0001019965-16-000372.txt : 20160330 0001019965-16-000372.hdr.sgml : 20160330 20160330120819 ACCESSION NUMBER: 0001019965-16-000372 CONFORMED SUBMISSION TYPE: 10-K PUBLIC DOCUMENT COUNT: 18 CONFORMED PERIOD OF REPORT: 20160330 0001547361 0001541557 FILED AS OF DATE: 20160330 DATE AS OF CHANGE: 20160330 Commercial mortgages FILER: COMPANY DATA: COMPANY CONFORMED NAME: Morgan Stanley Bank of America Merrill Lynch Trust 2014-C18 CENTRAL INDEX KEY: 0001617760 STANDARD INDUSTRIAL CLASSIFICATION: ASSET-BACKED SECURITIES [6189] STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: 10-K SEC ACT: 1934 Act SEC FILE NUMBER: 333-180779-11 FILM NUMBER: 161537890 BUSINESS ADDRESS: STREET 1: 1585 BROADWAY CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212-761-4000 MAIL ADDRESS: STREET 1: 1585 BROADWAY CITY: NEW YORK STATE: NY ZIP: 10036 10-K 1 msc2014c18_10k_32016.htm MSC 2014-C18 FORM 10-K MSC 2014-C18_10k_32016

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C.  20549

FORM 10-K
(Mark One)
☒ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the fiscal year ended December 31, 2015
or
☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the transition period from _____________ to _____________

333-180779-11
Commission File Number of issuing entity:

Morgan Stanley Bank of America Merrill Lynch Trust 2014-C18
(Central Index Key Number 0001617760)
(Exact name of issuing entity as specified in its charter)

Morgan Stanley Capital I Inc.
(Central Index Key Number 0001547361)
(Exact name of registrant as specified in its charter)

Morgan Stanley Mortgage Capital Holdings LLC
(Central Index Key Number 0001541557)
Bank of America, National Association
(Central Index Key Number 0001102113)
CIBC Inc.
(Central Index Key Number 0001548567)
(Exact names of sponsors as specified in their charters)

47-2087494
47-2098931
47-2108850
47-6535473
(I.R.S. Employer Identification No.)

New York
(State or other jurisdiction of incorporation or organization of the issuing entity)

c/o Morgan Stanley Capital I Inc.
1585 Broadway New York, NY
(Address of principal executive offices of issuing entity)

10036
(Zip Code)

(212) 762-6148
(Registrant's telephone number, including area code of issuing entity)

Securities registered pursuant to Section 12(b) of the Act:  None.
Securities registered pursuant to Section 12(g) of the Act:  None.

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.
Yes ☐  No ☒

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.
Yes ☐  No ☒

Note - Checking the box above will not relieve any registrant required to file reports pursuant to Section 13 or 15(d) of the Exchange Act from their obligations under those Sections

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.     Yes ☒  No ☐

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web Site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files).
Not Applicable.

Indicate by check mark  if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K (§ 229.405 of this chapter) is not contained herein, and will not be contained, to the best of registrant's knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K.
Not Applicable.

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or a smaller reporting company. See the definitions of "large accelerated filer", "accelerated filer", and "smaller reporting company" in Rule 12b-2 of the Exchange Act.
Large accelerated filer ☐Accelerated filer ☐
Non-accelerated filer ☒Smaller reporting company ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act). Yes ☐ No ☒

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at which the common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrant's most recently completed second fiscal quarter.
Not Applicable.

Indicate by check mark whether the registrant has filed all documents and reports required to be filed by Section 12, 13 or 15(d) of the Securities Exchange Act of 1934 subsequent to the distribution of securities under a plan confirmed by a court.
Not Applicable.

Indicate the number of shares outstanding of each of the registrant's classes of common stock, as of the last practicable date.  
Not Applicable.

DOCUMENTS INCORPORATED BY REFERENCE
List hereunder the following documents if incorporated by reference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) into which the document is incorporated:  (1)Any annual report to security holders; (2) Any proxy or information statement; and (3) Any prospectus filed pursuant to Rule 424(b) or (c) under the Securities Act of 1933.  The listed documents should be clearly described for identification purposes (e.g., annual report to security holders for fiscal year ended December 24, 1980).
Not Applicable.

EXPLANATORY NOTES
Except as set forth below, each of the parties to each pooling and servicing agreement listed in the Exhibit Index both (1) participates in the servicing function for purposes of Item 1122 of Regulation AB and (2) constitutes a servicer that meets the criteria in Item 1108(a)(2)(i) through (iii) of Regulation AB for purposes of Item 1123 of Regulation AB:

•   The trustee under a pooling and servicing agreement has a nominal role with respect to the mortgage pool securitized pursuant to such pooling and servicing agreement.  The trustee’s only servicing function is the contingent obligation to make certain advances if the master servicer under such pooling and servicing agreement fails to do so, while all other servicing functions are performed by other parties.  The trustee under each of the pooling and servicing agreements listed in the Exhibit Index has confirmed to the registrant that it has not made any such contingent advances during the reporting period, and consequently, each such trustee does not participate in the servicing function for purposes of Item 1122 of Regulation AB, nor does it perform the functions of a servicer for purposes of the definition of “servicer” under Item 1101 of Regulation AB or for purposes of Item 1123 of Regulation AB.

•   The trust advisor under a pooling and servicing agreement represents the interests of senior certificateholders in the transaction governed by such pooling and servicing agreement and is responsible for monitoring the performance of the special servicer under such pooling and servicing agreement and producing certain reports to certificateholders relating to the resolution of the mortgage pool securitized pursuant to such pooling and servicing agreement.  While the trust advisor under a pooling and servicing agreement has certain reporting obligations in respect of the related mortgage pool, it has no obligation to collect or disburse funds in respect of the mortgage pool or to administer any of the underlying mortgage loans.  Consequently, the trust advisor under a pooling and servicing agreement participates in the servicing function for purposes of Item 1122 of Regulation AB, but is not responsible for the “management or collection of the pool assets or making allocations or distributions to holders of the asset-backed securities” within the meaning of “servicer” under Item 1101 of Regulation AB and does not perform the functions of a servicer for purposes of Item 1123 of Regulation AB.  

In addition, each of the following parties engaged the services of certain servicing function participants and sub-servicers for the reporting period, as set forth below:

•   Wells Fargo Bank, National Association, as master servicer, engaged the services of CoreLogic Commercial Real Estate Services, Inc. and National Tax Search, LLC, in each case as a servicing function participant in respect of the entire mortgage pool for the reporting period.

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
Omitted.

PART II

Item 5. Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities.
Omitted.

Item 6. Selected Financial Data.
Omitted.

Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operation.
Omitted.

Item 7A. Quantitative and Qualitative Disclosures About Market Risk.
Omitted.

Item 8. Financial Statements and Supplementary Data.
Omitted.

Item 9. Changes in and Disagreements With Accountants on Accounting and Financial Disclosure.
Omitted.

Item 9A. Controls and Procedures.
Omitted.

Item 9B. Other Information.
None.

PART III

Item 10. Directors and Executive Officers and Corporate Governance.
Omitted.

Item 11. Executive Compensation.
Omitted.

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters.
Omitted.

Item 13. Certain Relationships and Related Transactions, and Director Independence.
Omitted.

Item 14. Principal Accounting Fees and Services.
Omitted.

PURSUANT TO GENERAL INSTRUCTION J(2) THE FOLLOWING SUBSTITUTE INFORMATION IS BEING PROVIDED IN THIS REPORT ON FORM 10-K

Item 1112(b) of Regulation AB, Significant Obligors Financial Information.
The mortgaged property securing the TKG Retail Portfolio A Mortgage Loan constitutes a significant obligor within the meaning of 1101(k)(2) of Regulation AB.  The most recent (unaudited) net operating income of the significant obligor for the 2015 fiscal year is $10,185,710.

Item 1114(b)(2) of Regulation AB, Significant Enhancement Provider Financial Information.
No entity or group of affiliated entities provides any enhancement or other support for the certificates as described under Item 1114(a) of Regulation AB.

Item 1115(b) of Regulation AB, Certain Derivatives Instruments (Financial Information).
No entity or group of affiliated entities provides any derivative instruments for the certificates as described under Item 1115 of Regulation AB.

Item 1117 of Regulation AB, Legal Proceedings.
The registrant knows of no legal proceedings pending against the sponsors, depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) of Regulation AB, originator contemplated by Item 1110(b) of Regulation AB, or other party contemplated by Item 1100(d)(1) of Regulation AB, or of which any property of the foregoing is the subject, that is material to security holders, other than as disclosed in the prospectus of the issuing entity filed in a 424(b)(5) filing dated September 30, 2014, and other than the following:

Since 2014 various plaintiffs or groups of plaintiffs, primarily investors, have filed claims against U.S. Bank National Association (“U.S. Bank”), in its capacity as trustee or successor trustee (as the case may be) under certain residential mortgage backed securities ("RMBS") trusts. The plaintiffs or plaintiff groups have filed substantially similar complaints against other RMBS trustees, including Deutsche Bank, Citibank, HSBC, Bank of New York Mellon and Wells Fargo. The complaints against U.S. Bank allege the trustee caused losses to investors as a result of alleged failures by the sponsors, mortgage loan sellers and servicers for these RMBS trusts and assert causes of action based upon the trustee's purported failure to enforce repurchase obligations of mortgage loan sellers for alleged breaches of representations and warranties concerning loan quality. The complaints also assert that the trustee failed to notify securityholders of purported events of default allegedly caused by breaches of servicing standards by mortgage loan servicers and that the trustee purportedly failed to abide by a heightened standard of care following alleged events of default.

Currently U.S. Bank is a defendant in multiple actions alleging individual or class action claims against the trustee with respect to multiple trusts as described above with the most substantial case being: BlackRock Balanced Capital Portfolio et al v. U.S. Bank National Association, No. 605204/2015 (N.Y. Sup. Ct.) (class action alleging claims with respect to approximately 794 trusts) and its companion case BlackRock Core Bond Portfolio et al v. U.S Bank National Association, No. 14-cv-9401 (S.D.N.Y.). Some of the trusts implicated in the aforementioned Blackrock cases, as well as other trusts, are involved in actions brought by separate groups of plaintiffs related to no more than 100 trusts per case.

There can be no assurance as to the outcome of any of the litigation, or the possible impact of these litigations on the trustee or the RMBS trusts. However, U.S. Bank denies liability and believes that it has performed its obligations under the RMBS trusts in good faith, that its actions were not the cause of losses to investors and that it has meritorious defenses, and it intends to contest the plaintiffs’ claims vigorously.

Item 1119 of Regulation AB, Affiliations and Certain Relationships and Related Transactions.
The information regarding this Item has been disclosed in the prospectus of the issuing entity filed in a 424(b)(5) filing dated September 30, 2014.

Item 1122 of Regulation AB, Compliance with Applicable Servicing Criteria.
The reports on assessment of compliance with the servicing criteria for asset-backed securities and the related attestation reports on such assessments of compliance are attached hereto under Item 15.

Item 1123 of Regulation AB, Servicer Compliance Statement.
The servicer compliance statements are attached hereto under Item 15.

PART IV

Item 15.  Exhibits, Financial Statement Schedules.

(a) Exhibits
4.1       Pooling and Servicing Agreement, dated as of September 1, 2014, between Morgan Stanley Capital I Inc., as depositor, Wells Fargo Bank, National Association, as master servicer, Rialto Capital Advisors, LLC, as special servicer, Park Bridge Lender Services LLC, as trust advisor, and U.S. Bank National Association, as custodian, trustee, certificate administrator, certificate registrar and authenticating agent (filed as Exhibit 4.1 to the registrant's Current Report on Form 8-K/A filed on October 17, 2014 under SEC File No. 333-180779-11 and incorporated by reference herein).

31       Rule 13a-14(d)/15d-14(d) Certifications.
33     Reports on assessment of compliance with servicing criteria for asset-backed securities.
33.1     U.S. Bank National Association, as Certificate Administrator
33.2     U.S. Bank National Association, as Custodian (see Exhibit 33.1)
33.3     Wells Fargo Bank, National Association, as Master Servicer
33.4     Rialto Capital Advisors, LLC, as Special Servicer
33.5     Park Bridge Lender Services LLC, as Trust Advisor
33.6     CoreLogic Commercial Real Estate Services, Inc., as Servicing Function Participant
33.7     National Tax Search, LLC, as Servicing Function Participant
34     Attestation reports on assessment of compliance with servicing criteria for asset-backed securities.
34.1     U.S. Bank National Association, as Certificate Administrator
34.2     U.S. Bank National Association, as Custodian (see Exhibit 34.1)
34.3     Wells Fargo Bank, National Association, as Master Servicer
34.4     Rialto Capital Advisors, LLC, as Special Servicer
34.5     Park Bridge Lender Services LLC, as Trust Advisor
34.6     CoreLogic Commercial Real Estate Services, Inc., as Servicing Function Participant
34.7     National Tax Search, LLC, as Servicing Function Participant
35     Servicer compliance statements.
35.1     U.S. Bank National Association, as Certificate Administrator
35.2     U.S. Bank National Association, as Custodian
35.3     Wells Fargo Bank, National Association, as Master Servicer
35.4     Rialto Capital Advisors, LLC, as Special Servicer

99.1Mortgage Loan Purchase Agreement, dated September 18, 2014, between Morgan Stanley Capital I Inc. and Morgan Stanley Mortgage Capital Holdings LLC (filed as Exhibit 99.1 to the registrant's Current Report on Form 8-K filed on October 1, 2014 under SEC File No. 333-180779-11 and incorporated by reference herein).
99.2Mortgage Loan Purchase Agreement, dated September 18, 2014, between Morgan Stanley Capital I Inc. and Bank of America, National Association (filed as Exhibit 99.2 to the registrant's Current Report on Form 8-K filed on October 1, 2014 under SEC File No. 333-180779-11 and incorporated by reference herein).
99.3Mortgage Loan Purchase Agreement, dated September 18, 2014, between Morgan Stanley Capital I Inc. and CIBC Inc. (filed as Exhibit 99.3 to the registrant's Current Report on Form 8-K filed on October 1, 2014 under SEC File No. 333-180779-11 and incorporated by reference herein).

b) See Item (a) above.
c) Not Applicable.

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Morgan Stanley Capital I Inc.
(Depositor)

By:  /s/ George Kok
George Kok, President (senior officer in
charge of securitization of the depositor)
Date: March 30, 2016

EXHIBIT INDEX

EXHIBIT DESCRIPTION

4.1       Pooling and Servicing Agreement, dated as of September 1, 2014, between Morgan Stanley Capital I Inc., as depositor, Wells Fargo Bank, National Association, as master servicer, Rialto Capital Advisors, LLC, as special servicer, Park Bridge Lender Services LLC, as trust advisor, and U.S. Bank National Association, as custodian, trustee, certificate administrator, certificate registrar and authenticating agent (filed as Exhibit 4.1 to the registrant's Current Report on Form 8-K/A filed on October 17, 2014 under SEC File No. 333-180779-11 and incorporated by reference herein).

