/s/ Glen Peters

Glen Peters

Chief Financial Officer

Regulation AB Criteria

JPMCC 2018-MINN

COMM 2012-CCRE2

GSMS 2018-TWR

AHT 2018 Keys

Bancorp 2018-CRE3

Bancorp 2018-CRE4

GSMS 2018-GS10

JPMC 2018-MBR MZ

CSMC 2017-PFHP

CPLV TRUST 2017-VICI

MSC 2017-ASHF

Section

Description

Criteria

General Servicing Considerations

(d)(1)(i)

Policies and
Procedures

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreement.

X

X

X

X

X

X

X

X

X

X

X

(d)(1)(ii)

Policies and
Procedures
(vendors)

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.

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

(d)(1)(iii)

Back-up Servicer

Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(1)(iv)

Fidelity Bond

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 agreement.

X

X

X

X

X

X

X

X

X

X

X

(d)(1)(v)

Accuracy of
Information

Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

Cash Collection and Administration

(d)(2)(i)

2 Days to deposit
Payments into
Custodial Accounts

Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of days specified in the transaction agreements.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(2)(ii)

Wire Transfers

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(2)(iii)

Advances

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.

X²

X¹

X²

X²

X²

X²

X¹

X²

X²

X²

X²

(d)(2)(iv)

Commingling

The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

Regulation AB Criteria

JPMCC 2018-MINN

COMM 2012-CCRE2

GSMS 2018-TWR

AHT 2018 Keys

Bancorp 2018-CRE3

Bancorp 2018-CRE4

GSMS 2018-GS10

JPMC 2018-MBR MZ

CSMC 2017-PFHP

CPLV TRUST 2017-VICI

MSC 2017-ASHF

Section

Description

Criteria

(d)(2)(v)

Federally Insured
Institution

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 this chapter. I.3 Each custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(2)(vi)

Unissued Checks

Unissued checks are safeguarded so as to prevent unauthorized access.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(2)(vii)

Reconciliations

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: (a) are mathematically accurate; (b) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (c) are 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.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

Investor Remittance and Reporting

(d)(3)(i)

Reports to the
Investor

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(3)(ii)

Investor Remittance

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(3)(iii)

Investor's Records

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Regulation AB Criteria

JPMCC 2018-MINN

COMM 2012-CCRE2

GSMS 2018-TWR

AHT 2018 Keys

Bancorp 2018-CRE3

Bancorp 2018-CRE4

GSMS 2018-GS10

JPMC 2018-MBR MZ

CSMC 2017-PFHP

CPLV TRUST 2017-VICI

MSC 2017-ASHF

Section

Description

Criteria

(d)(3)(iv)

Remittance and
Bank Statements

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Pool Asset Administration

(d)(4)(i)

Collateral/Security on Pool Assets

Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(4)(ii)

Safeguard Pool
Assets

Pool assets and related documents are safeguarded as required by the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(iii)

Changes to the Pool Assets

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.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(4)(iv)

Obligor's Payment Record

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(v)

Pool Asset Records Match UPB

The servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid principal balance.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(vi)

Loan Modifications

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 pool asset documents.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(4)(vii)

Loss Mitigation
Actions

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 agreement.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(4)(viii)

Collection Efforts
Documented

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).

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

Regulation AB Criteria

JPMCC 2018-MINN

COMM 2012-CCRE2

GSMS 2018-TWR

AHT 2018 Keys

Bancorp 2018-CRE3

Bancorp 2018-CRE4

GSMS 2018-GS10

JPMC 2018-MBR MZ

CSMC 2017-PFHP

CPLV TRUST 2017-VICI

MSC 2017-ASHF

Section

Description

Criteria

(d)(4)(ix)

ARMs

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(x)

Escrow Funds

Regarding any funds held in trust for an obligor such funds are (a) 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)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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xi)

Timely Payments

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xii)

Late Payment
Penalties

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xiii)

Obligor's Records

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xiv)

Delinquencies,
Charge-offs, and
Other Uncollectible

Delinquencies, Charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xv)

Any External
Enhancement

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Regulation AB Criteria

VSD 2017-PLT1

RPT 2017-ROSS

Bancorp 2017-CRE2

CGMS 2017 MDDR

COLD 2017-ICE3

2016-225L

BANCORP 2016-CRE1

GSMS 2016-GS3

CGBAM 2015-SMRT MZ

Lone Star 2015 LSP-MZ

WFCG 2015-BXRP

Section

Description

Criteria

General Servicing Considerations

(d)(1)(i)

Policies and
Procedures

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreement.

