ASSESSMENT OF COMPLIANCE WITH
APPLICABLE SERVICING CRITERIA
  Platform
 Period
 Applicable Servicing Criteria


With
  respect to servicing criterion 1122(d)(2)(vi) the Company’s management has engaged a vendor to perform the activities
  required by the   servicing criterion. The Company’s management has determined that this vendor is not considered a
  servicer   as defined in   Item 1101(j) of Regulation AB, and the Company’s management has elected to take
  responsibility for   assessing   compliance   with the servicing   criterion applicable to this vendor as permitted by the
  SEC’s Compliance   and   Disclosure   Interpretation, 200.06, Vendors Engaged by Servicers(C&DI 200.06).
  The Company’s   management   has policies   and procedures in place designed to   provide   reasonable assurance   that
  the   vendors   activities   comply in all   material respects with the servicing   criterion   applicable to the
  vendor.   The   Company’s management is   solely   responsible for   determining that it meets the SEC requirements
  to apply    C&DI 200.06 for the vendor   and related   servicing criterion.








---









The Bank of New York Mellon
        
        BNY Mellon Trust 
   of Delaware/s/ Alphonse Briand Jr.
        
        /s/ William D. LindelofAlphonse Briand Jr. 
          Authorized Signatory
        
        William D. Lindelof Authorized SignatoryThe Bank of New York Mellon TrustCompany, N.A./s/ Antonio I. PortuondoAntonio I. Portuondo
      Authorized Signatory Dated: February 28, 2020























Schedule A



Material Instances of Noncompliance by the
Company





Management’s Assessment of Compliance with Applicable Servicing
Criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB as of and for the Period,
disclosed that material instances of noncompliance occurred with respect to the servicing criterion set forth in Items 1122(d)(3)(i)(A)
as follows: Certain reports to investors were not prepared in accordance with the timeframes set forth in the transaction agreements.













Schedule B



Management’s Discussion of Material
Instances of Noncompliance by the Company





1122(d)(3)(i)(A): Reports to investors, including those to be
filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements.
Specifically, such reports are prepared in accordance with timeframes and other terms set forth in the transaction agreements.



1122(d)(3)(i)(A):

Noncompliance:

During the Period, certain reports to investors were
not prepared in accordance with the timeframes set forth in the transaction agreements.



Remediation:

| | - | Transaction identifiers will be verified and made uniform, as needed, between the BNY Mellon Investor Reporting website and
the system that generates investor reports.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | - | All desktop procedures for the Platform will be reviewed to make sure the correct transaction identifiers are listed for all
reports that need to be made available to investors on the BNY Mellon Investor Reporting website.
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | - | A review of the BNY Mellon Investor Reporting website will be undertaken on the relevant Payment Dates to verify that all pertinent
reports have been successfully posted and assure any needed remediation occurs on the same date.
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------













