(logo)TRIMONT ®

 

GlenPeters

ChiefFinancial Officer, Global

gpeters@trimontrea.com

Direct:404-581-7525

 

3500Lenox Road,

SuiteG1

Atlanta,GA 30326

 

trimontrea.com

 

 

**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 assessingcompliance as of and for the year ended December 31, 2021 (“the ReportingPeriod”) with the applicable servicing criteria set forth in Item 1122(d) ofthe Securities and Exchange Commission’s Regulation AB as set forth in ExhibitA hereto (the “Applicable Servicing Criteria”). The transactions covered bythis report are only those transactions processed by the Asserting Party in capacityas primary servicer for the asset backed securities transactions listed inExhibit 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 31,2021 with respect to the Platform, except for the material noncompliancedescribed in Exhibit C.

 

GrantThornton, LLP, an independent registered public accounting firm, has issued anattestation report on the assessment of compliance with the ApplicableServicing Criteria as of and for the year ended December 31, 2021 as set forthin this assertion.

 

 

TrimontReal Estate Advisors, LLC 

February28, 2022

 

/s/Glen Peters

GlenPeters

ChiefFinancial Officer

 

 

TrimontReal Estate Advisors

 

Amsterdam| Atlanta | Dallas | Kansas City | London | Los Angeles | New York |

 

 

**Exhibit A**

 

 

|  

**Regulation  AB Criteria** |  

 

**MSBAM  2015- C21**                           |  

 

**MSBAM  2015- C22**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
|-------------------------------------|----------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| ***Section***                       | ***Description***                                              | ***Criteria***                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |   |
| General Servicing  Considerations   |
| (d)(1)(i)                           | Policies  and Procedures                                       | Policiesandproceduresareinstitutedtomonitoranyperformanceorothertriggersand events of default in accordance with thetransactionagreement.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X | X |
| (d)(1)(ii)                          | Policies  and Procedures (vendors)                             | Ifanymaterialservicingactivitiesareoutsourcedtothirdparties,policiesandprocedures areinstitutedtomonitorthethirdparty'sperformanceandcompliancewithsuchservicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

X1 |  

X1 |
| (d)(1)(iii)                         | Back-up  Servicer                                              | Anyrequirementsinthetransactionagreementstomaintainaback-upservicerforthepool assets aremaintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

N/A |  

N/A |
| (d)(1)(iv)                          | Fidelity  Bond                                                 | Afidelitybondanderrorsandomissionspolicyisineffectonthepartyparticipatinginthe servicingfunctionthroughoutthereportingperiodintheamountofcoveragerequiredby and otherwise in accordance with the terms of the  transactionagreement.                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  

X |  

X |
| (d)(1)(v)                           | Accuracy  of Information                                       | Aggregationofinformation,asapplicable,ismathematicallyaccurateandtheinformation conveyed accurately  reflects theinformation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X | X |
| Cash Collection and  Administration |
| (d)(2)(i)                           | 2 Days to deposit  PaymentsintoCustodial Accounts              | Paymentsonpoolassetsaredepositedintotheappropriatecustodialbankaccountsand relatedbankclearingaccountsnomorethantwobusinessdaysofreceipt,orsuchother number of days specified in the  transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

X |  

X |
| (d)(2)(ii)                          | Wire  Transfers                                                | Disbursementsmadeviawiretransferonbehalfofanobligorortoaninvestoraremade  only by authorizedpersonnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

N/A |  

N/A |
| (d)(2)(iii)                         | Advances                                                       | Advancesoffundsorguaranteesregardingcollections,cashflowsordistributions,andany  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  

X10 |  

X10 |
| (d)(2)(iv)                          | Commingling                                                    | The related accounts for the transaction, such as  cash reserve accounts or accounts establishedasaformofovercollateralization,areseparatelymaintained(e.g.,withrespect to commingling of cash) as set  forth in the transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

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 depositoryinstitution"withrespecttoaforeignfinancialinstitutionmeansaforeignfinancial institution that meets the  requirements of §240.13k-1(b)(1) of thischapter.                                                                                                                                                                                                                                                                                                                       |  

