**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: 333-206677-26**

**Central Index Key Number of the issuing entity:0001744707**

**BANK 2018-BNK13**

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

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, 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: 0001541557**

**Morgan Stanley Mortgage CapitalHoldings LLC**

**(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: 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)** | **38-4083254**

**38-4083255**

**38-7206196**

**(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:**

**(704) 374-6161**

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 by referencein Part III of this Form 10-K or any amendment to this Form 10-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                                                                                                       Acceleratedfiler                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller 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 Griffin Portfolio II Mortgage Loan, thePfizer Building Mortgage Loan, the Showcase II Mortgage Loan, the Town CenterAventura Mortgage Loan and the Anderson Towne Center Mortgage Loan, whichconstituted approximately 9.0%, 6.9%, 5.3%, 4.2% and 2.6%, respectively, of theasset pool of the issuing entity as of its cut-off date, are each an asset ofthe issuing entity and are each part of a loan combination that includes (a)with respect to the Griffin Portfolio II Mortgage Loan, five other *paripassu* loans, which are not assets of the issuing entity, (b) with respectto the Pfizer Building Mortgage Loan, two other *pari passu* loans, whichare not assets of the issuing entity, (c) with respect to the Showcase IIMortgage Loan, two other *pari passu* loans, which are not assets of theissuing entity, (d) with respect to the Town Center Aventura Mortgage Loan, oneother *pari passu* loan, which is not an asset of the issuing entity and(e) with respect to the Anderson Towne Center Mortgage Loan, one other *paripassu* loan, which is not an asset of the issuing entity. These loancombinations, including the Griffin Portfolio II Mortgage Loan, the PfizerBuilding Mortgage Loan, the Showcase II Mortgage Loan, the Town Center AventuraMortgage Loan and the Anderson Towne Center Mortgage Loan, are being servicedand administered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 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 Fair Oaks Mall Mortgage Loan and theCoolSprings Galleria Mortgage Loan, which constituted approximately 3.6% and1.6%, respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Fair Oaks Mall Mortgage Loan and the CoolSprings GalleriaMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Fair Oaks Mall MortgageLoan, four other *pari passu* loans and two subordinate companion loans,which are not assets of the issuing entity or (b) with respect to theCoolSprings Galleria Mortgage Loan, four other *pari passu* loans, whichare not assets of the issuing entity. A *pari passu* portion of each loan combinationwas securitized in the BANK 2018-BNK12 transaction, Commission File Number333-206847-09 (the “BANK 2018-BNK12 Transaction”). These loancombinations, including the Fair Oaks Mall Mortgage Loan and the CoolSpringsGalleria Mortgage Loan, are being serviced and administered pursuant to thepooling and servicing agreement for the BANK 2018-BNK12 Transaction, which isincorporated by reference as Exhibit 4.2 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 1745 Broadway Mortgage Loan, whichconstituted approximately 9.96% of the asset pool of the issuing entity as ofits cut-off date.  The 1745 Broadway Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 1745Broadway Mortgage Loan and six other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Wells Fargo Commercial Mortgage Trust2018-1745 transaction (the “WFCM 2018-1745 Transaction”). This loancombination, including the 1745 Broadway Mortgage Loan, is being serviced andadministered pursuant to the trust and servicing agreement for the WFCM 2018-1745Transaction, which is incorporated by reference as Exhibit 4.3 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Shoppes at Chino Hills Mortgage Loan, whichconstituted approximately 2.3% of the asset pool of the issuing entity as ofits cut-off date.  The Shoppes at Chino Hills Mortgage Loan is an asset ofthe issuing entity and is part of a loan combination that includes the Shoppesat Chino Hills Mortgage Loan and three other *pari passu* loans, which arenot assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Morgan Stanley Capital I Trust 2018-H3transaction, Commission File Number 333-206582-15 (the “MSC 2018-H3Transaction”). This loan combination, including the Shoppes at Chino HillsMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2018-H3 Transaction, which is incorporated byreference as Exhibit 4.4 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 2.3% 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. A *pari passu* portion of the loancombination was securitized in the Benchmark 2018-B4 Mortgage Trusttransaction, Commission File Number 333-206705-14 (the “Benchmark 2018-B4Transaction”). This loan combination, including the 181 Fremont StreetMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2018-B4 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 Plaza Frontenac Mortgage Loan, whichconstituted approximately 4.2% of the asset pool of the issuing entity as ofits cut-off date.  The Plaza Frontenac Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the PlazaFrontenac Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. This loan combination, including the PlazaFrontenac Mortgage Loan, was serviced under the Pooling and Servicing Agreementfor the issuing entity prior to the closing of the securitization of the other *paripassu* portion of the Plaza Frontenac loan combination in the Morgan StanleyCapital I Trust 2018-L1 transaction, Commission File Number 333-206582-17 (the“MSC 2018-L1 Transaction”).  After the closing of the MSC 2018-L1Transaction on October 23, 2018, this loan combination, including the PlazaFrontenac Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the MSC 2018-L1Transaction, which is incorporated by reference as Exhibit 4.6 to this AnnualReport 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 themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer of the 1745 Broadway Mortgage Loan, the Fair Oaks MallMortgage Loan, the Shoppes at Chino Hills Mortgage Loan, the 181 Fremont StreetMortgage Loan and the CoolSprings Galleria Mortgage Loan. As a result, WellsFargo Bank, National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Wells Fargo Bank, National Association inthe capacities described above 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 1745Broadway Mortgage Loan, the Plaza Frontenac Mortgage Loan, the Fair Oaks MallMortgage Loan, the 181 Fremont Street Mortgage Loan, the Shoppes at Chino HillsMortgage Loan and the CoolSprings Galleria Mortgage Loan.  As a result,Wells Fargo Bank, National Association is a servicing function participant inthe capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of themortgage loans serviced under the Pooling and Servicing Agreement and the PlazaFrontenac Mortgage Loan.  As a result, Pentalpha Surveillance LLC is aservicing function participant in the capacities described above, because it isservicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPentalpha Surveillance LLC in the capacities described above are listed in theExhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe Fair Oaks Mall Mortgage Loan, the Shoppes at Chino Hills Mortgage Loan, the181 Fremont Street Mortgage Loan and the CoolSprings Galleria 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.

