Trimont Real Estate Advisors, LLC

Management’s Report on Assessment of Compliance
with SEC Regulation AB Servicing Criteria

 

Trimont Real Estate Advisors, LLC (“the Asserting Party”) is responsible for assessing compliance as of and for the year ended December 31, 2020 (“the Reporting Period”) with the applicable servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB as set forth in Exhibit A hereto (the “Applicable Servicing Criteria”). The transactions covered by this report are only those transactions processed by the Asserting Party in capacity in the Senior Trust Advisor, Trust Advisor, or Operating Advisor Services Platform for the asset backed securities transactions listed in Exhibit B hereto (the “Platform”).

The Asserting Party has used the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB to assess its compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that the Asserting Party has complied, in all material respects, with the Applicable Servicing Criteria as of and for the year ended December 31, 2020 with respect to the Platform.

Grant Thornton, LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Applicable Servicing Criteria as of and for the year ended December 31, 2020 as set forth in this assertion.

 

Trimont Real Estate Advisors, LLC
February 22, 2021

 

 

 

_________________________________________

Glen Peters
Chief Financial Officer

 

 

Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

General Servicing  Considerations

1122(d)(1)(i)

Policies and Procedures

Policies and procedures are instituted to monitor any performance or other triggers  and events of default in accordance with the transaction agreement.

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1122(d)(1)(ii)

Policies and Procedures (vendors)

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.

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1122(d)(1)(iii)

Back-up  Servicer

Any requirements in the transaction agreements to maintain a back-up servicer  for the pool assets are maintained.

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1122(d)(1)(iv)

Fidelity Bond

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 agreement.

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1122(d)(1)(v)

Accuracy of Information

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

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Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

Cash  Collection and Administration

1122(d)(2)(i)

2 Days to Deposit Payments into Custodial Accounts

Payments on pool assets are deposited 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.

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1122(d)(2)(ii)

Wire Transfers

Disbursements made via wire transfer  on behalf of an obligor or to an investor are made only by authorized personnel.

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1122(d)(2)(iii)

Advances

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.

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1122(d)(2)(iv)

Commingling

The related  accounts for the transaction, such  as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g. with respect to commingling of cash)  as set forth in the transaction agreements.

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Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

1122(d)(2)(v)

Federally Insured Institution

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 §240.13k-1(b)(1) of this chapter.  I.3 Each  custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor.

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1122(d)(2)(vi)

Unissued Checks

Unissued checks are safeguarded so as to prevent  unauthorized access.

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Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

1122(d)(2)(vii)

Reconciliations

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:  (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.

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N/A

Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

Investor Remittance and Reporting

1122(d)(3)(i)

Reports to the Investor

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.

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X6

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X6

1122(d)(3)(ii)

Investor Remittance

Amounts due to investors are allocated and remitted  in accordance with timeframes, distribution priority and other terms  set forth in the transaction agreements.

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1122(d)(3)(iii)

Investor's Records

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.

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1122(d)(3)(iv)

Remittance and Bank Statements

Amounts remitted  to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

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Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

Pool Asset  Administration

1122(d)(4)(i)

Collateral/Security on Pool Assets

Collateral or security on pool assets is maintained as required  by the transaction agreements or related pool asset documents.

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1122(d)(4)(ii)

Safeguard Pool Assets

Pool assets and related  documents are safeguarded as required  by the transaction agreements.

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1122(d)(4)(iii)

Changes to the Pool Assets

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.

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1122(d)(4)(iv)

Obligor's Payment Record

Payments on pool assets, including any 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.

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1122(d)(4)(v)

Pool Asset Records Match UPB

The servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid  principal balance.

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Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

1122(d)(4)(vi)

Loan Modifications

Changes with respect to the terms  or status of an obligor's pool asset (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.

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N/A

1122(d)(4)(vii)

Loss Mitigation Actions

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 agreement.

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X2

1122(d)(4)(viii)

Collection Efforts Documented

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).

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Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

1122(d)(4)(ix)

ARMs

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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1122(d)(4)(x)

Escrow Funds

Regarding any funds held in trust for an obligor such  funds are (a) 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)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.

