**Reportof Independent Registered Public Accounting Firm**

 

 

Tothe Board of Governors 

NorthmarqCapital, LLC

 

 

Wehave examined management’s assertion, included in the accompanying Management’sReport on Assessment of 2022 Compliance by Northmarq Capital, LLC withRegulation AB Servicing Criteria (Management’s Assertion), that NorthmarqCapital, LLC (the Company) complied with the servicing criteria set forth inItem 1122(d) of the Securities and Exchange Commission’s (SEC) Regulation ABfor services by the Company that are encompassed by contractual obligations toperform Regulation AB reporting (the “Platform”), including only thoseasset-backed securities transactions defined below, as of and for the yearended December 31, 2022, excluding the following criteria set forth in Items1122(d)(1)(iii), 1122(d)(3)(i)C and D, 1122(d)(3)(ii), 1122(d)(3)(iii),1122(d)(3)(iv), 1122(d)(4)(vii) and1122(d)(4)(xv), which management hasdetermined are not applicable to the activities performed by the Company withrespect to the Platform covered by this report. Appendices A and B toManagement’s Assertion identify the individual asset-backed transactionsdefined by management as constituting the Platform. Management is responsiblefor Northmarq Capital, LLC’s compliance with the applicable servicing criteria.Our responsibility is to express an opinion on management’s assertion about theCompany’s compliance with the applicable servicing criteria based on our examination.

 

Ourexamination was conducted in accordance with attestation standards of thePublic Company Accounting Oversight Board (United States) and, accordingly,included examining, on a test basis, evidence about the Company’s compliancewith the applicable servicing criteria, including tests on a sample basis ofthe servicing activities related to the Platform, determining whether theCompany performed those activities in compliance with the servicing criteriaduring the specified period and performing such other procedures as weconsidered necessary in the circumstances. Our procedures were limited toselected servicing activities performed by the Company during the periodcovered by this report and, accordingly, such samples may not have included servicingactivities related to each asset- backed transaction in the Platform. Further,an examination is not designed to detect noncompliance arising from errors thatmay have occurred prior to the period specified above that may have affectedthe balances or amounts calculated or reported by the Company during the periodcovered by this report. We believe that our examination provides a reasonablebasis for our opinion. Our examination does not provide a legal determinationon the Company’s compliance with the servicing criteria.

 

Asdescribed in Management’s Assertion, for servicing criterion 1122(d)(1)(ii) and1122(d)(2)(i), the Company has engaged vendors to perform certain activitiesrequired by this servicing criterion. The Company has determined that thesevendors are not considered “servicers” as defined in Item 1101(j) of RegulationAB, and the Company has elected to take responsibility for assessing compliancewith the servicing criterion applicable to these vendors as permitted bySection 200.06 of the Compliance and Disclosure Interpretations (Section200.06). As permitted by Section 200.06, the Company has asserted that it haspolicies and procedures in place designed to provide reasonable assurance thatthe vendor's activities comply in all material respects with the servicingcriterion applicable to these vendors. The Company is solely responsible fordetermining that it meets the SEC requirements to apply Section 200.06 for thevendors and related criterion as described in its assertion, and we performedno procedures with respect to the Company’s determination of its eligibility touse Section 200.06.

 

Inour opinion, management’s assertion that Northmarq Capital, LLC complied withthe aforementioned applicable servicing criteria as of and for the year endedDecember 31, 2022, for the Platform is fairly stated, in all material respects.

 

 

/s/RSM US LLP

Minneapolis,Minnesota 

February13, 2023