APPENDIX 1

|REG ABREFERENCE                  | SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                   | APPLICABLE TO PLATFORM | NOT APPLICABLETO PLATFORM
|-------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------- | -------------------------
|Performed Directlyby the Company | Performed byVendor(s) for whichthe Company is theResponsible Party                                                                                                                                                                                                                                                                                                  
|                                 | General servicing considerations                                                                                                                                                                                                                                                                                                                                     |                        |                          
|1122(d)(1)(i)                    | Policies and procedures are instituted tomonitor any performance or othertriggers and events of default inaccordance with the transactionagreements.                                                                                                                                                                                                                 | X                      |                          
|1122(d)(1)(ii)                   | If any material servicing activities areoutsourced to third parties, policies andprocedures are instituted to monitor thethird partys performance andcompliance with such servicingactivities.                                                                                                                                                                      | X                      |                          
|1122(d)(1)(iii)                  | Any requirements in the transactionagreements to maintain a back-upservicer for the pool assets aremaintained.                                                                                                                                                                                                                                                       |                        |                          
|1122(d)(1)(iv)                   | A fidelity bond and errors and omissionspolicy is in effect on the partyparticipating in the servicing functionthroughout the reporting period in theamount of coverage required by andotherwise in accordance with the termsof the transaction agreements.                                                                                                          |                        |                          
|1122(d)(1)(v)                    | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately
reflects the information.                                                                                                                                                                                                                              |                        |                          
|                                 | Cash collection and administration                                                                                                                                                                                                                                                                                                                                   |                        |                          
|1122(d)(2)(i)                    | Payments on pool assets are depositedinto the appropriate custodial bankaccounts and related bank clearingaccounts no more than two businessdays of receipt, or such other number ofdays specified in the transactionagreements.                                                                                                                                     | X                      |                          
|1122(d)(2)(ii)                   | Disbursements made via wire transfer onbehalf of an obligor or to an investor aremade only by authorized personnel.                                                                                                                                                                                                                                                  | X                      |                          
|1122(d)(2)(iii)                  | Advances of funds or guaranteesregarding collections, cash flows ordistributions, and any interest or otherfees charged for such advances, aremade, reviewed and approved asspecified in the transaction agreements.                                                                                                                                                 |                        |                          
|1122(d)(2)(iv)                   | The related accounts for the transaction, such as cash reserve accounts or
    accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling
    of cash) as set forth in the transaction agreements.                                                                                                       | X                      |                          
|1122(d)(2)(v)                    | Each custodial account is maintained at a federally insured depository institution
as set forth in the transaction agreements. For purposes of this criterion, federally insured depository institution
with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Rule 240.13k-1(b)(1)
of this chapter. | X                      |                          
|1122(d)(2)(vi)                   | Unissued checks are safeguarded so asto prevent unauthorized access.                                                                                                                                                                                                                                                                                                 |                        | X                        







|REG ABREFERENCE                  | SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | APPLICABLE TO PLATFORM | NOT APPLICABLETO PLATFORM
|-------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ---------------------- | -------------------------
|Performed Directlyby the Company | Performed byVendor(s) for whichthe Company is theResponsible Party                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                
|1122(d)(2)(vii)                  | Reconciliations are prepared on amonthly basis for all asset-backedsecurities
    related bank accounts,including custodial accounts and relatedbank clearing
    accounts. Thesereconciliations (A) Are mathematicallyaccurate; (B) Are prepared
    within     30calendar days after the bank statementcutoff date, or such other
    number ofdays     specified in the transactionagreements; (C) Are reviewed and
    approvedby     someone other     than the person whoprepared the reconciliation;
    and (D)Contain     explanations for     reconcilingitems. These reconciling items
    areresolved within     90 calendar days     of theiroriginal identification, or
    such othernumber of days     specified in thetransaction
    agreements. | X                      |                          
|                                 | Investor remittances and reporting                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                        |                          
|1122(d)(3)(i)                    | Reports to investors, including those tobe filed with the Commission, aremaintained in accordance with thetransaction agreements and applicableCommission requirements. Specifically,such reports (A) Are prepared inaccordance with timeframes and otherterms set forth in the transactionagreements; (B) Provide informationcalculated in accordance with the termsspecified in the transaction agreements;(C) Are filed with the Commission asrequired by its rules and regulations; and(D) Agree with investors or the trusteesrecords as to the total unpaid principalbalance and number of pool assetsserviced by the servicer.                                                                                                                            | X                      |                          
|1122(d)(3)(ii)                   | Amounts due to investors are allocatedand remitted in accordance withtimeframes, distribution priority andother terms set forth in the transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | X                      |                          
|1122(d)(3)(iii)                  | Disbursements made to an investor areposted within two business days to theservicers investor records, or such othernumber of days specified in thetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | X                      |                          
|1122(d)(3)(iv)                   | Amounts remitted to investors per theinvestor reports agree with cancelledchecks, or other form of payment, orcustodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | X                      |                          
|                                 | Pool asset administration                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                        |                          
|1122(d)(4)(i)                    | Collateral or security on pool assets ismaintained as required by the transactionagreements or related pool assetdocuments.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | X                      |                          
|1122(d)(4)(ii)                   | Pool asset and related documents aresafeguarded as required by thetransaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | X                      |                          
|1122(d)(4)(iii)                  | Any additions, removals or substitutionsto the asset pool are made, reviewed andapproved in accordance with anyconditions or requirements in thetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | X                      |                          







