EX-33.4 6 cik0001564968-ex334_194.htm EX-33.4 cik0001564968-ex334_194.htm

 

Exhibit 33.4

 

 

 

 

Management Assessment

 

Management of the Cenlar FSB (Cenlar or the Bank) is responsible for assessing compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of residential mortgage loans (the Platform), except for servicing criteria 1122 (d)(1)(iii), 1122(d)(3)(i)(b)-(c), 1122(d)(4)(i), 1122(d)(4)(ii) and 1122(d)(4)(xi), as of and for the year ended December 31, 2020. These criteria are not applicable to the Bank because the Bank does not perform activities with respect to the Platform relating to these criteria. Appendix A identifies the individual asset-backed transactions and securities defined by management as constituting the Platform. With respect to servicing criterion 1122(d)(2)(i), management has engaged various vendors to perform the activities required by these servicing criteria, has determined that these vendors are not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Bank has elected to take responsibility for assessing compliance with the applicable servicing criteria applicable to each vendor as permitted by Regulation AB Compliance and Disclosure Interpretations of the Division of Corporation Finance, Section 200.06, “Vendors Engaged by Servicers” (C&DI 200.06). As permitted by C&DI 200.06, the Bank asserts that it has policies and procedures in place, designed and operating effectively, to provide reasonable assurance that the vendors’ activities comply in all material respects with servicing criteria applicable to each vendor. The Bank is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendors and related criteria as described in our assertion.

 

The Bank's management has assessed the Bank's compliance with the applicable servicing criteria as of and for the year ended December 31, 2020. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.

 

Based on such assessment, management has concluded that, as of and for the year ended December 31, 2020, the Bank has complied in all material respects with the servicing criteria, except as set forth in the column titled “Inapplicable Servicing Criteria on Appendix B, set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform.

 

Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report with respect to management 's assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2020.

 

 

Gregory S. Tornquist

 

Chairman of the Board and Chief Executive Officer

 

 

 

Stephen W. Gozdan

 

Robert Lux

Executive Vice President and Chief Financial Officer

 

Executive Vice President and Chief Operating Officer

March 1, 2021

 

 

 

 

 

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

 

 

 

Investor

 

Servicer

 