AEGON USA Realty Advisors, LLC isthe special servicer of the 1745 Broadway Mortgage Loan and the Fair Oaks MallMortgage Loan, which constituted approximately 9.96% and 3.6%, respectively, ofthe asset pool of the issuing entity as of its cut-off date. In accordance withthe Compliance and Disclosure Interpretations, Section 200.03 (Rules 13a-18 and15d-18, Servicer’s Assessment of Compliance), this percentage must be reducedpro rata because it was only acting as special servicer of the 1745 BroadwayMortgage Loan from January 1, 2021 to April 27, 2021 and the Fair Oaks MallMortgage Loan from January 1, 2021 to March 11, 2021. As a result, it fallsbelow the de minimis requirements in Item 1122 of Regulation AB and no suchassessment or attestation is required. In addition, AEGON USA Realty Advisors,LLC is an unaffiliated party that, as a result of such pro rata reduction ofsuch percentage, is not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliancestatement is required.

Argentic Services Company LP isthe special servicer of the 1745 Broadway Mortgage Loan and the CoolSpringsGalleria Mortgage Loan, which constituted approximately 9.96% and 1.6%, respectively,of the asset pool of the issuing entity as of its cut-off date. In accordancewith the Compliance and Disclosure Interpretations, Section 200.03 (Rules13a-18 and 15d-18, Servicer’s Assessment of Compliance), this percentage mustbe reduced pro rata because it was only acting as special servicer of the 1745Broadway Mortgage Loan on and after April 28, 2021. As a result, ArgenticServices Company LP is an unaffiliated party that, as a result of such pro ratareduction of such percentage, is not a “servicer” that meets the criteria inItem 1108(a)(2)(i) through (iii) of Regulation AB and so no servicer compliancestatement is required.

Wells Fargo Bank, NationalAssociation acts as trustee of the Plaza Frontenac Mortgage Loan. Pursuant to the pooling and servicing agreement for the MSC 2018-L1Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe Plaza Frontenac Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the CoolSprings Galleria Mortgage Loan, theFair Oaks Mall Mortgage Loan, the 1745 Broadway Mortgage Loan, the Shoppes atChino Hills Mortgage Loan and the 181 Fremont Street Mortgage Loan. Pursuant to the Pooling and Servicing Agreement, the pooling and servicingagreement for the BANK 2018-BNK12 Transaction, the trust and servicing agreementfor the WFCM 2018-1745 Transaction, the pooling and servicing agreement for theMSC 2018-H3 Transaction and the pooling and servicing agreement for theBenchmark 2018-B4 Transaction, the trustee is required to provide an assessmentof compliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicersof  the mortgage loans serviced under the Pooling and Servicing Agreement,the CoolSprings Galleria Mortgage Loan, the Fair Oaks Mall Mortgage Loan, the1745 Broadway Mortgage Loan, the Shoppes at Chino Hills Mortgage Loan and the181 Fremont Street Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation 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 CoolSprings Galleria Mortgage Loan,the Fair Oaks Mall Mortgage Loan, the 1745 Broadway Mortgage Loan, the Shoppesat Chino Hills Mortgage Loan and the 181 Fremont Street Mortgage Loan to remittax payments 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)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the CoolSprings Galleria Mortgage Loan, the Fair Oaks MallMortgage Loan, the 1745 Broadway Mortgage Loan, the Shoppes at Chino HillsMortgage Loan, the 181 Fremont Street Mortgage Loan and the Plaza FrontenacMortgage Loan are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

With respect to the *pari passu*loan combination that includes the 1745 Broadway Mortgage Loan, the Fair OaksMall Mortgage Loan, the Shoppes at Chino Hills Mortgage Loan, the 181 FremontStreet Mortgage Loan, the Plaza Frontenac Mortgage Loan, (i) the reports onassessment of compliance with servicing criteria and attestation reports onassessment of compliance with servicing criteria of Situs Holdings, LLC asspecial servicer of the Fair Oaks Mall Mortgage Loan on and after March 12,2021, LNR Partners, LLC as special servicer of the Shoppes at Chino HillsMortgage Loan, CWCapital Asset Management LLC as special servicer of the 181Fremont Street Mortgage Loan and Midland Loan Services, a Division of PNC Bank,National Association as primary servicer and special servicer of the PlazaFrontenac Mortgage Loan, listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as they are not required to be included on thisAnnual Report on Form 10-K per Instruction 3 to Item 1122 of Regulation ABbecause they are parties performing activities that address servicing criteriarelating to 5% or less of the assets of the issuing entity, and the report onassessment of compliance with servicing criteria and attestation report onassessment of compliance with servicing criteria of AEGON USA Realty Advisors,LLC as special servicer of the 1745 Broadway Mortgage Loan prior to April 28,2021 and the Fair Oaks Mall Mortgage Loan prior to March 12, 2021 listed on theExhibit Index are omitted from this Annual Report on Form 10-K for the reasonsset forth in the Explanatory Notes above; and (ii) the servicer compliancestatements of Midland Loan Services, a Division of PNC Bank, NationalAssociation as primary servicer and special servicer of the Plaza FrontenacMortgage Loan, Situs Holdings, LLC as special servicer of the Fair Oaks MallMortgage Loan on and after March 12, 2021, LNR Partners, LLC as specialservicer of the Shoppes at Chino Hills Mortgage Loan and CWCapital AssetManagement LLC as special servicer of the 181 Fremont Street Mortgage Loan,listed on the Exhibit Index are omitted from this Annual Report on Form 10-K asthey are not required by Item 1123 of Regulation AB to be included on thisAnnual Report on Form 10-K because they are each an unaffiliated party that isnot a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB, and the servicer compliance statements of Argentic ServicesCompany LP as special servicer of the 1745 Broadway Mortgage Loan on and afterApril 28, 2021 and the CoolSprings Galleria Mortgage Loan and AEGON USA RealtyAdvisors, LLC as special servicer of the 1745 Broadway Mortgage Loan prior toApril 28, 2021 and the Fair Oaks Mall Mortgage Loan prior to March 12, 2021listed on the Exhibit Index are omitted from this Annual Report on From 10-Kfor the 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,Related Stockholder 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 this transactionas described under Item 1115 of Regulation AB.

