**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: 333-226943-01**

**Central Index Key Number of the issuing entity:0001757018**

**Benchmark 2018-B7 Mortgage Trust**

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

** **

**Central Index Key Number of the depositor: 0001013454**

**Deutsche Mortgage & AssetReceiving Corporation**

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

** **

**Central Index Key Number of the sponsor: 0001541294**

**German American Capital Corporation**

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

** **

**Central Index Key Number of the sponsor: 0001701238**

**Citi Real Estate Funding Inc.**

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

** **

**Central Index Key Number of the sponsor: 0000835271**

**JPMorgan Chase Bank, NationalAssociation**

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

** **

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

**the issuing entity)** | **38-4096482**

**38-4096483**

**38-7206261**

**(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:**

**(212) 250-2500**

Securities registered pursuant to Section 12(b) of the Act:

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

 

Securities registered pursuant to Section 12(g) of theAct:  None.

Indicate by check mark if the registrant is a well-knownseasoned issuer, as defined in Rule 405 of the Securities Act.  o Yes ⌧No

Indicate by check mark if the registrant is not required tofile reports pursuant to Section 13 or Section 15(d) of the Act.  o Yes ⌧No

Indicate by check mark whether the registrant (1) has filedall reports required to be filed by Section 13 or 15(d) of the SecuritiesExchange Act of 1934 during the preceding 12 months (or for such shorter periodthat the registrant was required to file such reports), and (2) has beensubject to such filing requirements for the past 90 days.  ⌧ Yes oNo

Indicate by check mark whether the registrant has submittedelectronically and posted on its corporate Web site, if any, every InteractiveData File required to be submitted and posted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit and postsuch files).

Not applicable.

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

Not applicable.

Indicate by check mark whether the registrant is a largeaccelerated filer, an accelerated filer, a non-accelerated filer, a 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                                                                                                       Acceleratedfiler                                     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 shell company(as defined in Rule 12b-2 of the Act).  oYes ⌧ 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 DUMBO Heights Portfolio Mortgage Loan, theLiberty Portfolio Mortgage Loan, the Shops at Solaris Mortgage Loan and the 192Lexington Avenue Mortgage Loan, which constituted approximately 6.8%, 4.3%,4.3% and 3.9%, respectively, of the asset pool of the issuing entity as of itscut-off date, are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the DUMBO Heights PortfolioMortgage Loan, four other *pari passu* loans and two subordinate companionloans, each of which are not assets of the issuing entity, (b) with respect tothe Liberty Portfolio Mortgage Loan, six other *pari passu* loans, whichare not assets of the issuing entity, (c) with respect to the Shops at SolarisMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity and (d) with respect to the 192 Lexington Avenue Mortgage Loan,one other *pari passu* loan, which is not an asset of the issuing entity.These loan combinations, including the DUMBO Heights Portfolio Mortgage Loan,the Liberty Portfolio Mortgage Loan, the Shops at Solaris Mortgage Loan and the192 Lexington Avenue Mortgage Loan, are being serviced and administeredpursuant to the Pooling and Servicing Agreement, which is incorporated byreference 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 4.3% 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 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 Aon Center Mortgage Loan, which constitutedapproximately 3.7% of the asset pool of the issuing entity as of its cut-offdate.  The Aon Center Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Aon Center Mortgage Loan, threeother *pari passu* loans and one subordinate companion loan, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the J.P. Morgan Chase Commercial MortgageSecurities Trust 2018-AON transaction (the “JPMCC 2018-AON Transaction”).This loan combination, including the Aon Center Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theJPMCC 2018-AON Transaction, which is incorporated by reference as Exhibit 4.3to 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 636 11th Avenue Mortgage Loan, whichconstituted approximately 3.4% of the asset pool of the issuing entity as ofits cut-off date.  The 636 11th Avenue Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 636 11th AvenueMortgage Loan and five other *pari passu* loans, which are not assets ofthe issuing entity. A *pari passu* portion of the loan combination wassecuritized in the Benchmark 2018-B4 Mortgage Trust transaction, CommissionFile Number 333-206705-14 (the “Benchmark 2018-B4 Transaction”). Thisloan combination, including the 636 11th Avenue Mortgage Loan, is beingserviced and administered pursuant to the pooling and servicing agreement forthe Benchmark 2018-B4 Transaction, which is incorporated by reference asExhibit 4.4 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Workspace Mortgage Loan, which constitutedapproximately 3.4% of the asset pool of the issuing entity as of its cut-offdate.  The Workspace Mortgage Loan is an asset of the issuing entity andis part of a loan combination that includes the Workspace Mortgage Loan, tenother *pari passu* loans and two subordinate companion loans, which arenot assets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the J.P. Morgan Chase Commercial MortgageSecurities Trust 2018-WPT transaction (the “JPMCC 2018-WPT Transaction”).This loan combination, including the Workspace Mortgage Loan, is being servicedand administered pursuant to the trust and servicing agreement for the JPMCC2018-WPT Transaction, which is incorporated by reference as Exhibit 4.5 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 Overland Park Xchange Mortgage Loan and theConcord Plaza Mortgage Loan, which constituted approximately 2.1% and 1.6%,respectively, of the asset pool of the issuing entity as of its cut-offdate.  The Overland Park Xchange Mortgage Loan and the Concord PlazaMortgage Loan are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Overland Park XchangeMortgage Loan, two other *pari passu* loans, which are not assets of theissuing entity or (b) with respect to the Concord Plaza Mortgage Loan, oneother *pari passu* loan, which is not an asset of the issuing entity. A *paripassu* portion of each loan combination was securitized in the Benchmark2018-B6 Mortgage Trust transaction, Commission File Number 333-207132-19 (the “Benchmark2018-B6 Transaction”). These loan combinations, including the Overland ParkXchange Mortgage Loan and the Concord Plaza Mortgage Loan, are being servicedand administered pursuant to the pooling and servicing agreement for theBenchmark 2018-B6 Transaction, which is incorporated by reference as Exhibit4.6 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 Shelbourne Global Portfolio I Mortgage Loan,which constituted approximately 1.5% of the asset pool of the issuing entity asof its cut-off date.  The Shelbourne Global Portfolio I Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe Shelbourne Global Portfolio I Mortgage Loan and five other *pari passu*loans, which are not assets of the issuing entity. A *pari passu* portionof the loan combination was securitized in the UBS Commercial Mortgage Trust2018-C13 transaction, Commission File Number 333-207340-14 (the “UBS2018-C13 Transaction”). This loan combination, including the ShelbourneGlobal Portfolio I Mortgage Loan, is being serviced and administered pursuantto the pooling and servicing agreement for the UBS 2018-C13 Transaction, whichis incorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Moffett Towers - Buildings E, F, G MortgageLoan and the Outlet Shoppes at El Paso Mortgage Loan, which constitutedapproximately 4.3% and 3.1%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The Moffett Towers - Buildings E, F, GMortgage Loan and the Outlet Shoppes at El Paso Mortgage Loan are each an assetof the issuing entity and are each part of a loan combination that includes (a)with respect to the Moffett Towers - Buildings E, F, G Mortgage Loan, eightother *pari passu* loans, which are not assets of the issuing entity or(b) with respect to the Outlet Shoppes at El Paso Mortgage Loan, one other *paripassu* loan, which is not an asset of the issuing entity. A *pari passu*portion of each loan combination was securitized in the DBGS 2018-C1 MortgageTrust transaction, Commission File Number 333-206705-16 (the “DBGS 2018-C1Transaction”). These loan combinations, including the Moffett Towers -Buildings E, F, G Mortgage Loan and the Outlet Shoppes at El Paso MortgageLoan, are being serviced and administered pursuant to the pooling and servicingagreement for the DBGS 2018-C1 Transaction, which is incorporated by referenceas Exhibit 4.8 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Phoenix Marriott Tempe at the ButtesMortgage Loan, which constituted approximately 2.1% of the asset pool of theissuing entity as of its cut-off date.  The Phoenix Marriott Tempe at theButtes Mortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Phoenix Marriott Tempe at the Buttes MortgageLoan and one other *pari passu* loan, which is not an asset of the issuingentity. This loan combination, including the Phoenix Marriott Tempe at theButtes Mortgage Loan, was serviced under the Pooling and Servicing Agreementfor the issuing entity prior to the closing of the securitization of the other *paripassu* portion of the Phoenix Marriott Tempe at the Buttes loan combinationin the Citigroup Commercial Mortgage Trust 2018-C6 transaction, Commission FileNumber 333-207132-20 (the “CGCMT 2018-C6 Transaction”).  After theclosing of the CGCMT 2018-C6 Transaction on December 11, 2018, this loancombination, including the Phoenix Marriott Tempe at the Buttes Mortgage Loanwas, and will continue to be, serviced and administered pursuant to the poolingand servicing agreement with respect to the CGCMT 2018-C6 Transaction, which isincorporated by reference as Exhibit 4.9 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.

