EX-33.12 11 cik0001651588-ex3312_35.htm EX-33.12 cik0001651588-ex3312_35.htm

Exhibit 33.12

PARK BRIDGE LENDER SERVICES LLC

 

January 31, 2022

 

RE:  Management’s Report on Assessment of 2021 Compliance by

Park Bridge Lender Services LLC with Regulation AB Servicing Criteria

 

 

Park Bridge Lender Services LLC (the “Asserting Party” or “PBLS”) is responsible for assessing its compliance, as of and for the calendar year ended December 31, 2021 (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 the Asserting Party 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 2021 Servicing Platform

 

 

 

 

 

 

 

Applicable Certification Period

Securitization Transaction

Start Date

 

End Date

3650 2021-PF1

 

November 18, 2021

to

December 31, 2021

AOA 2021-1177

 

November 04, 2021

to

December 31, 2021

AREIT 2019-CRE3

 

January 01, 2021

to

December 31, 2021

AREIT 2021-CRE5

 

October 05, 2021

to

December 31, 2021

AVMT 2018-AVM

 

January 01, 2021

to

December 31, 2021

BACM 2016-UBS10

 

January 01, 2021

to

December 31, 2021

BACM 2017-BNK3

 

January 01, 2021

to

December 31, 2021

BAMLL 2020-JGDN

 

January 01, 2021

to

December 15, 2021

BAMLL 2021-JACX

 

September 15, 2021

to

December 31, 2021

Bancorp 2016-CRE1

 

January 01, 2021

to

August 17, 2021

Bancorp 2017-CRE2

 

January 01, 2021

to

December 31, 2021

Bancorp 2018-CRE3

 

January 01, 2021

to

December 31, 2021

Bancorp 2018-CRE4

 

January 01, 2021

to

December 31, 2021

Bancorp 2019-CRE5

 

January 01, 2021

to

December 31, 2021

BANK 2017-BNK5

 

January 01, 2021

to

December 31, 2021

BANK 2017-BNK6

 

January 01, 2021

to

December 31, 2021

BANK 2017-BNK8

 

January 01, 2021

to

December 31, 2021

BANK 2017-BNK9

 

January 01, 2021

to

December 31, 2021

BANK 2018-BNK11

 

January 01, 2021

to

December 31, 2021

BANK 2018-BNK12

 

January 01, 2021

to

December 31, 2021

BANK 2018-BNK14

 

January 01, 2021

to

December 31, 2021

BANK 2018-BNK15

 

January 01, 2021

to

December 31, 2021

BANK 2019-BNK16

 

January 01, 2021

to

December 31, 2021

BANK 2019-BNK19

 

January 01, 2021

to

December 31, 2021

BANK 2019-BNK20

 

January 01, 2021

to

December 31, 2021

BANK 2019-BNK21

 

January 01, 2021

to

December 31, 2021

BANK 2019-BNK23

 

January 01, 2021

to

December 31, 2021

BANK 2019-BNK24

 

January 01, 2021

to

December 31, 2021

BANK 2020-BNK26

 

January 01, 2021

to

December 31, 2021

BANK 2020-BNK27

 

January 01, 2021

to

December 31, 2021

BANK 2020-BNK28

 

January 01, 2021

to

December 31, 2021

BANK 2020-BNK30

 

January 01, 2021

to

December 31, 2021

BANK 2021-BNK31

 

February 11, 2021

to

December 31, 2021

BANK 2021-BNK32

 

March 24, 2021

to

December 31, 2021

BANK 2021-BNK33

 

May 20, 2021

to

December 31, 2021

BANK 2021-BNK35

 

August 11, 2021

to

December 31, 2021

BANK 2021-BNK37

 

November 22, 2021

to

December 31, 2021

BBCMS 2017-C1

 

January 01, 2021

to

December 31, 2021

BBCMS 2018-C2

 

January 01, 2021

to

December 31, 2021

 

 

 

 

BBCMS 2019-BWAY

 

