(logo) TRIMONT

 

 

Trimont Real EstateAdvisors, LLC

 

Management's Reporton Assessment of Compliance

with SEC RegulationAB Servicing Criteria

 

 

TrimontReal Estate Advisors, LLC ("the Asserting Party") is responsible for assessingcompliance as of and for the year ended December 31, 2019 ("the ReportingPeriod") with the applicable servicing criteria set forth in Item 1122(d)of the Securities and Exchange Commission's Regulation AB as set forth inExhibit A hereto (the "Applicable Servicing Criteria"). Thetransactions covered by this report are only those transactions processed bythe Asserting Party in capacity as primary servicer for the asset backedsecurities transactions listed in Exhibit B hereto (the "Platform").

 

TheAsserting Party has used the servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission's Regulation AB to assess its compliancewith the Applicable Servicing Criteria for the Reporting Period and hasconcluded that the Asserting Party has complied, in all material respects, withthe Applicable Servicing Criteria as of and for the year ended December 31,2019 with respect to the Platform.

 

GrantThornton, LLP, an independent registered public accounting firm, has issued anattestation report on the assessment of compliance with the Applicable ServicingCriteria as of and for the year ended December 31, 2019 as set forth in thisassertion.

 

 

TrimontReal Estate Advisors, LLC 

February25, 2020

 

/s/Glen Peters

GlenPeters

ChiefFinancial Officer

 

 

AMSTERDAM I ATLANTA I DALLASI KANSAS CITY I LONDON I LOS ANGELES I NEW YORK I SYDNEY

 

 

ExhibitA

 

|  

**Regulation  AB Criteria** |  

 

**MSBAM  2015- C21**                |  

 

**MSBAM  2015- C22**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  

 

**VSD  2017- PLT1** |
|-------------------------------------|-----------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|
| ***Section***                       | ***Description***                                   | ***Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                |
| General  Servicing Considerations   |
| (d)(1)(i)                           | Policies  and Procedures                            | Policies  and procedures are instituted to monitor any performance or other triggers  and events of default in accordance with the transaction agreement.                                                                                                                                                                                                                                                                                                                                                                 | X                                   | X | X |
| (d)(1)(ii)                          | Policies  and Procedures (vendors)                  | If any material servicing  activities are outsourced to third parties, policies and procedures are  instituted to monitor the third party's performance and compliance with such  servicing activities.                                                                                                                                                                                                                                                                                                                   |  

X1                          |  

X1 |  

X1 |
| (d)(1)(iii)                         | Back-up  Servicer                                   | Any  requirements in the transaction agreements to maintain a back-up servicer for  the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                       |  

N/A                         |  

N/A |  

N/A |
| (d)(1)(iv)                          | Fidelity  Bond                                      | A  fidelity bond and errors and omissions policy is in effect on the party  participating in the servicing function throughout the reporting period in  the amount of coverage required by and otherwise in accordance with the terms  of the transaction agreement.                                                                                                                                                                                                                                                      |  

X                           |  

X |  

X |
| (d)(1)(v)                           | Accuracy  of Information                            | Aggregation  of information, as applicable, is mathematically accurate and the information  conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                 | X                                   | X | X |
| Cash  Collection and Administration |
| (d)(2)(i)                           | 2 Days to deposit Payments into  Custodial Accounts | Payments  on pool assets are deposited into the appropriate custodial bank accounts and  related bank clearing accounts no more than two business days of receipt, or  such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                 |  

X                           |  

X |  

X |
| (d)(2)(ii)                          | Wire  Transfers                                     | Disbursements  made via wire transfer on behalf of an obligor or to an investor are made  only by authorized personnel                                                                                                                                                                                                                                                                                                                                                                                                    | N/A                                 | N/A | N/A |
| (d)(2)(iii)                         | Advances                                            | Advances  of funds or guarantees regarding collections, cash flows or distributions,  and any interest or other fees charged for such advances, are made, reviewed  and approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                              |  

