Trimont Real Estate Advisors, LLC

Management’s Report on Assessment of Compliance
with SEC Regulation AB Servicing Criteria

Trimont Real Estate Advisors, LLC
(“the Asserting Party”) is responsible for assessing compliance as of and for the year ended December 31, 2021 (“the
Reporting Period”) with the applicable servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s
Regulation AB as set forth in Exhibit A hereto (the “Applicable Servicing Criteria”). The transactions covered by this report
are only those transactions processed by the Asserting Party in capacity as special servicer for the asset backed securities transactions
listed in Exhibit B hereto (the “Platform”).

The Asserting Party has used the
servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB to assess its compliance
with the Applicable Servicing Criteria for the Reporting Period and has concluded that the Asserting Party has complied, in all material
respects, with the Applicable Servicing Criteria as of and for the year ended December 31, 2021 with respect to the Platform.

Grant Thornton, LLP, an independent
registered public accounting firm, has issued an attestation report on the assessment of compliance with the Applicable Servicing Criteria
as of and for the year ended December 31, 2021 as set forth in this assertion.



Trimont Real Estate Advisors, LLC
February 28, 2022



________________________________



Glen Peters

Chief Financial Officer










Exhibit A

|Regulation AB Criteria                 | JPMCC 2018-MINN                                                  | COMM 2012-CCRE2                                                                                                                                                                                                                                                                                                                                                              | GSMS 2018-TWR | Ashford Hospitality Trust 2018-KEYS | Bancorp 2018-CRE3 | Bancorp 2018-CRE4 | GSMS 2018-GS10 | CSMC 2017-PFHP | MSC 2017-ASHF | JPMCC 2020-ACE | RPT 2017-ROSS | Bancorp 2017-CRE2 | CGMS 2017 MDDR | 25 Liberty Street Trust 2016-225L | BANCORP 2016-CRE1
|-------------------------------------- | ---------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------- | ----------------------------------- | ----------------- | ----------------- | -------------- | -------------- | ------------- | -------------- | ------------- | ----------------- | -------------- | --------------------------------- | -----------------
|Section                                | Description                                                      | Criteria                                                                                                                                                                                                                                                                                                                                                                     |               |                                     |                   |                   |                |                |               |                |               |                   |                |                                   |                  
|General
    Servicing Considerations  
|(d)(1)(i)                              | Policies
    and 
    Procedures                                 | Policies
    and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction
    agreement.                                                                                                                                                                                                              | X             | X                                   | X                 | X                 | X              | X              | X             | X              | X             | X                 | X              | X                                 | X                
|(d)(1)(ii)                             | Policies
    and 
    Procedures 
    (vendors)                  | 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.                                                                                                                                                                 | X7            | X7                                  | X7                | X7                | X7             | X7             | X7            | X7             | X7            | X7                | X7             | X7                                | X7               
|(d)(1)(iii)                            | Back-up
    Servicer                                             | Any
    requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                        | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(1)(iv)                             | Fidelity
    Bond                                                | 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 agreement.                                                                                                     | X             | X                                   | X                 | X                 | X              | X              | X             | X              | X             | X                 | X              | X                                 | X                
|(d)(1)(v)                              | Accuracy
    of 
    Information                                 | Aggregation
    of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                                                                                                                                  | X4            | X4                                  | X1                | X4                | X4             | X4             | X1            | X4             | X4            | X1                | X1             | X4                                | X1               
|Cash
    Collection and Administration
|(d)(2)(i)                              | 2
    Days to deposit 
    Payments into 
    Custodial Accounts | Payments
    on pool assets are deposited into the appropriate 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.                                                                                                                               | X3            | X3                                  | X1                | X3                | X3             | X3             | X1            | X3             | X3            | X1                | X1             | X3                                | X1               
|(d)(2)(ii)                             | Wire
    Transfers                                               | Disbursements
    made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                    | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(2)(iii)                            | Advances                                                         | 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.                                                                                                                                            | X2            | X9                                  | X2                | X2                | X2             | X2             | X1            | X2             | X2            | X2                | X2             | X2                                | X2               
|(d)(2)(iv)                             | Commingling                                                      | The
    related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization,
    are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.                                                                                                               | X5            | X5                                  | X1                | X5                | X5             | X5             | X1            | X5             | X5            | X1                | X1             | X5                                | X1               
|(d)(2)(v)                              | Federally
    Insured 
    Institution                           | 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. | X5            | X5                                  | X1                | X5                | X5             | X5             | X1            | X5             | X5            | X1                | X1             | X5                                | X1               
|(d)(2)(vi)                             | Unissued
    Checks                                              | Unissued
    checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                    | X             | X                                   | X1                | X                 | X              | X              | X1            | X              | X             | X1                | X1             | X                                 | X1               










