**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**WASHINGTON,D.C. 20549**

**FORM 10‐K**

(Mark one)

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

**    For the fiscal year endedDecember 31, 2022 OR**

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

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

 

 

 

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

 

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

 

**Morgan Stanley Capital ITrust 2018-L1**

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

 

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

 

**Morgan Stanley Capital I Inc.**

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

 

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

 

**Morgan Stanley MortgageCapital Holdings LLC**

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

 

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

 

**KeyBank National Association**

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

 

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

 

**Starwood Mortgage Capital LLC**

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

 

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

 

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

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

 

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

 

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

**9062 Old Annapolis Road**

** Columbia, MD**

**(Address of principal executive offices)**

 

**21045**

**(Zip Code)**

 

**Telephone number, including area code:**

**(410) 884‐2000**

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

 

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

 

 

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

 

  NONE.

 

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

 

  Yes___ No X

 

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

 

  Yes___ No X

 

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

 

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

 

  YesX No ___

 

Indicateby check mark whether the registrant has submitted electronically everyInteractive Data File required to be submitted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit suchfiles).

 

  Notapplicable.

  

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

 

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

 

Emerginggrowth company ___

 

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

 

  Notapplicable.

 

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

 

  Notapplicable.

 

If securities are registered pursuant to Section 12(b)of the Act, indicate by check mark whether the financial statements of the

registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements.

 

Not applicable.

 

Indicateby check mark whether any of those error corrections are restatements thatrequired a recovery analysis of incentive-based compensation received by any ofthe registrant’s executive officers during the relevant recovery periodpursuant to §240.10D-1(b).

 

Not applicable.

 

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

 

  Yes___ No X

 

Statethe aggregate market value of the voting and non-voting common equity held by non-affiliatescomputed by reference to the price at which the common equity was last sold, orthe average bid and asked price of such common equity, as of the last businessday of the registrant's most recently completed second fiscal quarter.

 

  Notapplicable.

 

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

 

  Notapplicable.

 

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

 

  Notapplicable.

 

DOCUMENTSINCORPORATED BY REFERENCE

 

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

 

  Notapplicable.

 

**EXPLANATORY NOTES**

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

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

 

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

 

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

 

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

 

•   The operating advisor under apooling and servicing agreement represents the interests of senior certificateholdersin the transaction governed by such pooling and servicing agreement and isresponsible for monitoring the performance of the special servicer under suchpooling and servicing agreement and producing certain reports tocertificateholders relating to the resolution of the mortgage pool securitizedpursuant to such pooling and servicing agreement.  The operating advisorunder a pooling and servicing agreement does not have any obligations withrespect to any other transaction and is solely obligated to perform loanreporting functions with respect to the securitization governed by such poolingand servicing agreement.  Consequently, the operating advisor under anOutside Pooling and Servicing Agreement neither participates in the servicing functionfor purposes of Item 1122 of Regulation AB nor performs the functions of aservicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.  In addition,while the operating advisor under a pooling and servicing agreement has certainreporting obligations in respect of the related mortgage pool, it has noobligation to collect or disburse funds in respect of the mortgage pool or toadminister any of the underlying mortgage loans.  Consequently, theoperating advisor under a pooling and servicing agreement participates in theservicing function for purposes of Item 1122 of Regulation AB, but is notresponsible for the “management or collection of the pool assets or makingallocations or distributions to holders of the asset-backed securities” withinthe meaning of “servicer” under Item 1101 of Regulation AB and does not performthe functions of a servicer for purposes of Item 1123 of Regulation AB. 

 

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

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

 

•   NCB, N.A. as NCB masterservicer and NCB special servicer under the BANK 2019-BNK16 pooling and servicingagreement, only has obligations in respect of certain mortgage loans sold tothe BANK 2019-BNK16 securitization trust by NCB, N.A. or its affiliate and hasno obligations with respect to the Regions Tower mortgage loan and therefore insuch capacity does not constitute a reporting “servicing function participant”for purposes of Item 1122 of Regulation AB, as specified in the Instruction 3to Item 1122, and does not constitute a reporting “servicer” for purposes ofItem 1123 of Regulation AB, as specified in the Instruction to Item 1123.

 

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

 

•   Torchlight Loan Services, LLCwas, until August 10, 2022, the special servicer under the BANK 2018-BNK13pooling and servicing agreement, pursuant to which the Griffin Portfolio IImortgage loan is serviced. Because Torchlight Loan Services, LLC is not the MSC2018-L1 special servicer, is not affiliated with any sponsor and serviced onlythe Griffin Portfolio II mortgage loan, which constitutes more than 5% but lessthan 10% of the mortgage pool, Torchlight Loan Services, LLC, as BANK2018-BNK13 special servicer, constitutes a reporting “servicing functionparticipant” for purposes of Item 1122 of Regulation AB, as specified in theInstruction 3 to Item 1122, but does not constitute a reporting “servicer” forpurposes of Item 1123 of Regulation AB, as specified in the Instruction to Item1123.

 

• Mount Street US (Georgia) LLP is the current specialservicer under the BANK 2018-BNK13 pooling and servicing agreement, pursuant towhich the Griffin Portfolio II mortgage loan is serviced. On August 11, 2022,Torchlight Loan Services, LLC was replaced as special servicer under the BANK2018-BNK13 pooling and servicing agreement and was succeeded by Mount Street US(Georgia) LLP. Because Mount Street US (Georgia) LLP is not the MSC 2018-L1special servicer, is not affiliated with any sponsor and services only theGriffin Portfolio II mortgage loan, which constitutes more than 5% but lessthan 10% of the mortgage pool, Mount Street US (Georgia) LLP, as BANK2018-BNK13 special servicer, constitutes a reporting “servicing functionparticipant” for purposes of Item 1122 of Regulation AB, as specified in theInstruction 3 to Item 1122, but does not constitute a reporting “servicer” forpurposes of Item 1123 of Regulation AB, as specified in the Instruction to Item1123.

