Attached files
EX-33.6
PARK BRIDGE LENDER SERVICES LLC
RE: Management's Report on Assessment of 2013 Compliance by Park Bridge
Lender Services LLC with Regulation AB Servicing Criteria
Park Bridge Lender Services LLC (the "Asserting Party") is responsible for
assessing its compliance, as of and for the period ended December 31, 2013, 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 or operating advisor for the
asset-backed securities transactions listed in Exhibit B 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 Section 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 A attached hereto.
Based on its assessment, the Asserting Party believes that, as of and for the
periods the contractual obligations existed in calendar year ending December 31,
2013, the Asserting Party has complied in all material respects with the
servicing criteria set forth in Item 1122(d) of Regulation AB relating to its
trust or operating advisor role with respect to the Platform, except for
servicing criteria 1122(d)(1)(i-iv), 1122(d)(2)(i-vii), 1122(d)(3)(ii-iv),
1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv), which the Asserting Party has
determined as being inapplicable to the activities it performs with respect the
Platform (the "applicable servicing criteria").
Curcio, Wieselthier & Cohen CPAs, PC, 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
Managing Member
560 LEXINGTON AVENUE, 17TH FLOOR, NEW YORK, NY 10022
WWW.PARKBRIDGEFINANCIAL.COM
(page)
Exhibit A
Regulation AB Section 229.1122(d) Servicing Criteria
Regulation AB Servicing Criterion Performed by Not Applicable to
Reference Park Bridge ^1 Park Bridge^2
1122(d)(1)(i) Policies and procedures are instituted X
to monitor any performance or other
triggers and events of default in
accordance with the transaction
agreements.
1122(d)(1)(ii) 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
activities.
1122(d)(1)(iii) Any requirements in the transaction X
agreements to maintain a backup servicer
for the mortgage loans are maintained.
1122(d)(1)(iv) 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
the transaction agreements.
1122(d)(2)(i) Payments on pool assets are deposited X
into the appropriate custodial bank
accounts and related bank clearing
accounts within no more than two
business days of receipt, or such
other number of days specified in
the transaction agreements.
1122(d)(2)(ii) Disbursements made via wire transfer on X
behalf of an obligor or to an investor
are made only by authorized personnel.
1122(d)(2)(iii) 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
the transaction documents
1122(d)(2)(iv) 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
the transaction agreements.
1122(d)(2)(v) 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) of this chapter.
1122(d)(2)(vi) Unissued checks were safeguarded so as X
to prevent unauthorized access.
1122(d)(2)(vii) 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 transaction
agreements.
1122(d)(3)(i)(A) Reports to investors, including those X
to be filed with the Commission, are
maintained in accordance with the
Page 2 of 5
(page)
Regulation AB Servicing Criterion Performed by Not Applicable to
Reference Park Bridge ^1 Park Bridge^2
transaction agreements and applicable
Commission requirements. Specifically,
such reports are prepared in accordance
with time frames and other terms set
forth in the transaction agreements.
1122(d)(3)(i)(B) 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 provide information
calculated in accordance with the terms
specified in the transaction agreements.
1122(d)(3)(i)(C) Reports to investors, including those X^3 X^4
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.
1122(d)(3)(i)(D) Reports to investors, including those X^3 X^4
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 mortgage
loans serviced by the servicer.
1122(d)(3)(ii) Amounts due to investors are allocated X
and remitted in accordance with
time frames, distribution priority and
other terms set forth in the transaction
agreements.
1122(d)(3)(iii) 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
agreements.
1122(d)(3)(iv) Amounts remitted to investors per the X
investor reports agree with canceled
checks, or other form of payment, or
custodial bank statements
1122(d)(4)(i) Collateral or security on pool assets X
is maintained as required by the
transaction agreements or related
pool asset documents.
1122(d)(4)(ii) Pool assets and related documents are X
safeguarded as required by the
transaction agreements.
1122(d)(4)(iii) Any additions, removals or substitutions X
to the asset pool are made, reviewed
and approved in accordance with
any conditions or requirements in the
transaction agreements.
1122(d)(4)(iv) 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 related pool asset documents.
1122(d)(4)(v) The servicer's records regarding the X
pool assets agree with the servicer's
records with respect to an obligor's
unpaid principal balance
1122(d)(4)(vi) Changes with respect to the terms or X
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.
1122(d)(4)(vii) Loss mitigation or recovery actions X
(e.g., forbearance plans, modifications
and deeds in lieu of foreclosure,
foreclosures
Page 3 of 5
(page)
Regulation AB Servicing Criterion Performed by Not Applicable to
Reference Park Bridge ^1 Park Bridge^2
and repossessions, as
applicable) are initiated, conducted and
concluded in accordance with the
time frames or other requirements
established by the transaction
agreements.
1122(d)(4)(viii) 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.,
illness or unemployment).
1122(d)(4)(ix) Adjustments to interest rates or rates X
of return for pool assets with variable
rates are computed based on the related
pool asset documents.
1122(d)(4)(x) 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 were 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 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
the transaction agreements.
1122(d)(4)(xii) Any late payment penalties in X
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.
1122(d)(4)(xiii) 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
agreements
1122(d)(4)(xiv) Delinquencies, charge-offs and X
uncollectible accounts are recognized
and recorded in accordance with the
transaction agreements
1122(d)(4)(xv) Any external enhancement or other X
support, identified in Item
1114(a)(1) through (3) or Item 1115 of
Regulation AB, is maintained as set
forth in the transaction agreements.
