**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

**For the fiscal year ended December 31, 2018or**

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-206847-01**

**Central Index Key Number of the issuing entity:0001665081**

**Morgan Stanley Bank of AmericaMerrill Lynch Trust 2016-C28**

**(exact name of the issuing entity as specified in itscharter)**

** **

**Central Index Key Number of the depositor: 0001005007**

**Banc of America Merrill LynchCommercial Mortgage Inc.**

**(exact name of the depositor as specified in itscharter)**

** **

**Central Index Key Number of the sponsor: 0001102113**

**Bank of America, NationalAssociation**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001541557**

**Morgan Stanley Mortgage CapitalHoldings LLC**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001548567**

**CIBC Inc.**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index KeyNumber of the sponsor: 0001682532**

**Starwood Mortgage Funding III LLC**

**(exact name of the sponsor as specified in its charter)**

** **

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

**the issuing entity)** | **38-3991327**

**38-3991328**

**38-7145089**

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

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

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

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(646) 855-3953**

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

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

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

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

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

Indicate by check mark whether the registrant has submittedelectronically and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form 10-K.  

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Accelerated filer                                     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 theregistrant has elected not to use the extended transition period for complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the ExchangeAct.                                            o

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

 

The Princeton Pike Corporate Center Mortgage Loan and the LeMeridien Cambridge MIT Mortgage Loan, which constituted approximately 5.2% and3.1%, respectively, of the asset pool of the issuing entity as of its cut-offdate, are each an asset of the issuing entity and are each part of a loancombination that includes the Princeton Pike Corporate Center Mortgage Loan orthe Le Meridien Cambridge MIT Mortgage Loan which are assets of the issuingentity and two other *pari passu* loans, which are not assets of theissuing entity. These loan combinations, including the Princeton Pike CorporateCenter Mortgage Loan and the Le Meridien Cambridge MIT Mortgage Loan, are beingserviced and administered pursuant to the Pooling and Servicing Agreement,which is incorporated by reference as Exhibit 4.1 to this Annual Report on Form10-K. Wells Fargo Bank, National Association is the master servicer under thePooling and Servicing Agreement.  The responsibilities of Wells FargoBank, National Association, as primary servicer of each of these loancombinations with respect to the issuing entity, are subsumed within itsresponsibilities as master servicer under the Pooling and ServicingAgreement.  Thus, the servicer compliance statement provided by WellsFargo Bank, National Association, as master servicer under the Pooling and ServicingAgreement, encompasses its roles as both master servicer and primary servicerwith respect to these loan combinations.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the University West Apartments Mortgage Loan,which constituted approximately 1.9% of the asset pool of the issuing entity asof its cut-off date.  The University West Apartments Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theUniversity West Apartments Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. The other *pari passu*portion of the loan combination was securitized in the Morgan Stanley Bank ofAmerica Merrill Lynch Trust 2015-C27 transaction, Commission File Number333-180779-20 (the “MSBAM 2015-C27 Transaction”). This loan combination,including the University West Apartments Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the MSBAM2015-C27 Transaction, which is incorporated by reference as Exhibit 4.2 to thisAnnual Report on Form 10-K.  Wells Fargo Bank, National Association is themaster servicer under the pooling and servicing agreement for the MSBAM 2015-C27Transaction.  The responsibilities of Wells Fargo Bank, NationalAssociation, as primary servicer of this loan combination with respect to theissuing entity, are subsumed within its responsibilities as master servicerunder the pooling and servicing agreement for the MSBAM 2015-C27Transaction.  Thus, the servicer compliance statement provided by WellsFargo Bank, National Association, as master servicer under such pooling andservicing agreement, encompasses its roles as both master servicer and primaryservicer with respect to this loan combination.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Ellenton Premium Outlets Mortgage Loan,which constituted approximately 7.5% of the asset pool of the issuing entity asof its cut-off date.  The Ellenton Premium Outlets Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theEllenton Premium Outlets Mortgage Loan and three other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the Morgan Stanley Capital I Trust2015-UBS8 transaction, Commission File Number 333-180779-21 (the “MSC2015-UBS8 Transaction”). This loan combination, including the EllentonPremium Outlets Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the MSC 2015-UBS8 Transaction, which isincorporated by reference as Exhibit 4.3 to this Annual Report on Form10-K.  Midland Loan Services, a Division of PNC Bank, National Associationis the master servicer under the pooling and servicing agreement for the MSC2015-UBS8 Transaction.  The responsibilities of Midland Loan Services, aDivision of PNC Bank, National Association, as primary servicer of this loancombination with respect to the issuing entity, are subsumed within itsresponsibilities as master servicer under the pooling and servicing agreementfor the MSC 2015-UBS8 Transaction.  Thus, the servicer compliancestatement provided by Midland Loan Services, a Division of PNC Bank, NationalAssociation, as master servicer under such pooling and servicing agreement,encompasses its roles as both master servicer and primary servicer with respectto this loan combination.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the GLP Industrial Portfolio A Mortgage Loan,which constituted approximately 7.3% of the asset pool of the issuing entity asof its cut-off date.  The GLP Industrial Portfolio A Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theGLP Industrial Portfolio A Mortgage Loan and four other *pari passu* loansand two subordinate companion loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe CSMC Trust 2015-GLPA transaction (the “CSMC 2015-GLPA Transaction”).This loan combination, including the GLP Industrial Portfolio A Mortgage Loan,is being serviced and administered pursuant to the trust and servicingagreement for the CSMC 2015-GLPA Transaction, which is incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K.  KeyBankNational Association is the master servicer under the trust and servicingagreement for the CSMC 2015-GLPA Transaction.  The responsibilities ofKeyBank National Association, as primary servicer of this loan combination withrespect to the issuing entity, are subsumed within its responsibilities asmaster servicer under the trust and servicing agreement for the CSMC 2015-GLPATransaction.  Thus, the servicer compliance statement provided by KeyBankNational Association, as master servicer under such trust and servicingagreement, encompasses its roles as both master servicer and primary servicerwith respect to this loan combination.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Penn Square Mall Mortgage Loan, whichconstituted approximately 9.4% of the asset pool of the issuing entity as ofits cut-off date.  The Penn Square Mall Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Penn SquareMall Mortgage Loan and two other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the Morgan Stanley Capital ITrust 2016-PSQ transaction (the “MSC 2016-PSQ Transaction”). This loancombination, including the Penn Square Mall Mortgage Loan, is being servicedand administered pursuant to the trust and servicing agreement for the MSC2016-PSQ Transaction, which is incorporated by reference as Exhibit 4.5 to thisAnnual Report on Form 10-K.  Wells Fargo Bank, National Association is themaster servicer under the trust and servicing agreement for the MSC 2016-PSQTransaction.  The responsibilities of Wells Fargo Bank, NationalAssociation, as primary servicer of this loan combination with respect to theissuing entity, are subsumed within its responsibilities as master servicerunder the trust and servicing agreement for the MSC 2016-PSQ Transaction. Thus, the servicer compliance statement provided by Wells Fargo Bank, NationalAssociation, as master servicer under such trust and servicing agreement,encompasses its roles as both master servicer and primary servicer with respectto this loan combination.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement, the primaryservicer and certificate administrator of the University West ApartmentsMortgage Loan, the certificate administrator of the Ellenton Premium OutletsMortgage Loan and the GLP Industrial Portfolio A Mortgage Loan and the primaryservicer, special servicer and certificate administrator of the Penn SquareMall Mortgage Loan. As a result, Wells Fargo Bank, National Association is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-off date.The assessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements delivered by Wells FargoBank, National Association in the capacities described above are listed in theExhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the University West Apartments Mortgage Loan, the PennSquare Mall Mortgage Loan, the Ellenton Premium Outlets Mortgage Loan and theGLP Industrial Portfolio A Mortgage Loan.  As a result, Wells Fargo Bank,National Association is a servicing function participant in the capacitiesdescribed above, because it is servicing mortgage loans that constituted 5% ormore of the assets of the issuing entity as of its cut-off date. Theassessments of compliance with applicable servicing criteria and accountants’attestation reports delivered by Wells Fargo Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Situs Holdings, LLC is theoperating advisor of the University West Apartments Mortgage Loan and theEllenton Premium Outlets Mortgage Loan.  As a result, Situs Holdings, LLCis 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 bySitus Holdings, LLC in the capacities described above are listed in the ExhibitIndex.