X

X

X

X

X

X

X

X

X

X

X

(d)(1)(ii)

Policies and
Procedures
(vendors)

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.

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

(d)(1)(iii)

Back-up Servicer

Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(1)(iv)

Fidelity Bond

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 agreement.

X

X

X

X

X

X

X

X

X

X

X

(d)(1)(v)

Accuracy of
Information

Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.

X¹⁰

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

Cash Collection and Administration

(d)(2)(i)

2 Days to deposit
Payments into
Custodial Accounts

Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of days specified in the transaction agreements.

X²

X¹

X¹

X¹

X¹

X¹

X³

X¹

X¹

X¹

X¹

(d)(2)(ii)

Wire Transfers

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(2)(iii)

Advances

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.

X²

X²

X²

X²

X²

X²

X²

X¹

X²

X²

X²

(d)(2)(iv)

Commingling

The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.

X²

X¹

X¹

X¹

X¹

X¹

X⁵

X¹

X¹

X¹

X¹

Regulation AB Criteria

VSD 2017-PLT1

RPT 2017-ROSS

Bancorp 2017-CRE2

CGMS 2017 MDDR

COLD 2017-ICE3

2016-225L

BANCORP 2016-CRE1

GSMS 2016-GS3

CGBAM 2015-SMRT MZ

Lone Star 2015 LSP-MZ

WFCG 2015-BXRP

Section

Description

Criteria

(d)(2)(v)

Federally Insured
Institution

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 this chapter. I.3 Each custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor.

X²

X¹

X¹

X¹

X¹

X¹

X⁵

X¹

X¹

X¹

X¹

(d)(2)(vi)

Unissued Checks

Unissued checks are safeguarded so as to prevent unauthorized access.

X²

X¹

X¹

X¹

X¹

X¹

X

X¹

X¹

X¹

X¹

(d)(2)(vii)

Reconciliations

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: (a) are mathematically accurate; (b) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (c) are 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.

X²

X¹

X¹

X¹

X¹

X¹

X⁵

X¹

X¹

X¹

X¹

Investor Remittance and Reporting

(d)(3)(i)

Reports to the
Investor

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(3)(ii)

Investor Remittance

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(3)(iii)

Investor's Records

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Regulation AB Criteria

VSD 2017-PLT1

RPT 2017-ROSS

Bancorp 2017-CRE2

CGMS 2017 MDDR

COLD 2017-ICE3

2016-225L

BANCORP 2016-CRE1

GSMS 2016-GS3

CGBAM 2015-SMRT MZ

Lone Star 2015 LSP-MZ

WFCG 2015-BXRP

Section

Description

Criteria

(d)(3)(iv)

Remittance and
Bank Statements

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Pool Asset Administration

(d)(4)(i)

Collateral/Security on Pool Assets

Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.

X²

X¹

X¹

X¹

X¹

X¹

X⁶

X¹

X¹

X¹

X¹

(d)(4)(ii)

Safeguard Pool
Assets

Pool assets and related documents are safeguarded as required by the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(iii)

Changes to the Pool Assets

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.

X²

X¹

X¹

X¹

X¹

X¹

X⁸

X¹

X¹

X¹

X¹

(d)(4)(iv)

Obligor's Payment Record

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(v)

Pool Asset Records Match UPB

The servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid principal balance.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(vi)

Loan Modifications

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 pool asset documents.

X⁹

X¹

X¹

X¹

X¹

X¹

X

X¹

X¹

X¹

X¹

(d)(4)(vii)

Loss Mitigation
Actions

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 agreement.

X

X¹

X¹

X¹

X¹

X¹

X

X¹

X¹

X¹

X¹

Regulation AB Criteria

VSD 2017-PLT1

RPT 2017-ROSS

Bancorp 2017-CRE2

CGMS 2017 MDDR

COLD 2017-ICE3

2016-225L

BANCORP 2016-CRE1

GSMS 2016-GS3

CGBAM 2015-SMRT MZ

Lone Star 2015 LSP-MZ

WFCG 2015-BXRP

Section

Description

Criteria

(d)(4)(viii)

Collection Efforts
Documented

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

X¹

X¹

X¹

X¹

X¹

X

X¹

X¹

X¹

X¹

(d)(4)(ix)

ARMs

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(x)

Escrow Funds

Regarding any funds held in trust for an obligor such funds are (a) 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)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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xi)

Timely Payments

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xii)

Late Payment
Penalties

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xiii)

Obligor's Records

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xiv)

Delinquencies,
Charge-offs, and
Other Uncollectible
Accounts

Delinquencies, Charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xv)

Any External
Enhancement

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Regulation AB Criteria

CF TRUST 19 BOSS

BANCORP 2019-CRES

BBCMS 2019-CLP

BBCMS 2019-Core

BCMARK 2019-B12

BX 2019-MMP

CAMB 2019-LIFE

CF2019-CFI

MTRO 2019-TECH

NOHT 2019-HNLA

NYT 2019-NYT

Section

Description

Criteria

General Servicing Considerations

(d)(1)(i)

Policies and
Procedures

Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreement.

