Attached files
EX-33.1
(logo) MIDLAND (logo) PNC
LOAN REAL ESTATE
SERVICES
Report on Assessment of Compliance with Regulation AB Servicing Criteria
Midland Loan Services ("Midland"), a division of PNC Bank, National Association,
is responsible for assessing compliance with the applicable servicing criteria
set forth in Item 1122 (d) of Regulation AB of the Securities and Exchange
Commission ("Regulation AB"), as set forth in Appendix A hereto, relating to its
role in the servicing of commercial mortgage-backed securities transactions.
Midland has assessed its compliance with the applicable servicing criteria as of
and for the year ended December 31, 2013 (the "Reporting Period"). In making
this assessment, Midland used the criteria set forth by the Securities and
Exchange Commission ("SEC") in Item 1122(d) of Regulation AB. This report covers
the commercial mortgage-backed securities transactions (the "Platform").
Midland engaged certain vendors, which are not servicers as defined in item
1101(j) of Regulation AB (the "Vendors"), to perform specific, limited or
scripted activities related to portions of the servicing criteria as set forth
in Appendix A. Midland elects 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. Midland has not identified
and is not aware of any material instances of noncompliance by the Vendors with
the applicable servicing criteria as of December 31, 2013 and for the Reporting
Period with respect to the Platform taken as a whole, nor has it identified any
material deficiencies in its policies and procedures to monitor the compliance
by the Vendors with the applicable servicing criteria as of December 31, 2013
and for the Reporting Period with respect to the Platform taken as a whole.
Based on this assessment, Midland believes that, as of and for the year ended
December 31, 2013, Midland has complied in all material respects with the
servicing criteria set forth in Item 1122(d) of Regulation AB relating to its
role in the servicing of commercial mortgage-backed securities transactions.
PricewaterhouseCoopers LLP, an independent registered public accounting firm,
has issued an attestation report on Midland's assessment of compliance with the
applicable servicing criteria as of and for the year ended December 31, 2013.
MIDLAND LOAN SERVICES
a division of PNC Bank, National Association
/s/ Steven W. Smith
Steven W. Smith
Executive Vice President
/s/ Bradley J. Hauger
Bradley J. Hauger
Senior Vice President
Date: February 24, 2014
Member of The PNC Financial Services Group
10851 Mastin Boulevard Overland Park, Kansas 66210
800-327-8083
www.pnc.com/midland
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(page)
(logo) MIDLAND (logo) PNC
LOAN REAL ESTATE
SERVICES
APPENDIX A
APPLICABLE
SERVICING CRITERIA SERVICING CRITERIA
Performed
by Vendor(s)
for which
Midland is
Performed the
Directly by Responsible
Reference Criteria Midland Party
General Servicing Considerations
1122(d)(1)(i) Policies and procedures are instituted to monitor any X
performance or other triggers and events of default in
accordance with the transaction agreements.
.
1122(d)(1)(ii) If any material servicing activities are outsourced to third X
parties, policies and procedures are instituted to monitor the
third party's performance and compliance with such servicing
activities.
1122(d)(1)(iii) Any requirements in the transaction agreements to maintain a N/A^1
back-up servicer for the pool assets are maintained.
1122(d)(1)(iv) A fidelity bond and errors and omissions policy is in effect on X
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.
Cash Collection and Administration
1122(d)(2)(i) Payments on pool assets are deposited into the appropriate X
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.
1122(d)(2)(ii) Disbursements made via wire transfer on behalf of an obligor or X
to an investor are made only by authorized personnel.
1122(d)(2)(iii) Advances of funds or guarantees regarding collections, cash X
flows or distributions, and any interest or other fees charged for
such advances, are made, reviewed and approved as specified in
the transaction agreements.
1122(d)(2)(iv) The related accounts for the transaction, such as cash reserve X
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.
1122(d)(2)(v) Each custodial account is maintained at a federally insured X
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.
1122(d)(2)(vi) Unissued checks are safeguarded so as to prevent unauthorized X
access.
^1 Midland has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D),
1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), and 1122(d)(4)(xv) to be inapplicable to the activities Midland
performs with respect to the commercial mortgage-backed securities transactions being serviced.
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(page)
(logo) MIDLAND (logo) PNC
LOAN REAL ESTATE
SERVICES
APPLICABLE
SERVICING CRITERIA SERVICING CRITERIA
Performed
by Vendor(s)
for which
Midland is
Performed the
Directly by Responsible
Reference Criteria Midland Party
Cash Collection and Administration (continued)
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:
(A) Are mathematically accurate; X
(B) Are prepared within 30 calendar days after the X
bank statement cutoff date, or such other number of
days specified in the transaction agreements;
(C) Are reviewed and approved by someone other than X
the person who prepared the reconciliation; and
(D) Contain explanations for reconciling items. These X
reconciling items are resolved within 90 calendar days
of their original identification, or such other number of
days specified in the transaction agreements.
