**UNITED STATESSECURITIES AND EXCHANGE COMMISSION**

**Washington, D.C. 20549**

**FORM 10-K**

(Mark One)

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

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

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

**For the transition period from _____ to _____Commission file number of the issuing entity: 333-226486-02**

**Central Index Key Number of the issuing entity:0001757928**

**Wells Fargo Commercial MortgageTrust 2018-C48**

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

** **

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

**Wells Fargo Commercial MortgageSecurities, Inc.**

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

** **

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

**Wells Fargo Bank, NationalAssociation**

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

** **

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

**Argentic Real Estate Finance LLC**

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

** **

**Central Index Key Number of the sponsor: 0000312070**

**Barclays Bank PLC**

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

** **

**Central Index Key Number of the sponsor: 0001542105**

**Basis Real Estate Capital II, LLC**

**(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****(State or other jurisdiction of  incorporation or organization of**

**the issuing entity)** | **38-4096511**

**38-4096512**

**38-7206273**

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

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

**c/o Wells Fargo Bank, National Association**

**as Certificate Administrator**

**9062 Old Annapolis Road**

**Columbia, MD**

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

**21045**

**(Zip Code)**

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

**(704) 374-6161**

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

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

 

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

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

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

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

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

Not applicable.

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

Not applicable.

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

Large acceleratedfiler        o                                                                                                       Acceleratedfiler                                     o

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

                                                                                                                                                       Emerging growthcompany                    o

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

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

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

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

Not applicable.

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

Not applicable.

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

Not applicable.

**DOCUMENTS INCORPORATED BY REFERENCE**

** **

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

Not applicable.

 

** **

**EXPLANATORY NOTES**

The Sheraton Grand Nashville Downtown MortgageLoan, the Danbury Commerce Portfolio Mortgage Loan and the Lakeside Pointe& Fox Club Apartments Mortgage Loan, which constituted approximately 7.2%,2.7% and 1.9%, respectively, of the asset pool of the issuing entity as of itscut-off date, are each an asset of the issuing entity and are each part of aloan combination that includes (a) with respect to the Sheraton Grand NashvilleDowntown Mortgage Loan, five other *pari passu* loans, which are notassets of the issuing entity, (b) with respect to the Danbury Commerce PortfolioMortgage Loan, one other *pari passu* loan, which is not an asset of theissuing entity and (c) with respect to the Lakeside Pointe & Fox ClubApartments Mortgage Loan, one other *pari passu* loan, which is not anasset of the issuing entity. These loan combinations, including the SheratonGrand Nashville Downtown Mortgage Loan, the Danbury Commerce Portfolio MortgageLoan and the Lakeside Pointe & Fox Club Apartments 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 Fair Oaks Mall Mortgage Loan, whichconstituted approximately 1.1% of the asset pool of the issuing entity as ofits cut-off date.  The Fair Oaks Mall Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the Fair OaksMall Mortgage Loan, five other *pari passu* loans and two subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the BANK 2018-BNK12transaction, Commission File Number 333-206847-09 (the “BANK 2018-BNK12Transaction”). This loan combination, including the Fair Oaks Mall MortgageLoan, is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2018-BNK12 Transaction, which is incorporated byreference as Exhibit 4.2 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Aventura Mall Mortgage Loan, whichconstituted approximately 2.4% of the asset pool of the issuing entity as ofits cut-off date.  The Aventura Mall Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the AventuraMall Mortgage Loan, twenty-five other *pari passu* loans and four subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the Aventura Mall Trust2018-AVM transaction (the “Aventura Mall Trust 2018-AVM Transaction”).This loan combination, including the Aventura Mall Mortgage Loan, is beingserviced and administered pursuant to the trust and servicing agreement for theAventura Mall Trust 2018-AVM Transaction, which is incorporated by reference asExhibit 4.3 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Christiana Mall Mortgage Loan, whichconstituted approximately 3.4% of the asset pool of the issuing entity as ofits cut-off date.  The Christiana Mall Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the ChristianaMall Mortgage Loan, twelve other *pari passu* loans and three subordinatecompanion loans, which are not assets of the issuing entity. A *pari passu*portion of the loan combination was securitized in the BBCMS 2018-CHRS MortgageTrust transaction (the “BBCMS 2018-CHRS Transaction”). This loancombination, including the Christiana Mall Mortgage Loan, is being serviced andadministered pursuant to the trust and servicing agreement for the BBCMS2018-CHRS Transaction, which is incorporated by reference as Exhibit 4.4 tothis Annual Report on Form 10-K.

The Exhibit Index describes exhibitsprovided by certain parties (in their capacities indicated on the ExhibitIndex) with respect to the Prudential - Digital Realty Portfolio Mortgage Loan,which constituted approximately 3.0% of the asset pool of the issuing entity asof its cut-off date.  The Prudential - Digital Realty Portfolio MortgageLoan is an asset of the issuing entity and is part of a loan combination thatincludes the Prudential - Digital Realty Portfolio Mortgage Loan and five other*pari passu* loans, which are not assets of the issuing entity. A *paripassu* portion of the loan combination was securitized in the BANK2018-BNK14 transaction, Commission File Number 333-206582-16 (the “BANK2018-BNK14 Transaction”). This loan combination, including the Prudential -Digital Realty Portfolio Mortgage Loan, is being serviced and administeredpursuant to the pooling and servicing agreement for the BANK 2018-BNK14Transaction, which is incorporated by reference as Exhibit 4.5 to this AnnualReport on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Starwood Hotel Portfolio Mortgage Loan andthe Virginia Beach Hotel Portfolio Mortgage Loan, which constitutedapproximately 3.6% and 1.8%, respectively, of the asset pool of the issuingentity as of its cut-off date.  The Starwood Hotel Portfolio Mortgage Loanand the Virginia Beach Hotel Portfolio Mortgage Loan are each an asset of theissuing entity and are each part of a loan combination that includes (a) withrespect to the Starwood Hotel Portfolio Mortgage Loan, three other *paripassu* loans, which are not assets of the issuing entity or (b) with respectto the Virginia Beach Hotel Portfolio Mortgage Loan, two other *pari passu*loans, which are not assets of the issuing entity. A *pari passu* portionof each loan combination was securitized in the Wells Fargo Commercial MortgageTrust 2018-C47 transaction, Commission File Number 333-226486-01 (the “WFCM2018-C47 Transaction”). These loan combinations, including the StarwoodHotel Portfolio Mortgage Loan and the Virginia Beach Hotel Portfolio MortgageLoan, are being serviced and administered pursuant to the pooling and servicingagreement for the WFCM 2018-C47 Transaction, which is incorporated by referenceas Exhibit 4.6 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Liberty Portfolio Mortgage Loan, whichconstituted approximately 1.5% of the asset pool of the issuing entity as ofits cut-off date.  The Liberty Portfolio Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the LibertyPortfolio Mortgage Loan and seven other *pari passu* loans, which are notassets of the issuing entity. A *pari passu* portion of the loancombination was securitized in the Benchmark 2018-B7 Mortgage Trusttransaction, Commission File Number 333-226943-01 (the “Benchmark 2018-B7Transaction”). This loan combination, including the Liberty PortfolioMortgage Loan, is being serviced and administered pursuant to the pooling andservicing agreement for the Benchmark 2018-B7 Transaction, which isincorporated by reference as Exhibit 4.7 to this Annual Report on Form 10-K.

