**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**WASHINGTON,D.C. 20549**

**FORM 10‐K**

(Mark one)

**/X/ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**    For the fiscal year endedDecember 31, 2021 OR**

**//TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**For the transition period from****            ****to****            **

 

 

 

**Commission file number:333-206582-17**

 

**Central Index Key Number of the issuing entity:0001751743**

 

**Morgan Stanley Capital ITrust 2018-L1**

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

 

**Central Index Key Number of the depositor:0001547361**

 

**Morgan Stanley Capital I Inc.**

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

 

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

 

**Morgan Stanley MortgageCapital Holdings LLC**

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

 

**Central Index Key Number of the sponsor:0001089877**

 

**KeyBank National Association**

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

 

**Central Index Key Number of the sponsor:0001548405**

 

**Starwood Mortgage Capital LLC**

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

 

**Central Index Key Number of the sponsor:0001558761**

 

**Cantor Commercial Real EstateLending, L.P.**

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

 

| **New York**                                                        | **38-4088383  38-4088384  38-7206240**       |
|---------------------------------------------------------------------|----------------------------------------------|
| **(State or other jurisdiction of incorporation or  organization)** | **(I.R.S. Employer Identification Numbers)** |

 

**c/o Wells Fargo Bank, N.A.**

**9062 Old Annapolis Road**

** Columbia, MD**

**(Address of principal executive offices)**

 

**21045**

**(Zip Code)**

 

**Telephone number, including area code:**

**(410) 884‐2000**

Securitiesregistered pursuant to Section 12(b) of the Act:

 

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

 

Securitiesregistered pursuant to Section 12(g) of the Act:

 

  NONE.

 

Indicateby check mark if the registrant is a well-known seasoned issuer, as defined in Rule405 of the Securities Act.

 

  Yes___ No X

 

Indicateby check mark if the registrant is not required to file reports pursuant toSection 13 or Section 15(d) of the Act.

 

  Yes___ No X

 

Note- Checking the box above will not relieve any registrant required to filereports pursuant to Section 13 or 15(d) of the Exchange Act from theirobligations under those Sections.

 

Indicate by check mark whether the registrant (1) has filed all reportsrequired to be filed by Section 13 or 15(d) of the Securities Exchange Act of1934 during the preceding 12 months (or for such shorter period that theregistrant was required to file such reports), and (2) has been subject to suchfiling requirements for the past 90 days.

 

  YesX No ___

 

Indicateby check mark whether the registrant has submitted electronically everyInteractive Data File required to be submitted 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 suchfiles).

 

  Notapplicable.

  

Indicateby check mark whether the registrant is a large accelerated filer, anaccelerated filer, a non-accelerated filer, a smaller reporting company, or emerginggrowth company. See the definitions of "large accelerated filer","accelerated filer," "smaller reporting company," and“emerging growth company” in Rule 12b-2 of the Exchange Act.

 

 Largeaccelerated filer ___ Accelerated filer ___ Non-accelerated filer X (Do not check if a smaller reporting company)Smaller reporting company ___

 

Emerginggrowth company ___

 

Ifan emerging growth company, indicate by check mark if the registrant haselected not to use the extended transition period for complying with any new orrevised financial accounting standards provided pursuant to Section 13(a) ofthe Ex­change Act.

 

  Notapplicable.

 

Indicateby check mark whether the registrant has filed a report on and attestation toits management’s assessment of the effectiveness of its internal control overfinancial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C.7262(b)) by the registered public accounting firm that prepared or issued itsaudit report.

 

  Notapplicable.

 

Indicateby check mark whether the registrant is a shell company (as defined in Rule12b-2 of the Act).

 

  Yes___ No X

 

Statethe aggregate market value of the voting and non-voting common equity held bynon-affiliates computed by reference to the price at which the common equitywas last sold, or the average bid and asked price of such common equity, as ofthe last business day of the registrant's most recently completed second fiscalquarter.

 

  Notapplicable.

 

Indicateby check mark whether the registrant has filed all documents and reportsrequired to be filed by Section 12, 13 or 15(d) of the Securities Exchange Actof 1934 subsequent to the distribution of securities under a plan confirmed bya court.

 

  Notapplicable.

 

Indicatethe number of shares outstanding of each of the registrant's classes of commonstock, as of the latest practicable date.

 

  Notapplicable.

 

DOCUMENTSINCORPORATED BY REFERENCE

 

Listhereunder the following documents if incorporated by reference and the Part ofthe Form 10-K (e.g., Part I, Part II, etc.) into which the document isincorporated: (1)Any annual report to security holders; (2) Any proxy orinformation statement; and (3)Any prospectus filed pursuant to Rule 424(b) or(c) under the Securities Act of 1933. The listed documents should be clearlydescribed for identification purposes (e.g., annual report to security holdersfor fiscal year ended December 24, 1980).

 

  Notapplicable.

 

**EXPLANATORY NOTES**

 

The MSC 2018-L1 mortgage pool includes thefollowing mortgage loans, each of which is serviced pursuant to a separatepooling and servicing agreement (each, an “Outside Pooling and ServicingAgreement”):

 

•   the Aventura Mall mortgageloan, which is serviced pursuant to the AMT 2018-AVM trust and servicing agreementattached hereto as Exhibit 4.2;

 

•   the Griffin Portfolio IImortgage loan, which is serviced pursuant to the BANK 2018-BNK13 pooling andservicing agreement attached hereto as Exhibit 4.3;

 

•   the Millennium PartnersPortfolio mortgage loan, which is serviced pursuant to the MSC 2018-MP trustand servicing agreement attached hereto as Exhibit 4.4;

 

•   The Gateway mortgage loan,which is serviced pursuant to the COMM 2018-HOME trust and servicing agreementattached hereto as Exhibit 4.5;

 

•   the Zenith Ridge mortgageloan, which is serviced pursuant to the CD 2018-CD7 pooling and servicingagreement attached hereto as Exhibit 4.6;

 

•   the Playa Largo mortgage loanand the Shoppes at Chino Hills mortgage loan, which are serviced pursuant tothe MSC 2018-H3 pooling and servicing agreement attached hereto as Exhibit 4.7;

 

•   the Shelbourne Global Portfolio I mortgage loan,which is serviced pursuant to the UBS 2018-C13 pooling and servicing agreementattached hereto as Exhibit 4.8; and

•   the Regions Tower mortgageloan, which is serviced pursuant to the BANK 2019-BNK16 pooling and servicingagreement attached hereto as Exhibit 4.9.

 

Except as set forth below, each of theparties to each pooling and servicing agreement listed in the Exhibit Indexboth (1) participates in the servicing function for purposes of Item 1122 ofRegulation AB and (2) constitutes a servicer that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB for purposes of Item 1123 ofRegulation AB:

 

•   The trustee under a poolingand servicing agreement has a nominal role with respect to the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Thetrustee’s only servicing function is the contingent obligation to make certainadvances if the master servicer under such pooling and servicing agreementfails to do so, while all other servicing functions are performed by otherparties.  The trustee under each of the pooling and servicing agreementslisted in the Exhibit Index has confirmed to the registrant that it has notmade any such contingent advances during the reporting period, andconsequently, each such trustee does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The certificate administratorunder a pooling and servicing agreement performs various payment administrationfunctions solely for the securitization governed by such pooling and servicingagreement and the mortgage pool securitized pursuant to such pooling andservicing agreement and does not have any obligations with respect to any othertransaction.  Consequently, the certificate administrator under an OutsidePooling and Servicing Agreement does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The operating advisor under apooling and servicing agreement represents the interests of seniorcertificateholders in the transaction governed by such pooling and servicingagreement and is responsible for monitoring the performance of the specialservicer under such pooling and servicing agreement and producing certainreports to certificateholders relating to the resolution of the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Theoperating advisor under a pooling and servicing agreement does not have anyobligations with respect to any other transaction and is solely obligated toperform loan reporting functions with respect to the securitization governed bysuch pooling and servicing agreement.  Consequently, the operating advisorunder an Outside Pooling and Servicing Agreement neither participates in theservicing function for purposes of Item 1122 of Regulation AB nor performs thefunctions of a servicer for purposes of the definition of “servicer” under Item1101 of Regulation AB or for purposes of Item 1123 of Regulation AB.  Inaddition, while the operating advisor under a pooling and servicing agreementhas certain reporting obligations in respect of the related mortgage pool, ithas no obligation to collect or disburse funds in respect of the mortgage poolor to administer any of the underlying mortgage loans.  Consequently, theoperating advisor under a pooling and servicing agreement participates in theservicing function for purposes of Item 1122 of Regulation AB, but is notresponsible for the “management or collection of the pool assets or makingallocations or distributions to holders of the asset-backed securities” withinthe meaning of “servicer” under Item 1101 of Regulation AB and does not performthe functions of a servicer for purposes of Item 1123 of Regulation AB. 

