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MANAGEMENT'S ASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA PURSUANT TO ITEM 1122 OF REGULATION AB
Management of Berkeley Point Capital LLC ("BPC") 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 relating to its role in the servicing of commercial mortgage-backed securities transactions conducted by BPC (the "Platform") as of and for the year ended December 31, 2015 (the "Reporting Period"). Appendix A identifies the individual asset-backed transactions and securities defined by management as constituting the Platform.
BPC's management has assessed BPC's compliance with the applicable servicing criteria during the Reporting Period. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission ("SEC") in paragraph (d) of Item 1122 of Regulation AB, excluding the criteria set forth in Appendix B, which management has determined are not applicable to the servicing activities it performs with respect to the Platform.
With respect to applicable servicing criteria identified in Appendix C, there were no activities performed for the Reporting Period with respect to the Platform, because there was no occurrence of events that would require BPC to perform such activities.
With respect to servicing criterion 1122(d)(l)(v), 1122(d)(2)(vi ) and 1122(d)(2)(vii), management has engaged Midland Loan Services, a division of PNC Bank, National Association ("Midland") to perform the activities required by these servicing criteria. BPC's management has determined that Midland is not a "servicer" as defined in Item 1101(j) of Regulation AB, and BPC's management has elected to take responsibility for assessing compliance with the servicing criteria applicable to Midland as permitted by the SEC's Compliance and Disclosure Interpretation (C&DI") 200.06, Vendors Engaged by Servicers (C&DI 200.06) (formerly SEC Regulation AB Manual of Publicly Available Telephone Interpretations, 17.06). Management has policies and procedures in place designed to provide reasonable assurance that Midland's activities comply in all material respects with the servicing criteria applicable to Midland. BPC has not identified and is not aware of any material instances of noncompliance by Midland with the applicable servicing criteria during 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 Midland with the applicable servicing criteria during the Reporting Period with respect to the Platform taken as a whole. BPC is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for Midland and the related criteria.
Based on such assessment, management believes that with respect to the Reporting Period, BPC has complied in all material respects with the servicing criteria set forth in Item 1122(d) of Regulation AB of the SEC, including servicing criterion 1122(d)(1)(v), 1122(d)(2)(vi ) and 1122(d)(2)(vii) for which compliance is determined based on C&DI 200.06 as described above relating to its role in the servicing of the Platform.
KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s assessment of compliance with the applicable servicing criteria with respect to the Reporting Period.
/s/ Ira Strassberg
Ira Strassberg
Chief Financial Officer
/s/ Ellen Miller
Ellen Miller
Managing Director, Head of Servicing
berkeley point capital llc
one beacon street ∙ 14th floor ∙ boston, ma 02108
(p) 877-526-3562 ∙ www.berkpoint.com
Appendix A to Management's Assessment
List of Loan for the Commercial Mortgage-Backed Securities constituting the "Platform"
|
Loan # |
Primary Borrower |
Primary Collateral |
Securitization |
|
|
201414364 |
Marble Cliff Commons Apartments LLC |
Marble Cliff Commons |
COMM 2014-CCRE 17 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201414099 |
YTC Butterfield Owner LLC |
Yorktown Center |
Commercial Mortgage Pass-Through Certificates Series 2014-FLl |
|
|
201414268 |
WC 717 N Harwood Properties LLC |
717 North Harwood |
Commercial Mortgage Pass-Through Certificates Series 2014-FLl |
|
|
201416328 |
BOT, LLC |
Library Lofts West |
COMM 2014-UBS4 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201416895 |
Pasadena East Office Investors LP |
2700 East Foothill |
COMM 2014-UBS4 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201416006 |
Sunroad Centrum Office One Partners, LP |
Bridgepoint Tower |
COMM 2014-CCRE19 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201416709 |
Millpond Village Apartments, II, LLC |
Millpond Village Apartments |
Commercial Mortgage Pass-Through Certificates Series 2014-GC24 |
|
|
201417736 |
Towne Independent Living, LLC |
Towne Village |
COMM 2014-CCRE20 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201418750 |
ST Mall Owner, LLC |
South Towne Center |
Commercial Mortgage Pass-Through Certificates Series 2014-FL2 |
|
|
201416474 |
29th Street Hotel Owner LLC |
Hotel Martha Washington |
Commercial Mortgage Pass-Through Certificates Series 2014-FL2 |
|
|
201409550 |
KRE Colonie Owner, LLC |
Colonie Center |
Commercial Mortgage Pass-Through Certificates Series 2014-FL2 |
|
|
201416542 |
Curtis Center TIC I, LLC |
The Curtis Center |
Commercial Mortgage Pass-Through Certificates Series 2014-FL2 |
|
|
201518310 |
Candlewood Lake Plaza, LLC. |
Candlewood Lake Plaza |
