**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**WASHINGTON,D.C. 20549**

**FORM 10‐K**

(Mark one)

**/X/ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**    For the fiscal year endedDecember 31, 2021 OR**

**//TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIESEXCHANGE ACT OF 1934**

**For the transition period from****            ****to****            **

 

 

 

**Commission file number:333-227446-02**

 

**Central Index Key Number of the issuing entity:****0001766660**

 

**Morgan Stanley Capital ITrust 2019-L2**

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

 

**Central Index Key Number of the depositor:0001547361**

 

**Morgan Stanley Capital I Inc.**

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

 

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

 

**Morgan Stanley MortgageCapital Holdings LLC**

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

 

**Central Index Key Number of the sponsor:0001624053**

 

**Argentic Real Estate FinanceLLC**

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

 

**Central Index Key Number of the sponsor:0001548405**

 

**Starwood Mortgage Capital LLC**

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

 

**Central Index Key Number of the sponsor:0001558761**

 

**Cantor Commercial Real EstateLending, L.P.**

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

** **

**Central Index Key Number of the sponsor:0001722518**

 

**BSPRT CMBS Finance, LLC**

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

 

| **New York**                                                        | **38-4014403  38-4014404  38-7221261**       |
|---------------------------------------------------------------------|----------------------------------------------|
| **(State or other jurisdiction of incorporation or  organization)** | **(I.R.S. Employer Identification Numbers)** |

 

**c/o Wells Fargo Bank, N.A.**

**9062 Old Annapolis Road**

** Columbia, MD**

**(Address of principal executive offices)**

 

**21045**

**(Zip Code)**

 

**Telephone number, including area code:**

**(410) 884‐2000**

Securitiesregistered pursuant to Section 12(b) of the Act:

 

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

 

Securitiesregistered pursuant to Section 12(g) of the Act:

 

  NONE.

 

Indicateby check mark if the registrant is a well-known seasoned issuer, as defined inRule 405 of the Securities Act.

 

  Yes___ No X

 

Indicateby check mark if the registrant is not required to file reports pursuant toSection 13 or Section 15(d) of the Act.

 

  Yes___ No X

 

Note- Checking the box above will not relieve any registrant required to filereports pursuant to Section 13 or 15(d) of the Exchange Act from theirobligations under those Sections.

 

Indicate by check mark whether the registrant (1) has filed all reportsrequired to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934during the preceding 12 months (or for such shorter period that the registrantwas required to file such reports), and (2) has been subject to such filingrequirements for the past 90 days.

 

  YesX No ___

 

Indicateby check mark whether the registrant has submitted electronically everyInteractive Data File required to be submitted pursuant to Rule 405 ofRegulation S-T (Section 232.405 of this chapter) during the preceding 12 months(or for such shorter period that the registrant was required to submit suchfiles).

 

 Not applicable.

  

Indicateby check mark whether the registrant is a large accelerated filer, anaccelerated filer, a non-accelerated filer, a smaller reporting company, oremerging growth company. See the definitions of "large acceleratedfiler", "accelerated filer," "smaller reportingcompany," and “emerging growth company” in Rule 12b-2 of the Exchange Act.

 

 Largeaccelerated filer ___ Accelerated filer ___ Non-accelerated filer X (Do not check if a smaller reporting company)Smaller reporting company ___

 

Emerginggrowth company ___

 

Ifan emerging growth company, indicate by check mark if the registrant haselected not to use the extended transition period for complying with any new orrevised financial accounting standards provided pursuant to Section 13(a) ofthe Ex­change Act.

 

  Notapplicable.

 

Indicateby check mark whether the registrant has filed a report on and attestation toits management’s assessment of the effectiveness of its internal control overfinancial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C.7262(b)) by the registered public accounting firm that prepared or issued itsaudit report.

 

Notapplicable. 

 

Indicateby check mark whether the registrant is a shell company (as defined in Rule12b-2 of the Act).

 

  Yes___ No X

 

Statethe aggregate market value of the voting and non-voting common equity held bynon-affiliates computed by reference to the price at which the common equitywas last sold, or the average bid and asked price of such common equity, as ofthe last business day of the registrant's most recently completed second fiscalquarter.

 

  Notapplicable.

 

Indicateby check mark whether the registrant has filed all documents and reports requiredto be filed by Section 12, 13 or 15(d) of the Securities Exchange Act of 1934subsequent to the distribution of securities under a plan confirmed by a court.

 

  Notapplicable.

 

Indicatethe number of shares outstanding of each of the registrant's classes of commonstock, as of the latest practicable date.

 

  Notapplicable.

 

DOCUMENTSINCORPORATED BY REFERENCE

 

Listhereunder the following documents if incorporated by reference and the Part of theForm 10-K (e.g., Part I, Part II, etc.) into which the document isincorporated: (1)Any annual report to security holders; (2) Any proxy orinformation statement; and (3)Any prospectus filed pursuant to Rule 424(b) or(c) under the Securities Act of 1933. The listed documents should be clearlydescribed for identification purposes (e.g., annual report to security holdersfor fiscal year ended December 24, 1980).

 

  Notapplicable.

 

**EXPLANATORY NOTES**

 

The MSC 2019-L2 mortgage pool includes thefollowing mortgage loans, each of which is serviced pursuant to a separatepooling and servicing agreement (each, an “Outside Pooling and ServicingAgreement”):

 

•   the One AT&T mortgageloan and the Residence Inn National Portfolio mortgage loan, which are servicedpursuant to the BANK 2019-BNK16 pooling and servicing agreement attached heretoas Exhibit 4.2; 

 

•   the Fairfax MultifamilyPortfolio mortgage loan, which is serviced pursuant to the CFK 2019-FAX trustand servicing agreement attached hereto as Exhibit 4.3; 

 

•   the Fidelis Portfoliomortgage loan, which is serviced pursuant to the BBCMS 2018-C2 pooling andservicing agreement attached hereto as Exhibit 4.4; and

 

•   the Sheraton Grand NashvilleDowntown mortgage loan, which is serviced pursuant to the WFCM 2018-C48 poolingand servicing agreement attached hereto as Exhibit 4.5.