Exhibit A



|Regulation AB Criteria                | JPMCC 2018-MINN                         | COMM 2012-CCRE2                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | GSMS 2018-TWR | Ashford Hospitality Trust 2018-KEYS | Bancorp 2018-CRE3 | Bancorp 2018-CRE4 | GSMS 2018-GS10 | CSMC 2017-PFHP | MSC 2017-ASHF | JPMCC 2020-ACE | RPT 2017-ROSS | Bancorp 2017-CRE2 | CGMS 2017 MDDR | 25 Liberty Street Trust 2016-225L | BANCORP 2016-CRE1
|------------------------------------- | --------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------- | ----------------------------------- | ----------------- | ----------------- | -------------- | -------------- | ------------- | -------------- | ------------- | ----------------- | -------------- | --------------------------------- | -----------------
|Section                               | Description                             | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |               |                                     |                   |                   |                |                |               |                |               |                   |                |                                   |                  
|(d)(2)(vii)                           | Reconciliations                         | 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. | X5            | X5                                  | X1                | X5                | X5             | X5             | X1            | X5             | X5            | X1                | X1             | X5                                | X1               
|Investor
    Remittance and Reporting
|(d)(3)(i)                             | Reports
    to the 
    Investor        | Reports to investors, including those
    to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements.
    Specifically, such reports:
    (a) are prepared in accordance
    with timeframes and other terms set forth in the transaction agreements; (b) provide information calculated in accordance with the
    terms specified in the transaction agreements; (c) are filed with the Commission as required by its rules and regulations; and (d)
    agree with investors' or the trustee's records as to the total unpaid principal balance and number of pool assets serviced by the
    servicer.                                                  | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(3)(ii)                            | Investor
    Remittance                 | Amounts
    due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the
    transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(3)(iii)                           | Investor's
    Records                  | 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/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(3)(iv)                            | Remittance
    and 
    Bank Statements | Amounts
    remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|Pool
    Asset Administration        
|(d)(4)(i)                             | Collateral/Security
    on Pool Assets  | Collateral
    or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X6            | X6                                  | X1                | X6                | X6             | X6             | X1            | X6             | X6            | X1                | X1             | X6                                | X1               
|(d)(4)(ii)                            | Safeguard
    Pool 
    Assets          | Pool
    assets and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(4)(iii)                           | Changes
    to the Pool Assets          | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | X8            | X8                                  | X1                | X8                | X8             | X8             | X1            | X8             | X8            | X1                | X1             | X8                                | X1               










