**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

**For the fiscal year ended December 31, 2019or**

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-206847-10**

**Central Index Key Number of the issuing entity:0001756271**

**BANK 2018-BNK15**

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

** **

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

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

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

** **

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

**Bank of America, NationalAssociation**

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

** **

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

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

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

**Wells Fargo Bank, NationalAssociation**

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

** **

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

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

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

** **

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

**the issuing entity)** | **38-4096495**

**38-4096496**

**38-7206265**

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

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

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

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(646) 855-3953**

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

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

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

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

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

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

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

Not applicable.

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

Not applicable.

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

Large accelerated filer       o                                                                                                 Acceleratedfiler                                  o

Non-acceleratedfiler         ⌧  (Do not check if a smaller reportingcompany)                        Smaller reporting company                          o

                                                                                                                                              Emerging growthcompany                          o

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

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 685 Fifth Avenue Retail Mortgage Loan,which constituted approximately 5.5% of the asset pool of the issuing entity asof its cut-off date, is an asset of the issuing entity and is part of a loancombination that includes the 685 Fifth Avenue Retail Mortgage Loan which is anasset of the issuing entity and one other *pari passu* loan, which is notan asset of the issuing entity. This loan combination, including the 685 FifthAvenue Retail Mortgage Loan, is being serviced and administered pursuant to thePooling and Servicing Agreement, which is incorporated by reference as Exhibit4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Aventura Mall Mortgage Loan, whichconstituted approximately 9.2% of the asset pool of the issuing entity as ofits cut-off date.  The Aventura Mall Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the AventuraMall Mortgage Loan and twenty-four other *pari passu* loans and foursubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Aventura MallTrust 2018-AVM transaction (the “Aventura Mall 2018-AVM Transaction”).This loan combination, including the Aventura Mall Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theAventura Mall 2018-AVM Transaction, which is incorporated by reference asExhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Pfizer Building Mortgage Loan, whichconstituted approximately 2.7% of the asset pool of the issuing entity as ofits cut-off date.  The Pfizer Building Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the PfizerBuilding Mortgage Loan and four other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BANK 2018-BNK13 transaction, Commission FileNumber 333-206677-26 (the “BANK 2018-BNK13 Transaction”). This loancombination, including the Pfizer Building Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2018-BNK13 Transaction, which is incorporated by reference as Exhibit 4.3 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Millennium Partners Portfolio Mortgage Loan,which constituted approximately 6.9% of the asset pool of the issuing entity asof its cut-off date.  The Millennium Partners Portfolio Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe Millennium Partners Portfolio Mortgage Loan and five other *pari passu*loans and six subordinate companion loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe Morgan Stanley Capital I Trust 2018-MP transaction (the “MSC 2018-MPTransaction”). This loan combination, including the Millennium PartnersPortfolio Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the MSC 2018-MP Transaction, which isincorporated by reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Prudential - Digital Realty PortfolioMortgage Loan, which constituted approximately 2.4% of the asset pool of theissuing entity as of its cut-off date.  The Prudential - Digital RealtyPortfolio Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Prudential - Digital Realty Portfolio MortgageLoan and four other *pari passu* loans, which are not assets of theissuing entity. A *pari passu* portion of the loan combination wassecuritized in the BANK 2018-BNK14 transaction, Commission File Number333-206582-16 (the “BANK 2018-BNK14 Transaction”). This loancombination, including the Prudential - Digital Realty Portfolio Mortgage Loan,is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2018-BNK14 Transaction, which is incorporated byreference as Exhibit 4.5 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Plaza Frontenac Mortgage Loan, whichconstituted approximately 1.8% of the asset pool of the issuing entity as ofits cut-off date.  The Plaza Frontenac Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the PlazaFrontenac Mortgage Loan and two other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Morgan Stanley Capital I Trust 2018-L1transaction, Commission File Number 333-206582-17 (the “MSC 2018-L1Transaction”). This loan combination, including the Plaza FrontenacMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the MSC 2018-L1 Transaction, which is incorporated byreference as Exhibit 4.6 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Starwood Hotel Portfolio Mortgage Loan,which constituted approximately 9.2% of the asset pool of the issuing entity asof its cut-off date.  The Starwood Hotel Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theStarwood Hotel Portfolio Mortgage Loan and three other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the Wells Fargo Commercial Mortgage Trust2018-C47 transaction, Commission File Number 333-226486-01 (the “WFCM2018-C47 Transaction”). This loan combination, including the Starwood HotelPortfolio Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the WFCM 2018-C47 Transaction, which isincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Moffett Towers – Buildings E,F,G MortgageLoan, which constituted approximately 5.2% of the asset pool of the issuingentity as of its cut-off date.  The Moffett Towers – Buildings E,F,GMortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Moffett Towers – Buildings E,F,G Mortgage Loanand eight other *pari passu* loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe DBGS 2018-C1 Mortgage Trust transaction, Commission File Number333-206705-16 (the “DBGS 2018-C1 Transaction”). This loan combination,including the Moffett Towers – Buildings E,F,G Mortgage Loan, is being servicedand administered pursuant to the pooling and servicing agreement for the DBGS2018-C1 Transaction, which is incorporated by reference as Exhibit 4.8 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the 2020 Fifth Avenue Mortgage Loan, which constitutedapproximately 2.2% of the asset pool of the issuing entity as of its cut-offdate.  The 2020 Fifth Avenue Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the 2020 Fifth AvenueMortgage Loan and one other *pari passu* loan, which is not an asset ofthe issuing entity. The other *pari passu* portion of the loan combinationwas securitized in the CSAIL 2018-C14 Commercial Mortgage Trust transaction,Commission File Number 333-207361-10 (the “CSAIL 2018-C14 Transaction”).This loan combination, including the 2020 Fifth Avenue Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe CSAIL 2018-C14 Transaction, which is incorporated by reference as Exhibit4.9 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Carriage Place Mortgage Loan, whichconstituted approximately 0.9% of the asset pool of the issuing entity as ofits cut-off date.  The Carriage Place Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the CarriagePlace Mortgage Loan and one other *pari passu* loan, which is not an assetof the issuing entity. This loan combination, including the Carriage PlaceMortgage Loan, was serviced under the Pooling and Servicing Agreement for theissuing entity prior to the closing of the securitization of the other *paripassu* portion of the Carriage Place loan combination in the BANK 2019-BNK16transaction, Commission File Number 333-226486-03 (the “BANK 2019-BNK16Transaction”).  After the closing of the BANK 2019-BNK16 Transactionon February 21, 2019, this loan combination, including the Carriage PlaceMortgage Loan was, and will continue to be, serviced and administered pursuantto the pooling and servicing agreement with respect to the BANK 2019-BNK16Transaction, which is incorporated by reference as Exhibit 4.10 to this AnnualReport on Form 10-K.

