**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

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

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

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

**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 smaller reportingcompany, or an emerging growth company. See the definitions of “largeaccelerated filer,” “accelerated filer,” “smaller reporting company,” and“emerging growth company” in Rule 12b-2 of the Exchange Act.

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

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

                                                                                                                                                       Emerging growthcompany                    o

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

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

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 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 and oneother *pari passu* loan, which is not an asset of the issuing entity. Thisloan combination, including the 685 Fifth Avenue Retail Mortgage Loan, is beingserviced and administered pursuant to the Pooling and Servicing Agreement,which is incorporated by reference as Exhibit 4.1 to this Annual Report on Form10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Aventura Mall Mortgage Loan, which constitutedapproximately 9.2% of the asset pool of the issuing entity as of its cut-offdate.  The Aventura Mall Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the Aventura Mall MortgageLoan, twenty-four other *pari passu* loans and four subordinate companionloans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the Aventura Mall Trust2018-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 not assetsof the issuing entity. A *pari passu* portion of the loan combination wassecuritized in the BANK 2018-BNK13 transaction, Commission File Number333-206677-26 (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, six 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 the ExhibitIndex) with respect to the Starwood Hotel Portfolio Mortgage Loan, whichconstituted approximately 9.2% of the asset pool of the issuing entity as ofits cut-off date.  The Starwood Hotel Portfolio Mortgage Loan is an assetof 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 Mortgage Loan, which constituted approximately 5.2% of the asset pool of theissuing entity as of its cut-off date.  The Moffett Towers - Buildings E,F, G  Mortgage Loan is an asset of the issuing entity and is part of aloan combination that includes the Moffett Towers - Buildings E, F, G Mortgage Loan and eight other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the DBGS 2018-C1 Mortgage Trust transaction, Commission FileNumber 333-206705-16 (the “DBGS 2018-C1 Transaction”). This loancombination, including the Moffett Towers - Buildings E, F, G  MortgageLoan, is being serviced and administered pursuant to the pooling and servicingagreement for the DBGS 2018-C1 Transaction, which is incorporated by referenceas Exhibit 4.8 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 2020 Fifth Avenue Mortgage Loan, whichconstituted approximately 2.2% of the asset pool of the issuing entity as ofits cut-off date.  The 2020 Fifth Avenue Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 2020 FifthAvenue Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. The other *pari passu* portion of the loancombination was securitized in the CSAIL 2018-C14 Commercial Mortgage Trusttransaction, Commission File Number 333-207361-10 (the “CSAIL 2018-C14Transaction”). This loan combination, including the 2020 Fifth AvenueMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the CSAIL 2018-C14 Transaction, which is incorporatedby reference as Exhibit 4.9 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,the Pfizer 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 - Buildings E,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 specialservicer of the mortgage loans (other than the Best Western Spring TX MortgageLoan) serviced under the Pooling and Servicing Agreement prior to July 7, 2021and the Best Western Spring TX Mortgage Loan prior to August 31, 2021,the primary servicer and special servicer of the Plaza Frontenac Mortgage Loanand the special servicer of the Starwood Hotel Portfolio Mortgage Loan. As aresult, Midland Loan Services, a Division of PNC Bank, National Association isa “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Midland Loan Services, a Division of PNC Bank, National Association in thecapacities described above are listed in the Exhibit Index.

LNR Partners, LLC is the special servicer of the mortgage loans (other thanthe Best Western Spring TX Mortgage Loan) serviced under the Pooling andServicing Agreement on and after July 7, 2021 and the Best Western Spring TXMortgage Loan on and after August 31, 2021. As a result, LNR Partners,LLC is a “servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby LNR Partners, LLC in the capacities described above are listed in theExhibit Index.

RialtoCapital Advisors, LLC is the special servicer of the Moffett Towers – BuildingsE,F,G Mortgage Loan, the Prudential - Digital Realty Portfolio Mortgage Loanand the 2020 Fifth Avenue Mortgage Loan. These mortgage loans constitute morethan 5%, but less than 10%, of the pool assets of the issuing entity. Therefore, the Depositor included in this Annual Report on Form 10-K anassessment of compliance with applicable servicing criteria for Rialto CapitalAdvisors, LLC and an accountants’ attestation report pursuant to Item 1122 ofRegulation AB because it is servicing more than 5% of the pool assets. However, the Depositor is not required to include in this Annual Report on Form10-K a servicer compliance statement pursuant to Item 1123 of Regulation AB ofRialto Capital Advisors, LLC because it is an unaffiliated servicer servicingless than 10% of pool 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 Realty Portfolio Mortgage Loan and the Carriage Place MortgageLoan.  As a result, Park Bridge Lender Services LLC is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Park Bridge LenderServices LLC in the capacities described above are listed in the Exhibit Index.