|REG ABREFERENCE                  | SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | APPLICABLE TO PLATFORM | NOT APPLICABLETO PLATFORM
|-------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------- | -------------------------
|Performed Directlyby the Company | Performed byVendor(s) for whichthe Company is theResponsible Party                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    
|1122(d)(4)(iv)                   | Payments on pool assets, including any payoffs, made in accordance with the
    related pool asset documents are posted to the applicable servicers obligor records maintained no more than two business
    days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest
    or other items (e.g., escrow) in accordance with the related pool asset documents.                                                                                                                                    |                        |                          
|1122(d)(4)(v)                    | The servicers records regarding thepool assets agree with the servicersrecords with respect to an obligorsunpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                 |                        |                          
|1122(d)(4)(vi)                   | Changes with respect to the terms or status of an obligor's pool assets (e.g.,
    loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction
    agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                        |                        |                          
|1122(d)(4)(vii)                  | Loss mitigation or recovery actions (e.g.,forbearance plans, modifications anddeeds in lieu of foreclosure, foreclosuresand repossessions, as applicable) areinitiated, conducted and concluded inaccordance with the timeframes or otherrequirements established by thetransaction agreements.                                                                                                                                                                                                                                                                        |                        |                          
|1122(d)(4)(viii)                 | Records documenting collection effortsare maintained during the period a poolasset is delinquent in accordance withthe transaction agreements. Such recordsare maintained on at least a monthlybasis, or such other period specified inthe transaction agreements, and describethe entitys activities in monitoringdelinquent pool assets including, forexample, phone calls, letters andpayment rescheduling plans in caseswhere delinquency is deemed temporary(e.g., illness or unemployment).                                                                     |                        |                          
|1122(d)(4)(ix)                   | Adjustments to interest rates or rates ofreturn for pool assets with variable ratesare computed based on the related poolasset documents.                                                                                                                                                                                                                                                                                                                                                                                                                              |                        |                          
|1122(d)(4)(x)                    | Regarding any funds held in trust for anobligor (such as escrow accounts): (A)Such funds are analyzed, in accordancewith the obligors pool asset documents,on at least an annual basis, or such otherperiod specified in the transactionagreements; (B) Interest on such funds ispaid, or credited, to obligors inaccordance with applicable pool assetdocuments and state laws; and (C) Suchfunds are returned to the obligor within30 calendar days of full repayment of therelated pool asset, or such other numberof days specified in the transactionagreements. |                        |                          







|REG ABREFERENCE                  | SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                     | APPLICABLE TO PLATFORM | NOT APPLICABLETO PLATFORM
|-------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------- | -------------------------
|Performed Directlyby the Company | Performed byVendor(s) for whichthe Company is theResponsible Party                                                                                                                                                                                                                                                                                                                    
|1122(d)(4)(xi)                   | Payments made on behalf of an obligor(such as tax or insurance payments) aremade on or before the related penalty orexpiration dates, as indicated on theappropriate bills or notices for suchpayments, provided that such supporthas been received by the servicer at least30 calendar days prior to these dates, orsuch other number of days specified inthe transaction agreements. |                        |                          
|1122(d)(4)(xii)                  | Any late payment penalties inconnection with any payment to be madeon behalf of an obligor are paid from theservicers funds and not charged to theobligor, unless the late payment was dueto the obligors error or omission.                                                                                                                                                         |                        |                          
|1122(d)(4)(xiii)                 | Disbursements made on behalf of anobligor are posted within two businessdays to the obligors records maintainedby the servicer, or such other number ofdays specified in the transactionagreements.                                                                                                                                                                                   |                        |                          
|1122(d)(4)(xiv)                  | Delinquencies, charge-offs anduncollectible accounts are recognizedand recorded in accordance with thetransaction agreements.                                                                                                                                                                                                                                                          |                        |                          
|1122(d)(4)(xv)                   | Any external enhancement or othersupport, identified in Item
    1114(a)(1)through (3) or Item 1115 of this RegulationAB, is maintained as set forth
    in thetransaction agreements.                                                                                                                                                                                                 | X                      |