**Management’s Assertion onCompliance with Applicable Regulation AB Servicing Criteria**

 

 

1. Rialto Capital Advisors,LLC (the “Asserting Party”) is responsible for assessing compliance with the servicingcriteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, asof and for the 12-month period ending December 31, 2022 (the “ReportingPeriod”), as set forth in Appendix A hereto. The transactions covered by thisreport, include commercial mortgage-asset-backed securities transactions, aslisted on Exhibit 1 hereto, for which the Asserting Party served as specialservicer, and that were registered with the Securities and Exchange Commissionpursuant to the Securities Act of 1933 (the “Platform”);

 

2. The Asserting Party hasengaged certain vendors, which are not servicers as defined in Item 1101(j) ofRegulation AB (the “Vendors”), to perform specific, limited or scriptedactivities, and the Asserting Party elects to take responsibility for assessingcompliance with the servicing criteria or portion of the servicing criteriaapplicable to such Vendors’ activities as set forth in Appendix A hereto;

 

3. Except as set forth inparagraph 4 below, the Asserting Party used the criteria set forth in paragraph(d) of Item 1122 of Regulation AB to assess the compliance with the applicableservicing criteria;

 

4. The criteria listed in thecolumn titled “Inapplicable Servicing Criteria” on Appendix A hereto areinapplicable to the Asserting Party based on the activities it performs,directly or through its Vendors, with respect to the Platform;

 

5. The Asserting Party hascomplied, in all material respects, with the applicable servicing criteria asof December 31, 2022 and for the Reporting Period with respect to the Platformtaken as a whole;

 

6. The Asserting Party has notidentified and is not aware of any material instance of noncompliance by theVendors with the applicable servicing criteria as of December 31, 2022 and forthe Reporting Period with respect to the Platform taken as a whole;

 

7. The Asserting Party has notidentified any material deficiency in its policies and procedures to monitorthe compliance by the Vendors with the applicable servicing criteria as ofDecember 31, 2022 and for the Reporting Period with respect to the Platformtaken as a whole; and

 

8. Deloitte & Touche LLP,an independent registered public accounting firm, has issued an attestationreport on the Asserting Party’s assessment of compliance with the applicableservicing criteria for the Reporting Period.

 

 

February 23, 2023

 

 

Name: Adam Singer 

Title: Managing Director

Signature: /s/ Adam Singer 

 