The Exhibit Index describesexhibits provided by certain parties (in their capacities indicated on theExhibit Index) with respect to the Home Depot Technology Center Mortgage Loan,which constituted approximately 1.7% of the asset pool of the issuing entity asof its cut-off date.  The Home Depot Technology Center Mortgage Loan is anasset of the issuing entity and is part of a loan combination that includes theHome Depot Technology 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 BBCMS Mortgage Trust2018-C2 transaction, Commission File Number 333-226850-01 (the “BBCMS2018-C2 Transaction”). This loan combination, including the Home DepotTechnology Center Mortgage Loan, is being serviced and administered pursuant tothe pooling and servicing agreement for the BBCMS 2018-C2 Transaction, which isincorporated by reference as Exhibit 4.8 to this Annual Report on Form 10-K.

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

Wells Fargo Bank, NationalAssociation is the master servicer and certificate administrator of themortgage loans serviced under the Pooling and Servicing Agreement, the primaryservicer of the Starwood Hotel Portfolio Mortgage Loan, the Prudential -Digital Realty Portfolio Mortgage Loan, the Aventura Mall Mortgage Loan, theVirginia Beach Hotel Portfolio Mortgage Loan, the Home Depot Technology CenterMortgage Loan and the Fair Oaks Mall Mortgage Loan and the primary servicer andspecial servicer of the Christiana Mall Mortgage Loan. As a result, Wells FargoBank, National Association is a “servicer” as defined in Item 1108(a)(2)(iii)of Regulation AB, in the capacities described above, because it is servicingmortgage loans that constituted 10% or more of the assets of the issuing entityas of its cut-off date. The assessments of compliance with applicable servicingcriteria, accountants’ attestation reports and servicer compliance statementsdelivered by Wells Fargo Bank, National Association in the capacities describedabove are listed in the Exhibit Index.

Wells Fargo Bank, National Association is the custodian ofthe mortgage loans serviced under the Pooling and Servicing Agreement, theStarwood Hotel Portfolio Mortgage Loan, the Christiana Mall Mortgage Loan, thePrudential - Digital Realty Portfolio Mortgage Loan, the Aventura Mall MortgageLoan, the Virginia Beach Hotel Portfolio Mortgage Loan, the Home DepotTechnology Center Mortgage Loan, the Liberty Portfolio Mortgage Loan and theFair Oaks Mall Mortgage Loan.  As a result, Wells Fargo Bank, NationalAssociation is a servicing function participant in the capacities describedabove, because it is servicing mortgage loans that constituted 5% or more ofthe assets of the issuing entity as of its cut-off date. The assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports delivered by Wells Fargo Bank, National Association in the capacitiesdescribed above are listed in the Exhibit Index.

Midland Loan Services, a Division of PNC Bank, NationalAssociation is the special servicer of the Starwood Hotel Portfolio MortgageLoan and the Virginia Beach Hotel Portfolio Mortgage Loan. These mortgage loansconstitute more than 5%, but less than 10%, of the pool assets of the issuingentity. Therefore, the Depositor included in this Annual Report on Form 10-K anassessment of compliance with applicable servicing criteria for Midland LoanServices, a Division of PNC Bank, National Association and an accountants’attestation report pursuant to Item 1122 of Regulation AB because Midland LoanServices, a Division of PNC Bank, National Association is servicing more than5% of the pool assets. However, the Depositor is not required to include inthis Annual Report on Form 10-K a servicer compliance statement pursuant toItem 1123 of Regulation AB of Midland Loan Services, a Division of PNC Bank,National Association because Midland Loan Services, a Division of PNC Bank,National Association is an unaffiliated servicer servicing less than 10% of thepool assets.

Park Bridge Lender Services LLC is the operating advisor ofthe Starwood Hotel Portfolio Mortgage Loan, the Prudential - Digital RealtyPortfolio Mortgage Loan, the Aventura Mall Mortgage Loan, the Virginia BeachHotel Portfolio Mortgage Loan, the Home Depot Technology Center Mortgage Loan,the Liberty Portfolio Mortgage Loan and the Fair Oaks Mall Mortgage Loan. As a result, Park Bridge Lender Services LLC is a servicing functionparticipant in the capacities described above, because it is servicing mortgageloans that constituted 5% or more of the assets of the issuing entity as of itscut-off date. The assessments of compliance with applicable servicing criteriaand accountants’ attestation reports delivered by Park Bridge Lender ServicesLLC in the capacities described above are listed in the Exhibit Index.

Wells Fargo Bank, NationalAssociation acts as trustee of the Liberty Portfolio Mortgage Loan. Pursuant to the pooling and servicing agreement for the Benchmark 2018-B7Transaction, 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 Liberty Portfolio Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(d)(2)(iii) of Regulation AB.

Wilmington Trust, NationalAssociation acts as trustee of the mortgage loans serviced under the Poolingand Servicing Agreement, the Fair Oaks Mall Mortgage Loan, the Aventura MallMortgage Loan, the Christiana Mall Mortgage Loan, the Prudential - DigitalRealty Portfolio Mortgage Loan, the Starwood Hotel Portfolio Mortgage Loan, theVirginia Beach Hotel Portfolio Mortgage Loan and the Home Depot TechnologyCenter Mortgage Loan.  Pursuant to the Pooling and Servicing Agreement,the pooling and servicing agreement for the BANK 2018-BNK12 Transaction, thetrust and servicing agreement for the Aventura Mall Trust 2018-AVM Transaction,the trust and servicing agreement for the BBCMS 2018-CHRS Transaction, thepooling and servicing agreement for the BANK 2018-BNK14 Transaction, thepooling and servicing agreement for the WFCM 2018-C47 Transaction and thepooling and servicing agreement for the BBCMS 2018-C2 Transaction, the trusteeis required to provide an assessment of compliance with applicable servicing criteriasolely with respect to Item 1122(d)(2)(iii) of Regulation AB (regardingadvances of funds or guarantees regarding collections, cash flows ordistributions, and any interest or other fees charged for such advances, aremade, reviewed and approved as specified in the transaction agreements).However, during the reporting period, the trustee did not perform any servicingfunction with respect to the servicing criteria specified in Item1122(d)(2)(iii) of Regulation AB.  The master servicer or the specialservicer, to the extent required, performed the servicing function identifiedwith respect to Item 1122(d)(2)(iii) of Regulation AB, and each such partyincluded Item 1122(d)(2)(iii) of Regulation AB in the assessment of compliancewith applicable servicing criteria and accountant’s attestation report for thesubject transaction.  As a result, this Annual Report on Form 10-K doesnot include an assessment of compliance with applicable servicing criteria ofthe trustee. One or more other servicers of  the mortgage loans servicedunder the Pooling and Servicing Agreement, the Fair Oaks Mall Mortgage Loan,the Aventura Mall Mortgage Loan, the Christiana Mall Mortgage Loan, thePrudential - Digital Realty Portfolio Mortgage Loan, the Starwood HotelPortfolio Mortgage Loan, the Virginia Beach Hotel Portfolio Mortgage Loan andthe Home Depot Technology Center Mortgage Loan have delivered one or moreassessments of compliance with respect to Item 1122(d)(2)(iii) of RegulationAB.

