Attached files
EX-33.13
(logo) Situs
Situs Holdings, LLC
2 Embarcadero Center, Suite 1300
San Francisco, CA 94111
Phone: 415.374.2820
Fax: 415. 374.2704
www.situs.com
Certification Regarding Compliance with Applicable Servicing Criteria
1. Situs Holdings, LLC (the "Company" or "Situs"), is responsible for
assessing compliance with the serv1cmg criteria applicable to it under
paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month
period ended December 31, 2013 (the "Reporting Period"), as set forth in
Appendix A hereto. The transactions covered by this report (these
transactions collectively referred to as the "Special Servicing Platform")
include asset-backed securities transactions for which Situs acted as special
servicer, involving commercial mortgage loans;
2. Situs has engaged certain vendors (the "Vendors") to perform specific,
limited or scripted activities for the Reporting Period, and Situs has
elected to take responsibility for assessing compliance with the servicing
criteria or portion of the servicing criteria applicable to such Vendors'
activities as set forth in Appendix A hereto;
3. Except as set forth in paragraph 4 below, Situs used the criteria set forth
in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with
the applicable servicing criteria;
4. The criteria listed in the column titled "Inapplicable Servicing Criteria"
on Appendix A hereto are inapplicable to Situs based on the activities it
performed, directly or through its Vendors, with respect to the Special
Servicing Platform for the Reporting Period; or, with respect to criteria
1122(d)(2)(i), 1122(d)(2)(iii), 1122(d)(2)(vi) and 1122(d)(4)(i), such
criteria are Inapplicable Servicing Criteria because Situs was not required
to perform any such criteria during the Reporting Period;
5. Situs has complied, in all material respects, with the applicable servicing
criteria as of December 31, 2013 and for the Reporting Period with respect
to the Special Servicing Platform taken as a whole;
6. For criteria 1122(d)(1)(iv), certain Pooling and Servicing Agreements (PSAs)
require the Special Servicer to maintain fidelity bond and errors and
omissions insurance policies in amounts at least equal to or great than the
Fannie Mae or Freddie Mac coverage requirements. While the applicable
insurance policies cover multiple servicing platforms, in determining the
required coverage requirement for these PSAs, the Company only considers the
Special Servicing Platform applicable to these PSAs;
7. Grant Thornton LLP, an independent registered public accounting firm, has
issued an attestation report on Situs' assessment of compliance with the
applicable servicing criteria for the Reporting Period.
Situs Holdings LLC
March 26, 2014
By: /s/ Linda Sanchez
Linda Sanchez
Managing Director
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APPENDIX A
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by Performed by NOT
Vendor(s) for subservicer(s) performed by
which Situs is or vendor(s) Situs or by
Performed the for which Situs subservicer(s)
Directly Responsible is NOT the or vendor(s
by Party Responsible retained by
Situs Party Situs
Reference Criteria
General Servicing Considerations
Policies and procedures are instituted X
to monitor any performance or other
triggers and events of default in
accordance with the transaction
1122(d)(1)(i) agreements.
If any material servicing activities X
are outsourced to third parties, policies
and procedures are instituted to monitor
the third party's performance and
compliance with such servicing
1122(d)(1)(ii) activities.
Any requirements in the transaction X
agreements to maintain a back-up servicer
1122(d)(1)(iii) for the pool assets are maintained.
A fidelity bond and errors and X
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
1122(d)(1)(iv) the transaction agreements.
Cash Collection and Administration
Payments on pool assets are deposited X
into the appropriate 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
1122(d)(2)(i) agreements.
Disbursements made via wire transfer on X
behalf of an obligor or to an investor are
1122(d)(2)(ii) made only by authorized personnel.
Advances of funds or guarantees X
regarding collections, cash flows or
distributions, and any interest or other
fees charged for such advances, are made,
reviewed and approved as specified in
1122(d)(2)(iii) the transaction agreements.
