Attached files
Exhibit 33.4
Management's Assertion on Compliance with Applicable
Regulation AB Servicing Criteria
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1. |
Rialto Capital Advisors, LLC. (the "Asserting Party") is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending December 31, 2019 (the "Reporting Period"), as set forth in Appendix A hereto. The transactions covered by this report, include commercial mortgage-asset-backed securities transactions, as listed on Exhibit 1 hereto, for which the Asserting Party served as special servicer, and that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933 (the "Platform"); |
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2. |
The Asserting Party has engaged certain vendors, which are not servicers as defined in Item 1101(j) of Regulation AB (the "Vendors"), to perform specific, limited or scripted activities, and the Asserting Party elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors' activities as set forth in Appendix A hereto; |
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3. |
Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria; |
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4. |
The criteria listed in the column titled "Inapplicable Servicing Criteria" on Appendix A hereto are inapplicable to the Asserting Party based on the activities it performs, directly or through its Vendors, with respect to the Platform; |
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5. |
The Asserting Party has complied, in all material respects, with the applicable servicing criteria as of December 31, 2019 and for the Reporting Period with respect to the Platform taken as a whole; |
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6. |
The Asserting Party has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria as of December 31, 2019 and for the Reporting Period with respect to the Platform taken as a whole; |
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7. |
The Asserting Party has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria as of December 31, 2019 and for the Reporting Period with respect to the Platform taken as a whole; and |
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8. |
Deloitte & Touche LLP, an independent registered public accounting firm, has issued an attestation report on the Asserting Party's assessment of compliance with the applicable servicing criteria for the Reporting Period. |
February 28, 2020
Name: Adam Singer |
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Title: Managing Director |
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Signature: |
/s/ Adam Singer |
Pooling and Servicing Agreements |
Applicable Certification Period |
WFRBS 2012-C8 |
January 1, 2019 to December 31, 2019 |
WFCM 2012-LC5 |
January 1, 2019 to December 31, 2019 |
UBS-Barclays 2012-C3 |
January 1, 2019 to December 31, 2019 |
UBS-Barclays 2012-C4 |
January 1, 2019 to December 31, 2019 |
GSMS 2012-GCJ9 |
January 1, 2019 to December 31, 2019 |
JPMCC 2012-LC9 |
January 1, 2019 to December 31, 2019 |
COMM 2013-LC6 |
January 1, 2019 to December 31, 2019 |
WFRBS 2013-C12 |
January 1, 2019 to December 31, 2019 |
UBS-Barclays 2013-C6 |
January 1, 2019 to December 31, 2019 |
GSMS 2013-GCJ12 |
January 1, 2019 to December 31, 2019 |
WFRBS 2013-C14 |
January 1, 2019 to December 31, 2019 |
WFRBS 2011-C5 |
January 1, 2019 to December 31, 2019 |
WFCM 2013-LC12 |
January 1, 2019 to December 31, 2019 |
WFRBS 2011-C2 |
January 1, 2019 to December 31, 2019 |
WFRBS 2011-C3 |
January 1, 2019 to December 31, 2019 |
WFRBS 2011-C4 |
January 1, 2019 to December 31, 2019 |
UBS-Citigroup 2011-C1 |
January 1, 2019 to December 31, 2019 |
UBS 2012-C1 |
January 1, 2019 to December 31, 2019 |
WFRBS 2012-C6 |
January 1, 2019 to December 31, 2019 |
GSMS 2011-GC3 |
January 1, 2019 to December 31, 2019 |
COMM 2013-LC13 |
January 1, 2019 to December 31, 2019 |
WFRBS 2013-C16 |
January 1, 2019 to December 31, 2019 |
GSMS 2013-GCJ16 |
January 1, 2019 to December 31, 2019 |
WFRBS 2013-C17 |
January 1, 2019 to December 31, 2019 |
GSMS 2012-GC6 |
January 1, 2019 to December 31, 2019 |
MSBAM 2013-C13 |
January 1, 2019 to December 31, 2019 |
COMM 2014-CCRE14 |
January 1, 2019 to December 31, 2019 |
MSBAM 2014-C14 |
January 1, 2019 to December 31, 2019 |
WFRBS 2014-LC14 |
January 1, 2019 to December 31, 2019 |
COMM 2014-LC15 |
