**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****  ANNUAL REPORT PURSUANT TO SECTION13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2019or**

**o**** ****TRANSITIONREPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-195164-08**

**Central Index Key Number of the issuing entity:0001638933**

**Wells Fargo Commercial MortgageTrust 2015-C28**

**(exact name of the issuing entity as specified in itscharter)**

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, Inc.**

**(exact name of the depositor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001592182**

**LMF Commercial, LLC**

**(exact name of the sponsor as specified in its charter)**

**(formerly known as RialtoMortgage Finance, LLC)**** **

** **

**Central Index Key Number of the sponsor: 0001541214**

**C-III Commercial Mortgage LLC**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001542105**

**Basis Real Estate Capital II, LLC**

**(exact name of the sponsor as specified in its charter)**

** **

| **New York****(State or other jurisdiction of  incorporation or organization of**

**the issuing entity)** | **38-3968483**

**38-3968484**

**38-3968485**

**38-7135359**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------|

**c/o Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

**Registrant’s telephone number,including area code:**

**(704) 374-6161**

Securities registered pursuant to Section 12(b) of the Act:

| Title of each class | Trading Symbol(s) | Name of each  exchange on which registered |
|---------------------|-------------------|--------------------------------------------|
| None                |              |                                       |

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

Indicate by check mark whether the registrant has submittedelectronically and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’s knowledge,in definitive proxy or information statements incorporated by reference in PartIII of this Form 10-K or any amendment to this Form 10-K.   

Not applicable.

Indicate by check mark whether the registrant is a large acceleratedfiler, an accelerated filer, a non-accelerated filer, a smaller reportingcompany, or an emerging growth company. See the definitions of “largeaccelerated filer,” “accelerated filer,” “smaller reporting company,” and“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check if asmaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

Indicate by check mark whether the registrant is a shellcompany (as defined in Rule 12b-2 of the Act).  o Yes ⌧ No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

Indicate the number of shares outstanding of each of theregistrant’s classes of common stock, as of the latest practicable date.

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the following documents if incorporated byreference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) intowhich the document is incorporated: (1) Any annual report to security holders;(2) Any proxy or information statement; and (3) Any prospectus filed pursuant toRule 424(b) or (c) under the Securities Act of 1933. The listed documentsshould be clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Eastgate One Phases I-VII & XIIMortgage Loan, the Eastgate Two Phases VIII-X Mortgage Loan and the BrickyardSquare Mortgage Loan, which constituted approximately 6.4%, 5.2% and 2.1%,respectively, of the asset pool of the issuing entity as of its cut-off date,are each an asset of the issuing entity and are each part of a loan combinationthat includes the Eastgate One Phases I-VII & XII Mortgage Loan, theEastgate Two Phases VIII-X Mortgage Loan or the Brickyard Square Mortgage Loanwhich are assets of the issuing entity and one other *pari passu* loan,which is not an asset of the issuing entity. These loan combinations, includingthe Eastgate One Phases I-VII & XII Mortgage Loan, the Eastgate Two PhasesVIII-X Mortgage Loan and the Brickyard Square Mortgage Loan, are being servicedand administered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Commerce Point I & II Mortgage Loan,which constituted approximately 0.9% of the asset pool of the issuing entity asof its cut-off date.  The Commerce Point I & II Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theCommerce Point I & II Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. The other *pari passu*portion of the loan combination was securitized in the Citigroup CommercialMortgage Trust 2015-GC29 transaction, Commission File Number 333-189017-08 (the“CGCMT 2015-GC29 Transaction”). This loan combination, including theCommerce Point I & II Mortgage Loan, is being serviced and administered pursuantto the pooling and servicing agreement for the CGCMT 2015-GC29 Transaction,which is incorporated by reference as Exhibit 4.2 to this Annual Report on Form10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Midland Loan Services, a Divisionof PNC Bank, National Association is the special servicer of the mortgage loansserviced under the Pooling and Servicing Agreement and the primary servicer andspecial servicer of the Commerce Point I & II Mortgage Loan. As a result,Midland Loan Services, a Division of PNC Bank, National Association is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Midland Loan Services, a Division of PNC Bank, National Association in thecapacities described above are listed in the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement.  Pursuant to the Pooling and Servicing Agreement,the trustee is required to provide an assessment of compliance with applicableservicing criteria solely with respect to Item 1122(d)(2)(iii) of Regulation AB(regarding advances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, are made,reviewed and approved as specified in the transaction agreements). However,during the reporting period, the trustee did not perform any servicing functionwith respect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of the mortgage loans serviced underthe Pooling and Servicing Agreement have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Deutsche Bank Trust CompanyAmericas acts as trustee of the Commerce Point I & II Mortgage Loan. Pursuant to the pooling and servicing agreement for the CGCMT 2015-GC29Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe Commerce Point I & II Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer under the Pooling and Servicing Agreement to remit taxpayments received from the escrow accounts of borrowers to local taxingauthorities, to report tax amounts due, to verify tax parcel information, andto verify non-escrow tax payments. These servicing functions are includedwithin the servicing criteria set forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii)of Regulation AB.  Therefore, under the principles-based definition of“servicer” set forth in Item 1101(j) of Regulation AB that looks to thefunctions that an entity performs, these vendors are “servicers” for thepurposes of Item 1122 of Regulation AB.  *See* Compliance andDisclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessment of compliance with applicable servicing criteria, accountants’attestation report and servicer compliance statement of the certificateadministrator of the Commerce Point I & II Mortgage Loan listed on theExhibit Index is omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because it isnot a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu*loan combination that includes the Commerce Point I & II Mortgage Loan, thereports on assessment of compliance with servicing criteria and attestationreports on assessment of compliance with servicing criteria of Deutsche BankTrust Company Americas as custodian of the Commerce Point I & II MortgageLoan and Situs Holdings, LLC as operating advisor of the Commerce Point I &II Mortgage Loan, listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K as they are not required to be included on this AnnualReport on Form 10-K per Instruction 3 to Item 1122 of Regulation AB becausethey are parties performing activities that address servicing criteria relatingto 5% or less of the assets of the issuing entity.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

