**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

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

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

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

**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 RialtoMortgage Finance, 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 acceleratedfiler        o                                                                                                       Accelerated filer                                     o

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

                                                                                                                                                       Emerging growthcompany                    o

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

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

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 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 Loan,three other *pari passu* loans, which are not assets of the issuingentity, (b) with respect to the Virginia Beach Hotel Portfolio Mortgage Loan,two other *pari passu* loans, which are not assets of the issuing entityand (c) with respect to the Ellsworth Place Mortgage Loan, four other *paripassu* loans, which are not assets of the issuing entity. These loancombinations, including the Starwood Hotel Portfolio Mortgage Loan, theVirginia Beach Hotel Portfolio Mortgage Loan and the Ellsworth Place MortgageLoan, are being serviced and administered pursuant to the Pooling and ServicingAgreement, which is incorporated by reference as Exhibit 4.1 to this AnnualReport 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, twenty-five other *pari passu* loans and four subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the Aventura Mall Trust2018-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 theissuing entity and is part of a loan combination that includes the ChristianaMall Mortgage Loan, 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 the ExhibitIndex) with respect to the Skyline Village Mortgage Loan, which constitutedapproximately 1.0% of the asset pool of the issuing entity as of its cut-offdate.  The Skyline Village Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the Skyline Village MortgageLoan and one other *pari passu* loan, which is not an asset of the issuingentity. The other *pari passu* portion of the loan combination wassecuritized in the Wells Fargo Commercial Mortgage Trust 2018-C46 transaction,Commission File Number 333-206677-27 (the “WFCM 2018-C46 Transaction”).This loan combination, including the Skyline Village Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe WFCM 2018-C46 Transaction, which is incorporated by reference as Exhibit4.5 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, 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-C6 transaction,Commission File Number 333-207132-20 (the “CGCMT 2018-C6 Transaction”). After the closing of the CGCMT 2018-C6 Transaction on December 11, 2018, thisloan combination, including the Holiday Inn FiDi Mortgage Loan was, and willcontinue to be, serviced and administered pursuant to the pooling and servicingagreement with respect to the CGCMT 2018-C6 Transaction, which is incorporatedby reference as Exhibit 4.7 to this Annual Report 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, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Midland Loan Services, a Divisionof PNC Bank, National Association is the special servicer of the mortgage loansserviced under the Pooling and Servicing Agreement 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 servicedunder the 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 Solutions, LLC.  Thisentity was engaged by the master servicer under the Pooling and ServicingAgreement and the primary servicer of 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 to remit tax payments received from the escrowaccounts of borrowers to local taxing authorities, to report tax amounts due,to verify tax parcel information, and to verify non-escrow tax payments. Theseservicing functions are included within the servicing criteria set forth inItems 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  Therefore,under the principles-based definition of “servicer” set forth in Item 1101(j)of Regulation AB that looks to the functions that an entity performs, thisvendor is a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  SeeCompliance 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 are omitted from this Annual Report on Form 10-K as the certificateadministrator pursuant to the related pooling and servicing agreement or trustand servicing agreement does not perform any activities that address servicingcriteria with respect to the issuing entity and because they are each not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respectto the *pari passu* loan combinations that include the Showcase IIMortgage Loan, the Skyline Village Mortgage Loan, the Indian Hills SeniorCommunity Mortgage Loan, the Holiday Inn FiDi Mortgage Loan and the AventuraMall Mortgage Loan, (i) the reports on assessment of compliance with servicingcriteria and attestation reports on assessment of compliance with servicingcriteria of Torchlight Loan Services, LLC as special servicer of the ShowcaseII Mortgage Loan, Argentic Services Company LP as special servicer of theSkyline Village Mortgage Loan, Rialto Capital Advisors, LLC as special servicerof the Indian Hills Senior Community Mortgage Loan, and Citibank, N.A. ascustodian of the Holiday Inn FiDi Mortgage Loan, listed on the Exhibit Indexare omitted from this Annual Report on Form 10-K as they are not required to beincluded on this Annual Report on Form 10-K per Instruction 3 to Item 1122 ofRegulation AB because they are parties performing activities that addressservicing criteria relating to 5% or less of the assets of the issuing entity;and (ii) the servicer compliance statements of CWCapital Asset Management LLCas special servicer of the Aventura Mall Mortgage Loan, Torchlight LoanServices, LLC as special servicer of the Showcase II Mortgage Loan, ArgenticServices Company LP as special servicer of the Skyline Village Mortgage Loanand Rialto Capital Advisors, LLC as special servicer of the Indian Hills SeniorCommunity Mortgage Loan, listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as they are not required by Item 1123 of RegulationAB to be included on this Annual Report on Form 10-K because they are each anunaffiliated party that is not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