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1122(d)(4)(xi)

Timely Payments

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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Exhibit A

 

 

Regulation AB Criteria

GSMS 2015-GC30

WFCM 2015-C27

WFCM 2015-C29

WFCM 2015-C31

WFCM 2015-LC20

WFCM 2015-NXS1

WFCM 2015-SG1

WFRBS 2014-C25

WFRBS 2014-C23

WFRBS 2014-C21

GSMS 2014-GC20

WFRBS 2014-C19

WFRBS 2013-C17

MSBAM 2013-C12

WFRBS 2013-C15

GSMS 2013-GC13

WFRBS 2013-C13

MSBAM 2013-C9

WFRBS 2013-C11

GSMS 2013-GC10

UBS 2012-C4

WFCM 2012-LC5

Section

Description

Criteria

Applicable Criteria

1122(d)(4)(xii)

Late Payment Penalties

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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1122(d)(4)(xiii)

Obligor's Records

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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1122(d)(4)(xiv)

Delinquencies, Charge-offs, and Other Uncollectible Accounts

Delinquencies, charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

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1122(d)(4)(xv)

Any External Enhancement

Any external  enhancement or other support, identified in Item 1114(a)(1) through  (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.

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Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

General Servicing  Considerations

1122(d)(1)(i)

Policies and Procedures

Policies and procedures are instituted to monitor any performance or other triggers  and events of default in accordance with the transaction agreement.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(1)(ii)

Policies and Procedures (vendors)

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(1)(iii)

Back-up  Servicer

Any requirements in the transaction agreements to maintain a back-up servicer  for the pool assets are maintained.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(1)(iv)

Fidelity Bond

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 agreement.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(1)(v)

Accuracy of Information

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

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

Cash  Collection and Administration

1122(d)(2)(i)

2 Days to Deposit Payments into Custodial Accounts

Payments on pool assets are deposited 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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(2)(ii)

Wire Transfers

Disbursements made via wire transfer  on behalf of an obligor or to an investor are made only by authorized personnel.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(2)(iii)

Advances

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(2)(iv)

Commingling

The related  accounts for the transaction, such  as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g. with respect to commingling of cash)  as set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

1122(d)(2)(v)

Federally Insured Institution

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 §240.13k-1(b)(1) of this chapter.  I.3 Each  custodial account shall be maintained at a federally insured depository institution in trust for the applicable investor.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(2)(vi)

Unissued Checks

Unissued checks are safeguarded so as to prevent  unauthorized access.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

1122(d)(2)(vii)

Reconciliations

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:  (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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

Investor Remittance and Reporting

1122(d)(3)(i)

Reports to the Investor

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.

X1

X4

X7

X1

X1

X1

X5

X1

X1

X1

X1

X3

X4

X3

X6

X1

X6

X1

X1

X1

X1

X1

1122(d)(3)(ii)

Investor Remittance

Amounts due to investors are allocated and remitted  in accordance with timeframes, distribution priority and other terms  set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(3)(iii)

Investor's Records

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(3)(iv)

Remittance and Bank Statements

Amounts remitted  to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

Pool Asset  Administration

1122(d)(4)(i)

Collateral/ Security on Pool Assets

Collateral or security on pool assets is maintained as required  by the transaction agreements or related pool asset documents.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(ii)

Safeguard Pool Assets

Pool assets and related  documents are safeguarded as required  by the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(iii)

Changes to the Pool Assets

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(iv)

Obligor's Payment Record

Payments on pool assets, including any 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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(v)

Pool Asset Records Match UPB

The servicers records regarding the pool assets agree with the servicer's records with respect to an obligor's unpaid  principal balance.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

1122(d)(4)(vi)

Loan Modifications

Changes with respect to the terms  or status of an obligor's pool asset (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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(vii)

Loss Mitigation Actions

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 agreement.

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

X2

1122(d)(4)(viii)

Collection Efforts Documented

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).

