**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

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

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226486-16**

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

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

**Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(704) 374-6161**

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

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

 

 

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

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

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

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

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

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

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

                                                                                                                                                       Emerging growthcompany                    o

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

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

If securities are registered pursuant to Section 12(b) of theAct, indicate by check mark whether the financial statements of the registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements. o

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). o

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 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 , theExchangeRight Net Leased Portfolio #39 Mortgage Loan  or the ChasewoodTechnology Park Mortgage Loan and one other *pari passu* loan, which isnot an asset of the issuing entity. These loan combinations, including the 9th& Thomas Mortgage Loan, the ExchangeRight Net Leased Portfolio #39 MortgageLoan and the Chasewood Technology Park Mortgage Loan, are being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference 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 AvenueMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the GSMS 2020-GC47 Transaction, which is incorporatedby reference 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 Fifth AvenueMortgage 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 thePooling and Servicing Agreement and the 711 Fifth Avenue Mortgage Loan. Pursuant to the Pooling and Servicing Agreement and the pooling and servicingagreement for the GSMS 2020-GC47 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of  the mortgage loans serviced underthe Pooling and Servicing Agreement and the 711 Fifth Avenue Mortgage Loan havedelivered one or more assessments of compliance with respect to Item1122(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 corporatetrust services 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 certificateadministrator of the 711 Fifth Avenue Mortgage Loan is omitted from this AnnualReport on Form 10-K as the certificate administrator pursuant to the relatedpooling and servicing agreement or trust and servicing agreement does notperform any activities that address servicing criteria with respect to theissuing entity and because it is not a “servicer” that meets the criteria inItem 1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.**

[Reserved].

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

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

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

 

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

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

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

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

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

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

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

**Item 1119 of Regulation AB, Affiliations and Certain Relationshipsand 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).

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

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

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

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

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

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

4.1          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 Asset RepresentationsReviewer (filed as Exhibit 4.1 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).

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. 333-226486-16 andincorporated 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, asCustodian

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

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

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 (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 (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 Operating Advisorof 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 (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 (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

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

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 (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 (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 (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 Operating Advisorof 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 (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

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 16, 2023