U.S. Bank National Associationacts as trustee of the mortgage loans serviced under the Pooling and ServicingAgreement.  Pursuant to the Pooling and Servicing Agreement, the trustee isrequired to provide an assessment of compliance with applicable servicingcriteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB(regarding advances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the mortgage loans serviced underthe Pooling and Servicing Agreement have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the University West Apartments Mortgage Loan andthe Penn Square Mall Mortgage Loan.  Pursuant to the pooling and servicingagreement for the MSBAM 2015-C27 Transaction and the trust and servicing agreementfor the MSC 2016-PSQ Transaction, the trustee is required to provide anassessment of compliance with applicable servicing criteria solely with respectto Item 1122(d)(2)(iii) of Regulation AB (regarding advances of funds orguarantees regarding collections, cash flows or distributions, and any interestor other fees charged for such advances, are made, reviewed and approved asspecified in the transaction agreements). However, during the reporting period,the trustee did not perform any servicing function with respect to theservicing criteria specified in Item 1122(d)(2)(iii) of Regulation AB. The master servicer or the special servicer, to the extent required, performedthe servicing function identified with respect to Item 1122(d)(2)(iii) of RegulationAB, and each such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation 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 University West Apartments Mortgage Loan and the Penn Square 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 and theprimary servicer of the University West Apartments Mortgage Loan and the PennSquare Mall Mortgage Loan and to remit tax payments received from the escrowaccounts of borrowers to local taxing authorities, to report tax amounts due,to verify tax parcel information, and to verify non-escrow tax payments. Theseservicing functions are included within the servicing criteria set forth inItems 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore,under the principles-based definition of “servicer” set forth in Item 1101(j)of Regulation AB that looks to the functions that an entity performs, thesevendors are “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