 

•   Wells Fargo Bank, NationalAssociation is the special servicer under the MSC 2018-MP trust and servicingagreement, pursuant to which the Millennium Partners Portfolio mortgage loan isserviced. Because Wells Fargo Bank, National Association is not the MSC 2018-L1special servicer, is not affiliated with any sponsor and services only theMillennium Partners Portfolio mortgage loan, which constitutes more than 5% butless than 10% of the mortgage pool, Wells Fargo Bank, National Association, asMSC 2018-MP special servicer, constitutes a reporting “servicing functionparticipant” for purposes of Item 1122 of Regulation AB, as specified in theInstruction 3 to Item 1122, but does not constitute a reporting “servicer” forpurposes of Item 1123 of Regulation AB, as specified in the Instruction to Item1123.

 

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

 

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

 

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

 

In addition, each of the following partiesengaged the services of certain servicing function participants and sub-servicersfor the reporting period, as set forth below:

 

•   Midland Loan Services, a Division of PNC Bank, NationalAssociation, as master servicer, engaged the servicesof KeyBank National Association and Berkeley PointCapital LLC, in each case as a sub-servicer inrespect of the entire mortgage pool for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the AMT 2018-AVM trust and servicingagreement, pursuant to which the Aventura Mall mortgage loan is serviced,engaged the services of CoreLogic Solutions, LLC as a servicing functionparticipant in respect of the Aventura Mall mortgage loan for the reportingperiod.

 

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

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BANK 2019-BNK16 pooling and servicingagreement, pursuant to which the Regions Tower mortgage loan is serviced,engaged the services of CoreLogic Solutions, LLC as a servicing functionparticipant in respect of the Regions Tower mortgage loan for the reportingperiod.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer and special servicer under the MSC 2018-MPtrust and servicing agreement, pursuant to which the Millennium PartnersPortfolio mortgage loan is serviced, engaged the services of CoreLogicSolutions, LLC as a servicing function participant in respect of the MillenniumPartners Portfolio mortgage loan for the reporting period.

 

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

 

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

 

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

 

 

| **PART I**   |                            |
|-------------------|---------------------------------|
|              |                            |
| **Item 1.**  | **Business.**                   |
|              | Omitted.                        |
| **Item 1A.** | **Risk Factors.**          |
|              | Omitted.                        |
| **Item 1B.** | **Unresolved Staff  Comments.** |
|              | None.                           |
| **Item 2.**  | **Properties.**                 |
|              | Omitted.                        |
| **Item 3.**  | **Legal Proceedings.**     |
|              | Omitted.                        |
| **Item 4.**  | **Mine Safety Disclosures.**    |
|              | Omitted.                        |
|              |                            |   |

 

| **PART II**  |                                                                                                                |
|-------------------|---------------------------------------------------------------------------------------------------------------------|
|              |                                                                                                                |
| **Item 5.**  | **Market for Registrant's Common  Equity, Related Stockholder Matters and Issuer Purchases of Equity  Securities.** |
|              | Omitted.                                                                                                            |
| **Item 6.**  | **[Reserved]**                                                                                                      |
|              |                                                                                                                |
| **Item 7.**  | **Management's Discussion  and Analysis of Financial Condition and Results of Operations.**                         |
|              | Omitted.                                                                                                            |
| **Item 7A.** | **Quantitative and  Qualitative Disclosures About Market Risk.**                                                    |
|              | Omitted.                                                                                                            |
| **Item 8.**  | **Financial Statements and  Supplementary Data.**                                                                   |
|              | Omitted.                                                                                                            |
| **Item 9.**  | **Changes in and  Disagreements With Accountants on Accounting and Financial Disclosure.**                          |
|              | Omitted.                                                                                                            |
| **Item 9A.** | **Controls and Procedures.**                                                                                        |
|              | Omitted.                                                                                                            |
| **Item 9B.** | **Other Information.**                                                                                         |
|              | None.                                                                                                               |
| **Item 9C.** | **Disclosure Regarding  Foreign Jurisdictions that Prevent Inspections.**                                           |
|              | None.                                                                                                               |
|              |                                                                                                                |   |

 

| **PART III** |                                                                                                 |
|-------------------|------------------------------------------------------------------------------------------------------|
|              |                                                                                                 |
| **Item 10.** | **Directors, Executive Officers  and Corporate Governance.**                                         |
|              | Omitted.                                                                                             |
| **Item 11.** | **Executive Compensation.**                                                                          |
|              | Omitted.                                                                                             |
| **Item 12.** | **Security Ownership of  Certain Beneficial Owners and Management and Related Stockholder Matters.** |
|              | Omitted.                                                                                             |
| **Item 13.** | **Certain Relationships and  Related Transactions, and Director Independence.**                      |
|              | Omitted.                                                                                             |
| **Item 14.** | **Principal Accountant Fees  and Services.**                                                         |
|              | Omitted.                                                                                             |
|              |                                                                                                 |   |

 

**ADDITIONALDISCLOSURE ITEMS FOR REGULATION AB**

 

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

 

Notapplicable.

