Management’s
Assertion



Report
on Assessment of Compliance with Applicable Servicing Criteria



U.S.
Bank National Association (“U.S. Bank”) is responsible for assessing compliance as of and for the year ended December
31, 2021 with the servicing criteria set forth in Item 1122 (d) of Regulation AB applicable to it as set forth on Exhibit A hereto.
This report covers asset backed securities transactions within the U.S. Bank Corporate Trust Repackaging Platform1(the “Platform”)



U.S.
Bank hereby provides the following report on its assessment of compliance with the servicing criteria set forth in Item 1122 of
Regulation AB applicable to it and as described on Exhibit A hereto:



| | 1. | U.S.
Bank is responsible for assessing its compliance with the servicing criteria applicable to it as noted on the accompanying Exhibit
A;
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------



| | 2. | Except
as set forth in paragraph 3 below, U.S. Bank used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess
its compliance with the applicable servicing criteria;
| | -- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 3. | The
criteria listed in the column titled “Inapplicable Servicing Criteria” on Exhibit A hereto are inapplicable to U.S.
Bank based on the servicing activities it performs directly with respect to the Platform;
| | -- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 4. | U.S.
Bank has complied, in all material respects, with the applicable servicing criteria as of and for the year ended December 31,
2021; and
| | -- | --------------------------------------------------------------------------------------------------------------------------------------------



| | 5. | Ernst
& Young, LLP, a registered public accounting firm, has issued an attestation report on U.S. Bank’s assessment of compliance
with the applicable servicing criteria as of and for the year ended December 31, 2021.
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | U.S. BANK NATIONAL ASSOCIATION 
| | -------------------------------
| |                                
| | /s/ John Stern                 
| | Name: John Stern               
| | Title: Executive Vice President



Date:
February 25, 2022








1The U.S. Bank Corporate Trust Repackaging Platform (the "Platform") consists of the activities involved in the performance of servicing functions for publicly issued transactions comprised of the repackaging of corporate debt and/or other agency securities the securities of which were offered on or after January 1, 2006.  The Platform does not include asset-backed or mortgage–backed transactions supported by a pool of receivables or other financial assets.













EXHIBIT
A to Management’s Assertion

|Reference                            | Servicing Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | ApplicableServicingCriteria | InapplicableServicingCriteria
|------------------------------------ | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------- | -----------------------------
|General
    Servicing Considerations
|1122(d)(1)(i)                        | Policies and procedures are instituted to monitor
    any performance or other triggers and events of default in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                             | X                            
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | X2                          |                              
|1122(d)(1)(iii)                      | Any requirements in the transaction agreements
    to maintain a back-up servicer for the Pool Assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                             | X                            
|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.                                                                                                                                                                                                                                                                                                                                                                                                                            |                             | X                            
|1122(d)(1)(v)                        | Aggregation of information, as applicable, is
    mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                             | X                            
|Cash Collection and Administration  
|1122(d)(2)(i)                        | Payments on pool assets are deposited into the
    appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or
    such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                | X                           |                              
|1122(d)(2)(ii)                       | Disbursements made via wire transfer on behalf
    of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                           |                              
|1122(d)(2)(iii)                      | Advances of funds or guarantees regarding collections,
    cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as
    specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                             | X                            
|1122(d)(2)(iv)                       | The related accounts for the transaction, such
    as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with
    respect to commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                       | X                           |                              
|1122(d)(2)(v)                        | Each custodial account is maintained at a federally
    insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally
    insured depository institution” with respect to a foreign financial institution means a foreign financial institution
    that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                          | X                           |                              
|1122(d)(2)(vi)                       | Unissued checks are safeguarded so as to prevent
    unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                             | X                            
|1122(d)(2)(vi)                       | 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 are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) 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. | X                           |                              








| | 2 | No
servicing activities were performed by the Company that required the servicing criteria to be complied with.
| | - | ---------------------------------------------------------------------------------------------------------------





Corporate Trust Repackaging Platform2







|Reference                              | Servicing Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | ApplicableServicingCriteria | InapplicableServicingCriteria
|-------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------- | -----------------------------
|Investor
    Remittances and Reporting
|1122(d)(3)(i)                          | Reports to
    investors, including those to be     filed with the Commission, are maintained in accordance with the transaction agreements
    and applicable Commission requirements.     Specifically, such reports (A) are prepared in accordance with time frames 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. | X                           |                              
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | X                           |                              
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | X                           |                              
|1122(d)(3)(iv)                         | Amounts remitted to investors per the investor
    reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | X                           |                              
|Pool
    Asset Administration         
|1122(d)(4)(i)                          | Collateral or security on pool assets is maintained
    as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                             | X                            
|1122(d)(4)(ii)                         | Pool assets and related documents are safeguarded
    as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | X                           |                              
|1122(d)(4)(iii)                        | Any additions, removals or substitutions to
    the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | X                           |                              
|1122(d)(4)(iv)                         | Payments on pool assets, including any payoffs,
    made in accordance with the related pool asset documents are posted to the Servicer’s obligor records maintained no
    more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated
    to principal, interest or other items (e.g., escrow) in accordance with the related pool asset documents.                                                                                                                                                                                                                                                                             | X                           |                              
|1122(d)(4)(v)                          | The Servicer’s records regarding the pool
    assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | X                           |                              
|1122(d)(4)(vi)                         | Changes with respect to the terms or status of an obligor's pool assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                              |                             | X                            
|1122(d)(4)(vii)                        | Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                               |                             | X                            





Corporate Trust Repackaging Platform3







|Reference        | Servicing Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ApplicableServicingCriteria | InapplicableServicingCriteria
|---------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------- | -----------------------------
|1122(d)(4)(viii) | Records documenting collection efforts are maintained
    during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on
    at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities
    in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases
    where delinquency is deemed temporary (e.g., illness or unemployment).                                                                            | X                           |                              
|1122(d)(4)(ix)   | Adjustments to interest rates or rates of return
    for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                             | X                            
|1122(d)(4)(x)    | Regarding any funds held in trust for an obligor
    (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s pool asset documents, on at
    least an annual basis, or such other period specified in the transaction agreements; (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 are returned to
    the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in
    the transaction agreements. |                             | X                            
|1122(d)(4)(xi)   | Payments made on behalf of an obligor (such
    as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate
    bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days
    prior to these dates, or such other number of days specified in the transaction agreements.                                                                                                                                                                                               |                             | X                            
|1122(d)(4)(xii)  | Any late payment penalties in connection with
    any payment to be made on behalf of an obligor are paid from the Servicer’s funds and not charged to the obligor, unless
    the late payment was due to the obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                                               |                             | X                            
|1122(d)(4)(xiii) | Disbursements made on behalf of an obligor are
    posted within two business days to the obligor’s records maintained by the servicer, or such other number of days specified
    in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                         |                             | X                            
|1122(d)(4)(xiv)  | Delinquencies, charge-offs and uncollectible
    accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                             | X                            
|1122(d)(4)(xv)   | Any external enhancement or other support, identified
    in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                         |                             | X                            





Corporate Trust Repackaging Platform4