Attached files
Exhibit 33.17 |
Management's Certification Regarding Compliance with Applicable Servicing Criteria on SEC Regulation AB
1. |
Torchlight Loan Services, LLC's (the "Company") management 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 ended December 31, 2019 (the "Reporting Period"), as set forth in Appendix A hereto. The transactions covered by this report include commercial mortgage-backed securities transactions that were issued on or after December 1, 2002 and that were registered with the SEC pursuant to the Securities Act of 1933, for which the Company acted as special servicer (the "Platform"); |
2. |
The commercial mortgage-backed securities transactions covered by this Platform, as of and for the 12-month period ended December 31, 2019 are included in Appendix B hereto; |
3. |
Except as set forth in paragraph 4 below, the Company used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria; |
5. |
The Company has complied, in all material respects, with the applicable servicing criteria as of and for the 12-month period ended December 31, 2019 and for the Reporting Period with respect to the Platform taken as a whole; and |
6. |
CohnReznick LLP, an independent registered public accounting firm, has issued an attestation report on the Company's assessment of compliance with the applicable servicing criteria for the Reporting Period. |
February 19, 2020 |
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Torchlight Loan Services, LLC |
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By: |
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/s/ William S. Clarkson |
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Name: |
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William A. Clarkson |
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Title: |
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Authorized Signatory |
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Appendix A
Servicing Criteria |
Applicable |
INAPPLICABLE |
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Reference |
Criteria |
Performed Directly Loan Services |
Performed by Vendor(s) for which Torchlight Loan Services is the Responsible Party |
Performed by subservicer(s) or vendor(s) for which Torchligh Loan Services Is NOT the Responsible Party |
NOT performed by Torchlight Loan Services or by subservicer(s) or vendor(s) retained by Torchlight Loan Services |
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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. |
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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 |
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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 following 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 overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements. |
X |
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Appendix A
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Appendix A
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Appendix A
Servicing Criteria |
Applicable |
INAPPLICABLE |
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Reference |
Criteria |
Performed Directly Loan Services |
Performed by Vendor(s) for which Torchlight Loan Services is the Responsible Party |
Performed by subservicer(s) or vendor(s) for which Torchligh Loan Services Is NOT the Responsible Party |
NOT performed by Torchlight Loan Services or by subservicer(s) or vendor(s) retained by Torchlight Loan Services |
Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents. |
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X |
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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. |
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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. |
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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. |
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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. |
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X |
1122(d)(4)(xiv) |
Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements. |
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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. |
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X |
i This criterion is applicable but the Asserting Party does not keep unissued checks.
ii This criterion is not applicable as the Asserting Party does not routinely accept or process payments directly.
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Appendix B
REG AB - Schedule I |
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Transaction ID |
Transaction (Full Name) |
Certification Restrictions (if any) |
BACM 2004-5 |
Banc of America Commercial Mortgage Inc. |
Deal terminated naturally as of August 2019 payment date. |
BACM 2006-1 |
Banc of America Commercial Mortgage Inc. |
Certification excludes the Torre Mayor Whole Loan and the KinderCare Portfolio Whole Loan. |
