**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, 2023or**

**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: 333-177891-05**

**Central Index Key Number of the issuing entity:0001578423**

**WFRBS Commercial Mortgage Trust2013-C15**

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

** **

**Central Index Key Number of the depositor: 0001112998**

**RBS Commercial Funding Inc.**

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

** **

**Central Index Key Number of the sponsor: 0000729153**

**NatWest Markets Plc**

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

**(formerly known as TheRoyal Bank of Scotland plc)**

** **

**Central Index Key Number of the sponsor: 0001541615**

**RBS Financial Products Inc.**

**(exact name of the sponsor 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: 0001577313**

**National Cooperative Bank, N.A.**

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

**(formerly known as NCB,FSB)**

** **

**Central Index Key Number of the sponsor: 0001555501**

**Liberty Island Group I LLC**

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

** **

**Central Index Key Number of the sponsor: 0001541214**

**C-III Commercial Mortgage LLC**

**(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)**

** **

| **New York****(State or other jurisdiction of  incorporation or organization of**

**the issuing entity)** | **38-3918453**

**38-3918454**

**38-3918455**

**38-7103174**

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

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

**c/o Computershare Trust Company, National Association, as agent for**

**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:**

**(203) 897-2700**

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-known seasonedissuer, 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 every Interactive Data File required to be submitted pursuant toRule 405 of Regulation S-T (Section 232.405 of this chapter) during thepreceding 12 months (or for such shorter period that the registrant wasrequired to submit such files).

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          ⌧                                                                                                       Smaller reportingcompany                    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

If securities are registered pursuant to Section 12(b) of theAct, indicate by check mark whether the financial statements of the registrantincluded in the filing reflect the correction of an error to previously issuedfinancial statements. o

Indicate by check mark whether any of those error correctionsare restatements that required a recovery analysis of incentive-basedcompensation received by any of the registrant’s executive officers during therelevant recovery period pursuant to §240.10D-1(b). 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 most recentlycompleted 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.) into whichthe document is incorporated: (1) Any annual report to security holders; (2)Any proxy or information statement; and (3) Any prospectus filed pursuant toRule 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 Augusta Mall Mortgage Loan, whichconstituted approximately 9.9% of the asset pool of the issuing entity as ofits cut-off date, is an asset of the issuing entity and is part of a loancombination that includes the Augusta Mall Mortgage Loan and one other *paripassu* loan, which is not an asset of the issuing entity. This loancombination, including the Augusta Mall Mortgage Loan, is being serviced andadministered pursuant to the Pooling and Servicing Agreement, which isincorporated by reference as Exhibit 4.1 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 Carolina Place Mortgage Loan, whichconstituted approximately 7.7% of the asset pool of the issuing entity as ofits cut-off date.  The Carolina Place Mortgage Loan is an asset of theissuing entity and is part of a loan combination that includes the CarolinaPlace Mortgage Loan and one other *pari passu* loan, which is not an assetof the issuing entity. The other *pari passu* portion of the loancombination was securitized in the Wells Fargo Commercial Mortgage Trust2013-LC12 transaction, Commission File Number 333-172366-08 (the “WFCMT2013-LC12 Transaction”). This loan combination, including the CarolinaPlace Mortgage Loan, is being serviced and administered pursuant to the poolingand servicing agreement for the WFCMT 2013-LC12 Transaction, which isincorporated by reference as Exhibit 4.2 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 FargoBank, National Association is the general master servicer (except with respectto those mortgage loans for which PGIM Real Estate Loan Services, Inc.(formerly known as Prudential Asset Resources, Inc.) is the primary servicer)and the certificate administrator of the mortgage loans serviced under thePooling and Servicing Agreement and the primary servicer of the Carolina PlaceMortgage Loan. As a result, Wells Fargo Bank, National Association is a“servicer” as defined in Item 1108(a)(2)(iii) of Regulation AB, in thecapacities described above, because it is servicing mortgage loans thatconstituted 10% or more of the assets of the issuing entity as of its cut-offdate.  The assessments of compliance with applicable servicing criteria,accountants’ attestation reports and servicer compliance statements deliveredby Wells Fargo Bank, National Association in the capacities described above arelisted in the Exhibit Index.