Security

* Period

Subserviced by

Cenlar FSB

R95

Baxter Credit Union

SEMT 2015-2

1/1 to 8/30/20

Q95

Baxter Credit Union

SEMT 2015-3

1/1 to 12/31/20

P95

Baxter Credit Union

SEMT 2016-3

1/1 to 12/31/20

T11

Bethpage Federal Credit Union

SEMT 2013-10

1/1 to 12/31/20

R11

Bethpage Federal Credit Union

SEMT 2013-11

1/1 to 12/31/20

BP1

Bethpage Federal Credit Union

SEMT 2014-1

1/1 to 12/31/20

BP2

Bethpage Federal Credit Union

SEMT 2015-2

1/1 to 12/31/20

SH0

Morgan Stanley Mortgage Capital Holdings LLC

SEMT 2018-2

1/1 to 12/31/20

SH1

Morgan Stanley Mortgage Capital Holdings LLC

SEMT 2018-CH1

1/1 to 12/31/20

SH2

Morgan Stanley Mortgage Capital Holdings LLC

SEMT 2014-2

1/1 to 12/31/20

SM3

Morgan Stanley Mortgage Capital Holdings LLC

MSMCH, NA

1/1 to 12/31/20

SM4

Morgan Stanley Mortgage Capital Holdings LLC

SEMT 2015-2

1/1 to 12/31/20

RD0

Redwood Residential Acquisition Corp

SEMT 2014-4

1/1 to 12/31/20

RD1

Redwood Residential Acquisition Corp

SEMT 2015-1

1/1 to 12/31/20

RD2

Redwood Residential Acquisition Corp

SEMT 2015-2

1/1 to 12/31/20

RD5

Redwood Residential Acquisition Corp

SEMT 2015-3

1/1 to 12/31/20

RS8

Redwood Residential Acquisition Corp

SEMT 2015-4

1/1 to 12/31/20

RT4

Redwood Residential Acquisition Corp

SEMT 2014-2

1/1 to 12/31/20

RT5

Redwood Residential Acquisition Corp

SEMT 2014-3

1/1 to 12/31/20

RV4

Redwood Residential Acquisition Corp

SEMT 2017-1

1/1 to 12/31/20

RV5

Redwood Residential Acquisition Corp

SEMT 2017-2

1/1 to 12/31/20

RW8

Redwood Residential Acquisition Corp

SEMT 2013-8

1/1 to 12/31/20

RX0

Redwood Residential Acquisition Corp

SEMT 2013-9

1/1 to 12/31/20

RX1

Redwood Residential Acquisition Corp

SEMT 2013-10

1/1 to 12/31/20

RX2

Redwood Residential Acquisition Corp

SEMT 2013-11

1/1 to 12/31/20

RX3

Redwood Residential Acquisition Corp

SEMT 2013-12

1/1 to 12/31/20

RX8

Redwood Residential Acquisition Corp

SEMT 2014-1

1/1 to 12/31/20

RV1

Redwood Residential Acquisition Corp

SEMT 2016-1

1/1 to 12/31/20

RV2

Redwood Residential Acquisition Corp

SEMT 2016-2

1/1 to 12/31/20

RV3

Redwood Residential Acquisition Corp

SEMT 2016-3

1/1 to 12/31/20

UB2

Redwood Residential Acquisition Corp

SEMT 2016-1

1/1 to 7/31/20

UB4

Redwood Residential Acquisition Corp

SEMT 2016-2

1/1 to 12/31/20

UB5

Redwood Residential Acquisition Corp

SEMT 2016-3

1/1 to 12/31/20

SF7

SOFI Lending Corp

SFPMT 2016-1

1/1 to 12/31/20

UB1

UBS Bank USA

SEMT 2015-4

1/1 to 12/31/20

LB7

Liberty Savings

REMIC 1997-6

1/1 to 12/31/20

M73

CRESCENT MORTGAGE COMPANY

 

1/1 to 12/31/20

 

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

 

 

 

 

RA6

 

 

Amerihome Mortgage Co. LLC

ATHENE ASSET MANAGEMENT- ACRA

 

 

1/1 to 12/31/20

 

 

RA7

 

 

Amerihome Mortgage Co. LLC

ATHENE ASSET MANAGEMENT- DIAMOND

 

 

1/1 to 12/31/20

 

TE9

 

Amerihome Mortgage Co. LLC

BANK OF AMERICA WL Holding - Jumbo

 

1/1 to 12/31/20

MH3

Amerihome Mortgage Co. LLC

BAML 2019-CRA

1/1 to 12/31/20

TD9

Amerihome Mortgage Co. LLC

JPM holding Inv

1/1 to 12/31/20

TL0

LoanDepot.com LLC

Mid-First EBO

1/1 to 12/31/20

LD3

LoanDepot.com LLC

Bank United EBO

1/1 to 12/31/20

 

Q69

 

LoanDepot.com LLC

JP MORGAN ACQUISITION CORP

 

1/1/20-12/31/20

SM2

Morgan Stanley Mortgage Capital Holdings LLC

CATHAY BANK

1/1 to 12/31/20

UF1

United Shore Financial Services, LLC

JP MORGAN CHASE

1/1 to 12/31/20

MH1

Amerihome Mortgage Co. LLC

JPMMT 2019-8

1/1 to 12/31/20

RA9

Amerihome Mortgage Co. LLC

JPMMT 2019-INV1

1/1 to 12/31/20

RH7

Amerihome Mortgage Co. LLC

JPMMT 2019-3

1/1 to 12/31/20

RH8

Amerihome Mortgage Co. LLC

JPMMT 2019-2

1/1 to 12/31/20

RH9

Amerihome Mortgage Co. LLC

JPMMT 2019-1

1/1 to 12/31/20

MH4

Amerihome Mortgage Co. LLC

JP MORGAN 2020-2

2/1/20-12/31/20

 

MH5

 

Amerihome Mortgage Co. LLC

JP MORGAN 2020- INV1

 