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

The registrant knows of nomaterial pending legal proceeding involving the trust or any party related tothe trust, other than routine litigation incidental to the duties of thoserespective parties, and the following, with respect to Wells Fargo Bank,National Association, as trustee, as certificate administrator and ascustodian, and CWCapital Asset Management LLC, as special servicer. 

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.

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 byCWCAM in connection with the sale of the Peter Cooper Village and StuyvesantTown property in New York, New York securing loans held by those trusts. CWCAM was the special servicer of such property.  The petition requeststhe State 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.  On February24, 2016, CWCAM made a limited appearance with the State Court to file a motionto dismiss this proceeding based on lack of jurisdiction, mootness, standingand 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 theOriginal  Complaint alleged breaches of a contract and fiduciary duties byCWCAM’s affiliate, CWCapital Investments LLC in its capacity as collateralmanager for the collateralized debt obligation transaction involving CWCapitalCobalt 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 abettingbreach of fiduciary duty, conversion and unjust enrichment. On May 23, 2018,the Original Complaint was dismissed for lack of subject matter jurisdiction.  On June 28, 2018, CWCapital Cobalt Vr Ltd. filed a substantially similarcomplaint in the Supreme Court of the State of New York, County of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., IndexNo. 653277/2018 (the “New Complaint”).  The gravamen of the NewComplaint is the same as the previous complaint filed in the United StateDistrict Court for the Southern District of New York.  In total there are16 counts pled in the New Complaint. Of those 16 counts, 5 claims were assertedagainst CWCAM for aiding and abetting breach of fiduciary duty, conversion andunjust enrichment, 1 count seeks a declaratory judgement that the plaintiff hasthe right to enforce the contracts in question and 1 count seeks an injunctionrequiring the defendants to recognize the plaintiff as the directing holder forthe trusts in question. On January 11, 2019, the plaintiff dismissed withprejudice the declaratory judgment and injunction counts.  The NewComplaint and related summons was not served on the defendants until July 13,2018 and July 16, 2018.  The plaintiff’s motion for a preliminaryinjunction was denied by the court on July 31, 2018.  On August 3, 2018,the defendants, including CWCAM, filed a motion to dismiss the New Complaint inits entirety. On August 20, 2019, the court entered an order grantingdefendants’ motion almost in its entirety, dismissing 11 of the 16 counts andpartially dismissing 2 additional counts.  Of the remaining counts, 2 areasserted against CWCAM for aiding and abetting breach of fiduciary duty andunjust enrichment.  On September 19, 2019, CWCapital Cobalt Vr Ltd. fileda notice of appeal relating to the August 20, 2019 dismissal order and onSeptember 26, 2019, filed an amended complaint against CWCI and CWCAM attemptingto address deficiencies relating to certain of the claims dismissed by theAugust, 20, 2019 order.  CWCI and CWCAM filed its Motion to Dismiss theamended complaint on October 28, 2019.  The court heard argument on theMotion to Dismiss the amended complaint on January 22, 2020 and on October 23,2020, the court granted the motion dismissing the amended claims.  OnNovember 30, 2020, CWCapital Cobalt Vr Ltd filed a notice of appeal relating tothe October 23, 2020 dismissal order.  On April 27, 2021, the FirstDepartment affirmed the dismissal as to claims against CWCAM that were part ofthe August 20, 2019 dismissal, but reversed the dismissal of two counts forbreach of the Collateral Management Agreement against CWCI.  CWCI hassought leave to file an appeal of the decision.  Both requests for leavewere denied by the First Department.  The plaintiff has also sought leaveto appeal the dismissal of the claims against CWCAM.  CWCAM believes thatit has performed its obligations under the related pooling and servicingagreements in good faith and the remaining allegations in the New Complaint arewithout merit.  

