**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, 2022or**

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

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

**Central Index Key Number of the issuing entity:0001756271**

**BANK 2018-BNK15**

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

** **

**Central Index Key Number of the depositor: 0001005007**

**Banc of America Merrill LynchCommercial Mortgage Inc.**

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

** **

**Central Index Key Number of the sponsor: 0001102113**

**Bank of America, NationalAssociation**

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

** **

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

**Morgan Stanley Mortgage CapitalHoldings LLC**

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

** **

**Central Index Key Number of the sponsor: 0000740906**

**Wells Fargo Bank, NationalAssociation**

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

** **

**Central Index Key Number of the sponsor: 0001577313**

**National Cooperative Bank, N.A.**

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

** **

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

**the issuing entity)** | **38-4096495**

**38-4096496**

**38-7206265**

**(I.R.S. Employer**

**Identification Numbers)** |
|------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|

**c/o Computershare Trust Company, National Association, as agent for**

**Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

**(Address of principalexecutive offices of the issuing entity)**

**21045**

**(Zip Code)**

**Registrant’s telephone number,including area code:**

**(646) 855-3953**

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

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

 

 

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

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

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

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

Indicate by check mark whether the registrant has submittedelectronically every Interactive Data File required to be submitted pursuant toRule 405 of Regulation S-T (Section 232.405 of this chapter) during thepreceding 12 months (or for such shorter period that the registrant wasrequired to submit such files).

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Accelerated filer                                     o

Non-acceleratedfiler          ⌧  (Do not check if asmaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growth company                    o

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

Indicate by check mark whether the registrant 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

If securities are registered pursuant to Section 12(b) of theAct, indicate by check mark whether the financial statements of the registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements. o

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). o

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The 685 Fifth Avenue Retail Mortgage Loan,which constituted approximately 5.5% of the asset pool of the issuing entity asof its cut-off date, is an asset of the issuing entity and is part of a loancombination that includes the 685 Fifth Avenue Retail Mortgage Loan and oneother *pari passu* loan, which is not an asset of the issuing entity. Thisloan combination, including the 685 Fifth Avenue Retail Mortgage Loan, is beingserviced and administered pursuant to the Pooling and Servicing Agreement,which is incorporated by reference as Exhibit 4.1 to this Annual Report on Form10-K. 

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Aventura Mall Mortgage Loan, whichconstituted approximately 9.2% 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-four 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 Pfizer Building Mortgage Loan, whichconstituted approximately 2.7% of the asset pool of the issuing entity as ofits cut-off date.  The Pfizer Building Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the PfizerBuilding Mortgage Loan and four other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the BANK 2018-BNK13 transaction, Commission FileNumber 333-206677-26 (the “BANK 2018-BNK13 Transaction”). This loancombination, including the Pfizer Building Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the BANK2018-BNK13 Transaction, which is incorporated by reference as Exhibit 4.3 tothis Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Millennium Partners Portfolio Mortgage Loan,which constituted approximately 6.9% of the asset pool of the issuing entity asof its cut-off date.  The Millennium Partners Portfolio Mortgage Loan isan asset of the issuing entity and is part of a loan combination that includesthe Millennium Partners Portfolio Mortgage Loan, six other *pari passu*loans and six subordinate companion loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe Morgan Stanley Capital I Trust 2018-MP transaction (the “MSC 2018-MPTransaction”). This loan combination, including the Millennium PartnersPortfolio Mortgage Loan, is being serviced and administered pursuant to thetrust and servicing agreement for the MSC 2018-MP Transaction, which is incorporatedby reference as Exhibit 4.4 to this Annual Report on Form 10-K.