2/1/20-12/31/20

MH6

Amerihome Mortgage Co. LLC

JPMMT 2020-4

6/1/20-12/31/20

MH7

Amerihome Mortgage Co. LLC

JPMMT 2020-INV2

7/1/20-12/31/20

MH8

Amerihome Mortgage Co. LLC

JPMMT 2020-8

10/1/20-12/31/20

TE2

Amerihome Mortgage Co. LLC

JPMMT 2020-9

11/1/20-12/31/20

TL1

LoanDepot.com LLC

JPMMT 2019-9

1/1 to 12/31/20

S69

LoanDepot.com LLC

JPMMT 2020-2

2/1/20-12/31/20

TL2

LoanDepot.com LLC

JPMMT 2020-3

2/1/20-12/31/20

T69

LoanDepot.com LLC

JPMMT 2020-4

6/1/20-12/31/20

TL3

LoanDepot.com LLC

JPMMT 2020-5

7/1/20-12/31/20

TL4

LoanDepot.com LLC

JPMMT 2020-7

9/1/20-12/31/20

TL5

LoanDepot.com LLC

JPMMT 2020-LTV2

9/1/20-12/31/20

TL6

LoanDepot.com LLC

JPMMT 2020-8

10/1/20-12/31/20

TL7

LoanDepot.com LLC

JPMMT 2020-9

11/1/20-12-31/20

J06

Redwood Residential Acquisition Corp

SEMT 2019-2

1/1 to 12/31/20

BU0

UBS Bank USA

SEMT 2018-CH4

1/1 to 12/31/20

 

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

 

 

