**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 SECURITIES EXCHANGE ACT OF 1934**

**For the fiscalyear ended December 31, 2019or**

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

**For the transitionperiod from _____ to _____Commission file number of the issuing entity: 333-206677-01**

**Central Index KeyNumber of the issuing entity: 0001659329**

**Wells Fargo Commercial Mortgage Trust 2015-P2**

**(exact name of theissuing entity as specified in its charter)**

** **

**Central Index KeyNumber of the depositor: 0000850779**

**Wells Fargo Commercial Mortgage Securities, Inc.**

**(exact name of thedepositor as specified in its charter)**

** **

**Central Index KeyNumber of the sponsor: 0000740906**

**Wells Fargo Bank, National Association**

**(exact name of thesponsor as specified in its charter)**

** **

**Central Index KeyNumber of the sponsor: 0001634437**

**Macquarie US Trading LLC**

**(exact name of thesponsor as specified in its charter)**

**d/b/a Principal Commercial Capital**

** **

**Central Index KeyNumber of the sponsor: 0001541468**

**Ladder Capital Finance LLC**

**(exact name of thesponsor as specified in its charter)**

** **

**Central Index KeyNumber of the sponsor: 0001541001**

**Citigroup Global Markets Realty Corp.**

**(exact name of thesponsor as specified in its charter)**

** **

**Central Index KeyNumber of the sponsor: 0001238163**

**Société Générale**

**(exact name of thesponsor as specified in its charter)**

** **

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

**the issuing entity)** | **38-3984627**

**38-3984628**

**38-7143660**

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

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

**c/o Wells Fargo Bank, National Association**

**as CertificateAdministrator**

**9062 Old AnnapolisRoad**

**Columbia, MD**

**(Address of principal executive offices of the issuingentity)**

**21045**

**(Zip Code)**

**Registrant’stelephone number, including area code:**

**(704) 374-6161**

Securities registered pursuant toSection 12(b) of the Act:

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

Securities registered pursuant toSection 12(g) of the Act:  None.

Indicate by check mark if theregistrant is a well-known seasoned issuer, as defined in Rule 405 of theSecurities Act.  o Yes ⌧ No

Indicate by check mark if theregistrant is not required to file reports pursuant to Section 13 or Section15(d) of the Act.  o Yes ⌧ No

Indicate by check mark whether theregistrant (1) has filed all reports required to be filed by Section 13 or15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (orfor such shorter period that the registrant was required to file such reports),and (2) has been subject to such filing requirements for the past 90days.  ⌧ Yes oNo

Indicate by check mark whether theregistrant has submitted electronically and posted on its corporate Web site,if any, every Interactive Data File required to be submitted and postedpursuant to Rule 405 of Regulation S-T (Section 232.405 of this chapter) duringthe preceding 12 months (or for such shorter period that the registrant wasrequired to submit and post such files).

Notapplicable.

Indicate by check mark ifdisclosure of delinquent filers pursuant to Item 405 of Regulation S-K (Section229.405 of this chapter) is not contained herein, and will not be contained, tothe best of registrant’s knowledge, in definitive proxy or informationstatements incorporated by reference in Part III of this Form 10-K or anyamendment to this Form 10-K.   

Notapplicable.

Indicate by check mark whether theregistrant is a large accelerated filer, an accelerated filer, anon-accelerated filer, a smaller reporting company, or an emerging growthcompany. See the definitions of “large accelerated filer,” “accelerated filer,”“smaller reporting company,” and “emerging growth company” in Rule 12b-2 of theExchange 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 the registrant has elected not to use the extendedtransition period for complying with any new or revised financial accountingstandards provided pursuant to Section 13(a) of the Exchange Act.  o

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

State the aggregate market valueof the voting and non-voting common equity held by non-affiliates computed byreference to the price at which the common equity was last sold, or the averagebid and asked price of such common equity, as of the last business day of theregistrant’s most recently completed second fiscal quarter.

Notapplicable.

Indicate by check mark whether theregistrant has filed all documents and reports required to be filed by Section12, 13 or 15(d) of the Securities Exchange Act of 1934 subsequent to thedistribution of securities under a plan confirmed by a court.  o Yes oNo

Notapplicable.

Indicate the number of sharesoutstanding of each of the registrant’s classes of common stock, as of thelatest practicable date.

Notapplicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the followingdocuments if incorporated by reference and the Part of the Form 10-K (e.g.,Part I, Part II, etc.) into which the document is incorporated: (1) Any annualreport to security holders; (2) Any proxy or information statement; and (3) Anyprospectus filed pursuant to Rule 424(b) or (c) under the Securities Act of1933. The listed documents should be clearly described for identificationpurposes (e.g., annual report to security holders for fiscal year endedDecember 24, 1980).

Notapplicable.

 