The Prudential - Digital RealtyPortfolio Mortgage Loan, previously an asset of the issuing entity, was not anasset of the issuing entity during the reporting period and is omitted fromthis Annual Report on Form 10-K and will be omitted from subsequent AnnualReports on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Plaza Frontenac Mortgage Loan, which constitutedapproximately 1.8% of the asset pool of the issuing entity as of its cut-offdate.  The Plaza Frontenac Mortgage Loan is an asset of the issuing entityand is part of a loan combination that includes the Plaza Frontenac MortgageLoan and two other *pari passu* loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe Morgan Stanley Capital I Trust 2018-L1 transaction, Commission File Number333-206582-17 (the “MSC 2018-L1 Transaction”). This loan combination,including the Plaza Frontenac Mortgage Loan, is being serviced and administeredpursuant to the pooling and servicing agreement for the MSC 2018-L1Transaction, which is incorporated by reference as Exhibit 4.5 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Starwood Hotel Portfolio Mortgage Loan,which constituted approximately 9.2% of the asset pool of the issuing entity asof its cut-off date.  The Starwood Hotel Portfolio Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theStarwood Hotel Portfolio Mortgage Loan and three other *pari passu* loans,which are not assets of the issuing entity. A *pari passu* portion of theloan combination was securitized in the Wells Fargo Commercial Mortgage Trust2018-C47 transaction, Commission File Number 333-226486-01 (the “WFCM2018-C47 Transaction”). This loan combination, including the Starwood HotelPortfolio Mortgage Loan, is being serviced and administered pursuant to thepooling and servicing agreement for the WFCM 2018-C47 Transaction, which isincorporated by reference as Exhibit 4.6 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 Moffett Towers - Buildings E, F, G MortgageLoan, which constituted approximately 5.2% of the asset pool of the issuingentity as of its cut-off date.  The Moffett Towers - Buildings E, F, GMortgage Loan is an asset of the issuing entity and is part of a loancombination that includes the Moffett Towers - Buildings E, F, G Mortgage Loanand eight other *pari passu* loans, which are not assets of the issuingentity. A *pari passu* portion of the loan combination was securitized inthe DBGS 2018-C1 Mortgage Trust transaction, Commission File Number 333-206705-16(the “DBGS 2018-C1 Transaction”). This loan combination, including theMoffett Towers - Buildings E, F, G Mortgage Loan, is being serviced andadministered pursuant to the pooling and servicing agreement for the DBGS2018-C1 Transaction, which is incorporated by reference as Exhibit 4.7 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 2020 Fifth Avenue Mortgage Loan, whichconstituted approximately 2.2% of the asset pool of the issuing entity as ofits cut-off date.  The 2020 Fifth Avenue Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the 2020 FifthAvenue Mortgage Loan and one other *pari passu* loan, which is not anasset of the issuing entity. The other *pari passu* portion of the loancombination was securitized in the CSAIL 2018-C14 Commercial Mortgage Trusttransaction, Commission File Number 333-207361-10 (the “CSAIL 2018-C14Transaction”). This loan combination, including the 2020 Fifth AvenueMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the CSAIL 2018-C14 Transaction, which is incorporatedby reference as Exhibit 4.8 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 Carriage Place Mortgage Loan, whichconstituted approximately 0.9% of the asset pool of the issuing entity as ofits cut-off date.  The Carriage Place Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the CarriagePlace Mortgage Loan and one other *pari passu* loan, which is not an assetof the issuing entity. This loan combination, including the Carriage PlaceMortgage Loan, was serviced under the Pooling and Servicing Agreement for theissuing entity prior to the closing of the securitization of the other *paripassu* portion of the Carriage Place loan combination in the BANK 2019-BNK16transaction, Commission File Number 333-226486-03 (the “BANK 2019-BNK16Transaction”).  After the closing of the BANK 2019-BNK16 Transactionon February 21, 2019, this loan combination, including the Carriage Place MortgageLoan was, and will continue to be, serviced and administered pursuant to thepooling and servicing agreement with respect to the BANK 2019-BNK16Transaction, which is incorporated by reference as Exhibit 4.9 to this AnnualReport on Form 10-K.

The master servicer of a poolingand servicing agreement or trust and servicing agreement also functions as theprimary servicer of the related mortgage loans serviced and administeredpursuant to such agreement unless a separate primary servicer is identified herein. If this report does not identify a separate primary servicer, the servicercompliance statement provided by the master servicer under any such agreementalso encompasses its responsibilities as primary servicer of the relatedmortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the general master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement, the primaryservicer of the Starwood Hotel Portfolio Mortgage Loan, the Aventura MallMortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan, the PfizerBuilding Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the CarriagePlace Mortgage Loan and the primary servicer and special servicer of theMillennium Partners Portfolio Mortgage Loan. As a result, Wells Fargo Bank,National Association is a “servicer” as defined in Item 1108(a)(2)(iii) ofRegulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the Starwood Hotel Portfolio Mortgage Loan, theAventura Mall Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan,the Moffett Towers - Buildings E, F, G Mortgage Loan, the Pfizer BuildingMortgage Loan, the 2020 Fifth Avenue Mortgage Loan, the Plaza FrontenacMortgage Loan and the Carriage Place Mortgage Loan.  As a result, WellsFargo Bank, 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 isthe operating advisor of the mortgage loans serviced under the Pooling andServicing Agreement, the Starwood Hotel Portfolio Mortgage Loan, the AventuraMall Mortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan andthe Carriage Place 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.

Pentalpha Surveillance LLC is theoperating advisor of the Pfizer Building Mortgage Loan, the 2020 Fifth AvenueMortgage Loan and the Plaza Frontenac Mortgage Loan.  As a result,Pentalpha Surveillance LLC 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 Pentalpha Surveillance LLC in thecapacities described above are listed in the Exhibit Index.

Rialto Capital Advisors, LLC isthe special servicer of the Moffett Towers - Buildings E, F, G Mortgage Loanand the 2020 Fifth Avenue Mortgage Loan.  These mortgage loans constitutemore 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.

Midland Loan Services, a Divisionof PNC Bank, National Association is the primary servicer and special servicerof the Plaza Frontenac Mortgage Loan and the special servicer of the StarwoodHotel Portfolio Mortgage Loan. As a result, Midland Loan Services, a Divisionof PNC 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 Midland Loan Services, a Division of PNCBank, National Association in the capacities described above are listed in theExhibit Index.