On January 24, 2016 PSW NYC LLCcommenced a complaint (the “PSW Complaint”) with the Supreme Court of the Stateof New York, County of New York (the “PSW Court”) against Bank of America, N.A.as trustee under the pooling and servicing agreements for Wachovia BankCommercial Mortgage Trust 2007-C30 and COBALT CMBS Commercial Trust 2007-C2,U.S. Bank National Association as trustee under the pooling and servicingagreements for Wachovia Bank Commercial Mortgage Trust 2007-C31, ML-CFCCommercial Mortgage Trust 2007-5 and ML-CFC Commercial Mortgage Trust 2007-6(collectively, the “PSW Trusts”), PCV-M Holdings LLC and CWCapital AssetManagement LLC, individually and as special servicer for the PSW Trusts(collectively, the “Defendants”) seeking either (a) damages in an amount to bedetermined by the PSW Court but alleged by the plaintiffs to be approximately$500,000,000 – such amount being the amount PSW NYC LLC alleges would have beenrecovered on certain mezzanine loans (the “PCVST Mezzanine Loans”) related tothe Peter Cooper Village and Stuyvesant Town property (the “PCVST Property”) inNew York City which PSW NYC LLC sold to an entity related to the Defendantspursuant to a settlement agreement related to certain prior litigation (the“2010 Settlement Agreement”) or (b) the rescission of the 2010 SettlementAgreement which would result in, among other things, the rescission of the saleof the PCVST Mezzanine Loans and a claim for certain proceeds from the sale ofthe PCVST Property. PSW NYC LLC alleges that the Defendants procured the 2010Settlement Agreement by fraud and further that the terms of the 2010 SettlementAgreement were breached by the Defendants. On February 26, 2016, CWCAM onbehalf of itself and the other Defendants filed a motion to dismiss the PSWComplaint (the “CWCAM Motion to Dismiss”). On April 11, 2016, PSW NYC LLCopposed the CWCAM Motion to Dismiss and cross-moved for a partial summaryjudgment on liability regarding allegations of breach of the 2010 SettlementAgreement (the “PSW Cross-Motion”). On May 5, 2016, the Defendants subsequentlyfiled its reply and opposition to the PSW Cross-Motion. On August 23, 2016,oral arguments were provided to the PSW Court regarding the PSW Complaint, theCWCAM Motion to Dismiss and the PSW Cross-Motion and the PSW Court took sucharguments under advisement. On October 31, 2016, the PSW Court issued an ordergranting the CWCAM Motion to Dismiss, denying the PSW Cross-Motion anddismissing the PSW Complaint with prejudice. Subsequently, PSW NYC LLC filed anotice of appeal relating to such order. On February 21, 2017, PSW NYC LLCfiled its appeal and supporting brief arguing that the PSW Court erred byfinding no breach of the assignment agreement and no fraudulent inducement.Oral argument was heard on May 4, 2017 at which point the court took thearguments 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 special servicerof the Loan and (d) other things.  On May 17, 2016, CWCAM filed a motionto dismiss the RAIT Complaint (“Motion to Dismiss”) stating that theRAIT 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, withprejudice.  On May 19, 2017 the Borrower repaid the Loan in accordancewith the terms of the notes and satisfied the condition to dismissal withprejudice.  RAIT has refused to dismiss the case and is claiming that theB Note should be paid in full.  CWCAM believes that it has performed itsobligations under the Operative Agreements in good faith, and that the actionshould be dismissed with prejudice.  On August 29, 2017, the RAIT Courtgranted leave to RAIT Preferred Funding to amend its complaint.  OnSeptember 20, 2017, RAIT Preferred Funding filed an Amended Complaint (the “RAITAmended Complaint”), which omits its original claims, adds Wells Fargo Bankas a defendant, and seeks (a) specific performance requiring repayment of the$18,500,000 principal amount of the B Note or, in the alternative, monetarydamages, including the $18,500,000 principal amount of the B Note, in an amountto be determined at trial, (b) monetary damages on any fees paid to CWCAM asspecial servicer or Wells Fargo Bank as master servicer in connection with theborrower’s repayment of the Loan, (c) a declaratory judgment that RAITPreferred Funding is entitled to recover the full $18,500,000 principal amountof the B Note, (d) punitive damages against CWCAM, and (e) other things. On October 11, 2017, CWCAM filed a motion to dismiss the RAIT Amended Complaint(“CWCAM Motion to Dismiss Amended Complaint”) stating that the RAITAmended Complaint did not state a claim and the essential facts of the RAITAmended Complaint are negated by the Operative Agreements and other admissibleevidentiary materials.  On November 13, 2017, Wells Fargo Bank filed amotion to dismiss the RAIT Amended Complaint (the “Wells Fargo Motion toDismiss Amended Complaint”) and joined the CWCAM Motion to Dismiss AmendedComplaint.  On January 29, 2018, the court dismissed all claims but forbreach of contract and discovery has commenced.  CWCAM filed a Motion forSummary Judgement on March 18, 2019.   This matter was settled andthe case dismissed on May 15, 2019.

**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 August 2, 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 Fair Oaks Mall Mortgage Loan andthe CoolSprings Galleria Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2018-BNK12 Transaction, are attached hereto under Item 15 to this Annual Reporton Form 10-K. Attached as Exhibit AA to the pooling and servicing agreement forthe BANK 2018-BNK12 Transaction incorporated by reference as Exhibit 4.2 tothis Annual Report on Form 10-K is a chart identifying the entitiesparticipating in a servicing function for the BANK 2018-BNK12 Transactionresponsible for each applicable 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 1745 Broadway Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the WFCM 2018-1745 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the WFCM 2018-1745 Transaction incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2018-1745 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 Shoppes at Chino Hills MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2018-H3 Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the MSC 2018-H3 Transaction incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSC2018-H3 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 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 4.5 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 reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Plaza Frontenac Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the MSC 2018-L1 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the MSC 2018-L1 Transaction incorporated by referenceas Exhibit 4.6 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the MSC 2018-L1 Transactionresponsible for each applicable servicing criteria 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 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.

**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 with respectto 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          Poolingand Servicing Agreement, dated as of August 1, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, Torchlight Loan Services, LLC, asGeneral Special Servicer, National Cooperative Bank, N.A. as NCB MasterServicer and NCB Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Pentalpha Surveillance LLC as Asset Representations Reviewer and OperatingAdvisor (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K filedon August 2, 2018 under Commission File No. 333-206677-26 and incorporated byreference herein).

4.2          Poolingand Servicing Agreement, dated as of May 1, 2018, by and among Banc of AmericaMerrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank,National Association, as General Master Servicer, Midland Loan Services, ADivision of PNC Bank, National Association, as General Special Servicer,National Cooperative Bank, N.A., as NCB Master Servicer and as NCB SpecialServicer, AEGON USA Realty Advisors, LLC, as Fair Oaks Mall Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and Asset Representations Reviewer (filed asExhibit 4.3 to the registrant’s Current Report on Form 8-K filed on August 2,2018 under Commission File No. 333-206677-26 and incorporated by referenceherein).

