EX-33.24 11 csc19c18_33-24.htm csc19c18_33-24.htm - Generated by SEC Publisher for SEC Filing

 

 

(logo) PARK BRIDGE LENDER SERVICES LLC

 

 

February 23, 2021

 

RE:          Management’s Report on Assessment of 2020 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 calendar year ended December 31, 2020 (the “Reporting Period”), 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 advisor or operating advisor for the asset-backed securities transactions listed in Exhibit A attached 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 Item 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. The servicing criteria listed in the column title “Inapplicable Servicing Criteria” on Exhibit B hereto are not applicable to PBLS based on the activities it performs with respect to the Platform.

 

Based on its assessment, the Asserting Party believes that, as of and for the periods the contractual obligations existed for the Platform in the Reporting Period, the Asserting Party has complied in all material respects with the servicing criteria listed in the column title “Applicable Servicing Criteria” on Exhibit B hereto (the “Applicable Servicing Criteria”).

 

Dixon Hughes Goodman LLP, 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

 

 

600 THIRD AVENUE, 40TH FLOOR, NEW YORK, NY 10016

WWW.PARKBRIDGEFINANCIAL.COM

 

 

Exhibit A

 

Asserting Party’s 2020 Servicing Platform

 

 

                                                                                                   Applicable Certification Period

Securitization Transaction                                                    Start Date                                      End Date

