**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, 2021or**

**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: 333-226486-16**

**Central Index Key Number of the issuing entity:0001822166**

**BANK 2020-BNK28**

**(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)**

** **

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

**the issuing entity)** | **38-4155239**

**38-4155240**

**38-7250431**

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

**Identification Number)** |
|------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------|

**c/o 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 and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted 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 and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form10-K.   

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“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller 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

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 9th & Thomas Mortgage Loan, theExchangeRight Net Leased Portfolio #39 Mortgage Loan and the ChasewoodTechnology Park Mortgage Loan, which constituted approximately 9.7%, 5.2% and4.2%, respectively, of the asset pool of the issuing entity as of its cut-offdate, are each an asset of the issuing entity and are each part of a loancombination that includes the 9th & Thomas Mortgage Loan, the ExchangeRightNet Leased Portfolio #39 Mortgage Loan or the Chasewood Technology ParkMortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity. These loan combinations, including the 9th & ThomasMortgage Loan, the ExchangeRight Net Leased Portfolio #39 Mortgage Loan and theChasewood Technology Park Mortgage Loan, are being serviced and administeredpursuant to the Pooling and Servicing Agreement, which is incorporated byreference as Exhibit 4.1 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 711 Fifth Avenue Mortgage Loan, whichconstituted approximately 8.3% of the asset pool of the issuing entity as ofits cut-off date.  The 711 Fifth Avenue Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 711 FifthAvenue Mortgage Loan and twenty other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the GS Mortgage Securities Trust 2020-GC47transaction, Commission File Number 333-226082-07 (the “GSMS 2020-GC47Transaction”). This loan combination, including the 711 Fifth Avenue MortgageLoan, is being serviced and administered pursuant to the pooling and servicingagreement for the GSMS 2020-GC47 Transaction, which is incorporated byreference as Exhibit 4.2 to this Annual Report 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 FargoBank, National Association is the general master servicer (except with respectto those mortgage loans for which National Cooperative Bank, N.A. is the masterservicer) and certificate administrator of the mortgage loans serviced underthe Pooling and Servicing Agreement and the primary servicer of the 711 FifthAvenue Mortgage Loan. As a result, Wells Fargo Bank, National Association 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 Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

KeyBankNational Association is the general special servicer (except with respect tothose mortgage loans for which National Cooperative Bank, N.A. is the specialservicer) of the mortgage loans serviced under the Pooling and ServicingAgreement and the special servicer of the 711 Fifth Avenue Mortgage Loan. As aresult, KeyBank National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by KeyBank National Association in thecapacities described above are listed in the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement and the 711 Fifth Avenue Mortgage Loan.  Pursuantto the Pooling and Servicing Agreement and the pooling and servicing agreementfor the GSMS 2020-GC47 Transaction, the trustee is required to provide anassessment of compliance with applicable servicing criteria solely with respectto Item 1122(d)(2)(iii) of Regulation AB (regarding advances of funds orguarantees regarding collections, cash flows or distributions, and any interestor other fees charged for such advances, are made, reviewed and approved asspecified in the transaction agreements). However, during the reporting period,the trustee did not perform any servicing function with respect to theservicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performedthe servicing function identified with respect to Item 1122(d)(2)(iii) ofRegulation AB, and each such party included Item 1122(d)(2)(iii) of RegulationAB in the assessment of compliance with applicable servicing criteria andaccountant’s attestation report for the subject transaction.  As a result,this Annual Report on Form 10-K does not include an assessment of compliancewith applicable servicing criteria of the trustee. One or more other servicersof the mortgage loans serviced under the Pooling and Servicing Agreement andthe 711 Fifth Avenue Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

This AnnualReport on Form 10-K includes assessments of compliance with applicableservicing criteria and accountants’ attestation reports from CoreLogicSolutions, LLC  This entity was engaged by the general master servicer(except with respect to those mortgage loans for which National CooperativeBank, N.A. is the master servicer) of the mortgage loans serviced under thePooling and Servicing Agreement and the primary servicer of the 711 FifthAvenue Mortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in Items1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation 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 corporate trustservices business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  SeeCompliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessment of compliance with applicable servicing criteria, accountants’attestation report and servicer compliance statement of the certificate administratorof the 711 Fifth Avenue Mortgage Loan is omitted from this Annual Report onForm 10-K as the certificate administrator pursuant to the related pooling andservicing agreement or trust and servicing agreement does not perform anyactivities that address servicing criteria with respect to the issuing entityand because it is not a “servicer” that meets the criteria in Item1108(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.  Selected Financial Data.**

Omitted.