 

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

 

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

 

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

 

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

 

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

 

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

 

InDecember 2014, Phoenix Light SF Limited (Phoenix Light) and certain relatedentities filed a complaint in the United States District Court for the SouthernDistrict of New York alleging claims against Wells Fargo Bank, N.A., in itscapacity as trustee for a number of residential mortgage-backed securities(RMBS) trusts. Complaints raising similar allegations have been filed byCommerzbank AG in the Southern District of New York and by IKB Internationaland IKB Deutsche Industriebank in New York state court. In each case, theplaintiffs allege that Wells Fargo Bank, N.A., as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. In July2022, the district court dismissed Phoenix Light’s claims and certain of theclaims asserted by Commerzbank AG, and subsequently entered judgment in eachcase in favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light andCommerzbank AG appealed the district court’s decision to the United StatesCourt of Appeals for the Second Circuit. Wells Fargo Bank, N.A. previouslysettled two class actions filed by institutional investors and an action filedby the National Credit Union Administration with similar allegations. In addition,Park Royal I LLC and Park Royal II LLC have filed substantially similarlawsuits in New York state court alleging Wells Fargo Bank, N.A., as trustee,failed to take appropriate actions upon learning of defective mortgage loandocumentation.

 

From time to time, CWCapital Asset Management LLC, aDelaware limited 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.

 

OnDecember 17, 2015, U.S. Bank National Association, the trustee under fivepooling and servicing agreements for (i) Wachovia Bank Commercial MortgageTrust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2, (iii) Wachovia BankCommercial Mortgage Trust 2007-C31, (iv) ML-CFC Commercial Mortgage Trust2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenced a proceedingwith the Second Judicial District Court of Ramsey County, Minnesota (the “StateCourt”) for a declaratory judgment as to the proper allocation of certainproceeds (“Disputed Proceeds”) received by CWCAM in connection with the sale ofthe Peter Cooper Village and Stuyvesant Town property in New York, New Yorksecuring loans held by those trusts. CWCAM was the special servicer of suchproperty. The petition requests the State Court to instruct the trustee, thetrust beneficiaries, and any other interested parties as to the amount of theDisputed Proceeds, if any, that constitute penalty interest and/or the amountof the Disputed Proceeds, if any, that constitute gain-on-sale proceeds, withrespect to each trust. On February 24, 2016, CWCAM made a limited appearancewith the State Court to file a motion to dismiss this proceeding based on lackof jurisdiction, mootness, standing and forum non conveniens. On July 19, 2016,the State Court denied CWCAM’s motion to dismiss. On July 22, 2016, the actionwas removed to federal court in Minnesota (“Federal Court”). On October 21,2016, the Federal Court held a hearing on the motion to transfer the action tothe United States District Court for the Southern District of New York (“SDNYCourt”), a motion to remand to state court and a motion to hear CWCAM’s requestfor reconsideration of the motion to dismiss. On March 14, 2017, the FederalCourt reserved the determination on the motion to hear CWCAM’s request forreconsideration of the motion to dismiss, denied the motion to remand thematter to state court and granted the motion to transfer the proceeding to theSDNY Court. Cross motions for judgment on the pleadings were filed but the SDNYCourt was unable to decide the case based on the pleadings and the SDNY Courtordered discovery. All fact discovery was completed in December, 2018 and expertdiscovery was completed on March 15, 2019. The parties submitted cross motionsfor summary judgment, and on March 19, 2020, the SDNY Court entered an opinionand order in which it granted summary judgment in CWCAM’s favor and held thatCWCAM was entitled to the entire amount of penalty interest and that CWCAM’sdetermination of Yield Maintenance was correct. In the 127-page opinion, theSDNY Court found for CWCAM on every issue presented by the trustee’s petition,namely, that the funds in dispute constitute penalty interest and yieldmaintenance, not gain-on-sale proceeds, and that the amount of penalty interestand yield maintenance was correctly calculated. An appeal of the SDNY Court’sdecision was taken on April 29, 2020. Oral argument on the appeal occurred onJune 21, 2021. On July 14, 2022, the Second Circuit entered a decisionaffirming in part and reversing in part the SDNY Court’s decision and remandingto the SDNY Court for further proceedings. The Second Circuit affirmed theSDNY’s Court holding that Penalty Interest and Yield Maintenance are paidbefore Gain-On-Sale Proceeds. The Second Circuit reversed and remanded forfurther proceedings that portion of the SDNY Court’s decision related toapproximately $67.2 million in interest on advances. On January 13, 2023, theparties entered into a settlement agreement, in which (among other things) theyagreed to stipulate that the amount of interest on advances that accrued on orbefore June 3, 2014 is $27.5 million, and that CWCAM would pay that amount intoescrow for distribution to certificateholders upon the entry of an order by theCourt approving the settlement. U.S. Bank National Association, as Trustee forthe trusts, provided notice of the settlement to all parties in interest via anotice program approved by the Court. A hearing on the settlement is scheduledfor March 16, 2023.

 