Exhibit A



|Regulation AB Criteria | JPMCC 
2018-MINN                       | COMM 2012-CCRE2                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | GSMS 2018-TWR | Ashford Hospitality Trust
 2018-KEYS | Bancorp 2018-CRE3 | Bancorp 2018-CRE4 | GSMS 2018-GS10 | CSMC 2017-PFHP | MSC 2017-ASHF | JPMCC 2020-ACE | RPT 2017-ROSS | Bancorp 2017-CRE2 | CGMS 2017 MDDR | 25 Liberty Street Trust 2016-225L | BANCORP 2016-CRE1
|---------------------- | -------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------- | ------------------------------------ | ----------------- | ----------------- | -------------- | -------------- | ------------- | -------------- | ------------- | ----------------- | -------------- | --------------------------------- | -----------------
|Section                | Description                            | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |               |                                      |                   |                   |                |                |               |                |               |                   |                |                                   |                  
|(d)(4)(iv)             | Obligor's
    Payment Record           | 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.                                                                                                                        | N/A           | N/A                                  | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(4)(v)              | Pool
    Asset Records Match UPB       | The
    servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                              | N/A           | N/A                                  | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(4)(vi)             | Loan
    Modifications                 | 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.                                                                                                                                                                                                                                                                                             | X10           | X                                    | X1                | X10               | X10            | X10            | X1            | X10            | X10           | X1                | X1             | X                                 | X1               
|(d)(4)(vii)            | Loss
    Mitigation 
    Actions       | 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 agreement.                                                                                                                                                                                                                                         | X             | X                                    | X1                | X                 | X              | X              | X1            | X              | X             | X1                | X1             | X                                 | X1               
|(d)(4)(viii)           | Collection
    Efforts 
    Documented | 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             | X                                    | X1                | X                 | X              | X              | X1            | X              | X             | X1                | X1             | X                                 | X1               
|(d)(4)(ix)             | ARMs                                   | Adjustments
    to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                          | N/A           | N/A                                  | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(4)(x)              | Escrow
    Funds                       | Regarding
    any funds held in trust for an obligor such funds are (a) 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)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. | N/A           | N/A                                  | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(4)(xi)             | Timely
    Payments                    | 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.                                                                                                                                               | N/A           | N/A                                  | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              










Exhibit A



|Regulation AB Criteria | JPMCC 2018-MINN                                                   | COMM 2012-CCRE2                                                                                                                                                                                                                             | GSMS 2018-TWR | Ashford Hospitality Trust 2018-KEYS | Bancorp 2018-CRE3 | Bancorp 2018-CRE4 | GSMS 2018-GS10 | CSMC 2017-PFHP | MSC 2017-ASHF | JPMCC 2020-ACE | RPT 2017-ROSS | Bancorp 2017-CRE2 | CGMS 2017 MDDR | 25 Liberty Street Trust 2016-225L | BANCORP 2016-CRE1
|---------------------- | ----------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------- | ----------------------------------- | ----------------- | ----------------- | -------------- | -------------- | ------------- | -------------- | ------------- | ----------------- | -------------- | --------------------------------- | -----------------
|Section                | Description                                                       | Criteria                                                                                                                                                                                                                                    |               |                                     |                   |                   |                |                |               |                |               |                   |                |                                   |                  
|(d)(4)(xii)            | Late
    Payment 
    Penalties                                   | 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. | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(4)(xiii)           | Obligor's
    Records                                             | 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.                           | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(4)(xiv)            | Delinquencies,
    
    Charge-offs, and 
    Other Uncollectible | Delinquencies,
    Charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                       | N/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              
|(d)(4)(xv)             | Any
    External 
    Enhancement                                 | 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/A           | N/A                                 | N/A               | N/A               | N/A            | N/A            | N/A           | N/A            | N/A           | N/A               | N/A            | N/A                               | N/A              










