**Management’sAssertion on Compliance with Applicable**

**RegulationAB Servicing Criteria**

 

 

1.       Rialto Capital Advisors, LLC. (the“Asserting Party”) is responsible for assessing compliance with the servicing criteriaapplicable to it under paragraph (d) of Item 1122 of Regulation AB, as ofand for the 12-month period ending December 31, 2018 (the“Reporting Period”), as set forth in Appendix A hereto. The transactionscovered by this report, include commercial mortgage-asset-backed securitiestransactions, as listed on Exhibit 1 hereto, for which the Asserting Partyserved as special servicer, and that were registered with the Securities andExchange Commission pursuant to the Securities Act of 1933 (the “Platform”);

 

2.       The Asserting Party has engaged certainvendors, which are not servicers as defined in Item 1101(j) of Regulation AB(the “Vendors”), to perform specific, limited or scripted activities, and theAsserting Party elects to take responsibility for assessing compliance with theservicing criteria or portion of the servicing criteria applicable to suchVendors’ activities as set forth in Appendix A hereto;

 

3.       Except as set forth in paragraph 4 below,the Asserting Party used the criteria set forth in paragraph (d) of Item1122 of Regulation AB to assess the compliance with the applicable servicingcriteria;

 

4.       The criteria listed in the column titled“Inapplicable Servicing Criteria” on Appendix A hereto are inapplicable to theAsserting Party based on the activities it performs, directly or through itsVendors, with respect to the Platform;

 

5.       The Asserting Party has complied, in allmaterial respects, with the applicable servicing criteria as ofDecember 31, 2018 and for the Reporting Period with respect to thePlatform taken as a whole;

 

6.       The Asserting Party has not identified andis not aware of any material instance of noncompliance by the Vendors with theapplicable servicing criteria as of December 31, 2018 and for theReporting Period with respect to the Platform taken as a whole;

 

7.       The Asserting Party has not identified anymaterial deficiency in its policies and procedures to monitor the compliance bythe Vendors with the applicable servicing criteria as of December 31, 2018and for the Reporting Period with respect to the Platform taken as a whole; and

 

8.       Deloitte & Touche LLP, anindependent registered public accounting firm, has issued an attestation reporton the Asserting Party’s assessment of compliance with the applicable servicingcriteria for the Reporting Period.

 

 

October 18, 2019

 

Name: Adam Singer

Title: Managing Director

 

Signature: /s/ Adam Singer

 

 