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

1122(d)(4)(ix)

ARMs

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related  pool asset documents.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(x)

Escrow Funds

Regarding any funds held in trust for an obligor such  funds are (a) 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) 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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(xi)

Timely Payments

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Exhibit A

 

 

Regulation AB Criteria

WFRBS 2012-C9

DBUBS 2011-LC3

WFRBS 2011-C5

WFCM 2016-NXS6

WFCM 2016-LC24

WFCM 2016-C37

245 Park Ave Trust 2017-245P

MSC 2017-H1

WFCM 2017-C39

WFCM 2017-RB1

WFCM 2017-C41

CFCRE 2011-C2

MSC 2011-C3

UBS CCMT 2011-C1

JPMCC 2012 CIBX

UBS 2012-C1

WFRBS 2014-LC14

CGCMT 2014-GC23

CGCMT 2016-C3

CGCMT 2017-B1

GSMS 2012-GC6

WFRBS 2012-C7

Section

Description

Criteria

Applicable Criteria

1122(d)(4)(xii)

Late Payment Penalties

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(xiii)

Obligor's Records

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.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(xiv)

Delinquencies, Charge-offs, and Other Uncollectible Accounts

Delinquencies, charge-offs, and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1122(d)(4)(xv)

Any External Enhancement

Any external  enhancement or other support, identified in Item 1114(a)(1) through  (3) or Item 1115 of this Regulation AB, is maintained as set forth in the transaction agreements.

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Key

 

X1	With respect to Item 1122(d)(3)(i), only parts A and B of this criteria are  applicable for the securitization. There were no activities performed during the reporting period for the loan(s) that were serviced under this securitization.
X2	With respect to Item 1122(d)(4)(vii), there were  no loss mitigation or recovery actions during the reporting period for the loan(s) that were serviced under this securitization.
X3	With respect to Item 1122(d)(3)(i), only parts A, B, andC are applicable. There were no activities performed during the reporting period for the loan(s) that were serviced under this securitization.
X4	With respect to Item 1122(d)(3)(i), there  were no activities performed during the reporting period for the loan(s) that were serviced under this securitization.
X5	With respect to Applicable Servicing Criteria, the securitization was not in scope based the transaction agreement.
X6	With respect to Item 1122(d)(3)(i), only parts A and B of this criteria are  applicable for the securitization.
X7	With respect to Item 1122(d)(3)(i), only parts A, B, and C of this criteria are  applicable for the securitization.
With respect to Applicable Servicing Criteria cells in Exhibit A that are denoted with an "N/A", per review of the respective servicing agreement, the criteria was not in scope for the transaction.

Exhibit B

 

 

