Attached files
EX-33.6
(logo) PARK BRIDGE LENDER SERVICES LLC
January 29, 2013
RE: Management's Report on Assessment of 2012 Compliance by Park Bridge Lender
Services LLC with Regulation AB Servicing Criteria
Park Bridge Lender Services LLC (the "Asserting Party") is responsible for
assessing its compliance, as of and for the period ended December 31, 2012,
with the servicing criteria set forth in Title 17, Section 229.1122(d) of the
Code of Federal Regulations.
The transactions covered by this assertion are those transactions processed by
the Asserting Party in its capacity as trust or operating advisor for the
asset-backed securities transactions listed in Exhibit B hereto (the
"Platform").
The Asserting Party is responsible for assessing its compliance with the
servicing criteria applicable to it. The Asserting Party used the criteria in
paragraph (d) of Section 1122 of Regulation AB (17 C.F.R.229.1122) to assess
its compliance. The full outline of the Asserting Party's contractually
applicable servicing criteria under various securitization pooling and
servicing agreements can be found in Exhibit A attached hereto.
Based on its assessment, the Asserting Party believes that, as of and for the
periods the contractual obligations began through December 31, 2012, the
Asserting Party has complied in all material respects with the servicing
criteria set forth in Item 1122(d) of Regulation AB relating to its trust or
operating advisor role with respect to the Platform, except for servicing
criteria 1122(d)(1)(i-iv), 1122(d)(2)(i-vii), 1122(d)(3)(ii-iv),
1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv), which the Asserting Party has
determined as being inapplicable to the activities it performs with respect the
Platform (the "applicable servicing criteria").
Curcio, Wieselthier & Cohen C.P.A.'S, P.C., an independent registered public
accounting firm, has issued an attestation report on the assessment of
compliance with the applicable servicing criteria for the reporting period as
set forth in this assertion.
Signed:
/s/ David M. Rodgers
David M. Rodgers
Principal
560 LEXINGTON AVENUE, 17TH FLOOR, NEW YORK, NY 10022
WWW.PARKBRIDGEFINANCIAL.COM
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Exhibit A
Regulation AB Section 229.1122(d) Servicing Criteria
Applicability/Compliance
Regulation AB Servicing Criterion COMM COMM UBS-B COMM COMM
Reference 2012- 2012- 2012-C3 2012- 2012-
LC4 CCRE2 CCRE4 CCRE5
1122(d)(1)(i) Policies and procedures are instituted NA NA NA NA NA
to monitor any performance or other
triggers and events of default in
accordance with the transaction
agreements.
1122(d)(1)(ii) If any material servicing activities NA NA NA NA NA
are outsourced to third parties, policies
and procedures are instituted to monitor
the third party's performance and
compliance with such servicing
activities.
1122(d)(1)(iii) Any requirements in the transaction NA NA NA NA NA
agreements to maintain a backup servicer
for the pool assets are maintained.
1122(d)(1)(iv) A fidelity bond and errors and NA NA NA NA NA
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.
1122(d)(2)(i) Payments on pool assets are deposited NA NA NA NA NA
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.
1122(d)(2)(ii) Disbursements made via wire transfer on NA NA NA NA NA
behalf of an obligor or to an investor
are made only by authorized personnel.
1122(d)(2)(iii) Advances of funds or guarantees NA NA NA NA NA
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 documents
1122(d)(2)(iv) The related accounts for the NA NA NA NA NA
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.
1122(d)(2)(v) Each custodial account is maintained at NA NA NA NA NA
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 Section
240.13k-1(b)(1) of this chapter.
1122(d)(2)(vi) Unissued checks were safeguarded so as NA NA NA NA NA
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to prevent unauthorized access.
1122(d)(2)(vii) Reconciliations are prepared on a NA NA NA NA NA
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.
1122(d)(3)(i)(A) Reports to investors, including those APPL APPL APPL APPL APPL
to be filed with the Commission, are
maintained in accordance with the
transaction agreements and applicable
Commission requirements. Specifically,
such reports are prepared in accordance
with time frames and other terms set
forth in the transaction agreements.
1122(d)(3)(i)(B) Reports to investors, including those APPL APPL APPL APPL APPL
to be filed with the Commission, are
maintained in accordance with the
transaction agreements and applicable
Commission requirements. Specifically,
such reports provide information
calculated in accordance with the terms
specified in the transaction agreements.
1122(d)(3)(i)(C) Reports to investors, including those APPL APPL NA APPL APPL
to be filed with the Commission, are
maintained in accordance with the
transaction agreements and applicable
Commission requirements. Specifically,
such reports are filed with the Commission
as required by its rules and regulations.