** **

**EXPLANATORY NOTES**

The Heritage Industrial Portfolio Mortgage Loan, whichconstituted approximately 4.1% of the asset pool of the issuing entity as ofits cut-off date, is an asset of the issuing entity and is part of a loancombination that includes the Heritage Industrial Portfolio Mortgage Loan whichis an asset of the issuing entity and one other *pari passu* loan, whichis not an asset of the issuing entity. This loan combination, including theHeritage Industrial Portfolio Mortgage Loan, is 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 Harvey Building Products Portfolio MortgageLoan, which constituted approximately 3.3% of the asset pool of the issuingentity as of its cut-off date.  The Harvey Building Products Portfolio MortgageLoan is an asset of the issuing entity and is part of a loan combination thatincludes the Harvey Building Products Portfolio Mortgage Loan and three other *paripassu* loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the COMM 2015-LC23 MortgageTrust transaction, Commission File Number 333-193376-25 (the “COMM 2015-LC23Transaction”). This loan combination, including the Harvey BuildingProducts Portfolio Mortgage Loan, is being serviced and administered pursuantto the pooling and servicing agreement for the COMM 2015-LC23 Transaction,which is incorporated by reference as Exhibit 4.2 to this Annual Report on Form10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Harbor Pointe Apartments Mortgage Loan, theAnchorage Marriott Downtown Mortgage Loan and the JW Marriott Santa Monica LeMerigot Mortgage Loan, which constituted approximately 5.0%, 3.8% and 3.1%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Harbor Pointe Apartments Mortgage Loan, the Anchorage MarriottDowntown Mortgage Loan and the JW Marriott Santa Monica Le Merigot MortgageLoan are each an asset of the issuing entity and are each part of a loancombination that includes the Harbor Pointe Apartments Mortgage Loan, theAnchorage Marriott Downtown Mortgage Loan or the JW Marriott Santa Monica LeMerigot Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. The other *pari passu* portion of each loancombination was securitized in the Citigroup Commercial Mortgage Trust2015-GC35 transaction, Commission File Number 333-189017-12 (the “CGCMT2015-GC35 Transaction”). These loan combinations, including the HarborPointe Apartments Mortgage Loan, the Anchorage Marriott Downtown Mortgage Loanand the JW Marriott Santa Monica Le Merigot Mortgage Loan, are being servicedand administered pursuant to the pooling and servicing agreement for the CGCMT2015-GC35 Transaction, which is incorporated by reference as Exhibit 4.3 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Empire Mall Mortgage Loan, which constitutedapproximately 7.5% of the asset pool of the issuing entity as of its cut-offdate.  The Empire Mall Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Empire Mall Mortgage Loan andfour other *pari passu* loans, which are not assets of the issuingentity.This loan combination, including the Empire Mall Mortgage Loan, wasserviced under the Pooling and Servicing Agreement for the issuing entity priorto the closing of the securitization of a *pari passu* portion of theEmpire Mall loan combination in the Citigroup Commercial Mortgage Trust 2016-P3transaction, Commission File Number 333-207132-02 (the “CGCMT 2016-P3Transaction”).  After the closing of the CGCMT 2016-P3 Transaction onApril 13, 2016, this loan combination, including the Empire Mall Mortgage Loanwas, and will continue to be, serviced and administered pursuant to the poolingand servicing agreement with respect to the CGCMT 2016-P3 Transaction, which isincorporated by reference as Exhibit 4.4 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 such agreementalso encompasses its responsibilities as primary servicer of the relatedmortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the Empire Mall Mortgage Loan and the Harvey BuildingProducts Portfolio Mortgage Loan. As a result, Wells Fargo Bank, NationalAssociation is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB,in the capacities 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.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement and the Harvey Building Products Portfolio MortgageLoan.  As a result, Wells Fargo Bank, National Association is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Wells Fargo Bank,National Association in the capacities described above are listed in theExhibit Index.

C-III Asset Management LLC was thespecial servicer of the mortgage loans serviced under the Pooling and ServicingAgreement prior to May 31, 2019, and is the special servicer of the Empire MallMortgage Loan, the Harbor Pointe Apartments Mortgage Loan, the AnchorageMarriott Downtown Mortgage Loan and the JW Marriott Santa Monica Le MerigotMortgage Loan. As a result, C-III Asset Management LLC is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by C-III Asset Management LLC inthe capacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC isthe operating advisor of the Empire Mall Mortgage Loan, the Harbor PointeApartments Mortgage Loan, the Anchorage Marriott Downtown Mortgage Loan, theHarvey Building Products Portfolio Mortgage Loan and the JW Marriott SantaMonica Le Merigot Mortgage Loan.  As a result, Park Bridge Lender ServicesLLC is a servicing function participant in the capacities described above,because it is servicing mortgage loans that constituted 5% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Park Bridge Lender Services LLC in the capacitiesdescribed above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer of the Harbor Pointe ApartmentsMortgage Loan, the Anchorage Marriott Downtown Mortgage Loan and the JWMarriott Santa Monica Le Merigot Mortgage Loan. As a result, Midland LoanServices, a Division of PNC Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Midland Loan Services, aDivision of PNC Bank, National Association in the capacities described aboveare listed in the Exhibit Index.

Deutsche Bank Trust CompanyAmericas is the custodian of the Harbor Pointe Apartments Mortgage Loan, theAnchorage Marriott Downtown Mortgage Loan and the JW Marriott Santa Monica LeMerigot Mortgage Loan.  As a result, Deutsche Bank Trust Company Americasis a servicing function participant in the capacities described above, becauseit is servicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byDeutsche Bank Trust Company Americas in the capacities described above arelisted in the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the Harvey Building Products Portfolio Mortgage Loanand the Empire Mall Mortgage Loan.  Pursuant to the Pooling and ServicingAgreement, the pooling and servicing agreement for the COMM 2015-LC23Transaction and the pooling and servicing agreement for the CGCMT 2016-P3Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountants’attestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theHarvey Building Products Portfolio Mortgage Loan and the Empire Mall MortgageLoan have delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer under the Pooling and Servicing Agreement (except withrespect to those mortgage loans for which Principal Real Estate Investors, LLCis the primary servicer)  and the primary servicer of the Harvey BuildingProducts Portfolio Mortgage Loan and the Empire Mall Mortgage Loan to remit taxpayments received from the escrow accounts of borrowers to local taxingauthorities, to report tax amounts due, to verify tax parcel information, andto verify non-escrow tax payments. These servicing functions are includedwithin the servicing criteria set forth in Items 1122(d)(4)(xi) and1122(d)(4)(xii) of Regulation AB.  Therefore, under the principles-baseddefinition of “servicer” set forth in Item 1101(j) of Regulation AB that looksto the functions that an entity performs, these vendors are “servicers” for thepurposes of Item 1122 of Regulation AB.  *See* Compliance andDisclosure Interpretations, Section 301.01 (Item 1101(j)).