KeyBank National Association isthe master servicer of the mortgage loans serviced under the Pooling andServicing Agreement, the primary servicer of the Aon Center Mortgage Loan, theOverland Park Xchange Mortgage Loan and the Concord Plaza Mortgage Loan and theprimary servicer and special servicer of the Workspace Mortgage Loan. As aresult, KeyBank National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of the issuingentity as of its cut-off date. The assessments of compliance with applicableservicing criteria, accountants’ attestation reports and servicer compliancestatements delivered by KeyBank National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the certificate administrator of the mortgage loans servicedunder the Pooling and Servicing Agreement and the primary servicer of theMoffett Towers - Buildings E, F, G Mortgage Loan, the Aventura Mall MortgageLoan, the 636 11th Avenue Mortgage Loan, the Outlet Shoppes at El Paso MortgageLoan and the Phoenix Marriott Tempe at the Buttes Mortgage Loan. As a result,Wells Fargo Bank, National Association is a “servicer” as defined in Item1108(a)(2)(iii) of Regulation AB, in the capacities described above, because itis servicing mortgage loans that constituted 10% or more of the assets of theissuing entity as of its cut-off date. The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements delivered by Wells Fargo Bank, National Association inthe capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theAventura Mall Mortgage Loan, the Moffett Towers - Buildings E, F, G MortgageLoan, the Aon Center Mortgage Loan, the Workspace Mortgage Loan, the 636 11thAvenue Mortgage Loan, the Outlet Shoppes at El Paso Mortgage Loan and theShelbourne Global Portfolio I Mortgage Loan.  As a result, Wells FargoBank, National Association is a servicing function participant in thecapacities 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 Wells Fargo 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, the Moffett Towers - Buildings E, F, G MortgageLoan, the Aon Center Mortgage Loan, the Workspace Mortgage Loan, the 636 11thAvenue Mortgage Loan, the Outlet Shoppes at El Paso Mortgage Loan, the OverlandPark Xchange Mortgage Loan, the Phoenix Marriott Tempe at the Buttes MortgageLoan and the Concord Plaza Mortgage Loan.  As a result, Park Bridge LenderServices LLC 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 Park Bridge Lender Services LLC in the capacitiesdescribed above are listed in the Exhibit Index.

CWCapital Asset Management LLC is the special servicer of theAventura Mall Mortgage Loan and the 636 11th Avenue Mortgage Loan.  Thesemortgage loans constitute more than 5%, but less than 10%, of the pool assetsof the issuing entity.  Therefore, the Depositor included in this AnnualReport on Form 10-K an assessment of compliance with applicable servicingcriteria for CWCapital Asset Management LLC and an accountants’ attestationreport pursuant to Item 1122 of Regulation AB because CWCapital AssetManagement LLC is servicing more than 5% of the pool assets.  However, theDepositor is not required to include in this Annual Report on Form 10-K aservicer compliance statement pursuant to Item 1123 of Regulation AB ofCWCapital Asset Management LLC because CWCapital Asset Management LLC is anunaffiliated servicer servicing less than 10% of pool assets.

Midland Loan Services, a Division of PNC Bank, NationalAssociation is the special servicer of the Concord Plaza Mortgage Loan, theOverland Park Xchange Mortgage Loan and the Phoenix Marriott Tempe at theButtes Mortgage Loan and the primary servicer and special servicer of theShelbourne Global Portfolio I Mortgage Loan.  These mortgage loansconstitute more than 5%, but less than 10%, of the pool assets of the issuingentity.  Therefore, the Depositor included in this Annual Report on Form10-K an assessment of compliance with applicable servicing criteria for MidlandLoan Services, a Division of PNC Bank, National Association and an accountants’attestation report pursuant to Item 1122 of Regulation AB because Midland LoanServices, a Division of PNC Bank, National Association is servicing more than5% of the pool assets.  However, the Depositor is not required to includein this Annual Report on Form 10-K a servicer compliance statement pursuant toItem 1123 of Regulation AB of Midland Loan Services, a Division of PNC Bank,National Association because Midland Loan Services, a Division of PNC Bank,National Association is an unaffiliated servicer servicing less than 10% ofpool assets.

Citibank, N.A. is the custodian of the Overland Park XchangeMortgage Loan, the Phoenix Marriott Tempe at the Buttes Mortgage Loan and theConcord Plaza Mortgage Loan.  As a result, Citibank, N.A. is a servicingfunction participant in the capacities described above, because it is servicingmortgage loans that constituted 5% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria and accountants’ attestation reports delivered by Citibank, N.A. inthe capacities described above are listed in the Exhibit Index, and exclude theservicing criteria set forth in Items 1122(d)(4)(i) and 1122(d)(4)(ii) ofRegulation AB,  relating to the maintenance of collateral or security onpool assets as required by the pooling and servicing agreement for theBenchmark 2018-B6 Transaction and the pooling and servicing agreement for theCGCMT 2018-C6 Transaction, and the safeguarding of pool assets and relateddocuments as required by the pooling and servicing agreement for the Benchmark2018-B6 Transaction and the pooling and servicing agreement for the CGCMT2018-C6 Transaction, which servicing criteria have been assessed by U.S. BankNational Association, as a servicing function participant, as described belowin these Explanatory Notes.

Rialto Capital Advisors, LLC isthe special servicer of the Outlet Shoppes at El Paso Mortgage Loan and theMoffett Towers - Buildings E,F,G Mortgage Loan.  These mortgage loansconstitute more than 5%, but less than 10%, of the pool assets of the issuingentity.  Therefore, the Depositor included in this Annual Report on Form10-K an assessment of compliance with applicable servicing criteria for RialtoCapital Advisors, LLC and an accountants’ attestation report pursuant to Item1122 of Regulation AB because Rialto Capital Advisors, LLC is servicing morethan 5% of the pool assets.  However, the Depositor is not required toinclude in this Annual Report on Form 10-K a servicer compliance statementpursuant to Item 1123 of Regulation AB of Rialto Capital Advisors, LLC becauseRialto Capital Advisors, LLC is an unaffiliated servicer servicing less than10% of pool assets.

Wells Fargo Bank, NationalAssociation acts as trustee of the DUMBO Heights Portfolio Mortgage Loan, theShops at Solaris Mortgage Loan, the Liberty Portfolio Mortgage Loan, the 192Lexington Avenue Mortgage Loan, the Aon Center Mortgage Loan, the WorkspaceMortgage Loan and the Shelbourne Global Portfolio I Mortgage Loan. Pursuant to the Pooling and Servicing Agreement, the trust and servicingagreement for the JPMCC 2018-AON Transaction, the trust and servicing agreementfor the JPMCC 2018-WPT Transaction and the pooling and servicing agreement forthe UBS 2018-C13 Transaction, the trustee is required to provide an assessmentof compliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in theassessment of compliance with applicable servicing criteria and accountant’sattestation report for the subject transaction.  As a result, this AnnualReport on Form 10-K does not include an assessment of compliance withapplicable servicing criteria of the trustee. One or more other servicers ofthe DUMBO Heights Portfolio Mortgage Loan, the Shops at Solaris Mortgage Loan,the Liberty Portfolio Mortgage Loan, the 192 Lexington Avenue Mortgage Loan,the Aon Center Mortgage Loan, the Workspace Mortgage Loan and the ShelbourneGlobal Portfolio I Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, National Associationacts as trustee of the Aventura Mall Mortgage Loan, the 636 11th AvenueMortgage Loan, the Overland Park Xchange Mortgage Loan, the Concord PlazaMortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan, the OutletShoppes at El Paso Mortgage Loan and the Phoenix Marriott Tempe at the ButtesMortgage Loan.  Pursuant to the trust and servicing agreement for theAventura Mall Trust 2018-AVM Transaction, the pooling and servicing agreementfor the Benchmark 2018-B4 Transaction, the pooling and servicing agreement forthe Benchmark 2018-B6 Transaction, the pooling and servicing agreement for theDBGS 2018-C1 Transaction and the pooling and servicing agreement for the CGCMT2018-C6 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master serviceror the special servicer, to the extent required, performed the servicingfunction identified with respect to Item 1122(d)(2)(iii) of Regulation AB, andeach such party included Item 1122(d)(2)(iii) of Regulation AB in the assessmentof compliance with applicable servicing criteria and accountant’s attestationreport for the subject transaction.  As a result, this Annual Report onForm 10-K does not include an assessment of compliance with applicableservicing criteria of the trustee. One or more other servicers of the AventuraMall Mortgage Loan, the 636 11th Avenue Mortgage Loan, the Overland ParkXchange Mortgage Loan, the Concord Plaza Mortgage Loan, the Moffett Towers -Buildings E, F, G Mortgage Loan, the Outlet Shoppes at El Paso Mortgage Loanand the Phoenix Marriott Tempe at the Buttes Mortgage Loan have delivered oneor more assessments of compliance with respect to Item 1122(d)(2)(iii) ofRegulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria andaccountants’ attestation reports from CoreLogic Solutions, LLC  Thisentity was engaged by the primary servicer of the Aventura Mall Mortgage Loan,the 636 11th Avenue Mortgage Loan, the Moffett Towers - Buildings E, F, GMortgage Loan, the Outlet Shoppes at El Paso Mortgage Loan and the PhoenixMarriott Tempe at the Buttes Mortgage Loan to remit tax payments received fromthe escrow accounts of borrowers to local taxing authorities, to report taxamounts due, to verify tax parcel information, and to verify non-escrow taxpayments. These servicing functions are included within the servicing criteriaset forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB. Therefore, under the principles-based definition of “servicer” set forth inItem 1101(j) of Regulation AB that looks to the functions that an entityperforms, this vendor is a “servicer” for the purposes of Item 1122 ofRegulation 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)).

