Attached files
LNR Partners, LLC
Certification Regarding Compliance with Applicable Servicing Criteria
1.
LNR Partners, LLC. (the "Asserting Party") is responsible for assessing compliance with the
servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and
for the 12-month period ending December 31, 2014 (the "Reporting Period"), as set forth in
Appendix A hereto. The transactions covered by this report, include commercial mortgage-
asset-backed securities transactions for which the Asserting Party served as special servicer,
and that were registered with the Securities and Exchange Commission pursuant to the
Securities Act of 1933 (the "Platform");
2.
The Asserting Party has 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,
and the Asserting Party 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 hereto;
3.
Except as set forth in paragraph 4 below, the Asserting Party 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 the Asserting Party based on the activities it performs, directly or through its
Vendors, with respect to the Platform;
5.
The Asserting Party has complied, in all material respects, with the applicable servicing criteria
as of December 31, 2014 and for the Reporting Period with respect to the Platform taken as a
whole;
6.
The Asserting Party has not identified and is not aware of any material instance of
noncompliance by the Vendors with the applicable servicing criteria as of December 31, 2014
and for the Reporting Period with respect to the Platform taken as a whole;
7.
The Asserting Party has not identified any material deficiency in its policies and procedures to
monitor the compliance by the Vendors with the applicable servicing criteria as of December
31, 2014 and for the Reporting Period with respect to the Platform taken as a whole; and
8.
Deloitte & Touche LLP, a registered public accounting firm, has issued an attestation report on
the Asserting Party's assessment of compliance with the applicable servicing criteria for the
Reporting Period.
February 23, 2015
LNR Partners, LLC
By:__/s/ Job Warshaw_______________
Name: Job Warshaw
Title: President
APPENDIX A
SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
Asserting
Party
Performed
by
Vendor(s)
for which
Asserting
Party is the
Responsible
Party
Performed by
subservicer(s)
or vendor(s)
for which
Asserting
Party is NOT
the
Responsible
Party
NOT
performed by
Asserting
Party or by
subservicer(s)
or vendor(s)
retained by
Asserting
Party
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
1122(d)(1)(iii)
Any requirements in the transaction agreements to maintain a
back-up servicer for the pool assets are maintained.
X
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 of the transaction
agreements.
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
X
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
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
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
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
1122(d)(2)(vi)
Unissued checks are safeguarded so as to prevent unauthorized
access.
X
1
Excludes the criteria as set forth on 3(i)(C) and 3(i)(D) which is not applicable to the Asserting Party.
2
The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not
routinely accept or process payments.
SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
Asserting
Party
Performed
by
Vendor(s)
for which
Asserting
Party is the
Responsible
Party
Performed by
subservicer(s)
or vendor(s)
for which
Asserting
Party is NOT
the
Responsible
Party
NOT
performed by
Asserting
Party or by
subservicer(s)
or vendor(s)
retained by
Asserting
Party
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
are (A) mathematically accurate; (B) prepared within 30 calendar
days after the bank statement cutoff date, or such other number of
days specified in the transaction agreements; (C) 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.
X
X
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 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 investors' or the trustee's records as to the total unpaid
principal balance and number of pool assets serviced by the
Servicer.
X
1
X
1
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.
X
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.
X
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.
X
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
1122(d)(4)(ii)
Pool asset and related documents are safeguarded as required by
the transaction agreements
X
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
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
2
SERVICING CRITERIA
APPLICABLE
SERVICING CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
Asserting
Party
Performed
by
Vendor(s)
for which
Asserting
Party is the
Responsible
Party
Performed by
subservicer(s)
or vendor(s)
for which
Asserting
Party is NOT
the
Responsible
Party
NOT
performed by
Asserting
Party or by
subservicer(s)
or vendor(s)
retained by
Asserting
Party
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.
X
1122(d)(4)(vi)
Changes with respect to the terms or 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.
X
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
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.
X
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
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 assets, or such other number of days
specified in the transaction agreements.
X
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.
X
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.
X
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.
X
1122(d)(4)(xiv)
Delinquencies, charge-offs and uncollectible accounts are
recognized and recorded in accordance with the transaction
agreements.
X
1122(d)(4)(xv)
Any external enhancement or other support, identified in Item
1114(a)(1) through (3) or Item 1115 of Regulation AB, is
maintained as set forth in the transaction agreements.
X
1
Excludes the criteria as set forth on 3(i)(C) and 3(i)(D) which is not applicable to the Asserting Party.
2
The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not
routinely accept or process payments.