**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

**x****  ANNUAL REPORT PURSUANT TO SECTION13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the fiscal year ended December 31, 2021or**

**o**** ****TRANSITIONREPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934**

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-206847-09**

**Central Index Key Number of the issuing entity:0001739423**

**BANK 2018-BNK12**

**(exact name of the issuing entity as specified in itscharter)**

** **

**Central Index Key Number of the depositor: 0001005007**

**Banc of America Merrill LynchCommercial Mortgage Inc.**

**(exact name of the depositor as specified in itscharter)**

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001102113**

**Bank of America, NationalAssociation**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001541557**

**Morgan Stanley Mortgage CapitalHoldings LLC**

**(exact name of the sponsor as specified in its charter)**

** **

**Central Index Key Number of the sponsor: 0001577313**

**National Cooperative Bank, N.A.**

**(exact name of the sponsor as specified in its charter)**

** **

| **New York****(State or other jurisdiction of  incorporation or organization of**

**the issuing entity)** | **38-4083173**

**38-4083174**

**38-7196293**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|

**c/o Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

**Registrant’s telephone number,including area code:**

**(646) 855-3953**

Securities registered pursuant to Section 12(b) of the Act:

| Title of each class | Trading Symbol(s) | Name of each exchange on which registered |
|---------------------|-------------------|-------------------------------------------|
| None                |              |                                      |

 

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

Indicate by check mark whether the registrant has submittedelectronically and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

Indicate by check mark if disclosure of delinquent filerspursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is notcontained herein, and will not be contained, to the best of registrant’sknowledge, in definitive proxy or information statements incorporated byreference in Part III of this Form 10-K or any amendment to this Form10-K.   

Not applicable.

Indicate by check mark whether the registrant is a largeaccelerated filer, an accelerated filer, a non-accelerated filer, a smallerreporting company, or an emerging growth company. See the definitions of “largeaccelerated filer,” “accelerated filer,” “smaller reporting company,” and“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Accelerated filer                                     o

Non-acceleratedfiler          ⌧  (Do not check if asmaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growthcompany                    o

If an emerging growth company, indicate by check mark if theregistrant has elected not to use the extended transition period for complyingwith any new or revised financial accounting standards provided pursuant toSection 13(a) of the Exchange Act.  o

Indicate by check mark whether the registrant has filed areport on and attestation to its management’s assessment of the effectivenessof its internal control over financial reporting under Section 404(b) of theSarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firmthat prepared or issued its audit report. o

Indicate by check mark whether the registrant is a shellcompany (as defined in Rule 12b-2 of the Act).  o Yes ⌧ No

State the aggregate market value of the voting and non-votingcommon equity held by non-affiliates computed by reference to the price atwhich the common equity was last sold, or the average bid and asked price ofsuch common equity, as of the last business day of the registrant’s mostrecently completed second fiscal quarter.

Not applicable.

Indicate by check mark whether the registrant has filed alldocuments and reports required to be filed by Section 12, 13 or 15(d) of theSecurities Exchange Act of 1934 subsequent to the distribution of securitiesunder a plan confirmed by a court.  oYes oNo

Not applicable.

Indicate the number of shares outstanding of each of theregistrant’s classes of common stock, as of the latest practicable date.

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

List hereunder the following documents if incorporated byreference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) intowhich the document is incorporated: (1) Any annual report to security holders;(2) Any proxy or information statement; and (3) Any prospectus filed pursuantto Rule 424(b) or (c) under the Securities Act of 1933. The listed documentsshould be clearly described for identification purposes (e.g., annual report tosecurity holders for fiscal year ended December 24, 1980).

Not applicable.

 

** **

**EXPLANATORY NOTES**

The CoolSprings Galleria Mortgage Loan, theOne Dulles Tower Mortgage Loan, the Fair Oaks Mall Mortgage Loan and theRittenhouse Hill Mortgage Loan, which constituted approximately 9.99%, 9.9%,8.9% and 7.0%, respectively, of the asset pool of the issuing entity as of its cut-offdate, are each an asset of the issuing entity and are each part of a loancombination that includes (a) with respect to the CoolSprings Galleria MortgageLoan, two other *pari passu* loans, which are not assets of the issuingentity, (b) with respect to the One Dulles Tower Mortgage Loan, one other *paripassu* loan, which is not an asset of the issuing entity, (c) with respectto the Fair Oaks Mall Mortgage Loan, four other *pari passu* loans and twosubordinate companion loans, each of which are not assets of the issuing entityand (d) with respect to the Rittenhouse Hill Mortgage Loan, two other *paripassu* loans, which are not assets of the issuing entity. These loancombinations, including the CoolSprings Galleria Mortgage Loan, the One DullesTower Mortgage Loan, the Fair Oaks Mall Mortgage Loan and the Rittenhouse HillMortgage Loan, are being serviced and administered pursuant to the Pooling andServicing Agreement, which is incorporated by reference as Exhibit 4.1 to thisAnnual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Apple Campus 3 Mortgage Loan, whichconstituted approximately 1.9% of the asset pool of the issuing entity as ofits cut-off date.  The Apple Campus 3 Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Apple Campus3 Mortgage Loan and five other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the BANK 2018-BNK10 transaction, Commission File Number333-206677-22 (the “BANK 2018-BNK10 Transaction”). This loancombination, including the Apple Campus 3 Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2018-BNK10 Transaction, which is incorporated by reference as Exhibit 4.2 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Extra Space - TIAA Self Storage PortfolioMortgage Loan, which constituted approximately 6.4% of the asset pool of theissuing entity as of its cut-off date.  The Extra Space - TIAA Self StoragePortfolio Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Extra Space - TIAA Self Storage PortfolioMortgage Loan and two other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the Citigroup Commercial Mortgage Trust 2018-B2 transaction,Commission File Number 333-207132-16 (the “CGCMT 2018-B2 Transaction”).This loan combination, including the Extra Space - TIAA Self Storage PortfolioMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the CGCMT 2018-B2 Transaction, which is incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the North Bay Portfolio Mortgage Loan, whichconstituted approximately 2.1% of the asset pool of the issuing entity as ofits cut-off date.  The North Bay Portfolio Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the NorthBay Portfolio Mortgage Loan and one other *pari passu* loan, which is notan asset of the issuing entity. The other *pari passu* portion of the loancombination was securitized in the BANK 2018-BNK11 transaction, Commission FileNumber 333-206582-14 (the “BANK 2018-BNK11 Transaction”). This loancombination, including the North Bay Portfolio Mortgage Loan, is being servicedand administered pursuant to the pooling and servicing agreement for the BANK2018-BNK11 Transaction, which is incorporated by reference as Exhibit 4.4 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Northwest Hotel Portfolio Mortgage Loan,which constituted approximately 3.7% of the asset pool of the issuing entity asof its cut-off date.  The Northwest Hotel Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theNorthwest Hotel Portfolio Mortgage Loan and two other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the Wells Fargo Commercial Mortgage Trust2018-C44 transaction, Commission File Number 333-206677-24 (the “WFCM2018-C44 Transaction”). This loan combination, including the NorthwestHotel Portfolio Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the WFCM 2018-C44 Transaction, which isincorporated by reference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to The Gateway Mortgage Loan, which constitutedapproximately 6.1% of the asset pool of the issuing entity as of its cut-offdate.  The Gateway Mortgage Loan is an asset of the issuing entity and ispart of a loan combination that includes The Gateway Mortgage Loan, three other*pari passu* loans and six subordinate companion loans, each of which arenot assets of the issuing entity. This loan combination, including The GatewayMortgage Loan, was serviced under the pooling and servicing agreement for theBANK 2018-BNK11 transaction prior to the closing of the securitization of a *paripassu* portion of The Gateway loan combination in the COMM 2018-HOMEMortgage Trust transaction (the “COMM 2018-HOME Transaction”). After the closing of the COMM 2018-HOME Transaction on June 19, 2018, this loancombination, including The Gateway Mortgage Loan was, and will continue to be,serviced and administered pursuant to the trust and servicing agreement withrespect to the COMM 2018-HOME Transaction, which is incorporated by referenceas Exhibit 4.6 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 181 Fremont Street Mortgage Loan, whichconstituted approximately 6.4% of the asset pool of the issuing entity as ofits cut-off date.  The 181 Fremont Street Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 181 FremontStreet Mortgage Loan and six other *pari passu* loans, which are notassets of the issuing entity. This loan combination, including the 181 FremontStreet Mortgage Loan, was serviced under the pooling and servicing agreementfor the WFCM 2018-C44 Transaction prior to the closing of the securitization ofa *pari passu* portion of the 181 Fremont Street loan combination in theBenchmark 2018-B4 Mortgage Trust transaction, Commission File Number333-206705-14 (the “Benchmark 2018-B4 Transaction”).  After theclosing of the Benchmark 2018-B4 Transaction on July 13, 2018, this loancombination, including the 181 Fremont Street Mortgage Loan was, and willcontinue to be, serviced and administered pursuant to the pooling and servicingagreement with respect to the Benchmark 2018-B4 Transaction, which isincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of the mortgageloans serviced under the Pooling and Servicing Agreement and the primaryservicer of the 181 Fremont Street Mortgage Loan, The Gateway Mortgage Loan,the Northwest Hotel Portfolio Mortgage Loan, the North Bay Portfolio MortgageLoan and the Apple Campus 3 Mortgage Loan. As a result, Wells Fargo Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 181Fremont Street Mortgage Loan, The Gateway Mortgage Loan, the Northwest HotelPortfolio Mortgage Loan, the North Bay Portfolio Mortgage Loan and the AppleCampus 3 Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, the 181Fremont Street Mortgage Loan, the Extra Space - TIAA Self Storage PortfolioMortgage Loan, The Gateway Mortgage Loan and the North Bay Portfolio MortgageLoan.  As a result, Park Bridge Lender Services LLC is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Park Bridge LenderServices LLC in the capacities described above are listed in the Exhibit Index.