4.3          Trustand Servicing Agreement, dated as of July 2, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Servicer, AEGON USA Realty Advisors, LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee (filed as Exhibit 4.2 to theregistrant’s Current Report on Form 8-K filed on August 2, 2018 underCommission File No. 333-206677-26 and incorporated by reference herein).

4.4          Poolingand Servicing Agreement, dated as of July 1, 2018, by and among Morgan StanleyCapital I Inc., as Depositor, Wells Fargo Bank, National Association, as MasterServicer, LNR Partners, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and Asset Representations Reviewer  (filed as Exhibit 4.5 to theregistrant’s Current Report on Form 8-K filed on August 2, 2018 underCommission File No. 333-206677-26 and incorporated by reference herein).

4.5          Poolingand Servicing Agreement, dated as of July 1, 2018, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, Wells Fargo Bank,National Association, as Master Servicer, CWCapital Asset Management LLC, asSpecial Servicer, Wilmington Trust, National Association, as Trustee, WellsFargo Bank, National Association, as Certificate Administrator, Paying Agentand Custodian, and Park Bridge Lender Services LLC, as Operating Advisor andAsset Representations Reviewer (filed as Exhibit 4.4 to the registrant’sCurrent Report on Form 8-K filed on August 2, 2018 under Commission File No.333-206677-26 and incorporated by reference herein).

4.6          Poolingand Servicing Agreement, dated as of October 1, 2018, by and among MorganStanley Capital I Inc., as Depositor, Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer and Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator and Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on October 25, 2018 under Commission File No. 333-206677-26 andincorporated by reference herein).

4.7          Co-LenderAgreement, dated as of July 1, 2018, between Wells Fargo Bank, NationalAssociation, as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial NoteA-3 Holder, Initial Note A-4 Holder, Initial Note A-5 Holder, Initial Note A-6Holder, Initial Note A-7 Holder, and Initial Note A-8 Holder (filed as Exhibit4.6 to the registrant’s Current Report on Form 8-K filed on August 2, 2018under Commission File No. 333-206677-26 and incorporated by reference herein).

4.8          AgreementBetween Note Holders, dated as of April 27, 2018, by and between Bank ofAmerica, N.A. and KeyBank National Association (filed as Exhibit 4.7 to theregistrant’s Current Report on Form 8-K filed on August 2, 2018 underCommission File No. 333-206677-26 and incorporated by reference herein).

4.9          AgreementBetween Note Holders, dated as of July 27, 2018, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial NoteA-3 Holder, Initial Note A-4 Holder, and Initial Note A-5 Holder, (filed asExhibit 4.8 to the registrant’s Current Report on Form 8-K filed on August 2,2018 under Commission File No. 333-206677-26 and incorporated by referenceherein).

4.10        AgreementBetween Note Holders, dated as of August 2, 2018, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, Initial Note A-2Holder, and Initial Note A-3 Holder (filed as Exhibit 4.9 to the registrant’sCurrent Report on Form 8-K filed on August 2, 2018 under Commission File No.333-206677-26 and incorporated by reference herein).

4.11        AgreementBetween Note Holders, dated as of July 27, 2018, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Initial Note A-2 Holder (filed asExhibit 4.10 to the registrant’s Current Report on Form 8-K filed on August 2,2018 under Commission File No. 333-206677-26 and incorporated by referenceherein).

4.12        AgreementBetween Note Holders, dated as of August 2, 2018, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder and Initial Note A-2Holder (filed as Exhibit 4.11 to the registrant’s Current Report on Form 8-Kfiled on August 2, 2018 under Commission File No. 333-206677-26 andincorporated by reference herein).

4.13        AgreementBetween Noteholders, dated as of April 27, 2018, by and between Bank ofAmerica, N.A., as Initial Note A-1-1 Holder, Initial Note A-1-2 Holder andInitial Note B-1 Holder and Barclays Bank PLC, as Initial Note A-2-1 Holder,Initial Note A-2-2 Holder, Initial Note A-2-3 Holder and Initial Note B-2Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form 8-Kfiled on August 2, 2018 under Commission File No. 333-206677-26 andincorporated by reference herein).

4.14        AgreementBetween Note Holders, dated as of July 27, 2018, by and between Morgan Stanley Bank,N.A, as Initial Note A-1 and Initial Note A-2 Holder (filed as Exhibit 4.13 tothe registrant’s Current Report on Form 8-K filed on August 2, 2018 underCommission File No. 333-206677-26 and incorporated by reference herein).

4.15        Co-LenderAgreement, dated as of May 7, 2018, between Deutsche Bank AG, New York Branch,as Note A-1 Holder, Note A-4 Holder, and Note A-5 Holder, Wells Fargo Bank,National Association, as Note A-2 Holder and Note A-3 Holder, Barclays BankPLC, as Note A-6-1 Holder and Note A-6-2 Holder (filed as Exhibit 4.14 to theregistrant’s Current Report on Form 8-K filed on August 2, 2018 underCommission File No. 333-206677-26 and incorporated by reference herein).

4.16        AgreementBetween Note Holders, dated as of July 12, 2018, by and between Morgan StanleyBank, N.A, as Initial Note A-1, Initial Note A-2 Holder, and Initial Note A-3Holder (filed as Exhibit 4.15 to the registrant’s Current Report on Form 8-Kfiled on August 2, 2018 under Commission File No. 333-206677-26 andincorporated by reference herein).