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

Wells Fargo Bank, NationalAssociation is the general master servicer and the certificate administrator ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theprimary servicer of the Starwood Hotel Portfolio Mortgage Loan, the AventuraMall Mortgage Loan, the Moffett Towers – Buildings E,F,G Mortgage Loan, thePfizer Building Mortgage Loan, the Prudential - Digital Realty PortfolioMortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage PlaceMortgage Loan and the primary servicer and special servicer of the MillenniumPartners Portfolio Mortgage Loan. As a result, Wells Fargo Bank, NationalAssociation is a “servicer” as defined in Item 1108(a)(2)(iii) of RegulationAB, in the capacities described above, because it is servicing mortgage loansthat constituted 10% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theStarwood Hotel Portfolio Mortgage Loan, the Aventura Mall Mortgage Loan, theMillennium Partners Portfolio Mortgage Loan, the Moffett Towers – BuildingsE,F,G Mortgage Loan, the Pfizer Building Mortgage Loan, the Prudential -Digital Realty Portfolio Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan,the Plaza Frontenac Mortgage Loan and the Carriage Place Mortgage Loan. As a result, Wells Fargo Bank, National Association is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the special servicer of the mortgage loansserviced under the Pooling and Servicing Agreement, the primary servicer andspecial servicer of the Plaza Frontenac Mortgage Loan and the special servicerof the Starwood Hotel Portfolio Mortgage Loan. As a result, Midland LoanServices, a Division of PNC Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria, accountants’ attestation reportsand servicer compliance statements delivered by Midland Loan Services, aDivision of PNC Bank, National Association in the capacities described aboveare listed in the Exhibit Index.

Wells Fargo Bank, National Associationis the custodian of the mortgage loans serviced under the Pooling and ServicingAgreement, the Aventura Mall Mortgage Loan, the Starwood Hotel PortfolioMortgage Loan, the Millennium Partners Portfolio Mortgage Loan, the MoffettTowers – Buildings E,F,G Mortgage Loan, the Pfizer Building Mortgage Loan, thePrudential - Digital Realty Portfolio Mortgage Loan, the 2020 Fifth AvenueMortgage Loan and the trustee and custodian of the Plaza Frontenac MortgageLoan. As a result, Wells Fargo Bank, National Association is servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Wells Fargo Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the Moffett Towers – Buildings E,F,G Mortgage Loan, thePrudential - Digital Realty Portfolio Mortgage Loan and the 2020 Fifth AvenueMortgage Loan. These mortgage loans constitute more than 5%, but less than 10%,of the pool assets of the issuing entity.  Therefore, the Depositorincluded in this Annual Report on Form 10-K an assessment of compliance withapplicable servicing criteria for Rialto Capital Advisors, LLC and anaccountants’ attestation report pursuant to Item 1122 of Regulation AB becauseit is servicing more than 5% of the pool assets.  However, the Depositoris not required to include in this Annual Report on Form 10-K a servicercompliance statement pursuant to Item 1123 of Regulation AB of Rialto CapitalAdvisors, LLC because it is an unaffiliated servicer servicing less than 10% ofpool assets.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theStarwood Hotel Portfolio Mortgage Loan, the Aventura Mall Mortgage Loan, theMoffett Towers – Buildings E,F,G Mortgage Loan, the Prudential - Digital RealtyPortfolio Mortgage Loan and the Carriage Place Mortgage Loan.  As aresult, Park Bridge Lender Services LLC is a servicing function participant inthe capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of thePfizer Building Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and thePlaza Frontenac Mortgage Loan.  As a result, Pentalpha Surveillance LLC isa servicing function participant in the capacities described above, because itis servicing mortgage loans that constituted 5% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria and accountants’ attestation reports delivered byPentalpha Surveillance LLC in the capacities described above are listed in theExhibit Index.

National Cooperative Bank, N.A., the NCB master servicer andNCB special servicer, is also a sponsor. Therefore, the Depositor included inthis Annual Report on Form 10-K a servicer compliance statement for NationalCooperative Bank, N.A. pursuant to Item 1123.  Because NationalCooperative Bank, N.A. is servicing less than 5% of the pool assets, anassessment of compliance with applicable servicing criteria and an accountants’attestation report pursuant to Item 1122 of Regulation AB are not required byRegulation AB. As the attestation made in the servicer compliance statement requiredby Item 1123 relates to a review of the servicing activities of NationalCooperative Bank, N.A. under the applicable servicing agreement, and thatreview was conducted in conjunction with the servicer’s preparation of itsassessment of compliance with applicable servicing criteria, that assessment ofcompliance with applicable servicing criteria and the accompanying accountants’attestation report are included in this Annual Report on Form 10-K for the sakeof completeness.