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.

NationalCooperative Bank, N.A., the NCB master servicer and NCB special servicer, isalso a sponsor. Therefore, the Depositor included in this Annual Report on Form10-K a servicer compliance statement for National Cooperative Bank, N.A.pursuant to Item 1123.  Because National Cooperative Bank, N.A. isservicing less than 5% of the pool assets, an assessment of compliance withapplicable servicing criteria and an accountants’ attestation report pursuantto Item 1122 of Regulation AB are not required by Regulation AB. As theattestation made in the servicer compliance statement required by Item 1123relates to a review of the servicing activities of National Cooperative Bank,N.A. under the applicable servicing agreement, and that review was conducted inconjunction with the servicer’s preparation of its assessment of compliancewith applicable servicing criteria, that assessment of compliance withapplicable servicing criteria and the accompanying accountants’ attestationreport are included in this Annual Report on Form 10-K for the sake ofcompleteness.

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

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the Aventura Mall Mortgage Loan, the PfizerBuilding Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan, thePrudential - Digital Realty Portfolio Mortgage Loan, the Starwood HotelPortfolio Mortgage Loan, the Moffett Towers - Buildings E, F, G  MortgageLoan, the 2020 Fifth Avenue Mortgage Loan and the Carriage Place MortgageLoan.  Pursuant to the Pooling and Servicing Agreement, the trust andservicing agreement for the Aventura Mall 2018-AVM  Transaction, thepooling and servicing agreement for the BANK 2018-BNK13 Transaction, the trustand servicing agreement for the MSC 2018-MP Transaction, the pooling andservicing agreement for the BANK 2018-BNK14 Transaction, the pooling andservicing agreement for the WFCM 2018-C47 Transaction, the pooling andservicing agreement for the DBGS 2018-C1 Transaction, the pooling and servicingagreement for the CSAIL 2018-C14 Transaction and the pooling and servicingagreement for the BANK 2019-BNK16 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) of RegulationAB.  The master servicer or the special servicer, to the extent required,performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of  the mortgage loans servicedunder the Pooling and Servicing Agreement, the Aventura Mall Mortgage Loan, thePfizer Building Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan,the Prudential - Digital Realty Portfolio Mortgage Loan, the Starwood HotelPortfolio Mortgage Loan, the Moffett Towers - Buildings E, F, G  MortgageLoan, the 2020 Fifth Avenue Mortgage Loan and the Carriage Place Mortgage Loanhave delivered 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 Solutions, LLC  Thisentity was engaged by the primary servicer of the Aventura Mall Mortgage Loan,the Pfizer Building Mortgage Loan, the Millennium Partners Portfolio MortgageLoan, the Prudential - Digital Realty Portfolio Mortgage Loan, the StarwoodHotel Portfolio Mortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage PlaceMortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in Items1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

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

 

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the 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 Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage PlaceMortgage Loan are omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because theyare each not a “servicer” that meets the criteria in Item 1108(a)(2)(i) through(iii) of Regulation AB.

Withrespect to the *pari passu* loan combinations that include theAventura Mall Mortgage Loan, the Pfizer Building Mortgage Loan, the PrudentialDigital Realty Portfolio Mortgage Loan, the Moffett Towers– Buildings E,F,GMortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage PlaceMortgage Loan, (i) the reports on assessment of compliance withservicing criteria and attestation reports on assessment of compliance withservicing criteria of Torchlight Loan Services, LLC as special servicer of thePfizer Building Mortgage Loan and KeyBank National Association as specialservicer of the Carriage Place Mortgage Loan, listed on the Exhibit Index areomitted from this Annual Report on Form 10-K as they are not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 ofRegulation AB because they are parties performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity;and (ii) the servicer compliance statements of CWCapital Asset Management LLCas special servicer of the Aventura Mall Mortgage Loan, Torchlight LoanServices, LLC as special servicer of the Pfizer Building Mortgage Loan, RialtoCapital Advisors, LLC as special servicer of the Prudential - Digital RealtyPortfolio Mortgage Loan, the Moffett Towers - Buildings E, F, G  MortgageLoan and the 2020 Fifth Avenue Mortgage Loan and KeyBank National Associationas special servicer of the Carriage Place Mortgage Loan, listed on the ExhibitIndex are omitted from this Annual Report on Form 10-K as they are not requiredby Item 1123 of Regulation AB to be included on this Annual Report on Form 10-Kbecause they are each an unaffiliated party that is not a “servicer” that meetsthe criteria in Item 1108(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, RelatedStockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