COMM 2015-LC19 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201418799 |
Canoga Office Investors LP |
5950 Canoga Avenue |
Commercial Mortgage Pass-Through Certificates Series 2015-GC28 |
|
|
201417076 |
Chestnut Oaks Land, Inc. |
Chestnut Oaks Condominium |
Commercial Mortgage Pass-Through Certificates Series 2015-GC28 |
|
|
201521700 |
Stony Brook Management, LLC. |
Stony Brook MHP |
Commercial Mortgage Pass-Through Certificates Series 2015-GC30 |
|
|
201521697 |
North View Manor, LLC. |
North View Manor MHP |
Commercial Mortgage Pass-Through Certificates Series 2015-GC30 |
|
|
201520588 |
Stonegate Apartments, LLC. |
Stonegate Apartments |
Commercial Mortgage Pass-Through Certificates Series 2015-CCRE23 |
|
|
201519159 |
College Station Apartments, LLC. |
College Station & The Polos |
Commercial Mortgage Pass-Through Certificates Series 2015-CCRE23 |
|
|
201521177 |
Mayfield NM, LLC |
Luxe Villas |
Commercial Mortgage Pass-Through Certificates Series 2015-CCRE23 |
|
|
201521698 |
The Pines at West Penn, LLC. |
Pines at West Penn MHP |
Commercial Mortgage Pass-Through Certificates Series 2015-LC21 |
|
|
201521695 |
Indian Run Village, LLC. |
Indian Run Village MHP |
Commercial Mortgage Pass-Through Certificates Series 2015-LC21 |
|
|
211521998 |
Eden Roc, LLLP. |
Eden Roc |
COMM 2015-CCRE24 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
221521998 |
Eden Roc, LLLP. |
Eden Roc A2 |
COMM 2015-CCRE24 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
231521998 |
Eden Roc, LLLP. |
Eden Roc A3 |
COMM 2015-CCRE24 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
241521998 |
Eden Roc, LLLP. |
Eden Roc A4 |
COMM 2015-CCRE24 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201523536 |
Newberry Estates Management, LLC. |
Newberry Estates MHP |
COMM 2015-CCRE26 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201521902 |
Clan Keith Real Estate Investments, LLC. |
Leisure Lake MHP |
COMM 2015-CCRE26 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201519207 |
EIP HOLLISTON, LLC |
89 Cross Street |
COMM 2015-CCRE26 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201523541 |
Cedar Manor Management, LLC. |
Cedar Manor MHP |
COMM 2015 CCRE27 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
201523532 |
Brookhaven MHP Management, LLC. |
Brookhaven MHP |
COMM 2015 CCRE27 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
211523066 |
NMS 1539, LLC. |
Luxe at 1539 Al |
COMM 2015 CCRE27 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
221523066 |
NMS 1539, LLC. |
Luxe at 1539 A2 |
COMM 2015 CCRE27 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
231523066 |
NMS 1539, LLC. |
Luxe at 1539 A3 |
COMM 2015 CCRE27 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
|
|
211521599 |
Hualalai Investors, LLC. |
Four Seasons Hualalai A-1 |
GSCCRE Commercial Mortgage Trust 2015-HULA Commercial Mortgage Pass-Through Certificates, Series 2015-HULA |
|
|
231521599 |
Hualalai Investors, LLC. |
Four Seasons Hualalai A-2 |
GSCCRE Commercial Mortgage Trust 2015-HULA Commercial Mortgage Pass-Through Certificates, Series 2015-HULA |
|
|
271521599 |
Hualalai Investors, LLC. |
Four Seasons Hualalai |
GSCCRE Commercial Mortgage Trust 2015-HULA Commercial Mortgage Pass-Through Certificates, Series 2015-HULA |
|
|
281521599 |
Hualalai Investors, LLC. |
Four Seasons Hualalai C-1 |
GSCCRE Commercial Mortgage Trust 2015-HULA Commercial Mortgage Pass-Through Certificates, Series 2015-HULA |
|
|
291521599 |
Hualalai Investors, LLC. |
Four Seasons Hualalai |
GSCCRE Commercial Mortgage Trust 2015-HULA Commercial Mortgage Pass-Through Certificates, Series 2015-HULA |
|
|
301521599 |
Hualalai Investors, LLC. |
Four Seasons Hualalai |
GSCCRE Commercial Mortgage Trust 2015-HULA Commercial Mortgage Pass-Through Certificates, Series 2015-HULA |
|
|
311521599 |
Hualalai Investors, LLC. |
Four Seasons Hualalai |
GSCCRE Commercial Mortgage Trust 2015-HULA Commercial Mortgage Pass-Through Certificates, Series 2015-HULA |
|
|
201523538 |
Deer Run Management, LLC. |
Deer Run MHP |
Commercial Mortgage Pass-Through Certificates Series 2015-GC34 |
|
|
201523533 |
Meadowview Management, LLC. |
Meadow View Estates MHP |
Commercial Mortgage Pass-Through Certificates Series 2015-GC34 |
|
|
201523530 |
Mill Creek MHP Management, LLC. |
Mill Creek Estates |
Commercial Mortgage Pass-Through Certificates Series 2015-GC34 |
|
|
221524031 |
Hudson Element LA, LLC. |
Element LA |
Commercial Mortgage Pass-Through Certificates Series 2015-GSl |
|
|
201517274 |
Landings Shops & Offices, Ltd. |
The Landings (Offices) |
COMM 2015-LC23 Mortgage Trust Commercial Mortgage Pass-Through Certificates |
Appendix B to Management's Assessment
Regulation AB Item 1122(d) criteriadetermined to be not applicable:
• 1122(d)(1)(iii)
• 1122(d)(2)(ii)
• 1122(d)(2)(iii)
• 1122(d)(3)(i)
• 1122(d)(3)(ii)
• 1122(d)(3)(iv)
• 1122(d)(4)(ii)
• 1122(d)(4)(vii)
• 1122(d)(4)(xv)
Appendix C to Management's Assessment
Regulation AB Item 1122(d) criteria that BPC is under contract to perform the activities required, but for which there were no occurrences of events for the year ended December 31, 2015 that required them to perform such activities:
• 1122(d)(4)(i)
• 1122(d)(4)(iii)
• 1122(d)(4)(vi)
• 1122(d)(4)(viii)
• 1122(d)(4)(xii)
• 1122(d)(4)(xiv)