1.

Situs Holdings, LLC (the “Company”), a wholly-owned subsidiary of SitusAMC Holdings Corporation, is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB of the Securities and Exchange Commission (“SEC”), as of and for the year ended December 31, 2020 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report (collectively referred to as the “Special Servicing Platform” or the “Platform”) include asset-backed transactions and securities. This includes the asset-backed transactions and securities for which Situs Holdings, LLC served in the capacity of special servicer, involving commercial mortgage loans, as defined in Appendix B.  

2.

Except as set forth in paragraph 3 below, the Company used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to provide an assertion on the Company’s assessment of compliance with the applicable servicing criteria.

3.

The criteria listed in the column titled “Inapplicable Servicing Criteria” in Appendix A hereto are inapplicable to the Company based on the activities it performed, directly or through its Vendors, with respect to the Platform for the Reporting Period.

4.

During the Reporting Period, there were no payments on asset pools received, nor any payments received where the depository responsibility of Situs Holdings, LLC as Special Servicer would require deposits be made to the operating account, therefore the Company did not perform any servicing activities related to criteria 1122(d)(2)(i) as of and for the year ended December 31, 2020.

5.

During the Reporting Period, there were no wire disbursements sent or required to be sent, therefore the Company did not perform any servicing activities related to criteria 1122(d)(2)(ii) as of and for the year ended December 31, 2020.

6.

During the Reporting Period, there were no additions, removals, or substitutions to the asset pools, therefore the Company did not perform any servicing activities related to criteria 1122(d)(4)(iii) as of and for the year ended December 31, 2020.

7.

During the Reporting Period, there were no active assets carrying an escrow balance maintained by Situs Holdings, LLC or escrow disbursements due to be paid by Situs Holdings, LLC therefore the Company did not perform any servicing activities related to criteria 1122(d)(4)(x-xiii) as of and for the year ended December 31, 2020. The only portfolio active during any part of the year ended

December 31, 2020 to which these criteria are required to be considered per the corresponding transaction agreements was CSMC 2006-C1.

8.

During the Reporting Period, there were no loans charged off or accounts determined to be uncollectible, therefore the Company did not perform any servicing activities related to criteria 1122(d)(4)(xiv) as of and for the year ended December 31, 2020. The only portfolio active during any part of the year ended December 31, 2020 to which this criterion is required to be considered per the corresponding transaction agreements was CSMC 2006-C1.

9.

With respect to servicing criteria 1122(d)(2)(vii), the Company has engaged various vendors to perform some or all of the activities required by these servicing criteria. Management has determined that these vendors are not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and has elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by the SEC’s Compliance & Disclosure Interpretation 200.06, Vendors Engaged by Servicers (“C&DI 200.06”), formerly Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations. As permitted by C&DI 200.06, management asserts 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 each vendor. Management is not aware of any material deficiencies in such policies and procedures or any material instances of non-compliance of the servicing criteria as relates to the Company by such vendors. Management is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendors and related criteria.  

10.

The Company has complied, in all material respects, with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB, as of and the year ended December 31, 2020 with respect to the Platform taken as a whole.

11.

Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on the Company’s assertion on compliance with the applicable servicing criteria for the Reporting Period.

/s/ Dean Wheeler

SERVICING CRITERIA

APPLICABLE SERVICING

CRITERIA

INAPPLICABLE SERVICING

CRITERIA

Reference

Criteria

Performed

Directly by

Situs

Holdings,

LLC

Performed by

Vendor(s) for

which Situs

Holdings, LLC

is the

Responsible

Party

Performed by

subservicer(s)

or Vendor(s)

for which Situs

Holdings, LLC

is NOT the

Responsible

Party

NOT

performed by

Situs Holdings,

LLC or by

subservicer(s)

or Vendor(s)

retained by

Situs Holdings,

LLC

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.

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

Cash Collection and Administration

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

SERVICING CRITERIA

APPLICABLE SERVICING

CRITERIA

INAPPLICABLE SERVICING

CRITERIA

Reference

Criteria

Performed

Directly by

Situs

Holdings,

LLC

Performed by

Vendor(s) for

which Situs

Holdings, LLC

is the

Responsible

Party

Performed by

subservicer(s)

or Vendor(s)

for which Situs

Holdings, LLC

is NOT the

Responsible

Party

NOT

performed by

Situs Holdings,

LLC or by

subservicer(s)

or Vendor(s)

retained by

Situs Holdings,

LLC

1122(d)(2)(iv)

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.

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.

X¹

X¹

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 pool assets serviced by the servicer.

