Exhibit 33.15

 

 

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Certification Regarding Compliance with Applicable Servicing Criteria

 

|   | 1. | LNR Partners, LLC. (the “Asserting Party”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending December 31, 2021 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report, include commercial mortgage-asset-backed securities transactions for which the Asserting Party served as special servicer, and that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933 (the “Platform”); |   |
|--------|----|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

|   | 2. | The Asserting Party has engaged certain vendors, which are not servicers as defined in Item 1101(j) of Regulation AB (the “Vendors”), to perform specific, limited or scripted activities, and the Asserting Party elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors’ activities as set forth in Appendix A hereto; |   |
|--------|----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

|   | 3. | Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria; |   |
|--------|----|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

|   | 4. | The criteria listed in the column titled “Inapplicable Servicing Criteria” on Appendix A hereto are inapplicable to the Asserting Party based on the activities it performs, directly or through its Vendors, with respect to the Platform; |   |
|--------|----|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

|   | 5. | The Asserting Party has complied, in all material respects, with the applicable servicing criteria as of December 31, 2021 and for the Reporting Period with respect to the Platform taken as a whole; |   |
|--------|----|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

|   | 6. | The Asserting Party has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria as of December 31, 2021 and for the Reporting Period with respect to the Platform taken as a whole; |   |
|--------|----|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

|   | 7. | The Asserting Party has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria as of December 31, 2021 and for the Reporting Period with respect to the Platform taken as a whole; and |   |
|--------|----|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

|   | 8. | Deloitte & Touche LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party’s assessment of compliance with the applicable servicing criteria for the Reporting Period. |   |
|--------|----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

 

February 15, 2022 

 

2340 Collins Avenue • Suite 700 • Miami Beach, Florida 33139-3164 Telephone: (305) 695-5600 • Fax: (305) 695-5601

 

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APPENDIX A

 

| SERVICING CRITERIA | APPLICABLE

SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                | INAPPLICABLE

SERVICING

CRITERIA         |
|--------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------|
| Reference          | Criteria                                                                                                                                                                                                                                                                                                                                                                                      | Performed

Directly

by

Asserting

Party | Performed

by

Vendor(s)

for which

Asserting

Party is the

Responsible

Party | Performed by

subservicer(s)

or vendor(s)

for which

Asserting

Party is NOT

the

Responsible

Party | NOT

performed by

Asserting

Party or by

subservicer(s)

or vendor(s)

retained by

Asserting

Party |
|               | General Servicing Considerations                                                                                                                                                                                                                                                                                                                                                              |                                      |   |   |   |
| 1122(d)(1)(i)      | Policies and procedures are instituted to monitor any performance

or other triggers and events of default in accordance with the

transaction agreements.                                                                                                                                                                                                                                    | X                                         |   |   |   |
| 1122(d)(1)(ii)     | If any material servicing activities are outsourced to third parties,

policies and procedures are instituted to monitor the third party’s

performance and compliance with such servicing activities.                                                                                                                                                                                  | X                                         |   |   |   |
| 1122(d)(1)(iii)    | Any requirements in the transaction agreements to maintain a

back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                            |                                      |   |   | X |
| 1122(d)(1)(iv)     | A fidelity bond and errors and omissions policy is in effect on the

party participating in the servicing function throughout the

reporting period in the amount of coverage required by and

otherwise in accordance with the terms of the transaction

agreements.                                                                                                                         | X                                         |   |   |   |
| 1122(d)(1)(v)      | Aggregation of information, as applicable, is mathematically

accurate and the information conveyed accurately reflects the

information                                                                                                                                                                                                                                                      | X                                         |   |   |   |
|               | Cash Collection and Administration                                                                                                                                                                                                                                                                                                                                                            |                                      |   |   |   |
| 1122(d)(2)(i)      | Payments on pool assets are deposited into the appropriate

custodial bank accounts and related bank clearing accounts no

more than two business days following receipt, or such other

number of days specified in the transaction agreements.                                                                                                                                              | X3                                        | X |   |   |
| 1122(d)(2)(ii)     | Disbursements made via wire transfer on behalf of an obligor or to

an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                        | X3                                        |   |   |   |
| 1122(d)(2)(iii)    | Advances of funds or guarantees regarding collections, cash flows

or distributions, and any interest or other fees charged for such

advances, are made, reviewed and approved as specified in the

transaction agreements.                                                                                                                                                                  | X3                                        |   |   |   |
| 1122(d)(2)(iv)     | The related accounts for the transaction, such as cash reserve

accounts or accounts established as a form of

overcollateralization, are separately maintained (e.g., with respect

to commingling of cash) as set forth in the transaction agreements.                                                                                                                                      | X                                         |   |   |   |
| 1122(d)(2)(v)      | Each custodial account is maintained at a federally insured

depository institution as set forth in the transaction agreements.

