EX-33.3
February 25, 2013


Management's Report on Assessment of 2012 Compliance by Pentalpha
Surveillance, LLC With Regulation AB Servicing Criteria


Pentalpha Surveillance, LLC (the Asserting Party) is responsible for assessing
its compliance, as of and for the period ended December 31, 2012, with the
servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of
Federal Regulations.

The assessment concerns the Asserting Party's servicing efforts for its
servicing "Platform," which consists of its servicing activities encompassed by
contractual obligations to perform Regulation AB reporting. (See Exhibit A for
a list of the Asserting Party's Platform of required reporting by the servicing
agreements.)

The Asserting Party has assessed its compliance with the applicable servicing
criteria as of and for the year ended December 31, 2012. The Asserting Party
used the criteria in paragraph (d) of Section 1122 of Regulation AB (17 C.F.R.
229.1122) to assess its compliance.

Based on such assessment, the Asserting Party believes that, as of and for the
year ended December 31, 2012, the Asserting Party has complied in all material
respects with the servicing criteria set forth in Item 1122(d) of Regulation AB
relating to its operational advisor role in the servicing of the Platform,
except for servicing criteria 1122(d)(1 )(i-iv), 1122(d)(2)(i-vii),
1122(d)(3)(ii-iv), 1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv), which the
Asserting Party has determined as being inapplicable to the activities it
performs with respect to the Platform being serviced (the "applicable servicing
criteria").

McGladrey LLP, an independent registered public accounting firm, has issued an
attestation report on the assessment of compliance with the applicable
servicing criteria for the reporting period as set forth in this assertion.


2


(page)


<TABLE>
<CAPTION>

Regulation AB Section 229.1122(d) Servicing Criteria


Regulation AB Reference                                     Servicing Criterion

                                                         <c>
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.

Applicability/Compliance:                                   Not applicable.


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.

Applicability/Compliance:                                   Not applicable.


1122(d)(1)(iii)                                             Any requirements in the transaction agreements to maintain a
                                                            backup servicer for the mortgage loans are maintained.

Applicability/Compliance:                                   Not applicable.


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.

Applicability/Compliance:                                   Not applicable.


1122(d)(2)(i)                                               Payments on pool assets are deposited into the appropriate
                                                            custodial bank accounts and related bank clearing accounts within
                                                            no more than two business days of receipt, or such other number
                                                            of days specified in the transaction agreements.

Applicability/Compliance:                                   Not applicable.


1122(d)(2)(ii)                                              Disbursements made via wire transfer on behalf of an obligor or to
                                                            an investor are made only by authorized personnel.

Applicability/Compliance:                                   Not applicable.


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 documents.

Applicability/Compliance:                                   Not applicable.


3


(page)


Regulation AB Reference                                     Servicing Criterion

                                                         <c>
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.

Applicability/Compliance:                                   Not applicable.


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
                                                            Section 240.13k-1(b)(1) of this chapter.

Applicability/Compliance:                                   Not applicable.


1122(d)(2)(vi)                                              Unissued checks were safeguarded so as to prevent unauthorized
                                                            access.

Applicability/Compliance:                                   Not applicable.


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

Applicability/Compliance:                                   Not applicable.


1122(d)(3)(i)(A)                                            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 are prepared in accordance with time frames and
                                                            other terms set forth in the transaction agreements.

Applicability/Compliance:                                   Applicable.


1122(d)(3)(i)(B)                                            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 provide information calculated in accordance with the
                                                            terms specified in the transaction agreements.

Applicability/Compliance:                                   Applicable.


4


(page)


Regulation AB Reference                                     Servicing Criterion

                                                         <c>
1122(d)(3)(i)(C)                                            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 are filed with the Commission as required by its rules
                                                            and regulations.

Applicability/Compliance:                                   Applicable.


1122(d)(3)(i)(D)                                            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 agree with investors or the trustee's records as to the
                                                            total unpaid principal balance and number of mortgage loans
                                                            serviced by the servicer.

Applicability/Compliance:                                   Applicable.


1122(d)(3)(ii)                                              Amounts due to investors are allocated and remitted in accordance
                                                            with time frames, distribution priority and other terms set forth in
                                                            the transaction agreements.

Applicability/Compliance:                                   Not applicable.


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.

Applicability/Compliance:                                   Not applicable.


1122(d)(3)(iv)                                              Amounts remitted to investors per the investor reports agree with
                                                            canceled checks, or other form of payment, or custodial bank
                                                            statements.