**Exhibit1**

** **

| **Pooling and Servicing Agreements**                                                                                                                                                                                                                | **Reporting Period**                    |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------|
| WFRBS 2012-C8                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2012-LC5                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| UBS-Barclays 2012-C3                                                                                                                                                                                                                                | January 1, 2018 to December 31, 2018    |
| UBS-Barclays 2012-C4                                                                                                                                                                                                                                | January 1, 2018 to December 31, 2018    |
| GSMS 2012-GCJ9                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| JPMCC 2012-LC9                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| COMM 2013-LC6                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFRBS 2013-C12                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| UBS-Barclays 2013-C6                                                                                                                                                                                                                                | January 1, 2018 to December 31, 2018    |
| GSMS 2013-GCJ12                                                                                                                                                                                                                                     | January 1, 2018 to December 31, 2018    |
| WFRBS 2013-C14                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| WFRBS 2011-C5                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2013-LC12                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| WFRBS 2011-C2                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFRBS 2011-C3                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFRBS 2011-C4                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| UBS-Citigroup 2011-C1                                                                                                                                                                                                                               | January 1, 2018 to December 31, 2018    |
| UBS 2012-C1                                                                                                                                                                                                                                         | January 1, 2018 to December 31, 2018    |
| WFRBS 2012-C6                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| GSMS 2011-GC3                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| COMM 2013-LC13                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| WFRBS 2013-C16                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| GSMS 2013-GCJ16                                                                                                                                                                                                                                     | January 1, 2018 to December 31, 2018    |
| WFRBS 2013-C17                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| GSMS 2012-GC6                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| MSBAM 2013-C13                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| COMM 2014-CCRE14                                                                                                                                                                                                                                    | January 1, 2018 to December 31, 2018    |
| MSBAM 2014-C14                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| WFRBS 2014-LC14                                                                                                                                                                                                                                     | January 1, 2018 to December 31, 2018    |
| COMM 2014-LC15                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| WFRBS 2014-C20                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| COMM 2014-CCRE18                                                                                                                                                                                                                                    | January 1, 2018 to December 31, 2018    |
| CGCMT 2014-GC23                                                                                                                                                                                                                                     | January 1, 2018 to December 31, 2018    |
| MSBAM 2014-C17                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| COMM 2014-UBS5                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| MSBAM 2014-C18                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| COMM 2012-CCRE4                                                                                                                                                                                                                                     | January 1, 2018 to December 31, 2018    |
| COMM 2012-LC4                                                                                                                                                                                                                                       | January 1, 2018 to May 31, 2018         |
| WFRBS 2014-C24                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| JPMBB 2014-C25                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| LCCM 2014-909                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2014-LC18                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| COMM 2015-DC1                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| GSMS 2015-GC28                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| WFCM 2015-C27                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2015-LC20                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| WFCM 2015-NXS1                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CSAIL 2015-C2                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2015-NXS2                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| COMM 2015-PC1                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| CSAIL 2015-C3                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2015-SG1                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2015-LC22                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| COMM 2015-CCRE27                                                                                                                                                                                                                                    | January 1, 2018 to December 31, 2018    |
| WFCM 2015-NXS4                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| MSCI 2015-UBS8                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CSAIL 2016-C5                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2016-C32                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2016-NXS5                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CGCMT 2015-GC27 (Special Servicer solely  for the Boca Hamptons Plaza Portfolio Loan prior to July 5, 2018 and named  Special Servicer under the applicable Pooling and Servicing Agreement from  and after July 5, 2018 through December 31, 2018) | January 1, 2018 to December 31, 2018    |
| WFCM 2016-C33                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| MSBAM 2016-C29                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CFCRE 2016-C4                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| GSMS 2016-GS2 (Special Servicer solely for  the Veritas Multifamily Pool 2 only)                                                                                                                                                                    | January 1, 2018 to December 31, 2018    |
| BACM 2016-UBS10                                                                                                                                                                                                                                     | January 1, 2018 to December 31, 2018    |
| SGCMS 2016-C5                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| WFCM 2016-BNK1                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CD 2016-CD1                                                                                                                                                                                                                                         | January 1, 2018 to December 31, 2018    |
| GSMS 2016-GS3                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| MSBAM 2016-C31                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CGCMT 2016-C3                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| CFCRE 2016-C6                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| CSAIL 2016-C7                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| MSCI 2016-UBS12                                                                                                                                                                                                                                     | January 1, 2018 to December 31, 2018    |
| BBCMS 2017-C1                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| GSMS 2017-GS5                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| CGCMT 2017-P7                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| BANK 2017-BNK4                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CD 2017-CD4                                                                                                                                                                                                                                         | January 1, 2018 to December 31, 2018    |
| CFCRE 2017-C8                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| JPMCC 2017-JP6                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CD 2017-CD5                                                                                                                                                                                                                                         | January 1, 2018 to December 31, 2018    |
| GSMS 2017-GS7                                                                                                                                                                                                                                       | January 1, 2018 to December 31, 2018    |
| BANK 2017-BNK7                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| CSAIL 2017-CX9                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| UBS 2017-C4                                                                                                                                                                                                                                         | January 1, 2018 to December 31, 2018    |
| UBS 2017-C6                                                                                                                                                                                                                                         | January 1, 2018 to December 31, 2018    |
| BANK 2017-BNK9                                                                                                                                                                                                                                      | January 1, 2018 to December 31, 2018    |
| GSMS 2018-GS9                                                                                                                                                                                                                                       | March 29, 2018 to December 31, 2018     |
| UBS 2018-C9                                                                                                                                                                                                                                         | March 29, 2018 to December 31, 2018     |
| MSCI 2012-C5                                                                                                                                                                                                                                        | April 13, 2018 to December 31, 2018     |
| WFCM 2018-C44                                                                                                                                                                                                                                       | May 17, 2018 to December 31, 2018       |
| UBS 2018-C10                                                                                                                                                                                                                                        | May 31, 2018 to December 31, 2018       |
| WFCM 2015-C30                                                                                                                                                                                                                                       | July 5, 2018 to December 31, 2018       |
| JPMBB 2014-C23                                                                                                                                                                                                                                      | July 5, 2018 to December 31, 2018       |
| MSBAM 2014-C19                                                                                                                                                                                                                                      | July 5, 2018 to December 31, 2018       |
| COMM 2015-LC21                                                                                                                                                                                                                                      | July 5, 2018 to December 31, 2018       |
| MSBAM 2015-C20                                                                                                                                                                                                                                      | July 5, 2018 to December 31, 2018       |
| JPMBB 2015-C31                                                                                                                                                                                                                                      | July 5, 2018 to December 31, 2018       |
| GSMS 2018-GS10                                                                                                                                                                                                                                      | July 30,2018 to December 31, 2018       |
| CD 2018-CD7                                                                                                                                                                                                                                         | August 24, 2018 to December 31, 2018    |
| GSMS 2018-3PCK                                                                                                                                                                                                                                      | September 27, 2018 to December 31, 2018 |
| BANK 2018-BNK14                                                                                                                                                                                                                                     | September 27, 2018 to December 31, 2018 |
| DBGS 2018-C1                                                                                                                                                                                                                                        | October 30, 2018 to December 31, 2018   |
| CSAIL 2018-C14                                                                                                                                                                                                                                      | November 29, 2018 to December 31, 2018  |
| UBS 2018-C14                                                                                                                                                                                                                                        | December 12, 2018 to December 31, 2018  |

