**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: 333-226486-03**

**Central Index Key Number of the issuing entity:0001763333**

**BANK 2019-BNK16**

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

** **

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

**Wells Fargo Commercial MortgageSecurities, Inc.**

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

** **

**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: 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: 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)** | **38-4104362**

**38-4104363**

**(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:**

**(704) 374-6161**

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

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

 

 

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

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

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

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

Indicate by check mark whether the registrant has submittedelectronically 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                                                                                                       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

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 One AT&T Mortgage Loan, the RegionsTower Mortgage Loan, the Carriage Place Mortgage Loan and the Residence InnNational Portfolio Mortgage Loan, which constituted approximately 7.3%, 4.4%,2.1% and 1.7%, 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 One AT&T MortgageLoan, one other *pari passu* loan, which is not an asset of the issuingentity, (b) with respect to the Regions Tower Mortgage Loan, one other *paripassu* loan, which is not an asset of the issuing entity, (c) with respectto the Carriage Place Mortgage Loan, one other *pari passu* loan, which isnot an asset of the issuing entity and (d) with respect to the Residence InnNational Portfolio Mortgage Loan, two other *pari passu* loans, which arenot assets of the issuing entity. These loan combinations, including the OneAT&T Mortgage Loan, the Regions Tower Mortgage Loan, the Carriage PlaceMortgage Loan and the Residence Inn National Portfolio Mortgage Loan, are 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 Millennium Partners Portfolio Mortgage Loan,which constituted approximately 6.7% 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, eight other *pari passu*loans and one subordinate companion loan, 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 “MSC2018-MP Transaction”). This loan combination, including the MillenniumPartners Portfolio Mortgage Loan, is being serviced and administered pursuantto the trust and servicing agreement for the MSC 2018-MP Transaction, which isincorporated by reference as Exhibit 4.2 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 theExhibit Index) with respect to the Penske Distribution Center Mortgage Loan,which constituted approximately 3.1% of the asset pool of the issuing entity asof its cut-off date.  The Penske Distribution Center Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes thePenske Distribution Center Mortgage Loan and one other *pari passu* loan,which is not an asset of the issuing entity. The other *pari passu*portion of the loan combination was securitized in the Morgan Stanley Capital ITrust 2018-H4 transaction, Commission File Number 333-227446-01 (the “MSC2018-H4 Transaction”). This loan combination, including the PenskeDistribution Center Mortgage Loan, is being serviced and administered pursuantto the pooling and servicing agreement for the MSC 2018-H4 Transaction, whichis incorporated by reference as Exhibit 4.3 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 administered pursuantto such agreement unless a separate primary servicer is identifiedherein.  If this report does not identify a separate primary servicer, theservicer compliance statement provided by the master servicer under any suchagreement also encompasses its responsibilities as primary servicer of therelated mortgage loan or mortgage loans.

Wells Fargo Bank, NationalAssociation is the general master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement and theprimary servicer and special servicer of the Millennium Partners PortfolioMortgage Loan. As a result, Wells Fargo Bank, National Association is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

National Cooperative Bank, N.A., the NCB master servicer andNCB special servicer, is also a sponsor. Therefore, the Depositor included inthis Annual Report on Form 10-K a servicer compliance statement for NationalCooperative Bank, N.A. pursuant to Item 1123.  Because NationalCooperative Bank, N.A. is servicing less than 5% of the pool assets, anassessment of compliance with applicable servicing criteria and an accountants’attestation report pursuant to Item 1122 of Regulation AB are not required byRegulation AB. As the attestation made in the servicer compliance statementrequired by Item 1123 relates to a review of the servicing activities ofNational Cooperative Bank, N.A. under the applicable servicing agreement, andthat review was conducted in conjunction with the servicer’s preparation of itsassessment of compliance with applicable servicing criteria, that assessment ofcompliance with applicable servicing criteria and the accompanying accountants’attestation report are included in this Annual Report on Form 10-K for the sakeof completeness.

