**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

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

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226486-01**

**Central Index Key Number of the issuing entity:0001753233**

**Wells Fargo Commercial MortgageTrust 2018-C47**

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

** **

**Central Index Key Number of the depositor: 0000850779**

**Wells Fargo Commercial MortgageSecurities, Inc.**

**(exact name of the depositor 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: 0000312070**

**Barclays Bank PLC**

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

** **

**Central Index Key Number of the sponsor: 0001541468**

**Ladder Capital Finance LLC**

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

** **

**Central Index Key Number of the sponsor: 0001592182**

**LMF Commercial, LLC**

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

**(formerly known as Rialto MortgageFinance, LLC)**

** **

**Central Index Key Number of the sponsor: 0001541214**

**C-III Commercial Mortgage LLC**

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

** **

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

**the issuing entity)** | **38-4088385**

**38-4088386**

**(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:**

**(704) 374-6161**

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

Not applicable.

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

Large accelerated filer       o                                       Accelerated filer                                                                        o

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

                                                                              Emerging growth company                                                        o

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

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Starwood Hotel Portfolio Mortgage Loan,the Virginia Beach Hotel Portfolio Mortgage Loan and the Ellsworth PlaceMortgage Loan, which constituted approximately 7.4%, 4.7% and 2.5%,respectively, of the asset pool of the issuing entity as of its cut-off date,are each an asset of the issuing entity and are each part of a loan combinationthat includes (a) with respect to the Starwood Hotel Portfolio Mortgage Loanwhich is an asset of the issuing entity and three other *pari passu*loans, which are not assets of the issuing entity, (b) with respect to theVirginia Beach Hotel Portfolio Mortgage Loan which is an asset of the issuingentity and two other *pari passu* loans, which are not assets of theissuing entity and (c) with respect to the Ellsworth Place Mortgage Loan whichis an asset of the issuing entity and four other *pari passu* loans, whichare not assets of the issuing entity. These loan combinations, including theStarwood Hotel Portfolio Mortgage Loan, the Virginia Beach Hotel PortfolioMortgage Loan and the Ellsworth Place Mortgage Loan, are being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 to this Annual Report on Form 10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Aventura Mall Mortgage Loan, whichconstituted approximately 5.3% of the asset pool of the issuing entity as ofits cut-off date.  The Aventura Mall Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the AventuraMall Mortgage Loan and twenty-five other *pari passu* loans and foursubordinate companion loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the Aventura MallTrust 2018-AVM transaction (the “Aventura Mall Trust 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 Trust 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 Showcase II Mortgage Loan, which constitutedapproximately 4.7% of the asset pool of the issuing entity as of its cut-offdate.  The Showcase II Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Showcase II Mortgage Loan andtwo other *pari passu* loans, which are not assets of the issuing entity.A *pari passu* portion of the loan combination was securitized in the BANK2018-BNK13 transaction, Commission File Number 333-206677-26 (the “BANK2018-BNK13 Transaction”). This loan combination, including the Showcase IIMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the BANK 2018-BNK13 Transaction, which is incorporatedby reference as Exhibit 4.3 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 Christiana Mall Mortgage Loan, whichconstituted approximately 5.3% of the asset pool of the issuing entity as ofits cut-off date.  The Christiana Mall Mortgage Loan is an asset of the issuingentity and is part of a loan combination that includes the Christiana MallMortgage Loan and twelve other *pari passu* loans and three subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the BBCMS 2018-CHRS MortgageTrust transaction (the “BBCMS 2018-CHRS Transaction”). This loancombination, including the Christiana Mall Mortgage Loan, is being serviced andadministered pursuant to the trust and servicing agreement for the BBCMS2018-CHRS Transaction, which is incorporated by reference as Exhibit 4.4 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 Skyline Village Mortgage Loan, whichconstituted approximately 1.0% of the asset pool of the issuing entity as ofits cut-off date.  The Skyline Village Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the SkylineVillage 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 Wells Fargo Commercial Mortgage Trust2018-C46 transaction, Commission File Number 333-206677-27 (the “WFCM2018-C46 Transaction”). This loan combination, including the SkylineVillage Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the WFCM 2018-C46 Transaction, which isincorporated by reference 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 Indian Hills Senior Community Mortgage Loan,which constituted approximately 2.3% of the asset pool of the issuing entity asof its cut-off date.  The Indian Hills Senior Community Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe Indian Hills Senior Community Mortgage Loan and two other *pari passu*loans, which are not assets of the issuing entity.This loan combination,including the Indian Hills Senior Community Mortgage Loan, was serviced underthe Pooling and Servicing Agreement for the issuing entity prior to the closingof the securitization of a *pari passu* portion of the Indian Hills SeniorCommunity loan combination in the CSAIL 2018-C14 Commercial Mortgage Trusttransaction, Commission File Number 333-207361-10 (the “CSAIL 2018-C14Transaction”).  After the closing of the CSAIL 2018-C14 Transaction onNovember 29, 2018, this loan combination, including the Indian Hills SeniorCommunity Mortgage Loan was, and will continue to be, serviced and administeredpursuant to the pooling and servicing agreement with respect to the CSAIL2018-C14 Transaction, which is incorporated by reference as Exhibit 4.6 to thisAnnual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Holiday Inn FiDi Mortgage Loan, whichconstituted approximately 3.7% of the asset pool of the issuing entity as ofits cut-off date.  The Holiday Inn FiDi Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Holiday InnFiDi Mortgage Loan and two other *pari passu* loans and one subordinatecompanion loan, which are not assets of the issuing entity.This loancombination, including the Holiday Inn FiDi Mortgage Loan, was serviced underthe Pooling and Servicing Agreement for the issuing entity prior to the closingof the securitization of a *pari passu* portion of the Holiday Inn FiDiloan combination in the Citigroup Commercial Mortgage Trust 2018-C6transaction, Commission File Number 333-207132-20 (the “CGCMT 2018-C6Transaction”).  After the closing of the CGCMT 2018-C6 Transaction onDecember 11, 2018, this loan combination, including the Holiday Inn FiDiMortgage Loan was, and will continue to be, serviced and administered pursuantto the pooling and servicing agreement with respect to the CGCMT 2018-C6Transaction, which is incorporated by reference as Exhibit 4.7 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 master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement, the primaryservicer of the Aventura Mall Mortgage Loan, the Showcase II Mortgage Loan, theHoliday Inn FiDi Mortgage Loan, the Indian Hills Senior Community Mortgage Loanand the Skyline Village Mortgage Loan and the primary servicer and specialservicer of the Christiana Mall Mortgage Loan. As a result, Wells Fargo Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theChristiana Mall Mortgage Loan, the Aventura Mall Mortgage Loan, the Showcase IIMortgage Loan, the Indian Hills Senior Community Mortgage Loan and the SkylineVillage Mortgage Loan.  As a result, Wells Fargo Bank, National Associationis a servicing function participant in the capacities described above, becauseit is 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 byWells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the special servicer of the mortgage loansserviced under the Pooling and Servicing Agreement and the Holiday Inn FiDiMortgage Loan. As a result, Midland Loan Services, a Division of PNC Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Midland Loan Services, a Division of PNC Bank, NationalAssociation in the capacities described above are listed in the Exhibit Index.

