MANAGEMENT’S ASSERTION ON COMPLIANCE WITH

APPLICABLE REGULATION AB SERVICING CRITERIA

 

 

Mount Street US (Georgia) LLP(the “Asserting Party”) is responsible for assessing compliance for thetransactions listed on Appendix A for the period January 1, 2023 throughDecember 31, 2023 (the “Reporting Period”), with the servicing criteria setforth in Title 17, Section 229.1122(d) of the Code of Federal Regulations (the“CFR”), except for the servicing criteria which the Asserting Party hasconcluded are not applicable, as indicated on Appendix B attached hereto (the“Applicable Servicing Criteria”), to the servicing of the transactions listedon Appendix A, backed by commercial real estate mortgage loans and serviced bythe Asserting Party. 

 

The Asserting Party hasassessed compliance with the Applicable Servicing Criteria for the ReportingPeriod and has concluded that the Asserting Party has complied, in all materialrespects, with the Applicable Servicing Criteria for the transactions listed onAppendix A backed by commercial real estate mortgage loans serviced by theAsserting Party.

 

The Asserting Party hasengaged certain vendors to perform specific, limited activities related to the Applicable Servicing Criteria1. The Asserting Partyhas determined that any such vendor is not a “servicer” as defined in Item1101(j) of Regulation AB, and the Asserting Party has elected to takeresponsibility for assessing compliance with any portion of the ApplicableServicing Criteria performed by any such vendor as permitted by Regulation ABCompliance and Disclosure Interpretations of the Division of CorporationFinance, Section 200.06, “Vendors Engaged by Servicers” C&DI 200.06. Aspermitted by C&DI 200.06, the Asserting Party asserts that it has policiesand procedures in place designed to provide reasonable assurance that thevendors’ activities comply in all material respects with servicing criteriaapplicable to the vendor and that the Asserting Party is not aware of anymaterial deficiency in such policies and procedures nor of any materialinstance of noncompliance by any such vendors with respect to the ApplicableServicing Criteria. The Asserting Party is solely responsible for determiningthat it meets the SEC requirements to apply C&DI 200.06 for any such vendorand related criteria.

 

Marcum LLP, an independentregistered public accounting firm, has issued an attestation report on theassessment of compliance with the Applicable Servicing Criteria for theReporting Period as set forth in this assertion.

 

 

Mount Street US (Georgia) LLP 

 

Date: February 29, 2024

 

By: /s/ Greg Chastin

Greg Chastin

Managing Director

 

 

1 1122(d)(2)(i) and 1122(d)(2)(vii)

 

 

Appendix A

 

| **Commercial Mortgage Pass Through Certificates** | **Applicable Reporting Period**        | **MSUS Role**    |
|---------------------------------------------------|----------------------------------------|------------------|
| BX TRUST2019-MMP                                  | January 1, 2023 to January 31, 2023    | Special Servicer |
| BAMMLL 2021-JACX                                  | January 1, 2023 to December 31, 2023   | Special Servicer |
| HMH 2017-NSS                                      | January 1, 2023 to December 31, 2023   | Special Servicer |
| MSBAM 2015-C21                                    | January 1, 2023 to December 31, 2023   | Special Servicer |
| NCMS 2018-FL1                                     | January 1, 2023 to December 31, 2023   | Special Servicer |
| COMM 2015-CCRE23                                  | January 1, 2023 to December 31, 2023   | Special Servicer |
| JPMC 2013-C16                                     | January 1, 2023 to December 31, 2023   | Special Servicer |
| BANK 2018-BNK13                                   | January 1, 2023 to December 31, 2023   | Special Servicer |
| CGCMT 2023-SMART                                  | May 24, 2023 to December 31, 2023      | Special Servicer |
| CGCMT 2023-PRM3                                   | June 29, 2023 to December 31, 2023     | Special Servicer |
| COAST 2023-2HTL                                   | July 25, 2023 to December 31, 2023     | Special Servicer |
| GSMS 2023-SHIP                                    | August 23, 2023 to December 31, 2023   | Special Servicer |
| UBS 2019-C16                                      | October 30, 2023 to December 31, 2023  | Special Servicer |
| BBCMS 2019-BWAY                                   | November 6, 2023 to December 31, 2023  | Special Servicer |
| BX 2023-XL3                                       | December 21, 2023 to December 31, 2023 | Special Servicer |

** **

 

**Appendix B**

** **

**Servicing Criteria to Be Addressed in Assessment ofCompliance**

** **

| ** **

**Reference** | ** **

**Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | **Applicable:  Performed by Servicer** | **Inapplicable  Servicing Criteria** |
|---------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------|--------------------------------------|
|                      | **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)             | Aggregation of information, as applicable, is mathematically accurate and  the information conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                   | 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 following 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                                    |
| 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.                                                                                                                                                                                                                                                                                                | X1                                     |                                 |
| 1122(d)(2)(iv)            | The related accounts for the transaction, such as cash reserve  accounts or accounts established as a form of over collateralization, 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 Rule 240.13k-1(b)(1) of the Securities Exchange  Act.                                                                                                                       | 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 are:                                                                                                                                                                                                                                                                                                                       |                                   |                                 |
|                      | (A) mathematically accurate;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | X                                      |                                 |
|                      | (B) prepared within 30 calendar days after the bank statement  cutoff date, or such other number of days specified in the transaction  agreements;                                                                                                                                                                                                                                                                                                                                                                         | X                                      |                                 |
|                      | (C) reviewed and approved by someone other than the person  who prepared the reconciliation; and                                                                                                                                                                                                                                                                                                                                                                                                                           | X                                      |                                 |
|                      | (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;                                                                                                                                                                                                                                                                                                                                                                                                                   |                                   | X                                    |
|                      | (B) provide information calculated in accordance with  the terms specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                  |                                   | X                                    |
|                      | (C) are filed with the Commission as required by its rules  and regulations;                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                   | X                                    |
|                      | (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.                                                                                                                                                                                                                                                                                                                                                                                            | X                                      |                                 |
| 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  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  assets (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;                                                                                                                                                                                                                                                                                                 |                                   | X                                    |
|                      | (B)       interest on such funds is paid,  or credited, to obligors in accordance with applicable pool asset documents  and state laws;and                                                                                                                                                                                                                                                                                                                                                   |                                   | X                                    |
|                      | (C)       such funds are returned to the  obligor within 30 calendar days of full repayment of the related pool assets,  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                                    |
| 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 Regulation AB, is maintained as set  forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                            |                                   | X                                    |

 

 

1 No transactions occurred with respect to this criteria.