OnDecember 1, 2017, a complaint against CWCAM and others was filed in the UnitedStates District Court for the Southern District of New York styled as CWCapitalCobalt Vr Ltd. v. CWCapital Investments LLC, et al., No. 17-cv-9463 (the“Original Complaint”). The gravamen of the Original Complaint alleged breachesof a contract and fiduciary duties by CWCAM’s affiliate, CWCapital InvestmentsLLC in its capacity as collateral manager for the collateralized debtobligation transaction involving CWCapital Cobalt Vr, Ltd. In total, there are14 counts pled in the Original Complaint. Of those 14, 5 claims were assertedagainst CWCAM for aiding and abetting breach of fiduciary duty, conversion andunjust enrichment. On May 23, 2018, the Original Complaint was dismissed forlack of subject matter jurisdiction. On June 28, 2018, CWCapital Cobalt Vr Ltd.filed a substantially similar complaint in the Supreme Court of the State ofNew York, County of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapitalInvestments LLC, 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. In totalthere are 16 counts pled in the New Complaint. Of those 16 counts, 5 claimswere asserted against CWCAM for aiding and abetting breach of fiduciary duty,conversion and unjust enrichment, 1 count seeks a declaratory judgement thatthe plaintiff has the right to enforce the contracts in question and 1 countseeks an injunction requiring the defendants to recognize the plaintiff as thedirecting holder for the trusts in question. On January 11, 2019, the plaintiffdismissed with prejudice the declaratory judgment and injunction counts. TheNew Complaint and related summons was not served on the defendants until July13, 2018 and July 16, 2018. The plaintiff’s motion for a preliminary injunctionwas denied by the court on July 31, 2018. On August 3, 2018, the defendants,including CWCAM, filed a motion to dismiss the New Complaint in its entirety.On August 20, 2019, the court entered an order granting defendants’ motionalmost in its entirety, dismissing 11 of the 16 counts and partially dismissing2 additional counts. Of the remaining counts, 2 are asserted against CWCAM foraiding and abetting breach of fiduciary duty and unjust enrichment. OnSeptember 19, 2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relatingto the August 20, 2019 dismissal order and on September 26, 2019, filed anamended complaint against CWCI and CWCAM attempting to address deficienciesrelating to certain of the claims dismissed by the August 20, 2019 order. CWCIand CWCAM filed its Motion to Dismiss the amended complaint on October 28,2019. The court heard argument on the Motion to Dismiss the amended complainton January 22, 2020 and on October 23, 2020, the court granted the motiondismissing the amended claims. On November 30, 2020, CWCapital Cobalt Vr Ltdfiled a notice of appeal relating to the October 23, 2020 dismissal order. OnApril 27, 2021, the First Department affirmed the dismissal as to claimsagainst CWCAM that were part of the August 20, 2019 dismissal, but reversed thedismissal of two counts for breach of the Collateral Management Agreementagainst CWCI. CWCI sought leave to file an appeal of the decision. Theplaintiff also sought leave to appeal the dismissal of the claims againstCWCAM. Both requests for leave were denied by the First Department. On May 15,2020, CWCI and CWCAM filed a motion to renew its motion to dismiss as to 4 ofthe remaining counts (including the remaining two counts against CWCAM foraiding and abetting breach of fiduciary duty and unjust enrichment), based on adecision entered by Judge Failla in a trust instruction proceeding in the USDistrict Court for the Southern District of New York awarding summary judgmentin favor of CWCAM. On September 7, 2021, the court denied the motion to renew.CWCI and CWCAM filed a notice of appeal, which they perfected by the filing oftheir opening brief on July 1, 2022. On November 15, 2022, the First Departmentaffirmed the court’s denial of the motion to renew. On October 1, 2021, CWCIand CWCAM moved to reargue the denial of the motion to renew (or alternatively,the motion to dismiss) with respect to certain of Cobalt’s claims, includingthe remaining 2 claims against CWCAM, based on the First Department’s April 27,2021 decision. On March 24, 2022, the court denied the relief sought in themotion to reargue. CWCI and CWCAM have appealed the court’s decision on themotion to reargue and filed their opening brief on July 11, 2022. The appealwas dismissed as being nonappealable on August 30, 2022. CWCAM believes that ithas performed its obligations under the related pooling and servicingagreements in good faith and the remaining allegations in the New Complaint arewithout merit.

 

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

 

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

 

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

 

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

 

Thereport on assessment of compliance with applicable servicing criteria furnishedpursuant to Item 1122 of Regulation AB by KeyBank National Associationdiscloses that a material instance of noncompliance occurred, as describedbelow:

 

KeyBankNational Association (KeyBank) has identified the following material instanceof noncompliance with servicing criteria 1122(d)(4)(ix) during the calendaryear ended December 31, 2022, with respect to the Platform. The materialinstance of noncompliance does not relate to KeyBank’s performance under anypooling and servicing agreement applicable to the securitization transactionthat is the subject of this Form 10-K.

 

1)Servicing Criteria impacted 

 

1122(d)(4)(ix) –Adjustments to interest rates or ratesof return for pool assets with variable rates are computed based on the relatedpool asset documents. 

 

2)Material Instance of Noncompliance with Servicing Criteria

 

During compliance testing, it was discovered, that notall FlexARM loan mortgagors were offered loan rates within 45-60 days beforethe rate change date, as required per the related pool asset documents. Per theNote, if the holder fails to offer a loan rate within 45-60 days of any changedate a margin of 2.25% is to be used. Given the notification was not made tothe borrowers, a 3% margin was incorrectly applied. The noncompliance in Item1122 (d)(4)(ix) is related to a servicing portfolio which is wholly owned bythe investor and is not held in a publicly traded security. 

 

3)Remediation

 

The following remediation procedures have beeninitiated by KeyBank: (i) the impacted mortgage loans are currently in theprocess of being identified, (ii) investor contact has been initiated, (iii)corrective actions are being considered and will be tracked and monitored bysenior management, (iv) procedures will be reviewed and revised, if necessary,to include new tracking and action steps to prevent this situation fromrecurring in the future, and (v) training will be provided to the relevantstaff members to prevent a recurrence.

 

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

 

Theservicer compliance statements are attached hereto under Item 15.

 

**PART IV**

 

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

 

(a) Exhibits.

