**MANAGEMENT’S ASSERTION OF COMPLIANCE**

** **

 

Management of the Agency andTrust division of Citibank, N.A. (or “Company”) is responsible for assessingcompliance with the servicing criteria set forth in Item 1122(d) of Regulation ABpromulgated by the Securities and Exchange Commission.

 

Management has determined thatthe servicing criteria set forth in Item 1122(d) of Regulation AB areapplicable in regard to the servicing platform as of and for the period asfollows:

 

Platform:  Publicly-issued (i.e.,transaction-levelreporting initially required under the Securities Exchange Act of 1934, asamended) and certain privately-issued (i.e., for which transaction-levelreporting is required pursuant to contractual obligation) commercialmortgage-backed securities issued on or after January 1, 2011,as listed inAppendix A, for which the Company provides the following servicing functions(the “Platform”):

 

•         paying agent,certificate administration and trustee; or

•         certificateadministration and paying agent

 

ApplicableServicing Criteria:  Allservicing criteria set forth in Item 1122(d), to the extent required by Item1122(d) servicing criteria in regards to the activities performed by theCompany with respect to the Platform as to any transaction, except for thefollowing servicing criteria: 1122(d)(1)(iii), 1122(d)(4)(i)-1122(d)(4)(ii) and1122(d)(4)(iv)-1122(d)(4)(xv), which management has determined are notapplicable to the activities the Company performs with respect to the Platform(the “Applicable Servicing Criteria”).  Servicing criterion 1122(d)(1)(v)is applicable only to the activities the Company performs related to themathematically accurate aggregation of information received from servicers andthe accurate conveyance of such information within reports to investors. Servicing criterion 1122(d)(4)(iii) is applicable to the activities the Companyperforms with respect to the Platform only as it relates to the Company’sobligation to report additions, removals or substitutions on reports toinvestors in accordance with the transaction agreements.  With respect toservicing criteria 1122(d)(2)(iii) and 1122(d)(4)(iii), there were noactivities performed during the twelve months ended December 31, 2018 with respectto the Platform, because there were no occurrences of events that would requirethe Company to perform such activities.

 

Period:  Twelve months ended December 31,2018 (the“Period”).

 

With respect to the Platformas of and for the Period, the Company’s management provides the followingassertion of compliance with respect to the Applicable Servicing Criteria: 

 

•         The Company’smanagement is responsible for assessing the Company’s compliance with theApplicable Servicing Criteria.

 

•         The Company’smanagement has assessed compliance with the Applicable Servicing Criteria. In making this assessment, management used the criteria set forth by theSecurities and Exchange Commission in paragraph (d) of Item 1122 of RegulationAB.

 

•         Based on suchassessment, the Company has complied, in all material respects, with theApplicable Servicing Criteria.

 

KPMG LLP, an independentregistered public accounting firm, has issued an attestation report withrespect to management’s assertion of compliance with the Applicable ServicingCriteria as of and for the Period. 

 

 

**CITIBANK, N.A.**

 

By: /s/ Karen Montbach 

Its: Managing Director

 

Dated: February 28, 2019

 

 

Appendix A

 

Mortgage-backed Transactions and SecuritiesConstituting the Platform

** **

**DEAL NAME**

225 LIBERTY STREET TRUST2016-225L

CGCMT 2015-GC29

CGBAM 2015-SMRT

CCMT 2013-375P

CCMT 2012-GC8

CCMT 2013-GCJ11

CCMT 2013-GC15

CCMT 2013-GC17

CCMT 2014-GC23

CCMT 2014-GC25

CCMT 2015-GC27

CCMT 2015-GC31

CCMT 2015-GC33

CCMT 2015-GC35

CCMT 2016-GC37

CCMT 2015-P1

CCMT 2016-P3

CCMT 2016-P4

CCMT 2016-P5

CCMT 2016-P6

CCMT 2016-C1

CCMT 2016-C2

CCMT 2016-C3

CFCRE 2011-C2

GSMC 2011-GC3

GSMST 2011-GC5

MSBAM 2014-C17

CGCMT 2017-P7

CGCMT 2017-B1

CGCMT 2017-P8

CD 2017-CD5 Mortgage Trust

CGCMT 2017-C4

CGCMT 2018-B2

BMARK 2018-B3

CGCMT 2018-C5

BMARK 2018-B6

CGCMT 2018-C6