4.17        Amendedand Restated Agreement Between Note Holders, dated as of July 17, 2018, by andbetween Wilmington Trust, National Association, as Trustee for the benefit ofthe registered holders of BANK 2018-BNK12, Commercial Mortgage Pass- ThroughSecurities, Series 2018-BNK12, as Note A-1 Holder and Note A-2 Holder, andWells Fargo Bank, National Association as Initial Note A-3, Initial Note A-4-1Holder, and Initial Note A-4-2 (filed as Exhibit 4.16 to the registrant’sCurrent Report on Form 8-K filed on August 2, 2018 under Commission File No.333-206677-26 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        Torchlight Loan Services, LLC, 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        Pentalpha Surveillance 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 and afterNovember 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 Griffin Portfolio II Mortgage Loan (see Exhibit 33.1)

33.13      Torchlight Loan Services, LLC, as Special Servicerof the Griffin Portfolio II Mortgage Loan (see Exhibit 33.3)

33.14      Wilmington Trust, National Association, as Trustee of the Griffin Portfolio IIMortgage Loan (Omitted. See Explanatory Notes.)

33.15      Wells Fargo Bank, National Association, asCustodian of the Griffin Portfolio II Mortgage Loan (see Exhibit 33.7)

33.16      Pentalpha Surveillance LLC, as Operating Advisor ofthe Griffin Portfolio II Mortgage Loan (see Exhibit 33.8)

33.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Griffin Portfolio II 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 PrimaryServicer of the Pfizer Building Mortgage Loan (see Exhibit 33.1)

33.20      Torchlight Loan Services, LLC, as Special Servicerof the Pfizer Building Mortgage Loan (see Exhibit 33.3)

33.21      Wilmington Trust, National Association, as Trustee of the Pfizer BuildingMortgage Loan (Omitted. See Explanatory Notes.)

33.22      Wells Fargo Bank, National Association, asCustodian of the Pfizer Building Mortgage Loan (see Exhibit 33.7)

33.23      Pentalpha Surveillance LLC, as Operating Advisor ofthe Pfizer Building Mortgage Loan (see Exhibit 33.8)

33.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Pfizer Building 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 Showcase II Mortgage Loan (see Exhibit 33.1)

33.27      Torchlight Loan Services, LLC, as Special Servicerof the Showcase II Mortgage Loan (see Exhibit 33.3)

33.28      Wilmington Trust, National Association, as Trustee of the Showcase II MortgageLoan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, asCustodian of the Showcase II Mortgage Loan (see Exhibit 33.7)

33.30      Pentalpha Surveillance LLC, as Operating Advisor ofthe Showcase II Mortgage Loan (see Exhibit 33.8)

33.31      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Showcase II Mortgage Loan (see Exhibit 33.9)

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

33.33      Wells Fargo Bank, National Association, as PrimaryServicer of the Town Center Aventura Mortgage Loan (see Exhibit 33.1)

33.34      Torchlight Loan Services, LLC, as Special Servicerof the Town Center Aventura Mortgage Loan (see Exhibit 33.3)

33.35      Wilmington Trust, National Association, as Trustee of the Town Center AventuraMortgage Loan (Omitted. See Explanatory Notes.)

33.36      Wells Fargo Bank, National Association, asCustodian of the Town Center Aventura Mortgage Loan (see Exhibit 33.7)

33.37      Pentalpha Surveillance LLC, as Operating Advisor ofthe Town Center Aventura Mortgage Loan (see Exhibit 33.8)

33.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Town Center Aventura Mortgage Loan (see Exhibit 33.9)

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

33.40      Wells Fargo Bank, National Association, as PrimaryServicer of the Anderson Towne Center Mortgage Loan (see Exhibit 33.1)

33.41      Torchlight Loan Services, LLC, as Special Servicerof the Anderson Towne Center Mortgage Loan (see Exhibit 33.3)

33.42      Wilmington Trust, National Association, as Trustee of the Anderson Towne CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.43      Wells Fargo Bank, National Association, asCustodian of the Anderson Towne Center Mortgage Loan (see Exhibit 33.7)

33.44      Pentalpha Surveillance LLC, as Operating Advisor ofthe Anderson Towne Center Mortgage Loan (see Exhibit 33.8)

33.45      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Anderson Towne Center Mortgage Loan (see Exhibit 33.9)

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

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

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

33.49      Situs Holdings, LLC, as Special Servicer of the Fair Oaks Mall Mortgage Loan onand after March 12, 2021 (Omitted. See Explanatory Notes.)

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

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

33.52      Park Bridge Lender Services LLC, as OperatingAdvisor of the Fair Oaks Mall Mortgage Loan

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

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

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

33.56      Argentic Services Company LP, as Special Servicerof the CoolSprings Galleria Mortgage Loan

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

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

33.59      Park Bridge Lender Services LLC, as OperatingAdvisor of the CoolSprings Galleria Mortgage Loan (see Exhibit 33.52)

33.60      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the CoolSprings Galleria 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 1745 Broadway Mortgage Loan (see Exhibit 33.1)

33.63      AEGON USA Realty Advisors, LLC, as Special Servicer of the 1745 BroadwayMortgage Loan prior to April 28, 2021 (Omitted. See Explanatory Notes.)

33.64      Argentic Services Company LP, as Special Servicerof the 1745 Broadway Mortgage Loan on and after April 28, 2021 (see Exhibit33.56)

33.65      Wilmington Trust, National Association, as Trustee of the 1745 BroadwayMortgage Loan (Omitted. See Explanatory Notes.)

33.66      Wells Fargo Bank, National Association, asCustodian of the 1745 Broadway Mortgage Loan (see Exhibit 33.7)

33.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 1745 Broadway 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 Shoppes at Chino Hills Mortgage Loan (see Exhibit 33.1)

33.70      LNR Partners, LLC, as Special Servicer of the Shoppes at Chino Hills MortgageLoan (Omitted. See Explanatory Notes.)