Name	Transaction	Period of Service
DBUBS 2011-LC3	Commercial Mortgage Pass-Through Certificates, DBUBS 2011-LC3 pursuant to the Pooling and Servicing Agreement dated August  1, 2011	January 1, 2020 - December 31, 2020
WFRBS  2011-C5	Commercial Mortgage Pass-Through Certificates, WFRBS  2011-C5 pursuant to the Pooling  and Servicing Agreement dated November 1, 2011	January 1, 2020 - December 31, 2020
MSC 2011-C3	Commercial Mortgage Pass-Through Certificates, MSC 2011-C3 pursuant to the Pooling  and Servicing Agreement dated October 1, 2011	January 1, 2020 - December 31, 2020
CFCRE 2011-C2	Commercial Mortgage Pass-Through Certificates, CFCRE 2011-C2 pursuant to the Pooling and Servicing Agreement dated December 11, 2011	January 1, 2020 - December 31, 2020
UBS CCMT-2011-C1	Commercial Mortgage Pass-Through Certificates, UBS CCMT-2011 pursuant to the Pooling and Servicing Agreement dated December 1, 2011	January 1, 2020 - December 31, 2020
GSMS  2012-GC6	Commercial Mortgage Pass-Through Certificates, Series 2012-GC6 pursuant to the Pooling and Servicing Agreement dated February 1, 2012	January 1, 2020 - December 31, 2020
UBS 2012-C1	Commercial Mortgage Pass-Through Certificates, Series 2012-C1 pursuant to the Pooling  and Servicing Agreement dated May 1, 2012	January 1, 2020 - December 31, 2020
JPMCC 2012  - CIBX	Commercial Mortgage Pass-Through Certificates, Series 2012-CIBX pursuant to the Pooling and Servicing Agreement dated June 1, 2012	January 1, 2020 - December 31, 2020
WFRBS  2012-C7	Commercial Mortgage Pass-Through Certificates, Series 2012-C7 pursuant to the Pooling  and Servicing Agreement dated June 1, 2012	January 1, 2020 - December 31, 2020
WFCM 2012-LC5	Commercial Mortgage Pass-Through Certificates, Series 2012-LC5 pursuant to the Pooling and Servicing Agreement dated September 1, 2012	January 1, 2020 - December 31, 2020
WFRBS  2012-C9	Commercial Mortgage Pass-Through Certificates, Series 2012-C9 pursuant to the Pooling  and Servicing Agreement dated October 1, 2012	January 1, 2020 - December 31, 2020
UBS 2012-C4	Commercial Mortgage Pass-Through Certificates, Series 2012-C4 pursuant to the Pooling  and Servicing Agreement dated December 1, 2012	January 1, 2020 - December 31, 2020
GSMS  2013-GC10	Commercial Mortgage Pass-Through Certificates, Series 2013-GC10 pursuant to the Pooling and Servicing Agreement dated February 1, 2013	January 1, 2020 - December 31, 2020
WFRBS  2013-C11	Commercial Mortgage Pass-Through Certificates, Series 2013-C11 pursuant to the Pooling and Servicing Agreement dated February 1, 2013	January 1, 2020 - December 31, 2020
MSBAM 2013-C9	Commercial Mortgage Pass-Through Certificates, Series 2013-C9 pursuant to the Pooling  and Servicing Agreement dated May 1, 2013	January 1, 2020 - December 31, 2020
WFRBS  2013-C13	Commercial Mortgage Pass-Through Certificates, Series 2013-C13 pursuant to the Pooling and Servicing Agreement dated May 1, 2013	January 1, 2020 - December 31, 2020
GSMS  2013-GC13	Commercial Mortgage Pass-Through Certificates, Series 2013-GC13 pursuant to the Pooling and Servicing Agreement dated July 1, 2013	January 1, 2020 - December 31, 2020

Exhibit B

 

 

Name	Transaction	Period of Service
WFRBS  2013-C15	Commercial Mortgage Pass-Through Certificates, Series 2013-C15 pursuant to the Pooling and Servicing Agreement dated August  1, 2013	January 1, 2020 - December 31, 2020
MSBAM 2013-C12	Commercial Mortgage Pass-Through Certificates, Series 2013-C12 pursuant to the Pooling and Servicing Agreement dated October 1, 2013	January 1, 2020 - December 31, 2020
WFRBS  2013-C17	Commercial Mortgage Pass-Through Certificates, Series 2013-C17 pursuant to the Pooling and Servicing Agreement dated August  1, 2013	January 1, 2020 - December 31, 2020
WFRBS  2014-LC14	Commercial Mortgage Pass-Through Certificates, Series 2014-LC14 pursuant to the Pooling and Servicing Agreement dated February 1, 2014	January 1, 2020 - December 31, 2020
WFRBS  2014-C19	Commercial Mortgage Pass-Through Certificates, Series 2014-C19 pursuant to the Pooling and Servicing Agreement dated February 26, 2014	January 1, 2020 - December 31, 2020
GSMS  2014-GC20	Commercial Mortgage Pass-Through Certificates, Series 2014-GC20 pursuant to the Pooling and Servicing Agreement dated April 1, 2014	January 1, 2020 - December 31, 2020
WFRBS  2014-C21	Commercial Mortgage Pass-Through Certificates, Series 2014-C21 pursuant to the Pooling and Servicing Agreement dated August  1, 2014	January 1, 2020 - December 31, 2020
CGCMT 2014-GC23	Commercial Mortgage Pass-Through Certificates, Series 2014-GC23 pursuant to the Pooling and Servicing Agreement dated August  1, 2014	January 1, 2020 - December 31, 2020
WFRBS  2014-C23	Commercial Mortgage Pass-Through Certificates, Series 2014-C23 pursuant to the Pooling and Servicing Agreement dated September 1, 2014	January 1, 2020 - December 31, 2020
WFRBS  2014-C25	Commercial Mortgage Pass-Through Certificates, Series 2014-C25 pursuant to the Pooling and Servicing Agreement dated December 1, 2014	January 1, 2020 - December 31, 2020
GSMS  2015-GC30	Commercial Mortgage Pass-Through Certificates, Series 2015-GC30 pursuant to the Pooling and Servicing Agreement dated May 1, 2015	January 1, 2020 - December 31, 2020
WFCM 2015-C27	Commercial Mortgage Pass-Through Certificates, Series 2015-C27 pursuant to the Pooling and Servicing Agreement dated March 1, 2015	January 1, 2020 - December 31, 2020
WFCM 2015-C29	Commercial Mortgage Pass-Through Certificates, Series 2015-C29 pursuant to the Pooling and Servicing Agreement dated June 1, 2015	January 1, 2020 - December 31, 2020
WFCM 2015-C31	Commercial Mortgage Pass-Through Certificates, Series 2015-C31 pursuant to the Pooling and Servicing Agreement dated November 1, 2015	January 1, 2020 - December 31, 2020
WFCM 2015-LC20	Commercial Mortgage Pass-Through Certificates, Series 2015-LC20 pursuant to the Pooling and Servicing Agreement dated March 1, 2015	January 1, 2020 - December 31, 2020
WFCM 2015-NXS1	Commercial Mortgage Pass-Through Certificates, Series 2015-NXS1 pursuant to the Pooling and Servicing Agreement dated April 1, 2015	January 1, 2020 - December 31, 2020
WFCM 2015-SG1	Commercial Mortgage Pass-Through Certificates, Series 2015-SG1 pursuant to the Pooling and Servicing Agreement dated August  1, 2015	January 1, 2020 - December 31, 2020

