**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, 2022or**

**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-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 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                                                                                                       Accelerated filer                                     o

Non-acceleratedfiler          ⌧  (Do not check ifa smaller reporting company)                          Smaller reporting company                    o

                                                                                                                                                       Emerging growth company                    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 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 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 Fargo Bank, NationalAssociation is the general master servicer (except with respect to thosemortgage loans for which PGIM Real Estate Loan Services, Inc. (formerly knownas Prudential Asset Resources, Inc.) is the primary servicer) and thecertificate administrator of the mortgage loans serviced under the Pooling andServicing Agreement and the primary servicer of the Carolina Place MortgageLoan. As a result, Wells Fargo Bank, National Association is a “servicer” asdefined in Item 1108(a)(2)(iii) of Regulation AB, in the capacities describedabove, because it is servicing mortgage loans that constituted 10% or more ofthe assets of the issuing entity as of its cut-off date.  The assessmentsof compliance with applicable servicing criteria, accountants’ attestationreports and servicer compliance statements delivered by Wells Fargo Bank,National Association in the capacities described above are listed in theExhibit Index.

U.S. Bank National Associationacts as trustee of the mortgage loans serviced under the Pooling and ServicingAgreement and the Carolina Place Mortgage Loan prior to October 17, 2022, andU.S. Bank Trust Company, National Association acts as trustee of the mortgageloans serviced under the Pooling and Servicing Agreement and the Carolina PlaceMortgage Loan on and after October 17, 2022.  Pursuant to the Pooling andServicing Agreement and the pooling and servicing agreement for the WFCMT2013-LC12 Transaction, the trustee is required to provide an assessment ofcompliance with applicable servicing criteria solely with respect to Item1122(d)(2)(iii) of Regulation AB (regarding advances of funds or guaranteesregarding collections, cash flows or distributions, and any interest or otherfees charged for such advances, are made, reviewed and approved as specified inthe transaction agreements). However, during the reporting period, the trusteedid not 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 mortgage loans serviced under the Pooling and Servicing Agreement and theCarolina Place Mortgage Loan have delivered one or more assessments ofcompliance with respect to Item 1122(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 PGIM RealEstate 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 Compliance andDisclosure 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)).

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 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 CWCapital Asset Management LLC, as special servicer,U.S. Bank National Association, as trustee, and Wells Fargo Bank, NationalAssociation, as certificate administrator and custodian. 