January 1, 2019 to December 31, 2019 |
WFRBS 2014-C20 |
January 1, 2019 to December 31, 2019 |
COMM 2014-CCRE18 |
January 1, 2019 to December 31, 2019 |
CGCMT 2014-GC23 |
January 1 , 2019 to December 31, 2019 |
MSBAM 2014-C17 |
January 1, 2019 to December 31, 2019 |
COMM 2014-UBS5 |
January 1, 2019 to December 31, 2019 |
MSBAM 2014-C18 |
January 1, 2019 to December 31, 2019 |
COMM 2012-CCRE4 |
January 1, 2019 to December 31, 2019 |
WFRBS 2014-C24 |
January 1, 2019 to December 31, 2019 |
JPMBB 2014-C25 |
January 1, 2019 to December 31, 2019 |
LCCM 2014-909 |
January 1, 2019 to December 31, 2019 |
WFCM 2014-LC18 |
January 1, 2019 to December 31, 2019 |
COMM 2015-DC1 |
January 1, 2019 to December 31, 2019 |
GSMS 2015-GC28 |
January 1, 2019 to December 31, 2019 |
WFCM 2015-C27 |
January 1, 2019 to December 31, 2019 |
WFCM 2015-LC20 |
January 1, 2019 to December 31, 2019 |
WFCM 2015-NXS1 |
January 1, 2019 to December 31, 2019 |
CSAIL 2015-C2 |
January 1, 2019 to December 31, 2019 |
WFCM 2015-NXS2 |
January 1, 2019 to December 31, 2019 |
COMM 2015-PC1 |
January 1, 2019 to December 31, 2019 |
CSAIL 2015-C3 |
January 1, 2019 to December 31, 2019 |
WFCM 2015-SG1 |
January 1, 2019 to December 31, 2019 |
2
January 1, 2019 to December 31, 2019 |
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COMM 2015-CCRE27 |
January 1, 2019 to December 31, 2019 |
WFCM 2015-NXS4 |
January 1, 2019 to December 31, 2019 |
MSCI 2015-UBS8 |
January 1, 2019 to December 31, 2019 |
CSAIL 2016-C5 |
January 1, 2019 to December 31, 2019 |
WFCM 2016-C32 |
January 1, 2019 to December 31, 2019 |
WFCM 2016-NXS5 |
January 1, 2019 to December 31, 2019 |
CGCMT 2015-GC27 |
January 1, 2019 to December 31, 2019 |
WFCM 2016-C33 |
January 1, 2019 to December 31, 2019 |
MSBAM 2016-C29 |
January 1, 2019 to December 31, 2019 |
CFCRE 2016-C4 |
January 1, 2019 to December 31, 2019 |
GSMS 2016-GS2 (Special Servicer solely for the Veritas Multifamily Pool 2 only) |
January 1, 2019 to December 31, 2019 |
BACM 2016-UBS10 |
January 1, 2019 to December 31, 2019 |
SGCMS 2016-C5 |
January 1, 2019 to December 31, 2019 |
WFCM 2016-BNK1 |
January 1, 2019 to December 31, 2019 |
CD 2016-CD1 |
January 1, 2019 to December 31, 2019 |
GSMS 2016-GS3 |
January 1, 2019 to December 31, 2019 |
MSBAM 2016-C31 |
January 1, 2019 to December 31, 2019 |
CGCMT 2016-C3 |
January 1, 2019 to December 31, 2019 |
CFCRE 2016-C6 |
January 1, 2019 to December 31, 2019 |
CSAIL 2016-C7 |
January 1, 2019 to December 31, 2019 |
MSCI 2016-UBS12 |
January 1, 2019 to December 31, 2019 |
BBCMS 2017-C1 |
January 1, 2019 to December 31, 2019 |
GSMS 2017-GS5 |
January 1, 2019 to December 31, 2019 |
CGCMT 2017-P7 |
January 1, 2019 to December 31, 2019 |
BANK 2017-BNK4 |
January 1, 2019 to December 31, 2019 |
CD 2017-CD4 |
January 1, 2019 to December 31, 2019 |
CFCRE 2017-C8 |
January 1, 2019 to December 31, 2019 |
JPMCC 2017-JP6 |
January 1, 2019 to December 31, 2019 |
CD 2017-CD5 |
January 1, 2019 to December 31, 2019 |
GSMS 2017-GS7 |
January 1, 2019 to December 31, 2019 |
BANK 2017-BNK7 |
January 1, 2019 to December 31, 2019 |
CSAIL 2017-CX9 |
January 1, 2019 to December 31, 2019 |
UBS 2017-C4 |
January 1, 2019 to December 31, 2019 |
UBS 2017-C6 |
January 1, 2019 to December 31, 2019 |
BANK 2017-BNK9 |
January 1, 2019 to December 31, 2019 |
GSMS 2018-GS9 |
January 1, 2019 to December 31, 2019 |
UBS 2018-C9 |
January 1, 2019 to December 31, 2019 |
MSCI 2012-C5 |
January 1, 2019 to December 31, 2019 |
WFCM 2018-C44 |
January 1, 2019 to December 31, 2019 |
UBS 2018-C10 |
January 1, 2019 to December 31, 2019 |
WFCM 2015-C30 |
January 1, 2019 to December 31, 2019 |
JPMBB 2014-C23 |
January 1, 2019 to December 31, 2019 |
MSBAM 2014-C19 |
January 1, 2019 to December 31, 2019 |
COMM 2015-LC21 |
January 1, 2019 to December 31, 2019 |
MSCI 2015-C20 |
January 1, 2019 to December 31, 2019 |
JPMBB 2015-C31 |
January 1, 2019 to December 31, 2019 |
GSMS 2018-GS10 |
January 1, 2019 to December 31, 2019 |
CD 2018-CD7 |
January 1, 2019 to December 31, 2019 |
GSMS 2018-3PCK |
January 1, 2019 to December 31, 2019 |
BANK 2018-BNK14 |
January 1, 2019 to December 31, 2019 |
DBGS 2018-C1 |
January 1, 2019 to December 31, 2019 |
CSAIL 2018-C14 |
January 1, 2019 to December 31, 2019 |
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January 1, 2019 to December 31, 2019 |
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ILPT 2019-SURF |