N/A                         |  

N/A |  

N/A |
| (d)(2)(iv)                          | Commingling                                         | The related accounts for the transaction, such as  cash reserve accounts or accounts established as a form of over  collateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                 |  

X                           |  

X |  

X |
| (d)(2)(v)                           | Federally Insured Institution                       | Each  custodial account is maintained at a federally insured depository institution  as set forth in the transaction agreements. For purposes of this criterion,  "federally insured depository institution" with respect to a  foreign financial institution means a foreign financial institution that  meets the requirements of §240.13k-1(b)(1) of this chapter. I.3 Each  custodial account shall be maintained at a federally insured depository  institution in trust for the applicable investor. |  

 

X                   |  

 

X |  

 

X |
| (d)(2)(vi)                          | Unissued  Checks                                    | Unissued checks  are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X                                   | X | X |

 

 

|  

**Regulation  AB Criteria** |  

 

**MSBAM  2015- C21** |  

 

**MSBAM  2015- C22**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

 

**VSD  2017- PLT1** |
|-------------------------------------|--------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|
| ***Section***                       | ***Description***                    | ***Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                |
| (d)(2)(vii)                         | Reconciliations                      | Reconciliations  are prepared on a monthly basis for all asset-backed securities related bank  accounts, including custodial accounts and related bank clearing accounts.  These reconciliations: (a) are mathematically accurate; (b) are prepared  within 30 calendar days after the bank statement cutoff date, or such other  number of days specified in the transaction agreements; (c) are reviewed and  approved by someone other than the person who prepared the reconciliation;  and (d) contain explanations for reconciling items. These reconciling items  are resolved within 90 calendar days of their original identification, or  such other number of days specified in the transaction agreements. |  

 

 

X           |  

 

 

X |  

 

 

X |
| Investor  Remittance and Reporting  |
| (d)(3)(i)                           | Reports  to the Investor             | Reports to investors, including  those to be filed with the Commission, are maintained in accordance with the  transaction agreements and applicable Commission requirements. Specifically,  such reports:

(a)  are prepared in accordance with timeframes and other terms set forth in the  transaction agreements; (b) provide information calculated in accordance with  the terms specified in the transaction agreements; (c) are filed with the  Commission as required by its rules and regulations; and (d) agree with  investors' or the trustee's records as to the

total unpaid  principal balance and number of pool assets serviced by the servicer.                                                    |  

 

 

N/A         |  

 

 

N/A |  

 

 

X2 |
| (d)(3)(ii)                          | Investor  Remittance                 | Amounts  due to investors are allocated and remitted in accordance with timeframes,  distribution priority and other terms set forth in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  

N/A                         |  

N/A |  

N/A |
| (d)(3)(iii)                         | Investor's  Records                  | Disbursements  made to an investor are posted within two business days to the servicer's  investor records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  

N/A                         |  

N/A |  

N/A |
| (d)(3)(iv)                          | Remittance  and Bank Statements      | Amounts  remitted to investors per the investor reports agree with cancelled checks,  or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | N/A                                 | N/A | N/A |
| Pool  Asset Administration          |
| (d)(4)(i)                           | Collateral/Security  on Pool Assets  | Collateral  or security on pool assets is maintained as required by the transaction  agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | X                                   | X | N/A |
| (d)(4)(ii)                          | Safeguard  Pool Assets               | Pool  assets and related documents are safeguarded as required by the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | N/A                                 | N/A | N/A |
| (d)(4)(iii)                         | Changes  to the Pool Assets          | Any additions,  removals or substitutions to the asset pool are made, reviewed and

approved in  accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | X3                                  | X3 | X3 |
| (d)(4)(iv)                          | Obligor's Payment Record             | Payments  on pool assets, including any payoffs, made in accordance with the related  pool asset documents are posted to the applicable servicer's obligor records  maintained no more than two business days after receipt, or such other number  of days specified in the transaction agreements, and allocated to principal,  interest or other items (e.g. escrow) in accordance with the related pool  asset documents.                                                                                                                                                                                                                                                                                           |  

