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Enterprise
CAPITAL ON A MISSION
Management's Assertion on Compliance with Applicable Regulation AB Servicing Criteria
Management of Bellwether Enterprise Real Estate Capital, LLC (the Company), 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 (SEC) for asset-backed securities transactions for which the Company acted as servicer including commercial and multifamily mortgage loans (the Platform), as of and for the year ended December 31, 2017, excluding the following criteria set forth in Items 1122(d)(1)(iii), 1122(d)(2)(iii), 1122(d)(3)(i)(C), 1122(d)(4)(iii), 1122(d)(4)(vi), 1122(d)(4)(vii), and 1122(d)(4)(xv), which management has determined are not applicable to the activities performed by the Company with respect to the Platform. Appendix A identifies the asset-backed securities constituting the Platform. Appendix B identifies the applicable servicing criteria with respect to the Platform.
With respect to servicing criteria 1122(d)(4)(ii), 1122(d)(4)(viii), 1122(d)(4)(xii), and 1122(d)(4)(xiv), the Company has determined there were no activities performed during the year ended December 31, 2017 with respect to the Platform, because there were no occurrences or events that would require the Company to perform such activities.
With respect to servicing criteria 1122(d)(1)(ii), the Company has engaged certain vendors (the Vendors) to perform specific, limited, or scripted activities and the Company elects to take responsibility for assessing compliance with the servicing criteria, or portion of the servicing criteria, applicable to such Vendors’ activities. The Company has determined its Vendors are not “servicers” as defined in Item 1101(j) of Regulation AB and asserts that it has policies and procedures in place to provide reasonable assurance that the Vendors’ activities comply, in all material respects, with the servicing criteria applicable to each vendor.
The Company's management has assessed the Company's compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB with respect to the Platform as of and for the year ended December 31, 2017. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB. Based on such assessment, management believes that, as of and for the year ended December 31, 2017, the Company has complied in all material respects with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB with respect to the Platform.
Skoda Minotti & Co., an independent registered public accounting firm, has issued an attestation report with respect to the Company’s compliance with the applicable servicing criteria as of and for the year ended December 31, 2017.
February 28, 2018
/s/ Deborah Rogan
Deborah Rogan
Executive Vice President
Bellwether Enterprise Real Estate Capital, LLC
WWW.BELLWETHERENTERPRISE.COM
1360 E. 9th Street
Suite 300
Cleveland, Ohio
44114
216.820.4500
APPENDIX A
Banc of America Merrill Lynch Commercial Mortgage Inc. Series 2011-K13
Banc of America Merrill Lynch Commercial Mortgage Inc. Series 2012-K21
Banc of America Merrill Lynch Commercial Mortgage Inc. Series 2013-K25
Banc of America Merrill Lynch Commercial Mortgage Inc. Series 2017-BNK3
Banc of America Merrill Lynch Commercial Mortgage Inc. Series 2017-BNK6
BANK 2017-BNK4
Barclays Commercial Mortgage Securities LLC Series 2012-K17
Barclays Commercial Mortgage Securities LLC Series 2012-K19
Barclays Commercial Mortgage Securities LLC Series 2012-K22
Barclays Commercial Mortgage Securities LLC Series 2013-K27
Barclays Commercial Mortgage Securities LLC Series 2013-K31
Citigroup Commercial Mortgage Trust Series 2015-GC27
Citigroup Commercial Mortgage Trust Series 2015-GC29
Citigroup Commercial Mortgage Trust Series 2015-GC31
Citigroup Commercial Mortgage Trust Series 2015-GC33
Citigroup Commercial Mortgage Trust Series 2016-GC36
Citigroup Commercial Mortgage Trust Series 2016-GC37
Citigroup Commercial Mortgage Trust Series 2016-P6
Citigroup Commercial Mortgage Trust Series 2017-B1
Credit Suisse First Boston Mortgage Securities Corp. Series 2013-K35
CSAIL 2015-C3 Commercial Mortgage Trust
CSAIL 2015-C4 Commercial Mortgage Trust
CSAIL 2016-C5 Commercial Mortgage Trust
Deutsche Bank Securities, Inc. Series COMM 2014-LC17
Deutsche Mortgage & Asset Receiving Corporation COMM Series 2015-DC1
Deutsche Mortgage & Asset Receiving Corporation Series 2011-K16
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2014-K38
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2014-K39
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2014-K41
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2014-K714
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2014-KX01
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K42
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K45
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K46
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K47
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K48
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K49
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K50
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K51
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2015-K720
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K1502
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K52
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K56
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K57
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K58
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K59
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K60
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K722
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-K723
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-KF14
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-KF17
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-KF21
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-KF25
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-KJ04
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-KJ09
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-KW01
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2016-KX02
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K61
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K62
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K63
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K64
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K65
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K68
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K69
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K70
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K726
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-K728
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-KF35
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-KF38
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-KJ11
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-KJ16
