Exhibit 33.7

1)

CWCAM has determined that the Not Applicable Criteria are in fact not applicable to the activities it performs with respect to the Platform.

2)

CWCAM has complied in all material respects with the applicable servicing criteria set forth in Item 1122.

By:

/s/ James P. Shevlin

Date: February 26, 2021

James P. Shevlin

President/Chief Operating Officer

By:

/s/ Bruce Cunningham

Date: February 26, 2021

Bruce Cunningham

Chief Financial Officer

Relevant Servicing Criteria

Reference

Criteria

CWCAM

General Servicing Considerations

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.

Applicable

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.

Applicable

1122(d)(1)(iii)

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

Not Applicable

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.

Applicable

1122(d)(1)(v)

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

Applicable

Cash Collection and Administration

1122(d)(2)(i)

Payments on mortgage loans 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.

Applicable

1122(d)(2)(ii)

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

Applicable

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.

Applicable

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.

Applicable

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.

Applicable

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

Applicable

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

Applicable

Relevant Servicing Criteria

Reference

Criteria

CWCAM

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.

Investor Remittances and Reporting

1122(d)(3)(i)

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 mortgage loans serviced by the Servicer.

(A)   Applicable

(B)   Not Applicable

(C)   Not Applicable

(D)   Not Applicable

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.

Not Applicable

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.

Not Applicable

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.

Not Applicable

Pool Asset Administration

1122(d)(4)(i)

Collateral or security on mortgage loans is maintained as required by the transaction agreements or related mortgage loan documents.

Applicable

1122(d)(4)(ii)

Mortgage loan and related documents are safeguarded as required by the transaction agreements.

Applicable

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.

Applicable

1122(d)(4)(iv)

Payments on mortgage loans, including any payoffs, made in accordance with the related mortgage loan documents are posted to the 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 mortgage loan documents.

Applicable

1122(d)(4)(v)

The Servicer’s records regarding the mortgage loans agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.

Not Applicable

1122(d)(4)(vi)

Changes with respect to the terms or status of an obligor’s mortgage loans (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.

Applicable

Relevant Servicing Criteria

Reference

Criteria

CWCAM

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.

Applicable

1122(d)(4)(viii)

Records documenting collection efforts are maintained during the period a mortgage loan 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 mortgage loans including, for example, phone calls, letters and payment rescheduling plans in cases

where delinquency is deemed temporary (e.g., illness or unemployment).

Applicable

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for mortgage loans with

variable rates are computed based on the related mortgage loan documents.

Not Applicable

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 mortgage loan 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 mortgage loan documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related mortgage loans, or

such other number of days specified in the transaction agreements.

Not Applicable

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.

Not Applicable

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.

Not Applicable

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.

Not Applicable

1122(d)(4)(xiv)

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

Not Applicable

1122(d)(4)(xv)

Any external enhancement or other support, identified in Item 1114(a)(1)

through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.

Not Applicable

Aventura 2018-AVM

CSAIL 2017-CX10

MLCFC 2007-5

BACM 2007-1

CSFB 2007-C4

MLCFC 2007-6

BACM 2007-5

CSMC 2008-C1

MLMT 2006-C1

BACM 2008-1

CSMC 2014-USA

MOFT 2020-ABC

BANCORP 2019-CRE6

DBJPM 2020-C9

MSBAM 2013-C8

BANK 2017-BNK5

DBUBS 2011-LC3

MSBAM 2014-C19

BANK 2020-BNK27

DCOT 2019-MTC

MSBAM 2015-C21

BENCHMARK 2018-B4

GRACE 2014-GRCE

MSBAM 2015-C27

BENCHMARK 2018-B8

GSMS 2012-GCJ7

MSC 2016-UBS11

BENCHMARK 2019-B13

GSMS 2014-GC22

MSCI 2016-UBS9

BHMS 2018-ATLS

GSMS 2014-GC26

MSC 2019-PLND

BMARK 2018-B2

GSMS 2015-GC32

UBS 2012-C2

BSCMS 2007-PWR18

GSMS 2018-RIVR

UBS 2017-C1

BX 2017-CQHP

GSMS 2019-BOCA

VNDO 2016 -350P

BX 2019-ATL

GSMS 2020-GC45

WBCMT 2006-C23

CD 2007-CD4

GSMS 2020-TWN3

WBCMT 2006-C28

CF 2019-MF1

HILT 2016-HHV

WBCMT 2007-C33

CFCRE 2016-C3

Hudson Yards 2019-55HY

WBCMT 2007-C34

CGCMT 2016-P4

JPMBB 2015-C33

WBHT 2019-WBM

CGCMT 2016-P6

JPMC 2006-CIBC17

WFCM 2016-C35

CGCMT 2020-GC46

JPMC 2006-LDP9

WFCM 2016-NXS6

CLNY 2019-IKPR

JPMCC 2008-C2

WFCM 2019-JWDR

COBALT 2007-C2

JPMC 2018-LAQ

WFRBS 2013-C11

COBALT 2007-C3

JPMCC 2013-C16

WFRBS 2013-C15

COMM 2013-CCRE11

JPMCC 2017-JP7

WFRBS 2013-UBS1

COMM 2015-CCRE23

JPMCC 2018-ASH8

WFRBS 2014-C21

COMM 2015-CCRE25

JPMCC 2019-ICON UES

WFRBS 2014-C22

COMM 2015-CCRE26

JPMCC 2020-NNN

WFRBS 2014-C23

COMM 2016-CCRE28

JPMDB 2017-C5

WFRBS 2014-C25

COMM 2016-DC2

LBUBS 2006-C6

COMM 2019-GC44

MLCFC 2006-1

CPTS 2019-CPT

MLCFC 2006-4