DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78





Management’s
Assertion on Compliance with Applicable Regulation AB Servicing Criteria





| | 1. | Rialto Capital Advisors, LLC (the “Asserting Party”) is responsible for assessing compliance
with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending
December 31, 2023 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report, include
commercial mortgage-asset-backed securities transactions, as listed on Exhibit 1 hereto, for which the Asserting Party served as special
servicer, and that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933 (the “Platform”);
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 2. | The Asserting Party has engaged certain vendors, which are not servicers as defined in Item 1101(j)
of Regulation AB (the “Vendors”), to perform specific, limited or scripted activities, and the Asserting Party elects to take
responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors’
activities as set forth in Appendix A hereto;
| | -- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 3. | Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in paragraph
(d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria;
| | -- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 4. | The criteria listed in the column titled “Inapplicable Servicing Criteria” on Appendix
A hereto are inapplicable to the Asserting Party based on the activities it performs, directly or through its Vendors, with respect to
the Platform;
| | -- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 5. | The Asserting Party has complied, in all material respects, with the applicable servicing criteria as
of December 31, 2023 and for the Reporting Period with respect to the Platform taken as a whole;
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 6. | The Asserting Party has not identified and is not aware of any material instance
of noncompliance by the Vendors with the applicable servicing criteria as of December 31, 2023 and for the Reporting Period with respect
to the Platform taken as a whole;
| | -- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 7. | The Asserting Party has not identified any material deficiency in its policies and procedures to monitor
the compliance by the Vendors with the applicable servicing criteria as of December 31, 2023 and for the Reporting Period with respect
to the Platform taken as a whole; and
| | -- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | 8. | Deloitte & Touche LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party’s
assessment of compliance with the applicable servicing criteria for the Reporting Period.
| | -- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



February 14, 2024





Name: Adam Singer
Title: Managing Director



Signature: /s/ Adam Singer







DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78





APPENDIX A



|SERVICING CRITERIA               |                                                                                                                                                                                                                                                                  
|-------------------------------- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|Reference                        | 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.                                                                                                         
|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.                                                             
|1122(d)(1)(iii)                  | Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                
|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.
|1122(d)(1)(v)                    | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                          





2





DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78



|Cash Collection and Administration
|----------------------------------
|1122(d)(2)(i)                     
|1122(d)(2)(ii)                    
|1122(d)(2)(iii)                   
|1122(d)(2)(iv)                    
|1122(d)(2)(v)                     
|1122(d)(2)(vi)                    
|1122(d)(2)(vii)                   



3





DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78



|Investor Remittances and Reporting
|----------------------------------
|1122(d)(3)(i)                     
|1122(d)(3)(ii)                    
|1122(d)(3)(iii)                   
|1122(d)(3)(iv)                    



4





DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78



|Pool Asset Administration
|-------------------------
|1122(d)(4)(i)            
|1122(d)(4)(ii)           
|1122(d)(4)(iii)          
|1122(d)(4)(iv)           
|1122(d)(4)(v)            
|1122(d)(4)(vi)           
|1122(d)(4)(vii)          
|1122(d)(4)(viii)         
|1122(d)(4)(ix)           
|1122(d)(4)(x)            



5





DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78



|                 | repayment of the related pool assets, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                     |    |  
|---------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -- | -
|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. | X5 |  
|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



X1-Rialto Capital Advisors, LLC performs
the activities pertaining to this criterion, except for specific, limited activities performed by its third-party property managers relating
to REO Property, if any. Rialto has elected to take responsibility for assessing compliance with these servicing criteria with respect
to the activities of its third-party property managers, as and if applicable.



X2- Primary responsibility for processing
borrower payments rests with the Master Servicer, however, Rialto Capital Advisors, LLC may from time to time receive payments on an exception
basis which are forwarded to the Master Servicer in accordance with such criteria. The criteria is marked applicable as Rialto Capital
Advisors, LLC had instances or activity relating to this criteria for the calendar year of January 1, 2023 to December 31, 2023.



X3- Although Rialto Capital Advisors,
LLC is responsible for performing the activities under this criteria, it is noted no such activities occurred during the calendar year
of January 1, 2023 to December 31, 2023.



X4- Only items (A) and (B) of the Servicing
Criteria are applicable to Rialto Capital Advisors, LLC as special servicer. Items (C) and (D) are inapplicable as the responsibility
for filing reports with the Commission and agreeing totals to the Servicer records rests with the Trustee and/or Certificate Administrator,
as applicable.



X5-Commencing in the regulatory reporting
year 2023, Rialto Capital Advisors periodically advances certain insurance premium payments on behalf of Obligors to insurance carriers
to avoid cancellation of policies or late payments and penalties. Advances are made in accordance with applicable transaction documents.

