MANAGEMENT’S ASSERTION ON

COMPLIANCE WITH APPLICABLE REGULATION AB SERVICINGCRITERIA

 

Mount Street US (Georgia) LLP(the “Asserting Party”) is responsible for assessing compliance, for thetransactions listed on Appendix A for the period January 1, 2022 throughDecember 31, 2022 (the “Reporting Period”), with the servicing criteriaset forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations,except for the servicing criteria which the Asserting Party has concluded arenot applicable, as indicated on Appendix B (the “Applicable ServicingCriteria”), with respect to the servicing of the transactions listed onAppendix A, backed by commercial real estate mortgage loans that are servicedby the 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 theApplicable Servicing Criteria. The Asserting Party has determined that any suchvendor is not a “servicer” as defined in Item 1101(j) of Regulation AB, and theAsserting Party has elected to take responsibility for assessing compliancewith any portion of the Applicable Servicing Criteria performed by any suchvendor as permitted by Regulation AB Compliance and Disclosure Interpretationsof the Division of Corporation Finance, Section 200.06, “Vendors Engaged byServicers” C&DI 200.06. As permitted by C&DI 200.06, the AssertingParty asserts that it has policies and procedures in place designed to providereasonable assurance that the vendors’ activities comply in all materialrespects with servicing criteria applicable to the vendor and that theAsserting Party is not aware of any material deficiency in such policies andprocedures nor of any material instance of noncompliance by any such vendorswith respect to the Applicable Servicing Criteria. The Asserting Party issolely responsible for determining that it meets the SEC requirements to applyC&DI 200.06 for any such vendor and related criteria.

 

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

 

Mount Street US (Georgia) LLP

February 28, 2023

 

 

By: /s/ Kristin Bonczynski

Kristin Bonczynski

Senior Director

 

 

Appendix A

 

 

| **Commercial Mortgage Pass  Through Certificates** | **Applicable Reporting  Period**        | **MSUS Role**    |
|----------------------------------------------------|-----------------------------------------|------------------|
| BAMLL 2021-JACX                                    | January 1, 2022 to December  31, 2022   | Special Servicer |
| HMH 2017-NSS                                       | January 1, 2022 to December  31, 2022   | Special Servicer |
| MSBAM 2015-C21                                     | January 1, 2022 to December  31, 2022   | Special Servicer |
| NCMS 2018-FL1                                      | January 1, 2022 to December  31, 2022   | Special Servicer |
| COMM 2015-CCRE23                                   | January 19, 2022 to December  31, 2022  | Special Servicer |
| JPMCC 2013-C16                                     | March 16, 2022 to December  31, 2022    | Special Servicer |
| BANK 2018-BNK13                                    | August 11, 2022 to December  31, 2022   | Special Servicer |
| BX Trust 2019-MMP                                  | December 21, 2022 to  December 31, 2022 | 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.                                                                                                     | X2                                    |                                |
| 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 thiscriteria.

2 Primary responsibility for processing borrowerpayments rests with the Master Servicer, however, Mount Street US (Georgia) LLP("Mount Street") may from time to time receive payments on anexception basis which are forwarded to the Master Servicer in accordance withsuch criteria. No transactions occurred with respect to this criteria.