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

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

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

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

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

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

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

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of theOriginal  Complaint alleged breaches of a contract and fiduciary duties byCWCAM’s affiliate, CWCapital Investments LLC in its capacity as collateralmanager for the collateralized debt obligation transaction involving CWCapitalCobalt Vr, Ltd. In total, there are 14 counts pled in the Original Complaint.Of those 14, 5 claims were asserted against CWCAM for aiding and abettingbreach of fiduciary duty, conversion and unjust enrichment. On May 23, 2018,the Original Complaint was dismissed for lack of subject matterjurisdiction.   On June 28, 2018, CWCapital Cobalt Vr Ltd. filed asubstantially similar complaint in the Supreme Court of the State of New York,County of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapital InvestmentsLLC, et al., Index No. 653277/2018 (the “New Complaint”).  Thegravamen of the New Complaint is the same as the previous complaint filed inthe United State District Court for the Southern District of New York.  Intotal there are 16 counts pled in the New Complaint. Of those 16 counts, 5claims were asserted against CWCAM for aiding and abetting breach of fiduciaryduty, conversion and unjust enrichment, 1 count seeks a declaratory judgementthat the plaintiff has the right to enforce the contracts in question and 1count seeks an injunction requiring the defendants to recognize the plaintiffas the directing holder for the trusts in question. On January 11, 2019, theplaintiff dismissed with prejudice the declaratory judgment and injunctioncounts.  The New Complaint and related summons was not served on thedefendants until July 13, 2018 and July 16, 2018.  The plaintiff’s motionfor a preliminary injunction was denied by the court on July 31, 2018.  OnAugust 3, 2018, the defendants, including CWCAM, filed a motion to dismiss theNew Complaint in its entirety. On August 20, 2019, the court entered an ordergranting defendants’ motion almost in its entirety, dismissing 11 of the 16counts and partially dismissing 2 additional counts.  Of the remainingcounts, 2 are asserted against CWCAM for aiding and abetting breach offiduciary duty and unjust enrichment.  On September 19, 2019, CWCapitalCobalt Vr Ltd. filed a notice of appeal relating to the August 20, 2019 dismissalorder and on September 26, 2019, filed an amended complaint against CWCI andCWCAM attempting to address deficiencies relating to certain of the claimsdismissed by the August, 20, 2019 order.  CWCI and CWCAM filed its Motionto Dismiss the amended complaint on October 28, 2019.  The court heardargument on the Motion to Dismiss the amended complaint on January 22, 2020 andon October 23, 2020, the court granted the motion dismissing the amendedclaims.  On November 30, 2020, CWCapital Cobalt Vr Ltd filed a notice ofappeal relating to the October 23, 2020 dismissal order.  On April 27,2021, the First Department affirmed the dismissal as to claims against CWCAMthat were part of the August 20, 2019 dismissal, but reversed the dismissal oftwo counts for breach of the Collateral Management Agreement againstCWCI.  CWCI has sought leave to file an appeal of the decision.  Bothrequests for leave were denied by the First Department.  The plaintiff hasalso sought leave to appeal the dismissal of the claims against CWCAM. CWCAM believes that it has performed its obligations under the related poolingand servicing agreements in good faith and the remaining allegations in the NewComplaint are without merit.  