January 01, 2021

to

December 31, 2021

BBCMS 2019-C4

 

January 01, 2021

to

December 31, 2021

BBCMS 2020-C7

 

January 01, 2021

to

December 31, 2021

BBCMS 2021-C11

 

September 29, 2021

to

December 31, 2021

BBCMS 2021-C9

 

March 10, 2021

to

December 31, 2021

BCP 2021-330N

 

June 29, 2021

to

December 31, 2021

BDS 2020-FL6

 

January 01, 2021

to

December 31, 2021

BDS 2021-FL8

 

August 05, 2021

to

December 31, 2021

BFLD 2019-DPLO

 

January 01, 2021

to

December 31, 2021

BFLD 2020-EYP

 

January 01, 2021

to

December 31, 2021

BFLD 2020-OBRK

 

January 01, 2021

to

December 31, 2021

BFLD 2021-FPM

 

June 22, 2021

to

December 31, 2021

BHPT 2019-BXHP

 

January 01, 2021

to

December 31, 2021

BLOX 2021-BLOX

 

August 31, 2021

to

December 31, 2021

BMARK 2018-B1

 

January 01, 2021

to

December 31, 2021

BMARK 2018-B3

 

January 01, 2021

to

December 31, 2021

BMARK 2018-B4

 

January 01, 2021

to

December 31, 2021

BMARK 2018-B6

 

January 01, 2021

to

December 31, 2021

BMARK 2018-B7

 

January 01, 2021

to

December 31, 2021

BMARK 2019-B13

 

January 01, 2021

to

December 31, 2021

BMARK 2019-B15

 

January 01, 2021

to

December 31, 2021

BMARK 2019-B9

 

January 01, 2021

to

December 31, 2021

BMARK 2020-B16

 

January 01, 2021

to

December 31, 2021

BMARK 2020-B18

 

January 01, 2021

to

December 31, 2021

BMARK 2020-B21

 

January 01, 2021

to

December 31, 2021

BMARK 2020-IG1

 

January 01, 2021

to

December 31, 2021

BMARK 2021-B23

 

February 18, 2021

to

December 31, 2021

BMARK 2021-B24

 

March 24, 2021

to

December 31, 2021

BMARK 2021-B26

 

May 27, 2021

to

December 31, 2021

BMARK 2021-B27

 

June 29, 2021

to

December 31, 2021

BMARK 2021-B29

 

September 30, 2021

to

December 31, 2021

BMARK 2021-B30

 

November 16, 2021

to

December 31, 2021

BPCRE 2021-FL1

 

March 04, 2021

to

December 31, 2021

BPR 2021-KEN

 

February 25, 2021

to

December 31, 2021

BPR 2021-NRD

 

December 22, 2021

to

December 31, 2021

BPR 2021-TY

 

September 23, 2021

to

December 31, 2021

BPR 2021-WILL

 

May 27, 2021

to

December 31, 2021

BSREP 2021-DC

 

August 16, 2021

to

December 31, 2021

BWAY 2021-1450

 

August 31, 2021

to

December 31, 2021

BX 2018-BILT

 

January 01, 2021

to

December 31, 2021

BX 2018-GW

 

January 01, 2021

to

December 31, 2021

BX 2019-OC11

 

January 01, 2021

to

December 31, 2021

BX 2019-XL

 

January 01, 2021

to

December 31, 2021

BX 2020-BXLP

 

January 01, 2021

to

December 31, 2021

BX 2020-VKNG

 

January 01, 2021

to

December 31, 2021

 

 

 

 

BX 2021-21M

 

November 08, 2021

to

December 31, 2021

BX 2021-ACNT

 

November 19, 2021

to

December 31, 2021

BX 2021-IRON

 

February 23, 2021

to

December 31, 2021

BX 2021-LGCY

 

October 21, 2021

to

December 31, 2021

BX 2021-PAC

 

November 02, 2021

to

December 31, 2021

BX 2021-SDMF

 

September 28, 2021

to

December 31, 2021

BX 2021-VINO

 