 

•   The asset representations reviewer under a poolingand servicing agreement has a limited obligation to review certain delinquentmortgage loans after a specified delinquency threshold has been met and therequired percentage of certificateholders vote to direct a review of suchdelinquent mortgage loans, and has no obligation to collect or disburse fundsin respect of the mortgage pool, to administer any of the underlying mortgageloans or to perform any servicing function.  Consequently, the assetrepresentations reviewer under a pooling and servicing agreement does notparticipate in the servicing function for purposes of Item 1122 of RegulationAB, is not responsible for the “management or collection of the pool assets ormaking allocations or distributions to holders of the asset-backed securities”within the meaning of “servicer” under Item 1101 of Regulation AB and does notperform the functions of a servicer for purposes of Item 1123 of Regulation AB.

•   NCB, N.A. as NCB masterservicer and NCB special servicer under the BANK 2018-BNK13 pooling andservicing agreement, only has obligations in respect of certain mortgage loanssold to the BANK 2018-BNK13 securitization trust by NCB, N.A. or its affiliateand has no obligations with respect to the Griffin Portfolio II mortgage loanand therefore in such capacity does not constitute a reporting “servicingfunction participant” for purposes of Item 1122 of Regulation AB, as specifiedin the Instruction 3 to Item 1122, and does not constitute a reporting“servicer” for purposes of Item 1123 of Regulation AB, as specified in theInstruction to Item 1123.

 

•   NCB, N.A. as NCB masterservicer and NCB special servicer under the BANK 2019-BNK16 pooling andservicing agreement, only has obligations in respect of certain mortgage loanssold to the BANK 2019-BNK16 securitization trust by NCB, N.A. or its affiliateand has no obligations with respect to the Regions Tower mortgage loan andtherefore in such capacity does not constitute a reporting “servicing functionparticipant” for purposes of Item 1122 of Regulation AB, as specified in theInstruction 3 to Item 1122, and does not constitute a reporting “servicer” forpurposes of Item 1123 of Regulation AB, as specified in the Instruction to Item1123.

 

•   CWCapital Asset ManagementLLC is the special servicer under the AMT 2018-AVM trust and servicingagreement, pursuant to which the Aventura Mall mortgage loan is serviced. Because CWCapital Asset Management LLC is not the MSC 2018-L1 special servicer,is not affiliated with any sponsor and services only the Aventura Mall mortgageloan, which constitutes more than 5% but less than 10% of the mortgage pool,CWCapital Asset Management LLC, as AMT 2018-AVM special servicer, constitutes areporting “servicing function participant” for purposes of Item 1122 ofRegulation AB, as specified in the Instruction 3 to Item 1122, but does notconstitute a reporting “servicer” for purposes of Item 1123 of Regulation AB,as specified in the Instruction to Item 1123.

 

•   Torchlight Loan Services, LLCis the special servicer under the BANK 2018-BNK13 pooling and servicingagreement, pursuant to which the Griffin Portfolio II mortgage loan isserviced. Because Torchlight Loan Services, LLC is not the MSC 2018-L1 specialservicer, is not affiliated with any sponsor and services only the GriffinPortfolio II mortgage loan, which constitutes more than 5% but less than 10% ofthe mortgage pool, Torchlight Loan Services, LLC, as BANK 2018-BNK13 specialservicer, constitutes a reporting “servicing function participant” for purposesof Item 1122 of Regulation AB, as specified in the Instruction 3 to Item 1122,but does not constitute a reporting “servicer” for purposes of Item 1123 ofRegulation AB, as specified in the Instruction to Item 1123.

 

•   Wells Fargo Bank, NationalAssociation is the special servicer under the MSC 2018-MP trust and servicingagreement, pursuant to which the Millennium Partners Portfolio mortgage loan isserviced. Because Wells Fargo Bank, National Association is not the MSC 2018-L1special servicer, is not affiliated with any sponsor and services only theMillennium Partners Portfolio mortgage loan, which constitutes more than 5% butless than 10% of the mortgage pool, Wells Fargo Bank, National Association, asMSC 2018-MP special servicer, constitutes a reporting “servicing function participant”for purposes of Item 1122 of Regulation AB, as specified in the Instruction 3to Item 1122, but does not constitute a reporting “servicer” for purposes ofItem 1123 of Regulation AB, as specified in the Instruction to Item 1123.

 

•   Aegon USA Realty Advisors,LLC was, until June 1, 2021, the special servicer under the COMM 2018-HOMEtrust and servicing agreement, pursuant to which The Gateway mortgage loan isserviced.  Because Aegon USA Realty Advisors, LLC is not the MSC 2018-L1special servicer, is not affiliated with any sponsor and serviced only TheGateway mortgage loan, which constitutes less than 5% of the mortgage pool,Aegon USA Realty Advisors, LLC, as COMM 2018-HOME special servicer, does notconstitute a reporting “servicing function participant” for purposes of Item1122 of Regulation AB, as specified in the Instruction 3 to Item 1122, and doesnot constitute a reporting “servicer” for purposes of Item 1123 of RegulationAB, as specified in the Instruction to Item 1123.

 

•   Rialto Capital Advisors, LLCis the special servicer under the CD 2018-CD7 pooling and servicing agreement,pursuant to which the Zenith Ridge mortgage loan is serviced.  BecauseRialto Capital Advisors, LLC is not the MSC 2018-L1 special servicer, is notaffiliated with any sponsor and services only the Zenith Ridge mortgage loan,which constitutes less than 5% of the mortgage pool, Rialto Capital Advisors,LLC, as CD 2018-CD7 special servicer, does not constitute a reporting“servicing function participant” for purposes of Item 1122 of Regulation AB, asspecified in the Instruction 3 to Item 1122, and does not constitute areporting “servicer” for purposes of Item 1123 of Regulation AB, as specifiedin the Instruction to Item 1123.

 

•   KeyBank National Association,as Westside NYC Multifamily Portfolio special servicer under the CD 2018-CD7pooling and servicing agreement, only has obligations in respect of theWestside NYC Multifamily Portfolio mortgage loan securitized thereunder. Suchparty has no obligations with respect to the Zenith Ridge mortgage loan andtherefore in such capacity does not constitute a reporting “servicing functionparticipant” for purposes of Item 1122 of Regulation AB, as specified in theInstruction 3 to Item 1122, and does not constitute a reporting “servicer” forpurposes of Item 1123 of Regulation AB, as specified in the Instruction to Item1123.

 

•   Situs Holdings, LLC is thecurrent special servicer under the COMM 2018-HOME trust and servicingagreement, pursuant to which The Gateway mortgage loan is serviced.  OnJune 1, 2021, Aegon USA Realty Advisors, LLC was replaced as special servicerunder the COMM 2018-HOME trust and servicing agreement and was succeeded bySitus Holdings, LLC. Because Situs Holdings, LLC is not the MSC 2018-L1 specialservicer, is not affiliated with any sponsor and services only The Gatewaymortgage loan, which constitutes less than 5% of the mortgage pool, SitusHoldings, LLC, as COMM 2018-HOME special servicer, does not constitute areporting “servicing function participant” for purposes of Item 1122 ofRegulation AB, as specified in the Instruction 3 to Item 1122, and does notconstitute a reporting “servicer” for purposes of Item 1123 of Regulation AB,as specified in the Instruction to Item 1123.

 

•   National Tax Search, LLCmerged into CoreLogic Solutions, LLC in 2021.  CoreLogic Solutions, LLC’sreport on assessment of compliance with servicing criteria and registeredpublic accounting firm attestation report, in each case provided pursuant to Item1122 of Regulation AB, also relate to National Tax Search, LLC’s platform forthe reporting period.

  

In addition, each of the following partiesengaged the services of certain servicing function participants andsub-servicers for the reporting period, as set forth below:

 

•   Midland Loan Services, aDivision of PNC Bank, National Association, as master servicer, engaged theservices of KeyBank National Association and BerkeleyPoint Capital LLC, in each case as a sub-servicer in respect of theentire mortgage pool for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the AMT 2018-AVM trust and servicingagreement, pursuant to which the Aventura Mall mortgage loan is serviced,engaged the services of CoreLogic Solutions, LLC and National Tax Search, LLC,in each case as a servicing function participant in respect of the AventuraMall mortgage loan for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BANK 2018-BNK13 pooling and servicingagreement, pursuant to which the Griffin Portfolio II mortgage loan isserviced, engaged the services of CoreLogic Solutions, LLC and National TaxSearch, LLC, in each case as a servicing function participant in respect of theGriffin Portfolio II mortgage loan for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BANK 2019-BNK16 pooling and servicingagreement, pursuant to which the Regions Tower mortgage loan is serviced,engaged the services of CoreLogic Solutions, LLC and National Tax Search, LLC,in each case as a servicing function participant in respect of the RegionsTower mortgage loan for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer and special servicer under the MSC 2018-MPtrust and servicing agreement, pursuant to which the Millennium PartnersPortfolio mortgage loan is serviced, engaged the services of CoreLogic Solutions,LLC and National Tax Search, LLC, in each case as a servicing functionparticipant in respect of the Millennium Partners Portfolio mortgage loan forthe reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the COMM 2018-HOME pooling and servicingagreement, pursuant to which The Gateway mortgage loan is serviced, engaged theservices of CoreLogic Solutions, LLC and National Tax Search, LLC, in each caseas a servicing function participant in respect of The Gateway mortgage loan forthe reporting period.