Wells Fargo Bank, NationalAssociation is the custodian of the mortgage loans serviced under the Poolingand Servicing Agreement, the Millennium Partners Portfolio Mortgage Loan andthe Penske Distribution Center 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 isthe operating advisor of the mortgage loans serviced under the Pooling andServicing Agreement and the Penske Distribution Center Mortgage Loan.  Asa result, Park Bridge Lender Services LLC is a servicing function participantin the capacities described above, because it is servicing mortgage loans thatconstituted 5% or more of the assets of the issuing entity as of its cut-offdate. The assessments of compliance with applicable servicing criteria andaccountants’ attestation reports delivered by Park Bridge Lender Services LLCin the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the Penske Distribution Center MortgageLoan.  Pursuant to the pooling and servicing agreement for the MSC 2018-H4Transaction, 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 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 Penske Distribution Center Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

Wilmington Trust, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement and the Millennium Partners Portfolio MortgageLoan.  Pursuant to the Pooling and Servicing Agreement and the trust andservicing agreement for the MSC 2018-MP 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 thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of  the mortgage loans servicedunder the Pooling and Servicing Agreement and the Millennium Partners PortfolioMortgage 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 andaccountants’ attestation reports from CoreLogic Solutions, LLC  Thisentity was engaged by the master servicer under the Pooling and ServicingAgreement and the primary servicer of the Millennium Partners PortfolioMortgage Loan and the to remit tax payments received from the escrow accountsof borrowers to local taxing authorities, to report tax amounts due, to verifytax parcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in Items1122(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 Annual Report on Form 10-Kincludes an assessment of compliance with applicable servicing criteria,accountants’ attestation report and servicer compliance statement fromComputershare Trust Company, National Association (“CTCNA”).  CTCNAwas engaged by Wells Fargo Bank, National Association (“Wells Fargo”),in its capacity as certificate administrator and custodian, to perform certainspecified servicing functions identified in the assessment of compliance withapplicable servicing criteria and accountants’ attestation reports.  WellsFargo engaged CTCNA in connection with the sale of Wells Fargo’s corporatetrust services business to CTCNA and its affiliates.  Further, under theprinciples-based definition of “servicer” set forth in Item 1101(j) ofRegulation AB that looks to the functions that an entity performs, this partyis a “servicer” for the purposes of Item 1123 of Regulation AB.  SeeCompliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

Theassessments of compliance with applicable servicing criteria, accountants’attestation reports and servicer compliance statements of the certificateadministrator of the Millennium Partners Portfolio Mortgage Loan and the PenskeDistribution Center Mortgage Loan are omitted from this Annual Report on Form10-K as the certificate administrator pursuant to the related pooling andservicing agreement or trust and servicing agreement does not perform anyactivities that address servicing criteria with respect to the issuing entityand because they are each not a “servicer” that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the *pari passu*loan combinations that include the Penske Distribution Center Mortgage Loan,(i) the reports on assessment of compliance with servicing criteria andattestation reports on assessment of compliance with servicing criteria ofMidland Loan Services, a Division of PNC Bank, National Association as primaryservicer of the Penske Distribution Center Mortgage Loan and Argentic ServicesCompany LP as special servicer of the Penske Distribution Center Mortgage Loan,listed on the Exhibit Index are omitted from this Annual Report on Form 10-K asthey are not required to be included on this Annual Report on Form 10-K perInstruction 3 to Item 1122 of Regulation AB because they are parties performingactivities that address servicing criteria relating to 5% or less of the assetsof the issuing entity; and (ii) the servicer compliance statements of MidlandLoan Services, a Division of PNC Bank, National Association as primary servicerof the Penske Distribution Center Mortgage Loan and Argentic Services CompanyLP as special servicer of the Penske Distribution Center Mortgage Loan, listedon the Exhibit Index are omitted from this Annual Report on Form 10-K as theyare not required by Item 1123 of Regulation AB to be included on this AnnualReport on Form 10-K because they are each an unaffiliated party that is not a“servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation 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 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 any derivativeinstruments or other support for the certificates within this transaction asdescribed 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 Wells Fargo Bank, National Association, ascertificate administrator, as trustee and as custodian.