From time to time, CWCapital AssetManagement LLC, a Delaware limited liability company (“CWCAM”), is a party tolawsuits and other legal proceedings as part of its duties as a specialservicer (e.g., enforcement of loan obligations) and/or arising in the ordinarycourse of business. Other than as set forth in the following paragraphs, thereare currently no legal proceedings pending, and no legal proceedings known tobe contemplated by governmental authorities, against CWCAM or of which any ofits property 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 CWCAM inconnection 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, thatconstitute penalty interest and/or the amount of the Disputed Proceeds, if any,that constitute gain-on-sale proceeds, with respect to each trust.  OnFebruary 24, 2016, CWCAM made a limited appearance with the State Court to filea motion to dismiss this proceeding based on lack of jurisdiction, mootness,standing and forum non conveniens.  On July 19, 2016, the State Courtdenied CWCAM’s motion to dismiss.  On July 22, 2016, the action wasremoved to federal court in Minnesota (“Federal Court”).  On October 21,2016, the Federal Court held a hearing on the motion to transfer the action tothe United States District Court for the Southern District of New York (“SDNY Court”),a motion to remand to state court and a motion to hear CWCAM’s request forreconsideration of the motion to dismiss.  On March 14, 2017, the FederalCourt reserved the determination on the motion to hear CWCAM’s request forreconsideration of the motion to dismiss, denied the motion to remand thematter to state court and granted the motion to transfer the proceeding to theSDNY Court.  Cross motions for judgment on the pleadings were filed butthe SDNY Court was unable to decide the case based on the pleadings and theSDNY Court ordered discovery.  All fact discovery was completed inDecember, 2018 and expert discovery was completed on March 15, 2019.  Theparties submitted cross motions for summary judgment, and on March 19, 2020,the SDNY Court entered an opinion and order in which it granted summaryjudgment in CWCAM’s favor and held that CWCAM was entitled to the entire amountof penalty interest and that CWCAM’s determination of Yield Maintenance wascorrect.  In the 127-page opinion, the SDNY Court found for CWCAM on everyissue presented by the trustee’s petition, namely, that the funds in disputeconstitute penalty interest and yield maintenance, not gain-on-sale proceeds,and that the amount of penalty interest and yield maintenance was correctlycalculated. An appeal of the SDNY Court’s decision was taken on April 29,2020.  Oral argument on the appeal occurred on June 21, 2021.  OnJuly 14, 2022, the Second Circuit entered a decision affirming in part andreversing in part the SDNY Court’s decision and remanding to the SDNY Court forfurther proceedings.  The Second Circuit affirmed the SDNY’s Court holdingthat Penalty Interest and Yield Maintenance are paid before Gain-On-SaleProceeds.  The Second Circuit reversed and remanded for furtherproceedings that portion of the SDNY Court’s decision related to approximately$67.2 million in interest on advances.   On January 13, 2023, theparties entered into a settlement agreement, in which (among other things) theyagreed to stipulate that the amount of interest on advances that accrued on orbefore June 3, 2014 is $27.5 million, and that CWCAM would pay that amount intoescrow for distribution to certificateholders upon the entry of an order by theCourt approving the settlement.  U.S. Bank National Association, asTrustee for the trusts, provided notice of the settlement to all parties ininterest via a notice program approved by the Court.  A hearing on thesettlement is scheduled for March 16, 2023.