 

•   Wells Fargo Bank,National Association, as master servicer under the MSC 2018-H3 pooling andservicing agreement, pursuant to which the Playa Largo mortgage loan and theShoppes at Chino Hills mortgage loan are serviced, engaged the services ofCoreLogic Solutions, LLC and National Tax Search, LLC, in each case as aservicing function participant in respect of the Playa Largo mortgage loan andthe Shoppes at Chino Hills mortgage loan for the reporting period.

 

•   On November 1,2021, pursuant to the second amended and restated servicing agreement attachedhereto as Exhibit 99.19, Computershare Trust Company, National Association wasengaged to perform all or virtually all of Wells Fargo Bank, NationalAssociation’s roles as certificate administrator, custodian and trustee, asapplicable, under (i) the pooling and servicing agreement and (ii) each OutsidePooling and Servicing Agreement.

 

 

| **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.**    |
|              | Omitted.                        |
|              |                            |   |

 

| **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 of Financial Condition and Results of Operations.**                         |
|              | Omitted.                                                                                                            |
| **Item 7A.** | **Quantitative and  Qualitative Disclosures About Market Risk.**                                                    |
|              | Omitted.                                                                                                            |
| **Item 8.**  | **Financial Statements and  Supplementary Data.**                                                                   |
|              | Omitted.                                                                                                            |
| **Item 9.**  | **Changes in and  Disagreements With Accountants 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 Corporate Governance.**                                         |
|              | Omitted.                                                                                             |
| **Item 11.** | **Executive Compensation.**                                                                          |
|              | Omitted.                                                                                             |
| **Item 12.** | **Security Ownership of  Certain Beneficial Owners and Management and Related Stockholder Matters.** |
|              | Omitted.                                                                                             |
| **Item 13.** | **Certain Relationships and  Related Transactions, and Director Independence.**                      |
|              | Omitted.                                                                                             |
| **Item 14.** | **Principal Accountant Fees  and Services.**                                                         |
|              | Omitted.                                                                                             |
|              |                                                                                                 |   |

 

**ADDITIONALDISCLOSURE ITEMS FOR REGULATION AB**

 

**Item1112(b) of Regulation AB, Significant Obligor Financial Information.**

 

Notapplicable.

 

**Item1114(b)(2) of Regulation AB, Significant Enhancement Provider FinancialInformation.**

 

Noentity or group of affiliated entities provides any enhancement or othersupport for the certificates as described under Item 1114 (a) of Regulation AB.

 

**Item1115(b) of Regulation AB, Certain Derivatives Instruments (FinancialInformation).**

 

Noentity or group of affiliated entities provides any derivative instruments forthe certificates as described under Item 1115 of Regulation AB.

 

**Item1117 of Regulation AB, Legal Proceedings.**

 

Theregistrant knows of no legal proceeding pending against the sponsors,depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) ofRegulation AB, originator contemplated by Item 1110(b) of Regulation AB, or otherparty contemplated by Item 1100(d)(1) of Regulation AB, or of which anyproperty of the foregoing is the subject, that is material to security holders,other than as follows:

 

InDecember 2014, Phoenix Light SF Limited and certain related entities and theNational Credit Union Administration (NCUA) filed complaints in the UnitedStates District Court for the Southern District of New York against Wells FargoBank, alleging claims against Wells Fargo Bank in its capacity as trustee for anumber of residential mortgage-backed securities trusts. Complaints raisingsimilar allegations have been filed by Commerzbank AG in the Southern Districtof New York and by IKB International and IKB Deutsche Industriebank in New Yorkstate court. In each case, the plaintiffs allege that Wells Fargo Bank, astrustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. Wells Fargo Bank previously settled two class action lawsuits withsimilar allegations that were filed in November 2014 and December 2016 byinstitutional investors in the Southern District of New York and New York statecourt, respectively. In addition, Park Royal I LLC and Park Royal II LLC havefiled complaints in New York state court alleging Wells Fargo Bank, N.A., astrustee, failed to take appropriate actions upon learning of defective mortgageloan documentation. In March 2021, the Company entered into an agreement toresolve the case filed by the NCUA.

 

Inaddition to the foregoing cases, in August 2014 and August 2015 Nomura Credit& Capital Inc. (“Nomura”) and Natixis Real Estate Holdings, LLC (“Natixis”)filed a total of seven third-party complaints against Wells Fargo Bank in NewYork state court. In the underlying first-party actions, Nomura and Natixishave been sued for alleged breaches of representations and warranties made inconnection with residential mortgage-backed securities sponsored by them. Inthe third-party actions, Nomura and Natixis allege that Wells Fargo Bank, asmaster servicer, primary servicer or securities administrator, failed to notifyNomura and Natixis of their own breaches, failed to properly oversee theprimary servicers, and failed to adhere to accepted servicing practices.Natixis additionally alleges that Wells Fargo Bank failed to perform defaultoversight duties. Wells Fargo Bank has asserted counterclaims alleging thatNomura and Natixis failed to provide Wells Fargo Bank notice of theirrepresentation and warranty breaches.

 

Withrespect to each of the foregoing litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the relatedRMBS trusts.

 

Fromtime to time, CWCapital Asset Management LLC, a Delaware limited liabilitycompany (“CWCAM”), is a party to lawsuits and other legal proceedings as partof its duties as a special servicer (e.g., enforcement of loan obligations)and/or arising in the ordinary course of business.  Other than as setforth in the following paragraphs, there are currently no legal proceedingspending, and no legal proceedings known to be contemplated by governmentalauthorities, against CWCAM or of which any of its property is the subject, thatare material to the certificateholders.

 

OnDecember 17, 2015, U.S. Bank National Association, the trustee under fivepooling and servicing agreements for (i) Wachovia Bank Commercial MortgageTrust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2, (iii) Wachovia BankCommercial Mortgage Trust 2007-C31, (iv) ML-CFC Commercial Mortgage Trust2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenced a proceedingwith the Second Judicial District Court of Ramsey County, Minnesota (the “StateCourt”) for a declaratory judgment as to the proper allocation of certainproceeds (“Disputed Proceeds”) received by CWCAM in connection with the sale ofthe Peter Cooper Village and Stuyvesant Town property in New York, New Yorksecuring loans held by those trusts.  CWCAM was the special servicer ofsuch property.  The petition requests the State Court to instruct thetrustee, the trust beneficiaries, and any other interested parties as to theamount of the Disputed Proceeds, if any, that constitute penalty interestand/or the amount of the Disputed Proceeds, if any, that constitutegain-on-sale proceeds, with respect to each trust.  On February 24, 2016,CWCAM made a limited appearance with the State Court to file a motion todismiss this proceeding based on lack of jurisdiction, mootness, standing andforum non conveniens.  On July 19, 2016, the State Court denied CWCAM’smotion to dismiss.  On July 22, 2016, the action was removed to federalcourt in Minnesota (“Federal Court”).  On October 21, 2016, the FederalCourt held a hearing on the motion to transfer the action to the United StatesDistrict Court for the Southern District of New York (“SDNY Court”), a motionto remand to state court and a motion to hear CWCAM’s request forreconsideration of the motion to dismiss.  On March 14, 2017, the FederalCourt reserved the determination on the motion to hear CWCAM’s request forreconsideration of the motion to dismiss, denied the motion to remand thematter to state court and granted the motion to transfer the proceeding to theSDNY Court.  Cross motions for judgment on the pleadings were filed butthe SDNY Court was unable to decide the case based on the pleadings and theSDNY Court ordered discovery.  All fact discovery was completed inDecember, 2018 and expert discovery was completed on March 15, 2019.  Theparties submitted cross motions for summary judgment, and on March 19, 2020,the SDNY Court entered an opinion and order in which it granted summaryjudgment in CWCAM’s favor and held that CWCAM was entitled to the entire amountof penalty interest and that CWCAM’s determination of Yield Maintenance wascorrect.  In the 127-page opinion, the SDNY Court found for CWCAM on everyissue presented by the trustee’s petition, namely, that the funds in disputeconstitute penalty interest and yield maintenance, not gain-on-sale proceeds,and that the amount of penalty interest and yield maintenance was correctlycalculated. An appeal of the SDNY Court’s decision was taken on April 29,2020.  Oral argument on the appeal occurred on June 21, 2021. The partiesawait the decision of the appeals court.  