 

-

Except as set forth below, each of theparties to each pooling and servicing agreement listed in the Exhibit Indexboth (1) participates in the servicing function for purposes of Item 1122 ofRegulation AB and (2) constitutes a servicer that meets the criteria in Item1108(a)(2)(i) through (iii) of Regulation AB for purposes of Item 1123 ofRegulation AB:

 

•   The trustee under a poolingand servicing agreement has a nominal role with respect to the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  Thetrustee’s only servicing function is the contingent obligation to make certainadvances if the master servicer under such pooling and servicing agreementfails to do so, while all other servicing functions are performed by otherparties.  The trustee under each of the pooling and servicing agreementslisted in the Exhibit Index has confirmed to the registrant that it has notmade any such contingent advances during the reporting period, andconsequently, each such trustee does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The certificate administratorunder a pooling and servicing agreement performs various payment administrationfunctions solely for the securitization governed by such pooling and servicingagreement and the mortgage pool securitized pursuant to such pooling andservicing agreement and does not have any obligations with respect to any othertransaction.  Consequently, the certificate administrator under an OutsidePooling and Servicing Agreement does not participate in the servicing functionfor purposes of Item 1122 of Regulation AB, nor does it perform the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.

 

•   The operating advisor under apooling and servicing agreement represents the interests of seniorcertificateholders in the transaction governed by such pooling and servicingagreement and is responsible for monitoring the performance of the specialservicer under such pooling and servicing agreement and producing certainreports to certificateholders relating to the resolution of the mortgage poolsecuritized pursuant to such pooling and servicing agreement.  The operatingadvisor under a pooling and servicing agreement does not have any obligationswith respect to any other transaction and is solely obligated to perform loanreporting functions with respect to the securitization governed by such poolingand servicing agreement.  Consequently, the operating advisor under anOutside Pooling and Servicing Agreement neither participates in the servicingfunction for purposes of Item 1122 of Regulation AB nor performs the functionsof a servicer for purposes of the definition of “servicer” under Item 1101 ofRegulation AB or for purposes of Item 1123 of Regulation AB.  In addition,while the operating advisor under a pooling and servicing agreement has certainreporting obligations in respect of the related mortgage pool, it has noobligation to collect or disburse funds in respect of the mortgage pool or toadminister any of the underlying mortgage loans.  Consequently, theoperating advisor under a pooling and servicing agreement participates in theservicing function for purposes of Item 1122 of Regulation AB, but is notresponsible for the “management or collection of the pool assets or makingallocations or distributions to holders of the asset-backed securities” withinthe meaning of “servicer” under Item 1101 of Regulation AB and does not performthe functions of a servicer for purposes of Item 1123 of Regulation AB. 

 

•  The asset representations reviewer under a pooling andservicing agreement has a limited obligation to review certain delinquentmortgage loans after a specified delinquency threshold has been met and therequired percentage of certificateholders vote to direct a review of suchdelinquent mortgage loans, and has no obligation to collect or disburse fundsin respect of the mortgage pool, to administer any of the underlying mortgageloans or to perform any servicing function.  Consequently, the assetrepresentations reviewer under a pooling and servicing agreement does notparticipate in the servicing function for purposes of Item 1122 of RegulationAB, is not responsible for the “management or collection of the pool assets ormaking allocations or distributions to holders of the asset-backed securities”within the meaning of “servicer” under Item 1101 of Regulation AB and does notperform the functions of a servicer for purposes of Item 1123 of Regulation AB.

•   NCB, N.A. as NCB masterservicer and NCB special servicer under the BANK 2019-BNK16 pooling andservicing agreement, only has obligations in respect of certain mortgage loanssold to the BANK 2019-BNK16 securitization trust by NCB, N.A. or its affiliateand has no obligations with respect to the One AT&T mortgage loan or theResidence Inn National Portfolio mortgage loan and therefore in such capacitydoes not constitute a reporting “servicing function participant” for purposesof Item 1122 of Regulation AB, as specified in the Instruction 3 to Item 1122,and does not constitute a reporting “servicer” for purposes of Item 1123 ofRegulation AB, as specified in the Instruction to Item 1123.

 

•   KeyBank National Association is the servicer underthe CFK 2019-FAX trust and servicing agreement, pursuant to which the FairfaxMultifamily Portfolio mortgage loan is serviced.  Because KeyBank NationalAssociation is not the MSC 2019-L2 master servicer, is not affiliated with anysponsor and services only the Fairfax Multifamily Portfolio mortgage loan,which constitutes less than 5% of the mortgage pool, KeyBank NationalAssociation, as CFK 2019-FAX servicer, does not constitute a reporting“servicing function participant” for purposes of Item 1122 of Regulation AB, asspecified in the Instruction 3 to Item 1122, and does not constitute areporting “servicer” for purposes of Item 1123 of Regulation AB, as specifiedin the Instruction to Item 1123.

•   Argentic ServicesCompany LP is the current special servicer under the WFCM 2018-C48 pooling andservicing agreement, under which the Sheraton Grand Nashville Downtown mortgageloan is serviced. On May 6, 2020, LNR Partners, LLC was replaced as special servicerunder the WFCM 2018-C48 pooling and servicing agreement and succeeded byArgentic Services Company LP.  

 

•   National TaxSearch, LLC merged into CoreLogic Solutions, LLC in 2021.  CoreLogicSolutions, LLC’s report on assessment of compliance with servicing criteria andregistered public accounting firm attestation report, in each case providedpursuant to Item 1122 of Regulation AB, also relate to National Tax Search,LLC’s platform for the reporting period.