31       Rule 13a-14(d)/15d-14(d) Certifications.
33     Reports on assessment of compliance with servicing criteria for asset-backed securities.
33.1     U.S. Bank National Association, as Certificate Administrator
33.2     U.S. Bank National Association, as Custodian (see Exhibit 33.1)
33.3     Wells Fargo Bank, National Association, as Master Servicer
33.4     Rialto Capital Advisors, LLC, as Special Servicer
33.5     Park Bridge Lender Services LLC, as Trust Advisor
33.6     CoreLogic Commercial Real Estate Services, Inc., as Servicing Function Participant
33.7     National Tax Search, LLC, as Servicing Function Participant
34     Attestation reports on assessment of compliance with servicing criteria for asset-backed securities.
34.1     U.S. Bank National Association, as Certificate Administrator
34.2     U.S. Bank National Association, as Custodian (see Exhibit 34.1)
34.3     Wells Fargo Bank, National Association, as Master Servicer
34.4     Rialto Capital Advisors, LLC, as Special Servicer
34.5     Park Bridge Lender Services LLC, as Trust Advisor
34.6     CoreLogic Commercial Real Estate Services, Inc., as Servicing Function Participant
34.7     National Tax Search, LLC, as Servicing Function Participant
35     Servicer compliance statements.
35.1     U.S. Bank National Association, as Certificate Administrator
35.2     U.S. Bank National Association, as Custodian
35.3     Wells Fargo Bank, National Association, as Master Servicer
35.4     Rialto Capital Advisors, LLC, as Special Servicer

99.1Mortgage Loan Purchase Agreement, dated September 18, 2014, between Morgan Stanley Capital I Inc. and Morgan Stanley Mortgage Capital Holdings LLC (filed as Exhibit 99.1 to the registrant's Current Report on Form 8-K filed on October 1, 2014 under SEC File No. 333-180779-11 and incorporated by reference herein).
99.2Mortgage Loan Purchase Agreement, dated September 18, 2014, between Morgan Stanley Capital I Inc. and Bank of America, National Association (filed as Exhibit 99.2 to the registrant's Current Report on Form 8-K filed on October 1, 2014 under SEC File No. 333-180779-11 and incorporated by reference herein).
99.3Mortgage Loan Purchase Agreement, dated September 18, 2014, between Morgan Stanley Capital I Inc. and CIBC Inc. (filed as Exhibit 99.3 to the registrant's Current Report on Form 8-K filed on October 1, 2014 under SEC File No. 333-180779-11 and incorporated by reference herein).

EX-31 2 31_1_msc2014c18.htm 31 RULE 13A-14(D)/15D-14(D) CERTIFICATIONS. X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\31_msc2014c18

ACTIVE 213861660v.1
CERTIFICATION
Re:
Morgan Stanley Bank of America Merrill Lynch Trust 2014-C18,
Commercial Mortgage Pass-Through Certificates, Series 2014-C18 (the "Transaction"),
issued pursuant to the Pooling and Servicing Agreement dated as of September 1, 2014 (the
"Pooling and Servicing Agreement"), executed in connection with the Transaction (capitalized
terms used but not defined herein have the meanings set forth in the Pooling and Servicing
Agreement).
__________________________________________
I, George Kok, certify that:
1.
I have reviewed this report on Form 10-K and all reports on Form 10-D required
to be filed in respect of the period covered by this report on Form 10-K of Morgan Stanley Bank
of America Merrill Lynch Trust 2014-C18 (the "Exchange Act periodic reports");
2.
Based on my knowledge, the Exchange Act periodic reports, taken as a whole, do
not contain any untrue statement of a material fact or omit to state a material fact necessary to
make the statements made, in light of the circumstances under which such statements were made,
not misleading with respect to the period covered by this report;
3.
Based on my knowledge, all of the distribution, servicing and other information
required to be provided under Form 10-D for the period covered by this report is included in the
Exchange Act periodic reports;
4.
Based on my knowledge and the servicer compliance statement(s) required in this
report under Item 1123 of Regulation AB, and except as disclosed in the Exchange Act periodic
reports, the servicer(s) have fulfilled their obligations under the servicing agreement(s) in all
material respects; and
5.
All of the reports on assessment of compliance with servicing criteria for asset-
backed securities and their related attestation reports on assessment of compliance with servicing
criteria for asset-backed securities required to be included in this report in accordance with Item
1122 of Regulation AB and Exchange Act Rules 13a-18 and 15d-18 have been included as an
exhibit to this report, except as otherwise disclosed in this report. Any material instances of
noncompliance described in such reports have been disclosed in this report on Form 10-K.
In giving the certifications above, I have reasonably relied on information provided to me
by the following unaffiliated parties:
U.S. Bank National Association, as Certificate Administrator
U.S. Bank National Association, as Custodian
Wells Fargo Bank, National Association, as Master Servicer
Rialto Capital Advisors, LLC, as Special Servicer
Park Bridge Lender Services LLC, as Trust Advisor
2
ACTIVE 213861660v.1
CoreLogic Commercial Real Estate Services, Inc., as Servicing Function
Participant
National Tax Search, LLC, as Servicing Function Participant
SOX Certification - MSBAM 2014-C18
ACTIVE 213861660v.1
Date: March 30, 2016
By /s/ George Kok
Name: George Kok
Title: President

EX-33 3 33_1_usba_cac.htm 33.1 U.S. BANK NATIONAL ASSOCIATION, AS CERTIFICATE ADMINISTRATOR X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\33_usba_cac

Management's Assertion
Report on Assessment of Compliance with Applicable Servicing Criteria
U.S. Bank National Association ("U.S. Bank") is responsible for assessing compliance as of and
for the year ended December 31, 2015 with the servicing criteria set forth in Item 1122 (d) of
Regulation AB applicable to it as set forth on Exhibit A hereto. This report covers asset backed
securities transactions within the U.S. Bank Corporate Trust Asset-Backed Securities
Platform
1
(the "Platform")
U.S. Bank hereby provides the following report on its assessment of compliance with the
servicing criteria set forth in Item 1122 of Regulation AB applicable to it and as described on
Exhibit A hereto:
1.
U.S. Bank is responsible for assessing its compliance with the servicing criteria
applicable to it as noted on the accompanying Exhibit A;
2.
Except as set forth in paragraph 3 below, U.S. Bank used the criteria set forth in
paragraph (d) of Item 1122 of Regulation AB to assess its compliance with the applicable
servicing criteria;
3.
The criteria listed in the column titled "Inapplicable Servicing Criteria" on Exhibit A
hereto are inapplicable to U.S. Bank based on the servicing activities it performs directly
with respect to the Platform;
4.
U.S. Bank has complied, in all material respects, with the applicable servicing criteria as
of and for the year ended December 31, 2015; and
5. Ernst & Young, LLP, a registered public accounting firm, has issued an attestation report
on U.S. Bank's assessment of compliance with the applicable servicing criteria as of and
for the year ended December 31, 2015.
U.S. BANK NATIONAL ASSOCIATION
/s/ Bryan R Calder
Name: Bryan R. Calder
Title: Executive Vice President
Date: February 26, 2016
1
The U.S. Bank Corporate Trust Asset-Backed Securities Platform (the "Platform") consists of the
activities involved in the performance of servicing functions for which the Company provides trustee,
securities administration, registrar, paying agent and document custody services for (i) publicly issued
asset-backed and mortgage-backed transactions the securities of which were offered on or after January 1,
2006 and (ii) certain asset-backed transactions for which the Issuer has voluntarily elected to make
Regulation AB compliant filings under the Securities Exchange Act of 1934, as amended.
Corporate Trust ABS Platform (B)
1
EXHIBIT A to Management's Assertion
Reference
Servicing Criteria
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
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
2
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
3
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
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
4
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 13k-1(b)(1) of the
Securities Exchange Act.
X
1122(d)(2)(vi)
Unissued checks are safeguarded so as to prevent unauthorized access.
X
2
No servicing activities were performed by the Company that required the servicing criteria to be complied with.
3
No servicing activities were performed by the Company that required the servicing criteria to be complied with.
4
No servicing activities were performed by the Company that required the servicing criteria to be complied with.
Corporate Trust ABS Platform (B)
2
Reference
Servicing Criteria
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
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.
X
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 pool asset documents.
X
1122(d)(4)(ii)
Pool assets and related documents are safeguarded as required by the transaction
agreements.
X
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.
X
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
Corporate Trust ABS Platform (B)
3
Reference
Servicing Criteria
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
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.
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
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
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.
X
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.
X

EX-33 4 33_3_welf_ms.htm 33.3 WELLS FARGO BANK, NATIONAL ASSOCIATION, AS MASTER SERVICER

 

 

(logo) WELLS
FARGO

Commercial Mortgage Servicing

P.O. Box 31388, Oakland, CA 94604

1901 Harrison St., 2nd Floor

Oakland, CA 94612

Tel: 800 986 9711

 

 

Management’s Assessment

 

Management of Wells Fargo Commercial Mortgage Servicing, a division of Wells Fargo Bank, National Association, (the “Company”) 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 commercial loans (the “Platform”), except for servicing criteria 1122(d)(l)(iii), 1122(d)(3)(i)(B-D), 1122(d)(3)(ii-iv), and l122(d)(4)(xv), which the Company has determined are not applicable to the activities it performs with respect to the Platform, as of and for the year ended December 31, 2015. Appendix A to this letter identifies the commercial mortgage pools and other structures involving the commercial loans constituting the Platform. Appendix B to this letter identifies the applicable servicing criteria with respect to the Platform.

 

With respect to servicing criteria 1122(d)(4)(xi) and 1122(d)(4)(xii), the Company performs applicable activities covered by these criteria, with respect to the Platform, except the Company has engaged various vendors to perform certain tax payment activities. Such vendors have provided separate Regulation AB Item 1122 management assessments and attestations for such activities.

 

With respect to applicable servicing criterion 1122(d)(4)(iii), there were no activities performed during the year ended December 31, 2015 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.

 

With respect to applicable servicing criterion 1122(d)( l )(v), the Company has assessed compliance for all transactions and securities in the Platform, including those issued on or before November 23, 2015 for which compliance was previously assessed under other servicing criteria in accordance with the SEC Division of Corporation Finance's Manual of Publicly Available Interpretations on Regulation AB and Related Rules, Interpretation 11.03, as applicable, for the entire assessment period as of and for the year ended December 31, 2015.

 

With respect to servicing criteria l122(d)(l)(i), 1122(d)(3)(i)(A), 1122(d)(4)(i), and 1122(d)(4)(vi), the Company has engaged various vendors to perform the activities required by these servicing criteria. The Company's management has determined that none of these vendors is 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 criteria applicable to each vendor as permitted by the SEC's Compliance and Disclosure Interpretation (“C&DI”) 200.06, Vendors Engaged by Servicers (C&DI 200.06) (formerly SEC Manual of Publicly Available Telephone Interpretations 17.06). The Company has policies and procedures in place designed to provide reasonable assurance that the vendors' activities comply in all material respects with the servicing criteria applicable to each vendor. The Company's management is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendors and related criteria.

 

The Company's management has assessed the Company's compliance with the applicable servicing criteria as of and for the year ended December 31, 2015. 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 believes that, as of and for the year ended December 31, 2015, the Company has complied in all material respects with the servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform.

 

KPMG 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, 2015.

 

 

March 18, 2016

 

/s/ Daniel E. Bober

Daniel E. Bober

Executive Vice President,

Commercial Mortgage Servicing

Wells Fargo Bank, National Association

 

 

APPENDIX A

 

 

COMMERCIAL MORTGAGE POOLS AND OTHER STRUCTURES

 

 

1166 AVENUE OF AMERICAS 2005-C6

BA-FUNB 2001-3

BANC OF AMERICA COMM MTG 2006-5

 

1166 AVENUE OF THE AMERICAS

2002-C5

BALDR SHERWOOD FUND WH

BANC OF AMERICA COMM MTG 2007-3

 

1211 Avenue of the Americas 2015-1211

BAMLL 2013-DSNY

BANCORP BANK WAREHOUSE

 

 

1345FB2005

 

BAMLL 2013-WBRK

 

BANK OF AMERICA WAREHOUSE

 

 

1345FB2005 (COMPANION)

 

BAMLL 2014-FL1

 

BANK OF NEW YORK MELLON

 

 

2001-CMLB-1

 

BAMLL 2014-520M

 

BARCLAYS WAREHOUSE

 

 

3 WORLD TRADE CENTER 2014

 

BAMLL 2014-8SPR

 

BASIS RE CAPITAL II (REPO)

 

 

7 WORLD TRADE CENTER 2012-WTC

 

BAMLL 2014-FL1 COMPANION

 

BB 2013-TYSN

 

 

7 WORLD TRADE CENTER 2012-WTC COMPANION

 

BAMLL 2014-ICTS

 

BB&T WAREHOUSE

 

A10 2013-1 BACK UP SERVICER

BAMLL 2014-INLD

BBCMS 2014-BXO

 

 

ACCOR MEZZ WAREHOUSE

 

BAMLL 2014-INLD MZ B

 

BBCMS 2015-MSQ

 

 

ACM TRAFFORD V LLC WAREHOUSE

 

BAMLL 2014-IP

 

BBCMS 2015-MSQ COMPANION

 

ACRE 2013-FL1

BAMLL 2015-200P

BBCMS 2015-SLP

 

 

ACRE 2014-FL2

 

BAMLL 2015-ASHF

 

BBCMS 2015-SLP MZ A

 

 

AG MIT CREL (ANGELO GORDON ENTITY) REPO

 

BAMLL 2015-ASHF MZ A

 

BBCRE 2015-GTP

 

ALL STATE_PPG (PARTICIPATION)

BAMLL 2015-ASHF MZ B

BB-UBS 2012-SHOW

 

 

ALTSHULER & FORETHOUGHT WAREHOUSE

 

BAMLL 2015-ASTR

 

BB-UBS 2012-TFT

 

AMERICOLD 2010-ART

BAMLL 2015-HAUL

BEAR 1999-C1

 

AOA 2015-1177

BANC OF AMERICA COMM MTG 2005-6

BELVEDERE CAPITAL WAREHOUSE

 

ARCHETYPE & BARCLAYS REPO

BANC OF AMERICA COMM MTG 2006-1

BERRY ENTERPRISES WAREHOUSE

 

BACM2007-1

BANC OF AMERICA COMM MTG 2006-2

BHMS 2014-ATLS

 

BLACKSTONE (BRE/MWT)

BSC06PWR13

BSCMS05TOP20

 

 

BLCP 2014-CLRN

 

BSC06PWR14

 

BSCMS05TOP20 (COMPANION) 1_NYLIFE

 

BMC MORTGAGES VI

BSC07PWR15

BSCMS05TOP20 (COMPANION) 2_HARTFORDLIFE

 

BROE WAREHOUSE

BSC07PWR16

BSCMS05TOP20 (COMPANION) 3_METLIFE

 

BS01TOP2

BSC07PWR17

BSCMS05TOP20 (COMPANION)_LANDESBANK

 

BSB06001

BSC07PWR18

BUCHANAN FUND V

 

 

BSC00WF2

 

BSC99WF2

 

BUCHANAN MORTGAGE CAPITAL

 

 

BSC01TP4

 

BSCM02TOP8

 

BWAY 2013-1515

 

 

BSC02TP6

 

BSCM03TOP10

 

BWAY 2015-1740

 

 

BSC03PWR2

 

BSCM03TOP12

 

BXHTL 2015-DRMZ MZ B

 

 

BSC04PWR3

 

BSCM04TOP14

 

BXHTL 2015-JWRZ

 

 

BSC04PWR4

 

BSCM04TOP16

 

CANTOR CRE LENDING LP

 

 

BSC04PWR5

 

BSCM05TOP18

 

CANTOR REPO WITH MET LIFE

 

 

BSC04PWR6

 

BSCM05TOP20 (NONPOOLED)

 

CAPITAL LEASE WAREHOUSE-398 & 526

 

BSC05PWR10

BSCM06TOP22

CAPITAL SOURCE RELT 2006-A

 

BSC05PWR7

BSCM06TOP24

CAPLEASE CDO 2005-1

 

BSC05PWR8

BSCM07TOP26

CD 2006-CD2

 

 

BSC05PWR9

 

BSCM07TOP28

 

CD 2006-CD3

 

 

BSC06PWR11

 

BSCM07TOP28 (COMPANION) 1_BALDEAGLE

 