 

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

 

OnJanuary 24, 2016 PSW NYC LLC commenced a complaint (the “PSW Complaint”) withthe Supreme Court of the State of New York, County of New York (the “PSWCourt”) against Bank of America, N.A. as trustee under the pooling andservicing agreements for Wachovia Bank Commercial Mortgage Trust 2007-C30 andCOBALT CMBS Commercial Trust 2007-C2, U.S. Bank National Association as trusteeunder the pooling and servicing agreements for Wachovia Bank CommercialMortgage Trust 2007-C31, ML-CFC Commercial Mortgage Trust 2007-5 and ML-CFCCommercial Mortgage Trust 2007-6 (collectively, the “PSW Trusts”), PCV-MHoldings LLC and CWCapital Asset Management LLC, individually and as specialservicer for the PSW Trusts (collectively, the “Defendants”) seeking either (a)damages in an amount to be determined by the PSW Court but alleged by theplaintiffs to be approximately $500,000,000 – such amount being the amount PSWNYC LLC alleges would have been recovered on certain mezzanine loans (the“PCVST Mezzanine Loans”) related to the Peter Cooper Village and StuyvesantTown property (the “PCVST Property”) in New York City which PSW NYC LLC sold toan entity related to the Defendants pursuant to a settlement agreement relatedto certain prior litigation (the “2010 Settlement Agreement”) or (b) therescission of the 2010 Settlement Agreement which would result in, among otherthings, the rescission of the sale of the PCVST Mezzanine Loans and a claim forcertain proceeds from the sale of the PCVST Property. PSW NYC LLC alleges thatthe Defendants procured the 2010 Settlement Agreement by fraud and further thatthe terms of the 2010 Settlement Agreement were breached by the Defendants. OnFebruary 26, 2016, CWCAM on behalf of itself and the other Defendants filed amotion to dismiss the PSW Complaint (the “CWCAM Motion to Dismiss”). On April11, 2016, PSW NYC LLC opposed the CWCAM Motion to Dismiss and cross-moved for apartial summary judgment on liability regarding allegations of breach of the2010 Settlement Agreement (the “PSW Cross-Motion”). On May 5, 2016, theDefendants subsequently filed its reply and opposition to the PSW Cross-Motion.On August 23, 2016, oral arguments were provided to the PSW Court regarding thePSW Complaint, the CWCAM Motion to Dismiss and the PSW Cross-Motion and the PSWCourt took such arguments under advisement. On October 31, 2016, the PSW Courtissued an order granting the CWCAM Motion to Dismiss, denying the PSWCross-Motion and dismissing the PSW Complaint with prejudice. Subsequently, PSWNYC LLC filed a notice of appeal relating to such order. On February 21, 2017,PSW NYC LLC filed its appeal and supporting brief arguing that the PSW Courterred by finding no breach of the assignment agreement and no fraudulentinducement. Oral argument was heard on May 4, 2017 at which point the courttook the arguments under advisement. On May 25, 2017, the New York 1stDepartment appellate court affirmed the dismissal of all PSW claims and denied arequest for leave to appeal to the New York Court of Appeals on September 12,2017.  

 

OnMarch 31, 2016, RAIT Preferred Funding II LTD. (“RAIT Preferred Funding”)commenced a complaint (“RAIT Complaint”) with the Supreme Court of the State ofNew York, County of New York (the “RAIT Court”), claiming it owns $18,500,000of a mortgage loan secured by the development of the One Congress StreetProperty in Boston, Massachusetts (the “Loan”) and seeking (a) a declaratoryjudgment stating that RAIT Preferred Funding is the directing lender under aco-lender agreement dated March 28, 2007 and a pooling and servicing agreementdated March 1, 2007 (collectively, the “Operative Agreements”) and was thedirecting lender at the time of the improper modification of the Loan, (b) adeclaratory judgment stating that RAIT Preferred Funding has the right toterminate the special servicer, (c) monetary damages for the value of the bondsand fees paid to CWCAM as the special servicer of the Loan and (d) otherthings.  On May 17, 2016, CWCAM filed a motion to dismiss the RAITComplaint (“Motion to Dismiss”) stating that the RAIT Complaint did not state aclaim and the essential facts of the RAIT Complaint are negated by affidavitsand evidentiary materials submitted with the RAIT Complaint.  On June 14,2016, RAIT Preferred Funding filed a Memorandum of Law in Opposition to theMotion to Dismiss (“Opposition”) stating that the claims in the RAIT Complaintwere properly stated.  On June 30, 2016, CWCAM filed a reply in support ofthe Motion to Dismiss and in response to the Opposition, stating that each ofCWCAM’s arguments is supported by the express language of the agreementsbetween the parties, the documentary evidence and New York case law.  OnSeptember 30, 2016, RAIT Preferred Funding and CWCAM entered into aconfidential Settlement Agreement (the “2016 Settlement”), which provides for astay of the RAIT Preferred Funding litigation (the “Litigation Stay”) throughAugust 25, 2017.  Pursuant to the terms of the 2016 Settlement, uponsatisfaction of a term of the 2016 Settlement by August 25, 2017 (or such laterdate agreed to by the parties), the RAIT Preferred Funding litigation will bedismissed, with prejudice.  On May 19, 2017 the Borrower repaid the Loanin accordance with the terms of the notes and satisfied the condition todismissal with prejudice.  RAIT has refused to dismiss the case and isclaiming that the B Note should be paid in full.  CWCAM believes that ithas performed its obligations under the Operative Agreements in good faith, andthat the action should be dismissed with prejudice.  On August 29, 2017,the RAIT Court granted leave to RAIT Preferred Funding to amend itscomplaint.  On September 20, 2017, RAIT Preferred Funding filed an AmendedComplaint (the “RAIT Amended Complaint”), which omits its original claims, addsWells Fargo Bank as a defendant, and seeks (a) specific performance requiringrepayment of the $18,500,000 principal amount of the B Note or, in thealternative, monetary damages, including the $18,500,000 principal amount ofthe B Note, in an amount to be determined at trial, (b) monetary damages on anyfees paid to CWCAM as special servicer or Wells Fargo Bank as master servicerin connection with the borrower’s repayment of the Loan, (c) a declaratoryjudgment that RAIT Preferred Funding is entitled to recover the full$18,500,000 principal amount of the B Note, (d) punitive damages against CWCAM,and (e) other things.  On October 11, 2017, CWCAM filed a motion todismiss the RAIT Amended Complaint (“CWCAM Motion to Dismiss AmendedComplaint”) stating that the RAIT Amended Complaint did not state a claim andthe essential facts of the RAIT Amended Complaint are negated by the OperativeAgreements and other admissible evidentiary materials.  On November 13,2017, Wells Fargo Bank filed a motion to dismiss the RAIT Amended Complaint(the “Wells Fargo Motion to Dismiss Amended Complaint”) and joined the CWCAMMotion to Dismiss Amended Complaint.  On January 29, 2018, the courtdismissed all claims but for breach of contract and discovery hascommenced.  CWCAM filed a Motion for Summary Judgement on March 18,2019.   This matter was settled and the case dismissed on May 15,2019.

 

On February 14, 2022, Cantor Commercial Real EstateLending, L.P. (“CCRE”) was named as a defendant in a lawsuit captionedKingsbridge 2005, LLC, Shelbourne Broad Street, LLC and 691 Central Avenue SPELLC v Cantor Commercial Real Estate Lending, L.P., and KKR Real Estate CreditOpportunity Partners Aggregator I L.P., and Midland Loan Services, Inc., IndexNo. 650687/2002, filed in the Supreme Court of the State of New York, County ofNew York.  Plaintiff seeks recission of a $93 million loan issued by CCREin September 2018 and subsequently sold into four commercial mortgage backedsecurities transactions on the theory of unilateral mistake.  Plaintiffclaims it discovered the issue when it was denied partial defeasance of oneproperty that served as collateral for the loan.  The case is in the earlystages.  At this point, CCRE does not believe the outcome of the casewould have a material impact on CCRE’s obligations with respect to the loan oron certificate holders, although no assurance can be given that it will nothave a material impact on certificate holders.

 

**Item1119 of Regulation AB, Affiliations and Certain Relationships and RelatedTransactions.**

 

Theinformation regarding this Item has been provided previously in an annualreport on Form 10-K of the issuing entity or in the prospectus of the issuingentity filed in a 424(b)(2) filing dated October 23, 2018.

 

**Item1122 of Regulation AB, Compliance with Applicable Servicing Criteria.**

 

Thereports on assessment of compliance with the servicing criteria forasset-backed securities and the related attestation reports on such assessmentsof compliance are attached hereto under Item 15.

 

Thereport on assessment of compliance for the twelve months ended December 31,2021, furnished pursuant to Item 1122 of Regulation AB by Aegon USA RealtyAdvisors, LLC (“Aegon” or the “Company”), as special servicer, discloses thatthe following material instance of noncompliance occurred with respect to itsplatform:

 

Theexamination performed by PWC identified an instance of material noncompliancewith the servicing criteria set forth in Item 1122(d)(3)(i)(A) of Regulation ABapplicable to the Company during year ended December 31, 2021. Morespecifically, for the only active special serviced deal subject to Item1122(d)(3)(i)(A), the report to the investors was not prepared in accordancewith the timeframes and other terms set forth in the transaction agreements forthe period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4 is thespecific deal related to the aforementioned finding. No other deals withinAegon’s CMBS special servicing portfolio were related to or impacted by thisinstance of non-compliance.

 

Managementacknowledges the timeframe for reporting for this active special serviced dealwas missed by two days. Despite the timing discrepancy, there was no impact onany investor reporting, issuing, or servicing. No additional testing wasavailable for this particular criteria due to the downsizing of the CMBSportfolio given Aegon’s pending exit from the business line.

 

**Item1123 of Regulation AB, Servicer Compliance Statement.**

 

Theservicer compliance statements are attached hereto under Item 15.

 

**PART IV**

 

**Item15. Exhibits, Financial Statement Schedules.**

 

(a) Exhibits.

