Trimont Real EstateAdvisors, LLC

 

Management’s Reporton Assessment of Compliance with SEC Regulation AB Servicing Criteria

 

 

TrimontReal Estate Advisors, LLC (the “Asserting Party”) is responsible for assessing complianceas of and for the year ended December 31, 2018 (the “Reporting Period”) withthe applicable servicing criteria set forth in Item 1122(d) of the Securitiesand Exchange Commission's Regulation AB as set forth in Exhibit A hereto (the“Applicable Servicing Criteria”). The transactions covered by this report areonly those transactions processed by the Asserting Party in capacity as primaryservicer for the asset backed securities transactions listed in Exhibit Bhereto (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 December 31, 2018 with respect to thePlatform.

 

GrantThornton, LLP, an independent registered public accounting firm, has issued anattestation report on the assessment of compliance with the ApplicableServicing Criteria as of December 31, 2018 as set forth in this assertion.

 

 

TrimontReal Estate Advisors, LLC 

February26, 2019

 

 

/s/Glen Peters

GlenPeters

ChiefFinancial Officer

 

 

| **Exhibit A**                      |
|------------------------------------|
| **Regulation AB Criteria**         | **MSBAM   2015-C21** | **MSBAM   2015-C22** | **VSD 2017-PLT1** | **GPMT 2018-FL1** |
| ***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 | 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 | 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 | 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 | 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 | 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 | 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 | 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 | 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 | 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 | X |
| (d)(2)(vi)                         | Unissued Checks | Unissued checks are  safeguarded so as to prevent unauthorized access. | X | X | X | X |
| (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 | 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  principalbalance and number of  pool assets serviced by the servicer. | N/A | N/A | X2 | N/A |
| (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 | 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 | 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 | 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 | X |
| (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 | 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 | X |
| (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 | X |
| (d)(4)(v)                          | Pool Asset Records Match UPB | The servicer’s  records regarding the pool assets agree with the servicer's records with  respect to an obligor's unpaid principal balance. | X | X | X | X |
| (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 | X | N/A |
| (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 | 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 | X5 |
| (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 | 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. | X | X | X | X |
| (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 | X | X |
| (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. | X | X | X | X |
| (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 | X | X |
| (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. | X7 | X7 | X | X7 |
| (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 | N/A |

 

 

Exhibit 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 this 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 this securitization.                                    |
| X7                                                                                                                                                                                                                   | 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.            |
| 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, 2018 -

December 31, 2018 |
| MSBAM  2015-C22 | Servicer for Commercial  Mortgage Pass-Through Certificates Series 2015-C22 pursuant to the Subservicing  Agreement dated February 5, 2015 | January  1, 2018 -

December 31, 2018 |
| 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, 2018 - January

23,  2018 |
| GPMT 2018-FL1   | Servicer  for Commercial Mortgage Pass-Through Certificates Series GPMT 2018-FL1  pursuant to the Pooling and Servicing Agreement dated May 9, 2018 | May 9, 2018 -

December 31, 2018 |