This AnnualReport on Form 10-K includes an assessment of compliance with applicableservicing criteria and an accountant’s attestation report from U.S. Bank,National Association. This entity was engaged by Citibank, N.A. as custodian ofthe Empire Mall Mortgage Loan to perform certain custodial services. Thesecustodial services are servicing functions included within the servicingcriteria set forth in Items 1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation AB.Therefore, under the principles-based definition of “servicer” set forth inItem 1101(j) or Regulation AB that looks to the functions that an entityperforms, this vendor is a “servicer” for the purposes of Item 1122 ofRegulation AB. See Compliance and Disclosure Interpretations, Section 301.01(Item 1101(j)).

The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements of the certificate administrator of the Harvey BuildingProducts Portfolio Mortgage Loan, the Harbor Pointe Apartments Mortgage Loan,the JW Marriott Santa Monica Le Merigot Mortgage Loan, the Anchorage MarriottDowntown Mortgage Loan and the Empire Mall Mortgage Loan listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu*loan combination that includes the Harvey Building Products Portfolio MortgageLoan, (i) the report on assessment of compliance with servicing criteria andattestation report on assessment of compliance with servicing criteria of LNRPartners, LLC as special servicer of the Harvey Building Products PortfolioMortgage Loan, listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as they are not required to be included on this Annual Report onForm 10-K per Instruction 3 to Item 1122 of Regulation AB because it is a partyperforming activities that address servicing criteria relating to 5% or less ofthe assets of the issuing entity; and (ii) the servicer compliance statement ofLNR Partners, LLC as special servicer of the Harvey Building Products PortfolioMortgage Loan, listed on the Exhibit Index is omitted from this Annual Reporton Form 10-K as it is not required by Item 1123 of Regulation AB to be includedon this Annual Report on Form 10-K because it is an unaffiliated party that isnot a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation 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 nomaterial pending legal proceeding involving the trust or any party related tothe trust, other than routine litigation incidental to the duties of thoserespective parties, and the following, with respect to Citibank N.A., ascustodian, Deutsche Bank Trust Company Americas, as trustee, and Wells FargoBank, National Association, as certificate administrator and as custodian. 

In the ordinary course of business, Citibank is involved in anumber of legal proceedings, including in connection with its role as trusteeof certain RMBS transactions.  Certain of these Citibank astrustee-related matters are disclosed herein. 

On June 18, 2014, a civil action was filed against Citibankin the Supreme Court of the State of New York by a group of investors in 48private-label RMBS trusts for which Citibank allegedly serves or did serve astrustee, asserting claims for purported violations of the Trust Indenture Actof 1939 (the “Trust Indenture Act”), breach of contract, breach offiduciary duty and negligence based on Citibank’s alleged failure to performits duties as trustee for the 48 RMBS trusts.  On November 24, 2014,plaintiffs sought leave to withdraw this action.  On the same day, a smallersubset of similar plaintiff investors in 27 private-label RMBS trusts for whichCitibank allegedly serves or did serve as trustee, filed a new civil actionagainst Citibank in the United States District Court for the Southern Districtof New York asserting similar claims as the prior action filed in statecourt.  In January 2015, the court closed plaintiffs’ original state courtaction.  On September 8, 2015, the federal court dismissed all claims asto 24 of the 27 trusts and allowed certain of the claims to proceed as to theother three trusts. Subsequently, plaintiffs voluntarily dismissed all claimswith respect to two of the three trusts. On April 7, 2017, Citibank filed amotion for summary judgment. Plaintiffs filed its consolidated opposition briefand cross motion for partial summary judgment on May 22, 2017.  Briefingon those motions was completed on August 4, 2017. On March 22, 2018, the courtgranted Citibank’s motion for summary judgment in its entirety, deniedPlaintiffs’ motion for summary judgment and ordered the clerk to close thecase. On April 20, 2018, plaintiffs filed a notice of appeal. Plaintiffs’opening brief was filed on August 3, 2018. Citibank filed its opposition onNovember 2, 2018.  Plaintiffs’ filed their reply on November 16,2018.  On June 7, 2019, the Second Circuit dismissed plaintiffs’ appealfollowing the parties’ filing of a stipulation withdrawing the case withprejudice pursuant to Federal Rule of Appellate Procedure 42.

On November 24, 2015, the same investors that brought thefederal case brought a new civil action in the Supreme Court of the State ofNew York related to 25 private-label RMBS trusts for which Citibank allegedlyserves or did serve as trustee.  This case includes the 24 trustspreviously dismissed in the federal action, and one additional trust.  Theinvestors assert claims for breach of contract, breach of fiduciary duty,breach of duty to avoid conflicts of interest, and violation of New York’sStreit Act (the “Streit Act”).  Following oral argument on Citibank’smotion to dismiss, Plaintiffs filed an amended complaint on August 5,2016.  On June 27, 2017, the state court issued a decision, dismissing theEvent of Default claims, mortgage-file-related claims, the fiduciary dutyclaims, and the conflict of interest claims.  The decision sustainedcertain breach of contract claims including the claim alleging discovery ofbreaches of representations and warranties, a claim related to robo-signing,and the implied covenant of good faith claim.  Citibank appealed the lowercourt’s decision, and on January 16, 2018, the Appellate Division, FirstDepartment, dismissed the claims related to robo-signing and the impliedcovenant of good faith, but allowed plaintiffs’ claim alleging discovery ofbreaches of representations and warranties to proceed.  On June 7, 2019,plaintiffs filed a motion for discontinuance of the action and dismissal ofplaintiffs’ claims with prejudice.

