img69977368_0.jpg














MANAGEMENT’S REPORT ON ASSESSMENT OF COMPLIANCE WITH

SEC REGULATION AB SERVICING CRITERIA

1. BellOak, LLC (the “Company”, or “BellOak”) is responsible for assessing compliance with the servicing criteria applicable to it in Items 1122(d)(3)(i)(A-B) and 1122(d)(4)(vii) of the U.S. Securities and Exchange Commission’s Regulation AB, as of and for the year ended December 31, 2023, (the “Reporting Period”), as set forth in Appendix A hereto (the “applicable servicing criteria”). The transactions covered by this report include asset-backed securities transactions for which the Company acted as the Senior Trust Advisor, Trust Advisor, and Operating Advisor for the asset-backed securities transactions listed in Appendix B hereto (the “Platform”).


2. BellOak, LLC used the criteria set forth in Items 1122(d)(3)(i)(A-B) and 1122(d)(4)(vii) of paragraph (d) of Item 1122 of Regulation AB (defined in Appendix A) to provide an assertion on the Company’s assessment of compliance with the applicable servicing criteria.




3. BellOak, LLC has complied, in all material respects, with the applicable servicing criteria as of and for the year ended December 31, 2023, for the Platform.


4. Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on the Company’s assertion on compliance with the applicable servicing criteria for the Reporting Period.








BellOak, LLC

February 19, 2024



/s/ Dennis Grzeskowiak



Dennis Grzeskowiak, Principal of BellOak, LLC



































Page1of4




---

img69977368_1.jpg




Appendix A – Applicable Servicing Criteria



|                        |                                                                                                                                                                                                                                                                                                                                                                                                                         
|----------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|SERVICING CRITERIA     
|Reference               | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                
|Item 1122(d)(3)(i)(A-B) | 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.
|Item 1122(d)(4)(vii)    | Loss mitigation or recovery actions (e.g. forbearance plans, modifications and deeds in lieu of foreclosure, foreclosure and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.                                                                                                                    



Page2of4


---

img69977368_1.jpg


Appendix B – The Platform

BellOak, LLC was named as the Senior Trust Advisor, Trust Advisor and Operating Advisor for all portfolios listed below. However, there was only activity requiring BellOak, LLC to perform the role of Senior Trust Advisor, Trust Advisor, and Operating Advisor for the portfolios designated with a “X” throughout the period in scope listed below.



|                                |                        |                         |                                                                                                                            
|------------------------------- | ---------------------- | ----------------------- | ---------------------------------------------------------------------------------------------------------------------------
|Portfolio Name                  | Service Agreement Date | Period in Scope         | Senior Trust Advisor, Trust Advisor, and Operating Advisor activity required as of and for the year ended December 31, 2023
|245 Park Avenue Trust 2017-245P | May 30, 2017           | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2017-C41                   | November 1, 2017       | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCMT 2017-C39                  | August 1, 2017         | 1/1/2023 to 12/31/2023  |                                                                                                                            
|CGCMT 2017-B1                   | August 1, 2017         | 1/1/2023 to 12/31/2023  |                                                                                                                            
|MSC 2017-H1                     | June 1, 2017           | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2017-RB1                   | March 1, 2017          | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2016-C37                   | December 1, 2016       | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2016-NXS6                  | October 1, 2016        | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2016-LC24                  | September 1, 2016      | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2015-C31                   | November 1, 2015       | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2015-SG1                   | August 1, 2015         | 1/1/2023 to 12/31/2023  | X                                                                                                                          
|WFCM 2015-C29                   | June 1, 2015           | 1/1/2023 to 12/31/2023  |                                                                                                                            
|GSMS 2015-GC30                  | May 1, 2015            | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2015-NXS1                  | April 1, 2015          | 1/1/2023 to 12/31/2023  | X                                                                                                                          
|WFRBS 2014-C25                  | December 1, 2014       | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFRBS 2014-C23                  | September 1, 2014      | 1/1/2023 to 12/31/2023  |                                                                                                                            
|WFRBS 2014-C21                  | August 1, 2014         | 1/1/2023 to 12/31/2023  |                                                                                                                            
|GSMS 2013-GC10                  | February 1, 2013       | 3/31/2023 to 12/31/2023 |                                                                                                                            
|GSMS 2013-GC13                  | May 1, 2013            | 3/31/2023 to 12/31/2023 |                                                                                                                            
|GSMS 2014-GC20                  | April 1, 2014          | 3/31/2023 to 12/31/2023 | X                                                                                                                          



Page3of4


---

img69977368_1.jpg




|                 |                        |                          |                                                                                                                            
|---------------- | ---------------------- | ------------------------ | ---------------------------------------------------------------------------------------------------------------------------
|Portfolio Name   | Service Agreement Date | Period in Scope          | Senior Trust Advisor, Trust Advisor, and Operating Advisor activity required as of and for the year ended December 31, 2023
|MSBAM 2013-C12   | October 1, 2013        | 3/31/2023 to 12/31/2023  |                                                                                                                            
|WFRBS 2013-C13   | May 1, 2013            | 3/31/2023 to 12/31/2023  |                                                                                                                            
|WFRBS 2013-C15   | August 1, 2013         | 3/31/2023 to 12/31/2023  | X                                                                                                                          
|WFRBS 2013-C17   | October 1, 2013        | 3/31/2023 to 12/31/2023  |                                                                                                                            
|WFRBS 2014-C19   | March 1, 2014          | 3/31/2023 to 12/31/2023  |                                                                                                                            
|CGCMT 2014-GC23  | August 1, 2014         | 3/31/2023 to 12/31/2023  |                                                                                                                            
|BMARK 2023 V2    | May 1, 2023            | 5/1/2023 to 12/31/2023   |                                                                                                                            
|CRSO 2023 - BRND | July 1, 2023           | 7/1/2023 to 12/31/2023   |                                                                                                                            
|BBCMS 2023 C21   | October 1, 2023        | 10/1/2023 to 12/31/2023  |                                                                                                                            
|WFCM 2015 LC20   | March 1, 2015          | 10/15/2023 to 12/31/2023 |                                                                                                                            
|WFRBS 2014-LC14  | February 1, 2014       | 10/15/2023 to 12/31/2023 |                                                                                                                            
|WFCM 2015 C27    | March 1, 2015          | 10/15/2023 to 12/31/2023 |                                                                                                                            
|CGCMT 2016 C3    | November 1, 2016       | 10/29/2023 to 12/31/2023 |                                                                                                                            
|BMO 2023-5C2     | November 1, 2023       | 11/1/2023 to 12/31/2023  |                                                                                                                            
|MSWF 2023-2      | December 1, 2023       | 12/1/2023 to 12/31/2023  |                                                                                                                            
|DTP 2023 STE2    | December 28, 2023      | 12/28/2023 to 12/31/2023 |                                                                                                                            



Page4of4


---