**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**WASHINGTON,D.C. 20549**

**FORM 10‐K**

(Mark one)

**/X/ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**    For the fiscal year endedDecember 31, 2022OR**

**//TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**For the transition period from****            ****to****            **

 

 

 

**Commission file number:333-227446-09**

 

**Central Index Key Number of the issuing entity:****0001799463**

 

**Morgan Stanley Capital ITrust 2020-L4**

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

 

**Central Index Key Number of the depositor:0001547361**

 

**Morgan Stanley Capital I Inc.**

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

 

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

 

**Morgan Stanley MortgageCapital Holdings LLC**

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

 

**Central Index Key Number of the sponsor:0001624053**

 

**Argentic Real Estate FinanceLLC**

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

**Central Index Key Numberof the sponsor:0001548405**

 

**Starwood Mortgage Capital LLC**

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

** Central Index KeyNumber of the sponsor:0001558761**

 

**Cantor Commercial Real EstateLending, L.P.**

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

 

 

| **New York**                                                        | **38-4139211**

**38-4139212**

**38-7235669** |
|---------------------------------------------------------------------|------------------------------------------------|
| **(State or other jurisdiction of incorporation or  organization)** | **(I.R.S. Employer Identification Numbers)**   |

 

**c/o Wells Fargo Bank, N.A.**

**9062 Old Annapolis Road**

** Columbia, MD**

**(Address of principal executive offices)**

 

**21045**

**(Zip Code)**

 

**Telephone number, including area code:**

**(410) 884‐2000**

Securitiesregistered pursuant to Section 12(b) of the Act:

 

 

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

 

 

Securitiesregistered pursuant to Section 12(g) of the Act:

 

  NONE.

 

Indicateby check mark if the registrant is a well-known seasoned issuer, as defined inRule 405 of the Securities Act.

 

  Yes___ No X

 

Indicateby check mark if the registrant is not required to file reports pursuant toSection 13 or Section 15(d) of the Act.

 

  Yes___ No X

 

Note- Checking the box above will not relieve any registrant required to filereports pursuant to Section 13 or 15(d) of the Exchange Act from theirobligations under those Sections.

 

Indicate by check mark whether the registrant (1) has filed all reportsrequired to be filed by Section 13 or 15(d) of the Securities Exchange Act of1934 during the preceding 12 months (or for such shorter period that theregistrant was required to file such reports), and (2) has been subject to suchfiling requirements for the past 90 days.

 

  YesX No ___

 

Indicateby check mark whether the registrant has submitted electronically everyInteractive Data File required to be submitted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit suchfiles).

 

  Notapplicable.

 

Indicateby check mark whether the registrant is a large accelerated filer, anaccelerated filer, a non-accelerated filer, a smaller reporting company, oremerging growth company. See the definitions of "large acceleratedfiler", "accelerated filer," "smaller reportingcompany," and “emerging growth company” in Rule 12b-2 of the Exchange Act.

 

 Largeaccelerated filer ___ Accelerated filer ___ Non-accelerated filer X (Do not check if a smaller reporting company)Smaller reporting company ___

 

Emerginggrowth company ___

 

Ifan emerging growth company, indicate by check mark if the registrant haselected not to use the extended transition period for complying with any new orrevised financial accounting standards provided pursuant to Section 13(a) ofthe Ex­change Act.

 

  Notapplicable.

 

Indicateby check mark whether the registrant has filed a report on and attestation toits management’s assessment of the effectiveness of its internal control overfinancial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C.7262(b)) by the registered public accounting firm that prepared or issued itsaudit report.

 

 Not applicable.

 

If securities are registered pursuant to Section 12(b)of the Act, indicate by check mark whether the financial statements of the

registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements.

 

Not applicable.

 

Indicateby check mark whether any of those error corrections are restatements thatrequired a recovery analysis of incentive-based compensation received by any ofthe registrant’s executive officers during the relevant recovery periodpursuant to §240.10D-1(b).

 

Not applicable.

 

Indicateby check mark whether the registrant is a shell company (as defined in Rule12b-2 of the Act).

 

  Yes___ No X

 

Statethe aggregate market value of the voting and non-voting common equity held bynon-affiliates computed by reference to the price at which the common equitywas last sold, or the average bid and asked price of such common equity, as ofthe last business day of the registrant's most recently completed second fiscalquarter.

 

  Notapplicable.

 

Indicateby check mark whether the registrant has filed all documents and reportsrequired to be filed by Section 12, 13 or 15(d) of the Securities Exchange Actof 1934 subsequent to the distribution of securities under a plan confirmed bya court.

 

  Notapplicable.

 

Indicatethe number of shares outstanding of each of the registrant's classes of commonstock, as of the latest practicable date.

 

  Notapplicable.

 

DOCUMENTSINCORPORATED BY REFERENCE

 

Listhereunder the following documents if incorporated by reference and the Part ofthe Form 10-K (e.g., Part I, Part II, etc.) into which the document isincorporated: (1)Any annual report to security holders; (2) Any proxy orinformation statement; and (3)Any prospectus filed pursuant to Rule 424(b) or (c)under the Securities Act of 1933. The listed documents should be clearlydescribed for identification purposes (e.g., annual report to security holdersfor fiscal year ended December 24, 1980).

 

  Notapplicable.

 

**EXPLANATORY NOTES**

 

The MSC 2020-L4 mortgage pool includes thefollowing mortgage loans, each of which is serviced pursuant to a separatepooling and servicing agreement (each, an “Outside Pooling and ServicingAgreement”):

 

•   the Bellagio Hotel and Casinomortgage loan, which is serviced pursuant to the BX 2019-OC11 trust andservicing agreement attached hereto as Exhibit 4.2;

 

•   the 545 Washington Boulevardmortgage loan, which is serviced pursuant to the BANK 2020-BNK25  poolingand servicing agreement attached hereto as Exhibit 4.3;

 

  • the 1412 Broadwaymortgage loan, which is serviced pursuant to the BANK 2019-BNK24 pooling andservicing agreement attached hereto as Exhibit 4.4;

 

  • the 55 Hudson Yardsmortgage loan, which is serviced pursuant to the Hudson Yards 2019-55HY trustand servicing agreement attached hereto as Exhibit 4.5;

 

  • the Alrig Portfoliomortgage loan, which is serviced pursuant to the CGCMT 2019-C7 pooling andservicing agreement attached hereto as Exhibit 4.6; and

 

•   the Sol y Luna mortgage loan,which is serviced pursuant to the CSAIL 2020-C19 pooling and servicing agreement attached hereto asExhibit 4.7.