Wilmington Trust, National Associationacts as trustee of the mortgage loans serviced under the Pooling and ServicingAgreement, the Aventura Mall Mortgage Loan, the Pfizer Building Mortgage Loan,the Millennium Partners Portfolio Mortgage Loan, the Prudential - DigitalRealty Portfolio Mortgage Loan, the Starwood Hotel Portfolio Mortgage Loan, theMoffett Towers – Buildings E,F,G Mortgage Loan, the 2020 Fifth Avenue MortgageLoan and the Carriage Place Mortgage Loan.  Pursuant to the Pooling andServicing Agreement, the trust and servicing agreement for the Aventura Mall2018-AVM Transaction, the pooling and servicing agreement for the BANK2018-BNK13 Transaction, the trust and servicing agreement for the MSC 2018-MPTransaction, the pooling and servicing agreement for the BANK 2018-BNK14Transaction, the pooling and servicing agreement for the WFCM 2018-C47Transaction, the pooling and servicing agreement for the DBGS 2018-C1Transaction, the pooling and servicing agreement for the CSAIL 2018-C14Transaction and the pooling and servicing agreement for the BANK 2019-BNK16Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theAventura Mall Mortgage Loan, the Pfizer Building Mortgage Loan, the MillenniumPartners Portfolio Mortgage Loan, the Prudential - Digital Realty PortfolioMortgage Loan, the Starwood Hotel Portfolio Mortgage Loan, the Moffett Towers –Buildings E,F,G Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and theCarriage Place Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wells Fargo Bank, NationalAssociation acts as trustee of the Plaza Frontenac Mortgage Loan. Pursuant to the pooling and servicing agreement for the MSC 2018-L1Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the Subject Transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe mortgage loans serviced under the Pooling and Servicing Agreement havedelivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real Estate Services,Inc. and National Tax Search, LLC.  These entities were engaged by theprimary servicer of the Aventura Mall Mortgage Loan, the Pfizer BuildingMortgage Loan, the Millennium Partners Portfolio Mortgage Loan, the Prudential- Digital Realty Portfolio Mortgage Loan, the Starwood Hotel Portfolio MortgageLoan, the Moffett Towers – Buildings E,F,G Mortgage Loan, the 2020 Fifth AvenueMortgage Loan and the Carriage Place Mortgage Loan to remit tax paymentsreceived from the escrow accounts of borrowers to local taxing authorities, toreport tax amounts due, to verify tax parcel information, and to verifynon-escrow tax payments. These servicing functions are included within theservicing criteria set forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) ofRegulation AB.  Therefore, under the principles-based definition of“servicer” set forth in Item 1101(j) of Regulation AB that looks to thefunctions that an entity performs, these vendors are “servicers” for thepurposes of Item 1122 of Regulation AB.  *See* Compliance andDisclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Aventura Mall Mortgage Loan, the Pfizer Building MortgageLoan, the Millennium Partners Portfolio Mortgage Loan, the Prudential - DigitalRealty Portfolio Mortgage Loan, the Plaza Frontenac Mortgage Loan, the StarwoodHotel Portfolio Mortgage Loan, the Moffett Towers – Buildings E,F,G MortgageLoan, the 2020 Fifth Avenue Mortgage Loan and the Carriage Place Mortgage Loanlisted on the Exhibit Index are omitted from this Annual Report on Form 10-K asthe certificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Aventura Mall Mortgage Loan, the PfizerBuilding Mortgage Loan, the Prudential - Digital Realty Portfolio MortgageLoan, the Moffett Towers – Buildings E,F,G Mortgage Loan, the 2020 Fifth AvenueMortgage Loan and the Carriage Place Mortgage Loan, (i) the reports onassessment of compliance with servicing criteria and attestation reports onassessment of compliance with servicing criteria of Torchlight Loan Services,LLC as special servicer of the Pfizer Building Mortgage Loan and KeyBankNational Association, as special servicer of the Carriage Place Mortgage Loan,listed on the Exhibit Index are omitted from this Annual Report on Form 10-K asthey are not required to be included on this Annual Report on Form 10-K perInstruction 3 to Item 1122 of Regulation AB because they are parties performingactivities that address servicing criteria relating to 5% or less of the assetsof the issuing entity; and (ii) the servicer compliance statements of CWCapitalAsset Management LLC as special servicer of the Aventura Mall Mortgage Loan,Torchlight Loan Services, LLC as special servicer of the Pfizer BuildingMortgage Loan, Rialto Capital Advisors, LLC as special servicer of thePrudential - Digital Realty Portfolio Mortgage Loan, the Moffett Towers –Buildings E,F,G Mortgage Loan and the 2020 Fifth Avenue Mortgage Loan andKeyBank National Association, as special servicer of the Carriage PlaceMortgage Loan, listed on the Exhibit Index are omitted from this Annual Reporton Form 10-K as they are not required by Item 1123 of Regulation AB to beincluded on this Annual Report on Form 10-K because they are each anunaffiliated party that is not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

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

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

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

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

The registrant knows of no material pending legal proceedinginvolving the trust or any party related to the trust, other than routinelitigation incidental to the duties of those respective parties, and the following,with respect to Wells Fargo Bank, National Association, as trustee, ascertificate administrator and as custodian.

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts atissue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such 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 RMBStrusts.

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on November 29, 2018 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Aventura Mall Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the Aventura Mall 2018-AVM Transaction, are attached hereto underItem 15 to this Annual Report on Form 10-K. Attached as Exhibit L to the trustand servicing agreement for the Aventura Mall 2018-AVM Transaction incorporatedby reference as Exhibit 4.2 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the AventuraMall 2018-AVM Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Pfizer Building Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2018-BNK13 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the poolingand servicing agreement for the BANK 2018-BNK13 Transaction incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BANK2018-BNK13 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Millennium Partners PortfolioMortgage Loan, which is being serviced and administered pursuant to the trustand servicing agreement for the MSC 2018-MP Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the MSC 2018-MP Transaction incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSC2018-MP Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Prudential - Digital RealtyPortfolio Mortgage Loan, which is being serviced and administered pursuant to thepooling and servicing agreement for the BANK 2018-BNK14 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit Z to the pooling and servicing agreement for the BANK 2018-BNK14Transaction incorporated by reference as Exhibit 4.5 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the BANK 2018-BNK14 Transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Plaza Frontenac Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the MSC 2018-L1 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the MSC 2018-L1 Transaction incorporated by referenceas Exhibit 4.6 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the MSC 2018-L1 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Starwood Hotel Portfolio MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the WFCM 2018-C47 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2018-C47 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2018-C47 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Moffett Towers – Buildings E,F,GMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the DBGS 2018-C1 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Schedule II tothe pooling and servicing agreement for the DBGS 2018-C1 Transaction incorporatedby reference as Exhibit 4.8 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the DBGS2018-C1 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 2020 Fifth Avenue Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the CSAIL 2018-C14 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the CSAIL 2018-C14 Transaction incorporated byreference as Exhibit 4.9 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CSAIL2018-C14 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Carriage Place Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2019-BNK16 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit Z to the pooling andservicing agreement for the BANK 2019-BNK16 Transaction incorporated byreference as Exhibit 4.10 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BANK2019-BNK16 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The report on assessment of compliance with applicableservicing criteria furnished pursuant to Item 1122 of Regulation AB by MidlandLoan Services, a Division of PNC Bank National Association (“Midland”)discloses that a material instance of noncompliance occurred, as describedbelow:

Material Instance of Noncompliance

In certain instances, the ScheduleAL Files (Item 1125 of Regulation AB) were not reported in accordance with theterms specified in the transaction agreements, in conflict with Item1122(d)(3)(i): “Reports to investors, including those to be filed with theCommission, are maintained in accordance with the transaction agreements andapplicable Commission requirements. Specifically, such reports: (A) Areprepared in accordance with timeframes and other terms set forth in thetransaction agreements”.  The noncompliance consisted of omitted orinaccurately reported fields as described in (1) and (2) below.  (1) Inconnection with other enhancements Midland made to its manual Schedule ALprocess, starting in April 2019, Midland developed and implemented new ScheduleAL reporting templates for each applicable CMBS transaction that closed priorto April 2019 and for each applicable CMBS transaction going forward. Related to this, Midland made certain template setup errors, along with relatedand other manual inputting of information errors, and the errors were notidentified prior to submission of the applicable Schedule AL Files in certaincases due to breakdowns in quality control.  (2) In one applicabletransaction, the related Schedule AL File for a given month was not savedproperly resulting in the prior month's Schedule AL File being submitted forthe given month instead of the correct Schedule AL File. 

The identified instances did notinvolve the servicing of assets included in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reportingprocess was enhanced in April of 2019, however, the process remained manual throughoutthe 2019 calendar year.  Errors relating to certain Schedule AL Filesduring 2019 were identified during the related audit.  Followingidentification, Midland made staffing changes and additional enhancements andimprovements to its processes and procedures to support its Schedule ALreporting obligations and expects to move to an automated solution for thisprocess.  

Midland is currently remediating theSchedule AL reporting for certain of the CMBS transactions found to beincorrect.

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

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

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of November 1, 2018, by and among Banc ofAmerica Merrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank,National Association, as General Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, as General Special Servicer, NationalCooperative Bank, N.A., as NCB Master Servicer and as NCB Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.1 to the registrant’s Current Report on Form 8-K filed on November29, 2018 under Commission File No. 333-206847-10 and incorporated by referenceherein).

4.2          Trustand Servicing Agreement, dated as of June 29, 2018, by and among J.P. MorganChase Commercial Mortgage Securities Corp., as Depositor, Wells Fargo Bank,National Association, as Servicer, CWCapital Asset Management 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 (filed as Exhibit 4.2 to the registrant’sCurrent Report on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of August 1, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, Torchlight Loan Services, LLC, asGeneral Special Servicer, National Cooperative Bank, N.A., as NCB MasterServicer and as NCB Special Servicer, Wells Fargo Bank, National Association,as Certificate Administrator, Wilmington Trust, National Association, asTrustee, and Pentalpha Surveillance LLC, as Operating Advisor and as AssetRepresentations Reviewer (filed as Exhibit 4.6 to the registrant’s CurrentReport on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

4.4          Trustand Servicing Agreement, dated as of August 7, 2018, by and among MorganStanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association,as Servicer and Special Servicer, Wilmington Trust, National Association, asTrustee, and Wells Fargo Bank, National Association, as CertificateAdministrator and Custodian, (filed as Exhibit 4.4 to the registrant’s CurrentReport on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

4.5          Poolingand Servicing Agreement, dated as of September 1, 2018, by and among MorganStanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association,as General Master Servicer, Rialto Capital Advisors, LLC, as General SpecialServicer, National Cooperative Bank, N.A., as NCB Master Servicer and as NCBSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and as Asset Representations Reviewer(filed as Exhibit 4.7 to the registrant’s Current Report on Form 8-K filed onNovember 29, 2018 under Commission File No. 333-206847-10 and incorporated byreference herein).

4.6          Poolingand Servicing Agreement, dated as of October 1, 2018, by and among MorganStanley Capital I Inc., as Depositor, Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer and Special Servicer, Wells FargoBank, National Association, as Certificate Administrator and Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.9 to the registrant’s Current Report on Form 8-Kfiled on November 29, 2018 under Commission File No. 333-206847-10 andincorporated by reference herein).

4.7          Poolingand Servicing Agreement, dated as of October 1, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.3 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.8          Poolingand Servicing Agreement, dated as of October 1, 2018, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, asSpecial Servicer, Wilmington Trust, National Association, as Trustee, WellsFargo Bank, National Association, as Certificate Administrator, Paying Agentand Custodian, and Park Bridge Lender Services LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 4.5 to the registrant’s CurrentReport on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

4.9          Poolingand Servicing Agreement, dated as of November 1, 2018, by and among CreditSuisse Commercial Mortgage Securities Corp., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.8 to the registrant’s Current Report on Form 8-Kfiled on November 29, 2018 under Commission File No. 333-206847-10 andincorporated by reference herein).

4.10       Poolingand Servicing Agreement, dated as of February 1, 2019, among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, KeyBank National Association, asGeneral Special Servicer, National Cooperative Bank, N.A., as NCB MasterServicer and as NCB Special Servicer, Wells Fargo Bank, National Association,as Certificate Administrator, Wilmington Trust, National Association, as Trustee,and Park Bridge Lender Services LLC, as Operating Advisor and as AssetRepresentations Reviewer (filed as Exhibit 4.1 to the registrant’s CurrentReport on Form 8-K/A filed on March 18, 2019 under Commission File No.333-206847-10 and incorporated by reference herein).

