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Report of IndependentRegistered Public Accounting Firm

 

TheBoard of Directors and Shareholders 

SunTrustBanks, Inc.

 

Wehave examined management’s assertion, included in the accompanying Report onAssessment of Compliance with SEC Regulation AB Servicing Criteria, that CohenFinancial (the Company), a division of SunTrust Bank, complied with theservicing criteria set forth in Item 1122 (d) of the Securities and ExchangeCommission’s Regulation AB for the commercial mortgage loan servicing platformas of and for the year ended December 31, 2018, except for criteria1122(d)(1)(iii), 1122(d)(3)(i)(C) and 1122(d)(3)(i)(D), which the Company hasdetermined are not applicable to the activities performed by them with respectto the servicing platform covered by this report. See Appendix A ofmanagement’s assertion for the asset backed transactions covered by thisplatform. Management is responsible for the Company’s compliance with thoseservicing criteria. Our responsibility is to express an opinion on management’sassertion about the Company’s compliance with the servicing criteria based onour examination.

 

Ourexamination was conducted in accordance with attestation standards establishedby the American Institute of Certified Public Accountants and the PublicCompany Accounting Oversight Board (United States) and, accordingly, includedexamining, on a test basis, evidence about the Company’s compliance with theapplicable servicing criteria and performing such other procedures as weconsidered necessary in the circumstances. Our examination included testing ofless than all of the individual asset backed transactions and securities thatcomprise the platform, testing of less than all of the servicing activitiesrelated to the Platform and determining whether the Company processed thoseselected transactions and performed those selected activities in compliancewith the servicing criteria and as permitted by Regulation AB Compliance andDisclosure Interpretations of the Division of Corporation Finance, Section200.06, “Vendors Engaged by Servicers” (C&DI 200.06). Furthermore, ourprocedures were limited to the selected transactions and servicing activitiesperformed by the Company during the period covered by this report. Ourprocedures were not designed to determine whether errors may have occurredeither prior to or subsequent to our tests that may have affected the balancesor amounts calculated or reported by the Company during the period covered bythis report for the selected transactions or any other transactions. Althoughthe Company is responsible for assessing compliance with Section 1122(d)(4)(ii)of Regulation AB, there were no servicing activities performed by the Companyduring the year ended December 31, 2018 that required these servicing criteriato be complied with. We believe that the evidence we obtained is sufficient andappropriate to provide a reasonable basis for our opinion.

 

Ourexamination does not provide a legal determination on the Company’s compliancewith the servicing criteria.

 

Asdescribed in management’s assertion, for servicing criteria 1122 (d)(4)(xi),the Company has engaged a vendor to perform the activities required by theseservicing criteria. The Company has determined that this vendor is notconsidered a “servicer” as defined in Item 1101(j) of Regulation AB, and theCompany has elected to take responsibility for assessing compliance with theapplicable servicing criteria applicable to each vendor as permitted byC&DI 200.06. As permitted by C&DI 200.06, the Company has asserted thatit has policies and procedures in place designed to provide reasonableassurance that the vendors’ activities comply in all material respects withservicing criteria applicable to each vendor. The Company is solely responsiblefor determining that it meets the SEC requirements to apply C&DI 200.06 forthe vendors and related criteria as described in its assertion, and weperformed no procedures with respect to the Company’s eligibility to applyC&DI 200.06.

 

Inour opinion, management’s assertion that the Company complied with theaforementioned servicing criteria, including servicing criteria 1122 (d)(4)(xi)for which compliance is determined based on C&DI 200.06 as described above,as of and for the year ended December 31, 2018 for the commercial mortgage loanservicing platform, is fairly stated, in all material respects.

 

 

/s/Ernst & Young LLP

 

February27, 2019

 

 

Amember firm of Ernst & Young Global Limited