 

In addition, each of the following partiesengaged the services of certain servicing function participants andsub-servicers for the reporting period, as set forth below:

 

•   Midland Loan Services, a Divisionof PNC Bank, National Association, as master servicer, engaged the services ofBerkeley Point Capital LLC as a sub-servicer in respect of the entire mortgagepool for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BANK 2019-BNK16 pooling and servicingagreement, pursuant to which the One AT&T mortgage loan and the ResidenceInn National Portfolio mortgage loan are serviced, engaged the services ofCoreLogic Solutions, LLC and National Tax Search, LLC, in each case as a servicingfunction participant in respect of the One AT&T mortgage loan and theResidence Inn National Portfolio mortgage loan for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the BBCMS 2018-C2 pooling and servicingagreement, pursuant to which the Fidelis Portfolio mortgage loan is serviced,engaged the services of CoreLogic Solutions, LLC and National Tax Search, LLC,in each case as a servicing function participant in respect of the FidelisPortfolio mortgage loan for the reporting period.

 

•   Wells Fargo Bank, NationalAssociation, as master servicer under the WFCM 2018-C48 pooling and servicingagreement, pursuant to which the Sheraton Grand Nashville Downtown mortgageloan is serviced, engaged the services of CoreLogic Solutions, LLC and NationalTax Search, LLC, in each case as a servicing function participant in respect ofthe Sheraton Grand Nashville Downtown mortgage loan for the reporting period.

 

•   On November 1, 2021, pursuantto the second amended and restated servicing agreement attached hereto asExhibit 99.15, Computershare Trust Company, National Association was engaged toperform all or virtually all of Wells Fargo Bank, National Association’s rolesas certificate administrator, custodian and trustee, as applicable, under (i)the pooling and servicing agreement and (ii) each Outside Pooling and ServicingAgreement.

 

 

| **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.**    |
|              | Omitted.                        |
|              |                            |   |

 

| **PART II**  |                                                                                                                |
|-------------------|---------------------------------------------------------------------------------------------------------------------|
|              |                                                                                                                |
| **Item 5.**  | **Market for Registrant's Common  Equity, Related Stockholder Matters and Issuer Purchases of Equity  Securities.** |
|              | Omitted.                                                                                                            |
| **Item 6.**  | **Selected Financial Data.**                                                                                        |
|              | Omitted.                                                                                                            |
| **Item 7.**  | **Management's Discussion  and Analysis of Financial Condition and Results of Operations.**                         |
|              | Omitted.                                                                                                            |
| **Item 7A.** | **Quantitative and  Qualitative Disclosures About Market Risk.**                                                    |
|              | Omitted.                                                                                                            |
| **Item 8.**  | **Financial Statements and  Supplementary Data.**                                                                   |
|              | Omitted.                                                                                                            |
| **Item 9.**  | **Changes in and  Disagreements With Accountants on Accounting and Financial Disclosure.**                          |
|              | Omitted.                                                                                                            |
| **Item 9A.** | **Controls and Procedures.**                                                                                        |
|              | Omitted.                                                                                                            |
| **Item 9B.** | **Other Information.**                                                                                         |
|              | None.                                                                                                               |
|              |                                                                                                                |   |

 

| **PART III** |                                                                                                 |
|-------------------|------------------------------------------------------------------------------------------------------|
|              |                                                                                                 |
| **Item 10.** | **Directors, Executive  Officers and Corporate Governance.**                                         |
|              | Omitted.                                                                                             |
| **Item 11.** | **Executive Compensation.**                                                                          |
|              | Omitted.                                                                                             |
| **Item 12.** | **Security Ownership of  Certain Beneficial Owners and Management and Related Stockholder Matters.** |
|              | Omitted.                                                                                             |
| **Item 13.** | **Certain Relationships and  Related Transactions, and Director Independence.**                      |
|              | Omitted.                                                                                             |
| **Item 14.** | **Principal Accountant Fees  and Services.**                                                         |
|              | Omitted.                                                                                             |
|              |                                                                                                 |   |

 

**ADDITIONALDISCLOSURE ITEMS FOR REGULATION AB**

 

**Item1112(b) of Regulation AB, Significant Obligor Financial Information.**

 

Notapplicable.

 

**Item1114(b)(2) of Regulation AB, Significant Enhancement Provider FinancialInformation.**

 

Noentity or group of affiliated entities provides any enhancement or othersupport for the certificates as described under Item 1114 (a) of Regulation AB.

 

**Item1115(b) of Regulation AB, Certain Derivatives Instruments (FinancialInformation).**

 

Noentity or group of affiliated entities provides any derivative instruments forthe certificates as described under Item 1115 of Regulation AB.

 

**Item1117 of Regulation AB, Legal Proceedings.**

 

Theregistrant knows of no legal proceeding pending against the sponsors,depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) ofRegulation AB, originator contemplated by Item 1110(b) of Regulation AB, or otherparty contemplated by Item 1100(d)(1) of Regulation AB, or of which anyproperty of the foregoing is the subject, that is material to security holders,other than as follows: 

 

InDecember 2014, Phoenix Light SF Limited and certain related entities and theNational Credit Union Administration (NCUA) filed complaints in the UnitedStates District Court for the Southern District of New York against Wells FargoBank, alleging claims against Wells Fargo Bank in its capacity as trustee for anumber of residential mortgage-backed securities trusts. Complaints raisingsimilar allegations have been filed by Commerzbank AG in the Southern Districtof New York and by IKB International and IKB Deutsche Industriebank in New Yorkstate court. In each case, the plaintiffs allege that Wells Fargo Bank, 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. Wells Fargo Bank previously settled two class action lawsuits withsimilar allegations that were filed in November 2014 and December 2016 byinstitutional investors in the Southern District of New York and New York statecourt, respectively. In addition, Park Royal I LLC and Park Royal II LLC havefiled complaints in New York state court alleging Wells Fargo Bank, N.A., astrustee, failed to take appropriate actions upon learning of defective mortgageloan documentation. In March 2021, the Company entered into an agreement toresolve the case filed by the NCUA.