This Annual Report on Form 10-K includesassessments of compliance with applicable servicing criteria and accountants’attestation reports from CoreLogic Solutions, LLC.  This entity wasengaged by the master servicer under the Pooling and Servicing Agreement andthe primary servicer of the Fair Oaks Mall Mortgage Loan, the Aventura MallMortgage Loan, the Christiana Mall Mortgage Loan, the Prudential - DigitalRealty Portfolio Mortgage Loan, the Starwood Hotel Portfolio Mortgage Loan, theVirginia Beach Hotel Portfolio Mortgage Loan and the Home Depot TechnologyCenter Mortgage Loan to remit tax payments received from the escrow accounts ofborrowers to local taxing authorities, to report tax amounts due, to verify taxparcel information, and to verify non-escrow tax payments. These servicingfunctions are included within the servicing criteria set forth in 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 Fair Oaks Mall Mortgage Loan, the Aventura Mall MortgageLoan, the Christiana Mall Mortgage Loan, the Prudential - Digital RealtyPortfolio Mortgage Loan, the Starwood Hotel Portfolio Mortgage Loan, theVirginia Beach Hotel Portfolio Mortgage Loan, the Liberty Portfolio MortgageLoan and the Home Depot Technology Center Mortgage Loan are omitted from thisAnnual Report on Form 10-K as the certificate administrator pursuant to therelated pooling and servicing agreement or trust and servicing agreement doesnot perform any activities that address servicing criteria with respect to theissuing entity and because they are each not a “servicer” that meets thecriteria in Item 1108(a)(2)(i) through (iii) of Regulation AB.

With respect to the pari passuloan combinations that includes the Liberty Portfolio Mortgage Loan, thePrudential-Digital Realty Portfolio Mortgage Loan, the Aventura Mall MortgageLoan, the Fair Oaks Mall Mortgage Loan, the Starwood Hotel Portfolio MortgageLoan and the Virginia Beach Hotel Portfolio Mortgage Loan, (i) the reports onassessment of compliance with servicing criteria and attestation reports onassessment of compliance with servicing criteria of KeyBank National Association,as primary servicer of the Liberty Portfolio Mortgage Loan, Rialto CapitalAdvisors, LLC, as special servicer of the Prudential-Digital Realty PortfolioMortgage Loan, CWCapital Asset Management LLC, as special servicer of theAventura Mall Mortgage Loan, AEGON USA Realty Advisors, LLC as special servicerfor the Fair Oaks Mall Mortgage Loan prior to March 12, 2021 and SitusHoldings, LLC as special servicer for the Fair Oaks Mall Mortgage Loan on andafter March 12, 2021 listed on the Exhibit Index are omitted from this AnnualReport on Form 10-K as they are not required to be included on this AnnualReport on Form 10-K per Instruction 3 to Item 1122 of Regulation AB becausethey are parties performing activities that address servicing criteria relatingto 5% or less of the assets of the issuing entity and (ii) the servicercompliance statements of KeyBank National Association, as primary servicer ofthe Liberty Portfolio Mortgage Loan, Rialto Capital Advisors, LLC, as specialservicer of the Prudential-Digital Realty Portfolio Mortgage Loan, CWCapitalAsset Management LLC, as special servicer of the Aventura Mall Mortgage Loan,AEGON USA Realty Advisors, LLC as special servicer of the Fair Oaks MallMortgage Loan prior to March 12, 2021, Situs Holdings, LLC as special servicerfor the Fair Oaks Mall Mortgage Loan on and after March 12, 2021 and MidlandLoan Services, a Division of PNC Bank, National Association, as specialservicer of the Starwood Hotel Portfolio Mortgage Loan and the Virginia BeachHotel Portfolio Mortgage Loan, listed on the Exhibit Index are omitted fromthis Annual Report on Form 10-K as they are not required by Item 1123 ofRegulation AB to be included on this Annual Report on Form 10-K because theyare each an unaffiliated party that is not a “servicer” that meets the criteriain Item 1108(a)(2)(i) through (iii) of Regulation AB.

**PART I**

**Item 1.  Business.**

Omitted.

**Item 1A.  Risk Factors.**

Omitted.

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

None.

**Item 2.  Properties.**

Omitted.

**Item 3.  Legal Proceedings.**

Omitted.

**Item 4.  Mine Safety Disclosures.**

Not applicable.

**PART II**

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

Omitted.

**Item 6.  Selected Financial Data.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**Item 9B.  Other Information.**

None.

**PART III**

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

Omitted.

**Item 11.  Executive Compensation.**

Omitted.

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

Omitted.

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

Omitted.

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

Omitted.

**ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB**

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

No single obligor represents 10% or more of the pool assets heldby the issuing entity. 