May 27, 2021

to

December 31, 2021

BX 2021-VOLT

 

September 29, 2021

to

December 31, 2021

BX 2021-XL2

 

October 26, 2021

to

December 31, 2021

BXMT 2017-FL1

 

January 01, 2021

to

April 16, 2021

CAMB 2021-CX2

 

November 09, 2021

to

December 31, 2021

Carbon 2019-FL2

 

January 01, 2021

to

December 31, 2021

CCUBS 2017-C1

 

January 01, 2021

to

December 31, 2021

CD 2016-CD1

 

January 01, 2021

to

December 31, 2021

CD 2016-CD2

 

January 01, 2021

to

December 31, 2021

CD 2017-CD3

 

January 01, 2021

to

December 31, 2021

CD 2017-CD4

 

January 01, 2021

to

December 31, 2021

CD 2017-CD5

 

January 01, 2021

to

December 31, 2021

CD 2017-CD6

 

January 01, 2021

to

December 31, 2021

CD 2018-CD7

 

January 01, 2021

to

December 31, 2021

CD 2019-CD8

 

January 01, 2021

to

December 31, 2021

CF 2019-BOSS

 

January 01, 2021

to

December 31, 2021

CF 2019-CF1

 

January 01, 2021

to

December 31, 2021

CF 2019-CF2

 

January 01, 2021

to

December 31, 2021

CF 2019-CF3

 

January 01, 2021

to

December 31, 2021

CF 2019-MF1

 

January 01, 2021

to

November 15, 2021

CF 2020-P1

 

January 01, 2021

to

December 31, 2021

CFCRE 2016-C3

 

January 01, 2021

to

December 31, 2021

CFCRE 2016-C4

 

January 01, 2021

to

December 31, 2021

CFCRE 2016-C6

 

January 01, 2021

to

December 31, 2021

CFCRE 2016-C7

 

January 01, 2021

to

December 31, 2021

CFCRE 2017-C8

 

January 01, 2021

to

December 31, 2021

CFCRE 2018-TAN

 

January 01, 2021

to

December 31, 2021

CGCMT 2014-GC21

 

January 01, 2021

to

December 31, 2021

CGCMT 2014-GC25

 

January 01, 2021

to

December 31, 2021

CGCMT 2015-GC27

 

January 01, 2021

to

December 31, 2021

CGCMT 2015-GC35

 

January 01, 2021

to

December 31, 2021

CGCMT 2015-P1

 

January 01, 2021

to

December 31, 2021

CGCMT 2016-C1

 

January 01, 2021

to

December 31, 2021

CGCMT 2016-GC37

 

January 01, 2021

to

December 31, 2021

CGCMT 2016-P3

 

January 01, 2021

to

December 31, 2021

CGCMT 2016-P4

 

January 01, 2021

to

December 31, 2021

CGCMT 2016-P5

 

January 01, 2021

to

December 31, 2021

CGCMT 2016-P6

 

January 01, 2021

to

December 31, 2021

CGCMT 2017-C4

 

January 01, 2021

to

December 31, 2021

 

 

 

 

CGCMT 2017-P7

 

January 01, 2021

to

December 31, 2021

CGCMT 2018-B2

 

January 01, 2021

to

December 31, 2021

CGCMT 2018-C6

 

January 01, 2021

to

December 31, 2021

CGCMT 2019-GC41

 

January 01, 2021

to

December 31, 2021

CGCMT 2019-GC43

 

January 01, 2021

to

December 31, 2021

CGCMT 2019-SMRT

 

January 01, 2021

to

December 31, 2021

CGCMT 2020-GC46

 

January 01, 2021

to

December 31, 2021

CHC 2019-CHC

 

January 01, 2021

to

December 31, 2021

COMM 2012-CCRE2

 

January 01, 2021

to

December 31, 2021

COMM 2012-CCRE4

 

January 01, 2021

to

December 31, 2021

COMM 2012-CCRE5

 

