Exhibit 34.9

 

|  |
|--|
|  |

 

 

 

 

| GRANTTHORNTONLLP          |   |                                                |
|---------------------------|--------|-----------------------------------------------------|
| 2001MarketSt.,Suite700    |   | REPORT OFINDEPENDENT REGISTEREDPUBLICACCOUNTINGFIRM |
| Philadelphia,PA19103-7065 |   |                                                |
|                      |   |                                                |
| D  +12155614200 |   |                                                |
| F  +12155611066 |   |                                                |

 

 

 

BoardofManagers

BerkadiaCommercialMortgageLLC

We have examined management’s assertion, included in the accompanyingManagement’s Report on Assessment of Compliance with SEC Regulation ABServicing Criteria as Primary Servicer (“Management’s Report”), that BerkadiaCommercialMortgageLLC(the“Company”)compliedwiththeservicingcriteriaset forth in Item 1122(d) of the U.S. Securities and Exchange Commission’sRegulation AB for the primary servicing of commercial mortgage loans sold inpublic securitizations (the “Primary Servicing Platform” or the “Platform”) as ofand for the year ended December 31, 2021, excluding criteria 1122(d)(1)(iii),(3)(i)(C), (4)(ii), (4)(vii), and (4)(xv), which management has determined are notapplicable to the activities performed by the Company with respect to thePlatform. The Platform consists of the publicly issued asset-backedtransactions and securities for which the Company is named the primaryservicer of commercial mortgage loans. Management is responsible for theCompany’s compliance with the applicable servicing criteria. Our responsibilityis to express an opinion on management’s assertion about the Company’scompliance with the applicable servicing criteria for the Platform based on ourexamination.

Our examination was conducted in accordance with the standards of the PublicCompany Accounting Oversight Board (United States) and in accordance withattestation standards established by the American Institute of Certified PublicAccountants, and, accordingly, included examining, on a test basis, evidenceabout the Company’s compliance with the applicable servicing criteria for thePlatform and performing such other procedures as we considered necessary inthe circumstances. Our examination included testing selected asset-backedtransactionsandsecuritiesconstitutingthePlatformandevaluatingwhethertheCompany performed servicing activities related to those transactions andsecurities in compliance with the applicable servicing criteria for the periodcovered by this report. Accordingly, our testing may not have included servicingactivities related to each asset-backed transaction or security constituting thePlatform. Further, our examination was not designed to detect materialnoncompliance that may have occurred prior to the period covered by thisreport and that may have affected the Company’s servicing activities during theperiod covered by this report. We believe that our examination provides areasonable basis for our opinion. Our examination does not provide a legaldetermination on the Company’s compliance with the applicable servicingcriteria.

 

 

|   |   |   |
|--------|--------|--------|

 

|   | GT.COM | Grant Thornton LLP is the U.S. member firm of Grant Thornton International Ltd (GTIL). GTIL and each of its member firmsareseparate legal entitiesand arenotaworldwide partnership |   |
|--------|--------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|

 

----

 

|  |
|--|
|  |
|  |

 

 

 

 

 

As described in Management’s Report, the Company engaged various vendorsto perform servicing activities with respect to criteria 1122(d)(4)(i) and (4)(xi)through 1122(d)(4)(xiii). The Company determined that each vendor is notconsidereda“servicer,”asthattermisdefinedinItem1101(j)ofRegulationAB, and therefore, the Company is assuming responsibility for compliance withsuch servicing criteria applicable to each vendor’s servicing activities. Inaccordance with Regulation AB and its related interpretations, the requirementfor management to assess compliance with the servicing criteria applicable to avendor’s activities is satisfied if the Company has instituted policies andprocedures to monitor whether such vendor’s activities comply in all materialrespects with such criteria. Compliance with the applicable servicing criteria isachieved if those policies and procedures are designed to provide reasonableassurance that such vendor’s activities comply with such criteria and thosepolicies and procedures are operating effectively for the period covered byManagement’s Report. Our examination does not provide a legal determinationof whether a vendor is or is not considered a servicer, and therefore, onwhether the Company, in its Management Report, is eligible to elect to takeresponsibility for assessing compliance with the servicing criteria applicable toeachvendor’sservicingactivities.

Inouropinion,management’sassertionthatBerkadiaCommercial

MortgageLLCcompliedwiththeaforementionedapplicableservicingcriteriaasof and for the year ended December 31, 2021 for the Primary ServicingPlatformis fairly stated, in all material respects.

 

|                            |
|----------------------------|
|                            |
|                       |
| Philadelphia, Pennsylvania |
| February15,2022            |