Attached files

file filename
EX-35.10 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_35-10.htm
EX-35.9 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_35-9.htm
EX-35.7 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_35-7.htm
EX-35.3 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_35-3.htm
EX-35.2 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_35-2.htm
EX-35.1 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_35-1.htm
EX-35.57 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-57.htm
EX-34.46 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-46.htm
EX-34.36 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-36.htm
EX-34.31 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-31.htm
EX-34.30 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-30.htm
EX-34.24 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-24.htm
EX-34.20 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-20.htm
EX-34.17 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-17.htm
EX-34.8 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-8.htm
EX-34.7 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-7.htm
EX-34.6 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-6.htm
EX-34.5 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-5.htm
EX-34.4 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-4.htm
EX-34.2 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-2.htm
EX-34.1 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_34-1.htm
EX-33.57 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-57.htm
EX-33.46 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-46.htm
EX-33.36 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-36.htm
EX-33.31 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-31.htm
EX-33.30 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-30.htm
EX-33.24 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-24.htm
EX-33.20 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-20.htm
EX-33.17 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-17.htm
EX-33.8 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-8.htm
EX-33.7 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-7.htm
EX-33.5 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-5.htm
EX-33.4 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-4.htm
EX-33.2 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-2.htm
EX-33.1 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-1.htm
EX-31 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_31.htm
10-K - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_10k-2019.htm

 

 

(logo) PARK BRIDGE LENDER SERVICES LLC

 

 

February 21, 2020

 

RE:          Management’s Report on Assessment of 2019 Compliance by

Park Bridge Lender Services LLC with Regulation AB Servicing Criteria

 

 

Park Bridge Lender Services LLC (the “Asserting Party”) is responsible for assessing its compliance, as of and for the period ended December 31, 2019, with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations.

 

The transactions covered by this assertion are those transactions processed by the Asserting Party in its capacity as trust advisor or operating advisor for the asset-backed securities transactions listed in Exhibit A attached hereto (the “Platform”).

 

The Asserting Party is responsible for assessing its compliance with the servicing criteria applicable to it. The Asserting Party used the criteria in paragraph (d) of Item 1122 of Regulation AB (17 C.F.R. 229.1122) to assess its compliance. The full outline of the Asserting Party’s contractually applicable servicing criteria under various securitization pooling and servicing agreements can be found in Exhibit B attached hereto.

 

Based on its assessment, the Asserting Party believes that, as of and for the periods the contractual obligations existed in the calendar year ending December 31, 2019, the Asserting Party has complied in all material respects with the servicing criteria set forth in Item 1122(d) of Regulation AB relating to its trust or operating advisor role with respect to the Platform, except for the servicing criteria set forth in 1122(d)(1)(i-v), 1122(d)(2)(i-vii), 1122(d)(3)(ii-iv), 1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv), which the Asserting Party has determined as being inapplicable to the activities it performs with respect to the Platform (the “Applicable Servicing Criteria”).

 

Gettry Marcus CPA, P.C., an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Applicable Servicing Criteria for the reporting period as set forth in this assertion.

 

 

Signed:

 

/s/ David M. Rodgers

David M. Rodgers

Principal

 

600 THIRD AVENUE, 40TH FLOOR, NEW YORK, NY 10016

WWW.PARKBRIDGEFINANCIAL.COM

 

 

Exhibit A

         

Asserting Party's 2019 Servicing Platform

         
   

Applicable Certification Period

Securitization Transaction

Start Date

 

End Date

AVMT 2018-AVM

 

January 01, 2019

to

December 31, 2019

BACM 2016-UBS10

 

January 01, 2019

to

December 31, 2019

BACM 2017-BNK3

 

January 01, 2019

to

December 31, 2019

BANK 2017-BNK5

 

January 01, 2019

to

December 31, 2019

BANK 2017-BNK6

 

January 01, 2019

to

December 31, 2019

BANK 2017-BNK8

 

January 01, 2019

to

December 31, 2019

BANK 2017-BNK9

 

January 01, 2019

to

December 31, 2019

BANK 2018-BNK11

 

January 01, 2019

to

December 31, 2019

BANK 2018-BNK12

 

January 01, 2019

to

December 31, 2019

BANK 2018-BNK14

 

January 01, 2019

to

December 31, 2019

BANK 2018-BNK15

 

January 01, 2019

to

December 31, 2019

BBCMS 2017-C1

 

January 01, 2019

to

December 31, 2019

BBCMS 2018-C2

 

January 01, 2019

to

December 31, 2019

BMARK 2018-B1

 

January 01, 2019

to

December 31, 2019

BMARK 2018-B3

 

