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**REPORT OFINDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

 

 

Boardof Directors

SabalCapital Partners, LLC

 

Wehave examined management’s assertion, included in the accompanying Management’sReport on Assessment of Compliance with SEC Regulation AB Servicing Criteria(“Management’s Report”), that Sabal Capital Partners, LLC (the “Company”)complied with the servicing criteria set forth in Items 1117 and 1122(d) of theU.S. Securities and Exchange Commission’s Regulation AB for the CommercialMortgage-Backed Securities Loans Platform (the “Platform”) as of and for theyear ended December 31, 2022, excluding criteria 1122(d)(1)(iii),1122(d)(3)(i–iv), 1122(d)(4)(ii), and 1122(d)(4)(xv), which management hasdetermined are not applicable to the activities performed by the Company withrespect to the Platform. The Platform consists of the asset-backed transactionsand securities defined by management in Appendix B of Management’s Report.Management is responsible for the Company’s compliance with the applicableservicing criteria. Our responsibility is to express an opinion on management’sassertion about the Company’s compliance with the applicable servicing criteriafor the Platform based on our examination.

 

Ourexamination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants, and, accordingly, included examining, on a test basis, evidenceabout the Company’s compliance with the applicable servicing criteria for thePlatform and performing such other procedures as we considered necessary in thecircumstances. Our examination included testing selected asset-backedtransactions and securities constituting the Platform and evaluating whetherthe Company performed servicing activities related to those transactions andsecurities in compliance with the applicable servicing criteria for the periodcovered by this report. Accordingly, our testing may not have includedservicing activities related to each asset-backed transaction or securityconstituting the Platform. Further, our examination was not designed to detectmaterial noncompliance that may have occurred prior to the period covered bythis report and that may have affected the Company’s servicing activitiesduring the period covered by this report. We believe that our examinationprovides a reasonable basis for our opinion. Our examination does not provide alegal determination on the Company’s compliance with the applicable servicingcriteria.

 

Weare required to be independent and to meet our other ethical responsibilitiesin accordance with relevant ethical requirements relating to the engagement.

 

Asdescribed in Management’s Report, the Company engaged various vendors toperform servicing activities with respect to criteria 1122(d)(2)(ii), 1122(d)(2)(iii),1122(d)(4)(i), and 1122(d)(4)(xi). The Company determined that each vendor isnot considered a “servicer,” as that term is defined in Item 1101(j) ofRegulation AB, and therefore, the Company is assuming responsibility forcompliance with such servicing criteria applicable to each vendor’s servicingactivities. In accordance with Regulation AB and its related interpretations,the requirement for management to assess compliance with the servicing criteriaapplicable to a vendor’s activities is satisfied if the Company has institutedpolicies and procedures to monitor whether such vendor’s activities comply inall material respects with such criteria. Compliance with the applicableservicing criteria is achieved if those policies and procedures are designed toprovide reasonable assurance that such vendor’s activities comply with suchcriteria and those policies and procedures are operating effectively for theperiod covered by Management’s Report. Our examination does not provide a legaldetermination of whether a vendor is or is not considered a servicer, andtherefore, on whether the Company, in its Management Report, is eligible toelect to take responsibility for assessing compliance with the servicingcriteria applicable to each vendor’s servicing activities.

 

Inour opinion, management’s assertion that Sabal Capital Partners, LLC compliedwith the aforementioned applicable servicing criteria as of and for the yearended December 31, 2022 for the Commercial Mortgage Backed Securities LoansPlatform is fairly stated, in all material respects.

 

 

/s/Grant Thornton LLP

KansasCity, Missouri 

February24, 2023

 

 

**GT.COM**

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