This AnnualReport on Form 10-K includes an assessment of compliance with applicableservicing criteria and an accountant’s attestation report from U.S. BankNational Association. This entity was engaged by Citibank, N.A., as thecustodian of the Overland Park Xchange Mortgage Loan, the Phoenix MarriottTempe at the Buttes Mortgage Loan and the Concord Plaza Mortgage Loan toperform certain custodial services. These custodial services are servicingfunctions included within the servicing criteria set forth in Items1122(d)(4)(i) and 1122(d)(4)(ii) of Regulation AB. Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) orRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB. See Complianceand Disclosure Interpretations, Section 301.01 (Item 1101(j)).

The assessments of compliance withapplicable servicing criteria, accountants’ attestation reports and servicercompliance statements of the certificate administrator of the Aventura MallMortgage Loan, the Aon Center Mortgage Loan, the 636 11th Avenue Mortgage Loan,the Workspace Mortgage Loan, the Shelbourne Global Portfolio I Mortgage Loan,the Moffett Towers - Buildings E, F, G Mortgage Loan, the Outlet Shoppes at ElPaso Mortgage Loan, the Overland Park Xchange Mortgage Loan, the Concord PlazaMortgage Loan and the Phoenix Marriott Tempe at the Buttes Mortgage Loan areomitted from this Annual Report on Form 10-K as the certificate administratorpursuant to the related pooling and servicing agreement or trust and servicingagreement does not perform any activities that address servicing criteria withrespect to the issuing entity and because they are each not a “servicer” thatmeets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the pari passuloan combinations that include the Aon Center Mortgage Loan, the ShelbourneGlobal Portfolio I Mortgage Loan, the Aventura Mall Mortgage Loan, the 636 11thAvenue Mortgage Loan, Overland Park Xchange Mortgage Loan, the Concord PlazaMortgage Loan, the Phoenix Marriott Tempe at the Buttes Mortgage Loan, MoffettTowers - Buildings E,F,G Mortgage Loan and the Outlet Shoppes at El PasoMortgage Loan, (i) the reports on assessment of compliance with servicingcriteria and attestation reports on assessment of compliance with servicingcriteria of AEGON USA Realty Advisors, LLC as special servicer of the AonCenter Mortgage Loan prior to March 29, 2021, Situs Holdings, LLC as specialservicer of the Aon Center Mortgage Loan on and after March 29, 2021 andPentalpha Surveillance LLC as operating advisor of the Shelbourne GlobalPortfolio I Mortgage Loan, listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as they are not required to be included on thisAnnual Report on Form 10-K per Instruction 3 to Item 1122 of Regulation ABbecause they are parties performing activities that address servicing criteriarelating to 5% or less of the assets of the issuing entity; and (ii) the servicercompliance statements of CWCapital Asset Management LLC as special servicer ofthe Aventura Mall Mortgage Loan and the 636 11th Avenue Mortgage Loan, AEGONUSA Realty Advisors, LLC as special servicer of the Aon Center Mortgage Loanprior to March 29, 2021, Situs Holdings, LLC as special servicer of the AonCenter Mortgage Loan on and after March 29, 2021, Midland Loan Services, aDivision of PNC Bank, National Association as special servicer of the OverlandPark Xchange Mortgage Loan, the Concord Plaza Mortgage Loan, the ShelbourneGlobal Portfolio I Mortgage Loan and the Phoenix Marriott Tempe at the ButtesMortgage Loan and Rialto Capital Advisors, LLC as special servicer of theMoffett Towers - Buildings E, F, G Mortgage Loan and the Outlet Shoppes at ElPaso Mortgage Loan, listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K as they are not required by Item 1123 of Regulation AB tobe 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,Wells Fargo Bank, National Association, as trustee, as certificateadministrator and as custodian, and the Shelbourne Global Portfolio I MortgageLoan.

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

On December 17, 2015, U.S. Bank National Association, thetrustee under five pooling and servicing agreements for (i) Wachovia BankCommercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC CommercialMortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenceda proceeding with the Second Judicial District Court of Ramsey County,Minnesota (the “State Court”) for a declaratory judgment as to theproper allocation of certain proceeds (“Disputed Proceeds”) received byCWCAM in connection with the sale of the Peter Cooper Village and StuyvesantTown property in New York, New York securing loans held by those trusts. CWCAM was the special servicer of such property.  The petition requeststhe State Court to instruct the trustee, the trust beneficiaries, and any otherinterested parties as to the amount of the Disputed Proceeds, if any, thatconstitute penalty interest and/or the amount of the Disputed Proceeds, if any,that constitute gain-on-sale proceeds, with respect to each trust.  OnFebruary 24, 2016, CWCAM made a limited appearance with the State Court to filea motion to dismiss this proceeding based on lack of jurisdiction, mootness,standing and forum non conveniens.  On July 19, 2016, the State Courtdenied CWCAM’s motion to dismiss.  On July 22, 2016, the action wasremoved to federal court in Minnesota (“Federal Court”).  OnOctober 21, 2016, the Federal Court held a hearing on the motion to transferthe action to the United States District Court for the Southern District of NewYork (“SDNY Court”), a motion to remand to state court and a motion tohear CWCAM’s request for reconsideration of the motion to dismiss.  OnMarch 14, 2017, the Federal Court reserved the determination on the motion tohear CWCAM’s request for reconsideration of the motion to dismiss, denied themotion to remand the matter to state court and granted the motion to transferthe proceeding to the SDNY Court.  Cross motions for judgment on thepleadings were filed but the SDNY Court was unable to decide the case based onthe pleadings and the SDNY Court ordered discovery.  All fact discoverywas completed 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’s petition,namely, that the funds in dispute constitute penalty interest and yieldmaintenance, not gain-on-sale proceeds, and that the amount of penalty interestand yield maintenance was correctly calculated. An appeal of the SDNY Court’sdecision was taken on April 29, 2020.  Oral argument on the appealoccurred on June 21, 2021. The parties await the decision of the appealscourt.  

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of theOriginal  Complaint alleged breaches of a contract and fiduciary duties byCWCAM’s affiliate, CWCapital Investments LLC in its capacity as collateralmanager for the collateralized debt obligation transaction involving CWCapitalCobalt Vr, Ltd. In total, there are 14 counts pled in the Original Complaint.Of those 14, 5 claims were asserted against CWCAM for aiding and abettingbreach of fiduciary duty, conversion and unjust enrichment. On May 23, 2018,the Original Complaint was dismissed for lack of subject matterjurisdiction.   On June 28, 2018, CWCapital Cobalt Vr Ltd. filed asubstantially similar complaint in the Supreme Court of the State of New York,County of New York styled as CWCapital Cobalt Vr Ltd. v. CWCapital InvestmentsLLC, et al., Index No. 653277/2018 (the “New Complaint”).  Thegravamen of the New Complaint is the same as the previous complaint filed inthe United State District Court for the Southern District of New York.  Intotal there are 16 counts pled in the New Complaint. Of those 16 counts, 5claims were asserted against CWCAM for aiding and abetting breach of fiduciaryduty, conversion and unjust enrichment, 1 count seeks a declaratory judgementthat the plaintiff has the right to enforce the contracts in question and 1count seeks an injunction requiring the defendants to recognize the plaintiffas the directing holder for the trusts in question. On January 11, 2019, theplaintiff dismissed with prejudice the declaratory judgment and injunctioncounts.  The New Complaint and related summons was not served on thedefendants until July 13, 2018 and July 16, 2018.  The plaintiff’s motionfor a preliminary injunction was denied by the court on July 31, 2018.  OnAugust 3, 2018, the defendants, including CWCAM, filed a motion to dismiss theNew Complaint in its entirety. On August 20, 2019, the court entered an ordergranting defendants’ motion almost in its entirety, dismissing 11 of the 16counts and partially dismissing 2 additional counts.  Of the remainingcounts, 2 are asserted against CWCAM for aiding and abetting breach offiduciary duty and unjust enrichment.  On September 19, 2019, CWCapitalCobalt Vr Ltd. filed a notice of appeal relating to the August 20, 2019dismissal order and on September 26, 2019, filed an amended complaint againstCWCI and CWCAM attempting to address deficiencies relating to certain of theclaims dismissed by the August, 20, 2019 order.  CWCI and CWCAM filed itsMotion to Dismiss the amended complaint on October 28, 2019.  The courtheard argument on the Motion to Dismiss the amended complaint on January 22,2020 and on October 23, 2020, the court granted the motion dismissing theamended claims.  On November 30, 2020, CWCapital Cobalt Vr Ltd filed anotice of appeal relating to the October 23, 2020 dismissal order.  OnApril 27, 2021, the First Department affirmed the dismissal as to claimsagainst CWCAM that were part of the August 20, 2019 dismissal, but reversed thedismissal of two counts for breach of the Collateral Management Agreementagainst CWCI.  CWCI has sought leave to file an appeal of thedecision.  Both requests for leave were denied by the First Department. The plaintiff has also sought leave to appeal the dismissal of the claimsagainst CWCAM.  CWCAM believes that it has performed its obligations underthe related pooling and servicing agreements in good faith and the remainingallegations 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 other Defendantsfiled a motion to dismiss the PSW Complaint (the “CWCAM Motion to Dismiss”). OnApril 11, 2016, PSW NYC LLC opposed the CWCAM Motion to Dismiss and cross-movedfor a partial summary judgment on liability regarding allegations of breach ofthe 2010 Settlement Agreement (the “PSW Cross-Motion”). On May 5, 2016, theDefendants subsequently filed its reply and opposition to the PSW Cross-Motion.On August 23, 2016, oral arguments were provided to the PSW Court regarding thePSW Complaint, the CWCAM Motion to Dismiss and the PSW Cross-Motion and the PSWCourt took such arguments under advisement. On October 31, 2016, the PSW Courtissued an order granting the CWCAM Motion to Dismiss, denying the PSWCross-Motion and dismissing the PSW Complaint with prejudice. Subsequently, PSWNYC LLC filed a notice of appeal relating to such order. On February 21, 2017,PSW NYC LLC filed its appeal and supporting brief arguing that the PSW Courterred by finding no breach of the assignment agreement and no fraudulent inducement.Oral argument was heard on May 4, 2017 at which point the court took thearguments under advisement. On May 25, 2017, the New York 1stDepartment appellate court affirmed the dismissal of all PSW claims and denieda request for leave to appeal to the New 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 with theRAIT Complaint.  On June 14, 2016, RAIT Preferred Funding filed aMemorandum of Law in Opposition to the Motion to Dismiss (“Opposition”)stating that the claims in the RAIT Complaint were properly stated.  OnJune 30, 2016, CWCAM filed a reply in support of the Motion to Dismiss and inresponse to the Opposition, stating that each of CWCAM’s arguments is supportedby the express language of the agreements between the parties, the documentaryevidence and New York case law.  On September 30, 2016, RAIT PreferredFunding and CWCAM entered into a confidential Settlement Agreement (the “2016Settlement”), which provides for a stay of the RAIT Preferred Fundinglitigation (the “Litigation Stay”) through August 25, 2017. Pursuant to the terms of the 2016 Settlement, upon satisfaction of a term ofthe 2016 Settlement by August 25, 2017 (or such later date agreed to by theparties), the RAIT Preferred Funding litigation will be dismissed, withprejudice.  On May 19, 2017 the Borrower repaid the Loan in accordancewith the terms of the notes and satisfied the condition to dismissal withprejudice.  RAIT has refused to dismiss the case and is claiming that theB Note should be paid in full.  CWCAM believes that it has performed itsobligations under the Operative Agreements in good faith, and that the actionshould be dismissed with prejudice.  On August 29, 2017, the RAIT Courtgranted leave to RAIT Preferred Funding to amend its complaint.  OnSeptember 20, 2017, RAIT Preferred Funding filed an Amended Complaint (the “RAITAmended Complaint”), which omits its original claims, adds Wells Fargo Bankas a defendant, and seeks (a) specific performance requiring repayment of the$18,500,000 principal amount of the B Note or, in the alternative, monetarydamages, including the $18,500,000 principal amount of the B Note, in an amountto be determined at trial, (b) monetary damages on any fees paid to CWCAM asspecial servicer or Wells Fargo Bank as master servicer in connection with theborrower’s repayment of the Loan, (c) a declaratory judgment that RAITPreferred Funding is entitled to recover the full $18,500,000 principal amountof the B Note, (d) punitive damages against CWCAM, and (e) other things. On October 11, 2017, CWCAM filed a motion to dismiss the RAIT Amended Complaint(“CWCAM Motion to Dismiss Amended Complaint”) stating that the RAITAmended Complaint did not state a claim and the essential facts of the RAITAmended Complaint are negated by the Operative Agreements and other admissibleevidentiary materials.  On November 13, 2017, Wells Fargo Bank filed amotion to dismiss the RAIT Amended Complaint (the “Wells Fargo Motion toDismiss Amended Complaint”) and joined the CWCAM Motion to Dismiss AmendedComplaint.  On January 29, 2018, the court dismissed all claims but forbreach of contract and discovery has commenced.  CWCAM filed a Motion forSummary Judgement on March 18, 2019.   This matter was settled andthe case dismissed on May 15, 2019. 