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

Wells Fargo Bank, NationalAssociation acts as trustee of the Plaza Frontenac Mortgage Loan. Pursuant to the pooling and servicing agreement for the MSC 2018-L1Transaction, the trustee is required to provide an assessment of compliancewith applicable servicing criteria solely with respect to Item 1122(d)(2)(iii)of Regulation AB (regarding advances of funds or guarantees regardingcollections, cash flows or distributions, and any interest or other feescharged for such advances, are made, reviewed and approved as specified in thetransaction agreements). However, during the reporting period, the trustee didnot perform any servicing function with respect to the servicing criteriaspecified in Item 1122(d)(2)(iii) of Regulation AB.  The master servicer orthe special servicer, to the extent required, performed the servicing functionidentified with respect to Item 1122(d)(2)(iii) of Regulation AB, and each suchparty included Item 1122(d)(2)(iii) of Regulation AB in the assessment ofcompliance 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 PlazaFrontenac Mortgage Loan have delivered one or more assessments of compliancewith respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement, the Aventura Mall Mortgage Loan, the PfizerBuilding Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan, theStarwood Hotel Portfolio Mortgage Loan, the Moffett Towers - Buildings E, F, GMortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage PlaceMortgage Loan.  Pursuant to the Pooling and Servicing Agreement, the trustand servicing agreement for the Aventura Mall Trust 2018-AVM Transaction, thepooling and servicing agreement for the BANK 2018-BNK13 Transaction, the trustand servicing agreement for the MSC 2018-MP Transaction, the pooling andservicing agreement for the WFCM 2018-C47 Transaction, the pooling andservicing agreement for the DBGS 2018-C1 Transaction, the pooling and servicingagreement for the CSAIL 2018-C14 Transaction and the pooling and servicingagreement for the BANK 2019-BNK16 Transaction, the trustee is required toprovide an assessment of compliance with applicable servicing criteria solelywith respect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances offunds or guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable servicing criteria and accountant’s attestation report for the subjecttransaction.  As a result, this Annual Report on Form 10-K does notinclude an assessment of compliance with applicable servicing criteria of thetrustee. One or more other servicers of  the mortgage loans serviced underthe Pooling and Servicing Agreement, the Aventura Mall Mortgage Loan, thePfizer Building Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan,the Starwood Hotel Portfolio Mortgage Loan, the Moffett Towers - Buildings E,F, G Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage PlaceMortgage Loan have delivered one or more assessments of compliance with respectto Item 1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-Kincludes assessments of compliance with applicable servicing criteria and accountants’attestation reports from CoreLogic Solutions, LLC.  This entity wasengaged by the general master servicer under the Pooling and ServicingAgreement and the primary servicer of the Aventura Mall Mortgage Loan, thePfizer Building Mortgage Loan, the Millennium Partners Portfolio Mortgage Loan,the Starwood Hotel Portfolio Mortgage Loan, the Moffett Towers - Buildings E,F, G Mortgage Loan, the 2020 Fifth Avenue Mortgage Loan and the Carriage PlaceMortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in Items 1122(d)(4)(xi)and 1122(d)(4)(xii) of Regulation AB.  Therefore, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this vendoris a “servicer” for the purposes of Item 1122 of Regulation AB.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This AnnualReport on Form 10-K includes an assessment of compliance with applicableservicing criteria, accountants’ attestation report and servicer compliancestatement from Computershare Trust Company, National Association (“CTCNA”). CTCNA was 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.  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 Pfizer Building Mortgage Loan, the Millennium PartnersPortfolio Mortgage Loan, the Plaza Frontenac Mortgage Loan, the Starwood HotelPortfolio Mortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan,the 2020 Fifth Avenue Mortgage Loan and the Carriage Place 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 passu*loan combinations that include the Aventura Mall Mortgage Loan, the PfizerBuilding Mortgage Loan, the Moffett Towers - Buildings E, F, G Mortgage Loan,the 2020 Fifth Avenue Mortgage Loan and the Carriage Place Mortgage Loan, (i)the reports on assessment of compliance with servicing criteria and attestationreports on assessment of compliance with servicing criteria of Torchlight LoanServices, LLC as special servicer of the Pfizer Building Mortgage Loan prior to August 11, 2022, Mount Street US (Georgia) LLP asspecial servicer of the Pfizer Building Mortgage Loan on and after August 11,2022 and KeyBank National Association as special servicer of the CarriagePlace Mortgage Loan, listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K as they are not required to be included on this AnnualReport on Form 10-K per Instruction 3 to Item 1122 of Regulation AB becausethey are parties performing activities that address servicing criteria relatingto 5% or less of the assets of the issuing entity; and (ii) the servicer compliancestatements of CWCapital Asset Management LLC as special servicer of theAventura Mall Mortgage Loan, Torchlight Loan Services, LLC as special servicerof the Pfizer Building Mortgage Loan prior to August 11, 2022, Mount Street US(Georgia) LLP as special servicer of the Pfizer Building Mortgage Loan on andafter August 11, 2022, Rialto Capital Advisors, LLC as special servicer of theMoffett Towers - Buildings E, F, G Mortgage Loan and the 2020 Fifth AvenueMortgage Loan and KeyBank National Association as special servicer of theCarriage Place Mortgage Loan, listed on the Exhibit Index are omitted from thisAnnual Report on Form 10-K as they are not required by Item 1123 of RegulationAB to be included on this Annual Report on Form 10-K because they are each anunaffiliated party that is not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6. **

[Reserved]

**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.

**Item 9C.  Disclosure Regarding Foreign Jurisdictionsthat Prevent Inspections.**

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 Accountant Fees and Services.**

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

**Item 1112(b) of Regulation AB, Significant Obligor FinancialInformation.**

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 CWCapital AssetManagement LLC, as special servicer, and Wells Fargo Bank, NationalAssociation, as certificate administrator, as trustee and as custodian.