 

Inaddition to the foregoing cases, in August 2014 and August 2015 Nomura Credit& Capital Inc. (“Nomura”) and Natixis Real Estate Holdings, LLC (“Natixis”)filed a total of seven third-party complaints against Wells Fargo Bank in NewYork state court. In the underlying first-party actions, Nomura and Natixishave been sued for alleged breaches of representations and warranties made inconnection with residential mortgage-backed securities sponsored by them. Inthe third-party actions, Nomura and Natixis allege that Wells Fargo Bank, asmaster servicer, primary servicer or securities administrator, failed to notifyNomura and Natixis of their own breaches, failed to properly oversee theprimary servicers, and failed to adhere to accepted servicing practices.Natixis additionally alleges that Wells Fargo Bank failed to perform defaultoversight duties. Wells Fargo Bank has asserted counterclaims alleging thatNomura and Natixis failed to provide Wells Fargo Bank notice of theirrepresentation and warranty breaches.

 

Withrespect to each of the foregoing litigations, Wells Fargo Bank believesplaintiffs' claims are without merit and intends to contest the claimsvigorously, but there can be no assurances as to the outcome of the litigationsor the possible impact of the litigations on Wells Fargo Bank or the relatedRMBS trusts.

 

OnFebruary 14, 2022, Cantor Commercial Real Estate Lending, L.P. (“CCRE”) wasnamed as a defendant in a lawsuit captioned Kingsbridge 2005, LLC, ShelbourneBroad Street, LLC and 691 Central Avenue SPE LLC v Cantor Commercial RealEstate Lending, L.P., and KKR Real Estate Credit Opportunity PartnersAggregator I L.P., and Midland Loan Services, Inc., Index No. 650687/2002,filed in the Supreme Court of the State of New York, County of New York. Plaintiff seeks recission of a $93 million loan issued by CCRE in September2018 and subsequently sold into four commercial mortgage backed securitiestransactions on the theory of unilateral mistake.  Plaintiff claims itdiscovered the issue when it was denied partial defeasance of one property thatserved as collateral for the loan.  The case is in the early stages. At this point, CCRE does not believe the outcome of the case would have amaterial impact on CCRE’s obligations with respect to the loan or on certificateholders, although no assurance can be given that it will not have a materialimpact on certificate holders.

 

**Item1119 of Regulation AB, Affiliations and Certain Relationships and RelatedTransactions.**

 

Theinformation regarding this Item has been provided previously in an annualreport on Form 10-K of the issuing entity or in the prospectus of the issuingentity filed in a 424(b)(2) filing dated March 12, 2019. 

 

**Item1122 of Regulation AB, Compliance with Applicable Servicing Criteria.**

 

Thereports on assessment of compliance with the servicing criteria forasset-backed securities and the related attestation reports on such assessmentsof compliance are attached hereto under Item 15.

 

**Item1123 of Regulation AB, Servicer Compliance Statement.**

 

Theservicer compliance statements are attached hereto under Item 15.

 

 

**PART IV**

 

**Item15. Exhibits, Financial Statement Schedules.**

 

(a) Exhibits.

 

(4.1)Pooling and Servicing Agreement, dated as of March 1,2019, between Morgan Stanley Capital I Inc., as depositor, Midland LoanServices, a Division of PNC Bank, National Association, as master servicer,Rialto Capital Advisors, LLC, as special servicer, Wells Fargo Bank, NationalAssociation, as certificate administrator and trustee, and PentalphaSurveillance LLC, as operating advisor and as asset representations reviewer(filed as Exhibit 4.1 to the registrant's Current Report on Form 8-K/A filed onFebruary 24, 2020 under SEC File No. 333-227446-02 and incorporated byreference herein).

 

(4.2)Pooling and Servicing Agreement, dated as of February1, 2019, between Wells Fargo Commercial Mortgage Securities, Inc., asdepositor, Wells Fargo Bank, National Association, as general master servicer,KeyBank National Association, as general special servicer, National CooperativeBank, N.A., as NCB master servicer and NCB special servicer, Wilmington Trust,National Association, as trustee, Wells Fargo Bank, National Association, ascertificate administrator, and Park Bridge Lender Services LLC, as operatingadvisor and as asset representations reviewer, relating to the BANK 2019-BNK16securitization transaction, pursuant to which the One AT&T Mortgage Loanand the Residence Inn National Portfolio Mortgage Loan are serviced (filed asExhibit 4.2 to the registrant's Current Report on Form 8-K filed on March 12,2019 under SEC File No. 333-227446-02 and incorporated by reference herein).

 

(4.3)Trust and Servicing Agreement, dated as of February 6,2019, between CCRE Commercial Mortgage Securities, L.P., as depositor, KeyBankNational Association, as servicer and special servicer, and Wells Fargo Bank,National Association, as trustee, certificate administrator and custodian,relating to the CFK Trust 2019-FAX securitization transaction, pursuant towhich the Fairfax Multifamily Portfolio Mortgage Loan is serviced (filed asExhibit 4.3 to the registrant's Current Report on Form 8-K filed on March 12,2019 under SEC File No. 333-227446-02 and incorporated by reference herein).

 

(4.4) Pooling and Servicing Agreement, dated as of December1, 2018, between Barclays Commercial Mortgage Securities LLC, as depositor,Wells Fargo Bank, National Association, as master servicer, LNR Partners, LLC,as special servicer, Wilmington Trust, National Association, as trustee, WellsFargo Bank, National Association, as certificate administrator, and Park BridgeLender Services LLC, as operating advisor and as asset representationsreviewer, relating to the BBCMS Mortgage Trust 2018-C2 securitizationtransaction, pursuant to which the Fidelis Portfolio Mortgage Loan is serviced(filed as Exhibit 4.4 to the registrant's Current Report on Form 8-K filed onMarch 12, 2019 under SEC File No. 333-227446-02 and incorporated by referenceherein).

