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MANAGEMENT'S ASSERTION ON COMPLIANCE WITH SEC REGULATION AB SERVICING CRITERIA
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.
Situs Holdings, LLC
February 26, 2021
/s/ Dean M Wheeler
Dean Wheeler, Managing Director, Head of Client Service Delivery –
Servicing, Asset Management & Special Servicing
Appendix A – Applicable Servicing Criteria
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SERVICING CRITERIA |
APPLICABLE SERVICING CRITERIA |
INAPPLICABLE SERVICING CRITERIA |
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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 |
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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. |
X |
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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. |
X |
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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)(1)(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 of 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. |
X |
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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 |
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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 |
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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 §240.13k-1(b)(1) of this chapter. |
X |
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1122(d)(2)(vi) |
Unissued checks are safeguarded so as to prevent unauthorized access. |
X |
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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 |
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Investor Remittances and Reporting |
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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 |
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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 |
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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 |
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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 |
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Pool Asset Administration |
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1122(d)(4)(i) |
Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents. |
X |
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1122(d)(4)(ii) |
Pool assets and related documents are safeguarded as required by the transaction agreements. |
X |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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1122(d)(4)(xiv) |
Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements. |
X3 |
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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 |
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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.
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.
APPENDIX B – The Platform
Situs Holdings, LLC was named as the Special Servicer for all portfolios listed below. However, there was only activity requiring Situs Holdings, LLC to perform the role as Special Servicer for the portfolios designated with a “X” throughout the period 1/1/2020 – 12/31/2020.
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Portfolio |
Servicing Agreement Date |
Special Servicing activity required as of and for the year ended December 31, 2020 |
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AFHT 2019-FAIR |
October 15, 2019 |
X |
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AREIT 2018-CRE2 |
November 15, 2018 |
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AREIT 2019-CRE3 |
August 29, 2019 |
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AREIT 2020-CRE4 |
May 21, 2020 |
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BACM 2017-BNK3 |
February 1, 2017 |
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BAMLL 2020-JGDN |
November 16, 2020 |
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Banc of CA 2019-Q010 |
July 1, 2019 |
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Bank 2019-BNK18 |
May 1, 2019 |
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BBCMS 2017-DELC |
August 29, 2017 |
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Benchmark 2020-IG3 |
May 1, 2020 |
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BFLD 2019-DPLO |
October 9, 2019 |
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BFLD 2020-EYP |
October 7, 2020 |
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BSPRT 2017-FL2 |
November 29, 2017 |
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BSPRT 2018-FL3 |
April 5, 2018 |
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BSPRT 2018-FL4 |
October 12, 2018 |
X |
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BSPRT 2019-FL5 |
May 30, 2019 |
X |
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BWAY 2019-1633 |
December 20, 2019 |
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BX 2018-BILT |
May 24, 2018 |
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BX 2018-GW |
May 22, 2018 |
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BX 2019-CALM |
December 12, 2019 |
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BX 2019-OC11 |
December 1, 2019 |
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BX 2020-VIVA |
May 5, 2020 |
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CAF 2016-1 |
May 1, 2016 |
X |
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CAF 2016-2 |
November 15, 2016 |
X |
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CAF 2018-1 |
June 9, 2018 |
X |
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CAF 2019-1 |
April 9, 2019 |
X |
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CAF 2019-2 |
July 9, 2019 |
X |
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CAF 2019-3 |
November 9, 2019 |
X |
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CAF 2020-1 |
March 9, 2020 |
X |
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CAF 2020-2 |
May 9, 2020 |
X |
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CAF 2020-3 |
September 9, 2020 |
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CAF 2020-4 |
December 9, 2020 |
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CAF 2020-P1 |
November 19, 2020 |
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CFCRE 2018-TAN |
February 6, 2018 |
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CGCMT 2020-420K |
November 6, 2020 |
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Citibank 2020-Q012 |
August 1, 2020 |
