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-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-33.6 - Wells Fargo Commercial Mortgage Trust 2017-C38wcm17c38_33-6.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

 

 

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Report of Independent Registered Public Accounting Firm

 

 

To the Board of Directors of Truist Bank

 

We have examined management’s assertion, included in the accompanying Management’s Report on Assessment of Compliance with Applicable Servicing Criteria (“management’s assertion”), that Cohen Financial, a division of Truist Bank, (the “Company”) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission's Regulation AB for the commercial mortgage backed security transactions specified in Appendix A attached to management’s assertion (the “Platform”), as of December 31, 2019 and for the year then ended, excluding the inapplicable servicing criteria as set forth in Appendix B hereto (such criteria, after giving effect to the exclusions identified on Appendix B attached to management’s assertion (the “Applicable Servicing Criteria”). As described in management's assertion, for servicing criterion 1122(d)(4)(xi), the Company has engaged a vendor to perform the activities required by this servicing criterion. The Company has determined that this vendor is not considered a "servicer” as defined in Item 1101(j) of Regulation AB, and the Company has elected to take responsibility for assessing compliance with the servicing criteria applicable to the vendor as permitted by Compliance and Disclosure Interpretation 200.06 of the SEC Division of Corporation Finance’s interpretations of the rules adopted under Regulation AB and the Securities Act and the Exchange Act ("Interpretation 200.06"). As permitted by Interpretation 200.06, the Company has asserted that it has policies and procedures in place designed to provide reasonable assurance that the vendor's activities comply in all material respects with the servicing criteria applicable to the vendor. The Company is solely responsible for determining that it meets the SEC requirements to apply Interpretation 200.06 for the vendor and related criteria as described in its assertion, and we performed no procedures with respect to the Company's determination of its eligibility to use Interpretation 200.06. The Company’s management is responsible for its assertion and for the Company's compliance with the applicable servicing criteria. Our responsibility is to express an opinion on management's assertion about the Company’s compliance with the applicable servicing criteria based on our examination.

 

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether management’s assertion about compliance with the applicable servicing criteria is fairly stated, in all material respects, and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of selected asset-backed transactions and securities that comprise the Platform, testing of selected servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the applicable servicing criteria. Our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to detect noncompliance arising from errors that may have occurred prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report. We believe that our examination provides, and that the evidence we obtained is sufficient and appropriate to provide, a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.

 

In our opinion, management’s assertion that Truist Bank complied with the aforementioned applicable servicing criteria as of and for the year ended December 31, 2019 for the Platform is fairly stated, in all material respects.

 

 

/s/ Pricewaterhouse Coopers LLP

Pricewaterhouse Coopers LLP

Charlotte, North Carolina

March 6, 2020

 

 

PricewaterhouseCoopers LLP, 214 North Tryon Street Suite 4200 Charlotte, North Carolina 28202

T: 704 344 7500, www.pwc.com/us