U.S. Bank Trust Company, NationalAssociation acts as trustee of  the mortgage loans serviced under thePooling and Servicing Agreement and the Carolina Place Mortgage Loan. Pursuant to the Pooling and Servicing Agreement and the pooling and servicingagreement for the WFCMT 2013-LC12 Transaction, the trustee is required to providean assessment of compliance with applicable servicing criteria solely withrespect to Item 1122(d)(2)(iii) of Regulation AB (regarding advances of fundsor guarantees regarding collections, cash flows or distributions, and anyinterest or other fees charged for such advances, are made, reviewed andapproved as specified in the transaction agreements). However, during thereporting period, the trustee did not perform any servicing function withrespect to the servicing criteria specified in Item 1122(d)(2)(iii) ofRegulation AB.  The master servicer or the special servicer, to the extentrequired, performed the servicing function identified with respect to Item1122(d)(2)(iii) of Regulation AB, and each such party included Item1122(d)(2)(iii) of Regulation AB in the assessment of compliance withapplicable 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 and the Carolina Place Mortgage Loanhave delivered one or more assessments of compliance with respect to Item1122(d)(2)(iii) of Regulation AB.

This Annual Report on Form 10-K includes assessments ofcompliance with applicable servicing criteria and accountants’ attestationreports from CoreLogic Solutions, LLC.  This entity was engaged by thegeneral master servicer under the Pooling and Servicing Agreement (except withrespect to those mortgage loans for which PGIM Real Estate Loan Services, Inc.(formerly known as Prudential Asset Resources, Inc.) is the primary servicer),the primary servicer under the Pooling and Servicing Agreement and the primaryservicer of the Carolina Place Mortgage Loan to remit tax payments receivedfrom the escrow accounts of borrowers to local taxing authorities, to reporttax amounts due, to verify tax parcel information, and to verify non-escrow taxpayments.  With respect to the reports provided as servicing functionparticipant on behalf of Wells Fargo Bank, National Association, theseservicing functions are included within the servicing criteria set forth inItems 1122(d)(4)(xi) and 1122(d)(4)(xii) of Regulation AB.  With respectto the reports provided as servicing function participant on behalf of PGIMReal Estate Loan Services, Inc. (formerly known as Prudential Asset Resources,Inc.), these servicing functions are included within the servicing criteria setforth in Items 1122(d)(2)(ii), 1122(d)(2)(vi), 1122(d)(4)(xi) and1122(d)(4)(xii) of Regulation AB.  Therefore, under the principles-baseddefinition of “servicer” set forth in Item 1101(j) of Regulation AB that looksto the functions that an entity performs, this vendor is a “servicer” for thepurposes of Item 1122 of Regulation AB.  *See* Complianceand Disclosure Interpretations, Section 301.01 (Item 1101(j)).

This AnnualReport on Form 10-K includes an assessment of compliance with applicable servicingcriteria, accountants’ attestation report and servicer compliance statementfrom Computershare Trust Company, National Association (“CTCNA”). CTCNA was 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.  *See*Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)).

The assessment of compliance withapplicable servicing criteria, accountants’ attestation report and servicercompliance statement of the certificate administrator of the Carolina PlaceMortgage Loan is omitted from this Annual Report on Form 10-K as thecertificate administrator pursuant to the related pooling and servicingagreement or trust and servicing agreement does not perform any activities thataddress servicing criteria with respect to the issuing entity and because it isnot a “servicer” that meets the criteria in Item 1108(a)(2)(i) through (iii) ofRegulation AB.

With respect to the *pari passu*loan combination that includes the Carolina Place Mortgage Loan, the servicercompliance statement of Rialto Capital Advisors, LLC as special servicer of theCarolina Place Mortgage Loan, listed on the Exhibit Index is omitted from thisAnnual Report on Form 10-K as it is not required by Item 1123 of Regulation ABto be included on this Annual Report on Form 10-K because it is an unaffiliatedparty that is not a “servicer” that meets the criteria in 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 1C.  Cybersecurity.**

Omitted.

**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.  [Reserved]**

**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.

**Item 9C.  Disclosure Regarding Foreign Jurisdictionsthat Prevent Inspections.**

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 Accountant 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 assetsheld by 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 U.S. Bank Trust Company, National Association, astrustee, and Wells Fargo Bank, National Association, as certificateadministrator and custodian. 