January 01, 2019

to

December 31, 2019

BMARK 2018-B4

 

January 01, 2019

to

December 31, 2019

BMARK 2018-B6

 

January 01, 2019

to

December 31, 2019

BMARK 2018-B7

 

January 01, 2019

to

December 31, 2019

CCUBS 2017-C1

 

January 01, 2019

to

December 31, 2019

CD 2016-CD1

 

January 01, 2019

to

December 31, 2019

CD 2016-CD2

 

January 01, 2019

to

December 31, 2019

CD 2017-CD3

 

January 01, 2019

to

December 31, 2019

CD 2017-CD4

 

January 01, 2019

to

December 31, 2019

CD 2017-CD5

 

January 01, 2019

to

December 31, 2019

CD 2017-CD6

 

January 01, 2019

to

December 31, 2019

CD 2018-CD7

 

January 01, 2019

to

December 31, 2019

CFCRE 2016-C3

 

January 01, 2019

to

December 31, 2019

CFCRE 2016-C4

 

January 01, 2019

to

December 31, 2019

CFCRE 2016-C6

 

January 01, 2019

to

December 31, 2019

CFCRE 2016-C7

 

January 01, 2019

to

December 31, 2019

CFCRE 2017-C8

 

January 01, 2019

to

December 31, 2019

CGCMT 2014-GC21

 

January 01, 2019

to

December 31, 2019

CGCMT 2014-GC25

 

January 01, 2019

to

December 31, 2019

CGCMT 2015-GC27

 

January 01, 2019

to

December 31, 2019

CGCMT 2015-GC35

 

January 01, 2019

to

December 31, 2019

CGCMT 2015-P1

 

January 01, 2019

to

December 31, 2019

CGCMT 2016-C1

 

January 01, 2019

to

December 31, 2019

CGCMT 2016-GC37

 

January 01, 2019

to

December 31, 2019

CGCMT 2016-P3

 

January 01, 2019

to

December 31, 2019

CGCMT 2016-P4

 

January 01, 2019

to

December 31, 2019

CGCMT 2016-P5

 

January 01, 2019

to

December 31, 2019

CGCMT 2016-P6

 

January 01, 2019

to

December 31, 2019

CGCMT 2017-C4

 

January 01, 2019

to

December 31, 2019

CGCMT 2017-P7

 

January 01, 2019

to

December 31, 2019

CGCMT 2018-B2

 

January 01, 2019

to

December 31, 2019

CGCMT 2018-C6

 

January 01, 2019

to

December 31, 2019

COMM 2012-CCRE2

 

January 01, 2019

to

December 31, 2019

COMM 2012-CCRE4

 

January 01, 2019

to

December 31, 2019

COMM 2012-CCRE5

 

January 01, 2019

to

December 31, 2019

COMM 2012-LC4

 

January 01, 2019

to

December 31, 2019

COMM 2013-CCRE10

 

January 01, 2019

to

December 31, 2019

COMM 2013-CCRE11

 

January 01, 2019

to

December 31, 2019

COMM 2013-CCRE12

 

January 01, 2019

to

December 31, 2019

COMM 2013-CCRE6

 

January 01, 2019

to

December 31, 2019

COMM 2013-CCRE7

 

January 01, 2019

to

December 31, 2019

COMM 2013-CCRE8

 

January 01, 2019

to

December 31, 2019

COMM 2013-CCRE9

 

January 01, 2019

to

December 31, 2019

COMM 2013-LC13

 

January 01, 2019

to

December 31, 2019

COMM 2013-LC6

 

January 01, 2019

to

December 31, 2019

COMM 2014-CCRE14

 

January 01, 2019

to

December 31, 2019

COMM 2014-CCRE15

 

January 01, 2019

to

December 31, 2019

COMM 2014-CCRE16

 

January 01, 2019

to

December 31, 2019

COMM 2014-CCRE17

 

January 01, 2019

to

December 31, 2019

COMM 2014-CCRE19

 

January 01, 2019

to

December 31, 2019

COMM 2014-CCRE20

 

January 01, 2019

to

December 31, 2019

COMM 2014-CCRE21

 

January 01, 2019

to

December 31, 2019

COMM 2014-LC17

 

January 01, 2019

to

December 31, 2019

COMM 2014-UBS2

 

January 01, 2019

to

December 31, 2019

COMM 2014-UBS3

 

January 01, 2019

to

December 31, 2019

COMM 2014-UBS4

 

January 01, 2019

to

December 31, 2019

COMM 2015-CCRE22

 

January 01, 2019

to

December 31, 2019

COMM 2015-CCRE24

 