33.71      Wilmington Trust, National Association, as Trustee of the Shoppes at ChinoHills Mortgage Loan (Omitted. See Explanatory Notes.)

33.72      Wells Fargo Bank, National Association, as Custodianof the Shoppes at Chino Hills Mortgage Loan (see Exhibit 33.7)

33.73      Park Bridge Lender Services LLC, as OperatingAdvisor of the Shoppes at Chino Hills Mortgage Loan (see Exhibit 33.52)

33.74      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Shoppes at Chino Hills Mortgage Loan (see Exhibit 33.9)

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

33.76      Wells Fargo Bank, National Association, as Primary Servicerof the 181 Fremont Street Mortgage Loan (see Exhibit 33.1)

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

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

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

33.80      Park Bridge Lender Services LLC, as OperatingAdvisor of the 181 Fremont Street Mortgage Loan (see Exhibit 33.52)

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

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

33.83      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory Notes.)

33.84      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory Notes.)

33.85      Wells Fargo Bank, National Association, as Trustee of the Plaza FrontenacMortgage Loan (Omitted. See Explanatory Notes.)

33.86      Wells Fargo Bank, National Association, asCustodian of the Plaza Frontenac Mortgage Loan (see Exhibit 33.7)

33.87      Pentalpha Surveillance LLC, as Operating Advisor ofthe Plaza Frontenac Mortgage Loan (see Exhibit 33.8)

33.88      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        Torchlight Loan Services, LLC, 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        Pentalpha Surveillance LLC, as Operating Advisor

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 Griffin Portfolio II Mortgage Loan (see Exhibit 34.1)

34.13      Torchlight Loan Services, LLC, as Special Servicerof the Griffin Portfolio II Mortgage Loan (see Exhibit 34.3)

34.14      Wilmington Trust, National Association, as Trustee of the Griffin Portfolio IIMortgage Loan (Omitted. See Explanatory Notes.)

34.15      Wells Fargo Bank, National Association, asCustodian of the Griffin Portfolio II Mortgage Loan (see Exhibit 34.7)

34.16      Pentalpha Surveillance LLC, as Operating Advisor ofthe Griffin Portfolio II Mortgage Loan (see Exhibit 34.8)

34.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Griffin Portfolio II 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 Pfizer Building Mortgage Loan (see Exhibit 34.1)

34.20      Torchlight Loan Services, LLC, as Special Servicerof the Pfizer Building Mortgage Loan (see Exhibit 34.3)

34.21      Wilmington Trust, National Association, as Trustee of the Pfizer BuildingMortgage Loan (Omitted. See Explanatory Notes.)

34.22      Wells Fargo Bank, National Association, asCustodian of the Pfizer Building Mortgage Loan (see Exhibit 34.7)

34.23      Pentalpha Surveillance LLC, as Operating Advisor ofthe Pfizer Building Mortgage Loan (see Exhibit 34.8)

34.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Pfizer Building 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 Showcase II Mortgage Loan (see Exhibit 34.1)

34.27      Torchlight Loan Services, LLC, as Special Servicerof the Showcase II Mortgage Loan (see Exhibit 34.3)

34.28      Wilmington Trust, National Association, as Trustee of the Showcase II MortgageLoan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, asCustodian of the Showcase II Mortgage Loan (see Exhibit 34.7)

34.30      Pentalpha Surveillance LLC, as Operating Advisor ofthe Showcase II Mortgage Loan (see Exhibit 34.8)

34.31      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Showcase II Mortgage Loan (see Exhibit 34.9)

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

34.33      Wells Fargo Bank, National Association, as PrimaryServicer of the Town Center Aventura Mortgage Loan (see Exhibit 34.1)

34.34      Torchlight Loan Services, LLC, as Special Servicerof the Town Center Aventura Mortgage Loan (see Exhibit 34.3)

34.35      Wilmington Trust, National Association, as Trustee of the Town Center AventuraMortgage Loan (Omitted. See Explanatory Notes.)

34.36      Wells Fargo Bank, National Association, as Custodianof the Town Center Aventura Mortgage Loan (see Exhibit 34.7)

34.37      Pentalpha Surveillance LLC, as Operating Advisor ofthe Town Center Aventura Mortgage Loan (see Exhibit 34.8)

34.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Town Center Aventura Mortgage Loan (see Exhibit 34.9)

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

34.40      Wells Fargo Bank, National Association, as PrimaryServicer of the Anderson Towne Center Mortgage Loan (see Exhibit 34.1)

34.41      Torchlight Loan Services, LLC, as Special Servicerof the Anderson Towne Center Mortgage Loan (see Exhibit 34.3)

34.42      Wilmington Trust, National Association, as Trustee of the Anderson Towne CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.43      Wells Fargo Bank, National Association, asCustodian of the Anderson Towne Center Mortgage Loan (see Exhibit 34.7)

34.44      Pentalpha Surveillance LLC, as Operating Advisor ofthe Anderson Towne Center Mortgage Loan (see Exhibit 34.8)

34.45      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Anderson Towne Center Mortgage Loan (see Exhibit 34.9)

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

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

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

34.49      Situs Holdings, LLC, as Special Servicer of the Fair Oaks Mall Mortgage Loan onand after March 12, 2021 (Omitted. See Explanatory Notes.)

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

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

34.52      Park Bridge Lender Services LLC, as OperatingAdvisor of the Fair Oaks Mall Mortgage Loan

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

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

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

34.56      Argentic Services Company LP, as Special Servicerof the CoolSprings Galleria Mortgage Loan

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

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

34.59      Park Bridge Lender Services LLC, as OperatingAdvisor of the CoolSprings Galleria Mortgage Loan (see Exhibit 34.52)

34.60      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the CoolSprings Galleria 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 1745 Broadway Mortgage Loan (see Exhibit 34.1)

34.63      AEGON USA Realty Advisors, LLC, as Special Servicer of the 1745 BroadwayMortgage Loan prior to April 28, 2021 (Omitted. See Explanatory Notes.)