 

(4.1)Pooling and Servicing Agreement, dated as of October 1,2018, between Morgan Stanley Capital I Inc., as depositor, Midland LoanServices, a Division of PNC Bank, National Association, as master servicer andspecial servicer, Wells Fargo Bank, National Association, as certificateadministrator and trustee, and Pentalpha Surveillance LLC, as operating advisorand as asset representations reviewer (filed as Exhibit 4.1 to the registrant'sCurrent Report on Form 8-K/A filed on February 8, 2019 under SEC File No.333-206582-17 and incorporated by reference herein).

 

(4.2)Trust and Servicing Agreement, dated as of June 29,2018, between J.P. Morgan Chase Commercial Mortgage Securities Corp., asdepositor, Wells Fargo Bank, National Association, as servicer, CWCapital AssetManagement LLC, as special servicer, Park Bridge Lender Services LLC, asoperating advisor, Wells Fargo Bank, National Association, as certificateadministrator, and Wilmington Trust, National Association, as trustee, relatingto the Aventura Mall Trust 2018-AVM securitization transaction, pursuant towhich the Aventura Mall Mortgage Loan is serviced (filed as Exhibit 4.2 to theregistrant's Current Report on Form 8-K filed on October 23, 2018 under SECFile No. 333-206582-17 and incorporated by reference herein).

 

(4.3)Pooling and Servicing Agreement, dated as of August 1,2018, between Wells Fargo Commercial Mortgage Securities, Inc., as depositor,Wells Fargo Bank, National Association, as general master servicer, TorchlightLoan Services, LLC, as general special servicer, National Cooperative Bank,N.A., as NCB master servicer and as NCB special servicer, Wells Fargo Bank,National Association, as certificate administrator, Wilmington Trust, NationalAssociation, as trustee, and Pentalpha Surveillance LLC, as operating advisorand as asset representations reviewer, relating to the BANK 2018-BNK13securitization transaction, pursuant to which the Griffin Portfolio II MortgageLoan is serviced (filed as Exhibit 4.3 to the registrant's Current Report onForm 8-K filed on October 23, 2018 under SEC File No. 333-206582-17 andincorporated by reference herein).

 

(4.4)Trust and Servicing Agreement, dated as of August 7,2018, between Morgan Stanley Capital I Inc., as depositor, Wells Fargo Bank,National Association, as servicer and as special servicer, Wilmington Trust,National Association, as trustee and Wells Fargo Bank, National Association, ascertificate administrator and custodian, relating to the MSC 2018-MPsecuritization transaction, pursuant to which the Millennium Partners PortfolioMortgage Loan is serviced  (filed as Exhibit 4.4 to the registrant'sCurrent Report on Form 8-K filed on October 23, 2018 under SEC File No.333-206582-17 and incorporated by reference herein).

 

(4.5)Pooling and Servicing Agreement, dated as of June 1,2018, between Deutsche Mortgage & Asset Receiving Corporation, asdepositor, Wells Fargo Bank, National Association, as master servicer, AEGONUSA Realty Advisors, LLC, as special servicer, Wells Fargo Bank, NationalAssociation, as certificate administrator, Wilmington Trust, NationalAssociation, as trustee, and Park Bridge Lender Services LLC, as operatingadvisor, relating to the COMM 2018-HOME securitization transaction, pursuant towhich The Gateway Mortgage Loan is serviced  (filed as Exhibit 4.5 to theregistrant's Current Report on Form 8-K filed on October 23, 2018 under SECFile No. 333-206582-17 and incorporated by reference herein).

 

(4.6)Pooling and Servicing Agreement, dated as of August 1,2018, between Deutsche Mortgage & Asset Receiving Corporation, asdepositor, KeyBank National Association, as master servicer and Westside NYCMultifamily Portfolio special servicer, Rialto Capital Advisors, LLC, asgeneral special servicer, Wells Fargo Bank, National Association, ascertificate administrator and as trustee, and Park Bridge Lender Services LLC,as operating advisor and as asset representations reviewer, relating to the CD2018-CD7 securitization transaction, pursuant to which the Zenith RidgeMortgage Loan is serviced  (filed as Exhibit 4.6 to the registrant'sCurrent Report on Form 8-K filed on October 23, 2018 under SEC File No. 333-206582-17and incorporated by reference herein).

 

(4.7)Pooling and Servicing Agreement, dated as of July 1,2018, between Morgan Stanley Capital I Inc., as depositor, Wells Fargo Bank,National Association, as master servicer, LNR Partners, LLC, as specialservicer, 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, relatingto the MSC 2018-H3 securitization transaction, pursuant to which the PlayaLargo Mortgage Loan and the Shoppes at Chino Hills Mortgage Loan areserviced  (filed as Exhibit 4.7 to the registrant's Current Report on Form8-K filed on October 23, 2018 under SEC File No. 333-206582-17 and incorporatedby reference herein).

 

(4.8)Pooling and Servicing Agreement, dated as of October 1,2018, between UBS Commercial Mortgage Securitization Corp., as depositor,Midland Loan Services, a Division of PNC Bank, National Association, as masterservicer and special servicer, Wells Fargo Bank, National Association, ascertificate administrator and as trustee, and Pentalpha Surveillance LLC, asoperating advisor and as asset representations reviewer, relating to the UBS2018-C13 securitization transaction, pursuant to which the Shelbourne GlobalPortfolio I Mortgage Loan is serviced  (filed as Exhibit 4.8 to theregistrant's Current Report on Form 8-K filed on October 23, 2018 under SECFile No. 333-206582-17 and incorporated by reference herein).

 

(4.9)Pooling and Servicing Agreement, dated as of February1, 2019, among Wells Fargo Commercial Mortgage Securities, Inc., as depositor,Wells Fargo Bank, National Association, as general master servicer, KeyBankNational Association, as general special servicer, National Cooperative Bank,N.A., as NCB master servicer and as NCB special servicer, Park Bridge LenderServices LLC, as operating advisor and as asset representations reviewer, WellsFargo Bank, National Association, as certificate administrator, and WilmingtonTrust, National Association, as trustee, relating to the BANK 2019-BNK16securitization transaction, pursuant to which the Regions Tower Mortgage Loanis serviced  (filed as Exhibit 4.9 to the registrant's Current Report onForm 8-K filed on February 27, 2019 under SEC File No. 333-206582-17 andincorporated by reference herein).

 

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

 

(33)  Reports on assessment of compliance with servicing criteria forasset-backed securities.

 

33.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

33.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator (from 11/1/21to 12/31/21)

 

33.3 Wells Fargo Bank, National Association, as Custodian

 

33.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (from 11/1/21 to 12/31/21)

 

33.5  Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

 

33.6  Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 33.5)

 

33.7  Pentalpha Surveillance LLC, as Operating Advisor

 

33.8  KeyBank National Association, as Primary Servicer

 

33.9  Berkeley Point Capital LLC, as Primary Servicer

 

33.10  Wells Fargo Bank, National Association, as MasterServicer under the AMT 2018-AVM securitization, pursuant to which the followingmortgage loans were serviced by such party: Aventura Mall (from 1/1/21 to12/31/21)

 

33.11  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the AMT 2018-AVM securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Aventura Mall (from1/1/21 to 12/31/21)

 

33.12  Wells Fargo Bank, National Association, as MasterServicer under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/21 to 12/31/21) (see Exhibit 33.10)

 

33.13  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/21 to 12/31/21) (see Exhibit 33.11)

 

33.14  Wells Fargo Bank, National Association, as MasterServicer under the MSC 2018-MP securitization, pursuant to which the followingmortgage loans were serviced by such party: Millennium Partners Portfolio (from1/1/21 to 12/31/21) (see Exhibit 33.10)

 

33.15  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/21 to 12/31/21) (see Exhibit 33.11)

 

33.16  Wells Fargo Bank, National Association, as MasterServicer under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/21to 12/31/21) (see Exhibit 33.10)

 

33.17  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/21to 12/31/21) (see Exhibit 33.11)

 

33.18  Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/21 to 12/31/21) (see Exhibit 33.10)

 

33.19  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/21 to 12/31/21) (see Exhibit 33.11)

 

33.20  KeyBank National Association, as Master Servicer underthe CD 2018-CD7 securitization, pursuant to which the following mortgage loanswere serviced by such party: Zenith Ridge (from 1/1/21 to 12/31/21) (seeExhibit 33.8)

 

33.21  Wells Fargo Bank, National Association, as MasterServicer under the MSC 2018-H3 securitization, pursuant to which the followingmortgage loans were serviced by such party: Playa Largo (from 1/1/21 to12/31/21) and Shoppes at Chino Hills (from 1/1/21 to 12/31/21) (see Exhibit33.10)

 

33.22  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-H3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Playa Largo (from 1/1/21to 12/31/21) and Shoppes at Chino Hills (from 1/1/21 to 12/31/21) (see Exhibit33.11)

 

33.23  Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer under the UBS 2018-C13 securitization,pursuant to which the following mortgage loans were serviced by such party:Shelbourne Global Portfolio I (from 1/1/21 to 12/31/21) (see Exhibit 33.5)

 

33.24  CWCapital Asset Management LLC, as Special Servicerunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/21 to 12/31/21)

 

33.25  Torchlight Loan Services, LLC, as Special Servicerunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/21to 12/31/21)

 