U.S. Bank National Association (“U.S.Bank”) and other large financial institutions have been sued in their capacityas trustee or successor trustee for certain residential mortgage backedsecurities ("RMBS") trusts.  The complaints, primarily filed byinvestors or investor groups against U.S. Bank and similar institutions, allegethe trustees caused losses to investors as a result of alleged failures by thesponsors, mortgage loan sellers and servicers to comply with the governingagreements for these RMBS trusts.  Plaintiffs generally assert causes ofaction based upon the trustees’ purported failures to enforce repurchaseobligations of mortgage loan sellers for alleged breaches of representationsand warranties, notify securityholders of purported events of default allegedlycaused by breaches of servicing standards by mortgage loan servicers and abideby a heightened standard of care following alleged events of default.  

U.S. Bank denies liability and believes that it has performedits obligations under the RMBS trusts in good faith, that its actions were notthe cause of losses to investors, that it has meritorious defenses, and it hascontested and intends to continue contesting the plaintiffs’ claimsvigorously.  However, U.S. Bank cannot assure you as to the outcome of anyof the litigation, or the possible impact of these litigations on the trusteeor the RMBS trusts.  

On March 9, 2018, a law firm purporting to represent fifteenDelaware statutory trusts (the “DSTs”) that issued securities backed by studentloans (the “Student Loans”) filed a lawsuit in the Delaware Court of Chanceryagainst U.S. Bank National Association (“U.S. Bank”) in its capacities asindenture trustee and successor special servicer, and three other institutionsin their respective transaction capacities, with respect to the DSTs and theStudent Loans.  This lawsuit is captioned The National Collegiate StudentLoan Master Trust I, et al. v. U.S. Bank National Association, et al., C.A. No.2018-0167-JRS (Del. Ch.) (the “NCMSLT Action”).  The complaint, as amendedon June 15, 2018, alleged that the DSTs have been harmed as a result ofpurported misconduct or omissions by the defendants concerning administrationof the trusts and special servicing of the Student Loans.  Since thefiling of the NCMSLT Action, certain Student Loan borrowers have madeassertions against U.S. Bank concerning special servicing that appear to bebased on certain allegations made on behalf of the DSTs in the NCMSLT Action.

U.S. Bank has filed a motion seeking dismissal of theoperative complaint in its entirety with prejudice pursuant to Chancery CourtRules 12(b)(1) and 12(b)(6) or, in the alternative, a stay of the case whileother prior filed disputes involving the DSTs and the Student Loans arelitigated.  On November 7, 2018, the Court ruled that the case should bestayed in its entirety pending resolution of the first-filed cases.  OnJanuary 21, 2020, the Court entered an order consolidating for pretrialpurposes the NCMSLT Action and three other lawsuits pending in the Delaware Courtof Chancery concerning the DSTs and the Student Loans, which remainspending.  

U.S. Bank denies liability in the NCMSLT Action and believesit has performed its obligations as indenture trustee and special servicer ingood faith and in compliance in all material respects with the terms of theagreements governing the DSTs and that it has meritorious defenses.  Ithas contested and intends to continue contesting the plaintiffs’ claimsvigorously.  

In December 2014, Phoenix Light SFLimited (Phoenix Light) and certain related entities filed a complaint in theUnited States District Court for the Southern District of New York allegingclaims against Wells Fargo Bank, N.A., in its capacity as trustee for a numberof residential mortgage-backed securities (RMBS) trusts. Complaints raisingsimilar allegations have been filed by Commerzbank AG in the Southern Districtof New York, IKB International and IKB Deutsche Industriebank (together, IKB)in New York state court, and Park Royal I LLC and Park Royal II LLC in New Yorkstate court. In each case, the plaintiffs allege that Wells Fargo Bank, N.A.,as trustee, caused losses to investors, and plaintiffs assert causes of actionbased upon, among other things, the trustee’s alleged failure to notify andenforce repurchase obligations of mortgage loan sellers for purported breachesof representations and warranties, notify investors of alleged events ofdefault, and abide by appropriate standards of care following alleged events ofdefault. In July 2022, the district court dismissed Phoenix Light’s claims andcertain of the claims asserted by Commerzbank AG, and subsequently enteredjudgment in each case in favor of Wells Fargo Bank, N.A. In August 2022,Phoenix Light and Commerzbank AG each appealed the district court’s decision tothe United States Court of Appeals for the Second Circuit. Phoenix Lightdismissed its appeal in May 2023, terminating its case. In November 2023, WellsFargo Bank, N.A. entered into an agreement with IKB to resolve IKB’s claims.Wells Fargo Bank, N.A. previously settled two class actions filed byinstitutional investors and an action filed by the National Credit UnionAdministration with similar allegations.