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

33.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

33.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

33.3 Wells Fargo Bank, National Association, as Custodian

 

33.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

 

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

 

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

 

33.7  Pentalpha Surveillance LLC, as Operating Advisor

 

33.8  KeyBank National Association, as Primary Servicer

 

33.9  Berkeley Point Capital LLC, as Primary Servicer

 

33.10  Wells Fargo Bank, National Association, as MasterServicer under the AMT 2018-AVM securitization, pursuant to which the followingmortgage loans were serviced by such party: Aventura Mall (from 1/1/22 to12/31/22)

 

33.11  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the AMT 2018-AVM securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Aventura Mall (from1/1/22 to 12/31/22)

 

33.12  Wells Fargo Bank, National Association, as MasterServicer under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/22 to 12/31/22) (see Exhibit 33.10)

 

33.13  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/22 to 12/31/22) (see Exhibit 33.11)

 

33.14  Wells Fargo Bank, National Association, as MasterServicer under the MSC 2018-MP securitization, pursuant to which the followingmortgage loans were serviced by such party: Millennium Partners Portfolio (from1/1/22 to 12/31/22) (see Exhibit 33.10)

 

33.15  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/22 to 12/31/22) (see Exhibit 33.11)

 

33.16  Wells Fargo Bank, National Association, as MasterServicer under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/22to 12/31/22) (see Exhibit 33.10)

 

33.17  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/22to 12/31/22) (see Exhibit 33.11)

 

33.18  Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/22 to 12/31/22) (see Exhibit 33.10)

 

33.19  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/22 to 12/31/22) (see Exhibit 33.11)

 

33.20  KeyBank National Association, as Master Servicer underthe CD 2018-CD7 securitization, pursuant to which the following mortgage loanswere serviced by such party: Zenith Ridge (from 1/1/22 to 12/31/22) (seeExhibit 33.8)

 

33.21  Wells Fargo Bank, National Association, as MasterServicer under the MSC 2018-H3 securitization, pursuant to which the followingmortgage loans were serviced by such party: Playa Largo (from 1/1/22 to12/31/22) and Shoppes at Chino Hills (from 1/1/22 to 12/31/22) (see Exhibit33.10)

 

33.22  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-H3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Playa Largo (from 1/1/22to 12/31/22) and Shoppes at Chino Hills (from 1/1/22 to 12/31/22) (see Exhibit33.11)

 

33.23  Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer under the UBS 2018-C13 securitization,pursuant to which the following mortgage loans were serviced by such party:Shelbourne Global Portfolio I (from 1/1/22 to 12/31/22) (see Exhibit 33.5)

 

33.24  CWCapital Asset Management LLC, as Special Servicerunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/22 to 12/31/22)

 

33.25  Mount Street US (Georgia) LLP, as Special Servicerunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 8/11/22to 12/31/22)

 

33.26  Torchlight Loan Services, LLC, as Special Servicerunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/22to 8/10/22)

 

33.27  Wells Fargo Bank, National Association, as SpecialServicer under the MSC 2018-MP securitization, pursuant to which the followingmortgage loans were serviced by such party: Millennium Partners Portfolio (from1/1/22 to 12/31/22) (see Exhibit 33.10)

 

33.28  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/22 to 12/31/22) (see Exhibit 33.11)

 

33.29  KeyBank National Association, as Special Servicerunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/22 to12/31/22) (see Exhibit 33.8)

 

33.30  LNR Partners, LLC, as Special Servicer under the MSC2018-H3 securitization, pursuant to which the following mortgage loans wereserviced by such party: Playa Largo (from 1/1/22 to 12/31/22) and Shoppes atChino Hills (from 1/1/22 to 12/31/22)

 

33.31  Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer under the UBS 2018-C13securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio I (from 1/1/22 to 12/31/22) (seeExhibit 33.5)

 

33.32  Wells Fargo Bank, National Association, as Custodianunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/22 to 12/31/22) (seeExhibit 33.3)

 

33.33  Computershare Trust Company, National Association, asServicing Function Participant under the AMT 2018-AVM securitization, pursuantto which the following mortgage loans were serviced by such party: AventuraMall (from 1/1/22 to 12/31/22) (see Exhibit 33.4)

 

33.34  Wells Fargo Bank, National Association, as Custodianunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/22to 12/31/22) (see Exhibit 33.3)

 

33.35  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2018-BNK13 securitization,pursuant to which the following mortgage loans were serviced by such party:Griffin Portfolio II (from 1/1/22 to 12/31/22) (see Exhibit 33.4)

 

33.36  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-MP securitization, pursuant to which the following mortgageloans were serviced by such party: Millennium Partners Portfolio (from 1/1/22to 12/31/22) (see Exhibit 33.3)  

 

33.37  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-MP securitization, pursuantto which the following mortgage loans were serviced by such party: MillenniumPartners Portfolio (from 1/1/22 to 12/31/22) (see Exhibit 33.4)

 

33.38  Wells Fargo Bank, National Association, as Custodianunder the COMM 2018-HOME securitization, pursuant to which the followingmortgage loans were serviced by such party: The Gateway (from 1/1/22 to12/31/22) (see Exhibit 33.3)

 

33.39  Computershare Trust Company, National Association, asServicing Function Participant under the COMM 2018-HOME securitization,pursuant to which the following mortgage loans were serviced by such party: TheGateway (from 1/1/22 to 12/31/22) (see Exhibit 33.4)

 

33.40  Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/22 to12/31/22) (see Exhibit 33.3)

 

33.41  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party:Regions Tower (from 1/1/22 to 12/31/22) (see Exhibit 33.4)

 

33.42  Wells Fargo Bank, National Association, as Custodianunder the CD 2018-CD7 securitization, pursuant to which the following mortgageloans were serviced by such party: Zenith Ridge (from 1/1/22 to 12/31/22) (seeExhibit 33.3)

 

33.43  Computershare Trust Company, National Association, asServicing Function Participant under the CD 2018-CD7 securitization, pursuantto which the following mortgage loans were serviced by such party: Zenith Ridge(from 1/1/22 to 12/31/22) (see Exhibit 33.4)

 

33.44  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-H3 securitization, pursuant to which the following mortgageloans were serviced by such party: Playa Largo (from 1/1/22 to 12/31/22) andShoppes at Chino Hills (from 1/1/22 to 12/31/22) (see Exhibit 33.3)