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 andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. In July 2022, the district court dismissed Phoenix Light’s claims andcertain of the claims asserted by Commerzbank AG, and subsequently enteredjudgment in each case in favor of Wells Fargo Bank, N.A. In August 2022,Phoenix Light and Commerzbank AG appealed the district court’s decision to theUnited States Court of Appeals for the Second Circuit. The Company previouslysettled two class actions filed by institutional investors and an action filedby the National Credit Union Administration with similar allegations. Inaddition, Park Royal I LLC and Park Royal II LLC have filed substantiallysimilar lawsuits in New York state court alleging Wells Fargo Bank, N.A., astrustee, failed to take appropriate actions upon learning of defective mortgageloan documentation.

**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 February 21, 2019 pursuant to Rule 424(b)(2).

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the mortgage loans are attachedhereto under Item 15 to this Annual Report on Form 10-K. Attached as Exhibit AAto the Pooling and Servicing Agreement incorporated by reference as Exhibit 4.1to this Annual Report on Form 10-K is a chart identifying the entities participatingin a servicing function for the 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 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 4.2 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 Penske Distribution CenterMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the MSC 2018-H4 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 MSC 2018-H4 Transaction incorporated byreference as Exhibit 4.3 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the MSC2018-H4 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          Poolingand Servicing Agreement, dated as of February 1, 2019, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as General Master Servicer, KeyBank National Association, asGeneral Special Servicer, National Cooperative Bank, N.A., as NCB MasterServicer and as NCB Special Servicer, Wells Fargo Bank, National Association,as Certificate Administrator, Wilmington Trust, National Association, asTrustee, and Park Bridge Lender Services LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 4.1 to the registrant’s CurrentReport on Form 8-K/A filed on March 14, 2019 under Commission File No.333-226486-03 and incorporated by reference herein). 

4.2          Trustand Servicing Agreement, dated as of August 7, 2018, by and among MorganStanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association, asServicer and Special Servicer, Wells Fargo Bank, National Association, asCertificate Administrator and Custodian, Wilmington Trust, NationalAssociation, as Trustee (filed as Exhibit 4.2 to the registrant’s CurrentReport on Form 8-K filed on February 21, 2019 under Commission File No.333-226486-03 and incorporated by reference herein).

4.3          Poolingand Servicing Agreement, dated as of December 1, 2018, by and among MorganStanley Capital I Inc., as Depositor, Midland Loan Services, a Division of PNCBank, National Association, as Master Servicer, LNR Partners, LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administratorand Trustee, and Park Bridge Lender Services LLC, as Operating Advisor andAsset Representations Reviewer (filed as Exhibit 4.3 to the registrant’sCurrent Report on Form 8-K filed on February 21, 2019 under Commission File No.333-226486-03 and incorporated by reference herein).

4.4          AgreementBetween Note Holders, dated as of February 8, 2019, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, and Morgan Stanley Bank, N.A.,as Initial Note A-2 Holder (filed as Exhibit 4.5 to the registrant’s CurrentReport on Form 8-K filed on February 21, 2019 under Commission File No.333-226486-03 and incorporated by reference herein).

4.5          AgreementBetween Note Holders, dated as of August 9, 2018, by and between Morgan StanleyBank, N.A., as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial NoteA-3 Holder, Initial Note A-4 Holder, Initial Note A-5 Holder and Initial NoteA-6 Holder, Morgan Stanley Bank, N.A., as Initial Note B-1 Holder, Initial NoteB-2 Holder, Initial Note B-3 Holder, Initial Note B-4 Holder, Initial Note B-5Holder and Initial Note B-6 Holder, and Morgan Stanley Bank, N.A., as InitialNote C Holder (filed as Exhibit 4.6 to the registrant’s Current Report on Form8-K filed on February 21, 2019 under Commission File No. 333-226486-03 andincorporated by reference herein).

4.6          AgreementBetween Note Holders, dated as of October 23, 3018, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, and Morgan Stanley Bank, N.A.,as Initial Note A-2 Holder (filed as Exhibit 4.7 to the registrant’s CurrentReport on Form 8-K filed on February 21, 2019 under Commission File No.333-226486-03 and incorporated by reference herein).

4.7          AgreementBetween Note Holders, dated as of December 27, 2018, by and between MorganStanley Bank, N.A., as Initial Note A-1 Holder, and Morgan Stanley Bank, N.A.,as Initial Note A-2 Holder (filed as Exhibit 4.8 to the registrant’s CurrentReport on Form 8-K filed on February 21, 2019 under Commission File No.333-226486-03 and incorporated by reference herein).