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

The information regarding this Item has been previouslyprovided in a prospectus supplement of the Registrant relating to the issuingentity filed on August 20, 2013 pursuant to Rule 424(b)(5).

**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 ScheduleIII to the Pooling and Servicing Agreement incorporated by reference as Exhibit4.1 to 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 Carolina Place Mortgage Loan,which is being serviced and administered pursuant to the pooling and servicingagreement for the WFCMT 2013-LC12 Transaction, are attached hereto under Item15 to this Annual Report on Form 10-K. Attached as Schedule III to the poolingand servicing agreement for the WFCMT 2013-LC12 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 WFCMT 2013-LC12Transaction responsible for each applicable servicing criteria set forth inItem 1122(d).

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

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

**PART IV**

**Item 15. Exhibit and 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          Pooling and Servicing Agreement, dated as of August 1,2013, by and among RBS Commercial Funding Inc., as Depositor, Wells Fargo Bank,National Association, as General Master Servicer, CWCapital Asset ManagementLLC, as General Special Servicer, NCB, FSB as NCB Master Servicer, NCB, FSB asCo-op Special Servicer, TriMont Real Estate Advisors, Inc., as Trust Advisor,Wells Fargo Bank, National Association, as Certificate Administrator, as TaxAdministrator and as Custodian, and U.S. Bank National Association, as Trustee(filed as Exhibit 4.1 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2013 under Commission File No. 333-177891-05 and incorporated byreference herein).

4.2          Pooling and Servicing Agreement, dated as of July 1,2013, by and among Wells Fargo Commercial Mortgage Securities, Inc., asDepositor, Wells Fargo Bank, National Association, as Master Servicer, RialtoCapital Advisors, LLC, as Special Servicer, Park Bridge Lender Services LLC, asTrust Advisor, Wells Fargo Bank, National Association, as CertificateAdministrator, as Tax Administrator and as Custodian, and U.S. Bank NationalAssociation, as Trustee (filed as Exhibit 4.1 to Wells Fargo CommercialMortgage Securities, Inc.’s Current Report on Form 8-K/A filed on October 15,2013 under Commission File No. 333-172366-08 and incorporated by referenceherein).

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 GeneralMaster Servicer

33.2        National Cooperative Bank, N.A. (f/k/a NCB, FSB),as NCB Master Servicer

33.3        CWCapital Asset Management LLC, as General SpecialServicer

33.4        National Cooperative Bank, N.A. (f/k/a NCB, FSB),as NCB Special Servicer (see Exhibit 33.2)

33.5        U.S. Bank Trust Company, National Association, as Trustee (Omitted. SeeExplanatory Notes.)

33.6        Wells Fargo Bank, National Association, asCertificate Administrator

33.7        Wells Fargo Bank, National Association, asCustodian

33.8         Trimont LLC (f/k/a TriMont Real Estate Advisors,Inc.), as Trust Advisor prior to March 31, 2023

33.9        BellOak, LLC, as Trust Advisor on and after March31, 2023

33.10      CoreLogic Solutions, LLC, as Servicing FunctionParticipant

33.11      PGIM Real Estate Loan Services, Inc. (formerlyknown as Prudential Asset Resources, Inc.), as Primary Servicer

33.12      CoreLogic Solutions, LLC, as Servicing FunctionParticipant for PGIM Real Estate Loan Services, Inc. (formerly known asPrudential Asset Resources, Inc.) (see Exhibit 33.10)

33.13      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

33.14      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

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

33.16      CWCapital Asset Management LLC, as Special Servicerof the Augusta Mall Mortgage Loan (see Exhibit 33.3)

33.17      U.S. Bank Trust Company, National Association, as Trustee of the Augusta MallMortgage Loan (Omitted. See Explanatory Notes.)