**Item 1B.  Unresolved Staff Comments.**

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

**Item 5.  Market for Registrant’s Common Equity,Related Stockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

**Item 7.  Management’s Discussion and Analysis ofFinancial Condition and Results of Operations.**

Omitted.

**Item 7A.  Quantitative and Qualitative DisclosuresAbout Market Risk.**

Omitted.

**Item 8.  Financial Statements and Supplementary Data.**

Omitted.

**Item 9.  Changes in and Disagreements WithAccountants on Accounting and Financial Disclosure.**

Omitted.

**Item 9A.  Controls and Procedures.**

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

**Item 10.  Directors, Executive Officers and CorporateGovernance.**

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

**Item 12.  Security Ownership of Certain BeneficialOwners and Management and Related Stockholder Matters.**

Omitted.

**Item 13.  Certain Relationships and RelatedTransactions, and Director Independence.**

Omitted.

**Item 14.  Principal Accounting Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

**Item 1112(b) of Regulation AB, Significant ObligorFinancial Information.**

No single obligor represents 10% or more of the pool assetsheld by the issuing entity. 

**Item 1114(b)(2) of Regulation AB, Significant EnhancementProvider Financial Information.**

No entity or group of affiliated entities provides any external creditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

**Item 1115(b) of Regulation AB, Certain DerivativesInstruments (Financial Information).**

No entity or group of affiliated entities provides anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

**Item 1117 of Regulation AB, Legal Proceedings.**

 

The registrant knows of nomaterial pending legal proceeding involving the trust or any party related tothe trust, other than routine litigation incidental to the duties of thoserespective parties, and the following, with respect to Deutsche Bank TrustCompany Americas, as trustee and as custodian, and Wells Fargo Bank, NationalAssociation, as certificate administrator and as custodian.

 

Deutsche Bank Trust CompanyAmericas (“DBTCA”) and Deutsche Bank National Trust Company (“DBNTC”) have beensued by investors in civil litigation concerning their role as trustees ofcertain RMBS trusts.