 

In December 2014, Phoenix LightSF Limited and certain related entities and the National Credit UnionAdministration (NCUA) filed complaints in the United States District Court forthe Southern District of New York against Wells Fargo Bank, alleging claimsagainst Wells Fargo Bank in its capacity as trustee for a number of residentialmortgage-backed securities trusts. Complaints raising similar allegations havebeen filed by Commerzbank AG in the Southern District of New York and by IKBInternational and IKB Deutsche Industriebank in New York state court. In each case,the plaintiffs allege that Wells Fargo Bank, as trustee, caused losses toinvestors, and plaintiffs assert causes of action based upon, among otherthings, the trustee’s alleged failure to notify and enforce repurchaseobligations of mortgage loan sellers for purported breaches of representationsand warranties, notify investors of alleged events of default, and abide byappropriate standards of care following alleged events of default. Wells FargoBank previously settled two class action lawsuits with similar allegations thatwere filed 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 New Yorkstate 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. 

 

On February 14, 2022, Cantor Commercial Real Estate Lending,L.P. (“CCRE”) was named as a defendant in a lawsuit captioned *Kingsbridge2005, LLC, Shelbourne Broad Street, LLC and 691 Central Avenue SPE LLC v CantorCommercial Real Estate Lending, L.P., and KKR Real Estate Credit OpportunityPartners Aggregator I L.P., and Midland Loan Services, Inc.,* Index No.650687/2002, filed in the Supreme Court of the State of New York, County of NewYork.  Plaintiff seeks recission of a $93 million loan issued by CCRE inSeptember 2018 and subsequently sold into four commercial mortgage backedsecurities transactions on the theory of unilateral mistake.  Plaintiffclaims it discovered the issue when it was denied partial defeasance of oneproperty that served as collateral for the loan.  The case is in the earlystages.  At this point, we do not believe the outcome of the case wouldhave a material impact on CCRE’s obligations with respect to the loan or on certificateholders, although no assurance can be given that it will not have a materialimpact on certificate holders.

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on November 28, 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 ScheduleII to the Pooling and Servicing Agreement incorporated by reference as Exhibit4.1 to 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 Aon Center Mortgage Loan, whichis being serviced and administered pursuant to the trust and servicingagreement for the JPMCC 2018-AON Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit L to the trust and servicingagreement for the JPMCC 2018-AON Transaction incorporated by reference asExhibit 4.3 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the JPMCC 2018-AONTransaction 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 636 11th Avenue Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2018-B4 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Schedule II to the poolingand servicing agreement for the Benchmark 2018-B4 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 theBenchmark 2018-B4 Transaction responsible for each applicable servicingcriteria 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 Workspace Mortgage Loan, which isbeing serviced and administered pursuant to the trust and servicing agreementfor the JPMCC 2018-WPT Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit L to the trust and servicingagreement for the JPMCC 2018-WPT 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 JPMCC 2018-WPTTransaction 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 Overland Park Xchange MortgageLoan and the Concord Plaza Mortgage Loan, which are being serviced andadministered pursuant to the pooling and servicing agreement for the Benchmark2018-B6 Transaction, are attached hereto under Item 15 to this Annual Report onForm 10-K. Attached as Exhibit O to the pooling and servicing agreement for theBenchmark 2018-B6 Transaction incorporated by reference as Exhibit 4.6 to thisAnnual Report on Form 10-K is a chart identifying the entities participating ina servicing function for the Benchmark 2018-B6 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 Shelbourne Global Portfolio IMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the UBS 2018-C13 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Z to thepooling and servicing agreement for the UBS 2018-C13 Transaction incorporatedby reference as Exhibit 4.7 to this Annual Report on Form 10-K is a chart identifyingthe entities participating in a servicing function for the UBS 2018-C13Transaction 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 Moffett Towers - Buildings E, F,G Mortgage Loan and the Outlet Shoppes at El Paso Mortgage Loan, which arebeing serviced and administered pursuant to the pooling and servicing agreementfor the DBGS 2018-C1 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Schedule II to the pooling andservicing agreement for the DBGS 2018-C1 Transaction incorporated by referenceas Exhibit 4.8 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the DBGS 2018-C1 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Phoenix Marriott Tempe at theButtes Mortgage Loan, which is being serviced and administered pursuant to thepooling and servicing agreement for the CGCMT 2018-C6 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit Oto the pooling and servicing agreement for the CGCMT 2018-C6 Transactionincorporated by reference as Exhibit 4.9 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theCGCMT 2018-C6 Transaction responsible for each applicable servicing criteriaset forth in Item 1122(d).

The report on assessment of compliance for the twelve monthsended December 31, 2021, furnished pursuant to Item 1122 of Regulation AB byAegon USA Realty Advisors, LLC (“Aegon” or the “Company”), as special servicer,discloses that the following material instance of noncompliance occurred withrespect to its platform:

The examination performed by PWC identified an instance ofmaterial noncompliance with the servicing criteria set forth in Item1122(d)(3)(i)(A) of Regulation AB applicable to the Company during year endedDecember 31, 2021. More specifically, for the only active special serviced dealsubject to Item 1122(d)(3)(i)(A), the report to the investors was not preparedin accordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4is the specific deal related to the aforementioned finding. No other dealswithin Aegon’s CMBS special servicing portfolio were related to or impacted bythis instance of non-compliance.

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timingdiscrepancy, there was no impact on any investor reporting, issuing, orservicing. No additional testing was available for this particular criteria dueto the downsizing of the CMBS portfolio given Aegon’s pending exit from thebusiness line.