6





DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78





Exhibit 1

|Pooling and Servicing Agreements | Applicable Certification Period      
|-------------------------------- | -------------------------------------
|UBSBB 2012-C2                    | January 1, 2023 to March 8, 2023     
|GSMS 2011-GC3                    | January 1, 2023 to September 29, 2023
|WFRBS 2013-C12                   | January 1, 2023 to October 20, 2023  
|WFCM 2012-LC5                    | January 1, 2023 to November 9, 2023  
|BACM 2016-UBS10                  | January 1, 2023 to December 31, 2023 
|BACM 2017-BNK3                   | January 1, 2023 to December 31, 2023 
|BAMLL 2022-DKLX                  | January 1, 2023 to December 31, 2023 
|BANK 2017-BNK4                   | January 1, 2023 to December 31, 2023 
|BANK 2017-BNK7                   | January 1, 2023 to December 31, 2023 
|BANK 2017-BNK9                   | January 1, 2023 to December 31, 2023 
|BANK 2018-BNK14                  | January 1, 2023 to December 31, 2023 
|BANK 2019-BNK18                  | January 1, 2023 to December 31, 2023 
|BANK 2019-BNK21                  | January 1, 2023 to December 31, 2023 
|BANK 2020-BNK29                  | January 1, 2023 to December 31, 2023 
|BANK 2021-BNK32                  | January 1, 2023 to December 31, 2023 
|BANK 2021-BNK33                  | January 1, 2023 to December 31, 2023 
|BANK 2021-BNK36                  | January 1, 2023 to December 31, 2023 
|BANK 2022-BN41                   | January 1, 2023 to December 31, 2023 
|BBCMS 2017-C1                    | January 1, 2023 to December 31, 2023 
|BBCMS 2019-C4                    | January 1, 2023 to December 31, 2023 
|BBCMS 2020-C7                    | January 1, 2023 to December 31, 2023 
|BBCMS 2021-C10                   | January 1, 2023 to December 31, 2023 
|BBCMS 2022-C15                   | January 1, 2023 to December 31, 2023 
|BBCMS 2022-C18                   | January 1, 2023 to December 31, 2023 
|BMARK 2019-B11                   | January 1, 2023 to December 31, 2023 
|BMARK 2020-B19                   | January 1, 2023 to December 31, 2023 
|BMARK 2020-B22                   | January 1, 2023 to December 31, 2023 
|BMARK 2021-B25                   | January 1, 2023 to December 31, 2023 
|BMARK 2021-B31                   | January 1, 2023 to December 31, 2023 
|BMARK 2022-B37                   | January 1, 2023 to December 31, 2023 
|BMO 2022-C2                      | January 1, 2023 to December 31, 2023 
|BSST 2021-1818                   | January 1, 2023 to December 31, 2023 
|BSST 2022-1700                   | January 1, 2023 to December 31, 2023 
|CD 2016-CD1                      | January 1, 2023 to December 31, 2023 
|CD 2017-CD4                      | January 1, 2023 to December 31, 2023 
|CD 2017-CD5                      | January 1, 2023 to December 31, 2023 







DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78



|Pooling and Servicing Agreements                                                                       | Applicable Certification Period     
|------------------------------------------------------------------------------------------------------ | ------------------------------------
|CD 2018-CD7                                                                                            | January 1, 2023 to December 31, 2023
|CFCRE 2016-C4                                                                                          | January 1, 2023 to December 31, 2023
|CFCRE 2016-C6                                                                                          | January 1, 2023 to December 31, 2023
|CFCRE 2017-C8                                                                                          | January 1, 2023 to December 31, 2023
|CGCMT 2014-GC23                                                                                        | January 1, 2023 to December 31, 2023
|CGCMT 2015-GC27                                                                                        | January 1, 2023 to December 31, 2023
|CGCMT 2016-C3                                                                                          | January 1, 2023 to December 31, 2023
|CGCMT 2017-P7                                                                                          | January 1, 2023 to December 31, 2023
|CGCMT 2019-GC41                                                                                        | January 1, 2023 to December 31, 2023
|CGCMT 2019-GC43                                                                                        | January 1, 2023 to December 31, 2023
|CGCMT 2022-GC48
(RCA is special servicer as to the Yorkshire & Lexington Towers loan combination only) | January 1, 2023 to December 31, 2023
|COMM 2012-CCRE4                                                                                        | January 1, 2023 to December 31, 2023
|COMM 2013-LC13                                                                                         | January 1, 2023 to December 31, 2023
|COMM 2013-LC6                                                                                          | January 1, 2023 to December 31, 2023
|COMM 2014-CCRE14                                                                                       | January 1, 2023 to December 31, 2023
|COMM 2014-CCRE15                                                                                       | January 1, 2023 to December 31, 2023
|COMM 2014-CCRE18                                                                                       | January 1, 2023 to December 31, 2023
|COMM 2014-LC15                                                                                         | January 1, 2023 to December 31, 2023
|COMM 2014-UBS5                                                                                         | January 1, 2023 to December 31, 2023
|COMM 2015-CCRE27                                                                                       | January 1, 2023 to December 31, 2023
|COMM 2015-DC1                                                                                          | January 1, 2023 to December 31, 2023
|COMM 2015-LC21                                                                                         | January 1, 2023 to December 31, 2023
|COMM 2015-PC1                                                                                          | January 1, 2023 to December 31, 2023
|COMM 2019-GC44                                                                                         | January 1, 2023 to December 31, 2023
|CSAIL 2015-C2                                                                                          | January 1, 2023 to December 31, 2023
|CSAIL 2015-C3                                                                                          | January 1, 2023 to December 31, 2023
|CSAIL 2016-C5                                                                                          | January 1, 2023 to December 31, 2023
|CSAIL 2016-C7                                                                                          | January 1, 2023 to December 31, 2023
|CSAIL 2017-CX9                                                                                         | January 1, 2023 to December 31, 2023
|CSAIL 2018-C14                                                                                         | January 1, 2023 to December 31, 2023
|CSAIL 2019-C18                                                                                         | January 1, 2023 to December 31, 2023
|CSMC 2020-FACT                                                                                         | January 1, 2023 to December 31, 2023
|CSMC 2020-NET                                                                                          | January 1, 2023 to December 31, 2023
|CSMC 2021-ADV                                                                                          | January 1, 2023 to December 31, 2023
|CSMC 2022-NWPT                                                                                         | January 1, 2023 to December 31, 2023
|DBGS 2018-C1                                                                                           | January 1, 2023 to December 31, 2023
|FSRIA 2019-FL1                                                                                         | January 1, 2023 to December 31, 2023







DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78



|Pooling and Servicing Agreements | Applicable Certification Period     
|-------------------------------- | ------------------------------------
|FSRIA 2021-FL2                   | January 1, 2023 to December 31, 2023
|FSRIA 2021-FL3                   | January 1, 2023 to December 31, 2023
|FSRIA 2022-FL4                   | January 1, 2023 to December 31, 2023
|FSRIA 2022-FL5                   | January 1, 2023 to December 31, 2023
|FSRIA 2022-FL6                   | January 1, 2023 to December 31, 2023
|FSRIA 2022-FL7                   | January 1, 2023 to December 31, 2023
|GSMS 2012-GCJ9                   | January 1, 2023 to December 31, 2023
|GSMS 2013-GCJ12                  | January 1, 2023 to December 31, 2023
|GSMS 2013-GCJ16                  | January 1, 2023 to December 31, 2023
|GSMS 2015-GC28                   | January 1, 2023 to December 31, 2023
|GSMS 2016-GS3                    | January 1, 2023 to December 31, 2023
|GSMS 2017-GS5                    | January 1, 2023 to December 31, 2023
|GSMS 2017-GS7                    | January 1, 2023 to December 31, 2023
|GSMS 2018-3PCK                   | January 1, 2023 to December 31, 2023
|GSMS 2018-GS10                   | January 1, 2023 to December 31, 2023
|GSMS 2018-GS9                    | January 1, 2023 to December 31, 2023
|ILPT 2019-SURF                   | January 1, 2023 to December 31, 2023
|JPMBB 2014-C23                   | January 1, 2023 to December 31, 2023
|JPMBB 2014-C25                   | January 1, 2023 to December 31, 2023
|JPMBB 2015-C31                   | January 1, 2023 to December 31, 2023
|JPMCC 2012-LC9                   | January 1, 2023 to December 31, 2023
|JPMCC 2017-JP6                   | January 1, 2023 to December 31, 2023
|MSBAM 2012-C5                    | January 1, 2023 to December 31, 2023
|MSBAM 2013-C13                   | January 1, 2023 to December 31, 2023
|MSBAM 2014-C14                   | January 1, 2023 to December 31, 2023
|MSBAM 2014-C17                   | January 1, 2023 to December 31, 2023
|MSBAM 2014-C18                   | January 1, 2023 to December 31, 2023
|MSBAM 2014-C19                   | January 1, 2023 to December 31, 2023
|MSBAM 2015-C20                   | January 1, 2023 to December 31, 2023
|MSBAM 2016-C29                   | January 1, 2023 to December 31, 2023
|MSBAM 2016-C31                   | January 1, 2023 to December 31, 2023
|MSCI 2015-UBS8                   | January 1, 2023 to December 31, 2023
|MSCI 2016-UBS12                  | January 1, 2023 to December 31, 2023
|MSCI 2019-L2                     | January 1, 2023 to December 31, 2023
|Rial 2022-FL8                    | January 1, 2023 to December 31, 2023
|SGCMS 2016-C5                    | January 1, 2023 to December 31, 2023
|SPGN 2022-TFLM                   | January 1, 2023 to December 31, 2023
|UBS-Barclays 2012-C3             | January 1, 2023 to December 31, 2023







DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78



|Pooling and Servicing Agreements | Applicable Certification Period     
|-------------------------------- | ------------------------------------
|UBS-Barclays 2012-C4             | January 1, 2023 to December 31, 2023
|UBS-Barclays 2013-C6             | January 1, 2023 to December 31, 2023
|UBS-Citigroup 2011-C1            | January 1, 2023 to December 31, 2023
|UBSCM 2012-C1                    | January 1, 2023 to December 31, 2023
|UBSCM 2017-C4                    | January 1, 2023 to December 31, 2023
|UBSCM 2017-C6                    | January 1, 2023 to December 31, 2023
|UBSCM 2018-C10                   | January 1, 2023 to December 31, 2023
|UBSCM 2018-C14                   | January 1, 2023 to December 31, 2023
|UBSCM 2018-C9                    | January 1, 2023 to December 31, 2023
|UBSCM 2019-C17                   | January 1, 2023 to December 31, 2023
|UBSCM 2019-C18                   | January 1, 2023 to December 31, 2023
|WFCM 2013-LC12                   | January 1, 2023 to December 31, 2023
|WFCM 2014-LC18                   | January 1, 2023 to December 31, 2023
|WFCM 2015-C27                    | January 1, 2023 to December 31, 2023
|WFCM 2015-C30                    | January 1, 2023 to December 31, 2023
|WFCM 2015-LC20                   | January 1, 2023 to December 31, 2023
|WFCM 2015-LC22                   | January 1, 2023 to December 31, 2023
|WFCM 2015-NXS1                   | January 1, 2023 to December 31, 2023
|WFCM 2015-NXS2                   | January 1, 2023 to December 31, 2023
|WFCM 2015-NXS4                   | January 1, 2023 to December 31, 2023
|WFCM 2015-P2                     | January 1, 2023 to December 31, 2023
|WFCM 2015-SG1                    | January 1, 2023 to December 31, 2023
|WFCM 2016-BNK1                   | January 1, 2023 to December 31, 2023
|WFCM 2016-C32                    | January 1, 2023 to December 31, 2023
|WFCM 2016-C33                    | January 1, 2023 to December 31, 2023
|WFCM 2016-NXS5                   | January 1, 2023 to December 31, 2023
|WFCM 2018-C44                    | January 1, 2023 to December 31, 2023
|WFCM 2019-C50                    | January 1, 2023 to December 31, 2023
|WFCM 2020-C55                    | January 1, 2023 to December 31, 2023
|WFCM 2020-C58                    | January 1, 2023 to December 31, 2023
|WFRBS 2011-C2                    | January 1, 2023 to December 31, 2023
|WFRBS 2011-C3                    | January 1, 2023 to December 31, 2023
|WFRBS 2011-C4                    | January 1, 2023 to December 31, 2023
|WFRBS 2011-C5                    | January 1, 2023 to December 31, 2023
|WFRBS 2013-C14                   | January 1, 2023 to December 31, 2023
|WFRBS 2013-C16                   | January 1, 2023 to December 31, 2023
|WFRBS 2013-C17                   | January 1, 2023 to December 31, 2023
|WFRBS 2014-C20                   | January 1, 2023 to December 31, 2023







DocuSign Envelope ID: EC419511-1DE9-420B-90A0-11077C076E78



|Pooling and Servicing Agreements | Applicable Certification Period       
|-------------------------------- | --------------------------------------
|WFRBS 2014-C24                   | January 1, 2023 to December 31, 2023  
|WFRBS 2014-LC14                  | January 1, 2023 to December 31, 2023  
|UBSCM 2017-C1                    | January 5, 2023 to December 31, 2023  
|BMO 2023-C5                      | June 21, 2023 to December 31, 2023    
|BMO 2023-C6                      | August 30, 2023 to December 31, 2023  
|BBCMS 2023-C22                   | November 1, 2023 to December 31, 2023 
|TMSQ 2014-1500                   | November 2, 2023 to December 31, 2023 
|SCG 2023-NASH                    | November 29, 2023 to December 31, 2023
|DTP 2023-STE2                    | December 28, 2023 to December 31, 2023