Applicability/Compliance:                                   Not applicable.


1122(d)(4)(i)                                               Collateral or security on pool assets is maintained as required by
                                                            the transaction agreements or related pool asset documents.

Applicability/Compliance:                                   Not applicable.


1122(d)(4)(ii)                                              Pool assets and related documents are safeguarded as required
                                                            by the transaction agreements.

Applicability/Compliance:                                   Not applicable.


5


(page)


Regulation AB Reference                                     Servicing Criterion

                                                         <c>
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.

Applicability/Compliance:                                   Not applicable.


1122(d)(4)(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.

Applicability/Compliance:                                   Not applicable.


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.

Applicability/Compliance:                                   Not applicable.


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.

Applicability/Compliance:                                   Not applicable.


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 time frames or other
                                                            requirements established by the transaction agreements.

Applicability/Compliance:                                   Applicable.


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).

Applicability/Compliance:                                   Not applicable.


6


(page)


Regulation AB Reference                                     Servicing Criterion

                                                         <c>
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.

Applicability/Compliance:                                   Not applicable.


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 were 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.

Applicability/Compliance:                                   Not applicable.


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.

Applicability/Compliance:                                   Not applicable.


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.

Applicability/Compliance:                                   Not applicable.


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.

Applicability/Compliance:                                   Not applicable.


1122(d)(4)(xiv)                                             Delinquencies, charge-offs and uncollectible accounts are
                                                            recognized and recorded in accordance with the transaction
                                                            agreements.

Applicability/Compliance:                                   Not applicable.


7


(page)


Regulation AB Reference                                     Servicing Criterion

                                                         <c>

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.

Applicability/Compliance:                                   Not applicable.

</TABLE>


February 25, 2013

/s/ James Callahan
James Callahan, Executive Director

/s/ Don Simon
Don Simon, Chief Operating Officer


8


(page)


Exhibit A

<TABLE>
<CAPTION>

                                     Platform and Public
Issuer                               Name of Securitization                          Master Servicer

                                  <c>                                             <c>

GS Mortgage Securities               Commercial Mortgage Pass-Through                Wells Fargo Bank, National
Corporation II                       Certificates Series 2011-GC5                    Association

J.P. Morgan Chase                    J.P. Morgan Chase Commercial Mortgage           Midland Loan Services, a division of
Commercial Mortgage                  Securities Trust 2011-C5                        PNC Bank, National Association
Securities Corp.

Wells Fargo Commercial               Commercial Mortgage Pass-Through                Wells Fargo Bank, National
Mortgage Securities, Inc.            Certificates Series 2012-C6                     Association

J.P. Morgan Chase                    J.P. Morgan Chase Commercial Mortgage           Wells Fargo Bank, National
Commercial Mortgage                  Securities Trust 2012-C6 Commercial             Association
Securities Corp.                     Mortgage Pass-Through Certificates
                                     Series 2012-C-6

Deutsche Mortgage &                  COMM 2012-CCRE1 Commercial                      Wells Fargo Bank, National
Asset Receiving                      Mortgage Pass-Through Certificates              Association
Corporation

UBS Commercial                       UBS-Barclays Commercial Mortgage Trust          Wells Fargo Bank, National
Mortgage Securitization              2012-C2, Commercial Mortgage Pass-              Association
Corp.                                Through Certificates, Series 2012-C2

Wells Fargo Commercial               Commercial Mortgage Pass-Through                Wells Fargo Bank, National
Mortgage Securities, Inc.            Certificates Series 2012-C8                     Association

J.P. Morgan Chase                    J.P. Morgan Chase Commercial Mortgage           Keycorp Real Estate Capital
Commercial Mortgage                  Securities Trust 2012-C8 Commercial             Markets, Inc.
Securities Corp.                     Mortgage Pass-Through Certificates
                                     Series 2012-C-8

GS Mortgage Securities               Commercial Mortgage Pass-Through                Wells Fargo Bank, National
Corporation II                       Certificates Series 2012-GCJ9                   Association

Wells Fargo Commercial               Commercial Mortgage Pass-Through                Wells Fargo Bank, National
Mortgage Securities, Inc.            Certificates Series 2012-C10                    Association

J.P. Morgan Chase                    J.P. Morgan Chase Commercial Mortgage           Midland Loan Services, a division of
Commercial Mortgage                  Securities Trust 2012-LC9 Commercial            PNC Bank, National Association
Securities Corp.                     Mortgage Pass-Through Certificates
                                     Series 2012-LC9

</TABLE>


9