X

X

X

X

X

X

X

X

X

X

X

(d)(1)(ii)

Policies and
Procedures
(vendors)

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.

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

X⁷

(d)(1)(iii)

Back-up Servicer

Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(1)(iv)

Fidelity Bond

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 agreement.

X

X

X

X

X

X

X

X

X

X

X

(d)(1)(v)

Accuracy of
Information

Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

X⁴

Cash Collection and Administration

(d)(2)(i)

2 Days to deposit
Payments into
Custodial Accounts

Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of days specified in the transaction agreements.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(2)(ii)

Wire Transfers

Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(2)(iii)

Advances

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.

X¹

X²

X²

X²

X²

X²

X²

X¹

X²

X²

X²

(d)(2)(iv)

Commingling

The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

Regulation AB Criteria

CF TRUST 19 BOSS

BANCORP 2019-CRES

BBCMS 2019-CLP

BBCMS 2019-Core

BCMARK 2019-B12

BX 2019-MMP

CAMB 2019-LIFE

CF2019-CFI

MTRO 2019-TECH

NOHT 2019-HNLA

NYT 2019-NYT

Section

Description

Criteria

(d)(2)(v)

Federally Insured
Institution

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 this chapter. I.3 Each custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(2)(vi)

Unissued Checks

Unissued checks are safeguarded so as to prevent unauthorized access.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(2)(vii)

Reconciliations

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: (a) are mathematically accurate; (b) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (c) are 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.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

Investor Remittance and Reporting

(d)(3)(i)

Reports to the
Investor

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(3)(ii)

Investor Remittance

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(3)(iii)

Investor's Records

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Regulation AB Criteria

CF TRUST 19 BOSS

BANCORP 2019-CRES

BBCMS 2019-CLP

BBCMS 2019-Core

BCMARK 2019-B12

BX 2019-MMP

CAMB 2019-LIFE

CF2019-CFI

MTRO 2019-TECH

NOHT 2019-HNLA

NYT 2019-NYT

Section

Description

Criteria

(d)(3)(iv)

Remittance and
Bank Statements

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Pool Asset Administration

(d)(4)(i)

Collateral/Security on Pool Assets

Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(4)(ii)

Safeguard Pool
Assets

Pool assets and related documents are safeguarded as required by the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(iii)

Changes to the Pool Assets

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.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(4)(iv)

Obligor's Payment Record

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(v)

Pool Asset Records Match UPB

The servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid principal balance.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(vi)

Loan Modifications

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 pool asset documents.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(4)(vii)

Loss Mitigation
Actions

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 agreement.

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

Regulation AB Criteria

CF TRUST 19 BOSS

BANCORP 2019-CRES

BBCMS 2019-CLP

BBCMS 2019-Core

BCMARK 2019-B12

BX 2019-MMP

CAMB 2019-LIFE

CF2019-CFI

MTRO 2019-TECH

NOHT 2019-HNLA

NYT 2019-NYT

Section

Description

Criteria

(d)(4)(viii)

Collection Efforts
Documented

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).

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

X¹

(d)(4)(ix)

ARMs

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(x)

Escrow Funds

Regarding any funds held in trust for an obligor such funds are (a) 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)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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xi)

Timely Payments

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xii)

Late Payment
Penalties

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xiii)

Obligor's Records

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xiv)

Delinquencies,
Charge-offs, and
Other Uncollectible
Accounts

Delinquencies, Charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

(d)(4)(xv)

Any External
Enhancement

Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

X¹

This criteria is applicable for the securitization; however, there were no loans serviced under this securitization during the reporting period.

X²

With respect to Applicable Servicing Criteria, the securitization was not in scope based on the transaction agreement.

X³

With respect to item 1122(d)(2)(i), this criteria is applicable for the securitization; however, there was no cash collected for loans under the securitization during the reporting period.

X⁴

With respect to item 1122(d)(1)(v), this criteria is applicable for the securitization; however, there was no aggregation of information related to reporting to external parties.

X⁵

With respect to item 1122(d)(2)(iv), 1122(d)(2)(v) and 1122(d)(2)(vii), the criteria is applicable for the securitization; however, there were no custodial bank accounts maintained under the securitization during the reporting period.