BU2

UBS Bank USA

SEMT 2018-8

1/1 to 12/31/20

UB8

UBS Bank USA

SEMT 2020-MC1

6/1/20-12/31/20

UF2

United Shore Financial Services, LLC

JPMMT 2019-INV2

1/1 to 12/31/20

UF3

United Shore Financial Services, LLC

JPMMT 2019-7

1/1 to 12/31/20

UF4

United Shore Financial Services, LLC

JPMMT 2019-8

1/1 to 12/31/20

UF6

United Shore Financial Services, LLC

JPMMT-LTV3

1/1 to 12/31/20

UF7

United Shore Financial Services, LLC

JPMMT 2019-9

1/1 to 12/31/20

UF8

United Shore Financial Services, LLC

JPMMT 2019-INV3

1/1 to 12/31/20

UF8

United Shore Financial Services, LLC

JPMMT 2019-INV3

12/1/19-12/31/20

NT0

United Shore Financial Services, LLC

JPMMT 2020-1

1/1/20-12/31/20

UF9

United Shore Financial Services, LLC

JPMMT 2020-LTV1

1/1/20-12/31/20

NT1

United Shore Financial Services, LLC

JPMMT 2020-2

2/1/20-12/31/20

NT2

United Shore Financial Services, LLC

JPMMT 2020-INV1

2/1/20-12/31/20

NT3

United Shore Financial Services, LLC

JPMMT 2020-3

2/1/20-12/31/20

NT5

United Shore Financial Services, LLC

JPMMT 2020-4

6/1/20-12/31/20

NT6

United Shore Financial Services, LLC

JPMMT 2020-5

7/1/20-12/31/20

NT7

United Shore Financial Services, LLC

JPMMT 2020-INV2

7/1/20-12/31/20

NT8

United Shore Financial Services, LLC

JPMMT 2020-6

8/1/20-12/31/20

NT9

United Shore Financial Services, LLC

JPMMT 2020-7

9/1/20-12/31/20

UW0

United Shore Financial Services, LLC

JPMMT 2020-LTV2

9/1/20-12/31/20

UW1

United Shore Financial Services, LLC

JPMMT 2020-8

10/1/20-12/31/20

U55

Amegy

2001-RS2

1/1 to 12/31/20

U55

Amegy

2002-WH32

1/1 to 12/31/20

U55

Amegy

2003-WH18

1/1 to 12/31/20

U55

Amegy

2005-WH3

1/1 to 12/31/20

M80

CITIMORTGAGE

2001-SB1

1/1 to 12/31/20

AG9

AIG Home Loans

PSMC 2018-1

1/1 to 12/31/20

AG2

AIG Home Loans

PSMC 2018-2

1/1 to 12/31/20

AG3

AIG Home Loans

PSMC 2018-3

1/1 to 12/31/20

AG4

AIG Home Loans

PSMC 2018-4

1/1 to 12/31/20

AG7

AIG Home Loans

CSMC 2017-HL1

1/1 to 12/31/20

AG8

AIG Home Loans

CSMC 2017-HL2

1/1 to 12/31/20

AG5

AIG Home Loans

PSMC 2019-1

1/1 to 12/31/20

AG6

AIG Home Loans

PSMC 2019-2

1/1 to 12/31/20

TM0

AIG Home Loans

PSMC 2019-3

1/1 to 12/31/20

AD9

Amerihome Mortgage Co. LLC

JPMMT 2018-8

1/1 to 12/31/20

TD8

Amerihome Mortgage Co. LLC

JPMMT 2018-6

1/1 to 12/31/20

 

RA5

 

Amerihome Mortgage Co. LLC

CIM TRUST 2019- INV3

 

1/1 to 12/31/20

 

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

 

 

 

RA8

 

Amerihome Mortgage Co. LLC

BOFA CIM TRUST

2019-INV2

 

1/1 to 12/31/20

S11

Bethpage Federal Credit Union

SEMT 2013-2

1/1 to 1/31/20

131

Cenlar FSB

ARMT 2004-4

1/1 to 12/31/20

080

Cenlar FSB

CSFB 2003-25

1/1 to 12/31/20

078

Cenlar FSB

CSFB 2003-27

1/1 to 12/31/20

079

Cenlar FSB

CSFB 2004-4

1/1 to 12/31/20

128

Cenlar FSB

CSFB 2004-7

1/1 to 12/31/20

076

Cenlar FSB

CSFB 2004-AR5

1/1 to 8/30/20

129

Cenlar FSB

CSFB 2004-AR8

1/1 to 12/31/20

120

Cenlar FSB

CSFB 2005-1

1/1 to 12/31/20

142 (Cat 1)

Cenlar FSB

MALT 2003-2

1/1 to 12/31/20

142 (Cat 3)

Cenlar FSB

MARM 2003-2

1/1 to 12/31/20

088

Cenlar FSB

MARM 2004-4

1/1 to 12/31/20

030

Cenlar FSB

MASTR 2003-3

1/1 to 12/31/20

135

Cenlar FSB

MASTR 2004-10

1/1 to 12/31/20

N80

CitiMortgage

SASCO 2002 AL1

1/1 to 12/31/20

FK3

FirstKey Mortgage, LLC

FKMT 2014-1

1/1 to 12/31/20

FY5

FirstKey Mortgage, LLC

FKMT 2015-1

1/1 to 12/31/20

H60

HarborView/Wells

HBV 2003-2

1/1 to 12/31/20

G60

HarborView/Wells

HBV 2007-4

1/1 to 12/31/20

HB9

Homebridge

AOMT 2019-1

1/1 to 12/31/20

HM6

Homebridge

AOMT 2019-2

1/1 to 12/31/20

LS2

Liberty Savings Bank

PRIME 2003-CL1

1/1 to 12/31/20

LS1

Liberty Savings Bank

PRIME 2004-CL2

1/1 to 12/31/20

C69

LoanDepot.com LLC

MMCA 2018-MTG1

1/1 to 12/31/20

LD2

LoanDepot.com LLC

MMCA 2018-MTG2

1/1 to 12/31/20

Y59

LoanDepot.com LLC

JPMMT 2017-6

1/1 to 12/31/20

C59

LoanDepot.com LLC

JPMMT 2018-1

1/1 to 12/31/20

D69

LoanDepot.com LLC

JPMMT 2018-4

1/1 to 12/31/20

LD5

LoanDepot.com LLC

JPMMT 2018-5

1/1 to 12/31/20

LD6

LoanDepot.com LLC

JPMMT 2018-6

1/1 to 12/31/20

LD7

LoanDepot.com LLC

JPMMT 2018-8

1/1 to 12/31/20

LD4

LoanDepot.com LLC

JPMMT 2018-LTV1

1/1 to 12/31/20

A79

LoanDepot.com LLC

GSMBS 2019-PJ1

1/1 to 12/31/20

B69

LoanDepot.com LLC

JPMMT 2020-LTV1

1/1/20-12/31/20

P69

LoanDepot.com LLC

JPMMT 2020-1

1/1/20-12/31/20

WF3

Lydian Bank/Wells Fargo

GSR 2006 AR1

1/1 to 12/31/20

WF4

Lydian Bank/Wells Fargo

GSR 2006 AR2

1/1 to 12/31/20

 