On January 24, 2016 PSW NYC LLC commenced a complaint (the“PSW Complaint”) with the Supreme Court of the State of New York, County of NewYork (the “PSW Court”) against Bank of America, N.A. as trustee under thepooling and servicing agreements for Wachovia Bank Commercial Mortgage Trust2007-C30 and COBALT CMBS Commercial Trust 2007-C2, U.S. Bank NationalAssociation as trustee under the pooling and servicing agreements for WachoviaBank Commercial Mortgage Trust 2007-C31, ML-CFC Commercial Mortgage Trust2007-5 and ML-CFC Commercial Mortgage Trust 2007-6 (collectively, the “PSWTrusts”), PCV-M Holdings LLC and CWCapital Asset Management LLC, individuallyand as special servicer for the PSW Trusts (collectively, the “Defendants”)seeking either (a) damages in an amount to be determined by the PSW Court butalleged by the plaintiffs to be approximately $500,000,000 – such amount beingthe amount PSW NYC LLC alleges would have been recovered on certain mezzanineloans (the “PCVST Mezzanine Loans”) related to the Peter Cooper Village andStuyvesant Town property (the “PCVST Property”) in New York City which PSW NYCLLC sold to an entity related to the Defendants pursuant to a settlementagreement related to certain prior litigation (the “2010 Settlement Agreement”)or (b) the rescission of the 2010 Settlement Agreement which would result in,among other things, the rescission of the sale of the PCVST Mezzanine Loans anda claim for certain proceeds from the sale of the PCVST Property. PSW NYC LLCalleges that the Defendants procured the 2010 Settlement Agreement by fraud andfurther that the terms of the 2010 Settlement Agreement were breached by theDefendants. On February 26, 2016, CWCAM on behalf of itself and the otherDefendants filed a motion to dismiss the PSW Complaint (the “CWCAM Motion toDismiss”). On April 11, 2016, PSW NYC LLC opposed the CWCAM Motion to Dismissand cross-moved for a partial summary judgment on liability regardingallegations of breach of the 2010 Settlement Agreement (the “PSWCross-Motion”). On May 5, 2016, the Defendants subsequently filed its reply andopposition to the PSW Cross-Motion. On August 23, 2016, oral arguments wereprovided to the PSW Court regarding the PSW Complaint, the CWCAM Motion toDismiss and the PSW Cross-Motion and the PSW Court took such arguments under advisement.On October 31, 2016, the PSW Court issued an order granting the CWCAM Motion toDismiss, denying the PSW Cross-Motion and dismissing the PSW Complaint withprejudice. Subsequently, PSW NYC LLC filed a notice of appeal relating to suchorder. On February 21, 2017, PSW NYC LLC filed its appeal and supporting briefarguing that the PSW Court erred by finding no breach of the assignmentagreement and no fraudulent inducement. Oral argument was heard on May 4, 2017at which point the court took the arguments under advisement. On May 25, 2017,the New York 1st Department appellate court affirmed the dismissalof all PSW claims and denied a request for leave to appeal to the New YorkCourt of Appeals on September 12, 2017.  

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

 

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

 

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

 

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

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on 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 attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thePooling and Servicing Agreement incorporated by reference as Exhibit 4.1 tothis 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 heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the Aventura Mall 2018-AVM  Transactionincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theAventura Mall 2018-AVM  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 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 tothe pooling 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 the entitiesparticipating 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 incorporatedby reference 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,G  Mortgage Loan, which is being serviced and administered pursuant to thepooling and servicing agreement for the DBGS 2018-C1 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as ScheduleII to the pooling and servicing agreement for the DBGS 2018-C1 Transactionincorporated by reference as Exhibit 4.8 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theDBGS 2018-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 AA to the poolingand servicing 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).

**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          Pooling and Servicing Agreement, dated as of November 1,2018, by and among Banc of America Merrill Lynch Commercial Mortgage Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Midland Loan Services, a Division of PNC Bank, National Association, as GeneralSpecial Servicer, National Cooperative Bank, N.A., as NCB Master Servicer andas NCB Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on November 29, 2018 under Commission File No. 333-206847-10 andincorporated by reference herein).

4.2          Trust and Servicing Agreement, dated as of June 29, 2018,by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, Wells Fargo Bank, National Association, as Servicer, CWCapital AssetManagement LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Park Bridge Lender Services LLC, as Operating Advisor (filed as Exhibit 4.2to the registrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.3          Pooling and Servicing Agreement, dated as of August 1,2018, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Torchlight Loan Services, LLC, as General Special Servicer, NationalCooperative Bank, N.A., as NCB Master Servicer and as NCB Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.6 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).