January 01, 2021

to

December 31, 2021

COMM 2012-LC4

 

January 01, 2021

to

December 31, 2021

COMM 2013-CCRE10

 

January 01, 2021

to

December 31, 2021

COMM 2013-CCRE11

 

January 01, 2021

to

December 31, 2021

COMM 2013-CCRE12

 

January 01, 2021

to

December 31, 2021

COMM 2013-CCRE6

 

January 01, 2021

to

December 31, 2021

COMM 2013-CCRE7

 

January 01, 2021

to

December 31, 2021

COMM 2013-CCRE8

 

January 01, 2021

to

December 31, 2021

COMM 2013-CCRE9

 

January 01, 2021

to

December 31, 2021

COMM 2013-LC13

 

January 01, 2021

to

December 31, 2021

COMM 2013-LC6

 

January 01, 2021

to

December 31, 2021

COMM 2014-CCRE14

 

January 01, 2021

to

December 31, 2021

COMM 2014-CCRE15

 

January 01, 2021

to

December 31, 2021

COMM 2014-CCRE16

 

January 01, 2021

to

December 31, 2021

COMM 2014-CCRE17

 

January 01, 2021

to

December 31, 2021

COMM 2014-CCRE18

 

January 01, 2021

to

December 31, 2021

COMM 2014-CCRE19

 

January 01, 2021

to

December 31, 2021

COMM 2014-CCRE20

 

January 01, 2021

to

December 31, 2021

COMM 2014-CCRE21

 

January 01, 2021

to

December 31, 2021

COMM 2014-LC15

 

January 01, 2021

to

December 31, 2021

COMM 2014-LC17

 

January 01, 2021

to

December 31, 2021

COMM 2014-UBS2

 

January 01, 2021

to

December 31, 2021

COMM 2014-UBS3

 

January 01, 2021

to

December 31, 2021

COMM 2014-UBS4

 

January 01, 2021

to

December 31, 2021

COMM 2014-UBS5

 

January 01, 2021

to

December 31, 2021

COMM 2015-CCRE22

 

January 01, 2021

to

December 31, 2021

COMM 2015-CCRE24

 

January 01, 2021

to

December 31, 2021

COMM 2015-CCRE26

 

January 01, 2021

to

December 31, 2021

COMM 2015-CCRE27

 

January 01, 2021

to

December 31, 2021

COMM 2015-DC1

 

January 01, 2021

to

December 31, 2021

COMM 2015-LC19

 

January 01, 2021

to

December 31, 2021

COMM 2015-LC21

 

January 01, 2021

to

December 31, 2021

COMM 2015-LC23

 

January 01, 2021

to

December 31, 2021

COMM 2015-PC1

 

January 01, 2021

to

December 31, 2021

COMM 2016-667M

 

January 01, 2021

to

December 31, 2021

 

 

 

 

COMM 2016-CCRE28

 

January 01, 2021

to

December 31, 2021

COMM 2016-COR1

 

January 01, 2021

to

December 31, 2021

COMM 2016-DC2

 

January 01, 2021

to

December 31, 2021

COMM 2017-COR2

 

January 01, 2021

to

December 31, 2021

COMM 2018-COR3

 

January 01, 2021

to

December 31, 2021

COMM 2018-HOME

 

January 01, 2021

to

December 31, 2021

COMM 2019-GC44

 

January 01, 2021

to

December 31, 2021

COMM 2020-CX

 

January 01, 2021

to

December 31, 2021

COMM 2021-2400

 

December 15, 2021

to

December 31, 2021

COMM 2021-LBA

 

March 17, 2021

to

December 31, 2021

CSAIL 2015-C1

 

January 01, 2021

to

December 31, 2021

CSAIL 2015-C2

 

January 01, 2021

to

December 31, 2021

CSAIL 2016-C6

 

January 01, 2021

to

December 31, 2021

CSAIL 2016-C7

 

January 01, 2021

to

December 31, 2021

CSAIL 2017-C8

 