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

On December 17, 2015, U.S. Bank National Association, thetrustee under five pooling and servicing agreements for (i) Wachovia BankCommercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC CommercialMortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenceda proceeding with the Second Judicial District Court of Ramsey County,Minnesota (the “State Court”) for a declaratory judgment as to the properallocation of certain proceeds (“Disputed Proceeds”) received by CWCAM inconnection with the sale of the Peter Cooper Village and Stuyvesant Townproperty in New York, New York securing loans held by those trusts.  CWCAMwas the special servicer of such property.  The petition requests theState 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”).  On October 21,2016, the Federal Court held a hearing on the motion to transfer the action tothe United States District Court for the Southern District of New York (“SDNYCourt”), a motion to remand to state court and a motion to hear CWCAM’s requestfor reconsideration of the motion to dismiss.  On March 14, 2017, theFederal Court reserved the determination on the motion to hear CWCAM’s requestfor reconsideration of the motion to dismiss, denied the motion to remand thematter to state court and granted the motion to transfer the proceeding to theSDNY Court.  Cross motions for judgment on the pleadings were filed butthe SDNY Court was unable to decide the case based on the pleadings and theSDNY Court ordered discovery.  All fact discovery was completed inDecember, 2018 and expert discovery was completed on March 15, 2019.  Theparties submitted cross motions for summary judgment, and on March 19, 2020,the SDNY Court entered an opinion and order in which it granted summaryjudgment in CWCAM’s favor and held that CWCAM was entitled to the entire amountof penalty interest and that CWCAM’s determination of Yield Maintenance wascorrect.  In the 127-page opinion, the SDNY Court found for CWCAM on everyissue presented by the trustee’s petition, namely, that the funds in disputeconstitute penalty interest and yield maintenance, not gain-on-sale proceeds,and that the amount of penalty interest and yield maintenance was correctlycalculated. An appeal of the SDNY Court’s decision was taken on April 29,2020.  Oral argument on the appeal occurred on June 21, 2021.  OnJuly 14, 2022, the Second Circuit entered a decision affirming in part andreversing in part the SDNY Court’s decision and remanding to the SDNY Court forfurther proceedings.  The Second Circuit affirmed the SDNY’s Court holdingthat Penalty Interest and Yield Maintenance are paid before Gain-On-SaleProceeds.  The Second Circuit reversed and remanded for furtherproceedings that portion of the SDNY Court’s decision related to approximately$67.2 million in interest on advances.   On January 13, 2023, theparties entered into a settlement agreement, in which (among other things) theyagreed to stipulate that the amount of interest on advances that accrued on orbefore June 3, 2014 is $27.5 million, and that CWCAM would pay that amount intoescrow for distribution to certificateholders upon the entry of an order by theCourt approving the settlement.  U.S. Bank National Association, asTrustee for the trusts, provided notice of the settlement to all parties ininterest via a notice program approved by the Court.  A hearing on thesettlement is scheduled for March 16, 2023.

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of the Original Complaint alleged breaches of a contract and fiduciary duties by CWCAM’saffiliate, CWCapital Investments LLC in its capacity as collateral manager forthe collateralized debt obligation transaction involving CWCapital Cobalt Vr,Ltd. In total, there are 14 counts pled in the Original Complaint. Of those 14,5 claims were asserted against CWCAM for aiding and abetting breach offiduciary duty, conversion and unjust enrichment. On May 23, 2018, the OriginalComplaint was dismissed for lack of subject matter jurisdiction.   OnJune 28, 2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaintin the Supreme Court of the State of New York, County of New York styled asCWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No.653277/2018 (the “New Complaint”).  The gravamen of the New Complaint isthe same as the previous complaint filed in the United State District Court forthe Southern District of New York.  In total there are 16 counts pled inthe New Complaint. Of those 16 counts, 5 claims were asserted against CWCAM foraiding and abetting breach of fiduciary duty, conversion and unjust enrichment,1 count seeks a declaratory judgement that the plaintiff has the right toenforce the contracts in question and 1 count seeks an injunction requiring thedefendants to recognize the plaintiff as the directing holder for the trusts inquestion. On January 11, 2019, the plaintiff dismissed with prejudice thedeclaratory judgment and injunction counts.  The New Complaint and relatedsummons was not served on the defendants until July 13, 2018 and July 16,2018.  The plaintiff’s motion for a preliminary injunction was denied bythe court on July 31, 2018.  On August 3, 2018, the defendants, includingCWCAM, filed a motion to dismiss the New Complaint in its entirety. On August20, 2019, the court entered an order granting defendants’ motion almost in itsentirety, dismissing 11 of the 16 counts and partially dismissing 2 additionalcounts.  Of the remaining counts, 2 are asserted against CWCAM for aidingand abetting breach of fiduciary duty and unjust enrichment.  On September19, 2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relating to theAugust 20, 2019 dismissal order and on September 26, 2019, filed an amendedcomplaint against CWCI and CWCAM attempting to address deficiencies relating tocertain of the claims dismissed by the August 20, 2019 order.  CWCI andCWCAM filed its Motion to Dismiss the amended complaint on October 28,2019.  The court heard argument on the Motion to Dismiss the amendedcomplaint on January 22, 2020 and on October 23, 2020, the court granted themotion dismissing the amended claims.  On November 30, 2020, CWCapitalCobalt Vr Ltd filed a notice of appeal relating to the October 23, 2020dismissal order.  On April 27, 2021, the First Department affirmed thedismissal as to claims against CWCAM that were part of the August 20, 2019dismissal, but reversed the dismissal of two counts for breach of theCollateral Management Agreement against CWCI.  CWCI sought leave to filean appeal of the decision. The plaintiff also sought leave to appeal thedismissal of the claims against CWCAM.  Both requests for leave weredenied by the First Department.  On May 15, 2020, CWCI and CWCAM filed amotion to renew its motion to dismiss as to 4 of the remaining counts (includingthe remaining two counts against CWCAM for aiding and abetting breach offiduciary duty and unjust enrichment), based on a decision entered by JudgeFailla in a trust instruction proceeding  in the US District Court for theSouthern District of New York awarding summary judgment in favor ofCWCAM.  On September 7, 2021, the court denied the motion to renew. CWCI and CWCAM filed a notice of appeal, which they perfected by the filing oftheir opening brief on July 1, 2022.  On November 15, 2022, the FirstDepartment affirmed the court’s denial of the motion to renew.  On October1, 2021, CWCI and CWCAM moved to reargue the denial of the motion to renew (oralternatively, the motion to dismiss) with respect to certain of Cobalt’sclaims, including the remaining 2 claims against CWCAM, based on the FirstDepartment’s April 27, 2021 decision.  On March 24, 2022, the court deniedthe relief sought in the motion to reargue.  CWCI and CWCAM have appealedthe court’s decision on the motion to reargue and filed their opening brief onJuly 11, 2022.  The appeal was dismissed as being non-appealable on August30, 2022.  CWCAM believes that it has performed its obligations under therelated pooling and servicing agreements in good faith and the remainingallegations in the New Complaint are without merit.   

