cik0001715824-ex3317

Report on Assessment of Compliance with Applicable Servicing Criteria Pursuant to Item 1122(d) of

AEGON USA Realty Advisors, LLC (“AEGON”) as special servicer for the commercial mortgage backed securities transactions in Appendix B (the “Platform”) hereby provides the following report on its assessment of compliance with the applicable servicing criteria pursuant paragraph (d) of Item 1122 of Regulation AB applicable to it and as described on Appendix A hereto.


	SERVICING CRITERIA	APPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by AEGON
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^C
1122(d)(1)(iii)	Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.	N/A^A
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 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^C
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^B
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

^A1122(d)( AEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v), 4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable to the activities AEGON performs with respect to the Platform.

^BThis servicing activity was not performed during the Reporting Period as there were no loans serviced on the Platform that would trigger the applicability of this criteria.

^CThis servicing activity was not performed during the Reporting Period as there was no activity for serviced loans on the Platform that would trigger performance of this activity.


	SERVICING CRITERIA	APPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by AEGON
Cash Collection and Administration (continued)
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^C
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^C
1122(d)(2)(vi)	Unissued checks are safeguarded so as to prevent unauthorized access.	X^C
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:	X^C
	(A) Are mathematically accurate;
	(B) Are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements;
	(C) Are reviewed and approved by someone other than the person who prepared the reconciliation; and
	(D) Contain explanations for reconciling 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.

^AAEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable to the activities AEGON performs with respect to the Platform.

^BThis servicing activity was not performed during the Reporting Period as there were no loans serviced on the Platform that would trigger the applicability of this criteria.

^CThis servicing activity was not performed during the Reporting Period as there was no activity for serviced loans on the Platform that would trigger performance of this activity.


	SERVICING CRITERIA	APPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by AEGON
Investor Remittances and Reporting
1122(d)(3)(i)	Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports:	X
	(A) Are prepared in accordance with timeframes and other terms set forth in the transaction agreements;
	(B) Provide information calculated in accordance with the terms specified in the transaction agreements;
	(C) Are filed with the Commission as required by its rules and regulations; and
	(D) Agree with investor’s or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the servicer.
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.	N/A^A
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.	N/A^A
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.	N/A^A
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^C
1122(d)(4)(ii)	Pool assets and related documents are safeguarded as required by the transaction agreements.	X^B
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^C

^BThis servicing activity was not performed during the Reporting Period as there were no loans serviced on the Platform that would trigger the applicability of this criteria.

^CThis servicing activity was not performed during the Reporting Period as there was no activity for serviced loans on the Platform that would trigger performance of this activity.


	SERVICING CRITERIA	APPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by AEGON
Pool Asset Administration
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^B
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.	N/A^A
1122(d)(4)(vi)	Changes with respect to the terms or status of an obligor’s pool asset (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.	X^C
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

^BThis servicing activity was not performed during the Reporting Period as there were no loans serviced on the Platform that would trigger the applicability of this criteria.

^CThis servicing activity was not performed during the Reporting Period as there was no activity for serviced loans on the Platform that would trigger performance of this activity.


	SERVICING CRITERIA	APPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed Directly by AEGON
Pool Asset Administration (continued)
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.	N/A^A
1122(d)(4)(x)	Regarding any funds held in trust for an obligor (such as escrow accounts):	N/A^A
	(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.
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.	N/A^A
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.	N/A^A
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.	N/A^A
1122(d)(4) (xiv)	Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.	N/A^A

^A AEGON has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv) and 1122(d)(4)(xv) to be inapplicable to the activities AEGON performs with respect to the Platform.

Appendix B – Commercial Mortgage Backed Securities Transactions included in AEGON’s

Master
Servicer	Deal Name	Loan Specific Name
Berkadia	MSC 2013-ALTM
KeyBank	COMM 2013-300P
	GSMS 2016-RENT	Mezzanine B Note
	SHOPS 2016-CSTL
	COMM 2016-667M
	CSMC 2017-LSTK
	CSMC 2017-MOON
	GSMS 2017-FARM
	BX 2018-BIOA
	DBGS 2018-BIOD
	JPMCC 2018-AON
	BBCMS 2017-DELC
	CGDBB 2017-BIOC
	BX 2019-RP
	COMM 2016-GCT
	SGCMS 2019-PREZ
	BX 2019-XL
	BX 2018-GW
	BX 2018-BILT
	JPMCC 2018-PHH
	MSC 2018-SUN
Midland	PRMA CDO-III
	PRMA CDO-IV
	PRMA CDO-V
	BACM 2015-UBS7	200 Helen St
	CSAIL 2015-C3	Charles River Plaza North
	GSMS 2017-485L
	CGCMT 2018-TBR
	UBSCM 2018-C9	DreamWorks Headquarters
	IPT 2018-INDP
	BAMLL 2018-PARK
	BAMLL 2019-BPR
USBank	PRMA CDO-VI
Wells Fargo	GSMS 2017-375H
	UBSCM 2017-C4	Fairmount at Brewerytown
	BAMLL 2013-WBRK
	WFLD 2014-MONT
	BAMLL 2015-200P

	BAMLL 2015-HAUL
	BAMLL 2015-ASTR
	GSMS 2015-590M
	BAMLL 2016-SS1
	BAMLL 2016-ISQ
	BBCMS 2016-ETC
	HY 2016-10HY
	CFCRE 2016-C6	Potomac Mills
	GSMS 2016-GS4	225 Bush Street
	DBWF 2016-85T
	PRKAV 2017-245P
	UBSCM 2017-C1	SaveMart
	HMH 2017-NSS
	BXP 2017-GM
	IMTT 2017-APTS
	MAD 2017-330M
	BXP 2017-CC
	DBUBS 2017-BRBK
	WFCM 2017-HSDB
	BAMLL 2017-SCH	The Sheraton Grand Chicago - Leased Fee
	WFCM 2017-SMP
	WFCM 2018-Bxi
	NCMS 2018-ALXA
	DBWF 2018-AMXP
	BANK 2018-BN12	Fair Oaks Mall
	COMM 2018-HOME
	WFCM 2018-1745
	NCMS 2018-FL1
	WFCM 2018-AUS
	BX 2018-EXCL
	BX 2018-IND
	SGCMS 2019-787E
	JAX 2019-LIC
	SGCMS 2020-COVE
	UBSCM 2018-NYCH
	BX 2017-CQHP
	FTST 2006-4TS