Except as set forth below, each of theparties to each pooling and servicing agreement listed in the Exhibit Indexboth (1) participates in the servicing function for purposes of Item 1122 ofRegulation AB and (2) constitutes a servicer that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB for purposes of Item 1123 ofRegulation AB:

 

•   The trustee under a poolingand servicing agreement has a nominal role with respect to the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Thetrustee’s only servicing function is the contingent obligation to make certainadvances if the master servicer under such pooling and servicing agreementfails to do so, while all other servicing functions are performed by otherparties.  The trustee under each of the pooling and servicing agreementslisted in the Exhibit Index has confirmed to the registrant that it has notmade any such contingent advances during the reporting period, andconsequently, each such trustee does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The certificate administratorunder a pooling and servicing agreement performs various payment administrationfunctions solely for the securitization governed by such pooling and servicingagreement and the mortgage pool securitized pursuant to such pooling andservicing agreement and does not have any obligations with respect to any othertransaction.  Consequently, the certificate administrator under an OutsidePooling and Servicing Agreement does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The operating advisor under apooling and servicing agreement represents the interests of seniorcertificateholders in the transaction governed by such pooling and servicingagreement and is responsible for monitoring the performance of the specialservicer under such pooling and servicing agreement and producing certainreports to certificateholders relating to the resolution of the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Theoperating advisor under a pooling and servicing agreement does not have anyobligations with respect to any other transaction and is solely obligated toperform loan reporting functions with respect to the securitization governed bysuch pooling and servicing agreement.  Consequently, the operating advisorunder an Outside Pooling and Servicing Agreement neither participates in theservicing function for purposes of Item 1122 of Regulation AB nor performs thefunctions of a servicer for purposes of the definition of “servicer” under Item1101 of Regulation AB or for purposes of Item 1123 of Regulation AB.  Inaddition, while the operating advisor under a pooling and servicing agreementhas certain reporting obligations in respect of the related mortgage pool, ithas no obligation to collect or disburse funds in respect of the mortgage poolor to administer any of the underlying mortgage loans.  Consequently, theoperating advisor under a pooling and servicing agreement participates in theservicing function for purposes of Item 1122 of Regulation AB, but is notresponsible for the “management or collection of the pool assets or makingallocations or distributions to holders of the asset-backed securities” withinthe meaning of “servicer” under Item 1101 of Regulation AB and does not performthe functions of a servicer for purposes of Item 1123 of Regulation AB. 

 

•   The asset representations reviewer under a poolingand servicing agreement has a limited obligation to review certain delinquentmortgage loans after a specified delinquency threshold has been met and therequired percentage of certificateholders vote to direct a review of suchdelinquent mortgage loans, and has no obligation to collect or disburse fundsin respect of the mortgage pool, to administer any of the underlying mortgageloans or to perform any servicing function.  Consequently, the assetrepresentations reviewer under a pooling and servicing agreement does notparticipate in the servicing function for purposes of Item 1122 of RegulationAB, is not responsible for the “management or collection of the pool assets ormaking allocations or distributions to holders of the asset-backed securities”within the meaning of “servicer” under Item 1101 of Regulation AB and does notperform the functions of a servicer for purposes of Item 1123 of Regulation AB.

•   NCB, N.A. as NCB masterservicer and NCB special servicer under each of the BANK 2019-BNK24 pooling andservicing agreement and the BANK 2020-BNK25 pooling and servicing agreement,only has obligations in respect of certain mortgage loans sold to the BANK2019-BNK24 securitization trust and the BANK 2020-BNK25 securitization trust,respectively, by NCB, N.A. Such party has no obligations with respect to anymortgage loan included in the MSC 2020-L4 mortgage pool and therefore in suchcapacity does not constitute a reporting “servicing function participant” forpurposes of Item 1122 of Regulation AB, as specified in the Instruction 3 toItem 1122, and does not constitute a reporting “servicer” for purposes of Item1123 of Regulation AB, as specified in the Instruction to Item 1123.

 

•   KeyBank NationalAssociation is the servicer under the BX 2019-OC11trust and servicing agreement, pursuant to which the Bellagio Hotel and Casinomortgage loan is serviced.  Because KeyBank National Association is not the MSC 2020-L4 master servicer, is not affiliatedwith any sponsor and services only the Bellagio Hotel and Casino mortgage loan,which constitutes more than 5% but less than 10% of the mortgage pool, KeyBankNational Association, as BX 2019-OC11 servicer,constitutes a reporting “servicing function participant” for purposes of Item1122 of Regulation AB, as specified in the Instruction 3 to Item 1122, but doesnot constitute a reporting “servicer” for purposes of Item 1123 of RegulationAB, as specified in the Instruction to Item 1123.

 

•   Situs Holdings, LLC is thespecial servicer under the BX 2019-OC11 trust and servicing agreement, pursuantto which the Bellagio Hotel and Casino mortgage loan is serviced.  BecauseSitus Holdings, LLC is not the MSC 2020-L4special servicer, is not affiliated with any sponsor and services only theBellagio Hotel and Casino mortgage loan, which constitutes more than 5% butless than 10% of the mortgage pool Situs Holdings, LLC, as BX 2019-OC11 special servicer, constitutes a reporting“servicing function participant” for purposes of Item 1122 of Regulation AB, asspecified in the Instruction 3 to Item 1122, but does not constitute areporting “servicer” for purposes of Item 1123 of Regulation AB, as specifiedin the Instruction to Item 1123.

 

•   KeyBank National Associationwas, until November 30, 2022, the general special servicer under the BANK2020-BNK25 pooling and servicing agreement, pursuant to which the 545Washington Boulevard mortgage loan is serviced.  Because KeyBankNational Association is not the MSC 2020-L4 specialservicer, is not affiliated with any sponsor and serviced only the 545Washington Boulevard mortgage loan, which constitutes more than 5% but lessthan 10% of the mortgage pool, KeyBank National Association, as BANK 2020-BNK25 general master servicer, constitutes areporting “servicing function participant” for purposes of Item 1122 ofRegulation AB, as specified in the Instruction 3 to Item 1122, but does notconstitute a reporting “servicer” for purposes of Item 1123 of Regulation AB,as specified in the Instruction to Item 1123.

 

•  CWCapital Asset Management LLC is the current special servicer under the BANK 2020-BNK25pooling and servicing agreement, pursuant to which the 545 Washington Boulevardmortgage loan is serviced. On December 1, 2022, KeyBank National Associationwas replaced as special servicer under the BANK 2020-BNK25 pooling andservicing agreement and was succeeded by CWCapital Asset Management LLC.

•   3650 REIT Loan Servicing LLC isthe special servicer under the CSAIL 2020-C19 pooling and servicing agreement,pursuant to which the Sol y Luna mortgage loan is serviced. Because 3650REIT Loan Servicing LLC is not the MSC 2020-L4special servicer, is not affiliated with any sponsor and services only the Soly Luna mortgage loan, which constitutes less than 5% of the mortgage pool, 3650REIT Loan Servicing LLC, as CSAIL 2019-C19 specialservicer, does not constitute a reporting “servicing function participant” forpurposes of Item 1122 of Regulation AB, as specified in the Instruction 3 toItem 1122, and does not constitute a reporting “servicer” for purposes of Item1123 of Regulation AB, as specified in the Instruction to Item 1123.

 

•  Citibank, N.A., as certificate administrator under the CGCMT 2019-C7 poolingand servicing agreement, pursuant to which the Alrig Portfolio mortgage loan isserviced, engaged U.S. Bank National Association to perform the relatedcustodial services with respect to such mortgage loan, and U.S. Bank NationalAssociation performed all such custodial services pursuant to the relatedpooling and servicing agreement. Because U.S. Bank National Association is notthe MSC 2020-L4 custodian, is not affiliated with any sponsor and only servicedthe Alrig Portfolio mortgage loan, which constitutes less than 5% of themortgage pool, U.S. Bank National Association, as a CGCMT 2019-C7 servicingfunction participant, does not constitute a reporting “servicing functionparticipant” for purposes of Item 1122 of Regulation AB, as specified in theInstruction 3 to Item 1122, and does not constitute a reporting “servicer” forpurposes of Item 1123 of Regulation AB, as specified in the Instruction to Item1123.

 

•   BREF Partners SpecialServicer LLC, as special servicer with respect to the 805 Third Avenue mortgageloan under the CGCMT 2019-C7 pooling and servicing agreement, only hasobligations in respect of the 805 Third Avenue mortgage loan securitizedthereunder. On May 7, 2020, LNR Partners, LLC was replaced as special servicerunder the CGCMT 2019-C7 pooling and servicing agreement with respect to the 805Third Avenue mortgage loan and was succeeded by BREF Partners Special ServicerLLC. BREF Partners Special Servicer LLC, as special servicer with respect tothe 805 Third Avenue mortgage loan under the CGCMT 2019-C7 pooling and servicingagreement, has no obligations with respect to any mortgage loan included in theMSC 2020-L4 mortgage pool and therefore such party in such capacity does notconstitute a reporting “servicing function participant” for purposes of Item1122 of Regulation AB, as specified in the Instruction 3 to Item 1122, and doesnot constitute a reporting “servicer” for purposes of Item 1123 of RegulationAB, as specified in the Instruction to Item 1123.