With respect to the *pari passu*loan combinations that include the University West Apartments Mortgage Loan,the Ellenton Premium Outlets Mortgage Loan and the GLP Industrial Portfolio AMortgage Loan, (i) the report on assessment of compliance with servicingcriteria and attestation report on assessment of compliance with servicingcriteria of CWCapital Asset Management LLC as special servicer of theUniversity West Apartments Mortgage Loan, listed on the Exhibit Index areomitted from this Annual Report on Form 10-K as it is not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 ofRegulation AB because it is a party performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity;and (ii) the servicer compliance statements of CWCapital Asset Management LLCas special servicer of the University West Apartments Mortgage Loan, MidlandLoan Services, a Division of PNC Bank, National Association, as primaryservicer of the Ellenton Premium Outlets Mortgage Loan, Rialto CapitalAdvisors, LLC as special servicer of the Ellenton Premium Outlets Mortgage Loan,KeyBank National Association as primary servicer of the GLP IndustrialPortfolio A Mortgage Loan and AEGON USA Realty Advisors, LLC as specialservicer of the GLP Industrial Portfolio A Mortgage Loan, listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as they are not requiredby Item 1123 of Regulation AB to be included on this Annual Report on Form 10-Kbecause they are each an unaffiliated party that is not a “servicer” that meetsthe criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  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 Enhancement ProviderFinancial Information.**

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

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

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

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

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to U.S. Bank National Association, as trustee, andWells Fargo Bank, National Association, as certificate administrator, custodianand trustee: 

Since 2014 various plaintiffs or groups of plaintiffs,primarily investors, have filed claims against U.S. Bank National Association(“U.S. Bank”), in its capacity as trustee or successor trustee (as thecase may be) under certain residential mortgage backed securities (“RMBS”)trusts.  The plaintiffs or plaintiff groups have filed substantiallysimilar complaints against other RMBS trustees, including Deutsche Bank,Citibank, HSBC, Bank of New York Mellon and Wells Fargo.  The complaintsagainst U.S. Bank allege the trustee caused losses to investors as a result ofalleged failures by the sponsors, mortgage loan sellers and servicers for theseRMBS trusts and assert causes of action based upon the trustee’s purportedfailure to enforce repurchase obligations of mortgage loan sellers for allegedbreaches of representations and warranties concerning loan quality.  Thecomplaints also assert that the trustee failed to notify securityholders ofpurported events of default allegedly caused by breaches of servicing standardsby mortgage loan servicers and that the trustee purportedly failed to abide by aheightened standard of care following alleged events of default.  

Currently U.S. Bank is a defendant in multiple actionsalleging individual or class action claims against the trustee with respect tomultiple trusts as described above.  Previously, U.S. Bank disclosed thatthe most substantial case was:  BlackRock Balanced Capital Portfolio et alv. U.S. Bank National Association, No. 605204/2015 (N.Y. Sup. Ct.) (classaction alleging claims with respect to approximately 770 trusts) and itscompanion case BlackRock Core Bond Portfolio et al v. U.S. Bank NationalAssociation, No. 14-cv-9401 (S.D.N.Y.) (collectively, the “BlackRock cases”).U.S. Bank has entered into a settlement agreement that will resolve theBlackRock cases following approval of the dismissals by the applicablecourt.  Some of the trusts implicated in the aforementioned Blackrockcases, as well as other trusts, are involved in actions brought by separategroups of plaintiffs related to no more than 100 trusts per case.

U.S. Bank cannot assure you as to the outcome of any of thelitigation, or the possible impact of these litigations on the trustee or theRMBS trusts. However, U.S. Bank denies liability and believes that it hasperformed its obligations under the RMBS trusts in. good faith, that itsactions were not the cause of losses to investors and that it has meritoriousdefenses, and it intends to contest the plaintiffs’ claims vigorously.

Since June 18, 2014, a group of institutional investors havefiled civil complaints in the Supreme Court of the State of New York, New YorkCounty, and later the U.S. District Court for the Southern District of New Yorkagainst Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in its capacity astrustee for certain residential mortgage backed securities (“RMBS”) trusts. The complaints against Wells Fargo Bank alleged that the trustee caused lossesto investors and asserted causes of action based upon, among other things, thetrustee’s alleged failure to: (i) notify and enforce repurchase obligations ofmortgage loan sellers for purported breaches of representations and warranties,(ii) notify investors of alleged events of default, and (iii) abide byappropriate standards of care following alleged events of default. Reliefsought included money damages in an unspecified amount, reimbursement ofexpenses, and equitable relief. Wells Fargo Bank has reached an agreement, inwhich it denies any wrongdoing, to resolve these claims on a classwide basisfor the 271 RMBS trusts currently at issue.  The settlement agreement issubject to court approval.  Separate lawsuits against Wells Fargo Bankmaking similar allegations filed by certain other institutional investorsconcerning 57 RMBS trusts in New York federal and state court are not coveredby the agreement.  With respect to the foregoing litigations, Wells FargoBank believes plaintiffs’ claims are without merit and intends to contest theclaims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe RMBS trusts. 