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

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

The servicer compliance statement for the twelve months endedDecember 31, 2021, furnished pursuant to Item 1123 of Regulation AB by AegonUSA Realty Advisors, LLC (“Aegon” or the “Company”), as special servicer,discloses that the following material instance of noncompliance occurred withrespect to its platform:

The examination performed by PWC identified an instance ofmaterial noncompliance with the servicing criteria set forth in Item1122(d)(3)(i)(A) of Regulation AB applicable to the Company during year endedDecember 31, 2021. More specifically, for the only active special serviced dealsubject to Item 1122(d)(3)(i)(A), the report to the investors was not preparedin accordance with the timeframes and other terms set forth in the transactionagreements for the period of January 1, 2021 to January 21, 2021. UBSCM 2017-C4is the specific deal related to the aforementioned finding. No other dealswithin Aegon’s CMBS special servicing portfolio were related to or impacted bythis instance of non-compliance.

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timingdiscrepancy, there was no impact on any investor reporting, issuing, orservicing. No additional testing was available for this particular criteria dueto the downsizing of the CMBS portfolio given Aegon’s pending exit from thebusiness line.

 

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Pooling and Servicing Agreement, dated as of November 1,2018, by and among Deutsche Mortgage & Asset Receiving Corporation, asDepositor, KeyBank National Association, as Master Servicer, LNR Partners, LLC,as Special Servicer, Wells Fargo Bank, National Association, as Trustee,Certificate Administrator, Paying Agent and Custodian, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.1 to the registrant’s Current Report on Form 8-K/A filed onJanuary 4, 2019 under Commission File No. 333-226943-01 and incorporated byreference herein).

4.2          Trust and Servicing Agreement, dated as of June 29, 2018,by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, Wells Fargo Bank, National Association, as Servicer, CWCapital AssetManagement LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator, Wilmington Trust, National Association, as Trustee,and Park Bridge Lender Services LLC, as Operating Advisor (filed as Exhibit 4.3to the registrant’s Current Report on Form 8-K filed on November 28, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.3          Trust and Servicing Agreement, dated as of June 29, 2018,by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, KeyBank National Association, as Servicer, AEGON USA RealtyAdvisors, LLC, as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator and as Trustee, and Park Bridge Lender Services LLC,as Operating Advisor (filed as Exhibit 4.4 to the registrant’s Current Reporton Form 8-K filed on November 28, 2018 under Commission File No. 333-226943-01and incorporated by reference herein).

4.4          Pooling and Servicing Agreement, dated as of July 1,2018, by and among Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Wells Fargo Bank, National Association, as Master Servicer,CWCapital Asset Management LLC, as Special Servicer, Wilmington Trust, NationalAssociation, as Trustee, Wells Fargo Bank, National Association, as CertificateAdministrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 4.6to the registrant’s Current Report on Form 8-K filed on November 28, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.5          Trust and Servicing Agreement, dated as of July 31, 2018,by and among J.P. Morgan Chase Commercial Mortgage Securities Corp., asDepositor, KeyBank National Association, as Servicer, KeyBank NationalAssociation, as Special Servicer, Wells Fargo Bank, National Association, asTrustee, Wells Fargo Bank, National Association, as Certificate Administrator,and Park Bridge Lender Services LLC, as Operating Advisor (filed as Exhibit 4.5to the registrant’s Current Report on Form 8-K filed on November 28, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.6          Pooling and Servicing Agreement, dated as of October 1,2018, by and among Citigroup Commercial Mortgage Securities Inc., as Depositor,KeyBank National Association, as Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, as Special Servicer, Park BridgeLender Services LLC, as Operating Advisor and as Asset RepresentationsReviewer, Citibank, N.A., as Certificate Administrator, and Wilmington Trust,National Association, as Trustee (filed as Exhibit 4.7 to the registrant’sCurrent Report on Form 8-K filed on November 28, 2018 under Commission File No.333-226943-01 and incorporated by reference herein).

4.7          Pooling and Servicing Agreement, dated as of October 1,2018, by and among UBS Commercial Mortgage Securitization Corp., as Depositor,Midland Loan Services, a Division of PNC Bank, National Association, as MasterServicer and as Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator and as Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and as Asset Representations Reviewer (filed as Exhibit 4.8to the registrant’s Current Report on Form 8-K filed on November 28, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.8          Pooling and Servicing Agreement, dated as of October 1,2018, by and among Deutsche Mortgage & Asset Receiving Corporation, asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wilmington Trust, NationalAssociation, as Trustee, Wells Fargo Bank, National Association, as CertificateAdministrator, Paying Agent and Custodian, and Park Bridge Lender Services LLC,as Operating Advisor and as Asset Representations Reviewer (filed as Exhibit4.2 to the registrant’s Current Report on Form 8-K/A filed on January 4, 2019under Commission File No. 333-226943-01 and incorporated by reference herein).

4.9          Pooling and Servicing Agreement, dated as of December 1,2018, by and among Citigroup Commercial Mortgage Securities Inc., as Depositor,Wells Fargo Bank, National Association, as Master Servicer, Midland LoanServices, a Division of PNC Bank, National Association, as Special Servicer,Park Bridge Lender Services LLC, as Operating Advisor and as AssetRepresentations Reviewer, Citibank, N.A., as Certificate Administrator, andWilmington Trust, National Association, as Trustee (filed as Exhibit 4.1 to theregistrant’s Current Report on Form 8-K filed on December 12, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.10         Amended and Restated Agreement Between Noteholders, datedas of November 27, 2018, by and between Citi Real Estate Funding Inc., as NoteA-1 Holder, Citi Real Estate Funding Inc., as Note A-2 Holder, Citi Real EstateFunding Inc., as Note A-3 Holder, Shinhan AIM Real Estate Fund No. 5, as NoteB-1 Holder, and Shinhan AIM Real Estate Fund No. 5-A, as Note B-2 Holder (filedas Exhibit 4.9 to the registrant’s Current Report on Form 8-K filed on November28, 2018 under Commission File No. 333-226943-01 and incorporated by referenceherein).

4.11         Agreement Between Note Holders, dated as of October 10,2018, by and between Citi Real Estate Funding Inc., as Initial Note A-1 Holder,and Cantor Commercial Real Estate Lending, L.P., as Initial Note A-2 Holder(filed as Exhibit 4.10 to the registrant’s Current Report on Form 8-K filed onNovember 28, 2018 under Commission File No. 333-226943-01 and incorporated byreference herein).

4.12         Agreement Between Note Holders, dated as of September 26,2018, by and between Citi Real Estate Funding Inc., as Initial Note A-1 Holder,Citi Real Estate Funding Inc., as Initial Note A-2 Holder, Citi Real EstateFunding Inc., as Initial Note A-3 Holder, Barclays Bank PLC, as Initial NoteA-4 Holder, Barclays Bank PLC, as Initial Note A-5 Holder, Cantor CommercialReal Estate Lending, L.P., as Initial Note A-6 Holder, Cantor Commercial RealEstate Lending, L.P., as Initial Note A-7 Holder, and Citi Real Estate FundingInc., as Initial Note A-8 Holder (filed as Exhibit 4.11 to the registrant’sCurrent Report on Form 8-K filed on November 28, 2018 under Commission File No.333-226943-01 and incorporated by reference herein).

4.13         Co-Lender Agreement, dated as of November 28, 2018, byand between Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and CitiReal Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.12 tothe registrant’s Current Report on Form 8-K filed on November 28, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.14         Co-Lender Agreement, dated as of November 28, 2018, byand between Citi Real Estate Funding, Inc., as Initial Note A-1 Holder and CitiReal Estate Funding, Inc., as Initial Note A-2 Holder (filed as Exhibit 4.13 tothe registrant’s Current Report on Form 8-K filed on November 28, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.15         Co-Lender Agreement, dated as of October 30, 2018,between Deutsche Bank AG, acting through its New York Branch, as Note A-1-1Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-2Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-3Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-4Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-2Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-3Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-4Holder, Goldman Sachs Mortgage Company, as Note A-5 Holder, Wells Fargo Bank,National Association, as Note A-6 Holder, and Wells Fargo Bank, NationalAssociation, as Note A-7 Holder (filed as Exhibit 4.14 to the registrant’sCurrent Report on Form 8-K filed on November 28, 2018 under Commission File No.333-226943-01 and incorporated by reference herein).

4.16         Co-Lender Agreement, dated as of October 30, 2018,between Deutsche Bank AG, acting through its New York Branch, as Note A-1-AHolder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-BHolder, Deutsche Bank AG, acting through its New York Branch, as Note A-2Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-3 Holder,and Deutsche Bank AG, acting through its New York Branch, as Note A-4 Holder(filed as Exhibit 4.15 to the registrant’s Current Report on Form 8-K filed onNovember 28, 2018 under Commission File No. 333-226943-01 and incorporated byreference herein).

4.17         Co-Lender Agreement, dated as of June 7, 2018, by andamong JPMorgan Chase Bank, National Association, Deutsche Bank, AG, New YorkBranch, Wells Fargo Bank, National Association and Morgan Stanley Bank, N.A(filed as Exhibit 4.16 to the registrant’s Current Report on Form 8-K filed onNovember 28, 2018 under Commission File No. 333-226943-01 and incorporated byreference herein).