On August 19, 2015, the Federal Deposit Insurance Corporation(“FDIC”) as Receiver for a failed financial institution filed a civilaction against Citibank in the Southern District of New York.  This actionrelates to one private-label RMBS trust for which Citibank formerly served astrustee.  FDIC asserts claims for breach of contract, violation of theStreit Act, and violation of the Trust Indenture Act. Citibank jointly briefeda motion to dismiss with The Bank of New York Mellon and U.S. Bank, N.A.,entities that have also been sued by FDIC in their capacity as trustee, andthese cases have all been consolidated in front of Judge Carter.  OnSeptember 30, 2016, the Court granted the motion to dismiss without prejudicefor lack of subject matter jurisdiction.  On October 14, 2016, FDIC fileda motion for reargument or relief from judgment from the Court’s dismissalorder.  On July 11, 2017, Judge Carter ruled on the motion forreconsideration regarding his dismissal of the action.  He deniedreconsideration of his decision on standing, but granted leave to amend thecomplaint by October 9, 2017.  The FDIC subsequently requested anextension of time to file its amended complaint, which was granted. The FDICfiled its amended complaint on December 8, 2017. Defendants’ jointly filed amotion to dismiss the amended complaint and that joint motion was fully briefedas of May 3, 2018.  On March 20, 2019, the Court granted Defendants’ jointmotion to dismiss the amended complaint. The FDIC's deadline to file a noticeof appeal was April 22, 2019. The FDIC has not appealed. 

There can be no assurances as to the outcome of litigation orthe possible impact of litigation on the trustee or the RMBS trusts. However, Citibank denies liability and continues to vigorously defend againstthese litigations.  Furthermore, neither the above-disclosed litigationsnor any other pending legal proceeding involving Citibank will materiallyaffect Citibank’s ability to perform its duties under the related servicingagreement for this CMBS transaction.

 

Deutsche Bank Trust Company Americas (“DBTCA”) andDeutsche Bank National Trust Company (“DBNTC”) have been sued byinvestors in civil litigation concerning their role as trustees of certain RMBStrusts. 

 

On June 18, 2014, a group of investors, including fundsmanaged by Blackrock Advisors, LLC, PIMCO-Advisors, L.P., and others, filed anaction against DBNTC and DBTCA in New York State Supreme Court alleging thatDBNTC and DBTCA failed to perform purported duties, as trustees for 544private-label RMBS trusts, to enforce breaches of representations andwarranties as to mortgage loans held by the trusts and to enforce breaches byservicers of their mortgage loan servicing obligations for the trusts. During the course of the litigation, plaintiffs dismissed the case from NewYork State Supreme Court and refiled two separate cases, one in the U.S.District Court for the Southern District of New York (the “*BlackRock*SDNYCase”) and the other in the Superior Court of California, Orange County(the “*BlackRock*California Case”).  Pursuant to asettlement among the parties, the *BlackRock*SDNY Case was dismissed onDecember 6, 2018 and the *BlackRock*California Case was dismissed onJanuary 11, 2019.

 

On September 27, 2017, DBTCA was added as a defendant to acase brought by certain special purpose entities including Phoenix Light SFLimited in the U.S. District Court for the Southern District of New York, inwhich the plaintiffs previously alleged incorrectly that DBNTC served astrustee for all 43 of the trusts at issue.  On September 27, 2017,plaintiffs filed a third amended complaint that names DBTCA as a defendant inaddition to DBNTC.  DBTCA serves as trustee for one of the 43 trusts atissue.  DBNTC serves as trustee for the other 42 trusts at issue. Plaintiffs’ third amended complaint brings claims for violation of the U.S.Trust Indenture Act of 1939 (“TIA”); breach of contract; breach offiduciary duty; negligence and gross negligence; violation of New York’s StreitAct; and breach of the covenant of good faith.  However, in the thirdamended complaint, plaintiffs acknowledge that, before DBTCA was added to thecase, the court dismissed plaintiffs’ TIA Act claims, negligence and grossnegligence claims, Streit Act claims, claims for breach of the covenant of goodfaith, and certain theories of plaintiffs’ breach of contract claims, andplaintiffs only include these claims to preserve any rights on appeal. Plaintiffs allege damages of “hundreds of millions of dollars.”  OnNovember 13, 2017, DBNTC and DBTCA filed an answer to the third amendedcomplaint.  On December 7, 2018, DBNTC and DBTCA filed a motion forsummary judgment.  Also on December 7, 2018, plaintiffs, jointly withCommerzbank AG (*see* description of *Commerzbank* case below), fileda motion for partial summary judgment.  As of March 1, 2020, both motionsfor summary judgment have been briefed and are awaiting decision by the court.

 

On November 30, 2017, DBTCA was added as a defendant to acase brought by Commerzbank AG (“Commerzbank”) in the U.S. DistrictCourt for the Southern District of New York, in which Commerzbank previouslyalleged incorrectly that DBNTC served as trustee for all 50 of the trusts atissue.  On November 30, 2017, Commerzbank filed a second amended complaintthat names DBTCA as a defendant in addition to DBNTC.  DBTCA serves as trusteefor 1 of the 50 trusts at issue.  DBNTC serves as trustee for the other 49trusts at issue.  Commerzbank’s second amended complaint brings claims forviolation of the TIA; breach of contract; breach of fiduciary duty; negligence;violation of the Streit Act; and breach of the covenant of good faith. However, in the second amended complaint, Commerzbank acknowledges that, beforeDBTCA was added to the case, the court dismissed Commerzbank’s TIA claims forthe trusts governed by pooling and servicing agreements, as well as its StreitAct claims and claims for breach of the covenant of good faith, and Commerzbankonly includes these claims to preserve any rights on appeal.  The secondamended complaint alleges that DBNTC and DBTCA caused Commerzbank to suffer“hundreds of millions of dollars in losses,” but the complaint does not includea demand for money damages in a sum certain.  On January 29, 2018, DBNTCand DBTCA filed an answer to the second amended complaint.  On December 7,2018, DBNTC and DBTCA filed a motion for summary judgment.  Also onDecember 7, 2018, Commerzbank, jointly with the *Phoenix Light*plaintiffs,filed a motion for partial summary judgment.  As of March 1, 2020, bothmotions for summary judgment have been briefed and are awaiting decision by thecourt.