 

On June 18, 2014, a group ofinvestors, including funds managed by Blackrock Advisors, LLC, PIMCO-Advisors,L.P., and others, filed an action against DBNTC and DBTCA in New York State SupremeCourt alleging that DBNTC and DBTCA failed to perform purported duties, astrustees for 544 private-label RMBS trusts, to enforce breaches ofrepresentations and warranties as to mortgage loans held by the trusts and toenforce breaches by servicers of their mortgage loan servicing obligations forthe trusts. During the course of the litigation, plaintiffs dismissed the casefrom New York State Supreme Court and refiled two separate cases, one in theU.S. District Court for the Southern District of New York (the “*BlackRock*SDNY Case”) and the other in the Superior Court of California, Orange County(the “*BlackRock*California Case”). Pursuant to a settlement among theparties, the *BlackRock*SDNY Case was dismissed on December 6, 2018 andthe *BlackRock*California Case was dismissed on January 11, 2019.

 

On September 27, 2017, DBTCA wasadded as a defendant to a case brought by certain special purpose entitiesincluding Phoenix Light SF Limited in the U.S. District Court for the SouthernDistrict of New York, in which the plaintiffs previously alleged incorrectlythat DBNTC served as trustee for all 43 of the trusts at issue. On September27, 2017, plaintiffs filed a third amended complaint that names DBTCA as adefendant in addition to DBNTC. DBTCA serves as trustee for one of the 43trusts at issue. DBNTC serves as trustee for the other 42 trusts at issue.Plaintiffs’ third amended complaint brings claims for violation of the U.S.Trust Indenture Act of 1939 (“TIA”); breach of contract; breach of fiduciaryduty; negligence and gross negligence; violation of New York’s Streit Act; andbreach of the covenant of good faith. However, in the third amended complaint,plaintiffs acknowledge that, before DBTCA was added to the case, the courtdismissed plaintiffs’ TIA Act claims, negligence and gross negligence claims,Streit Act claims, claims for breach of the covenant of good faith, and certaintheories of plaintiffs’ breach of contract claims, and plaintiffs only includethese claims to preserve any rights on appeal. Plaintiffs allege damages of“hundreds of millions of dollars.” On November 13, 2017, DBNTC and DBTCA filedan answer to the third amended complaint. On December 7, 2018, DBNTC and DBTCAfiled a motion for summary judgment. Also on December 7, 2018, plaintiffs,jointly with Commerzbank AG (*see*description of *Commerzbank*casebelow), filed a motion for partial summary judgment. As of March 1, 2020, bothmotions for summary judgment have been briefed and are awaiting decision by thecourt.

 

On November 30, 2017, DBTCA wasadded as a defendant to a case brought by Commerzbank AG (“Commerzbank”) in theU.S. District Court for the Southern District of New York, in which Commerzbankpreviously alleged incorrectly that DBNTC served as trustee for all 50 of thetrusts at issue. On November 30, 2017, Commerzbank filed a second amendedcomplaint that names DBTCA as a defendant in addition to DBNTC. DBTCA serves astrustee for 1 of the 50 trusts at issue. DBNTC serves as trustee for the other49 trusts at issue. Commerzbank’s second amended complaint brings claims forviolation of the TIA; breach of contract; breach of fiduciary duty; negligence;violation of the Streit Act; and breach of

the covenant of good faith.However, in the second amended complaint, Commerzbank acknowledges that, beforeDBTCA was added to the case,the court dismissed Commerzbank’s TIA claims forthe trusts governed by pooling and servicing agreements, as well as its StreitAct claims and claims for breach of the covenant of good faith, and Commerzbankonly includes these claims to preserve any rights on appeal. The second amendedcomplaint alleges that DBNTC and DBTCA caused Commerzbank to suffer “hundredsof millions of dollars in losses,” but the complaint does not include a demandfor money damages in a sum certain. On January 29, 2018, DBNTC and DBTCA filedan answer to the second amended complaint. On December 7, 2018, DBNTC and DBTCAfiled a motion for summary judgment. Also on December 7, 2018, Commerzbank,jointly with the *Phoenix Light*plaintiffs, filed a motion for partialsummary judgment. As of March 1, 2020, both motions for summary judgment havebeen briefed and are awaiting decision by the court.