 

•   Argentic Services Company LPis the current special servicer under the MSC 2020-L4 pooling and servicingagreement. On May 6, 2020, LNR Partners, LLC was replaced as special servicerunder the MSC 2020-L4 pooling and servicing agreement and was succeeded byArgentic Services Company LP.

•   LNR Partners, LLC is thecurrent special servicer under the BANK 2019-BNK24 pooling and servicingagreement, pursuant to which the 1412 Broadway mortgage loan is serviced. OnJuly 13, 2021, Midland Loan Services, a Division of PNC Bank, NationalAssociation was replaced as special servicer under the BANK 2019-BNK24 poolingand servicing agreement and was succeeded by LNR Partners, LLC.

 

 In addition, each of the following partiesengaged the services of certain servicing function participants andsub-servicers for the reporting period, as set forth below:

 

•   Wells Fargo Bank, NationalAssociation, as general master servicer under the BANK 2020-BNK25 pooling andservicing agreement, pursuant to which the 545 Washington Boulevard mortgageloan is serviced, engaged the services of CoreLogic Solutions, LLC as aservicing function participant in respect of the 545 Washington Boulevardmortgage loan for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as general master servicer under the BANK 2019-BNK24 pooling andservicing agreement, pursuant to which the 1412 Broadway mortgage loan isserviced, engaged the services of CoreLogic Solutions, LLC as a servicingfunction participant in respect of the 1412 Broadway mortgage loan for thereporting period.

 

•   Wells Fargo Bank, NationalAssociation, as servicer under the Hudson Yard 2019-55HY trust and servicingagreement, pursuant to which the 55 Hudson Yards mortgage loan is serviced,engaged the services of CoreLogic Solutions, LLC as a servicing functionparticipant in respect of the 55 Hudson Yards mortgage loan for the reportingperiod.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the CGCMT 2019-C7 pooling and servicingagreement, pursuant to which the Alrig Portfolio mortgage loan is serviced,engaged the services of CoreLogic Solutions, LLC as a servicing functionparticipant in respect of the Alrig Portfolio mortgage loan for the reportingperiod.

 

•   On November 1, 2021, pursuantto the second amended and restated servicing agreement attached hereto asExhibit 99.15, Computershare Trust Company, National Association was engaged toperform all or virtually all of Wells Fargo Bank, National Association’s rolesas certificate administrator, custodian and trustee, as applicable, under (i)the pooling and servicing agreement and (ii) each Outside Pooling and ServicingAgreement.

 

 

 

| **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.**    |
|              | Omitted.                        |
|              |                            |   |

 

| **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 of Financial Condition and Results of Operations.**                         |
|              | Omitted.                                                                                                            |
| **Item 7A.** | **Quantitative and  Qualitative Disclosures About Market Risk.**                                                    |
|              | Omitted.                                                                                                            |
| **Item 8.**  | **Financial Statements and  Supplementary Data.**                                                                   |
|              | Omitted.                                                                                                            |
| **Item 9.**  | **Changes in and  Disagreements With Accountants on Accounting and Financial Disclosure.**                          |
|              | Omitted.                                                                                                            |
| **Item 9A.** | **Controls and Procedures.**                                                                                        |
|              | Omitted.                                                                                                            |
| **Item 9B.** | **Other Information.**                                                                                         |
|              | None.                                                                                                               |
| **Item 9C.** | **Disclosure Regarding  Foreign Jurisdictions that Prevent Inspections.**                                           |
|              | None.                                                                                                               |
|              |                                                                                                                |   |
|              |                                                                                                                |   |   |

 

| **PART III** |                                                                                                 |
|-------------------|------------------------------------------------------------------------------------------------------|
|              |                                                                                                 |
| **Item 10.** | **Directors, Executive  Officers and Corporate Governance.**                                         |
|              | Omitted.                                                                                             |
| **Item 11.** | **Executive Compensation.**                                                                          |
|              | Omitted.                                                                                             |
| **Item 12.** | **Security Ownership of  Certain Beneficial Owners and Management and Related Stockholder Matters.** |
|              | Omitted.                                                                                             |
| **Item 13.** | **Certain Relationships and  Related Transactions, and Director Independence.**                      |
|              | Omitted.                                                                                             |
| **Item 14.** | **Principal Accountant Fees  and Services.**                                                         |
|              | Omitted.                                                                                             |
|              |                                                                                                 |   |

 

**ADDITIONALDISCLOSURE ITEMS FOR REGULATION AB**

 

**Item1112(b) of Regulation AB, Significant Obligor Financial Information.**

 

Notapplicable.

 

**Item1114(b)(2) of Regulation AB, Significant Enhancement Provider FinancialInformation.**

 

Noentity or group of affiliated entities provides any enhancement or othersupport for the certificates as described under Item 1114 (a) of Regulation AB.

 

**Item1115(b) of Regulation AB, Certain Derivatives Instruments (FinancialInformation).**

 

Noentity or group of affiliated entities provides any derivative instruments forthe certificates as described under Item 1115 of Regulation AB.

 

**Item1117 of Regulation AB, Legal Proceedings.**

 

Theregistrant knows of no legal proceeding pending against the sponsors,depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) ofRegulation AB, originator contemplated by Item 1110(b) of Regulation AB, orother party contemplated by Item 1100(d)(1) of Regulation AB, or of which anyproperty of the foregoing is the subject, that is material to security holders,other than as follows:

 

InDecember 2014, Phoenix Light SF Limited (Phoenix Light) and certain relatedentities filed a complaint in the United States District Court for the SouthernDistrict of New York alleging claims against Wells Fargo Bank, N.A., in itscapacity as trustee for a number of residential mortgage-backed securities(RMBS) trusts. Complaints raising similar allegations have been filed byCommerzbank AG in the Southern District of New York and by IKB Internationaland IKB Deutsche Industriebank in New York state court. In each case, theplaintiffs allege that Wells Fargo Bank, N.A., as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. In July2022, the district court dismissed Phoenix Light’s claims and certain of theclaims asserted by Commerzbank AG, and subsequently entered judgment in eachcase in favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light andCommerzbank AG appealed the district court’s decision to the United StatesCourt of Appeals for the Second Circuit. Wells Fargo Bank, N.A. previouslysettled two class actions filed by institutional investors and an action filedby the National Credit Union Administration with similar allegations. In addition,Park Royal I LLC and Park Royal II LLC have filed substantially similarlawsuits in New York state court alleging Wells Fargo Bank, N.A., as trustee,failed to take appropriate actions upon learning of defective mortgage loandocumentation.

 

Fromtime to time, CWCapital Asset Management LLC, a Delaware limited liabilitycompany (“CWCAM”), is a party to lawsuits and other legal proceedings as partof its duties as a special servicer (e.g., enforcement of loan obligations)and/or arising in the ordinary course of business. Other than as set forth inthe following paragraphs, there are currently no legal proceedings pending, andno legal proceedings known to be contemplated by governmental authorities,against CWCAM or of which any of its property is the subject, that are materialto the certificateholders.

