(logo) Cohen Financial ®

 

** **

**Management's Report on Assessment of**

**Compliance with Applicable Servicing Criteria**

** **

Management of Cohen Financial,a division of Truist Bank, a North Carolina banking corporation (assuccessor-by-merger to SunTrust Bank , a Georgia banking corporation) (referredto herein as the "Company "), is responsible for compliance with theapplicable servicing criteria set forth in forth in Item 1122(d) of theSecurities and Exchange Commission's Regulation AB for commercial mortgagebacked security transactions specified in Appendix A hereto (the"Platform") as of December 31, 2019 and for the year ended December31, 2019 (the "Reporting Period"), excluding the inapplicableservicing criteria as set forth in Appendix B hereto (such criteria, aftergiving effect to the exclusions identified on Appendix B, the "ApplicableServicing Criteria").

 

The Company has engaged avendor, which are not deemed to be a servicer as defined in Item 1101(j) ofRegulation AB (the "Vendors"), to perform specific and limitedactivities or activities scripted by the Company as of and during the ReportingPeriod, and the Company elects to take responsibility for assessing compliancewith the Applicable Servicing Criteria or portion of the servicing criteriaapplicable to such Vendors as set forth in Appendix A hereto (such criteria,the "Applicable Vendor Servicing Criteria").

 

The Company has policies andprocedures in place designed to provide reasonable assurance that the vendor'sactivities comply in all material respects for the purposes of Regulation ABwith the Applicable Vendor Servicing Criteria. The Company (i) has notidentified and is not aware of any material instance of noncompliance by thevendor with the Applicable Vendor Servicing Criteria and (ii) has notidentified any material deficiency in its policies and procedures to monitorthe compliance by the vendor with the Applicable Vendor Servicing Criteria forthe Reporting Period.

 

The Company has complied, inall material respects, with the Applicable Servicing Criteria as of December31, 2019 and for the Reporting Period with respect to the Platform taken as awhole.

 

PricewaterhouseCoopers LLP, anindependent registered public accounting firm, has issued an attestation reportfor the Platform on the Company's compliance with the Applicable ServicingCriteria as of December 31, 2019 and for the Reporting Period as set forth inthis assertion.

 

March 6, 2020

 

 

/s/ Eric Rosen

Eric Rosen

Head of Investor ServicesOperations

Cohen Financial, a Division ofTruist Bank

 

 

/s/ Vance Patterson

Vance Patterson

Senior Vice President

Cohen Financial, a Division ofTruist Bank

 

 

4601 College Boulevard, Suite300 | Leawood, Kansas 66211

866.315.6212 Office| 866.315.6202 Fax

 

www.cohenfinancial.com

 

**Appendix A**

 

 

Cohen Financial acted asservicer on behalf of master servicers and certain investors for thetransactions below.

 