AVMT 2018-AVM

January 01, 2020

to

December 31, 2020

BACM 2016-UBS10

January 01, 2020

to

December 31, 2020

BACM 2017-BNK3

January 01, 2020

to

December 31, 2020

BANK 2017-BNK5

January 01, 2020

to

December 31, 2020

BANK 2017-BNK6

January 01, 2020

to

December 31, 2020

BANK 2017-BNK8

January 01, 2020

to

December 31, 2020

BANK 2017-BNK9

January 01, 2020

to

December 31, 2020

BANK 2018-BNK11

January 01, 2020

to

December 31, 2020

BANK 2018-BNK12

January 01, 2020

to

December 31, 2020

BANK 2018-BNK14

January 01, 2020

to

December 31, 2020

BANK 2018-BNK15

January 01, 2020

to

December 31, 2020

BANK 2019-BNK16

January 01, 2020

to

December 31, 2020

BANK 2019-BNK19

January 01, 2020

to

December 31, 2020

BANK 2019-BNK20

January 01, 2020

to

December 31, 2020

BANK 2019-BNK21

January 01, 2020

to

December 31, 2020

BANK 2019-BNK23

January 01, 2020

to

December 31, 2020

BANK 2019-BNK24

January 01, 2020

to

December 31, 2020

BANK 2020-BNK26

March 12, 2020

to

December 31, 2020

BANK 2020-BNK27

June 26, 2020

to

December 31, 2020

BANK 2020-BNK28

September 30, 2020

to

December 31, 2020

BANK 2020-BNK30

December 22, 2020

to

December 31, 2020

BBCMS 2017-C1

January 01, 2020

to

December 31, 2020

BBCMS 2018-C2

January 01, 2020

to

December 31, 2020

BBCMS 2019-C4

January 01, 2020

to

December 31, 2020

BBCMS 2020-C7

June 25, 2020

to

December 31, 2020

BMARK 2018-B1

January 01, 2020

to

December 31, 2020

BMARK 2018-B3

January 01, 2020

to

December 31, 2020

BMARK 2018-B4

January 01, 2020

to

December 31, 2020

BMARK 2018-B6

January 01, 2020

to

December 31, 2020

BMARK 2018-B7

January 01, 2020

to

December 31, 2020

BMARK 2019-B13

January 01, 2020

to

December 31, 2020

BMARK 2019-B15

January 01, 2020

to

December 31, 2020

BMARK 2019-B9

January 01, 2020

to

December 31, 2020

BMARK 2020-B16

February 12, 2020

to

December 31, 2020

BMARK 2020-B18

July 31, 2020

to

December 31, 2020

BMARK 2020-B21

November 30, 2020

to

December 31, 2020

BMARK 2020-IG1

February 28, 2020

to

December 31, 2020

BX 2019-OC11

January 01, 2020

to

December 31, 2020

CCUBS 2017-C1

January 01, 2020

to

December 31, 2020

CD 2016-CD1

January 01, 2020

to

December 31, 2020

CD 2016-CD2

January 01, 2020

to

December 31, 2020

CD 2017-CD3

January 01, 2020

to

December 31, 2020

CD 2017-CD4

January 01, 2020

to

December 31, 2020

CD 2017-CD5

January 01, 2020

to

December 31, 2020

CD 2017-CD6

January 01, 2020

to

December 31, 2020

CD 2018-CD7

January 01, 2020

to

December 31, 2020

CD 2019-CD8

January 01, 2020

to

December 31, 2020

CF 2019-CF1

January 01, 2020

to

December 31, 2020

CF 2019-CF2

January 01, 2020

to

December 31, 2020

CF 2019-CF3

January 01, 2020

to

December 31, 2020

CF 2020-P1

April 30, 2020

to

December 31, 2020

CFCRE 2016-C3

January 01, 2020

to

December 31, 2020

CFCRE 2016-C4

January 01, 2020

to

December 31, 2020

CFCRE 2016-C6

January 01, 2020

to

December 31, 2020

CFCRE 2016-C7

January 01, 2020

to

December 31, 2020

CFCRE 2017-C8

January 01, 2020

to

December 31, 2020

CGCMT 2014-GC21

January 01, 2020

to

December 31, 2020

CGCMT 2014-GC25

January 01, 2020

to

December 31, 2020

CGCMT 2015-GC27

January 01, 2020

to

December 31, 2020

CGCMT 2015-GC35

January 01, 2020

to

December 31, 2020

CGCMT 2015-P1

January 01, 2020

to

December 31, 2020

CGCMT 2016-C1

January 01, 2020

to

December 31, 2020

CGCMT 2016-GC37

January 01, 2020

to

December 31, 2020

CGCMT 2016-P3

January 01, 2020

to

December 31, 2020

CGCMT 2016-P4

January 01, 2020

to

December 31, 2020

CGCMT 2016-P5

January 01, 2020

to

December 31, 2020

CGCMT 2016-P6

January 01, 2020

to

December 31, 2020

CGCMT 2017-C4