January 01, 2019

to

December 31, 2019

COMM 2015-CCRE26

 

January 01, 2019

to

December 31, 2019

COMM 2015-CCRE27

 

January 01, 2019

to

December 31, 2019

COMM 2015-DC1

 

January 01, 2019

to

December 31, 2019

COMM 2015-LC19

 

January 01, 2019

to

December 31, 2019

COMM 2015-LC21

 

January 01, 2019

to

December 31, 2019

COMM 2015-LC23

 

January 01, 2019

to

December 31, 2019

COMM 2015-PC1

 

January 01, 2019

to

December 31, 2019

COMM 2016-667M

 

January 01, 2019

to

December 31, 2019

COMM 2016-CCRE28

 

January 01, 2019

to

December 31, 2019

COMM 2016-COR1

 

January 01, 2019

to

December 31, 2019

COMM 2016-DC2

 

January 01, 2019

to

December 31, 2019

COMM 2017-COR2

 

January 01, 2019

to

December 31, 2019

COMM 2018-COR3

 

January 01, 2019

to

December 31, 2019

COMM 2018-HOME

 

January 01, 2019

to

December 31, 2019

CSAIL 2015-C1

 

January 01, 2019

to

December 31, 2019

CSAIL 2015-C2

 

January 01, 2019

to

December 31, 2019

CSAIL 2016-C6

 

January 01, 2019

to

December 31, 2019

CSAIL 2016-C7

 

January 01, 2019

to

December 31, 2019

CSAIL 2017-C8

 

January 01, 2019

to

December 31, 2019

CSAIL 2017-CX10

 

January 01, 2019

to

December 31, 2019

CSAIL 2018-CX11

 

January 01, 2019

to

December 31, 2019

CSAIL 2018-CX12

 

January 01, 2019

to

December 31, 2019

CSMC 2016-NXSR

 

January 01, 2019

to

December 31, 2019

CSMC 2017-CALI

 

January 01, 2019

to

December 31, 2019

CSMC 2017-MOON

 

January 01, 2019

to

December 31, 2019

DAFC 2017-AMO

 

January 01, 2019

to

December 31, 2019

DBGS 2018-C1

 

January 01, 2019

to

December 31, 2019

DBJPM 2016-C1

 

January 01, 2019

to

December 31, 2019

DBJPM 2016-C3

 

January 01, 2019

to

December 31, 2019

DBUBS 2017-BRBK

 

January 01, 2019

to

December 31, 2019

GSMS 2014-GC18

 

January 01, 2019

to

December 31, 2019

GSMS 2015-GC32

 

January 01, 2019

to

December 31, 2019

GSMS 2016-GS4

 

January 01, 2019

to

December 31, 2019

GSMS 2017-GS7

 

January 01, 2019

to

December 31, 2019

GSMS 2018-GS10

 

January 01, 2019

to

December 31, 2019

JPMCC 2013-C10

 

January 01, 2019

to

December 31, 2019

JPMCC 2018-AON

 

January 01, 2019

to

December 31, 2019

JPMCC 2018-BCON

 

January 01, 2019

to

December 31, 2019

JPMCC 2018-PTC

 

January 01, 2019

to

December 31, 2019

JPMCC 2018-WPT

 

January 01, 2019

to

December 31, 2019

JPMDB 2017-C5

 

January 01, 2019

to

December 31, 2019

LCCM 2017-LC26

 

January 01, 2019

to

December 31, 2019

MSBAM 2013-C10

 

January 01, 2019

to

December 31, 2019

MSBAM 2014-C14

 

January 01, 2019

to

December 31, 2019

MSBAM 2014-C18

 

January 01, 2019

to

December 31, 2019

MSBAM 2014-C19

 

January 01, 2019

to

December 31, 2019

MSBAM 2015-C20

 

January 01, 2019

to

December 31, 2019

MSBAM 2015-C22

 

January 01, 2019

to

December 31, 2019

MSBAM 2015-C24

 

January 01, 2019

to

December 31, 2019

MSBAM 2015-C26

 

January 01, 2019

to

December 31, 2019

MSBAM 2016-C28

 

January 01, 2019

to

December 31, 2019

MSBAM 2016-C29

 

January 01, 2019

to

December 31, 2019

MSBAM 2016-C30

 

January 01, 2019

to

December 31, 2019

MSBAM 2016-C31

 

January 01, 2019

to

December 31, 2019

MSBAM 2016-C32

 

January 01, 2019

to

December 31, 2019

MSBAM 2017-C33

 

January 01, 2019

to

December 31, 2019

MSBAM 2017-C34

 

January 01, 2019

to

December 31, 2019

MSC 2015-MS1

 

