**Report on Assessment ofCompliance with SEC Regulation AB**

**Servicing Criteria as PrimaryServicer**

 

Berkadia Commercial MortgageLLC (“Berkadia”) is responsible for assessing compliance, as of andfor the year ended December 31, 2016 (the “Reporting Period”), withthe Servicing Criteria set forth in Item 1122(d) of Regulation AB of the U.S.Securities and Exchange Commission for asset-backed securities transactions.This assertion includes all commercial mortgage loans sold in publicsecuritizations from the period January 1, 2016 through December 31, 2016 forwhich Berkadia served as primary servicer (the “Platform”). 

 

Berkadia has concluded thatthe criteria are applicable as shown below (indicated by X) to the primaryservicing of the loans in the Platform:

 

| **Regulation AB Criteria 1122(d)**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **Applicability of Criteria as the Primary  Servicer** |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------|
| (1)     General servicing  considerations.                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                   |
| (i)      Policies and  procedures are instituted to monitor any performance or other triggers and  events of default in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                             | X                                                      |
| (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                                                      |
| (iii)    Any requirements in the  transaction agreements to maintain a back-up servicer for the pool assets are  maintained.                                                                                                                                                                                                                                                                                                                                                                                              | (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                                                      |
| (v)      Aggregation of  information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                              | X                                                      |
| (2)     Cash collection and  administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                                   |
| (i)      Payments on pool  assets are deposited into the custodial bank accounts and related bank  clearing accounts no more than two business days of receipt, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                          | X                                                      |
| (ii)     Disbursements made via  wire transfer on behalf of an obligor or to an investor are made only by  authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                     | X                                                      |
| (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 transection agreements.                                                                                                                                                                                                                                                                                     | X                                                      |
| (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                                                      |
| (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 §  240.13k-1(b)(1) of this chapter.                                                                                                                      | X                                                      |
| (vi)    Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                                                      |
| (vii)   Reconciliations are prepared on a  monthly basis for all asset-backed securities related bank accounts,  including custodial accounts and related bank clearing accounts. These  reconciliations:                                                                                                                                                                                                                                                                                                                      |                                                   |
| (A)    Are mathematically accurate;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | X                                                      |
| (B)     Are prepared within 30  calendar days after the bank statement cutoff date, or such other number of  days specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                           | X                                                      |
| (C)     Are reviewed and approved  by someone other than the person who prepared the reconciliation; and                                                                                                                                                                                                                                                                                                                                                                                                             | X                                                      |
| (D)    Contain explanations for  reconciling items. These reconciling items are resolved within 90 calendar  days of their original identification, or such other number of days specified  in the transaction agreements.                                                                                                                                                                                                                                                                                                | X                                                      |
| (3)     Investor remittances and reporting.                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                   |
| (i)      Reports to  investors, including those to be filed with the Commission, are maintained in  accordance with the transaction agreements and applicable Commission  requirements. Specifically, such reports:                                                                                                                                                                                                                                                                                             |                                                   |
| (A)    Are prepared in accordance with  timeframes and other terms set forth in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                               | X                                                      |
| (B)     Provide information  calculated in accordance with the terms specified in the transaction  agreements;                                                                                                                                                                                                                                                                                                                                                                                                       | X                                                      |
| (C)     Are filed with the  Commission as required by its rules and regulations; and                                                                                                                                                                                                                                                                                                                                                                                                                                 | (1)                                                    |
| (D)    Agree with investors’ or  the trustee’s records as to the total unpaid principal balance and  number of pool assets serviced by the servicer.                                                                                                                                                                                                                                                                                                                                                          | X                                                      |
| (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                                                      |
| (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                                                      |
| (iv)    Amounts remitted to investors  per the investor reports agree with cancelled checks, or other form of  payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                     | X                                                      |
| (4)     Pool asset  administration.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                                   |
| (i)      Collateral or  security on pool assets is maintained as required by the transaction  agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                       | X(2)                                                   |
| (ii)     Pool assets and related  documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                               | (1)                                                    |
| (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                                                      |
| (iv)    Payments on pool assets,  including any payoffs, made in accordance with the related pool asset  documents are posted to the applicable 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.                                                                               | X                                                      |
| (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                                                      |
| (vi)    Changes with respect to the  terms or status of an obligor’s pool asset (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                                                      |
| (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.                                                                                                                                                                                                             | (1)                                                    |
| (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                                                      |
| (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                                                      |
| (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;                                                                                                                                                                                                                                                                                                                                 | X                                                      |
| (B)     Interest on such funds is  paid, or credited, to obligors in accordance with applicable pool asset documents  and state laws; and                                                                                                                                                                                                                                                                                                                                                                            | X                                                      |
| (C)     Such funds are returned  to the obligor within 30 calendar days of full repayment of the related pool  asset, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                          | X                                                      |
| (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(2)                                                   |
| (xii)   Any late payment penalties in  connection with any payment to be made on behalf of an obligor are paid from  the servicer’s funds and not charged to the obligor, unless the late  payment was due to the obligor’s error or omission.                                                                                                                                                                                                                                                                     | X(2)                                                   |
| (xiii)  Disbursements made on behalf of an  obligor are posted within two business days to the obligor’s records  maintained by the servicer, or such other number of days specified in the  transaction agreements.                                                                                                                                                                                                                                                                                                          | X(2)                                                   |
| (xiv)  Delinquencies, charge-offs and  uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                           | X                                                      |
| (xv)   Any external enhancement or other  support, identified in Item 1114(a) (1) through (3) or Item 1115 of this  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                   | (1)                                                    |

 

X  Servicer wasresponsible for this criteria in its role as Primary Servicer. 

(1)  Per servicing and pooling agreements, the criteriadoes not apply to the role of Primary Servicer. 

(2)  Vendor(s), for which Berkadia is the ResponsibleParty, contributes to the servicing activities for this criteria.

 

 

The Servicing Criteria, aftergiving effect to the foregoing exclusions, are referred to as the“Applicable Servicing Criteria”. 

 

Berkadia utilizes vendors tosupport its servicing operations, including the use of a commercial tax servicewhich supports its assertions under 1122(d)(4)(xi) through (xiii) and the useof a lien filing firm to support its assertion under 1122(d)(4)(i). This vendoractivity contributes to the servicing activities to which Berkadia isasserting. In all cases, the vendors’ activities are limited, andBerkadia assumes responsibility for the 1122 assessment for these vendoractivities. These vendors do not fit the definition of servicer under Item1101(j), and Berkadia employs policies and procedures designed to provideassurance that the vendors’ activities comply with the ApplicableServicing Criteria to such vendors. 

 

For the Reporting Period,Berkadia has assessed its compliance with the Applicable Servicing Criteria forthe Platform and has concluded that its servicing operation has complied, inall material respects, with the Applicable Servicing Criteria. 

 

Grant Thornton LLP, anindependent registered public accounting firm, has issued an attestation reporton management’s assertion of compliance with the Applicable ServicingCriteria. 

 

 

Berkadia Commercial MortgageLLC

 

 

/s/ Mark E. McCool

Mark E. McCool

Executive Vice President

Berkadia Commercial MortgageLLC