 

33.45  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-H3 securitization, pursuantto which the following mortgage loans were serviced by such party: Playa Largo(from 1/1/22 to 12/31/22) and Shoppes at Chino Hills (from 1/1/22 to 12/31/22)(see Exhibit 33.4)

 

33.46  Wells Fargo Bank, National Association, as Custodianunder the UBS 2018-C13 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio I (from 1/1/22to 12/31/22) (see Exhibit 33.3)

 

33.47  Computershare Trust Company, National Association, asServicing Function Participant under the UBS 2018-C13 securitization, pursuantto which the following mortgage loans were serviced by such party: ShelbourneGlobal Portfolio I (from 1/1/22 to 12/31/22) (see Exhibit 33.4)

 

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

 

34.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

34.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

34.3 Wells Fargo Bank, National Association, as Custodian

 

34.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

 

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

 

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

 

34.7  Pentalpha Surveillance LLC, as Operating Advisor

 

34.8  KeyBank National Association, as Primary Servicer

 

34.9  Berkeley Point Capital LLC, as Primary Servicer

 

34.10  Wells Fargo Bank, National Association, as MasterServicer under the AMT 2018-AVM securitization, pursuant to which the followingmortgage loans were serviced by such party: Aventura Mall (from 1/1/22 to12/31/22)

 

34.11  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the AMT 2018-AVM securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Aventura Mall (from1/1/22 to 12/31/22)

 

34.12  Wells Fargo Bank, National Association, as MasterServicer under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/22 to 12/31/22) (see Exhibit 34.10)

 

34.13  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/22 to 12/31/22) (see Exhibit 34.11)

 

34.14  Wells Fargo Bank, National Association, as MasterServicer under the MSC 2018-MP securitization, pursuant to which the followingmortgage loans were serviced by such party: Millennium Partners Portfolio (from1/1/22 to 12/31/22) (see Exhibit 34.10)

 

34.15  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/22 to 12/31/22) (see Exhibit 34.11)

 

34.16  Wells Fargo Bank, National Association, as MasterServicer under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/22to 12/31/22) (see Exhibit 34.10)

 

34.17  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/22to 12/31/22) (see Exhibit 34.11)

 

34.18  Wells Fargo Bank, National Association, as MasterServicer under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from 1/1/22to 12/31/22) (see Exhibit 34.10)

 

34.19  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/22 to 12/31/22) (see Exhibit 34.11)

 

34.20  KeyBank National Association, as Master Servicer underthe CD 2018-CD7 securitization, pursuant to which the following mortgage loanswere serviced by such party: Zenith Ridge (from 1/1/22 to 12/31/22) (seeExhibit 34.8)

 

34.21  Wells Fargo Bank, National Association, as MasterServicer under the MSC 2018-H3 securitization, pursuant to which the followingmortgage loans were serviced by such party: Playa Largo (from 1/1/22 to12/31/22) and Shoppes at Chino Hills (from 1/1/22 to 12/31/22) (see Exhibit34.10)

 

34.22  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-H3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Playa Largo (from 1/1/22to 12/31/22) and Shoppes at Chino Hills (from 1/1/22 to 12/31/22) (see Exhibit34.11)

 

34.23  Midland Loan Services, a Division of PNC Bank,National Association, as Master Servicer under the UBS 2018-C13 securitization,pursuant to which the following mortgage loans were serviced by such party:Shelbourne Global Portfolio I (from 1/1/22 to 12/31/22) (see Exhibit 34.5)

 

34.24  CWCapital Asset Management LLC, as Special Servicerunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/22 to 12/31/22)

 

34.25  Mount Street US (Georgia) LLP, as Special Servicerunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 8/11/22to 12/31/22)

 

34.26  Torchlight Loan Services, LLC, as Special Servicerunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/22to 8/10/22)

 

34.27  Wells Fargo Bank, National Association, as SpecialServicer under the MSC 2018-MP securitization, pursuant to which the followingmortgage loans were serviced by such party: Millennium Partners Portfolio (from1/1/22 to 12/31/22) (see Exhibit 34.10)

 

34.28  CoreLogic Solutions, LLC, as Servicing FunctionParticipant under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/22 to 12/31/22) (see Exhibit 34.11)

 

34.29  KeyBank National Association, as Special Servicerunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/22 to12/31/22) (see Exhibit 34.8)

 

34.30  LNR Partners, LLC, as Special Servicer under the MSC2018-H3 securitization, pursuant to which the following mortgage loans wereserviced by such party: Playa Largo (from 1/1/22 to 12/31/22) and Shoppes atChino Hills (from 1/1/22 to 12/31/22)

 

34.31  Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer under the UBS 2018-C13securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio I (from 1/1/22 to 12/31/22) (see Exhibit34.5)

 

34.32  Wells Fargo Bank, National Association, as Custodianunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/22 to 12/31/22) (seeExhibit 34.3)

 

34.33  Computershare Trust Company, National Association, asServicing Function Participant under the AMT 2018-AVM securitization, pursuantto which the following mortgage loans were serviced by such party: AventuraMall (from 1/1/22 to 12/31/22) (see Exhibit 34.4)

 

34.34  Wells Fargo Bank, National Association, as Custodianunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/22to 12/31/22) (see Exhibit 34.3)

 

34.35  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2018-BNK13 securitization,pursuant to which the following mortgage loans were serviced by such party:Griffin Portfolio II (from 1/1/22 to 12/31/22) (see Exhibit 34.4)

 

34.36  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-MP securitization, pursuant to which the following mortgageloans were serviced by such party: Millennium Partners Portfolio (from 1/1/22to 12/31/22) (see Exhibit 34.3)  

 