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

 

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

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

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

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

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

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

From time to time, CWCapital Asset Management LLC, a Delawarelimited liability company (“CWCAM”), is a party to lawsuits and other legalproceedings as part of its duties as a special servicer (e.g., enforcement ofloan obligations) and/or arising in the ordinary course of business. Other than as set forth in the following paragraphs, there are currently nolegal proceedings pending, and no legal proceedings known to be contemplated bygovernmental authorities, against CWCAM or of which any of its property is thesubject, that are material to the certificateholders.

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

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of the Original Complaint alleged breaches of a contract and fiduciary duties by CWCAM’saffiliate, CWCapital Investments LLC in its capacity as collateral manager forthe collateralized debt obligation transaction involving CWCapital Cobalt Vr,Ltd. In total, there are 14 counts pled in the Original Complaint. Of those 14,5 claims were asserted against CWCAM for aiding and abetting breach offiduciary duty, conversion and unjust enrichment. On May 23, 2018, the OriginalComplaint was dismissed for lack of subject matter jurisdiction.   OnJune 28, 2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaintin the Supreme Court of the State of New York, County of New York styled asCWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No. 653277/2018(the “New Complaint”).  The gravamen of the New Complaint is thesame as the previous complaint filed in the United State District Court for theSouthern District of New York.  In total there are 16 counts pled in theNew Complaint. Of those 16 counts, 5 claims were asserted against CWCAM foraiding and abetting breach of fiduciary duty, conversion and unjust enrichment,1 count seeks a declaratory judgement that the plaintiff has the right toenforce the contracts in question and 1 count seeks an injunction requiring thedefendants to recognize the plaintiff as the directing holder for the trusts inquestion. On January 11, 2019, the plaintiff dismissed with prejudice thedeclaratory judgment and injunction counts.  The New Complaint and relatedsummons was not served on the defendants until July 13, 2018 and July 16,2018.  The plaintiff’s motion for a preliminary injunction was denied bythe court on July 31, 2018.  On August 3, 2018, the defendants, includingCWCAM, filed a motion to dismiss the New Complaint in its entirety. On August20, 2019, the court entered an order granting defendants’ motion almost in itsentirety, dismissing 11 of the 16 counts and partially dismissing 2 additionalcounts.  Of the remaining counts, 2 are asserted against CWCAM for aidingand abetting breach of fiduciary duty and unjust enrichment.  On September19, 2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relating to theAugust 20, 2019 dismissal order and on September 26, 2019, filed an amendedcomplaint against CWCI and CWCAM attempting to address deficiencies relating tocertain of the claims dismissed by the August, 20, 2019 order.  CWCI andCWCAM filed its Motion to Dismiss the amended complaint on October 28,2019.  The court heard argument on the Motion to Dismiss the amendedcomplaint on January 22, 2020 and on October 23, 2020, the court granted themotion dismissing the amended claims.  On November 30, 2020, CWCapitalCobalt Vr Ltd filed a notice of appeal relating to the October 23, 2020 dismissalorder.  On April 27, 2021, the First Department affirmed the dismissal asto claims against CWCAM that were part of the August 20, 2019 dismissal, butreversed the dismissal of two counts for breach of the Collateral ManagementAgreement against CWCI.  CWCI has sought leave to file an appeal of thedecision.  Both requests for leave were denied by the FirstDepartment.  The plaintiff has also sought leave to appeal the dismissalof the claims against CWCAM.  CWCAM believes that it has performed itsobligations under the related pooling and servicing agreements in good faithand the remaining allegations in the New Complaint are without merit.  