4.8          AgreementBetween Note Holders, dated as of November 2, 2018, by and between Bank ofAmerica, N.A., as Initial Note A-1 Holder, and Bank of America, N.A., as InitialNote A-2 Holder (filed as Exhibit 4.9 to the registrant’s Current Report onForm 8-K filed on February 21, 2019 under Commission File No. 333-226486-03 andincorporated by reference herein).

4.9        AgreementBetween Note Holders, dated as of February 8, 2019, by and between MorganStanley Bank, N.A., as Initial Note A-1-A Holder, Morgan Stanley Bank, N.A., asInitial Note A-1-B, and Morgan Stanley Bank, N.A., as Initial Note A-2 Holder(filed as Exhibit 4.10 to the registrant’s Current Report on Form 8-K filed onFebruary 21, 2019 under Commission File No. 333-226486-03 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        Wells Fargo Bank, National Association, as GeneralMaster Servicer

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

33.3        KeyBank National Association, as General SpecialServicer

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 One AT&T Mortgage Loan (see Exhibit 33.1)

33.13      KeyBank National Association, as Special Servicerof the One AT&T Mortgage Loan (see Exhibit 33.3)

33.14      Wilmington Trust, National Association, as Trustee of the One AT&T MortgageLoan (Omitted. See Explanatory Notes.)

33.15      Wells Fargo Bank, National Association, asCustodian of the One AT&T Mortgage Loan (see Exhibit 33.7)

33.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the One AT&T Mortgage Loan (see Exhibit 33.8)

33.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the One AT&T 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 PrimaryServicer of the Regions Tower Mortgage Loan (see Exhibit 33.1)

33.20      KeyBank National Association, as Special Servicerof the Regions Tower Mortgage Loan (see Exhibit 33.3)

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

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

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

33.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Regions Tower 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 Carriage Place Mortgage Loan (see Exhibit 33.1)

33.27      KeyBank National Association, as Special Servicerof the Carriage Place Mortgage Loan (see Exhibit 33.3)

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

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

33.30      Park Bridge Lender Services LLC, as Operating Advisorof the Carriage Place Mortgage Loan (see Exhibit 33.8)

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

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

33.33      Wells Fargo Bank, National Association, as PrimaryServicer of the Residence Inn National Portfolio Mortgage Loan (see Exhibit33.1)

33.34      KeyBank National Association, as Special Servicerof the Residence Inn National Portfolio Mortgage Loan (see Exhibit 33.3)

33.35      Wilmington Trust, National Association, as Trustee of the Residence InnNational Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.36      Wells Fargo Bank, National Association, asCustodian of the Residence Inn National Portfolio Mortgage Loan (see Exhibit33.7)

33.37      Park Bridge Lender Services LLC, as OperatingAdvisor of the Residence Inn National Portfolio Mortgage Loan (see Exhibit33.8)

33.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Residence Inn National 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      Wells Fargo Bank, National Association, as PrimaryServicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 33.1)

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

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

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

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

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

33.46      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Penske Distribution Center Mortgage Loan (Omitted. SeeExplanatory Notes.) 

33.47      Argentic Services Company LP, as Special Servicer of the Penske DistributionCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.48      Wells Fargo Bank, National Association, as Trustee of the Penske DistributionCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.49      Wells Fargo Bank, National Association, asCustodian of the Penske Distribution Center Mortgage Loan (see Exhibit 33.7)

33.50      Park Bridge Lender Services LLC, as OperatingAdvisor of the Penske Distribution Center Mortgage Loan (see Exhibit 33.8)

33.51      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        KeyBank National Association, as General SpecialServicer

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

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

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 One AT&T Mortgage Loan (see Exhibit 34.1)

34.13      KeyBank National Association, as Special Servicerof the One AT&T Mortgage Loan (see Exhibit 34.3)

34.14      Wilmington Trust, National Association, as Trustee of the One AT&T MortgageLoan (Omitted. See Explanatory Notes.)