4.18         Co-Lender Agreement, dated as of June 8, 2018, by andbetween JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder,JPMorgan Chase Bank, National Association, as Initial Note A-2 Holder, JPMorganChase Bank, National Association, as Initial Note A-3 Holder, JPMorgan ChaseBank, National Association, as Initial Note A-4 Holder, and JPMorgan ChaseBank, National Association, as Initial Note B Holder (filed as Exhibit 4.17 tothe registrant’s Current Report on Form 8-K filed on November 28, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.19         Co-Lender Agreement, dated as of July 12, 2018, by andamong JPMorgan Chase Bank, National Association, as Initial Note A-1 Holder andInitial Note A-2 Holder, JPMorgan Chase Bank, National Association, as InitialNote A-3 Holder and Initial Note A-4 Holder, JPMorgan Chase Bank, NationalAssociation, as Initial Note A-5 Holder, Initial Note A-6 Holder, Initial NoteA-7 Holder, Initial Note A-8 Holder, Initial Note A-9 Holder, Initial Note A-10Holder, and JPMorgan Chase Bank, National Association, as Initial Note B-1Holder and Initial Note B-2 Holder (filed as Exhibit 4.18 to the registrant’sCurrent Report on Form 8-K filed on November 28, 2018 under Commission File No.333-226943-01 and incorporated by reference herein).

4.20         Co-Lender Agreement, dated as of June 21, 2018, betweenJPMorgan Chase Bank, National Association, as Initial Note A-1 Holder, JPMorganChase Bank, National Association, as Initial Note A-2 Holder, JPMorgan ChaseBank, National Association, as Initial Note A-3 Holder, Citi Real EstateFunding Inc., as Initial Note A-4 Holder, and Citi Real Estate Funding Inc., asInitial Note A-5 Holder (filed as Exhibit 4.19 to the registrant’s CurrentReport on Form 8-K filed on November 28, 2018 under Commission File No.333-226943-01 and incorporated by reference herein).

4.21         Amended and Restated Co-Lender Agreement, dated as ofSeptember 17, 2018, by and between Wilmington Trust, National Association asTrustee for the benefit of the Registered Holders of Benchmark 2018-B5 MortgageTrust, Commercial Mortgage Pass-Through Certificates, Series 2018-B5 (Note A-1Holder), JPMorgan Chase Bank, National Association (Initial Note A-2A Holder)and JPMorgan Chase Bank, National Association (Initial Note A-2B Holder) (filedas Exhibit 4.20 to the registrant’s Current Report on Form 8-K filed onNovember 28, 2018 under Commission File No. 333-226943-01 and incorporated byreference herein).

4.22         Co-Lender Agreement, dated as of September 17, 2018, byand between Citi Real Estate Funding Inc., as Initial Note A-1 Holder, and CitiReal Estate Funding Inc., as Initial Note A-2 Holder (filed as Exhibit 4.21 tothe registrant’s Current Report on Form 8-K filed on November 28, 2018 underCommission File No. 333-226943-01 and incorporated by reference herein).

4.23         Co-Lender Agreement, dated as of October 11, 2018,between Cantor Commercial Real Estate Lending, L.P., as Note A-1 Holder, CantorCommercial Real Estate Lending, L.P., as Note A-2 Holder, Cantor CommercialReal Estate Lending, L.P., as Note A-3 Holder, Cantor Commercial Real EstateLending, L.P., as Note A-4 Holder, Cantor Commercial Real Estate Lending, L.P.,as Note A-5 Holder, Cantor Commercial Real Estate Lending, L.P., as Note A-6Holder, and Cantor Commercial Real Estate Lending, L.P., as Note A-7 Holder(filed as Exhibit 4.22 to the registrant’s Current Report on Form 8-K filed onNovember 28, 2018 under Commission File No. 333-226943-01 and incorporated byreference herein).

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

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

33.1        KeyBank National Association, as Master Servicer

33.2        LNR Partners, LLC, as Special Servicer

33.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

33.4        Wells Fargo Bank, National Association, asCustodian

33.5        Park Bridge Lender Services LLC, as OperatingAdvisor

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

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

33.8        KeyBank National Association, as Primary Servicerof the DUMBO Heights Portfolio Mortgage Loan (see Exhibit 33.1)

33.9        LNR Partners, LLC, as Special Servicer of the DUMBOHeights Portfolio Mortgage Loan (see Exhibit 33.2)

33.10      Wells Fargo Bank, National Association, as Trustee of the DUMBO HeightsPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.11      Wells Fargo Bank, National Association, asCustodian of the DUMBO Heights Portfolio Mortgage Loan (see Exhibit 33.4)

33.12      Park Bridge Lender Services LLC, as OperatingAdvisor of the DUMBO Heights Portfolio Mortgage Loan (see Exhibit 33.5)

33.13      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.14      KeyBank National Association, as Primary Servicerof the Liberty Portfolio Mortgage Loan (see Exhibit 33.1)

33.15      LNR Partners, LLC, as Special Servicer of theLiberty Portfolio Mortgage Loan (see Exhibit 33.2)

33.16      Wells Fargo Bank, National Association, as Trustee of the Liberty PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.17      Wells Fargo Bank, National Association, asCustodian of the Liberty Portfolio Mortgage Loan (see Exhibit 33.4)

33.18      Park Bridge Lender Services LLC, as OperatingAdvisor of the Liberty Portfolio Mortgage Loan (see Exhibit 33.5)

33.19      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.20      KeyBank National Association, as Primary Servicer ofthe Shops at Solaris Mortgage Loan (see Exhibit 33.1)

33.21      LNR Partners, LLC, as Special Servicer of the Shopsat Solaris Mortgage Loan (see Exhibit 33.2)

33.22      Wells Fargo Bank, National Association, as Trustee of the Shops at SolarisMortgage Loan (Omitted. See Explanatory Notes.)

33.23      Wells Fargo Bank, National Association, asCustodian of the Shops at Solaris Mortgage Loan (see Exhibit 33.4)

33.24      Park Bridge Lender Services LLC, as OperatingAdvisor of the Shops at Solaris Mortgage Loan (see Exhibit 33.5)

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.26      KeyBank National Association, as Primary Servicerof the 192 Lexington Avenue Mortgage Loan (see Exhibit 33.1)

33.27      LNR Partners, LLC, as Special Servicer of the 192Lexington Avenue Mortgage Loan (see Exhibit 33.2)

33.28      Wells Fargo Bank, National Association, as Trustee of the 192 Lexington AvenueMortgage Loan (Omitted. See Explanatory Notes.)

33.29      Wells Fargo Bank, National Association, asCustodian of the 192 Lexington Avenue Mortgage Loan (see Exhibit 33.4)

33.30      Park Bridge Lender Services LLC, as OperatingAdvisor of the 192 Lexington Avenue Mortgage Loan (see Exhibit 33.5)

33.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.32      Wells Fargo Bank, National Association, as PrimaryServicer of the Aventura Mall Mortgage Loan

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

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

33.35      Wells Fargo Bank, National Association, as Custodianof the Aventura Mall Mortgage Loan (see Exhibit 33.4)

33.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aventura Mall Mortgage Loan (see Exhibit 33.5)

33.37      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Aventura Mall Mortgage Loan

33.38      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.39      KeyBank National Association, as Primary Servicerof the Aon Center Mortgage Loan (see Exhibit 33.1)

33.40      AEGON USA Realty Advisors, LLC, as Special Servicer of the Aon Center MortgageLoan prior to March 29, 2021 (Omitted. See Explanatory Notes.)

33.41      Situs Holdings, LLC, as Special Servicer of the Aon Center Mortgage Loan on andafter March 29, 2021 (Omitted. See Explanatory Notes.)

33.42      Wells Fargo Bank, National Association, as Trustee of the Aon Center MortgageLoan (Omitted. See Explanatory Notes.)

33.43      Wells Fargo Bank, National Association, as Custodianof the Aon Center Mortgage Loan (see Exhibit 33.4)

33.44      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aon Center Mortgage Loan (see Exhibit 33.5)

33.45      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.46      Wells Fargo Bank, National Association, as PrimaryServicer of the 636 11th Avenue Mortgage Loan (see Exhibit 33.32)

33.47      CWCapital Asset Management LLC, as SpecialServicer of the 636 11th Avenue Mortgage Loan (see Exhibit 33.33)

33.48      Wilmington Trust, National Association, as Trustee of the 636 11th AvenueMortgage Loan (Omitted. See Explanatory Notes.)

33.49      Wells Fargo Bank, National Association, asCustodian of the 636 11th Avenue Mortgage Loan (see Exhibit 33.4)

33.50      Park Bridge Lender Services LLC, as OperatingAdvisor of the 636 11th Avenue Mortgage Loan (see Exhibit 33.5)

33.51      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 636 11th Avenue Mortgage Loan (see Exhibit 33.37)

33.52      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.53      KeyBank National Association, as Primary Servicerof the Workspace Mortgage Loan (see Exhibit 33.1)

33.54      KeyBank National Association, as Special Servicerof the Workspace Mortgage Loan (see Exhibit 33.1)

33.55      Wells Fargo Bank, National Association, as Trustee of the Workspace MortgageLoan (Omitted. See Explanatory Notes.)

33.56      Wells Fargo Bank, National Association, asCustodian of the Workspace Mortgage Loan (see Exhibit 33.4)

33.57      Park Bridge Lender Services LLC, as OperatingAdvisor of the Workspace Mortgage Loan (see Exhibit 33.5)

33.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.59      KeyBank National Association, as Primary Servicerof the Overland Park Xchange Mortgage Loan (see Exhibit 33.1)

33.60      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Overland Park Xchange MortgageLoan

33.61      Wilmington Trust, National Association, as Trustee of the Overland Park XchangeMortgage Loan (Omitted. See Explanatory Notes.)