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

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

 

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

 

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

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

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on 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 such assessmentsof compliance with respect to the Skyline Village Mortgage Loan, which is beingserviced and administered pursuant to the pooling and servicing agreement forthe WFCM 2018-C46 Transaction, are attached hereto under Item 15 to this AnnualReport on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the WFCM 2018-C46 Transaction incorporated by reference asExhibit 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 such assessmentsof compliance with respect to the Indian Hills Senior Community Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the CSAIL 2018-C14 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the CSAIL 2018-C14 Transaction incorporated byreference as Exhibit 4.6 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).

**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. MorganChase Commercial Mortgage Securities Corp., as Depositor, Wells Fargo Bank,National Association, as Servicer, CWCapital Asset Management LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor (filed as Exhibit 4.2 to the registrant’sCurrent Report on Form 8-K filed on 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, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Pentalpha 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-2Holder, Initial Note A-3 Holder and Initial Note A-4 Holder (filed as Exhibit4.6 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).

4.9          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-LenderAgreement, dated as of August 9, 2018, by and among Barclays Bank PLC, asInitial Note 1 Holder, Société Générale, as Initial Note 2 Holder and DeutscheBank, AG, New York Branch, as Initial Note 3 Holder (filed as Exhibit 4.8 tothe registrant’s Current Report on Form 8-K filed on October 25, 2018 under CommissionFile 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, National Association, as MasterServicer

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

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

33.4        Wells Fargo Bank, National Association, asCertificate Administrator

33.5        Wells Fargo Bank, National Association, asCustodian

33.6        Park Bridge Lender Services LLC, as OperatingAdvisor

33.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

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

33.11      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 33.2)

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

33.13      Wells Fargo Bank, National Association, asCustodian of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.5)

33.14      Park Bridge Lender Services LLC, as OperatingAdvisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.6)

33.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.7)

33.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit 33.1)

33.18      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Virginia Beach Hotel PortfolioMortgage Loan (see Exhibit 33.2)

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

33.20      Wells Fargo Bank, National Association, asCustodian of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit33.5)

33.21      Park Bridge Lender Services LLC, as OperatingAdvisor of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit 33.6)

33.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit33.7)

33.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

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

33.25      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Ellsworth Place Mortgage Loan(see Exhibit 33.2)

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

33.27      Wells Fargo Bank, National Association, asCustodian of the Ellsworth Place Mortgage Loan (see Exhibit 33.5)

33.28      Park Bridge Lender Services LLC, as OperatingAdvisor of the Ellsworth Place Mortgage Loan (see Exhibit 33.6)

33.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Ellsworth Place Mortgage Loan (see Exhibit 33.7)

33.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

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

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

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

33.34      Wells Fargo Bank, National Association, asCustodian of the Aventura Mall Mortgage Loan (see Exhibit 33.5)

33.35      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aventura Mall Mortgage Loan (see Exhibit 33.6)

33.36      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Aventura Mall Mortgage Loan (see Exhibit 33.7)

33.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Showcase II Mortgage Loan (see Exhibit 33.1)

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

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

33.41      Wells Fargo Bank, National Association, asCustodian of the Showcase II Mortgage Loan (see Exhibit 33.5)

33.42      Pentalpha Surveillance LLC, as Operating Advisorof the Showcase II Mortgage Loan

33.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Showcase II Mortgage Loan (see Exhibit 33.7)

33.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1, 2021(see Exhibit 33.9)

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

33.46      Wells Fargo Bank, National Association, as SpecialServicer of the Christiana Mall Mortgage Loan (see Exhibit 33.1)