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COLD 2020-ICE5 |
October 29, 2020 |
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COMM 2013-CCRE7 |
April 1, 2013 |
X |
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COMM 2019-521F |
June 20, 2019 |
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COMM 2019-WCM |
October 30, 2019 |
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COMM 2020-CX |
November 5, 2020 |
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COMM 2020-SBX |
December 30, 2020 |
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CSAIL 2015-C1 |
March 1, 2015 |
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CSMC 2006-C1 |
March 1, 2006 |
X |
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CSMC 2017-CALI |
November 6, 2017 |
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CSMC 2019-ICE4 |
June 5, 2019 |
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CSMC 2019-UVIL |
December 6, 2019 |
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DAFC 2017-AMO |
June 20, 2017 |
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DBGS 2019-1735 |
April 6, 2019 |
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First Foundation 2018- Q007 |
September 1, 2018 |
X |
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First Foundation 2019- Q011 |
September 1, 2019 |
X |
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First Foundation 2020- Q013 |
September 1, 2020 |
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First Republic 2018-Q008 |
December 1, 2018 |
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FMBT 2019-FBLU |
December 6, 2019 |
X |
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FREMF 2017-K67 |
September 1, 2017 |
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FRESB 2015-SB8 |
November 1, 2015 |
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FRESB 2016-SB19 |
July 1, 2016 |
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FRESB 2019-SB60 |
March 1, 2019 |
X |
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GACM 2019-FL1 |
June 6, 2019 |
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GACM 2020-FL2 |
June 5, 2020 |
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Grace Trust 2020-GRCE |
November 18, 2020 |
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Great Wolf 2019-WLF |
December 30, 2019 |
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GSMS 2017-STAY |
August 15, 2017 |
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GSMS 2019-70P |
October 23, 2019 |
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HAMLET 2020-CRE1 |
May 1, 2020 |
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HBST 2015-HBS |
November 1, 2015 |
X |
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HFX 2017-1 |
March 30, 2020 |
X |
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HY 2019-30HY |
July 6, 2019 |
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JPMCC 2018-BCON |
February 1, 2018 |
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JPMCC 2018-PHH |
August 7, 2018 |
X |
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JPMCC 2018-PTC |
May 16, 2018 |
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JPMCC 2019-ICON |
April 1, 2019 |
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JPMCC 2019-MARG |
May 30, 2019 |
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JPMCC 2019-MFP |
July 18, 2019 |
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JPMCC 2019-OSB |
June 13, 2019 |
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JPMCC 2020-LOOP |
February 5, 2020 |
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KNDL 2019-KNSQ |
May 30, 2019 |
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LoanCore 2018-CRE1 |
June 5, 2018 |
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LoanCore 2019-CRE2 |
May 30, 2019 |
X |
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LoanCore 2019-CRE3 |
May 30, 2019 |
X |
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Luther Burbank 2017-Q004 |
September 1, 2017 |
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Manhattan West 2020- 1MW |
August 28, 2020 |
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MBRT 2019-MBR |
December 19, 2019 |
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Merit 2020-HILL |
August 31, 2020 |
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MEZZ CAP 2006-C4 |
December 1, 2006 |
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MFTII 2019-B3B4 |
July 11, 2019 |
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MKT 2020-525M |
February 26, 2020 |
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MSC 2011-C2 |
June 1, 2011 |
X |
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MSC 2018-SUN |
August 2, 2018 |
X |
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MSC 2019-H7 |
July 1, 2019 |
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MSC 2019-L3 |
November 1, 2019 |
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NCMS 2019-LVL |
April 23, 2019 |
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NCMS 2019-NEMA |
March 29, 2019 |
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Opus Bank 2016-Q003 |
December 1, 2016 |
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PRIMA 2019-1S |
August 23, 2019 |
X |
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PRIMA 2019-RK1 |
June 27, 2019 |
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PRIMA 2019-VII |
October 22, 2019 |
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PRIMA 2020-VIII |
July 15, 2020 |
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SCMT 2020-SBC9 |
June 30, 2020 |
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Selkirk 1 |
December 13, 2013 |
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Selkirk 2 |
December 13, 2013 |
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Selkirk 3 |
September 26, 2014 |
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SGCP 2019-FL2 |
June 5, 2019 |
X |
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SLIDE 2018-1 FUN |
September 28, 2018 |
X |
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TPG 2018-FL2 |
November 29, 2018 |
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TPG 2019-FL3 |
October 25, 2019 |
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UBS 2019-C16 |
April 1, 2019 |
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UBSCM 2018-NYCH |
February 26, 2018 |
X |
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VLS 2020-LAB |
November 6, 2020 |
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WBCMT 2005-C18 |
May 1, 2005 |
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WFCM 2019-C50 |
May 1, 2019 |
X |
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WWPT 2017-WWP |
November 10, 2017 |