Midland Loan Services, a Division of PNC Bank, NationalAssociation is the primary servicer of the Extra Space - TIAA Self StoragePortfolio Mortgage Loan and the special servicer of the North Bay PortfolioMortgage Loan prior to July 2, 2021. These mortgage loans constitute more than5%, but less than 10%, of the pool assets of the issuing entity. Therefore, the Depositor included in this Annual Report on Form 10-K anassessment of compliance with applicable servicing criteria for Midland LoanServices, a Division of PNC Bank, National Association and an accountants’attestation report pursuant to Item 1122 of Regulation AB because Midland LoanServices, a Division of PNC Bank, National Association is servicing more than5% of the pool assets.  However, the Depositor is not required to includein this Annual Report on Form 10-K a servicer compliance statement pursuant toItem 1123 of Regulation AB of Midland Loan Services, a Division of PNC Bank, NationalAssociation because Midland Loan Services, a Division of PNC Bank, NationalAssociation is an unaffiliated servicer servicing less than 10% of pool assets.

LNR Partners, LLC is the special servicer of the Extra Space- TIAA Self Storage Portfolio Mortgage Loan and the special servicer of theNorth Bay Portfolio Mortgage Loan on and after July 2, 2021. These mortgageloans constitute more than 5%, but less than 10%, of the pool assets of theissuing entity.  Therefore, the Depositor included in this Annual Reporton Form 10-K an assessment of compliance with applicable servicing criteria forLNR Partners, LLC and an accountants’ attestation report pursuant to Item 1122of Regulation AB because LNR Partners, LLC is servicing more than 5% of thepool assets.  However, the Depositor is not required to include in thisAnnual Report on Form 10-K a servicer compliance statement pursuant to Item1123 of Regulation AB of LNR Partners, LLC because LNR Partners, LLC is anunaffiliated servicer servicing less than 10% of pool assets.

AEGON USA Realty Advisors, LLC is the special servicer of theFair Oaks Mall Mortgage Loan and The Gateway Mortgage Loan, which constitutedapproximately 8.9% and 6.1%, respectively, of the asset pool of the issuingentity as of its cut-off date. In accordance with the Compliance and DisclosureInterpretations, Section 200.03 (Rules 13a-18 and 15d-18, Servicer’s Assessmentof Compliance), this percentage must be reduced *pro rata*because it wasonly acting as special servicer of the Fair Oaks Mall Mortgage Loan MortgageLoan from January 1, 2021 to March 11, 2021 and The Gateway Mortgage Loan fromJanuary 1, 2021 to May 31, 2021. As a result, it falls below the *de minimis*requirements in Item 1122 of Regulation AB and no such assessment or attestationis required. In addition, AEGON USA Realty Advisors, LLC is an unaffiliatedparty that, as a result of such *pro rata* reduction of such percentage,is not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii)of Regulation AB and so no servicer compliance statement is required.

Situs Holdings, LLC is the special servicer of the Fair OaksMall Mortgage Loan on and after March 12, 2021 and The Gateway Mortgage Loan onand after June 1, 2021. As a result, Situs Holdings, LLC is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Situs Holdings, LLC in thecapacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of theNorthwest Hotel Portfolio Mortgage Loan and the Apple Campus 3 MortgageLoan.  As a result, Pentalpha Surveillance LLC is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Pentalpha Surveillance LLC inthe capacities described above are listed in the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the Apple Campus 3 Mortgage Loan, the ExtraSpace - TIAA Self Storage Portfolio Mortgage Loan, the North Bay PortfolioMortgage Loan, the Northwest Hotel Portfolio Mortgage Loan, The GatewayMortgage Loan and the 181 Fremont Street Mortgage Loan.  Pursuant to thePooling and Servicing Agreement, the pooling and servicing agreement for theBANK 2018-BNK10 Transaction, the pooling and servicing agreement for the CGCMT2018-B2 Transaction, the pooling and servicing agreement for the BANK2018-BNK11 Transaction, the pooling and servicing agreement for the WFCM2018-C44 Transaction, the trust and servicing agreement for the COMM 2018-HOMETransaction and the pooling and servicing agreement for the Benchmark 2018-B4Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii) ofRegulation AB (regarding advances of funds or guarantees regarding collections,cash flows or distributions, and any interest or other fees charged for suchadvances, are made, reviewed and approved as specified in the transactionagreements). However, during the reporting period, the trustee did not performany servicing function with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of  the mortgage loans servicedunder the Pooling and Servicing Agreement, the Apple Campus 3 Mortgage Loan,the Extra Space - TIAA Self Storage Portfolio Mortgage Loan, the North BayPortfolio Mortgage Loan, the Northwest Hotel Portfolio Mortgage Loan, TheGateway Mortgage Loan and the 181 Fremont Street Mortgage Loan have deliveredone or more assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC  Thisentity was engaged by the master servicer under the Pooling and ServicingAgreement and the primary servicer of the Apple Campus 3 Mortgage Loan, theNorth Bay Portfolio Mortgage Loan, the Northwest Hotel Portfolio Mortgage Loan,The Gateway Mortgage Loan and the 181 Fremont Street Mortgage Loan to remit taxpayments received from the escrow accounts of borrowers to local taxingauthorities, to report tax amounts due, to verify tax parcel information, andto verify non-escrow tax payments. These servicing functions are includedwithin the servicing criteria set forth in Items 1122(d)(4)(xi) and1122(d)(4)(xii) of Regulation AB.  Therefore, under the principles-baseddefinition of “servicer” set forth in Item 1101(j) of Regulation AB that looksto the functions that an entity performs, this vendor is a “servicer” for thepurposes of Item 1122 of Regulation AB.  *See* Compliance andDisclosure Interpretations, Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  SeeCompliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This AnnualReport on Form 10-K includes an assessment of compliance with applicableservicing criteria and an accountant’s attestation report from U.S. BankNational Association. This entity was engaged by Citibank, N.A., as custodianof the Extra Space - TIAA Self Storage Portfolio Mortgage Loan to performcertain custodial services. These custodial services are servicing functionsincluded within the servicing criteria set forth in Items 1122(d)(4)(i) and1122(d)(4)(ii) of Regulation AB. Therefore, under the principles-baseddefinition of “servicer” set forth in Item 1101(j) or Regulation AB that looksto the functions that an entity performs, this vendor is a “servicer” for thepurposes of Item 1122 of Regulation AB. See Compliance and DisclosureInterpretations, Section 301.01 (Item 1101(j)).