AREIT 2019-CRE3 Trust

AREIT 2018-CREl Trust

AREIT 2018-CRE2 Trust

CGCMT 2017-1500

COMM 2014-CCRE19 MortgageTrust

COMM 2014-CCRE21 MortgageTrust 

Freddie - Program Plus Bonds#157182

Freddie Program Plus #108094

FREMF 2011-K16

FREMF 2014-K40

FREMF 2015-K42

FREMF 2015-K44

FREMF 2015-KJ02

FREMF 2016-K55 

FREMF 2016-K56 

FREMF 2016-K57

FREMF 2016-K58

FREMF 2016-K59

FREMF 2016-KF17

FREMF 2016-KF19

FREMF 2016-KF23 

FREMF 2016-KF25 

FREMF 2016-KX02

FREMF 2017-K63

FREMF 2017-K64

FREMF 2017-K65 

FREMF 2017-K67 

FREMF 2017-K70 

FREMF 2017-K71 

FREMF 2017-K724 

FREMF 2017-K728 

FREMF 2017-KF35 

FREMF 2017-KF36 

FREMF 2017-KW03 

FREMF 2018-K1508 

FREMF 2018-K1509

FREMF 2018-K72 

FREMF 2018-K76 

FREMF 2018-K78 

FREMF 2018-K80 

FREMF 2018-K81 

FREMF 2018-K82 

FREMF 2018 -KF43 

FREMF 2018-KF44

FREMF 2018-KF46 

FREMF 2018-KF47 

FREMF 2018-KF49 

FREMF 2018-KF53

FREMF 2018-KF54

FREMF 2018-KP05

FREMF 2018-KW06

FREMF 2018-KX03 

FREMF 2019-K100 

FREMF 2019-K102

FREMF 2019-K1510 

FREMF 2019-K1511 

FREMF 2019-K1512 

FREMF 2019-K734 

FREMF 2019-K87 

FREMF 2019-K88 

FREMF 2019-K89 

FREMF 2019-K90 

FREMF 2019-K94 

FREMF 2019-K97 

FREMF 2019-K98 

FREMF 2019-KC05 

FREMF 2019-KF57 

FREMF 2019 -KF60 

FREMF 2019-KF64 

FREMF 2019-KF67 

FREMF 2019-KJ25

FREMF 2019-KLUl 

FRETE 2017-ML01

FRETE 2017-ML02 

FRETE 2019-ML06 

GACM 2019 -FL1

Global Investment Holding CoLtd. 

GSMS 2016-GS2

Impac Funding Corporation 

JPMBB 2014-C25

MSBAM 2014-C18 

MSBAM 2015-C22 

MSBAM Series 2012-C5 

MSBAM Series 2013-C7

ReadyCap-SCMT 2019-SBC8 

SG CRE 2018-FLI CLO

SG CRE 2019-FL2 CLO 

TAH #161828

GS 2017-STAY*

CSMC 2017-CALI*

WPT 2017-WWP*

GSMS 2014-GSFL* 

DAFC 2017-AMO*

CFCRE 2018-TAN*

JPMCC 2018-PTC*

JPMCC 2018-BCON*

 

*Cohen Financial is assignedto act as special servicer on behalf of master servicers and certain investorsfor the transactions below, but there were no special servicing activitiesperformed as of and for the year ended December 31, 2019.

 

 

**Appendix B**

 

 

| ** **

** **

**SERVICING CRITERIA**    | ** **

**APPLICABLE**

**SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **

**INAPPLICAB LE**

**SERVICING CRITERIA**     |
|---------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------|
| ** **

** **

** **

**Reference** | ** **

** **

** **

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

** **

**Performed by**

**Servicer**    | ** **

** **

**Performed by**

**Vendor(s)** | ** **

**Performed by Sub- Servicer(s) or Vendor(s)** | **Not performed by Servicer, Vendor(s) and/or Sub-  Servicer(s)** |
| **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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

 

X                                         |   |   |   |
| 1122(d)(1)(iii)                                   | Any requirements in the transaction  agreements to maintain a back-up servicer for the mortgage loans 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)(1)(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 mortgage loans  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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  

X                                                 |   |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  

 

X                                         |   |   |   |
| 1122(d)(2)(iv)                                    | The related accounts for the  transaction, such as cash reserve accounts or accounts established as a form of  over collateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  

X                                                 |   |   |   |
| 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 mortgage loans serviced by the Servicer.                                           |  

 

 

 

 

 

 

X |   |   |  

 

 

 

 

 

 

X1 |   |
| 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  mortgage loans is maintained as required by the transaction agreements or  related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  

 

X                                         |   |   |   |   |
| 1122(d)(4)(ii)                                    | Mortgage loan 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  

X2                                                |   |   |   |   |
| 1122(d)(4)(iv)                                    | Payments on mortgage loans,  including any payoffs, made in accordance with the related mortgage loan  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 mortgage loan documents.                                                                                                                                                                                                                                                                                     |  

 

 

 

X                         |   |   |   |   |
| 1122(d)(4)(v)                                     | The Servicer's records  regarding the mortgage loans 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 mortgage loans (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 mortgage loan 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 mortgage loans 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 mortgage loans with variable rates are  computed based on the related mortgage loan 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 mortgage loan 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 mortgage loan documents and state laws; and (C) such funds  are returned to the obligor within 30 calendar days of full repayment of the  related mortgage loans, 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                                                         | X3 |   |   |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | X4                                                        |   |   |   |   |
|                                              |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                      |   |   |   |   |   |   |   |   |   |   |

 

 

1 The company does not file a 10D or 10K with theCommission nor are is the Company responsible for agreeing the investor recordsto the Trustee. As such, criteria C and D are inapplicable.

 

2 There have been no additions, removals or substitutionsto the asset pools executed by the Company during the Reporting Period.

 

3 A vendor provides limited services to the Company topay taxes on behalf of obligors. The Company elects to take responsibility forassessing compliance with 1122(d)(4)(xi) .

 

4 There were no transactions within the Platform duringthe Reporting Period that required external enhancement.