Exhibit A



|Regulation AB Criteria                 | GSMS 2016-GS3                                                    | BSREP 2021-DC                                                                                                                                                                                                                                                                                                                                                                | GSMS 2021-ROSS | CF 2019-BOSS | BANCORP 2019-CRE5 | BBCMS 2019-CLP | BBCMS 2019-Core | BCMARK 2019-B12 | BX 2019-MMP | CAMB Trust 2019-LIFE | CF 2019-CF1 | MTRO 2019-TECH | NOHT 2019-HNLA | NYT 2019-NYT
|-------------------------------------- | ---------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------- | ------------ | ----------------- | -------------- | --------------- | --------------- | ----------- | -------------------- | ----------- | -------------- | -------------- | ------------
|Section                                | Description                                                      | Criteria                                                                                                                                                                                                                                                                                                                                                                     |                |              |                   |                |                 |                 |             |                      |             |                |                |             
|General
    Servicing Considerations  
|(d)(1)(i)                              | Policies
    and 
    Procedures                                 | Policies
    and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction
    agreement.                                                                                                                                                                                                              | X              | X            | X                 | X              | X               | X               | X           | X                    | X           | X              | X              | X           
|(d)(1)(ii)                             | Policies
    and 
    Procedures 
    (vendors)                  | 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.                                                                                                                                                                 | X7             | X7           | X7                | X7             | X7              | X7              | X7          | X7                   | X7          | X7             | X7             | X7          
|(d)(1)(iii)                            | Back-up
    Servicer                                             | Any
    requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                        | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(1)(iv)                             | Fidelity
    Bond                                                | 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 agreement.                                                                                                     | X              | X            | X                 | X              | X               | X               | X           | X                    | X           | X              | X              | X           
|(d)(1)(v)                              | Accuracy
    of 
    Information                                 | Aggregation
    of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                                                                                                                                  | X1             | X1           | X1                | X4             | X4              | X1              | X1          | X1                   | X1          | X1             | X1             | X1          
|Cash
    Collection and Administration
|(d)(2)(i)                              | 2
    Days to deposit 
    Payments into 
    Custodial Accounts | Payments
    on pool assets are deposited into the appropriate 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.                                                                                                                               | X1             | X1           | X1                | X3             | X3              | X1              | X1          | X1                   | X1          | X1             | X1             | X1          
|(d)(2)(ii)                             | Wire
    Transfers                                               | Disbursements
    made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                    | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(2)(iii)                            | Advances                                                         | 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.                                                                                                                                            | X1             | X2           | X2                | X9             | X2              | X2              | X2          | X2                   | X2          | X2             | X1             | X2          
|(d)(2)(iv)                             | Commingling                                                      | The
    related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization,
    are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.                                                                                                               | X1             | X1           | X1                | X5             | X5              | X1              | X1          | X1                   | X1          | X1             | X1             | X1          
|(d)(2)(v)                              | Federally
    Insured Institution                                | 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. | X1             | X1           | X1                | X5             | X5              | X1              | X1          | X1                   | X1          | X1             | X1             | X1          
|(d)(2)(vi)                             | Unissued
    Checks                                              | Unissued
    checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                    | X1             | X1           | X1                | X              | X               | X1              | X1          | X1                   | X1          | X1             | X1             | X1          










Exhibit A

|Regulation AB Criteria                | GSMS 2016-GS3                          | BSREP 2021-DC                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | GSMS 2021-ROSS | CF 2019-BOSS | BANCORP 2019-CRE5 | BBCMS 2019-CLP | BBCMS 2019-Core | BCMARK 2019-B12 | BX 2019-MMP | CAMB Trust 2019-LIFE | CF 2019-CF1 | MTRO 2019-TECH | NOHT 2019-HNLA | NYT 2019-NYT
|------------------------------------- | -------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------- | ------------ | ----------------- | -------------- | --------------- | --------------- | ----------- | -------------------- | ----------- | -------------- | -------------- | ------------
|Section                               | Description                            | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                |              |                   |                |                 |                 |             |                      |             |                |                |             
|(d)(2)(vii)                           | Reconciliations                        | 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. | X1             | X1           | X1                | X5             | X5              | X1              | X1          | X1                   | X1          | X1             | X1             | X1          
|Investor
    Remittance and Reporting
|(d)(3)(i)                             | Reports
    to the 
    Investor       | Reports to investors, including those
    to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements.
    Specifically, such reports:
    (a) are prepared in accordance with timeframes
    and other terms set forth in the transaction agreements; (b) provide information calculated in accordance with the terms specified
    in the transaction agreements; (c) are filed with the Commission as required by its rules and regulations; and (d) agree with investors'
    or the trustee's records as to the total unpaid principal balance and number of pool assets serviced by the servicer.                                                      | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(3)(ii)                            | Investor
    Remittance                | Amounts
    due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the
    transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(3)(iii)                           | Investor's
    Records                 | 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/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(3)(iv)                            | Remittance
    and Bank Statements     | Amounts
    remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|Pool
    Asset Administration        
|(d)(4)(i)                             | Collateral/Security
    on Pool Assets | Collateral
    or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X1             | X1           | X1                | X6             | X6              | X1              | X1          | X1                   | X1          | X1             | X1             | X1          
|(d)(4)(ii)                            | Safeguard
    Pool 
    Assets         | Pool
    assets and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(iii)                           | Changes
    to the Pool Assets         | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | X1             | X1           | X1                | X8             | X8              | X1              | X1          | X1                   | X1          | X1             | X1             | X1          