4.11        Co-LenderAgreement, dated as of June 7, 2018, by and among JPMorgan Chase Bank, NationalAssociation, Deutsche Bank, AG, New York Branch, Wells Fargo Bank, NationalAssociation and Morgan Stanley Bank, N.A. (filed as Exhibit 4.10 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.12        AgreementBetween Note Holders, dated as of September 27, 2018, by and between WellsFargo Bank, National Association, as Initial Note A-1 Holder, Wells Fargo Bank,National Association, as Initial Note A-2 Holder, Wells Fargo Bank, NationalAssociation, as Initial Note A-3 Holder, and Wells Fargo Bank, NationalAssociation, as Initial Note A-4 Holder (filed as Exhibit 4.11 to the registrant’sCurrent Report on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

4.13        AgreementBetween Note Holders, dated as of August 9, 2018, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial NoteA-3 Holder, Initial Note A-4 Holder, Initial Note A-5 Holder and Initial NoteA-6 Holder, and Morgan Stanley Bank, N.A., as Initial Note B-1 Holder, InitialNote B-2 Holder, Initial Note B-3 Holder, Initial Note B-4 Holder, Initial NoteB-5 Holder and Initial Note B-6 Holder (filed as Exhibit 4.12 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.14        Amendedand Restated Agreement Between Note Holders, dated as of September 26, 2018, byand between Bank of America, N.A., as Initial Note A-1 Holder, and Bank ofAmerica, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.13 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.15        Co-LenderAgreement, dated as of October 30, 2018, by and among Deutsche Bank AG, actingthrough its New York Branch, as Note A-1-1 Holder, Deutsche Bank AG, actingthrough its New York Branch, as Note A-1-2 Holder, Deutsche Bank AG, actingthrough its New York Branch, as Note A-1-3 Holder, Deutsche Bank AG, actingthrough its New York Branch, as Note A-1-4 Holder, Deutsche Bank AG, actingthrough its New York Branch, as Note A-2 Holder, Deutsche Bank AG, actingthrough its New York Branch, as Note A-3 Holder, Deutsche Bank AG, acting throughits New York Branch, as Note A-4 Holder, Goldman Sachs Mortgage Company, asNote A-5 Holder, Wells Fargo Bank, National Association, as Note A-6 Holder,and Wells Fargo Bank, National Association, as Note A-7 Holder (filed asExhibit 4.14 to the registrant’s Current Report on Form 8-K filed on November29, 2018 under Commission File No. 333-206847-10 and incorporated by referenceherein).

4.16        AgreementBetween Note Holders, dated as of July 27, 2018, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Morgan Stanley Bank, N.A., as InitialNote A-2 Holder, Morgan Stanley Bank, N.A., as Initial Note A-3 Holder, MorganStanley Bank, N.A., as Initial Note A-4 Holder, and Morgan Stanley Bank, N.A.,as Initial Note A-5 Holder (filed as Exhibit 4.15 to the registrant’s CurrentReport on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

4.17        AgreementBetween Note Holders, dated as of September 7, 2018, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder and Initial Note A-2Holder, and Column Financial, Inc., as Initial Note A-3 Holder and Initial NoteA-4 Holder (filed as Exhibit 4.16 to the registrant’s Current Report on Form8-K filed on November 29, 2018 under Commission File No. 333-206847-10 andincorporated by reference herein).

4.18        AgreementBetween Note Holders, dated as of August 22, 2018, by and between ColumnFinancial, Inc., as Initial Note A-1 Holder, and Wells Fargo Bank, NationalAssociation, as Initial Note A-2 Holder (filed as Exhibit 4.17 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.19        AgreementBetween Note Holders, dated as of July 27, 2018, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, and Morgan Stanley Bank, as InitialNote A-2 Holder (filed as Exhibit 4.18 to the registrant’s Current Report onForm 8-K filed on November 29, 2018 under Commission File No. 333-206847-10 andincorporated by reference herein).

4.20        AgreementBetween Note Holders, dated as of November 2, 2018, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, and Bank of America, N.A., asInitial Note A-2 Holder (filed as Exhibit 4.19 to the registrant’s CurrentReport on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

 

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

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

33.1       Wells Fargo Bank, NationalAssociation, as General Master Servicer

33.2       National Cooperative Bank,N.A., as NCB Master Servicer

33.3       Midland Loan Services, aDivision of PNC Bank, National Association, as General Special Servicer

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

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

33.6       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.7       Wells Fargo Bank, NationalAssociation, as Custodian

33.8       Park Bridge LenderServices LLC, as Operating Advisor

33.9       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

33.10     National Tax Search, LLC,as Servicing Function Participant

33.11     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 685 Fifth Avenue Retail Mortgage Loan(see Exhibit 33.1)

33.12     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan (see Exhibit 33.3)

33.13     Wilmington Trust, National Association, as Trustee of the 685 Fifth AvenueRetail Mortgage Loan (Omitted. See Explanatory Notes.)

33.14     Wells Fargo Bank, NationalAssociation, as Custodian of the 685 Fifth Avenue Retail Mortgage Loan (seeExhibit 33.7)

33.15     Park Bridge LenderServices LLC, as Operating Advisor of the 685 Fifth Avenue Retail Mortgage Loan(see Exhibit 33.8)

33.16     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 685 FifthAvenue Retail Mortgage Loan (see Exhibit 33.9)

33.17     National Tax Search, LLC,as Servicing Function Participant of the 685 Fifth Avenue Retail Mortgage Loan(see Exhibit 33.10)

33.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Aventura Mall Mortgage Loan (seeExhibit 33.1)

33.19     CWCapital AssetManagement LLC, as Special Servicer of the Aventura Mall Mortgage Loan

33.20     Wilmington Trust, National Association, as Trustee of the Aventura MallMortgage Loan (Omitted. See Explanatory Notes.)

33.21     Wells Fargo Bank, NationalAssociation, as Custodian of the Aventura Mall Mortgage Loan (see Exhibit 33.7)

33.22     Park Bridge LenderServices LLC, as Operating Advisor of the Aventura Mall Mortgage Loan (seeExhibit 33.8)

33.23     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Aventura MallMortgage Loan (see Exhibit 33.9)

33.24     National Tax Search, LLC,as Servicing Function Participant of the Aventura Mall Mortgage Loan (seeExhibit 33.10)

33.25     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Pfizer Building Mortgage Loan (seeExhibit 33.1)

33.26     Torchlight Loan Services, LLC, as Special Servicer of the Pfizer BuildingMortgage Loan (Omitted. See Explanatory Notes.)