January 01, 2021

to

December 31, 2021

CSAIL 2017-CX10

 

January 01, 2021

to

December 31, 2021

CSAIL 2018-CX11

 

January 01, 2021

to

December 31, 2021

CSAIL 2018-CX12

 

January 01, 2021

to

December 31, 2021

CSAIL 2019-C15

 

January 01, 2021

to

December 31, 2021

CSAIL 2019-C17

 

January 01, 2021

to

December 31, 2021

CSAIL 2020-C19

 

January 01, 2021

to

December 31, 2021

CSAIL 2021-C20

 

March 30, 2021

to

December 31, 2021

CSMC 2016-NXSR

 

January 01, 2021

to

December 31, 2021

CSMC 2017-CALI

 

January 01, 2021

to

December 31, 2021

CSMC 2017-CHOP

 

January 01, 2021

to

December 31, 2021

CSMC 2017-LSTK

 

January 01, 2021

to

March 05, 2021

CSMC 2017-MOON

 

January 01, 2021

to

December 31, 2021

CSMC 2017-PFHP

 

January 01, 2021

to

December 31, 2021

CSMC 2018-SITE

 

January 01, 2021

to

December 31, 2021

CSMC 2019-ICE4

 

January 01, 2021

to

December 31, 2021

CSMC 2019-UVIL

 

January 01, 2021

to

December 31, 2021

CSMC 2020-FACT

 

January 01, 2021

to

December 31, 2021

CSMC 2020-TMIC

 

January 01, 2021

to

December 31, 2021

CSMC 2021-980M

 

August 10, 2021

to

December 31, 2021

CSMC 2021-B33

 

October 19, 2021

to

December 31, 2021

CSMC 2021-BHAR

 

November 23, 2021

to

December 31, 2021

DAFC 2017-AMO

 

January 01, 2021

to

December 31, 2021

DBGS 2018-5BP

 

January 01, 2021

to

December 31, 2021

DBGS 2018-BIOD

 

January 01, 2021

to

December 31, 2021

DBGS 2018-C1

 

January 01, 2021

to

December 31, 2021

DBJPM 2016-C1

 

January 01, 2021

to

December 31, 2021

DBJPM 2016-C3

 

January 01, 2021

to

December 31, 2021

DBJPM 2020-C9

 

January 01, 2021

to

December 31, 2021

DBUBS 2017-BRBK

 

January 01, 2021

to

December 31, 2021

DBWF 2018-AMXP

 

January 01, 2021

to

December 31, 2021

 

 

 

 

DBWF 2018-GLKS

 

January 01, 2021

to

December 31, 2021

DOLP 2021-NYC

 

April 20, 2021

to

December 31, 2021

ELP 2021-ELP

 

November 17, 2021

to

December 31, 2021

EQUS 2021-EQAZ

 

November 03, 2021

to

December 31, 2021

ESA 2021-ESH

 

July 08, 2021

to

December 31, 2021

FMBT 2019-FBLU

 

January 01, 2021

to

December 31, 2021

GACM 2020-FL2

 

January 01, 2021

to

December 31, 2021

GCT 2021-GCT

 

February 05, 2021

to

December 31, 2021

GPMT 2018-FL1

 

January 01, 2021

to

December 31, 2021

GPMT 2021-FL3

 

May 14, 2021

to

December 31, 2021

GRACE 2020-GRCE

 

January 01, 2021

to

December 31, 2021

GSMS 2013-GCJ12

 

January 01, 2021

to

December 31, 2021

GSMS 2013-GCJ16

 

January 01, 2021

to

December 31, 2021

GSMS 2014-GC18

 

January 01, 2021

to

December 31, 2021

GSMS 2015-GC32

 

January 01, 2021

to

December 31, 2021

GSMS 2016-GS4

 

January 01, 2021

to

December 31, 2021

GSMS 2017-GS7

 

January 01, 2021

to

December 31, 2021

GSMS 2017-STAY

 

January 01, 2021

to

December 31, 2021

GSMS 2018-3PCK

 