Park Bridge Lender Services LLC is the operating advisor ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theAventura Mall Mortgage Loan and the Holiday Inn FiDi Mortgage Loan.  As aresult, Park Bridge Lender Services LLC is a servicing function participant inthe capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

Pentalpha Surveillance LLC is the operating advisor of theShowcase II Mortgage Loan, the Indian Hills Senior Community Mortgage Loan andthe Skyline Village Mortgage Loan.  As a result, Pentalpha SurveillanceLLC is a servicing function participant in the capacities described above,because it is servicing mortgage loans that constituted 5% or more of theassets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Pentalpha Surveillance LLC in the capacities describedabove are listed in the Exhibit Index.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the Aventura Mall Mortgage Loan, the Showcase IIMortgage Loan, the Christiana Mall Mortgage Loan, the Skyline Village MortgageLoan, the Indian Hills Senior Community Mortgage Loan and the Holiday Inn FiDiMortgage Loan.  Pursuant to the Pooling and Servicing Agreement, the trustand servicing agreement for the Aventura Mall Trust 2018-AVM Transaction, thepooling and servicing agreement for the BANK 2018-BNK13 Transaction, the trustand servicing agreement for the BBCMS 2018-CHRS Transaction, the pooling andservicing agreement for the WFCM 2018-C46 Transaction, the pooling andservicing agreement for the CSAIL 2018-C14 Transaction and the pooling andservicing agreement for the CGCMT 2018-C6 Transaction, the trustee is requiredto provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regardingadvances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable 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 serviced underthe Pooling and Servicing Agreement, the Aventura Mall Mortgage Loan, theShowcase II Mortgage Loan, the Christiana Mall Mortgage Loan, the SkylineVillage Mortgage Loan, the Indian Hills Senior Community Mortgage Loan and theHoliday Inn FiDi Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Commercial Real EstateServices, Inc. and National Tax Search, LLC.  These entities were engagedby the master servicer under the Pooling and Servicing Agreement and theprimary servicer of the Aventura Mall Mortgage Loan, the Showcase II MortgageLoan, the Christiana Mall Mortgage Loan, the Skyline Village Mortgage Loan, theIndian Hills Senior Community Mortgage Loan and the Holiday Inn FiDi MortgageLoan to remit tax payments received from the escrow accounts of borrowers tolocal taxing authorities, to report tax amounts due, to verify tax parcelinformation, and to verify non-escrow tax payments. These servicing functionsare included within the servicing criteria set forth in Items 1122(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, thesevendors are “servicers” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and 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 Showcase II MortgageLoan, the Christiana Mall Mortgage Loan, the Skyline Village Mortgage Loan, theIndian Hills Senior Community Mortgage Loan and the Holiday Inn FiDi MortgageLoan listed on the Exhibit Index are omitted from this Annual Report on Form10-K as the certificate administrator pursuant to the related pooling andservicing agreement or trust and servicing agreement does not perform anyactivities that address servicing criteria with respect to the issuing entityand because they are each not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Showcase II Mortgage Loan, the SkylineVillage Mortgage Loan, the Indian Hills Senior Community Mortgage Loan, theHoliday Inn FiDi Mortgage Loan and the Aventura Mall Mortgage Loan, (i) thereports on assessment of compliance with servicing criteria and attestationreports on assessment of compliance with servicing criteria of Torchlight LoanServices, LLC as special servicer of the Showcase II Mortgage Loan, LNRPartners, LLC as special servicer of the Skyline Village Mortgage Loan, RialtoCapital Advisors, LLC as special servicer of the Indian Hills Senior CommunityMortgage Loan, and Citibank, N.A. as custodian of the Holiday Inn FiDi MortgageLoan, listed on the Exhibit Index are omitted from this Annual Report on Form10-K as they are not required to be included on this Annual Report on Form 10-Kper Instruction 3 to Item 1122 of Regulation AB because they are partiesperforming activities that address servicing criteria relating to 5% or less ofthe assets of the issuing entity and (ii) the servicer compliance statements ofCWCapital Asset Management LLC as special servicer of the Aventura MallMortgage Loan, Torchlight Loan Services, LLC as special servicer of theShowcase II Mortgage Loan, LNR Partners, LLC as special servicer of the SkylineVillage Mortgage Loan and Rialto Capital Advisors, LLC as special servicer ofthe Indian Hills Senior Community Mortgage Loan, listed on the Exhibit Indexare omitted from this Annual Report on Form 10-K as they are not required byItem 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,Related Stockholder Matters and Issuer Purchases of Equity Securities.**

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

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

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

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

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

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

 

The registrant knows of nomaterial pending legal proceeding involving the trust or any party related tothe trust, other than routine litigation incidental to the duties of thoserespective parties, and the following, with respect to Citibank N.A., ascustodian, and Wells Fargo Bank, National Association, as certificateadministrator and as custodian.