1122(d)(3)(i)(D) Reports to investors, including those APPL APPL NA APPL APPL
to be filed with the Commission, are
maintained in accordance with the
transaction agreements and applicable
Commission requirements. Specifically,
such reports agree with the investors' or
trustee's records as to the total unpaid
principal balance and number of pool assets
serviced by the servicer.
1122(d)(3)(ii) Amounts due to investors are allocated NA NA NA NA NA
and remitted in accordance with
time frames, distribution priority and
other terms set forth in the transaction
agreements.
1122(d)(3)(iii) Disbursements made to an investor are NA NA NA NA NA
posted within two business days to the
servicer's investor records, or such other
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number of days specified in the transaction
agreements.
1122(d)(3)(iv) Amounts remitted to investors per the NA NA NA NA NA
investor reports agree with cancelled
checks, or other form of payment, or
custodial bank statements
1122(d)(4)(i) Collateral or security on pool assets NA NA NA NA NA
is maintained as required by the
transaction agreements or related
pool asset documents.
1122(d)(4)(ii) Pool assets and related documents are NA NA NA NA NA
safeguarded as required by the
transaction agreements.
1122(d)(4)(iii) Any additions, removals or substitutions NA NA NA NA NA
to the asset pool are made, reviewed
and approved in accordance with
any conditions or requirements in the
transaction agreements.
1122(d)(4)(iv) Payments on pool assets, including any NA NA NA NA NA
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.
1122(d)(4)(v) The servicer's records regarding the NA NA NA NA NA
pool assets agree with the servicer's
records with respect to an obligor's
unpaid principal balance
1122(d)(4)(vi) Changes with respect to the terms or NA NA NA NA NA
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 related pool
asset documents.
1122(d)(4)(vii) Loss mitigation or recovery actions APPL APPL APPL APPL APPL
(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
time frames or other requirements
established by the transaction
agreements.
1122(d)(4)(viii) Records documenting collection efforts NA NA NA NA NA
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.,
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illness or unemployment).
1122(d)(4)(ix) Adjustments to interest rates or rates NA NA NA NA NA
of return for pool assets with variable
rates are computed based on the related
pool asset documents.
1122(d)(4)(x) Regarding any funds held in trust for NA NA NA NA NA
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 were 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.
1122(d)(4)(xi) Payments made on behalf of an obligor NA NA NA NA NA
(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.
1122(d)(4)(xii) Any late payment penalties in NA NA NA NA NA
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.
1122(d)(4)(xiii) Disbursements made on behalf of an NA NA NA NA NA
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
1122(d)(4)(xiv) Delinquencies, charge-offs and NA NA NA NA NA
uncollectible accounts are recognized and
recorded in accordance with the
transaction agreements
1122(d)(4)(xv) Any external enhancement or other NA NA NA NA NA
support, identified in Item
1114(a)(1) through (3) or Item 1115 of
Regulation AB, is maintained as set
forth in the transaction agreements.
Note 1: The criteria marked as "APPL" is applicable for the related securitization transaction; however, there are no
specially serviced loans serviced under the related securitization transaction during the reporting period.
Therefore, no trust/operating advisor actions were required.
Note 2: With respect to those servicing criteria marked as "NA", the criteria were not within the scope of the Asserting
Party's duties in the related securitization transaction.
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Exhibit B
Asserting Party's 2012 Servicing Platform by Issuer and Master Servicer
Depositor Public Name of Securitization Master Servicer Period of Service
Deutsche Mortgage & Asset COMM 2012-LC4 Commercial Mortgage Wells Fargo Bank, March 20, 2012-
Receiving Corporation Pass-Through Certificates National Association December 31, 2012
Deutsche Mortgage & Asset COMM 2012-CCRE2 Commercial Wells Fargo Bank, August 22, 2012-
Receiving Corporation Mortgage Pass-Through Certificates National Association December 31, 2012
UBS Commercial Mortgage UBS-Barclays Commercial Mortgage Midland Loan September 27, 2012-
Securitization Corp. Trust 2012-C3, Commercial Mortgage Services, a division of December 31, 2012
Pass-Through Certificates, Series 2012-C3 PNC Bank, National
Association
Deutsche Mortgage & Asset COMM 2012-CCRE4 Commercial Wells Fargo Bank, November 13, 2012-
Receiving Corporation Mortgage Pass-Through Certificates National Association December 31, 2012
Deutsche Mortgage & Asset COMM 2012-CCRE5 Commercial Midland Loan December 13, 2012-
Receiving Corporation Mortgage Pass-Through Certificates Services, a division of December 31, 2012
PNC Bank, National
Association
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