Exhibit 33.4

MANAGEMENT’S ASSERTION OF COMPLIANCE



Management of the Agency and Trust division of Citibank, N.A. (or “Company”) is responsible for assessing compliance with the servicing criteria set forth in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission.



Management has determined that the servicing criteria set forth in Item 1122(d) of Regulation AB are applicable in regard to the servicing platform as of and for the period as follows:



Platform:  Publicly-issued (i.e., transaction-level reporting initially required under the Securities Exchange Act of 1934, as amended) and certain privately-issued (i.e., for which transaction-level reporting is required pursuant to contractual obligation) commercial mortgage-backed securities issued on or after January 1, 2011, as listed in Appendix A, for which the Company provides the following servicing functions (the “Platform”):



• paying agent, certificate administration and trustee; or


• certificate administration and paying agent




Applicable Servicing Criteria:  All servicing criteria set forth in Item 1122(d), to the extent required by Item 1122(d) servicing criteria in regards to the activities performed by the Company with respect to the Platform as to any transaction, except for the following servicing criteria: 1122(d)(1)(iii), 1122(d)(4)(i)-1122(d)(4)(ii) and 1122(d)(4)(iv)-1122(d)(4)(xv), which management has determined are not applicable to the activities the Company performs with respect to the Platform (the “Applicable Servicing Criteria”).  Servicing criterion 1122(d)(1)(v) is applicable only to the activities the Company performs related to the mathematically accurate aggregation of information received from servicers and the accurate conveyance of such information within reports to investors.  Servicing criterion 1122(d)(4)(iii) is applicable to the activities the Company performs with respect to the Platform only as it relates to the Company’s obligation to report additions, removals or substitutions on reports to investors in accordance with the transaction agreements.  With respect to servicing criteria 1122(d)(2)(iii) and 1122(d)(4)(iii), there were no activities performed during the twelve months ended December 31, 2022 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.



Period:  Twelve months ended December 31, 2022 (the “Period”).



With respect to the Platform as of and for the Period, the Company’s management provides the following assertion of compliance with respect to the Applicable Servicing Criteria:

• The Company’s management is responsible for assessing the Company’s compliance with the Applicable Servicing Criteria.


• The Company’s management has assessed compliance with the Applicable Servicing Criteria.  In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.


• Based on such assessment, the Company has complied, in all material respects, with the Applicable Servicing Criteria.


KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s assertion of compliance with the Applicable Servicing Criteria as of and for the Period.







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CITIBANK, N.A.



By: __/S/ James Maitland_______________________



Its: __Managing Director___ ____________________



Dated: February 28, 2023





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Appendix A



Mortgage-backed Transactions and Securities Constituting the Platform



DEAL NAME



|                           |                                         
|-------------------------- | ----------------------------------------
|Benchmark 2021-B31         | CGCMT 2016-P3                           
|BMARK 2018-B3              | CGCMT 2016-P5                           
|BMARK 2018-B6              | CGCMT 2017-B1                           
|BMARK 2019-B12             | CGCMT 2017-C4                           
|BMARK 2019-B15             | CGCMT 2017-P7                           
|BMARK 2019-B9              | CGCMT 2017-P8                           
|BMARK 2020-B19             | CGCMT 2018-B2                           
|BMARK 2021-B23             | CGCMT 2018-C5                           
|BMARK 2021-B27             | CGCMT 2018-C6                           
|BXCMT 2020-VIVA            | CGCMT 2019-C7                           
|CCMT 2015-GC27             | CGCMT 2019-GC41                         
|CCMT16C2                   | CGCMT 2019-GC43                         
|CCMT16GC37                 | CGCMT 2020-420K                         
|CCMT16P4                   | CGCMT 2020-555                          
|CCMT16P6                   | CGCMT 2020-GC46                         
|CD 2017-CD5 Mortgage Trust | CGCMT 225 Liberty Street Trust 2016-225L
|CF 2019-CF1 Mortgage Trust | GSMC 2011-GC3                           
|CF 2019-CF2 Mortgage Trust | GSMST-2011GC5                           
|CFCRE 2011-C2              | MAD 2019-650M                           
|CFK Trust 2020-MF2         | MSBAM Trust Series 2014-C17             
|CGCMT 2012-GC8             | NYC 2021-909                            
|CGCMT 2013-375P           
|CGCMT 2013-GC15           
|CGCMT 2013-GC17           
|CGCMT 2013-GCJ11          
|CGCMT 2014-GC23           
|CGCMT 2014-GC25           
|CGCMT 2015-GC29           
|CGCMT 2015-GC31           
|CGCMT 2015-GC33           
|CGCMT 2015-GC35           
|CGCMT 2015-P1             
|CGCMT 2016-C1             
|CGCMT 2016-C3             







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