In the ordinary course of business, Citibank is involved in anumber of legal proceedings, including in connection with its role as trusteeof certain RMBS transactions.  Certain of these Citibank astrustee-related matters are disclosed herein. 

On June 18, 2014, a civil action was filed against Citibank,N.A. (“Citibank”) in the Supreme Court of the State of New York by agroup of investors in 48 private-label RMBS trusts for which Citibank allegedlyserves or did serve as trustee, asserting claims for purported violations ofthe Trust Indenture Act of 1939 (the “Trust Indenture Act”), breach ofcontract, breach of fiduciary duty and negligence based on Citibank’s allegedfailure to perform its duties as trustee for the 48 RMBS trusts.  OnNovember 24, 2014, plaintiffs sought leave to withdraw this action.  Onthe same day, a smaller subset of similar plaintiff investors in 27private-label RMBS trusts for which Citibank allegedly serves or did serve astrustee, filed a new civil action against Citibank in the United StatesDistrict Court for the Southern District of New York asserting similar claimsas the prior action filed in state court.  In January 2015, the courtclosed plaintiffs’ original state court action.  On September 8, 2015, thefederal court dismissed all claims as to 24 of the 27 trusts and allowedcertain of the claims to proceed as to the other three trusts. Subsequently,plaintiffs voluntarily dismissed all claims with respect to two of the threetrusts. On April 7, 2017, Citibank filed a motion for summary judgment.Plaintiffs filed its consolidated opposition brief and cross motion for partialsummary judgment on May 22, 2017.  Briefing on those motions was completedon August 4, 2017. On March 22, 2018, the court granted Citibank’s motion forsummary judgment in its entirety, denied Plaintiffs’ motion for summaryjudgment and ordered the clerk to close the case. On April 20, 2018, plaintiffsfiled a notice of appeal. Plaintiffs’ opening brief was filed on August 3,2018. Citibank filed its opposition on November 2, 2018.  Plaintiffs’filed their reply on November 16, 2018.  On June 7, 2019, the SecondCircuit dismissed plaintiffs’ appeal following the parties’ filing of astipulation withdrawing the case with prejudice pursuant to Federal Rule ofAppellate Procedure 42.

On November 24, 2015, the same investors that brought thefederal case brought a new civil action in the Supreme Court of the State ofNew York related to 25 private-label RMBS trusts for which Citibank allegedlyserves or did serve as trustee.  This case includes the 24 trustspreviously dismissed in the federal action, and one additional trust.  Theinvestors assert claims for breach of contract, breach of fiduciary duty,breach of duty to avoid conflicts of interest, and violation of New York’sStreit Act (the “Streit Act”).  Following oral argument on Citibank’smotion to dismiss, Plaintiffs filed an amended complaint on August 5,2016.  On June 27, 2017, the state court issued a decision, dismissing theEvent of Default claims, mortgage-file-related claims, the fiduciary dutyclaims, and the conflict of interest claims.  The decision sustainedcertain breach of contract claims including the claim alleging discovery ofbreaches of representations and warranties, a claim related to robo-signing,and the implied covenant of good faith claim.  Citibank appealed the lowercourt’s decision, and on January 16, 2018, the Appellate Division, FirstDepartment, dismissed the claims related to robo-signing and the impliedcovenant of good faith, but allowed plaintiffs’ claim alleging discovery ofbreaches of representations and warranties to proceed.  On June 7, 2019,plaintiffs filed a motion for discontinuance of the action and dismissal ofplaintiffs’ claims with prejudice.

On August 19, 2015, the Federal Deposit Insurance Corporation(“FDIC”) as Receiver for a failed financial institution filed a civilaction against Citibank in the Southern District of New York.  This actionrelates to one private-label RMBS trust for which Citibank formerly served astrustee.  FDIC asserts claims for breach of contract, violation of theStreit Act, and violation of the Trust Indenture Act. Citibank jointly briefeda motion to dismiss with The Bank of New York Mellon and U.S. Bank, N.A.,entities that have also been sued by FDIC in their capacity as trustee, andthese cases have all been consolidated in front of Judge Carter.  OnSeptember 30, 2016, the Court granted the motion to dismiss without prejudicefor lack of subject matter jurisdiction.  On October 14, 2016, FDIC fileda motion for reargument or relief from judgment from the Court’s dismissalorder.  On July 11, 2017, Judge Carter ruled on the motion forreconsideration regarding his dismissal of the action.  He deniedreconsideration of his decision on standing, but granted leave to amend thecomplaint by October 9, 2017.  The FDIC subsequently requested anextension of time to file its amended complaint, which was granted. The FDICfiled its amended complaint on December 8, 2017. Defendants’ jointly filed amotion to dismiss the amended complaint and that joint motion was fully briefedas of May 3, 2018.  On March 20, 2019, the Court granted Defendants’ jointmotion to dismiss the amended complaint. The FDIC's deadline to file a noticeof appeal was April 22, 2019. The FDIC has not appealed. 