**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.

**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 Accounting 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 Wells Fargo Bank, National Association, ascertificate administrator and as custodian.

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit UnionAdministration (NCUA) filed complaints in the United States District Court forthe Southern District of New York against Wells Fargo Bank, alleging claimsagainst Wells Fargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In eachcase, the plaintiffs allege that Wells Fargo Bank, 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. Wells Fargo Bankpreviously settled two class action lawsuits with similar allegations that werefiled in November 2014 and December 2016 by institutional investors in theSouthern District of New York and New York state court, respectively. Inaddition, Park Royal I LLC and Park Royal II LLC have filed complaints in NewYork state court alleging Wells Fargo Bank, N.A., as trustee, failed to takeappropriate actions upon learning of defective mortgage loan documentation. InMarch 2021, the Company entered into an agreement to resolve the case filed bythe NCUA.

 

In addition to the foregoingcases, in August 2014 and August 2015 Nomura Credit & Capital Inc. (“Nomura”)and Natixis Real Estate Holdings, LLC (“Natixis”) filed a total of seventhird-party complaints against Wells Fargo Bank in New York state court. In theunderlying first-party actions, Nomura and Natixis have been sued for allegedbreaches of representations and warranties made in connection with residentialmortgage-backed securities sponsored by them. In the third-party actions,Nomura and Natixis allege that Wells Fargo Bank, as master servicer, primaryservicer or securities administrator, failed to notify Nomura and Natixis oftheir own breaches, failed to properly oversee the primary servicers, and failedto adhere to accepted servicing practices. Natixis additionally alleges thatWells Fargo Bank failed to perform default oversight duties. Wells Fargo Bankhas asserted counterclaims alleging that Nomura and Natixis failed to provideWells Fargo Bank notice of their representation and warranty breaches. 

With respect to each of the foregoing litigations, WellsFargo Bank believes plaintiffs' claims are without merit and intends to contestthe claims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe related RMBS trusts.

**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 September 30, 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 711 Fifth Avenue Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the GSMS 2020-GC47 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the GSMS 2020-GC47 Transaction incorporated byreference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the GSMS2020-GC47 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

**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. Exhibits, 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          Poolingand Servicing Agreement, dated as of September 1, 2020, among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, KeyBank National Association, asGeneral Special Servicer, National Cooperative Bank, N.A., as Co-op MasterServicer and as Co-op Special Servicer, Wells Fargo Bank, National Association,as Certificate Administrator, Wilmington Trust, National Association, asTrustee, and Park Bridge Lender Services LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 4.1 to the registrant’s CurrentReport on Form 8-K filed on September 30, 2020 under Commission File No.333-226486-16 and incorporated by reference herein).

4.2          Poolingand Servicing Agreement, dated as of May 1, 2020, by and among GS MortgageSecurities Corporation II, as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, KeyBank National Association, as SpecialServicer, Wilmington Trust, National Association, as Trustee, Wells Fargo Bank,National Association, as Certificate Administrator, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.2 to the registrant’s Current Report on Form 8-K filed onSeptember 30, 2020 under Commission File No. 333-226486-16 and incorporated byreference herein).

4.3          AgreementBetween Note Holders, dated as of September 4, 2020, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, Bank of America, N.A., as InitialNote A-2 Holder, Bank of America, N.A., as Initial Note A-3 Holder, Bank ofAmerica, N.A., as Initial Note A-4 Holder, and Bank of America, N.A., InitialNote A-5 Holder (filed as Exhibit 4.3 to the registrant’s Current Report onForm 8-K filed on September 30, 2020 under Commission File No. 333-226486-16and incorporated by reference herein)

4.4          AgreementBetween Noteholders, dated as of May 21, 2020, by and among Goldman Sachs BankUSA, as Initial Note A-1-1 Holder, Initial Note A-1-2 Holder, Initial NoteA-1-3 Holder, Initial Note A-1-4 Holder, Initial Note A-1-5 Holder, InitialNote A-1-6 Holder, Initial Note A-1-7 Holder, Initial Note A-1-8 Holder,Initial Note A-1-9 Holder, Initial Note A-1-10 Holder, Initial Note A-1-11Holder, Initial Note A-1-12 Holder, Initial Note A-1-13 Holder, Initial NoteA-1-14 Holder, Initial Note A-1-15 Holder, Initial Note A-1-16 Holder andInitial Note A-1-17 Holder, and Bank of America, N.A., as Initial Note A-2-1Holder, Initial Note A-2-2 Holder, Initial Note A-2-3 Holder and Initial NoteA-2-4 Holder (filed as Exhibit 4.4 to the registrant’s Current Report on Form8-K filed on September 30, 2020 under Commission File No. 333-226486-16 andincorporated by reference herein)

