**Certification Regarding Compliance with ApplicableServicing Criteria**

 

 

1.        LNR Partners, LLC. (the “Asserting Party”) isresponsible for assessing compliance with the servicing criteria applicable to itunder paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-monthperiod ending December 31, 2017 (the “Reporting Period”), as set forth inAppendix A hereto. The transactions covered by this report, include commercialmortgage-asset-backed securities transactions for which the Asserting Partyserved as special servicer, and that were registered with the Securities andExchange Commission pursuant to the Securities Act of 1933 (the “Platform”);

 

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

 

3.        Except as set forth in paragraph 4 below, the AssertingParty used the criteria set forth in paragraph (d) of Item 1122 of RegulationAB to assess the compliance with the applicable servicing criteria;

 

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

 

5.        The Asserting Party has complied, in all materialrespects, with the applicable servicing criteria as of December 31, 2017 andfor the Reporting Period with respect to the Platform taken as a whole;

 

6.        The Asserting Party has not identified and is not awareof any material instance of noncompliance by the Vendors with the applicableservicing criteria as of December 31, 2017 and for the Reporting Period withrespect to the Platform taken as a whole;

 

7.        The Asserting Party has not identified any materialdeficiency in its policies and procedures to monitor the compliance by theVendors with the applicable servicing criteria as of December 31, 2017 and forthe Reporting Period with respect to the Platform taken as a whole; and

 

8.        Deloitte & Touche LLP, a registered publicaccounting firm, has issued an attestation report on the Asserting Party'sassessment of compliance with the applicable servicing criteria for theReporting Period.

 

 

February 20, 2018

 

 

LNR Partners, LLC

 

 

By: /s/ Job Warshaw 

Name: Job Warshaw

Title: President

 

 

APPENDIX A

 

|  

SERVICING CRITERIA                 |  

APPLICABLE SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | INAPPLICABLE   SERVICING CRITERIA     |
|--------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|
| Reference                                  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Performed Directly by Asserting Party | Performed   by Vendor(s) for which Asserting Party is the Responsible Party | Performed by   subservicer(s) or vendor(s) for which Asserting Party is NOT the Responsible   Party | NOT   performed by Asserting Party or by subservicer(s) or vendor(s) retained by   Asserting Party |
| 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 to the extent you are required to report  on that servicing criteria pursuant to the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                          | 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                                     | X |   |   |
| 1122(d)(2)(ii)                             | Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorizedpersonnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | X                                     |   |   |   |
| 1122(d)(2)(iv)                             | The related accounts for  the transaction, such as cash reserve accounts or accounts established as a  form of overcollateralization, 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 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; (B) prepared within 30  calendar days after the bank statement cutoff date, or such other number of  days specified in the transaction agreements; (C) reviewed and approved by  someone other than the person who prepared the reconciliation; and (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                                     | 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; (B) provide information  calculated in accordance with the terms specified in the transaction  agreements; (C) are filed with the Commission as required by its rules and  regulations; and (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.                                               | X1                                    |   |   | X1 |
| 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 mortgage loandocuments.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | X                                     |   |   |   |
| 1122(d)(4)(ii)                             | Pool asset and related documents are safeguarded as  required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X                                     |   |   |   |
| 122(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  transactionagreements, 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;  (B) interest on such funds is paid, or credited, to obligors in accordance  with applicable pool asset documents and state laws; and (C) such funds are  returned to the obligor within 30 calendar days of full repayment of the  related pool assets, or such other number ofdays 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 thetransaction 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 Excludes the criteria as set forth on 3(i)(C) and3(i)(D) which is not applicable to the Asserting Party.

2 The processing of payments within 2 business daycriteria is not applicable as the Asserting Party does not routinely accept orprocess payments.