There can be no assurances as to the outcome of litigation orthe possible impact of litigation on the trustee or the RMBS trusts. However, Citibank denies liability and continues to vigorously defend againstthese litigations.  Furthermore, neither the above-disclosed litigationsnor any other pending legal proceeding involving Citibank will materiallyaffect Citibank’s ability to perform its duties under the related servicingagreement for this CMBS transaction.

Beginning on June 18, 2014, a group of institutionalinvestors filed civil complaints in the Supreme Court of the State of New York,New York County, and later the U.S. District Court for the Southern District ofNew York, against Wells Fargo Bank, N.A., (“Wells Fargo Bank”) in itscapacity as trustee for certain residential mortgage backed securities (“RMBS”)trusts.  The complaints against Wells Fargo Bank alleged that the trusteecaused losses to investors and asserted causes of action based upon, amongother things, the trustee's alleged failure to: (i) notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, (ii) notify investors of alleged events ofdefault, and (iii) abide by appropriate standards of care following allegedevents of default. Relief sought included money damages in an unspecifiedamount, reimbursement of expenses, and equitable relief. In November 2018,Wells Fargo Bank reached an agreement, in which it denied any wrongdoing, toresolve such claims on a classwide basis for the 271 RMBS trusts atissue.  On May 6, 2019, the court entered an order approving thesettlement agreement.  Separate lawsuits against Wells Fargo Bank makingsimilar allegations filed by certain other institutional investors concerningseveral RMBS trusts in New York federal and state court are not covered by theagreement.  With respect to such litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the RMBStrusts.

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on October 25, 2018 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Aventura Mall Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the Aventura Mall Trust 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 Trust 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 Trust 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 Showcase II Mortgage Loan, whichis 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 Christiana Mall Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the BBCMS 2018-CHRS Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the BBCMS 2018-CHRS 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 BBCMS2018-CHRS 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 Skyline Village Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the WFCM 2018-C46 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 WFCM 2018-C46 Transaction incorporated by referenceas Exhibit 4.5 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the WFCM 2018-C46Transaction responsible for each applicable servicing criteria set forth inItem 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 Indian Hills Senior CommunityMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the CSAIL 2018-C14 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 CSAIL 2018-C14 Transaction incorporatedby reference as Exhibit 4.6 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 Holiday Inn FiDi Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the CGCMT 2018-C6 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit O to the pooling andservicing agreement for the CGCMT 2018-C6 Transaction incorporated by referenceas Exhibit 4.7 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the CGCMT 2018-C6Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

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

Material Instance of Noncompliance

In certain instances, the Schedule AL Files (Item 1125 ofRegulation AB) were not reported in accordance with the terms specified in thetransaction agreements, in conflict with Item 1122(d)(3)(i): “Reports to investors,including those to be filed with the Commission, are maintained in accordancewith the transaction agreements and applicable Commission requirements.Specifically, such reports: (A) Are prepared in accordance with timeframes andother terms set forth in the transaction agreements”.  The noncomplianceconsisted of omitted or inaccurately reported fields as described in (1) and(2) below.  (1) In connection with other enhancements Midland made to itsmanual Schedule AL process, starting in April 2019, Midland developed andimplemented new Schedule AL reporting templates for each applicable CMBStransaction that closed prior to April 2019 and for each applicable CMBStransaction going forward.  Related to this, Midland made certain templatesetup errors, along with related and other manual inputting of informationerrors, and the errors were not identified prior to submission of theapplicable Schedule AL Files in certain cases due to breakdowns in qualitycontrol.  (2) In one applicable transaction, the related Schedule AL Filefor a given month was not saved properly resulting in the prior month'sSchedule AL File being submitted for the given month instead of the correctSchedule AL File. 

The identified instances did not involve the servicing of assetsincluded in this securitization.

Steps Taken to Remedy the Material Instance of Noncompliance

Midland’s Schedule AL reporting process was enhanced in Aprilof 2019, however, the process remained manual throughout the 2019 calendaryear.  Errors relating to certain Schedule AL Files during 2019 wereidentified during the related audit.  Following identification, Midlandmade staffing changes and additional enhancements and improvements to itsprocesses and procedures to support its Schedule AL reporting obligations andexpects to move to an automated solution for this process.  

Midland is currently remediating the Schedule AL reportingfor certain of the CMBS transactions found to be incorrect.

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

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

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

 

4.1          Poolingand Servicing Agreement, dated as of October 1, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Park Bridge Lender Services LLC as OperatingAdvisor and Asset Representations Reviewer (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K filed on October 25, 2018 underCommission File No. 333-226486-01 and incorporated by reference herein).

4.2          Trustand Servicing Agreement, dated as of June 29, 2018, by and among J.P. Morgan ChaseCommercial Mortgage Securities Corp., as Depositor, Wells Fargo Bank, NationalAssociation, as Servicer, CWCapital Asset Management LLC, as Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor (filed as Exhibit 4.2 to the registrant’sCurrent Report on Form 8-K filed on October 25, 2018 under Commission File No.333-226486-01 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of August 1, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, Torchlight Loan Services, LLC, asGeneral Special Servicer, National Cooperative Bank, N.A., as NCB MasterServicer and NCB Special Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor  and AssetRepresentations Reviewer (filed as Exhibit 4.4 to the registrant’s CurrentReport on Form 8-K filed on October 25, 2018 under Commission File No.333-226486-01 and incorporated by reference herein).

4.4          Trustand Servicing Agreement, dated as of August 9, 2018, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Wells Fargo Bank, NationalAssociation, as Servicer and Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and Custodian, and Wilmington Trust,National Association, as Trustee (filed as Exhibit 4.3 to the registrant’sCurrent Report on Form 8-K filed on October 25, 2018 under Commission File No.333-226486-01 and incorporated by reference herein).

