REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors of

Comenity Capital Bank:

We have examined management of Comenity Capital Bank’s assertion, included in the accompanying

Management’s Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria, that

Comenity Capital Bank (the “Bank”) complied with the servicing criteria set forth in Item 1122(d) of the

Securities and Exchange Commission’s Regulation AB for the asset‐Dbacked securities transactions

sponsored by the Bank for which the Bank acted as a servicer involving credit card receivables, accounts

receivables and asset based lending receivables (the “Platform”), excluding criteria 1122 (d)(1)(iii),

(d)(1)(v), (d)(2)(i), (d)(2)(ii), (d)(2)(iii), (d)(2)(vi), (d)(2)(vii), (d)(3)(i), (d)(3)(ii), (d)(3)(iii), (d)(3)(iv), (d)(4)(i),

(d)(4)(iv), (d)(4)(v), (d)(4)(vi), (d)(4)(viii), (d)(4)(ix), (d)(4)(x), (d)(4)(xi), (d)(4)(xii), (d)(4)(xiii), (d)(4)(xiv),

and (d)(4)(xv) (the “servicing criteria”), as of and for the year ended December 31, 2022, which

management has determined are not applicable to the activities performed by the Bank with respect to

the Platform. Appendix A to management’s assertion identifies the individual asset‐Dbacked transactions

defined by management as constituting the Platform. Management is responsible for the Bank’s

compliance with the servicing criteria and its assertion. Our responsibility is to express an opinion on

management’s assertion about the Bank’s compliance with the servicing criteria based on our

examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting

Oversight Board (United States) and in accordance with attestation standards established by the

American Institute of Certified Public Accountants. Those standards require that we plan and perform

the examination to obtain reasonable assurance about whether management’s assertion about

compliance with the servicing criteria is fairly stated, in all material respects, and, accordingly, included

examining, on a test basis, evidence about the Bank’s compliance with the servicing criteria, including

tests on a sample basis of the servicing activities related to the Platform, determining whether the Bank

performed those selected activities in compliance with the servicing criteria during the specified period,

and performing such other procedures as we considered necessary in the circumstances. Our

procedures were limited to selected servicing activities performed by the Bank during the period

covered by this report and, accordingly, such samples may not have included servicing activities related

to each asset‐Dbacked transaction included in the Platform. Further, an examination is not designed to

detect noncompliance arising from errors that may have occurred prior to the period specified above

that may have affected the balances or amounts calculated or reported by the Bank during the period

covered by this report. We believe that the evidence we obtained in our examination is sufficient and

appropriate to provide a reasonable basis for our opinion.

Our examination does not provide a legal determination on the Bank’s compliance with the servicing

criteria.

In our opinion, management’s assertion that the Bank complied with the aforementioned servicing

criteria as of and for the year ended December 31, 2022, for the Platform, is fairly stated, in all material

respects.

Deloitte & Touche LLP