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

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

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

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

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

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

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

On December 17, 2015, U.S. Bank National Association, thetrustee under five pooling and servicing agreements for (i) Wachovia BankCommercial Mortgage Trust 2007-C30, (ii) COBALT CMBS Commercial Trust 2007-C2,(iii) Wachovia Bank Commercial Mortgage Trust 2007-C31, (iv) ML-CFC CommercialMortgage Trust 2007-5 and (v) ML-CFC Commercial Mortgage Trust 2007-6 commenceda proceeding with the Second Judicial District Court of Ramsey County, Minnesota(the “State Court”) for a declaratory judgment as to the properallocation of certain proceeds (“Disputed Proceeds”) received by CWCAMin connection with the sale of the Peter Cooper Village and Stuyvesant Townproperty in New York, New York securing loans held by those trusts.  CWCAMwas the special servicer of such property.  The petition requests theState Court to instruct the trustee, the trust beneficiaries, and any otherinterested parties as to the amount of the Disputed Proceeds, if any, that constitutepenalty interest and/or the amount of the Disputed Proceeds, if any, thatconstitute gain-on-sale proceeds, with respect to each trust.  On February24, 2016, CWCAM made a limited appearance with the State Court to file a motionto dismiss this proceeding based on lack of jurisdiction, mootness, standingand forum non conveniens.  On July 19, 2016, the State Court deniedCWCAM’s motion to dismiss.  On July 22, 2016, the action was removed tofederal court in Minnesota (“Federal Court”).  On October 21, 2016,the Federal Court held a hearing on the motion to transfer the action to theUnited States District Court for the Southern District of New York (“SDNYCourt”), a motion to remand to state court and a motion to hear CWCAM’srequest for reconsideration of the motion to dismiss.  On March 14, 2017,the Federal Court reserved the determination on the motion to hear CWCAM’srequest for reconsideration of the motion to dismiss, denied the motion toremand the matter to state court and granted the motion to transfer theproceeding to the SDNY Court.  Cross motions for judgment on the pleadingswere filed but the SDNY Court was unable to decide the case based on thepleadings and the SDNY Court ordered discovery.  All fact discovery wascompleted in December, 2018 and expert discovery was completed on March 15,2019.  The parties submitted cross motions for summary judgment, and onMarch 19, 2020, the SDNY Court entered an opinion andorder in which it granted summary judgment in CWCAM’s favor and held that CWCAMwas entitled to the entire amount of penalty interest and that CWCAM’sdetermination of Yield Maintenance was correct.  In the 127-page opinion,the SDNY Court found for CWCAM on every issue presented by the trustee’spetition, namely, that the funds in dispute constitute penalty interest andyield maintenance, not gain-on-sale proceeds, and that the amount of penaltyinterest and yield maintenance was correctly calculated. An appeal of the SDNYCourt’s decision was taken on April 29, 2020.  Oral argument on the appealoccurred on June 21, 2021. The parties await the decision of the appealscourt.  

On December 1, 2017, a complaint against CWCAM and others wasfiled in the United States District Court for the Southern District of New Yorkstyled as CWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., No.17-cv-9463 (the “Original Complaint”). The gravamen of the OriginalComplaint alleged breaches of a contract and fiduciary duties by CWCAM’saffiliate, CWCapital Investments LLC in its capacity as collateral manager forthe collateralized debt obligation transaction involving CWCapital Cobalt Vr,Ltd. In total, there are 14 counts pled in the Original Complaint. Of those 14,5 claims were asserted against CWCAM for aiding and abetting breach offiduciary duty, conversion and unjust enrichment. On May 23, 2018, the OriginalComplaint was dismissed for lack of subject matter jurisdiction.   OnJune 28, 2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaintin the Supreme Court of the State of New York, County of New York styled asCWCapital Cobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No.653277/2018 (the “New Complaint”).  The gravamen of the NewComplaint is the same as the previous complaint filed in the United StateDistrict Court for the Southern District of New York.  In total there are16 counts pled in the New Complaint. Of those 16 counts, 5 claims were assertedagainst CWCAM for aiding and abetting breach of fiduciary duty, conversion andunjust enrichment, 1 count seeks a declaratory judgement that the plaintiff hasthe right to enforce the contracts in question and 1 count seeks an injunctionrequiring the defendants to recognize the plaintiff as the directing holder forthe trusts in question. On January 11, 2019, the plaintiff dismissed withprejudice the declaratory judgment and injunction counts.  The NewComplaint and related summons was not served on the defendants until July 13,2018 and July 16, 2018.  The plaintiff’s motion for a preliminary injunctionwas denied by the court on July 31, 2018.  On August 3, 2018, thedefendants, including CWCAM, filed a motion to dismiss the New Complaint in itsentirety. On August 20, 2019, the court entered an order granting defendants’motion almost in its entirety, dismissing 11 of the 16 counts and partiallydismissing 2 additional counts.  Of the remaining counts, 2 are assertedagainst CWCAM for aiding and abetting breach of fiduciary duty and unjustenrichment.  On September 19, 2019, CWCapital Cobalt Vr Ltd. filed anotice of appeal relating to the August 20, 2019 dismissal order and onSeptember 26, 2019, filed an amended complaint against CWCI and CWCAMattempting to address deficiencies relating to certain of the claims dismissedby the August, 20, 2019 order.  CWCI and CWCAM filed its Motion to Dismissthe amended complaint on October 28, 2019.  The court heard argument onthe Motion to Dismiss the amended complaint on January 22, 2020 and on October23, 2020, the court granted the motion dismissing the amended claims.  OnNovember 30, 2020, CWCapital Cobalt Vr Ltd filed a notice of appeal relating tothe October 23, 2020 dismissal order.  On April 27, 2021, the FirstDepartment affirmed the dismissal as to claims against CWCAM that were part ofthe August 20, 2019 dismissal, but reversed the dismissal of two counts forbreach of the Collateral Management Agreement against CWCI.  CWCI hassought leave to file an appeal of the decision.  Both requests for leavewere denied by the First Department.  The plaintiff has also sought leaveto appeal the dismissal of the claims against CWCAM.  CWCAM believes thatit has performed its obligations under the related pooling and servicingagreements in good faith and the remaining allegations in the New Complaint arewithout merit.  

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

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

 

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

 

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

 

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

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

The information regarding this Item has been previouslyprovided in the prospectus of the Registrant relating to the issuing entityfiled on December 20, 2018 pursuant to Rule 424(b)(2).

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

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

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Fair Oaks Mall Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the BANK 2018-BNK12 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit AA to the poolingand servicing agreement for the BANK 2018-BNK12 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 BANK2018-BNK12 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 Aventura Mall Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the Aventura Mall Trust 2018-AVM Transaction, are attached heretounder Item 15 to this Annual Report on Form 10-K. Attached as Exhibit L to thetrust and servicing agreement for the Aventura Mall Trust 2018-AVM Transactionincorporated by reference as Exhibit 4.3 to this Annual Report on Form 10-K isa chart identifying the entities participating in a servicing function for theAventura Mall Trust 2018-AVM Transaction responsible for each applicableservicing criteria set forth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Christiana Mall Mortgage Loan,which is being serviced and administered pursuant to the trust and servicingagreement for the BBCMS 2018-CHRS Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Exhibit L to the trust andservicing agreement for the BBCMS 2018-CHRS Transaction incorporated byreference as Exhibit 4.4 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BBCMS2018-CHRS Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Prudential - Digital RealtyPortfolio Mortgage Loan, which is being serviced and administered pursuant tothe pooling and servicing agreement for the BANK 2018-BNK14 Transaction, areattached hereto under Item 15 to this Annual Report on Form 10-K. Attached asExhibit Z to the pooling and servicing agreement for the BANK 2018-BNK14Transaction incorporated by reference as Exhibit 4.5 to this Annual Report onForm 10-K is a chart identifying the entities participating in a servicingfunction for the BANK 2018-BNK14 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 Starwood Hotel Portfolio MortgageLoan and the Virginia Beach Hotel Portfolio Mortgage Loan, which are beingserviced and administered pursuant to the pooling and servicing agreement forthe WFCM 2018-C47 Transaction, are attached hereto under Item 15 to this AnnualReport on Form 10-K. Attached as Exhibit AA to the pooling and servicingagreement for the WFCM 2018-C47 Transaction incorporated by reference asExhibit 4.6 to this Annual Report on Form 10-K is a chart identifying theentities participating in a servicing function for the WFCM 2018-C47Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