33.26  Wells Fargo Bank, National Association, as SpecialServicer under the MSC 2018-MP securitization, pursuant to which the followingmortgage loans were serviced by such party: Millennium Partners Portfolio (from1/1/21 to 12/31/21) (see Exhibit 33.10)

 

33.27  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/21 to 12/31/21) (see Exhibit 33.11)

 

33.28  KeyBank National Association, as Special Servicerunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/21 to12/31/21) (see Exhibit 33.8)

 

33.29  LNR Partners, LLC, as Special Servicer under the MSC2018-H3 securitization, pursuant to which the following mortgage loans wereserviced by such party: Playa Largo (from 1/1/21 to 12/31/21) and Shoppes atChino Hills (from 1/1/21 to 12/31/21)

 

33.30  Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer under the UBS 2018-C13securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio I (from 1/1/21 to 12/31/21) (seeExhibit 33.5)

 

33.31  Wells Fargo Bank, National Association, as Custodianunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/21 to 12/31/21) (seeExhibit 33.3)

 

33.32  Computershare Trust Company, National Association, asServicing Function Participant under the AMT 2018-AVM securitization, pursuantto which the following mortgage loans were serviced by such party: AventuraMall (from 11/1/21 to 12/31/21) (see Exhibit 33.4)

 

33.33  Wells Fargo Bank, National Association, as Custodianunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/21to 12/31/21) (see Exhibit 33.3)

 

33.34  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2018-BNK13 securitization,pursuant to which the following mortgage loans were serviced by such party:Griffin Portfolio II (from 11/1/21 to 12/31/21) (see Exhibit 33.4)

 

33.35  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-MP securitization, pursuant to which the following mortgageloans were serviced by such party: Millennium Partners Portfolio (from 1/1/21to 12/31/21) (see Exhibit 33.3)  

 

33.36  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-MP securitization, pursuantto which the following mortgage loans were serviced by such party: MillenniumPartners Portfolio (from 11/1/21 to 12/31/21) (see Exhibit 33.4)

 

33.37  Wells Fargo Bank, National Association, as Custodianunder the COMM 2018-HOME securitization, pursuant to which the followingmortgage loans were serviced by such party: The Gateway (from 1/1/21 to12/31/21) (see Exhibit 33.3)

 

33.38  Computershare Trust Company, National Association, asServicing Function Participant under the COMM 2018-HOME securitization,pursuant to which the following mortgage loans were serviced by such party: TheGateway (from 11/1/21 to 12/31/21) (see Exhibit 33.4)

 

33.39  Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/21 to12/31/21) (see Exhibit 33.3)

 

33.40  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party:Regions Tower (from 11/1/21 to 12/31/21) (see Exhibit 33.4)

 

33.41  Wells Fargo Bank, National Association, as Custodianunder the CD 2018-CD7 securitization, pursuant to which the following mortgageloans were serviced by such party: Zenith Ridge (from 1/1/21 to 12/31/21) (seeExhibit 33.3)

 

33.42  Computershare Trust Company, National Association, asServicing Function Participant under the CD 2018-CD7 securitization, pursuantto which the following mortgage loans were serviced by such party: Zenith Ridge(from 11/1/21 to 12/31/21) (see Exhibit 33.4)

 

33.43  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-H3 securitization, pursuant to which the following mortgageloans were serviced by such party: Playa Largo (from 1/1/21 to 12/31/21) andShoppes at Chino Hills (from 1/1/21 to 12/31/21) (see Exhibit 33.3)

 

33.44  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-H3 securitization, pursuantto which the following mortgage loans were serviced by such party: Playa Largo(from 11/1/21 to 12/31/21) and Shoppes at Chino Hills (from 11/1/21 to12/31/21) (see Exhibit 33.4)

 

33.45  Wells Fargo Bank, National Association, as Custodianunder the UBS 2018-C13 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio I (from 1/1/21to 12/31/21) (see Exhibit 33.3)

 

33.46  Computershare Trust Company, National Association, asServicing Function Participant under the UBS 2018-C13 securitization, pursuantto which the following mortgage loans were serviced by such party: ShelbourneGlobal Portfolio I (from 11/1/21 to 12/31/21) (see Exhibit 33.4)

 

(34). Attestation reports on assessment ofcompliance with servicing criteria for asset-backed securities.

 

34.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

34.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator (from 11/1/21to 12/31/21)

 

34.3 Wells Fargo Bank, National Association, as Custodian

 

34.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (from 11/1/21 to 12/31/21)

 

34.5  Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer

 

34.6  Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 34.5)

 

34.7  Pentalpha Surveillance LLC, as Operating Advisor

 

34.8  KeyBank National Association, as Primary Servicer

 

34.9  Berkeley Point Capital LLC, as Primary Servicer

 

34.10  Wells Fargo Bank, National Association, as MasterServicer under the AMT 2018-AVM securitization, pursuant to which the followingmortgage loans were serviced by such party: Aventura Mall (from 1/1/21 to12/31/21)

 

34.11  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the AMT 2018-AVM securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Aventura Mall (from 1/1/21to 12/31/21)

 

34.12  Wells Fargo Bank, National Association, as MasterServicer under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/21 to 12/31/21) (see Exhibit 34.10)

 

34.13  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/21 to 12/31/21) (see Exhibit 34.11)

 

34.14  Wells Fargo Bank, National Association, as MasterServicer under the MSC 2018-MP securitization, pursuant to which the followingmortgage loans were serviced by such party: Millennium Partners Portfolio (from1/1/21 to 12/31/21) (see Exhibit 34.10)

 

34.15  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/21 to 12/31/21) (see Exhibit 34.11)

 

34.16  Wells Fargo Bank, National Association, as MasterServicer under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/21to 12/31/21) (see Exhibit 34.10)

 

34.17  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/21to 12/31/21) (see Exhibit 34.11)

 

34.18  Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/21 to 12/31/21) (see Exhibit 34.10)

 

34.19  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/21 to 12/31/21) (see Exhibit 34.11)

 

34.20  KeyBank National Association, as Master Servicer underthe CD 2018-CD7 securitization, pursuant to which the following mortgage loanswere serviced by such party: Zenith Ridge (from 1/1/21 to 12/31/21) (seeExhibit 34.8)

 

34.21  Wells Fargo Bank, National Association, as MasterServicer under the MSC 2018-H3 securitization, pursuant to which the followingmortgage loans were serviced by such party: Playa Largo (from 1/1/21 to12/31/21) and Shoppes at Chino Hills (from 1/1/21 to 12/31/21) (see Exhibit34.10)

 

34.22  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-H3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Playa Largo (from 1/1/21to 12/31/21) and Shoppes at Chino Hills (from 1/1/21 to 12/31/21) (see Exhibit34.11)

 

34.23  Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer under the UBS 2018-C13 securitization,pursuant to which the following mortgage loans were serviced by such party:Shelbourne Global Portfolio I (from 1/1/21 to 12/31/21) (see Exhibit 34.5)

 

34.24  CWCapital Asset Management LLC, as Special Servicerunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/21 to 12/31/21)

 

34.25  Torchlight Loan Services, LLC, as Special Servicerunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/21 to12/31/21)

 

34.26  Wells Fargo Bank, National Association, as SpecialServicer under the MSC 2018-MP securitization, pursuant to which the followingmortgage loans were serviced by such party: Millennium Partners Portfolio (from1/1/21 to 12/31/21) (see Exhibit 34.10)

 

34.27  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/21 to 12/31/21) (see Exhibit 34.11)

 

34.28  KeyBank National Association, as Special Servicerunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/21 to12/31/21) (see Exhibit 34.8)

 

34.29  LNR Partners, LLC, as Special Servicer under the MSC2018-H3 securitization, pursuant to which the following mortgage loans wereserviced by such party: Playa Largo (from 1/1/21 to 12/31/21) and Shoppes atChino Hills (from 1/1/21 to 12/31/21)

 

34.30  Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer under the UBS 2018-C13securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio I (from 1/1/21 to 12/31/21) (see Exhibit34.5)

 

34.31  Wells Fargo Bank, National Association, as Custodianunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/21 to 12/31/21) (seeExhibit 34.3)

 

34.32  Computershare Trust Company, National Association, asServicing Function Participant under the AMT 2018-AVM securitization, pursuantto which the following mortgage loans were serviced by such party: AventuraMall (from 11/1/21 to 12/31/21) (see Exhibit 34.4)

 

34.33  Wells Fargo Bank, National Association, as Custodianunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/21to 12/31/21) (see Exhibit 34.3)

 

34.34  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2018-BNK13 securitization,pursuant to which the following mortgage loans were serviced by such party:Griffin Portfolio II (from 11/1/21 to 12/31/21) (see Exhibit 34.4)

 

34.35  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-MP securitization, pursuant to which the following mortgageloans were serviced by such party: Millennium Partners Portfolio (from 1/1/21to 12/31/21) (see Exhibit 34.3)  

 

34.36  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-MP securitization, pursuantto which the following mortgage loans were serviced by such party: MillenniumPartners Portfolio (from 11/1/21 to 12/31/21) (see Exhibit 34.4)

 