The related accounts for the X
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
1122(d)(2)(iv) the transaction agreements.
Each custodial account is maintained at X
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 section 240.13k-1(b)(1)
1122(d)(2)(v) of this chapter.
(logo) Situs
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INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by Performed by NOT
Vendor(s) for subservicer(s) performed by
which Situs is or vendor(s) Situs or by
Performed the for which Situs subservicer(s)
Directly Responsible is NOT the or vendor(s
by Party Responsible retained by
Situs Party Situs
Reference Criteria
Unissued checks are safeguarded so as X
1122(d)(2)(vi) to prevent unauthorized access^1.
Reconciliations are prepared on a X
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; (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
1122(d)(2)(vii) transaction agreements.
Investor Remittances and Reporting
Reports to investors, including those X
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;
(C) Are filed with the Commission as
required by its rules and regulations;
(D) Agree with the investors' or trustee's
records as to the total unpaid principal
balance and number of pool assets
1122(d)(3)(i) serviced by the servicer.
Amounts due to investors are allocated X
and remitted in accordance with
timeframes, distribution priority and
other terms set forth in the transaction
1122(d)(3)(ii) agreements.
Disbursements made to an investor are X
posted within two business days to the
servicer's investor records, or such other
number of days specified in the transaction
1122(d)(3)(iii) agreements.
Amounts remitted to Investors per the X
investor reports agree with cancelled
checks, or other form of payment, or
1122(d)(3)(iv) custodial bank statements.
Pool Asset Administration
Collateral or security on pool assets X
is maintained as required by the
transaction agreements or related
1122(d)(4)(i) pool assets documents.
Pool assets and related documents are X
safeguarded as required by the
1122(d)(4)(ii) transaction agreements.
^1 Situs does not maintain unissued checks.
(logo) Situs
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INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by Performed by NOT
Vendor(s) for subservicer(s) performed by
which Situs is or vendor(s) Situs or by
Performed the for which Situs subservicer(s)
Directly Responsible is NOT the or vendor(s
by Party Responsible retained by
Situs Party Situs
Reference Criteria
Any additions, removals or substitutions X
to the asset pool are made, reviewed
and approved in accordance with
any conditions or requirements in the
1122(d)(4)(iii) transaction agreements.
Payments on pool assets, including any X
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
1122(d)(4)(iv) related pool asset documents.
The servicer's records regarding the X
pool asset agree with the servicer's
records with respect to an obligor's
1122(d)(4)(v) unpaid principal balance.
Changes with respect to the terms or X
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
1122(d)(4)(vi) related pool asset documents.
Loss mitigation or recovery actions X
(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
1122(d)(4)(vii) agreements.
Records documenting collection efforts X
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.,
1122(d)(4)(viii) illness or unemployment).
Adjustments to interest rates or rates X
of return for pool assets with variable
rates are computed based on the related
1122(d)(4)(ix) pool assets documents.
Regarding any funds held in trust for X
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
1122(d)(4)(x) transaction agreements.
(logo) Situs
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INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by Performed by NOT
Vendor(s) for subservicer(s) performed by
which Situs is or vendor(s) Situs or by
Performed the for which Situs subservicer(s)
Directly Responsible is NOT the or vendor(s
by Party Responsible retained by
Situs Party Situs
Reference Criteria
Payments made on behalf of an obligor X
(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
1122(d)(4)(xi) the transaction agreements.
Any late payment penalties in connection X
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
1122(d)(4)(xii) to the obligor's error or omission.
Disbursements made on behalf of an X
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
1122(d)(4)(xiii) agreements.
Delinquencies, charge-offs and X
uncollectible accounts are recognized and
recorded in accordance with the
1122(d)(4)(xiv) transaction agreements.
Any external enhancement or other X
support, identified in Item
1114(a)(1) through (3) or Item 1115 of
this Regulation AB, is maintained as set
1122(d)(4)(xv) forth in the transaction agreements.
(logo) Situs