**Exhibit 1**

| ** **

**Pooling********and********Servicing********Agreements**                                        | ** **

**Applicable********Certification********Period** |
|--------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------|
| CLNY 2019-IKPR                                                                                               | January 1, 2022 to June 3, 2022                               |
| WFRBS 2012-C6                                                                                                | January 1, 2022 to June 6, 2022                               |
| WFRBS 2012-C8                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2012-LC5                                                                                                | January 1, 2022 to December 31, 2022                          |
| UBS-Barclays 2012-C3                                                                                         | January 1, 2022 to December 31, 2022                          |
| UBS-Barclays 2012-C4                                                                                         | January 1, 2022 to December 31, 2022                          |
| GSMS 2012-GCJ9                                                                                               | January 1, 2022 to December 31, 2022                          |
| JPMCC 2012-LC9                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2013-LC6                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFRBS 2013-C12                                                                                               | January 1, 2022 to December 31, 2022                          |
| UBS-Barclays 2013-C6                                                                                         | January 1, 2022 to December 31, 2022                          |
| GSMS 2013-GCJ12                                                                                              | January 1, 2022 to December 31, 2022                          |
| WFRBS 2013-C14                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFRBS 2011-C5                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2013-LC12                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFRBS 2011-C2                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFRBS 2011-C3                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFRBS 2011-C4                                                                                                | January 1, 2022 to December 31, 2022                          |
| UBS-Citigroup 2011-C1                                                                                        | January 1, 2022 to December 31, 2022                          |
| UBSCM 2012-C1                                                                                                | January 1, 2022 to December 31, 2022                          |
| GSMS 2011-GC3                                                                                                | January 1, 2022 to December 31, 2022                          |
| COMM 2013-LC13                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFRBS 2013-C16                                                                                               | January 1, 2022 to December 31, 2022                          |
| GSMS 2013-GCJ16                                                                                              | January 1, 2022 to December 31, 2022                          |
| WFRBS 2013-C17                                                                                               | January 1, 2022 to December 31, 2022                          |
| GSMS 2012-GC6                                                                                                | January 1, 2022 to December 31, 2022                          |
| MSBAM 2013-C13                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2014-CCRE14                                                                                             | January 1, 2022 to December 31, 2022                          |
| MSBAM 2014-C14                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFRBS 2014-LC14                                                                                              | January 1, 2022 to December 31, 2022                          |
| COMM 2014-LC15                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFRBS 2014-C20                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2014-CCRE18                                                                                             | January 1, 2022 to December 31, 2022                          |
| CGCMT 2014-GC23                                                                                              | January 1, 2022 to December 31, 2022                          |
| MSBAM 2014-C17                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2014-UBS5                                                                                               | January 1, 2022 to December 31, 2022                          |
| MSBAM 2014-C18                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2012-CCRE4                                                                                              | January 1, 2022 to December 31, 2022                          |
| WFRBS 2014-C24                                                                                               | January 1, 2022 to December 31, 2022                          |
| JPMBB 2014-C25                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFCM 2014-LC18                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2015-DC1                                                                                                | January 1, 2022 to December 31, 2022                          |
| GSMS 2015-GC28                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-C27                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-LC20                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-NXS1                                                                                               | January 1, 2022 to December 31, 2022                          |
| CSAIL 2015-C2                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-NXS2                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2015-PC1                                                                                                | January 1, 2022 to December 31, 2022                          |
| CSAIL 2015-C3                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-SG1                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-LC22                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2015-CCRE27                                                                                             | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-NXS4                                                                                               | January 1, 2022 to December 31, 2022                          |
| MSCI 2015-UBS8                                                                                               | January 1, 2022 to December 31, 2022                          |
| CSAIL 2016-C5                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2016-C32                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2016-NXS5                                                                                               | January 1, 2022 to December 31, 2022                          |
| CGCMT 2015-GC27                                                                                              | January 1, 2022 to December 31, 2022                          |
| WFCM 2016-C33                                                                                                | January 1, 2022 to December 31, 2022                          |
| MSBAM 2015-C20                                                                                               | January 1, 2022 to December 31, 2022                          |
| CFCRE 2016-C4                                                                                                | January 1, 2022 to December 31, 2022                          |
| BACM 2016-UBS10                                                                                              | January 1, 2022 to December 31, 2022                          |
| SGCMS 2016-C5                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2016-BNK1                                                                                               | January 1, 2022 to December 31, 2022                          |
| CD 2016-CD1                                                                                                  | January 1, 2022 to December 31, 2022                          |
| GSMS 2016-GS3                                                                                                | January 1, 2022 to December 31, 2022                          |
| MSBAM 2016-C31                                                                                               | January 1, 2022 to December 31, 2022                          |
| CGCMT 2016-C3                                                                                                | January 1, 2022 to December 31, 2022                          |
| CFCRE 2016-C6                                                                                                | January 1, 2022 to December 31, 2022                          |
| CSAIL 2016-C7                                                                                                | January 1, 2022 to December 31, 2022                          |
| MSCI 2016-UBS12                                                                                              | January 1, 2022 to December 31, 2022                          |
| BBCMS 2017-C1                                                                                                | January 1, 2022 to December 31, 2022                          |
| GSMS 2017-GS5                                                                                                | January 1, 2022 to December 31, 2022                          |
| CGCMT 2017-P7                                                                                                | January 1, 2022 to December 31, 2022                          |
| BANK 2017-BNK4                                                                                               | January 1, 2022 to December 31, 2022                          |
| CD 2017-CD4                                                                                                  | January 1, 2022 to December 31, 2022                          |
| CFCRE 2017-C8                                                                                                | January 1, 2022 to December 31, 2022                          |
| JPMCC 2017-JP6                                                                                               | January 1, 2022 to December 31, 2022                          |
| CD 2017-CD5                                                                                                  | January 1, 2022 to December 31, 2022                          |