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

 

 

E60

Lydian Bank/Wells Fargo

CSFB 2004-AR3

1/1 to 7/31/20

WF1

Lydian Bank/Wells Fargo

CSFB 2004-AR4

1/1 to 12/31/20

J60

Lydian Bank/Wells Fargo

GSR 2005-AR3

1/1 to 12/31/20

WF2

Lydian Bank/Wells Fargo

GSR 2005-AR5

1/1 to 12/31/20

WF7

Lydian Bank/Wells Fargo

MALT 2004-5

1/1 to 12/31/20

WF9

Lydian Bank/Wells Fargo

MALT 2004-9

1/1 to 12/31/20

U60

Lydian Bank/Wells Fargo

MARM 2003-2

1/1 to 12/31/20

WF5

Lydian Bank/Wells Fargo

MARM 2004-1

1/1 to 12/31/20

WF6

Lydian Bank/Wells Fargo

MARM 2004-5

1/1 to 12/31/20

TM1

MAPLE ACQUISITION TRUST (AIG)

PSMC 2020-1

1/1 to 12/31/20

TM2

MAPLE ACQUISITION TRUST (AIG)

PSMC 2020-2

6/1/20-12/31/20

TM3

MAPLE ACQUISITION TRUST (AIG)

PSMC 2020-3

10/1/20-12/31/20

TB5

Matrix Financial Services Corporation-Two Harbors

ABMT 2016-2

1/1 to 12/31/20

TB6

Matrix Financial Services Corporation-Two Harbors

ABMT 2016-1

1/1 to 12/31/20

TB7

Matrix Financial Services Corporation-Two Harbors

ABMT 2015-7

1/1 to 12/31/20

TH3

Matrix Financial Services Corporation-Two Harbors

ABMT 2014-3

1/1 to 12/31/20

TH4

Matrix Financial Services Corporation-Two Harbors

ABMT 2014-2

1/1 to 12/31/20

TH5

Matrix Financial Services Corporation-Two Harbors

ABMT 2014-1

1/1 to 12/31/20

TH6

Matrix Financial Services Corporation-Two Harbors

ABMT 2013-1

1/1 to 12/31/20

TR3

Matrix Financial Services Corporation-Two Harbors

ABMT 2016-3

1/1 to 12/31/20

TW1

Matrix Financial Services Corporation-Two Harbors

ABMT 2015-1

1/1 to 12/31/20

TW2

Matrix Financial Services Corporation-Two Harbors

ABMT 2015-2

1/1 to 12/31/20

TW3

Matrix Financial Services Corporation-Two Harbors

ABMT 2015-3

1/1 to 12/31/20

TW4

Matrix Financial Services Corporation-Two Harbors

ABMT 2015-4

1/1 to 12/31/20

TW5

Matrix Financial Services Corporation-Two Harbors

ABMT 2015-5

1/1 to 12/31/20

TW6

Matrix Financial Services Corporation-Two Harbors

ABMT 2015-6

1/1 to 12/31/20

D94

New York Mortgage

NYMT 2005-1

1/1 to 12/31/20

G94

New York Mortgage

NYMT 2005-2

1/1 to 12/31/20

A94

New York Mortgage

NYMT 2005-3

1/1 to 12/31/20

A54

New York Mortgage Company

NYMC 2006-1

1/1 to 12/31/20

GP2

Pingora Loan Servicing, LLC

JPMMT 2014-5

1/1 to 12/31/20

GP0

Pingora Loan Servicing, LLC

JPMMT 2014-IVR3

1/1 to 10/31/20

PN7

Pingora Loan Servicing, LLC

JPMMT 2014-IVR3

1/1 to 12/31/20

GP1

Pingora Loan Servicing, LLC

JPMMT 2014-OAK4

1/1 to 12/31/20

PN9

Pingora Loan Servicing, LLC

JPMMT 2014-OAK4

1/1 to 12/31/20

GP9

Pingora Loan Servicing, LLC

JPMMT 2015-3

1/1 to 12/31/20

PV9

Pingora Loan Servicing, LLC

JPMMT 2015-5

1/1 to 4/30/20

K06

Redwood Residential Acquisition Corp

SEMT 2012-2

1/1 to 12/31/20

L06

Redwood Residential Acquisition Corp

SEMT 2012-3

1/1 to 12/31/20

 