The reports on assessments of compliance with the servicingcriteria for asset-backed securities and related attestation reports on suchassessments of compliance with respect to the Liberty Portfolio Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the Benchmark 2018-B7 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Schedule II to the poolingand servicing agreement for the Benchmark 2018-B7 Transaction incorporated byreference as Exhibit 4.7 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the Benchmark2018-B7 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 Home Depot Technology CenterMortgage Loan, which is being serviced and administered pursuant to the poolingand servicing agreement for the BBCMS 2018-C2 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 BBCMS 2018-C2 Transaction incorporatedby reference as Exhibit 4.8 to this Annual Report on Form 10-K is a chartidentifying the entities participating in a servicing function for the BBCMS2018-C2 Transaction responsible for each applicable servicing criteria setforth in Item 1122(d).

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

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

Management acknowledges the timeframe for reporting for thisactive special serviced deal was missed by two days. Despite the timing discrepancy,there was no impact on any investor reporting, issuing, or servicing. Noadditional testing was available for this particular criteria due to thedownsizing of the CMBS portfolio given Aegon’s pending exit from the businessline.

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

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

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

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

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

**PART IV**

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

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

(1) Not applicable

(2) Not applicable

(3) See below

4.1          Poolingand Servicing Agreement, dated as of December 1, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Pentalpha Surveillance LLC, asOperating Advisor and Asset Representations Reviewer (filed as Exhibit 4.1 tothe registrant’s Current Report on Form 8-K/A filed on January 3, 2019 underCommission File No. 333-226486-02 and incorporated by reference herein).

4.2          Poolingand Servicing Agreement, dated as of May 1, 2018, by and among Banc of AmericaMerrill Lynch Commercial Mortgage Inc., as Depositor, Wells Fargo Bank,National Association, as General Master Servicer, Midland Loan Services, aDivision of PNC Bank, National Association, as General Special Servicer,National Cooperative Bank, N.A., as NCB Master Servicer and NCB SpecialServicer, AEGON USA Realty Advisors, LLC, as Fair Oaks Mall Special Servicer,Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor and Asset Representations Reviewer (filed asExhibit 99.12 to the registrant’s Current Report on Form 8-K filed on December20, 2018 under Commission File No. 333-226486-02 and incorporated by referenceherein).

4.3          Trustand Servicing Agreement, dated as of June 29, 2018, by and among J.P. MorganChase Commercial Mortgage Securities Corp., as Depositor, Wells Fargo Bank,National Association, as Servicer, CWCapital Asset Management LLC, as SpecialServicer, Wells Fargo Bank, National Association, as Certificate Administrator,Wilmington Trust, National Association, as Trustee, and Park Bridge LenderServices LLC, as Operating Advisor (filed as Exhibit 99.9 to the registrant’sCurrent Report on Form 8-K filed on December 20, 2018 under Commission File No.333-226486-02 and incorporated by reference herein).

4.4          Trustand Servicing Agreement, dated as of August 9, 2018, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Wells Fargo Bank, NationalAssociation, as Servicer and Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator and Custodian, and Wilmington Trust,National Association, as Trustee (filed as Exhibit 99.7 to the registrant’sCurrent Report on Form 8-K filed on December 20, 2018 under Commission File No.333-226486-02 and incorporated by reference herein).

4.5          Poolingand Servicing Agreement, dated as of September 1, 2018, by and among MorganStanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association,as General Master Servicer, Rialto Capital Advisors, LLC, as General SpecialServicer, National Cooperative Bank, N.A., as NCB Master Servicer and NCBSpecial Servicer, Wells Fargo Bank, National Association, as CertificateAdministrator, Wilmington Trust, National Association, as Trustee, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.8 to the registrant’s Current Report on Form 8-Kfiled on December 20, 2018 under Commission File No. 333-226486-02 andincorporated by reference herein).

4.6          Poolingand Servicing Agreement, dated as of October 1, 2018, by and among Wells FargoCommercial Mortgage Securities, Inc., as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer, Wells Fargo Bank, NationalAssociation, as Certificate Administrator, Wilmington Trust, National Association,as Trustee, and Park Bridge Lender Services LLC, as Operating Advisor and AssetRepresentations Reviewer (filed as Exhibit 99.6 to the registrant’s CurrentReport on Form 8-K filed on December 20, 2018 under Commission File No.333-226486-02 and incorporated by reference herein).

4.7          Poolingand Servicing Agreement, dated as of November 1, 2018, by and among DeutscheMortgage & Asset Receiving Corporation, as Depositor, KeyBank NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Trustee, Wells Fargo Bank, NationalAssociation as Certificate Administrator, Paying Agent and Custodian, and ParkBridge Lender Services LLC, as Operating Advisor and Asset RepresentationsReviewer (filed as Exhibit 99.11 to the registrant’s Current Report on Form 8-Kfiled on December 20, 2018 under Commission File No. 333-226486-02 and incorporatedby reference herein).

4.8          Poolingand Servicing Agreement, dated as of December 1, 2018, by and among BarclaysCommercial Mortgage Securities LLC, as Depositor, Wells Fargo Bank, NationalAssociation, as Master Servicer, LNR Partners, LLC, as Special Servicer, WellsFargo Bank, National Association, as Certificate Administrator, WilmingtonTrust, National Association, as Trustee, and Park Bridge Lender Services LLC,as Operating Advisor and Asset Representations Reviewer (filed as Exhibit 99.10to the registrant’s Current Report on Form 8-K filed on December 20, 2018 underCommission File No. 333-226486-02 and incorporated by reference herein).

4.9          AgreementBetween Note Holders, dated as of November 6, 2018, by and between SPREF WH IILLC, as Initial Note A-1 Holder, Initial Note A-2 Holder, Initial Note A-3Holder, Initial Note A-4 Holder, Initial Note A-5 Holder, Initial Note A-6Holder, Initial Note A-7 Holder and Initial Note A-8 Holder (filed as Exhibit99.13 to the registrant’s Current Report on Form 8-K filed on December 20, 2018under Commission File No. 333-226486-02 and incorporated by reference herein).