The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements of the certificate administrator of the Apple Campus 3Mortgage Loan, the North Bay Portfolio Mortgage Loan, the Northwest HotelPortfolio Mortgage Loan, The Gateway Mortgage Loan, the 181 Fremont StreetMortgage Loan and the Extra Space - TIAA Self Storage Portfolio Mortgage Loanare omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu*loan combinations that include the 181 Fremont Street Mortgage Loan, the ExtraSpace - TIAA Self Storage Portfolio Mortgage Loan, the North Bay PortfolioMortgage Loan, the Northwest Hotel Portfolio Mortgage Loan and the Apple Campus3 Mortgage Loan, (i) the reports on assessment of compliance with servicingcriteria and attestation reports on assessment of compliance with servicingcriteria of Torchlight Loan Services, LLC as special servicer of the AppleCampus 3 Mortgage Loan and Rialto Capital Advisors, LLC as special servicer ofthe Northwest Hotel Portfolio Mortgage Loan, listed on the Exhibit Index areomitted from this Annual Report on Form 10-K as they are not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 ofRegulation AB because they are parties performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity,and the report on assessment of compliance with servicing criteria andattestation report on assessment of compliance with servicing criteria of AEGONUSA Realty Advisors, LLC as special servicer of the Fair Oaks Mall MortgageLoan prior to March 12, 2021 and The Gateway Mortgage Loan prior to June 1,2021 listed on the Exhibit Index are omitted from this Annual Report on Form10-K for the reasons set forth in the Explanatory Notes above; and (ii) theservicer compliance statements of Torchlight Loan Services, LLC as specialservicer of the Apple Campus 3 Mortgage Loan, Midland Loan Services, a Divisionof PNC Bank, National Association as primary servicer of the Extra Space - TIAASelf Storage Portfolio Mortgage Loan and the North Bay Portfolio Mortgage Loanprior to July 2, 2021, LNR Partners, LLC as special servicer of the Extra Space- TIAA Self Storage Portfolio Mortgage Loan and the North Bay PortfolioMortgage Loan on and after July 2, 2021, Rialto Capital Advisors, LLC asspecial servicer of the Northwest Hotel Portfolio Mortgage Loan and CWCapitalAsset Management LLC as special servicer of the 181 Fremont Street MortgageLoan, listed on the Exhibit Index are omitted from this Annual Report on Form10-K as they are not required by Item 1123 of Regulation AB to be included onthis Annual Report on Form 10-K because they are each an unaffiliated partythat is not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB, and the servicer compliance statement of AEGON USARealty Advisors, LLC as special servicer of the Fair Oaks Mall Mortgage Loanprior to March 12, 2021 and The Gateway Mortgage Loan prior to June 1, 2021listed on the Exhibit Index is omitted from this Annual Report on Form 10-K forthe reasons set forth in the Explanatory Notes above.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

**Item 1B.  Unresolved Staff Comments.**

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

**Item 5.  Market for Registrant’s Common Equity, RelatedStockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

**Item 7.  Management’s Discussion and Analysis ofFinancial Condition and Results of Operations.**

Omitted.

**Item 7A.  Quantitative and Qualitative DisclosuresAbout Market Risk.**

Omitted.

**Item 8.  Financial Statements and Supplementary Data.**

Omitted.

**Item 9.  Changes in and Disagreements WithAccountants on Accounting and Financial Disclosure.**

Omitted.

**Item 9A.  Controls and Procedures.**

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

**Item 10.  Directors, Executive Officers and CorporateGovernance.**

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

**Item 12.  Security Ownership of Certain BeneficialOwners and Management and Related Stockholder Matters.**

Omitted.

**Item 13.  Certain Relationships and RelatedTransactions, and Director Independence.**

Omitted.

**Item 14.  Principal Accounting Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

**Item 1112(b) of Regulation AB, Significant ObligorFinancial Information.**

No single obligor represents 10% or more of the pool assetsheld by the issuing entity. 

**Item 1114(b)(2) of Regulation AB, Significant EnhancementProvider Financial Information.**

No entity or group of affiliated entities provides any external creditenhancement or other support for the certificates within this transaction asdescribed under Item 1114(a) of Regulation AB.

**Item 1115(b) of Regulation AB, Certain DerivativesInstruments (Financial Information).**

No entity or group of affiliated entities provides anyderivative instruments or other support for the certificates within thistransaction as described under Item 1115 of Regulation AB.

**Item 1117 of Regulation AB, Legal Proceedings.**

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and thefollowing, with respect to CWCapital Asset Management LLC, as special servicer,and Wells Fargo Bank, National Association, as certificate administrator and ascustodian.

From time to time, CWCapital Asset Management LLC, a Delawarelimited liability company (“CWCAM”), is a party to lawsuits and otherlegal proceedings as part of its duties as a special servicer (e.g.,enforcement of loan obligations) and/or arising in the ordinary course ofbusiness.  Other than as set forth in the following paragraphs, there arecurrently no legal proceedings pending, and no legal proceedings known to becontemplated by governmental authorities, against CWCAM or of which any of itsproperty is the subject, that are material to the certificateholders.

On December 17, 2015, U.S. Bank National Association, thetrustee under five pooling and servicing agreements for (i) Wachovia BankCommercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC CommercialMortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenceda proceeding with the Second Judicial District Court of Ramsey County,Minnesota (the “State Court”) for a declaratory judgment as to theproper allocation of certain proceeds (“Disputed Proceeds”) received by CWCAMin connection with the sale of the Peter Cooper Village and Stuyvesant Townproperty in New York, New York securing loans held by those trusts.  CWCAMwas the special servicer of such property.  The petition requests theState Court to instruct the trustee, the trust beneficiaries, and any otherinterested parties as to the amount of the Disputed Proceeds, if any, thatconstitute penalty interest and/or the amount of the Disputed Proceeds, if any,that constitute gain-on-sale proceeds, with respect to each trust.  OnFebruary 24, 2016, CWCAM made a limited appearance with the State Court to filea motion to dismiss this proceeding based on lack of jurisdiction, mootness,standing and forum non conveniens.  On July 19, 2016, the State Court deniedCWCAM’s motion to dismiss.  On July 22, 2016, the action was removed tofederal court in Minnesota (“Federal Court”).  On October 21, 2016,the Federal Court held a hearing on the motion to transfer the action to theUnited States District Court for the Southern District of New York (“SDNYCourt”), a motion to remand to state court and a motion to hear CWCAM’srequest for reconsideration of the motion to dismiss.  On March 14, 2017,the Federal Court reserved the determination on the motion to hear CWCAM’srequest for reconsideration of the motion to dismiss, denied the motion toremand the matter to state court and granted the motion to transfer theproceeding to the SDNY Court.  Cross motions for judgment on the pleadingswere filed but the SDNY Court was unable to decide the case based on thepleadings and the SDNY Court ordered discovery.  All fact discovery wascompleted in December, 2018 and expert discovery was completed on March 15,2019.  The parties submitted cross motions for summary judgment, and onMarch 19, 2020, the SDNY Court entered an opinion andorder in which it granted summary judgment in CWCAM’s favor and held that CWCAMwas entitled to the entire amount of penalty interest and that CWCAM’sdetermination of Yield Maintenance was correct.  In the 127-page opinion,the SDNY Court found for CWCAM on every issue presented by the trustee’spetition, namely, that the funds in dispute constitute penalty interest andyield maintenance, not gain-on-sale proceeds, and that the amount of penaltyinterest and yield maintenance was correctly calculated. An appeal of the SDNYCourt’s decision was taken on April 29, 2020.  Oral argument on the appealoccurred on June 21, 2021. The parties await the decision of the appealscourt.  

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of the Original Complaint alleged breaches of a contract and fiduciary duties by CWCAM’saffiliate, CWCapital Investments LLC in its capacity as collateral manager forthe collateralized debt obligation transaction involving CWCapital Cobalt Vr,Ltd. In total, there are 14 counts pled in the Original Complaint. Of those 14,5 claims were asserted against CWCAM for aiding and abetting breach offiduciary duty, conversion and unjust enrichment. On May 23, 2018, the OriginalComplaint was dismissed for lack of subject matter jurisdiction.   OnJune 28, 2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaintin the Supreme Court of the State of New York, County of New York styled asCWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No. 653277/2018(the “New Complaint”).  The gravamen of the New Complaint is thesame as the previous complaint filed in the United State District Court for theSouthern District of New York.  In total there are 16 counts pled in theNew Complaint. Of those 16 counts, 5 claims were asserted against CWCAM foraiding and abetting breach of fiduciary duty, conversion and unjust enrichment,1 count seeks a declaratory judgement that the plaintiff has the right toenforce the contracts in question and 1 count seeks an injunction requiring thedefendants to recognize the plaintiff as the directing holder for the trusts inquestion. On January 11, 2019, the plaintiff dismissed with prejudice thedeclaratory judgment and injunction counts.  The New Complaint and relatedsummons was not served on the defendants until July 13, 2018 and July 16,2018.  The plaintiff’s motion for a preliminary injunction was denied bythe court on July 31, 2018.  On August 3, 2018, the defendants, includingCWCAM, filed a motion to dismiss the New Complaint in its entirety. On August20, 2019, the court entered an order granting defendants’ motion almost in itsentirety, dismissing 11 of the 16 counts and partially dismissing 2 additionalcounts.  Of the remaining counts, 2 are asserted against CWCAM for aidingand abetting breach of fiduciary duty and unjust enrichment.  On September19, 2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relating to theAugust 20, 2019 dismissal order and on September 26, 2019, filed an amendedcomplaint against CWCI and CWCAM attempting to address deficiencies relating tocertain of the claims dismissed by the August, 20, 2019 order.  CWCI andCWCAM filed its Motion to Dismiss the amended complaint on October 28,2019.  The court heard argument on the Motion to Dismiss the amendedcomplaint on January 22, 2020 and on October 23, 2020, the court granted themotion dismissing the amended claims.  On November 30, 2020, CWCapitalCobalt Vr Ltd filed a notice of appeal relating to the October 23, 2020 dismissalorder.  On April 27, 2021, the First Department affirmed the dismissal asto claims against CWCAM that were part of the August 20, 2019 dismissal, butreversed the dismissal of two counts for breach of the Collateral ManagementAgreement against CWCI.  CWCI has sought leave to file an appeal of thedecision.  Both requests for leave were denied by the FirstDepartment.  The plaintiff has also sought leave to appeal the dismissalof the claims against CWCAM.  CWCAM believes that it has performed itsobligations under the related pooling and servicing agreements in good faithand the remaining allegations in the New Complaint are without merit.  