Appendix A

Securities Covered in Cenlar FSB’s REG AB Attestation

 

 

RW0

Redwood Residential Acquisition Corp

SEMT 2012-6

1/1 to 12/31/20

RW1

Redwood Residential Acquisition Corp

SEMT 2013-1

1/1 to 12/31/20

RW2

Redwood Residential Acquisition Corp

SEMT 2013-2

1/1 to 12/31/20

RW3

Redwood Residential Acquisition Corp

SEMT 2013-3

1/1 to 12/31/20

RW4

Redwood Residential Acquisition Corp

SEMT 2013-4

1/1 to 12/31/20

RW5

Redwood Residential Acquisition Corp

SEMT 2013-5

1/1 to 12/31/20

RW6

Redwood Residential Acquisition Corp

SEMT 2013-6

1/1 to 12/31/20

RW7

Redwood Residential Acquisition Corp

SEMT 2013-7

1/1 to 12/31/20

Y06

Redwood Residential Acquisition Corp

SEMT 2012-5

1/1 to 12/31/20

Z06

Redwood Residential Acquisition Corp

SEMT 2012-4

1/1 to 12/31/20

 

G52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

OMAC 06-1

 

1/1 to 12/31/20

 

H52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

OMAC 2006-2

 

1/1 to 12/31/20

 

J52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

BAFC 2006-H

 

1/1 to 12/31/20

 

K52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

CMLTI 2006-FX1

 

1/1 to 12/31/20

 

P52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

CMLTI 2007-OPX1

 

1/1 to 12/31/20

 

H30

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

HMAC 2004-6

 

1/1 to 12/31/20

 

B52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

OMAC 2005-1

 

1/1 to 12/31/20

 

D52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

OMAC 2005-3

 

1/1 to 12/31/20

 

E52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

OMAC 2005-4

 

1/1 to 12/31/20

 

F52

Wells Fargo (previous client Orchid Island TRS, LLC

fka Opteum Financial Services, LLC)

 

OPTMAC05-5

 

1/1 to 12/31/20

 

 

 

 

 

 

 

Appendix B

 

 

 

SERVICING CRITERIA

 

 

Reference

Criteria

Applicable:

Performed by

Cenlar

Applicable:

Performed by

Vendor (s) for

which Cenlar is

the responsible

party

Inapplicable:

Performed by

Vendor (s)

For which

Cenlar is

NOT the

responsible party

Inapplicable:

NOT performed

by Cenlar or by

subservicer(s) or

vendor (s)

retained by

Cenlar

 

General Servicing Considerations

 

 

 

1122(d)(1)(i)

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.

X

 

 

 

1122(d)(1)(ii)

If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.

 

X

 

 

 

1122(d)(1)(iii)

Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.

 

 

 

X

1122(d)(1)(iv)

A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements.

X

 

 

 

1122(d)(1)(v)

Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.

X

 

 

 

  

Cash Collection and Administration

 

 

 

1122(d)(2)(i)

Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the transaction agreements.

X

X1

 

 

1122(d)(2)(ii)

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

X

 

 

 

1122(d)(2)(iii)

Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.

X

 

 

 

1122(d)(2)(iv)

The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.

 

X2

 

 

 

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

X

 

 

 

 

1

Cenlar uses a third-party provider (Excela Technologies) for processing checks received through its lockbox and Ventanex, a web-based service provider used for borrowers to make payments. Cenlar has elected to take responsibility for assessing compliance with the servicing criterion as permitted by Regulation AB Compliance and Disclosure Interpretations of the Division of Corporation Finance 200.06, “Vendors Engaged by Servicers”

2

Cenlar is required to comply with these criteria in the event that these criteria would occur. There were no instances of occurrence in our Applicable Reporting Period.