34.64      Argentic Services Company LP, as Special Servicerof the 1745 Broadway Mortgage Loan on and after April 28, 2021 (see Exhibit34.56)

34.65      Wilmington Trust, National Association, as Trustee of the 1745 BroadwayMortgage Loan (Omitted. See Explanatory Notes.)

34.66      Wells Fargo Bank, National Association, asCustodian of the 1745 Broadway Mortgage Loan (see Exhibit 34.7)

34.67      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 1745 Broadway 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 Shoppes at Chino Hills Mortgage Loan (see Exhibit 34.1)

34.70      LNR Partners, LLC, as Special Servicer of the Shoppes at Chino Hills MortgageLoan (Omitted. See Explanatory Notes.)

34.71      Wilmington Trust, National Association, as Trustee of the Shoppes at ChinoHills Mortgage Loan (Omitted. See Explanatory Notes.)

34.72      Wells Fargo Bank, National Association, asCustodian of the Shoppes at Chino Hills Mortgage Loan (see Exhibit 34.7)

34.73      Park Bridge Lender Services LLC, as OperatingAdvisor of the Shoppes at Chino Hills Mortgage Loan (see Exhibit 34.52)

34.74      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Shoppes at Chino Hills Mortgage Loan (see Exhibit 34.9)

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

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

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

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

34.79      Wells Fargo Bank, National Association, asCustodian of the 181 Fremont Street Mortgage Loan (see Exhibit 34.7)

34.80      Park Bridge Lender Services LLC, as OperatingAdvisor of the 181 Fremont Street Mortgage Loan (see Exhibit 34.52)

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

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

34.83      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory Notes.)

34.84      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory Notes.)

34.85      Wells Fargo Bank, National Association, as Trustee of the Plaza FrontenacMortgage Loan (Omitted. See Explanatory Notes.)

34.86      Wells Fargo Bank, National Association, asCustodian of the Plaza Frontenac Mortgage Loan (see Exhibit 34.7)

34.87      Pentalpha Surveillance LLC, as Operating Advisor ofthe Plaza Frontenac Mortgage Loan (see Exhibit 34.8)

34.88      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        Torchlight Loan Services, LLC, 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 Griffin Portfolio II Mortgage Loan (see Exhibit 35.1)

35.8        Torchlight Loan Services, LLC, as Special Servicerof the Griffin Portfolio II Mortgage Loan (see Exhibit 35.3)

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the Pfizer Building Mortgage Loan (see Exhibit 35.1)

35.10      Torchlight Loan Services, LLC, as Special Servicerof the Pfizer Building Mortgage Loan (see Exhibit 35.3)

35.11      Wells Fargo Bank, National Association, as PrimaryServicer of the Showcase II Mortgage Loan (see Exhibit 35.1)

35.12      Torchlight Loan Services, LLC, as Special Servicerof the Showcase II Mortgage Loan (see Exhibit 35.3)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the Town Center Aventura Mortgage Loan (see Exhibit 35.1)

35.14      Torchlight Loan Services, LLC, as Special Servicerof the Town Center Aventura Mortgage Loan (see Exhibit 35.3)

35.15      Wells Fargo Bank, National Association, as PrimaryServicer of the Anderson Towne Center Mortgage Loan (see Exhibit 35.1)

35.16      Torchlight Loan Services, LLC, as Special Servicerof the Anderson Towne Center Mortgage Loan (see Exhibit 35.3)

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

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

35.19      Situs Holdings, LLC, as Special Servicer of the Fair Oaks Mall Mortgage Loan onand after March 12, 2021 (Omitted. See Explanatory Notes.)

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

35.21      Argentic Services Company LP, as Special Servicer of the CoolSprings GalleriaMortgage Loan (Omitted. See Explanatory Notes.)

35.22      Wells Fargo Bank, National Association, as PrimaryServicer of the 1745 Broadway Mortgage Loan (see Exhibit 35.1)

35.23      AEGON USA Realty Advisors, LLC, as Special Servicer of the 1745 Broadway MortgageLoan prior to April 28, 2021 (Omitted. See Explanatory Notes.)

35.24      Argentic Services Company LP, as Special Servicer of the 1745 Broadway MortgageLoan on and after April 28, 2021 (Omitted. See Explanatory Notes.)

35.25      Wells Fargo Bank, National Association, as PrimaryServicer of the Shoppes at Chino Hills Mortgage Loan (see Exhibit 35.1)

35.26      LNR Partners, LLC, as Special Servicer of the Shoppes at Chino Hills MortgageLoan (Omitted. See Explanatory Notes.)

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

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

35.29      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory Notes.)

35.30      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Plaza Frontenac Mortgage Loan (Omitted. See Explanatory Notes.)

99.1        MortgageLoan Purchase Agreement, dated as of July 23, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onAugust 2, 2018 under Commission File No. 333-206677-26 and incorporated byreference herein)

99.2        MortgageLoan Purchase Agreement, dated as of July 23, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.2 to the registrant’s Current Report on Form8-K filed on August 2, 2018 under Commission File No. 333-206677-26 andincorporated by reference herein)

99.3        MortgageLoan Purchase Agreement, dated as of July 23, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Bank of America, National Association(filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K filed onAugust 2, 2018 under Commission File No. 333-206677-26 and incorporated byreference herein)

99.4        MortgageLoan Purchase Agreement, dated as of July 23, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and National Cooperative Bank, N.A. (filedas Exhibit 99.4 to the registrant’s Current Report on Form 8-K filed on August2, 2018 under Commission File No. 333-206677-26 and incorporated by referenceherein)

(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.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 14, 2022