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**GRANT THORNTON LLP**

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Kansas City, MO 64106

 

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**REPORT OF INDEPENDENT REGISTERED PUBLICACCOUNTING FIRM**

 

 

Board of Directors

 

Sabal Capital Partners, LLC

 

We have examined management’s assertion,included in the accompanying Management’s Report on Assessment of Compliancewith SEC Regulation AB Servicing Criteria (“Management’s Report”), that SabalCapital Partners, LLC (the “Company”) complied with the servicing criteria setforth in Item 1122(d) of the U.S. Securities and Exchange Commission’sRegulation AB for the Commercial Mortgage Backed Securities Loans Platform (the“Platform”) as of and for the year ended December 31, 2021, excluding criteria1122(d)(1)(iii), 1122(d)(3)(i–iv), 1122(d)(4)(ii), and 1122(d)(4)(xv), whichmanagement has determined are not applicable to the activities performed by theCompany with respect to the Platform. The Platform consists of the asset-backedtransactions and securities defined by management in Appendix B of Management’sReport. Management is responsible for the Company’s compliance with theapplicable servicing criteria. Our responsibility is to express an opinion onmanagement’s assertion about the Company’s compliance with the applicableservicing criteria for the Platform based on our examination.

 

Our examination was conducted inaccordance with the standards of the Public Company Accounting Oversight Board(United States) and in accordance with attestation standards established by theAmerican Institute of Certified Public Accountants, and, accordingly, includedexamining, on a test basis, evidence about the Company’s compliance with theapplicable servicing criteria for the Platform and performing such other proceduresas we considered necessary in the circumstances. Our examination includedtesting selected asset-backed transactions and securities constituting thePlatform and evaluating whether the Company performed servicing activitiesrelated to those transactions and securities in compliance with the applicableservicing criteria for the period covered by this report. Accordingly, ourtesting may not have included servicing activities related to each asset-backedtransaction or security constituting the Platform. Further, our examination wasnot designed to detect material noncompliance that may have occurred prior tothe period covered by this report and that may have affected the Company’sservicing activities during the period covered by this report. We believe thatour examination provides a reasonable basis for our opinion. Our examinationdoes not provide a legal determination on the Company’s compliance with theapplicable servicing criteria.

 

As described in Management’s Report, theCompany engaged various vendors to perform servicing activities with respect tocriteria 1122(d)(2)(ii), 1122(d)(2)(iii), 1122(d)(4)(i), and 1122(d)(4)(xi).The Company determined that each vendor is not considered a “servicer,” as thatterm is defined in Item 1101(j) of Regulation AB, and therefore, the Company isassuming responsibility for compliance with such servicing criteria applicableto each vendor’s servicing activities. In accordance with Regulation AB and itsrelated interpretations, the requirement for management to assess compliancewith the servicing criteria applicable to a vendor’s activities is satisfied ifthe Company has instituted policies and procedures to monitor whether suchvendor’s activities comply in all material respects with such criteria. Compliancewith the applicable servicing criteria is achieved if those policies andprocedures are designed to provide reasonable assurance that such vendor’sactivities comply with such criteria and those policies and procedures areoperating effectively for the period covered by Management’s Report. Ourexamination does not provide a legal determination of whether a vendor is or isnot considered a servicer, and therefore, on whether the Company, in itsManagement Report, is eligible to elect to take responsibility for assessingcompliance with the servicing criteria applicable to each vendor’s servicingactivities.

 

In our opinion, management’s assertionthat Sabal Capital Partners, LLC complied with the aforementioned applicableservicing criteria as of and for the year ended December 31, 2021 for theCommercial Mortgage Backed Securities Loans Platform is fairly stated, in allmaterial respects.

 

/s/ Grant Thornton LLP

 

Kansas City, Mo. 

March 7, 2022