On January 24, 2016 PSW NYC LLC commenced a complaint (the“PSW Complaint”) with the Supreme Court of the State of New York, County of NewYork (the “PSW Court”) against Bank of America, N.A. as trustee under thepooling and servicing agreements for Wachovia Bank Commercial Mortgage Trust2007-C30 and COBALT CMBS Commercial Trust 2007-C2, U.S. Bank NationalAssociation as trustee under the pooling and servicing agreements for WachoviaBank Commercial Mortgage Trust 2007-C31, ML-CFC Commercial Mortgage Trust2007-5 and ML-CFC Commercial Mortgage Trust 2007-6 (collectively, the “PSWTrusts”), PCV-M Holdings LLC and CWCapital Asset Management LLC, individuallyand as special servicer for the PSW Trusts (collectively, the “Defendants”)seeking either (a) damages in an amount to be determined by the PSW Court butalleged by the plaintiffs to be approximately $500,000,000 – such amount beingthe amount PSW NYC LLC alleges would have been recovered on certain mezzanineloans (the “PCVST Mezzanine Loans”) related to the Peter Cooper Village andStuyvesant Town property (the “PCVST Property”) in New York City which PSW NYCLLC sold to an entity related to the Defendants pursuant to a settlementagreement related to certain prior litigation (the “2010 Settlement Agreement”)or (b) the rescission of the 2010 Settlement Agreement which would result in,among other things, the rescission of the sale of the PCVST Mezzanine Loans anda claim for certain proceeds from the sale of the PCVST Property. PSW NYC LLCalleges that the Defendants procured the 2010 Settlement Agreement by fraud andfurther that the terms of the 2010 Settlement Agreement were breached by theDefendants. On February 26, 2016, CWCAM on behalf of itself and the otherDefendants filed a motion to dismiss the PSW Complaint (the “CWCAM Motion toDismiss”). On April 11, 2016, PSW NYC LLC opposed the CWCAM Motion to Dismiss andcross-moved for a partial summary judgment on liability regarding allegationsof breach of the 2010 Settlement Agreement (the “PSW Cross-Motion”). On May 5,2016, the Defendants subsequently filed its reply and opposition to the PSWCross-Motion. On August 23, 2016, oral arguments were provided to the PSW Courtregarding the PSW Complaint, the CWCAM Motion to Dismiss and the PSWCross-Motion and the PSW Court took such arguments under advisement. On October31, 2016, the PSW Court issued an order granting the CWCAM Motion to Dismiss,denying the PSW Cross-Motion and dismissing the PSW Complaint with prejudice.Subsequently, PSW NYC LLC filed a notice of appeal relating to such order. OnFebruary 21, 2017, PSW NYC LLC filed its appeal and supporting brief arguingthat the PSW Court erred by finding no breach of the assignment agreement andno fraudulent inducement. Oral argument was heard on May 4, 2017 at which pointthe court took the arguments under advisement. On May 25, 2017, the New York 1stDepartment appellate court affirmed the dismissal of all PSW claims and denieda request for leave to appeal to the New York Court of Appeals on September 12,2017.  

On March 31, 2016, RAIT Preferred Funding II LTD. (“RAITPreferred Funding”) commenced a complaint (“RAIT Complaint”) withthe Supreme Court of the State of New York, County of New York (the “RAITCourt”), claiming it owns $18,500,000 of a mortgage loan secured by thedevelopment of the One Congress Street Property in Boston, Massachusetts (the “Loan”)and seeking (a) a declaratory judgment stating that RAIT Preferred Funding isthe directing lender under a co-lender agreement dated March 28, 2007 and apooling and servicing agreement dated March 1, 2007 (collectively, the “OperativeAgreements”) and was the directing lender at the time of the impropermodification of the Loan, (b) a declaratory judgment stating that RAITPreferred Funding has the right to terminate the special servicer, (c) monetarydamages for the value of the bonds and fees paid to CWCAM as the specialservicer of the Loan and (d) other things.  On May 17, 2016, CWCAM filed amotion to dismiss the RAIT Complaint (“Motion to Dismiss”) stating thatthe RAIT Complaint did not state a claim and the essential facts of the RAITComplaint are negated by affidavits and evidentiary materials submitted withthe RAIT Complaint.  On June 14, 2016, RAIT Preferred Funding filed aMemorandum of Law in Opposition to the Motion to Dismiss (“Opposition”)stating that the claims in the RAIT Complaint were properly stated.  OnJune 30, 2016, CWCAM filed a reply in support of the Motion to Dismiss and inresponse to the Opposition, stating that each of CWCAM’s arguments is supportedby the express language of the agreements between the parties, the documentaryevidence and New York case law.  On September 30, 2016, RAIT PreferredFunding and CWCAM entered into a confidential Settlement Agreement (the “2016Settlement”), which provides for a stay of the RAIT Preferred Fundinglitigation (the “Litigation Stay”) through August 25, 2017. Pursuant to the terms of the 2016 Settlement, upon satisfaction of a term ofthe 2016 Settlement by August 25, 2017 (or such later date agreed to by theparties), the RAIT Preferred Funding litigation will be dismissed, with prejudice. On May 19, 2017 the Borrower repaid the Loan in accordance with the terms ofthe notes and satisfied the condition to dismissal with prejudice.  RAIThas refused to dismiss the case and is claiming that the B Note should be paidin full.  CWCAM believes that it has performed its obligations under theOperative Agreements in good faith, and that the action should be dismissedwith prejudice.  On August 29, 2017, the RAIT Court granted leave to RAITPreferred Funding to amend its complaint.  On September 20, 2017, RAITPreferred Funding filed an Amended Complaint (the “RAIT Amended Complaint”),which omits its original claims, adds Wells Fargo Bank as a defendant, andseeks (a) specific performance requiring repayment of the $18,500,000 principalamount of the B Note or, in the alternative, monetary damages, including the$18,500,000 principal amount of the B Note, in an amount to be determined attrial, (b) monetary damages on any fees paid to CWCAM as special servicer orWells Fargo Bank as master servicer in connection with the borrower’s repaymentof the Loan, (c) a declaratory judgment that RAIT Preferred Funding is entitledto recover the full $18,500,000 principal amount of the B Note, (d) punitivedamages against CWCAM, and (e) other things.  On October 11, 2017, CWCAMfiled a motion to dismiss the RAIT Amended Complaint (“CWCAM Motion toDismiss Amended Complaint”) stating that the RAIT Amended Complaint did notstate a claim and the essential facts of the RAIT Amended Complaint are negatedby the Operative Agreements and other admissible evidentiary materials. On November 13, 2017, Wells Fargo Bank filed a motion to dismiss the RAITAmended Complaint (the “Wells Fargo Motion to Dismiss Amended Complaint”)and joined the CWCAM Motion to Dismiss Amended Complaint.  On January 29,2018, the court dismissed all claims but for breach of contract and discoveryhas commenced.  CWCAM filed a Motion for Summary Judgement on March 18,2019.   This matter was settled and the case dismissed on May 15,2019.  

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit UnionAdministration (NCUA) filed complaints in the United States District Court forthe Southern District of New York against Wells Fargo Bank, alleging claimsagainst Wells Fargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In eachcase, the plaintiffs allege that Wells Fargo Bank, as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. Wells FargoBank previously settled two class action lawsuits with similar allegations thatwere filed in November 2014 and December 2016 by institutional investors in theSouthern District of New York and New York state court, respectively. Inaddition, Park Royal I LLC and Park Royal II LLC have filed complaints in NewYork state court alleging Wells Fargo Bank, N.A., as trustee, failed to takeappropriate actions upon learning of defective mortgage loan documentation. InMarch 2021, the Company entered into an agreement to resolve the case filed bythe NCUA.

 

In addition to the foregoingcases, in August 2014 and August 2015 Nomura Credit & Capital Inc. (“Nomura”)and Natixis Real Estate Holdings, LLC (“Natixis”) filed a total of seventhird-party complaints against Wells Fargo Bank in New York state court. In theunderlying first-party actions, Nomura and Natixis have been sued for allegedbreaches of representations and warranties made in connection with residentialmortgage-backed securities sponsored by them. In the third-party actions,Nomura and Natixis allege that Wells Fargo Bank, as master servicer, primaryservicer or securities administrator, failed to notify Nomura and Natixis oftheir own breaches, failed to properly oversee the primary servicers, andfailed to adhere to accepted servicing practices. Natixis additionally allegesthat Wells Fargo Bank failed to perform default oversight duties. Wells FargoBank has asserted counterclaims alleging that Nomura and Natixis failed toprovide Wells Fargo Bank notice of their representation and warranty breaches.