Exhibit A

|Regulation AB Criteria | GSMS 2016-GS3                          | BSREP 2021-DC                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | GSMS 2021-ROSS | CF 2019-BOSS | BANCORP 2019-CRE5 | BBCMS 2019-CLP | BBCMS 2019-Core | BCMARK 2019-B12 | BX 2019-MMP | CAMB Trust 2019-LIFE | CF 2019-CF1 | MTRO 2019-TECH | NOHT 2019-HNLA | NYT 2019-NYT
|---------------------- | -------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------- | ------------ | ----------------- | -------------- | --------------- | --------------- | ----------- | -------------------- | ----------- | -------------- | -------------- | ------------
|Section                | Description                            | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                |              |                   |                |                 |                 |             |                      |             |                |                |             
|(d)(4)(iv)             | Obligor's
    Payment Record           | 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.                                                                                                                        | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(v)              | Pool
    Asset Records Match UPB       | The
    servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                              | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(vi)             | Loan
    Modifications                 | 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.                                                                                                                                                                                                                                                                                             | X10            | X            | X1                | X10            | X10             | X10             | X1          | X10                  | X10         | X1             | X1             | X           
|(d)(4)(vii)            | Loss
    Mitigation 
    Actions       | 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 agreement.                                                                                                                                                                                                                                         | X              | X            | X1                | X              | X               | X               | X1          | X                    | X           | X1             | X1             | X           
|(d)(4)(viii)           | Collection
    Efforts 
    Documented | 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              | X            | X1                | X              | X               | X               | X1          | X                    | X           | X1             | X1             | X           
|(d)(4)(ix)             | ARMs                                   | Adjustments
    to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                          | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(x)              | Escrow
    Funds                       | Regarding
    any funds held in trust for an obligor such funds are (a) 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)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. | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(xi)             | Timely
    Payments                    | 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.                                                                                                                                               | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         








Exhibit A

|Regulation AB Criteria | GSMS 2016-GS3                                                                   | BSREP 2021-DC                                                                                                                                                                                                                                                                                                                                                                                               | GSMS 2021-ROSS | CF 2019-BOSS | BANCORP 2019-CRE5 | BBCMS 2019-CLP | BBCMS 2019-Core | BCMARK 2019-B12 | BX 2019-MMP | CAMB Trust 2019-LIFE | CF 2019-CF1 | MTRO 2019-TECH | NOHT 2019-HNLA | NYT 2019-NYT
|---------------------- | ------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------- | ------------ | ----------------- | -------------- | --------------- | --------------- | ----------- | -------------------- | ----------- | -------------- | -------------- | ------------
|Section                | Description                                                                     | Criteria                                                                                                                                                                                                                                                                                                                                                                                                    |                |              |                   |                |                 |                 |             |                      |             |                |                |             
|(d)(4)(xi)             | Timely
    Payments                                                             | 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. | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(xii)            | Late
    Payment 
    Penalties                                                 | 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.                                                                                                                                                                 | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(xiii)           | Obligor's
    Records                                                           | 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.                                                                                                                                                                                           | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(xiv)            | Delinquencies,
    
    Charge-offs, and 
    Other Uncollectible 
    Accounts | Delinquencies,
    Charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                       | N/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         
|(d)(4)(xv)             | Any
    External 
    Enhancement                                               | 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/A            | N/A          | N/A               | N/A            | N/A             | N/A             | N/A         | N/A                  | N/A         | N/A            | N/A            | N/A         