4.5          Poolingand Servicing Agreement, dated as of August 1, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and Asset Representations Reviewer, (filed as Exhibit 4.5 tothe registrant’s Current Report on Form 8-K filed on October 25, 2018 underCommission File No. 333-226486-01 and incorporated by reference herein).

4.6          Poolingand Servicing Agreement, dated as of November 1, 2018, by and among CreditSuisse Commercial Mortgage Securities Corp., as Depositor, Wells Fargo Bank,National Association, as Master Servicer, Rialto Capital Advisors, LLC, asSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, andPentalpha Surveillance LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on December 3, 2018 under Commission File No. 333-226486-01 andincorporated by reference herein).

4.7          Poolingand Servicing Agreement, dated as of December 1, 2018, by and among CitigroupCommercial Mortgage Securities Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer, Park Bridge Lender Services LLC asOperating Advisor and Asset Representations Reviewer, Citibank, N.A., asCertificate Administrator, and Wilmington Trust, National Association, asTrustee (filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-Kfiled on December 12, 2018 under Commission File No. 333-226486-01 andincorporated by reference herein).

4.8          AgreementBetween Note Holders, dated as of September 27, 2018, by and between WellsFargo Bank, National Association, as Initial Note A-1 Holder, Initial Note A-2 Holder,Initial Note A-3 Holder and Initial Note A-4 Holder (filed as Exhibit 4.6 tothe registrant’s Current Report on Form 8-K filed on October 25, 2018 underCommission File No. 333-226486-01 and incorporated by reference herein).

4.9          Co-LenderAgreement, dated as of June 7, 2018, by and among JPMorgan Chase Bank, NationalAssociation, Deutsche Bank, AG, New York Branch, Wells Fargo Bank, NationalAssociation and Morgan Stanley Bank, N.A. (filed as Exhibit 4.7 to theregistrant’s Current Report on Form 8-K filed on October 25, 2018 underCommission File No. 333-226486-01 and incorporated by reference herein).

4.10        Co-Lender Agreement, dated as of August 9, 2018, by and among Barclays BankPLC, as Initial Note 1 Holder, Société Générale, as Initial Note 2 Holder andDeutsche Bank, AG, New York Branch, as Initial Note 3 Holder (filed as Exhibit4.8 to the registrant’s Current Report on Form 8-K filed on October 25, 2018under Commission File No. 333-226486-01 and incorporated by reference herein).

4.11        AgreementBetween Note Holders, dated as of August 2, 2018, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder, Initial Note A-2 Holderand Initial Note A-3 Holder (filed as Exhibit 4.9 to the registrant’s CurrentReport on Form 8-K filed on October 25, 2018 under Commission File No.333-226486-01 and incorporated by reference herein).

4.12        AgreementBetween Note Holders, dated as of October 11, 2018, by and between BarclaysBank PLC, as Initial Note A-1 Holder, Initial Note A-2 Holder and Initial NoteA-3 Holder (filed as Exhibit 4.10 to the registrant’s Current Report on Form8-K filed on October 25, 2018 under Commission File No. 333-226486-01 andincorporated by reference herein).

4.13        Co-LenderAgreement, dated as of September 18, 2018, by and between Ladder CapitalFinance LLC, as Initial Note A-1 Holder, Initial Note A-2 Holder and InitialNote A-3 Holder and IGIS US Private Placement Real Estate Trust No. 228, asInitial Note B Holder (filed as Exhibit 4.11 to the registrant’s Current Reporton Form 8-K filed on October 25, 2018 under Commission File No. 333-226486-01and incorporated by reference herein).

4.14        Co-LenderAgreement, dated as of September 25, 2018, between Rialto Mortgage Finance,LLC, as Note A-1 Holder, Note A-2 Holder, Note A-3 Holder, Note A-4 Holder andNote A-5 Holder (filed as Exhibit 4.12 to the registrant’s Current Report onForm 8-K filed on October 25, 2018 under Commission File No. 333-226486-01 andincorporated by reference herein).

4.15        Co-LenderAgreement, dated as of October 12, 2018, by and between Ladder Capital FinanceI LLC, for itself to the extent of its interest and on behalf of Series TRS ofLadder Capital Finance I LLC and Series TRS of Ladder Capital Finance I LLC, asInitial Note A-1 holder, Initial Note A-2 Holder and Initial Note A-3 Holder(filed as Exhibit 4.13 to the registrant’s Current Report on Form 8-K filed onOctober 25, 2018 under Commission File No. 333-226486-01 and incorporated byreference herein).

4.16        AgreementBetween Note Holders, dated as of August 23, 2018, by and between Barclays BankPLC, as Initial Note A-1 Holder and Initial Note A-2 Holder (filed as Exhibit4.14 to the registrant’s Current Report on Form 8-K filed on October 25, 2018under Commission File No. 333-226486-01 and incorporated by reference herein).