 

(4.5)Pooling and Servicing Agreement, dated as of December1, 2018, between Wells Fargo Commercial Mortgage Securities, Inc., asdepositor, Wells Fargo Bank, National Association, as master servicer, LNRPartners, LLC, as special servicer, Wilmington Trust, National Association, astrustee, Wells Fargo Bank, National Association, as certificate administrator,and Pentalpha Surveillance LLC, as operating advisor and as assetrepresentations reviewer, relating to the WFCM 2018-C48 securitizationtransaction, pursuant to which the Sheraton Grand Nashville Downtown MortgageLoan is serviced (filed as Exhibit 4.5 to the registrant's Current Report onForm 8-K filed on March 12, 2019 under SEC File No. 333-227446-02 andincorporated by reference herein).

  

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

 

(33)  Reports on assessment of compliance withservicing criteria for asset-backed securities.

 

33.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

33.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator (from 11/1/21to 12/31/21)

 

33.3 Wells Fargo Bank, National Association, as Custodian

 

33.4 Computershare Trust Company, National Association, as ServicingFunction Participant for the Custodian (from 11/1/21 to 12/31/21)

 

33.5 Midland Loan Services,a Division of PNC Bank, National Association, as Master Servicer

 

33.6 Rialto CapitalAdvisors, LLC, as Special Servicer

 

33.7 Pentalpha SurveillanceLLC, as Operating Advisor

 

33.8 Berkeley Point CapitalLLC, as Primary Servicer

 

33.9 Wells Fargo Bank,National Association, as Master Servicer under the BANK 2019-BNK16securitization, pursuant to which the following mortgage loans were serviced bysuch party: One AT&T (from 1/1/21 to 12/31/21) and Residence Inn NationalPortfolio (from 1/1/21 to 12/31/21)

 

33.10 CoreLogic Solutions,LLC, as Servicing Function Participant under the BANK 2019-BNK16securitization, pursuant to which the following mortgage loans were serviced bysuch party: One AT&T (from 1/1/21 to 12/31/21) and Residence Inn NationalPortfolio (from 1/1/21 to 12/31/21)

 

33.11 Wells Fargo Bank,National Association, as Master Servicer under the BBCMS 2018-C2securitization, pursuant to which the following mortgage loans were serviced bysuch party: Fidelis Portfolio (from 1/1/21 to 12/31/21) (See exhibit 33.9)

 

33.12 CoreLogic Solutions,LLC, as Servicing Function Participant under the BBCMS 2018-C2 securitization,pursuant to which the following mortgage loans were serviced by such party:Fidelis Portfolio (from 1/1/21 to 12/31/21) (See exhibit 33.10)

 

33.13 Wells Fargo Bank,National Association, as Master Servicer under the WFCM 2018-C48securitization, pursuant to which the following mortgage loans were serviced bysuch party: Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21) (Seeexhibit 33.9)

 

33.14 CoreLogic Solutions,LLC, as Servicing Function Participant under the WFCM 2018-C48 securitization,pursuant to which the following mortgage loans were serviced by such party:Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21) (See exhibit 33.10)

 

33.15 KeyBank NationalAssociation, as Special Servicer under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party: OneAT&T (from 1/1/21 to 12/31/21) and Residence Inn National Portfolio (from1/1/21 to 12/31/21)

 

33.16 KeyBank NationalAssociation, as Special Servicer under the CFK 2019-FAX securitization,pursuant to which the following mortgage loans were serviced by such party:Fairfax Multifamily Portfolio (from 1/1/21 to 12/31/21) (See exhibit 33.15)

 

33.17 LNR Partners, LLC,as Special Servicer under the BBCMS 2018-C2 securitization, pursuant to whichthe following mortgage loans were serviced by such party: Fidelis Portfolio(from 1/1/21 to 12/31/21)

 

33.18 Argentic ServicesCompany LP, as Special Servicer under the WFCM 2018-C48 securitization,pursuant to which the following mortgage loans were serviced by such party:Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21)

 

33.19 Wells Fargo Bank,National Association, as Custodian under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party: OneAT&T (from 1/1/21 to 12/31/21) and Residence Inn National Portfolio (from1/1/21 to 12/31/21) (See exhibit 33.3)

 

33.20 Computershare TrustCompany, National Association, as Servicing Function Participant under the BANK2019-BNK16 securitization, pursuant to which the following mortgage loans wereserviced by such party: One AT&T (from 11/1/21 to 12/31/21) and ResidenceInn National Portfolio (from 11/1/21 to 12/31/21) (See exhibit 33.4)

 

33.21 Wells Fargo Bank,National Association, as Custodian under the CFK 2019-FAX securitization,pursuant to which the following mortgage loans were serviced by such party:Fairfax Multifamily Portfolio (from 1/1/21 to 12/31/21) (See exhibit 33.3)

 

33.22 Computershare TrustCompany, National Association, as Servicing Function Participant under the CFK2019-FAX securitization, pursuant to which the following mortgage loans wereserviced by such party: Fairfax Multifamily Portfolio (from 11/1/21 to12/31/21) (See exhibit 33.4)

 

33.23 Wells Fargo Bank,National Association, as Custodian under the BBCMS 2018-C2 securitization,pursuant to which the following mortgage loans were serviced by such party:Fidelis Portfolio (from 1/1/21 to 12/31/21) (See exhibit 33.3)

 

33.24 Computershare TrustCompany, National Association, as Servicing Function Participant under theBBCMS 2018-C2 securitization, pursuant to which the following mortgage loanswere serviced by such party: Fidelis Portfolio (from 11/1/21 to 12/31/21) (Seeexhibit 33.4)

 

33.25 Wells Fargo Bank,National Association, as Custodian under the WFCM 2018-C48 securitization,pursuant to which the following mortgage loans were serviced by such party:Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21) (See exhibit 33.3)

 

33.26 Computershare TrustCompany, National Association, as Servicing Function Participant under the WFCM2018-C48 securitization, pursuant to which the following mortgage loans wereserviced by such party: Sheraton Grand Nashville Downtown (from 11/1/21 to12/31/21) (See exhibit 33.4)

 

(34). Attestation reports on assessment of compliancewith servicing criteria for asset-backed securities.

