ccm16g36_33-8.htm - Generated by SEC Publisher for SEC Filing

Berkadia Commercial Mortgage LLC (“Berkadia”) is responsible for assessing compliance, as of and for the year ended December 31, 2022 (the “Reporting Period”), with the Servicing Criteria set forth in Item 1122(d) of Regulation AB of the U.S. Securities and Exchange Commission for asset-backed securities transactions. This assertion includes all commercial mortgage loans sold in public securitizations from the period January 1, 2006 through December 31, 2022 for which Berkadia served as Primary servicer (the “Platform”).

Berkadia has concluded that the criteria are applicable as shown below (indicated by X) to the primary servicing of the loans in the Platform:

Regulation AB Criteria 1122(d)

Applicability of Criteria as the Primary Servicer

(1) General servicing considerations.

(i) Policies and procedures are instituted to monitor any performance or other triggers and

events of default in accordance with the transaction agreements.

(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.

(iii) Any requirements in the transaction agreements to maintain a back-up servicer for the

pool assets are maintained.

(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.

(v) Aggregation of information, as applicable, is mathematically accurate and the information

conveyed accurately reflects the information.

(2) Cash collection and administration.

(i) Payments on pool assets are deposited into the custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of

days specified in the transaction agreements.

X¹

(ii) Disbursements made via wire transfer on behalf of an obligor or to an investor are made

only by authorized personnel.

(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 transection agreements.

X¹

(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.

(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 § 240.13k-1(b)(1) of this chapter.

(vi) Unissued checks are safeguarded to prevent unauthorized access.

(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.

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.

(3) Investor remittances and reporting.

(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;

(1)

(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.

(ii) Amounts due to investors are allocated and remitted in accordance with timeframes,

distribution priority and other terms set forth in the transaction agreements.

(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.

(iv) Amounts remitted to investors per the investor reports agree with cancelled checks, or

other form of payment, or custodial bank statements.

(4) Pool asset administration.

(i) Collateral or security on pool assets is maintained as required by the transaction

agreements or related pool asset documents.

X¹

(ii) Pool assets and related documents are safeguarded as required by the transaction

agreements.

(1)

(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.

X²

(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.

(v) The servicer’s records regarding the pool assets agree with the servicer’s records with

respect to an obligor’s unpaid principal balance.

(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.

(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.

(1)

(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).

(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) 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 asset, or such other number of days specified in the transaction agreements.

(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.

X¹

(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.

X¹

(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.

X¹

(xiv) Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in

accordance with the transaction agreements.

X²

(xv) Any external enhancement or other support, identified in Item 1114(a) (1) through (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.

(1)

X¹ Vendors, for which Berkadia is the Responsible Party, contributes to the servicing activities for these criteria.

X² There was no transaction activity relevant to the servicing criteria as of and for the yead ended December 31, 2022.

(1) Per servicing and pooling agreements, the criteria does not apply to the role of Primary Servicer.

The Servicing Criteria, after giving effect to the foregoing exclusions, are referred to as the “Applicable Servicing Criteria.”

For the Reporting Period, Berkadia has assessed its compliance with the Applicable Servicing Criteria for the Platform and has concluded that its servicing operation has complied, in all material respects, with the Applicable Servicing Criteria.

Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on management’s assertion of compliance with the Applicable Servicing Criteria.