| (logo)  PNC  REAL ESTATE | MIDLAND  LOAN  SERVICES |
|-------------------------------|-------------------------|

 

 

**Report on Assessment of Compliancewith Regulation AB Servicing Criteria**

 

Midland Loan Services(“Midland”), a division of PNC Bank, National Association, isresponsible for assessing compliance with the applicable servicing criteria setforth in Item 1122 (d) of Regulation AB of the Securities and ExchangeCommission (“Regulation AB”), as set forth in Appendix A.

 

Midland has assessed itscompliance with the applicable servicing criteria as of and for the year endedDecember 31, 2016 (the “Reporting Period”). In making this assessment,Midland used the criteria set forth by the Securities and Exchange Commission(“SEC”) in Item 1122(d) of Regulation AB. This report covers alltransactions serviced on the *Enterprise!* Loan Management System (the“Platform”).

 

Midland engaged certainvendors, which are not servicers as defined in item 1101(j) of Regulation AB(the “Vendors”), to perform specific, limited or scriptedactivities related to portions of the servicing criteria as set forth inAppendix A.  Midland elects to take responsibility for assessingcompliance with the servicing criteria or portion of the servicing criteriaapplicable to such Vendors’ activities as set forth in Appendix A.Midland has not identified and is not aware of any material instances ofnoncompliance by the Vendors with the applicable servicing criteria as ofDecember 31, 2016 and for the Reporting Period with respect to the Platformtaken as a whole, nor has it identified any material deficiencies in itspolicies and procedures to monitor the compliance by the Vendors with theapplicable servicing criteria as of December 31, 2016 and for the ReportingPeriod with respect to the Platform taken as a whole.

 

Based on this assessment,Midland believes that, as of and for the year ended December 31, 2016, Midlandhas complied in all material respects with the applicable servicing criteriaset forth in Item 1122(d) of Regulation AB.

 

PricewaterhouseCoopers LLP, anindependent registered public accounting firm, has issued an attestation reporton Midland’s assessment of compliance with the applicable servicingcriteria as of and for the year ended December 31, 2016.

 

MIDLAND LOAN SERVICES

a division of PNC Bank,National Association

 

 

/s/ Steven W. Smith

Steven W. Smith

Executive Vice President

 

/s/ Bradley J. Hauger

Bradley J. Hauger

Senior Vice President 

 

Date: February 17, 2017

 

 

**Member of The PNC FinancialServices Group**

10851 Mastin Boulevard •Overland Park, Kansas • 66210 

800-327-8083

www.pnc.com/midland

 

 

**APPENDIX A**

 

| ** **

**SERVICING CRITERIA**                                        | **APPLICABLE SERVICING   CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
|---------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| ** **

** **

** **

** **

** **

**Reference** | ** **

** **

** **

** **

** **

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

** **

** **

**Performed Directly by   Midland** | **Performed by Vendor(s)   for which Midland is the Responsible 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 | X

(only with respect to  financial performance activities) |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                         | N/A1 |
| 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 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.                                                                                                                                                                                                                                                                                                | ** **

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:                                                                                                                                                                                                                                                                                                                          |   |   |   |
|                                                                      | (A) Are mathematically  accurate;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | X |   |   |
|                                                                      | (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 |   |   |
| **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;                                                                                                                                                                                                                                                                                                                                                                                                                  | N/A1 |   |
|                                                                      | (C) Are filed with the  Commission as required by its rules and regulations; and                                                                                                                                                                                                                                                                                                                                                                                                                                            | N/A1 |   |
|                                                                      | (D) Agree with  investor’s or the trustee’s records as to the total unpaid  principal balance and number of pool assets serviced by the servicer.                                                                                                                                                                                                                                                                                                                                                               |  

N/A1 |   |
| 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.                                                                                                                                                                                                                                                                                                                                                         |  

N/A1 |   |
| 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.                                                                                                                                                                                                                                                                                                                                    |  

N/A1 |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                               |  

N/A1 |   |
| **Pool Asset Administration**                                             |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
| 1122(d)(4)(i)                                                             | Collateral or security on  pool assets is maintained as required by the transaction agreements or  related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                         |  

 

X | X

(only with respect to  removal from pools and loan assumptions) |   |
| 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 | X

(only with respect to  removal from pools) |   |
| 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.                                                                                                    |  

 

X |   |   |
| 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 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 | X

(only with respect to loan  assumptions) |   |
| 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  asset, 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 |  

X

(with respect to insurance  and tax related activities) |   |
| 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 this  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                        |  

N/A1 |   |
|                                                                      |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |   |   |   |   |   |   |

 

1 Midland has determined servicing criteria 1122(d)(1)(iii),1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D), 1122(d)(3)(ii),1122(d)(3)(iii), 1122(d)(3)(iv), and 1122(d)(4)(xv) to be inapplicable to theactivities Midland performs with respect to the Platform.