X⁶

With respect to item 1122(d)(4)(i), the criteria is applicable for the securitization; however, as special servicer, Trimont was not responsible for maintaining collateral or security on pool assets under the securitization during the reporting period.

X⁷

With respect to item 1122(d)(1)(ii), this criteria is applicable for the securitization; however, there were no material servicing activities outsourced to third parties under this securitization during the reporting period.

X⁸

With respect to item 1122(d)(4)(iii), the criteria is applicable for the securitization; however, there were no additions, removals, or substitutions to the pool assets under the securitization during the reporting period.

X⁹

With respect to item 1122(d)(4)(vi), the criteria is applicable for the securitization; however, there were no changes to the terms or status of an obligor's pool assets under the securitization during the reporting period.

X¹⁰

With respect to item 1122(d)(1)(v), this criteria is applicable for the securitization; however, is only applicable in Trimont's role as primary servicer. As such, there was no aggregation of information related to reporting to external parties for this platform.

With respect to Applicable Servicing Criteria cells in Exhibit A that are denoted with an "N/A", per review of the respective servicing agreement, the criteria was not in scope for the transaction.

Name

Transaction

Period of Service

CGBAM 2015-SMRT MZ

Special Servicer for Commercial Mortgage Pass-Through Certificates Series 2014-TISH pursuant to the Pooling and Servicing Agreement dated April 28, 2015

January 1, 2019 - December 31, 2019

Lone Star 2015 LSP-MZ

Special Servicer for Commercial Mortgage Pass-Through Certificates Series Lone Star 2015 LSP-MZ pursuant to the Pooling and Servicing Agreement dated November 13, 2015

January 1, 2019 - December 31, 2019

WFCG 2015-BXRP

Special Servicer for Commercial Mortgage Pass-Through Certificates Series WFCG 2015-BXRP pursuant to the Pooling and Servicing Agreement dated April 1, 2015

January 1, 2019 - December 31, 2019

2016-225L

Special Servicer for Commercial Mortgage Pass-Through Certificates Series 2016-225L pursuant to the Pooling and Servicing Agreement dated February 6, 2016

January 1, 2019 - December 31, 2019

BANCORP 2016-CRE1

Special Servicer for Commercial Mortgage Pass-Through Certificates Series BANCORP 2016-CRE1 pursuant to the Pooling and Servicing Agreement dated December 6, 2016

January 1, 2019 - December 31, 2019

GSMS 2016-GS3

Special Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2016-GS3 pursuant to the Pooling and Servicing Agreement dated September 1, 2016

January 1, 2019 - December 31, 2019

Bancorp 2017-CRE2

Special Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2017-CRE2 pursuant to the Pooling and Servicing Agreement dated August 30, 2017

January 1, 2019 - December 31, 2019

CGMS 2017 MDDR

Special Servicer for Commercial Mortgage Pass-Through Certificates Series CGMS 2017 MDDR pursuant to the Pooling and Servicing Agreement dated July 6, 2017

January 1, 2019 - December 31, 2019

COLD 2017-ICE3

Special Servicer for Commercial Mortgage Pass-Through Certificates Series COLD 2017-ICE3 pursuant to the Pooling and Servicing Agreement dated April 28, 2017

January 1, 2019 - December 31, 2019

RPT 2017-ROSS

Special Servicer for Commercial Mortgage Pass-Through Certificates Series RPT 2017-ROSS pursuant to the Pooling and Servicing Agreement dated June 30, 2017

January 1, 2019 - December 31, 2019

CPLV TRUST 2017-VICI

Special Servicer for Commercial Mortgage Pass-Through Certificates Series CPLV 2017-VICI pursuant to the Pooling and Servicing Agreement dated November 30, 2017

January 1, 2019 - December 31, 2019

MSC 2017-ASHF

Special Servicer for Commercial Mortgage Pass-Through Certificates Series MSC 2017-ASHF pursuant to the Pooling and Servicing Agreement dated December 9, 2017

January 1, 2019 - December 31, 2019

CSMC 2017-PFHP

Special Servicer for Commercial Mortgage Pass-Through Certificates Series CSMC 2017-PFHP pursuant to the Pooling and Servicing Agreement dated December 19, 2017

January 1, 2019 - December 31, 2019

VSD 2017-PLT1

Special Servicer for Commercial Mortgage Pass-Through Certificates Series VSD 2017-PLT1 pursuant to the Pooling and Servicing Agreement dated March 10, 2017