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

33.48      Wells Fargo Bank, National Association, asCustodian of the Christiana Mall Mortgage Loan (see Exhibit 33.5)

33.49      CoreLogic Solutions, LLC, as Servicing Function Participantof the Christiana Mall Mortgage Loan (see Exhibit 33.7)

33.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.51      Wells Fargo Bank, National Association, as PrimaryServicer of the Skyline Village Mortgage Loan (see Exhibit 33.1)

33.52      Argentic Services Company LP, as Special Servicer of the Skyline VillageMortgage Loan (Omitted. See Explanatory Notes.)

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

33.54      Wells Fargo Bank, National Association, asCustodian of the Skyline Village Mortgage Loan (see Exhibit 33.5)

33.55      Pentalpha Surveillance LLC, as Operating Advisorof the Skyline Village Mortgage Loan (see Exhibit 33.42)

33.56      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Skyline Village Mortgage Loan (see Exhibit 33.7)

33.57      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.58      Wells Fargo Bank, National Association, as PrimaryServicer of the Indian Hills Senior Community Mortgage Loan (see Exhibit 33.1)

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

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

33.61      Wells Fargo Bank, National Association, asCustodian of the Indian Hills Senior Community Mortgage Loan (see Exhibit 33.5)

33.62      Pentalpha Surveillance LLC, as Operating Advisorof the Indian Hills Senior Community Mortgage Loan (see Exhibit 33.42)

33.63      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Indian Hills Senior Community Mortgage Loan (see Exhibit33.7)

33.64      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.9)

33.65      Wells Fargo Bank, National Association, as PrimaryServicer of the Holiday Inn FiDi Mortgage Loan (see Exhibit 33.1)

33.66      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Holiday Inn FiDi Mortgage Loan(see Exhibit 33.2)

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

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

33.69      Park Bridge Lender Services LLC, as OperatingAdvisor of the Holiday Inn FiDi Mortgage Loan (see Exhibit 33.6)

33.70      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Holiday Inn FiDi Mortgage Loan (see Exhibit 33.7)

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

34.1        Wells Fargo Bank, National Association, as MasterServicer

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

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

34.4        Wells Fargo Bank, National Association, asCertificate Administrator

34.5        Wells Fargo Bank, National Association, asCustodian

34.6        Park Bridge Lender Services LLC, as OperatingAdvisor

34.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

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

34.11      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 34.2)

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

34.13      Wells Fargo Bank, National Association, asCustodian of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.5)

34.14      Park Bridge Lender Services LLC, as OperatingAdvisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.6)

34.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.7)

34.16      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit 34.1)

34.18      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Virginia Beach Hotel PortfolioMortgage Loan (see Exhibit 34.2)

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

34.20      Wells Fargo Bank, National Association, as Custodianof the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit 34.5)

34.21      Park Bridge Lender Services LLC, as OperatingAdvisor of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit 34.6)

34.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit34.7)

34.23      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

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

34.25      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Ellsworth Place Mortgage Loan(see Exhibit 34.2)

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

34.27      Wells Fargo Bank, National Association, asCustodian of the Ellsworth Place Mortgage Loan (see Exhibit 34.5)

34.28      Park Bridge Lender Services LLC, as OperatingAdvisor of the Ellsworth Place Mortgage Loan (see Exhibit 34.6)

34.29      CoreLogic Solutions, LLC, as Servicing Function Participantof the Ellsworth Place Mortgage Loan (see Exhibit 34.7)

34.30      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

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

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

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

34.34      Wells Fargo Bank, National Association, asCustodian of the Aventura Mall Mortgage Loan (see Exhibit 34.5)

34.35      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aventura Mall Mortgage Loan (see Exhibit 34.6)

34.36      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Aventura Mall Mortgage Loan (see Exhibit 34.7)

34.37      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.38      Wells Fargo Bank, National Association, as PrimaryServicer of the Showcase II Mortgage Loan (see Exhibit 34.1)