 

OnDecember 17, 2015, U.S. Bank National Association, the trustee under fivepooling and servicing agreements for (i) Wachovia Bank Commercial MortgageTrust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2, (iii) Wachovia BankCommercial Mortgage Trust 2007-C31, (iv) ML-CFC Commercial Mortgage Trust2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenced a proceedingwith the Second Judicial District Court of Ramsey County, Minnesota (the “StateCourt”) for a declaratory judgment as to the proper allocation of certainproceeds (“Disputed Proceeds”) received by CWCAM in connection with the sale ofthe Peter Cooper Village and Stuyvesant Town property in New York, New Yorksecuring loans held by those trusts. CWCAM was the special servicer of suchproperty. The petition requests the State Court to instruct the trustee, thetrust beneficiaries, and any other interested parties as to the amount of theDisputed Proceeds, if any, that constitute penalty interest and/or the amountof the Disputed Proceeds, if any, that constitute gain-on-sale proceeds, withrespect to each trust. On February 24, 2016, CWCAM made a limited appearancewith the State Court to file a motion to dismiss this proceeding based on lackof jurisdiction, mootness, standing and forum non conveniens. On July 19, 2016,the State Court denied CWCAM’s motion to dismiss. On July 22, 2016, the actionwas removed 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, the FederalCourt reserved the determination on the motion to hear CWCAM’s request forreconsideration 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 but the SDNYCourt was unable to decide the case based on the pleadings and the SDNY Courtordered discovery. All fact discovery was completed in December, 2018 and expertdiscovery was completed on March 15, 2019. The parties submitted cross motionsfor summary judgment, and on March 19, 2020, the SDNY Court entered an opinionand order in which it granted summary judgment in CWCAM’s favor and held thatCWCAM was entitled to the entire amount of penalty interest and that CWCAM’sdetermination of Yield Maintenance was correct. In the 127-page opinion, theSDNY Court found for CWCAM on every issue presented by the trustee’s petition,namely, that the funds in dispute constitute penalty interest and yieldmaintenance, not gain-on-sale proceeds, and that the amount of penalty interestand yield maintenance was correctly calculated. An appeal of the SDNY Court’sdecision was taken on April 29, 2020. Oral argument on the appeal occurred onJune 21, 2021. On July 14, 2022, the Second Circuit entered a decisionaffirming in part and reversing in part the SDNY Court’s decision and remandingto the SDNY Court for further proceedings. The Second Circuit affirmed theSDNY’s Court holding that Penalty Interest and Yield Maintenance are paidbefore Gain-On-Sale Proceeds. The Second Circuit reversed and remanded forfurther proceedings that portion of the SDNY Court’s decision related toapproximately $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, as Trustee forthe trusts, provided notice of the settlement to all parties in interest via anotice program approved by the Court. A hearing on the settlement is scheduledfor March 16, 2023.

 

OnDecember 1, 2017, a complaint against CWCAM and others was filed in the UnitedStates District Court for the Southern District of New York styled as CWCapitalCobalt Vr Ltd. v. CWCapital Investments LLC, et al., No. 17-cv-9463 (the“Original Complaint”). The gravamen of the Original Complaint alleged breachesof a contract and fiduciary duties by CWCAM’s affiliate, CWCapital InvestmentsLLC in its capacity as collateral manager for the collateralized debtobligation transaction involving CWCapital Cobalt Vr, Ltd. In total, there are14 counts pled in the Original Complaint. Of those 14, 5 claims were assertedagainst CWCAM for aiding and abetting breach of fiduciary duty, conversion andunjust enrichment. On May 23, 2018, the Original Complaint was dismissed forlack of subject matter jurisdiction. On June 28, 2018, CWCapital Cobalt Vr Ltd.filed a substantially similar complaint in the Supreme Court of the State ofNew York, County of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapitalInvestments LLC, et al., Index No. 653277/2018 (the “New Complaint”). Thegravamen of the New Complaint is the same as the previous complaint filed inthe United State District Court for the Southern District of New York. In totalthere are 16 counts pled in the New Complaint. Of those 16 counts, 5 claimswere asserted against CWCAM for aiding and abetting breach of fiduciary duty,conversion and unjust enrichment, 1 count seeks a declaratory judgement thatthe plaintiff has the right to enforce the contracts in question and 1 countseeks an injunction requiring the defendants to recognize the plaintiff as thedirecting holder for the trusts in question. On January 11, 2019, the plaintiffdismissed with prejudice the declaratory judgment and injunction counts. TheNew Complaint and related summons was not served on the defendants until July13, 2018 and July 16, 2018. The plaintiff’s motion for a preliminary injunctionwas denied by the court on July 31, 2018. On August 3, 2018, the defendants,including CWCAM, filed a motion to dismiss the New Complaint in its entirety.On August 20, 2019, the court entered an order granting defendants’ motionalmost in its entirety, dismissing 11 of the 16 counts and partially dismissing2 additional counts. Of the remaining counts, 2 are asserted against CWCAM foraiding and abetting breach of fiduciary duty and unjust enrichment. OnSeptember 19, 2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relatingto the August 20, 2019 dismissal order and on September 26, 2019, filed anamended complaint against CWCI and CWCAM attempting to address deficienciesrelating to certain of the claims dismissed by the August 20, 2019 order. CWCIand CWCAM filed its Motion to Dismiss the amended complaint on October 28,2019. The court heard argument on the Motion to Dismiss the amended complainton January 22, 2020 and on October 23, 2020, the court granted the motiondismissing the amended claims. On November 30, 2020, CWCapital Cobalt Vr Ltdfiled a notice of appeal relating to the October 23, 2020 dismissal order. OnApril 27, 2021, the First Department affirmed the dismissal as to claimsagainst CWCAM that were part of the August 20, 2019 dismissal, but reversed thedismissal of two counts for breach of the Collateral Management Agreementagainst CWCI. CWCI sought leave to file an appeal of the decision. Theplaintiff also sought leave to appeal the dismissal of the claims againstCWCAM. Both requests for leave were denied by the First Department. On May 15,2020, CWCI and CWCAM filed a motion to renew its motion to dismiss as to 4 ofthe remaining counts (including the remaining two counts against CWCAM foraiding and abetting breach of fiduciary duty and unjust enrichment), based on adecision entered by Judge Failla in a trust instruction proceeding in the USDistrict Court for the Southern District of New York awarding summary judgmentin favor of CWCAM. 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, CWCIand CWCAM moved to reargue the denial of the motion to renew (or alternatively,the motion to dismiss) with respect to certain of Cobalt’s claims, includingthe remaining 2 claims against CWCAM, based on the First Department’s April 27,2021 decision. On March 24, 2022, the court denied the relief sought in themotion to reargue. CWCI and CWCAM have appealed the court’s decision on themotion to reargue and filed their opening brief on July 11, 2022. The appealwas dismissed as being nonappealable on August 30, 2022. CWCAM believes that ithas performed its obligations under the related pooling and servicingagreements in good faith and the remaining allegations in the New Complaint arewithout merit.

 

**Item1119 of Regulation AB, Affiliations and Certain Relationships and RelatedTransactions.**

 

Theinformation regarding this Item has been provided previously in an annualreport on Form 10-K of the issuing entity or in the prospectus of the issuingentity filed in a 424(b)(2) filing dated February 20, 2020.  In addition,CWCapital Asset Management LLC, the special servicer under the BANK 2020-BNK25pooling and servicing agreement, pursuant to which the 545 Washington Boulevardmortgage loan is serviced, is also the special servicer under the Hudson Yards2019-55HY trust and servicing agreement, pursuant to which the 55 Hudson Yardsmortgage loan is serviced.

 

**Item1122 of Regulation AB, Compliance with Applicable Servicing Criteria.**

 

Thereports on assessment of compliance with the servicing criteria forasset-backed securities and the related attestation reports on such assessmentsof compliance are attached hereto under Item 15. 