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

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

33.1       Wells Fargo Bank, NationalAssociation, as Master Servicer

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

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

33.4       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

33.5       Wells Fargo Bank, NationalAssociation, as Custodian

33.6       Park Bridge LenderServices LLC, as Operating Advisor

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

33.8       National Tax Search, LLC,as Servicing Function Participant

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

33.10     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the StarwoodHotel Portfolio Mortgage Loan (see Exhibit 33.2)

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

33.12     Wells Fargo Bank, NationalAssociation, as Custodian of the Starwood Hotel Portfolio Mortgage Loan (seeExhibit 33.5)

33.13     Park Bridge LenderServices LLC, as Operating Advisor of the Starwood Hotel Portfolio MortgageLoan (see Exhibit 33.6)

33.14     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Starwood HotelPortfolio Mortgage Loan (see Exhibit 33.7)

33.15     National Tax Search, LLC,as Servicing Function Participant of the Starwood Hotel Portfolio Mortgage Loan(see Exhibit 33.8)

33.16     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Virginia Beach Hotel Portfolio MortgageLoan (see Exhibit 33.1)

33.17     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VirginiaBeach Hotel Portfolio Mortgage Loan (see Exhibit 33.2)

33.18     Wilmington Trust, National Association, as Trustee of the Virginia Beach HotelPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.19     Wells Fargo Bank, NationalAssociation, as Custodian of the Virginia Beach Hotel Portfolio Mortgage Loan(see Exhibit 33.5)

33.20     Park Bridge LenderServices LLC, as Operating Advisor of the Virginia Beach Hotel Portfolio MortgageLoan (see Exhibit 33.6)

33.21     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Virginia BeachHotel Portfolio Mortgage Loan (see Exhibit 33.7)

33.22     National Tax Search, LLC,as Servicing Function Participant of the Virginia Beach Hotel PortfolioMortgage Loan (see Exhibit 33.8)

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

33.24     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of theEllsworth Place Mortgage Loan (see Exhibit 33.2)

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

33.26     Wells Fargo Bank, NationalAssociation, as Custodian of the Ellsworth Place Mortgage Loan (see Exhibit33.5)

33.27     Park Bridge LenderServices LLC, as Operating Advisor of the Ellsworth Place Mortgage Loan (seeExhibit 33.6)

33.28     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Ellsworth PlaceMortgage Loan (see Exhibit 33.7)

33.29     National Tax Search, LLC,as Servicing Function Participant of the Ellsworth Place Mortgage Loan (see Exhibit33.8)

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

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

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

33.33     Wells Fargo Bank, NationalAssociation, as Custodian of the Aventura Mall Mortgage Loan (see Exhibit 33.5)

33.34     Park Bridge LenderServices LLC, as Operating Advisor of the Aventura Mall Mortgage Loan (seeExhibit 33.6)

33.35     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Aventura MallMortgage Loan (see Exhibit 33.7)

33.36     National Tax Search, LLC,as Servicing Function Participant of the Aventura Mall Mortgage Loan (seeExhibit 33.8)

33.37     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Showcase II Mortgage Loan (see Exhibit33.1)

33.38     Torchlight Loan Services, LLC, as Special Servicer of the Showcase II MortgageLoan (Omitted. See Explanatory Notes.)

33.39     Wilmington Trust, National Association, as Trustee of the Showcase II MortgageLoan (Omitted. See Explanatory Notes.)

33.40     Wells Fargo Bank, NationalAssociation, as Custodian of the Showcase II Mortgage Loan (see Exhibit 33.5)

33.41     Pentalpha SurveillanceLLC, as Operating Advisor of the Showcase II Mortgage Loan

33.42     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Showcase IIMortgage Loan (see Exhibit 33.7)

33.43     National Tax Search, LLC,as Servicing Function Participant of the Showcase II Mortgage Loan (see Exhibit33.8)

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

33.45     Wells Fargo Bank, NationalAssociation, as Special Servicer of the Christiana Mall Mortgage Loan (seeExhibit 33.1)

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

33.47     Wells Fargo Bank, NationalAssociation, as Custodian of the Christiana Mall Mortgage Loan (see Exhibit33.5)

33.48     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Christiana MallMortgage Loan (see Exhibit 33.7)

33.49     National Tax Search, LLC,as Servicing Function Participant of the Christiana Mall Mortgage Loan (see Exhibit33.8)

33.50     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Skyline Village Mortgage Loan (seeExhibit 33.1)

33.51     LNR Partners, LLC, as Special Servicer of the Skyline Village Mortgage Loan(Omitted. See Explanatory Notes.)

33.52     Wilmington Trust, National Association, as Trustee of the Skyline VillageMortgage Loan (Omitted. See Explanatory Notes.)

33.53     Wells Fargo Bank, NationalAssociation, as Custodian of the Skyline Village Mortgage Loan (see Exhibit33.5)

33.54     Pentalpha SurveillanceLLC, as Operating Advisor of the Skyline Village Mortgage Loan (see Exhibit33.41)

33.55     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Skyline VillageMortgage Loan (see Exhibit 33.7)

33.56     National Tax Search, LLC,as Servicing Function Participant of the Skyline Village Mortgage Loan (seeExhibit 33.8)

33.57     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Indian Hills Senior Community MortgageLoan (see Exhibit 33.1)

33.58     Rialto Capital Advisors, LLC, as Special Servicer of the Indian Hills SeniorCommunity Mortgage Loan (Omitted. See Explanatory Notes.)

33.59     Wilmington Trust, National Association, as Trustee of the Indian Hills SeniorCommunity Mortgage Loan (Omitted. See Explanatory Notes.)

33.60     Wells Fargo Bank, NationalAssociation, as Custodian of the Indian Hills Senior Community Mortgage Loan(see Exhibit 33.5)

33.61     Pentalpha SurveillanceLLC, as Operating Advisor of the Indian Hills Senior Community Mortgage Loan(see Exhibit 33.41)

33.62     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Indian HillsSenior Community Mortgage Loan (see Exhibit 33.7)

33.63     National Tax Search, LLC,as Servicing Function Participant of the Indian Hills Senior Community MortgageLoan (see Exhibit 33.8)

33.64     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Holiday Inn FiDi Mortgage Loan (seeExhibit 33.1)

33.65     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the HolidayInn FiDi Mortgage Loan (see Exhibit 33.2)

33.66     Wilmington Trust, National Association, as Trustee of the Holiday Inn FiDiMortgage Loan (Omitted. See Explanatory Notes.)