4.4          Trust and Servicing Agreement, dated as of August 7,2018, by and among Morgan Stanley Capital I Inc., as Depositor, Wells FargoBank, National Association, as Servicer and Special Servicer, Wilmington Trust,National Association, as Trustee, and Wells Fargo Bank, National Association,as Certificate Administrator and Custodian, (filed as Exhibit 4.4 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).

4.5          Pooling and Servicing Agreement, dated as of September 1,2018, by and among Morgan Stanley Capital I Inc., as Depositor, Wells FargoBank, National Association, as General Master Servicer, Rialto CapitalAdvisors, LLC, as General Special Servicer, National Cooperative Bank, N.A., asNCB Master Servicer and as NCB 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 4.7 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).

4.6          Pooling and Servicing Agreement, dated as of October 1,2018, by and among Morgan Stanley Capital I Inc., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer andSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator and Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand Asset Representations Reviewer (filed as Exhibit 4.9 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).

4.7          Pooling and Servicing Agreement, dated as of October 1,2018, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, MidlandLoan Services, a Division of PNC Bank, National Association, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.3 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).

4.8          Pooling and Servicing Agreement, dated as of October 1,2018, by and among Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wilmington Trust, NationalAssociation, as Trustee, Wells Fargo Bank, National Association, as CertificateAdministrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 4.5to the registrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.9          Pooling and Servicing Agreement, dated as of November 1,2018, by and among Credit Suisse Commercial Mortgage Securities Corp., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand as Asset Representations Reviewer (filed as Exhibit 4.8 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).

4.10         Pooling and Servicing Agreement, dated as of February 1,2019, among Wells Fargo Commercial Mortgage Securities, Inc., as Depositor,Wells Fargo Bank, National Association, as General Master Servicer, KeyBankNational Association, as General Special Servicer, National Cooperative Bank,N.A., as NCB Master Servicer and as NCB Special Servicer, Wells Fargo Bank,National Association, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC, as OperatingAdvisor and as Asset Representations Reviewer (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K/A filed on March 18, 2019 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.11         Co-Lender Agreement, dated as of June 7, 2018, by andamong JPMorgan Chase Bank, National Association, Deutsche Bank, AG, New YorkBranch, Wells Fargo Bank, National Association and Morgan Stanley Bank, N.A.(filed as Exhibit 4.10 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).

4.12         Agreement Between Note Holders, dated as of September 27,2018, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder, Wells Fargo Bank, National Association, as Initial Note A-2 Holder,Wells Fargo Bank, National Association, as Initial Note A-3 Holder, and WellsFargo Bank, National Association, as Initial Note A-4 Holder (filed as Exhibit4.11 to the registrant’s Current Report on Form 8-K filed on November 29, 2018under Commission File No. 333-206847-10 and incorporated by reference herein).

4.13         Agreement Between Note Holders, dated as of August 9,2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Initial Note A-2 Holder, Initial Note A-3 Holder, Initial Note A-4 Holder,Initial Note A-5 Holder and Initial Note A-6 Holder, and Morgan Stanley Bank,N.A., as Initial Note B-1 Holder, Initial Note B-2 Holder, Initial Note B-3Holder, Initial Note B-4 Holder, Initial Note B-5 Holder and Initial Note B-6Holder (filed as Exhibit 4.12 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).

4.14         Amended and Restated Agreement Between Note Holders,dated as of September 26, 2018, by and between Bank of America, N.A., asInitial Note A-1 Holder, and Bank of America, N.A., as Initial Note A-2 Holder(filed as Exhibit 4.13 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).

4.15         Co-Lender Agreement, dated as of October 30, 2018, by andamong Deutsche Bank AG, acting through its New York Branch, as Note A-1-1Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-2Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-3Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-4Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-2Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-3Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-4Holder, Goldman Sachs Mortgage Company, as Note A-5 Holder, Wells Fargo Bank,National Association, as Note A-6 Holder, and Wells Fargo Bank, NationalAssociation, as Note A-7 Holder (filed as Exhibit 4.14 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).

4.16         Agreement Between Note Holders, dated as of July 27,2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank,N.A., as Initial Note A-3 Holder, Morgan Stanley Bank, N.A., as Initial NoteA-4 Holder, and Morgan Stanley Bank, N.A., as Initial Note A-5 Holder (filed asExhibit 4.15 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).