34.37  Wells Fargo Bank, National Association, as Custodianunder the COMM 2018-HOME securitization, pursuant to which the followingmortgage loans were serviced by such party: The Gateway (from 1/1/21 to12/31/21) (see Exhibit 34.3)

 

34.38  Computershare Trust Company, National Association, asServicing Function Participant under the COMM 2018-HOME securitization,pursuant to which the following mortgage loans were serviced by such party: TheGateway (from 11/1/21 to 12/31/21) (see Exhibit 34.4)

 

34.39  Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/21 to12/31/21) (see Exhibit 34.3)

 

34.40  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party:Regions Tower (from 11/1/21 to 12/31/21) (see Exhibit 34.4)

 

34.41  Wells Fargo Bank, National Association, as Custodianunder the CD 2018-CD7 securitization, pursuant to which the following mortgageloans were serviced by such party: Zenith Ridge (from 1/1/21 to 12/31/21) (seeExhibit 34.3)

 

34.42  Computershare Trust Company, National Association, asServicing Function Participant under the CD 2018-CD7 securitization, pursuantto which the following mortgage loans were serviced by such party: Zenith Ridge(from 11/1/21 to 12/31/21) (see Exhibit 34.4)

 

34.43  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-H3 securitization, pursuant to which the following mortgageloans were serviced by such party: Playa Largo (from 1/1/21 to 12/31/21) andShoppes at Chino Hills (from 1/1/21 to 12/31/21) (see Exhibit 34.3)

 

34.44  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-H3 securitization, pursuantto which the following mortgage loans were serviced by such party: Playa Largo(from 11/1/21 to 12/31/21) and Shoppes at Chino Hills (from 11/1/21 to12/31/21) (see Exhibit 34.4)

 

34.45  Wells Fargo Bank, National Association, as Custodianunder the UBS 2018-C13 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio I (from 1/1/21to 12/31/21) (see Exhibit 34.3)

 

34.46  Computershare Trust Company, National Association, asServicing Function Participant under the UBS 2018-C13 securitization, pursuantto which the following mortgage loans were serviced by such party: ShelbourneGlobal Portfolio I (from 11/1/21 to 12/31/21) (see Exhibit 34.4)

  

(35). Servicer compliance statement.

 

35.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

35.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator (from 11/1/21to 12/31/21)

 

35.3 Wells Fargo Bank, National Association, as Custodian

 

35.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (from 11/1/21 to 12/31/21)

 

35.5 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer

 

35.6 Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer (see Exhibit 35.5)

 

35.7 KeyBank National Association, as PrimaryServicer

 

35.8 Berkeley Point Capital LLC, as PrimaryServicer

 

35.9 Wells Fargo Bank, National Association, asMaster Servicer under the AMT 2018-AVM securitization, pursuant to which the followingmortgage loans were serviced by such party: Aventura Mall (from 1/1/21 to12/31/21)

 

35.10 Wells Fargo Bank, National Association, asMaster Servicer under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/21 to 12/31/21) (see Exhibit 35.9)

 

35.11 Wells Fargo Bank, National Association, asMaster Servicer under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/21 to 12/31/21) (see Exhibit 35.9)

 

35.12 Wells Fargo Bank, National Association, asMaster Servicer under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/21to 12/31/21) (see Exhibit 35.9)

 

35.13 Wells Fargo Bank, National Association, asMaster Servicer under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/21 to 12/31/21) (see Exhibit 35.9)

 

35.14 KeyBank National Association, as MasterServicer under the CD 2018-CD7 securitization, pursuant to which the followingmortgage loans were serviced by such party: Zenith Ridge (from 1/1/21 to12/31/21) (see Exhibit 35.7)

 

35.15 Wells Fargo Bank, National Association, asMaster Servicer under the MSC 2018-H3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Playa Largo (from 1/1/21to 12/31/21) and Shoppes at Chino Hills (from 1/1/21 to 12/31/21) (see Exhibit35.9)

 

35.16 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the UBS 2018-C13securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio I (from 1/1/21 to 12/31/21) (seeExhibit 35.5)

 

35.17 KeyBank National Association, as SpecialServicer under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/21 to 12/31/21) (see Exhibit 35.7)

 

35.18 LNR Partners, LLC, as Special Servicer underthe MSC 2018-H3 securitization, pursuant to which the following mortgage loanswere serviced by such party: Playa Largo (from 1/1/21 to 12/31/21) and Shoppesat Chino Hills (from 1/1/21 to 12/31/21)

 

35.19 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer under the UBS 2018-C13securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio I (from 1/1/21 to 12/31/21) (seeExhibit 35.5)

 

35.20  Wells Fargo Bank, National Association, as Custodianunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/21 to 12/31/21) (seeExhibit 35.3)

 

35.21  Computershare Trust Company, National Association, asServicing Function Participant under the AMT 2018-AVM securitization, pursuantto which the following mortgage loans were serviced by such party: AventuraMall (from 11/1/21 to 12/31/21) (see Exhibit 35.4)

 

35.22  Wells Fargo Bank, National Association, as Custodianunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/21to 12/31/21) (see Exhibit 35.3)

 

35.23  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2018-BNK13 securitization,pursuant to which the following mortgage loans were serviced by such party:Griffin Portfolio II (from 11/1/21 to 12/31/21) (see Exhibit 35.4)

 

35.24  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-MP securitization, pursuant to which the following mortgageloans were serviced by such party: Millennium Partners Portfolio (from 1/1/21to 12/31/21) (see Exhibit 35.3)  

 

35.25  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-MP securitization, pursuantto which the following mortgage loans were serviced by such party: MillenniumPartners Portfolio (from 11/1/21 to 12/31/21) (see Exhibit 35.4)

 

35.26  Wells Fargo Bank, National Association, as Custodianunder the COMM 2018-HOME securitization, pursuant to which the followingmortgage loans were serviced by such party: The Gateway (from 1/1/21 to12/31/21) (see Exhibit 35.3)

 

35.27  Computershare Trust Company, National Association, asServicing Function Participant under the COMM 2018-HOME securitization,pursuant to which the following mortgage loans were serviced by such party: TheGateway (from 11/1/21 to 12/31/21) (see Exhibit 35.4)

 

35.28  Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/21 to12/31/21) (see Exhibit 35.3)

 

35.29  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party:Regions Tower (from 11/1/21 to 12/31/21) (see Exhibit 35.4)

 

35.30  Wells Fargo Bank, National Association, as Custodianunder the CD 2018-CD7 securitization, pursuant to which the following mortgageloans were serviced by such party: Zenith Ridge (from 1/1/21 to 12/31/21) (seeExhibit 35.3)

 

35.31  Computershare Trust Company, National Association, asServicing Function Participant under the CD 2018-CD7 securitization, pursuantto which the following mortgage loans were serviced by such party: Zenith Ridge(from 11/1/21 to 12/31/21) (see Exhibit 35.4)

 

35.32  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-H3 securitization, pursuant to which the following mortgageloans were serviced by such party: Playa Largo (from 1/1/21 to 12/31/21) andShoppes at Chino Hills (from 1/1/21 to 12/31/21) (see Exhibit 35.3)

 

35.33  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-H3 securitization, pursuantto which the following mortgage loans were serviced by such party: Playa Largo(from 11/1/21 to 12/31/21) and Shoppes at Chino Hills (from 11/1/21 to12/31/21) (see Exhibit 35.4)

 

35.34  Wells Fargo Bank, National Association, as Custodianunder the UBS 2018-C13 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio I (from 1/1/21to 12/31/21) (see Exhibit 35.3)

 

35.35  Computershare Trust Company, National Association, asServicing Function Participant under the UBS 2018-C13 securitization, pursuantto which the following mortgage loans were serviced by such party: ShelbourneGlobal Portfolio I (from 11/1/21 to 12/31/21) (see Exhibit 35.4)

 

(99.1)Mortgage Loan Purchase Agreement, dated October 12,2018, between Morgan Stanley Capital I Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.1 to the registrant's Current Report on Form8-K filed on October 23, 2018 under SEC File No. 333-206582-17 and incorporatedby reference herein).

 

(99.2)Mortgage Loan Purchase Agreement, dated October 12,2018, between Morgan Stanley Capital I Inc. and KeyBank National Association(filed as Exhibit 99.2 to the registrant's Current Report on Form 8-K filed onOctober 23, 2018 under SEC File No. 333-206582-17 and incorporated by referenceherein).

 

(99.3)Mortgage Loan Purchase Agreement, dated October 12,2018, between Morgan Stanley Capital I Inc. and Starwood Mortgage Capital LLC(filed as Exhibit 99.3 to the registrant's Current Report on Form 8-K filed onOctober 23, 2018 under SEC File No. 333-206582-17 and incorporated by referenceherein).

 

(99.4)Mortgage Loan Purchase Agreement, dated October 12,2018, between Morgan Stanley Capital I Inc. and Cantor Commercial Real EstateLending, L.P. (filed as Exhibit 99.4 to the registrant's Current Report on Form8-K filed on October 23, 2018 under SEC File No. 333-206582-17 and incorporatedby reference herein).

