GS Mortgage Securities Trust 2012-GCJ9 - FORM 10-K - EX-33 - 33.2 RIALTO CAPITAL ADVISORS, LLC, AS SPECIAL SERVICER - March 31, 2014

Attached files

file filename
EX-35 - 35.2 RIALTO CAPITAL ADVISORS, LLC, AS SPECIAL SERVICER - GS Mortgage Securities Trust 2012-GCJ9ex35_2rialto2012gcj9.htm
EX-34 - 34.5 CORELOGIC COMMERCIAL REAL ESTATE SERVICES, INC., AS SERVICING FUNCTION PARTICIPANT - GS Mortgage Securities Trust 2012-GCJ9ex34_5corelogic.htm
EX-34 - 34.1 WELLS FARGO BANK, NATIONAL ASSOCIATION, AS MASTER SERVICER - GS Mortgage Securities Trust 2012-GCJ9ex34_1wellsfargomastserv.htm
EX-35 - 35.5 MIDLAND LOAN SERVICES, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION, AS SPECIAL SERVICER FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN PRIOR TO DECEMBER 16, 2013 - GS Mortgage Securities Trust 2012-GCJ9ex35_5midlandgoldman.htm
EX-33 - 33.3 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, CERTIFICATE ADMINISTRATOR AND CUSTODIAN - GS Mortgage Securities Trust 2012-GCJ9ex33_3usb1122manassert.htm
EX-34 - 34.2 RIALTO CAPITAL ADVISORS, LLC, AS SPECIAL SERVICER - GS Mortgage Securities Trust 2012-GCJ9ex34_2rialto.htm
EX-33 - 33.1 WELLS FARGO BANK, NATIONAL ASSOCIATION, AS MASTER SERVICER - GS Mortgage Securities Trust 2012-GCJ9ex33_1wellsfargo.htm
EX-34 - 34.3 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, CERTIFICATE ADMINISTRATOR AND CUSTODIAN - GS Mortgage Securities Trust 2012-GCJ9ex34_3usbaccountantsattest.htm
EX-33 - 33.5 CORELOGIC COMMERCIAL REAL ESTATE SERVICES, INC., AS SERVICING FUNCTION PARTICIPANT - GS Mortgage Securities Trust 2012-GCJ9ex33_5corelogic1122.htm
EX-34 - 34.4 PENTALPHA SURVEILLANCE, LLC, AS OPERATING ADVISOR - GS Mortgage Securities Trust 2012-GCJ9ex34_4pentalphaaccounts.htm
EX-34 - 34.10 SITUS HOLDINGS, LLC, AS OPERATING ADVISOR FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN - GS Mortgage Securities Trust 2012-GCJ9ex34_10situsopadgcj9.htm
EX-33 - 33.4 PENTALPHA SURVEILLANCE, LLC, AS OPERATING ADVISOR - GS Mortgage Securities Trust 2012-GCJ9ex33_4pentalphamanassert.htm
EX-34 - 34.9 CITIBANK, N.A., AS CERTIFICATE ADMINISTRATOR AND CUSTODIAN FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN - GS Mortgage Securities Trust 2012-GCJ9ex34_9citigaccountnts.htm
EX-35 - 35.6 CITIBANK, N.A., AS CERTIFICATE ADMINISTRATOR AND CUSTODIAN FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN - GS Mortgage Securities Trust 2012-GCJ9ex35_6citgroupgs.htm
EX-33 - 33.8 MIDLAND LOAN SERVICES, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION, AS SPECIAL SERVICER FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN PRIOR TO DECEMBER 16, 2013 - GS Mortgage Securities Trust 2012-GCJ9ex33_8midland.htm
EX-35 - 35.4 WELLS FARGO BANK, NATIONAL ASSOCIATION, AS PRIMARY SERVICER FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN - GS Mortgage Securities Trust 2012-GCJ9ex35_4wells1123cg12cg8forgs.htm
EX-35 - 35.3 U.S. BANK NATIONAL ASSOCIATION, AS CERTIFICATE ADMINISTRATOR - GS Mortgage Securities Trust 2012-GCJ9ex35_3usb12gcj9.htm
EX-35 - 35.1 WELLS FARGO BANK, NATIONAL ASSOCIATION, AS MASTER SERVICER - GS Mortgage Securities Trust 2012-GCJ9ex35_1wellsfargogcj9.htm
EX-33 - 33.6 NATIONAL TAX SEARCH, LLC, AS SERVICING FUNCTION PARTICIPANT - GS Mortgage Securities Trust 2012-GCJ9ex33_6nationaltaxsearch.htm
EX-33 - CITIBANK, N.A., AS CERTIFICATE ADMINISTRATOR AND CUSTODIAN FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN - GS Mortgage Securities Trust 2012-GCJ9ex33_9citiassertion.htm
EX-34 - 34.6 NATIONAL TAX SEARCH, LLC, AS SERVICING FUNCTION PARTICIPANT - GS Mortgage Securities Trust 2012-GCJ9ex34_6nationaltaxsearch.htm
10-K - GS MORTGAGE SECURITIES TRUST 2012-GCJ9 FORM 10-K - GS Mortgage Securities Trust 2012-GCJ9gsmsc2012gcj9_10K_122013.htm
EX-33 - 33.10 SITUS HOLDINGS, LLC, AS OPERATING ADVISOR FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN - GS Mortgage Securities Trust 2012-GCJ9ex33_10situsopadassert.htm
EX-34 - 34.8 MIDLAND LOAN SERVICES, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION, AS SPECIAL SERVICER FOR THE GANSEVOORT PARK AVENUE MORTGAGE LOAN PRIOR TO DECEMBER 16, 2013 - GS Mortgage Securities Trust 2012-GCJ9ex34_8midlandaccount.htm