33.67     Citibank, N.A., as Custodian of the Holiday Inn FiDi Mortgage Loan (Omitted.See Explanatory Notes.)

33.68     Park Bridge LenderServices LLC, as Operating Advisor of the Holiday Inn FiDi Mortgage Loan (seeExhibit 33.6)

33.69     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Holiday InnFiDi Mortgage Loan (see Exhibit 33.7)

33.70     National Tax Search, LLC,as Servicing Function Participant of the Holiday Inn FiDi Mortgage Loan (seeExhibit 33.8)

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

34.1       Wells Fargo Bank, NationalAssociation, as Master Servicer

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

34.3       Wilmington Trust, National Association, as Trustee (Omitted. See Explanatory Notes.)

34.4       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

34.5       Wells Fargo Bank, NationalAssociation, as Custodian

34.6       Park Bridge LenderServices LLC, as Operating Advisor

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

34.8       National Tax Search, LLC,as Servicing Function Participant

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

34.10     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the StarwoodHotel Portfolio Mortgage Loan (see Exhibit 34.2)

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

34.12     Wells Fargo Bank, NationalAssociation, as Custodian of the Starwood Hotel Portfolio Mortgage Loan (seeExhibit 34.5)

34.13     Park Bridge LenderServices LLC, as Operating Advisor of the Starwood Hotel Portfolio MortgageLoan (see Exhibit 34.6)

34.14     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Starwood HotelPortfolio Mortgage Loan (see Exhibit 34.7)

34.15     National Tax Search, LLC,as Servicing Function Participant of the Starwood Hotel Portfolio Mortgage Loan(see Exhibit 34.8)

34.16     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Virginia Beach Hotel Portfolio MortgageLoan (see Exhibit 34.1)

34.17     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VirginiaBeach Hotel Portfolio Mortgage Loan (see Exhibit 34.2)

34.18     Wilmington Trust, National Association, as Trustee of the Virginia Beach HotelPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.19     Wells Fargo Bank, NationalAssociation, as Custodian of the Virginia Beach Hotel Portfolio Mortgage Loan(see Exhibit 34.5)

34.20     Park Bridge LenderServices LLC, as Operating Advisor of the Virginia Beach Hotel PortfolioMortgage Loan (see Exhibit 34.6)

34.21     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Virginia BeachHotel Portfolio Mortgage Loan (see Exhibit 34.7)

34.22     National Tax Search, LLC,as Servicing Function Participant of the Virginia Beach Hotel PortfolioMortgage Loan (see Exhibit 34.8)

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

34.24     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of theEllsworth Place Mortgage Loan (see Exhibit 34.2)

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

34.26     Wells Fargo Bank, NationalAssociation, as Custodian of the Ellsworth Place Mortgage Loan (see Exhibit34.5)

34.27     Park Bridge LenderServices LLC, as Operating Advisor of the Ellsworth Place Mortgage Loan (seeExhibit 34.6)

34.28     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Ellsworth PlaceMortgage Loan (see Exhibit 34.7)

34.29     National Tax Search, LLC,as Servicing Function Participant of the Ellsworth Place Mortgage Loan (seeExhibit 34.8)

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

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

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

34.33     Wells Fargo Bank, NationalAssociation, as Custodian of the Aventura Mall Mortgage Loan (see Exhibit 34.5)

34.34     Park Bridge LenderServices LLC, as Operating Advisor of the Aventura Mall Mortgage Loan (seeExhibit 34.6)

34.35     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Aventura MallMortgage Loan (see Exhibit 34.7)

34.36     National Tax Search, LLC,as Servicing Function Participant of the Aventura Mall Mortgage Loan (seeExhibit 34.8)

34.37     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Showcase II Mortgage Loan (see Exhibit34.1)

34.38     Torchlight Loan Services, LLC, as Special Servicer of the Showcase II MortgageLoan (Omitted. See Explanatory Notes.)

34.39     Wilmington Trust, National Association, as Trustee of the Showcase II MortgageLoan (Omitted. See Explanatory Notes.)

34.40     Wells Fargo Bank, NationalAssociation, as Custodian of the Showcase II Mortgage Loan (see Exhibit 34.5)

34.41     Pentalpha SurveillanceLLC, as Operating Advisor of the Showcase II Mortgage Loan

34.42     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Showcase IIMortgage Loan (see Exhibit 34.7)

34.43     National Tax Search, LLC,as Servicing Function Participant of the Showcase II Mortgage Loan (see Exhibit34.8)

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

34.45     Wells Fargo Bank, NationalAssociation, as Special Servicer of the Christiana Mall Mortgage Loan (seeExhibit 34.1)

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

34.47     Wells Fargo Bank, NationalAssociation, as Custodian of the Christiana Mall Mortgage Loan (see Exhibit34.5)

34.48     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Christiana MallMortgage Loan (see Exhibit 34.7)

34.49     National Tax Search, LLC,as Servicing Function Participant of the Christiana Mall Mortgage Loan (seeExhibit 34.8)

34.50     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Skyline Village Mortgage Loan (seeExhibit 34.1)

34.51     LNR Partners, LLC, as Special Servicer of the Skyline Village Mortgage Loan(Omitted. See Explanatory Notes.)

34.52     Wilmington Trust, National Association, as Trustee of the Skyline VillageMortgage Loan (Omitted. See Explanatory Notes.)