34.37  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-MP securitization, pursuantto which the following mortgage loans were serviced by such party: MillenniumPartners Portfolio (from 1/1/22 to 12/31/22) (see Exhibit 34.4)

 

34.38  Wells Fargo Bank, National Association, as Custodianunder the COMM 2018-HOME securitization, pursuant to which the followingmortgage loans were serviced by such party: The Gateway (from 1/1/22 to12/31/22) (see Exhibit 34.3)

 

34.39  Computershare Trust Company, National Association, asServicing Function Participant under the COMM 2018-HOME securitization,pursuant to which the following mortgage loans were serviced by such party: TheGateway (from 1/1/22 to 12/31/22) (see Exhibit 34.4)

 

34.40  Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/22 to12/31/22) (see Exhibit 34.3)

 

34.41  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party:Regions Tower (from 1/1/22 to 12/31/22) (see Exhibit 34.4)

 

34.42  Wells Fargo Bank, National Association, as Custodianunder the CD 2018-CD7 securitization, pursuant to which the following mortgageloans were serviced by such party: Zenith Ridge (from 1/1/22 to 12/31/22) (seeExhibit 34.3)

 

34.43  Computershare Trust Company, National Association, asServicing Function Participant under the CD 2018-CD7 securitization, pursuantto which the following mortgage loans were serviced by such party: Zenith Ridge(from 1/1/22 to 12/31/22) (see Exhibit 34.4)

 

34.44  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-H3 securitization, pursuant to which the following mortgageloans were serviced by such party: Playa Largo (from 1/1/22 to 12/31/22) andShoppes at Chino Hills (from 1/1/22 to 12/31/22) (see Exhibit 34.3)

 

34.45  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-H3 securitization, pursuantto which the following mortgage loans were serviced by such party: Playa Largo(from 1/1/22 to 12/31/22) and Shoppes at Chino Hills (from 1/1/22 to 12/31/22)(see Exhibit 34.4)

 

34.46  Wells Fargo Bank, National Association, as Custodianunder the UBS 2018-C13 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio I (from 1/1/22to 12/31/22) (see Exhibit 34.3)

 

34.47  Computershare Trust Company, National Association, asServicing Function Participant under the UBS 2018-C13 securitization, pursuantto which the following mortgage loans were serviced by such party: ShelbourneGlobal Portfolio I (from 1/1/22 to 12/31/22) (see Exhibit 34.4)

  

(35). Servicer compliance statement.

 

35.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

35.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator

 

35.3 Wells Fargo Bank, National Association, as Custodian

 

35.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian

 

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

 

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

 

35.7 KeyBank National Association, as PrimaryServicer

 

35.8 Berkeley Point Capital LLC, as PrimaryServicer

 

35.9 Wells Fargo Bank, National Association, asMaster Servicer under the AMT 2018-AVM securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Aventura Mall (from1/1/22 to 12/31/22)

 

35.10 Wells Fargo Bank, National Association, asMaster Servicer under the BANK 2018-BNK13 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Griffin Portfolio II(from 1/1/22 to 12/31/22) (see Exhibit 35.9)

 

35.11 Wells Fargo Bank, National Association, asMaster Servicer under the MSC 2018-MP securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Millennium PartnersPortfolio (from 1/1/22 to 12/31/22) (see Exhibit 35.9)

 

35.12 Wells Fargo Bank, National Association, asMaster Servicer under the COMM 2018-HOME securitization, pursuant to which thefollowing mortgage loans were serviced by such party: The Gateway (from 1/1/22to 12/31/22) (see Exhibit 35.9)

 

35.13 Wells Fargo Bank, National Association, asMaster Servicer under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/22 to 12/31/22) (see Exhibit 35.9)

 

35.14 KeyBank National Association, as MasterServicer under the CD 2018-CD7 securitization, pursuant to which the followingmortgage loans were serviced by such party: Zenith Ridge (from 1/1/22 to12/31/22) (see Exhibit 35.7)

 

35.15 Wells Fargo Bank, National Association, asMaster Servicer under the MSC 2018-H3 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Playa Largo (from 1/1/22to 12/31/22) and Shoppes at Chino Hills (from 1/1/22 to 12/31/22) (see Exhibit35.9)

 

35.16 Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer under the UBS 2018-C13securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio I (from 1/1/22 to 12/31/22) (seeExhibit 35.5)

 

35.17 KeyBank National Association, as SpecialServicer under the BANK 2019-BNK16 securitization, pursuant to which thefollowing mortgage loans were serviced by such party: Regions Tower (from1/1/22 to 12/31/22) (see Exhibit 35.7)

 

35.18 LNR Partners, LLC, as Special Servicer underthe MSC 2018-H3 securitization, pursuant to which the following mortgage loanswere serviced by such party: Playa Largo (from 1/1/22 to 12/31/22) and Shoppesat Chino Hills (from 1/1/22 to 12/31/22)

 

35.19 Midland Loan Services, a Division of PNCBank, National Association, as Special Servicer under the UBS 2018-C13securitization, pursuant to which the following mortgage loans were serviced bysuch party: Shelbourne Global Portfolio I (from 1/1/22 to 12/31/22) (seeExhibit 35.5)

 

35.20  Wells Fargo Bank, National Association, as Custodianunder the AMT 2018-AVM securitization, pursuant to which the following mortgageloans were serviced by such party: Aventura Mall (from 1/1/22 to 12/31/22) (seeExhibit 35.3)

 

35.21  Computershare Trust Company, National Association, asServicing Function Participant under the AMT 2018-AVM securitization, pursuantto which the following mortgage loans were serviced by such party: AventuraMall (from 1/1/22 to 12/31/22) (see Exhibit 35.4)

 

