1.

Situs Holdings, LLC (the "Company" or "Situs"), 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, 2019 (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 acted as a 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 assess the 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 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, 2019.

5.

During the Reporting Period, there were no active assets carrying an escrow balance maintained by Situs or escrow disbursements due to be paid by Situs, 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, 2019. The only portfolio active during any part of the year ended December 31, 2019 to which these criterion are required to be considered per the corresponding transaction agreement was CSMC 2006-C1.

6.

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, 2019. The only portfolio active during any part of the year ended December 31, 2019 to which this criteria is required to be considered per the corresponding transaction agreement was CSMC 2006-C1.

7.

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.

8.

The Company has complied, in all material respects, with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB, as of December 31, 2019 and for the Reporting Period with respect to the Platform taken as a whole.

9.

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.

  /s/ George Wisniewski

George Wisniewski

Executive Managing Director

SERVICINGCRITERIA

APPLICABLESERVICING CRITERIA

INAPPLICABLE SERVICINGCRITERIA

Reference

Criteria

Performed Directlyby Situs

Performedby Vendor(s)for whichSitusis the Responsible Party

Performedby subservicer(s) orVendor(s) forwhich SitusisNOT the Responsible Party

NOT performedby Situsorby subservicer(s) orVendor(s) retainedby Situs

General Servicing Considerations

1122(d)(1)(i)

Policies and procedures are instituted to monitor any performance or other triggers andeventsof defaultin accordance with the transactionagreements.

X

1122(d)(1)(ii)

If any materialservicing activities are outsourcedto third parties,policies andprocedures are institutedto monitor the thirdparty's performanceandcompliancewithsuch servicing activities.

X

1122(d)(1)(iii)

Any requirements inthe transactionagreements to maintain aback-upservicer for the poolassetsaremaintained.

X

1122(d)(1)(iv)

Afidelitybondanderrors andomissions policyisin effect onthe partyparticipatingin theservicing function throughout the reporting period intheamountofcoverage requiredbyandotherwiseinaccordancewiththeterms of thetransaction agreements.

X

1122(d)(1)(v)

Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.

X

CashCollectionandAdministration

1122(d)(2)(i)

Payments onpool assetsare deposited into the appropriate custodial bank accounts and relatedbankclearing accounts no more than two businessdays of receipt, or such other number of days specified in the transactionagreements.

X

1122(d)(2)(ii)

Disbursements made viawire transfer on behalf of anobligor or to an investor are made onlybyauthorizedpersonnel.

X

1122(d)(2)(iii)

Advances of funds or guarantees regarding collections,cash flows or distributions,andany interestor other fees charged for such advances,are made,reviewedandapprovedas specified inthe transactionagreements.

X

SERVICING CRITERIA

APPLICABLESERVICING CRITERIA

INAPPLICABLE SERVICINGCRITERIA

Reference

Criteria

Performed Directlyby Situs

Performedby Vendor(s)for which Situs is the Responsible Party

Performedby subservicer(s) orVendor(s) forwhich Situs isNOT the Responsible Party

NOT performedby Situs orby subservicer(s) orVendor(s) retainedby Situs

1122(d)(2)(iv)

The relatedaccounts for thetransaction,suchas cashreserve accounts or accounts establishedas aform of over collateralization,areseparatelymaintained(e.g.,withrespect to commingling of cash) as setforth inthetransaction agreements.

X

1122(d)(2)(v)

Eachcustodialaccountismaintainedatafederallyinsured depositoryinstitution assetforth inthetransaction agreements.For purposes of thiscriterion,"federallyinsured depositoryinstitution" withrespect toaforeignfinancial institutionmeans a foreignfinancial institution thatmeets the requirements of240.13k-1(b)(1) ofthis chapter.

X

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.