 

X |  

 

X |
| (d)(2)(vi)                          | Unissued  Checks                                               | Unissued checks are safeguarded so as to  prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | 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  transactionagreements;(c)arereviewedandapprovedbysomeoneotherthantheperson whopreparedthereconciliation;and(d)containexplanationsforreconcilingitems.These  reconciling items are resolved within 90 calendar days of their original  identification, or such other number of days specified in the transactionagreements. |  

 

 

X11 |  

 

 

X11 |
| Investor Remittance and  Reporting  |
| (d)(3)(i)                           | Reports  to the Investor                                       | Reportstoinvestors,includingthosetobefiledwiththeCommission,aremaintainedin accordancewiththetransactionagreementsandapplicableCommissionrequirements.  Specifically, suchreports:

(a)arepreparedinaccordancewithtimeframesandothertermssetforthinthetransaction 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 theservicer.                                                                   |  

 

 

 

N/A |  

 

 

 

N/A |
| (d)(3)(ii)                          | Investor  Remittance                                           | Amountsduetoinvestorsareallocatedandremittedinaccordancewithtimeframes, distributionpriorityandothertermssetforthinthetransactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

N/A |  

N/A |
| (d)(3)(iii)                         | Investor's  Records                                            | Disbursementsmadetoaninvestorarepostedwithintwobusinessdaystotheservicer's investorrecords,orsuchothernumberofdaysspecifiedinthetransactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

N/A |  

N/A |
| (d)(3)(iv)                          | Remittance  and Bank Statements                                | Amountsremittedtoinvestorspertheinvestorreportsagreewithcancelledchecks,or other form of payment, or custodial bankstatements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | N/A | N/A |
| Pool AssetAdministration            |
| (d)(4)(i)                           | Collateral/Security  on Pool Assets                            | Collateralorsecurityonpoolassetsismaintainedasrequiredbythetransaction agreements or related pool  assetdocuments.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |  

X |  

X |
| (d)(4)(ii)                          | Safeguard  Pool Assets                                         | Poolassetsandrelateddocumentsaresafeguardedasrequiredbythetransactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | N/A | N/A |
| (d)(4)(iii)                         | Changes  to the Pool Assets                                    | Anyadditions,removalsorsubstitutionstotheassetpoolaremade,reviewedand approved in  accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  

X2 |  

X2 |
| (d)(4)(iv)                          | Obligor's  Payment Record                                      | Paymentsonpoolassets,includinganypayoffs,madeinaccordancewiththerelatedpool 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 transactionagreements,andallocatedtoprincipal,interestorotheritems(e.g.escrow)in accordance with the related pool  assetdocuments.                                                                                                                                                                                                                                                                                              |  

 

X |  

 

X |
| (d)(4)(v)                           | Pool  Asset Records Match UPB                                  | Theservicersrecordsregardingthepoolassetsagreewiththeservicer'srecordswith respect to an obligor's unpaid principalbalance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | X | X |
| (d)(4)(vi)                          | Loan  Modifications                                            | Changes  with respect to the terms or status of an obligor's pool asset (e.g. loan  modificationsorre-agings)aremade,reviewedandapprovedbyauthorizedpersonnelin accordancewiththetransactionagreementsandrelatedpoolassetdocuments.                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  

X3 |  

X3 |
| (d)(4)(vii)                         | Loss  Mitigation Actions                                       | Loss mitigation or recovery actions (e.g.,  forbearance plans, modifications and deeds in lieuofforeclosure,foreclosuresandrepossessions,asapplicable)areinitiated,conducted andconcludedinaccordancewiththetimeframesorotherrequirementsestablishedbythe transactionagreement.                                                                                                                                                                                                                                                                                                                                                                                                              |  

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,phonecalls,lettersandpaymentreschedulingplansincaseswheredelinquency is deemed  temporary (e.g., illness orunemployment).                                                                                                                                                                                     |  

 

X4 |  

 