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

33.28     Wells Fargo Bank, NationalAssociation, as Custodian of the Pfizer Building Mortgage Loan (see Exhibit33.7)

33.29     Pentalpha SurveillanceLLC, as Operating Advisor of the Pfizer Building Mortgage Loan

33.30     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Pfizer BuildingMortgage Loan (see Exhibit 33.9)

33.31     National Tax Search, LLC,as Servicing Function Participant of the Pfizer Building Mortgage Loan (seeExhibit 33.10)

33.32     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Millennium Partners Portfolio MortgageLoan (see Exhibit 33.1)

33.33     Wells Fargo Bank, NationalAssociation, as Special Servicer of the Millennium Partners Portfolio MortgageLoan (see Exhibit 33.1)

33.34     Wilmington Trust, National Association, as Trustee of the Millennium PartnersPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.35     Wells Fargo Bank, NationalAssociation, as Custodian of the Millennium Partners Portfolio Mortgage Loan(see Exhibit 33.7)

33.36     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the MillenniumPartners Portfolio Mortgage Loan (see Exhibit 33.9)

33.37     National Tax Search, LLC,as Servicing Function Participant of the Millennium Partners Portfolio MortgageLoan (see Exhibit 33.10)

33.38     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Prudential - Digital Realty PortfolioMortgage Loan (see Exhibit 33.1)

33.39     Rialto Capital Advisors,LLC, as Special Servicer of the Prudential - Digital Realty Portfolio MortgageLoan

33.40     Wilmington Trust, National Association, as Trustee of the Prudential - DigitalRealty Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.41     Wells Fargo Bank, NationalAssociation, as Custodian of the Prudential - Digital Realty Portfolio MortgageLoan (see Exhibit 33.7)

33.42     Park Bridge LenderServices LLC, as Operating Advisor of the Prudential - Digital Realty PortfolioMortgage Loan (see Exhibit 33.8)

33.43     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Prudential -Digital Realty Portfolio Mortgage Loan (see Exhibit 33.9)

33.44     National Tax Search, LLC,as Servicing Function Participant of the Prudential - Digital Realty PortfolioMortgage Loan (see Exhibit 33.10)

33.45     Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PlazaFrontenac Mortgage Loan (see Exhibit 33.3)

33.46     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PlazaFrontenac Mortgage Loan (see Exhibit 33.3)

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

33.48     Wells Fargo Bank, NationalAssociation, as Custodian of the Plaza Frontenac Mortgage Loan (see Exhibit33.7)

33.49     Pentalpha SurveillanceLLC, as Operating Advisor of the Plaza Frontenac Mortgage Loan (see Exhibit33.29)

33.50     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Starwood Hotel Portfolio Mortgage Loan(see Exhibit 33.1)

33.51     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the StarwoodHotel Portfolio Mortgage Loan (see Exhibit 33.3)

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

33.53     Wells Fargo Bank, NationalAssociation, as Custodian of the Starwood Hotel Portfolio Mortgage Loan (seeExhibit 33.7)

33.54     Park Bridge LenderServices LLC, as Operating Advisor of the Starwood Hotel Portfolio MortgageLoan (see Exhibit 33.8)

33.55     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Starwood HotelPortfolio Mortgage Loan (see Exhibit 33.9)

33.56     National Tax Search, LLC,as Servicing Function Participant of the Starwood Hotel Portfolio Mortgage Loan(see Exhibit 33.10)

33.57     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Moffett Towers – Buildings E,F,GMortgage Loan (see Exhibit 33.1)

33.58     Rialto Capital Advisors,LLC, as Special Servicer of the Moffett Towers – Buildings E,F,G Mortgage Loan(see Exhibit 33.39)

33.59     Wilmington Trust, National Association, as Trustee of the Moffett Towers –Buildings E,F,G Mortgage Loan (Omitted. See Explanatory Notes.)

33.60     Wells Fargo Bank, NationalAssociation, as Custodian of the Moffett Towers – Buildings E,F,G Mortgage Loan(see Exhibit 33.7)

33.61     Park Bridge LenderServices LLC, as Operating Advisor of the Moffett Towers – Buildings E,F,GMortgage Loan (see Exhibit 33.8)

33.62     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Moffett Towers– Buildings E,F,G Mortgage Loan (see Exhibit 33.9)

33.63     National Tax Search, LLC,as Servicing Function Participant of the Moffett Towers – Buildings E,F,GMortgage Loan (see Exhibit 33.10)

33.64     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 2020 Fifth Avenue Mortgage Loan (seeExhibit 33.1)

33.65     Rialto Capital Advisors,LLC, as Special Servicer of the 2020 Fifth Avenue Mortgage Loan (see Exhibit33.39)

33.66     Wilmington Trust, National Association, as Trustee of the 2020 Fifth AvenueMortgage Loan (Omitted. See Explanatory Notes.)

33.67     Wells Fargo Bank, NationalAssociation, as Custodian of the 2020 Fifth Avenue Mortgage Loan (see Exhibit33.7)

33.68     Pentalpha SurveillanceLLC, as Operating Advisor of the 2020 Fifth Avenue Mortgage Loan (see Exhibit33.29)

33.69     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 2020 FifthAvenue Mortgage Loan (see Exhibit 33.9)

33.70     National Tax Search, LLC,as Servicing Function Participant of the 2020 Fifth Avenue Mortgage Loan (seeExhibit 33.10)

33.71     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Carriage Place Mortgage Loan (seeExhibit 33.1)

33.72     KeyBank National Association, as Special Servicer of the Carriage PlaceMortgage Loan (Omitted. See Explanatory Notes.)

33.73     Wilmington Trust, National Association, as Trustee of the Carriage Place MortgageLoan (Omitted. See Explanatory Notes.)