4.10        AgreementBetween Note Holders, dated as of September 27, 2018, by and between WellsFargo Bank, National Association, as Initial Note A-1 Holder, Initial Note A-2Holder, Initial Note A-3 Holder and Initial Note A-4 Holder (filed as Exhibit99.14 to the registrant’s Current Report on Form 8-K filed on December 20, 2018under Commission File No. 333-226486-02 and incorporated by reference herein).

4.11        Co-LenderAgreement, dated as of August 9, 2018, by and among Barclays Bank PLC, asInitial Note A-1 Holder, Société Générale, as Initial Note A-2 Holder andDeutsche Bank, AG, New York Branch, as Initial Note A-3 Holder (filed asExhibit 99.15 to the registrant’s Current Report on Form 8-K filed on December20, 2018 under Commission File No. 333-226486-02 and incorporated by referenceherein).

4.12        AgreementBetween Note Holders, dated as of September 7, 2018, by and between Wells FargoBank, National Association, as Initial Note A-1 Holder and Initial Note A-2Holder, and Column Financial, Inc., as Initial Note A-3 Holder and Initial NoteA-4 Holder (filed as Exhibit 99.16 to the registrant’s Current Report on Form8-K filed on December 20, 2018 under Commission File No. 333-226486-02 andincorporated by reference herein).

4.13        Co-LenderAgreement, dated as of October 26, 2018, by and among Citi Real Estate FundingInc., as Note A-1 Holder, and Argentic Real Estate Finance LLC, as Note A-2Holder (filed as Exhibit 99.17 to the registrant’s Current Report on Form 8-Kfiled on December 20, 2018 under Commission File No. 333-226486-02 andincorporated by reference herein).

4.14        Co-LenderAgreement, dated as of June 7, 2018, by and among JPMorgan Chase Bank, NationalAssociation, Deutsche Bank, AG, New York Branch and Wells Fargo Bank, NationalAssociation and Morgan Stanley Bank, N.A. (filed as Exhibit 99.18 to theregistrant’s Current Report on Form 8-K filed on December 20, 2018 underCommission File No. 333-226486-02 and incorporated by reference herein).

4.15        AgreementBetween Note Holders, dated as of December 20, 2018, by and between ArgenticReal Estate Finance LLC, as Initial Note A-1 Holder and Initial Note A-2 Holder(filed as Exhibit 99.19 to the registrant’s Current Report on Form 8-K filed onDecember 20, 2018 under Commission File No. 333-226486-02 and incorporated byreference herein).

4.16        AgreementBetween Note Holders, dated as of October 11, 2018, by and between BarclaysBank PLC, as Initial Note A-1 Holder, Initial Note A-2 Holder and Initial NoteA-3 Holder  (filed as Exhibit 99.20 to the registrant’s Current Report onForm 8-K filed on December 20, 2018 under Commission File No. 333-226486-02 andincorporated by reference herein).

4.17        AgreementBetween Note Holders, dated as of October 11, 2018, by and between Barclays BankPLC, as Initial Note A-1 Holder and Initial Note A-2 Holder (filed as Exhibit99.21 to the registrant’s Current Report on Form 8-K filed on December 20, 2018under Commission File No. 333-226486-02 and incorporated by reference herein).

4.18        AgreementBetween Note Holders, dated as of September 26, 2018, by and between Citi RealEstate Funding Inc., as Initial Note A-1 Holder, Initial Note A-2 Holder,Initial Note A-3 Holder and Initial Note A-8 Holder, Barclays Bank PLC, asInitial Note A-4 Holder and Initial Note A-5 Holder, and Cantor Commercial RealEstate Lending, L.P., as Initial Note A-6 Holder and Initial Note A-7 Holder(filed as Exhibit 99.22 to the registrant’s Current Report on Form 8-K filed onDecember 20, 2018 under Commission File No. 333-226486-02 and incorporated byreference herein).

4.19        AgreementBetween Noteholders, dated as of April 27, 2018, by and between Bank ofAmerica, N.A, as Initial Note A-1-1 Holder, Initial Note A-1-2 Holder andInitial Note B-1 Holder, and Barclays Bank, PLC, as Initial Note A-2-1 Holder,Initial Note A-2-2 Holder, Initial Note A-2-3 Holder and Initial Note B-2Holder (filed as Exhibit 99.23 to the registrant’s Current Report on Form 8-Kfiled on December 20, 2018 under Commission File No. 333-226486-02 andincorporated by reference herein).

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

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

33.1        Wells Fargo Bank, National Association, as MasterServicer

33.2        Argentic Services Company LP, as Special Servicer

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

33.4        Wells Fargo Bank, National Association, asCertificate Administrator

33.5        Wells Fargo Bank, National Association, asCustodian

33.6        Pentalpha Surveillance LLC, as Operating Advisor

33.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

33.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit33.1)

33.11      Argentic Services Company LP, as Special Servicerof the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit 33.2)

33.12      Wilmington Trust, National Association, as Trustee of the Sheraton GrandNashville Downtown Mortgage Loan (Omitted. See Explanatory Notes.)

33.13      Wells Fargo Bank, National Association, asCustodian of the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit33.5)

33.14      Pentalpha Surveillance LLC, as Operating Advisor ofthe Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit 33.6)

33.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit33.7)

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

33.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Danbury Commerce Portfolio Mortgage Loan (see Exhibit 33.1)

33.18      Argentic Services Company LP, as Special Servicer ofthe Danbury Commerce Portfolio Mortgage Loan (see Exhibit 33.2)

33.19      Wilmington Trust, National Association, as Trustee of the Danbury CommercePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.20      Wells Fargo Bank, National Association, asCustodian of the Danbury Commerce Portfolio Mortgage Loan (see Exhibit 33.5)

33.21      Pentalpha Surveillance LLC, as Operating Advisor ofthe Danbury Commerce Portfolio Mortgage Loan (see Exhibit 33.6)

33.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Danbury Commerce Portfolio Mortgage Loan (see Exhibit 33.7)

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

33.24      Wells Fargo Bank, National Association, as PrimaryServicer of the Lakeside Pointe & Fox Club Apartments Mortgage Loan (seeExhibit 33.1)

33.25      Argentic Services Company LP, as Special Servicerof the Lakeside Pointe & Fox Club Apartments Mortgage Loan (see Exhibit33.2)

33.26      Wilmington Trust, National Association, as Trustee of the Lakeside Pointe &Fox Club Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

33.27      Wells Fargo Bank, National Association, asCustodian of the Lakeside Pointe & Fox Club Apartments Mortgage Loan (seeExhibit 33.5)

33.28      Pentalpha Surveillance LLC, as Operating Advisor ofthe Lakeside Pointe & Fox Club Apartments Mortgage Loan (see Exhibit 33.6)

33.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Lakeside Pointe & Fox Club Apartments Mortgage Loan (seeExhibit 33.7)

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

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

33.32      AEGON USA Realty Advisors, LLC, as Special Servicer of the Fair Oaks MallMortgage Loan prior to March 12, 2021 (Omitted. See Explanatory Notes.)

