**Certification RegardingCompliance with Applicable Servicing Criteria**

** **

**To PricewaterhouseCoopersLLP**

 

1. Prudential Asset Resources,Inc. (the "Servicer") is responsible for assessing compliance by itwith the servicing criteria applicable to it under paragraph (d) of Item 1122of Regulation AB (the "Servicing Criteria"), as of and for the yearended December 31, 2016, as set forth in Exhibit A hereto in connectionwith commercial mortgage securities transactions for the-mortgage loansecuritizations listed in Exhibit C;

 

2. Except as set forth in paragraph3 below, the Servicer used the criteria set forth in paragraph (d) of Item 1122of Regulation AB to assess the compliance with the Servicing Criteria;

 

3. The criteria described asnot applicable on Exhibit A hereto are inapplicable to the Servicerbased on the activities it performs with respect to commercial mortgagesecurities transactions involving mortgage loans, also the Servicer hasidentified specific servicing criteria for which no transaction activityoccurred;

 

4. The Servicer has engagedcertain vendors, which are not deemed to be servicers as defined in Item1101(j) of Regulation AB (the "Vendors"), to perform specific andlimited activities or activities scripted by the Servicer as of and during theReporting Period, and the Servicer elects to take responsibility for assessingcompliance with the Servicing Criteria or portion of the Servicing Criteriaapplicable to such Vendors as set forth in Exhibit A hereto (such criteria, the"Applicable Servicing Criteria Performed by Vendor(s)").

 

The Servicer has policies andprocedures in place designed to provide reasonable assurance that the Vendor'sactivities comply in all material respects for purposes of Regulation AB withthe Applicable Vendor Servicing Criteria. The Servicer (i) has not identifiedand is not aware of any material instance of noncompliance by the Vendors withthe Applicable Vendor Servicing Criteria that would affect the Servicer'scompliance and (ii) has not identified any material deficiency in its policiesand procedures to monitor the compliance by the Vendor with the ApplicableServicing Criteria Performed by Vendor(s) as of December 31, 2016 and for theReporting Period.

 

5. The Servicer has complied,in all material respects, with the Servicing Criteria as of and for the yearending December 31, 2016; and

 

6. PricewaterhouseCoopers LLPhas issued an attestation report with respect to the Servicer's assessment ofcompliance with the Servicing Criteria as of and for the year ended December31, 2016, which attestation report is included in Exhibit B attachedhereto. This Certification is being provided to PricewaterhouseCoopers LLP infulfillment of its requirement for issuance of the final report.

 

February 22, 2017

 

Prudential Asset Resources,Inc.

 

/s/ Timothy E. Steward

Timothy E. Steward, President

 

/s/ Lukshmi A. Subendranathan

Lukshmi A. Subendranathan,Vice President

 

 

**EXHIBIT A**

 

| **SERVICING CRITERIA**

**Reg AB Portfolio** | **APPLICABLE SERVICING   CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **INAPPLICABLE SERVICING   CRITERIA** |                   |
|----------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|------------------------|
|  

 

Reference                    |  

 

Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Performed by Servicer                 | Performed by Vendor(s) |   |   |
| **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y                                     |                   |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                     |                   |   |   |
| 1122(d)(1)(iii)                              | Any requirements in the transaction  agreements to maintain a back-up servicer for the mortgage loans are  maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                  |                   | N/A |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                           | Y#1                                   |                   |   |   |
| 1122(d)(1)(v)                                | Aggregation of information, as  applicable, is mathematically accurate and the information conveyed  accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Y                                     |                   |   |   |
| **Cash Collection and  Administration**      |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
| 1122(d)(2)(i)                                | Payments on mortgage loans 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | Y                                     |                   |   |   |
| 1122(d)(2)(ii)                               | Disbursements made via wire  transfer on behalf of an obligor or to an investor are made only by  authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Y                                     | Y#2                    |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Y                                     |                   |   |   |
| 1122(d)(2)(iv)                               | The related accounts for the  transaction, such as cash reserve accounts or accounts established as a form  of overcollateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in  the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y                                     |                   |   |   |
| 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-l(b)(l) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                                       | Y                                     |                   |   |   |
| 1122(d)(2)(vi)                               | Unissued checks are safeguarded  so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Y                                     | Y#2                    |   |   |
| 1122(d)(2)(vii)                              | Reconciliations are prepared  on a monthly basis for all commercial mortgage 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. | Y                                     | Y#3                    |   |   |
| **Investor Remittances and  Reporting**      |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
| 1122(d)(3)(i)                                | Reports to investors, including  those to be filed with the Commission, are maintained in accordance with the  transaction agreements and applicable Commission requirements. Specifically,  such reports (A) are prepared in accordance with timeframes and other terms  set forth in the transaction agreements; (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 mortgage loans serviced by the Servicer.                                                   | Y for (A&B)                       |                   | N/A for (C&D) |   |
| 1122(d)(3)(ii)                               | Amounts due to investors are  allocated and remitted in accordance with timeframes, distribution priority  and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                  |                   | N/A |   |
| 1122(d)(3)(iii)                              | Disbursements made to an  investor are posted within two business days to the Servicer's investor  records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                  |                   | N/A |   |
| 1122(d)(3)(iv)                               | Amounts remitted to  investors per the investor reports agree with cancelled checks, or other form  of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                  |                   | N/A |   |
| **Pool Asset Administration**                |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
| 1122(d)(4)(i)                                | Collateral or security on  mortgage loans is maintained as required by the transaction agreements or  related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Y                                     |                   |   |   |
| 1122(d)(4)(ii)                               | Mortgage loan and related  documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y#4                                   |                   |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Y#5                                   |                   |   |   |
| 1122(d)(4)(iv)                               | Payments on mortgage loans,  including any payoffs, made in accordance with the related mortgage loan  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  mortgage  loan documents.                                                                                                                                                                                                                                                | Y                                     |                   |   |   |
| 1122(d)(4)(v)                                | The Servicer's records  regarding the mortgage loans agree with the Servicer's records with respect  to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Y                                     |                   |   |   |
| 1122(d)(4)(vi)                               | Changes with respect to the  terms or status of an obligor's mortgage loans (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.                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Y                                     |                   |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                           | Y#6                                   |                   |   |
| 1122(d)(4)(viii)                             | Records documenting  collection efforts are maintained during the period a mortgage loan 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 mortgage loans including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or unemployment).                                                                                                                                                                                          | Y                                     |                   |   |
| 1122(d)(4)(ix)                               | Adjustments to interest  rates or rates of return for mortgage loans with variable rates are computed  based on the related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Y                                     |                   |   |
| 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 mortgage loan 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 mortgage loan documents and state laws; and (C)  such funds are returned to the obligor within 30 calendar days of full  repayment of the related mortgage loans, or such other number of days  specified in the transaction agreements.                                                                                                         | Y                                     |                   |   |
| 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.                                                                                                                                                                                                                                                                                                                 | Y                                     | Y#2                    |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Y                                     | Y#2                    |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | Y                                     |                   |   |
| 1122(d)(4)(xiv)                              | Delinquencies, charge-offs and  uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Y                                     |                   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                  |                   | N/A |
|                                         |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                  |                   |   |   |   |   |   |   |   |

 

**Y**=Yes

 

**Y#l** = Fidelity bond and errors and omissions policies in forcefor Prudential. In addition, fidelity bond and errors and omissions policiesare in force for the following vendors: Silverskills ($1MM), NTS ($2MM) andCovius ($1MM).

 

**Y#2** = The only third party vendor to whom this applies is NationalTax Search, LLC (NTS). PAR transferred to the vendor the process of payingproperty taxes to the local government taxing authorities. Payment is made onlyafter review, authorization and transfer of funds is completed by PAR. Policiesand procedures are in place to monitor this vendor.

 

**Y#3** = Silverskills Private Limited (SPL) performs monthlyP&I, Tax & Insurance, Reserve, and Suspense account compilationsincluding review and approval of all self reconciling bank accounts. PAR hasprocedures in place to review work performed by SPL.

 

**Y#4** = As outlined in the PSAs, the primary responsibilityfor safeguarding all original documents (except Letters of Credit, which areheld by PAR) is with the named Document Custodian. The named Trustee hasoversight responsibility for the custodian, not the Servicer. However, to theextent that loans are secured by Letters of Credit or loans are modified orsome other credit action occurs which generates a new or revised loan document,then Servicer complies with this criteria.

 

**Y#5** = PAR's role related to additions, removals orsubstitutions to the asset pool only occurs after a decision is made to somodify the asset pool.  The responsibility and any decisions related toadditions, removals or substitutions to the asset pool is with the Trustee,Issuer and related mortgage loan seller. PAR as Servicer has not experiencedany of these types of actions in its CMBS asset pools.

 

**Y#6** = There are currently no transactions during the yearthat applied to this servicing criteria within the Reg AB where PAR was namedthe special servicer.

 

**N/A** = Not applicable, as the criteria is not theresponsibility of the primary/master servicer or no event has occurred whichtriggered an action by the primary/master servicer.