CD 2007-CD4

 

BSC06PWR12

BSCM07TOP28 (COMPANION) 2_STARWOOD

CD 2007-CD4 COMPANION

 

CD 2007-CD5

CGWF 2013-RKWH

COBALT 2007- C3

 

 

CFCRE 2015-RUM

 

CGWF 2013-RKWH COMPANION

 

COBALT 2007- C3 COMPANION

 

CGBAM 2014-HD

CHASE 1999-2

COBALT 2007-C2

 

 

CGBAM 2014-HD COMPANION

 

CHASE 2000-3

 

COBALT 2007-C2 COMPANION

 

 

CGCMT 2013-GC15

 

CHASE-FUNB 1999-1

 

COMM 2009-K3

 

 

CGCMT 2013-GC17

 

CITIGROUP 2005 C3

 

COMM 2009-K4 PRIMARY

 

 

CGCMT 2014-388G

 

CITIGROUP 2006 C5

 

COMM 2010-C1

 

 

CGCMT 2014-GC19

 

CITIGROUP 2006-FL2 COMPANION

 

COMM 2010-C1 COMPANION

 

CGCMT 2014-GC19 COMPANION

CITIGROUP 2007-C6

COMM 2012-9W57

 

 

CGCMT 2014-GC21

 

CITIGROUP 2007-C6 (COMPANION)

 

COMM 2012-CCRE1

 

CGCMT 2014-GC21 COMPANION

CITIGROUP 2012-GC8

COMM 2012-CCRE2

 

 

CGCMT 2014-GC25

 

CITIGROUP 2012-GC8 COMPANION

 

COMM 2012-CCRE3

 

CGCMT 2015-101A

CITIGROUP 2013-375P

COMM 2012-CCRE4

 

 

CGCMT 2015-GC27

 

CITIGROUP 2013-375P COMPANION

 

COMM 2012-LC4

 

CGCMT 2015-GC27 COMPANION

CITIGROUP 2013-GCJ11

COMM 2012-MVP

 

CGCMT 2015-GC31

CITIGROUP 2013-SMP

COMM 2013-CCRE10

 

 

CGCMT 2015-GC31 COMPANION

 

CITIGROUP CMT 2004 C1

 

COMM 2013-CCRE10 COMPANION

 

 

CGCMT 2015-GC33

 

CITIGROUP GLOBAL MARKETS REALTY CORP

 

COMM 2013-CCRE12

 

CGCMT 2015-P1

CITY CENTER 2011-CCHP

COMM 2013-CCRE13

 

 

CGCMT 2015-P1 Companion

 

CITY CENTER 2011-CCHP COMPANION

 

COMM 2013-CCRE6

 

CGCMT 2015-SSHP

CMAT 1999 C1

COMM 2013-CCRE6 COMPANION

 

 

CGRBS 2013-VNO5TH

 

COBALT 2006-C1

 

COMM 2013-FL3 COMPANION

 

 

COMM 2013-SFS

 

COMM 2014-UBS5

 

CORE 2015-CALW

 

 

COMM 2013-THL

 

COMM 2014-UBS5 COMPANION

 

CORE 2015-WEST

 

 

COMM 2013-WWP

 

COMM 2015 -3BP

 

COUNTRYWIDE 2007-MF1

 

 

COMM 2013-WWP COMPANION

 

COMM 2015 CCRE25 Companion

 

CRESS 2008-1 CDO_PLAZAELSEGUNDO

 

COMM 2014-277P

COMM 2015-3BP MEZZ

CREST 2003-2

 

 

COMM 2014-BBG

 

COMM 2015-CCRE22

 

CS FIRST BOSTON 1998 C2

 

 

COMM 2014-CCRE14

 

COMM 2015-CCRE22 COMPANION

 

CSAIL 2015-C2

 

COMM 2014-CCRE14 COMPANION

COMM 2015-CCRE23

CSAIL 2015-C2 COMPANION

 

 

COMM 2014-CCRE15 PRIMARY

 

COMM 2015-CCRE24

 

CSCMC 2007-C4

 

 

COMM 2014-CCRE20

 

COMM 2015-CCRE24 COMPANION

 

CSCMT 2007-C2

 

COMM 2014-FL4

COMM 2015-CCRE25

CSCMT 2007-C3

 

COMM 2014-FL4 COMPANION

COMM 2015-CCRE26

CSF99C01

 

COMM 2014-FL5

COMM 2015-CCRE26 COMPANION

CSFB 2006-C2

COMM 2014-KYO

COMM 2015-LC23

CSFB94CFB1

 

COMM 2014-LC15

 

COMM 2015-LC23 COMPANION

 

CSMC 2014-USA

 

COMM 2014-LC15 COMPANION

 

COMM 2015-PC1

 

DAVIS COMPANIES WAREHOUSE

 

COMM 2014-LC17

 

COMM 2015-PC1 COMPANION

 

DBCCRE 2014-ARCP

 

COMM 2014-LC17 COMPANION

 

COMM07FL14

 

DBUBS 2011- LC3

 

COMM 2014-PAT

 

COMM07FL14 (COMPANION) 2_SOCIETE GENERAL

 

DBUBS 2011-LC1

COMM 2014-UB6 PRIMARY ONLY

COMM07FL14 (NONPOOLED)

DBUBS 2011-LC1 COMPANION

 

COMM 2014-UBS3

 

COMMUNITY SOUTH BANK PORTFOLIO

 

DBUBS 2011-LC2

COMM 2014-UBS3 COMPANION

CORE 2015- TEXW

DBWF 2015-LCM

 

DBWF 2015-LCM COMPANION

 

FREDDIE MAC 2010 K-SCT

 

FREMF 2012-K22 (PRIMARY ONLY)

 

DELPHI CRE FUNDING (ACORE WAREHOUSE)

 

FREMF 2010-K6 PRIMARY ONLY

 

FREMF 2012-K23

DESERT RIDGE MEZZ A WAREHOUSE

FREMF 2010-K7

FREMF 2012-K501-PRIMARY ONLY

DEXIA REAL ESTATE PORTFOLIO

FREMF 2010-K8

FREMF 2012-K705-PRIMARY ONLY

 

DLJ 1998-CG1

 

FREMF 2010-K9

 

FREMF 2012-K706

 

DLJ 1999-CG1

 

FREMF 2011 K12 PRIMARY ONLY

 

FREMF 2012-K707

DLJ 1999-CG2

FREMF 2011-K10 - PRIMARY ONLY

FREMF 2012-K708

DLJ 1999-CG3

FREMF 2011-K11

FREMF 2012-K709 - PRIMARY ONLY

DMARC 1998-C1

FREMF 2011-K13

FREMF 2012-K710 PRIMARY ONLY

DOLLAR GENERAL

FREMF 2011-K14 PRIMARY ONLY

FREMF 2012-K711

ELLIOTT WAREHOUSE

FREMF 2011-K15

FREMF 2012-KF01 PRIMARY ONLY

 

ENERGY PLAZA LEASE TRUST 2002

 

FREMF 2011-K16 - PRIMARY ONLY

 

FREMF 2012-KP01 PRIMARY ONLY

FII F DEBT ACCT PTE LTD

FREMF 2011-K701

FREMF 2013 K28 (PRIMARY)

 

FIVE MILE WAREHOUSE

 

FREMF 2011-K702

 

FREMF 2013 K29 (MASTER)

 

FIVE MILE WAREHOUSE (GS)

 

FREMF 2011-K703

 

FREMF 2013 K30 MASTER

 

FKL 2015-SFR1

 

FREMF 2011-K704

 

FREMF 2013 K32  PRIMARY ONLY

 

FKL SELLER 1 LLC -WF REPO

 

FREMF 2011-KAIV PRIMARY ONLY

 

FREMF 2013 K713

FORTRESS (CF TRANS HOLDCO LLC) WAREHOUSE

FREMF 2012 - K19 PRIMARY ONLY

FREMF 2013-K24 (PRIMARY ONLY)

FORTRESS CREDIT CORP WAREHOUSE

FREMF 2012-K17 PRIMARY AND SPECIAL

FREMF 2013-K25

FORTRESS REPO WITH NATIXIS

FREMF 2012-K18 - PRIMARY ONLY

FREMF 2013-K26

FOUR TIMES SQUARE 2006 - 4TS

FREMF 2012-K20

FREMF 2013-K27

 

FOUR TIMES SQUARE 2006 - 4TS COMPANION

 

FREMF 2012-K21 - PRIMARY ONLY

 

FREMF 2013-K31

FREMF 2013-K33

FREMF 2015-K1501 PRIMARY

FUNB 2000 C2

 

FREMF 2013-K34

 

FREMF 2015-K42

 

FUNB 2001 C2

 

FREMF 2013-K35 (PRIMARY)

 

FREMF 2015-K43 (PRIMARY)

 

FUNB 2001 C2 B NOTES

 

FREMF 2013-K712 PRIMARY ONLY

 

FREMF 2015-K44

 

FUNB 2001 C3

 

FREMF 2013-KS01 PRIMARY

 

FREMF 2015-K45

 

FUNB 2001 C3 B NOTES

 

FREMF 2014 K37 (PRIMARY)

 

FREMF 2015-K46 PRIMARY

 

FUNB 2001 C4

FREMF 2014 K39 PRIMARY

FREMF 2015-K47

FUNB/CHASE 1999 C2

 

FREMF 2014 K715

 

FREMF 2015-K48

 

FUNB99C1

 

FREMF 2014 KS02

 

FREMF 2015-K49

 

FUNB-BA 2001 C1

 

FREMF 2014-K36

 

FREMF 2015-K50 (PRIMARY)

 

GAHR 2015-NRF

 

FREMF 2014-K38 PRIMARY

 

FREMF 2015-K720

 

GCCP H-1, LLC (GROSSMAN)

 

FREMF 2014-K40

 

FREMF 2015-KF07 (PRIMARY)

 

GE 2002 C2

 

FREMF 2014-K41 (PRIMARY)

 

FREMF 2015-KF09 (Primary

Only)

 

GE 2006 C1

FREMF 2014-K714

FREMF 2015-KF10 (PRIMARY)

GECC 2001-3

 

FREMF 2014-K716

 

FREMF 2015-KJ01 (PRIMARY)

 

GECC 2002-1

 

FREMF 2014-K717 PRIMARY

 

FREMF 2015-KKA PRIMARY

 

GECC 2002-3

 

FREMF 2014-KF04

 

FREMF 2015-KP02 (Primary

Only)

 

GECMC 2004 C2

FREMF 2014-KF05

FREMF 2015-KS03

GECMC 2007-C1

 

FREMF 2014-KF06 PRIMARY

 

FULB 1997 C2

 

GEMINI ALTO CENTERVILLE WAREHOUSE

FREMF 2014-KX01 (PRIMARY)

FUNB 1999 C4

GERMAN AMERICAN CAPITAL CORPORATION WARE

FREMF 2015 - K718

FUNB 2000 C1

GOLDMAN 2006-GG6

 

GOLDMAN 2006-GG6 COMPANIONS

 

GSMS 2010-C2

 

GSMS 2014-GC26

 

GOLDMAN 2006-GG8

 

GSMS 2010-C2 COMPANION

 

GSMS 2015-590M

 

GOLDMAN 2006-GG8 COMPANIONS

 

GSMS 2011-GC3

 

GSMS 2015-590M COMPANION

 

GOLDMAN 2007-GG10

 

GSMS 2011-GC5

 

GSMS 2015-GC28

GOLDMAN 2007-GG10 COMPANION

GSMS 2011-GC5 COMPANION

GSMS 2015-GC34

 

GOLDMAN 2010-K5 - PRIMARY ONLY

 

GSMS 2012-ALOHA

 

GSMSC 2010-C1

GOLDMAN SACHS 2005-ROCK

GSMS 2012-BWTR

GSMSC 2010-C1 COMPANION

 

GOLDMAN SACHS WAREHOUSE

 

GSMS 2012-GCJ7

 

GSMSC04GG2

 

GRACE 2014-GRCE

 

GSMS 2012-GCJ7 COMPANION

 

GSMSC04GG2 (COMPANION) 1_VARIABLELIFE

GRAND PACIFIC BUSINESS LOAN TRUST 2005-1

GSMS 2012-GCJ9

HBST 2015-HBS

GREENWICH CCFC 05 GG5 (COMPANION)

GSMS 2012-SHOP

Inland Mortgage Capital LLC Warehouse

GREENWICH CCFC 2002 C1

GSMS 2012-TMSQ

Inland Mortgage Lending REPO

 

GREENWICH CCFC 2003-C1

 

GSMS 2013-GC10

 

IRVINE CORE OFFICE TRUST 2013-IRV

 

GREENWICH CCFC 2003-C2

 

GSMS 2013-GC13

 

JEMB MADISON AVE LLC (BASIS I - 292 MAD)

GREENWICH CCFC 2004-GG1

GSMS 2013-GCJ12

JLC VII WAREHOUSE

 

GREENWICH CCFC 2005-GG5

 

GSMS 2013-GCJ14

 

JLC WAREHOUSE I LLC

 

GREENWICH CCFC 2007-GG11

 

GSMS 2013-GCJ16

 

JLC WAREHOUSE II LLC

 

GREENWICH CCFC 2007-GG11 COMPANION

 

GSMS 2013-KING

 

JLC WAREHOUSE IV LLC (DEUTSCHE REPO)

GREENWICH CCFC 2007-GG9

GSMS 2014-GC18

JLC WH & MEZZ VI LLC (JEFFRIES REPO)

GREENWICH CCFC 2007-GG9 COMPANION

GSMS 2014-GC22

JLC WH & MEZZ VI LLC PT2 (JEFFRIES REPO)

GS COMMERCIAL REAL ESTATE WAREHOUSE

GSMS 2014-GC22 COMPANION

JP MORGAN CHASE

JPM 2012-CIBX COMPANION

JPMBB 2015-C28

JPMC 2014-C20 COMPANION

JPM06CIBC15

JPMBB 2015-C28 COMPANION

JPMC03LN1

JPM06CIBC17

JPMBB 2015-C29

JPMCC 2007-LDP10

 

JPM07CIBC19

 

JPMBB 2015-C30

 

JPMCC 2007-LDP10 COMPANION

 

JPM08C2

 

JPMBB 2015-C30 COMPANION

 

JPMCC 2007-LDP11

 

JPM2006LDP8

 

JPMBB 2015-C32

 

JPMCC 2007-LDP11 COMPANION

 

JPM2007LDP12

 

JPMBB 2015-C32 COMPANION

 

JPMCC 2012-C6

 

JPM6LDP9

 

JPMC 2002 C1

 

JPMCC 2013-C16

 

JPMBB 2013-C15

 

JPMC 2002 C2

 

JPMCC 2013-C16 COMPANION

 

JPMBB 2013-C15 COMPANION

 

JPMC 2002 CIBC5

 

JPMCC 2014-DSTY

 

JPMBB 2013-C17

 

JPMC 2003 CIBC6

 

JPMCC 2014-FL5

 

JPMBB 2013-C17 COMPANION

 

JPMC 2003 ML1

 

JPMCC 2014-FL5 COMPANION

 

JPMBB 2014 - C21 COMPANION

 

JPMC 2003-C1

 

JPMCC 2015-COSMO

 

JPMBB 2014-C21

 

JPMC 2005-LDP2

 

KGS-ALPHA REAL ESTATE

 

JPMBB 2014-C22

 

JPMC 2006 FL2

 

KGS-ALPHA RECM WH REPO W/ CITIBANK

JPMBB 2014-C22 COMPANION

JPMC 2006 FL2 COMPANION

LADDER CAPITAL LLC REPO

 

JPMBB 2014-C23

 

JPMC 2006-LDP7

 

LADDER DEUTSCHE REPO

 

