(logo)SABAL

 

SABALCAPITAL PARTNERS, LLC 

465NORTH HALSTEAD STREET│ SUITE 105

PASADENA│CALIFORNIA 91107

 

P877.900.6272 │ F 888.611.9030

 

WWW.SABAL.COM

 

 

**Management’s Reporton Assessment of Compliance with SEC Regulation AB Servicing Criteria**

** **

1.     Sabal Capital Partners, LLC (the “Company” or “Sabal”) is responsible forassessing compliance with the servicing criteria applicable to it for Item 1117and paragraph (d) of Item 1122 of Regulation AB as of and for the year endedDecember 31, 2022, (the “specified period”), as set forth in Appendix A hereto.The transactions covered by this report include Commercial Mortgage-BackedSecurities Loans within the asset pools specified in Appendix B for which Sabalacted as servicer (the “Platform”).

 

2.     Except as set forth in paragraph 4 below, Sabal used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to assess the compliance with theapplicable servicing criteria.

 

3.     Pursuant to Item 1117 of Regulation AB (defined in Appendix A), the Company hasdetermined that, during the reporting period, there were no pending legalproceedings or proceedings by governmental authorities against the Company thatare material to security holders of individual asset-backed securities listedin Appendix B;

 

4.     The criteria 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.

 

5.     Sabal has engaged certain unrelated third-party vendors (the “Vendors”), noneof whom are considered a “servicer” as defined in Item 1101(j) of RegulationAB, to perform specific activities and Sabal elects to take responsibility forassessing compliance with the servicing criteria or portion of the servicingcriteria applicable to such Vendors’ activities as identified in Appendix Ahereto. Sabal has policies and procedures in place designed to providereasonable assurance that the Vendors’ activities comply in all materialrespects with the servicing criteria applicable to such Vendors.

 

6.     With respect 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 transactions related tothe Platform that would require Sabal to perform servicing activities relevantto the criteria during the specified period.

 

7.     Sabal has complied, in all material respects, with the applicable servicingcriteria for the specified period with respect to the Platform taken as awhole.

 

8.     Grant Thornton LLP, an independent registered public accounting firm, hasissued an attestation report on Sabal’s assessment of compliance with theapplicable servicing criteria for the specified period.

 

SabalCapital Partners, LLC 

February24, 2023

 

By:/s/ Joe Garcia

JoeGarcia, Chief Financial Officer

 

 

**Appendix A —servicing criteria**

** **

| **REGULATION********AB********1117**                        |
|-------------------------------------------------------------|
| **Reference**                                               | **Criteria** |
| ** **

1117                                            | Describebrieflyanylegalproceedingspendingagainstthesponsor,depositor,trustee,issuingentity,servicercontemplated byItem1108(a)(3) ofthisRegulation AB, originator contemplated  by Item 1110(b) of this Regulation AB, or other party contemplated by Item 1100(d)(1)  of this Regulation AB, orofwhichanypropertyoftheforegoingisthesubject,that ismaterialtosecurity  holders.Include similarinformationastoany suchproceedingsknown  to be contemplated by governmental authorities. |
| **REGULATION********AB********1122(d)**                     | **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 anyperformanceorothertriggersandeventsofdefaultinaccordance  with the transaction agreements. | ** **

**X** |   |   |   |
| ** **

1122(d)(1)(ii)                                  | If  any material servicing activities are outsourced to thirdparties, policies and procedures are  instituted to monitor thethirdparty’sperformanceandcompliancewithsuchservicingactivities. | ** **

**X** |   |   |   |
| 1122(d)(1)(iii)                                             | Anyrequirementsinthetransactionagreementstomaintainaback-up servicer  for the pool assets are maintained. |   |   |   | **X** |
| ** **

1122(d)(1)(iv)                                  | A  fidelity bond and errors and omissions policy is in effect onthepartyparticipatingintheservicingfunctionthroughoutthereporting  period in the amount of coverage required by andotherwise in accordance with the terms of the transactionagreements. | ** **

**X** |   |   |   |
| ** **

1122(d)(1)(v)                                   | ** **

An  assessment is conducted of the conveyance andmathematicalaccuracyofdatathatisaggregatedbyonepartyand then provided to a servicing party. | ** **

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

1122(d)(2)(i)                                   | Payments  on pool assets are deposited into the appropriatecustodialbankaccountsandrelatedbankclearingaccountsnomorethantwobusinessdaysofreceipt,orsuchothernumberof days specified in  the transaction agreements. | ** **