In December 2014, Phoenix Light SF Limited (Phoenix Light)and certain related entities filed a complaint in the United States DistrictCourt for the Southern District of New York alleging claims against Wells FargoBank, N.A., in its capacity as trustee for a number of residentialmortgage-backed securities (RMBS) trusts. Complaints raising similarallegations have been filed by Commerzbank AG in the Southern District of NewYork and by IKB International and IKB Deutsche Industriebank in New York statecourt. In each case, the plaintiffs allege that Wells Fargo Bank, N.A., astrustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify and enforcerepurchase obligations of mortgage loan sellers for purported breaches ofrepresentations and warranties, notify investors of alleged events of default,and abide by appropriate standards of care following alleged events of default.In July 2022, the district court dismissed Phoenix Light’s claims and certainof the claims asserted by Commerzbank AG, and subsequently entered judgment ineach case in favor of Wells Fargo Bank, N.A. In August 2022, Phoenix Light andCommerzbank AG appealed the district court’s decision to the United StatesCourt of Appeals for the Second Circuit. The Company previously settled twoclass actions filed by institutional investors and an action filed by theNational Credit Union Administration with similar allegations. In addition,Park Royal I LLC and Park Royal II LLC have filed substantially similarlawsuits in New York state court alleging Wells Fargo Bank, N.A., as trustee,failed to take appropriate actions upon learning of defective mortgage loandocumentation. 

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on November 29, 2018 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Aventura Mall Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the Aventura Mall Trust 2018-AVM Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the Aventura Mall Trust 2018-AVM Transactionincorporated by reference as Exhibit 4.2 to this Annual Report on Form 10-K is achart 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 servicing criteriafor asset-backed securities and related attestation reports on such assessmentsof compliance with respect to the Pfizer Building Mortgage Loan, which is beingserviced and administered pursuant to the pooling and servicing agreement forthe BANK 2018-BNK13 Transaction, are attached hereto under Item 15 to thisAnnual Report on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the BANK 2018-BNK13 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 BANK 2018-BNK13Transaction 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 Millennium Partners PortfolioMortgage Loan, which is being serviced and administered pursuant to the trustand servicing agreement for the MSC 2018-MP Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the MSC 2018-MP Transaction incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSC2018-MP Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Plaza Frontenac Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the MSC 2018-L1 Transaction, are attached hereto under Item 15 tothis Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the MSC 2018-L1 Transaction incorporated by referenceas Exhibit 4.5 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the MSC 2018-L1 Transactionresponsible for each applicable servicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Starwood Hotel Portfolio MortgageLoan, which is being serviced and administered pursuant to the pooling andservicing agreement for the WFCM 2018-C47 Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AA to thepooling and servicing agreement for the WFCM 2018-C47 Transaction incorporatedby reference as Exhibit 4.6 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the WFCM2018-C47 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Moffett Towers - Buildings E, F,G Mortgage Loan, which is being serviced and administered pursuant to thepooling and servicing agreement for the DBGS 2018-C1 Transaction, are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as ScheduleII to the pooling and servicing agreement for the DBGS 2018-C1 Transactionincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theDBGS 2018-C1 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the 2020 Fifth Avenue Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the CSAIL 2018-C14 Transaction, are attached hereto under Item 15to this Annual Report on Form 10-K. Attached as Exhibit AA to the pooling andservicing agreement for the CSAIL 2018-C14 Transaction incorporated byreference as Exhibit 4.8 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the CSAIL2018-C14 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Carriage Place Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2019-BNK16 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the poolingand servicing agreement for the BANK 2019-BNK16 Transaction incorporated byreference as Exhibit 4.9 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BANK2019-BNK16 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The report on assessmentof compliance for the twelve months ended December 31, 2022, furnished pursuantto Item 1122 of Regulation AB by KeyBank National Association (“KeyBank”), asservicer, discloses that the following material instance of noncomplianceoccurred with respect to its platform:

The examination performed by Ernst & Young LLP identifiedan instance of material noncompliance with the servicing criteria set forth inItem 1122(d)(4)(ix) of Regulation AB applicable to KeyBank during the yearended December 31, 2022. During compliance testing, it was discovered, that notall FlexARM loan mortgagors were offered loan rates within 45-60 days beforethe rate change date, as required per the related pool asset documents. Per therelated note, if the holder fails to offer a loan rate within 45-60 days of anychange date a margin of 2.25% is to be used. Given the notification was notmade to the borrowers, a 3% margin was incorrectly applied. The noncompliancein Item 1122 (d)(4)(ix) is related to a servicing portfolio which is whollyowned by the investor and is not held in a publicly traded security.