January 01, 2021

to

December 31, 2021

GSMS 2018-GS10

 

January 01, 2021

to

December 31, 2021

GSMS 2019-GC39

 

January 01, 2021

to

December 31, 2021

GSMS 2019-GC42

 

January 01, 2021

to

December 31, 2021

GSMS 2019-GSA1

 

January 01, 2021

to

December 31, 2021

GSMS 2019-SOHO

 

January 01, 2021

to

July 15, 2021

GSMS 2020-GC47

 

January 01, 2021

to

December 31, 2021

GSMS 2020-TWN3

 

January 01, 2021

to

December 31, 2021

GSMS 2021-DM

 

December 16, 2021

to

December 31, 2021

GSMS 2021-IP

 

October 15, 2021

to

December 31, 2021

GWT 2019-WOLF

 

January 01, 2021

to

December 31, 2021

HCMT 2017-FL1

 

January 01, 2021

to

June 15, 2021

HONO 2021-LULU

 

October 15, 2021

to

December 31, 2021

ILPT 2019-SURF

 

January 01, 2021

to

December 31, 2021

JPMCC 2013-C10

 

January 01, 2021

to

December 31, 2021

JPMCC 2018-AON

 

January 01, 2021

to

December 31, 2021

JPMCC 2018-ASH8

 

January 01, 2021

to

December 31, 2021

JPMCC 2018-BCON

 

January 01, 2021

to

December 31, 2021

JPMCC 2018-MINN

 

January 01, 2021

to

December 31, 2021

JPMCC 2018-PHH

 

January 01, 2021

to

December 31, 2021

JPMCC 2018-PTC

 

January 01, 2021

to

December 31, 2021

JPMCC 2018-WPT

 

January 01, 2021

to

December 31, 2021

JPMCC 2019-ICON

 

January 01, 2021

to

December 31, 2021

JPMCC 2019-OSB

 

January 01, 2021

to

December 31, 2021

JPMCC 2020-609M

 

January 01, 2021

to

December 31, 2021

JPMCC 2020-LOOP

 

January 01, 2021

to

December 31, 2021

JPMCC 2021-1MEM

 

October 14, 2021

to

December 31, 2021

 

 

 

 

JPMCC 2021-2NU

 

January 29, 2021

to

December 31, 2021

JPMCC 2021-410T

 

March 12, 2021

to

December 31, 2021

JPMDB 2017-C5

 

January 01, 2021

to

December 31, 2021

KIND 2021-KDIP

 

January 28, 2021

to

December 31, 2021

KNDR 2021-KIND

 

August 16, 2021

to

December 31, 2021

LCCM 2017-LC26

 

January 01, 2021

to

December 31, 2021

LIFE 2021-BMR

 

March 30, 2021

to

December 31, 2021

LUXE 2021-MLBH

 

November 04, 2021

to

December 31, 2021

MARG 2019-MARG

 

January 01, 2021

to

December 31, 2021

MHC 2021-MHC

 

April 22, 2021

to

December 31, 2021

MHC 2021-MHC2

 

May 27, 2021

to

December 31, 2021

MHP 2021-STOR

 

August 05, 2021

to

December 31, 2021

MRCD 2019-PARK

 

January 01, 2021

to

December 31, 2021

MSBAM 2012-C5

 

January 01, 2021

to

December 31, 2021

MSBAM 2013-C10

 

January 01, 2021

to

December 31, 2021

MSBAM 2013-C13

 

January 01, 2021

to

December 31, 2021

MSBAM 2014-C14

 

January 01, 2021

to

December 31, 2021

MSBAM 2014-C18

 

January 01, 2021

to

December 31, 2021

MSBAM 2014-C19

 

January 01, 2021

to

December 31, 2021

MSBAM 2015-C20

 

January 01, 2021

to

December 31, 2021

MSBAM 2015-C22

 

January 01, 2021

to

December 31, 2021

MSBAM 2015-C24

 