JPMBB 2014-C23 COMPANION

 

JPMC 2006-LDP9

 

LADDER JPM REPO

 

JPMBB 2014-C24

 

JPMC 2006-LDP9 COMPANION

 

LADDER MET LIFE REPO

 

JPMBB 2014-C24 COMPANION

 

JPMC 2011-PLSD

 

LADDER WELLS FARGO REPO

JPMBB 2014-C25

JPMC 2012-CIBX

LB 1998 C4

JPMBB 2014-C25 COMPANION

JPMC 2014-C20

LB 1999 C1

 

LB 1999 C2

 

LB-UBS 2003 C5

 

LBUBS05C3 (SENIOR MEZZ) 5_BAYERISCHE

LB UBS 2000 C5

LB-UBS 2003-C1

LCCM 2014-909

 

LB UBS 2001 C3

 

LB-UBS 2003-C3

 

LCCM2013GCP

 

LB UBS 2002 C2

 

LB-UBS 2005 C5

 

LCRT HOLDINGS LLC WAREHOUSE

 

LB UBS 2002 C7

 

LB-UBS 2005 C7

 

LEHMAN BROTHERS WAREHOUSE

 

LB UBS 2003 C8

 

LB-UBS 2005-C7 COMPANION

 

LEHMAN-UBS 2005 C5 COMPANION

 

LB UBS 2004 C1

 

LB-UBS 2006 C1

 

LIBREMAX WAREHOUSE

 

LB UBS 2004 C4

 

LB-UBS 2006 C1 COMPANION

 

LOANCORE (JEFFERIES) WAREHOUSE

 

LB UBS 2004 C6

 

LB-UBS 2006 C3

 

LONE STAR REPO WITH WELLS FARGO

LB UBS 2004 C6 COMPANION

LB-UBS 2006-C3 COMPANION

LONESTAR (RELIUS) WAREHOUSE 2013

LB UBS 2004 C7

LB-UBS 2006-C6 COMPANION

LONESTAR REPO WITH CB

 

LB UBS 2004 C8

 

LB-UBS 2007-C2

 

LSTAR 2015-3

 

LB UBS 2004 C8 COMPANION

 

LB-UBS 2007-C6

 

LVS II SPE III LLC (AFFILIATE OF PIMCO)

LB UBS 2005 C1

LB-UBS 2007-C6 (COMPANION)

MAIDEN 2008-1

 

LB UBS 2005 C1 COMPANION

 

LB-UBS 2007-C7

 

MARATHON REAL ESTATE CDO 2006- 1

LB UBS 2006-C4

LBUBS05C2

MC FIVE MILE SPE B LLC (COLUMN REPO)

LB UBS 2006-C4 COMPANION

LBUBS05C3

MDC01TP5

 

LB UBS 2006-C6

 

LBUBS05C3 (COMPANION) 1_SORINRE

 

MDC02TP7

LB UBS 2006-C7

LBUBS05C3 (SENIOR MEZZ) 1_METLIFE

MERRILL LYNCH 1996 C2

LB UBS 2006-C7 COMPANION

LBUBS05C3 (SENIOR MEZZ) 2_ING

MERRILL LYNCH 1998 C2

LB UBS 2007-C2 COMPANION

LBUBS05C3 (SENIOR MEZZ) 3_LRP

MERRILL LYNCH 2008-C1

LB UBS 2008-C1

LBUBS05C3 (SENIOR MEZZ) 4_AIBDEBT

MEZZ CAP 2004-C1

MEZZ CAP 2004-C2

MLCFC07-9

MS06TOP23 (COMPANION)_LANDESBANK

MEZZ CAP 2005-C3

MLMT 2002 MW1

MS07TOP25

 

MEZZ CAP 2006-C4

 

MLMT 2005-CKI1

 

MS07TOP27

 

MEZZ CAP 2007-C5

 

MLMT 2006-C2

 

MS07TOP27 AW34 (NONPOOLED)

 

MEZZ CAP LLC (FKA CBA MEZZ)

 

MLMT06C1

 

MS08TOP29

 

MEZZ CAP REIT I, INC

 

MLMT07C1

 

MS2000PRIN

 

MKP CREDIT MASTER FUND MEZZANINE

 

MORGAN GUARANTY TRUST CO. OF NY

 

MSBAM 2013-C11

MKP CREDIT MASTER FUND WAREHOUSE

MORGAN STANLEY

MSBAM 2013-C11 COMPANION

ML 1997-C2

MORGAN STANLEY

MSBAM 2013-C12

 

ML 1998-C3

 

MORGAN STANLEY 2007 IQ14

 

MSBAM 2013-C12 COMPANION

 

ML-CFC 2006-1

 

MORGAN STANLEY 2007-HQ13

 

MSBAM 2013-C13

 

ML-CFC 2006-2

 

MORGAN STANLEY 2007-HQ13 COMPANION

 

MSBAM 2013-C8

ML-CFC 2007-6

MORGAN STANLEY 2011-C3

MSBAM 2013-C8 COMPANION

 

ML-CFC 2007-7

 

MORGAN STANLEY BAML 2012-C6

 

MSBAM 2014-C14

ML-CFC 2007-7 COMPANION

MS03TOP11

MSBAM 2014-C15

MLCFC06-4

MS04TOP13

MSBAM 2014-C15 COMPANION

 

MLCFC07-5

 

MS04TOP15

 

MSBAM 2014-C16

 

MLCFC07-5 (COMPANION)_LEXINGTON

 

MS05TOP17

 

MSBAM 2014-C17

MLCFC07-6

MS05TOP19

MSBAM 2014-C18

 

MLCFC07-6 (COMPANION)_ASTAR

 

MS06TOP21

 

MSBAM 2014-C19

 

MLCFC07-8

 

MS06TOP23

 

MSBAM 2014-C19 COMPANION

 

MSBAM 2015-C22

 

MSC07HQ12

 

MSDWMC OWNER TRUST 2000-F1

 

MSBAM 2015-C22 COMPANION

 

MSC07HQ12 (COMPANION) 1_CIT

 

MSJP 2015-HAUL

MSBAM 2015-C23

MSC07HQ12 (COMPANION) 2_DEUTSCHEAG

NBS REAL ESTATE CAPITAL WAREHOUSE

MSBAM 2015-C23 COMPANION

MSC07IQ13

NLY 2014-FL1

 

MSBAM 2015-C24

 

MSC07IQ14

 

NORTEL NETWORKS TRUST 2001-1

 

MSBAM 2015-C24 COMPANION

 

MSC07IQ16

 

NORTHSTAR (CB LOAN NT-II,LLC) CB REPO

MSBAM 2015-C25

MSC98WF2

NORTHSTAR (NS HEALTHCARE PT 2) WAREHOUSE

MSBAM 2015-C25 COMPANION

MSC99WF1

NORTHSTAR 2013-1 (CLO)

 

MSBAM 2015-C26

 

MSCI03IQ6

 

NORTHSTAR CDO IV LTD

 

MSC 2014-CPT

 

MSCI04IQ7

 

NORTHSTAR CDO IX PRIMARY (MEMORIAL MALL)

MSC 2014-MP

MSCI04IQ8

NORTHSTAR CDO VI

 

MSC 2015-420

 

MSCI05IQ9

 

NORTHSTAR CDO VIII

 

MSC 2015-420 COMPANION

 

MSCI06HQ8

 

NORTHSTAR DB LOAN NT-II REPO

MSC04HQ4

MSCI06HQ9

NORTHSTAR WAREHOUSE

 

MSC05HQ6

 

MSCI06TOP21 (NONPOOLED)

 

NORTHSTAR-CITI REPO WAREHOUSE

 

MSC05HQ6 (COMPANION)_PRUDENTIAL

 

MSCI2007IQ16

 

NORTHSTAR-DB REPO WAREHOUSE (NRFC)

MSC05HQ7

MSD01TP3

NORTHSTAR-DB REPO WAREHOUSE (NSINCOME)

MSC06HQ10

MSDW03HQ2

NS INCOME REIT HOLDINGS LLC WH

 

MSC06IQ11

 

MSDW03TOP9

 

NS RE INCOME OPERATING PARTNESHIP II, LP

NStar (MS Loan NT-I, LLC) MS Repo

PFP III SUB I, LLC

RESOURCE CAPITAL CORP. WAREHOUSE

NSTAR (MS LOAN NT-II, LLC) MS REPO

PILLAR FUNDING (COLUMN FINANCIAL REPO)

RESOURCE CAPITAL REPO WAREHOUSE

NXT CAPITAL FUNDING II, LLC

PILLAR FUNDING LLC WAREHOUSE

RESOURCE REAL ESTATE FUNDING CDO 2006-1

OBP DEPOSITOR, LLC TRUST 2010- OBP

PIMCO (GCCU I LLC)

RESOURCE REF CDO 2007-1

OMEGA WAREHOUSE

PIMCO (TOCU I LLC)

RESOURCES REPO WITH DB

 

ONE LINCOLN 2004-C3

 

PRIME AND METLIFE REPO

 

REXFORD INDUSTRIAL FUND V LP WAREHOUSE

ONE WEST BANK REPO

PRIME FINANCE PARTNERS II, L.P.

RIALTO REPO W/ GS

ONE WILLIAM STREET CAP MASTER FUND WH

PRIME FINANCE PARTNERS III, LP

RIALTO REPO WITH WF

OWS ABS MASTER FUND II, LP

PRIME REPO WITH METLIFE

RIALTO WAREHOUSE 2013

 

OWS CF II SPV LLC Warehouse

 

PRIME REPO WITH U.S. BANK

 

RIVER MARKET BROE WAREHOUSE

 

OWS CF SUB I WAREHOUSE

 

PROPHET WAREHOUSE

 

RLJ III - FINANCE HOLDINGS, LLC

 

OWS COF I MASTER WH

 

PROSIRIS Warehouse

 

RMF SUB LLC WF REPO

 

OWS CREDIT OPPORTUNITY I WH

 

PSBAmherst Finance Construction WH

 

RMF SUB2 LLC (RIALTO REPO)

OWS I ACQUISITIONS, LLC WH

QCMT13QC

ROC DEBT STRATEGY FUND MANAGER LLC

 

OXFORD PROPERTIES WAREHOUSE

RAITH RE FUND I LP WAREHOUSE

ROCKWOOD (375 PARK) WAREHOUSE

 

OXFORD PROPERTIES WAREHOUSE 2

RAITH WAREHOUSE

ROCKWOOD CAPITAL, LLC (NORTHROCK)

 

PCMT03PWR1

RBSCF 2013-GSP

RSO 2015-CRE3

 

 

PEOPLE'S UNITED BANK_COLE MT AND PPG (PA

 

RBSCF 2013-SMV

 

RSO 2015-CRE3 Companion

 

PFP 2015-2

RECM AND COMPASS (KR OFFICE 2)

RSO 2015-CRE4

 

PFP II SUB I, LLC

RESOURCE 2013-CRE1

RSO 2015-CRE4 (Companion)

 

 

PFP III 2014-1

 

RESOURCE 2014-CRE2

 

SAS WAREHOUSE 2013 (H2)

 

 

SCG 2013-SRP1

 

STARWOOD PROPERTY MORTGAGE SUB-2, L.L.C.

 

UCB07-1

 

Seer Capital Management LP

STRATEGIC LAND JOINT VENTURE 2

VALSTONE WAREHOUSE

 

SFAVE 2015-5AVE

TEACHERS INSURANCE & ANNUITY ASSOCIATION

VDNO 2013-PENN

 

SILVERPEAK RE FINANCE LLC WAREHOUSE

TIAA 2007-C4

VNO 2012-6AVE

 

SINGERMAN (RIDGMAR MEZZ LOAN)

TIMES SQUARE HOTEL TRUST

VORNADO DP LLC 2010-VNO

 

SL GREEN - JPM REPO

TISHMAN TFO II LLC WAREHOUSE

VORNADO REALTY L.P. WAREHOUSE

 

SL GREEN REALTY CORP/GRAMERCY

TMSQ 2014-1500

WACHOVIA 2003 C3

 

SL GREEN WAREHOUSE

TOCU II LLC  (PIMCO ENTITY)

WACHOVIA 2003-C4

 

 

SOCIETE GENERALE WAREHOUSE

 

TRIANGLE (NORTHSIDE- ROSSER DEBT HOLDING)

 

WACHOVIA 2003-C5

 

SOUND MARK HORIZONS FUND LP WAREHOUSE

TRIANGLE WAREHOUSE

WACHOVIA 2003-C6

 

SPREF WH I LLC (DEUTSCHE REPO)

TRT LENDING REPO WAREHOUSE

WACHOVIA 2003-C7

 

SPREF WH II WF REPO

TRT LENDING SUBSIDIARY II LLC WAREHOUSE

WACHOVIA 2003-C9

SPREF WH III (SILVERPEAK) COLUMN REPO

TRT LENDING SUBSIDIARY LLC

WACHOVIA 2004 C10

SRE FW MEZZ WAREHOUSE (RIDGMAR MEZZ)

TUEBOR WAREHOUSE (LADDER)

WACHOVIA 2004 C11

SRPT 2014-STAR

UBS 2012-C1

WACHOVIA 2004 C15

 

STARWOOD CITI REPO SUB 6

 

UBS WAREHOUSE

 

WACHOVIA 2004-C11 (COMPANION)

 

STARWOOD MORT FUNDING- MORGAN STANLEY REP

 

UBS-BARCLAYS 2012-C2

 

WACHOVIA 2004-C12

STARWOOD MORTGAGE CAPITAL WAREHOUSE

UBS-BARCLAYS 2012-C4

WACHOVIA 2005 C17

STARWOOD PROPERTY MORTGAGE LLC WAREHOUSE

UBS-CITIGROUP 2011-C1

WACHOVIA 2005-C16

WACHOVIA 2005-C18

WACHOVIA 2007-C32

WFCM 2014-LC16 COMPANION

 

WACHOVIA 2005-C19

 

WACHOVIA 2007-C32 COMPANION

 

WFCM 2014-LC18

WACHOVIA 2005-C20

WACHOVIA 2007-C33

WFCM 2014-TISH

 

WACHOVIA 2005-C21

 

WACHOVIA 2007-C33 COMPANION

 

WFCM 2015-BXRP

WACHOVIA 2005-C21 (COMPANION)

WACHOVIA 2007-C34

WFCM 2015-C26

 

WACHOVIA 2005-C22

 

WACHOVIA 2007-C34 COMPANION

 

WFCM 2015-C27

WACHOVIA 2006 WHALE 7 NON TRUST

WACHOVIA 2007-WHALE 8

WFCM 2015-C28

WACHOVIA 2006-C23

WACHOVIA 2007-WHALE 8 NON TRUST

WFCM 2015-C28 COMPANION

WACHOVIA 2006-C24

WACHOVIA GENERAL PARTICIPANT

WFCM 2015-C29

WACHOVIA 2006-C25

WACHOVIA RED - TAX CREDIT

WFCM 2015-C29 COMPANION

WACHOVIA 2006-C25 (COMPANION)

WASHINGTON SUB, LLC

WFCM 2015-C30

WACHOVIA 2006-C26

WEST RIVER WAREHOUSE

WFCM 2015-C30 COMPANION

 

WACHOVIA 2006-C27

 

WESTERN ALLIANCE BANK WAREHOUSE

 

WFCM 2015-C31

WACHOVIA 2006-C27 - COMPANION

WESTIN TIME SQUARE MEZZANINE

WFCM 2015-C31 Companion

WACHOVIA 2006-C28

WESTIN TIME SQUARE MEZZANINE 2

WFCM 2015-LC20

WACHOVIA 2006-C29

WFCM 2012-LC5

WFCM 2015-LC22

 