The following remediation procedures have been initiated byKeyBank: (i) the impacted mortgage loans are currently in the process of beingidentified, (ii) investor contact has been initiated, (iii) corrective actionsare being considered and will be tracked and monitored by senior management,(iv) procedures will be reviewed and revised, if necessary, to include newtracking and action steps to prevent this situation from recurring in thefuture, and (v) training will be provided to the relevant staff members toprevent a recurrence.

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

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

**PART IV**

**Item 15. Exhibit and Financial Statement Schedules**

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

(1) Not applicable

(2) Not applicable

(3) See below

 

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

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

4.3          Pooling and Servicing Agreement, dated as of August 1,2018, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as General Master Servicer,Torchlight Loan Services, LLC, as General Special Servicer, NationalCooperative Bank, N.A., as NCB Master Servicer and as NCB Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Pentalpha SurveillanceLLC, as Operating Advisor and as Asset Representations Reviewer (filed asExhibit 4.6 to the registrant’s Current Report on Form 8-K filed on November29, 2018 under Commission File No. 333-206847-10 and incorporated by referenceherein).

4.4          Trust and Servicing Agreement, dated as of August 7,2018, by and among Morgan Stanley Capital I Inc., as Depositor, Wells FargoBank, National Association, as Servicer and Special Servicer, Wilmington Trust,National Association, as Trustee, and Wells Fargo Bank, National Association,as Certificate Administrator and Custodian, (filed as Exhibit 4.4 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.5          Pooling and Servicing Agreement, dated as of October 1,2018, by and among Morgan Stanley Capital I Inc., as Depositor, Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer andSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator and Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand Asset Representations Reviewer (filed as Exhibit 4.9 to the registrant’sCurrent Report on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

4.6          Pooling and Servicing Agreement, dated as of October 1,2018, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, MidlandLoan Services, a Division of PNC Bank, National Association, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and as Asset Representations Reviewer (filedas Exhibit 4.3 to the registrant’s Current Report on Form 8-K filed on November29, 2018 under Commission File No. 333-206847-10 and incorporated by referenceherein).

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

4.8          Pooling and Servicing Agreement, dated as of November 1,2018, by and among Credit Suisse Commercial Mortgage Securities Corp., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, NationalAssociation, as Trustee, and Pentalpha Surveillance LLC, as Operating Advisorand as Asset Representations Reviewer (filed as Exhibit 4.8 to the registrant’sCurrent Report on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

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

4.10         Co-Lender Agreement, dated as of June 7, 2018, by andamong JPMorgan Chase Bank, National Association, Deutsche Bank, AG, New YorkBranch, Wells Fargo Bank, National Association and Morgan Stanley Bank, N.A.(filed as Exhibit 4.10 to the registrant’s Current Report on Form 8-K filed onNovember 29, 2018 under Commission File No. 333-206847-10 and incorporated byreference herein).

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

4.12         Agreement Between Note Holders, dated as of August 9,2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Initial Note A-2 Holder, Initial Note A-3 Holder, Initial Note A-4 Holder,Initial Note A-5 Holder and Initial Note A-6 Holder, and Morgan Stanley Bank,N.A., as Initial Note B-1 Holder, Initial Note B-2 Holder, Initial Note B-3Holder, Initial Note B-4 Holder, Initial Note B-5 Holder and Initial Note B-6Holder (filed as Exhibit 4.12 to the registrant’s Current Report on Form 8-Kfiled on November 29, 2018 under Commission File No. 333-206847-10 andincorporated by reference herein).

4.13         Amended and Restated Agreement Between Note Holders,dated as of September 26, 2018, by and between Bank of America, N.A., asInitial Note A-1 Holder, and Bank of America, N.A., as Initial Note A-2 Holder(filed as Exhibit 4.13 to the registrant’s Current Report on Form 8-K filed onNovember 29, 2018 under Commission File No. 333-206847-10 and incorporated byreference herein).

4.14         Co-Lender Agreement, dated as of October 30, 2018, by andamong Deutsche Bank AG, acting through its New York Branch, as Note A-1-1Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-2Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-3Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-1-4Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-2Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-3Holder, Deutsche Bank AG, acting through its New York Branch, as Note A-4Holder, Goldman Sachs Mortgage Company, as Note A-5 Holder, Wells Fargo Bank,National Association, as Note A-6 Holder, and Wells Fargo Bank, NationalAssociation, as Note A-7 Holder (filed as Exhibit 4.14 to the registrant’sCurrent Report on Form 8-K filed on November 29, 2018 under Commission File No.333-206847-10 and incorporated by reference herein).