35.22  Wells Fargo Bank, National Association, as Custodianunder the BANK 2018-BNK13 securitization, pursuant to which the followingmortgage loans were serviced by such party: Griffin Portfolio II (from 1/1/22to 12/31/22) (see Exhibit 35.3)

 

35.23  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2018-BNK13 securitization,pursuant to which the following mortgage loans were serviced by such party:Griffin Portfolio II (from 1/1/22 to 12/31/22) (see Exhibit 35.4)

 

35.24  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-MP securitization, pursuant to which the following mortgageloans were serviced by such party: Millennium Partners Portfolio (from 1/1/22to 12/31/22) (see Exhibit 35.3)  

 

35.25  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-MP securitization, pursuantto which the following mortgage loans were serviced by such party: MillenniumPartners Portfolio (from 1/1/22 to 12/31/22) (see Exhibit 35.4)

 

35.26  Wells Fargo Bank, National Association, as Custodianunder the COMM 2018-HOME securitization, pursuant to which the followingmortgage loans were serviced by such party: The Gateway (from 1/1/22 to12/31/22) (see Exhibit 35.3)

 

35.27  Computershare Trust Company, National Association, asServicing Function Participant under the COMM 2018-HOME securitization,pursuant to which the following mortgage loans were serviced by such party: TheGateway (from 1/1/22 to 12/31/22) (see Exhibit 35.4)

 

35.28  Wells Fargo Bank, National Association, as Custodianunder the BANK 2019-BNK16 securitization, pursuant to which the followingmortgage loans were serviced by such party: Regions Tower (from 1/1/22 to12/31/22) (see Exhibit 35.3)

 

35.29  Computershare Trust Company, National Association, asServicing Function Participant under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party: RegionsTower (from 1/1/22 to 12/31/22) (see Exhibit 35.4)

 

35.30  Wells Fargo Bank, National Association, as Custodianunder the CD 2018-CD7 securitization, pursuant to which the following mortgageloans were serviced by such party: Zenith Ridge (from 1/1/22 to 12/31/22) (seeExhibit 35.3)

 

35.31  Computershare Trust Company, National Association, asServicing Function Participant under the CD 2018-CD7 securitization, pursuantto which the following mortgage loans were serviced by such party: Zenith Ridge(from 1/1/22 to 12/31/22) (see Exhibit 35.4)

 

35.32  Wells Fargo Bank, National Association, as Custodianunder the MSC 2018-H3 securitization, pursuant to which the following mortgageloans were serviced by such party: Playa Largo (from 1/1/22 to 12/31/22) andShoppes at Chino Hills (from 1/1/22 to 12/31/22) (see Exhibit 35.3)

 

35.33  Computershare Trust Company, National Association, asServicing Function Participant under the MSC 2018-H3 securitization, pursuantto which the following mortgage loans were serviced by such party: Playa Largo(from 1/1/22 to 12/31/22) and Shoppes at Chino Hills (from 1/1/22 to 12/31/22) (seeExhibit 35.4)

 

35.34  Wells Fargo Bank, National Association, as Custodianunder the UBS 2018-C13 securitization, pursuant to which the following mortgageloans were serviced by such party: Shelbourne Global Portfolio I (from 1/1/22to 12/31/22) (see Exhibit 35.3)

 

35.35  Computershare Trust Company, National Association, asServicing Function Participant under the UBS 2018-C13 securitization, pursuantto which the following mortgage loans were serviced by such party: ShelbourneGlobal Portfolio I (from 1/1/22 to 12/31/22) (see Exhibit 35.4)

 

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

 

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

 

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

 

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

 

(99.5)Co-lender Agreement, dated as of June 7, 2018, by andamong JPMorgan Chase Bank, National Association, as initial note A-1-A holder, initialnote A-2-A-1 holder, initial note A-2-A-2 holder, initial note A-2-A-3 holder,initial note A-2-A-4 holder, initial note A-2-A-5 holder and initial note B-1holder, Deutsche Bank, AG, New York Branch, as initial note A-1-B holder,initial note A-2-B-1 holder, initial note A-2-B-2 holder, initial note A-2-B-3holder, initial note A-2-B-4 holder, initial note A-2-B-5 holder and initialnote B-2 holder, Wells Fargo Bank, National Association, as initial note A-1-Dholder, initial note A-2-D-1 holder, initial note A-2-D-2 holder, initial noteA-2-D-3 holder, initial note A-2-D-4 holder, initial note A-2-D-5 holder andinitial note B-4 holder, and Morgan Stanley Bank, N.A., as initial note A-1-Cholder, initial note A-2-C-1 holder, initial note A-2-C-2 holder, initial noteA-2-C-3 holder, initial note A-2-C-4 holder, initial note A-2-C-5 holder andinitial note B-3 holder, relating to the Aventura Mall loan combination (filedas Exhibit 99.5 to the registrant's Current Report on Form 8-K filed on October23, 2018 under SEC File No. 333-206582-17 and incorporated by referenceherein).

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

(99.16)Agreement Between Note Holders, dated as of July 12,2018, by and between Morgan Stanley Bank, N.A., as initial note A-1 holder,Morgan Stanley Bank, N.A., as initial note A-2 holder, and Morgan Stanley Bank,N.A., as initial note A-3 holder, relating to the Shoppes at Chino Hills loan combination(filed as Exhibit 99.16 to the registrant's Current Report on Form 8-K filed onOctober 23, 2018 under SEC File No. 333-206582-17 and incorporated by referenceherein).

 

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

 

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

 

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

 

(b)See (a) above.

 

(c) NotApplicable.

 

**SIGNATURES**

 

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

 

MorganStanley Capital I Inc.

(Depositor)

 

By:/s/ Jane Lam

JaneLam, President

(seniorofficer in charge of securitization of the depositor)

 

Date: March 28, 2023