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-KJ18
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-KW02
Freddie Mac Multifamily Mortgage Pass-Through Certificates Series 2017-KW03
GS Mortgage Securities Corporation II Series 2014-GC20
GS Mortgage Securities Corporation II Series 2014-GC24
GS Mortgage Securities Corporation II Series 2014-GC30
GS Mortgage Securities Corporation II Series 2015-GC20
GS Mortgage Securities Corporation II Series 2016-GS4
GS Mortgage Securities Trust Series 2013-GCJ12
GS Mortgage Securities Trust Series 2014-GC26
GS Mortgage Securities Trust Series 2015-GC28
GS Mortgage Securities Trust Series 2015-GC30
GS Mortgage Securities Trust Series 2015-GC34
JP Morgan Chase Commercial Mortgage Securities Corp. Series 2011-K10
JP Morgan Chase Commercial Mortgage Securities Corp. Series 2012-K18
JP Morgan Chase Commercial Mortgage Securities Corp. Series 2013-K32
JPMBB Commercial Mortgage Securities Trust Series 2013-C15
JPMBB Commercial Mortgage Securities Trust Series 2013-C17
JPMBB Commercial Mortgage Securities Trust Series 2014-C18
JPMBB Commercial Mortgage Securities Trust Series 2014-C23
JPMBB Commercial Mortgage Securities Trust Series 2014-C25
JPMBB Commercial Mortgage Securities Trust Series 2015-C28
JPMBB Commercial Mortgage Securities Trust Series 2015-C30
JPMBB Commercial Mortgage Securities Trust Series 2015-C33
JPMCC Commercial Mortgage Securities Trust Series 2017-JP5
JPMCC Commercial Mortgage Securities Trust Series 2017-JP7
JPMDB Commercial Mortgage Securities Trust Series 2017-C5
JPMDB Commercial Mortgage Securities Trust Series 2017-C7
Morgan Stanley Bank of America Merrill Lynch Trust Series 2013-C11
Morgan Stanley Bank of America Merrill Lynch Trust Series 2014-C16
Morgan Stanley Bank of America Merrill Lynch Trust Series 2014-C17
Morgan Stanley Bank of America Merrill Lynch Trust Series 2014-C18
Morgan Stanley Bank of America Merrill Lynch Trust Series 2014-C19
Morgan Stanley Bank of America Merrill Lynch Trust Series 2015-C20
Morgan Stanley Bank of America Merrill Lynch Trust Series 2015-C21
Morgan Stanley Bank of America Merrill Lynch Trust Series 2015-C22
Morgan Stanley Bank of America Merrill Lynch Trust Series 2015-C24
Morgan Stanley Bank of America Merrill Lynch Trust Series 2015-C25
Morgan Stanley Bank of America Merrill Lynch Trust Series 2015-C27
Morgan Stanley Bank of America Merrill Lynch Trust Series 2016-C31
Morgan Stanley Bank of America Merrill Lynch Trust Series 2016-C32
Morgan Stanley Capital I Commercial Mortgage Series 2017-BNK8
Morgan Stanley Capital I Inc. Series 2012-K20
Morgan Stanley Capital I Trust Series 2015-MS1
Morgan Stanley Capital I Trust Series 2017-H1
UBS-Barclays Commercial Mortgage Trust Series 2013-C6
UBS Commercial Mortgage Trust 2017-C4
UBS Commercial Mortgage Trust 2017-C5
Wells Fargo Commercial Mortgage Securities, Inc. Series 2011-K12
Wells Fargo Commercial Mortgage Securities, Inc. Series 2011-K703
Wells Fargo Commercial Mortgage Securities, Inc. Series 2013-K24
Wells Fargo Commercial Mortgage Securities, Inc. Series 2013-K26
Wells Fargo Commercial Mortgage Securities, Inc. Series 2013-K29
Wells Fargo Commercial Mortgage Securities, Inc. Series 2013-K34
Wells Fargo Commercial Mortgage Securities, Inc. Series 2013-KF02
Wells Fargo Commercial Mortgage Trust Series 2013-LC12
Wells Fargo Commercial Mortgage Trust Series 2014-LC18
Wells Fargo Commercial Mortgage Trust Series 2015-C29
Wells Fargo Commercial Mortgage Trust Series 2015-C31
Wells Fargo Commercial Mortgage Trust Series 2015-NXS1
Wells Fargo Commercial Mortgage Trust Series 2016-C32
Wells Fargo Commercial Mortgage Trust Series 2016-C33
Wells Fargo Commercial Mortgage Trust Series 2016-C34
Wells Fargo Commercial Mortgage Trust Series 2016-C35
Wells Fargo Commercial Mortgage Trust Series 2016-C36
Wells Fargo Commercial Mortgage Trust Series 2016-C37
Wells Fargo Commercial Mortgage Trust Series 2016-LC24
Wells Fargo Commercial Mortgage Trust Series 2017-C38
Wells Fargo Commercial Mortgage Trust Series 2017-C39
Wells Fargo Commercial Mortgage Trust Series 2017-C40
Wells Fargo Commercial Mortgage Trust Series 2017-C41
Wells Fargo Commercial Mortgage Trust Series 2017-C42
Wells Fargo Commercial Mortgage Trust Series 2017-RC1
WFRBS Commercial Mortgage Trust Series 2012-C10
WFRBS Commercial Mortgage Trust Series 2013-C15
WFRBS Commercial Mortgage Trust Series 2014-C21
WFRBS Commercial Mortgage Trust Series 2014-C24
APPENDIX B
APPLICABLE SERVICING CRITERIA WITH RESPECT TO THE PLATFORM
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REFERENCE |
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SERVICING CRITERIA |
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APPLICABLE SERVICING CRITERIA |
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INAPPLICABLE SERVICING CRITERIA |
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General Servicing Considerations |
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1122(d)(1)(i) |
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Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements. |
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X |
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1122(d)(1)(ii) |
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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. |
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X |
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1122(d)(1)(iii) |
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Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained. |
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X |
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1122(d)(1)(iv) |
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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. |
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X |
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1122(d)(1)(v) |
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Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information. |
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X |
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Cash Collection and Administration |
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1122(d)(2)(i) |
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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. |
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X |
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1122(d)(2)(ii) |
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Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel. |
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X |
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1122(d)(2)(iii) |
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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. |
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X |
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1122(d)(2)(iv) |