 

Thereport on assessment of compliance with applicable servicing criteria furnishedpursuant to Item 1122 of Regulation AB by KeyBank National Associationdiscloses that a material instance of noncompliance occurred, as describedbelow:

 

KeyBankNational Association (KeyBank) has identified the following material instanceof noncompliance with servicing criteria 1122(d)(4)(ix) during the calendaryear ended December 31, 2022, with respect to the Platform. The materialinstance of noncompliance does not relate to KeyBank’s performance under anypooling and servicing agreement applicable to the securitization transactionthat is the subject of this Form 10-K.

 

1)Servicing Criteria impacted 

 

1122(d)(4)(ix) –Adjustments to interest rates or ratesof return for pool assets with variable rates are computed based on the relatedpool asset documents. 

 

2)Material Instance of Noncompliance with Servicing Criteria

 

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 theNote, if the holder fails to offer a loan rate within 45-60 days of any changedate a margin of 2.25% is to be used. Given the notification was not made tothe borrowers, a 3% margin was incorrectly applied. The noncompliance in Item1122 (d)(4)(ix) is related to a servicing portfolio which is wholly owned bythe investor and is not held in a publicly traded security. 

 

3)Remediation

 

Thefollowing remediation procedures have been initiated by KeyBank: (i) theimpacted mortgage loans are currently in the process of being identified, (ii)investor contact has been initiated, (iii) corrective actions are beingconsidered and will be tracked and monitored by senior management, (iv)procedures will be reviewed and revised, if necessary, to include new trackingand 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.

 

**Item1123 of Regulation AB, Servicer Compliance Statement.**

 

Theservicer compliance statements are attached hereto under Item 15.

 

**PART IV**

 

**Item15. Exhibits, Financial Statement Schedules.**

 

(a) Exhibits.

 

(4.1) Pooling and Servicing Agreement, dated as ofFebruary 1, 2020, between Morgan Stanley Capital I Inc., as depositor, MidlandLoan Services, a Division of PNC Bank, National Association, as masterservicer, LNR Partners, LLC, as special servicer, Wells Fargo Bank, NationalAssociation, as certificate administrator and trustee, and PentalphaSurveillance LLC, as operating advisor and as asset representations reviewer(filed as Exhibit 4.1 to the registrant's Current Report on Form 8-K/A filed onAugust 6, 2020 under SEC File No. 333-227446-09 and incorporated by referenceherein).

 

(4.2) Trust and Servicing Agreement, dated as ofDecember 1, 2019, between 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,relating to the BX 2019-OC11 securitization transaction, pursuant to which theBellagio Hotel and Casino Mortgage Loan is serviced (filed as Exhibit 4.2 tothe registrant's Current Report on Form 8-K filed on February 20, 2020 underSEC File No. 333-227446-09 and incorporated by reference herein).

 

(4.3) Pooling and Servicing Agreement, dated as ofFebruary 1, 2020, between 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 NCB special servicer, Wells Fargo Bank,National Association, as certificate administrator, Wilmington Trust, NationalAssociation, as trustee, and Pentalpha Surveillance LLC, as operating advisorand as asset representations reviewer, relating to the BANK 2020-BNK25securitization transaction, pursuant to which the 545 Washington BoulevardMortgage Loan is serviced (filed as Exhibit 4.3 to the registrant's CurrentReport on Form 8-K filed on February 20, 2020 under SEC File No. 333-227446-09 andincorporated by reference herein).

 

(4.4) Pooling and Servicing Agreement, dated as ofDecember 1, 2019, between Banc of America Merrill Lynch Commercial MortgageInc., as depositor, Wells Fargo Bank, National Association, as general masterservicer, Midland Loan Services, a Division of PNC Bank, National Association,as general special servicer, National Cooperative Bank, N.A., as NCB masterservicer and NCB special servicer, Wells Fargo Bank, National Association, ascertificate administrator, Wilmington Trust, National Association, as trustee,and Park Bridge Lender Services LLC, as operating advisor and as assetrepresentations reviewer, relating to the BANK 2019-BNK24 securitizationtransaction, pursuant to which the 1412 Broadway Mortgage Loan is serviced(filed as Exhibit 4.4 to the registrant's Current Report on Form 8-K filed onFebruary 20, 2020 under SEC File No. 333-227446-09 and incorporated byreference herein).

 

(4.5) Trust and Servicing Agreement, dated as ofDecember 6, 2019, between 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, paying agent and custodian, relating to the HY2019-55HY securitization transaction, pursuant to which the 55 Hudson YardsMortgage Loan is serviced (filed as Exhibit 4.5 to the registrant's CurrentReport on Form 8-K filed on February 20, 2020 under SEC File No. 333-227446-09and incorporated by reference herein).

 

(4.6) Pooling and Servicing Agreement, dated as ofDecember 1, 2019, between Citigroup Commercial Mortgage Securities Inc., asdepositor, Wells Fargo Bank, National Association, as master servicer, LNRPartners, LLC, as a special servicer, Wilmington Trust, National Association,as trustee, Citibank, N.A., as certificate administrator, and Pentalpha SurveillanceLLC, as operating advisor and asset representations reviewer, relating to theCGCMT 2019-C7 securitization transaction, pursuant to which the Alrig PortfolioMortgage Loan is serviced (filed as Exhibit 4.6 to the registrant's CurrentReport on Form 8-K filed on February 20, 2020 under SEC File No. 333-227446-09and incorporated by reference herein).

 

(4.7) Pooling and Servicing Agreement, dated as ofMarch 1, 2020, between Credit Suisse Commercial Mortgage Securities Corp., asdepositor, Midland Loan Services, a Division of PNC Bank, National Association,as master servicer, 3650 REIT Loan Servicing LLC, as special servicer, ParkBridge Lender Services LLC, as operating advisor and as asset representationsreviewer, and Wells Fargo Bank, National Association, as certificateadministrator and trustee, relating to the CSAIL 2020-C19 securitizationtransaction, pursuant to which the Sol y Luna Mortgage Loan is serviced (filedas Exhibit 4.7 to the registrant's Current Report on Form 8-K/A filed on April13, 2020 under SEC File No. 333-227446-09 and incorporated by referenceherein).

 

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

 

(33)  Reports onassessment of compliance with servicing criteria for asset-backed securities.

 

33.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

33.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

33.3 Wells Fargo Bank, National Association, as Custodian

 

33.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

 

33.5 Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer 

 

33.6 Argentic Services Company LP, as Special Servicer

 

33.7 Pentalpha Surveillance LLC, as Operating Advisor

 

33.8 KeyBank National Association, as Master Servicer underthe BX 2019-OC11 securitization, pursuant to which the following mortgage loanswere serviced by such party: Bellagio Hotel and Casino (from 1/1/22 to12/31/22)

 

33.9 Wells Fargo Bank, National Association, as MasterServicer under the BANK 2020-BNK25 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 545 Washington Boulevard(from 1/1/22 to 12/31/22)

 

33.10 CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2020-BNK25 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 545 Washington Boulevard(from 1/1/22 to 12/31/22)

 

33.11 Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK24 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 1412 Broadway (from1/1/22 to 12/31/22) (See exhibit 33.9)

 

33.12 CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2019-BNK24 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 1412 Broadway (from 1/1/22to 12/31/22) (See exhibit 33.10)

 

33.13 Wells Fargo Bank, National Association, as MasterServicer under the Hudson Yards 2019-55HY securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 33.9)

 

33.14 CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the Hudson Yards 2019-55HY securitization, pursuant to whichthe following mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 33.10)

 