Exhibit A Key

|X1                                                                                                                                                                                                            | This
    criteria is applicable for the securitization; however, there were no loans serviced under this securitization during the reporting
    period.                                                                                                            
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|X2                                                                                                                                                                                                            | With
    respect to Applicable Servicing Criteria, the securitization was not in scope based the transaction agreement.                                                                                                                                             
|X3                                                                                                                                                                                                            | With
    respect to item 1122(d)(2)(i), this criteria is applicable for the securitization; however, there was no cash collected for loans
    under the securitization during the reporting period.                                                                
|X4                                                                                                                                                                                                            | With
    respect to item 1122(d)(1)(v), this criteria is applicable for the securitization; however, there was no aggregation of information
    related to reporting to external parties.                                                                          
|X5                                                                                                                                                                                                            | With
    respect to item 1122(d)(2)(iv), 1122(d)(2)(v) and 1122(d)(2)(vii), the criteria is applicable for the securitization; however, there
    were no custodial bank accounts maintained under the securitization during the reporting period.                  
|X6                                                                                                                                                                                                            | With
    respect to item 1122(d)(4)(i), the criteria is applicable for the securitization; however, as special servicer, Trimont was not responsible
    for maintaining collateral or security on pool assets under the securitization during the reporting period.
|X7                                                                                                                                                                                                            | With
    respect to item 1122(d)(1)(ii), this criteria is applicable for the securitization; however, there were no material servicing activities
    outsourced to third parties under this securitization during the reporting period.                            
|X8                                                                                                                                                                                                            | With
    respect to item 1122(d)(4)(iii), the criteria is applicable for the securitization; however, there were no additions, removals, or
    substitutions to the pool assets under the securitization during the reporting period.                              
|X9                                                                                                                                                                                                            | With
    respect to item 1122(d)(2)(iii), the criteria is applicable for the securitization; however, there were no advances of funds or guarantees
    regarding collections, cash flows or distributions under the securitization during the reporting period.    
|X10                                                                                                                                                                                                           | With
    respect to item 1122(d)(4)(vi), the criteria is applicable for the securitization; however, there were no loan modifications under
    the securitization during the reporting period.                                                                     
|With
    respect to Applicable Servicing Criteria cells in Exhibit A that are denoted with an "N/A", per review of the respective
    servicing agreement, the criteria was not in scope for the transaction.






Exhibit
B

|Name                                   | Transaction                                                                                                                                                              | Period
    of Service                  
|-------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ---------------------------------------
|GSMS
    2021-ROSS                     | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2021-ROSS pursuant to the Pooling and Servicing Agreement
    dated May 28, 2021      | May
    28, 2021 - December 31, 2021   
|BSREP
    2021-DC                      | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series BSREP 2021-DC pursuant to the Pooling and Servicing Agreement dated
    August 16, 2021    | August
    16, 2021 - December 31, 2021
|225
    Liberty Street Trust 2016-225L | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series 2016-225L pursuant to the Pooling and Servicing Agreement dated
    February 6, 2016       | January
    1, 2021 - December 31, 2021
|Bancorp
    2016-CRE1                  | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series BANCORP 2016-CRE1 pursuant to the Pooling and Servicing Agreement dated December 6, 2016   | January
    1, 2021 - August 17, 2021  
|GSMS
    2016-GS3                      | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2016-GS3 pursuant to the Pooling and Servicing Agreement dated
    September 1, 2016  | January
    1, 2021 - December 31, 2021
|Bancorp
    2017-CRE2                  | Special
Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2017-CRE2 pursuant to the Pooling and Servicing Agreement dated
August 30, 2017        | January
    1, 2021 - December 31, 2021
|CGMS
    2017-MDDR                     | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series CGMS 2017 MDDR pursuant to the Pooling and Servicing Agreement
    dated July 6, 2017      | January
    1, 2021 - December 31, 2021
|RPT
    2017-ROSS                      | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series RPT 2017-ROSS pursuant to the Pooling and Servicing Agreement dated
    June 30, 2017      | January
    1, 2021 - June 30, 2021    
|MSC
    2017-ASHF                      | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series MSC 2017-ASHF pursuant to the Pooling and Servicing Agreement dated
    December 9, 2017   | January
    1, 2021 - December 31, 2021
|CSMC
    2017-PFHP                     | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series CSMC 2017-PFHP pursuant to the Pooling and Servicing Agreement
    dated December 19, 2017 | January
    1, 2021 - December 31, 2021
|GSMS
    2018-GS10                     | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-GS10 pursuant to the Pooling and Servicing Agreement
    dated July 1, 2018      | January
    1, 2021 - December 31, 2021
|Bancorp
    2018-CRE4                  | Special
Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2018-CRE4 pursuant to the Pooling and Servicing Agreement dated
September 27, 2018     | January
    1, 2021 - December 31, 2021
|Bancorp
    2018-CRE3                  | Special
Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2018-CRE3 pursuant to the Pooling and Servicing Agreement dated
March 29, 2018         | January
    1, 2021 - December 31, 2021
|Ashford
    Hospitality Trust 2018     | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series AHT 2018 Keys pursuant to the Pooling and Servicing Agreement dated July 16, 2018          | January
    1, 2021 - December 31, 2021
|GSMS
    2018-TWR                      | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-TWR pursuant to the Pooling and Servicing Agreement dated
    July 31, 2018      | January
    1, 2021 - December 31, 2021
|COMM
    2012 CCRE2                    | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series COMM 2012-CCRE2 pursuant to the Pooling and Servicing Agreement
    dated August 1, 2018   | January
    1, 2021 - December 31, 2021