 

**APPENDIX A**

| **Servicing Criteria** | ** **                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **                                                        |
|------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------|
| **Reference**          | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **Performed by Servicer**                                         | **Inapplicable    Servicing Criteria** |   |
|                   | **General Servicing Considerations**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                              |   |   |
| 1122(d)(1)(i)          | Policies and procedures are instituted  to monitor any performance or other triggers and events of default in  accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | **X**                                                             | ** ** |   |
| 1122(d)(1)(ii)         | If any material servicing  activities are outsourced to third parties, policies and procedures are instituted  to monitor the third party’s performance and compliance with such servicing  activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **

**X1**                                                | ** ** |   |
| 1122(d)(1)(iii)        | Any requirements in the  transaction agreements to maintain a back-up servicer for the pool assets are  maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **                                                        | **X** |   |
| 1122(d)(1)(iv)         | A fidelity bond and errors  and omissions policy is in effect on the party participating in the servicing  function throughout the reporting period in the amount of coverage required  by and otherwise in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**

** **                                     | ** ** |   |
| 1122(d)(i)(v)          | Aggregation of information,  as applicable, is mathematically accurate and the information conveyed  accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | ** **

**X**

** **                                     | ** ** |   |
|                   | **Cash Collection and Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **                                                        | ** ** |   |
| 1122(d)(2)(i)          | Payments on pool assets are  deposited into the appropriate custodial bank accounts and related bank  clearing accounts no more than two business days following receipt, or such  other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                              | **X**                                                             |   |   |
| 1122(d)(2)(ii)         | Disbursements made via wire  transfer on behalf of an obligor or to an investor are made only by  authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | ** **                                                        | **X3** |   |
| 1122(d)(2)(iii)        | Advances of funds or  guarantees regarding collections, cash flows or distributions, and any  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | ** **                                                        | **X3** |   |
| 1122(d)(2)(iv)         | The related accounts for the  transaction, such as cash reserve accounts or accounts established as a form  of overcollateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **X**                                                             | ** ** |   |
| 1122(d)(2)(v)          | Each custodial account is  maintained at a federally insured depository institution as set forth in the  transaction agreements. For purposes of this criterion, “federally insured  depository institution” with respect to a foreign financial institution means  a foreign financial institution that meets the requirements of Rule  13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                              | **X**                                                             | ** ** |   |
| 1122(d)(2)(vi)         | Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | **X**                                                             | ** ** |   |
| 1122(d)(2)(vii)        | Reconciliations are prepared  on a monthly basis for all asset-backed securities related bank accounts,  including custodial accounts and related bank clearing accounts. These  reconciliations are (A) mathematically accurate; (B) prepared within 30  calendar days after the bank statement cutoff date, or such other number of  days specified in the transaction agreements; (C) reviewed and approved by  someone other than the person who prepared the reconciliation; and (D)  contain explanations for reconciling items. These reconciling items are resolved  within 90 calendar days of their original identification, or such other  number of days specified in the transaction agreements. | ** **

** **

** **

** **

** **

**X** | ** ** |   |
|                   | **Investor Remittances and Reporting**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **                                                        | ** ** |   |
| 1122(d)(3)(i)          | Reports to investors,  including those to be filed with the Commission, are maintained in accordance  with the transaction agreements and applicable Commission requirements.  Specifically, such reports (A) are prepared in accordance with timeframes and  other terms set forth in the transaction agreements; (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.                                  | **X4**                                                            | ** ** |   |
| 1122(d)(3)(ii)         | Amounts due to investors are  allocated and remitted in accordance with timeframes, distribution priority  and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **                                                        | **X** |   |
| 1122(d)(3)(iii)        | Disbursements made to an  investor are posted within two business days to the Servicer’s investor  records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **                                                        | **X** |   |
| 1122(d)(3)(iv)         | Amounts remitted to  investors per the investor reports agree with cancelled checks, or other form  of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **                                                        | **X** |   |
|                   | **Pool Asset Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **                                                        | ** ** |   |
| 1122(d)(4)(i)          | Collateral or security on  pool assets is maintained as required by the transaction agreements or  related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | **X**                                                             |   |   |
| 1122(d)(4)(ii)         | pool asset and related  documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | **X**                                                             | ** ** |   |
| 1122(d)(4)(iii)        | Any additions, removals or substitutions  to the asset pool are made, reviewed and approved in accordance with any  conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | **X**                                                             | ** ** |   |
| 1122(d)(4)(iv)         | Payments on pool assets,  including any payoffs, made in accordance with the related pool asset  documents are posted to the Servicer’s obligor records maintained no more  than two business days after receipt, or such other number of days specified  in the transaction agreements, and allocated to principal, interest or other  items (e.g., escrow) in accordance with the related pool asset documents.                                                                                                                                                                                                                                                                                       | ** **                                                        | **X2** |   |
| 1122(d)(4)(v)          | The Servicer’s records  regarding the pool assets agree with the Servicer’s records with respect to  an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **                                                        | **X** |   |
| 1122(d)(4)(vi)         | Changes with respect to the  terms or status of an obligor's pool assets (e.g., loan modifications or  re-agings) are made, reviewed and approved by authorized personnel in  accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | **X**                                                             | ** ** |   |
| 1122(d)(4)(vii)        | Loss mitigation or recovery  actions (e.g., forbearance plans, modifications and deeds in lieu of  foreclosure, foreclosures and repossessions, as applicable) are initiated,  conducted and concluded in accordance with the timeframes or other requirements  established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