34.53     Wells Fargo Bank, NationalAssociation, as Custodian of the Skyline Village Mortgage Loan (see Exhibit34.5)

34.54     Pentalpha SurveillanceLLC, as Operating Advisor of the Skyline Village Mortgage Loan (see Exhibit34.41)

34.55     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Skyline VillageMortgage Loan (see Exhibit 34.7)

34.56     National Tax Search, LLC,as Servicing Function Participant of the Skyline Village Mortgage Loan (seeExhibit 34.8)

34.57     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Indian Hills Senior Community MortgageLoan (see Exhibit 34.1)

34.58     Rialto Capital Advisors, LLC, as Special Servicer of the Indian Hills SeniorCommunity Mortgage Loan (Omitted. See Explanatory Notes.)

34.59     Wilmington Trust, National Association, as Trustee of the Indian Hills SeniorCommunity Mortgage Loan (Omitted. See Explanatory Notes.)

34.60     Wells Fargo Bank, NationalAssociation, as Custodian of the Indian Hills Senior Community Mortgage Loan(see Exhibit 34.5)

34.61     Pentalpha SurveillanceLLC, as Operating Advisor of the Indian Hills Senior Community Mortgage Loan(see Exhibit 34.41)

34.62     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Indian HillsSenior Community Mortgage Loan (see Exhibit 34.7)

34.63     National Tax Search, LLC,as Servicing Function Participant of the Indian Hills Senior Community MortgageLoan (see Exhibit 34.8)

34.64     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Holiday Inn FiDi Mortgage Loan (seeExhibit 34.1)

34.65     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the HolidayInn FiDi Mortgage Loan (see Exhibit 34.2)

34.66     Wilmington Trust, National Association, as Trustee of the Holiday Inn FiDiMortgage Loan (Omitted. See Explanatory Notes.)

34.67     Citibank, N.A., as Custodian of the Holiday Inn FiDi Mortgage Loan (Omitted.See Explanatory Notes.)

34.68     Park Bridge LenderServices LLC, as Operating Advisor of the Holiday Inn FiDi Mortgage Loan (seeExhibit 34.6)

34.69     CoreLogic Commercial RealEstate Services, Inc., as Servicing Function Participant of the Holiday InnFiDi Mortgage Loan (see Exhibit 34.7)

34.70     National Tax Search, LLC,as Servicing Function Participant of the Holiday Inn FiDi Mortgage Loan (seeExhibit 34.8)

35          Servicer compliance statements.

35.1       Wells Fargo Bank, NationalAssociation, as Master Servicer

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

35.3       Wells Fargo Bank, NationalAssociation, as Certificate Administrator

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

35.5       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the StarwoodHotel Portfolio Mortgage Loan (see Exhibit 35.2)

35.6       Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Virginia Beach Hotel Portfolio MortgageLoan (see Exhibit 35.1)

35.7       Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the VirginiaBeach Hotel Portfolio Mortgage Loan (see Exhibit 35.2)

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

35.9       Midland Loan Services, a Divisionof PNC Bank, National Association, as Special Servicer of the Ellsworth PlaceMortgage Loan (see Exhibit 35.2)

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

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

35.12     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Showcase II Mortgage Loan (see Exhibit35.1)

35.13     Torchlight Loan Services, LLC, as Special Servicer of the Showcase II MortgageLoan (Omitted. See Explanatory Notes.)

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

35.15     Wells Fargo Bank, NationalAssociation, as Special Servicer of the Christiana Mall Mortgage Loan (seeExhibit 35.1)

35.16     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Skyline Village Mortgage Loan (seeExhibit 35.1)

35.17     LNR Partners, LLC, as Special Servicer of the Skyline Village Mortgage Loan(Omitted. See Explanatory Notes.)

35.18     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Indian Hills Senior Community MortgageLoan (see Exhibit 35.1)

35.19     Rialto Capital Advisors, LLC, as Special Servicer of the Indian Hills SeniorCommunity Mortgage Loan (Omitted. See Explanatory Notes.)

35.20     Wells Fargo Bank, NationalAssociation, as Primary Servicer of the Holiday Inn FiDi Mortgage Loan (seeExhibit 35.1)

35.21     Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer of the HolidayInn FiDi Mortgage Loan (see Exhibit 35.2)

99.1        MortgageLoan Purchase Agreement, dated as of October 9, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onOctober 25, 2018 under Commission File No. 333-226486-01 and incorporated byreference herein).

99.2        MortgageLoan Purchase Agreement, dated as of October 9, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Barclays Bank PLC (filed as Exhibit99.2 to the registrant’s Current Report on Form 8-K filed on October 25, 2018under Commission File No. 333-226486-01 and incorporated by reference herein).

99.3        MortgageLoan Purchase Agreement, dated as of October 9, 2018, among Wells FargoCommercial Mortgage Securities, Inc., Ladder Capital Finance LLC, LadderCapital Finance Holdings LLLP, Series REIT of Ladder Capital Finance HoldingsLLLP and Series TRS of Ladder Capital Finance Holdings LLLP (filed as Exhibit99.3 to the registrant’s Current Report on Form 8-K filed on October 25, 2018under Commission File No. 333-226486-01 and incorporated by reference herein).

99.4        MortgageLoan Purchase Agreement, dated as of October 9, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Rialto Mortgage Finance, LLC (filed asExhibit 99.4 to the registrant’s Current Report on Form 8-K filed on October25, 2018 under Commission File No. 333-226486-01 and incorporated by referenceherein).

99.5        MortgageLoan Purchase Agreement, dated as of October 9, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and C-III Commercial Mortgage LLC (filedas Exhibit 99.5 to the registrant’s Current Report on Form 8-K filed on October25, 2018 under Commission File No. 333-226486-01 and incorporated by referenceherein).

(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.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 18, 2020