33.15 Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer under the CSAIL 2020-C19securitization, pursuant to which the following mortgage loans were serviced bysuch party: Sol y Luna (from 1/1/22 to 12/31/22) (See exhibit 33.5)

 

33.16 Wells Fargo Bank, National Association, as MasterServicer under the CGCMT 2019-C7 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Alrig Portfolio (from1/1/22 to 12/31/22) (See exhibit 33.9)

 

33.17 CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the CGCMT 2019-C7 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Alrig Portfolio (from1/1/22 to 12/31/22) (See exhibit 33.10)

 

33.18 Situs Holdings, LLC, as Special Servicer under the BX2019-OC11 securitization, pursuant to which the following mortgage loans wereserviced by such party: Bellagio Hotel and Casino (from 1/1/22 to 12/31/22)

 

33.19 CWCapital Asset Management LLC, as Special Servicerunder the BANK 2020-BNK25 securitization, pursuant to which the followingmortgage loans were serviced by such party: 545 Washington Boulevard (from12/1/22 to 12/31/22)

 

33.20 KeyBank National Association, as Special Servicerunder the BANK 2020-BNK25 securitization, pursuant to which the followingmortgage loans were serviced by such party: 545 Washington Boulevard (from1/1/22 to 11/30/22) (See exhibit 33.8)

 

33.21 LNR Partners, LLC, as Special Servicer under the BANK2019-BNK24 securitization, pursuant to which the following mortgage loans wereserviced by such party: 1412 Broadway (from 1/1/22 to 12/31/22)

 

33.22 CWCapital Asset Management LLC, as Special Servicerunder the Hudson Yards 2019-55HY securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 33.19)

 

33.23 LNR Partners, LLC, as Special Servicer under theCGCMT 2019-C7 securitization, pursuant to which the following mortgage loanswere serviced by such party: Alrig Portfolio (from 1/1/22 to 12/31/22) (Seeexhibit 33.21)

 

33.24 Wells Fargo Bank, National Association, as Custodianunder the BX 2019-OC11 securitization, pursuant to which the following mortgageloans were serviced by such party: Bellagio Hotel and Casino (from 1/1/22 to12/31/22) (See exhibit 33.3)

 

33.25 Computershare Trust Company, National Association, asServicing Function Participant under the BX 2019-OC11 securitization, pursuantto which the following mortgage loans were serviced by such party: BellagioHotel and Casino (from 1/1/22 to 12/31/22) (See exhibit 33.4)

 

33.26 Wells Fargo Bank, National Association, as Custodianunder the BANK 2020-BNK25 securitization, pursuant to which the followingmortgage loans were serviced by such party: 545 Washington Boulevard (from1/1/22 to 12/31/22) (See exhibit 33.3)

 

33.27  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2020-BNK25 securitization,pursuant to which the following mortgage loans were serviced by such party: 545Washington Boulevard (from 1/1/22 to 12/31/22) (See exhibit 33.4)

 

33.28 Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK24 securitization, pursuant to which the followingmortgage loans were serviced by such party: 1412 Broadway (from 1/1/22 to12/31/22) (See exhibit 33.3)

 

33.29  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK24 securitization,pursuant to which the following mortgage loans were serviced by such party:1412 Broadway (from 1/1/22 to 12/31/22) (See exhibit 33.4)

 

33.30 Wells Fargo Bank, National Association, as Custodianunder the Hudson Yards 2019-55HY securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 33.3)

 

33.31  Computershare Trust Company, National Association, asServicing Function Participant under the Hudson Yards 2019-55HY securitization,pursuant to which the following mortgage loans were serviced by such party: 55Hudson Yards (from 1/1/22 to 12/31/22) (See exhibit 33.4)

 

33.32 Wells Fargo Bank, National Association, as Custodianunder the CSAIL 2020-C19 securitization, pursuant to which the followingmortgage loans were serviced by such party: Sol y Luna (from 1/1/22 to12/31/22) (See exhibit 33.3)

 

33.33  Computershare Trust Company, National Association, asServicing Function Participant under the CSAIL 2020-C19 securitization,pursuant to which the following mortgage loans were serviced by such party: Soly Luna (from 1/1/22 to 12/31/22) (See exhibit 33.4)

 

(34). Attestation reports onassessment of compliance with servicing criteria for asset-backed securities.

 

34.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

34.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

34.3 Wells Fargo Bank, National Association, as Custodian

 

34.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

 

34.5 Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer 

 

34.6 Argentic Services Company LP, as Special Servicer

 

34.7 Pentalpha Surveillance LLC, as Operating Advisor

 

34.8 KeyBank National Association, as Master Servicer underthe BX 2019-OC11 securitization, pursuant to which the following mortgage loanswere serviced by such party: Bellagio Hotel and Casino (from 1/1/22 to12/31/22)

 

34.9 Wells Fargo Bank, National Association, as MasterServicer under the BANK 2020-BNK25 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 545 Washington Boulevard(from 1/1/22 to 12/31/22)

 

34.10 CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2020-BNK25 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 545 Washington Boulevard(from 1/1/22 to 12/31/22)

 

34.11 Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK24 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 1412 Broadway (from1/1/22 to 12/31/22) (See exhibit 34.9)

 

34.12 CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2019-BNK24 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 1412 Broadway (from1/1/22 to 12/31/22) (See exhibit 34.10)

 

34.13 Wells Fargo Bank, National Association, as MasterServicer under the Hudson Yards 2019-55HY securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 34.9)

 

34.14 CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the Hudson Yards 2019-55HY securitization, pursuant to whichthe following mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 34.10)

 

34.15 Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer under the CSAIL 2020-C19securitization, pursuant to which the following mortgage loans were serviced bysuch party: Sol y Luna (from 1/1/22 to 12/31/22) (See exhibit 34.5)

 

34.16 Wells Fargo Bank, National Association, as MasterServicer under the CGCMT 2019-C7 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Alrig Portfolio (from1/1/22 to 12/31/22) (See exhibit 34.9)

 

34.17 CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the CGCMT 2019-C7 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Alrig Portfolio (from1/1/22 to 12/31/22) (See exhibit 34.10)

 

34.18 Situs Holdings, LLC, as Special Servicer under the BX2019-OC11 securitization, pursuant to which the following mortgage loans wereserviced by such party: Bellagio Hotel and Casino (from 1/1/22 to 12/31/22)

 

34.19 CWCapital Asset Management LLC, as Special Servicerunder the BANK 2020-BNK25 securitization, pursuant to which the followingmortgage loans were serviced by such party: 545 Washington Boulevard (from12/1/22 to 12/31/22)

 

34.20 KeyBank National Association, as Special Servicerunder the BANK 2020-BNK25 securitization, pursuant to which the followingmortgage loans were serviced by such party: 545 Washington Boulevard (from1/1/22 to 11/30/22) (See exhibit 34.8)

 

34.21 LNR Partners, LLC, as Special Servicer under the BANK2019-BNK24 securitization, pursuant to which the following mortgage loans wereserviced by such party: 1412 Broadway (from 1/1/22 to 12/31/22)

 

34.22 CWCapital Asset Management LLC, as Special Servicerunder the Hudson Yards 2019-55HY securitization, pursuant to which the followingmortgage loans were serviced by such party: 55 Hudson Yards (from 1/1/22 to12/31/22) (See exhibit 34.19)

 

34.23 LNR Partners, LLC, as Special Servicer under theCGCMT 2019-C7 securitization, pursuant to which the following mortgage loanswere serviced by such party: Alrig Portfolio (from 1/1/22 to 12/31/22) (Seeexhibit 34.21)

 