Exhibit
B

|JPMCC
    2018-MINN      | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series JPMCC 2018-MINN pursuant to the Pooling and Servicing Agreement
    dated December 7, 2018   | January
    1, 2021 - December 31, 2021
|------------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------
|CF
    2019-BOSS         | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series CF-TRUST 19 BOSS pursuant to the Pooling and Servicing Agreement
    dated November 26, 2019 | January
    1, 2021 - December 31, 2021
|Bancorp
    2019-CRE5    | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series BANCORP 2019-CRES pursuant to the Pooling and Servicing Agreement
    dated March 28, 2019   | January
    1, 2021 - December 31, 2021
|BBCMS
    2019-CLP       | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series BBCMS 2019-CLP pursuant to the Pooling and Servicing Agreement
    dated February 27, 2019   | January
    1, 2021 - June 15, 2021    
|BBCMS
    2019-CORE      | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series BBCMS 2019-Core pursuant to the Pooling and Servicing Agreement
    dated March 15, 2019     | January
    1, 2021 - December 31, 2021
|BCMARK
    2019-B12      | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series BCMARK 2019-B12 pursuant to the Pooling and Servicing Agreement
    dated August 1, 2019     | January
    1, 2021 - June 11, 2021    
|BX
    2019-MMP          | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series BX 2019-MMP pursuant to the Pooling and Servicing Agreement dated
    August 29, 2019        | January
    1, 2021 - December 31, 2021
|CAMB
    Trust 2019-LIFE | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series CAMB 2019-LIFE pursuant to the Pooling and Servicing Agreement
    dated January 9, 2019     | January
    1, 2021 - December 31, 2021
|CF
    2019-CF1          | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series CF 2019-CFI pursuant to the Pooling and Servicing Agreement dated
    April 1, 2019          | January
    1, 2021 - June 11, 2021    
|MTRO
    2019-TECH       | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series MTRO 2019-TECH pursuant to the Pooling and Servicing Agreement
    dated February 9, 2019    | January
    1, 2021 - December 31, 2021
|NOHT
    2019-HNLA       | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series NOHT 2019-HNLA pursuant to the Pooling and Servicing Agreement
    dated May 15, 2019        | January
    1, 2021 - February 19, 2021
|NYT
    2019-NYT         | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series NYT 2019-NYT pursuant to the Pooling and Servicing Agreement dated
    January 30, 2019      | January
    1, 2021 - December 31, 2021
|JPMCC
    2020-ACE       | Special
    Servicer for Commercial Mortgage Pass-Through Certificates Series JPMCC 2020-ACE pursuant to the Pooling and Servicing Agreement
    dated February 20, 2020   | January
    1, 2021 - December 31, 2021