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

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

34.41      Wells Fargo Bank, National Association, asCustodian of the Showcase II Mortgage Loan (see Exhibit 34.5)

34.42      Pentalpha Surveillance LLC, as Operating Advisorof the Showcase II Mortgage Loan

34.43      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Showcase II Mortgage Loan (see Exhibit 34.7)

34.44      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

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

34.46      Wells Fargo Bank, National Association, as SpecialServicer of the Christiana Mall Mortgage Loan (see Exhibit 34.1)

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

34.48      Wells Fargo Bank, National Association, asCustodian of the Christiana Mall Mortgage Loan (see Exhibit 34.5)

34.49      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Christiana Mall Mortgage Loan (see Exhibit 34.7)

34.50      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.51      Wells Fargo Bank, National Association, as PrimaryServicer of the Skyline Village Mortgage Loan (see Exhibit 34.1)

34.52      Argentic Services Company LP, as Special Servicer of the Skyline VillageMortgage Loan (Omitted. See Explanatory Notes.)

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

34.54      Wells Fargo Bank, National Association, asCustodian of the Skyline Village Mortgage Loan (see Exhibit 34.5)

34.55      Pentalpha Surveillance LLC, as Operating Advisorof the Skyline Village Mortgage Loan (see Exhibit 34.42)

34.56      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Skyline Village Mortgage Loan (see Exhibit 34.7)

34.57      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.58      Wells Fargo Bank, National Association, as PrimaryServicer of the Indian Hills Senior Community Mortgage Loan (see Exhibit 34.1)

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

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

34.61      Wells Fargo Bank, National Association, asCustodian of the Indian Hills Senior Community Mortgage Loan (see Exhibit 34.5)

34.62      Pentalpha Surveillance LLC, as Operating Advisorof the Indian Hills Senior Community Mortgage Loan (see Exhibit 34.42)

34.63      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Indian Hills Senior Community Mortgage Loan (see Exhibit34.7)

34.64      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.9)

34.65      Wells Fargo Bank, National Association, as PrimaryServicer of the Holiday Inn FiDi Mortgage Loan (see Exhibit 34.1)

34.66      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Holiday Inn FiDi Mortgage Loan(see Exhibit 34.2)

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

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

34.69      Park Bridge Lender Services LLC, as OperatingAdvisor of the Holiday Inn FiDi Mortgage Loan (see Exhibit 34.6)

34.70      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Holiday Inn FiDi Mortgage Loan (see Exhibit 34.7)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as MasterServicer

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

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

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

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

35.6        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 35.2)

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit 35.1)

35.8        Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Virginia Beach Hotel PortfolioMortgage Loan (see Exhibit 35.2)

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

35.10      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Ellsworth Place Mortgage Loan(see Exhibit 35.2)

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

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

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

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

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

35.16      Wells Fargo Bank, National Association, as SpecialServicer of the Christiana Mall Mortgage Loan (see Exhibit 35.1)

35.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Skyline Village Mortgage Loan (see Exhibit 35.1)

35.18      Argentic Services Company LP, as Special Servicer of the Skyline VillageMortgage Loan (Omitted. See Explanatory Notes.)

35.19      Wells Fargo Bank, National Association, as PrimaryServicer of the Indian Hills Senior Community Mortgage Loan (see Exhibit 35.1)

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

35.21      Wells Fargo Bank, National Association, as PrimaryServicer of the Holiday Inn FiDi Mortgage Loan (see Exhibit 35.1)

35.22      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Holiday Inn FiDi Mortgage Loan(see Exhibit 35.2)

99.1        MortgageLoan Purchase Agreement, dated as of October 9, 2018, between Wells Fargo CommercialMortgage Securities, Inc. and Wells Fargo Bank, National Association (filed asExhibit 99.1 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).

99.2        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 the Registrant pursuant to Item 601 ofRegulation 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 Mortgage Securities,Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 10, 2022