March 7, 2019 to December 31, 2019 |
MSCI 2019-L2 |
March 12, 2019 to December 31, 2019 |
WFCM 2019-C50 |
May 14, 2019 to December 31, 2019 |
BANK 2019-BNK18 |
May 31, 2019 to December 31, 2019 |
WFCM 2015-P2 |
May 31, 2019 to December 31, 2019 |
BMARK 2019-B11 |
June 17, 2019 to December 31, 2019 |
CGCMT 2019-CG41 |
August 20, 2019 to December 31, 2019 |
BBCMS 2019-C4 |
August 28, 2019 to December 31, 2019 |
COMM 2014-CCRE15 |
August 29, 2019 to December 31, 2019 |
UBSCM 2019-C17 |
October 15, 2019 to December 31, 2019 |
BANK 2019-BNK21 |
October 23, 2019 to December 31, 2019 |
CGCMT 2019-GC43 |
November 13, 2019 to December 31, 2019 |
FS RIALTO 2019-FL1 |
December 5, 2019 to December 31, 2019 |
CSAIL 2019-C18 |
December 12, 2019 to December 31, 2019 |
COMM 2019-GC44 |
December 12, 2019 to December 31, 2019 |
UBS 2019-C18 |
December 20, 2019 to December 31, 2019 |
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SERVICING CRITERIA |
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Reference |
Criteria |
Performed by Servicer |
Inapplicable Servicing Criteria |
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General Servicing Considerations |
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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 |
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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. |
X1 |
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1122(d)(1)(iii) |
Any requirements in the transaction agreements to maintain a back-up servicer for the [pool assets] are maintained. |
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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 |
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1122(d)(i)(v) |
Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information. |
X |
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Cash Collection and Administration |
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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 following receipt, or such other number of days specified in the transaction agreements. |
X |
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1122 (d)(2)(ii) |
Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel. |
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X3 |
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. |
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X3 |
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 |
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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 Rule 13k-1(b)(1) of the Securities Exchange Act. |
X |
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1122(d)(2)(vi) |
Unissued checks are safeguarded so as to prevent unauthorized access. |
X |
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Xl- Rialto Capital Advisors, LLC performs the activities pertaining to this criterion, except for specific, limited activities performed by its third-party property managers relating to REO Property, if any. Rialto has elected to take responsibility for assessing compliance with these servicing criteria with respect to the activities of its third-party property managers.
X2-Primary responsibility for processing borrower payments rests with the Master Servicer, however, Rialto Capital Advisors, LLC may from time to time receive payments on an exception basis which are forwarded to the Master Servicer in accordance with such criteria. The criteria is marked applicable as Rialto Capital Advisors, LLC had instances or activity relating to this criteria for the calendar year of January 1, 2019 to December 31, 2019.
X3-Rialto Capital Advisors, LLC performs the activities under the criteria, however the related criteria are marked inapplicable as Rialto did not have instances/activity during the calendar year of January 1, 2019 and ending on December 31, 2019 relating to the criteria.
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X4-Only items (A) and (B) of the Servicing Criteria are applicable to Rialto Capital Advisors, LLC as special servicer. Items (C) and (D) are inapplicable as the responsibility for filing reports with the Commission and agreeing totals to the Servicer records rests with the Trustee and/or Certificate Administrator, as applicable.7
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