January 1, 2019 - January 24, 2019

Name

Transaction

Period of Service

JPMC 2018-MBR MZ

Special Servicer for Commercial Mortgage Pass-Through Certificates Series JPMC 2018-MBR MZ pursuant to the Pooling and Servicing Agreement dated August 22, 2018

January 1, 2019 - December 31, 2019

GSMS 2018-GS10

Special Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-GS10 pursuant to the Pooling and Servicing Agreement dated July 1, 2018

January 1, 2019 - December 31, 2019

Bancorp 2018-CRE4

Special Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2018-CRE4 pursuant to the Pooling and Servicing Agreement dated September 27, 2018

January 1, 2019 - December 31, 2019

Bancorp 2018-CRE3

Special Servicer for Commercial Mortgage Pass-Through Certificates Series Bancorp 2018-CRE3 pursuant to the Pooling and Servicing Agreement dated March 29, 2018

January 1, 2019 - December 31, 2019

AHT 2018 Keys

Special Servicer for Commercial Mortgage Pass-Through Certificates Series AHT 2018 Keys pursuant to the Pooling and Servicing Agreement dated July 16, 2018

January 1, 2019 - December 31, 2019

GSMS 2018-TWR

Special Servicer for Commercial Mortgage Pass-Through Certificates Series GSMS 2018-TWR pursuant to the Pooling and Servicing Agreement dated July 31, 2018

January 1, 2019 - December 31, 2019

COMM 2012-CCRE2

Special Servicer for Commercial Mortgage Pass-Through Certificates Series COMM 2012-CCRE2 pursuant to the Pooling and Servicing Agreement dated August 1, 2018

January 1, 2019 - December 31, 2019

JPMCC 2018-MINN

Special Servicer for Commercial Mortgage Pass-Through Certificates Series JPMCC 2018-MINN pursuant to the Pooling and Servicing Agreement dated December 7, 2018

January 1, 2019 - December 31, 2019

CF TRUST 19 BOSS

Special Servicer for Commercial Mortgage Pass-Through Certificates Series CF-TRUST 19 BOSS pursuant to the Pooling and Servicing Agreement dated November 26, 2019

November 26, 2019 - December 31, 2019

BANCORP 2019-CRES

Special Servicer for Commercial Mortgage Pass-Through Certificates Series BANCORP 2019-CRES pursuant to the Pooling and Servicing Agreement dated March 28, 2019

March 28, 2019 - December 31, 2019

BBCMS 2019-CLP

Special Servicer for Commercial Mortgage Pass-Through Certificates Series BBCMS 2019-CLP pursuant to the Pooling and Servicing Agreement dated February 27, 2019

February 27, 2019 - December 31, 2019

BBCMS 2019-Core

Special Servicer for Commercial Mortgage Pass-Through Certificates Series BBCMS 2019-Core pursuant to the Pooling and Servicing Agreement dated March 15, 2019

March 15, 2019 - December 31, 2019

BCMARK 2019-B12

Special Servicer for Commercial Mortgage Pass-Through Certificates Series BCMARK 2019-B12 pursuant to the Pooling and Servicing Agreement dated August 1, 2019

August 1, 2019 - December 31, 2019

BX 2019-MMP

Special Servicer for Commercial Mortgage Pass-Through Certificates Series BX 2019-MMP pursuant to the Pooling and Servicing Agreement dated August 29, 2019

August 29, 2019 - December 31, 2019

CAMB 2019-LIFE

Special Servicer for Commercial Mortgage Pass-Through Certificates Series CAMB 2019-LIFE pursuant to the Pooling and Servicing Agreement dated January 9, 2019

January 9, 2019 - December 31, 2019

CF 2019- CFI

Special Servicer for Commercial Mortgage Pass-Through Certificates Series CF 2019-CFI pursuant to the Pooling and Servicing Agreement dated April 1, 2019

April 1, 2019 - December 31, 2019

MTRO 2019-TECH

Special Servicer for Commercial Mortgage Pass-Through Certificates Series MTRO 2019-TECH pursuant to the Pooling and Servicing Agreement dated February 9, 2019

February 9, 2019 - December 31, 2019

Name

Transaction

Period of Service

NOHT 2019-HNLA

Special Servicer for Commercial Mortgage Pass-Through Certificates Series NOHT 2019-HNLA pursuant to the Pooling and Servicing Agreement dated May 15, 2019

May 15, 2019 - December 31, 2019

NYT 2019-NYT

Special Servicer for Commercial Mortgage Pass-Through Certificates Series NYT 2019-NYT pursuant to the Pooling and Servicing Agreement dated January 30, 2019

January 30,, 2019 - December 31, 2019