 

X                   |  

 

X |  

 

X |
| (d)(4)(v)                           | Pool Asset Records Match UPB         | The  servicers records regarding the pool assets agree with the servicer's records  with respect to an obligor's unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | X                                   | X | X |

 

 

|  

**Regulation  AB Criteria** |  

 

**MSBAM  2015- C21**                            |  

 

**MSBAM  2015- C22**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  

 

**VSD  2017- PLT1** |
|-------------------------------------|-----------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------|
| ***Section***                       | ***Description***                                               | ***Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                |
| (d)(4)(vi)                          | Loan  Modifications                                             | Changes with respect to the terms or status of an  obligor's pool asset (e.g. loan modifications or re-agings) are made,  reviewed and approved by authorized personnel in accordance with the  transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                          |  

X4                          |  

X4 |  

X4 |
| (d)(4)(vii)                         | Loss  Mitigation Actions                                        | Loss  mitigation or recovery actions (e.g., forbearance plans, modifications and  deeds in lieu of foreclosure, foreclosures and repossessions, as applicable)  are initiated, conducted and concluded in accordance with the timeframes or  other requirements established by the transaction agreement.                                                                                                                                                                                                                                         |  

N/A                         |  

N/A |  

N/A |
| (d)(4)(viii)                        | Collection Efforts Documented                                   | Records  documenting collection efforts are maintained during the period a pool asset  is delinquent in accordance with the transaction agreements. Such records are  maintained on at least a monthly basis, or such other period specified in the  transaction agreements, and describe the entity's activities in monitoring  delinquent pool assets including, for example, phone calls, letters and  payment rescheduling plans in cases where delinquency is deemed temporary  (e.g., illness or unemployment).                             |  

 

X5                  |  

 

X5 |  

 

X |
| (d)(4)(ix)                          | ARMs                                                            | Adjustments  to interest rates or rates of return for pool assets with variable rates are  computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                    | X6                                  | X6 | X |
| (d)(4)(x)                           | Escrow  Funds                                                   | Regarding  any funds held in trust for an obligor such funds are (a) analyzed, in  accordance with the obligor's pool asset documents, on at least an annual  basis, or such other period specified in the transaction agreements; (b)  interest on such funds is paid, or credited, to obligors in accordance with  applicable pool asset documents and state laws; and (c)returned to the  obligor within 30 calendar days of full repayment of the related pool asset,  or such other number of days specified in the transaction

agreements. |  

 

X9                  |  

 

X9 |  

 

X9 |
| (d)(4)(xi)                          | Timely  Payments                                                | Payments  made on behalf of an obligor (such as tax or insurance payments) are made on  or before the related penalty or expiration dates, as indicated on the  appropriate bills or notices for such payments, provided that such support  has been received by the servicer at least 30 calendar days prior to these  dates, or such other number of days specified in the transaction agreements.                                                                                                                                              |  

 

X                   |  

 

X |  

 

X10 |
| (d)(4)(xii)                         | Late  Payment Penalties                                         | Any late payment penalties in connection with any  payment to be made on behalf of an obligor are paid from the Servicer's funds  and not charged to the obligor, unless the late payment was due to the  obligor's error or omission.                                                                                                                                                                                                                                                                                                            |  

X7                          |  

X7 |  

X7 |
| (d)(4)(xiii)                        | Obligor's  Records                                              | Disbursements  made on behalf of an obligor are posted within two business days to the  obligor's records maintained by the servicer, or such other number of days  specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                      |  

X                           |  

X |  

X10 |
| (d)(4)(xiv)                         | Delinquencies, Charge- offs, and Other

Uncollectible  Accounts | Delinquencies,  Charge-offs, and uncollectible accounts are recognized and recorded in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                               | X8                                  | X8 |  