January 01, 2019

to

December 31, 2019

MSC 2016-BNK2

 

January 01, 2019

to

December 31, 2019

MSC 2016-UBS12

 

January 01, 2019

to

December 31, 2019

MSC 2017-HR2

 

January 01, 2019

to

December 31, 2019

MSC 2018-H3

 

January 01, 2019

to

December 31, 2019

MSC 2018-H4

 

January 01, 2019

to

December 31, 2019

MSCI 2016-UBS11

 

January 01, 2019

to

December 31, 2019

MSCI 2016-UBS9

 

January 01, 2019

to

December 31, 2019

MSSG 2017-237P

 

January 01, 2019

to

December 31, 2019

SGCMS 2016-C5

 

January 01, 2019

to

December 31, 2019

UBS 2017-C2

 

January 01, 2019

to

December 31, 2019

UBS 2017-C3

 

January 01, 2019

to

December 31, 2019

UBS 2017-C5

 

January 01, 2019

to

December 31, 2019

UBS 2018-C10

 

January 01, 2019

to

December 31, 2019

UBS 2018-C12

 

January 01, 2019

to

December 31, 2019

UBS 2018-C14

 

January 01, 2019

to

December 31, 2019

UBS 2018-C8

 

January 01, 2019

to

December 31, 2019

UBS-B 2012-C3

 

January 01, 2019

to

December 31, 2019

UBSBB 2013-C6

 

January 01, 2019

to

December 31, 2019

WFCM 2013-LC12

 

January 01, 2019

to

December 31, 2019

WFCM 2014-LC18

 

January 01, 2019

to

December 31, 2019

WFCM 2015-LC22

 

January 01, 2019

to

December 31, 2019

WFCM 2016-BNK1

 

January 01, 2019

to

December 31, 2019

WFCM 2016-C33

 

January 01, 2019

to

December 31, 2019

WFCM 2016-C36

 

January 01, 2019

to

December 31, 2019

WFCM 2016-NXS5

 

January 01, 2019

to

December 31, 2019

WFCM 2017-C38

 

January 01, 2019

to

December 31, 2019

WFCM 2017-C42

 

January 01, 2019

to

December 31, 2019

WFCM 2018-C43

 

January 01, 2019

to

December 31, 2019

WFCM 2018-C45

 

January 01, 2019

to

December 31, 2019

WFCM 2018-C47

 

January 01, 2019

to

December 31, 2019

WFRBS 2013-UBS1

 

January 01, 2019

to

December 31, 2019

WPT 2017-WWP

 

January 01, 2019

to

December 31, 2019

BMARK 2019-B9

 

February 14, 2019

to

December 31, 2019

BANK 2019-BNK16

 

February 21, 2019

to

December 31, 2019

CSAIL 2019-C15

 

March 06, 2019

to

December 31, 2019

ILPT 2019-SURF

 

March 07, 2019

to

December 31, 2019

UBS 2019-C16

 

April 16, 2019

to

December 31, 2019

JPMCC 2019-ICON

 

April 26, 2019

to

December 31, 2019

CF 2019-CF1

 

April 30, 2019

to

December 31, 2019

WFCM 2019-C50

 

May 14, 2019

to

December 31, 2019

GSMS 2019-GC39

 

May 23, 2019

to

December 31, 2019

JPMCC 2019-OSB

 

June 13, 2019

to

December 31, 2019

MSC 2019-H6

 

June 19, 2019

to

December 31, 2019

BANK 2019-BNK19

 

August 08, 2019

to

December 31, 2019

CGCMT 2019-GC41

 

August 20, 2019

to

December 31, 2019

CD 2019-CD8

 

August 22, 2019

to

December 31, 2019

BBCMS 2019-C4

 

August 28, 2019

to

December 31, 2019

CSAIL 2019-C17

 

September 25, 2019

to

December 31, 2019

BANK 2019-BNK20

 

September 26, 2019

to

December 31, 2019

GSMS 2019-GC42

 

September 27, 2019

to

December 31, 2019

CF 2019-CF2

 

October 17, 2019

to

December 31, 2019

BMARK 2019-B13

 

October 17, 2019

to

December 31, 2019

BANK 2019-BNK21

 

October 23, 2019

to

December 31, 2019

WFCM 2019-C53

 

November 07, 2019

to

December 31, 2019

GSMS 2019-GSA1

 

November 08, 2019

to

December 31, 2019

CGCMT 2019-GC43

 

November 13, 2019

to

December 31, 2019

MSC 2019-L3

 

November 21, 2019

to

December 31, 2019

WFCM 2019-C54

 

