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**Reporton Assessment of Compliance with SEC Regulation AB**

**ServicingCriteria as Primary Servicer**

 

BerkadiaCommercial Mortgage LLC (“Berkadia”) is responsible for assessing compliance, as of and for the year ended December31, 2019 (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 mortgageloans sold in public securitizations from the period January 1, 2006 through December 31, 2019 for which Berkadia served as primaryservicer (the “Platform”).

 

Berkadiahas 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. |
|--|-----|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

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| **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)                                                                      | Lossmitigation 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 thetransaction 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. |

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| **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. |
|-----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

 

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TheServicing Criteria, after giving effect to the foregoing exclusions, are referred to as the “Applicable Servicing Criteria”.

 

Berkadiautilizes vendors to support its servicing operations, including the use of a commercial tax service which supports its assertionsunder 1122(d)(4)(xi) through (xiii) and the use of a lien filing firm to support its assertion under 1122(d)(4)(i).  Thisvendor activity contributes to the servicing activities to which Berkadia is asserting. In all cases, the vendors’ activitiesare limited, and Berkadia assumes responsibility for the 1122 assessment for these vendor activities.  These vendors do notfit the definition of servicer under Item 1101(j), and Berkadia employs policies and procedures designed to provide assurancethat the vendors’ activities comply with the Applicable Servicing Criteria to such vendors.

 

Forthe Reporting Period, Berkadia has assessed its compliance with the Applicable Servicing Criteria for the Platform and has concludedthat its servicing operation has complied, in all material respects, with the Applicable Servicing Criteria.

 

GrantThornton LLP, an independent registered public accounting firm, has issued an attestation report on management’s assertionof compliance with the Applicable Servicing Criteria.

 

| Berkadia                                         Commercial Mortgage LLC

                                          February 14, 2020 |   |   |
|--------------------------------------------------------------------------------------------------------------------------------------------|--------|--------|
| /s/Mark E. McCool                                                                                                                          |   |   |
| Mark                                         E. McCool

Executive    Vice President 

Berkadia    Commercial Mortgage LLC                  |   |   |

 

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