 

 

On December 30, 2015, IKB International, S.A. in Liquidationand IKB Deutsche Industriebank A.G. (collectively, “IKB”), as aninvestor in 37 RMBS trusts, filed a summons with notice in the Supreme Court ofthe State of New York, New York County, against DBNTC and DBTCA as trustees ofthe trusts.  On May 27, 2016, IKB served its complaint asserting claimsfor breach of contract, breach of fiduciary duty, breach of duty to avoidconflicts of interest, violation of the Streit Act, violation of the TIA,violation of Regulation AB, and violation of Section 9 of the UniformCommercial Code.  IKB alleges that DBNTC and DBTCA are liable for overU.S. $268 million in damages.  On October 5, 2016, DBNTC and DBTCA,together with several other trustees defending lawsuits by IKB, filed a jointmotion to dismiss.  On January 6, 2017 and June 20, 2017, IKB voluntarilydismissed with prejudice all claims as to seven trusts.  As of March 1,2020, DBNTC and DBTCA’s motion to dismiss has been briefed and is awaitingdecision by the court.

It is DBTCA’s belief that it has nopending legal proceedings (including, based on DBTCA’s present evaluation, thelitigation disclosed in the foregoing paragraphs) that would materially affectits ability to perform its duties under the related servicing agreement forthis transaction.

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts atissue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the RMBStrusts.

**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 December 23, 2015 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 Harvey Building ProductsPortfolio Mortgage Loan, which is being serviced and administered pursuant tothe pooling and servicing agreement for the COMM 2015-LC23 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asSchedule II to the pooling and servicing agreement for the COMM 2015-LC23Transaction incorporated by reference as Exhibit 4.2 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the COMM 2015-LC23 Transaction responsible for each applicableservicing 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 Harbor Pointe Apartments MortgageLoan, the Anchorage Marriott Downtown Mortgage Loan and the JW Marriott SantaMonica Le Merigot Mortgage Loan, which are being serviced and administeredpursuant to the pooling and servicing agreement for the CGCMT 2015-GC35Transaction, are attached hereto under Item 15 to this Annual Report on Form10-K. Attached as Exhibit O to the pooling and servicing agreement for theCGCMT 2015-GC35 Transaction incorporated by reference as Exhibit 4.3 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the CGCMT 2015-GC35 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 Empire Mall Mortgage Loan, whichis being serviced and administered pursuant to the pooling and servicingagreement for the CGCMT 2016-P3 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit O to the pooling andservicing agreement for the CGCMT 2016-P3 Transaction incorporated by referenceas Exhibit 4.4 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the CGCMT 2016-P3Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The report on assessment of compliance with applicableservicing criteria furnished pursuant to Item 1122 of Regulation AB by MidlandLoan Services, a Division of PNC Bank National Association (“Midland”)discloses that a material instance of noncompliance occurred, as describedbelow:

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements andapplicable Commission requirements. Specifically, such reports: (A) Areprepared in accordance with timeframes and other terms set forth in thetransaction agreements”.  The noncompliance consisted of omitted orinaccurately reported fields as described in (1) and (2) below.  (1) Inconnection with other enhancements Midland made to its manual Schedule ALprocess, starting in April 2019, Midland developed and implemented new ScheduleAL reporting templates for each applicable CMBS transaction that closed priorto April 2019 and for each applicable CMBS transaction going forward. Related to this, Midland made certain template setup errors, along with relatedand other manual inputting of information errors, and the errors were notidentified prior to submission of the applicable Schedule AL Files in certaincases due to breakdowns in quality control.  (2) In one applicabletransaction, the related Schedule AL File for a given month was not savedproperly resulting in the prior month's Schedule AL File being submitted forthe given month instead of the correct Schedule AL File. 

The identified instances did notinvolve the servicing of assets included in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reportingprocess was enhanced in April of 2019, however, the process remained manualthroughout the 2019 calendar year.  Errors relating to certain Schedule ALFiles during 2019 were identified during the related audit.  Followingidentification, Midland made staffing changes and additional enhancements andimprovements to its processes and procedures to support its Schedule ALreporting obligations and expects to move to an automated solution for thisprocess.  

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to beincorrect. 

**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 December 1, 2015, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, C-III Asset Management LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and Asset Representations Reviewer (filed as Exhibit4.1 to the registrant’s Current Report on Form 8-K/A filed on January 6, 2016 underCommission File No. 333-206677-01 and incorporated by reference herein).

4.2          Poolingand Servicing Agreement, dated as of November 1, 2015, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, Wells Fargo Bank,National Association, as Master Servicer, LNR Partners, LLC, as SpecialServicer, Park Bridge Lender Services LLC, as Operating Advisor, WilmingtonTrust, National Association, as Trustee, and Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Paying Agent and Custodian (filed asExhibit 4.1 to the registrant’s Current Report on Form 8-K/A filed on January15, 2016 under Commission File No. 333-206677-01 and incorporated by referenceherein).