34.15      Wells Fargo Bank, National Association, asCustodian of the One AT&T Mortgage Loan (see Exhibit 34.7)

34.16      Park Bridge Lender Services LLC, as OperatingAdvisor of the One AT&T Mortgage Loan (see Exhibit 34.8)

34.17      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the One AT&T 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 Regions Tower Mortgage Loan (see Exhibit 34.1)

34.20      KeyBank National Association, as Special Servicerof the Regions Tower Mortgage Loan (see Exhibit 34.3)

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

34.22      Wells Fargo Bank, National Association, as Custodianof the Regions Tower Mortgage Loan (see Exhibit 34.7)

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

34.24      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Regions Tower 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 Carriage Place Mortgage Loan (see Exhibit 34.1)

34.27      KeyBank National Association, as Special Servicerof the Carriage Place Mortgage Loan (see Exhibit 34.3)

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

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

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

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

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

34.33      Wells Fargo Bank, National Association, as PrimaryServicer of the Residence Inn National Portfolio Mortgage Loan (see Exhibit34.1)

34.34      KeyBank National Association, as Special Servicerof the Residence Inn National Portfolio Mortgage Loan (see Exhibit 34.3)

34.35      Wilmington Trust, National Association, as Trustee of the Residence InnNational Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.36      Wells Fargo Bank, National Association, asCustodian of the Residence Inn National Portfolio Mortgage Loan (see Exhibit34.7)

34.37      Park Bridge Lender Services LLC, as OperatingAdvisor of the Residence Inn National Portfolio Mortgage Loan (see Exhibit34.8)

34.38      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Residence Inn National 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      Wells Fargo Bank, National Association, as PrimaryServicer of the Millennium Partners Portfolio Mortgage Loan (see Exhibit 34.1)

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

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

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

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

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

34.46      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Penske Distribution Center Mortgage Loan (Omitted. SeeExplanatory Notes.) 

34.47      Argentic Services Company LP, as Special Servicer of the Penske DistributionCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.48      Wells Fargo Bank, National Association, as Trustee of the Penske DistributionCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.49      Wells Fargo Bank, National Association, asCustodian of the Penske Distribution Center Mortgage Loan (see Exhibit 34.7)

34.50      Park Bridge Lender Services LLC, as OperatingAdvisor of the Penske Distribution Center Mortgage Loan (see Exhibit 34.8)

34.51      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        KeyBank National Association, as General SpecialServicer

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 One AT&T Mortgage Loan (see Exhibit 35.1)

35.8        KeyBank National Association, as Special Servicerof the One AT&T Mortgage Loan (see Exhibit 35.3)

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

35.10      KeyBank National Association, as Special Servicerof the Regions Tower Mortgage Loan (see Exhibit 35.3)

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

35.12      KeyBank National Association, as Special Servicerof the Carriage Place Mortgage Loan (see Exhibit 35.3)

35.13      Wells Fargo Bank, National Association, as PrimaryServicer of the Residence Inn National Portfolio Mortgage Loan (see Exhibit35.1)

35.14      KeyBank National Association, as Special Servicerof the Residence Inn National Portfolio Mortgage Loan (see Exhibit 35.3)

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

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

35.17      Midland Loan Services, a Division of PNC Bank, National Association, as PrimaryServicer of the Penske Distribution Center Mortgage Loan (Omitted. SeeExplanatory Notes.) 

35.18      Argentic Services Company LP, as Special Servicer of the Penske DistributionCenter Mortgage Loan (Omitted. See Explanatory Notes.)

99.1        MortgageLoan Purchase Agreement, dated as of February 1, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onFebruary 21, 2019 under Commission File No. 333-226486-03 and incorporated byreference herein)

99.2        MortgageLoan Purchase Agreement, dated as of February 1, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Bank of America, National Association(filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K filed onFebruary 21, 2019 under Commission File No. 333-226486-03 and incorporated byreference herein)

99.3        MortgageLoan Purchase Agreement, dated as of February 1, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.2 to the registrant’s Current Report on Form8-K filed on February 21, 2019 under Commission File No. 333-226486-03 andincorporated by reference herein)

99.4        MortgageLoan Purchase Agreement, dated as of February 1, 2019, between Wells FargoCommercial Mortgage Securities, Inc. and National Cooperative Bank, N.A. (filedas Exhibit 99.4 to the registrant’s Current Report on Form 8-K filed onFebruary 21, 2019 under Commission File No. 333-226486-03 and incorporated byreference 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.

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 10, 2023