December 03, 2019

to

December 31, 2019

BANK 2019-BNK23

 

December 10, 2019

to

December 31, 2019

COMM 2019-GC44

 

December 12, 2019

to

December 31, 2019

BX 2019-OC11

 

December 12, 2019

to

December 31, 2019

BMARK 2019-B15

 

December 18, 2019

to

December 31, 2019

BANK 2019-BNK24

 

December 19, 2019

to

December 31, 2019

MRCD 2019-PARK

 

December 19, 2019

to

December 31, 2019

CSMC 2019-UVIL

 

December 19, 2019

to

December 31, 2019

CF 2019-CF3

 

December 20, 2019

to

December 31, 2019

UBS 2019-C18

 

December 20, 2019

to

December 31, 2019

COMM 2014-CCRE18

 

December 27, 2019

to

December 31, 2019

COMM 2014-LC15

 

December 27, 2019

to

December 31, 2019

COMM 2014-UBS5

 

December 27, 2019

to

December 31, 2019

GSMS 2013-GCJ12

 

December 27, 2019

to

December 31, 2019

GSMS 2013-GCJ16

 

December 27, 2019

to

December 31, 2019

MSBAM 2012-C5

 

December 27, 2019

to

December 31, 2019

MSBAM 2013-C13

 

December 27, 2019

to

December 31, 2019

MSC 2015-UBS8

 

December 27, 2019

to

December 31, 2019

 

 Exhibit B

Regulation AB Section 229.1122(d) Servicing Criteria

Regulation

AB Reference

 

Servicing Criterion

Performed by Park Bridge1

Not Applicable to Park Bridge2

1122(d)(1)(i)

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

 

 

X

1122(d)(1)(ii)

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.

 

 

X

1122(d)(1)(iii)

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

 

X

1122(d)(1)(iv)

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.

 

 

X

1122(d)(1)(v)

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

 

X

1122(d)(2)(i)

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.

 

 

X

1122(d)(2)(ii)

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

 

X

1122(d)(2)(iii)

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.

 

 

X

1122(d)(2)(iv)

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.

 

 

X

1122(d)(2)(v)

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.

 

 

X

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

 

X

1122(d)(2)(vii)

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.

 

 

X

1122(d)(3)(i)(A)

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 are prepared in accordance with timeframes and other terms set forth in the transaction agreements.

 

X

 

1122(d)(3)(i)(B)

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 provide information calculated in accordance with the terms specified in the transaction agreements.

 

X

 

1122(d)(3)(i)(C)

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 are filed with the Commission as required by its rules and regulations.

 

X3

 

X4

1122(d)(3)(i)(D)

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 agree with investors’ or the trustee's records as to the total unpaid principal balance and number of pool assets serviced by the servicer.

 

X3

 

X4

1122(d)(3)(ii)

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

 

 

X

1122(d)(3)(iii)

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.

 

 

X

1122(d)(3)(iv)

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

 

 

X

1122(d)(4)(i)

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

 

 

X

1122(d)(4)(ii)

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

 

X

1122(d)(4)(iii)

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.

 

 

X

1122(d)(4)(iv)

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.

 

 

X

1122(d)(4)(v)

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

 

 

X

1122(d)(4)(vi)

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.

 

 

X

1122(d)(4)(vii)

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.

 

X

 

1122(d)(4)(viii)

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

1122(d)(4)(ix)

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

 

 

X

1122(d)(4)(x)

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 were 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.

 

 

X

1122(d)(4)(xi)

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.

 

 

X

1122(d)(4)(xii)

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.

 

 

X

1122(d)(4)(xiii)

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.

 

 

X

1122(d)(4)(xiv)

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

 

 

X

1122(d)(4)(xv)

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.

 

 

X

 

1    The criteria in the column “Performed by Park Bridge” and marked with an “X” are applicable for the Transactions unless otherwise noted; however, there were no specially serviced loans under the related Transactions during the reporting period.  Therefore, no trust/operating advisor actions were required.

 

2    The criteria in the column “Not Applicable to Park Bridge” and marked with an “X” were not within the scope of the Asserting Party’s duties in the Transactions.

 

3    Applicable only to the Transactions listed in Table 2 below.

 

4    Not applicable to Transactions other than the Transactions listed in Table 2 below.

 

 

Table 2

 

COMM 2012-LC4

COMM 2012 CCRE2

COMM 2012 CCRE4

COMM 2012-CCRE5

COMM 2013-CCRE7

COMM 2013-CCRE9

COMM 2013-LC6

COMM 2013-LC13

COMM 2013-CCRE11

MSBAM 2012-C5

 

 

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