4.17         Agreement Between Note Holders, dated as of September 7,2018, by and between Wells Fargo Bank, National Association, as Initial NoteA-1 Holder and Initial Note A-2 Holder, and Column Financial, Inc., as InitialNote A-3 Holder and Initial Note A-4 Holder (filed as Exhibit 4.16 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).

4.18         Agreement Between Note Holders, dated as of August 22,2018, by and between Column Financial, Inc., as Initial Note A-1 Holder, andWells Fargo Bank, National Association, as Initial Note A-2 Holder (filed asExhibit 4.17 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).

4.19         Agreement Between Note Holders, dated as of July 27,2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, andMorgan Stanley Bank, as Initial Note A-2 Holder (filed as Exhibit 4.18 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).

4.20         Agreement Between Note Holders, dated as of November 2,2018, by and between Bank of America, N.A., as Initial Note A-1 Holder, andBank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.19 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).

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

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

33.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

33.3        Midland Loan Services, a Division of PNC Bank,National Association, as General Special Servicer prior to July 7, 2021

33.4        LNR Partners, LLC, as General Special Servicer onand after July 7, 2021

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

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

33.7        Wells Fargo Bank, National Association, asCertificate Administrator

33.8        Wells Fargo Bank, National Association, asCustodian

33.9        Park Bridge Lender Services LLC, as OperatingAdvisor

33.10      CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

33.13      Wells Fargo Bank, National Association, as PrimaryServicer of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.1)

33.14      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 685 Fifth Avenue RetailMortgage Loan prior to July 7, 2021 (see Exhibit 33.3)

33.15      LNR Partners, LLC, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan on and after July 7, 2021 (see Exhibit 33.4)

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

33.17      Wells Fargo Bank, National Association, asCustodian of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.8)

33.18      Park Bridge Lender Services LLC, as OperatingAdvisor of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.9)

33.19      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.10)

33.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

33.21      Wells Fargo Bank, National Association, as PrimaryServicer of the Aventura Mall Mortgage Loan (see Exhibit 33.1)

33.22      CWCapital Asset Management LLC, as SpecialServicer of the Aventura Mall Mortgage Loan

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

33.24      Wells Fargo Bank, National Association, as Custodianof the Aventura Mall Mortgage Loan (see Exhibit 33.8)

33.25      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aventura Mall Mortgage Loan (see Exhibit 33.9)

33.26      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Aventura Mall Mortgage Loan (see Exhibit 33.10)

33.27      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

33.28      Wells Fargo Bank, National Association, as PrimaryServicer of the Pfizer Building Mortgage Loan (see Exhibit 33.1)

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

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

33.31      Wells Fargo Bank, National Association, asCustodian of the Pfizer Building Mortgage Loan (see Exhibit 33.8)

33.32      Pentalpha Surveillance LLC, as Operating Advisorof the Pfizer Building Mortgage Loan

33.33      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Pfizer Building Mortgage Loan (see Exhibit 33.10)

33.34      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

33.35      Wells Fargo Bank, National Association, as PrimaryServicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 33.1)

33.36      Wells Fargo Bank, National Association, as SpecialServicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 33.1)

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

33.38      Wells Fargo Bank, National Association, asCustodian of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 33.8)

33.39      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Millennium Partners Portfolio Mortgage Loan (see Exhibit33.10)

33.40      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

33.41      Wells Fargo Bank, National Association, as PrimaryServicer of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 33.1)

33.42      Rialto Capital Advisors, LLC, as Special Servicerof the Prudential - Digital Realty Portfolio Mortgage Loan

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

33.44      Wells Fargo Bank, National Association, asCustodian of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 33.8)

33.45      Park Bridge Lender Services LLC, as OperatingAdvisor of the Prudential - Digital Realty Portfolio Mortgage Loan (see Exhibit33.9)

33.46      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 33.10)

33.47      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

33.48      Midland Loan Services, a Division of PNC Bank, NationalAssociation, as Primary Servicer of the Plaza Frontenac Mortgage Loan (seeExhibit 33.3)

33.49      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Plaza Frontenac Mortgage Loan(see Exhibit 33.3)

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

33.51      Wells Fargo Bank, National Association, as Custodianof the Plaza Frontenac Mortgage Loan (see Exhibit 33.8)

33.52      Pentalpha Surveillance LLC, as Operating Advisorof the Plaza Frontenac Mortgage Loan (see Exhibit 33.32)

33.53      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

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

33.55      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 33.3)