WACHOVIA 2006-C29 COMPANION

 

WFCM 2013-120B

 

WFCM 2015-NXS1

 

WACHOVIA 2006-WHALE 7

 

WFCM 2013-BTC

 

WFCM 2015-NXS1 COMPANION

 

WACHOVIA 2007-C30

 

WFCM 2013-LC12

 

WFCM 2015-NXS2

 

WACHOVIA 2007-C30 COMPANION

 

WFCM 2013-LC12 COMPANION

 

WFCM 2015-NXS2 COMPANION

 

WACHOVIA 2007-C31

 

WFCM 2014- LC18 COMPANION

 

WFCM 2015-NXS3

WACHOVIA 2007-C31 COMPANION

WFCM 2014-LC16

WFCM 2015-NXS3 COMPANION

 

WFCM 2015-SG1

 

WFRBS 2013-C13

 

WFRBS 2014-C22 COMPANION

 

WFCM 2015-SG1 Companion

 

WFRBS 2013-C14

 

WFRBS 2014-C23

 

WFCM10C1

 

WFRBS 2013-C15

 

WFRBS 2014-C23 COMPANION

 

WFCM10C1 (PARTICIPATION)_BASIS

 

WFRBS 2013-C15 COMPANION

 

WFRBS 2014-C24

 

WFLD 2014-MONT

 

WFRBS 2013-C16

 

WFRBS 2014-C24 COMPANION

 

WFRBS 2011-C3

 

WFRBS 2013-C16 COMPANION

 

WFRBS 2014-C25

 

WFRBS 2011-C5

 

WFRBS 2013-C17

 

WFRBS 2014-C25 COMPANION

 

WFRBS 2012-C10

 

WFRBS 2013-C18

 

WFRBS 2014-LC14

WFRBS 2012-C6

WFRBS 2013-UBS1

WFRBS11C2

 

WFRBS 2012-C7

 

WFRBS 2014-C19 COMPANION

 

WFRBS11C2 (PARTICIPATION)_WEST RIVER

WFRBS 2012-C8

WFRBS 2014-C19W

WFRBS11C4

 

WFRBS 2012-C9

 

WFRBS 2014-C20

 

WFRBS11C4 (COMPANION)_LIBERTYLIFE

WFRBS 2013 - C17 COMPANION

WFRBS 2014-C21

YELLOW BRICK REAL ESTATE CAPITAL I, LLC

WFRBS 2013-C11

WFRBS 2014-C21 COMPANION

MSFMSFF WH

 

WFRBS 2013-C12

 

WFRBS 2014-C22

 

CGCMT 2015-GC33 Companion

 

LCF UBS Bank Repo

 

FREMF 2015-KJ02

 

FREMF 2015-KF11

 

MSBAM 2015-C27

 

CSAIL 2015-C4

 

JPMBB 2015-C33

 

JPMBB 2015-C33 Companion

 

FREMF 2015-KF12

 

WFCM 2015-NXS4

 

(Pearlmark) Prep Investment Advisors WH

 

FREMF 2015-K721

 

FREMF 2015-K51

WFCM 2015-P2

JPMCC 2015-JP1

CITIGROUP UK WAREHOUSE

 

GOLDMAN SACHS UK WAREHOUSE

 

WELLS FARGO BANK- PARTICIPATION

 

WFB - PORTFOLIO SLAM

WFB - PORTFOLIO

WFB - HELD FOR SALE

WFB - BRIDGE LOANS

 

RECM WFFL SELF STORAGE

 

RECM WFFL SELF STORAGE

 

WFBCREAM

 

WFB - WFRF PORTFOLIO

 

WFB - WFRF MCDONALDS

 

MLFT 2006-1

 

CIBC

 

RAYMOND JAMES BANK

 

VERTICAL CRE CDO

 

CAPITAL TRUST, INC

 

PNC Bank

 

WELLS FARGO IMMG

SOVEREIGN BANK NA

TD BANK

UNION BANK

 

CBA-MEZZANINE CAPITAL FINANCE,

 

LBUBS2005C2 COMPANION

 

LBUBS2005C3 COMPANION

CRE/AFS ESCROW ONLY LOANS

MLCFC 2007 C7

RECM NUVEEN

 

FNMA World Savings

 

RECM GUGGENHEIM

 

World Savings

 

RECM FANNIE MAE II

 

RBS Citizens

 

RECM FANNIE MAE TRANSFER

 

MUFG UNION BANK WAREHOUSE

 

WACHOVIA STRUCTURED FINANCE

 

WACHOVIA STRUCTURED FINANCE

COMM 2014-CCRE20 COMPANION

OWS BCA FUNDING WAREHOUSE

WFCM 2015-LC20 COMPANION

OWS BACF SPV LLC (OWS WH)

COMM 2015-CCRE23 COMPANION

TRIANGLE (NORTHSIDE-ROSSER DEB

REGIONS BANK

FIRSTKEY MASTER SELLER 1 LLC (

RESOURCE (RCC REAL ESTATE SPE

MSBAM 2015-C27 COMPANION

WFBNA ITF CITIBANK NA

GSMS 2015-GC34 COMPANION

 

LOGISTICS UK 2015-PLC

 

SBL 2015-KIND

 

CMTG/CN MORTGAGE REIT LLC (MA

CONCORD REAL ESTATE CDO 2006- 1 (CERITOS

 

MARATHON STRUCTURED FINANCE FUND LP

 

MLFT 2006-1 (COMPANION)_CAPTRUST

 

 

WACHOVIA 2004 C14

 

GECC 2000-1

1999-LIFE1

 

WACHOVIA 2002 C2

 

 

COMM 2013-FL3

 

MSCI04HQ3

 

FREMF 2013-K502 - PRIMARY ONLY

 

 

 

FREMF 2013 KF02 PRIMARY ONLY

 

JPM05LDP3

 

JPMC 2006-LDP7 COMPANION

 

 

FREMF 2014 KF03 (PRIMARY)

 

WACHOVIA 2002 C1

 

CONCORD REAL ESTATE CDO 2006- 1

 

NS 2012-1

WACHOVIA 2003-C8

JPMC 2001 CIBC3

 

 

BREDS LOAN CAPITAL REPO WAREHOUSE

 

WACHOVIA CRE CDO 2006-1

 

LB UBS 2002 C1

 

RBS 2010-MB1

WACHOVIA 2005-C20 (COMPANION)

WACHOVIA 2006-C24 (COMPANION)

NEWCASTLE CDO IX

MS01TOP1

GREENWICH CAPITAL FINANCIAL PRODUCTS INC

RBS WAREHOUSE

CITIGROUP 2006-FL2

 

 

NORTHSTAR-DORAL WAREHOUSE (NRFC)

 

SAF FUNDING, LLC

 

BREDS LOAN CAPITAL II REPO WAREHOUSE

 

KEARNY CREDIT FACILITY WAREHOUSE

 

NRFC WAREHOUSE (SOHO HOUSE)

 

MS2000LIFE1

JPMC 2005-LDP2 COMPANIONS

 

 

GSMS 2015-GS1

 

FREMF 2015-K719

 

APPENDIX B

 

 

APPLICABLE SERVICING CRITERIA WITH RESPECT TO COMMERCIAL LOANS

(THE PLATFORM)

 

 

 

 

 

 

 

SERVICING CRITERIA

 

APPLICABLE SERVICING CRITERIA

 

INAPPLICABLE SERVICING CRITERIA

 

 

 

 

 

 

 

 

 

 

 

 

Reference

 

 

 

 

 

 

 

 

 

 

Criteria

 

 

 

Performed Directly by the Company

Performed by Vendor(s) for which the Company is the Responsible Party

 

 

Performed by vendor(s) for which the Company is NOT the Responsible Party

 

NOT performed by the Company or by subservicer(s) or vendor(s) retained by the Company

 

 

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

 

X

 

 

 

 

 

 

 

1122(d)(l)(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 withsuch servicing activities.

 

X

 

 

 

 

 

 

1122(d)(l)(iii)

Any requirements inthe 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)(l)(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

 

 

 

 

 

 

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

 

 

 

 

 

 

 

 

 

l122(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.

 

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

 

 

 

X

 

 

 

 

 

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

X

 

 

 

 

 

 

 

 

  

 

 

  

 

1122(d)(2)(vi i)

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 with in 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) (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 (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements;

 

 

X

 

 

X

 

 

 

1122(d)(3)(i)(B)

(B) provide information calculated in accordance with the terms specified in the transaction agreements;

 

 

 

X

 

1122(d)(3)(i)(C)

(C) are filed with the Commission as required by its rules and regulations;

 

 

 

X

 

1122(d)(3)(i)(D)

(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.

 

 

 

X

 

 

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 agreement

 

 

 

 

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 Ad ministration

 

 

 

1122(d)(4)(i)

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

X

X

 

 

 

 

 

1122(d)(4)(ii)

Pool assets and related documents are safeguarded as required by the transaction agreement.

X

 

 

 

 

 

 

 

 

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.

 

 

X(l)

 

 

 

 

 

 

 

 

 

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 mortgage loan 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 re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.

 

 

X

 

 

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 mortgage loan 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 mortgage loan documents.

X

 

 

 

 

 

 

 

1122(d)(4)(x)(A)

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

 

 

X

 

 

 

 

 

1122(d)(4)(x)(B)

(B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws;

X

 

 

 

 

 

 

1122(d)(4)(x)(C)

(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

 

 

 

 

 

 

 

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.

 

 

X

 

 

 

 

X (2)

 

 

 

 

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

 

 

 

X(2)

 

 

 

 

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)(l) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.

 

 

 

 

X

 

 

 

(1) There were no activities performed during the year ended December 31, 2015 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.

(2) The vendors, CoreLogic, Inc. and National Tax Search, LLC, provided separate Reg. AB 1122(d) attestations for their tax payment activities as they relate to criteria 1122(d) (4) (xi) and (xii).

 

 EX-33 5 33_4_rial_ss.htm 33.4 RIALTO CAPITAL ADVISORS, LLC, AS SPECIAL SERVICER X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\33_rial_ss

Management's Assertion on Compliance
Management's Assertion on Compliance with Applicable
Regulation AB Servicing Criteria
1.
Rialto Capital Advisors, LLC ("Rialto"), the Special Servicer in the agreements listed on
Exhibit 1 (the "Pooling and Servicing Agreements"), is responsible for assessing compliance
with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB,
for the period from January 1, 2015 up to and including December 31, 2015 or applicable shorter
period there within, (the "Reporting Period"), as set forth in Appendix A hereto. The
transactions covered by this report include the transactions listed on Exhibit 1 that are
commercial mortgage-asset backed securities transactions for which Rialto acted as Special
Servicer on or after January 1, 2015 or for the Applicable Certification Period as listed on
Exhibit 1 (the "Platform"), and were registered after January 1, 2006, with the Securities and
Exchange Commission pursuant to the Securities Act of 1933.
2.
Rialto has engaged certain vendors (the "Vendors") to perform specific, limited, or
scripted activities, and Rialto elects to take responsibility for assessing compliance with the
servicing criteria, or portion of the servicing criteria, applicable to such Vendors' activities as set
forth in Appendix A hereto. Rialto has determined its Vendors are not "servicers" as defined in
Item 1101 (j) of Regulation AB and asserts that it has policies and procedures in place to provide
reasonable assurance that the Vendors' activities comply, in all material respects, with the
servicing criteria applicable to each vendor;
3.
Except as set forth in paragraph 4 below, Rialto used the criteria set forth in paragraph (d)
of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria;
4.
The criteria listed in the column titled "Inapplicable Servicing Criteria" on Appendix A
hereto are inapplicable to Rialto based on the activities it performs, directly or through its
Vendors, with respect to the Platform;
5.
Rialto has complied, in all material respects, with the applicable servicing criteria as of
December 31, 2015, and for the Reporting Period with respect to the Platform taken as a whole.
6.
Rialto has not identified and is not aware of any material instance of noncompliance by
the Vendors with the applicable servicing criteria as of December 31, 2015, and for the
Reporting Period with respect to the Platform taken as a whole;
7.
Rialto has not identified any material deficiency in its policies and procedures to monitor
the compliance by the Vendors with the applicable servicing criteria as of December 31, 2015,
and for the Reporting Period with respect to the Platform taken as a whole; and
8.
NDB Accountants & Consultants, LLP, a registered public accounting firm, has issued an
attestation report on Rialto's assessment of compliance with the applicable servicing criteria for
the Reporting Period.
Management's Assertion on Compliance
Date: March 15, 2016
Name: Adam Singer
Title: Managing Director
Signature: /s/ Adam Singer
Exhibit 1
Pooling and Servicing Agreements
Applicable Certification Period
WFRBS 2012-C8
January 1, 2015, to December 31, 2015
FDIC 2012-C1
January 1, 2015, to December 31, 2015
WFCM 2012-LC5
January 1, 2015, to December 31, 2015
UBS-Barclays 2012-C3
January 1, 2015, to December 31, 2015
UBS-Barclays 2012-C4
January 1, 2015, to December 31, 2015
GSMS 2012-GCJ9
January 1, 2015, to December 31, 2015
JPMCC 2012-LC9
January 1, 2015, to December 31, 2015
COMM 2013-LC6
January 1, 2015, to December 31, 2015
WFRBS 2013-C12
January 1, 2015, to December 31, 2015
UBS-Barclays 2013-C6
January 1, 2015, to December 31, 2015
GSMS 2013-GCJ12
January 1, 2015, to December 31, 2015
WFRBS 2013-C14
January 1, 2015, to December 31, 2015
WFRBS 2011-C5
January 1, 2015, to December 31, 2015
WFCM 2013-LC12
January 1, 2015, to December 31, 2015
WFRBS 2011-C2
January 1, 2015, to December 31, 2015
WFRBS 2011-C3
January 1, 2015, to December 31, 2015
WFRBS 2011-C4
January 1, 2015, to December 31, 2015
UBS-Citigroup 2011-C1
January 1, 2015, to December 31, 2015
UBS 2012-C1
January 1, 2015, to December 31, 2015
WFRBS 2012-C6
January 1, 2015, to December 31, 2015
GSMS 2011-GC3
January 1, 2015, to December 31, 2015
COMM 2013-LC13
January 1, 2015, to December 31, 2015
WFRBS 2013-C16
January 1, 2015, to December 31, 2015
GSMS 2013-GCJ16
January 1, 2015, to December 31, 2015
WFRBS 2013-C17
January 1, 2015, to December 31, 2015
GSMS 2012-GC6
January 1, 2015, to December 31, 2015
MSBAM 2013-C13
January 1, 2015, to December 31, 2015
COMM 2014-CCRE14
January 1, 2015, to December 31, 2015
MSBAM 2014-C14
January 1, 2015, to December 31, 2015
WFRBS 2014-LC14
January 1, 2015, to December 31, 2015
COMM 2014-LC15
January 1, 2015, to December 31, 2015
WFRBS 2014-C20
January 1, 2015, to December 31, 2015
COMM 2014-CCRE18
January 1, 2015, to December 31, 2015
CGCMT 2014-GC23
January 1 , 2015, to December 31, 2015
MSBAM 2014-C17
January 1, 2015, to December 31, 2015
Management's Assertion on Compliance
COMM 2014-UBS5
January 1, 2015, to December 31, 2015
MSBAM 2014-C18
January 1, 2015, to December 31, 2015
COMM 2012-CCRE4
January 1, 2015, to December 31, 2015
COMM 2012-LC4
January 1, 2015, to December 31, 2015
WFRBS 2014-C24
January 1, 2015, to December 31, 2015
JPMBB 2014-C25
January 1, 2015, to December 31, 2015
LCCM 2014-909
January 1, 2015, to December 31, 2015
MLMI 1998-C3
January 1, 2015, to December 31, 2015
Carefree Portfolio Trust 2014-CARE MZ A
January 1, 2015 to December 31, 2015
WFCM 2014-LC18
January 1, 2015, to December 31, 2015
COMM 2015-DC1
March 4, 2015, to December 31, 2015
GSMS 2015-GC28
February 27, 2015, to December 31, 2015
WFCM 2015-C27
March 12, 2015, to December 31, 2015
WFCM 2015-LC20
March 31, 2015, to December 31, 2015
WFCM 2015-NXS1
April 29, 2015, to December 31, 2015
CSAIL 2015-C2
May 20, 2015, to December 31, 2015
CGCMT 2015-GC27 *
July 1, 2015 to December 31, 2015
WFCM 2015-NXS2
July 14, 2015, to December 31, 2015
COMM 2015-PC1
July 14, 2015, to December 31, 2015
CSAIL 2015-C3
August 18, 2015, to December 31, 2015
WFCM 2015-SG1
August 27, 2015, to December 31, 2015
WFCM 2015-LC22
September 29, 2015, to December 31, 2015
COMM 2015-CCRE27
October 29, 2015, to December 31, 2015
WFCM 2015-NXS4
December 9, 2015, to December 31, 2015
MSCI 2015-UBS8
December 15, 2015, to December 31, 2015
*As special servicer solely for the Boca Hamptons Plaza Portfolio Loan Combination.
Management's Assertion on Compliance
APPENDIX A
SERVICING CRITERIA
Reference
Criteria
Performed
by
Servicer
Inapplicable
Servicing
Criteria
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.
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.
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
13k-1(b)(1) of the Securities Exchange Act.
X
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
X
Management's Assertion on Compliance
SERVICING CRITERIA
Reference
Criteria
Performed
by
Servicer
Inapplicable
Servicing
Criteria
specified in the transaction agreements.
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.
X2
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
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.
X
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.
X3
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 re-agings) 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
X
Management's Assertion on Compliance
SERVICING CRITERIA
Reference
Criteria
Performed
by
Servicer
Inapplicable
Servicing
Criteria
requirements established by the transaction agreements.
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
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
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.
X
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.
X4
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.
X
1)
Rialto Capital Advisors, LLC performs the activities pertaining to these criteria, except for specific, limited activities
performed by its third party property managers relating to REO Property, if any. Rialto has elected to take responsibility for
assessing compliance with these servicing criteria with respect to the activities of its third party property managers.
2)
Only items (A) and (B) of the Servicing Criteria are applicable to Rialto Capital Advisors, LLC as special servicer. Items (C)
and (D) are inapplicable as the responsibility for filing reports with the Commission and agreeing totals to the Servicer
records rests with the Trustee and/or Certificate Administrator, as applicable.
Management's Assertion on Compliance
3)
Primary responsibility for processing borrower payments rests with the Master Servicer, however, Rialto Capital Advisors,
LLC may from time to time receive payments on an exception basis which are forwarded to the Master Servicer in
accordance with such criterion.
4)
Rialto Capital Advisors, LLC provides the applicable Master Servicer relating to each deal with the final recovery
determination and data utilized to complete IRS Form 1099C on loans with charge-offs, however, the ultimate responsibility
for adjusting the loan record, reporting to the IRS, and delivering 1099C Forms to the borrower rests with the Master
Servicer.