4.3          Poolingand Servicing Agreement, dated as of December 1, 2015, by and among CitigroupCommercial Mortgage Securities Inc., as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, C-III AssetManagement LLC, as Special Servicer, Park Bridge Lender Services LLC, asOperating Advisor, Deutsche Bank Trust Company Americas, as Trustee, andCitibank, N.A., as Certificate Administrator (filed as Exhibit 4.2 to theregistrant’s Current Report on Form 8-K filed on December 23, 2015 underCommission File No. 333-206677-01 and incorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of April 1, 2016, by and among CitigroupCommercial Mortgage Securities Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, C-III Asset Management LLC, as SpecialServicer, Park Bridge Lender Services LLC, as Operating Advisor and AssetRepresentations Reviewer, Wilmington Trust, National Association, as Trustee,and Citibank, N.A., as Certificate Administrator (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K filed on April 15, 2016 underCommission File No. 333-206677-01 and incorporated by reference herein).

4.5          Co-LenderAgreement, dated as of December 1, 2015, by and between Citigroup GlobalMarkets Realty Corp., as Initial Note A-1 Holder, and Citigroup Global MarketsRealty Corp., as Initial Note A-2 Holder (filed as Exhibit 4.4 to theregistrant’s Current Report on Form 8-K filed on December 23, 2015 underCommission File No. 333-206677-01 and incorporated by reference herein).

4.6          Co-LenderAgreement, dated as of December 1, 2015, by and between Citigroup GlobalMarkets Realty Corp., as Initial Note A-1 Holder, and Citigroup Global MarketsRealty Corp., as Initial Note A-2 Holder (filed as Exhibit 4.5 to theregistrant’s Current Report on Form 8-K filed on December 23, 2015 underCommission File No. 333-206677-01 and incorporated by reference herein).

4.7          Co-LenderAgreement, dated as of November 17, 2015, between Ladder Capital Finance IIILLC – Series 98 - Harvey Portfolio, as Note A-1 Holder, Ladder Capital FinanceIII LLC – Series 98 - Harvey Portfolio, as Note A-2A Holder, Ladder CapitalFinance III LLC – Series 98 - Harvey Portfolio, as Note A-2B Holder, and LadderCapital Finance III LLC – Series 98 - Harvey Portfolio, as Note A-3 Holder(filed as Exhibit 4.6 to the registrant’s Current Report on Form 8-K filed onDecember 23, 2015 under Commission File No. 333-206677-01 and incorporated byreference herein).

4.8          Co-LenderAgreement, dated as of December 1, 2015, by and between Citigroup GlobalMarkets Realty Corp., as Initial Note A-1 Holder, and Citigroup Global MarketsRealty Corp., as Initial Note A-2 Holder (filed as Exhibit 4.7 to the registrant’sCurrent Report on Form 8-K filed on December 23, 2015 under Commission File No.333-206677-01 and incorporated by reference herein).

4.9          Co-LenderAgreement, dated as of December 23, 2015, by and between Société Générale, asInitial Note A-1 Holder, Société Générale, as Initial Note A-2 Holder, SociétéGénérale, as Initial Note A-3 Holder, Société Générale, as Initial Note A-4Holder, Société Générale, as Initial Note A-5 Holder (filed as Exhibit 4.8 tothe registrant’s Current Report on Form 8-K filed on December 23, 2015 underCommission File No. 333-206677-01 and incorporated by reference herein).

4.10        Co-LenderAgreement, dated as of December 14, 2015, by and between Macquarie US TradingLLC d/b/a Principal Commercial Capital, as Initial Note A-1 Holder, MacquarieUS Trading LLC d/b/a Principal Commercial Capital, as Initial Note A-2 Holder(filed as Exhibit 4.9 to the registrant’s Current Report on Form 8-K filed onDecember 23, 2015 under Commission File No. 333-206677-01 and incorporated byreference 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, NationalAssociation, as Master Servicer

33.2        C-III Asset ManagementLLC, as Special Servicer prior to May 31, 2019

33.3        Rialto Capital Advisors,LLC, as Special Servicer on and after May 31, 2019

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

33.5        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.6        Wells Fargo Bank, NationalAssociation, as Custodian

33.7        Pentalpha SurveillanceLLC, as Operating Advisor

33.8        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

33.9        National Tax Search, LLC,as Servicing Function Participant

33.10      Principal Real EstateInvestors, LLC, as Primary Servicer

33.11      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Heritage Industrial Portfolio MortgageLoan (see Exhibit 33.1)

33.12      C-III Asset ManagementLLC, as Special Servicer of the Heritage Industrial Portfolio Mortgage Loanprior to May 31, 2019 (see Exhibit 33.2)

33.13      Rialto Capital Advisors,LLC, as Special Servicer of the Heritage Industrial Portfolio Mortgage Loan on andafter May 31, 2019 (see Exhibit 33.3)

33.14      Wilmington Trust, National Association, as Trustee of the Heritage IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.15      Wells Fargo Bank, NationalAssociation, as Custodian of the Heritage Industrial Portfolio Mortgage Loan(see Exhibit 33.6)

33.16      Pentalpha SurveillanceLLC, as Operating Advisor of the Heritage Industrial Portfolio Mortgage Loan(see Exhibit 33.7)

33.17      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the HeritageIndustrial Portfolio Mortgage Loan (see Exhibit 33.8)

33.18      National Tax Search, LLC,as Servicing Function Participant of the Heritage Industrial Portfolio MortgageLoan (see Exhibit 33.9)

33.19      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Harvey Building Products PortfolioMortgage Loan (see Exhibit 33.1)

33.20      LNR Partners, LLC, as Special Servicer of the Harvey Building ProductsPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.21      Wilmington Trust, National Association, as Trustee of the Harvey BuildingProducts Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.22      Wells Fargo Bank, NationalAssociation, as Custodian of the Harvey Building Products Portfolio MortgageLoan (see Exhibit 33.6)

33.23      Park Bridge LenderServices LLC, as Operating Advisor of the Harvey Building Products PortfolioMortgage Loan

33.24      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Harvey BuildingProducts Portfolio Mortgage Loan (see Exhibit 33.8)

33.25      National Tax Search, LLC,as Servicing Function Participant of the Harvey Building Products PortfolioMortgage Loan (see Exhibit 33.9)