4.5          AgreementBetween Note Holders, dated as of September 3, 2020, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, and Bank of America, N.A., asInitial Note A-2 Holder (filed as Exhibit 4.5 to the registrant’s CurrentReport on Form 8-K filed on September 30, 2020 under Commission File No.333-226486-16 and incorporated by reference herein)

4.6          AgreementBetween Note Holders, dated as of September 30, 2020, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., asInitial Note A-2 Holder, and Morgan Stanley Mortgage Capital Holdings LLC, asInitial Agent (filed as Exhibit 4.6 to the registrant’s Current Report on Form8-K filed on September 30, 2020 under Commission File No. 333-226486-16 andincorporated 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 Co-op MasterServicer

33.3        KeyBank National Association, as General SpecialServicer

33.4        National Cooperative Bank, N.A., as Co-op SpecialServicer (see Exhibit 33.2)

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

33.6        Wells Fargo Bank, National Association, asCertificate Administrator

33.7        Wells Fargo Bank, National Association, as Custodian

33.8        Park Bridge Lender Services LLC, as OperatingAdvisor

33.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

33.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

33.12      Wells Fargo Bank, National Association, as PrimaryServicer of the 9th & Thomas Mortgage Loan (see Exhibit 33.1)

33.13      KeyBank National Association, as Special Servicerof the 9th & Thomas Mortgage Loan (see Exhibit 33.3)

33.14      Wilmington Trust, National Association, as Trustee of the 9th & ThomasMortgage Loan (Omitted. See Explanatory Notes.)

33.15      Wells Fargo Bank, National Association, asCustodian of the 9th & Thomas Mortgage Loan (see Exhibit 33.7)

33.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the 9th & Thomas Mortgage Loan (see Exhibit 33.8)

33.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 9th & Thomas Mortgage Loan (see Exhibit 33.9)

33.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.19      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 33.1)

33.20      KeyBank National Association, as Special Servicerof the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (see Exhibit 33.3)

33.21      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio #39 Mortgage Loan (Omitted. See Explanatory Notes.)

33.22      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 33.7)

33.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 33.8)

33.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 33.9)

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Chasewood Technology Park Mortgage Loan (see Exhibit 33.1)

33.27      KeyBank National Association, as Special Servicerof the Chasewood Technology Park Mortgage Loan (see Exhibit 33.3)

33.28      Wilmington Trust, National Association, as Trustee of the Chasewood TechnologyPark Mortgage Loan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, asCustodian of the Chasewood Technology Park Mortgage Loan (see Exhibit 33.7)

33.30      Park Bridge Lender Services LLC, as OperatingAdvisor of the Chasewood Technology Park Mortgage Loan (see Exhibit 33.8)

33.31      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Chasewood Technology Park Mortgage Loan (see Exhibit 33.9)

33.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.33      Wells Fargo Bank, National Association, as PrimaryServicer of the 711 Fifth Avenue Mortgage Loan (see Exhibit 33.1)

33.34      KeyBank National Association, as Special Servicerof the 711 Fifth Avenue Mortgage Loan (see Exhibit 33.3)

33.35      Wilmington Trust, National Association, as Trustee of the 711 Fifth AvenueMortgage Loan (Omitted. See Explanatory Notes.)

33.36      Wells Fargo Bank, National Association, asCustodian of the 711 Fifth Avenue Mortgage Loan (see Exhibit 33.7)

33.37      Park Bridge Lender Services LLC, as OperatingAdvisor of the 711 Fifth Avenue Mortgage Loan (see Exhibit 33.8)

33.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 711 Fifth Avenue Mortgage Loan (see Exhibit 33.9)

33.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

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 Co-op MasterServicer

34.3        KeyBank National Association, as General SpecialServicer

34.4        National Cooperative Bank, N.A., as Co-op SpecialServicer (see Exhibit 34.2)

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

34.6        Wells Fargo Bank, National Association, asCertificate Administrator

34.7        Wells Fargo Bank, National Association, asCustodian

34.8        Park Bridge Lender Services LLC, as OperatingAdvisor

34.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

34.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

34.12      Wells Fargo Bank, National Association, as PrimaryServicer of the 9th & Thomas Mortgage Loan (see Exhibit 34.1)

34.13      KeyBank National Association, as Special Servicerof the 9th & Thomas Mortgage Loan (see Exhibit 34.3)

34.14      Wilmington Trust, National Association, as Trustee of the 9th & ThomasMortgage Loan (Omitted. See Explanatory Notes.)