X |
| (d)(4)(xv)                          | Any  External Enhancement                                       | Any external  enhancement or other support, identified in Item 1114(a)(1) through (3) or

Item 1115 of this  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                             |  

N/A                         |  

N/A |  

N/A |

 

 

Key

 

 

|  

X1                                                                                                                                                                                                         | With  respect to Item 1122(d)(1)(ii), there were no third party vendors utilized  during the reporting period for the loans serviced under this securitization.                                                                                                                                                                                                                                                                               |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| X2                                                                                                                                                                                                                 | With  respect to Item 1122(d)(3)(i), only parts A and B of this criteria are  applicable for the securitization.                                                                                                                                                                                                                                                                                                                              |
|  

X3                                                                                                                                                                                                         | With  respect to Item 1122(d)(4)(iii), there were no additions, removals, or  substitutions to pool assets or loan modifications during the reporting  period for the loan(s) that were serviced under this securitization.                                                                                                                                                                                                                   |
|  

X4                                                                                                                                                                                                         | With  respect to Item 1122(d)(4)(vi), there were no changes to the terms or status  of any of the primary serviced loans during the reporting period for the  loan(s) that were serviced under the securitization.                                                                                                                                                                                                                            |
|  

X5                                                                                                                                                                                                         | With  respect to Item 1122(d)(4)(viii), there were no delinquent loans or  collection efforts during the reporting period associated with the loans  under this securitization.                                                                                                                                                                                                                                                               |
|  

X6                                                                                                                                                                                                         | With  respect to Item 1122(d)(4)(ix), there were no adjustments to interest rates  during the reporting period associated with the loan(s) that were serviced  under the securitization.                                                                                                                                                                                                                                                      |
|  

X7                                                                                                                                                                                                         | With  respect to Item 1122(d)(4)(xii), there were no late payments during the  reporting period associated with the loan(s) that were serviced under the  securitization.                                                                                                                                                                                                                                                                     |
|  

X8                                                                                                                                                                                                         | With  respect to Item 1122(d)(4)(xiv), there were no delinquencies, charge-offs, or  uncollectible amounts during the reporting period associated with the loan(s)  that were serviced under this securitization.                                                                                                                                                                                                                             |
|  

 

X9                                                                                                                                                                                                 | With  respect to Item 1122(d)(4)(x)(a), is applicable to the loan(s) that were  serviced under the securitization. With respect to Item 1122(d)(4)(x)(b),  there were no requirements to allocate interest with the loan(s) that were  serviced under the securitization. With respect to Item 1122(d)(4)(x)(c),  there were no payoffs during the reporting period associated with the loan(s)  that were serviced under the securitization. |
|  

X10                                                                                                                                                                                                        | With  respect to Item 1122(d)(4)(xi) and 1122(d)(4)(xiii), there were no  disbursements made during the reporting period associated with the loan(s)  that were serviced under the securitization.                                                                                                                                                                                                                                            |
| With  respect to Applicable Servicing Criteria cells in Exhibit A that are denoted  with an "N/A", per review of the respective servicing agreement,  the criteria was not in scope for the transaction. |

 

 

Exhibit B

 

 

| **Name**       | **Transaction**                                                                                                                                         | **Period of Service**                |
|----------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------|
| MSBAM 2015-C21 | Servicer  for Commercial Mortgage Pass-Through Certificates Series 2015-C21 pursuant to  the Subservicing Agreement dated February 1, 2015              | January 1, 2019 -

December 31, 2019 |
| MSBAM 2015-C22 | Servicer  for Commercial Mortgage Pass-Through Certificates Series 2015-C22 pursuant to  the Subservicing Agreement dated February 5, 2015              | January 1, 2019 -

December 31, 2019 |
| VSD 2017-PLT1  | Servicer for  Commercial Mortgage Pass-Through Certificates Series VSD 2017-PLT1

pursuant to the  Pooling and Servicing Agreement dated March 10, 2017 | January 1, 2019-

January 24,2019    |