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 Original  Complaintalleged breaches of a contract and fiduciary duties by CWCAM’s affiliate,CWCapital Investments LLC in its capacity as collateral manager for thecollateralized debt obligation transaction involving CWCapital Cobalt Vr, Ltd.In total, there are 14 counts pled in the Original Complaint. Of those 14, 5claims were asserted against CWCAM for aiding and abetting breach of fiduciaryduty, conversion and unjust enrichment. On May 23, 2018, the Original Complaintwas dismissed for lack of subject matter jurisdiction.   On June 28,2018, CWCapital Cobalt Vr Ltd. filed a substantially similar complaint in theSupreme Court of the State of New York, County of New York styled as CWCapitalCobalt Vr Ltd. v. CWCapital Investments LLC, et al., Index No. 653277/2018 (the“New Complaint”).  The gravamen of the New Complaint is the same as theprevious complaint filed in the United State District Court for the SouthernDistrict of New York.  In total there are 16 counts pled in the NewComplaint. Of those 16 counts, 5 claims were asserted against CWCAM for aidingand abetting breach of fiduciary duty, conversion and unjust enrichment, 1count seeks a declaratory judgement that the plaintiff has the right to enforcethe contracts in question and 1 count seeks an injunction requiring thedefendants to recognize the plaintiff as the directing holder for the trusts inquestion. On January 11, 2019, the plaintiff dismissed with prejudice thedeclaratory judgment and injunction counts.  The New Complaint and relatedsummons was not served on the defendants until July 13, 2018 and July 16,2018.  The plaintiff’s motion for a preliminary injunction was denied bythe court on July 31, 2018.  On August 3, 2018, the defendants, includingCWCAM, filed a motion to dismiss the New Complaint in its entirety. On August20, 2019, the court entered an order granting defendants’ motion almost in itsentirety, dismissing 11 of the 16 counts and partially dismissing 2 additionalcounts.  Of the remaining counts, 2 are asserted against CWCAM for aiding andabetting breach of fiduciary duty and unjust enrichment.  On September 19,2019, CWCapital Cobalt Vr Ltd. filed a notice of appeal relating to the August20, 2019 dismissal order and on September 26, 2019, filed an amended complaintagainst CWCI and CWCAM attempting to address deficiencies relating to certainof the claims dismissed by the August 20, 2019 order.  CWCI and CWCAMfiled its Motion to Dismiss the amended complaint on October 28, 2019. The court heard argument on the Motion to Dismiss the amended complaint onJanuary 22, 2020 and on October 23, 2020, the court granted the motiondismissing the amended claims.  On November 30, 2020, CWCapital Cobalt VrLtd filed a notice of appeal relating to the October 23, 2020 dismissalorder.  On April 27, 2021, the First Department affirmed the dismissal asto claims against CWCAM that were part of the August 20, 2019 dismissal, butreversed the dismissal of two counts for breach of the Collateral ManagementAgreement against CWCI.  CWCI sought leave to file an appeal of thedecision. The plaintiff also sought leave to appeal the dismissal of the claimsagainst CWCAM.  Both requests for leave were denied by the FirstDepartment.  On May 15, 2020, CWCI and CWCAM filed a motion to renew itsmotion to dismiss as to 4 of the remaining counts (including the remaining twocounts against CWCAM for aiding and abetting breach of fiduciary duty andunjust enrichment), based on a decision entered by Judge Failla in a trustinstruction proceeding  in the US District Court for the Southern Districtof New York awarding summary judgment in favor of CWCAM.  On September 7,2021, the court denied the motion to renew.  CWCI and CWCAM filed a noticeof appeal, which they perfected by the filing of their opening brief on July 1,2022.  On November 15, 2022, the First Department affirmed the court’sdenial of the motion to renew.  On October 1, 2021, CWCI and CWCAM movedto reargue the denial of the motion to renew (or alternatively, the motion todismiss) with respect to certain of Cobalt’s claims, including the remaining 2claims against CWCAM, based on the First Department’s April 27, 2021decision.  On March 24, 2022, the court denied the relief sought in themotion to reargue.  CWCI and CWCAM have appealed the court’s decision onthe motion to reargue and filed their opening brief on July 11, 2022.  Theappeal was dismissed as being non-appealable on August 30, 2022.  CWCAMbelieves that it has performed its obligations under the related pooling andservicing agreements in good faith and the remaining allegations in the NewComplaint are without merit.   

In the last several years, U.S. BankNational Association (“U.S. Bank”) and other large financial institutions havebeen sued in their capacity as trustee or successor trustee for certainresidential mortgage backed securities ("RMBS") trusts.  Thecomplaints, primarily filed by investors or investor groups against U.S. Bankand similar institutions, allege the trustees caused losses to investors as aresult of alleged failures by the sponsors, mortgage loan sellers and servicersto comply with the governing agreements for these RMBS trusts.  Plaintiffsgenerally assert causes of action based upon the trustees’ purported failuresto enforce repurchase obligations of mortgage loan sellers for alleged breachesof representations and warranties, notify securityholders of purported eventsof default allegedly caused by breaches of servicing standards by mortgage loanservicers and abide by a heightened standard of care following alleged eventsof 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 believes that it has performed its obligations asindenture trustee and special servicer in good faith and in compliance in allmaterial respects with the terms of the agreements governing the DSTs (the“Governing Agreements”), and accordingly that the claims against it in theNCMSLT Action are without merit.  

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 DelawareCourt of Chancery concerning the DSTs and the Student Loans (the “ConsolidatedAction”).  U.S. Bank and other parties to the Consolidated Action havebriefed and argued motions for judgment on the pleadings pursuant to ChanceryCourt Rule 12(c) regarding disputed issues of contractual interpretation at issuein one or more of the cases comprising the Consolidated Action, including theNCMSLT Action.  The Court has not yet ruled on these motions or on U.S.Bank’s dismissal motion in the NCMSLT Action.