**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 February 25, 2016 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 University West ApartmentsMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the MSBAM 2015-C27 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule X to thepooling and servicing agreement for the MSBAM 2015-C27 Transaction incorporatedby reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSBAM2015-C27 Transaction responsible for each applicable servicing criteria setforth 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 Ellenton Premium Outlets MortgageLoan, which is being serviced and administered pursuant to the pooling and servicingagreement for the MSC 2015-UBS8 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Schedule X to the pooling andservicing agreement for the MSC 2015-UBS8 Transaction incorporated by referenceas Exhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the MSC 2015-UBS8Transaction responsible for each applicable servicing criteria set forth inItem 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 GLP Industrial Portfolio AMortgage Loan, which is being serviced and administered pursuant to the trust andservicing agreement for the CSMC 2015-GLPA Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the CSMC 2015-GLPA Transaction incorporatedby reference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CSMC2015-GLPA Transaction responsible for each applicable servicing criteria setforth 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 Penn Square Mall Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the MSC 2016-PSQ Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the MSC 2016-PSQ Transaction incorporated by referenceas Exhibit 4.5 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the MSC 2016-PSQ Transactionresponsible for each applicable servicing criteria set forth in Item 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 discloses that amaterial instance of noncompliance occurred, as described below:

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 numbers due to the following: (1) the initial setup filescontained information at the asset level, and Midland was required to manuallycompile the information to present it at the loan level as required by ScheduleAL; and (2) certain reporting requirements required manual processing byMidland, including the use of various data computation formulas, qualitycontrol checks and analysis.

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

Steps Taken to Remedy the Material Instance of Noncompliance

Midland is currently remediating theSchedule AL reporting for the CMBS transactions found to be incorrect, and willbe making improvements to its systems, processes and procedures to support itsSchedule AL reporting obligations.

The report on assessment of compliance with applicableservicing criteria furnished pursuant to Item 1122 of Regulation AB byCWCapital Asset Management LLC (“CWCAM”) discloses that a materialinstance of noncompliance occurred, as described below:

Material Instance of Noncompliance:

1122(d)(2)(vii): “Reconciliationsare prepared on a monthly basis for all asset-backed securities related bankaccounts, including custodial accounts and related bank clearing accounts.These reconciliations: (A) are mathematically accurate; (B) are prepared within30 calendar days after the bank statement cutoff date, or such other number ofdays specified in the transaction agreements; (C) are reviewed and approved bysomeone other than the person who prepared the reconciling items; and (D)contain explanations for reconciling items. These reconciling items areresolved within 90 calendar days of their original identification, or such othernumber of days specified in the transaction agreements.”

The instance of materialnoncompliance, for the reporting period included a failure to complete therequired bank reconciliations within 30 calendar days after the bank statement cutoffdate.  In five of the twelve months related to the reporting period, therequired reconciliations were not completed within the 30 calendar daysrequirement as follows: 

February 2018: bank reconciliationswere prepared on June 22, 2018

March 2018: bank reconciliationswere prepared on May 1, 2018

September 2018: bankreconciliations were prepared on November 6, 2018

November 2018: bank reconciliationswere prepared on February 19, 2019

December 2018: bank reconciliationswere prepared on February 6, 2019

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

Steps Taken to Remedy the Material Instance of Noncompliance

In response to the lack of adherenceto company policy and procedures, CWCAM’s Compliance Committee reviewed thereasons for noncompliance and added two additional procedures to supplement itsexisting procedures: 

1) theaccounting department has added the completion of bank account reconciliationswithin 30 calendar days to its monthly closing checklist, which is reviewed andsigned off by a CWCAM officer; and 

2) the ChiefFinancial Officer has set up a monthly electronic reminder requiring that thecompleted bank reconciliations be forwarded to the CFO for an additional layerof review.    

Report on Assessment of Compliance with Applicable ServicingCriteria Not Included

For the reasons discussed in theExplanatory Notes above, CWCAM is not a party performing activities thataddress servicing criteria relating to 5% or more of the assets of the issuingentity.  Therefore, the report of assessment of compliance with applicableservicing criteria for CWCAM has not been included as an exhibit to this AnnualReport on Form 10-K.

**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 February 1, 2016, by and among Banc ofAmerica Merrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, C-III Asset Management LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, U.S. Bank National Association, as Trustee, Park Bridge LenderServices LLC, as Operating Advisor, and Park Bridge Lender Services LLC, asAsset Representations Reviewer (filed as Exhibit 4.1 to the registrant’sCurrent Report on Form 8-K/A filed on March 8, 2016 under Commission File No.333-206847-01 and incorporated by reference herein).

4.2          Poolingand Servicing Agreement, dated as of November 1, 2015, by and among Morgan StanleyCapital I Inc., as Depositor, Wells Fargo Bank, National Association, as MasterServicer, CWCapital Asset Management LLC, as Special Servicer, Situs Holdings,LLC, as Trust Advisor, Wilmington Trust, National Association, as Trustee, andWells Fargo Bank, National Association, as Certificate Administrator,Certificate Registrar, Authenticating Agent and Custodian (filed as Exhibit 4.5to the registrant’s Current Report on Form 8-K filed on February 25, 2016 underCommission File No. 333-206847-01 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of December 1, 2015, by and among MorganStanley Capital I Inc., as Depositor, Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer, Rialto Capital Advisors, LLC,as Special Servicer, Situs Holdings, LLC, Trust Advisor, and Wells Fargo Bank,National Association, as Trustee, Certificate Administrator, CertificateRegistrar, Authenticating Agent and Custodian (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on February 25, 2016 underCommission File No. 333-206847-01 and incorporated by reference herein).