 

On December 30, 2015, IKBInternational, S.A. in Liquidation and IKB Deutsche Industriebank A.G.(collectively, “IKB”), as an investor in 37 RMBS trusts, filed a summons withnotice in the Supreme Court of the State of New York, New York County, againstDBNTC and DBTCA as trustees of the trusts. On May 27, 2016, IKB served its complaintasserting claims for breach of contract, breach of fiduciary duty, breach ofduty to avoid conflicts of interest, violation of the Streit Act, violation ofthe TIA, violation of Regulation AB, and violation of Section 9 of the UniformCommercial Code. IKB alleges that DBNTC and DBTCA are liable for over U.S. $268million in damages. On October 5, 2016, DBNTC and DBTCA, together with severalother trustees defending lawsuits by IKB, filed a joint motion to dismiss. OnJanuary 6, 2017 and June 20, 2017, IKB voluntarily dismissed with prejudice allclaims as to seven trusts. As of March 1, 2020, DBNTC and DBTCA’s motion todismiss has been briefed and is awaiting decision by the court.

 

It is DBTCA’s belief that it hasno pending legal proceedings (including, based on DBTCA’s present evaluation,the litigation disclosed in the foregoing paragraphs) that would materiallyaffect its ability to perform its duties under the related servicing agreementfor this transaction.

 

Beginning on June 18, 2014, agroup of institutional investors filed civil complaints in the Supreme Court ofthe State of New York, New York County, and later the U.S. District Court forthe Southern District of New York, against 

Wells Fargo Bank, N.A., (“WellsFargo Bank”) in its capacity as trustee for certain residential mortgage backedsecurities (“RMBS”) trusts. The complaints against Wells Fargo Bank allegedthat the trustee caused losses to investors and asserted causes of action basedupon, among other things, the trustee's alleged failure to: (i) notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts at issue. OnMay 6, 2019, the court entered an order approving the settlement agreement.Separate lawsuits against Wells Fargo Bank making similar allegations filed bycertain other institutional investors concerning several RMBS trusts in NewYork federal and state court are not covered by the agreement. With respect tosuch litigations, Wells Fargo Bank believes plaintiffs' claims are withoutmerit and intends to contest the claims vigorously, but there can be no assurancesas to the outcome of the litigations or the possible impact of the litigationson Wells Fargo Bank or the RMBS trusts.

**Item 1119 of Regulation AB, Affiliations and CertainRelationships and Related Transactions.**

The information regarding this Item has been previouslyprovided in a prospectus supplement of the Registrant relating to the issuingentity filed on May 21, 2015 pursuant to Rule 424(b)(5).

**Item 1122 of Regulation AB, Compliance with ApplicableServicing Criteria.**

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as ScheduleIII to the Pooling and Servicing Agreement incorporated by reference as Exhibit4.1 to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Commerce Point I & IIMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the CGCMT 2015-GC29 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Oto the pooling and servicing agreement for the CGCMT 2015-GC29 Transactionincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theCGCMT 2015-GC29 Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

 

The report on assessment ofcompliance with applicable servicing criteria furnished pursuant to Item 1122of Regulation AB by Midland Loan Services, a Division of PNC Bank NationalAssociation (“Midland”) discloses that a material instance of noncomplianceoccurred, as described below:

 

Material Instance ofNoncompliance

 

In certaininstances, the Schedule AL Files (Item 1125 of Regulation AB) were not reportedin accordance with the terms specified in the transaction agreements, inconflict with Item 1122(d)(3)(i): “Reports to investors, including those to befiled with the Commission, are maintained in accordance with the transactionagreements and applicable Commission requirements. Specifically, such reports:(A) Are prepared in accordance with timeframes and other terms set forth in thetransaction agreements”. The noncompliance consisted of omitted or inaccuratelyreported fields as described in (1) and (2) below. (1) In connection with otherenhancements Midland made to its manual Schedule AL process, starting in April2019, Midland developed and implemented new Schedule AL reporting templates foreach applicable CMBS transaction that closed prior to April 2019 and for eachapplicable CMBS transaction going forward. Related to this, Midland madecertain template setup errors, along with related and other manual inputting ofinformation errors, and the errors were not identified prior to submission ofthe applicable Schedule AL Files in certain cases due to breakdowns in qualitycontrol. (2) In one applicable transaction, the related Schedule AL File for agiven month was not saved properly resulting in the prior month's Schedule ALFile being submitted for the given month instead of the correct Schedule ALFile.