X²

¹

Servicing activities associated with criterion 1122(d)(2)(vii) are performed by Situs Holdings, LLC and a third party vendor for which Situs Holdings, LLC is the responsible party.

²

For criterion 1122(d) (3)(i)(B-D), Situs Holdings, LLC did not perform the activity described in this criterion for the Reporting Period as these components of 1122(d)(3)(i) are inapplicable to the functions performed by Situs Holdings, LLC. No assertion on compliance, therefore, is necessary.

SERVICING CRITERIA

APPLICABLE SERVICING

CRITERIA

INAPPLICABLE SERVICING

CRITERIA

Reference

Criteria

Performed

Directly by

Situs

Holdings,

LLC

Performed by

Vendor(s) for

which Situs

Holdings, LLC

is the

Responsible

Party

Performed by

subservicer(s)

or Vendor(s)

for which Situs

Holdings, LLC

is NOT the

Responsible

Party

NOT

performed by

Situs Holdings,

LLC or by

subservicer(s)

or Vendor(s)

retained by

Situs Holdings,

LLC

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

Pool Asset Administration

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

SERVICING CRITERIA

APPLICABLE SERVICING

CRITERIA

INAPPLICABLE SERVICING

CRITERIA

Reference

Criteria

Performed

Directly by

Situs

Holdings, LLC

Performed by

Vendor(s) for which Situs

Holdings, LLC

is the

Responsible

Party

Performed by

subservicer(s)

or Vendor(s)

for which Situs

Holdings, LLC

is NOT the

Responsible

Party

NOT

performed by

Situs Holdings,

LLC or by

subservicer(s)

or Vendor(s)

retained by

Situs Holdings,

LLC

1122(d)(4)(vi)

Changes with respect to the terms or status of an obligor's mortgage loans (e.g., loan modifications or re-aging's) 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, foreclosure 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) See following: (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 are 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.

X³

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.

X³

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.

X³

³

Servicing activities associated with criteria 1122(d)(4)(x-xiv) are only in-scope for the ‘CSMC-2006 C1’ portfolio. These servicing criteria are inapplicable for all other portfolios on the Platform. Refer to Appendix B of this Management’s Assertion for the in-scope portfolios.

SERVICING CRITERIA

APPLICABLE SERVICING CRITERIA

INAPPLICABLE SERVICING CRITERIA

Reference

Criteria

Performed

Directly by

Situs

Holdings,

LLC

Performed by

Vendor(s) for

which Situs

Holdings, LLC

is the

Responsible

Party

Performed by

subservicer(s)

or Vendor(s)

for which Situs

Holdings, LLC

is NOT the

Responsible

Party

NOT

performed by

Situs Holdings,

LLC or by

subservicer(s)

or Vendor(s)

retained by

Situs Holdings,

LLC

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.

X³

1122(d)(4)(xiv)