**X** |   |   |   |
| 1122(d)(2)(ii)                                              | Disbursementsmadeviawiretransferonbehalfofanobligororto an investor  are made only by authorized personnel. | **X** | **X****1** |   |   |
|  

1122(d)(2)(iii)                                     | Advances  of funds or guarantees regarding collections, cashflowsordistributions,andanyinterestorotherfeeschargedforsuchadvances,aremade,reviewedandapprovedasspecifiedinthe  transaction agreements. |  

**X****2** |  

**X****1** |   |   |
|  

1122(d)(2)(iv)                                      | The  related accountsfor the  transaction, such as cash reserveaccounts  or accounts established as a form ofovercollateralization,  are separately maintained (e.g., withrespecttocomminglingofcash)assetforthinthetransactionagreements. |  

**X** |   |   |   |
|  

 

1122(d)(2)(v)                               | Each  custodial account is maintained at a federally insureddepositoryinstitutionassetforthinthetransactionagreements.For  purposes of this criterion, “federally insured depositoryinstitution”withrespectto aforeignfinancialinstitutionmeansa foreign  financial institution that meets the requirements of §240.13k-1(b)(1) of this chapter. |  

 

**X** |   |   |   |
|  

1122(d)(2)(vi)                                      | Unissuedchecksaresafeguardedsoastopreventunauthorizedaccess. |  

**X** |   |   |   |
|  

 

 

 

1122(d)(2)(vii)             | Reconciliations  are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodialaccounts and related bank clearing  accounts. Thesereconciliations:  (A) Are mathematically accurate; (B) Arepreparedwithin30calendardaysafterthebankstatementcutoffdate, or such other number of days  specified in the transactionagreements;  (C) Are reviewed and approved by someone otherthan the person who prepared the reconciliation; and (D)Contain explanations for reconciling  items. These reconcilingitems are  resolved within 90 calendar days of their originalidentification, or such other number of days specified in the  transactionagreements. |  

 

 

 

**X** |   |   |   |
| **Investor********Remittances********and********Reporting** |
|  

 

 

 

1122(d)(3)(i)               | Reports  to investors, including those to be filed with theCommission,aremaintainedinaccordancewiththetransactionagreements and applicable Commission requirements.  Specifically,suchreports:(A)Arepreparedinaccordancewithtimeframes and other terms set forth in the transactionagreements; (B) Provide information  calculated in accordancewiththetermsspecifiedinthetransactionagreements;(C)Arefiled  with the Commission as required by its rules andregulations; and (D) Agree with investors’ or the trustee’srecordsastothetotalunpaidprincipalbalanceand numberof poolassetsserviced bythe servicer. |   |   |   |  

 

 

 

**X** |
|  

1122(d)(3)(ii)                                      | Amounts  due to investors are allocated and remitted inaccordancewithtimeframes,distributionpriorityandotherterms set forth in the  transaction agreements. |   |   |   |  

**X** |
|  

1122(d)(3)(iii)                                     | Disbursements  made to an investor are posted within twobusinessdaystotheservicer’sinvestorrecords,orsuchothernumber of days specified in the  transaction agreements. |   |   |   |  

**X** |
|  

1122(d)(3)(iv)                                      | Amounts remitted to investors per theinvestor reports agreewithcancelledchecks,orotherformofpayment,orcustodialbankstatements. |   |   |   |  

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

1122(d)(4)(i)                                       | Collateralorsecurityonpoolassetsismaintainedasrequiredbythe  transaction agreements or related pool asset documents. |   |  

**X****3** |   |   |
| 1122(d)(4)(ii)                                              | Poolassetsandrelateddocumentsaresafeguardedasrequiredby the transaction agreements. |   |   |   | **X** |
|  

1122(d)(4)(iii)                                     | Anyadditions,removalsorsubstitutionstotheassetpoolaremade, reviewed and approved in  accordance with anyconditions or  requirements in the transaction agreements. |  

**X** |   |   |   |
|  

 

1122(d)(4)(iv)                              | Payments  on pool assets, including any payoffs, made inaccordancewiththerelatedpoolassetdocumentsarepostedtothe  applicable servicer’s obligor records maintained no morethan two business days after receipt, or  such other number ofdays specified  in the transaction agreements, and allocated toprincipal, interest or other items (e.g., escrow) in  accordancewith the related pool  asset documents. |  

 