EX-33 6 33_5_parb_ta.htm 33.5 PARK BRIDGE LENDER SERVICES LLC, AS TRUST ADVISOR X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\33_parb_oa

Park Bridge Lender Services llc
41 Watchung Plaza, Suite 250, Montclair, NJ 07042
www.parkbridgefinancial.com
March 18, 2016
RE: Management's Report on Assessment of 2015 Compliance by
Park Bridge Lender Services LLC with Regulation AB Servicing Criteria
Park Bridge Lender Services LLC (the "Asserting Party") is responsible for assessing its
compliance, as of and for the period ended December 31, 2015, with the servicing criteria set forth in
Title 17, Section 229.1122(d) of the Code of Federal Regulations.
The transactions covered by this assertion are those transactions processed by the Asserting Party in
its capacity as trust or operating advisor for the asset-backed securities transactions listed in Exhibit
A hereto (the "Platform").
The Asserting Party is responsible for assessing its compliance with the servicing criteria applicable
to it. The Asserting Party used the criteria in paragraph (d) of Section 1122 of Regulation AB (17
C.F.R. 229.1122) to assess its compliance. The full outline of the Asserting Party's contractually
applicable servicing criteria under various securitization pooling and servicing agreements can be
found in Exhibit B attached hereto.
Based on its assessment, the Asserting Party believes that, as of and for the periods the contractual
obligations existed in calendar year ending December 31, 2015, the Asserting Party has complied in
all material respects with the servicing criteria set forth in Item 1122(d) of Regulation AB relating to
its trust or operating advisor role with respect to the Platform, except for servicing criteria
1122(d)(1)(i-v), 1122(d)(2)(i-vii), 1122(d)(3)(ii-iv), 1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv), which
the Asserting Party has determined as being inapplicable to the activities it performs with respect the
Platform (the "Applicable Servicing Criteria").
Curcio & Cohen CPAs, PC, an independent registered public accounting firm, has issued an
attestation report on the assessment of compliance with the Applicable Servicing Criteria for the
reporting period as set forth in this assertion.
Signed:
/s/ David M Rodgers
David M. Rodgers
Principal
Exhibit A - page 2 of 7
Exhibit A
Asserting Party's 2015 Servicing Platform
Applicable Certification Period
Securitization Transaction
Start Date
End Date
COMM 2012-LC4
January 01, 2015 to
December 31, 2015
COMM 2012-CCRE2
January 01, 2015 to
December 31, 2015
UBS-B 2012-C3
January 01, 2015 to
December 31, 2015
COMM 2012-CCRE4
January 01, 2015 to
December 31, 2015
COMM 2012-CCRE5
January 01, 2015 to
December 31, 2015
COMM 2013-LC6
January 01, 2015 to
December 31, 2015
COMM 2013-CCRE6
January 01, 2015 to
December 31, 2015
JPMCC 2013-C10
January 01, 2015 to
December 31, 2015
COMM 2013-CCRE7
January 01, 2015 to
December 31, 2015
UBSBB 2013-C6
January 01, 2015 to
December 31, 2015
COMM 2013-CCRE8
January 01, 2015 to
December 31, 2015
MSBAM 2013-C10
January 01, 2015 to
December 31, 2015
COMM 2013-CCRE9
January 01, 2015 to
December 31, 2015
WFCM 2013-LC12
January 01, 2015 to
December 31, 2015
COMM 2013-CCRE10
January 01, 2015 to
December 31, 2015
COMM 2013-LC13
January 01, 2015 to
December 31, 2015
COMM 2013-CCRE11
January 01, 2015 to
December 31, 2015
COMM 2013-CCRE12
January 01, 2015 to
December 31, 2015
WFRBS 2013-UBS1
January 01, 2015 to
December 31, 2015
GSMS 2014-GC18
January 01, 2015 to
December 31, 2015
COMM 2014-CCRE14
January 01, 2015 to
December 31, 2015
MSBAM 2014-C14
January 01, 2015 to
December 31, 2015
COMM 2014-CCRE15
January 01, 2015 to
December 31, 2015
COMM 2014-UBS2
January 01, 2015 to
December 31, 2015
COMM 2014-CCRE16
January 01, 2015 to
December 31, 2015
CGCMT 2014-GC21
January 01, 2015 to
December 31, 2015
COMM 2014-CCRE17
January 01, 2015 to
December 31, 2015
COMM 2014-UBS3
January 01, 2015 to
December 31, 2015
COMM 2014-UBS4
January 01, 2015 to
December 31, 2015
COMM 2014-CCRE19
January 01, 2015 to
December 31, 2015
COMM 2014-LC17
January 01, 2015 to
December 31, 2015
MSBAM 2014-C18
January 01, 2015 to
December 31, 2015
CGCMT 2014-GC25
January 01, 2015 to
December 31, 2015
COMM 2014-CCRE20
January 01, 2015 to
December 31, 2015
COMM 2014-CCRE21
January 01, 2015 to
December 31, 2015
MSBAM 2014-C19
January 01, 2015 to
December 31, 2015
WFCM 2014-LC18
January 01, 2015 to
December 31, 2015
Exhibit A - page 3 of 7
CGCMT 2015-GC27
February 09, 2015 to
December 31, 2015
COMM 2015-LC19
February 04, 2015 to
December 31, 2015
MSBAM 2015-C20
January 29, 2015 to
December 31, 2015
COMM 2015-DC1
March 04, 2015 to
December 31, 2015
CSAIL 2015-C1
March 20, 2015 to
December 31, 2015
COMM 2015-CCRE22
March 25, 2015 to
December 31, 2015
MSBAM 2015-C22
April 22, 2015 to
December 31, 2015
CSAIL 2015-C2
May 20, 2015 to
December 31, 2015
COMM 2015-LC21
June 18, 2015 to
December 31, 2015
MSC 2015-MS1
July 08, 2015 to
December 31, 2015
COMM 2015-PC1
July 14, 2015 to
December 31, 2015
GSMS 2015-GC32
July 31, 2015 to
December 31, 2015
MSBAM 2015-C24
August 05, 2015 to
December 31, 2015
COMM 2015-CCRE24
August 06, 2015 to
December 31, 2015
CGCMT 2015-P1
August 19, 2015 to
December 31, 2015
WFCM 2015-LC22
September 29, 2015 to
December 31, 2015
COMM 2015-CCRE26
October 08, 2015 to
December 31, 2015
COMM 2015-CCRE27
October 29, 2015 to
December 31, 2015
MSBAM 2015-C26
November 12, 2015 to
December 31, 2015
COMM 2015-LC23
November 17, 2015 to
December 31, 2015
CGCMT 2015-GC35
December 08, 2015 to
December 31, 2015
Exhibit B - page 4 of 7
Exhibit B
Regulation AB Section 229.1122(d) Servicing Criteria
Regulation
AB Reference
Servicing Criterion
Performed by
Park Bridge
1
Not Applicable to
Park Bridge
2
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
backup servicer for the mortgage loans 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
1122(d)(2)(i)
Payments on pool assets are deposited into the appropriate
custodial bank accounts and related bank clearing accounts
within no more than two business days of receipt, or such
other number of days specified in the transaction agreements.
X
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.
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 Section 240.13k-1 (b)(1) of this chapter.
X
1122(d)(2)(vi)
Unissued checks were 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: (A) are mathematically accurate; (B) are
prepared within 30 calendar days after the bank statement
cutoff date, or such other number of days specified in the
transaction agreements; (C) are reviewed and approved by
someone other than the person who prepared the
reconciliation; and (D) contain explanations for reconciling
X
Exhibit B - page 5 of 7
Regulation
AB Reference
Servicing Criterion
Performed by
Park Bridge
1
Not Applicable to
Park Bridge
2
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.
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 time frames and other terms set forth in the
transaction agreements.
X
1122(d)(3)(i)(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 provide information
calculated in accordance with the terms specified in the
transaction agreements.
X
1122(d)(3)(i)(C)
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 filed with the
Commission as required by its rules and regulations.
X
3
X
4
1122(d)(3)(i)(D)
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 agree with investors'
or the trustee's records as to the total unpaid principal balance
and number of mortgage loans serviced by the servicer.
X
3
X
4
1122(d)(3)(ii)
Amounts due to investors are allocated and remitted in
accordance with time frames, 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 canceled checks, or other form of payment, or custodial
bank statements.
X
1122(d)(4)(i)
Collateral or security on pool assets is maintained as required
by the transaction agreements or related pool asset
documents.
X
1122(d)(4)(ii)
Pool assets and related documents are safeguarded as
required by the transaction agreements.
X
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.
X
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.
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
Exhibit B - page 6 of 7
Regulation
AB Reference
Servicing Criterion
Performed by
Park Bridge
1
Not Applicable to
Park Bridge
2
1122(d)(4)(vi)
Changes with respect to the terms or status of an obligor's
pool asset (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.
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 time frames 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
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 were returned to the
obligor within 30 calendar days of full repayment of the
related pool asset, or such other number of days specified in
the transaction agreements.
X
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.
X
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.
X
Exhibit B - page 7 of 7
1
The criteria in the column "Performed by Park Bridge" and marked with an "X" is applicable for the Transactions unless
otherwise noted; however, there were no specially serviced loans under the related Transactions during the reporting period.
Therefore, no trust/operating advisor actions were required.
2
The criteria in the column "Not Applicable to Park Bridge" and marked with an "X" was not within the scope of the Asserting
Party's duties in the Transactions.
3
Applicable only to the Transactions listed in Table 2 below.
4
Not applicable to Transactions other than the Transactions identified in Note 3 above.
Table 2
COMM 2012-LC4
COMM 2012-CCRE2
COMM 2012-CCRE4
COMM 2012-CCRE5
COMM 2013-CCRE7
COMM 2013-CCRE9
COMM 2013-LC6
COMM 2013-LC13
COMM 2013-CCRE11
N

EX-33 7 33_6_corl_sfp.htm 33.6 CORELOGIC COMMERCIAL REAL ESTATE SERVICES, INC., AS SERVICING FUNCTION PARTICIPANT

 

(logo) CoreLogic

1 Corelogic Drive

Westlake, TX 76262

corelogic.com

 

 

REPORT ON ASSESSMENT OF COMPLIANCE

 

 

CoreLogic Commercial Real Estate Services, Inc. (the "Asserting Party"), an indirect subsidiary of CoreLogic, Inc, is responsible for assessing compliance as of December 31, 2015, and for the period from January l, 2015 through December 31, 2015 (the "Reporting Period") with the applicable servicing criteria set forth in Title 17, Sections 229 as identified in Appendix A (the "Applicable Servicing Criteria"). The servicing activities covered by this report include all loans for commercial mortgage loan outsourcing customers for which the Asserting Party served as the commercial tax service provider (the "Platform").

 

The Asserting Party has assessed its compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that the Asserting Party has complied, in all material respects, with the Applicable Servicing Criteria as of December 31, 2015, and for the Reporting Period with respect to the Platform taken as a whole.

 

PricewaterhouseCoopers LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Applicable Servicing Criteria as of December 31, 2015, and for the Reporting Period.

 

 

CORELOGIC COMMERCIAL REAL ESTATE SERVICES, INC.

 

/s/ Vicki Chenault

Vicki Chenault,

Senior Vice President

February 4, 2016

 

 

APPENDIX A

 

SERVICING CRITERIA for TITLE 17, SECTION 229

 

 

REFERENCE

 

 

CRITERIA

Applicable

Servicing Criteria

Inapplicable

Servicing Criteria

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 mortgage loans 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 mortgage loans 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

1122(d)(2)(ii)

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

X(i)

 

 

 

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 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)

Eash 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 13‐k‐1(b)(1) of the Securities Exchange Act.

 

 

 

 

X

 

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 assetbacked 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

 

 

SERVICING CRITERIA for TITLE 17, SECTION 229

 

 

REFERENCE

 

 

CRITERIA

Applicable

Servicing Criteria

Inapplicable

Servicing Criteria

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 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 mortgage loans serviced by the Servicer.

 

 

 

 

 

 

 

X

 

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 specfied 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 mortgage loans is maintained as required by the transaction agreements or related mortgage loan documents.

 

X

1122(d)(4)(ii)

Mortgage loan and related documents are safeguarded as required by the transaction agreements.

 

X

 

1122(d)(4)(iii)

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

 

 

X

 

 

 

 

1122(d)(4)(iv)

Payments on mortgage loans, including any payoffs, made in accordance with the related mortgage loan 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 mortgage loan documents.

 

 

 

 

 

X

1122(d)(4)(v)

The Servicer's records regarding the mortgage loans 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 mortgage loans (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.