33.26      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the HarborPointe Apartments Mortgage Loan

33.27      C-III Asset ManagementLLC, as Special Servicer of the Harbor Pointe Apartments Mortgage Loan (seeExhibit 33.2)

33.28      Deutsche Bank TrustCompany Americas, as Trustee and Custodian of the Harbor Pointe ApartmentsMortgage Loan

33.29      Park Bridge LenderServices LLC, as Operating Advisor of the Harbor Pointe Apartments MortgageLoan (see Exhibit 33.23)

33.30      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theAnchorage Marriott Downtown Mortgage Loan (see Exhibit 33.26)

33.31      C-III Asset ManagementLLC, as Special Servicer of the Anchorage Marriott Downtown Mortgage Loan (seeExhibit 33.2)

33.32      Deutsche Bank TrustCompany Americas, as Trustee and Custodian of the Anchorage Marriott DowntownMortgage Loan (see Exhibit 33.28)

33.33      Park Bridge LenderServices LLC, as Operating Advisor of the Anchorage Marriott Downtown MortgageLoan (see Exhibit 33.23)

33.34      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the JWMarriott Santa Monica Le Merigot Mortgage Loan (see Exhibit 33.26)

33.35      C-III Asset ManagementLLC, as Special Servicer of the JW Marriott Santa Monica Le Merigot MortgageLoan (see Exhibit 33.2)

33.36      Deutsche Bank TrustCompany Americas, as Trustee and Custodian of the JW Marriott Santa Monica LeMerigot Mortgage Loan (see Exhibit 33.28)

33.37      Park Bridge LenderServices LLC, as Operating Advisor of the JW Marriott Santa Monica Le MerigotMortgage Loan (see Exhibit 33.23)

33.38      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Empire Mall Mortgage Loan (see Exhibit33.1)

33.39      C-III Asset ManagementLLC, as Special Servicer of the Empire Mall Mortgage Loan (see Exhibit 33.2)

33.40      Wilmington Trust, National Association, as Trustee of the Empire Mall MortgageLoan (Omitted. See Explanatory Notes.)

33.41      Citibank, N.A., asCustodian of the Empire Mall Mortgage Loan

33.42      Park Bridge LenderServices LLC, as Operating Advisor of the Empire Mall Mortgage Loan (seeExhibit 33.23)

33.43      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Empire MallMortgage Loan (see Exhibit 33.8)

33.44      National Tax Search, LLC,as Servicing Function Participant of the Empire Mall Mortgage Loan (see Exhibit33.9)

33.45      U.S. Bank National Association,as Servicing Function Participant of the Empire Mall Mortgage Loan

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

34.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2        C-III Asset ManagementLLC, as Special Servicer prior to May 31, 2019

34.3        Rialto Capital Advisors,LLC, as Special Servicer on and after May 31, 2019

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

34.5        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.6        Wells Fargo Bank, NationalAssociation, as Custodian

34.7        Pentalpha SurveillanceLLC, as Operating Advisor

34.8        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

34.9        National Tax Search, LLC,as Servicing Function Participant

34.10      Principal Real EstateInvestors, LLC, as Primary Servicer

34.11      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Heritage Industrial Portfolio MortgageLoan (see Exhibit 34.1)

34.12      C-III Asset ManagementLLC, as Special Servicer of the Heritage Industrial Portfolio Mortgage Loanprior to May 31, 2019 (see Exhibit 34.2)

34.13      Rialto Capital Advisors,LLC, as Special Servicer of the Heritage Industrial Portfolio Mortgage Loan onand after May 31, 2019 (see Exhibit 34.3)

34.14      Wilmington Trust, National Association, as Trustee of the Heritage IndustrialPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.15      Wells Fargo Bank, NationalAssociation, as Custodian of the Heritage Industrial Portfolio Mortgage Loan(see Exhibit 34.6)

34.16      Pentalpha SurveillanceLLC, as Operating Advisor of the Heritage Industrial Portfolio Mortgage Loan(see Exhibit 34.7)

34.17      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the HeritageIndustrial Portfolio Mortgage Loan (see Exhibit 34.8)

34.18      National Tax Search, LLC,as Servicing Function Participant of the Heritage Industrial Portfolio MortgageLoan (see Exhibit 34.9)

34.19      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Harvey Building Products PortfolioMortgage Loan (see Exhibit 34.1)

34.20      LNR Partners, LLC, as Special Servicer of the Harvey Building ProductsPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.21      Wilmington Trust, National Association, as Trustee of the Harvey BuildingProducts Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.22      Wells Fargo Bank, NationalAssociation, as Custodian of the Harvey Building Products Portfolio MortgageLoan (see Exhibit 34.6)

34.23      Park Bridge LenderServices LLC, as Operating Advisor of the Harvey Building Products PortfolioMortgage Loan

34.24      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Harvey BuildingProducts Portfolio Mortgage Loan (see Exhibit 34.8)

34.25      National Tax Search, LLC, asServicing Function Participant of the Harvey Building Products PortfolioMortgage Loan (see Exhibit 34.9)

34.26      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the HarborPointe Apartments Mortgage Loan

34.27      C-III Asset ManagementLLC, as Special Servicer of the Harbor Pointe Apartments Mortgage Loan (seeExhibit 34.2)

34.28      Deutsche Bank TrustCompany Americas, as Trustee and Custodian of the Harbor Pointe ApartmentsMortgage Loan

34.29      Park Bridge LenderServices LLC, as Operating Advisor of the Harbor Pointe Apartments MortgageLoan (see Exhibit 34.23)

34.30      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theAnchorage Marriott Downtown Mortgage Loan (see Exhibit 34.26)

34.31      C-III Asset ManagementLLC, as Special Servicer of the Anchorage Marriott Downtown Mortgage Loan (seeExhibit 34.2)

