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**REPORTOF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

 

 

Board ofDirectors and Management of 

Situs Holdings,LLC 

 

We haveexamined management’s assertion, included in the accompanying Management’sReport on Assessment of Compliance with SEC Regulation AB Servicing Criteria(“Management’s Report”), that Situs Holdings, LLC (the “Company”), a wholly-ownedsubsidiary of SitusAMC Holdings Corporation, complied with the servicingcriteria set forth in Item 1122(d) of the U.S. Securities and ExchangeCommission’s Regulation AB for the Special Servicing Platform (the “Platform”)as of and for the year ended December 31, 2021, excluding criteria1122(d)(1)(iii), 1122(d)(3)(i)(B-D), 1122(d)(3)(ii-iv), 1122(d)(4)(iv-v),1122(d)(4)(ix), and 1122(d)(4)(xv) which management has determined are notapplicable to the activities performed by the Company with respect to thePlatform. The Platform consists of the asset-backed transactions and securitiesfor which the Company acted as special servicer as defined by management inAppendix B of Management’s Report. Management is responsible for the Company’scompliance with the applicable servicing criteria. Our responsibility is toexpress an opinion on management’s assertion about the Company’s compliancewith the applicable servicing criteria for the Platform based on ourexamination. 

 

Ourexamination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants, and, accordingly, included examining, on a test basis, evidenceabout the Company’s compliance with the applicable servicing criteria for thePlatform and performing such other procedures as we considered necessary in thecircumstances. Our examination included testing selected asset-backedtransactions and securities constituting the Platform and evaluating whetherthe Company performed servicing activities related to those transactions andsecurities in compliance with the applicable servicing criteria for the periodcovered by this report. Accordingly, our testing may not have includedservicing activities related to each asset-backed transaction or securityconstituting the Platform. Further, our examination was not designed to detectmaterial noncompliance that may have occurred prior to the period covered bythis report and that may have affected the Company’s servicing activitiesduring the period covered by this report. We believe that our examinationprovides a reasonable basis for our opinion. Our examination does not provide alegal determination on the Company’s compliance with the applicable servicingcriteria. 

 

Asdescribed in Management’s Report, the Company engaged various vendors toperform servicing activities with respect to criteria 1122(d)(2)(vii). TheCompany determined that each vendor is not considered a “servicer,” as thatterm is defined in Item 1101(j) of Regulation AB, and therefore, the Company isassuming responsibility for compliance with such servicing criteria applicableto each vendor’s servicing activities. In accordance with Regulation AB and itsrelated interpretations, the requirement for management to assess compliancewith the servicing criteria applicable to a vendor’s activities is satisfied ifthe Company has instituted policies and procedures to monitor whether suchvendor’s activities comply in all material respects with such criteria.Compliance with the applicable servicing criteria is achieved if those policiesand procedures are designed to provide reasonable assurance that such vendor’sactivities comply with such criteria and those policies and procedures areoperating effectively for the period covered by Management’s Report. Ourexamination does not provide a legal determination of whether a vendor is or isnot considered a servicer, and therefore, on whether the Company, in itsManagement Report, is eligible to elect to take responsibility for assessingcompliance with the servicing criteria applicable to each vendor’s servicingactivities. 

 

In ouropinion, management’s assertion that Situs Holdings, LLC complied with theaforementioned applicable servicing criteria as of and for the year endedDecember 31, 2021 for the Platform is fairly stated, in all material respects. 

 

 

/s/ GrantThornton LLP

 

KansasCity, Missouri 

February28, 2022 

 

 

**GT.COM**

 

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