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

33.57      Wells Fargo Bank, National Association, as Custodianof the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.8)

33.58      Park Bridge Lender Services LLC, as OperatingAdvisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.9)

33.59      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.10)

33.60      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

33.61      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 33.1)

33.62      Rialto Capital Advisors, LLC, as Special Servicerof the Moffett Towers - Buildings E, F, G  Mortgage Loan (see Exhibit33.42)

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

33.64      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 33.8)

33.65      Park Bridge Lender Services LLC, as OperatingAdvisor of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 33.9)

33.66      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 33.10)

33.67      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

33.68      Wells Fargo Bank, National Association, as PrimaryServicer of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.1)

33.69      Rialto Capital Advisors, LLC, as Special Servicerof the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.42)

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

33.71      Wells Fargo Bank, National Association, asCustodian of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.8)

33.72      Pentalpha Surveillance LLC, as Operating Advisorof the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.32)

33.73      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.10)

33.74      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

33.75      Wells Fargo Bank, National Association, as PrimaryServicer of the Carriage Place Mortgage Loan (see Exhibit 33.1)

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

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

33.78      Wells Fargo Bank, National Association, asCustodian of the Carriage Place Mortgage Loan (see Exhibit 33.8)

33.79      Park Bridge Lender Services LLC, as OperatingAdvisor of the Carriage Place Mortgage Loan (see Exhibit 33.9)

33.80      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Carriage Place Mortgage Loan (see Exhibit 33.10)

33.81      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.12)

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

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

34.3        Midland Loan Services, a Division of PNC Bank,National Association, as General Special Servicer prior to July 7, 2021

34.4        LNR Partners, LLC, as General Special Servicer onand after July 7, 2021

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

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

34.7        Wells Fargo Bank, National Association, asCertificate Administrator

34.8        Wells Fargo Bank, National Association, asCustodian

34.9        Park Bridge Lender Services LLC, as OperatingAdvisor

34.10      CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

34.13      Wells Fargo Bank, National Association, as Primary Servicerof the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.1)

34.14      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 685 Fifth Avenue RetailMortgage Loan prior to July 7, 2021 (see Exhibit 34.3)

34.15      LNR Partners, LLC, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan on and after July 7, 2021 (see Exhibit 34.4)

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

34.17      Wells Fargo Bank, National Association, asCustodian of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.8)

34.18      Park Bridge Lender Services LLC, as OperatingAdvisor of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.9)

34.19      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.10)

34.20      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.21      Wells Fargo Bank, National Association, as PrimaryServicer of the Aventura Mall Mortgage Loan (see Exhibit 34.1)

34.22      CWCapital Asset Management LLC, as SpecialServicer of the Aventura Mall Mortgage Loan

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

34.24      Wells Fargo Bank, National Association, asCustodian of the Aventura Mall Mortgage Loan (see Exhibit 34.8)

34.25      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aventura Mall Mortgage Loan (see Exhibit 34.9)

34.26      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Aventura Mall Mortgage Loan (see Exhibit 34.10)

34.27      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.28      Wells Fargo Bank, National Association, as PrimaryServicer of the Pfizer Building Mortgage Loan (see Exhibit 34.1)

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

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

34.31      Wells Fargo Bank, National Association, asCustodian of the Pfizer Building Mortgage Loan (see Exhibit 34.8)

34.32      Pentalpha Surveillance LLC, as Operating Advisorof the Pfizer Building Mortgage Loan

34.33      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Pfizer Building Mortgage Loan (see Exhibit 34.10)

34.34      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.35      Wells Fargo Bank, National Association, as PrimaryServicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 34.1)

34.36      Wells Fargo Bank, National Association, as SpecialServicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 34.1)

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

34.38      Wells Fargo Bank, National Association, asCustodian of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 34.8)

34.39      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Millennium Partners Portfolio Mortgage Loan (see Exhibit34.10)

34.40      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.41      Wells Fargo Bank, National Association, as PrimaryServicer of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 34.1)

34.42      Rialto Capital Advisors, LLC, as Special Servicerof the Prudential - Digital Realty Portfolio Mortgage Loan

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

34.44      Wells Fargo Bank, National Association, asCustodian of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 34.8)

34.45      Park Bridge Lender Services LLC, as OperatingAdvisor of the Prudential - Digital Realty Portfolio Mortgage Loan (see Exhibit34.9)