4.4          Trustand Servicing Agreement, dated as of December 15, 2015, by and among CreditSuisse First Boston Mortgage Securities Corp., as Depositor, KeyBank NationalAssociation, as Servicer, AEGON USA Realty Advisors, LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator and WellsFargo Bank, National Association, as Trustee (filed as Exhibit 4.4 to theregistrant’s Current Report on Form 8-K filed on February 25, 2016 underCommission File No. 333-206847-01 and incorporated by reference herein).

4.5          Trustand Servicing Agreement, dated as of February 1, 2016, by and among MorganStanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association,as Servicer and Special Servicer, Wilmington Trust, National Association, asTrustee and Wells Fargo Bank, National Association, as CertificateAdministrator (filed as Exhibit 4.2 to the registrant’s Current Report on Form8-K filed on February 25, 2016 under Commission File No. 333-206847-01 andincorporated by reference herein).

4.6          AmendedAnd Restated Agreement Between Note Holders, dated as of April 21, 2016, by andbetween U.S. Bank National Association, as Trustee for Morgan StanleyBank  of America Merrill Lynch Trust 2016-C28, Commercial MortgagePass-Through Certificates, Series 2016-C28, as Note A-1 Holder, Wells FargoBank, National Association, as Trustee for Morgan Stanley Capital I Trust2016-UBS9, Commercial Mortgage Pass-Through Certificates, Series 2016-UBS9, asNote A-2 Holder, Morgan Stanley Bank, N.A., as Note A-3 Holder, and MorganStanley Bank, N.A., as Note A-4 Holder (filed as Exhibit 4.12 to theregistrant’s Current Report on Form 8-K filed on April 27, 2016 underCommission File No. 333-206847-01 and incorporated by reference herein).

4.7          AgreementBetween Note Holders, dated as of February 5, 2016, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, Bank of America, N.A., as InitialNote A-2 Holder, and Bank of America, N.A., as Initial Note A-3 Holder (filedas Exhibit 4.7 to the registrant’s Current Report on Form 8-K filed on February25, 2016 under Commission File No. 333-206847-01 and incorporated by referenceherein).

4.8          AgreementBetween Note Holders, dated as of October 28, 2015, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, and Bank of America, N.A., asInitial Note A-2 Holder (filed as Exhibit 4.11 to the registrant’s CurrentReport on Form 8-K filed on February 25, 2016 under Commission File No.333-206847-01 and incorporated by reference herein).

4.9          AgreementBetween Note Holders, dated as of November 5, 2015, by and between UBS RealEstate Securities Inc., as Initial Note A-1 Holder, UBS Real Estate SecuritiesInc., as Initial Note A-2 Holder, UBS Real Estate Securities Inc., as InitialNote A-3 Holder, and Bank of America, N.A., as Initial Note A-4 Holder (filedas Exhibit 4.9 to the registrant’s Current Report on Form 8-K filed on February25, 2016 under Commission File No. 333-206847-01 and incorporated by referenceherein).

4.10        AmendedAnd Restated Co-Lender Agreement, dated as of May 26, 2016, by and among WellsFargo Bank, National Association, not in its individual capacity but solely asTrustee for the benefit of the Holders of CSMC 2015-GLPA Mortgage TrustCommercial Mortgage Pass-Through Certificates, as Note A-1 Holder, Note A-2Holder, Note B-1 Holder and Note B-2 Holder, Wells Fargo Bank, NationalAssociation, not in its individual capacity but solely as Trustee for thebenefit of the Holders of CSAIL 2016-C5 Mortgage Trust Commercial MortgagePass-Through Certificates, as Note A-3-1 Holder, Column Financial, Inc., asNote A-3-2 Holder, and U.S. Bank National Association, as Trustee for MorganStanley Bank  of America Merrill Lynch Trust 2016-C28, Commercial MortgagePass-Through Certificates, Series 2016-C28, as Note A-4 Holder (filed asExhibit 4.13 to the registrant’s Current Report on Form 8-K filed on June 1,2016 under Commission File No. 333-206847-01 and incorporated by referenceherein).

4.11        AgreementBetween Note Holders, dated as of February 11, 2016, by and between MorganStanley Bank, N.A., as Initial Note A-1A Holder, Morgan Stanley Bank, N.A., asInitial Note A-1B Holder, Morgan Stanley Bank, N.A., as Initial Note A-1CHolder, and Morgan Stanley Bank, N.A., as Initial Note A-2 Holder (filed asExhibit 4.8 to the registrant’s Current Report on Form 8-K filed on February25, 2016 under Commission File No. 333-206847-01 and incorporated by referenceherein).