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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. |
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X |
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1122(d)(2)(v) |
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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 240.13k-1(b)(1) of the Securities Exchange Act. |
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X |
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1122(d)(2)(vi) |
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Unissued checks are safeguarded so as to prevent unauthorized access. |
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X |
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1122(d)(2)(vii) |
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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. |
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X |
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Investor Remittances and Reporting |
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1122(d)(3)(i) |
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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: |
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(A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; |
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X |
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(B) provide information calculated in accordance with the terms specified in the transaction agreements; |
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X |
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(C) are filed with the Commission as required by its rules and regulations; and |
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X |
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(D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pledged assets serviced by the Servicer. |
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X |
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1122(d)(3)(ii) |
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Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements. |
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X |
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1122(d)(3)(iii) |
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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. |
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X |
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1122(d)(3)(iv) |
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Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements. |
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X |
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Pool Asset Administration |
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1122(d)(4)(i) |
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Collateral or security on pool assets is maintained as required by the transaction agreements or related documents. |
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X |
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1122(d)(4)(ii) |
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Pool assets and related documents are safeguarded as required by the transaction agreements. |
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X(1) |
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1122(d)(4)(iii) |
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Any additions, removals or substitutions to the pool asset are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements. |
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X |
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1122(d)(4)(iv) |
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Payments on pool assets, including any 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. |
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X |
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1122(d)(4)(v) |
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The Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance. |
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X |
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1122(d)(4)(vi) |
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Changes with respect to the terms or status of an obligor’s pool asset (e.g. loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related asset documents. |
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X |
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1122(d)(4)(vii) |
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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. |
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X |
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1122(d)(4)(viii) |
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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 assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment). |
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X(1) |
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1122(d)(4)(ix) |
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Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents. |
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X |
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1122(d)(4)(x) |
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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 asset, or such other number of days specified in the transaction agreements. |
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X |
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1122(d)(4)(xi) |
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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. |
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X |
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1122(d)(4)(xii) |
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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. |
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X(1) |
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1122(d)(4)(xiii) |
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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. |
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X |
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1122(d)(4)(xiv) |
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Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements. |
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X(1) |
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1122(d)(4)(xv) |
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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. |
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X |
(1) There were no activities performed during the year ended December 31, 2017 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.