Attached files

file filename
10-K - FROM 10-K - COMM 2015-LC21 Mortgage Trustdb152110k.txt
EX-31 - EXHIBIT 31 - COMM 2015-LC21 Mortgage Trustex31.txt
EX-33 - EXHIBIT 33.3 - COMM 2015-LC21 Mortgage Trustex333db.htm
EX-33 - EXHIBIT 33.4 - COMM 2015-LC21 Mortgage Trustex334pbls.htm
EX-33 - EXHIBIT 33.7 - COMM 2015-LC21 Mortgage Trustex337wells.htm
EX-33 - EXHIBIT 33.5 - COMM 2015-LC21 Mortgage Trustex335keybank.htm
EX-33 - EXHIBIT 33.1 - COMM 2015-LC21 Mortgage Trustex331midland.htm
EX-35 - EXHIBIT 35.3 - COMM 2015-LC21 Mortgage Trustex353db.htm
EX-34 - EXHIBIT 34.4 - COMM 2015-LC21 Mortgage Trustex344pbls.htm
EX-34 - EXHIBIT 34.15 - COMM 2015-LC21 Mortgage Trustex3415cwc.htm
EX-33 - EXHIBIT 33.13 - COMM 2015-LC21 Mortgage Trustex3313nts.htm
EX-34 - EXHIBIT 34.13 - COMM 2015-LC21 Mortgage Trustex3413nts.htm
EX-33 - EXHIBIT 33.12 - COMM 2015-LC21 Mortgage Trustex3312core.htm
EX-34 - EXHIBIT 34.12 - COMM 2015-LC21 Mortgage Trustex3412core.htm
EX-34 - EXHIBIT 34.7 - COMM 2015-LC21 Mortgage Trustex347wells.htm
EX-35 - EXHIBIT 35.8 - COMM 2015-LC21 Mortgage Trustex358wells.htm
EX-35 - EXHIBIT 35.6 - COMM 2015-LC21 Mortgage Trustex356wells.htm
EX-35 - EXHIBIT 35.12 - COMM 2015-LC21 Mortgage Trustex3512wells.htm
EX-35 - EXHIBIT 35.11 - COMM 2015-LC21 Mortgage Trustex3511wells.htm
EX-35 - EXHIBIT 35.10 - COMM 2015-LC21 Mortgage Trustex3510wells.htm
EX-34 - EXHIBIT 34.5 - COMM 2015-LC21 Mortgage Trustex345keybank.htm
EX-34 - EXHIBIT 34.9 - COMM 2015-LC21 Mortgage Trustex349wellsca.htm
EX-35 - EXHIBIT 35.1 - COMM 2015-LC21 Mortgage Trustex351midland.htm
EX-34 - EXHIBIT 34.1 - COMM 2015-LC21 Mortgage Trustex341midland.htm
EX-33 - EXHIBIT 33.9 - COMM 2015-LC21 Mortgage Trustex339wellsca.htm
EX-35 - EXHIBIT 35.4 - COMM 2015-LC21 Mortgage Trustex354keybank.htm
EX-34 - EXHIBIT 34.6 - COMM 2015-LC21 Mortgage Trustex346berkeley.htm
EX-35 - EXHIBIT 35.5 - COMM 2015-LC21 Mortgage Trustex355berkeley.htm
EX-33 - EXHIBIT 33.11 - COMM 2015-LC21 Mortgage Trustex3311pentalpha.htm
EX-34 - EXHIBIT 34.11 - COMM 2015-LC21 Mortgage Trustex3411pentalpha.htm
EX-33 - EXHIBIT 33.10 - COMM 2015-LC21 Mortgage Trustex3310wellscust.htm
EX-34 - EXHIBIT 34.3 - COMM 2015-LC21 Mortgage Trustex343db.htm
EX-33 - EXHIBIT 33.15 - COMM 2015-LC21 Mortgage Trustex3315cwc.htm
EX-34 - EXHIBIT 34.10 - COMM 2015-LC21 Mortgage Trustex3410wellscust.htm
Exhibit 33.6

 

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)(1)(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.

 

     

 

 

 

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-FL1
       
201414268 WC 717 N Harwood Properties LLC 717 North Harwood Commercial Mortgage Pass-Through Certificates Series 2014-FL1
       
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  I nvestors, 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-GS1
       
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) criteria determined 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)