33.62      Citibank, N.A., as Custodian of the Overland ParkXchange Mortgage Loan

33.63      Park Bridge Lender Services LLC, as OperatingAdvisor of the Overland Park Xchange Mortgage Loan (see Exhibit 33.5)

33.64      U.S. Bank National Association, as ServicingFunction Participant of the Overland Park Xchange Mortgage Loan

33.65      KeyBank National Association, as Primary Servicerof the Concord Plaza Mortgage Loan (see Exhibit 33.1)

33.66      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Concord Plaza Mortgage Loan(see Exhibit 33.60)

33.67      Wilmington Trust, National Association, as Trustee of the Concord PlazaMortgage Loan (Omitted. See Explanatory Notes.)

33.68      Citibank, N.A., as Custodian of the Concord PlazaMortgage Loan (see Exhibit 33.62)

33.69      Park Bridge Lender Services LLC, as Operating Advisorof the Concord Plaza Mortgage Loan (see Exhibit 33.5)

33.70      U.S. Bank National Association, as ServicingFunction Participant of the Concord Plaza Mortgage Loan (see Exhibit 33.64)

33.71      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Shelbourne Global Portfolio IMortgage Loan (see Exhibit 33.60)

33.72      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Shelbourne Global Portfolio IMortgage Loan (see Exhibit 33.60)

33.73      Wells Fargo Bank, National Association, as Trustee of the Shelbourne GlobalPortfolio I Mortgage Loan (Omitted. See Explanatory Notes.)

33.74      Wells Fargo Bank, National Association, asCustodian of the Shelbourne Global Portfolio I Mortgage Loan (see Exhibit 33.4)

33.75      Pentalpha Surveillance LLC, as Operating Advisor of the Shelbourne GlobalPortfolio I Mortgage Loan (Omitted. See Explanatory Notes.)

33.76      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.77      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit33.32)

33.78      Rialto Capital Advisors, LLC, as Special Servicerof the Moffett Towers - Buildings E, F, G Mortgage Loan

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

33.80      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit33.4)

33.81      Park Bridge Lender Services LLC, as OperatingAdvisor of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit33.5)

33.82      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Moffett Towers - Buildings E, F, G Mortgage Loan (seeExhibit 33.37)

33.83      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.84      Wells Fargo Bank, National Association, as PrimaryServicer of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 33.32)

33.85      Rialto Capital Advisors, LLC, as Special Servicerof the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 33.78)

33.86      Wilmington Trust, National Association, as Trustee of the Outlet Shoppes at ElPaso Mortgage Loan (Omitted. See Explanatory Notes.)

33.87      Wells Fargo Bank, National Association, asCustodian of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 33.4)

33.88      Park Bridge Lender Services LLC, as OperatingAdvisor of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 33.5)

33.89      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 33.37)

33.90      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 33.7)

33.91      Wells Fargo Bank, National Association, as PrimaryServicer of the Phoenix Marriott Tempe at the Buttes Mortgage Loan (see Exhibit33.32)

33.92      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Phoenix Marriott Tempe at theButtes Mortgage Loan (see Exhibit 33.60)

33.93      Wilmington Trust, National Association, as Trustee of the Phoenix MarriottTempe at the Buttes Mortgage Loan (Omitted. See Explanatory Notes.)

33.94      Citibank, N.A., as Custodian of the PhoenixMarriott Tempe at the Buttes Mortgage Loan (see Exhibit 33.62)

33.95      Park Bridge Lender Services LLC, as OperatingAdvisor of the Phoenix Marriott Tempe at the Buttes Mortgage Loan (see Exhibit33.5)

33.96      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Phoenix Marriott Tempe at the Buttes Mortgage Loan (seeExhibit 33.37)

33.97      U.S. Bank National Association, as ServicingFunction Participant of the Phoenix Marriott Tempe at the Buttes Mortgage Loan(see Exhibit 33.64)

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

34.1        KeyBank National Association, as Master Servicer

34.2        LNR Partners, LLC, as Special Servicer

34.3        Wells Fargo Bank, National Association, as Trusteeand Certificate Administrator

34.4        Wells Fargo Bank, National Association, asCustodian

34.5        Park Bridge Lender Services LLC, as Operating Advisor

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

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

34.8        KeyBank National Association, as Primary Servicerof the DUMBO Heights Portfolio Mortgage Loan (see Exhibit 34.1)

34.9        LNR Partners, LLC, as Special Servicer of the DUMBOHeights Portfolio Mortgage Loan (see Exhibit 34.2)

34.10      Wells Fargo Bank, National Association, as Trustee of the DUMBO HeightsPortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.11      Wells Fargo Bank, National Association, asCustodian of the DUMBO Heights Portfolio Mortgage Loan (see Exhibit 34.4)

34.12      Park Bridge Lender Services LLC, as OperatingAdvisor of the DUMBO Heights Portfolio Mortgage Loan (see Exhibit 34.5)

34.13      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.14      KeyBank National Association, as Primary Servicerof the Liberty Portfolio Mortgage Loan (see Exhibit 34.1)

34.15      LNR Partners, LLC, as Special Servicer of theLiberty Portfolio Mortgage Loan (see Exhibit 34.2)

34.16      Wells Fargo Bank, National Association, as Trustee of the Liberty PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.17      Wells Fargo Bank, National Association, asCustodian of the Liberty Portfolio Mortgage Loan (see Exhibit 34.4)

34.18      Park Bridge Lender Services LLC, as Operating Advisorof the Liberty Portfolio Mortgage Loan (see Exhibit 34.5)

34.19      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.20      KeyBank National Association, as Primary Servicerof the Shops at Solaris Mortgage Loan (see Exhibit 34.1)

34.21      LNR Partners, LLC, as Special Servicer of the Shopsat Solaris Mortgage Loan (see Exhibit 34.2)

34.22      Wells Fargo Bank, National Association, as Trustee of the Shops at SolarisMortgage Loan (Omitted. See Explanatory Notes.)

34.23      Wells Fargo Bank, National Association, asCustodian of the Shops at Solaris Mortgage Loan (see Exhibit 34.4)

34.24      Park Bridge Lender Services LLC, as OperatingAdvisor of the Shops at Solaris Mortgage Loan (see Exhibit 34.5)

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.26      KeyBank National Association, as Primary Servicerof the 192 Lexington Avenue Mortgage Loan (see Exhibit 34.1)

34.27      LNR Partners, LLC, as Special Servicer of the 192Lexington Avenue Mortgage Loan (see Exhibit 34.2)

34.28      Wells Fargo Bank, National Association, as Trustee of the 192 Lexington AvenueMortgage Loan (Omitted. See Explanatory Notes.)

34.29      Wells Fargo Bank, National Association, as Custodianof the 192 Lexington Avenue Mortgage Loan (see Exhibit 34.4)

34.30      Park Bridge Lender Services LLC, as OperatingAdvisor of the 192 Lexington Avenue Mortgage Loan (see Exhibit 34.5)

34.31      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.32      Wells Fargo Bank, National Association, as PrimaryServicer of the Aventura Mall Mortgage Loan

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

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

34.35      Wells Fargo Bank, National Association, asCustodian of the Aventura Mall Mortgage Loan (see Exhibit 34.4)

34.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aventura Mall Mortgage Loan (see Exhibit 34.5)

34.37      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Aventura Mall Mortgage Loan

34.38      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.39      KeyBank National Association, as Primary Servicerof the Aon Center Mortgage Loan (see Exhibit 34.1)

34.40      AEGON USA Realty Advisors, LLC, as Special Servicer of the Aon Center MortgageLoan prior to March 29, 2021 (Omitted. See Explanatory Notes.)

34.41      Situs Holdings, LLC, as Special Servicer of the Aon Center Mortgage Loan on andafter March 29, 2021 (Omitted. See Explanatory Notes.)

34.42      Wells Fargo Bank, National Association, as Trustee of the Aon Center MortgageLoan (Omitted. See Explanatory Notes.)

34.43      Wells Fargo Bank, National Association, asCustodian of the Aon Center Mortgage Loan (see Exhibit 34.4)

34.44      Park Bridge Lender Services LLC, as Operating Advisorof the Aon Center Mortgage Loan (see Exhibit 34.5)

34.45      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.46      Wells Fargo Bank, National Association, as PrimaryServicer of the 636 11th Avenue Mortgage Loan (see Exhibit 34.32)

34.47      CWCapital Asset Management LLC, as Special Servicerof the 636 11th Avenue Mortgage Loan (see Exhibit 34.33)

34.48      Wilmington Trust, National Association, as Trustee of the 636 11th AvenueMortgage Loan (Omitted. See Explanatory Notes.)

34.49      Wells Fargo Bank, National Association, asCustodian of the 636 11th Avenue Mortgage Loan (see Exhibit 34.4)

34.50      Park Bridge Lender Services LLC, as OperatingAdvisor of the 636 11th Avenue Mortgage Loan (see Exhibit 34.5)

34.51      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 636 11th Avenue Mortgage Loan (see Exhibit 34.37)

34.52      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.53      KeyBank National Association, as Primary Servicerof the Workspace Mortgage Loan (see Exhibit 34.1)

34.54      KeyBank National Association, as Special Servicerof the Workspace Mortgage Loan (see Exhibit 34.1)

34.55      Wells Fargo Bank, National Association, as Trustee of the Workspace MortgageLoan (Omitted. See Explanatory Notes.)