X

1122(d)(2)(vii)

Reconciliationsareprepared ona monthlybasis for allasset- backed securities relatedbank accounts,including custodial accounts andrelatedbankclearingaccounts.These reconciliations: (A)Aremathematicallyaccurate; (B) Are preparedwithin30 calendardays after thebank statement cutoff date, or such othernumber of days specifiedin the transaction agreements; (C) Arereviewedandapprovedby someone other thanthepersonwho preparedthe reconciliation;and(D)Containexplanationsfor reconciling items. These reconciling items are resolvedwithin90 calendardays of their original identification, or such other number of days specifiedin thetransactionagreements.

X¹

X¹

InvestorRemittancesandReporting

1122(d)(3)(i)

Reports toinvestors, including those to be filedwiththe Commission,aremaintained inaccordancewith the transaction agreements and applicableCommission requirements. Specifically, suchreports:(A)Arepreparedin accordancewithtimeframes andother terms set forth inthe transaction agreements; (B)Provide informationcalculated inaccordancewiththeterms specifiedin thetransaction agreements; (C) Are filedwiththeCommissionasrequired byits rules and regulations;and(D)Agree withinvestors' or thetrustee's records asto thetotal unpaid principalbalance andnumber of poolassets servicedbytheservicer.

X³

¹ 

Servicing activities associated with criterion 1122(d)(2)(vii) are performed by Situs and a third party vendor for which Situs is the responsible party.

² 

For criterion 1122(d) (3)(i)(B-D), Situs 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. No assessment of compliance, therefore, is necessary.

SERVICING CRITERIA

APPLICABLESERVICING CRITERIA

INAPPLICABLE SERVICINGCRITERIA

Reference

Criteria

Performed Directlyby Situs

Performedby Vendor(s)for whichSitus is the Responsible Party

Performedby subservicer(s) orVendor(s) forwhich Situs isNOT the Responsible Party

NOT performedby Situs orby subservicer(s) orVendor(s) retainedby Situs

1122(d)(3)(ii)

Amountsdueto investors areallocatedandremittedin accordancewithtimeframes,distributionpriority and other terms setforthin thetransactionagreements.

X

1122(d)(3)(iii)

Disbursements made toaninvestor are postedwithintwo business days to the servicer's investor records,or such other number ofdays specified in the transactionagreements.

X

1122(d)(3)(iv)

Amounts remittedto investors per the investor reports agree withcancelledchecks, or other formof payment,or custodial bank statements.

X

PoolAssetAdministration

1122(d)(4)(i)

Collateral or securityonpoolassets ismaintainedas required bythetransactionagreements or relatedpoolasset documents.

X

1122(d)(4)(ii)

Pool assets andrelated documentsare safeguarded as required bythe transaction agreements.

X

1122(d)(4)(iii)

Any additions, removals or substitutionsto theassetpoolare made,reviewedandapprovedinaccordancewithany conditionsor requirementsinthetransactionagreements.

X

1122(d)(4)(iv)

Payments onpool assets, includinganypayoffs,made in accordance with the relatedpool asset documentsare posted to the applicable servicer's obligor records maintained no more thantwo business days after receipt, or such other number of days specified in the transactionagreements, and allocated toprincipal,interestor other items (e.g.,escrow) in accordance with the relatedpool asset documents.

X

1122(d)(4)(v)

Theservicer's records regardingthepoolassets agreewith theservicer's records withrespecttoanobligor's unpaid principal balance.

X

SERVICING CRITERIA

APPLICABLESERVICING CRITERIA

INAPPLICABLE SERVICINGCRITERIA

Reference

Criteria

Performed Directlyby Situs

Performedby Vendor(s)for whichSitus is the Responsible Party

Performedby subservicer(s) orVendor(s) forwhich Situs isNOT the Responsible Party

NOT performedby Situs orby subservicer(s) orVendor(s) retainedby Situs

1122(d)(4)(vi)

Changes with respectto theterms or status ofan obligor's mortgage loans (e.g., loanmodifications or re-aging's) are made, reviewedandapprovedbyauthorizedpersonnelin accordancewith thetransactionagreements andrelatedpool asset documents.