| GSMS 2017-GS7                                                                                                | January 1, 2022 to December 31, 2022                          |
| BANK 2017-BNK7                                                                                               | January 1, 2022 to December 31, 2022                          |
| CSAIL 2017-CX9                                                                                               | January 1, 2022 to December 31, 2022                          |
| UBSCM 2017-C4                                                                                                | January 1, 2022 to December 31, 2022                          |
| UBSCM 2017-C6                                                                                                | January 1, 2022 to December 31, 2022                          |
| BANK 2017-BNK9                                                                                               | January 1, 2022 to December 31, 2022                          |
| GSMS 2018-GS9                                                                                                | January 1, 2022 to December 31, 2022                          |
| UBSCM 2018-C9                                                                                                | January 1, 2022 to December 31, 2022                          |
| MSBAM 2012-C5                                                                                                | January 1, 2022 to December 31, 2022                          |
| WFCM 2018-C44                                                                                                | January 1, 2022 to December 31, 2022                          |
| UBSCM 2018-C10                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-C30                                                                                                | January 1, 2022 to December 31, 2022                          |
| JPMBB 2014-C23                                                                                               | January 1, 2022 to December 31, 2022                          |
| MSBAM 2014-C19                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2015-LC21                                                                                               | January 1, 2022 to December 31, 2022                          |
| MSBAM 2016-C29                                                                                               | January 1, 2022 to December 31, 2022                          |
| JPMBB 2015-C31                                                                                               | January 1, 2022 to December 31, 2022                          |
| GSMS 2018-GS10                                                                                               | January 1, 2022 to December 31, 2022                          |
| CD 2018-CD7                                                                                                  | January 1, 2022 to December 31, 2022                          |
| GSMS 2018-3PCK                                                                                               | January 1, 2022 to December 31, 2022                          |
| BANK 2018-BNK14                                                                                              | January 1, 2022 to December 31, 2022                          |
| DBGS 2018-C1                                                                                                 | January 1, 2022 to December 31, 2022                          |
| CSAIL 2018-C14                                                                                               | January 1, 2022 to December 31, 2022                          |
| UBSCM 2018-C14                                                                                               | January 1, 2022 to December 31, 2022                          |
| ILPT 2019-SURF                                                                                               | January 1, 2022 to December 31, 2022                          |
| MSCI 2019-L2                                                                                                 | January 1, 2022 to December 31, 2022                          |
| WFCM 2019-C50                                                                                                | January 1, 2022 to December 31, 2022                          |
| BANK 2019-BNK18                                                                                              | January 1, 2022 to December 31, 2022                          |
| WFCM 2015-P2                                                                                                 | January 1, 2022 to December 31, 2022                          |
| BMARK 2019-B11                                                                                               | January 1, 2022 to December 31, 2022                          |
| CGCMT 2019-GC41                                                                                              | January 1, 2022 to December 31, 2022                          |
| BBCMS 2019-C4                                                                                                | January 1, 2022 to December 31, 2022                          |
| COMM 2014-CCRE15                                                                                             | January 1, 2022 to December 31, 2022                          |
| UBSCM 2019-C17                                                                                               | January 1, 2022 to December 31, 2022                          |
| BANK 2019-BNK21                                                                                              | January 1, 2022 to December 31, 2022                          |
| CGCMT 2019-GC43                                                                                              | January 1, 2022 to December 31, 2022                          |
| CSAIL 2019-C18                                                                                               | January 1, 2022 to December 31, 2022                          |
| COMM 2019-GC44                                                                                               | January 1, 2022 to December 31, 2022                          |
| UBSCM 2019-C18                                                                                               | January 1, 2022 to December 31, 2022                          |
| WFCM 2020-C55                                                                                                | January 1, 2022 to December 31, 2022                          |
| UBSBB 2012-C2                                                                                                | January 1, 2022 to December 31, 2022                          |
| BBCMS 2020-C7                                                                                                | January 1, 2022 to December 31, 2022                          |
| CSMC 2020-NET                                                                                                | January 1, 2022 to December 31, 2022                          |
| BMARK 2020-B19                                                                                               | January 1, 2022 to December 31, 2022                          |
| BMARK 2020-B22                                                                                               | January 1, 2022 to December 31, 2022                          |
| CSMC 2020-FACT                                                                                               | January 1, 2022 to December 31, 2022                          |
| BANK 2020-BNK29                                                                                              | January 1, 2022 to December 31, 2022                          |
| WFCM 2020-C58                                                                                                | January 1, 2022 to December 31, 2022                          |
| FSRIA 2019-FL1                                                                                               | January 1, 2022 to December 31, 2022                          |
| BANK 2021-BNK32                                                                                              | January 1, 2022 to December 31, 2022                          |
| BSST 2021-1818                                                                                               | January 1, 2022 to December 31, 2022                          |
| BMARK 2021-B25                                                                                               | January 1, 2022 to December 31, 2022                          |
| FSRIA 2021-FL2                                                                                               | January 1, 2022 to December 31, 2022                          |
| MSC 2007-T27                                                                                                 | January 1, 2022 to December 31, 2022                          |
| BANK 2021-BNK33                                                                                              | January 1, 2022 to December 31, 2022                          |
| BBCMS 2021-C10                                                                                               | January 1, 2022 to December 31, 2022                          |
| CSMC 2021-ADV                                                                                                | January 1, 2022 to December 31, 2022                          |
| BANK 2021-BNK36                                                                                              | January 1, 2022 to December 31, 2022                          |
| FSRIA 2021-FL3                                                                                               | January 1, 2022 to December 31, 2022                          |
| BACM 2017-BNK3                                                                                               | January 1, 2022 to December 31, 2022                          |
| BMARK 2021-B31                                                                                               | January 1, 2022 to December 31, 2022                          |
| BSST 2022-1700                                                                                               | February 22, 2022 to December 31, 2022                        |
| SPGN 2022-TFLM                                                                                               | February 25, 2022 to December 31, 2022                        |
| FSRIA 2022-FL4                                                                                               | March 31, 2022 to December 31, 2022                           |
| BBCMS 2022-C15                                                                                               | April 13, 2022 to December 31, 2022                           |
| BANK 2022-BN41                                                                                               | May 5, 2022 to December 31, 2022                              |
| Rial 2022-FL8                                                                                                | May 20, 2022 to December 31, 2022                             |
| CGCMT 2022-GC48