34.56      Wells Fargo Bank, National Association, asCustodian of the Workspace Mortgage Loan (see Exhibit 34.4)

34.57      Park Bridge Lender Services LLC, as OperatingAdvisor of the Workspace Mortgage Loan (see Exhibit 34.5)

34.58      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.59      KeyBank National Association, as Primary Servicerof the Overland Park Xchange Mortgage Loan (see Exhibit 34.1)

34.60      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Overland Park Xchange MortgageLoan

34.61      Wilmington Trust, National Association, as Trustee of the Overland Park XchangeMortgage Loan (Omitted. See Explanatory Notes.)

34.62      Citibank, N.A., as Custodian of the Overland ParkXchange Mortgage Loan

34.63      Park Bridge Lender Services LLC, as OperatingAdvisor of the Overland Park Xchange Mortgage Loan (see Exhibit 34.5)

34.64      U.S. Bank National Association, as ServicingFunction Participant of the Overland Park Xchange Mortgage Loan

34.65      KeyBank National Association, as Primary Servicerof the Concord Plaza Mortgage Loan (see Exhibit 34.1)

34.66      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Concord Plaza Mortgage Loan(see Exhibit 34.60)

34.67      Wilmington Trust, National Association, as Trustee of the Concord PlazaMortgage Loan (Omitted. See Explanatory Notes.)

34.68      Citibank, N.A., as Custodian of the Concord PlazaMortgage Loan (see Exhibit 34.62)

34.69      Park Bridge Lender Services LLC, as OperatingAdvisor of the Concord Plaza Mortgage Loan (see Exhibit 34.5)

34.70      U.S. Bank National Association, as ServicingFunction Participant of the Concord Plaza Mortgage Loan (see Exhibit 34.64)

34.71      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Shelbourne Global Portfolio IMortgage Loan (see Exhibit 34.60)

34.72      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Shelbourne Global Portfolio IMortgage Loan (see Exhibit 34.60)

34.73      Wells Fargo Bank, National Association, as Trustee of the Shelbourne GlobalPortfolio I Mortgage Loan (Omitted. See Explanatory Notes.)

34.74      Wells Fargo Bank, National Association, asCustodian of the Shelbourne Global Portfolio I Mortgage Loan (see Exhibit 34.4)

34.75      Pentalpha Surveillance LLC, as Operating Advisor of the Shelbourne GlobalPortfolio I Mortgage Loan (Omitted. See Explanatory Notes.)

34.76      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.77      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit34.32)

34.78      Rialto Capital Advisors, LLC, as Special Servicerof the Moffett Towers - Buildings E, F, G Mortgage Loan

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

34.80      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit34.4)

34.81      Park Bridge Lender Services LLC, as OperatingAdvisor of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit34.5)

34.82      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Moffett Towers - Buildings E, F, G Mortgage Loan (seeExhibit 34.37)

34.83      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.84      Wells Fargo Bank, National Association, as PrimaryServicer of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 34.32)

34.85      Rialto Capital Advisors, LLC, as Special Servicerof the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 34.78)

34.86      Wilmington Trust, National Association, as Trustee of the Outlet Shoppes at ElPaso Mortgage Loan (Omitted. See Explanatory Notes.)

34.87      Wells Fargo Bank, National Association, asCustodian of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 34.4)

34.88      Park Bridge Lender Services LLC, as OperatingAdvisor of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 34.5)

34.89      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 34.37)

34.90      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian on and after November 1,2021 (see Exhibit 34.7)

34.91      Wells Fargo Bank, National Association, as PrimaryServicer of the Phoenix Marriott Tempe at the Buttes Mortgage Loan (see Exhibit34.32)

34.92      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Phoenix Marriott Tempe at theButtes Mortgage Loan (see Exhibit 34.60)

34.93      Wilmington Trust, National Association, as Trustee of the Phoenix Marriott Tempeat the Buttes Mortgage Loan (Omitted. See Explanatory Notes.)

34.94      Citibank, N.A., as Custodian of the PhoenixMarriott Tempe at the Buttes Mortgage Loan (see Exhibit 34.62)

34.95      Park Bridge Lender Services LLC, as OperatingAdvisor of the Phoenix Marriott Tempe at the Buttes Mortgage Loan (see Exhibit34.5)

34.96      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Phoenix Marriott Tempe at the Buttes Mortgage Loan (seeExhibit 34.37)

34.97      U.S. Bank National Association, as ServicingFunction Participant of the Phoenix Marriott Tempe at the Buttes Mortgage Loan(see Exhibit 34.64)

35           Servicer compliance statements.

35.1        KeyBank National Association, as Master Servicer

35.2        LNR Partners, LLC, 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        KeyBank National Association, as Primary Servicerof the DUMBO Heights Portfolio Mortgage Loan (see Exhibit 35.1)

35.6        LNR Partners, LLC, as Special Servicer of the DUMBOHeights Portfolio Mortgage Loan (see Exhibit 35.2)

35.7        KeyBank National Association, as Primary Servicerof the Liberty Portfolio Mortgage Loan (see Exhibit 35.1)

35.8        LNR Partners, LLC, as Special Servicer of theLiberty Portfolio Mortgage Loan (see Exhibit 35.2)

35.9        KeyBank National Association, as Primary Servicerof the Shops at Solaris Mortgage Loan (see Exhibit 35.1)

35.10      LNR Partners, LLC, as Special Servicer of the Shopsat Solaris Mortgage Loan (see Exhibit 35.2)

35.11      KeyBank National Association, as Primary Servicerof the 192 Lexington Avenue Mortgage Loan (see Exhibit 35.1)

35.12      LNR Partners, LLC, as Special Servicer of the 192Lexington Avenue Mortgage Loan (see Exhibit 35.2)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the Aventura Mall Mortgage Loan

35.14      CWCapital Asset Management LLC, as Special Servicer of the Aventura Mall MortgageLoan (Omitted. See Explanatory Notes.)

35.15      KeyBank National Association, as Primary Servicerof the Aon Center Mortgage Loan (see Exhibit 35.1)

35.16      AEGON USA Realty Advisors, LLC, as Special Servicer of the Aon Center MortgageLoan prior to March 29, 2021 (Omitted. See Explanatory Notes.)

35.17      Situs Holdings, LLC, as Special Servicer of the Aon Center Mortgage Loan on andafter March 29, 2021 (Omitted. See Explanatory Notes.)

35.18      Wells Fargo Bank, National Association, as PrimaryServicer of the 636 11th Avenue Mortgage Loan (see Exhibit 35.13)

35.19      CWCapital Asset Management LLC, as Special Servicer of the 636 11th AvenueMortgage Loan (Omitted. See Explanatory Notes.)

35.20      KeyBank National Association, as Primary Servicerof the Workspace Mortgage Loan (see Exhibit 35.1)

35.21      KeyBank National Association, as Special Servicerof the Workspace Mortgage Loan (see Exhibit 35.1)

35.22      KeyBank National Association, as Primary Servicerof the Overland Park Xchange Mortgage Loan (see Exhibit 35.1)

35.23      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Overland Park Xchange Mortgage Loan (Omitted. See ExplanatoryNotes.)

35.24      KeyBank National Association, as Primary Servicerof the Concord Plaza Mortgage Loan (see Exhibit 35.1)

35.25      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Concord Plaza Mortgage Loan (Omitted. See Explanatory Notes.)

35.26      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Shelbourne Global Portfolio I Mortgage Loan (Omitted. SeeExplanatory Notes.)

35.27      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Shelbourne Global Portfolio I Mortgage Loan (Omitted. SeeExplanatory Notes.)

35.28      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit 35.13)

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

35.30      Wells Fargo Bank, National Association, as PrimaryServicer of the Outlet Shoppes at El Paso Mortgage Loan (see Exhibit 35.13)

35.31      Rialto Capital Advisors, LLC, as Special Servicer of the Outlet Shoppes at ElPaso Mortgage Loan (Omitted. See Explanatory Notes.)

35.32      Wells Fargo Bank, National Association, as PrimaryServicer of the Phoenix Marriott Tempe at the Buttes Mortgage Loan (see Exhibit35.13)

35.33      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Phoenix Marriott Tempe at the Buttes Mortgage Loan (Omitted.See Explanatory Notes.)

99.1         Mortgage Loan Purchase Agreement, dated as of November 9,2018, between Deutsche Mortgage & Asset Receiving Corporation and GermanAmerican Capital Corporation (filed as Exhibit 99.1 to the registrant’s CurrentReport on Form 8-K filed on November 28, 2018 under Commission File No. 333-226943-01and incorporated by reference herein)

99.2         Mortgage Loan Purchase Agreement, dated as of November 9,2018, between Deutsche Mortgage & Asset Receiving Corporation and Citi RealEstate Funding Inc. (filed as Exhibit 99.2 to the registrant’s Current Reporton Form 8-K filed on November 28, 2018 under Commission File No. 333-226943-01and incorporated by reference herein)

99.3         Mortgage Loan Purchase Agreement, dated as of November 9,2018, between Deutsche Mortgage & Asset Receiving Corporation and JPMorganChase Bank, National Association (filed as Exhibit 99.3 to the registrant’sCurrent Report on Form 8-K filed on November 28, 2018 under Commission File No.333-226943-01 and incorporated by reference herein)

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Deutsche Mortgage & AssetReceiving Corporation(Depositor)

/s/ HelaineM. Kaplan

Helaine M.Kaplan, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 18, 2022

/s/ MattSmith

Matt Smith, Director

Date: March 18, 2022