X

1122(d)(4)(vii)

Loss mitigation or recoveryactions (e.g.forbearanceplans, modifications and deeds in lieuof foreclosure,foreclosure andrepossessions,as applicable) areinitiated,conductedand concludedin accordancewiththetimeframes or other requirements establishedbytheatransactionagreements.

X

1122(d)(4)(viii)

Recordsdocumenting collection efforts aremaintained duringtheperiodapoolasset isdelinquentin accordance withthetransaction agreements. Such records aremaintained onat least amonthlybasis, or suchother periodspecifiedin thetransaction agreements, anddescribe theentity's activities inmonitoringdelinquentpoolassets including, for example, phonecalls, letters andpayment rescheduling plans incases wheredelinquencyisdeemedtemporary(e.g., illness or unemployment).

X

1122(d)(4)(ix)

Adjustmentsto interestrates or ratesof returnfor poolassets withvariable rates arecomputedbasedon the relatedpool assetdocuments.

X

1122(d)(4)(x)

Regarding anyfundsheldintrust for anobligor (suchas escrowaccounts) See following:(A) Suchfundsare analyzed, inaccordancewith the obligor's poolasset documents, onat least anannualbasis, or such otherperiod specified inthetransactionagreements; (B) Interest onsuch fundsispaid, or credited,to obligors inaccordancewith applicablepoolassetdocumentsandstate laws; and (C) Such fundsare returnedto the obligor within30 calendardays of full repayment of the relatedpoolasset, or suchother number of days specifiedin thetransactionagreements.

X⁴

1122(d)(4)(xi)

Payments made on behalf of an obligor (such astax or insurancepayments) are made onorbefore the related penaltyor expiration dates,asindicatedon the appropriate bills or notices for such payments, provided that such support hasbeenreceivedbythe servicer atleast 30calendar days prior tothese dates,or suchother number of days specified in thetransactionagreements.

X³

1122(d)(4)(xii)

Any latepayment penalties inconnectionwithany payment to bemade onbehalf of anobligor arepaidfrom the servicer's fundsandnotchargedto the obligor, unless the latepaymentwas dueto the obligor's error or omission.

X³

³ 

Servicing activities associated with criteria 1122(d)(4)(x-xiii) are only in-scope for the 'CSMC-2006 C1' portfolio. These servicing criteria are inapplicable for all other servicing criteria for all other portfolios on the Platform. Refer to Appendix B of this Management's Assertion for the in-scope portfolios.

SERVICING CRITERIA

APPLICABLESERVICING CRITERIA

INAPPLICABLE SERVICINGCRITERIA

Reference

Criteria

Performed Directlyby Situs

Performedby Vendor(s)for whichSitus is the Responsible Party

Performedby subservicer(s) orVendor(s) forwhich Situs isNOT the Responsible Party

NOT performedby Situs orby subservicer(s) orVendor(s) retainedby Situs

1122(d)(4)(xiii)

Disbursements made on behalf of anobligor are posted withintwo business days to the obligor's records maintained bythe servicer,or suchother number of days specified in the transaction agreements.

X³

1122(d)(4)(xiv)

Delinquencies, charge-offs and uncollectible accountsare recognizedandrecorded in accordance withthe transaction agreements.

X⁵

1122(d)(4)(xv)

Any externalenhancement or other support,identified in Item 1114(a) (1) through (3) or Item 1115ofthisRegulation AB,is maintainedassetforth inthe transaction agreements.

X

³ Servicing activities associated with criteria 1122(d)(4)(x-xiii) are only in-scope for the 'CSMC-2006 C1' portfolio. These servicing criteria are inapplicable for all other servicing criteria for all other portfolios on the Platform. Refer to Appendix B of this Management's Assertion for the in-scope portfolios.