4.15         Agreement Between Note Holders, dated as of July 27,2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder,Morgan Stanley Bank, N.A., as Initial Note A-2 Holder, Morgan Stanley Bank,N.A., as Initial Note A-3 Holder, Morgan Stanley Bank, N.A., as Initial NoteA-4 Holder, and Morgan Stanley Bank, N.A., as Initial Note A-5 Holder (filed asExhibit 4.15 to the registrant’s Current Report on Form 8-K filed on November29, 2018 under Commission File No. 333-206847-10 and incorporated by referenceherein).

4.16         Agreement Between Note Holders, dated as of August 22,2018, by and between Column Financial, Inc., as Initial Note A-1 Holder, andWells Fargo Bank, National Association, as Initial Note A-2 Holder (filed asExhibit 4.17 to the registrant’s Current Report on Form 8-K filed on November29, 2018 under Commission File No. 333-206847-10 and incorporated by referenceherein).

4.17         Agreement Between Note Holders, dated as of July 27,2018, by and between Morgan Stanley Bank, N.A., as Initial Note A-1 Holder, andMorgan Stanley Bank, as Initial Note A-2 Holder (filed as Exhibit 4.18 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein).

4.18         Agreement Between Note Holders, dated as of November 2,2018, by and between Bank of America, N.A., as Initial Note A-1 Holder, andBank of America, N.A., as Initial Note A-2 Holder (filed as Exhibit 4.19 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 under CommissionFile No. 333-206847-10 and incorporated by reference herein).

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

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

33.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

33.3        LNR Partners, LLC, as General Special Servicer

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

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

33.6        Wells Fargo Bank, National Association, asCertificate Administrator

33.7        Wells Fargo Bank, National Association, asCustodian

33.8        Park Bridge Lender Services LLC, as OperatingAdvisor

33.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

33.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

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

33.13      LNR Partners, LLC, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan (see Exhibit 33.3)

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

33.15      Wells Fargo Bank, National Association, asCustodian of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.7)

33.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.8)

33.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 33.9)

33.18       Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (see Exhibit 33.11)

33.19      Wells Fargo Bank, National Association, as Primary Servicerof the Aventura Mall Mortgage Loan (see Exhibit 33.1)

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

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

33.22      Wells Fargo Bank, National Association, asCustodian of the Aventura Mall Mortgage Loan (see Exhibit 33.7)

33.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aventura Mall Mortgage Loan (see Exhibit 33.8)

33.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Aventura Mall Mortgage Loan (see Exhibit 33.9)

33.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

33.27      Torchlight Loan Services, LLC, as Special Servicer of the Pfizer BuildingMortgage Loan prior to August 11, 2022 (Omitted. See Explanatory Notes.)

33.28      Mount Street US (Georgia) LLP, as Special Servicer of the Pfizer BuildingMortgage Loan on and after August 11, 2022 (Omitted. See Explanatory Notes.)

33.29      Wilmington Trust, National Association, as Trustee of the Pfizer Building MortgageLoan (Omitted. See Explanatory Notes.)

33.30      Wells Fargo Bank, National Association, asCustodian of the Pfizer Building Mortgage Loan (see Exhibit 33.7)

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

33.32      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Pfizer Building Mortgage Loan (see Exhibit 33.9)

33.33      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

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

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

33.37      Wells Fargo Bank, National Association, asCustodian of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 33.7)

33.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Millennium Partners Portfolio Mortgage Loan (see Exhibit33.9)

33.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.40      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Plaza Frontenac Mortgage Loan

33.41      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Plaza Frontenac Mortgage Loan(see Exhibit 33.40)

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

33.43      Wells Fargo Bank, National Association, asCustodian of the Plaza Frontenac Mortgage Loan (see Exhibit 33.7)

33.44      Pentalpha Surveillance LLC, as Operating Advisorof the Plaza Frontenac Mortgage Loan (see Exhibit 33.31)

33.45      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

33.47      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 33.40)

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

33.49      Wells Fargo Bank, National Association, asCustodian of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.7)

33.50      Park Bridge Lender Services LLC, as OperatingAdvisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.8)

33.51      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.9)

33.52      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

33.53      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit33.1)

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

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

33.56      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit33.7)

33.57      Park Bridge Lender Services LLC, as OperatingAdvisor of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit33.8)

33.58      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Moffett Towers - Buildings E, F, G Mortgage Loan (seeExhibit 33.9)

33.59      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

33.61      Rialto Capital Advisors, LLC, as Special Servicerof the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.54)

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

33.63      Wells Fargo Bank, National Association, asCustodian of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.7)

33.64      Pentalpha Surveillance LLC, as Operating Advisorof the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.31)

33.65      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 33.9)

33.66      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

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

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

33.70      Wells Fargo Bank, National Association, asCustodian of the Carriage Place Mortgage Loan (see Exhibit 33.7)

33.71      Park Bridge Lender Services LLC, as OperatingAdvisor of the Carriage Place Mortgage Loan (see Exhibit 33.8)

33.72      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Carriage Place Mortgage Loan (see Exhibit 33.9)

33.73      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.11)

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

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

34.3        LNR Partners, LLC, as General Special Servicer

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

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

34.6        Wells Fargo Bank, National Association, asCertificate Administrator

34.7        Wells Fargo Bank, National Association, asCustodian

34.8        Park Bridge Lender Services LLC, as OperatingAdvisor

34.9        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.10      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

34.11      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

34.12      Wells Fargo Bank, National Association, as PrimaryServicer of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.1)

34.13      LNR Partners, LLC, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan (see Exhibit 34.3)

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

34.15      Wells Fargo Bank, National Association, asCustodian of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.7)

34.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.8)

34.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 685 Fifth Avenue Retail Mortgage Loan (see Exhibit 34.9)

34.18      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

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

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

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

34.22      Wells Fargo Bank, National Association, asCustodian of the Aventura Mall Mortgage Loan (see Exhibit 34.7)

34.23      Park Bridge Lender Services LLC, as OperatingAdvisor of the Aventura Mall Mortgage Loan (see Exhibit 34.8)

34.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Aventura Mall Mortgage Loan (see Exhibit 34.9)

34.25      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

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

34.27      Torchlight Loan Services, LLC, as Special Servicer of the Pfizer BuildingMortgage Loan prior to August 11, 2022 (Omitted. See Explanatory Notes.)