33.33      Situs Holdings, LLC, as Special Servicer of the Fair Oaks Mall Mortgage Loan onand after March 12, 2021 (Omitted. See Explanatory Notes.)

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

33.35      Wells Fargo Bank, National Association, asCustodian of the Fair Oaks Mall Mortgage Loan (see Exhibit 33.5)

33.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Fair Oaks Mall Mortgage Loan

33.37      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Fair Oaks Mall Mortgage Loan (see Exhibit 33.7)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

33.52      Wells Fargo Bank, National Association, as PrimaryServicer of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 33.1)

33.53      Rialto Capital Advisors, LLC, as Special Servicer of the Prudential - DigitalRealty Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.54      Wilmington Trust, National Association, as Trustee of the Prudential - DigitalRealty Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

33.55      Wells Fargo Bank, National Association, asCustodian of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 33.5)

33.56      Park Bridge Lender Services LLC, as OperatingAdvisor of the Prudential - Digital Realty Portfolio Mortgage Loan (see Exhibit33.36)

33.57      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 33.7)

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

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

33.60      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan

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

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

33.63      Park Bridge Lender Services LLC, as OperatingAdvisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 33.36)

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

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

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

33.67      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Virginia Beach Hotel PortfolioMortgage Loan (see Exhibit 33.60)

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

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

33.70      Park Bridge Lender Services LLC, as OperatingAdvisor of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit 33.36)

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

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

33.73      KeyBank National Association, as Primary Servicer of the Liberty PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

33.74      LNR Partners, LLC, as Special Servicer of the Liberty Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

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

33.76      Wells Fargo Bank, National Association, asCustodian of the Liberty Portfolio Mortgage Loan (see Exhibit 33.5)

33.77      Park Bridge Lender Services LLC, as OperatingAdvisor of the Liberty Portfolio Mortgage Loan (see Exhibit 33.36)

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

33.79      Wells Fargo Bank, National Association, as PrimaryServicer of the Home Depot Technology Center Mortgage Loan (see Exhibit 33.1)

33.80      LNR Partners, LLC, as Special Servicer of the Home Depot Technology CenterMortgage Loan (Omitted. See Explanatory Notes.)

33.81      Wilmington Trust, National Association, as Trustee of the Home Depot TechnologyCenter Mortgage Loan (Omitted. See Explanatory Notes.)

33.82      Wells Fargo Bank, National Association, asCustodian of the Home Depot Technology Center Mortgage Loan (see Exhibit 33.5)

33.83      Park Bridge Lender Services LLC, as OperatingAdvisor of the Home Depot Technology Center Mortgage Loan (see Exhibit 33.36)

33.84      CoreLogic Solutions, LLC, as Servicing Function Participantof the Home Depot Technology Center Mortgage Loan (see Exhibit 33.7)

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

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

34.1        Wells Fargo Bank, National Association, as MasterServicer

34.2        Argentic Services Company LP, as Special Servicer

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

34.4        Wells Fargo Bank, National Association, asCertificate Administrator

34.5        Wells Fargo Bank, National Association, asCustodian

34.6        Pentalpha Surveillance LLC, as Operating Advisor

34.7        CoreLogic Solutions, LLC, as Servicing FunctionParticipant

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

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

34.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit34.1)

34.11      Argentic Services Company LP, as Special Servicerof the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit 34.2)

34.12      Wilmington Trust, National Association, as Trustee of the Sheraton GrandNashville Downtown Mortgage Loan (Omitted. See Explanatory Notes.)

34.13      Wells Fargo Bank, National Association, asCustodian of the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit34.5)

34.14      Pentalpha Surveillance LLC, as Operating Advisor ofthe Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit 34.6)

34.15      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit34.7)

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

34.17      Wells Fargo Bank, National Association, as PrimaryServicer of the Danbury Commerce Portfolio Mortgage Loan (see Exhibit 34.1)

34.18      Argentic Services Company LP, as Special Servicerof the Danbury Commerce Portfolio Mortgage Loan (see Exhibit 34.2)

34.19      Wilmington Trust, National Association, as Trustee of the Danbury CommercePortfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.20      Wells Fargo Bank, National Association, asCustodian of the Danbury Commerce Portfolio Mortgage Loan (see Exhibit 34.5)

34.21      Pentalpha Surveillance LLC, as Operating Advisor ofthe Danbury Commerce Portfolio Mortgage Loan (see Exhibit 34.6)

34.22      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Danbury Commerce Portfolio Mortgage Loan (see Exhibit 34.7)

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

34.24      Wells Fargo Bank, National Association, as PrimaryServicer of the Lakeside Pointe & Fox Club Apartments Mortgage Loan (seeExhibit 34.1)

34.25      Argentic Services Company LP, as Special Servicerof the Lakeside Pointe & Fox Club Apartments Mortgage Loan (see Exhibit34.2)

34.26      Wilmington Trust, National Association, as Trustee of the Lakeside Pointe &Fox Club Apartments Mortgage Loan (Omitted. See Explanatory Notes.)

34.27      Wells Fargo Bank, National Association, asCustodian of the Lakeside Pointe & Fox Club Apartments Mortgage Loan (seeExhibit 34.5)

34.28      Pentalpha Surveillance LLC, as Operating Advisor ofthe Lakeside Pointe & Fox Club Apartments Mortgage Loan (see Exhibit 34.6)

34.29      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Lakeside Pointe & Fox Club Apartments Mortgage Loan (seeExhibit 34.7)

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

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

34.32      AEGON USA Realty Advisors, LLC, as Special Servicer of the Fair Oaks MallMortgage Loan prior to March 12, 2021 (Omitted. See Explanatory Notes.)

34.33      Situs Holdings, LLC, as Special Servicer of the Fair Oaks Mall Mortgage Loan onand after March 12, 2021 (Omitted. See Explanatory Notes.)