33.18      Wells Fargo Bank, National Association, as Custodianof the Augusta Mall Mortgage Loan (see Exhibit 33.7)

33.19       TrimontLLC (f/k/a TriMont Real Estate Advisors, Inc.), as Trust Advisor of the AugustaMall Mortgage Loan prior to March 31, 2023 (see Exhibit 33.8)

33.20      BellOak, LLC, as Trust Advisor of the Augusta Mall MortgageLoan on and after March 31, 2023 (see Exhibit 33.9)

33.21      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Augusta Mall Mortgage Loan (see Exhibit 33.10)

33.22      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.14)

33.23      Wells Fargo Bank, National Association, as PrimaryServicer of the Carolina Place Mortgage Loan (see Exhibit 33.1)

33.24      Rialto Capital Advisors, LLC, as Special Servicerof the Carolina Place Mortgage Loan

33.25      U.S. Bank Trust Company, National Association, as Trustee of the Carolina PlaceMortgage Loan (Omitted. See Explanatory Notes.)

33.26      Wells Fargo Bank, National Association, asCustodian of the Carolina Place Mortgage Loan (see Exhibit 33.7)

33.27      Park Bridge Lender Services LLC, as Trust Advisorof the Carolina Place Mortgage Loan

33.28      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Carolina Place Mortgage Loan (see Exhibit 33.10)

33.29      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 33.14)

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

34.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

34.2        National Cooperative Bank, N.A. (f/k/a NCB, FSB),as NCB Master Servicer

34.3        CWCapital Asset Management LLC, as General SpecialServicer

34.4        National Cooperative Bank, N.A. (f/k/a NCB, FSB),as NCB Special Servicer (see Exhibit 34.2)

34.5        U.S. Bank Trust Company, National Association, as Trustee (Omitted. SeeExplanatory Notes.)

34.6        Wells Fargo Bank, National Association, asCertificate Administrator

34.7        Wells Fargo Bank, National Association, asCustodian

34.8         Trimont LLC (f/k/a TriMont Real Estate Advisors,Inc.), as Trust Advisor prior to March 31, 2023

34.9        BellOak, LLC, as Trust Advisor on and after March31, 2023

34.10      CoreLogic Solutions, LLC, as Servicing FunctionParticipant

34.11      PGIM Real Estate Loan Services, Inc. (formerlyknown as Prudential Asset Resources, Inc.), as Primary Servicer

34.12      CoreLogic Solutions, LLC, as Servicing FunctionParticipant for PGIM Real Estate Loan Services, Inc. (formerly known asPrudential Asset Resources, Inc.) (see Exhibit 34.10)

34.13      Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

34.14      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian

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

34.16      CWCapital Asset Management LLC, as Special Servicerof the Augusta Mall Mortgage Loan (see Exhibit 34.3)

34.17      U.S. Bank Trust Company, National Association, as Trustee of the Augusta MallMortgage Loan (Omitted. See Explanatory Notes.)

34.18      Wells Fargo Bank, National Association, asCustodian of the Augusta Mall Mortgage Loan (see Exhibit 34.7)

34.19       TrimontLLC (f/k/a TriMont Real Estate Advisors, Inc.), as Trust Advisor of the AugustaMall Mortgage Loan prior to March 31, 2023 (see Exhibit 34.8)

34.20      BellOak, LLC, as Trust Advisor of the Augusta MallMortgage Loan on and after March 31, 2023 (see Exhibit 34.9)

34.21      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Augusta Mall Mortgage Loan (see Exhibit 34.10)

34.22      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.14)

34.23      Wells Fargo Bank, National Association, as PrimaryServicer of the Carolina Place Mortgage Loan (see Exhibit 34.1)

34.24      Rialto Capital Advisors, LLC, as Special Servicerof the Carolina Place Mortgage Loan

34.25      U.S. Bank Trust Company, National Association, as Trustee of the Carolina PlaceMortgage Loan (Omitted. See Explanatory Notes.)