January 01, 2021

to

December 31, 2021

MSBAM 2015-C26

 

January 01, 2021

to

December 31, 2021

MSBAM 2016-C28

 

January 01, 2021

to

December 31, 2021

MSBAM 2016-C29

 

January 01, 2021

to

December 31, 2021

MSBAM 2016-C30

 

January 01, 2021

to

December 31, 2021

MSBAM 2016-C31

 

January 01, 2021

to

December 31, 2021

MSBAM 2016-C32

 

January 01, 2021

to

December 31, 2021

MSBAM 2017-C33

 

January 01, 2021

to

December 31, 2021

MSBAM 2017-C34

 

January 01, 2021

to

December 31, 2021

MSC 2015-MS1

 

January 01, 2021

to

December 31, 2021

MSC 2015-UBS8

 

January 01, 2021

to

December 31, 2021

MSC 2016-BNK2

 

January 01, 2021

to

December 31, 2021

MSC 2016-UBS12

 

January 01, 2021

to

December 31, 2021

MSC 2017-ASHF

 

January 01, 2021

to

December 31, 2021

MSC 2017-CLS

 

January 01, 2021

to

December 31, 2021

MSC 2017-HR2

 

January 01, 2021

to

December 31, 2021

MSC 2018-H3

 

January 01, 2021

to

December 31, 2021

MSC 2018-H4

 

January 01, 2021

to

December 31, 2021

MSC 2018-SUN

 

January 01, 2021

to

December 31, 2021

MSC 2019-H6

 

January 01, 2021

to

December 31, 2021

MSC 2019-L3

 

January 01, 2021

to

December 31, 2021

MSC 2019-PLND

 

January 01, 2021

to

December 31, 2021

MSC 2020-HR8

 

January 01, 2021

to

December 31, 2021

MSC 2021-ILP

 

November 30, 2021

to

December 31, 2021

 

 

 

 

MSC 2021-L6

 

July 13, 2021

to

December 31, 2021

MSCI 2016-UBS11

 

January 01, 2021

to

December 31, 2021

MSCI 2016-UBS9

 

January 01, 2021

to

December 31, 2021

MSSG 2017-237P

 

January 01, 2021

to

December 31, 2021

MTK 2021-GRNY

 

December 15, 2021

to

December 31, 2021

NCMS 2018-850T (B Note)

January 01, 2021

to

July 15, 2021

NCMS 2019-AMZ7B

 

January 01, 2021

to

December 31, 2021

NCMS 2019-TRUE

 

January 01, 2021

to

December 31, 2021

NCMS 2020-AGC

 

January 01, 2021

to

December 31, 2021

NYO 2021-1290

 

November 16, 2021

to

December 31, 2021

OBPT 2019-OBP

 

January 01, 2021

to

December 31, 2021

OMPT 2017-1MKT

 

January 01, 2021

to

December 31, 2021

OMW 2020-1MW

 

January 01, 2021

to

December 31, 2021

ONE 2021-PARK

 

February 26, 2021

to

December 31, 2021

ONYP 2020-1NYP

 

January 01, 2021

to

December 31, 2021

OPG 2021-PORT

 

October 07, 2021

to

December 31, 2021

PFP 2019-5

 

January 01, 2021

to

December 31, 2021

PFP 2019-6

 

January 01, 2021

to

December 31, 2021

PFP 2021-7

 

March 25, 2021

to

December 31, 2021

PRK 2017-280P

 

January 01, 2021

to

December 31, 2021

RCMF 2018-FL2

 

January 01, 2021

to

April 26, 2021

RCMF 2019-FL3

 

January 01, 2021

to

December 31, 2021

RCMF 2020-FL4

 

January 01, 2021

to

December 31, 2021

RCMF 2021-FL5

 

March 31, 2021

to

December 31, 2021

RCMF 2021-FL6

 

August 17, 2021

to

December 31, 2021

RCMF 2021-FL7

 

November 24, 2021

to

December 31, 2021

RLGH 2021-TROT

 