33.74     Wells Fargo Bank, NationalAssociation, as Custodian of the Carriage Place Mortgage Loan (see Exhibit33.7)

33.75     Park Bridge LenderServices LLC, as Operating Advisor of the Carriage Place Mortgage Loan (seeExhibit 33.8)

33.76     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Carriage PlaceMortgage Loan (see Exhibit 33.9)

33.77     National Tax Search, LLC,as Servicing Function Participant of the Carriage Place Mortgage Loan (seeExhibit 33.10)

34          Attestation reports onassessment of compliance with servicing criteria for asset-backed securities.

34.1       Wells Fargo Bank, NationalAssociation, as General Master Servicer

34.2       National Cooperative Bank,N.A., as NCB Master Servicer

34.3       Midland Loan Services, aDivision of PNC Bank, National Association, as General Special Servicer

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

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

34.6       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.7       Wells Fargo Bank, NationalAssociation, as Custodian

34.8       Park Bridge LenderServices LLC, as Operating Advisor

34.9       CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant

34.10     National Tax Search, LLC,as Servicing Function Participant

34.11     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 685 Fifth Avenue Retail Mortgage Loan(see Exhibit 34.1)

34.12     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan (see Exhibit 34.3)

34.13     Wilmington Trust, National Association, as Trustee of the 685 Fifth AvenueRetail Mortgage Loan (Omitted. See Explanatory Notes.)

34.14     Wells Fargo Bank, NationalAssociation, as Custodian of the 685 Fifth Avenue Retail Mortgage Loan (seeExhibit 34.7)

34.15     Park Bridge LenderServices LLC, as Operating Advisor of the 685 Fifth Avenue Retail Mortgage Loan(see Exhibit 34.8)

34.16     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 685 FifthAvenue Retail Mortgage Loan (see Exhibit 34.9)

34.17     National Tax Search, LLC,as Servicing Function Participant of the 685 Fifth Avenue Retail Mortgage Loan(see Exhibit 34.10)

34.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Aventura Mall Mortgage Loan (seeExhibit 34.1)

34.19     CWCapital AssetManagement LLC, as Special Servicer of the Aventura Mall Mortgage Loan

34.20     Wilmington Trust, National Association, as Trustee of the Aventura MallMortgage Loan (Omitted. See Explanatory Notes.)

34.21     Wells Fargo Bank, NationalAssociation, as Custodian of the Aventura Mall Mortgage Loan (see Exhibit 34.7)

34.22     Park Bridge Lender ServicesLLC, as Operating Advisor of the Aventura Mall Mortgage Loan (see Exhibit 34.8)

34.23     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Aventura Mall MortgageLoan (see Exhibit 34.9)

34.24     National Tax Search, LLC,as Servicing Function Participant of the Aventura Mall Mortgage Loan (seeExhibit 34.10)

34.25     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Pfizer Building Mortgage Loan (seeExhibit 34.1)

34.26     Torchlight Loan Services, LLC, as Special Servicer of the Pfizer BuildingMortgage Loan (Omitted. See Explanatory Notes.)

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

34.28     Wells Fargo Bank, NationalAssociation, as Custodian of the Pfizer Building Mortgage Loan (see Exhibit34.7)

34.29     Pentalpha SurveillanceLLC, as Operating Advisor of the Pfizer Building Mortgage Loan

34.30     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Pfizer BuildingMortgage Loan (see Exhibit 34.9)

34.31     National Tax Search, LLC,as Servicing Function Participant of the Pfizer Building Mortgage Loan (seeExhibit 34.10)

34.32     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Millennium Partners Portfolio MortgageLoan (see Exhibit 34.1)

34.33     Wells Fargo Bank, NationalAssociation, as Special Servicer of the Millennium Partners Portfolio MortgageLoan (see Exhibit 34.1)

34.34     Wilmington Trust, National Association, as Trustee of the Millennium PartnersPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.35     Wells Fargo Bank, NationalAssociation, as Custodian of the Millennium Partners Portfolio Mortgage Loan(see Exhibit 34.7)

34.36     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the MillenniumPartners Portfolio Mortgage Loan (see Exhibit 34.9)

34.37     National Tax Search, LLC,as Servicing Function Participant of the Millennium Partners Portfolio MortgageLoan (see Exhibit 34.10)

34.38     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Prudential - Digital Realty PortfolioMortgage Loan (see Exhibit 34.1)

34.39     Rialto Capital Advisors,LLC, as Special Servicer of the Prudential - Digital Realty Portfolio MortgageLoan

34.40     Wilmington Trust, National Association, as Trustee of the Prudential - DigitalRealty Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.41     Wells Fargo Bank, NationalAssociation, as Custodian of the Prudential - Digital Realty Portfolio MortgageLoan (see Exhibit 34.7)

34.42     Park Bridge LenderServices LLC, as Operating Advisor of the Prudential - Digital Realty PortfolioMortgage Loan (see Exhibit 34.8)

34.43     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Prudential -Digital Realty Portfolio Mortgage Loan (see Exhibit 34.9)

34.44     National Tax Search, LLC,as Servicing Function Participant of the Prudential - Digital Realty PortfolioMortgage Loan (see Exhibit 34.10)

34.45     Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PlazaFrontenac Mortgage Loan (see Exhibit 34.3)

34.46     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PlazaFrontenac Mortgage Loan (see Exhibit 34.3)

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

34.48     Wells Fargo Bank, NationalAssociation, as Custodian of the Plaza Frontenac Mortgage Loan (see Exhibit34.7)

34.49     Pentalpha SurveillanceLLC, as Operating Advisor of the Plaza Frontenac Mortgage Loan (see Exhibit34.29)

34.50     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Starwood Hotel Portfolio Mortgage Loan(see Exhibit 34.1)

34.51     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the StarwoodHotel Portfolio Mortgage Loan (see Exhibit 34.3)

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

34.53     Wells Fargo Bank, NationalAssociation, as Custodian of the Starwood Hotel Portfolio Mortgage Loan (seeExhibit 34.7)

34.54     Park Bridge LenderServices LLC, as Operating Advisor of the Starwood Hotel Portfolio MortgageLoan (see Exhibit 34.8)

34.55     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Starwood HotelPortfolio Mortgage Loan (see Exhibit 34.9)

34.56     National Tax Search, LLC,as Servicing Function Participant of the Starwood Hotel Portfolio Mortgage Loan(see Exhibit 34.10)

34.57     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Moffett Towers – Buildings E,F,GMortgage Loan (see Exhibit 34.1)

34.58     Rialto Capital Advisors,LLC, as Special Servicer of the Moffett Towers – Buildings E,F,G Mortgage Loan(see Exhibit 34.39)

34.59     Wilmington Trust, National Association, as Trustee of the Moffett Towers –Buildings E,F,G Mortgage Loan (Omitted. See Explanatory Notes.)