January 01, 2020

to

December 31, 2020

CGCMT 2017-P7

January 01, 2020

to

December 31, 2020

CGCMT 2018-B2

January 01, 2020

to

December 31, 2020

CGCMT 2018-C6

January 01, 2020

to

December 31, 2020

CGCMT 2019-GC41

January 01, 2020

to

December 31, 2020

CGCMT 2019-GC43

January 01, 2020

to

December 31, 2020

CGCMT 2020-GC46

February 26, 2020

to

December 31, 2020

COMM 2012-CCRE2

January 01, 2020

to

December 31, 2020

COMM 2012-CCRE4

January 01, 2020

to

December 31, 2020

COMM 2012-CCRE5

January 01, 2020

to

December 31, 2020

COMM 2012-LC4

January 01, 2020

to

December 31, 2020

COMM 2013-CCRE10

January 01, 2020

to

December 31, 2020

COMM 2013-CCRE11

January 01, 2020

to

December 31, 2020

COMM 2013-CCRE12

January 01, 2020

to

December 31, 2020

COMM 2013-CCRE6

January 01, 2020

to

December 31, 2020

COMM 2013-CCRE7

January 01, 2020

to

December 31, 2020

COMM 2013-CCRE8

January 01, 2020

to

December 31, 2020

COMM 2013-CCRE9

January 01, 2020

to

December 31, 2020

COMM 2013-LC13

January 01, 2020

to

December 31, 2020

COMM 2013-LC6

January 01, 2020

to

December 31, 2020

COMM 2014-CCRE14

January 01, 2020

to

December 31, 2020

COMM 2014-CCRE15

January 01, 2020

to

December 31, 2020

COMM 2014-CCRE16

January 01, 2020

to

December 31, 2020

COMM 2014-CCRE17

January 01, 2020

to

December 31, 2020

COMM 2014-CCRE18

January 01, 2020

to

December 31, 2020

COMM 2014-CCRE19

January 01, 2020

to

December 31, 2020

COMM 2014-CCRE20

January 01, 2020

to

December 31, 2020

COMM 2014-CCRE21

January 01, 2020

to

December 31, 2020

COMM 2014-LC15

January 01, 2020

to

December 31, 2020

COMM 2014-LC17

January 01, 2020

to

December 31, 2020

COMM 2014-UBS2

January 01, 2020

to

December 31, 2020

COMM 2014-UBS3

January 01, 2020

to

December 31, 2020

COMM 2014-UBS4

January 01, 2020

to

December 31, 2020

COMM 2014-UBS5

January 01, 2020

to

December 31, 2020

COMM 2015-CCRE22

January 01, 2020

to

December 31, 2020

COMM 2015-CCRE24

January 01, 2020

to

December 31, 2020

COMM 2015-CCRE26

January 01, 2020

to

December 31, 2020

COMM 2015-CCRE27

January 01, 2020

to

December 31, 2020

COMM 2015-DC1

January 01, 2020

to

December 31, 2020

COMM 2015-LC19

January 01, 2020

to

December 31, 2020

COMM 2015-LC21

January 01, 2020

to

December 31, 2020

COMM 2015-LC23

January 01, 2020

to

December 31, 2020

COMM 2015-PC1

January 01, 2020

to

December 31, 2020

COMM 2016-667M

January 01, 2020

to

December 31, 2020

COMM 2016-CCRE28

January 01, 2020

to

December 31, 2020

COMM 2016-COR1

January 01, 2020

to

December 31, 2020

COMM 2016-DC2

January 01, 2020

to

December 31, 2020

COMM 2017-COR2

January 01, 2020

to

December 31, 2020

COMM 2018-COR3

January 01, 2020

to

December 31, 2020

COMM 2018-HOME

January 01, 2020

to

December 31, 2020

COMM 2019-GC44

January 01, 2020

to

December 31, 2020

COMM 2020-CX

November 05, 2020

to

December 31, 2020

CSAIL 2015-C1

January 01, 2020

to

December 31, 2020

CSAIL 2015-C2

January 01, 2020

to

December 31, 2020

CSAIL 2016-C6

January 01, 2020

to

December 31, 2020

CSAIL 2016-C7

January 01, 2020

to

December 31, 2020

CSAIL 2017-C8

January 01, 2020

to

December 31, 2020

CSAIL 2017-CX10

January 01, 2020

to

December 31, 2020

CSAIL 2018-CX11

January 01, 2020

to

December 31, 2020

CSAIL 2018-CX12

January 01, 2020

to

December 31, 2020

CSAIL 2019-C15

January 01, 2020

to

December 31, 2020

CSAIL 2019-C17

January 01, 2020

to

December 31, 2020

CSAIL 2020-C19

March 30, 2020

to

December 31, 2020

CSMC 2016-NXSR

January 01, 2020

to

December 31, 2020

CSMC 2017-CALI

January 01, 2020

to

December 31, 2020

CSMC 2017-MOON

January 01, 2020

to

December 31, 2020

CSMC 2018-SITE

