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Ernst& Young LLP 

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**Report of IndependentRegistered Public Accounting Firm**

 

Managementof

ArborMultifamily Lending, LLC

 

Wehave examined management’s assertion, included in the accompanying Management’sReport on Assessment of Compliance with SEC Regulation AB Servicing Criteria (“Management’sReport”), that Arbor Multifamily Lending, LLC (the Company) complied with theservicing criteria set forth in Item 1122 (d) of the Securities and ExchangeCommission’s Regulation AB for the Commercial Mortgage- Backed Securities’loans platform (the “Platform”) as of and for the period ended December 31,2023, except for criteria 1122(d)(1)(iii), 1122(d)(2)(ii), 1122(d)(3)(i)-(iv),1122(d)(4)(ii), 1122(d)(4)(vii), and 1122(d)(xv), which the Company hasdetermined are not applicable to the activities performed by them with respectto the Platform covered by this report. Refer to Appendix B of Management’sReport for the asset backed transactions covered by this Platform. Managementis responsible for the Company’s compliance with those servicing criteria. Ourresponsibility is to express an opinion on management’s assertion about theCompany’s compliance with the servicing criteria based on our examination.

 

Ourexamination was conducted in accordance with attestation standards establishedby the American Institute of Certified Public Accountants and the PublicCompany Accounting Oversight Board (United States) and, accordingly, includedexamining, on a test basis, evidence about the Company’s compliance with theapplicable servicing criteria and performing such other procedures as weconsidered necessary in the circumstances. Our examination included testing ofless than all of the individual asset backed transactions and securities thatcomprise the platform, testing of less than all of the servicing activitiesrelated to the Platform and determining whether the Company processed thoseselected transactions and performed those selected activities in compliancewith the servicing criteria and as permitted by Regulation AB Compliance andDisclosure Interpretations of the Division of Corporation Finance, Section200.06, “Vendors Engaged by Servicers” (C&DI 200.06). Furthermore, ourprocedures were limited to the selected transactions and servicing activitiesperformed by the Company during the period covered by this report. Ourprocedures were not designed to determine whether errors may have occurredeither prior to or subsequent to our tests that may have affected the balancesor amounts calculated or reported by the Company during the period covered bythis report for the selected transactions or any other transactions. Althoughthe Company is responsible for assessing compliance with Item 1122(d)(2)(iii),1122(d)(4)(iii), 1122(d)(4)(vi), 1122(d)(4)(viii)-(ix), 1122(d)(4)(xii) and1122(d)(4)(xiv) of Regulation AB, there were no servicing activities performedby the Company during the period ended December 31, 2023 that required theseservicing criteria to be complied with. We believe that the evidence weobtained is sufficient and appropriate to provide a reasonable basis for ouropinion.

 

Weare required to be independent of Arbor Multifamily Lending, LLC and to meetour other ethical responsibilities, in accordance with the relevant ethicalrequirements related to our examination engagement.

 

Ourexamination does not provide a legal determination on the Company’s compliancewith the servicing criteria.

 

Asdescribed in management’s assertion, for servicing criteria 1122(d)(4)(xi), theCompany has engaged a vendor to perform the activities required by thisservicing criteria. The Company has determined that this vendor is notconsidered a “servicer” as defined in Item 1101(j) of Regulation AB, and theCompany has elected to take responsibility for assessing compliance with theapplicable servicing criteria applicable to each vendor as permitted byC&DI 200.06. As permitted by C&DI 200.06, the Company has asserted thatit has policies and procedures in place designed to provide reasonableassurance that the vendors’ activities comply in all material respects withservicing criteria applicable to each vendor. The Company is solely responsiblefor determining that it meets the SEC requirements to apply C&DI 200.06 forthe vendors and related criteria as described in its assertion, and weperformed no procedures with respect to the Company’s eligibility to applyC&DI 200.06.

 

Inour opinion, management’s assertion that the Company complied with theservicing criteria set forth in Item 1122 (d) of the Securities and ExchangeCommission’s Regulation AB, including servicing criteria 1122(d)(4)(xi) forwhich compliance is determined based on C&DI 200.06 as described above, asof and for the period ended December 31, 2023 for the Platform, is fairlystated, in all material respects.

 

 

/s/Ernst & Young LLP 

NewYork, New York 

February15, 2024