Attached files
EX-33.8
(logo) LNR
Partners, LLC
Certification Regarding Compliance with Applicable Servicing Criteria
1. LNR Partners, 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, 2013 (the "Reporting Period"), as set forth in Appendix A
hereto. The transactions covered by this report, include commercial
mortgage-asset-backed securities transactions 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");
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;
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;
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;
5. The Asserting Party has complied, in all material respects, with the
applicable servicing criteria as of December 31, 2013 and for the Reporting
Period with respect to the Platform taken as a whole;
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, 2013 and for the Reporting Period with respect
to the Platform taken as a whole;
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, 2013 and for the Reporting
Period with respect to the Platform taken as a whole; and
8. Deloitte & Touche LLP, a 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, 2014
LNR Partners, LLC
By: /s/ Job Warshaw
Name: Job Warshaw
Title: President
1601 Washington Avenue * Suite 700 * Miami Beach, Florida 33139-3164
Telephone: (305) 695-5600 * Fax: (305) 695-5601
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APPENDIX A
INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by NOT
Performed subservicer(s) performed by
by or vendor(s) Asserting
Vendor(s) for which Party or by
Performed for which Asserting subservicer(s)
Directly Asserting Party is NOT or vendor(s)
by Party is the the retained by
Asserting Responsible Responsible Asserting
Party Party Party Party
Reference Criteria
General Servicing Considerations
Policies and procedures are instituted X
to monitor any performance or other
triggers and events of default in
accordance with the transaction
1122(d)(1)(i) agreements.
If any material servicing activities X
are outsourced to third parties, policies
and procedures are instituted to monitor
the third party's performance and
compliance with such servicing
1122(d)(1)(ii) activities.
Any requirements in the transaction X
agreements to maintain a back-up servicer
1122(d)(1)(iii) for the pool assets are maintained.
A fidelity bond and errors and X
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
1122(d)(1)(iv) the transaction agreements.
Cash Collection and Administration
Payments on pool assets are deposited X X
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
1122(d)(2)(i) agreements.
Disbursements made via wire transfer on X
behalf of an obligor or to investor are
1122(d)(2)(ii) made only by authorized personnel.
Advances of funds or guarantees X
regarding collections, cash flows or
distributions, and any interest or other
fees charged for such advances, are made,
reviewed and approved as specified in
1122(d)(2)(iii) the transaction agreements.
The related accounts for the X
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
1122(d)(2)(iv) the transaction agreements.
Each custodial account is maintained at X
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)
1122(d)(2)(v) of the Securities Exchange Act.
Unissued checks are safeguarded so as X
1122(d)(2)(vi) to prevent unauthorized access.
^1 Excludes the criteria as set forth on 3(i)(C) aud 3(i)(D) which is not applicable to the Asserting Party.
^2 The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not
routinely accept or process payments.
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INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by NOT
Performed subservicer(s) performed by
by or vendor(s) Asserting
Vendor(s) for which Party or by
Performed for which Asserting subservicer(s)
Directly Asserting Party is NOT or vendor(s)
by Party is the the retained by
Asserting Responsible Responsible Asserting
Party Party Party Party
Reference Criteria
Reconciliations are prepared on a X X
monthly basis for all asset-backed
securities related bank accounts,
including custodial accounts and related
bank clearing accounts. These
reconciliations are (A)
mathematically accurate; (B) prepared
within 30 calendar days after the bank
statement cutoff date, or such other
number of days specified in the
transaction agreements; (C) 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
1122(d)(2)(vii) transaction agreements.
Investor Remittances and Reporting
Reports to investors, including those X^1 X^1
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 the investors' or trustee's
records as to the total unpaid principal
balance and number of pool assets
1122(d)(3)(i) serviced by the Servicer.
Amounts due to investors are allocated X
and remitted in accordance with
timeframes, distribution priority and
other terms set forth in the transaction
1122(d)(3)(ii) agreements.
Disbursements made to an investor are X
posted within two business days to the
Servicer's investor records, or such other
number of days specified in the transaction
1122(d)(3)(iii) agreements.
Amounts remitted to investors per the X
investor reports agree with cancelled
checks, or other form of payment, or
1122(d)(3)(iv) custodial bank statements.
Pool Asset Administration
Collateral or security on pool assets X
is maintained as required by the
transaction agreements or related
1122(d)(4)(i) mortgage loan documents.
Pool asset and related documents are X
safeguarded as required by the
1122(d)(4)(ii) transaction agreements
Any additions, removals or substitutions X
to the asset pool are made, reviewed
and approved in accordance with
any conditions or requirements in the
1122(d)(4)(iii) transaction agreements.
Payments on pool assets, including any X^2
payoffs, made in accordance with related
pool asset 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
1122(d)(4)(iv) with the related pool asset documents.
^1 Excludes the criteria as set forth on 3(i)(C) aud 3(i)(D) which is not applicable to the Asserting Party.
^2 The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not
routinely accept or process payments.
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INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by NOT
Performed subservicer(s) performed by
by or vendor(s) Asserting
Vendor(s) for which Party or by
Performed for which Asserting subservicer(s)
Directly Asserting Party is NOT or vendor(s)
by Party is the the retained by
Asserting Responsible Responsible Asserting
Party Party Party Party
Reference Criteria
The Servicer's records regarding the X
pool assets agree with the Servicer's
records with respect to an obligor's
1122(d)(4)(v) unpaid principal balance.
Changes with respect to the terms or X
status of an obligor's pool assets
(e.g., loan modifications or re-agings)
are made, reviewed and approved by
authorized personnel in accordance
with the transaction agreements and
1122(d)(4)(vi) related pool asset documents.
Loss mitigation or recovery actions X
(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
1122(d)(4)(vii) agreements.
Records documenting collection efforts X
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.,
1122(d)(4)(viii) illness or unemployment).
Adjustments to interest rates or rates X
of return for pool assets with variable
rates are computed based on the related
1122(d)(4)(ix) pool asset documents.
Regarding any funds held in trust for X
an obligor (such as escrow accounts): (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 assets, or such
other number of days specified in the
1122(d)(4)(x) transaction agreements.
Payments made on behalf of an obligor X
(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
1122(d)(4)(xi) the transaction agreements.
Any late payment penalties in connection X
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
1122(d)(4)(xii) to the obligor's error or omission.
Disbursements made on behalf of an X
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
1122(d)(4)(xiii) agreements.
Delinquencies, charge-offs and X
uncollectible accounts are recognized and
recorded in accordance with the
1122(d)(4)(xiv) transaction agreements.
^1 Excludes the criteria as set forth on 3(i)(C) aud 3(i)(D) which is not applicable to the Asserting Party.
^2 The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not
routinely accept or process payments.
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INAPPLICABLE
APPLICABLE SERVICING
SERVICING CRITERIA SERVICING CRITERIA CRITERIA
Performed by NOT
Performed subservicer(s) performed by
by or vendor(s) Asserting
Vendor(s) for which Party or by
Performed for which Asserting subservicer(s)
Directly Asserting Party is NOT or vendor(s)
by Party is the the retained by
Asserting Responsible Responsible Asserting
Party Party Party Party
Reference Criteria
Any external enhancement or other X
support, identified in Item
1114(a)(1) through (3) or Item 1115 of
Regulation AB, is maintained as set
1122(d)(4)(xv) forth in the transaction agreements.
^1 Excludes the criteria as set forth on 3(i)(C) aud 3(i)(D) which is not applicable to the Asserting Party.
^2 The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not
routinely accept or process payments.