For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act. | X                                         |   |   |   |
| 1122(d)(2)(vi)     | Unissued checks are safeguarded so as to prevent unauthorized

access.                                                                                                                                                                                                                                                                                                                        | X                                         |   |   |   |

 

 

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| SERVICING CRITERIA | APPLICABLE

SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | INAPPLICABLE

SERVICING

CRITERIA          |
|--------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------|
| Reference          | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Performed

Directly

by

Asserting 

Party | Performed

by

Vendor(s)

for which

Asserting

Party is the

Responsible

Party | Performed by

subservicer(s)

or vendor(s)

for which

Asserting

Party is NOT

the

Responsible

Party | NOT

performed by

Asserting

Party or by

subservicer(s)

or vendor(s)

retained by

Asserting

Party |
| 1122(d)(2)(vii)    | Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodialaccounts and related bank clearing accounts. These reconciliationsare (A) mathematically accurate; (B) prepared within 30 calendardays after the bank statement cutoff date, or such other number ofdays specified in the transaction agreements; (C) reviewed andapproved by someone other than the person who prepared thereconciliation; and (D) contain explanations for reconciling items.These reconciling items are resolved within 90 calendar days oftheir original identification, or such other number of days specified in the transaction agreements. | X                                          | X |   |   |
|               | Investor Remittances and Reporting                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                       |   |   |   |
| 1122(d)(3)(i)      | Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transactionagreements and applicable Commission requirements.Specifically, such reports (A) are prepared in accordance withtimeframes and other terms set forth in the transaction agreements;(B) provide information calculated in accordance with the termsspecified in the transaction agreements; (C) are filed with theCommission as required by its rules and regulations; and (D) agreewith investors’ or the trustee’s records as to the total unpaidprincipal balance and number of pool assets serviced by the Servicer.                                   | X1                                         |   |   | X1 |
| 1122(d)(3)(ii)     | Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                       |   |   | X |
| 1122(d)(3)(iii)    | Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                       |   |   | X |
| 1122(d)(3)(iv)     | Amounts remitted to investors per the investor reports agree withcancelled checks, or other form of payment, or custodial bankstatements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                       |   |   | X |
|               | Pool Asset Administration                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                       |   |   |   |
| 1122(d)(4)(i)      | Collateral or security on pool assets is maintained as required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                                          |   |   |   |
| 1122(d)(4)(ii)     | Pool asset and related documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | X                                          |   |   |   |

 

1 Excludes the criteria as set forth on 3(i)(C) and 3(i)(D) which is not applicable to the Asserting Party

2 The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not routinely accept or process payments. 

3 No transactions occurred with respect to the criteria

 

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| SERVICING CRITERIA | APPLICABLE

SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | INAPPLICABLE

SERVICING

CRITERIA          |
|--------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------|
| Reference          | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | Performed

Directly

by

Asserting 

Party | Performed 

by

Vendor(s)

for which

Asserting

Party is the

Responsible

Party | Performed by

subservicer(s)

or vendor(s)

for which

Asserting

Party is NOT

the

Responsible

Party | NOT

performed by

Asserting

Party or by

subservicer(s)

or vendor(s)

retained by

Asserting

Party |
| 1122(d)(4)(iii)    | Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                 | X                                          |   |   |   |
| 1122(d)(4)(iv)     | Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related pool asset documents.                                                                                                                                                                          | X2                                         |   |   |   |
| 1122(d)(4)(v)      | The Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                       |   |   | X |
| 1122(d)(4)(vi)     | Changes with respect to the terms or status of an obligor’s pool

assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the

transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                             | X                                          |   |   |   |
| 1122(d)(4)(vii)    | Loss mitigation or recovery actions (e.g., forbearance plans,

modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                     | X                                          |   |   |   |
| 1122(d)(4)(viii)   | Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).                                                                        | X                                          |   |   |   |
| 1122(d)(4)(ix)     | Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                       |   |   | X |
| 1122(d)(4)(x)      | Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements. |                                       |   |   | X |
| 1122(d)(4)(xi)     | Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.                                                                                                                                                                                             |                                       |   |   | X |

 

1 Excludes the criteria as set forth on 3(i)(C) and 3(i)(D) which is not applicable to the Asserting Party. 

2 The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not routinely accept or process payments. 

 

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| SERVICING CRITERIA | APPLICABLE

SERVICING CRITERIA                                                                                                                                                                                                               | INAPPLICABLE

SERVICING

CRITERIA          |
|--------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------|
| Reference          | Criteria                                                                                                                                                                                                                                     | Performed

Directly

by

Asserting 

Party | Performed 

by

Vendor(s)

for which

Asserting

Party is the

Responsible

Party | Performed by subservicer(s)

or vendor(s)

for which

Asserting

Party is NOT

the

Responsible

Party | NOT

performed by

Asserting

Party or by

subservicer(s)

or vendor(s)

retained by

Asserting

Party |
| 1122(d)(4)(xii)    | Any late payment penalties in connection with any payment to bemade on behalf of an obligor are paid from the Servicer’s fundsand not charged to the obligor, unless the late payment was due tothe obligor’s error or omission. |                                       |   |   | X |
| 1122(d)(4)(xiii)   | Disbursements made on behalf of an obligor are posted within twobusiness days to the obligor’s records maintained by the Servicer,or such other number of days specified in the transactionagreements.                                 |                                       |   |   | X |
| 1122(d)(4)(xiv)    | Delinquencies, charge-offs and uncollectible accounts are

recognized and recorded in accordance with the transaction

agreements.                                                                                                           |                                       |   |   | X |
| 1122(d)(4)(xv)     | Any external enhancement or other support, identified in Item1114(a)(1) through (3) or Item 1115 of Regulation AB, ismaintained as set forth in the transaction agreements.                                                                  |                                       |   |   | X |

 

1 Excludes the criteria as set forth on 3(i)(C) and 3(i)(D) which is not applicable to the Asserting Party.

2 The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not routinely accept or process payments. 

3 No transactions occurred with respect to the criteria