34.28      Mount Street US (Georgia) LLP, as Special Servicer of the Pfizer BuildingMortgage Loan on and after August 11, 2022 (Omitted. See Explanatory Notes.)

34.29      Wilmington Trust, National Association, as Trustee of the Pfizer Building MortgageLoan (Omitted. See Explanatory Notes.)

34.30      Wells Fargo Bank, National Association, asCustodian of the Pfizer Building Mortgage Loan (see Exhibit 34.7)

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

34.32      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Pfizer Building Mortgage Loan (see Exhibit 34.9)

34.33      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

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

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

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

34.37      Wells Fargo Bank, National Association, asCustodian of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 34.7)

34.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Millennium Partners Portfolio Mortgage Loan (see Exhibit34.9)

34.39      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.40      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Plaza Frontenac Mortgage Loan

34.41      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Plaza Frontenac Mortgage Loan(see Exhibit 34.40)

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

34.43      Wells Fargo Bank, National Association, as Custodianof the Plaza Frontenac Mortgage Loan (see Exhibit 34.7)

34.44      Pentalpha Surveillance LLC, as Operating Advisorof the Plaza Frontenac Mortgage Loan (see Exhibit 34.31)

34.45      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

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

34.47      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 34.40)

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

34.49      Wells Fargo Bank, National Association, asCustodian of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.7)

34.50      Park Bridge Lender Services LLC, as OperatingAdvisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.8)

34.51      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.9)

34.52      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

34.53      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit34.1)

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

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

34.56      Wells Fargo Bank, National Association, asCustodian of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit34.7)

34.57      Park Bridge Lender Services LLC, as OperatingAdvisor of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit34.8)

34.58      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Moffett Towers - Buildings E, F, G Mortgage Loan (seeExhibit 34.9)

34.59      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

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

34.61      Rialto Capital Advisors, LLC, as Special Servicerof the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.54)

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

34.63      Wells Fargo Bank, National Association, asCustodian of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.7)

34.64      Pentalpha Surveillance LLC, as Operating Advisorof the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.31)

34.65      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the 2020 Fifth Avenue Mortgage Loan (see Exhibit 34.9)

34.66      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

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

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

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

34.70      Wells Fargo Bank, National Association, asCustodian of the Carriage Place Mortgage Loan (see Exhibit 34.7)

34.71      Park Bridge Lender Services LLC, as OperatingAdvisor of the Carriage Place Mortgage Loan (see Exhibit 34.8)

34.72      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Carriage Place Mortgage Loan (see Exhibit 34.9)

34.73      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.11)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

35.3        LNR Partners, LLC, as General Special Servicer

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

35.5        Wells Fargo Bank, National Association, asCertificate Administrator

35.6        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

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

35.8        LNR Partners, LLC, as Special Servicer of the 685Fifth Avenue Retail Mortgage Loan (see Exhibit 35.3)

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

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

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

35.12      Torchlight Loan Services, LLC, as Special Servicer of the Pfizer BuildingMortgage Loan prior to August 11, 2022 (Omitted. See Explanatory Notes.)

35.13      Mount Street US (Georgia) LLP, as Special Servicer of the Pfizer BuildingMortgage Loan on and after August 11, 2022 (Omitted. See Explanatory Notes.)

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

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

35.16      Midland Loan Services, a Division of PNC Bank,National Association, as Primary Servicer of the Plaza Frontenac Mortgage Loan

35.17      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Plaza Frontenac Mortgage Loan(see Exhibit 35.16)

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

35.19      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan (see Exhibit 35.16)

35.20      Wells Fargo Bank, National Association, as PrimaryServicer of the Moffett Towers - Buildings E, F, G Mortgage Loan (see Exhibit35.1)

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

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

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

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

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

99.1         Mortgage Loan Purchase Agreement, dated as of November16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. andMorgan Stanley Mortgage Capital Holdings LLC (filed as Exhibit 99.1 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein)

99.2         Mortgage Loan Purchase Agreement, dated as of November16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. andWells Fargo Bank, National Association (filed as Exhibit 99.2 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein)

99.3         Mortgage Loan Purchase Agreement, dated as of November16, 2018, between Banc of America Merrill Lynch Commercial Mortgage Inc. andBank of America, National Association (filed as Exhibit 99.3 to theregistrant’s Current Report on Form 8-K filed on November 29, 2018 underCommission File No. 333-206847-10 and incorporated by reference herein)

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

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Banc of America Merrill LynchCommercial Mortgage Inc.(Depositor)

/s/ LelandF. Bunch, III

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

(senior officer in charge of securitizationof the depositor)

Date: March 17, 2023