 

With respect to each of the foregoing litigations, WellsFargo Bank believes plaintiffs' claims are without merit and intends to contestthe claims vigorously, but there can be no assurances as to the outcome of thelitigations or the possible impact of the litigations on Wells Fargo Bank orthe related RMBS trusts.

**Item 1119 of Regulation AB, Affiliations and CertainRelationships and Related Transactions.**

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on May 30, 2018 pursuant to Rule 424(b)(2).

**Item 1122 of Regulation AB, Compliance with ApplicableServicing Criteria.**

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AAto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the transaction responsible for eachapplicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Apple Campus 3 Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2018-BNK10 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the poolingand servicing agreement for the BANK 2018-BNK10 Transaction incorporated byreference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BANK2018-BNK10 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Extra Space - TIAA Self StoragePortfolio Mortgage Loan, which is being serviced and administered pursuant tothe pooling and servicing agreement for the CGCMT 2018-B2 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit O to the pooling and servicing agreement for the CGCMT 2018-B2Transaction incorporated by reference as Exhibit 4.3 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the CGCMT 2018-B2 Transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the North Bay Portfolio MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the BANK 2018-BNK11 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thepooling and servicing agreement for the BANK 2018-BNK11 Transactionincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theBANK 2018-BNK11 Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Northwest Hotel PortfolioMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the WFCM 2018-C44 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2018-C44 Transaction incorporatedby reference as Exhibit 4.5 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2018-C44 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to The Gateway Mortgage Loan, which isbeing serviced and administered pursuant to the trust and servicing agreementfor the COMM 2018-HOME Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Schedule II to the trust and servicingagreement for the COMM 2018-HOME Transaction incorporated by reference asExhibit 4.6 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the COMM 2018-HOMETransaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 181 Fremont Street Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2018-B4 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Schedule II to the poolingand servicing agreement for the Benchmark 2018-B4 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for theBenchmark 2018-B4 Transaction responsible for each applicable servicingcriteria set forth in Item 1122(d).

The report on assessment of compliance for the twelve monthsended December 31, 2021, furnished pursuant to Item 1122 of Regulation AB byAegon USA Realty Advisors, LLC (“Aegon” or the “Company”), as special servicer,discloses that the following material instance of noncompliance occurred withrespect to its platform:

The examination performed by PWC identified an instance ofmaterial noncompliance with the servicing criteria set forth in Item1122(d)(3)(i)(A) of Regulation AB applicable to the Company during year endedDecember 31, 2021. More specifically, for the only active special serviced dealsubject to Item 1122(d)(3)(i)(A), the report to the investors was not preparedin accordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4is the specific deal related to the aforementioned finding. No other dealswithin Aegon’s CMBS special servicing portfolio were related to or impacted bythis instance of non-compliance.

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timing discrepancy,there was no impact on any investor reporting, issuing, or servicing. Noadditional testing was available for this particular criteria due to thedownsizing of the CMBS portfolio given Aegon’s pending exit from the businessline.

**Item 1123 of Regulation AB, Servicer Compliance Statement.**

The servicer compliance statements are attached as Exhibitsto this Annual Report on Form 10-K.

The servicer compliance statement for the twelve months endedDecember 31, 2021, furnished pursuant to Item 1123 of Regulation AB by AegonUSA Realty Advisors, LLC (“Aegon” or the “Company”), as special servicer,discloses that the following material instance of noncompliance occurred withrespect to its platform:

The examination performed by PWC identified an instance ofmaterial noncompliance with the servicing criteria set forth in Item1122(d)(3)(i)(A) of Regulation AB applicable to the Company during year endedDecember 31, 2021. More specifically, for the only active special serviced dealsubject to Item 1122(d)(3)(i)(A), the report to the investors was not preparedin accordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4is the specific deal related to the aforementioned finding. No other dealswithin Aegon’s CMBS special servicing portfolio were related to or impacted bythis instance of non-compliance.

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timingdiscrepancy, there was no impact on any investor reporting, issuing, orservicing. No additional testing was available for this particular criteria dueto the downsizing of the CMBS portfolio given Aegon’s pending exit from thebusiness line.

 

**PART IV**

**Item 15. Exhibits, Financial Statement Schedules**

(a) The following is a list of documents filed as part ofthis Annual Report on Form 10-K:

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Pooling and Servicing Agreement, dated as of May 1, 2018,by and among Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Midland Loan Services, a Division of PNC Bank, National Association, as GeneralSpecial Servicer, National Cooperative Bank, N.A., as NCB Master Servicer andas NCB Special Servicer, AEGON USA Realty Advisors, LLC, as Fair Oaks MallSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on May 30, 2018 under Commission File No. 333-206847-09 and incorporatedby reference herein).

4.2          Pooling and Servicing Agreement, dated as of February 1,2018, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Torchlight Loan Services, LLC, as General Special Servicer, NationalCooperative Bank, N.A., as NCB Master Servicer and as NCB Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.5 to the registrant’s Current Report on Form 8-K filed on May 30,2018 under Commission File No. 333-206847-09 and incorporated by referenceherein).

4.3          Pooling and Servicing Agreement, dated as of March 1,2018, by and among Citigroup Commercial Mortgage Securities Inc., as Depositor,Midland Loan Services, a Division of PNC Bank, National Association, as MasterServicer, LNR Partners, LLC, as Special Servicer, Park Bridge Lender ServicesLLC as Operating Advisor and Asset Representations Reviewer, Citibank, N.A., asCertificate Administrator, and Wilmington Trust, National Association, asTrustee (filed as Exhibit 4.3 to the registrant’s Current Report on Form 8-Kfiled on May 30, 2018 under Commission File No. 333-206847-09 and incorporatedby reference herein).

4.4          Pooling and Servicing Agreement, dated as of April 1,2018, by and among Morgan Stanley Capital I Inc., as Depositor, Wells FargoBank, National Association, as General Master Servicer, Midland Loan Services,a Division of PNC Bank, National Association, as General Special Servicer,National Cooperative Bank, N.A., as NCB Master Servicer and as NCB SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.4 to the registrant’s Current Report on Form 8-K/A filed onFebruary 20, 2019 under Commission File No. 333-206847-09 and incorporated byreference herein).

4.5          Pooling and Servicing Agreement, dated as of May 1, 2018,by and among Wells Fargo Commercial Mortgage Securities, Inc., as Depositor,Wells Fargo Bank, National Association, as Master Servicer, Rialto CapitalAdvisors, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Pentalpha Surveillance LLC, as Operating Advisor and as AssetRepresentations Reviewer (filed as Exhibit 4.2 to the registrant’s CurrentReport on Form 8-K filed on May 30, 2018 under Commission File No.333-206847-09 and incorporated by reference herein).

4.6          Pooling and Servicing Agreement, dated as of June 1,2018, by and among Deutsche Mortgage & Asset Receiving Corporation, as Depositor,Wells Fargo Bank, National Association, as Master Servicer, AEGON USA RealtyAdvisors, LLC, as Special Servicer, Wilmington Trust, National Association, asTrustee, Wells Fargo Bank, National Association, as Certificate Administrator,Paying Agent and Custodian, and Park Bridge Lender Services LLC, as OperatingAdvisor (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K/Afiled on June 25, 2018 under Commission File No. 333-206847-09 and incorporatedby reference herein).

4.7          Pooling and Servicing Agreement, dated as of July 1,2018, by and among Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Wells Fargo Bank, National Association, as Master Servicer,CWCapital Asset Management LLC, as Special Servicer, Wilmington Trust, NationalAssociation, as Trustee, Wells Fargo Bank, National Association, as CertificateAdministrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit4.1 to the registrant’s Current Report on Form 8-K filed on July 17, 2018 underCommission File No. 333-206847-09 and incorporated by reference herein).

4.8          Agreement Between Note Holders, dated as of May 30, 2018,by and between Wells Fargo Bank, National Association, as Initial Note A-1Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,Wells Fargo Bank, National Association, as Initial Note A-3 Holder, and WellsFargo Bank, National Association, as Initial Note A-4 Holder (filed as Exhibit4.6 to the registrant’s Current Report on Form 8-K filed on May 30, 2018 underCommission File No. 333-206847-09 and incorporated by reference herein).

4.9          Agreement Between Note Holders, dated as of April 26,2018, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, and Wells Fargo Bank, National Association, as Initial Note A-2Holder (filed as Exhibit 4.7 to the registrant’s Current Report on Form 8-Kfiled on May 30, 2018 under Commission File No. 333-206847-09 and incorporatedby reference herein).

