Report on Assessment of Compliance with SEC Regulation AB
Servicing Criteria as Primary Servicer

Berkadia Commercial Mortgage LLC ("Berkadia") is responsible for assessing compliance, as of and
for the year ended December 31, 2015 (the "Reporting Period"), with the Servicing Criteria set forth
in Item 1122(d) of Regulation AB of the U.S. Securities and Exchange Commission for asset-backed
securities  transactions.  This  assertion  includes  all  commercial  mortgage  loans  sold  in  public
securitizations  from  the  period  January  1,  2006  through  December  31,  2015  for  which  Berkadia
served as primary servicer (the "Platform").

Berkadia  has  concluded  that  the  criteria  are  applicable  as  shown  below  (indicated  by  X)  to  the
primary servicing of the loans in the Platform:




Regulation AB Criteria 1122(d)

Applicability
of Criteria as
the Primary
Servicer

(1)  General servicing considerations.


(i)  Policies and procedures are instituted to monitor any performance or other triggers and
events of default in accordance with the transaction agreements.

X

(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

(iii)   Any requirements in the transaction agreements to maintain a back-up servicer for the
pool assets are maintained.


(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

(v)  Aggregation   of   information,   as   applicable,   is   mathematically   accurate   and   the
information conveyed accurately reflects the information.

X

(2)  Cash collection and administration.


(i)  Payments  on  pool  assets  are  deposited  into  the  custodial  bank  accounts  and  related
bank  clearing  accounts  no  more  than  two  business  days  of  receipt,  or  such  other
number of days specified in the transaction agreements.


X

(ii)  Disbursements  made  via  wire  transfer  on  behalf  of  an  obligor  or  to  an  investor  are
made only by authorized personnel.

X

(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 transection agreements.


X

(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

(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 § 240.13k-1(b)(1) of this chapter.


X

(vi)   Unissued checks are safeguarded so as to prevent unauthorized access.

X

(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:


(A)   Are mathematically accurate;

X


X  Servicer was responsible for this criteria in its role as Primary Servicer.
(1)
Per servicing and pooling agreements, the criteria does not apply to the role of Primary Servicer.

Regulation AB Criteria 1122(d)

Applicability
of Criteria as
the Primary
Servicer

(B)   Are prepared within 30 calendar days after the bank statement cutoff date, or such other
number of days specified in the transaction agreements;

X

(C)   Are  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

(3)  Investor remittances and reporting.


(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; and

(1)

(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

(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

(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

(iv)   Amounts remitted to investors per the investor reports agree with cancelled checks, or
other form of payment, or custodial bank statements.

X

(4)  Pool asset administration.


(i)  Collateral  or  security  on  pool  assets  is  maintained  as  required  by  the  transaction
agreements or related pool asset documents.

X
(2)

(ii)   Pool  assets  and  related  documents  are  safeguarded  as  required  by  the  transaction
agreements.


(1)

(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

(iv)  Payments  on  pool  assets,  including  any  payoffs,  made  in  accordance  with  the  related
pool asset documents are posted to the applicable servicer's obligor records maintained
no more than two business days after receipt, or such other number of days specified in
the  transaction  agreements,  and  allocated  to  principal,  interest  or  other  items  (e.g.,
escrow) in accordance with the related pool asset documents.



X

(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

(vi)  Changes  with  respect  to  the  terms  or  status  of  an  obligor's  pool  asset  (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

(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.



(1)

X  Servicer was responsible for this criteria in its role as Primary Servicer.
(1)
Per servicing and pooling agreements, the criteria does not apply to the role of Primary Servicer.
(2)
Vendor(s), for which Berkadia is the Responsible Party, contributes to the servicing activities for this criteria.

Regulation AB Criteria 1122(d)

Applicability
of Criteria as
the Primary
Servicer

(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

(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

(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 asset, or such other number of days specified in the transaction agreements.

X

(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
(2)

(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
(2)

(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
(2)

(xiv) Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in
accordance with the transaction agreements.

X

(xv)  Any external enhancement or other support, identified in Item 1114(a) (1) through (3)
or  Item  1115  of  this  Regulation  AB,  is  maintained  as  set  forth  in  the  transaction
agreements.


(1)


X  Servicer was responsible for this criteria in its role as Primary Servicer.
(1)
Per servicing and pooling agreements, the criteria does not apply to the role of Primary Servicer.
(2)
Vendor(s), for which Berkadia is the Responsible Party, contributes to the servicing activities for this criteria.

The  Servicing  Criteria,  after  giving  effect  to  the  foregoing  exclusions,  are  referred  to  as  the
"Applicable Servicing Criteria".

Berkadia utilizes vendors to support its servicing operations, including the use of a commercial tax
service  which  supports its assertions  under  1122(d)(4)(xi)  through (xiii)  and the use  of a  lien filing
firm  to  support  its  assertion  under  1122(d)(4)(i).  This  vendor  activity  contributes  to  the  servicing
activities to which Berkadia is asserting. In all cases, the vendors' activities are limited, and Berkadia
assumes responsibility for the 1122 assessment for these vendor activities. These vendors do not fit
the definition of servicer under Item 1101(j), and Berkadia employs policies and procedures designed
to provide assurance that the vendors' activities comply with the Applicable Servicing Criteria to such
vendors.

For the Reporting Period, Berkadia has assessed its compliance with the Applicable Servicing Criteria
for  the  transactions  and  has  concluded  that  its  servicing  operation  has  complied,  in  all  material
respects, with the Applicable Servicing Criteria.

Grant  Thornton  LLP,  an  independent  registered  public  accounting  firm,  has  issued  an  attestation
report on management's assertion of compliance with the Applicable Servicing Criteria.


Berkadia Commercial Mortgage LLC
February 29, 2016
/s/ Mark E. McCool


Mark E. McCool
President, Commercial Real Estate Services
Berkadia Commercial Mortgage LLC