31           Rule 13a-14(d)/15d-14(d) Certifications.

33           Reports on assessment of compliance with servicing criteria for asset-backedsecurities.

 

33.1        Wells Fargo Bank,National Association, as Master Servicer

33.2        C-III Asset ManagementLLC, as Special Servicer

33.3        U.S. Bank National Association, as Trustee (Omitted. SeeExplanatory Notes.)

33.4        Wells Fargo Bank,National Association, as Certificate Administrator

33.5        Wells Fargo Bank,National Association, as Custodian

33.6        Park Bridge LenderServices LLC, as Operating Advisor

33.7        CoreLogic CommercialReal Estate Services, Inc., as Servicing Function Participant

33.8        National Tax Search, LLC,as Servicing Function Participant

33.9        Wells Fargo Bank,National Association, as Primary Servicer of the Princeton Pike CorporateCenter Mortgage Loan (see Exhibit 33.1) 

33.10       C-III Asset Management LLC,as Special Servicer of the Princeton Pike Corporate Center Mortgage Loan (seeExhibit 33.2) 

33.11       U.S. Bank National Association, as Trustee of the PrincetonPike Corporate Center Mortgage Loan (Omitted. See Explanatory Notes.)

33.12       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the Princeton Pike CorporateCenter Mortgage Loan (see Exhibit 33.4) 

33.13       Wells Fargo Bank, NationalAssociation, as Custodian of the Princeton Pike Corporate Center Mortgage Loan(see Exhibit 33.5) 

33.14       Park Bridge Lender ServicesLLC, as Operating Advisor of the Princeton Pike Corporate Center Mortgage Loan(see Exhibit 33.6) 

33.15       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Princeton PikeCorporate Center Mortgage Loan (see Exhibit 33.7) 

33.16       National Tax Search, LLC, asServicing Function Participant of the Princeton Pike Corporate Center MortgageLoan (see Exhibit 33.8) 

33.17       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Le Meridien Cambridge MIT Mortgage Loan(see Exhibit 33.1) 

33.18       C-III Asset Management LLC,as Special Servicer of the Le Meridien Cambridge MIT Mortgage Loan (see Exhibit33.2) 

33.19       U.S. Bank National Association, as Trustee of the Le MeridienCambridge MIT Mortgage Loan (Omitted. See Explanatory Notes.)

33.20       Wells Fargo Bank, National Association,as Certificate Administrator of the Le Meridien Cambridge MIT Mortgage Loan(see Exhibit 33.4) 

33.21       Wells Fargo Bank, NationalAssociation, as Custodian of the Le Meridien Cambridge MIT Mortgage Loan (seeExhibit 33.5) 

33.22       Park Bridge Lender ServicesLLC, as Operating Advisor of the Le Meridien Cambridge MIT Mortgage Loan (seeExhibit 33.6) 

33.23       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Le MeridienCambridge MIT Mortgage Loan (see Exhibit 33.7) 

33.24       National Tax Search, LLC, asServicing Function Participant of the Le Meridien Cambridge MIT Mortgage Loan(see Exhibit 33.8) 

33.25       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the University West Apartments MortgageLoan (see Exhibit 33.1) 

33.26       CWCapital Asset Management LLC, as Special Servicer of theUniversity West Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

33.27       Wilmington Trust, National Association, as Trustee of theUniversity West Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

33.28       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the University West ApartmentsMortgage Loan (see Exhibit 33.4) 

33.29       Wells Fargo Bank, NationalAssociation, as Custodian of the University West Apartments Mortgage Loan (seeExhibit 33.5) 

33.30       Situs Holdings, LLC, asTrust Advisor of the University West Apartments Mortgage Loan

33.31       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the University WestApartments Mortgage Loan (see Exhibit 33.7) 

33.32       National Tax Search, LLC, asServicing Function Participant of the University West Apartments Mortgage Loan(see Exhibit 33.8) 

33.33       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the EllentonPremium Outlets Mortgage Loan

33.34       Rialto Capital Advisors,LLC, as Special Servicer of the Ellenton Premium Outlets Mortgage Loan

33.35       Wells Fargo Bank, NationalAssociation, as Trustee and Certificate Administrator of the Ellenton PremiumOutlets Mortgage Loan (see Exhibit 33.4) 

33.36       Wells Fargo Bank, NationalAssociation, as Custodian of the Ellenton Premium Outlets Mortgage Loan (seeExhibit 33.5) 

33.37       Situs Holdings, LLC, asOperating Advisor of the Ellenton Premium Outlets Mortgage Loan (see Exhibit33.30) 

33.38       KeyBank National Association,as Primary Servicer of the GLP Industrial Portfolio A Mortgage Loan

33.39       AEGON USA Realty Advisors,LLC, as Special Servicer of the GLP Industrial Portfolio A Mortgage Loan

33.40       Wells Fargo Bank, NationalAssociation, as Trustee and Certificate Administrator of the GLP IndustrialPortfolio A Mortgage Loan (see Exhibit 33.4) 

33.41       Wells Fargo Bank, NationalAssociation, as Custodian of the GLP Industrial Portfolio A Mortgage Loan (seeExhibit 33.5) 

33.42       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Penn Square Mall Mortgage Loan (seeExhibit 33.1) 

33.43       Wells Fargo Bank, NationalAssociation, as Special Servicer of the Penn Square Mall Mortgage Loan (seeExhibit 33.1) 

33.44       Wilmington Trust, National Association, as Trustee of the PennSquare Mall Mortgage Loan (Omitted. See Explanatory Notes.)

