, as Initial Note 3 Holder (filedas Exhibit 99.20 to the registrant’s Current Report on Form 8-K filed onFebruary 13, 2020 under Commission File No. 333-226486-12 and incorporated byreference herein).

99.11      Agreement Between Note Holders, dated as of December 19,2019, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank,N.A., as Initial Note A-3 Holder and Morgan Stanley Mortgage Capital HoldingsLLC, as Initial Agent (filed as Exhibit 99.21 to the registrant’s CurrentReport on Form 8-K filed on February 13, 2020 under Commission File No.333-226486-12 and incorporated by reference herein).

99.12      Agreement Between Note Holders, dated as of October 24,2019, by and among KeyBank National Association, as Initial Note A-1 Holder andas Initial Agent, KeyBank National Association, as Initial Note A-2 Holder,KeyBank National Association, as Initial Note A-3 Holder, Bank of America,N.A., as Initial Note A-4 Holder, and Bank of America, N.A., as Initial NoteA-5 Holder (filed as Exhibit 99.22 to the registrant’s Current Report on Form8-K filed on February 13, 2020 under Commission File No. 333-226486-12 and incorporatedby reference herein).

99.13      Agreement Between Note Holders, dated as of September 16,2019, by and between Bank of America, N.A., as Initial Note A-1 Holder, Bank ofAmerica, N.A., as Initial Note A-2 Holder, Bank of America, N.A., as InitialNote A-3 Holder, Bank of America, N.A., as Initial Note A-4 Holder, Bank ofAmerica, N.A., as Initial Note A-5 Holder, Bank of America, N.A., as InitialNote A-6 Holder, Bank of America, N.A., as Initial Note A-7 Holder, Bank ofAmerica, N.A., as Initial Note A-8 Holder, Bank of America, N.A., as InitialNote A-9 Holder, and Bank of America, N.A., as Initial Note A-10 Holder (filedas Exhibit 99.23 to the registrant’s Current Report on Form 8-K filed onFebruary 13, 2020 under Commission File No. 333-226486-12 and incorporated byreference herein).

99.14      Agreement Between Noteholders, dated as of January 30,2020, by and between DBR Investments Co. Limited, as Initial Note A-1-1 Holder,DBR Investments Co. Limited, as Initial Note A-1-2-A Holder, DBR InvestmentsCo. Limited, as Initial Note A-1-2-B Holder, DBR Investments Co. Limited, asInitial Note A-1-3 Holder, DBR Investments Co. Limited, as Initial Note A-1-4Holder, Bank of America, N.A. as Initial Note A-2-A Holder, and Bank ofAmerica, N.A. as Initial Note A-2-B Holder (filed as Exhibit 99.24 to theregistrant’s Current Report on Form 8-K filed on February 13, 2020 underCommission File No. 333-226486-12 and incorporated by reference herein).

99.15      Agreement Between Note Holders, dated as of December 20,2019, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, and Wells Fargo Bank, National Association, as Initial Note A-2Holder (filed as Exhibit 99.25 to the registrant’s Current Report on Form 8-Kfiled on February 13, 2020 under Commission File No. 333-226486-12 andincorporated by reference herein).

99.16      Agreement Between Note Holders, dated as of November 13,2019, by and between Bank of America, N.A., as Initial Note A-1 Holder, andBank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 99.26 tothe registrant’s Current Report on Form 8-K filed on February 13, 2020 underCommission File No. 333-226486-12 and incorporated by reference herein).

(b)   The exhibits required to be filed by theRegistrant 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 theSecurities Exchange Act of 1934, the registrant has duly caused this report tobe signed on its behalf by the undersigned, thereunto duly authorized.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 16, 2023