(RCA is special servicer as to the Yorkshire &  Lexington Towers loan combination only) |  

June 1, 2022 to December 31, 2022                     |
| BAMLL 2022-DKLX                                                                                              | June 6, 2022 to December 31, 2022                             |
| FSRIA 2022-FL5                                                                                               | June 16, 2022 to December 31, 2022                            |
| BMO 2022-C2                                                                                                  | July 12, 2022 to December 31, 2022                            |
| FSRIA 2022-FL6                                                                                               | August 25, 2022 to December 31, 2022                          |
| CSMC 2022-NWPT                                                                                               | September 21, 2022 to December 31, 2022                       |
| BMARK 2022-B37                                                                                               | November 3, 2022 to December 31, 2022                         |
| BBCMS 2022-C18                                                                                               | December 14, 2022 to December 31, 2022                        |

# ** **

**APPENDIX A **

| **SERVICING********CRITERIA**                                               |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
|-----------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| ** **

**Reference**                                                   | ** **

**Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | **Performed********by****Servicer** | **Inapplicable Servicing Criteria** |
| **General********Servicing********Considerations**                          |
| ** **

1122(d)(1)(i)                                                   | Policies and procedures are  instituted to monitor any performance or other triggers and events of default  in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

**X** |   |
| ** **

1122(d)(1)(ii)                                                  | If any material servicing  activities are outsourced to third parties, policies and procedures are  instituted to monitor the third party’s performance and compliance with such  servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **

**X1** |   |
| 1122(d)(1)(iii)                                                             | Any requirements in the transaction  agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   | **X** |
| ** **

** **

1122(d)(1)(iv)                                      | A fidelity bond and errors  and omissions policy is in effect on the party participating in the servicing  function throughout the reporting period in the amount of coverage

required by and otherwise in  accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                         | ** **

** **

**X** |   |
| ** **

1122(d)(1)(v)                                                   | Aggregation of information,  as applicable, is

mathematically accurate and the  information conveyed accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