34.32      Deutsche Bank TrustCompany Americas, as Trustee and Custodian of the Anchorage Marriott DowntownMortgage Loan (see Exhibit 34.28)

34.33      Park Bridge LenderServices LLC, as Operating Advisor of the Anchorage Marriott Downtown MortgageLoan (see Exhibit 34.23)

34.34      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the JWMarriott Santa Monica Le Merigot Mortgage Loan (see Exhibit 34.26)

34.35      C-III Asset ManagementLLC, as Special Servicer of the JW Marriott Santa Monica Le Merigot MortgageLoan (see Exhibit 34.2)

34.36      Deutsche Bank TrustCompany Americas, as Trustee and Custodian of the JW Marriott Santa Monica LeMerigot Mortgage Loan (see Exhibit 34.28)

34.37      Park Bridge LenderServices LLC, as Operating Advisor of the JW Marriott Santa Monica Le MerigotMortgage Loan (see Exhibit 34.23)

34.38      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Empire Mall Mortgage Loan (see Exhibit34.1)

34.39      C-III Asset ManagementLLC, as Special Servicer of the Empire Mall Mortgage Loan (see Exhibit 34.2)

34.40      Wilmington Trust, National Association, as Trustee of the Empire Mall MortgageLoan (Omitted. See Explanatory Notes.)

34.41      Citibank, N.A., asCustodian of the Empire Mall Mortgage Loan

34.42      Park Bridge LenderServices LLC, as Operating Advisor of the Empire Mall Mortgage Loan (seeExhibit 34.23)

34.43      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Empire MallMortgage Loan (see Exhibit 34.8)

34.44      National Tax Search, LLC,as Servicing Function Participant of the Empire Mall Mortgage Loan (see Exhibit34.9)

34.45      U.S. Bank NationalAssociation, as Servicing Function Participant of the Empire Mall Mortgage Loan

35           Servicer compliance statements.

35.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2        C-III Asset ManagementLLC, as Special Servicer prior to May 31, 2019

35.3        Rialto Capital Advisors,LLC, as Special Servicer on and after May 31, 2019

35.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.5        Principal Real EstateInvestors, LLC, as Primary Servicer

35.6        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Heritage Industrial Portfolio MortgageLoan (see Exhibit 35.1)

35.7        C-III Asset ManagementLLC, as Special Servicer of the Heritage Industrial Portfolio Mortgage Loanprior to May 31, 2019 (see Exhibit 35.2)

35.8        Rialto Capital Advisors,LLC, as Special Servicer of the Heritage Industrial Portfolio Mortgage Loan onand after May 31, 2019 (see Exhibit 35.3)

35.9        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Harvey Building Products PortfolioMortgage Loan (see Exhibit 35.1)

35.10      LNR Partners, LLC, as Special Servicer of the Harvey Building ProductsPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

35.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the HarborPointe Apartments Mortgage Loan

35.12      C-III Asset ManagementLLC, as Special Servicer of the Harbor Pointe Apartments Mortgage Loan (seeExhibit 35.2)

35.13      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of theAnchorage Marriott Downtown Mortgage Loan (see Exhibit 35.11)

35.14      C-III Asset Management LLC,as Special Servicer of the Anchorage Marriott Downtown Mortgage Loan (seeExhibit 35.2)

35.15      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the JWMarriott Santa Monica Le Merigot Mortgage Loan (see Exhibit 35.11)

35.16      C-III Asset ManagementLLC, as Special Servicer of the JW Marriott Santa Monica Le Merigot MortgageLoan (see Exhibit 35.2)

35.17      Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Empire Mall Mortgage Loan (see Exhibit35.1)

35.18      C-III Asset ManagementLLC, as Special Servicer of the Empire Mall Mortgage Loan (see Exhibit 35.2)

99.1        MortgageLoan Purchase Agreement, dated as of December 8, 2015, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.4 to the registrant’s Current Report on Form 8-K filed onDecember 23, 2015 under Commission File No. 333-206677-01 and incorporated byreference herein)

99.2        MortgageLoan Purchase Agreement, dated as of December 8, 2015, between Wells FargoCommercial Mortgage Securities, Inc. and Macquarie US Trading LLC d/b/aPrincipal Commercial Capital (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on December 23, 2015 under Commission File No.333-206677-01 and incorporated by reference herein)

99.3        MortgageLoan Purchase Agreement, dated as of December 8, 2015, among Wells FargoCommercial Mortgage Securities, Inc., Ladder Capital Finance LLC, LadderCapital Finance Holdings LLLP, Series REIT of Ladder Capital Finance HoldingsLLLP, and Series TRS of Ladder Capital Finance Holdings LLLP (filed as Exhibit99.2 to the registrant’s Current Report on Form 8-K filed on December 23, 2015under Commission File No. 333-206677-01 and incorporated by reference herein)

99.4        MortgageLoan Purchase Agreement, dated as of December 8, 2015, between Wells FargoCommercial Mortgage Securities, Inc. and Citigroup Global Markets Realty Corp(filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K filed onDecember 23, 2015 under Commission File No. 333-206677-01 and incorporated byreference herein)

99.5        MortgageLoan Purchase Agreement, dated as of December 8, 2015, between Wells FargoCommercial Mortgage Securities, Inc. and Société Générale (filed as Exhibit99.5 to the registrant’s Current Report on Form 8-K filed on December 23, 2015under Commission File No. 333-206677-01 and incorporated by reference herein)

99.6        Sub-ServicingAgreement, dated as of December 1, 2015, between Wells Fargo Bank, NationalAssociation, as Master Servicer and Principal Global Investors, LLC, asSub-Servicer (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K/A filed on January 6, 2016 under Commission File No. 333-206677-01 and incorporatedby 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 19, 2020