 

 

 

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 mortgage loan 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 mortgage loans including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).

 

 

 

 

 

 

 

X

 

SERVICING CRITERIA for TITLE 17, SECTION 229

 

 

REFERENCE

 

 

CRITERIA

Applicable

Servicing Criteria

Inapplicable

Servicing Criteria

 

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for mortgage loans with variable rates are computed based on the related mortgage loan documents.

 

X

 

 

 

 

 

 

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 mortgage loan 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 mortgage loan documents and state laws; and (C ) such funds are returned to the obligor within 30 calendar days of full repayment of the related mortgage loans, or such other number of days specified in the transaction agreements.

 

 

 

 

 

 

 

X

 

 

 

 

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.

 

 

 

 

X

 

 

 

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 agreement.

 

X(ii)

 

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.

 

 

X

 

(i) – All wires issued by CoreLogic from client custodial accounts are made by authorized CoreLogic personnel.

 

(ii) – In certaininstances Corelogic has the responsibility for posting disbursements related to tax payments made on behalfof an obligor to the obligor's records maintained by the servicerwithin two businessdays, or such other numberof days specified by the contractwith the servicer.In other instances, Corelogic is not responsible for posting disbursements related to tax payments made on behalfof an obligor to the obligor's records maintained by the servicer.In such instances, Corelogic providesinformation regarding disbursements related to tax payments made on behalfof an obligor to the servicers withintwo business days, or such other numberof days specified by the contract with the servicer.

 

 EX-33 8 33_7_nts_sfp.htm 33.7 NATIONAL TAX SEARCH, LLC, AS SERVICING FUNCTION PARTICIPANT

 

(logo) NTS NATIONAL

TAX SEARCH, LLC

303 E Wacker Drive, Suite 900

Chicago, IL 60601

(312) 233-6440

 

 

REPORT ON ASSESSMENT OF COMPLIANCE WITH APPLICABLE SECURITIES AND

EXCHANGE COMMISSION'S REGULATION AB SERVICING CRITERIA

 

 

For the calendar year ending December 31, 2015, National Tax Search, LLC has been a Tax Service Vendor for Wells Fargo Bank (the "Servicer").

 

National Tax Search, LLC ("NTS") is responsible for assessing compliance as of December 31, 2015 and for the period from January 1, 2015 through December 31, 2015 (the "Reporting Period") with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations (the "CFR''). NTS has used the servicing criteria communicated to NTS by the Servicer to assess compliance with the applicable servicing criteria. Only servicing criteria 1122 (d) (l)(ii), 1122 (d)l(iv), 1122 (d)2(ii), 1122 (d)2(v), 1122(d)2(vi), 1122 (d)2(vii), 1122(d)(4)(xi), and 1122(d)(4)(xii) (the "Applicable Servicing Criteria") are applicable to the activities NTS performs with respect to the transactions covered by this report. NTS has determined that the remaining servicing criteria set forth in Item 1122 (d) of the SEC Regulation AB are not applicable to the activities it performs with respect to the transactions covered by this report. The transactions covered by this report include all tax payments made on behalf of the Servicer using NTS's TaxQ system (the "Platform Transactions").

 

NTS, as a vendor, has assessed its compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that the NTS has complied, in all material respects, with the Applicable Servicing Criteria as of December 31, 2015 and for the Reporting Period with respect to the Platform Transactions taken as a whole.

 

Plante& Moran, PLLC, an independent registered public accounting firm, has issued an attestation report on 'the assessment of compliance with the Applicable Servicing Criteria as of December 31, 2015 and for the Reporting Period as set forth in this assertion.

 

 

National Tax Search, LLC, as Vendor to Servicer

/s/ Lori D. Eshoo

Lori D. Eshoo, President/CEO

January 18, 2016

 

 EX-34 9 34_1_usba_cac.htm 34.1 U.S. BANK NATIONAL ASSOCIATION, AS CERTIFICATE ADMINISTRATOR X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\34_usba_cac

1
Report of Independent Registered Public Accounting Firm
The Board of Directors
U.S. Bank National Association
We have examined management's assertion, included in the accompanying Report on Assessment of
Compliance with Applicable Servicing Criteria, that U.S. Bank National Association (the "Company")
complied with the servicing criteria set forth in Item 1122 (d) of the Securities and Exchange
Commission's Regulation AB for the U.S. Bank Corporate Trust Asset-Backed Securities Platform (the
"Platform"), for which the Company provides trustee, securities administration, registrar, paying agent
and document custody services, as of and for the year ended December 31, 2015, except for servicing
criteria 1122 (d)(1)(iii) and 1122 (d)(4)(iv)-(xiv), which the Company has determined are not applicable
to the activities performed by them with respect to the servicing platform covered by this report.
Management is responsible for the Company's compliance with those servicing criteria. Our
responsibility is to express an opinion on management's assertion about the Company's compliance with
the servicing criteria based on our examination.
Our examination was conducted in accordance with attestation standards established by the American
Institute of Certified Public Accountants, as adopted by the Public Company Accounting Oversight Board
(United States) and, accordingly, included examining, on a test basis, evidence about the Company's
compliance with the applicable servicing criteria and performing such other procedures as we considered
necessary in the circumstances. Our examination included testing of less than all of the individual asset-
backed transactions and securities that comprise the Platform, testing of less than all of the servicing
activities related to the Platform, and determining whether the Company processed those selected
transactions and performed those selected activities in compliance with the servicing criteria.
Furthermore, our procedures were limited to the selected transactions and servicing activities performed
by the Company during the period covered by this report. Our procedures were not designed to determine
whether errors may have occurred either prior to or subsequent to our tests that may have affected the
balances or amounts calculated or reported by the Company during the period covered by this report for
the selected transactions or any other transactions. Although the Company is responsible for assessing
compliance with Items 1122 (d)(1)(ii), 1122 (d)(1)(v) and 1122 (d)(2)(iii) of Regulation AB, there were
no servicing activities performed by the Company as of and for the year ended December 31, 2015, that
required these servicing criteria to be complied with. We believe that our examination provides a
reasonable basis for our opinion. Our examination does not provide a legal determination on the
Company's compliance with the servicing criteria.
In our opinion, management's assertion that the Company complied with the aforementioned servicing
criteria as of and for the year ended December 31, 2015, for the U.S. Bank Corporate Trust Asset-Backed
Securities Platform is fairly stated, in all material respects.
/s/ Ernst & Young LLP
Minneapolis, MN
February 26, 2016

EX-34 10 34_3_welf_ms.htm 34.3 WELLS FARGO BANK, NATIONAL ASSOCIATION, AS MASTER SERVICER

(logo) KPMG

KPMG LLP
Suite 1400
55 Second Street
San Francisco, CA 94105



Report of Independent Registered Public Accounting Firm
 
 
The Board of Directors
Wells Fargo Bank, National Association:
 
We have examined management’s assessment, included in the accompanying Management’s Assessment, that Wells Fargo Commercial Mortgage Servicing, a division of Wells Fargo Bank, National Association (the Company), complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB for the servicing of commercial loans (the Platform), except for servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B-D), 1122(d)(3)(ii-iv), and 1122(d)(4)(xv), which the Company has determined are not applicable to the activities it performs with respect to the Platform, as of and for the year ended December 31, 2015. The Company has determined that servicing criteria 1122(d)(4)(xi) and 1122(d)(4)(xii) are applicable to the activities the Company performs with respect to the Platform, except for certain tax payment activities which the Company has engaged various vendors to perform. With respect to applicable servicing criterion 1122(d)(4)(iii), the Company has determined that there were no activities performed during the year ended December 31, 2015 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities. The Company has determined that servicing criterion 1122(d)(1)(v) is applicable to the activities the Company performs with respect to the Platform for all transactions and securities in the Platform, including those issued on or before November 23, 2015, for which compliance was previously assessed under other servicing criteria in accordance with the SEC Division of Corporate Finance’s Manual of Publicly Available Interpretations on Regulation and Related Rules, Interpretation 11.03, as applicable, for the 2015 assessment period as of and for the year ended December 31, 2015. Appendix A to the accompanying Management’s Assessment identifies the commercial mortgage pools and other structures involving the commercial loans defined by management as constituting the Platform. Management is responsible for the Company’s compliance with the servicing criteria. Our responsibility is to express an opinion on management’s assessment about the Company’s compliance based on our examination.
 
Our examination was conducted in accordance with the attestation standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the servicing criteria specified above and performing such other procedures as we considered necessary in the circumstances. Our examination included testing selected asset-backed transactions and securities that comprise the Platform, testing selected servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.
 
KPMG LLP is a Delaware limited liability partnership, the U.S. member firm of KPMG International Cooperative (“KPMG International”), a Swiss entity.
 
As described in the accompanying Management’s Assessment, for servicing criteria 1122(d)(1)(i), 1122(d)(3)(i)(A), 1122(d)(4)(i), and 1122(d)(4)(vi), the Company has engaged various vendors to perform the activities required by these servicing criteria. The Company has determined that none of these vendors is considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Company has elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by the SEC’s Compliance and Disclosure Interpretation (C&DI) 200.06, Vendors Engaged by Servicers (C&DI 200.06) (formerly SEC Manual Telephone Interpretation 17.06). As permitted by C&DI 200.06, the Company has asserted that it has policies and procedures in place designed to provide reasonable assurance that the vendors’ activities comply in all material respects with the servicing criteria applicable to each vendor. The Company 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 its assertion, and we performed no procedures with respect to the Company’s eligibility to apply C&DI 200.06.
 
In our opinion, management’s assessment that the Company complied with the aforementioned servicing criteria, including servicing criteria 1122(d)(1)(i), 1122(d)(3)(i)(A), 1122(d)(4)(i), and 1122(d)(4)(vi), for which compliance is determined based on C&DI 200.06 as described above, as of and for the year ended December 31, 2015 is fairly stated, in all material respects.
 
 
/s/ KPMG LLP
 
San Francisco, California
March 18, 2016


KPMG LLP is a Delaware limited liability partnership,
the U.S. member firm of KPMG International Cooperative
(“KPMG International”), a Swiss entity.

 

 EX-34 11 34_4_rial_ss.htm 34.4 RIALTO CAPITAL ADVISORS, LLC, AS SPECIAL SERVICER X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\34_rial_ss

NDB, A PCAOB Registered CPA Firm
NDB LLP
Accountants & Consultants
Report of Independent Registered Public Accounting Firm
Senior Management
Rialto Capital Advisors, LLC
We have examined Management
'
s As
s
ertion
,
included in the accomp
a
nying Management's
Assertion on Compliance with Applicable Regulation AB Servicing Criteria ("Management
Assertion
"
), that Rialto Capital Advisors
,
LLC (
"
Rialto")
,
complied with the servicing criteria
set forth in Item 1122(d) of the Securities and E
x
change Commission's (SEC) Regulation AB
with respect to the commercial mortgage loan platform
(
"
Regulation AB Platform
"
)
as defined
in the Management Asse1tion related to the below-named Commercial Mortgage-Asset Backed
Securities Transactions, except for any instances of material non-compliance described therein,
as of December 31
,
2015
,
and for the reporting period of January 1, 2015
,
to December 31, 2015,
or the applicable shorter period there within
,
excluding criteria 1122 (d)(l)(iii), (d)(3)(ii),
(d)(3)(iii), (d)(3)(iv)
,
(d)(4)(iv)
,
(d)(4)(v), (d)(4)(i
x
), (d)(4)(x) (d)(4)(
x
i)
,
(d)(4)(xii)
,
(d)(4)(xiii),
(d)(4)(xiv)
,
and (d)(4)(xv)
,
which management ha
s
determined are not applicable to the activities
performed by Rialto with respect to the platform.
Pooling and Servicing Agreements
Applicable Certification Period
WFRBS 2012-C8
January 1, 2015, to December 31, 2015
FDIC 2012-Cl
January 1,2015, to December 31, 2015
WFCM 2012-LC5
January 1,2015,to December 31,2015
UBS-Barclays 2012-C3
January 1, 2015, to December 31,2015
UBS-Barclays 2012-C4
January 1, 2015, to December 31,2015
GSMS 2012-GJC9
January 1, 2015, to December 31, 2015
JPMCC 2012-LC9
January 1, 2015, to December 31, 2015
COMM 2013-LC6
January 1, 2015, to December 31, 2015
WFRBS 2013-C12
January 1, 2015, to December 31, 2015
UBS-Barclays 2013-C6
January 1,2015, to December 31, 2015
6SMS 2013-6012
January 1, 2015, to December 31, 2015
WFRBS 2013-C14
January 1,2015, to December 31, 2015
WFRBS 2011-C5
January 1,2015, to December 31,2015
WFCM 2013-LC12
January 1,2015, to December 31,2015
WFRBS 2011-C2
January 1, 2015, to December 31,2015
WFRBS 2011-C3
January 1, 2015, to December 31,2015
2
NDB, A PCAOB Registered CPA Firm
As special servicer solely for the Boca Hamptons Plaza Portfolio Loan Combination.
WFRBS 2011-C4
January 1,2015, to December 31,2015
UBS-Citigroup 2011-Cl
January 1,2015, to December 31,2015
UBS 2012-Cl
January 1,2015, to December 31, 2015
WFRBS 2012-C6
January 1,2015, to December 31, 2015
GSMS 2011-GC3
January 1,2015, to December 31, 2015
COMM 2013-LC13
January 1,2015, to December 31, 2015
WFRBS 2013-C16
January 1, 2015, to December 31,2015
GSMS 2013-GCJ16
January 1, 2015, to December 31,2015
WFRBS 2013-C17
January 1, 2015, to December 31,2015
GSMS 2012-GC6
January 1, 2015, to December 31,2015
MSBAM 2013-C13
January 1, 2015, to December 31, 2015
COMM 2014-CCRE14
January 1, 2015, to December 31, 2015
MSBAM 2014-C14
January 1,2015, to December 31,2015
WFRBS 2014-LC14
January 1,2015, to December 31, 2015
COMM 2014-LC15
January 1,2015, to December 31, 2015
WFRBS 2014-C20
January 1,2015, to December 31, 2015
COMM 2014-CCRE18
January 1,2015, to December 31, 2015
CGCMT 2014-GC23
January 1,2015, to December 31, 2015
MSBAM 2014-C17
January 1,2015, to December 31, 2015
COMM 2014-UBS5
January 1, 2015, to December 31, 2015
MSBAM 2014-C18
January 1,2015, to December 31, 2015
COMM 2012-CCRE4
January 1,2015, to December 31, 2015
COMM 2012-LC4
January 1,2015, to December 31, 2015
WFRBS 2014-C24
January 1,2015, to December 31, 2015
JPMBB 2014-C25
January 1,2015, to December 31, 2015
LCCM 2014-909
January 1,2015, to December 31, 2015
MLMI 1998-C3
January 1, 2015, to December 31, 2015
Carefree Portfolio Trust 2014-
CARE MZ A
January 1,2015, to December 31, 2015
WFCM 2014-LC18
January 1,2015, to December 31, 2015
COMM 2015-DCl
March 4, 2015, to December 31,2015
GSMS 2015-GC28
February 27, 2015, to December 31,2015
WFCM 2015-C27
March 12, 2015, to December 31, 2015
WFCM 2015-LC20
March 31,2015, to December 31, 2015
WFCM 2015-NXSl
April 29, 2015, to December 31,2015
CSAIL 2015-C2
May 20, 2015, to December 31,2015
CGCMT 2015-GC27*
July 1, 2015, to December 31, 2015
WFCM 2015-NXS2
July 14, 2015, to December 31, 2015
COMM 2015-PCl
July 14, 2015, to December 31, 2015
CSAIL 2015-C3
August 18, 2015, to December 31,2015
WFCM 2015-SGl
August 27, 2015, to December 31,2015
WFCM 2015-LC22
September 29, 2015, to December 31,2015
COMM 2015-CCRE27
October 29, 2015, to December 31, 2015
WFCM 2015-NXS4
December 9, 2015, to December 31, 2015
MSCI 2015-UBS8
December 15, 2015, to December 31,2015
3
NDB, A PCAOB Registered CPA Firm
Management is responsible for Rialto's compliance with the servicing criteria. Our
responsibility is to express an opinion on Management's Assertion about Rialto's compliance
with the relevant servicing criteria based on our examination.
Our examination was conducted in accordance with standards of the Public Company
Accounting Oversight Board (PCAOB) (United States) and, accordingly, included examining on
a test basis, evidence about Rialto's compliance with the servicing criteria and performing such
other procedures as we considered necessary in the circumstances. Our examination included a
selection of samples of transactions and compliance activities related to the platform during the
examination period and determining whether Rialto processed those transactions and performed
those activities in compliance with the relevant servicing criteria. Our testing of selected
transactions and compliance activities was limited to calculations, reports, and activities
performed by Rialto during the period covered by this report. Our procedures did not include
determining whether errors may have occurred prior to our tests that may have affected the
balances or amounts calculated or reported by Rialto during the period covered by this report for
the selected transactions or any other transaction. We believe that our examination provides a
reasonable basis for our opinion. Our examination does not provide a legal determination on
Rialto' s compliance with the servicing criteria.
In our opinion, Management's Assertion that Rialto complied with the relevant servicing criteria
related to the aforementioned Commercial Mortgage-Asset Backed Securities Transactions,
backed by the mortgage collateral pledged under such Commercial Mortgage-Asset Backed
Securities Transactions, as of December 31, 2015, and the aforementioned reporting period then
ended, is fairly stated, in all material respects.
By: /s/ NDB Accountants & Consultants, LLP
Atlanta, Georgia.
March
15, 2016.