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

34.35      Wells Fargo Bank, National Association, asCustodian of the Fair Oaks Mall Mortgage Loan (see Exhibit 34.5)

34.36      Park Bridge Lender Services LLC, as OperatingAdvisor of the Fair Oaks Mall Mortgage Loan

34.37      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Fair Oaks Mall Mortgage Loan (see Exhibit 34.7)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

34.52      Wells Fargo Bank, National Association, as PrimaryServicer of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 34.1)

34.53      Rialto Capital Advisors, LLC, as Special Servicer of the Prudential - DigitalRealty Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.54      Wilmington Trust, National Association, as Trustee of the Prudential - DigitalRealty Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

34.55      Wells Fargo Bank, National Association, asCustodian of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 34.5)

34.56      Park Bridge Lender Services LLC, as OperatingAdvisor of the Prudential - Digital Realty Portfolio Mortgage Loan (see Exhibit34.36)

34.57      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 34.7)

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

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

34.60      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Starwood Hotel PortfolioMortgage Loan

34.61      Wilmington Trust, National Association, as Trustee of the Starwood Hotel PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

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

34.63      Park Bridge Lender Services LLC, as OperatingAdvisor of the Starwood Hotel Portfolio Mortgage Loan (see Exhibit 34.36)

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

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

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

34.67      Midland Loan Services, a Division of PNC Bank,National Association, as Special Servicer of the Virginia Beach Hotel PortfolioMortgage Loan (see Exhibit 34.60)

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

34.69      Wells Fargo Bank, National Association, asCustodian of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit34.5)

34.70      Park Bridge Lender Services LLC, as OperatingAdvisor of the Virginia Beach Hotel Portfolio Mortgage Loan (see Exhibit 34.36)

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

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

34.73      KeyBank National Association, as Primary Servicer of the Liberty PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

34.74      LNR Partners, LLC, as Special Servicer of the Liberty Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

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

34.76      Wells Fargo Bank, National Association, asCustodian of the Liberty Portfolio Mortgage Loan (see Exhibit 34.5)

34.77      Park Bridge Lender Services LLC, as OperatingAdvisor of the Liberty Portfolio Mortgage Loan (see Exhibit 34.36)

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

34.79      Wells Fargo Bank, National Association, as PrimaryServicer of the Home Depot Technology Center Mortgage Loan (see Exhibit 34.1)

34.80      LNR Partners, LLC, as Special Servicer of the Home Depot Technology CenterMortgage Loan (Omitted. See Explanatory Notes.)

34.81      Wilmington Trust, National Association, as Trustee of the Home Depot TechnologyCenter Mortgage Loan (Omitted. See Explanatory Notes.)

34.82      Wells Fargo Bank, National Association, asCustodian of the Home Depot Technology Center Mortgage Loan (see Exhibit 34.5)

34.83      Park Bridge Lender Services LLC, as OperatingAdvisor of the Home Depot Technology Center Mortgage Loan (see Exhibit 34.36)

34.84      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Home Depot Technology Center Mortgage Loan (see Exhibit34.7)

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

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as MasterServicer

35.2        Argentic Services Company LP, as Special Servicer

35.3        Wells Fargo Bank, National Association, asCertificate Administrator

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

35.5        Wells Fargo Bank, National Association, as PrimaryServicer of the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit35.1)

35.6        Argentic Services Company LP, as Special Servicerof the Sheraton Grand Nashville Downtown Mortgage Loan (see Exhibit 35.2)

35.7        Wells Fargo Bank, National Association, as PrimaryServicer of the Danbury Commerce Portfolio Mortgage Loan (see Exhibit 35.1)

35.8        Argentic Services Company LP, as Special Servicer ofthe Danbury Commerce Portfolio Mortgage Loan (see Exhibit 35.2)

35.9        Wells Fargo Bank, National Association, as PrimaryServicer of the Lakeside Pointe & Fox Club Apartments Mortgage Loan (seeExhibit 35.1)

35.10      Argentic Services Company LP, as Special Servicerof the Lakeside Pointe & Fox Club Apartments Mortgage Loan (see Exhibit35.2)

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

35.12      AEGON USA Realty Advisors, LLC, as Special Servicer of the Fair Oaks MallMortgage Loan prior to March 12, 2021 (Omitted. See Explanatory Notes.)

35.13      Situs Holdings, LLC, as Special Servicer of the Fair Oaks Mall Mortgage Loan onand after March 12, 2021 (Omitted. See Explanatory Notes.)

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

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

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

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

35.18      Wells Fargo Bank, National Association, as PrimaryServicer of the Prudential - Digital Realty Portfolio Mortgage Loan (seeExhibit 35.1)

35.19      Rialto Capital Advisors, LLC, as Special Servicer of the Prudential - DigitalRealty Portfolio Mortgage Loan (Omitted. See Explanatory Notes.)

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

35.21      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Starwood Hotel Portfolio Mortgage Loan (Omitted. SeeExplanatory Notes.)

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

35.23      Midland Loan Services, a Division of PNC Bank, National Association, as SpecialServicer of the Virginia Beach Hotel Portfolio Mortgage Loan (Omitted. SeeExplanatory Notes.)

35.24      KeyBank National Association, as Primary Servicer of the Liberty PortfolioMortgage Loan (Omitted. See Explanatory Notes.)

35.25      LNR Partners, LLC, as Special Servicer of the Liberty Portfolio Mortgage Loan(Omitted. See Explanatory Notes.)

35.26      Wells Fargo Bank, National Association, as PrimaryServicer of the Home Depot Technology Center Mortgage Loan (see Exhibit 35.1)

35.27      LNR Partners, LLC, as Special Servicer of the Home Depot Technology CenterMortgage Loan (Omitted. See Explanatory Notes.)

99.1        MortgageLoan Purchase Agreement, dated as of December 7, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Wells Fargo Bank, National Association(filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K filed onDecember 20, 2018 under Commission File No. 333-226486-02 and incorporated byreference herein).

99.2        MortgageLoan Purchase Agreement, dated as of December 7, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Argentic Real Estate Finance LLC(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onDecember 20, 2018 under Commission File No. 333-226486-02 and incorporated byreference herein).

99.3        MortgageLoan Purchase Agreement, dated as of December 7, 2018, between Wells FargoCommercial Mortgage Securities, Inc. and Barclays Bank PLC (filed as Exhibit99.3 to the registrant’s Current Report on Form 8-K filed on December 20, 2018under Commission File No. 333-226486-02 and incorporated by reference herein).

99.4        MortgageLoan Purchase Agreement, dated as of December 7, 2018, among Wells FargoCommercial Mortgage Securities, Inc., Basis Real Estate Capital II, LLC andBasis Investment Group LLC (filed as Exhibit 99.4 to the registrant’s CurrentReport on Form 8-K filed on December 20, 2018 under Commission File No.333-226486-02 and incorporated by reference herein).

99.5        MortgageLoan Purchase Agreement, dated as of December 7, 2018, between Wells FargoCommercial Mortgage Securities, 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 December 20, 2018 under Commission File No.333-226486-02 and incorporated by reference herein).

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

(c)    Not Applicable.

 

**SIGNATURES**

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

Wells Fargo Commercial MortgageSecurities, Inc.(Depositor)

/s/ AnthonySfarra

AnthonySfarra, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 11, 2022