33.45       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the Penn Square Mall Mortgage Loan(see Exhibit 33.4) 

33.46       Wells Fargo Bank, NationalAssociation, as Custodian of the Penn Square Mall Mortgage Loan (see Exhibit33.5) 

33.47       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Penn SquareMall Mortgage Loan (see Exhibit 33.7) 

33.48       National Tax Search, LLC, asServicing Function Participant of the Penn Square Mall Mortgage Loan (seeExhibit 33.8) 

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

 

34.1        Wells Fargo Bank,National Association, as Master Servicer

34.2        C-III Asset Management LLC,as Special Servicer

34.3        U.S. Bank National Association, as Trustee (Omitted. SeeExplanatory Notes.)

34.4        Wells Fargo Bank,National Association, as Certificate Administrator

34.5        Wells Fargo Bank,National Association, as Custodian

34.6        Park Bridge LenderServices LLC, as Operating Advisor

34.7        CoreLogic CommercialReal Estate Services, Inc., as Servicing Function Participant

34.8        National Tax Search,LLC, as Servicing Function Participant

34.9        Wells Fargo Bank,National Association, as Primary Servicer of the Princeton Pike CorporateCenter Mortgage Loan (see Exhibit 34.1) 

34.10       C-III Asset Management LLC,as Special Servicer of the Princeton Pike Corporate Center Mortgage Loan (seeExhibit 34.2) 

34.11       U.S. Bank National Association, as Trustee of the PrincetonPike Corporate Center Mortgage Loan (Omitted. See Explanatory Notes.)

34.12       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the Princeton Pike CorporateCenter Mortgage Loan (see Exhibit 34.4) 

34.13       Wells Fargo Bank, NationalAssociation, as Custodian of the Princeton Pike Corporate Center Mortgage Loan(see Exhibit 34.5) 

34.14       Park Bridge Lender ServicesLLC, as Operating Advisor of the Princeton Pike Corporate Center Mortgage Loan(see Exhibit 34.6) 

34.15       CoreLogic Commercial Real EstateServices, Inc., as Servicing Function Participant of the Princeton PikeCorporate Center Mortgage Loan (see Exhibit 34.7) 

34.16       National Tax Search, LLC, asServicing Function Participant of the Princeton Pike Corporate Center MortgageLoan (see Exhibit 34.8) 

34.17       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Le Meridien Cambridge MIT Mortgage Loan(see Exhibit 34.1) 

34.18       C-III Asset Management LLC,as Special Servicer of the Le Meridien Cambridge MIT Mortgage Loan (see Exhibit34.2) 

34.19       U.S. Bank National Association, as Trustee of the Le Meridien CambridgeMIT Mortgage Loan (Omitted. See Explanatory Notes.)

34.20       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the Le Meridien Cambridge MITMortgage Loan (see Exhibit 34.4) 

34.21       Wells Fargo Bank, NationalAssociation, as Custodian of the Le Meridien Cambridge MIT Mortgage Loan (seeExhibit 34.5) 

34.22       Park Bridge Lender ServicesLLC, as Operating Advisor of the Le Meridien Cambridge MIT Mortgage Loan (seeExhibit 34.6) 

34.23       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Le MeridienCambridge MIT Mortgage Loan (see Exhibit 34.7) 

34.24       National Tax Search, LLC, asServicing Function Participant of the Le Meridien Cambridge MIT Mortgage Loan(see Exhibit 34.8) 

34.25       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the University West Apartments MortgageLoan (see Exhibit 34.1) 

34.26       CWCapital Asset Management LLC, as Special Servicer of theUniversity West Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

34.27       Wilmington Trust, National Association, as Trustee of theUniversity West Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

34.28       Wells Fargo Bank, National Association,as Certificate Administrator of the University West Apartments Mortgage Loan(see Exhibit 34.4) 

34.29       Wells Fargo Bank, NationalAssociation, as Custodian of the University West Apartments Mortgage Loan (seeExhibit 34.5) 

34.30       Situs Holdings, LLC, asTrust Advisor of the University West Apartments Mortgage Loan

34.31       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the University WestApartments Mortgage Loan (see Exhibit 34.7) 

34.32       National Tax Search, LLC, asServicing Function Participant of the University West Apartments Mortgage Loan(see Exhibit 34.8) 

34.33       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the EllentonPremium Outlets Mortgage Loan

34.34       Rialto Capital Advisors,LLC, as Special Servicer of the Ellenton Premium Outlets Mortgage Loan

34.35       Wells Fargo Bank, NationalAssociation, as Trustee and Certificate Administrator of the Ellenton PremiumOutlets Mortgage Loan (see Exhibit 34.4) 

34.36       Wells Fargo Bank, NationalAssociation, as Custodian of the Ellenton Premium Outlets Mortgage Loan (seeExhibit 34.5) 

34.37       Situs Holdings, LLC, asOperating Advisor of the Ellenton Premium Outlets Mortgage Loan (see Exhibit34.30) 

34.38       KeyBank NationalAssociation, as Primary Servicer of the GLP Industrial Portfolio A MortgageLoan

34.39       AEGON USA Realty Advisors,LLC, as Special Servicer of the GLP Industrial Portfolio A Mortgage Loan

34.40       Wells Fargo Bank, NationalAssociation, as Trustee and Certificate Administrator of the GLP IndustrialPortfolio A Mortgage Loan (see Exhibit 34.4) 

34.41       Wells Fargo Bank, NationalAssociation, as Custodian of the GLP Industrial Portfolio A Mortgage Loan (seeExhibit 34.5) 

34.42       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Penn Square Mall Mortgage Loan (seeExhibit 34.1) 

34.43       Wells Fargo Bank, NationalAssociation, as Special Servicer of the Penn Square Mall Mortgage Loan (seeExhibit 34.1) 

34.44       Wilmington Trust, National Association, as Trustee of the PennSquare Mall Mortgage Loan (Omitted. See Explanatory Notes.)