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 and by IKB International and IKB Deutsche Industriebank 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 appealed the district court’s decision to theUnited States Court of Appeals for the Second Circuit. The Company previouslysettled two class actions filed by institutional investors and an action filedby the National Credit Union Administration with similar allegations. Inaddition, Park Royal I LLC and Park Royal II LLC have filed substantiallysimilar lawsuits in New York state court alleging Wells Fargo Bank, N.A., astrustee, failed to take appropriate actions upon learning of defective mortgageloan documentation.

**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 WFCMT2013-LC12 Transaction responsible for each applicable servicing criteria setforth in Item 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 National Association, as Trustee prior to October 17, 2022 (Omitted.See Explanatory Notes.)

33.6        U.S. Bank Trust Company, National Association, as Trustee on and after October17, 2022 (Omitted. See Explanatory Notes.)

33.7        Wells Fargo Bank, National Association, asCertificate Administrator

33.8        Wells Fargo Bank, National Association, asCustodian

33.9        Trimont Real Estate Advisors, LLC (f/k/a TriMontReal Estate Advisors, Inc.), as Trust Advisor

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 National Association, as Trustee of the Augusta Mall Mortgage Loanprior to October 17, 2022 (Omitted. See Explanatory Notes.)

33.18      U.S. Bank Trust Company, National Association, as Trustee of the Augusta MallMortgage Loan on and after October 17, 2022 (Omitted. See Explanatory Notes.)

33.19      Wells Fargo Bank, National Association, asCustodian of the Augusta Mall Mortgage Loan (see Exhibit 33.8)

33.20      Trimont Real Estate Advisors, LLC (f/k/a TriMontReal Estate Advisors, Inc.), as Trust Advisor of the Augusta Mall Mortgage Loan(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, asServicing 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 National Association, as Trustee of the Carolina Place Mortgage Loanprior to October 17, 2022 (Omitted. See Explanatory Notes.)

33.26      U.S. Bank Trust Company, National Association, as Trustee of the Carolina PlaceMortgage Loan on and after October 17, 2022 (Omitted. See Explanatory Notes.)

33.27      Wells Fargo Bank, National Association, asCustodian of the Carolina Place Mortgage Loan (see Exhibit 33.8)

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

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

33.30      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 National Association, as Trustee prior to October 17, 2022 (Omitted.See Explanatory Notes.)

34.6        U.S. Bank Trust Company, National Association, as Trustee on and after October17, 2022 (Omitted. See Explanatory Notes.)

34.7        Wells Fargo Bank, National Association, asCertificate Administrator

34.8        Wells Fargo Bank, National Association, asCustodian

34.9        Trimont Real Estate Advisors, LLC (f/k/a TriMontReal Estate Advisors, Inc.), as Trust Advisor

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 National Association, as Trustee of the Augusta Mall Mortgage Loanprior to October 17, 2022 (Omitted. See Explanatory Notes.)

34.18      U.S. Bank Trust Company, National Association, as Trustee of the Augusta MallMortgage Loan on and after October 17, 2022 (Omitted. See Explanatory Notes.)

34.19      Wells Fargo Bank, National Association, as Custodianof the Augusta Mall Mortgage Loan (see Exhibit 34.8)

34.20      Trimont Real Estate Advisors, LLC (f/k/a TriMontReal Estate Advisors, Inc.), as Trust Advisor of the Augusta Mall Mortgage Loan(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 National Association, as Trustee of the Carolina Place Mortgage Loanprior to October 17, 2022 (Omitted. See Explanatory Notes.)

34.26      U.S. Bank Trust Company, National Association, as Trustee of the Carolina PlaceMortgage Loan on and after October 17, 2022 (Omitted. See Explanatory Notes.)

34.27      Wells Fargo Bank, National Association, asCustodian of the Carolina Place Mortgage Loan (see Exhibit 34.8)

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

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

34.30      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. (formerly knownas 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 99.7to the registrant’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 10, 2023

** **