X4 |
| (d)(4)(ix)                          | ARMs                                                           | Adjustmentstointerestratesorratesofreturnforpoolassetswithvariableratesare computed based on the related pool assetdocuments.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | X5 | X5 |
| (d)(4)(x)                           | Escrow  Funds                                                  | Regardinganyfundsheldintrustforanobligorsuchfundsare(a)analyzed,inaccordance  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,orsuchothernumberofdaysspecifiedinthetransactionagreements.                                                                                                                                                                         |  

 

 

X8 |  

 

 

X8 |
| (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 noticesforsuchpayments,providedthatsuchsupporthasbeenreceivedbytheservicerat least 30 calendar days prior to these dates, or such other  number of days specified in the transactionagreements.                                                                                                                                                                                                                                                                                                         |  

 

X9 |  

 

X9 |
| (d)(4)(xii)                         | Late  Payment Penalties                                        | Anylatepaymentpenaltiesinconnectionwithanypaymenttobemadeonbehalfofan  obligorarepaidfromtheServicer'sfundsandnotchargedtotheobligor,unlessthelate paymentwas due to the obligor's  error oromission.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  

X6 |  

X6 |
| (d)(4)(xiii)                        | Obligor's  Records                                             | Disbursements made on behalf of an obligor are  posted within two business days to the obligor'srecordsmaintainedbytheservicer,orsuchothernumberofdaysspecifiedinthe transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

X9 |  

X9 |
| (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 |
| (d)(4)(xv)                          | Any  External Enhancement                                      | Any  external enhancement or other support, identified in Item 1114(a)(1) through  (3) or Item1115ofthisRegulationAB,ismaintainedassetforthinthetransactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

N/A |  

N/A |

##  

##  

## ExhibitA 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)(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.                                                                                                                                                                                                                                       |
| X3                                                                                                                                                                                                                 | 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.                                                                                                                                                                                                                                                |
| X4                                                                                                                                                                                                                 | 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.                                                                                                                                                                                                                                                                                   |
| X5                                                                                                                                                                                                                 | 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.                                                                                                                                                                                                                                                                          |
| X6                                                                                                                                                                                                                 | 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.                                                                                                                                                                                                                                                                                         |
| 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.                                                                                                                                                                                                                                                 |
|  

 

X8                                                                                                                                                                                                 | With  respect to Item 1122(d)(4)(x)(a), the funds can be used at the borrower's  discretion, and is not the responsibility of Trimont. 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. |
|  

X9                                                                                                                                                                                                         | With  respect to Item 1122(d)(4)(xi) and 1122(d)(4)(xiii), there were no  disbursements made on behalf of the obligor during the reporting period  associated with the loan(s) that were serviced under the securitization.                                                                                                                                                                                                                                       |
|  

X10                                                                                                                                                                                                        | With  respect to Item 1122(d)(2)(iii), there were no advances of funds or  guarantees regarding collections, cash flows or distributions and interest or  other fees charged for such advances associated with the loan(s) that were  serviced under the securitization.                                                                                                                                                                                          |
| X11                                                                                                                                                                                                                | With  respect to Item 1122(d)(2)(vii), see Exhibit C regarding the identified  material noncompliance.                                                                                                                                                                                                                                                                                                                                                            |
| 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, 2021 -

December 31, 2021 |
| MSBAM 2015-C22 | Servicer  for Commercial Mortgage Pass-Through Certificates Series 2015-C22 pursuant to  the Subservicing Agreement dated February 5, 2015 | January 1, 2021 -

December 31, 2021 |

** **

** **

**Exhibit C**

** **

** **

** **

**MaterialInstances of Non-Compliance by Trimont Real Estate Advisors, LLC**

 

1122(d)(2)(vii)– During the Reporting Period, reconciliations were not in compliance with thestated criteria.

 

**ManagementResponse (unaudited)**

 

Managementacknowledges material noncompliance with Servicing Criteria 1122(d)(2)(vii) asof and for the year ended December 31, 2021. In June of 2021, the AssertingParty self-identified certain instances from February 2021 to June 2021 inwhich reconciliations were not completed timely and management conductedremediation of these errors. Reconciliations from July 2021 through December2021 were performed timely. All reconciliations that were not completed within thetimeframe defined in the criteria were performed within 90 days of the relatedmonth end.