**X** |   |   |   |
|  

1122(d)(4)(v)                                       | Theservicer’srecordsregardingthepoolassetsagreewiththeservicer’srecordswithrespecttoanobligor’sunpaidprincipalbalance. |  

**X** |   |   |   |
|  

1122(d)(4)(vi)                                      | Changeswithrespecttothetermsorstatusofanobligor’spoolasset (e.g.,  loan modifications or re-agings) are made, reviewedand approved by authorized personnel in accordance with thetransaction agreements and related pool  asset documents. |  

**X** |   |   |   |
|  

1122(d)(4)(vii)                                     | Loss  mitigation or recovery actions (e.g., forbearance plans,modificationsanddeedsinlieuofforeclosure,foreclosuresandrepossessions, as  applicable) are initiated, conducted andconcluded  in accordance with the timeframes or otherrequirements established by the transaction agreements. |  

**X** |   |   |   |
|  

 

 

1122(d)(4)(viii)                    | Records  documenting collection efforts are maintained duringthe period a pool asset is delinquent in accordance with thetransaction agreements. Such records are  maintained on at leasta monthly  basis, or such other period specified in thetransaction agreements, and describe the entity’s activities inmonitoringdelinquentpoolassetsincluding,forexample,phonecalls, letters  and payment rescheduling plans in cases wheredelinquency is deemed temporary (e.g., illness or unemployment). |  

 

 

**X** |   |   |   |
|  

1122(d)(4)(ix)                                      | Adjustments  to interest rates or rates of return for pool assetswithvariableratesarecomputedbasedontherelatedpoolassetdocuments. |  

**X** |   |   |   |
|  

 

 

1122(d)(4)(x)                       | Regardinganyfundsheld intrustforanobligor(suchasescrowaccounts): (A) Such funds are analyzed, in accordance with theobligor’s pool asset documents, on at  least an annual basis, orsuch  other period specified in the transaction agreements; (B)Interest on such funds is paid, or  credited, to obligors inaccordancewithapplicablepoolassetdocumentsandstatelaws;and (C) Such funds are  returned to the obligor within 30calendardaysoffullrepaymentoftherelatedpoolasset,orsuchother number of days specified in the  transaction agreements. |  

 

 

**X** |   |   |   |
|  

 

1122(d)(4)(xi)                              | Payments  made on behalf of an obligor (such as tax orinsurance payments) are made on or before the related penaltyor expiration dates, as indicated on the  appropriate bills ornoticesforsuchpayments,providedthatsuchsupporthasbeenreceived by the servicer at least 30  calendar days prior to thesedates,orsuch  othernumberofdaysspecifiedin thetransactionagreements. |  

 

**X** |  

 

**X****1** |   |   |
|  

1122(d)(4)(xii)                                     | Anylatepaymentpenaltiesinconnectionwithanypaymenttobe  made on behalf of an obligor are paid from the servicer’sfunds and not charged to the obligor,  unless the late paymentwas due to  the obligor’s error or omission. |  

**X** |   |   |   |
|  

1122(d)(4)(xiii)                                    | Disbursementsmadeonbehalfofanobligorarepostedwithintwo business days to the obligor’s records maintained by theservicer, or such other number of days  specified in thetransactionagreements. |  

**X** |   |   |   |
|  

1122(d)(4)(xiv)                                     | Delinquencies,  charge-offs and uncollectible accounts arerecognizedandrecordedinaccordancewiththetransactionagreements. |  

**X** |   |   |   |
|  

1122(d)(4)(xv)                                      | Anyexternalenhancementorothersupport,identifiedinItem1114(a)(1) through (3) or Item 1115 of  this Regulation AB, ismaintained  as set forth in the transaction agreements. |   |   |   |  

**X** |

 

 

1Sabalandathird-partyvendorperformedservicingactivitiesforwhichSabalwastheresponsibleparty.

2Criterion1122(d)(2)(iii)wasapplicableonlytopoolassetsSeries2021-C11,Series2022-C1,andSeries2022-C3.

3Athird-partyvendorperformedservicingactivitiesforwhichSabalwastheresponsibleparty.

 

 

**Appendix********B**

** **

| **Pool****asset** | **For********the****period**    |
|-------------------|---------------------------------|
| Series2020-RR1    | January1–December31,2022  |
| Series2021-C11    | January1–December31,2022  |
| Series2022-C1     | February1–December31,2022 |
| Series2022-C3     | October1–December31, 2022 |