⁴ 

Servicing activities associated with criterion 1122(d)(4)(xiv) is only in-scope for the 'CSMC-2006 C1' portfolio. This criteria is an inapplicable servicing criteria for all other portfolios on the Platform. Refer to Appendix B of this Management's Assertion for the in-scope portfolios.

Portfolio

Servicing Agreement Date

Active for any part of the

Year Ended 12/31/2019

Banc of California 2019-Q010

July 1, 2019

BANK 2019-BNK18

May 1, 2019

BBCMS 2019-C4

August 1, 2019

Benchmark 2019-B12

August 1, 2019

BFLD 2019-DPLO

October 9, 2019

BSPRT 2018-FL3

April 5, 2018

BSPRT 2018-FL4

October 12, 2018

BSPRT 2019-FL5

May 30, 2019

BWAY 2019-1633

December 20, 2019

BX 2019-CALM

December 12, 2019

BX 2019-OC11

December 1, 2019

CAF 2016-1

May 1, 2016

X

CAF 2016-2

November 15, 2016

X

CAF 2018-1

June 9, 2018

X

CAF 2019-1

April 9, 2019

X

CAF 2019-2

July 9, 2019

X

CAF 2019-3

November 9, 2019

CGCMT 2019-GC41

August 1, 2019

COMM 2007-C9

August 1, 2007

X

COMM 2013-CCRE7

April 1, 2013

X

COMM 2013-CCRE11

October 1, 2013

X

COMM 2019-521F

June 20, 2019

COMM 2019-WCM

October 30, 2019

CSAIL 2019-C18

December 1, 2019

CSMC 2006-C1

March 1, 2006

X

CSMC 2019-ICE4

June 5, 2019

DBGS 2019-1735

April 6, 2019

First Foundation 2018-Q007

September 1, 2018

First Foundation 2019-Q011

September 1, 2019

First Republic 2018-Q008

December 1, 2018

FMBT 2019-FBLU

December 6, 2019

FREMF 2017-K67

September 1, 2017

FRESB 2015-SB8

November 1, 2015

FRESB 2016-SB19

July 1, 2016

FRESB 2019-SB60

March 1, 2019

Great Wolf Trust 2019-WOLF

December 30, 2019

GSMS 2019-70P

October 23, 2019

HBST 2015-HBS

November 1, 2015

Hudson Yards 2019-30HY

July 6, 2019

JPMCC 2019-ICON

April 1, 2019

JPMCC 2019-MFP

July 18, 2019

JPMCC 2019-OSB

June 13, 2019

KNDL 2019-KNSQ

May 30, 2019

LBS 2017-Q004

September 1, 2017

LNCR 2019-CRE2

May 30, 2019

LNCR 2019-CRE3

May 30, 2019

LoanCore 2018-CRE1

June 5, 2018

MARG 2019-MARG

May 30, 2019

MBRT 2019-MBR

December 19, 2019

MEZZ CAP 2006-C4

December 1, 2006

X

MEZZ CAP 2007-C5

January 1, 2008

X

MFTII 2019-B3B4

July 11, 2019

MSC 2011-C2

June 1, 2011

X

MSC 2019-L3

November 1, 2019

NCMS 2019-LVL

April 23, 2019

NCMS 2019-NEMA

March 29, 2019

Opus Bank 2016-Q003

December 1, 2016

PRIMA 2019-1S

August 23, 2019

PRIMA 2019-RK1

June 27, 2019

PRIMA 2019-VII

October 22, 2019

Selkirk 1

December 13, 2013

Selkirk 2

December 13, 2013

Selkirk 3

September 26, 2014

SGCP 2019-FL2

June 5, 2019

SLIDE 2018-FUN

September 28, 2018

TPG 2018-FL2

November 29, 2018

TPG 2019-FL3

October 25, 2019

UBS 2019-C16

April 1, 2019

UBS 2019-C18

December 1, 2019

WBCMT 2005-C18

May 1, 2005