 

 

**EXHIBIT C**

 

**List of CommercialMortgage-Backed Security Transactions - RegAB Portfolio**

 

 

1. Morgan Stanley Capital IInc., Commercial Mortgage Pass-Through Certificates, Series 2006-IQ12("MSCI 2006-IQ12")

 

2. Merrill Lynch MortgageTrust 2006-C2, Commercial Mortgage Pass-Through Certificates, Series 2006-C2("MLMT 2006-C2")

 

3. Bear Steams CommercialMortgage Securities II Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR11 ("BSCMS 2006-PWR11")

 

4. Bear Steams Commercial MortgageSecurities Inc., Commercial Mortgage Pass-Through Certificates, 2006-PWR12("BSCMS 2006-PWR12")

 

5. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR 13 ("BSCMS 2006-PWR13")

 

6. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2006-PWR14 ("BSCMS 2006-PWR14")

 

7. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR15 ("BSCMS 2007-PWR15")

 

8. Morgan Stanley Capital IInc., Commercial Mortgage Pass-Through Certificates, Series 2007-IQ14("MSCI 2007-IQ14")

 

9. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR16 ("BSCMS 2007-PWR16")

 

10. Morgan Stanley Capital IInc., Commercial Mortgage Pass-Through Certificates, 2007-IQ15 ("MSCI2007-IQ15")

 

11. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR17 ("BSCMS 2007-PWR17")

 

12. Bear Stearns CommercialMortgage Securities Inc., Commercial Mortgage Pass-Through Certificates,2007-PWR18 ("BSCMS 2007-PWR18")

 

13. WFRBS Commercial MortgageTrust 2012-C6, Commercial Mortgage Pass-Through Certificates, Series 2012-C6

 

14. WFRBS Commercial MortgageTrust 2012-C7, Commercial Mortgage Pass-Through Certificates, Series 2012-C7

 

15. WFRBS Commercial MortgageTrust 2012-C8, Commercial Mortgage Pass-Through Certificates, Series 2012-C8

 

16. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2012-C9

 

17. WFRBS Commercial MortgageTrust 2012-C10, Commercial Mortgage Pass-Through Certificates, Series 2012-C10

 

18. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2013- C11

 

19. WFRBS Commercial MortgageTrust 2013-C12, Commercial Mortgage Pass-Through Certificates, Series 2013-C12

 

20. WFRBS Commercial MortgageTrust 2013-C13, Commercial Mortgage Pass-Through Certificates, Series 2013-C13

 

21. WFRBS Commercial Mortgage Trust2013-C14, Commercial Mortgage Pass-Through Certificates, Series 2013-C14

 

22. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2013- C15

 

23. WFRBS Commercial MortgageTrust 2013-C16, Commercial Mortgage Pass-Through Certificates, Series 2013-C16

 

24. WFRBS Commercial MortgageTrust 2013-C17, Commercial Mortgage Pass-Through Certificates, Series 2013-C17

 

25. WFRBS Commercial MortgageTrust 2013-C18, Commercial Mortgage Pass-Through Certificates, Series 2013-C18

 

26. COMM 2013-CCRE13 MortgageTrust Commercial Mortgage Pass-Through Certificates

 

27. COMM 2014-CCRE14 MortgageTrust Commercial Mortgage Pass-Through Certificates

 

28. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014- C19

 

29. WFRBS Commercial MortgageTrust 2014- C20, Commercial Mortgage Pass-Through Certificates, Series 2014-C20

 

30. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014- C21

 

31. WFRBS Commercial Mortgage Trust2014-C22, Commercial Mortgage Pass-Through Certificates, Series 2014-C22

 

32. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014- C23

 

33. WFRBS Commercial MortgageTrust 2014-C24, Commercial Mortgage Pass-Through Certificates, Series 2014-C24

 

34. Wells Fargo CommercialMortgage Trust 2014-LC18, Commercial Mortgage Pass-Through Certificates, Series2014-LC18

 

35. RBS Commercial FundingInc., Commercial Mortgage Pass-Through Certificates, Series 2014- C25

 

36. Wells Fargo CommercialMortgage Trust 2015-C26, Commercial Mortgage Pass-Through Certificates, Series2015-C26

 

37. Wells Fargo CommercialMortgage Trust 2015-C27, Commercial Mortgage Pass-Through Certificates, Series2015-C27

 

38. Wells Fargo CommercialMortgage Trust 2015-C28, Commercial Mortgage Pass-Through Certificates, Series2015-C28

 

39. Wells Fargo CommercialMortgage Trust 2015-SG1, Commercial Mortgage Pass-Through Certificates, Series2015-SG1

 

40. Wells Fargo CommercialMortgage Trust 2015-C31, Commercial Mortgage Pass-Through Certificates, Series2015-C31

 

41. CFCRE 2016-C3 MortgageTrust, Commercial Mortgage Pass-Through Certificates, Series 2016-C3

 

42. SG Commercial MortgageSecurities Trust 2016-C5, Commercial Mortgage Pass-Through Certificates Series2016-C5