 

The identifiedinstances did not involve the servicing of assets included in thissecuritization.

 

Steps Taken to Remedy theMaterial Instance of Noncompliance

 

Midland’s ScheduleAL reporting process was enhanced in April of 2019, however, the processremained manual throughout the 2019 calendar year. Errors relating to certainSchedule AL Files during 2019 were identified during the related audit.Following identification, Midland made staffing changes and additionalenhancements and improvements to its processes and procedures to support itsSchedule AL reporting obligations and expects to move to an automated solutionfor this process.

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to beincorrect.

**Item 1123 of Regulation AB, Servicer Compliance Statement.**

The servicer compliance statements are attached as Exhibitsto this Annual Report on Form 10-K.

**PART IV**

**Item 15. Exhibits, Financial Statement Schedules**

(a) The following is a list of documents filed as part ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of May 1, 2015, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer, Pentalpha Surveillance LLC, as TrustAdvisor, Wells Fargo Bank, National Association, as Certificate Administrator,as Tax Administrator and as Custodian, and Wilmington Trust, National Association,as Trustee (filed as Exhibit 4.1 to the registrant’s Current Report on Form8-K/A filed on July 1, 2015 under Commission File No. 333-195164-08 andincorporated by reference herein).

4.2          Poolingand Servicing Agreement, dated as of April 1, 2015, by and among CitigroupCommercial Mortgage Securities Inc., as Depositor, Midland Loan Services, aDivision of PNC Bank, National Association, as Master Servicer, Midland LoanServices, a Division of PNC Bank, National Association, as Special Servicer,Situs Holdings, LLC, as Operating Advisor, Citibank, N.A., as CertificateAdministrator, and Deutsche Bank Trust Company Americas, as Trustee (filed asExhibit 99.5 to the registrant’s Current Report on Form 8-K filed on May 21,2015 under Commission File No. 333-195164-08 and incorporated by referenceherein).

31           Rule 13a-14(d)/15d-14(d)Certifications.

33           Reports on assessment of compliance with servicing criteria for asset-backedsecurities.

33.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

33.2        Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer

33.3        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

33.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.5        Wells Fargo Bank, NationalAssociation, as Custodian

33.6        Pentalpha SurveillanceLLC, as Trust Advisor

33.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

33.8        National Tax Search, LLC,as Servicing Function Participant

33.9        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Eastgate One Phases I-VII & XIIMortgage Loan (see Exhibit 33.1)

33.10      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EastgateOne Phases I-VII & XII Mortgage Loan (see Exhibit 33.2)

33.11      Wilmington Trust, National Association, as Trustee of the Eastgate One PhasesI-VII & XII Mortgage Loan (Omitted. See Explanatory Notes.)

33.12      Wells Fargo Bank, NationalAssociation, as Custodian of the Eastgate One Phases I-VII & XII MortgageLoan (see Exhibit 33.5)

33.13      Pentalpha SurveillanceLLC, as Trust Advisor of the Eastgate One Phases I-VII & XII Mortgage Loan(see Exhibit 33.6)

33.14      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Eastgate OnePhases I-VII & XII Mortgage Loan (see Exhibit 33.7)

33.15      National Tax Search, LLC,as Servicing Function Participant of the Eastgate One Phases I-VII & XIIMortgage Loan (see Exhibit 33.8)

 

33.16       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Eastgate Two Phases VIII-X MortgageLoan (see Exhibit 33.1)

33.17      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EastgateTwo Phases VIII-X Mortgage Loan (see Exhibit 33.2)

33.18      Wilmington Trust, National Association, as Trustee of the Eastgate Two PhasesVIII-X Mortgage Loan (Omitted. See Explanatory Notes.)