 

34.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

34.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator (from 11/1/21to 12/31/21)

 

34.3 Wells Fargo Bank, National Association, as Custodian

 

34.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (from 11/1/21 to 12/31/21)

 

34.5 Midland Loan Services,a Division of PNC Bank, National Association, as Master Servicer

 

34.6 Rialto CapitalAdvisors, LLC, as Special Servicer

 

34.7 Pentalpha SurveillanceLLC, as Operating Advisor

 

34.8 Berkeley Point CapitalLLC, as Primary Servicer

 

34.9 Wells Fargo Bank,National Association, as Master Servicer under the BANK 2019-BNK16securitization, pursuant to which the following mortgage loans were serviced bysuch party: One AT&T (from 1/1/21 to 12/31/21) and Residence Inn NationalPortfolio (from 1/1/21 to 12/31/21)

 

34.10 CoreLogic Solutions,LLC, as Servicing Function Participant under the BANK 2019-BNK16securitization, pursuant to which the following mortgage loans were serviced bysuch party: One AT&T (from 1/1/21 to 12/31/21) and Residence Inn NationalPortfolio (from 1/1/21 to 12/31/21)

 

34.11 Wells Fargo Bank,National Association, as Master Servicer under the BBCMS 2018-C2securitization, pursuant to which the following mortgage loans were serviced bysuch party: Fidelis Portfolio (from 1/1/21 to 12/31/21) (See exhibit 34.9)

 

34.12 CoreLogic Solutions,LLC, as Servicing Function Participant under the BBCMS 2018-C2 securitization,pursuant to which the following mortgage loans were serviced by such party:Fidelis Portfolio (from 1/1/21 to 12/31/21) (See exhibit 34.10)

 

34.13 Wells Fargo Bank,National Association, as Master Servicer under the WFCM 2018-C48securitization, pursuant to which the following mortgage loans were serviced bysuch party: Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21) (Seeexhibit 34.9)

 

34.14 CoreLogic Solutions,LLC, as Servicing Function Participant under the WFCM 2018-C48 securitization,pursuant to which the following mortgage loans were serviced by such party:Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21) (See exhibit 34.10)

 

34.15 KeyBank NationalAssociation, as Special Servicer under the BANK 2019-BNK16 securitization, pursuantto which the following mortgage loans were serviced by such party: One AT&T(from 1/1/21 to 12/31/21) and Residence Inn National Portfolio (from 1/1/21 to12/31/21)

 

34.16 KeyBank National Association,as Special Servicer under the CFK 2019-FAX securitization, pursuant to whichthe following mortgage loans were serviced by such party: Fairfax MultifamilyPortfolio (from 1/1/21 to 12/31/21) (See exhibit 34.15)

 

34.17 LNR Partners, LLC,as Special Servicer under the BBCMS 2018-C2 securitization, pursuant to whichthe following mortgage loans were serviced by such party: Fidelis Portfolio(from 1/1/21 to 12/31/21)

 

34.18 Argentic ServicesCompany LP, as Special Servicer under the WFCM 2018-C48 securitization,pursuant to which the following mortgage loans were serviced by such party:Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21)

 

34.19 Wells Fargo Bank,National Association, as Custodian under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party: OneAT&T (from 1/1/21 to 12/31/21) and Residence Inn National Portfolio (from1/1/21 to 12/31/21) (See exhibit 34.3)

 

34.20 Computershare TrustCompany, National Association, as Servicing Function Participant under the BANK2019-BNK16 securitization, pursuant to which the following mortgage loans wereserviced by such party: One AT&T (from 11/1/21 to 12/31/21) and ResidenceInn National Portfolio (from 11/1/21 to 12/31/21) (See exhibit 34.4)

 

34.21 Wells Fargo Bank,National Association, as Custodian under the CFK 2019-FAX securitization,pursuant to which the following mortgage loans were serviced by such party:Fairfax Multifamily Portfolio (from 1/1/21 to 12/31/21) (See exhibit 34.3)

 

34.22 Computershare TrustCompany, National Association, as Servicing Function Participant under the CFK2019-FAX securitization, pursuant to which the following mortgage loans wereserviced by such party: Fairfax Multifamily Portfolio (from 11/1/21 to 12/31/21)(See exhibit 34.4)

 

34.23 Wells Fargo Bank,National Association, as Custodian under the BBCMS 2018-C2 securitization,pursuant to which the following mortgage loans were serviced by such party:Fidelis Portfolio (from 1/1/21 to 12/31/21) (See exhibit 34.3)

 

34.24 Computershare TrustCompany, National Association, as Servicing Function Participant under theBBCMS 2018-C2 securitization, pursuant to which the following mortgage loans wereserviced by such party: Fidelis Portfolio (from 11/1/21 to 12/31/21) (Seeexhibit 34.4)

 

34.25 Wells Fargo Bank,National Association, as Custodian under the WFCM 2018-C48 securitization,pursuant to which the following mortgage loans were serviced by such party:Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21) (See exhibit 34.3)

 

34.26 Computershare TrustCompany, National Association, as Servicing Function Participant under the WFCM2018-C48 securitization, pursuant to which the following mortgage loans wereserviced by such party: Sheraton Grand Nashville Downtown (from 11/1/21 to12/31/21) (See exhibit 34.4)

 

(35). Servicer compliance statement.

