EX-33.5 6 e335_parboa.htm PARK BRIDGE LENDER SERVICES LLC, AS OPERATING ADVISOR

 

 

 

 

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

 

Exhibit A - page 1 of 6 

 

 

Exhibit A

 

Asserting Party’s 2020 Servicing Platform

 

  Applicable Certification Period
Securitization Transaction Start Date   End Date
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

 

Exhibit A - page 2 of 6 

 

 

Exhibit A

 

Asserting Party’s 2020 Servicing Platform

 

  Applicable Certification Period
Securitization Transaction Start Date   End Date
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

 

Exhibit A - page 3 of 6 

 

 

Exhibit A

 

Asserting Party’s 2020 Servicing Platform

 

  Applicable Certification Period
Securitization Transaction Start Date   End Date
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

 

Exhibit A - page 4 of 6 

 

 

Exhibit A

 

Asserting Party’s 2020 Servicing Platform

 

  Applicable Certification Period
Securitization Transaction Start Date   End Date
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

 

Exhibit A - page 5 of 6 

 

 

Exhibit A

 

Asserting Party’s 2020 Servicing Platform

 

  Applicable Certification Period
Securitization Transaction Start Date   End Date
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 A - page 6 of 6 

 

 

EXHIBIT B

  SERVICING CRITERIA

APPLICABLE

SERVICING CRITERIA

INAPPLICABLE

SERVICING

CRITERIA

Regulation

AB

Reference

Criterion

Performed

Directly by

PBLS1

Performed by

Vendor(s) for

which PBLS

is the Responsible

Party

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

  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

 

Exhibit B – page 1 of 5 

 

 

  SERVICING CRITERIA

APPLICABLE

SERVICING CRITERIA

INAPPLICABLE

SERVICING

CRITERIA

Regulation

AB

Reference

Criterion

Performed

Directly by

PBLS1

Performed by

Vendor(s) for

which PBLS

is the Responsible

Party

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

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

 

Exhibit B – page 2 of 5 

 

 

  SERVICING CRITERIA

APPLICABLE

SERVICING CRITERIA

INAPPLICABLE

SERVICING

CRITERIA

Regulation

AB

Reference

Criterion

Performed

Directly by

PBLS1

Performed by

Vendor(s) for

which PBLS

is the Responsible

Party

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

  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

  

Exhibit B – page 3 of 5 

 

 

  SERVICING CRITERIA

APPLICABLE

SERVICING CRITERIA

INAPPLICABLE

SERVICING

CRITERIA

Regulation

AB

Reference

Criterion

Performed

Directly by

PBLS1

Performed by

Vendor(s) for

which PBLS

is the Responsible

Party

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

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

 

Remainder of page left blank intentionally

 

Exhibit B – page 4 of 5 

 

 

1The 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.

 

2The 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.

  

3Applicable only to the Transactions listed in Table 2 below.

 

4Not 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

 

Exhibit B – page 5 of 5