33.19      Wells Fargo Bank, NationalAssociation, as Custodian of the Eastgate Two Phases VIII-X Mortgage Loan (seeExhibit 33.5)

33.20      Pentalpha SurveillanceLLC, as Trust Advisor of the Eastgate Two Phases VIII-X Mortgage Loan (seeExhibit 33.6)

33.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Eastgate TwoPhases VIII-X Mortgage Loan (see Exhibit 33.7)

33.22      National Tax Search, LLC,as Servicing Function Participant of the Eastgate Two Phases VIII-X MortgageLoan (see Exhibit 33.8)

 

33.23       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Brickyard Square Mortgage Loan (seeExhibit 33.1)

33.24      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of theBrickyard Square Mortgage Loan (see Exhibit 33.2)

33.25      Wilmington Trust, National Association, as Trustee of the Brickyard SquareMortgage Loan (Omitted. See Explanatory Notes.)

33.26      Wells Fargo Bank, NationalAssociation, as Custodian of the Brickyard Square Mortgage Loan (see Exhibit33.5)

33.27      Pentalpha SurveillanceLLC, as Trust Advisor of the Brickyard Square Mortgage Loan (see Exhibit 33.6)

33.28      CoreLogic Commercial Real EstateServices, Inc., as Servicing Function Participant of the Brickyard SquareMortgage Loan (see Exhibit 33.7)

33.29      National Tax Search, LLC,as Servicing Function Participant of the Brickyard Square Mortgage Loan (seeExhibit 33.8)

 

33.30       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CommercePoint I & II Mortgage Loan (see Exhibit 33.2)

33.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CommercePoint I & II Mortgage Loan (see Exhibit 33.2)

33.32      Deutsche Bank Trust Company Americas, as Trustee and Custodian of the Commerce PointI & II Mortgage Loan (Omitted. See Explanatory Notes.)

33.33      Situs Holdings, LLC, as Operating Advisor of the Commerce Point I & IIMortgage Loan (Omitted. See Explanatory Notes.)

34           Attestationreports on assessment of compliance with servicing criteria for asset-backedsecurities.

34.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

34.2        Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer

34.3        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

34.4        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.5        Wells Fargo Bank, NationalAssociation, as Custodian

34.6        Pentalpha SurveillanceLLC, as Trust Advisor

34.7        CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

34.8        National Tax Search, LLC,as Servicing Function Participant

34.9        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Eastgate One Phases I-VII & XIIMortgage Loan (see Exhibit 34.1)

34.10      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EastgateOne Phases I-VII & XII Mortgage Loan (see Exhibit 34.2)

34.11      Wilmington Trust, National Association, as Trustee of the Eastgate One PhasesI-VII & XII Mortgage Loan (Omitted. See Explanatory Notes.)

34.12      Wells Fargo Bank, NationalAssociation, as Custodian of the Eastgate One Phases I-VII & XII MortgageLoan (see Exhibit 34.5)

34.13      Pentalpha SurveillanceLLC, as Trust Advisor of the Eastgate One Phases I-VII & XII Mortgage Loan(see Exhibit 34.6)

34.14      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Eastgate OnePhases I-VII & XII Mortgage Loan (see Exhibit 34.7)

34.15      National Tax Search, LLC,as Servicing Function Participant of the Eastgate One Phases I-VII & XIIMortgage Loan (see Exhibit 34.8)

 

34.16       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Eastgate Two Phases VIII-X MortgageLoan (see Exhibit 34.1)

34.17      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EastgateTwo Phases VIII-X Mortgage Loan (see Exhibit 34.2)

34.18      Wilmington Trust, National Association, as Trustee of the Eastgate Two PhasesVIII-X Mortgage Loan (Omitted. See Explanatory Notes.)

