EX-33.9 9 wcm14c19_33-9.htm wcm14c19_33-9.htm - Generated by SEC Publisher for SEC Filing

(logo) BELLOAK

ADVISORS

 

 

MANAGEMENT’S REPORT ON ASSESSMENT OF COMPLIANCE WITH

SEC REGULATION AB SERVICING CRITERIA

 

1.        BellOak, LLC (the “Company”, or “BellOak”) is responsible for assessing compliance with the servicing criteria applicable to it in Items 1122(d)(3)(i)(A-B) and 1122(d)(4)(vii) of the U.S. Securities and Exchange Commission’s Regulation AB, as of and for the year ended December 31, 2023, (the “Reporting Period”), as set forth in Appendix A hereto (the “applicable servicing criteria”). The transactions covered by this report include asset-backed securities transactions for which the Company acted as the Senior Trust Advisor, Trust Advisor, and Operating Advisor for the asset-backed securities transactions listed in Appendix B hereto (the “Platform”).

 

2.        BellOak, LLC used the criteria set forth in Items 1122(d)(3)(i)(A-B) and 1122(d)(4)(vii) of paragraph (d) of Item 1122 of Regulation AB (defined in Appendix A) to provide an assertion on the Company’s assessment of compliance with the applicable servicing criteria.

 

3.        BellOak, LLC has complied, in all material respects, with the applicable servicing criteria as of and for the year ended December 31, 2023, for the Platform.

 

4.        Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on the Company’s assertion on compliance with the applicable servicing criteria for the Reporting Period.

  

 

BellOak, LLC

February 19, 2024

 

/s/ Dennis Grzeskowiak

Dennis Grzeskowiak, Principal of BellOak, LLC

 

 

Appendix A – Applicable Servicing Criteria

 

SERVICING CRITERIA

Reference

Criteria

Item 1122(d)(3)(i)(A-B)

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.

Item 1122(d)(4)(vii)

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

 

 

Appendix B – The Platform

 

BellOak, LLC was named as the Senior Trust Advisor, Trust Advisor and Operating Advisor for all portfolios listed below. However, there was only activity requiring BellOak, LLC to perform the role of Senior Trust Advisor, Trust Advisor, and Operating Advisor for the portfolios designated with a “X” throughout the period in scope listed below.

 

 

 

 

 

Portfolio Name

 

 

 

 

Service Agreement Date

 

 

 

 

Period in Scope

Senior Trust Advisor, Trust Advisor, and Operating Advisor activity required as of and for the year ended December 31, 2023

245 Park Avenue Trust 2017-245P

May 30, 2017

1/1/2023 to 12/31/2023

 

WFCM 2017-C41

November 1, 2017

1/1/2023 to 12/31/2023

 

WFCMT 2017-C39

August 1, 2017

1/1/2023 to 12/31/2023

 

CGCMT 2017-B1

August 1, 2017

1/1/2023 to 12/31/2023

 

MSC 2017-H1

June 1, 2017

1/1/2023 to 12/31/2023

 

WFCM 2017-RB1

March 1, 2017

1/1/2023 to 12/31/2023

 

WFCM 2016-C37

December 1, 2016

1/1/2023 to 12/31/2023

 

WFCM 2016-NXS6

October 1, 2016

1/1/2023 to 12/31/2023

 

WFCM 2016-LC24

September 1, 2016

1/1/2023 to 12/31/2023

 

WFCM 2015-C31

November 1, 2015

1/1/2023 to 12/31/2023

 

WFCM 2015-SG1

August 1, 2015

1/1/2023 to 12/31/2023

X

WFCM 2015-C29

June 1, 2015

1/1/2023 to 12/31/2023

 

GSMS 2015-GC30

May 1, 2015

1/1/2023 to 12/31/2023

 

WFCM 2015-NXS1

April 1, 2015

1/1/2023 to 12/31/2023

X

WFRBS 2014-C25

December 1, 2014

1/1/2023 to 12/31/2023

 

WFRBS 2014-C23

September 1, 2014

1/1/2023 to 12/31/2023

 

WFRBS 2014-C21

August 1, 2014

1/1/2023 to 12/31/2023

 

GSMS 2013-GC10

February 1, 2013

3/31/2023 to 12/31/2023

 

GSMS 2013-GC13

May 1, 2013

3/31/2023 to 12/31/2023

 

GSMS 2014-GC20

April 1, 2014

3/31/2023 to 12/31/2023

X

MSBAM 2013-C12

October 1, 2013

3/31/2023 to 12/31/2023

 

WFRBS 2013-C13

May 1, 2013

3/31/2023 to 12/31/2023

 

WFRBS 2013-C15

August 1, 2013

3/31/2023 to 12/31/2023

X

WFRBS 2013-C17

October 1, 2013

3/31/2023 to 12/31/2023

 

WFRBS 2014-C19

March 1, 2014

3/31/2023 to 12/31/2023

 

CGCMT 2014-GC23

August 1, 2014

3/31/2023 to 12/31/2023

 

BMARK 2023 V2

May 1, 2023

5/1/2023 to 12/31/2023

 

CRSO 2023 - BRND

July 1, 2023

7/1/2023 to 12/31/2023

 

BBCMS 2023 C21

October 1, 2023

10/1/2023 to 12/31/2023

 

WFCM 2015 LC20

March 1, 2015

10/15/2023 to 12/31/2023

 

WFRBS 2014-LC14

February 1, 2014

10/15/2023 to 12/31/2023

 

WFCM 2015 C27

March 1, 2015

10/15/2023 to 12/31/2023

 

CGCMT 2016 C3

November 1, 2016

10/29/2023 to 12/31/2023

 

BMO 2023-5C2

November 1, 2023

11/1/2023 to 12/31/2023

 

MSWF 2023-2

December 1, 2023

12/1/2023 to 12/31/2023

 

DTP 2023 STE2

December 28, 2023

12/28/2023 to 12/31/2023