34.26      Wells Fargo Bank, National Association, asCustodian of the Carolina Place Mortgage Loan (see Exhibit 34.7)

34.27      Park Bridge Lender Services LLC, as Trust Advisorof the Carolina Place Mortgage Loan

34.28      CoreLogic Solutions, LLC, as Servicing FunctionParticipant of the Carolina Place Mortgage Loan (see Exhibit 34.10)

34.29      Computershare Trust Company, National Association,as Servicing Function Participant for the Custodian (see Exhibit 34.14)

35           Servicer compliance statements.

35.1        Wells Fargo Bank, National Association, as GeneralMaster Servicer

35.2        National Cooperative Bank, N.A. (f/k/a NCB, FSB),as NCB Master Servicer

35.3        CWCapital Asset Management LLC, as General SpecialServicer

35.4        National Cooperative Bank, N.A. (f/k/a NCB, FSB),as NCB Special Servicer (see Exhibit 35.2)

35.5        Wells Fargo Bank, National Association, asCertificate Administrator

35.6        PGIM Real Estate Loan Services, Inc. (formerlyknown as Prudential Asset Resources, Inc.), as Primary Servicer

35.7        Computershare Trust Company, National Association,as Servicing Function Participant for the Certificate Administrator

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

35.9        CWCapital Asset Management LLC, as Special Servicerof the Augusta Mall Mortgage Loan (see Exhibit 35.3)

35.10      Wells Fargo Bank, National Association, as PrimaryServicer of the Carolina Place Mortgage Loan (see Exhibit 35.1)

35.11      Rialto Capital Advisors, LLC, as Special Servicer of the Carolina PlaceMortgage Loan (Omitted. See Explanatory Notes.)

99.1         Mortgage Loan Purchase Agreement, dated as of August 5,2013, between RBS Commercial Funding Inc. and The Royal Bank of Scotland plc(filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2013 under Commission File No. 333-177891-05 and incorporated byreference herein)

99.2         Mortgage Loan Purchase Agreement, dated as of August 5,2013, between RBS Commercial Funding Inc. and RBS Financial Products Inc.(filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2013 under Commission File No. 333-177891-05 and incorporated byreference herein)

99.3         Mortgage Loan Purchase Agreement, dated as of August 5,2013, between RBS Commercial Funding Inc. and Wells Fargo Bank, NationalAssociation (filed as Exhibit 99.3 to the registrant’s Current Report on Form8-K filed on August 20, 2013 under Commission File No. 333-177891-05 andincorporated by reference herein)

99.4         Mortgage Loan Purchase Agreement, dated as of August 5, 2013,between RBS Commercial Funding Inc. and NCB, FSB (filed as Exhibit 99.7 to theregistrant’s Current Report on Form 8-K filed on August 20, 2013 underCommission File No. 333-177891-05 and incorporated by reference herein)

99.5         Mortgage Loan Purchase Agreement, dated as of August 5,2013, among RBS Commercial Funding Inc., Liberty Island Group I LLC and LibertyIsland Group LLC (filed as Exhibit 99.5 to the registrant’s Current Report onForm 8-K filed on August 20, 2013 under Commission File No. 333-177891-05 andincorporated by reference herein)

99.6         Mortgage Loan Purchase Agreement, dated as of August 5,2013, between RBS Commercial Funding Inc. and C-III Commercial Mortgage LLC(filed as Exhibit 99.6 to the registrant’s Current Report on Form 8-K filed onAugust 20, 2013 under Commission File No. 333-177891-05 and incorporated byreference herein)

99.7         Mortgage Loan Purchase Agreement, dated as of August 5,2013, among RBS Commercial Funding 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 August 20, 2013 under Commission File No.333-177891-05 and incorporated by reference herein)

99.8         Primary Servicing Agreement, dated as of August 1, 2013,between Wells Fargo Bank, National Association and Prudential Asset Resources,Inc. (filed as Exhibit 99.8 to the registrant’s Current Report on Form 8-Kfiled on August 20, 2013 under Commission File No. 333-177891-05 andincorporated 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.

RBS Commercial Funding Inc.(Depositor)

/s/ AdamTrebing

AdamTrebing, President

(senior officer in charge ofsecuritization of the depositor)

Date: March 18, 2024