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:
(A) Are prepared in accordance with timeframes and X
other terms set forth in the transaction agreements;
(B) Provide information calculated in accordance with N/A^1
the terms specified in the transaction agreements;
(C) Are filed with the Commission as required by its N/A^1
rules and regulations; and
(D) Agree with the investor's or the trustee's records as to N/A^1
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 N/A^1
accordance with timeframes, distribution priority and other
terms set forth in the transaction agreements.
1122(d)(3)(iii) Disbursements made to an investor are posted within two N/A^1
business days to the servicer's investor records, or such other
number of days specified in the transaction agreements.
1122(d)(3)(iv) Amounts remitted to investors per the investor reports agree N/A^1
with cancelled checks, or other form of payment, or custodial
bank statements.
^1 Midland has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D),
1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), and 1122(d)(4)(xv) to be inapplicable to the activities Midland
performs with respect to the commercial mortgage-backed securities transactions being serviced.
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(page)
(logo) MIDLAND (logo) PNC
LOAN REAL ESTATE
SERVICES
APPLICABLE
SERVICING CRITERIA SERVICING CRITERIA
Performed
by Vendor(s)
for which
Midland is
Performed the
Directly by Responsible
Reference Criteria Midland Party
Pool Asset Administration
1122(d)(4)(i) Collateral or security on pool assets is maintained as required by X X
the transaction agreements or related mortgage loan documents. (only with
respect to
removal from
pools)
1122(d)(4)(ii) Pool assets and related documents are safeguarded as required X
by the transaction agreements.
1122(d)(4)(iii) Any additions, removals or substitutions to the asset pool are X X
made, reviewed and approved in accordance with any conditions (only with
or requirements in the transaction agreements. respect to
removal from
pools)
1122(d)(4)(iv) Payments on pool assets, including any payoffs, made in X
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.
1122(d)(4)(v) The servicer's records regarding the pool assets agree with the X
servicer's records with respect to an obligor's unpaid principal
balance.
1122(d)(4)(vi) Changes with respect to the terms or status of an obligor's pool X X
asset (e.g., loan modifications or re-agings) are made, reviewed (only with
and approved by authorized personnel in accordance with the respect to
transaction agreements and related pool asset documents. loan
assumptions)
1122(d)(4)(vii) Loss mitigation or recovery actions (e.g., forbearance plans, X
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.
1122(d)(4)(viii) Records documenting collection efforts are maintained during X
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).
1122(d)(4)(ix) Adjustments to interest rates or rates of return for pool assets X
with variable rates are computed based on the related pool asset
documents.
^1 Midland has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D),
1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), and 1122(d)(4)(xv) to be inapplicable to the activities Midland
performs with respect to the commercial mortgage-backed securities transactions being serviced.
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(page)
(logo) MIDLAND (logo) PNC
LOAN REAL ESTATE
SERVICES
APPLICABLE
SERVICING CRITERIA SERVICING CRITERIA
Performed
by Vendor(s)
for which
Midland is
Performed the
Directly by Responsible
Reference Criteria Midland Party
Pool Asset Administration (continued)
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 X
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 X
obligors in accordance with applicable pool asset
documents and state laws; and
(C) Such funds are returned to the obligor within 30 X
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 X X
payments) are made on or before the related penalty or (only with
expiration dates, as indicated on the appropriate bills or notices respect to
for such payments, provided that such support has been received tax-related
by the servicer at least 30 calendar days prior to these dates, or activities)
such other number of days specified in the transaction
agreements.
1122(d)(4)(xii) Any late payment penalties in connection with any payment to X
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.
1122(d)(4)(xiii) Disbursements made on behalf of an obligor are posted within X
two business days to the obligor's records maintained by the
servicer, or such other number of days specified in the
transaction agreements.
1122(d)(4)(xiv) Delinquencies, charge-offs and uncollectible accounts are X
recognized and recorded in accordance with the transaction
agreements.
1122(d)(4)(xv) Any external enhancement or other support, identified in Item N/A^1
1114(a)(1) through (3) or Item 1115 of this Regulation AB, is
maintained as set forth in the transaction agreements.
^1 Midland has determined servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D),
1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), and 1122(d)(4)(xv) to be inapplicable to the activities Midland
performs with respect to the commercial mortgage-backed securities transactions being serviced.
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