4.10         Agreement Between Noteholders, dated as of April 27,2018, by and between Bank of America, N.A., as Initial Note A-1-1 Holder, Bankof America, N.A., as Initial Note A-1-2 Holder, Barclays Bank PLC, as InitialNote A-2-1 Holder, Barclays Bank PLC, as Initial Note A-2-2 Holder, BarclaysBank PLC, as Initial Note A-2-3 Holder, Bank of America, N.A., as Initial NoteB-1 Holder, and Barclays Bank PLC, as Initial Note B-2 Holder (filed as Exhibit4.8 to the registrant’s Current Report on Form 8-K filed on May 30, 2018 underCommission File No. 333-206847-09 and incorporated by reference herein).

4.11         Agreement Between Note Holders, dated as of May 24, 2018,by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, MorganStanley Bank, N.A., as Initial Note A-2 Holder, and Morgan Stanley Bank, N.A.,as Initial Note A-3 Holder (filed as Exhibit 4.9 to the registrant’s CurrentReport on Form 8-K filed on May 30, 2018 under Commission File No.333-206847-09 and incorporated by reference herein).

4.12         Co-Lender Agreement, dated as of May 7, 2018, betweenDeutsche Bank AG, New York Branch, as Note A-1 Holder, Wells Fargo Bank,National Association, as Note A-2 Holder, Wells Fargo Bank, NationalAssociation, as Note A-3 Holder, Deutsche Bank AG, New York Branch, as Note A-4Holder, Deutsche Bank AG, New York Branch, as Note A-5 Holder, Barclays BankPLC, as Note A-6-1 Holder,  and Barclays Bank PLC, as Note A-6-2 Holder(filed as Exhibit 4.10 to the registrant’s Current Report on Form 8-K filed onMay 30, 2018 under Commission File No. 333-206847-09 and incorporated byreference herein).

4.13         Agreement Between Note Holders, dated as of February 2,2018, by and between Bank of America, N.A., as Initial Note A-1 Holder, Bank ofAmerica, N.A., as Initial Note A-2 Holder, and Bank of America, N.A., asInitial Note A-3 Holder (filed as Exhibit 4.11 to the registrant’s Current Reporton Form 8-K filed on May 30, 2018 under Commission File No. 333-206847-09 andincorporated by reference herein).

4.14         Agreement Between Noteholders, dated as of March 23,2018, by and between Deutsche Bank AG, New York Branch, as Initial Note A-1-AHolder, Deutsche Bank AG, New York Branch, as Initial Note A-1-B Holder, Bankof America, N.A., as Initial Note A-2-A Holder, Bank of America, N.A., asInitial Note A-2-B Holder, Deutsche Bank AG, New York Branch, as Initial NoteB-1-A Holder, Deutsche Bank AG, New York Branch, as Initial Note B-1-B Holder,Bank of America, N.A., as Initial Note B-2-A Holder, Bank of America, N.A., asInitial Note B-2-B Holder, Deutsche Bank AG, New York Branch, as Initial NoteC-1 Holder, and Bank of America, N.A., as Initial Note C-2 Holder (filed asExhibit 4.12 to the registrant’s Current Report on Form 8-K filed on May 30,2018 under Commission File No. 333-206847-09 and incorporated by referenceherein).

4.15         Agreement Between Note Holders, dated as of April 26,2018, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,and Wells Fargo Bank, National Association, as Initial Note A-3 Holder (filedas Exhibit 4.13 to the registrant’s Current Report on Form 8-K filed on May 30,2018 under Commission File No. 333-206847-09 and incorporated by referenceherein).

4.16         Agreement Between Note Holders, dated as of March 8,2018, by and between Bank of America, N.A., as Initial Note A-1 Holder, andBank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.14 to theregistrant’s Current Report on Form 8-K filed on May 30, 2018 under CommissionFile No. 333-206847-09 and incorporated by reference herein).

4.17         Co-Lender Agreement, dated as of February 13, 2018, byand among Wells Fargo Bank, National Association, as Initial Note A-1 Holder,Wells Fargo Bank, National Association, as Initial Note A-2 Holder, Wells FargoBank, National Association, as Initial Note A-3 Holder, Deutsche Bank AG, NewYork Branch, as Initial Note A-4 Holder, and Goldman Sachs Mortgage Company, asInitial Note A-5 Holder (filed as Exhibit 4.15 to the registrant’s CurrentReport on Form 8-K filed on May 30, 2018 under Commission File No.333-206847-09 and incorporated by reference herein).

31           Rule 13a-14(d)/15d-14(d) Certifications.

33           Reports on assessment of compliance with servicing criteria for asset-backedsecurities.

33.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

33.2        National Cooperative Bank, N.A., as NCB MasterServicer

33.3        Argentic Services Company LP, as General SpecialServicer

33.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 33.2)

33.5        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

33.6        Wells Fargo Bank, National Association, asCertificate Administrator

33.7        Wells Fargo Bank, National Association, asCustodian

33.8        Park Bridge Lender Services LLC, as Operating Advisor

33.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

33.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

33.12      Wells Fargo Bank, National Association, as PrimaryServicer of the CoolSprings Galleria Mortgage Loan (see Exhibit 33.1)

33.13      Argentic Services Company LP, as Special Servicerof the CoolSprings Galleria Mortgage Loan (see Exhibit 33.3)

33.14      Wilmington Trust, National Association, as Trustee of the CoolSprings GalleriaMortgage Loan (Omitted. See Explanatory Notes.)

33.15      Wells Fargo Bank, National Association, asCustodian of the CoolSprings Galleria Mortgage Loan (see Exhibit 33.7)

33.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the CoolSprings Galleria Mortgage Loan (see Exhibit 33.8)

33.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the CoolSprings Galleria Mortgage Loan (see Exhibit 33.9)

33.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.19      Wells Fargo Bank, National Association, as Primary Servicerof the One Dulles Tower Mortgage Loan (see Exhibit 33.1)

33.20      Argentic Services Company LP, as Special Servicerof the One Dulles Tower Mortgage Loan (see Exhibit 33.3)

33.21      Wilmington Trust, National Association, as Trustee of the One Dulles TowerMortgage Loan (Omitted. See Explanatory Notes.)

33.22      Wells Fargo Bank, National Association, asCustodian of the One Dulles Tower Mortgage Loan (see Exhibit 33.7)

33.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the One Dulles Tower Mortgage Loan (see Exhibit 33.8)

33.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the One Dulles Tower Mortgage Loan (see Exhibit 33.9)

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Fair Oaks Mall Mortgage Loan (see Exhibit 33.1)

33.27      AEGON USA Realty Advisors, LLC, as Special Servicer of the Fair Oaks Mall MortgageLoan prior to March 12, 2021 (Omitted. See Explanatory Notes.)

33.28      Situs Holdings, LLC, as Special Servicer of theFair Oaks Mall Mortgage Loan on and after March 12, 2021

33.29      Wilmington Trust, National Association, as Trustee of the Fair Oaks MallMortgage Loan (Omitted. See Explanatory Notes.)

33.30      Wells Fargo Bank, National Association, asCustodian of the Fair Oaks Mall Mortgage Loan (see Exhibit 33.7)

33.31      Park Bridge Lender Services LLC, as OperatingAdvisor of the Fair Oaks Mall Mortgage Loan (see Exhibit 33.8)

33.32      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Fair Oaks Mall Mortgage Loan (see Exhibit 33.9)

33.33      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.34      Wells Fargo Bank, National Association, as PrimaryServicer of the Rittenhouse Hill Mortgage Loan (see Exhibit 33.1)

33.35      Argentic Services Company LP, as Special Servicerof the Rittenhouse Hill Mortgage Loan (see Exhibit 33.3)

33.36      Wilmington Trust, National Association, as Trustee of the Rittenhouse HillMortgage Loan (Omitted. See Explanatory Notes.)

33.37      Wells Fargo Bank, National Association, asCustodian of the Rittenhouse Hill Mortgage Loan (see Exhibit 33.7)

33.38      Park Bridge Lender Services LLC, as OperatingAdvisor of the Rittenhouse Hill Mortgage Loan (see Exhibit 33.8)

33.39      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Rittenhouse Hill Mortgage Loan (see Exhibit 33.9)

33.40      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.41      Wells Fargo Bank, National Association, as PrimaryServicer of the Apple Campus 3 Mortgage Loan (see Exhibit 33.1)

33.42      Torchlight Loan Services, LLC, as Special Servicer of the Apple Campus 3Mortgage Loan (Omitted. See Explanatory Notes.)

33.43      Wilmington Trust, National Association, as Trustee of the Apple Campus 3Mortgage Loan (Omitted. See Explanatory Notes.)