May 17, 2021

to

December 31, 2021

SBALR 2020-RR1

 

January 01, 2021

to

December 31, 2021

SFO 2021-555

 

May 10, 2021

to

December 31, 2021

SGCMS 2016-C5

 

January 01, 2021

to

December 31, 2021

SGCP 2018-FL1

 

January 01, 2021

to

January 15, 2021

SGCP 2019-FL2

 

January 01, 2021

to

December 31, 2021

SGCP 2021-FL3

 

September 27, 2021

to

December 31, 2021

SLIDE 2018-FUN

 

January 01, 2021

to

December 31, 2021

SREIT 2021-FLWR

 

July 22, 2021

to

December 31, 2021

SREIT 2021-MFP

 

November 30, 2021

to

December 31, 2021

SREIT 2021-MFP2

 

December 16, 2021

to

December 31, 2021

STWD 2021-HTS

 

July 29, 2021

to

December 31, 2021

TPGI 2021-DGWD

 

June 15, 2021

to

December 31, 2021

TRTX 2018-FL2

 

January 01, 2021

to

December 31, 2021

UBS 2017-C2

 

January 01, 2021

to

December 31, 2021

UBS 2017-C3

 

January 01, 2021

to

December 31, 2021

UBS 2017-C5

 

January 01, 2021

to

December 31, 2021

UBS 2018-C10

 

January 01, 2021

to

December 31, 2021

UBS 2018-C12

 

January 01, 2021

to

December 31, 2021

 

 

 

 

UBS 2018-C14

 

January 01, 2021

to

December 31, 2021

UBS 2018-C8

 

January 01, 2021

to

December 31, 2021

UBS 2019-C16

 

January 01, 2021

to

December 31, 2021

UBS 2019-C18

 

January 01, 2021

to

December 31, 2021

UBS-B 2012-C3

 

January 01, 2021

to

December 31, 2021

UBSBB 2013-C6

 

January 01, 2021

to

December 31, 2021

VASA 2021-VASA

 

April 15, 2021

to

December 31, 2021

VLS 2020-LAB

 

January 01, 2021

to

December 31, 2021

WBHT 2019-WBM

 

January 01, 2021

to

December 31, 2021

WFCM 2013-LC12

 

January 01, 2021

to

December 31, 2021

WFCM 2014-LC18

 

January 01, 2021

to

December 31, 2021

WFCM 2015-LC22

 

January 01, 2021

to

December 31, 2021

WFCM 2016-BNK1

 

January 01, 2021

to

December 31, 2021

WFCM 2016-C33

 

January 01, 2021

to

December 31, 2021

WFCM 2016-C36

 

January 01, 2021

to

December 31, 2021

WFCM 2016-NXS5

 

January 01, 2021

to

December 31, 2021

WFCM 2017-C38

 

January 01, 2021

to

December 31, 2021

WFCM 2017-C42

 

January 01, 2021

to

December 31, 2021

WFCM 2018-C43

 

January 01, 2021

to

December 31, 2021

WFCM 2018-C45

 

January 01, 2021

to

December 31, 2021

WFCM 2018-C47

 

January 01, 2021

to

December 31, 2021

WFCM 2019-C50

 

January 01, 2021

to

December 31, 2021

WFCM 2019-C53

 

January 01, 2021

to

December 31, 2021

WFCM 2019-C54

 

January 01, 2021

to

December 31, 2021

WFCM 2020-C55

 

January 01, 2021

to

December 31, 2021

WFRBS 2013-UBS1

 

January 01, 2021

to

December 31, 2021

WPT 2017-WWP

 

January 01, 2021

to

December 31, 2021

XAN 2020-RSO8

 

January 01, 2021

to

December 31, 2021

XAN 2020-RSO9

 

January 01, 2021

to

December 31, 2021

 

 

 

 

 

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

 

 

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)(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

 

 

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)(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

 

 

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)(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

 

 

 

Remainder of page left blank intentionally

 

 

 

 

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