^1 The criteria in the column "Performed by Park Bridge" and marked with an "X"
is applicable for the Transactions unless otherwise noted; however, there
were no specially serviced loans under the related Transactions during the
reporting period. Therefore, no trust/operating advisor actions were
required.
^2 The criteria in the column "Not Applicable to Park Bridge" and marked with an
"X" was not within the scope of the Asserting Party's duties in the
Transactions.
^3 Applicable to the COMM 2012-LC4, COMM 2012-CCRE2, COMM 2012-CCRE4,
COMM 2012-CCRE5, COMM 2013-CCRE6, COMM 2013-CCRE7, COMM 2013-CCRE9,
COMM 2013-LC13, and COMM 2013-CCRE10 Transactions only.
^4 Not applicable to Transactions other than the Transactions identified in Note
3 above.
Page 4 of 5
(page)
Exhibit B
Asserting Party's 2013 Servicing Platform by Issuer and Master Servicer
Depositor Name of Securitization Master Servicer Period of Service
Deutsche Mortgage & Asset COMM 2012-LC4 Commercial Mortgage Wells Fargo Bank, January 1, 2013-
Receiving Corporation Pass-Through Certificates National Association December 31, 2013
Deutsche Mortgage & Asset COMM 2012-CCRE2 Commercial Wells Fargo Bank, January 1, 2013-
Receiving Corporation Mortgage Pass-Through Certificates National Association December 31, 2013
UBS Commercial Mortgage UBS-Barclays Commercial Mortgage Midland Loan January 1, 2013-
Securitization Corp. Trust 2012-C3, Commercial Mortgage Services, a division of December 31, 2013
Pass-Through Certificates, Series 2012-C3 PNC Bank, National
Association
Deutsche Mortgage & Asset COMM 2012-CCRE4 Commercial Wells Fargo Bank, January 1, 2013-
Receiving Corporation Mortgage Pass-Through Certificates National Association December 31, 2013
Deutsche Mortgage & Asset COMM 2012-CCRE5 Commercial Midland Loan January 1, 2013-
Receiving Corporation Mortgage Pass-Through Certificates Services, a division of December 31, 2013
PNC Bank, National
Association
Deutsche Mortgage & Asset COMM 2013-LC6 Commercial Midland Loan January 30, 2013-
Receiving Corporation Mortgage Pass-Through Certificates Services, a division of December 31, 2013
PNC Bank, National
Association
Deutsche Mortgage & Asset COMM 2013-CCRE6 Commercial Wells Fargo Bank, March 7, 2013-
Receiving Corporation Mortgage Pass-Through Certificates National Association December 31, 2013
J.P. Morgan Chase JPMCC 2013-C10 Commercial Midland Loan March 14, 2013-
Commercial Mortgage Mortgage Pass-Through Certificates Services, a division of December 31, 2013
Securities Corp. PNC Bank, National
Association
Deutsche Mortgage & Asset COMM 2013-CCRE7 Commercial Midland Loan April 23, 2013-
Receiving Corporation Mortgage Pass-Through Certificates Services, a division of December 31, 2013
PNC Bank, National
Association
Barclays Commercial Mortgage UBS-Barclays Commercial Midland Loan April 25, 2013-
Securities LLC Mortgage Trust 2013-C6 Services, a division of December 31, 2013
Commercial Mortgage Pass-Through PNC Bank, National
Certificates, Series 2013-C6 Association
Deutsche Mortgage & Asset COMM 2013-CCRE8 Commercial Midland Loan June 13, 2013-
Receiving Corporation Mortgage Pass-Through Certificates Services, a division of December 31, 2013
PNC Bank, National
Association
Morgan Stanley Capital I Inc. Morgan Stanley Bank of America . Midland Loan July 2, 2013-
Merrill Lynch Trust 2013-C10 Services, a division of December 31, 2013
Commercial Mortgage Pass-Through PNC Bank, National
Certificates, Series 2013-C10. Association
Deutsche Mortgage & Asset COMM 2013-CCRE9 Commercial KeyCorp Real Estate July 10, 2013-
Receiving Corporation Mortgage Pass-Through Capital Markets, Inc. December 31, 2013
Certificates
Wells Fargo Commercial Wells Fargo Commercial Wells Fargo Bank, July 30, 2013-
Mortgage Securities, Inc. Mortgage Trust Pass-Through National Association December 31, 2013
Certificates, Series 2013-LC12
Deutsche Mortgage & Asset COMM 2013-CCRE10 Commercial Wells Fargo Bank, August 13, 2013-
Receiving Corporation Mortgage Pass-Through National Association December 31, 2013
Certificates
Deutsche Mortgage & Asset COMM 2013-LC13 Commercial Midland Loan September 27, 2013-
Receiving Corporation Mortgage Pass-Through Services, a division of December 31, 2013
Certificates PNC Bank, National
Association
Deutsche Mortgage & Asset COMM 2013-CCRE11 Commercial Midland Loan October 8, 2013-
Receiving Corporation Mortgage Pass-Through Services, a division of December 31, 2013
Certificates PNC Bank, National
Association
Deutsche Mortgage & Asset COMM 2013-CCRE12 Commercial Wells Fargo Bank, November 7, 2013-
Receiving Corporation Mortgage Pass-Through National Association December 31, 2013
Certificates
Wells Fargo Commercial WFRBS Commercial Mortgage Wells Fargo Bank, December 11, 2013-
Mortgage Securities, Inc. Trust 2013-UBS1, Commercial National Association December 31, 2013
Mortgage Pass-Through
Certificates, Series
2013-UBS1
Page 5 of 5