 

35.1 Wells Fargo Bank, National Association, as CertificateAdministrator

 

35.2 Computershare Trust Company, National Association, asServicing Function Participant for the Certificate Administrator (from 11/1/21to 12/31/21)

 

35.3 Wells Fargo Bank, National Association, as Custodian

 

35.4 Computershare Trust Company, National Association, asServicing Function Participant for the Custodian (from 11/1/21 to 12/31/21)

 

35.5 Midland LoanServices, a Division of PNC Bank, National Association, as Master Servicer

 

35.6 Rialto CapitalAdvisors, LLC, as Special Servicer

 

35.7 Berkeley PointCapital LLC, as Primary Servicer

 

35.8 Wells Fargo Bank, NationalAssociation, as Master Servicer under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party: OneAT&T (from 1/1/21 to 12/31/21) and Residence Inn National Portfolio (from1/1/21 to 12/31/21)

 

35.9 Wells Fargo Bank,National Association, as Master Servicer under the BBCMS 2018-C2securitization, pursuant to which the following mortgage loans were serviced bysuch party: Fidelis Portfolio (from 1/1/21 to 12/31/21) (See exhibit 35.8)

 

35.10 Wells Fargo Bank,National Association, as Master Servicer under the WFCM 2018-C48securitization, pursuant to which the following mortgage loans were serviced bysuch party: Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21) (Seeexhibit 35.8)

 

35.11 KeyBankNational Association, as Special Servicer under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party: OneAT&T (from 1/1/21 to 12/31/21) and Residence Inn National Portfolio (from1/1/21 to 12/31/21)

 

35.12 KeyBank NationalAssociation, as Special Servicer under the CFK 2019-FAX securitization,pursuant to which the following mortgage loans were serviced by such party:Fairfax Multifamily Portfolio (from 1/1/21 to 12/31/21) (See exhibit 35.11)

 

35.13 LNR Partners, LLC,as Special Servicer under the BBCMS 2018-C2 securitization, pursuant to whichthe following mortgage loans were serviced by such party: Fidelis Portfolio(from 1/1/21 to 12/31/21)

 

35.14 Argentic ServicesCompany LP, as Special Servicer under the WFCM 2018-C48 securitization,pursuant to which the following mortgage loans were serviced by such party:Sheraton Grand Nashville Downtown (from 1/1/21 to 12/31/21)

 

35.15 Wells Fargo Bank,National Association, as Custodian under the BANK 2019-BNK16 securitization,pursuant to which the following mortgage loans were serviced by such party: OneAT&T (from 1/1/21 to 12/31/21) and Residence Inn National Portfolio (from 1/1/21to 12/31/21) (See exhibit 35.3)

 

35.16 Computershare TrustCompany, National Association, as Servicing Function Participant under the BANK2019-BNK16 securitization, pursuant to which the following mortgage loans wereserviced by such party: One AT&T (from 11/1/21 to 12/31/21) and ResidenceInn National Portfolio (from 11/1/21 to 12/31/21) (See exhibit 35.4)

 

35.17 Wells Fargo Bank,National Association, as Custodian under the CFK 2019-FAX securitization,pursuant to which the following mortgage loans were serviced by such party:Fairfax Multifamily Portfolio (from 1/1/21 to 12/31/21) (See exhibit 35.3)

 

35.18 Computershare TrustCompany, National Association, as Servicing Function Participant under the CFK2019-FAX securitization, pursuant to which the following mortgage loans wereserviced by such party: Fairfax Multifamily Portfolio (from 11/1/21 to12/31/21) (See exhibit 35.4)

 

35.19 Wells Fargo Bank,National Association, as Custodian under the BBCMS 2018-C2 securitization,pursuant to which the following mortgage loans were serviced by such party:Fidelis Portfolio (from 1/1/21 to 12/31/21) (See exhibit 35.3)

 

35.20 Computershare TrustCompany, National Association, as Servicing Function Participant under theBBCMS 2018-C2 securitization, pursuant to which the following mortgage loanswere serviced by such party: Fidelis Portfolio (from 11/1/21 to 12/31/21) (Seeexhibit 35.4)

 

35.21 Wells Fargo Bank,National Association, as Custodian under the WFCM 2018-C48 securitization, pursuantto which the following mortgage loans were serviced by such party: SheratonGrand Nashville Downtown (from 1/1/21 to 12/31/21) (See exhibit 35.3)

 

35.22 Computershare TrustCompany, National Association, as Servicing Function Participant under the WFCM2018-C48 securitization, pursuant to which the following mortgage loans wereserviced by such party: Sheraton Grand Nashville Downtown (from 11/1/21 to12/31/21) (See exhibit 35.4)

 

(99.1)Mortgage Loan Purchase Agreement, dated March 1, 2019,between Morgan Stanley Capital I Inc. and Morgan Stanley Mortgage CapitalHoldings LLC (filed as Exhibit 99.1 to the registrant's Current Report on Form8-K filed on March 12, 2019 under SEC File No. 333-227446-02 and incorporatedby reference herein).

 

(99.2)Mortgage Loan Purchase Agreement, dated March 1, 2019,between Morgan Stanley Capital I Inc. and Argentic Real Estate Finance LLC(filed as Exhibit 99.2 to the registrant's Current Report on Form 8-K filed onMarch 12, 2019 under SEC File No. 333-227446-02 and incorporated by referenceherein).

 

(99.3) Mortgage Loan Purchase Agreement, dated March 1, 2019,between Morgan Stanley Capital I Inc. and Starwood Mortgage Capital LLC (filedas Exhibit 99.3 to the registrant's Current Report on Form 8-K filed on March12, 2019 under SEC File No. 333-227446-02 and incorporated by reference herein).

 

(99.4)Mortgage Loan Purchase Agreement, dated March 1, 2019,between Morgan Stanley Capital I Inc. and Cantor Commercial Real EstateLending, L.P. (filed as Exhibit 99.4 to the registrant's Current Report on Form8-K filed on March 12, 2019 under SEC File No. 333-227446-02 and incorporatedby reference herein).