34.15      Wells Fargo Bank, National Association, asCustodian of the 9th & Thomas Mortgage Loan (see Exhibit 34.7)

34.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the 9th & Thomas Mortgage Loan (see Exhibit 34.8)

34.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 9th & Thomas Mortgage Loan (see Exhibit 34.9)

34.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.19      Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 34.1)

34.20      KeyBank National Association, as Special Servicerof the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (see Exhibit 34.3)

34.21      Wilmington Trust, National Association, as Trustee of the ExchangeRight NetLeased Portfolio #39 Mortgage Loan (Omitted. See Explanatory Notes.)

34.22      Wells Fargo Bank, National Association, asCustodian of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 34.7)

34.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 34.8)

34.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 34.9)

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Chasewood Technology Park Mortgage Loan (see Exhibit 34.1)

34.27      KeyBank National Association, as Special Servicerof the Chasewood Technology Park Mortgage Loan (see Exhibit 34.3)

34.28      Wilmington Trust, National Association, as Trustee of the Chasewood TechnologyPark Mortgage Loan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, asCustodian of the Chasewood Technology Park Mortgage Loan (see Exhibit 34.7)

34.30      Park Bridge Lender Services LLC, as OperatingAdvisor of the Chasewood Technology Park Mortgage Loan (see Exhibit 34.8)

34.31      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Chasewood Technology Park Mortgage Loan (see Exhibit 34.9)

34.32      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.33      Wells Fargo Bank, National Association, as PrimaryServicer of the 711 Fifth Avenue Mortgage Loan (see Exhibit 34.1)

34.34      KeyBank National Association, as Special Servicerof the 711 Fifth Avenue Mortgage Loan (see Exhibit 34.3)

34.35      Wilmington Trust, National Association, as Trustee of the 711 Fifth AvenueMortgage Loan (Omitted. See Explanatory Notes.)

34.36      Wells Fargo Bank, National Association, asCustodian of the 711 Fifth Avenue Mortgage Loan (see Exhibit 34.7)

34.37      Park Bridge Lender Services LLC, as OperatingAdvisor of the 711 Fifth Avenue Mortgage Loan (see Exhibit 34.8)

34.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 711 Fifth Avenue Mortgage Loan (see Exhibit 34.9)

34.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

35.2        National Cooperative Bank, N.A., as Co-op MasterServicer

35.3        KeyBank National Association, as General SpecialServicer

35.4        National Cooperative Bank, N.A., as Co-op SpecialServicer (see Exhibit 35.2)

35.5        Wells Fargo Bank, National Association, asCertificate Administrator

35.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of the 9th & Thomas Mortgage Loan (see Exhibit 35.1)

35.8        KeyBank National Association, as Special Servicerof the 9th & Thomas Mortgage Loan (see Exhibit 35.3)

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (seeExhibit 35.1)

35.10      KeyBank National Association, as Special Servicerof the ExchangeRight Net Leased Portfolio #39 Mortgage Loan (see Exhibit 35.3)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of the Chasewood Technology Park Mortgage Loan (see Exhibit 35.1)

35.12      KeyBank National Association, as Special Servicerof the Chasewood Technology Park Mortgage Loan (see Exhibit 35.3)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the 711 Fifth Avenue Mortgage Loan (see Exhibit 35.1)

35.14      KeyBank National Association, as Special Servicerof the 711 Fifth Avenue Mortgage Loan (see Exhibit 35.3)

99.1        MortgageLoan Purchase Agreement, dated as of September 21, 2020, between Wells FargoBank, National Association and Wells Fargo Commercial Mortgage Securities, Inc.(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onSeptember 30, 2020 under Commission File No. 333-226486-16 and incorporated byreference herein)

99.2        MortgageLoan Purchase Agreement, dated as of September 21, 2020, between Morgan StanleyMortgage Capital Holdings LLC and Wells Fargo Commercial Mortgage Securities,Inc. (filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-Kfiled on September 30, 2020 under Commission File No. 333-226486-16 andincorporated by reference herein)

99.3        MortgageLoan Purchase Agreement, dated as of September 21, 2020, between Bank ofAmerica, National Association and Wells Fargo Commercial Mortgage Securities,Inc. (filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-Kfiled on September 30, 2020 under Commission File No. 333-226486-16 andincorporated 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 15, 2022