Exhibit 34.1

 

 

KPMGLLP

Suite900

10SouthBroadway

St.Louis,MO63102-1761

 

 

ReportofIndependentRegisteredPublic AccountingFirm

 

TheBoardofDirectors

CitiMortgage,Inc.:

 

We have examined management’s assertion, included in the accompanying Management Assessment ofCompliance with Applicable Servicing Criteria, that CitiMortgage, Inc. (the Servicer) complied with the servicing criteriasetforthinItem1122(d)(1)(i),1122(d)(1)(iv),1122(d)(1)(v),1122(d)(2)(ii),1122(d)(2)(iii),1122(d)(2)(v),1122(d)(2)(vii), 1122(d)(3)(i) through 1122(d)(3)(iv); 1122(d)(4)(i) through 1122(d)(4)(iii) and 1122(d)(4)(xv); ofthe Securities and Exchange Commission’s Regulation AB (the Servicing Criteria) for servicing of residentialmortgage loans included in publicly issued residential mortgage-backed securities issued on or after January 1,2006; certain publicly issued residential mortgage-backed securities issued prior to January 1, 2006; andcertain residential mortgage transactions for which the Servicer has agreed to apply the servicing criteria setforth in Item 1122(d) of Regulation AB (Servicing Criteria) for which the Servicer performs a particular servicing function pursuant to a servicing agreement with a third party, except for Federal Home Loan MortgageCorporation, Federal National Mortgage Association, and Government National Mortgage Associationresidential mortgage loan securitization unless part of a special bond program (the Platform), as of and for theyear ended December 31, 2021. The Servicer’s management has determined that all other criteria set forth inItem 1122(d) are not applicable to the Servicer because the Servicer does not perform activities with respect to the Platform relating to those criteria. The Servicer has determined that servicing criterion 1122(d)(4)(i) isapplicable to the activities the Servicer performs with respect to the Platform only as it relates to collectionactivities for outstanding documents, and preparing and shipping the documents to another party participatingin the servicing function. The Servicer has determined that servicing criterion 1122(d)(4)(ii) is applicable to theactivities the Servicer performs with respect to the Platform only as it relates to collection activities foroutstanding documents. With respect to applicable servicing criterion 1122(d)(4)(iii), the Servicer hasdetermined that there were no activities performed during the year ended December 31, 2021 with respect tothe Platform, because there were no occurrences of events that would require the Servicer to perform suchactivities. The Servicer has determined that servicing criterion 1122(d)(1)(v) is applicable to the activities theServicer performs with respect to the Platform for all transactions and securities in the Platform, including those issued on or before November 23, 2015 for which compliance was previously assessed under other servicingcriteria, as applicable, for the assessment period as of and for the year ended December 31, 2021. Exhibit B to theManagementAssessmentofCompliancewith ApplicableServicingCriteriaidentifiestheindividual asset-backed transactions and securities defined by management as constituting the Platform. Management is responsible for the Servicer’s compliance with the Servicing Criteria. Our responsibility is to express an opinion on management’s assertion about the Servicer’s compliance with the Servicing Criteria based on ourexamination.

 

OurexaminationwasconductedinaccordancewiththestandardsofthePublicCompanyAccountingOversight Board (United States) and in accordance with attestation standards established by the American Institute ofCertified Public Accountants to obtain reasonable assurance and, accordingly, included examining, on a testbasis, evidence about the Servicer’s compliance with the Servicing Criteria and performing such otherproceduresasweconsiderednecessaryinthecircumstances.Ourexamination includedtestingselected asset-backedtransactionsandsecuritiesthatcomprisethePlatform,testingselectedservicingactivitiesrelated to the Platform, and determining whether the Servicer processed those selected transactions and performedthose selected activities in compliance with the Servicing Criteria. Furthermore, our procedures were limited totheselectedtransactionsandservicingactivitiesperformedbythe Servicerduringtheperiodcoveredbythis report. Our procedures were not designed to determine whether errors may have occurred either prior to orsubsequent to 

KPMG LLP, a Delaware limited liability partnership and a member firm of

theKPMGglobalorganizationofindependentmemberfirmsaffiliatedwith

KPMGInternationalLimited, aprivate Englishcompany limitedby guarantee.

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our tests that may have affected the balances or amounts calculated or reported by the Servicerduring the period covered by this report for the selected transactions or any other transactions. We believe thatour examination provides a reasonable basis for our opinion. Our examination does not provide a legaldeterminationontheServicer’s compliancewiththe ServicingCriteria.

 

As described in Exhibit A to the Management Assessment of Compliance with Applicable Servicing Criteria, the Servicer has engaged various vendors to perform the activities required for certain activities related to servicing criterion 1122(d)(2)(ii). The Servicer has determined that none of these vendors is considered a servicer asdefined in Item 1101(j) of Regulation AB, and the Servicer has elected to take responsibility for assessingcompliance with the servicing criteria applicable to each vendor as permitted by the SEC’s Compliance andDisclosure Interpretation (C&DI) 200.60, Vendors Engaged by Servicer (C&DI 200.06). As permitted by C&DI200.06, the Servicer has asserted that it has policies and procedures in place designed to provide reasonableassurance that the vendors’ activities comply in all material respects with the servicing criteria applicable toeach vendor. The Servicer is solely responsible for determining that it meets the SEC requirements to applyC&DI 200.06 for the vendors and related criteria as described in its assertion, and we performed no procedures withrespecttothe Servicer’s eligibility toapply C&DI200.06.

 

Inouropinion,management’sassertionthatCitiMortgage,Inc.(theServicer)compliedwiththeaforementioned Servicing Criteria, including servicing criterion 1122(d)(2)(ii), as described in Exhibit A to the ManagementAssessment of Compliance with Applicable Servicing Criteria for which compliance is determined based onC&DI 200.06 as described above, as of and for the year ended December 31, 2021, is fairly stated, in allmaterial respects.

 

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St. Louis, Missouri

February25,2022