 

(99.5)Mortgage Loan Purchase Agreement, dated March 1, 2019,between Morgan Stanley Capital I Inc., BSPRT CMBS Finance, LLC and BenefitStreet Partners Realty Trust, Inc. (filed as Exhibit 99.5 to the registrant'sCurrent Report on Form 8-K filed on March 12, 2019 under SEC File No.333-227446-02 and incorporated by reference herein).

 

(99.6)Agreement Between Note Holders, dated as of February 8,2019, by and between Morgan Stanley Bank, N.A., as initial note A-1 holder andMorgan Stanley Bank, N.A., as initial note A-2 holder, relating to the OneAT&T loan combination (filed as Exhibit 99.6 to the registrant's CurrentReport on Form 8-K filed on March 12, 2019 under SEC File No. 333-227446-02 andincorporated by reference herein).

 

(99.7)Intercreditor Agreement, dated as of February 1, 2019,by and between Morgan Stanley Bank, N.A., as note A holder, Sun Life AssuranceCompany of Canada, as note B-1 holder, and Sun Life Hong Kong Limited, as noteB-2 holder, relating to the Serenity Apartments loan combination (filed asExhibit 99.7 to the registrant's Current Report on Form 8-K filed on March 12,2019 under SEC File No. 333-227446-02 and incorporated by reference herein).

 

(99.8)Co-lender Agreement, dated as of February 6, 2019, by andamong Cantor Commercial Real Estate Lending, L.P., as initial note A-1-Sholder, initial note A-1-C1 holder, initial note A-1-C2 holder, initial noteA-1-C3 holder, initial note A-1-C4 holder and initial note B-1-S holder, andKeyBank National Association, as initial note A-2-S holder, initial note A-2-C1holder and initial note B-2-S holder, relating to the Fairfax MultifamilyPortfolio loan combination (filed as Exhibit 99.8 to the registrant's CurrentReport on Form 8-K filed on March 12, 2019 under SEC File No. 333-227446-02 andincorporated by reference herein).

 

(99.9)Co-lender Agreement, dated as of March 12, 2019, by andbetween Cantor Commercial Real Estate Lending, L.P. as note A-1 holder, CantorCommercial Real Estate Lending, L.P. as note A-2 holder, Cantor Commercial RealEstate Lending, L.P. as note A-3 holder and Cantor Commercial Real EstateLending, L.P. as note A-4 holder, relating to the Stern Multifamily Portfolioloan combination (filed as Exhibit 99.9 to the registrant's Current Report onForm 8-K filed on March 12, 2019 under SEC File No. 333-227446-02 andincorporated by reference herein).

 

(99.10) Co-lender Agreement, dated as of October 5, 2018, byand among Starwood Mortgage Capital LLC as initial note A-1 holder, StarwoodMortgage Capital LLC as initial note A-2 holder and Starwood Mortgage CapitalLLC as initial note A-3 holder, relating to the Fidelis Portfolio loancombination (filed as Exhibit 99.10 to the registrant's Current Report on Form8-K filed on March 12, 2019 under SEC File No. 333-227446-02 and incorporatedby reference herein).

 

(99.11)Agreement Between Note Holders, dated as of November 6,2018, by and between SPREF WH II LLC as initial note A-1 holder, initial noteA-2 holder, initial note A-3 holder, initial note A-4 holder, initial note A-5holder, initial note A-6 holder, initial note A-7 holder and initial note A-8holder, relating to the Sheraton Grand Nashville Downtown loan combination (filedas Exhibit 99.11 to the registrant's Current Report on Form 8-K filed on March12, 2019 under SEC File No. 333-227446-02 and incorporated by reference herein).

 

(99.12)Co-lender Agreement, dated as of November 26, 2018, byand between Starwood Mortgage Capital LLC as initial note A-1 holder andStarwood Mortgage Capital LLC, as initial note A-2 holder, relating to the 1001Frontier Road loan combination (filed as Exhibit 99.12 to the registrant'sCurrent Report on Form 8-K filed on March 12, 2019 under SEC File No.333-227446-02 and incorporated by reference herein).

 

(99.13)Agreement Between Note Holders, dated as of February 8,2019, by and between Morgan Stanley Bank, N.A., as initial note A-1-A holder,Morgan Stanley Bank, N.A., as initial note A-1-B holder and Morgan StanleyBank, N.A., as initial note A-2 holder, relating to the Residence Inn NationalPortfolio loan combination (filed as Exhibit 99.13 to the registrant's CurrentReport on Form 8-K filed on March 12, 2019 under SEC File No. 333-227446-02 andincorporated by reference herein).

 

(99.14)Primary Servicing Agreement, dated as of March 1, 2019,by and between Midland Loan Services, a Division of PNC Bank, NationalAssociation, as master servicer, and Berkeley Point Capital LLC d/b/a NewmarkKnight Frank, as primary servicer (filed as Exhibit 99.14 to the registrant'sCurrent Report on Form 8-K filed on March 12, 2019 under SEC File No.333-227446-02 and incorporated by reference herein).

 

(99.15)Second Amended and Restated Servicing Agreement, effectiveas of October 31, 2021, between Wells Fargo Bank, N.A., Wells Fargo DelawareTrust Company, N.A., Computershare Trust Company, N.A., Computershare DelawareTrust Company and Computershare Limited (filed as Exhibit 99.1 to theregistrant's Current Report on Form 8-K filed on November 5, 2021 under SECFile No. 333-227446-02 and incorporated by reference herein).

 

(b)See (a) above.

 

(c) NotApplicable.

 

**SIGNATURES**

 

Pursuantto the requirements of Section 13 or 15(d) of the Securities Exchange Act of1934, the registrant has duly caused this report to be signed on its behalf bythe undersigned, thereunto duly authorized.

 

MorganStanley Capital I Inc.

(Depositor)

 

By:/s/ Jane Lam

JaneLam, President

(seniorofficer in charge of securitization of the depositor)

 

Date: March 30, 2022