EX-34 12 34_5_parb_ta.htm 34.5 PARK BRIDGE LENDER SERVICES LLC, AS TRUST ADVISOR X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\34_parb_oa

CURCIO
+ COHEN
CERTIFIED PUBLIC ACCOUNTANTS PC 7 PENN PLAZA , SUITE 1500, NEW YORK NY 10001
TEL: 212 557-9800 · FAX: 212 557-9819 · website: w ww.cwccpafirm.com
Report of Independent Registered Public Accounting Firm
Managing Member
Park Bridge Lender Services LLC
Montclair, NJ
We have examined management's assertion, included in the accompanying Management's Report on
Assessment of 2015 Compliance by Park Bridge Lender Services LLC with Regulation AB Servicing
Criteria ("Management's Report"), that Park Bridge Lender Services LLC (the "Company") complied
with the servicing criteria set forth in Item 1122(d) of the U.S. Securities and Exchange Commission's
Regulation AB as of and for the year ended December 31, 2015, excluding those criteria noted as not
applicable (N/A) within Exhibit B to Management's Report. The transactions covered by this report are
only those transactions processed by the Company in its capacity as trust advisor or operating advisor for
the asset backed securities transactions (the "Platform") identified in Management's Report. Reference
Exhibit A to Management's Report for the transactions covered by this examination. Management is
responsible for the Company's compliance with the applicable servicing criteria. Our responsibility is to
express an opinion on management's assertion based on our examination.
Our examination was conducted in accordance with attestation standards of the Public Company
Accounting Oversight Board (United States) and, accordingly, including examining, on a test basis,
evidence about the Company's compliance with the applicable servicing criteria and performing such
other procedures as we considered necessary in the circumstances. Our examination included testing of a
selected sample of the servicing activities related to the Platform, determining whether the Company
performed those selected activities in compliance with the applicable servicing criteria during the
specified period. Our procedures were limited to the selected transactions and servicing activities
performed by the Company during the period covered by this report. Our examination was not designed
to detect material noncompliance arising from errors that may have occurred prior to or subsequent to our
tests, that may have affected the Company's servicing activities during the period covered by this report.
We believe that our examination provides a reasonable basis for our opinion. Our examination does not
provide a legal determination on the Company's compliance with the applicable servicing criteria.
In our opinion, management's assertion that the Company complied with the aforementioned applicable
servicing criteria identified in Exhibit B to Management's Report with respect to the transactions
identified in Exhibit A to Management's Report as of and for the year ended December 31, 2015, for the
Platform, is fairly stated in all material aspects.
/s/ Curcio
&
Cohen, CPA'S, P.C.
Curcio
&
Cohen, CPA'S, P.C.
New York, NY
February 15, 2016
MEMBER OF THE AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS

EX-34 13 34_6_corl_sfp.htm 34.6 CORELOGIC COMMERCIAL REAL ESTATE SERVICES, INC., AS SERVICING FUNCTION PARTICIPANT

 

(logo) pwc

 

 

Report of Independent Registered Public Accounting Firm

 

To the Board of Directors and shareholders of CoreLogic, Inc.:

 

We have examined management’s assertion, included in the accompanying Report on Assessment of Compliance, that CoreLogic Commercial Real Estate Services, Inc. (the "Company"), an indirect subsidiary of CoreLogic, Inc. complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission's Regulation AB for all loans for commercial mortgage loan outsourcing customers for which the Company served as the commercial tax service provider (the "Platform"), as of December 31, 2015 and for the year then ended, only including 1122(d)(1)(iv), 1122(d)(2)(ii), 1122(d)(2)(v), 1122(d)(2)(vi), 1122(d)(2)(vii), 1122(d)(4)(xi), 1122(d)(4)(xii) and 1122(d)(4)(xiii), which the Company has determined are applicable to the servicing activities performed by it with respect to the Platform. Management is responsible for the Company's compliance with the servicing criteria. Our responsibility is to express an opinion on management's assertion based on our examination.

 

Our examination was conducted in accordance with attestation standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of selected servicing activities related to the Platform, and determining whether the Company performed those selected activities in compliance with the applicable servicing criteria. Our procedures were limited to the selected servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to detect noncompliance arising from errors that may have occurred prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.

 

In our opinion, management’s assertion that the Company complied with the aforementioned applicable servicing criteria as of and for the year ended December 31, 2015 for all loans for commercial mortgage loan outsourcing customers for which the Company served as the commercial tax service provider is fairly stated, in all material respects.

 

 

February 4, 2016

 

/s/ PricewaterhouseCoopers

 

 

PricewaterhouseCoopers LLP, 2001 Ross Avenue, Suite 1800, Dallas, Texas 75201

T: (214) 999-1400, F: (214) 754-7991, www.pwc.com/us

 

 EX-34 14 34_7_nts_sfp.htm 34.7 NATIONAL TAX SEARCH, LLC, AS SERVICING FUNCTION PARTICIPANT

 

(logo) plante

           moran

Plante & Moran, PLLC

10 South Riverside Plaza

9th Floor

Chicago, IL 60606

Tel: 312.207.1040

Fax: 312.207.1066

plantemoran.com

 

Report of Independent Registered Public Accounting Firm

 

 

To the Board of Directors

National Tax Search, LLC

 

We have examined National Tax Search, LLC (the "Company") compliance with the Securities and Exchange Commission's Regulation AB Servicing Criteria, set forth-in Item 1122(d) of the Security and Exchange Commission's Regulation AB for the National Tax Search TaxQ system (the "Platform") as of and for the year ended December 31 , 2015. The Company has determined that only certain servicing criteria, 1122(d)(1)(ii), 1122(d)1(iv), 1122(d)2(ii), 1122(d)2(v), 1122(d)2(vi), 1122(d)2(vii), 1122(d)(4)(xi), and 1122(d)(4)(xii), are applicable to the activities performed by it with respect to the Platform covered by this report. The Company has determined that the remaining servicing criteria set forth in Item 1122(d) of the SEC Regulation AB are not applicable to the activities performed by it with respect to the Platform covered by this report.

 

Management is responsible for the Company's compliance with those servicing criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the servicing criteria based on our examination. Our examination was conducted in accordance with standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included a selection of a sample of transactions and compliance activities related to the Platform during the examination period and determining whether the Company processed those transactions and performed those activities in compliance with the servicing criteria. Our testing of selected transactions and compliance activities was limited to calculations, reports, and activities performed by the Company during the period covered by this report. Our procedures did not include determining whether errors may have occurred prior to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company's compliance with the servicing criteria.

 

In our opinion, management’s assertion that the Company complied with the aforementioned servicing criteria as of and for the year ended December 31, 2015 for the Platform is fairly stated in all material respects.

 

 

/s/ Plante & Moran, PLLC

 

Chicago, IL

January 18, 2016

 

(logo) Praxity

MEMBER

GLOBAL ALLIANCE OF

INDEPENDENT FIRMS

 

 EX-35 15 35_1_usba_ca_msc2014c18.htm 35.1 U.S. BANK NATIONAL ASSOCIATION, AS CERTIFICATE ADMINISTRATOR X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\35_usba_ca_msc2014c18

usbank
Annual Statement of Compliance
Morgan Stanley Bank of America Merrill Lynch Trust 2014-C18
VIA: EMAIL
Morgan Stanley Capital I Inc.
1585 Broadway
New York, New York 10036
Attention: Stephen Holmes
stephen.holmes@morganstanley.com
Re:
Pooling and Servicing Agreement dated as of September 1, 2014 (the "Agreement") between
Morgan Stanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association, as the
Master Servicer, Rialto Capital Advisors, LLC, as the Special Servicer, Park Bridge Lender
Services LLC, as the Trust Advisor, U.S. Bank National Association, as the Trustee, Certificate
Administrator, Certificate Registrar, Authenticating Agent and Custodian.
I, Kimberly O. Jacobs, a Senior Vice President of U.S. Bank National Association, as Certificate
Administrator, as a certifying servicer hereby certify that:
(1) A review of the activities of the Certificate Administrator during the preceding calendar year
(the "Reporting Period") and of the performance of the Certificate Administrator under the Agreement
has been made under my supervision; and
(2) To the best of my knowledge, based on such review, the Certificate Administrator has fulfilled
all its obligations under the Agreement in all material respects throughout such Reporting Period.
Capitalized terms used but not defined herein have the meanings set forth in the Agreement.
Date: March 10, 2016
U.S. Bank National Association, as Certificate Administrator
By: /s/ Kimberly O. Jacobs
Kimberly O. Jacobs
Senior Vice President

EX-35 16 35_2_usba_cus_msc2014c18.htm 35.2 U.S. BANK NATIONAL ASSOCIATION, AS CUSTODIAN X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\35_usba_cus_msc2014c18

usbank
Annual Statement of Compliance
Morgan Stanley Bank of America Merrill Lynch Trust 2014-C18
VIA: EMAIL
Morgan Stanley Capital I Inc.
1585 Broadway
New York, New York 10036
Attention: Stephen Holmes
stephen.holmes@morganstanley.com
Re:
Pooling and Servicing Agreement dated as of September 1, 2014 (the "Agreement") between
Morgan Stanley Capital I Inc., as Depositor, Wells Fargo Bank, National Association, as the
Master Servicer, Rialto Capital Advisors, LLC, as the Special Servicer, Park Bridge Lender
Services LLC, as the Trust Advisor, U.S. Bank National Association, as the Trustee, Certificate
Administrator, Certificate Registrar, Authenticating Agent and Custodian.
I, Michael Farrell, a Senior Vice President of U.S. Bank National Association, as Custodian, as a
certifying servicer hereby certify that:
(1) A review of the activities of the Custodian during the preceding calendar year (the "Reporting
Period") and of the performance of the Custodian under the Agreement has been made under my
supervision; and
(2) To the best of my knowledge, based on such review, the Custodian has fulfilled all its
obligations under the Agreement in all material respects throughout such Reporting Period.
Capitalized terms used but not defined herein have the meanings set forth in the Agreement.
Date: March 10, 2016
U.S. Bank National Association, as Custodian
By: /s/ Michael Farrell
Michael Farrell
Senior Vice President

EX-35 17 35_3_welf_ms_msc2014c18.htm 35.3 WELLS FARGO BANK, NATIONAL ASSOCIATION, AS MASTER SERVICER X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\35_welf_ms_msc2014c18

WELLS FARGO
Commercial Mortgage Servicing
D1086-120, 12th Floor
550 South Tryon Street
Charlotte, NC 28202
1-800-326-1334
ANNUAL STATEMENT OF COMPLIANCE
Reference is hereby made to that certain Pooling and Servicing Agreement dated as of
September 1, 2014, by and among Morgan Stanley Capital I Inc., as Depositor, Wells Fargo
Bank, National Association, as Master Servicer, Rialto Capital Advisors, LLC, as Special Servicer,
Park Bridge Lender Services LLC, as Trust Advisor, U.S. Bank National Association, as Trustee,
Certificate Administrator, Certificate Registrar, Authenticating Agent and Custodian , with respect
to Commercial Mortgage Pass-Through Certificates Series 2014-C18 (the "Agreement").
Capitalized terms used herein not otherwise defined shall have the meanings assigned in the
Agreement.
Pursuant to Section 13.9 of the Agreement, I, Daniel Bober, Executive Vice President of
Commercial Mortgage Services do hereby certify that:
1.
A review of the activities of the Master Servicer during the period from January 1,
2015 through December 31, 2015 (the "Reporting Period") , and of its performance
per the Agreement during such period has been made under my supervision, and
2.
To the best of my knowledge, based on such review, the Master Servicer, has fulfilled
all of its obligations under the Agreement in all material respects throughout the
Reporting Period.
IN WITNESS WHEREOF, the undersigned has executed this Certificate as of the
4th day of March 2016.
/s/ Daniel Bober
Daniel Bober
Executive Vice President
Wells Fargo Bank
Wells Fargo Bank, N.A.

EX-35 18 35_4_rial_ss_msc2014c18.htm 35.4 RIALTO CAPITAL ADVISORS, LLC, AS SPECIAL SERVICER X:\Structured Finance\Reg AB\@SEC Filings\Annual Exhibits\Word or PDF Versions\To be Converted\35_rial_ss_msc2014c18

Rialto
CAPITAL
2015 Annual Statement of Servicer Compliance (Item 1123)
Pooling and Servicing Agreement (the "Pooling and Servicing Agreement") dated as of September 1, 2014 by and
among Morgan Stanley Capital I, Inc. as Depositor, Wells Fargo Bank, National Association as Master Servicer,
Rialto Capital Advisors, LLC as Special Servicer, U.S. Bank National Association as Trustee, Certificate
Administrator, Certificate Registrar, Authenticating Agent and Custodian and Park Bridge Lender Services LLC as
Trust Advisor relating to Morgan Stanley Bank of America Merrill Lynch Trust 2014-C18, Commercial Mortgage
Pass-Through Certificates, Series 2014-C18 (MSBAM 2014-C18)
The undersigned, a duly authorized officer of Rialto Capital Advisors, LLC, as special servicer (the "Special
Servicer") herein certifies to the following:
1.
All servicing activities and performance of such servicing activities under the Pooling and Servicing
Agreement are performed on behalf of the Special Servicer.
2.
A review of the servicing activities and performance by the Special Servicer for the period of January 1,
2015 to December 31, 2015 (the "Reporting Period") in accordance with the Pooling and Servicing
Agreement has been conducted under my supervision.
3.
To the best of my knowledge, based on such review, the Special Servicer has fulfilled all of its obligations
under the terms of the Pooling and Servicing Agreement, in all material respects for the Reporting Period
and if there has been a failure to fulfill any such obligations in any material respect, each failure and the
nature and status thereof has been specifically identified herein.
Certified by: /s/ Adam Singer
Date: March 1, 2016
Adam Singer, Managing Director