** **

**X**                                     | ** ** |   |
| 1122(d)(4)(viii)       | Records documenting  collection efforts are maintained during the period a pool asset is delinquent  in accordance with the transaction agreements. Such records are maintained on  at least a monthly basis, or such other period specified in the transaction  agreements, and describe the entity’s activities in monitoring delinquent  pool assets including, for example, phone calls, letters and payment  rescheduling plans in cases where delinquency is deemed temporary (e.g.,  illness or unemployment).                                                                                                                                                                                   | ** **

** **

** **

** **

**X**             | ** ** |   |
| 1122(d)(4)(ix)         | Adjustments to interest rates  or rates of return for pool assets with variable rates are computed based on  the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | ** **                                                        | **X** |   |
| 1122(d)(4)(x)          | Regarding any funds held in  trust for an obligor (such as escrow accounts): (A) such funds are analyzed,  in accordance with the obligor’s pool asset documents, on at least an annual  basis, or such other period specified in the transaction agreements; (B)  interest on such funds is paid, or credited, to obligors in accordance with  applicable pool asset documents and state laws; and (C) such funds are  returned to the obligor within 30 calendar days of full repayment of the  related pool assets, or such other number of days specified in the  transaction agreements.                                                                                                           | ** **                                                        | **X** |   |
| 1122(d)(4)(xi)         | Payments made on behalf of  an obligor (such as tax or insurance payments) are made on or before the  related penalty or expiration dates, as indicated on the appropriate bills or  notices for such payments, provided that such support has been received by  the Servicer at least 30 calendar days prior to these dates, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                          | ** **                                                        | **X** |   |
| 1122(d)(4)(xii)        | Any late payment penalties  in connection with any payment to be made on behalf of an obligor are paid from  the Servicer’s funds and not charged to the obligor, unless the late payment  was due to the obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **                                                        | **X** |   |
| 1122(d)(4)(xiii)       | Disbursements made on behalf  of an obligor are posted within two business days to the obligor’s records maintained  by the Servicer, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **                                                        | **X** |   |
| 1122(d)(4)(xiv)        | Delinquencies, charge-offs  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  

** **                                                | **X**

** ** |   |
| 1122(d)(4)(xv)         | Any external enhancement or  other support, identified in Item 1114(a)(1) through (3) or Item 1115 of  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **                                                        | **X** |   |
|                   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                              |   |   |   |

 

**X1**-RialtoCapital Advisors, LLC performs the activities pertaining to this criterion,except for specific, limited activities performed by its third-party propertymanagers relating to REO Property, if any.  Rialto has elected to takeresponsibility for assessing compliance with these servicing criteria withrespect to the activities of its third-party property managers.

 

**X2**-Primaryresponsibility for processing borrower payments rests with the Master Servicer,however, Rialto Capital Advisors, LLC may from time to time receive payments onan exception basis which are forwarded to the Master Servicer in accordancewith such criteria. The criteria is marked inapplicable as Rialto CapitalAdvisors, LLC had no instances or activity relating to this criteria for thecalendar year of January 1, 2018 to December 31, 2018

 

**X3**-RialtoCapital Advisors, LLC performs the activities under the criteria, however therelated criteria are marked inapplicable as Rialto did not haveinstances/activity during the calendar year of January 1, 2018 and ending onDecember 31, 2018 relating to the criteria.

 

**X4**-Only items(A) and (B) of the Servicing Criteria are applicable to Rialto CapitalAdvisors, LLC as special servicer.  Items (C) and (D) are inapplicable asthe responsibility for filing reports with the Commission and agreeing totalsto the Servicer records rests with the Trustee and/or CertificateAdministrator, as applicable.