**X** |   |
| **Cash********Collection********and********Administration**                 |
| ** **

** **

1122(d)(2)(i)                                       | Payments on pool assets are  deposited into the appropriate custodial bank accounts and related bank clearing  accounts no more than two business days following receipt, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X** |   |
| ** **

1122(d)(2)(ii)                                                  | Disbursements made via wire transfer  on behalf of an obligor or to an investor are made only by authorized  personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | ** **

**X3** |   |
| ** **

1122(d)(2)(iii)                                                 | Advances of funds or  guarantees regarding collections, cash flows or distributions, and any  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | ** **

**X3** |   |
| ** **

** **

1122(d)(2)(iv)                                      | The related accounts for the  transaction, such as cash reserve accounts or accounts established as a form  of overcollateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **

**X** |   |
| ** **

** **

** **

1122(d)(2)(v)                           | Each custodial account is maintained  at a federally insured depository institution as set forth in the transaction

agreements. For purposes of  this criterion, “federally insured depository institution” with respect to a  foreign

financial institution means  a foreign financial institution that meets the requirements of Rule  13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                            | ** **

** **

** **

**X** |   |
| 1122(d)(2)(vi)                                                              | Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | **X** |   |
| ** **

** **

** **

** **

** **

1122(d)(2)(vii) | Reconciliations are prepared  on a monthly basis for all asset-backed securities related bank accounts,  including custodial accounts and related bank clearing accounts. These  reconciliations are (A) mathematically accurate; (B) prepared within 30  calendar days after the bank statement cutoff date, or such other number of  days specified in the transaction agreements; (C) reviewed and approved by  someone other than the person who prepared the reconciliation; and (D)  contain explanations for reconciling items. These reconciling items are resolved  within 90 calendar days of their original identification, or such other  number of days specified in the transaction agreements. | ** **

** **

** **

** **

**X** |   |
| **Investor********Remittances********and********Reporting**                 |
| ** **

** **

** **

** **

1122(d)(3)(i)               | Reports to investors,  including those to be filed with the Commission, are maintained in accordance  with the transaction agreements and applicable Commission requirements.  Specifically, such reports (A) are prepared in accordance with timeframes and  other terms set forth in the transaction agreements; (B) provide information  calculated in accordance with the terms specified in the transaction  agreements; (C) are filed with the Commission as required by its rules and  regulations; and (D) agree with investors’ or the trustee’s records as to the  total unpaid principal balance and number of pool assets serviced by the  Servicer.                                  | ** **

** **

** **

** **

**X4** |   |
| ** **

1122(d)(3)(ii)                                                  | Amounts due to investors are  allocated and remitted in accordance with timeframes, distribution priority and  other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |   | ** **

**X** |
| ** **

1122(d)(3)(iii)                                                 | Disbursements made to an  investor are posted within two business days to the Servicer’s investor  records, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |   | ** **

**X** |
| ** **

1122(d)(3)(iv)                                                  | Amounts remitted to  investors per the investor reports agree with cancelled checks, or other form  of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   | ** **

**X** |
| **Pool********Asset********Administration**                                 |
| ** **

1122(d)(4)(i)                                                   | Collateral or security on  Pool assets is maintained as required by the transaction agreements or  related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **

**X** |   |
| ** **

1122(d)(4)(ii)                                                  | Pool asset and related  documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | ** **

**X** |   |
| ** **

1122(d)(4)(iii)                                                 | Any additions, removals or  substitutions to the asset pool are made, reviewed and approved in accordance  with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **

**X3** |   |
| ** **

** **

** **

1122(d)(4)(iv)                          | Payments on pool assets, including  any payoffs, made in accordance with the related pool asset documents are

posted to the Servicer’s  obligor records maintained no more than two business days after receipt, or  such other number of days specified in the transaction agreements, and allocated  to principal, interest or other items (e.g., escrow) in accordance with the  related pool asset documents.                                                                                                                                                                                                                                                                                      | ** **

** **

** **

**X2** |   |
| ** **

1122(d)(4)(v)                                                   | The Servicer’s records  regarding the pool assets agree with the Servicer’s records with respect to  an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |   | ** **

**X** |
| ** **

** **

1122(d)(4)(vi)                                      | Changes with respect to the  terms or status of an obligor's pool assets (e.g., loan modifications or  re-agings) are made, reviewed and approved by authorized personnel in accordance  with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