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

X³

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

Portfolio

Servicing Agreement

Date

Special Servicing activity

required as of

and for the year ended

December 31, 2020

AFHT 2019-FAIR

October 15, 2019

X

AREIT 2018-CRE2

November 15, 2018

AREIT 2019-CRE3

August 29, 2019

AREIT 2020-CRE4

May 21, 2020

BACM 2017-BNK3

February 1, 2017

BAMLL 2020-JGDN

November 16, 2020

Banc of CA 2019-Q010

July 1, 2019

Bank 2019-BNK18

May 1, 2019

BBCMS 2017-DELC

August 29, 2017

Benchmark 2020-IG3

May 1, 2020

BFLD 2019-DPLO  

October 9, 2019

BFLD 2020-EYP

October 7, 2020

BSPRT 2017-FL2

November 29, 2017

BSPRT 2018-FL3  

April 5, 2018

BSPRT 2018-FL4  

October 12, 2018

X

BSPRT 2019-FL5  

May 30, 2019

X

BWAY 2019-1633  

December 20, 2019

BX 2018-BILT

May 24, 2018

BX 2018-GW

May 22, 2018

BX 2019-CALM

December 12, 2019

BX 2019-OC11  

December 1, 2019

BX 2020-VIVA

May 5, 2020

CAF 2016-1  

May 1, 2016

X

CAF 2016-2

November 15, 2016

X

CAF 2018-1

June 9, 2018

X

CAF 2019-1

April 9, 2019

X

CAF 2019-2

July 9, 2019

X

CAF 2019-3  

November 9, 2019

X

CAF 2020-1

March 9, 2020

X

CAF 2020-2

May 9, 2020

X

CAF 2020-3

September 9, 2020

CAF 2020-4

December 9, 2020

CAF 2020-P1

November 19, 2020

CFCRE 2018-TAN  

February 6, 2018

CGCMT 2020-420K

November 6, 2020

Citibank 2020-Q012

August 1, 2020

COLD 2020-ICE5

October 29, 2020

COMM 2013-CCRE7

April 1, 2013

X

COMM 2019-521F  

June 20, 2019

COMM 2019-WCM

October 30, 2019

COMM 2020-CX

November 5, 2020

COMM 2020-SBX

December 30, 2020

CSAIL 2015-C1

March 1, 2015

CSMC 2006-C1

March 1, 2006

X

CSMC 2017-CALI  

November 6, 2017

Portfolio

Servicing Agreement

Date

Special Servicing

activity required as of

and for the year ended

December 31, 2020

CSMC 2019-ICE4  

June 5, 2019

CSMC 2019-UVIL  

December 6, 2019

DAFC 2017-AMO

June 20, 2017

DBGS 2019-1735  

April 6, 2019

First Foundation 2018-

Q007

September 1, 2018

X

First Foundation 2019-

Q011

September 1, 2019

X

First Foundation 2020-

Q013

September 1, 2020

First Republic 2018-Q008

December 1, 2018

FMBT 2019-FBLU  

December 6, 2019

X

FREMF 2017-K67  

September 1, 2017

FRESB 2015-SB8  

November 1, 2015

FRESB 2016-SB19

July 1, 2016

FRESB 2019-SB60

March 1, 2019

X

GACM 2019-FL1

June 6, 2019

GACM 2020-FL2

June 5, 2020

Grace Trust 2020-GRCE

November 18, 2020

Great Wolf 2019-WLF

December 30, 2019

GSMS 2017-STAY  

August 15, 2017

GSMS 2019-70P  

October 23, 2019

HAMLET 2020-CRE1

May 1, 2020

HBST 2015-HBS  

November 1, 2015

X

HFX 2017-1

March 30, 2020

X

HY 2019-30HY  

July 6, 2019

JPMCC 2018-BCON  

February 1, 2018

JPMCC 2018-PHH

August 7, 2018

X

JPMCC 2018-PTC  

May 16, 2018

JPMCC 2019-ICON  

April 1, 2019

JPMCC 2019-MARG

May 30, 2019

JPMCC 2019-MFP

July 18, 2019

JPMCC 2019-OSB  

June 13, 2019

JPMCC 2020-LOOP

February 5, 2020

KNDL 2019-KNSQ  

May 30, 2019

LoanCore 2018-CRE1  

June 5, 2018

LoanCore 2019-CRE2

May 30, 2019

X

LoanCore 2019-CRE3

May 30, 2019

X

Luther Burbank 2017-Q004

September 1, 2017

Manhattan West 2020-

1MW

August 28, 2020

MBRT 2019-MBR  

December 19, 2019

Merit 2020-HILL  

August 31, 2020

MEZZ CAP 2006-C4  

December 1, 2006

MFTII 2019-B3B4  

July 11, 2019

MKT 2020-525M

February 26, 2020

MSC 2011-C2  

June 1, 2011

X

MSC 2018-SUN

August 2, 2018

X

MSC 2019-H7

July 1, 2019

MSC 2019-L3

November 1, 2019

Portfolio

Servicing Agreement

Date

Special Servicing activity

required as of

and for the year ended

December 31, 2020

NCMS 2019-LVL  

April 23, 2019

NCMS 2019-NEMA  

March 29, 2019

Opus Bank 2016-Q003

December 1, 2016

PRIMA 2019-1S

August 23, 2019

X

PRIMA 2019-RK1

June 27, 2019

PRIMA 2019-VII

October 22, 2019

PRIMA 2020-VIII

July 15, 2020

SCMT 2020-SBC9  

June 30, 2020

Selkirk 1

December 13, 2013

Selkirk 2

December 13, 2013

Selkirk 3

September 26, 2014

SGCP 2019-FL2

June 5, 2019

X

SLIDE 2018-1 FUN

September 28, 2018

X

TPG 2018-FL2  

November 29, 2018

TPG 2019-FL3  

October 25, 2019

UBS 2019-C16  

April 1, 2019

UBSCM 2018-NYCH

February 26, 2018

X

VLS 2020-LAB

November 6, 2020

WBCMT 2005-C18

May 1, 2005

WFCM 2019-C50  

May 1, 2019

X

WWPT 2017-WWP

November 10, 2017