1.     Rialto Capital Advisors, LLC ("Rialto"), the Special Servicer in the agreements listed on
Exhibit 1 (the "Servicing Agreements"), is responsible for assessing compliance with the
servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, for the
period from January 1, 2013, up to and including December 31, 2013 (the "Reporting Period"),
as set forth in Appendix A hereto. The transactions covered by this report include the
transactions listed on Exhibit 1 that are commercial mortgage-asset backed securities
transactions for which Rialto acted as Special Servicer on or after January 1, 2013, or for the
Applicable Certification Period as listed on Exhibit 1 (the "Platform"), and were registered after
January 1, 2006, with the Securities and Exchange Commission pursuant to the Securities Act of
1933.

2.     Rialto has engaged certain vendors (the "Vendors") to perform specific, limited, or
scripted activities, and Rialto 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. Rialto has determined its Vendors are not "servicers" as defined in
Item 1101 (j) of Regulation AB and asserts that it has policies and procedures in place to provide
reasonable assurance that the Vendors' activities comply, in all material respects, with the
servicing criteria applicable to each vendor;

3.     Except as set forth in paragraph 4 below, Rialto 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 Rialto based on the activities it performs, directly or through its
Vendors, with respect to the Platform;

5.     Rialto 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.     Rialto 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.     Rialto 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.     NDB Accountants & Consultants LLP, a registered public accounting firm, has issued an
attestation report on Rialto's assessment of compliance with the applicable servicing criteria for
the Reporting Period.

Agreements Applicable Certification Period
WFRBS 2012-C8 January 1, 2013, to December 31,2013
FDIC 2012-C1 January 1, 2013, to December 31,2013
WFCM 2012-LC5 January 1, 2013, to December 31,2013
UBS 2012-C3 January 1, 2013, to December 31,2013
UBS 2012-C4 January 1, 2013, to December 31,2013
GSMS 2012-GCJ9 January 1, 2013, to December 31,2013
JPMCC 2012-LC9 January 1, 2013, to December 31,2013
COMM 2013-LC6 January 30, 2013, to December 31,2013
WFRBS 2013-C12 March 20, 2013, to December 31,2013
UBS 2013-C6 April 25, 2013, to December 31,2013
GSMS 2013-GCJ12 May 30, 2013, to December 31,2013
WFRBS 2013-C14 June 6, 2013, to December 31,2013
WFRBS 2011-C5 June 19, 2013, to December 31,2013
WFCM 2013-LC12 July 30, 2013, to December 31,2013
WFRBS 2011-C2 August 22, 2013, to December 31,2013
WFRBS 2011-C3 August 22, 2013, to December 31,2013
WFRBS 2011-C4 August 22, 2013, to December 31,2013
UBS 2011-C1 August 30, 2013, to December 31,2013
UBS 2012-C1 August 30, 2013, to December 31,2013
WFRBS 2012-C6 August 30, 2013, to December 31,2013
GSMS 2011-GC3 September 4, 2013, to December 31,2013
COMM 2013-LC13 September 27, 2013, to December 31,2013
WFRBS 2013-C16 September 30, 2013, to December 31,2013
GSMS 2013-GCJ16 November 20, 2013, to December 31,2013
WFRBS 2013-C17 November 20, 2013, to December 31,2013
GSMS 2012-GC6 October 18, 2013, to December 31,2013
MSBAM 2013-C13 December 18, 2013, to December 31,2013


Management's Assertion on Compliance
SERVICING CRITERIA
Reference Criteria Performed by Servicer Inapplicable Servicing Criteria
General Servicing Criteria
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
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 following receipt, or such other number of days specified in the transaction agreements. X1
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
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. 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 Rule 13k-1(b)(1) of the Securities Exchange Act. 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 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 transaction agreements. X

SERVICING CRITERIA
Reference Criteria Performed by Servicer Inapplicable Servicing Criteria
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
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 mortgage loan documents. X
1122(d)(4)(ii) [pool asset] 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 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. X3
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
1122(d)(4)(vi) Changes with respect to the terms or 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. X
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. 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


Management's Assertion on Compliance

SERVICING CRITERIA
Reference Criteria Performed by Servicer Inapplicable Servicing Criteria
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): (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 transaction agreements. X
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. X
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. X
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. X
1122(d)(4)(xiv) Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements. X
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. X


Rialto performs the activities pertaining to these criteria, except for specific, limited activities performed by its third party
property managers relating to REO Property, if any. Rialto has elected to take responsibility for assessing compliance with
these servicing criteria with respect to the activities of its third party property managers.


Only items (A) and (B) of the Servicing Criteria are applicable to Rialto Capital Advisors, LLC as special servicer. Items (C)
and (D) are inapplicable as the responsibility for filing reports with the Commission and agreeing totals to the Servicer
records rests with the Trustee and/or Certificate Administrator, as applicable.


Primary responsibility for processing borrower payments rests with the Master Servicer, however, Rialto Capital Advisors,
LLC may from time to time receive payments on an exception basis which are forwarded to the Master Servicer in
accordance with such criterion.