Attached files
Exhibit 34.6
KPMG LLP Two Financial Center | ||
60 South Street | ||
Boston, MA 02111 |
Report of Independent Registered Public Accounting Firm
Member
Berkeley Point Capital LLC:
We have examined managements assessment, included in the accompanying Managements Assessment of Compliance with Applicable Criteria Pursuant to Item 1122 of Regulation AB, that Berkeley Point Capital LLC (BPC or the Company) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commissions Regulation AB for commercial mortgage-backed security transactions for which BPC acted as primary servicer (the Platform), except for servicing criteria 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), and 1122(d)(4)(xv), which the Company has determined are not applicable to the activities it performs with respect to the Platform, as of and for the year ended December 31, 2016. With respect to applicable servicing criteria 1122(d)(4)(i), 1122(d)(4)(iii), 1122(d)(4)(vi), 1122(d)(4)(viii), 1122(d)(4)(xii), and 1122(d)(4)(xiv), the Company has determined that there were no activities performed during the year ended December 31, 2016 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities. Appendix A to Managements Assessment identifies the primary collateral and securitizations defined by management as constituting the Platform. Management is responsible for the Companys compliance with the servicing criteria. Our responsibility is to express an opinion on managements assessments about the Companys compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants and, accordingly, included examining, on a test basis, evidence about the Companys compliance with the servicing criteria specified above and performing such other procedures as we considered necessary in the circumstances. Our examination included testing selected asset-backed transactions and collateral that comprise the Platform, testing selected servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Companys compliance with the servicing criteria.
As described in the accompanying Managements Assessment, for servicing criteria 1122(d)(1)(v), 1122(d)(2)(vi), and 1122(d)(2)(vii), BPC has engaged Midland Loan Services, a division of PNC Bank, National Association (Midland) to perform the activities required by these servicing criteria. BPC has determined that Midland is not considered a servicer as defined in Item 1101(j) of Regulation AB, and BPC has elected to take responsibility for assessing compliance with the servicing criteria applicable to
Midland as permitted by the SECs Compliance and Disclosure Interpretation (C&DI) 200.06, Vendors
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Engaged by Servicers (C&DI 200.06) (formerly SEC Manual Telephone Interpretation 17.06). As permitted by C&DI 200.06, BPC has asserted that it has policies and procedures in place designed to provide reasonable assurance that Midlands activities comply in all material respects with the servicing criteria applicable to Midland. BPC is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for Midland and the related servicing criteria as described in Managements Assessment, and we performed no procedures with respect to BPCs eligibility to apply C&DI 200.06.
The Company has determined that servicing criterion 1122(d)(1)(v) is applicable to the activities the Company performs with respect to the Platform for all transactions and securities in the Platform, including those issued on or before November 23, 2015 for which compliance was previously assessed under other servicing criteria, as applicable, for the assessment period as of and for the year ended December 31, 2016.
In our opinion, managements assessment that Berkeley Point Capital LLC complied with the aforementioned servicing criteria as of and for the year ended December 31, 2016 is fairly stated, in all material respects.
Boston, MA
February 22, 2017