January 01, 2020

to

December 31, 2020

CSMC 2019-UVIL

January 01, 2020

to

December 31, 2020

DAFC 2017-AMO

January 01, 2020

to

December 31, 2020

DBGS 2018-C1

January 01, 2020

to

December 31, 2020

DBJPM 2016-C1

January 01, 2020

to

December 31, 2020

DBJPM 2016-C3

January 01, 2020

to

December 31, 2020

DBJPM 2020-C9

August 28, 2020

to

December 31, 2020

DBUBS 2017-BRBK

January 01, 2020

to

December 31, 2020

GRACE 2020-GRCE

November 18, 2020

to

December 31, 2020

GSMS 2013-GCJ12

January 01, 2020

to

December 31, 2020

GSMS 2013-GCJ16

January 01, 2020

to

December 31, 2020

GSMS 2014-GC18

January 01, 2020

to

December 31, 2020

GSMS 2015-GC32

January 01, 2020

to

December 31, 2020

GSMS 2016-GS4

January 01, 2020

to

December 31, 2020

GSMS 2017-GS7

January 01, 2020

to

December 31, 2020

GSMS 2018-GS10

January 01, 2020

to

December 31, 2020

GSMS 2019-GC39

January 01, 2020

to

December 31, 2020

GSMS 2019-GC42

January 01, 2020

to

December 31, 2020

GSMS 2019-GSA1

January 01, 2020

to

December 31, 2020

GSMS 2020-GC47

May 21, 2020

to

December 31, 2020

ILPT 2019-SURF

January 01, 2020

to

December 31, 2020

JPMCC 2013-C10

January 01, 2020

to

December 31, 2020

JPMCC 2018-AON

January 01, 2020

to

December 31, 2020

JPMCC 2018-BCON

January 01, 2020

to

December 31, 2020

JPMCC 2018-PTC

January 01, 2020

to

December 31, 2020

JPMCC 2018-WPT

January 01, 2020

to

December 31, 2020

JPMCC 2019-ICON

January 01, 2020

to

December 31, 2020

JPMCC 2019-OSB

January 01, 2020

to

December 31, 2020

JPMCC 2020-LOOP

February 05, 2020

to

December 31, 2020

JPMDB 2017-C5

January 01, 2020

to

December 31, 2020

LCCM 2017-LC26

January 01, 2020

to

December 31, 2020

MRCD 2019-PARK

January 01, 2020

to

December 31, 2020

MSBAM 2012-C5

January 01, 2020

to

December 31, 2020

MSBAM 2013-C10

January 01, 2020

to

December 31, 2020

MSBAM 2013-C13

January 01, 2020

to

December 31, 2020

MSBAM 2014-C14

January 01, 2020

to

December 31, 2020

MSBAM 2014-C18

January 01, 2020

to

December 31, 2020

MSBAM 2014-C19

January 01, 2020

to

December 31, 2020

MSBAM 2015-C20

January 01, 2020

to

December 31, 2020

MSBAM 2015-C22

January 01, 2020

to

December 31, 2020

MSBAM 2015-C24

January 01, 2020

to

December 31, 2020

MSBAM 2015-C26

January 01, 2020

to

December 31, 2020

MSBAM 2016-C28

January 01, 2020

to

December 31, 2020

MSBAM 2016-C29

January 01, 2020

to

December 31, 2020

MSBAM 2016-C30

January 01, 2020

to

December 31, 2020

MSBAM 2016-C31

January 01, 2020

to

December 31, 2020

MSBAM 2016-C32

January 01, 2020

to

December 31, 2020

MSBAM 2017-C33

January 01, 2020

to

December 31, 2020

MSBAM 2017-C34

January 01, 2020

to

December 31, 2020

MSC 2015-MS1

January 01, 2020

to

December 31, 2020

MSC 2015-UBS8

January 01, 2020

to

December 31, 2020

MSC 2016-BNK2

January 01, 2020

to

December 31, 2020

MSC 2016-UBS12

January 01, 2020

to

December 31, 2020

MSC 2017-HR2

January 01, 2020

to

December 31, 2020

MSC 2018-H3

January 01, 2020

to

December 31, 2020

MSC 2018-H4

January 01, 2020

to

December 31, 2020

MSC 2019-H6

January 01, 2020

to

December 31, 2020

MSC 2019-L3

January 01, 2020

to

December 31, 2020

MSC 2020-HR8

July 31, 2020

to

December 31, 2020

MSCI 2016-UBS11

January 01, 2020

to

December 31, 2020

MSCI 2016-UBS9

January 01, 2020

to

December 31, 2020

MSSG 2017-237P

January 01, 2020

to

December 31, 2020

OMW 2020-1MW

August 28, 2020

to

December 31, 2020

SBALR 2020-RR1

March 04, 2020

to

December 31, 2020

SGCMS 2016-C5

January 01, 2020

to

December 31, 2020

UBS 2017-C2

January 01, 2020

to

December 31, 2020

UBS 2017-C3

January 01, 2020

to

December 31, 2020

UBS 2017-C5

January 01, 2020

to

