(logo)SABAL

 

SABALCAPITAL PARTNERS, LLC 

465NORTH HALSTEAD STREET│ SUITE 105

PASADENA│CALIFORNIA 91107

 

P877.900.6272 │ F 888.611.9030

 

WWW.SABAL.COM

 

 

**Management’sReport on Assessment of Compliance with SEC Regulation AB**

**ServicingCriteria**

 

1.       Sabal CapitalPartners, LLC (the “Company” or “Sabal”) is responsible for assessingcompliance with the servicing criteria applicable to it under paragraph (d) ofItem 1122 of Regulation AB as of and for the year ended December 31, 2021, (the“specified period”), as set forth in Appendix A hereto. The transactionscovered by this report include Commercial Mortgage Backed Securities LoansPlatform specified in Appendix B for which Sabal acted as servicer (the“Platform”).

 

2.       Exceptas set forth in paragraph 3 below, Sabal used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to assess the compliance with theapplicable servicing criteria.

 

3.       Thecriteria listed in the column titled “Inapplicable Servicing Criteria” inAppendix A hereto are inapplicable to Sabal based on the activities itperformed, directly or through its Vendors, with respect to the Platform forthe specified period.

 

4.       Sabalhas engaged certain unrelated third party vendors (the “Vendors”), none of whomare considered a “servicer” as defined in Item 1101(j) of Regulation AB, toperform specific activities and Sabal elects to take responsibility forassessing compliance with the servicing criteria or portion of the servicing criteriaapplicable to such Vendors’ activities as identified in Appendix A hereto.Sabal has policies and procedures in place designed to provide reasonableassurance that the Vendors’ activities comply in all material respects with theservicing criteria applicable to such Vendors.

 

5.       Withrespect to applicable servicing criteria 1122(d)(2)(iii), 1122(d)(4)(iii),1122(d)(4)(vi–ix), and 1122(d)(4)(xiv), there were no occurrences that wouldrequire Sabal to perform servicing activities related to the Platform duringthe specified period.

 

6.       Sabalhas complied, in all material respects, with the applicable servicing criteriafor the specified period with respect to the Platform taken as a whole.

 

7.       Grant ThorntonLLP, an independent registered public accounting firm, has issued anattestation report on Sabal’s assessment of compliance with the applicableservicing criteria for the specified period.

 

SabalCapital Partners, LLC 

March7, 2022

 

By:/s/ Joe Garcia

JoeGarcia, Chief Financial Officer

 

 

**AppendixA**

 

|  

**SERVICING  CRITERIA**                   | ** **

**APPLICABLE  SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**INAPPLICABLE  SERVICING CRITERIA**                   |
|---------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------|
| ** **

** **

** **

**Reference** | ** **

** **

** **

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

** **

**Performed  directly**

**by**

**Sabal** | ** **

**Performed by  Vendor(s) for**

**which Sabal is**

**the**

**Responsible**

**Party** | **Performed by  subservicer(s)**

**or vendor(s)**

**for which**

**Sabal is NOT**

**the**

**Responsible**

**Party** | **NOT**

**performed by  Sabal or by subservicer(s)**

**or vendor(s)  retained**

**by Sabal** |
| **General  Servicing Considerations**             |
|  

1122(d)(1)(i)                             | Policies  and procedures are instituted to monitor any performance or other triggers  and events of default in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                                                  |   |   |   |
|  

1122(d)(1)(ii)                            | If  any material servicing activities are outsourced to third parties, policies  and procedures are instituted to monitor the third party’s performance and  compliance with such servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **

**X**                                                  |   |   |   |
| 1122(d)(1)(iii)                                   | Any  requirements in the transaction agreements to maintain a back-up servicer for  the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                               |   |   | **X** |
|  

1122(d)(1)(iv)                            | A  fidelity bond and errors and omissions policy is in effect on the party  participating in the servicing function throughout the reporting period in  the amount of coverage required by and otherwise in accordance with the terms  of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                   | ** **

**X**                                                  |   |   |   |
|  

1122(d)(1)(v)                             |  

An  assessment is conducted of the conveyance and mathematical accuracy of data  that is aggregated by one party and then provided to a servicing party.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

**X**                                                  |   |   |   |
| **Cash  Collection and Administration**           |
|  

1122(d)(2)(i)                             | Payments  on pool assets are deposited into the appropriate custodial bank accounts and  related bank clearing accounts no more than two business days of receipt, or  such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X**                                                  |   |   |   |
| 1122(d)(2)(ii)                                    | Disbursements  made via wire transfer on behalf of an obligor or to an investor are made only  by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | **X**                                                              | **X1** |   |   |
|  

1122(d)(2)(iii)                           | Advances  of funds or guarantees regarding collections, cash flows or distributions,  and any interest or other fees charged for such advances, are made, reviewed  and approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **

**X2**                                                 | ** **

**X3** |   |   |
|  

1122(d)(2)(iv)                            | The  related accounts for the transaction, such as cash reserve accounts or  accounts established as a form of overcollateralization, are separately  maintained (e.g., with respect to commingling of cash) as set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X**                                                  |   |   |   |
|  

 

1122(d)(2)(v)                     | Each  custodial account is maintained at a federally insured depository institution  as set forth in the transaction agreements. For purposes of this criterion,  “federally insured depository institution” with respect to a foreign  financial institution means a foreign financial institution that meets the  requirements of § 240.13k-1(b)(1) of this chapter.                                                                                                                                                                                                                                                                                                                                 | ** **