34.45       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the Penn Square Mall Mortgage Loan(see Exhibit 34.4) 

34.46       Wells Fargo Bank, NationalAssociation, as Custodian of the Penn Square Mall Mortgage Loan (see Exhibit34.5) 

34.47       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Penn SquareMall Mortgage Loan (see Exhibit 34.7) 

34.48       National Tax Search, LLC, asServicing Function Participant of the Penn Square Mall Mortgage Loan (seeExhibit 34.8) 

35           Servicer compliance statements.

 

35.1        Wells Fargo Bank,National Association, as Master Servicer

35.2        C-III Asset ManagementLLC, as Special Servicer

35.3        Wells Fargo Bank,National Association, as Certificate Administrator

35.4        Wells Fargo Bank,National Association, as Primary Servicer of the Princeton Pike CorporateCenter Mortgage Loan (see Exhibit 35.1) 

35.5        C-III Asset Management LLC,as Special Servicer of the Princeton Pike Corporate Center Mortgage Loan (seeExhibit 35.2) 

35.6        Wells Fargo Bank,National Association, as Certificate Administrator of the Princeton PikeCorporate Center Mortgage Loan (see Exhibit 35.3) 

35.7        Wells Fargo Bank,National Association, as Primary Servicer of the Le Meridien Cambridge MITMortgage Loan (see Exhibit 35.1) 

35.8        C-III Asset ManagementLLC, as Special Servicer of the Le Meridien Cambridge MIT Mortgage Loan (seeExhibit 35.2) 

35.9        Wells Fargo Bank,National Association, as Certificate Administrator of the Le Meridien CambridgeMIT Mortgage Loan (see Exhibit 35.3) 

35.10       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the University West Apartments MortgageLoan

35.11       CWCapital Asset Management LLC, as Special Servicer of theUniversity West Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

35.12       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the University West ApartmentsMortgage Loan (see Exhibit 35.3) 

35.13       Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the Ellenton Premium Outlets Mortgage Loan(Omitted. See Explanatory Notes.)

35.14       Rialto Capital Advisors, LLC, as Special Servicer of theEllenton Premium Outlets Mortgage Loan (Omitted. See Explanatory Notes.)

35.15       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the Ellenton Premium OutletsMortgage Loan (see Exhibit 35.3) 

35.16       KeyBank National Association, as Primary Servicer of the GLPIndustrial Portfolio A Mortgage Loan (Omitted. See Explanatory Notes.)

35.17       AEGON USA Realty Advisors, LLC, as Special Servicer of the GLPIndustrial Portfolio A Mortgage Loan (Omitted. See Explanatory Notes.)

35.18       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the GLP Industrial Portfolio AMortgage Loan (see Exhibit 35.3) 

35.19       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Penn Square Mall Mortgage Loan

35.20       Wells Fargo Bank, NationalAssociation, as Special Servicer of the Penn Square Mall Mortgage Loan

35.21       Wells Fargo Bank, NationalAssociation, as Certificate Administrator of the Penn Square Mall Mortgage Loan(see Exhibit 35.3) 

99.1        MortgageLoan Purchase Agreement, dated as of February 12, 2016, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and Bank of America, NationalAssociation (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K filed on February 25, 2016 under Commission File No. 333-206847-01 andincorporated by reference herein)

99.2        MortgageLoan Purchase Agreement, dated as of February 12, 2016, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.2 to the registrant’s Current Report on Form8-K filed on February 25, 2016 under Commission File No. 333-206847-01 andincorporated by reference herein)

99.3        MortgageLoan Purchase Agreement, dated as of February 12, 2016, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and CIBC Inc. (filed as Exhibit 99.3 tothe registrant’s Current Report on Form 8-K filed on February 25, 2016 underCommission File No. 333-206847-01 and incorporated by reference herein)

99.4        MortgageLoan Purchase Agreement, dated as of February 12, 2016, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc., Starwood Mortgage Funding III LLC, andStarwood Mortgage Capital LLC (filed as Exhibit 99.4 to the registrant’sCurrent Report on Form 8-K filed on February 25, 2016 under Commission File No.333-206847-01 and incorporated by reference herein)

(b)   The exhibits required to be filed by theRegistrant pursuant to Item 601 of Regulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

Pursuant to the requirements of Section 13 or 15(d) of theSecurities Exchange Act of 1934, the registrant has duly caused this report tobe signed on its behalf by the undersigned, thereunto duly authorized.

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

Leland F.Bunch, III, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 21, 2019