34.24 Wells Fargo Bank, National Association, as Custodianunder the BX 2019-OC11 securitization, pursuant to which the following mortgageloans were serviced by such party: Bellagio Hotel and Casino (from 1/1/22 to12/31/22) (See exhibit 34.3)

 

34.25 Computershare Trust Company, National Association, asServicing Function Participant under the BX 2019-OC11 securitization, pursuantto which the following mortgage loans were serviced by such party: BellagioHotel and Casino (from 1/1/22 to 12/31/22) (See exhibit 34.4)

 

34.26 Wells Fargo Bank, National Association, as Custodianunder the BANK 2020-BNK25 securitization, pursuant to which the followingmortgage loans were serviced by such party: 545 Washington Boulevard (from1/1/22 to 12/31/22) (See exhibit 34.3)

 

34.27  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2020-BNK25 securitization,pursuant to which the following mortgage loans were serviced by such party: 545Washington Boulevard (from 1/1/22 to 12/31/22) (See exhibit 34.4)

 

34.28 Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK24 securitization, pursuant to which the followingmortgage loans were serviced by such party: 1412 Broadway (from 1/1/22 to12/31/22) (See exhibit 34.3)

 

34.29  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK24 securitization,pursuant to which the following mortgage loans were serviced by such party:1412 Broadway (from 1/1/22 to 12/31/22) (See exhibit 34.4)

 

34.30 Wells Fargo Bank, National Association, as Custodianunder the Hudson Yards 2019-55HY securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 34.3)

 

34.31  Computershare Trust Company, National Association, asServicing Function Participant under the Hudson Yards 2019-55HY securitization,pursuant to which the following mortgage loans were serviced by such party: 55Hudson Yards (from 1/1/22 to 12/31/22) (See exhibit 34.4)

 

34.32 Wells Fargo Bank, National Association, as Custodianunder the CSAIL 2020-C19 securitization, pursuant to which the followingmortgage loans were serviced by such party: Sol y Luna (from 1/1/22 to12/31/22) (See exhibit 34.3)

 

34.33  Computershare Trust Company, National Association, asServicing Function Participant under the CSAIL 2020-C19 securitization,pursuant to which the following mortgage loans were serviced by such party: Soly Luna (from 1/1/22 to 12/31/22) (See exhibit 34.4)

 

(35). Servicer compliancestatement.

 

35.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

35.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

35.3 Wells Fargo Bank, National Association, as Custodian

 

35.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

 

35.5 Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

 

35.6 Argentic Services Company LP, as Special Servicer

 

35.7 Wells Fargo Bank, National Association, as MasterServicer under the BANK 2020-BNK25 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 545 Washington Boulevard(from 1/1/22 to 12/31/22)

 

35.8 Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK24 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 1412 Broadway (from1/1/22 to 12/31/22) (See exhibit 35.7)

 

35.9 Wells Fargo Bank, National Association, as MasterServicer under the Hudson Yards 2019-55HY securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 35.7)

 

35.10 Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer under the CSAIL 2020-C19securitization, pursuant to which the following mortgage loans were serviced bysuch party: Sol y Luna (from 1/1/22 to 12/31/22) (See exhibit 35.5)

 

35.11 Wells Fargo Bank, National Association, as MasterServicer under the CGCMT 2019-C7 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Alrig Portfolio (from1/1/22 to 12/31/22) (See exhibit 35.7)

 

35.12 CWCapital Asset Management LLC, as Special Servicerunder the BANK 2020-BNK25 securitization, pursuant to which the followingmortgage loans were serviced by such party: 545 Washington Boulevard (from12/1/22 to 12/31/22)

 

35.13 LNR Partners, LLC, as Special Servicer under the BANK2019-BNK24 securitization, pursuant to which the following mortgage loans wereserviced by such party: 1412 Broadway (from 1/1/22 to 12/31/22)

 

35.14 CWCapital Asset Management LLC, as Special Servicerunder the Hudson Yards 2019-55HY securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 35.12)

 

35.15 LNR Partners, LLC, as Special Servicer under theCGCMT 2019-C7 securitization, pursuant to which the following mortgage loanswere serviced by such party: Alrig Portfolio (from 1/1/22 to 12/31/22) (Seeexhibit 35.13)

 

35.16 Wells Fargo Bank, National Association, as Custodianunder the BX 2019-OC11 securitization, pursuant to which the following mortgageloans were serviced by such party: Bellagio Hotel and Casino (from 1/1/22 to12/31/22) (See exhibit 35.3)

 

35.17 Computershare Trust Company, National Association, asServicing Function Participant under the BX 2019-OC11 securitization, pursuantto which the following mortgage loans were serviced by such party: BellagioHotel and Casino (from 1/1/22 to 12/31/22) (See exhibit 35.4)

 

35.18 Wells Fargo Bank, National Association, as Custodianunder the BANK 2020-BNK25 securitization, pursuant to which the followingmortgage loans were serviced by such party: 545 Washington Boulevard (from1/1/22 to 12/31/22) (See exhibit 35.3)

 

35.19  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2020-BNK25 securitization,pursuant to which the following mortgage loans were serviced by such party: 545Washington Boulevard (from 1/1/22 to 12/31/22) (See exhibit 35.4)

 

35.20 Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK24 securitization, pursuant to which the followingmortgage loans were serviced by such party: 1412 Broadway (from 1/1/22 to12/31/22) (See exhibit 35.3)

 

35.21  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK24 securitization,pursuant to which the following mortgage loans were serviced by such party:1412 Broadway (from 1/1/22 to 12/31/22) (See exhibit 35.4)

 

35.22 Wells Fargo Bank, National Association, as Custodianunder the Hudson Yards 2019-55HY securitization, pursuant to which thefollowing mortgage loans were serviced by such party: 55 Hudson Yards (from1/1/22 to 12/31/22) (See exhibit 35.3)

 

35.23  Computershare Trust Company, National Association, asServicing Function Participant under the Hudson Yards 2019-55HY securitization,pursuant to which the following mortgage loans were serviced by such party: 55Hudson Yards (from 1/1/22 to 12/31/22) (See exhibit 35.4)

 

35.24 Wells Fargo Bank, National Association, as Custodianunder the CSAIL 2020-C19 securitization, pursuant to which the followingmortgage loans were serviced by such party: Sol y Luna (from 1/1/22 to12/31/22) (See exhibit 35.3)

 

35.25  Computershare Trust Company, National Association, asServicing Function Participant under the CSAIL 2020-C19 securitization,pursuant to which the following mortgage loans were serviced by such party: Soly Luna (from 1/1/22 to 12/31/22) (See exhibit 35.4)

 

(99.1) Mortgage Loan Purchase Agreement, dated February7, 2020, between Morgan Stanley Capital I Inc. and Morgan Stanley MortgageCapital Holdings LLC (filed as Exhibit 99.1 to the registrant's Current Reporton Form 8-K filed on February 20, 2020 under SEC File No. 333-227446-09 andincorporated by reference herein).

 

(99.2) Mortgage Loan Purchase Agreement, dated February7, 2020, between Morgan Stanley Capital I Inc. and Argentic Real Estate FinanceLLC (filed as Exhibit 99.2 to the registrant's Current Report on Form 8-K filedon February 20, 2020 under SEC File No. 333-227446-09 and incorporated byreference herein).

 

(99.3) Mortgage Loan Purchase Agreement, dated February7, 2020, between Morgan Stanley Capital I Inc. and Starwood Mortgage CapitalLLC (filed as Exhibit 99.3 to the registrant's Current Report on Form 8-K filedon February 20, 2020 under SEC File No. 333-227446-09 and incorporated byreference herein).