 

 

 

 

 

 

 

 

 

SERVICING CRITERIA

 

 

Reference

Criteria

Applicable:

Performed by

Cenlar

Applicable:

Performed by

Vendor (s) for

which Cenlar is

the responsible

party

Inapplicable:

Performed by

Vendor (s)

For which

Cenlar is

NOT the

responsible party

Inapplicable:

NOT performed

by Cenlar or by

subservicer(s) or

vendor (s)

retained by

Cenlar

 

to a foreign financial institution means a foreign financial institution that meets the requirements of

Rule 13k-1(b)(1) of the Securities Exchange Act.

 

 

 

 

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

X

 

 

 

1122(d)(2)(vii)

Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; and (D) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements.

X

 

 

 

  

Investor Remittances and Reporting

 

 

 

1122(d)(3)(i)

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 (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the Servicer.

X3

 

 

 

1122(d)(3)(ii)

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

X

 

 

 

1122(d)(3)(iii)

Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.

X

 

 

 

1122(d)(3)(iv)

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

X

 

 

 

  

Pool Asset Administration

 

 

 

1122(d)(4)(i)

Collateral or security on pool assets is maintained as required by the transaction agreements or related mortgage loan documents.

 

 

 

X

1122(d)(4)(ii)

Pool asset and related documents are safeguarded as required by the transaction agreements

 

 

 

X

 

3

Cenlar’s responsibility in criterion 1122(d)(3)(i)(A) is for providing information to the master servicer in timeframes set forth in the transaction documents. Cenlar is not responsible for criteria 1122(d)(3)(i)(B) and 1122(d)(3)(i)(C). Cenlar is responsible for agreeing the unpaid principal balance to the records of the master servicer as listed in criteria 1122(d)(3)(i)(D).

 

 

 

 

 

SERVICING CRITERIA

 

Reference

Criteria

Applicable:

Performed by

Cenlar

Applicable:

Performed by

Vendor (s) for

which Cenlar is

the responsible

party

Inapplicable:

Performed by

Vendor (s)

For which

Cenlar is

NOT the

responsible party

Inapplicable:

NOT performed

by Cenlar or by

subservicer(s) or

vendor (s)

retained by

Cenlar

1122(d)(4)(iii)

Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.

X4

 

 

 

1122(d)(4)(iv)

Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the 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.

X

 

 

 

1122(d)(4)(v)

The Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.

X

 

 

 

1122(d)(4)(vi)

Changes with respect to the terms or status of an obligor's pool assets (e.g., loan modifications or reagings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.

X

 

 

 

1122(d)(4)(vii)

Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.

X

 

 

 

1122(d)(4)(viii)

Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).

X

 

 

 

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

X

 

 

 

 

4

Cenlar is required to comply with these criteria in the event that these criteria would occur. There were no instances of occurrence in our Applicable Reporting Period.

 

 

1122(d)(4)(x)

Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements.

X

 

 

 

 

 

SERVICING CRITERIA

 

 

Reference

Criteria

Applicable:

Performed by

Cenlar

Applicable:

Performed by

Vendor (s) for

which Cenlar is

the responsible

party

Inapplicable:

Performed by

Vendor (s)

For which

Cenlar is

NOT the

responsible party

Inapplicable:

NOT performed

by Cenlar or by

subservicer(s) or

vendor (s)

retained by

Cenlar

1122(d)(4)(xi)

Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.

 

 

X4

 

1122(d)(4)(xii)

Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission.

X

 

 

 

1122(d)(4)(xiii)

Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the Servicer, or such other number of days specified in the transaction agreements.

X

 

 

 

 

 

1122(d)(4)(xiv)

Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

X

 

 

 

1122(d)(4)(xv)

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.

X2

 

 

 

 

 

 

 

 

2 Cenlar is required to comply with these criteria in the event that these criteria would occur. There were no instances of occurrence in our Applicable Reporting Period.

4 Cenlar obtains an assertion and accompanying 1122 attestation report from CoreLogic Tax Services, LLC and American Security Insurance Company, Standard Guaranty Insurance Company, and TrackSure Insurance Agency, Inc. (collectively Assurant) for performing such activities.