34.19      Wells Fargo Bank, NationalAssociation, as Custodian of the Eastgate Two Phases VIII-X Mortgage Loan (seeExhibit 34.5)

34.20      Pentalpha SurveillanceLLC, as Trust Advisor of the Eastgate Two Phases VIII-X Mortgage Loan (seeExhibit 34.6)

34.21      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Eastgate TwoPhases VIII-X Mortgage Loan (see Exhibit 34.7)

34.22      National Tax Search, LLC,as Servicing Function Participant of the Eastgate Two Phases VIII-X MortgageLoan (see Exhibit 34.8)

 

34.23       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Brickyard Square Mortgage Loan (seeExhibit 34.1)

34.24      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of theBrickyard Square Mortgage Loan (see Exhibit 34.2)

34.25      Wilmington Trust, National Association, as Trustee of the Brickyard SquareMortgage Loan (Omitted. See Explanatory Notes.)

34.26      Wells Fargo Bank, NationalAssociation, as Custodian of the Brickyard Square Mortgage Loan (see Exhibit34.5)

34.27      Pentalpha SurveillanceLLC, as Trust Advisor of the Brickyard Square Mortgage Loan (see Exhibit 34.6)

34.28      CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Brickyard SquareMortgage Loan (see Exhibit 34.7)

34.29      National Tax Search, LLC,as Servicing Function Participant of the Brickyard Square Mortgage Loan (seeExhibit 34.8)

 

34.30       Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CommercePoint I & II Mortgage Loan (see Exhibit 34.2)

34.31      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CommercePoint I & II Mortgage Loan (see Exhibit 34.2)

34.32      Deutsche Bank Trust Company Americas, as Trustee and Custodian of the CommercePoint I & II Mortgage Loan (Omitted. See Explanatory Notes.)

34.33      Situs Holdings, LLC, as Operating Advisor of the Commerce Point I & IIMortgage Loan (Omitted. See Explanatory Notes.)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, NationalAssociation, as Master Servicer

35.2        Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer

35.3        Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.4        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Eastgate One Phases I-VII & XIIMortgage Loan (see Exhibit 35.1)

35.5        Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EastgateOne Phases I-VII & XII Mortgage Loan (see Exhibit 35.2)

35.6        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Eastgate Two Phases VIII-X MortgageLoan (see Exhibit 35.1)

35.7        Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the EastgateTwo Phases VIII-X Mortgage Loan (see Exhibit 35.2)

35.8        Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Brickyard Square Mortgage Loan (seeExhibit 35.1)

35.9        Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of theBrickyard Square Mortgage Loan (see Exhibit 35.2)

35.10      Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the CommercePoint I & II Mortgage Loan (see Exhibit 35.2)

35.11      Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the CommercePoint I & II Mortgage Loan (see Exhibit 35.2)

99.1        MortgageLoan Purchase Agreement, dated as of May 13, 2015, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K/A filedon July 1, 2015 under Commission File No. 333-195164-08 and incorporated byreference herein)

99.2        MortgageLoan Purchase Agreement, dated as of May 13, 2015, between Wells FargoCommercial Mortgage Securities, Inc. and Rialto Mortgage Finance, LLC (filed asExhibit 99.2 to the registrant’s Current Report on Form 8-K/A filed on July 1,2015 under Commission File No. 333-195164-08 and incorporated by referenceherein)

99.3        MortgageLoan Purchase Agreement, dated as of May 13, 2015, between Wells FargoCommercial Mortgage Securities, Inc. and C-III Commercial Mortgage LLC (filedas Exhibit 99.3 to the registrant’s Current Report on Form 8-K/A filed on July1, 2015 under Commission File No. 333-195164-08 and incorporated by referenceherein)

99.4        MortgageLoan Purchase Agreement, dated as of May 13, 2015, among Wells Fargo CommercialMortgage Securities, Inc., Basis Real Estate Capital II, LLC and BasisInvestment Group LLC (filed as Exhibit 99.4 to the registrant’s Current Reporton Form 8-K/A filed on July 1, 2015 under Commission File No. 333-195164-08 andincorporated by reference herein)

(b)   The exhibits required to be filed by theRegistrant pursuant to Item 601 of Regulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

Pursuant to the requirements of Section 13 or 15(d) of the SecuritiesExchange Act of 1934, the registrant has duly caused this report to be signedon its behalf by the undersigned, thereunto duly authorized.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 19, 2020