Exhibit 33.15 Managements Assertion on Compliance with Applicable Regulation AB Servicing Criteria 1.
Rialto Capital Advisors, LLC (Rialto), the Special Servicer in the agreements listed on Exhibit 1 (the Pooling and Servicing Agreements), is responsible for assessing compliance with the servicing criteria applicable to it
under paragraph (d) of Item 1122 of Regulation AB, for the period from January 1, 2015 up to and including December 31, 2015 or applicable shorter period there within, (the Reporting Period), as set forth in Appendix A hereto. The
transactions covered by this report include the transactions listed on Exhibit 1 that are commercial mortgage-asset backed securities transactions for which Rialto acted as Special Servicer on or after January 1, 2015 or for the Applicable
Certification Period as listed on Exhibit 1 (the Platform), and were registered after January 1, 2006, with the Securities and Exchange Commission pursuant to the Securities Act of 1933. 2. Rialto has engaged certain vendors (the Vendors) to perform specific, limited, or scripted activities, and Rialto elects to take responsibility
for assessing compliance with the servicing criteria, or portion of the servicing criteria, applicable to such Vendors activities as set forth in Appendix A hereto. Rialto has determined its Vendors are not servicers as defined in
Item 1101 (j) of Regulation AB and asserts that it has policies and procedures in place to provide reasonable assurance that the Vendors activities comply, in all material respects, with the servicing criteria applicable to each vendor; 3. Except as set forth in paragraph 4 below, Rialto used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with
the applicable servicing criteria; 4. The criteria listed in the column titled Inapplicable Servicing Criteria on Appendix A hereto are
inapplicable to Rialto based on the activities it performs, directly or through its Vendors, with respect to the Platform; 5. Rialto has complied, in all
material respects, with the applicable servicing criteria as of December 31, 2015, and for the Reporting Periodwith respect to the Platform taken as a whole. 6. Rialto has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria as of December
31, 2015, and for the Reporting Period with respect to the Platform taken as a whole; 7. Rialto has not identified any material deficiency in its
policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria as of December 31, 2015, and for the Reporting Period with respect to the Platform taken as a whole;and 8. NDB Accountants & Consultants, LLP, a registered public accounting firm, has issued an attestation report on Rialtos assessment of compliance
with the applicable servicing criteria for the Reporting Period.




Managements
Assertion on Compliance



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Date:

March 15, 2016Name:

Adam SingerTitle:

Managing DirectorSignature:

/s/ Adam Singer
 Exhibit 1  Pooling and Servicing Agreements

Applicable Certification PeriodWFRBS 2012-C8

January 1, 2015, to December 31, 2015FDIC 2012-C1

January 1, 2015, to December 31, 2015WFCM 2012-LC5

January 1, 2015, to December 31, 2015UBS-Barclays 2012-C3

January 1, 2015, to December 31, 2015UBS-Barclays 2012-C4

January 1, 2015, to December 31, 2015GSMS 2012-GCJ9

January 1, 2015, to December 31, 2015JPMCC 2012-LC9

January 1, 2015, to December 31, 2015COMM 2013-LC6

January 1, 2015, to December 31, 2015WFRBS 2013-C12

January 1, 2015, to December 31, 2015UBS-Barclays 2013-C6

January 1, 2015, to December 31, 2015GSMS 2013-GCJ12

January 1, 2015, to December 31, 2015WFRBS 2013-C14

January 1, 2015, to December 31, 2015WFRBS 2011-C5

January 1, 2015, to December 31, 2015WFCM 2013-LC12

January 1, 2015, to December 31, 2015WFRBS 2011-C2

January 1, 2015, to December 31, 2015WFRBS 2011-C3

January 1, 2015, to December 31, 2015WFRBS 2011-C4

January 1, 2015, to December 31, 2015UBS-Citigroup 2011-C1

January 1, 2015, to December 31, 2015UBS 2012-C1

January 1, 2015, to December 31, 2015WFRBS 2012-C6

January 1, 2015, to December 31, 2015GSMS 2011-GC3

January 1, 2015, to December 31, 2015COMM 2013-LC13

January 1, 2015, to December 31, 2015WFRBS 2013-C16

January 1, 2015, to December 31, 2015GSMS 2013-GCJ16

January 1, 2015, to December 31, 2015WFRBS 2013-C17

January 1, 2015, to December 31, 2015GSMS 2012-GC6

January 1, 2015, to December 31, 2015MSBAM 2013-C13

January 1, 2015, to December 31, 2015COMM 2014-CCRE14

January 1, 2015, to December 31, 2015MSBAM 2014-C14

January 1, 2015, to December 31, 2015WFRBS 2014-LC14

January 1, 2015, to December 31, 2015COMM 2014-LC15

January 1, 2015, to December 31, 2015WFRBS 2014-C20

January 1, 2015, to December 31, 2015COMM 2014-CCRE18

January 1, 2015, to December 31, 2015




Managements
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CGCMT 2014-GC23

January 1 , 2015, to December 31, 2015MSBAM 2014-C17

January 1, 2015, to December 31, 2015COMM 2014-UBS5

January 1, 2015, to December 31, 2015MSBAM 2014-C18

January 1, 2015, to December 31, 2015COMM 2012-CCRE4

January 1, 2015, to December 31, 2015COMM 2012-LC4

January 1, 2015, to December 31, 2015WFRBS 2014-C24

January 1, 2015, to December 31, 2015JPMBB 2014-C25

January 1, 2015, to December 31, 2015LCCM 2014-909

January 1, 2015, to December 31, 2015MLMI 1998-C3

January 1, 2015, to December 31, 2015Carefree Portfolio Trust 2014-CARE MZ A

January 1, 2015 to December 31, 2015WFCM 2014-LC18

January 1, 2015, to December 31, 2015COMM 2015-DC1

March 4, 2015, to December 31, 2015GSMS 2015-GC28

February 27, 2015, to December 31, 2015WFCM 2015-C27

March 12, 2015, to December 31, 2015WFCM 2015-LC20

March 31, 2015, to December 31, 2015WFCM 2015-NXS1

April 29, 2015, to December 31, 2015CSAIL 2015-C2

May 20, 2015, to December 31, 2015CGCMT 2015-GC27*

July 1, 2015 to December 31, 2015WFCM 2015-NXS2

July 14, 2015, to December 31, 2015COMM 2015-PC1

July 14, 2015, to December 31, 2015CSAIL 2015-C3

August 18, 2015, to December 31, 2015WFCM 2015-SG1

August 27, 2015, to December 31, 2015WFCM 2015-LC22

September 29, 2015, to December 31, 2015COMM 2015-CCRE27

October 29, 2015, to December 31, 2015WFCM 2015-NXS4

December 9, 2015, to December 31, 2015MSCI 2015-UBS8

December 15, 2015, to December 31, 2015  *
As special servicer solely for the Boca Hamptons Plaza Portfolio Loan Combination.




Managements
Assertion on Compliance



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APPENDIX A  SERVICING CRITERIAReference

Criteria

PerformedbyServicer

InapplicableServicingCriteriaGeneral Servicing Considerations1122(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.

X1122(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.

X1122(d)(1)(iii)

Any requirements in the transaction agreements to maintain a back-up servicer for the [pool assets] are maintained.



X1122(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.

X1122(d)(1)(v)

Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.

XCash Collection and Administration1122(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.

X11122(d)(2)(ii)

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

X1122(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.

X1122(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.

X1122(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.

X1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

X1122(d)(2)(vii)

Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations 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




Managements
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SERVICING CRITERIAReference

Criteria

PerformedbyServicer


InapplicableServicingCriteriaInvestor Remittances and Reporting1122(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 [pool assets] serviced by the Servicer.


X21122(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.






X1122(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.






X1122(d)(3)(iv)

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.






XPool Asset Administration1122(d)(4)(i)

Collateral or security on [pool assets] is maintained as required by the transaction agreements or related mortgage loan documents.


X1122(d)(4)(ii)

[pool asset] and related documents are safeguarded as required by the transaction agreements


X1122(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.


X1122(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.






X31122(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.






X1122(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.


X1122(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




Managements
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SERVICING CRITERIAReference

Criteria

PerformedbyServicer

InapplicableServicingCriteria1122(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).

X1122(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.



X1122(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.



X1122(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.



X1122(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.



X1122(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.



X1122(d)(4)(xiv)

Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.



X41122(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  1)
Rialto Capital Advisors, LLC performs the activities pertaining to these criteria, except for specific, limited activities performed by its third party property managers relating to REO Property, if any. Rialto has
elected to take responsibility for assessing compliance with these servicing criteria with respect to the activities of its third party property managers. 2)
Only items (A) and (B) of the Servicing Criteria are applicable to Rialto Capital Advisors, LLC as special servicer. Items (C) and (D) are inapplicable as the responsibility for filing reports with the Commission
and agreeing totals to the Servicer records rests with the Trustee and/or Certificate Administrator, as applicable.




Managements
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3)
Primary responsibility for processing borrower payments rests with the Master Servicer, however, Rialto Capital Advisors, LLC may from time to time receive payments on an exception basis which are forwarded to the
Master Servicer in accordance with such criterion. 4)
Rialto Capital Advisors, LLC provides the applicable Master Servicer relating to each deal with the final recovery determination and data utilized to complete IRS Form 1099C on loans with charge-offs, however, the
ultimate responsibility for adjusting the loan record, reporting to the IRS, and delivering 1099C Forms to the borrower rests with the Master Servicer.




Managements
Assertion on Compliance