34.60     Wells Fargo Bank, NationalAssociation, as Custodian of the Moffett Towers – Buildings E,F,G Mortgage Loan(see Exhibit 34.7)

34.61     Park Bridge LenderServices LLC, as Operating Advisor of the Moffett Towers – Buildings E,F,GMortgage Loan (see Exhibit 34.8)

34.62     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Moffett Towers– Buildings E,F,G Mortgage Loan (see Exhibit 34.9)

34.63     National Tax Search, LLC,as Servicing Function Participant of the Moffett Towers – Buildings E,F,GMortgage Loan (see Exhibit 34.10)

34.64     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 2020 Fifth Avenue Mortgage Loan (seeExhibit 34.1)

34.65     Rialto Capital Advisors,LLC, as Special Servicer of the 2020 Fifth Avenue Mortgage Loan (see Exhibit34.39)

34.66     Wilmington Trust, National Association, as Trustee of the 2020 Fifth AvenueMortgage Loan (Omitted. See Explanatory Notes.)

34.67     Wells Fargo Bank, NationalAssociation, as Custodian of the 2020 Fifth Avenue Mortgage Loan (see Exhibit34.7)

34.68     Pentalpha SurveillanceLLC, as Operating Advisor of the 2020 Fifth Avenue Mortgage Loan (see Exhibit34.29)

34.69     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the 2020 FifthAvenue Mortgage Loan (see Exhibit 34.9)

34.70     National Tax Search, LLC,as Servicing Function Participant of the 2020 Fifth Avenue Mortgage Loan (seeExhibit 34.10)

34.71     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Carriage Place Mortgage Loan (seeExhibit 34.1)

34.72     KeyBank National Association, as Special Servicer of the Carriage PlaceMortgage Loan (Omitted. See Explanatory Notes.)

34.73     Wilmington Trust, National Association, as Trustee of the Carriage PlaceMortgage Loan (Omitted. See Explanatory Notes.)

34.74     Wells Fargo Bank, NationalAssociation, as Custodian of the Carriage Place Mortgage Loan (see Exhibit34.7)

34.75     Park Bridge LenderServices LLC, as Operating Advisor of the Carriage Place Mortgage Loan (seeExhibit 34.8)

34.76     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Carriage PlaceMortgage Loan (see Exhibit 34.9)

34.77     National Tax Search, LLC,as Servicing Function Participant of the Carriage Place Mortgage Loan (seeExhibit 34.10)

35          Servicer compliance statements.

35.1       Wells Fargo Bank, NationalAssociation, as General Master Servicer

35.2       National Cooperative Bank,N.A., as NCB Master Servicer

35.3       Midland Loan Services, aDivision of PNC Bank, National Association, as General Special Servicer

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

35.5       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

35.6       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 685 Fifth Avenue Retail Mortgage Loan(see Exhibit 35.1)

35.7       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan (see Exhibit 35.3)

35.8       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Aventura Mall Mortgage Loan (seeExhibit 35.1)

35.9       CWCapital Asset Management LLC, as Special Servicer of the Aventura MallMortgage Loan (Omitted. See Explanatory Notes.)

35.10     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Pfizer Building Mortgage Loan (seeExhibit 35.1)

35.11     Torchlight Loan Services, LLC, as Special Servicer of the Pfizer BuildingMortgage Loan (Omitted. See Explanatory Notes.)

35.12     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Millennium Partners Portfolio MortgageLoan (see Exhibit 35.1)

35.13     Wells Fargo Bank, NationalAssociation, as Special Servicer of the Millennium Partners Portfolio MortgageLoan (see Exhibit 35.1)

35.14     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Prudential - Digital Realty PortfolioMortgage Loan (see Exhibit 35.1)

35.15     Rialto Capital Advisors, LLC, as Special Servicer of the Prudential - DigitalRealty Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

35.16     Midland Loan Services, aDivision of PNC Bank, National Association, as Primary Servicer of the PlazaFrontenac Mortgage Loan (see Exhibit 35.3)

35.17     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the PlazaFrontenac Mortgage Loan (see Exhibit 35.3)

35.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Starwood Hotel Portfolio Mortgage Loan(see Exhibit 35.1)

35.19     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the StarwoodHotel Portfolio Mortgage Loan (see Exhibit 35.3)

35.20     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Moffett Towers – Buildings E,F,GMortgage Loan (see Exhibit 35.1)

35.21     Rialto Capital Advisors, LLC, as Special Servicer of the Moffett Towers –Buildings E,F,G Mortgage Loan (Omitted. See Explanatory Notes.)

35.22     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the 2020 Fifth Avenue Mortgage Loan (seeExhibit 35.1)

35.23     Rialto Capital Advisors, LLC, as Special Servicer of the 2020 Fifth AvenueMortgage Loan (Omitted. See Explanatory Notes.)

35.24     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Carriage Place Mortgage Loan (seeExhibit 35.1)

35.25     KeyBank National Association, as Special Servicer of the Carriage PlaceMortgage Loan (Omitted. See Explanatory Notes.)

99.1        MortgageLoan Purchase Agreement, dated as of November 16, 2018, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.1 to the registrant’s Current Report on Form8-K filed on November 29, 2018 under Commission File No. 333-206847-10 andincorporated by reference herein)

99.2        MortgageLoan Purchase Agreement, dated as of November 16, 2018, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K filed onNovember 29, 2018 under Commission File No. 333-206847-10 and incorporated byreference herein)

99.3        MortgageLoan Purchase Agreement, dated as of November 16, 2018, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and Bank of America, NationalAssociation (filed as Exhibit 99.3 to the registrant’s Current Report on Form8-K filed on November 29, 2018 under Commission File No. 333-206847-10 andincorporated by reference herein)

99.4        MortgageLoan Purchase Agreement, dated as of November 16, 2018, between Banc of AmericaMerrill Lynch Commercial Mortgage Inc. and National Cooperative Bank, N.A.(filed as Exhibit 99.4 to the registrant’s Current Report on Form 8-K filed onNovember 29, 2018 under Commission File No. 333-206847-10 and incorporated byreference herein)

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

(c)   Not Applicable.

 

**SIGNATURES**

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

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

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

(senior officer in charge ofsecuritization of the depositor)

Date: March 20, 2020