33.44      Wells Fargo Bank, National Association, asCustodian of the Apple Campus 3 Mortgage Loan (see Exhibit 33.7)

33.45      Pentalpha Surveillance LLC, as Operating Advisorof the Apple Campus 3 Mortgage Loan

33.46      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Apple Campus 3 Mortgage Loan (see Exhibit 33.9)

33.47      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.48      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Extra Space - TIAA SelfStorage Portfolio Mortgage Loan

33.49      LNR Partners, LLC, as Special Servicer of theExtra Space - TIAA Self Storage Portfolio Mortgage Loan

33.50      Wilmington Trust, National Association, as Trustee of the Extra Space - TIAASelf Storage Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.51      Citibank, N.A., as Custodian of the Extra Space -TIAA Self Storage Portfolio Mortgage Loan

33.52      Park Bridge Lender Services LLC, as OperatingAdvisor of the Extra Space - TIAA Self Storage Portfolio Mortgage Loan (seeExhibit 33.8)

33.53      U.S. Bank National Association, as ServicingFunction Participant of the Extra Space - TIAA Self Storage Portfolio MortgageLoan

33.54      Wells Fargo Bank, National Association, as PrimaryServicer of the North Bay Portfolio Mortgage Loan (see Exhibit 33.1)

33.55      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the North Bay Portfolio MortgageLoan prior to July 2, 2021 (see Exhibit 33.48)

33.56      LNR Partners, LLC, as Special Servicer of theNorth Bay Portfolio Mortgage Loan on and after July 2, 2021 (see Exhibit 33.49)

33.57      Wilmington Trust, National Association, as Trustee of the North Bay PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.58      Wells Fargo Bank, National Association, asCustodian of the North Bay Portfolio Mortgage Loan (see Exhibit 33.7)

33.59      Park Bridge Lender Services LLC, as OperatingAdvisor of the North Bay Portfolio Mortgage Loan (see Exhibit 33.8)

33.60      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the North Bay Portfolio Mortgage Loan (see Exhibit 33.9)

33.61      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.62      Wells Fargo Bank, National Association, as PrimaryServicer of the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 33.1)

33.63      Rialto Capital Advisors, LLC, as Special Servicer of the Northwest HotelPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.64      Wilmington Trust, National Association, as Trustee of the Northwest HotelPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.65      Wells Fargo Bank, National Association, asCustodian of the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 33.7)

33.66      Pentalpha Surveillance LLC, as Operating Advisorof the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 33.45)

33.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 33.9)

33.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.69      Wells Fargo Bank, National Association, as PrimaryServicer of The Gateway Mortgage Loan (see Exhibit 33.1)

33.70      AEGON USA Realty Advisors, LLC, as Special Servicer of The Gateway MortgageLoan prior to June 1, 2021 (Omitted. See Explanatory Notes.)

33.71      Situs Holdings, LLC, as Special Servicer of TheGateway Mortgage Loan on and after June 1, 2021 (see Exhibit 33.28)

33.72      Wilmington Trust, National Association, as Trustee of The Gateway Mortgage Loan(Omitted. See Explanatory Notes.)

33.73      Wells Fargo Bank, National Association, asCustodian of The Gateway Mortgage Loan (see Exhibit 33.7)

33.74      Park Bridge Lender Services LLC, as OperatingAdvisor of The Gateway Mortgage Loan (see Exhibit 33.8)

33.75      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Gateway Mortgage Loan (see Exhibit 33.9)

33.76      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

33.77      Wells Fargo Bank, National Association, as PrimaryServicer of the 181 Fremont Street Mortgage Loan (see Exhibit 33.1)

33.78      CWCapital Asset Management LLC, as SpecialServicer of the 181 Fremont Street Mortgage Loan

33.79      Wilmington Trust, National Association, as Trustee of the 181 Fremont StreetMortgage Loan (Omitted. See Explanatory Notes.)

33.80      Wells Fargo Bank, National Association, asCustodian of the 181 Fremont Street Mortgage Loan (see Exhibit 33.7)

33.81      Park Bridge Lender Services LLC, as OperatingAdvisor of the 181 Fremont Street Mortgage Loan (see Exhibit 33.8)

33.82      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 181 Fremont Street Mortgage Loan (see Exhibit 33.9)

33.83      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.11)

34           Attestationreports on assessment of compliance with servicing criteria for asset-backedsecurities.

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

34.2        National Cooperative Bank, N.A., as NCB MasterServicer

34.3        Argentic Services Company LP, as General SpecialServicer

34.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 34.2)

34.5        Wilmington Trust, National Association, as Trustee (Omitted. See ExplanatoryNotes.)

34.6        Wells Fargo Bank, National Association, asCertificate Administrator

34.7        Wells Fargo Bank, National Association, asCustodian

34.8        Park Bridge Lender Services LLC, as OperatingAdvisor

34.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

34.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021

34.12      Wells Fargo Bank, National Association, as PrimaryServicer of the CoolSprings Galleria Mortgage Loan (see Exhibit 34.1)

34.13      Argentic Services Company LP, as Special Servicerof the CoolSprings Galleria Mortgage Loan (see Exhibit 34.3)

34.14      Wilmington Trust, National Association, as Trustee of the CoolSprings GalleriaMortgage Loan (Omitted. See Explanatory Notes.)

34.15      Wells Fargo Bank, National Association, asCustodian of the CoolSprings Galleria Mortgage Loan (see Exhibit 34.7)

34.16      Park Bridge Lender Services LLC, as Operating Advisorof the CoolSprings Galleria Mortgage Loan (see Exhibit 34.8)

34.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the CoolSprings Galleria Mortgage Loan (see Exhibit 34.9)

34.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.19      Wells Fargo Bank, National Association, as PrimaryServicer of the One Dulles Tower Mortgage Loan (see Exhibit 34.1)

34.20      Argentic Services Company LP, as Special Servicerof the One Dulles Tower Mortgage Loan (see Exhibit 34.3)

34.21      Wilmington Trust, National Association, as Trustee of the One Dulles TowerMortgage Loan (Omitted. See Explanatory Notes.)

34.22      Wells Fargo Bank, National Association, asCustodian of the One Dulles Tower Mortgage Loan (see Exhibit 34.7)

34.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the One Dulles Tower Mortgage Loan (see Exhibit 34.8)

34.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the One Dulles Tower Mortgage Loan (see Exhibit 34.9)

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Fair Oaks Mall Mortgage Loan (see Exhibit 34.1)

34.27      AEGON USA Realty Advisors, LLC, as Special Servicer of the Fair Oaks MallMortgage Loan prior to March 12, 2021 (Omitted. See Explanatory Notes.)

34.28      Situs Holdings, LLC, as Special Servicer of theFair Oaks Mall Mortgage Loan on and after March 12, 2021

34.29      Wilmington Trust, National Association, as Trustee of the Fair Oaks MallMortgage Loan (Omitted. See Explanatory Notes.)

34.30      Wells Fargo Bank, National Association, asCustodian of the Fair Oaks Mall Mortgage Loan (see Exhibit 34.7)

34.31      Park Bridge Lender Services LLC, as OperatingAdvisor of the Fair Oaks Mall Mortgage Loan (see Exhibit 34.8)

34.32      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Fair Oaks Mall Mortgage Loan (see Exhibit 34.9)

34.33      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.34      Wells Fargo Bank, National Association, as PrimaryServicer of the Rittenhouse Hill Mortgage Loan (see Exhibit 34.1)

34.35      Argentic Services Company LP, as Special Servicerof the Rittenhouse Hill Mortgage Loan (see Exhibit 34.3)

34.36      Wilmington Trust, National Association, as Trustee of the Rittenhouse HillMortgage Loan (Omitted. See Explanatory Notes.)

34.37      Wells Fargo Bank, National Association, asCustodian of the Rittenhouse Hill Mortgage Loan (see Exhibit 34.7)

34.38      Park Bridge Lender Services LLC, as OperatingAdvisor of the Rittenhouse Hill Mortgage Loan (see Exhibit 34.8)

34.39      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Rittenhouse Hill Mortgage Loan (see Exhibit 34.9)

34.40      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.41      Wells Fargo Bank, National Association, as Primary Servicerof the Apple Campus 3 Mortgage Loan (see Exhibit 34.1)

34.42      Torchlight Loan Services, LLC, as Special Servicer of the Apple Campus 3Mortgage Loan (Omitted. See Explanatory Notes.)

34.43      Wilmington Trust, National Association, as Trustee of the Apple Campus 3Mortgage Loan (Omitted. See Explanatory Notes.)

