MANAGEMENT’S ASSESSMENT OF COMPLIANCE WITH RELEVANT SERVICINGCRITERIA

 

Mount Street US (Georgia) LLP(the “Asserting Party”) is responsible for assessing compliance for thetransactions listed on Appendix A for the period August 16, 2021 throughDecember 31, 2021 (the “Reporting Period”), with the servicing criteria set forthin Title 17, Section 229.1122(d) of the Code of Federal Regulations (the“CFR”), except for the servicing criteria which the Asserting Party hasconcluded are not applicable, as indicated on Appendix B attached hereto (the “ApplicableServicing Criteria”), to the servicing of the transactions listed on Appendix A,backed by commercial real estate mortgage loans and serviced by the Asserting Party.

 

The Asserting Party has assessedcompliance with the Applicable Servicing Criteria for the Reporting Period and hasconcluded that the Asserting Party has complied, in all material respects, withthe applicable servicing criteria for the transactions listed on Appendix Abacked by commercial real estate mortgage loans serviced by the Asserting Party.

 

The Asserting Party hasengaged certain vendors to perform specific, limited activities related to theApplicable Servicing Criteria. The Asserting Party has determined that any suchvendor is not a “servicer” as defined in Item 1101(j) of Regulation AB, and theAsserting Party has elected to take responsibility for assessing compliancewith any portion of the Applicable Servicing Criteria performed by any such vendoras permitted by Regulation AB Compliance and Disclosure Interpretations of the Divisionof Corporation Finance, Section 200.06, “Vendors Engaged by Servicers” C&DI200.06. As permitted by C&DI 200.06, the Asserting Party asserts that ithas policies and procedures in place designed to provide reasonable assurancethat the vendors’ activities comply in all material respects with servicingcriteria applicable to the vendor and that the Asserting Party is not aware of anymaterial deficiency in such policies and procedures nor of any material instanceof noncompliance by any such vendors with respect to the Applicable Servicing Criteria.The Asserting Party is solely responsible for determining that it meets the SECrequirements to apply C&DI 200.06 for any such vendor and related criteria.

 

Marcum LLP, an independentregistered public accounting firm, has issued an attestation report on theassessment of compliance with the Applicable Servicing Criteria for theReporting Period as set forth in this assertion.

 

Mount Street US (Georgia) LLP

 

March 1, 2022

 

By: /s/ Kristin Bonczynski

Kristin Bonczynski

Senior Director, SpecialServicing

 

 

Appendix A

 

| **Commercial Mortgage Pass Through Certificates** | **Applicable Reporting Period**         | **MSUS Role**    |
|---------------------------------------------------|-----------------------------------------|------------------|
| BAMLL 2021-JACX                                   | September 15, 2021 to December 31, 2021 | Special Servicer |
| HMH 2017-NSS                                      | August 26, 2021 to December 31, 2021    | Special Servicer |
| MSBAM 2015-C21                                    | August 16, 2021 to December 31, 2021    | Special Servicer |
| NCMS 2018-FL1                                     | September 20, 2021 to December 31, 2021 | Special Servicer |

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**Appendix B**

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**Servicing Criteria to Be Addressed in Assessment ofCompliance**

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| ** **

**Reference** | ** **

**Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | **Applicable: Performed byServicer** | **Inapplicable Servicing Criteria** |
|---------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------|-------------------------------------|
|                      | **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.                                                                                                                                                                                                                                                                                                                | X                                    |                                |
| 1122(d)(1)(iii)           | Any  requirements in the transaction agreementsto 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 ofan  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.                                                                                                                                                                                                                                                                                                |  

X1                           |                                |
| 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 240.13k-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)(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;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X                                    |                                |
|                      | (B) prepared within 30 calendar days after the bank statement cutoff  date, or such other number of days specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                           | X                                    |                                |
|                      | (C) reviewed and approved by someone other than the person  who prepared the reconciliation; and                                                                                                                                                                                                                                                                                                                                                                                                                            | X                                    |                                |
|                      | (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                                    |                                |
|                      | **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;                                                                                                                                                                                                                                                                                                                                                                                                                    |                                 | X                                   |
|                      | (B) provide information calculated in accordance with  the terms specified in the transaction agreements;                                                                                                                                                                                                                                                                                                                                                                                                                   |                                 | X                                   |
|                      | (C) are filed with the Commission as required by its rules  and regulations;                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                 | X                                   |
|                      | (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  timeframes, 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.                                                                                                                                                                                                                                                                                                                                                                                             |  

X1                           |                                |
| 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 withany  conditions or requirements in the transactionagreements.                                                                                                                                                                                                                                                                                                                                                |  

X1                           |                                |
| 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.                                                                                                     |  

X1                           |                                |
| 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.                                                                                                                                                                                                                                                            |  

X1                           |                                |
| 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                                    |                                |
| 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 annualbasis, or such other periodspecified  in the transaction agreements;                                                                                                                                                                                                                                                                                                                     |                                 | X                                   |
|                      | (B)     interest on such funds is paid,  or credited,to obligors in  accordance with applicable pool asset documents and state laws;and                                                                                                                                                                                                                                                                                                                                                                      |                                 | X                                   |
|                      | (C)     such funds are returned to the  obligor within 30 calendar days of full repayment of the related poolassets, 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                                   |

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1 Notransactions occurred with respect to this criteria.