 

(99.4) Mortgage Loan Purchase Agreement, dated February7, 2020, between Morgan Stanley Capital I Inc. and Cantor Commercial RealEstate Lending, L.P. (filed as Exhibit 99.4 to the registrant's Current Reporton Form 8-K filed on February 20, 2020 under SEC File No. 333-227446-09 andincorporated by reference herein).

 

(99.5) Agreement Between Note Holders, dated as ofDecember 9, 2019, by and between Morgan Stanley Bank, N.A., as initial noteA-1-S1 holder, initial note A-1-S2 holder, initial note A-1-RL holder, initialnote A-1-C1 holder, initial note 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-Sholder, initial note B-1-RL holder and initial note C-1-S holder, Citi RealEstate Funding Inc., as initial note A-2-S1 holder, initial note A-2-S2 holder,initial note A-2-RL holder, initial note A-2-C1 holder, initial note A-2-C2 holder,initial note A-2-C3 holder, initial note A-2-C4 holder, initial note A-2-C5holder, initial note B-2-S holder, initial note B-2-RL holder and initial noteC-2-S holder, and JPMorgan Chase Bank, National Association, as initial noteA-3-S1 holder, initial note A-3-S2 holder, initial note A-3-RL holder, initialnote A-3-C1 holder, initial note A-3-C2 holder, initial note A-3-C3 holder,initial note A-3-C4 holder, initial note A-3-C5 holder, initial note B-3-Sholder, initial note B-3-RL holder and initial note C-3-S holder, relating tothe Bellagio Hotel and Casino loan combination (filed as Exhibit 99.5 to theregistrant's Current Report on Form 8-K filed on February 20, 2020 under SECFile No. 333-227446-09 and incorporated by reference herein).

 

(99.6) Agreement Between Note Holders, dated as ofJanuary 23, 2020, by and between Morgan Stanley Bank, N.A., as initial note A-1holder, Morgan Stanley Bank, N.A., as initial note A-2 holder, Morgan StanleyBank, N.A., as initial note A-3 holder, Barclays Capital Real Estate Inc., asinitial note A-4 holder, and Morgan Stanley Mortgage Capital Holdings LLC, asinitial agent, relating to the 545 Washington Boulevard loan combination (filedas Exhibit 99.6 to the registrant's Current Report on Form 8-K filed onFebruary 20, 2020 under SEC File No. 333-227446-09 and incorporated byreference herein).

 

(99.7) Agreement Between Note Holders, dated as ofNovember 21, 2019, by and between Argentic Real Estate Finance LLC, as initialnote A-1 holder, Argentic Real Estate Finance LLC, as initial note A-2 holder,Argentic Real Estate Finance LLC, as initial note A-3 holder, and Argentic RealEstate Finance LLC, as initial note A-4 holder, relating to the Royal PalmPlace loan combination (filed as Exhibit 99.7 to the registrant's CurrentReport on Form 8-K filed on February 20, 2020 under SEC File No. 333-227446-09and incorporated by reference herein).

 

(99.8) Agreement Between Noteholders, dated as of February20, 2020, by and among Cantor Commercial Real Estate Lending, L.P., as initialnote A-1 holder, Cantor Commercial Real Estate Lending, L.P., as initial noteA-2 holder, Cantor Commercial Real Estate Lending, L.P., as initial note A-3holder, Cantor Commercial Real Estate Lending, L.P., as initial note A-4holder, and Cantor Commercial Real Estate Lending, L.P., as initial note A-5holder, relating to the AVR Atlanta Airport Marriott Gateway loan combination(filed as Exhibit 99.8 to the registrant's Current Report on Form 8-K filed onFebruary 20, 2020 under SEC File No. 333-227446-09 and incorporated byreference herein).

 

(99.9) Agreement Between Note Holders, dated as ofDecember 19, 2019, by and between Morgan Stanley Bank, N.A., as initial noteA-1 holder, Morgan Stanley Bank, N.A., as initial note A-2 holder, MorganStanley Bank, N.A., as initial note A-3 holder, and Morgan Stanley Mortgage CapitalHoldings LLC, as initial agent, relating to the 1412 Broadway loan combination(filed as Exhibit 99.9 to the registrant's Current Report on Form 8-K filed onFebruary 20, 2020 under SEC File No. 333-227446-09 and incorporated byreference herein).

 

(99.10) Co-Lender Agreement, dated as of November 21,2019, by and between Wells Fargo Bank, National Association, as initial note Aholder, DBR Investments Co. Limited, as initial note A holder, Morgan StanleyBank, National Association, as initial note A holder, Wells Fargo Bank,National Association, as initial note B-1 holder, DBR Investments Co. Limited,as initial note B-2 holder, and Morgan Stanley Bank, National Association, asinitial note B-3 holder, relating to the 55 Hudson Yards loan combination(filed as Exhibit 99.10 to the registrant's Current Report on Form 8-K filed onFebruary 20, 2020 under SEC File No. 333-227446-09 and incorporated byreference herein).

 

(99.11) Agreement Between Noteholders, dated as ofJanuary 3, 2020, by and among Grass River Real Estate Credit Partners LoanFunding, LLC, as initial note A-1, A-2, A-3, A-4, A-5 and A-6 holder, andCantor Commercial Real Estate Lending, L.P., as initial note B holder, relatingto the Sol y Luna loan combination (filed as Exhibit 99.11 to the registrant'sCurrent Report on Form 8-K filed on February 20, 2020 under SEC File No.333-227446-09 and incorporated by reference herein).

 

(99.12) Co-Lender Agreement, dated as of January 24,2020, by and between Starwood Mortgage Capital LLC, as initial note A-1 holder,and Starwood Mortgage Capital LLC, as initial note A-2 holder, relating to theMcCarthy Ranch loan combination (filed as Exhibit 99.12 to the registrant'sCurrent Report on Form 8-K filed on February 20, 2020 under SEC File No.333-227446-09 and incorporated by reference herein).

 

(99.13) Co-Lender Agreement, dated as of October 25,2019, by and among Starwood Mortgage Capital LLC, as initial note A-1 holder,Starwood Mortgage Capital LLC, as initial note A-2 holder, and StarwoodMortgage Capital LLC, as initial note A-3 holder, relating to the AlrigPortfolio loan combination (filed as Exhibit 99.13 to the registrant's CurrentReport on Form 8-K filed on February 20, 2020 under SEC File No. 333-227446-09and incorporated by reference herein).

 

(99.14) Agreement Between Noteholders, dated as ofFebruary 20, 2020, by and among Cantor Commercial Real Estate Lending, L.P., asinitial note A-1 holder, and Cantor Commercial Real Estate Lending, L.P., asinitial note A-2 holder, relating to the Jewelry Building loan combination(filed as Exhibit 99.14 to the registrant's Current Report on Form 8-K filed onFebruary 20, 2020 under SEC File No. 333-227446-09 and incorporated byreference herein).

 

(99.15)Second Amended and Restated Servicing Agreement,effective as of October 31, 2021, between Wells Fargo Bank, N.A., Wells FargoDelaware Trust Company, N.A., Computershare Trust Company, N.A., ComputershareDelaware Trust Company and Computershare Limited (filed as Exhibit 99.1 to theregistrant's Current Report on Form 8-K filed on November 5, 2021 under SECFile No. 333-227446-09 and incorporated by reference herein).

 

(b)See (a) above.

 

(c) NotApplicable.

** **

**SIGNATURES**

 

Pursuantto the requirements of Section 13 or 15(d) of the Securities Exchange Act of1934, the registrant has duly caused this report to be signed on its behalf bythe undersigned, thereunto duly authorized.

 

MorganStanley Capital I Inc.

(Depositor)

 

By:/s/ Jane Lam

JaneLam, President

(seniorofficer in charge of securitization of the depositor)

 

Date: March 28, 2023