December 31, 2020

UBS 2018-C10

January 01, 2020

to

December 31, 2020

UBS 2018-C12

January 01, 2020

to

December 31, 2020

UBS 2018-C14

January 01, 2020

to

December 31, 2020

UBS 2018-C8

January 01, 2020

to

December 31, 2020

UBS 2019-C16

January 01, 2020

to

December 31, 2020

UBS 2019-C18

January 01, 2020

to

December 31, 2020

UBS-B 2012-C3

January 01, 2020

to

December 31, 2020

UBSBB 2013-C6

January 01, 2020

to

December 31, 2020

WFCM 2013-LC12

January 01, 2020

to

December 31, 2020

WFCM 2014-LC18

January 01, 2020

to

December 31, 2020

WFCM 2015-LC22

January 01, 2020

to

December 31, 2020

WFCM 2016-BNK1

January 01, 2020

to

December 31, 2020

WFCM 2016-C33

January 01, 2020

to

December 31, 2020

WFCM 2016-C36

January 01, 2020

to

December 31, 2020

WFCM 2016-NXS5

January 01, 2020

to

December 31, 2020

WFCM 2017-C38

January 01, 2020

to

December 31, 2020

WFCM 2017-C42

January 01, 2020

to

December 31, 2020

WFCM 2018-C43

January 01, 2020

to

December 31, 2020

WFCM 2018-C45

January 01, 2020

to

December 31, 2020

WFCM 2018-C47

January 01, 2020

to

December 31, 2020

WFCM 2019-C50

January 01, 2020

to

December 31, 2020

WFCM 2019-C53

January 01, 2020

to

December 31, 2020

WFCM 2019-C54

January 01, 2020

to

December 31, 2020

WFCM 2020-C55

February 27, 2020

to

December 31, 2020

WFRBS 2013-UBS1

January 01, 2020

to

December 31, 2020

WPT 2017-WWP

January 01, 2020

to

December 31, 2020
           

 

 

EXHIBIT B

 

 

 

SERVICING CRITERIA

 

APPLICABLE SERVICING CRITERIA

INAPPLICABLE

SERVICING CRITERIA

 

 

 

 

Performed by

subservicer(s)

or vendor(s)

for which

PBLS is NOT

the Responsible Party

 

 

 

 

  

NOT

performed by

PBLS or by

subservicer(s) or vendor(s)

retained by PBLS2

 

 

 

Performed by

Vendor(s) for

which PBLS is the

Responsible Party
     

Regulation AB

Reference

Criterion

 

Performed Directly by PBLS1
           

                                    General Servicing Considerations

 

 

1122(d)(1)(i)

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

 

 

 

X

 

 

 

1122(d)(1)(ii)

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

 

 

 

X

 

1122(d)(1)(iii)

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

 

 

 

X

 

 

 

 

1122(d)(1)(iv)

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

 

 

 

 

X

 

 

1122(d)(1)(v)

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

 

 

 

X

                               Cash Collection and Administration

 

 

 

 

1122(d)(2)(i)

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

 

 

 

 

X

 

 

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 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 are prepared in accordance with timeframes 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.

 

X3

    

 

X4

 

 

 

 

 

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 pool assets serviced by the Servicer.

 

X3

    

 

X4

 

 

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.

 

 

 

 

 

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

 

 

 

 

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

 

 

1 The criteria in the columns “Applicable Servicing Criteria” and marked with an “X” are applicable for the Transactions unless otherwise noted. If there were no specially serviced loans under the related Transactions during the reporting period, then no trust advisor, senior trust advisor or operating advisor actions were required.

 

2 The criteria in the columns “Inapplicable Servicing Criteria” and marked with an “X” were 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 listed in Table 2 below.

 

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

MSBAM 2012-C5