BANK 2018-BN10 |
WELLS FARGO COMMERCIAL MORTGAGE SECURITIES, |
Certification excludes the Extra Space Self Storage |
BANK 2018-BN13 |
WELLS FARGO COMMERCIAL MORTGAGE SECURITIES, INC., |
Certification excludes the 1745 Broadway, Plaza Frontenac, Fair Oaks Mall, 181 Fremont Street, Shoppes at Chino Hills, and CoolSprings Galleria Whole Loans |
BBCMS 2018-RRI |
BBCMS Trust 2018-RRI |
None |
BBSG 2016-MRP |
BBSG 2016-MRP Mortgage Trust, |
None |
BSCMS 2005-PW10 |
Bear Stearns Commercial Mortgage Securities II Inc., |
None |
CGCMT 2004-C2 |
Citigroup Commercial Mortgage Securities, Inc. |
Deal terminated naturally as of October 2019 payment date. |
CGCMT 2015-GC31 |
CITIGROUP COMMERCIAL MORTGAGE SECURITIES INC., |
Certification excludes the Selig Office Portfolio, Dallas Market Center and Crowne Plaza Bloomington Whole Loans. |
COMM 2014-CCRE20 |
COMM 2014-CCRE20 Commercial Mortgage Pass-Through Certificates |
Certification excludes the 80 and 90 Maiden Lane Loan Combination, the Beverly Connection Loan Combination, and the Myrtle Beach Marriott Resort & Spa Loan Combination. |
COMM 2014-UBS5 |
COMM 2014-UBS5 Commercial Mortgage Pass-Through Certificates |
Certification is restricted to the Harwood Center Whole Loan. |
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Appendix B
Transaction ID |
Transaction (Full Name) |
Certification Restrictions (if any) |
CSAIL 2016-C6 |
CSAIL 2016-C6 Commercial Mortgage Trust, |
Certification excludes the GLP Industrial Portfolio A Mortgage Loan, the GLP Industrial Portfolio B Mortgage Loan, the Quaker Bridge Mall Mortgage Loan, and the Starwood Capital Extended Stay Portfolio Mortgage Loan. |
CSFB 2003-C5 |
Credit Suisse First Boston Mortgage Securities Corp. |
None |
CSMC 2007-C2 |
Credit Suisse Commercial Mortgage Trust |
Certification excludes the 599 Lexington Avenue Whole Loan. |
CSMC 2016-NXSR |
Credit Suisse Commercial Mortgage Trust |
Certification excludes the Gurnee Mills Mortgage Loan, the QLIC Mortgage Loan, the Wolfchase Galleria Mortgage Loan, the Federal Way Crossings Mortgage Loan and the 681 Fifth Avenue Mortgage Loan. |
FREMF 2014-K39 |
CITIBANK, N.A., AS TRUSTEE FOR THE REGISTERED |
None |
GMACC 2004-C2 |
GMAC Commercial Mortgage Securities, Inc., |
None |
GSMS 2016-GS2 |
GS Mortgage Securities Trust 2016-GS2 |
Certification excludes the Veritas Multifamily Pool 1 Mortgage Loan. |
JPMBB 2015-C28 |
JPMBB COMMERCIAL MORTGAGE SECURITIES TRUST |
Certification excludes the Houston Galleria, One Campus Martius, The Club Row Building and the Shaner Hotels Portfolio Whole Loans. |
JPMBB 2015-C30 |
JPMBB COMMERCIAL MORTGAGE SECURITIES TRUST |
Certification excludes the One City Centre, Marriott - Pittsburgh and JAGR Portfolio Whole Loans. |
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Appendix B
Transaction ID |
Transaction (Full Name) |
Certification Restrictions (if any) |
JPMBB COMMERCIAL MORTGAGE SECURITIES TRUST |
Certification excludes the New Center One Building Mortgage Loan. |
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JPMCC 2002-C3 |
J.P. Morgan Chase Commercial Mortgage Securities Corp. |
None |
JPMCC 2004-LN2 |
J.P. Morgan Chase Commercial Mortgage Securities Corp. |
None |
JPMCC 2006-LDP6 |
J.P. Morgan Chase Commercial Mortgage Securities Trust 2006-LDP6 Commercial Mortgage Pass-Through Certificates, |
None |
JPMCC 2011-C5 |
J.P. Morgan Chase Commercial Mortgage Securities Trust 2011-C5 |
None |
JPMCC 2014-C20 |
J.P. Morgan Chase Commercial Mortgage Securities Trust 2014-C20 |
Certification excludes the Outlets at Orange Whole Loan, the Gumberg Retail Portfolio Whole Loan, the 470 Vanderbilt Avenue Whole Loan, and the Westminster Mall Whole Loan. |
JPMCC 2016-JP3 |
J.P. Morgan Chase Commercial Mortgage Securities Trust 2016-JP3 |
Certification excludes the 9 West 57th Street Whole Loan, the 693 Fifth Avenue Whole Loan, the Opry Mills Whole Loan, the Westfield San Francisco Centre Whole Loan, the Crocker Park Phase One & Two Whole Loan, the 100 East Wisconsin Avenue Whole Loan, and the West LA Office - 1950 Sawtelle Boulevard Whole Loan. |
MLMT 2005-MKB2 |
Merrill Lynch Mortgage Investors, Inc. |
Deal terminated naturally as of September 2019 payment date. |
MSCI 2011-C1 |
MORGAN STANLEY CAPITAL I INC., COMMERCIAL |
Certification is restricted to the period which Torchlight served as Special Servicer, from January 9, 2019 to December 31, 2019. |
WBCMT 2003-C7 |
Wachovia Bank Commercial Mortgage Trust |
None |
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Appendix B
Transaction ID |
Transaction (Full Name) |
Certification Restrictions (if any) |
Wachovia Bank Commercial Mortgage Trust |
None |
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WBCMT 2004-C15 |
Wachovia Bank Commercial Mortgage Trust |
None |
WBCMT 2007-C33 |
Wachovia Bank Commercial Mortgage Trust |
Certification excludes the 666 Fifth Avenue Loan, the Sawgrass Mills Loan, and the Potomac Mills Loan. |
WWCAP 2005-1A |
Wrightwood Capital Real Estate CDO 2005-1, Ltd. |
None |
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