** **

**X** |   |
| ** **

** **

1122(d)(4)(vii)                                     | Loss mitigation or recovery  actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure,  foreclosures and repossessions, as applicable) are initiated, conducted and  concluded in accordance with the timeframes or other requirements established  by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

** **

** **

**X** |   |
| ** **

** **

** **

1122(d)(4)(viii)                        | Records documenting collection  efforts are maintained during the period a pool asset is delinquent in  accordance with the transaction agreements. Such records are maintained on at  least a monthly basis, or such other period specified in the transaction  agreements, and describe the

entity’s activities in  monitoring delinquent pool assets including, for example, phone calls,  letters and payment rescheduling plans in cases where delinquency is deemed  temporary (e.g., illness or unemployment).                                                                                                                                                                                  | ** **

** **

** **

**X** |   |
| ** **

1122(d)(4)(ix)                                                  | Adjustments to interest  rates or rates of return for pool assets with variable rates are computed  based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |   | ** **

**X** |
| ** **

** **

1122(d)(4)(x)                                       | Regarding any funds held in trust  for an obligor (such as escrow accounts): (A) such funds are analyzed, in

accordance with the  obligor’s pool asset documents, on at least an annual basis, or such other  period specified in the transaction agreements; (B) interest on such funds is  paid, or credited, to obligors in accordance with applicable pool

asset documents and state  laws; and (C) such funds are returned to the obligor within 30 calendar days  of full repayment of the related pool assets, or such other number of days  specified in the transaction agreements.                                                                                                          |   | ** **

** **

**X** |
| ** **

** **

** **

1122(d)(4)(xi)                          | Payments made on behalf of  an obligor (such as tax or insurance payments) are made on or before the  related penalty or expiration dates, as indicated on the appropriate bills or  notices for such payments, provided that such support has been received by  the Servicer at least 30 calendar days prior to these dates, or such other  number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                          |   | ** **

** **

** **

**X** |
| ** **

1122(d)(4)(xii)                                                 | Any late payment penalties in  connection with any payment to be made on behalf of an obligor are paid from  the

Servicer’s funds and not  charged to the obligor, unless the late payment was due to the obligor’s  error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                          |   | ** **

**X** |
| ** **

1122(d)(4)(xiii)                                                | Disbursements made on behalf  of an obligor are posted within two business days to the obligor’s records  maintained by the Servicer, or such other number of days specified in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   | ** **

**X** |
| ** **

1122(d)(4)(xiv)                                                 | Delinquencies, charge-offs and  uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |   | **X** |
| ** **

1122(d)(4)(xv)                                                  | Any external enhancement or  other support, identified in Item 1114(a)(1) through (3) or Item 1115 of  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |   | ** **

**X** |

 

**X1**- Rialto Capital Advisors, LLC performs the activitiespertaining to this criterion, except for specific, limited activities performedby (a) its third-party property managers relating to REO Property, if any; and(b) RERC, LLC, a SitusAMC Company, pursuant to a Staffing Agreement, in whichRERC provides RCA with real estate consultant and valuation professionals toperform support functions in connection with property appraisals. Rialto haselected to take responsibility for assessing compliance with these servicingcriteria with respect to the activities of its third-party property managersand RERC, LLC.

 

**X2**-Primary responsibility for processing borrowerpayments rests with the Master Servicer, however, Rialto Capital Advisors, LLCmay from time to time receive payments on an exception basis which areforwarded to the Master Servicer in accordance with such criteria. The criteriais marked applicable as Rialto Capital Advisors, LLC had instances or activityrelating to this criteria for the calendar year of January 1, 2022 to December31, 2022.

 

**X3**- Although Rialto Capital Advisors, LLC is responsible forperforming the activities under this criteria, it is noted no such activitiesoccurred during the calendar year of January 1, 2022 to December 31, 2022.

 

**X4**-Only items (A) and (B) of the Servicing Criteria areapplicable to Rialto Capital Advisors, LLC as special servicer. Items (C) and(D) are inapplicable as the responsibility for filing reports with theCommission and agreeing totals to the Servicer records rests with the Trusteeand/or Certificate Administrator, as applicable.