 

(99.5)Co-lender Agreement, dated as of June 7, 2018, by andamong JPMorgan Chase Bank, National Association, as initial note A-1-A holder,initial note A-2-A-1 holder, initial note A-2-A-2 holder, initial note A-2-A-3holder, initial note A-2-A-4 holder, initial note A-2-A-5 holder and initialnote B-1 holder, Deutsche Bank, AG, New York Branch, as initial note A-1-Bholder, initial note A-2-B-1 holder, initial note A-2-B-2 holder, initial noteA-2-B-3 holder, initial note A-2-B-4 holder, initial note A-2-B-5 holder andinitial note B-2 holder, Wells Fargo Bank, National Association, as initialnote A-1-D holder, initial note A-2-D-1 holder, initial note A-2-D-2 holder,initial note A-2-D-3 holder, initial note A-2-D-4 holder, initial note A-2-D-5holder and initial note B-4 holder, and Morgan Stanley Bank, N.A., as initialnote A-1-C holder, initial note A-2-C-1 holder, initial note A-2-C-2 holder,initial note A-2-C-3 holder, initial note A-2-C-4 holder, initial note A-2-C-5holder and initial note B-3 holder, relating to the Aventura Mall loan combination(filed as Exhibit 99.5 to the registrant's Current Report on Form 8-K filed onOctober 23, 2018 under SEC File No. 333-206582-17 and incorporated by referenceherein).

 

(99.6)Agreement Between Note Holders, dated as of April 27,2018, by and between Bank of America, N.A. and KeyBank National Association,relating to the Griffin Portfolio II loan combination (filed as Exhibit 99.6 tothe registrant's Current Report on Form 8-K filed on October 23, 2018 under SECFile No. 333-206582-17 and incorporated by reference herein).

 

(99.7)Agreement Between Note Holders, dated as of August 9,2018, by and between Morgan Stanley Bank, N.A., as initial note A-1 holder,initial note A-2 holder, initial note A-3 holder, initial note A-4 holder,initial note A-5 holder and initial note A-6 holder, Morgan Stanley Bank, N.A.,as initial note B-1 holder, initial note B-2 holder, initial note B-3 holder,initial note B-4 holder, initial note B-5 holder and initial note B-6 holder,and Morgan Stanley Bank, N.A., as initial note C holder, relating to the MillenniumPartners Portfolio loan combination (filed as Exhibit 99.7 to the registrant'sCurrent Report on Form 8-K filed on October 23, 2018 under SEC File No.333-206582-17 and incorporated by reference herein).

 

(99.8)Agreement Between Note Holders, dated as of September27, 2018, by and between Morgan Stanley Bank, N.A., as initial note A-1 holder,and Morgan Stanley Bank, N.A., as initial note A-2 holder, relating to theNavika Six Portfolio loan combination (filed as Exhibit 99.8 to theregistrant's Current Report on Form 8-K filed on October 23, 2018 under SECFile No. 333-206582-17 and incorporated by reference herein).

 

(99.9)Agreement Between Noteholders, dated as of March 23,2018, by and between Deutsche Bank AG, New York Branch, as initial note A-1-Aholder and initial note A-1-B holder, Bank of America, N.A., as initial noteA-2-A holder and initial note A-2-B holder, Deutsche Bank AG, New York Branch,as initial note B-1-A holder and initial note B-1-B holder, Bank of America,N.A., as initial note B-2-A holder and initial note B-2-B holder, Deutsche BankAG, New York Branch, as initial note C-1 holder, and Bank of America, N.A., asinitial note C-2 holder, relating to The Gateway loan combination (filed asExhibit 99.9 to the registrant's Current Report on Form 8-K filed on October23, 2018 under SEC File No. 333-206582-17 and incorporated by referenceherein).

 

(99.10)Agreement Between Note Holders, dated as of July 27, 2018,by and between Morgan Stanley Bank, N.A., as initial note A-1 holder, andMorgan Stanley Bank, N.A., as initial note A-2 holder, relating to the PlazaFrontenac loan combination (filed as Exhibit 99.10 to the registrant's CurrentReport on Form 8-K filed on October 23, 2018 under SEC File No. 333-206582-17and incorporated by reference herein).

 

(99.11)Agreement Between Note Holders, dated as of October 23,2018, by and between Morgan Stanley Bank, N.A., as initial note A-1 holder, andMorgan Stanley Bank, N.A., as initial note A-2 holder, relating to the RegionsTower loan combination (filed as Exhibit 99.11 to the registrant's CurrentReport on Form 8-K filed on October 23, 2018 under SEC File No. 333-206582-17and incorporated by reference herein).

 

(99.12)Co-Lender Agreement, dated as of August 24, 2018, byand among Starwood Mortgage Capital LLC, as initial note A-1 holder, StarwoodMortgage Capital LLC, as initial note A-2 holder, Starwood Mortgage CapitalLLC, as initial note A-3 holder, Starwood Mortgage Capital LLC, as initial noteA-4 holder, and Starwood Mortgage Capital LLC, as initial note A-5 holder,relating to the Zenith Ridge loan combination (filed as Exhibit 99.12 to theregistrant's Current Report on Form 8-K filed on October 23, 2018 under SECFile No. 333-206582-17 and incorporated by reference herein).

 

(99.13)Agreement Between Noteholders, dated as of September24, 2018, by and among KeyBank National Association, as initial note A-1holder, and KeyBank National Association, initial note A-2 holder, relating tothe Alex Park South loan combination (filed as Exhibit 99.13 to theregistrant's Current Report on Form 8-K filed on October 23, 2018 under SECFile No. 333-206582-17 and incorporated by reference herein).

 

(99.14)Co-Lender Agreement, dated as of May 17, 2018, by andamong Starwood Mortgage Capital LLC, as initial note A-1 holder, StarwoodMortgage Capital LLC, as initial note A-2 holder, Starwood Mortgage CapitalLLC, as initial note A-3 holder, Starwood Mortgage Capital LLC, as initial noteA-4 holder, Starwood Mortgage Capital LLC, as initial note A-5 holder, andStarwood Mortgage Capital LLC, as initial note A-6 holder, relating to thePlaya Largo loan combination (filed as Exhibit 99.14 to the registrant'sCurrent Report on Form 8-K filed on October 23, 2018 under SEC File No.333-206582-17 and incorporated by reference herein).

 

(99.15)Co-Lender Agreement, dated as of October 11, 2018,between Cantor Commercial Real Estate Lending, L.P., as note A-1 holder, CantorCommercial Real Estate Lending, L.P., as note A-2 holder, Cantor CommercialReal Estate Lending, L.P., as note A-3 holder, Cantor Commercial Real EstateLending, L.P., as note A-4 holder, Cantor Commercial Real Estate Lending, L.P.,as note A-5 holder, Cantor Commercial Real Estate Lending, L.P., as note A-6holder, and Cantor Commercial Real Estate Lending, L.P., as note A-7 holder,relating to the Shelbourne Global Portfolio I loan combination (filed asExhibit 99.15 to the registrant's Current Report on Form 8-K filed on October23, 2018 under SEC File No. 333-206582-17 and incorporated by referenceherein).

 

(99.16)Agreement Between Note Holders, dated as of July 12,2018, by and between Morgan Stanley Bank, N.A., as initial note A-1 holder,Morgan Stanley Bank, N.A., as initial note A-2 holder, and Morgan Stanley Bank,N.A., as initial note A-3 holder, relating to the Shoppes at Chino Hills loancombination (filed as Exhibit 99.16 to the registrant's Current Report on Form8-K filed on October 23, 2018 under SEC File No. 333-206582-17 and incorporatedby reference herein).

 

(99.17)Primary Servicing Agreement, dated as of October 1,2018, by and between Midland Loan Services, a Division of PNC Bank, NationalAssociation, as master servicer, and KeyBank National Association, as primaryservicer (filed as Exhibit 99.17 to the registrant's Current Report on Form 8-Kfiled on October 23, 2018 under SEC File No. 333-206582-17 and incorporated byreference herein).

 

(99.18)Primary Servicing Agreement, dated as of October 1,2018, by and between Midland Loan Services, a Division of PNC Bank, NationalAssociation, as master servicer, and Berkeley Point Capital LLC d/b/a NewmarkKnight Frank, as primary servicer (filed as Exhibit 99.18 to the registrant'sCurrent Report on Form 8-K filed on October 23, 2018 under SEC File No.333-206582-17 and incorporated by reference herein).

 

(99.19)Second Amended and Restated Servicing Agreement,effective as of October 31, 2021, between Wells Fargo Bank, N.A., Wells FargoDelaware Trust Company, N.A., Computershare Trust Company, N.A., ComputershareDelaware Trust Company and Computershare Limited (filed as Exhibit 99.1 to theregistrant's Current Report on Form 8-K filed on November 5, 2021 under SECFile No. 333-206582-17 and incorporated by reference herein).

 

(b)See (a) above.

 

(c) NotApplicable.

 

**SIGNATURES**

 

Pursuantto the requirements of Section 13 or 15(d) of the Securities Exchange Act of1934, the registrant has duly caused this report to be signed on its behalf by theundersigned, thereunto duly authorized.

 

MorganStanley Capital I Inc.

(Depositor)

 

By:/s/ Jane Lam

JaneLam, Pesident

(seniorofficer in charge of securitization of the depositor)

 

Date: March 29, 2022