34.44      Wells Fargo Bank, National Association, asCustodian of the Apple Campus 3 Mortgage Loan (see Exhibit 34.7)

34.45      Pentalpha Surveillance LLC, as Operating Advisorof the Apple Campus 3 Mortgage Loan

34.46      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Apple Campus 3 Mortgage Loan (see Exhibit 34.9)

34.47      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.48      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Extra Space - TIAA SelfStorage Portfolio Mortgage Loan

34.49      LNR Partners, LLC, as Special Servicer of theExtra Space - TIAA Self Storage Portfolio Mortgage Loan

34.50      Wilmington Trust, National Association, as Trustee of the Extra Space - TIAASelf Storage Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.51      Citibank, N.A., as Custodian of the Extra Space -TIAA Self Storage Portfolio Mortgage Loan

34.52      Park Bridge Lender Services LLC, as OperatingAdvisor of the Extra Space - TIAA Self Storage Portfolio Mortgage Loan (seeExhibit 34.8)

34.53      U.S. Bank National Association, as ServicingFunction Participant of the Extra Space - TIAA Self Storage Portfolio MortgageLoan

34.54      Wells Fargo Bank, National Association, as PrimaryServicer of the North Bay Portfolio Mortgage Loan (see Exhibit 34.1)

34.55      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the North Bay Portfolio MortgageLoan prior to July 2, 2021 (see Exhibit 34.48)

34.56      LNR Partners, LLC, as Special Servicer of theNorth Bay Portfolio Mortgage Loan on and after July 2, 2021 (see Exhibit 34.49)

34.57      Wilmington Trust, National Association, as Trustee of the North Bay PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.58      Wells Fargo Bank, National Association, as Custodianof the North Bay Portfolio Mortgage Loan (see Exhibit 34.7)

34.59      Park Bridge Lender Services LLC, as OperatingAdvisor of the North Bay Portfolio Mortgage Loan (see Exhibit 34.8)

34.60      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the North Bay Portfolio Mortgage Loan (see Exhibit 34.9)

34.61      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.62      Wells Fargo Bank, National Association, as PrimaryServicer of the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 34.1)

34.63      Rialto Capital Advisors, LLC, as Special Servicer of the Northwest HotelPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.64      Wilmington Trust, National Association, as Trustee of the Northwest HotelPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.65      Wells Fargo Bank, National Association, asCustodian of the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 34.7)

34.66      Pentalpha Surveillance LLC, as Operating Advisorof the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 34.45)

34.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 34.9)

34.68      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.69      Wells Fargo Bank, National Association, as PrimaryServicer of The Gateway Mortgage Loan (see Exhibit 34.1)

34.70      AEGON USA Realty Advisors, LLC, as Special Servicer of The Gateway MortgageLoan prior to June 1, 2021 (Omitted. See Explanatory Notes.)

34.71      Situs Holdings, LLC, as Special Servicer of TheGateway Mortgage Loan on and after June 1, 2021 (see Exhibit 34.28)

34.72      Wilmington Trust, National Association, as Trustee of The Gateway Mortgage Loan(Omitted. See Explanatory Notes.)

34.73      Wells Fargo Bank, National Association, asCustodian of The Gateway Mortgage Loan (see Exhibit 34.7)

34.74      Park Bridge Lender Services LLC, as OperatingAdvisor of The Gateway Mortgage Loan (see Exhibit 34.8)

34.75      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of The Gateway Mortgage Loan (see Exhibit 34.9)

34.76      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

34.77      Wells Fargo Bank, National Association, as PrimaryServicer of the 181 Fremont Street Mortgage Loan (see Exhibit 34.1)

34.78      CWCapital Asset Management LLC, as SpecialServicer of the 181 Fremont Street Mortgage Loan

34.79      Wilmington Trust, National Association, as Trustee of the 181 Fremont StreetMortgage Loan (Omitted. See Explanatory Notes.)

34.80      Wells Fargo Bank, National Association, as Custodianof the 181 Fremont Street Mortgage Loan (see Exhibit 34.7)

34.81      Park Bridge Lender Services LLC, as OperatingAdvisor of the 181 Fremont Street Mortgage Loan (see Exhibit 34.8)

34.82      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 181 Fremont Street Mortgage Loan (see Exhibit 34.9)

34.83      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.11)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

35.2        National Cooperative Bank, N.A., as NCB MasterServicer

35.3        Argentic Services Company LP, as General SpecialServicer

35.4        National Cooperative Bank, N.A., as NCB SpecialServicer (see Exhibit 35.2)

35.5        Wells Fargo Bank, National Association, asCertificate Administrator

35.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator on andafter November 1, 2021

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of the CoolSprings Galleria Mortgage Loan (see Exhibit 35.1)

35.8        Argentic Services Company LP, as Special Servicerof the CoolSprings Galleria Mortgage Loan (see Exhibit 35.3)

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the One Dulles Tower Mortgage Loan (see Exhibit 35.1)

35.10      Argentic Services Company LP, as Special Servicerof the One Dulles Tower Mortgage Loan (see Exhibit 35.3)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of the Fair Oaks Mall Mortgage Loan (see Exhibit 35.1)

35.12      AEGON USA Realty Advisors, LLC, as Special Servicer of the Fair Oaks MallMortgage Loan prior to March 12, 2021 (Omitted. See Explanatory Notes.)

35.13      Situs Holdings, LLC, as Special Servicer of theFair Oaks Mall Mortgage Loan on and after March 12, 2021

35.14      Wells Fargo Bank, National Association, as PrimaryServicer of the Rittenhouse Hill Mortgage Loan (see Exhibit 35.1)

35.15      Argentic Services Company LP, as Special Servicerof the Rittenhouse Hill Mortgage Loan (see Exhibit 35.3)

35.16      Wells Fargo Bank, National Association, as PrimaryServicer of the Apple Campus 3 Mortgage Loan

35.17      Torchlight Loan Services, LLC, as Special Servicer of the Apple Campus 3Mortgage Loan (Omitted. See Explanatory Notes.)

35.18      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Extra Space - TIAA Self Storage Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

35.19      LNR Partners, LLC, as Special Servicer of the Extra Space - TIAA Self StoragePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

35.20      Wells Fargo Bank, National Association, as PrimaryServicer of the North Bay Portfolio Mortgage Loan (see Exhibit 35.1)

35.21      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the North Bay Portfolio Mortgage Loan prior to July 2, 2021(Omitted. See Explanatory Notes.)

35.22      LNR Partners, LLC, as Special Servicer of the North Bay Portfolio Mortgage Loanon and after July 2, 2021 (Omitted. See Explanatory Notes.)

35.23      Wells Fargo Bank, National Association, as PrimaryServicer of the Northwest Hotel Portfolio Mortgage Loan (see Exhibit 35.1)

35.24      Rialto Capital Advisors, LLC, as Special Servicer of the Northwest HotelPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

35.25      Wells Fargo Bank, National Association, as PrimaryServicer of The Gateway Mortgage Loan (see Exhibit 35.1)

35.26      AEGON USA Realty Advisors, LLC, as Special Servicer of The Gateway MortgageLoan prior to June 1, 2021 (Omitted. See Explanatory Notes.)

35.27      Situs Holdings, LLC, as Special Servicer of TheGateway Mortgage Loan on and after June 1, 2021 (see Exhibit 35.13)

35.28      Wells Fargo Bank, National Association, as PrimaryServicer of the 181 Fremont Street Mortgage Loan (see Exhibit 35.1)

35.29      CWCapital Asset Management LLC, as Special Servicer of the 181 Fremont StreetMortgage Loan (Omitted. See Explanatory Notes.)

99.1         Mortgage Loan Purchase Agreement, dated as of May 15,2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. and WellsFargo Bank, National Association (filed as Exhibit 99.1 to the registrant’sCurrent Report on Form 8-K filed on May 30, 2018 under Commission File No.333-206847-09 and incorporated by reference herein)

99.2         Mortgage Loan Purchase Agreement, dated as of May 15,2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. and Bankof America, National Association (filed as Exhibit 99.2 to the registrant’sCurrent Report on Form 8-K filed on May 30, 2018 under Commission File No.333-206847-09 and incorporated by reference herein)

99.3         Mortgage Loan Purchase Agreement, dated as of May 15, 2018,between Banc of America Merrill Lynch Commercial Mortgage Inc. and MorganStanley Mortgage Capital Holdings LLC (filed as Exhibit 99.3 to theregistrant’s Current Report on Form 8-K filed on May 30, 2018 under CommissionFile No. 333-206847-09 and incorporated by reference herein)

99.4         Mortgage Loan Purchase Agreement, dated as of May 15,2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. andNational Cooperative Bank, N.A. (filed as Exhibit 99.4 to the registrant’sCurrent Report on Form 8-K filed on May 30, 2018 under Commission File No.333-206847-09 and incorporated by reference herein)

(b)   The exhibits required to be filed by theRegistrant pursuant to Item 601 of Regulation S-K are listed above.

(c)    Not Applicable.

 

**SIGNATURES**

Pursuant to the requirements of Section 13 or 15(d) of theSecurities Exchange Act of 1934, the registrant has duly caused this report tobe signed on its behalf by the undersigned, thereunto duly authorized.

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

Leland F.Bunch, III, President and Chief Executive Officer

(senior officer in charge ofsecuritization of the depositor)

Date: March 15, 2022