Exhibit B

 

 

Name	Transaction	Period of Service
WFCM 2016-C37	Commercial Mortgage Pass-Through Certificates, Series WFCM 2016-C37 pursuant to the Pooling and Servicing Agreement dated December 1, 2016	January 1, 2020 - December 31, 2020
CGCMT 2016-C3	Commercial Mortgage Pass-Through Certificates, Series CGCMT 2016-C3 pursuant to the Pooling  and Servicing Agreement dated November 1, 2016	January 1, 2020 - December 31, 2020
WFCM 2016-LC24	Commercial Mortgage Pass-Through Certificates, Series WFCM 2016-LC24 pursuant to the Pooling  and Servicing Agreement dated September 1, 2016	January 1, 2020 - December 31, 2020
WFCM 2016-NXS6	Commercial Mortgage Pass-Through Certificates, Series WFCM 2016-NXS6 pursuant to the Pooling and Servicing Agreement dated October 1, 2016	January 1, 2020 - December 31, 2020
245 Park  Ave Trust2017-245P	Commercial Mortgage Pass-Through Certificates, Series 245 Park  Ave Trust 2017-245P pursuant to the Pooling and Servicing Agreement dated May 30, 2017	January 1, 2020 - December 31, 2020
CGCMT 2017-B1	Commercial Mortgage Pass-Through Certificates, Series CGCMT 2017-B1 pursuant to the Pooling and Servicing Agreement dated August  29, 2017	January 1, 2020 - December 31, 2020
MSC 2017-H1	Commercial Mortgage Pass-Through Certificates, Series MSC 2017-H1 pursuant to the Pooling  and Servicing Agreement dated June 8, 2017	January 1, 2020 - December 31, 2020
WFCM 2017-C39	Commercial Mortgage Pass-Through Certificates, Series WFCM 2017-C39 pursuant to the Pooling and Servicing Agreement dated August  22, 2017	January 1, 2020 - December 31, 2020
WFCM 2017-RB1	Commercial Mortgage Pass-Through Certificates, Series WFCM 2017-RB1 pursuant to the Pooling and Servicing Agreement dated March 1, 2017	January 1, 2020 - December 31, 2020
WFCM 2017-C41	Commercial Mortgage Pass-Through Certificates, Series WFCM 2017-RB1 pursuant to the Pooling and Servicing Agreement dated November 1, 2017	January 1, 2020 - December 31, 2020