** **

**X**                                      |   |   |   |
|  

1122(d)(2)(vi)                            | Unissued  checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | ** **

**X**                                                  |   |   |   |
|  

 

 

 

1122(d)(2)(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; (B) Are prepared  within 30 calendar days after the bank statement cutoff date, or such other  number of days specified in the transaction agreements; (C) Are reviewed and  approved by someone other than the person who prepared the reconciliation;  and (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**              |   |   |   |
| **Investor  Remittances and Reporting**           |
|  

 

 

 

1122(d)(3)(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; (B) Provide information calculated  in accordance with the terms specified in the transaction agreements; (C) Are  filed with the Commission as required by its rules and regulations; and (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** |
|  

1122(d)(3)(ii)                            | Amounts  due to investors are allocated and remitted in accordance with timeframes,  distribution priority and other terms set forth in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                               |   |   | ** **

**X** |
|  

1122(d)(3)(iii)                           | Disbursements  made to an investor are posted within two business days to the servicer’s  investor records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                                               |   |   | ** **

**X** |
|  

1122(d)(3)(iv)                            | Amounts  remitted to investors per the investor reports agree with cancelled checks,  or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                                               |   |   | ** **

**X** |
| **Pool  Asset Administration**                    |
|  

1122(d)(4)(i)                             | Collateral  or security on pool assets is maintained as required by the transaction  agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                               | ** **

**X4** |   |   |
| 1122(d)(4)(ii)                                    | Pool  assets and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                               |   |   | **X** |
|  

1122(d)(4)(iii)                           | Any  additions, removals or substitutions to the asset pool are made, reviewed and  approved in accordance with any conditions or requirements in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                                                  |   |   |   |
|  

 

1122(d)(4)(iv)                    | Payments  on pool assets, including any payoffs, made in accordance with the related pool  asset documents are posted to the 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**                                      |   |   |   |
|  

1122(d)(4)(v)                             | The  servicer’s records regarding the pool assets agree with the servicer’s  records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **

**X**                                                  |   |   |   |
|  

1122(d)(4)(vi)                            | Changes  with respect to the terms or status of an obligor’s pool 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**                                                  |   |   |   |
|  

1122(d)(4)(vii)                           | Loss  mitigation or recovery actions (e.g., forbearance plans, modifications and  deeds in lieu of foreclosure, foreclosures and repossessions, as applicable)  are initiated, conducted and concluded in accordance with the timeframes or  other requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                                                  |   |   |   |
|  

 

 

1122(d)(4)(viii)          | Records  documenting collection efforts are maintained during the period a pool asset  is delinquent in accordance with the transaction agreements. Such records are  maintained on at least a monthly basis, or such other period specified in the  transaction agreements, and describe the entity’s activities in monitoring  delinquent pool assets including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or

unemployment).                                                                                                                                                                                            | ** **

** **

** **

**X**                          |   |   |   |
|  

1122(d)(4)(ix)                            | Adjustments  to interest rates or rates of return for pool assets with variable rates are  computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                                                  |   |   |   |
|  

 

 

1122(d)(4)(x)             | Regarding  any funds held in trust for an obligor (such as escrow accounts): (A) Such  funds are analyzed, in accordance with the obligor’s pool asset documents, on  at least an annual basis, or such other period specified in the transaction  agreements; (B) Interest on such funds is paid, or credited, to obligors in  accordance with applicable pool asset documents and state laws; and (C) Such  funds are returned to the obligor within 30 calendar days of full repayment  of the related pool asset, or such other number of days specified in the  transaction agreements.                                                                                                                      | ** **

** **

** **

**X**                          |   |   |   |
|  

 

1122(d)(4)(xi)                    | Payments  made on behalf of an obligor (such as tax or insurance payments) are made on  or before the related penalty or expiration dates, as indicated on the  appropriate bills or notices for such payments, provided that such support  has been received by the servicer at least 30 calendar days prior to these  dates, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                    | ** **

** **

**X**                                      | ** **

** **

**X5** |   |   |
|  

1122(d)(4)(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**                                                  |   |   |   |
|  

1122(d)(4)(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**                                                  |   |   |   |
|  

1122(d)(4)(xiv)                           | Delinquencies,  charge-offs and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **

**X**                                                  |   |   |   |
|  

1122(d)(4)(xv)                            | Any  external enhancement or other support, identified in Item 1114(a)(1) through (3)  or Item 1115 of this Regulation AB, is maintained as set forth in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                               |   |   | ** **

**X** |

 

 

1 In associationwith criterion 1122(d)(2)(ii), Sabal and a third-party vendor performed servicingactivities for which Sabal was the responsible party.

2 Criterion1122(d)(2)(iii) was applicable only to pool asset BBCMS-2021-C11.

3 In associationwith criterion 1122(d)(2)(iii), Sabal and a third-party vendor performedservicing activities for which Sabal was the responsible party.

4 In associationwith criterion 1122(d)(4)(i), a third-party vendor performed servicingactivities for which Sabal was the responsible party.

5 In associationwith criterion 1122(d)(4)(xi), Sabal and a third-party vendor performedservicing activities for which Sabal was the responsible party.

** **

** **

**AppendixB**

 

| Pool asset     | For the  period                 |
|----------------|-----------------------------------------------------------------------------------------------------------------|
| SBALR-2020-RR1 | January  1–December 31, 2021                                                                              |
| BBCMS-2021-C11 | September  1–December 31, 2021                                                                            |