34.46      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 34.10)

34.47      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.48      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Plaza Frontenac Mortgage Loan(see Exhibit 34.3)

34.49      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Plaza Frontenac Mortgage Loan(see Exhibit 34.3)

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

34.51      Wells Fargo Bank, National Association, asCustodian of the Plaza Frontenac Mortgage Loan (see Exhibit 34.8)

34.52      Pentalpha Surveillance LLC, as Operating Advisorof the Plaza Frontenac Mortgage Loan (see Exhibit 34.32)

34.53      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

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

34.55      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 34.3)

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

34.57      Wells Fargo Bank, National Association, asCustodian of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.8)

34.58      Park Bridge Lender Services LLC, as OperatingAdvisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.9)

34.59      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.10)

34.60      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.61      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 34.1)

34.62      Rialto Capital Advisors, LLC, as Special Servicerof the Moffett Towers - Buildings E, F, G  Mortgage Loan (see Exhibit34.42)

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

34.64      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 34.8)

34.65      Park Bridge Lender Services LLC, as OperatingAdvisor of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 34.9)

34.66      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 34.10)

34.67      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.68      Wells Fargo Bank, National Association, as PrimaryServicer of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.1)

34.69      Rialto Capital Advisors, LLC, as Special Servicerof the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.42)

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

34.71      Wells Fargo Bank, National Association, asCustodian of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.8)

34.72      Pentalpha Surveillance LLC, as Operating Advisorof the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.32)

34.73      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.10)

34.74      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

34.75      Wells Fargo Bank, National Association, as PrimaryServicer of the Carriage Place Mortgage Loan (see Exhibit 34.1)

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

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

34.78      Wells Fargo Bank, National Association, as Custodianof the Carriage Place Mortgage Loan (see Exhibit 34.8)

34.79      Park Bridge Lender Services LLC, as OperatingAdvisor of the Carriage Place Mortgage Loan (see Exhibit 34.9)

34.80      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Carriage Place Mortgage Loan (see Exhibit 34.10)

34.81      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.12)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

35.3        Midland Loan Services, a Division of PNC Bank,National Association, as General Special Servicer prior to July 7, 2021

35.4        LNR Partners, LLC, as General Special Servicer onand after July 7, 2021

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

35.6        Wells Fargo Bank, National Association, asCertificate Administrator

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

35.8        Wells Fargo Bank, National Association, as PrimaryServicer of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 35.1)

35.9        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the 685 Fifth Avenue RetailMortgage Loan prior to July 7, 2021 (see Exhibit 35.3)

35.10      LNR Partners, LLC, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan on and after July 7, 2021 (see Exhibit 35.4)

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

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

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

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

35.15      Wells Fargo Bank, National Association, as PrimaryServicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 35.1)

35.16      Wells Fargo Bank, National Association, as SpecialServicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 35.1)

35.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 35.1)

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

35.19      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Plaza Frontenac Mortgage Loan(see Exhibit 35.3)

35.20      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Plaza Frontenac Mortgage Loan(see Exhibit 35.3)

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

35.22      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 35.3)

35.23      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G  Mortgage Loan (seeExhibit 35.1)

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

35.25      Wells Fargo Bank, National Association, as PrimaryServicer of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 35.1)

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

35.27      Wells Fargo Bank, National Association, as PrimaryServicer of the Carriage Place Mortgage Loan (see Exhibit 35.1)

35.28      KeyBank National Association, as Special Servicer of the Carriage Place MortgageLoan (Omitted. See Explanatory Notes.)

99.1         Mortgage Loan Purchase Agreement, dated as of November16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. andMorgan Stanley Mortgage Capital Holdings LLC (filed as Exhibit 99.1 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)

99.2         Mortgage Loan Purchase Agreement, dated as of November16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. andWells Fargo Bank, National Association (filed as Exhibit 99.2 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)

99.3         Mortgage Loan Purchase Agreement, dated as of November16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. andBank of America, National Association (filed as Exhibit 99.3 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)

99.4         Mortgage Loan Purchase Agreement, dated as of November16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. andNational Cooperative Bank, N.A. (filed as Exhibit 99.4 to the registrant’sCurrent Report on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein)

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

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

(senior officer in charge ofsecuritization of the depositor)

Date: March 10, 2022