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REPORT OFINDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
RialtoCapital Advisors, LLC.
We have examined management of Rialto CapitalAdvisors,LLC’s assertion,included intheaccompanyingManagement’sAssertion on Compliance withApplicableRegulation AB Servicing Criteria,thatRialto CapitalAdvisors, LLC,(the “Company”) complied with the servicing criteria setforthin Item1122(d)of the Securities andExchangeCommission’s Regulation AB for the commercial mortgage loan platform (the “Platform”), excluding criteria in Items1122(d)(1)(iii), (d)(2)(ii), (d)(2)(iii), (d)(3)(i.C), (d)(3)(i.D), (d)(3)(ii), (d)(3)(iii), (d)(3)(iv), (d)(4)(v), (d)(4)(ix),(d)(4)(x), (d)(4)(xi), (d)(4)(xii), (d)(4)(xiii), (d)(4)(xiv), and (d)(4)(xv) (the “servicing criteria”), as of and for the year endedDecember31, 2019, which management has determined are not applicable to the activities performed by the Company with respect to thePlatform. Exhibit 1 tomanagement’s assertionidentifiesthe individualasset-backed transactionsdefinedby management as constituting thePlatform. Managementis responsible for the Company’s compliance with the servicing criteria anditsassertion.Ourresponsibilityis toexpress an opinion on management’s assertion abouttheCompany’s compliancewith theservicing criteria based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether management’s assertion about compliance with the servicing criteria is fairly stated, in all material respects, and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the servicing criteria, including tests on a sample basis of the servicing activities related to the Platform, determining whether theCompany performedthose selected activities in compliance with the servicing criteria duringthe specified period, and performing such other procedures as we considered necessary in the circumstances. Our procedures were limited to selected servicing activities performed by the Company during the period covered by this report and, accordingly, such samples may not have included servicing activities related to each asset-backed transaction included in the Platform. Further, an examination is not designed to detect noncompliance arising from errors that may have occurred prior to the period specified above that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report.We believe that the evidence we obtained in our examination is sufficient and appropriate to provide a reasonable basis for our opinion.
As described in management’s assertion, for servicing criteria Item 1122(d)(1)(ii), the Company has engaged a vendor to perform certain activities required by this servicing criteria. The Company has determined that this vendor is not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Company has elected to take responsibility for assessing compliance with the servicing criteria applicable to this vendor as permitted by the SEC’sCompliance and Disclosure Interpretation 200.06, Vendors Engaged by Servicers (“C&DI 200.06”). As permitted by C&DI 200.06, the Company has asserted that it has policies and procedures in place designed to provide reasonableassurance that the vendor’s activities comply in all material respects with the servicing criteria applicable to this vendor. The Company is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendor and related criteria as described in its assertion, and we performed no procedures with respect to the Company’s determination of its eligibility to apply C&DI 200.06.
Our examination does not provide alegaldetermination on the Company’scompliancewith the servicing criteria.
Inouropinion,management’s assertion that the Company complied withtheaforementioned servicing criteria as of and for the yearended December31, 2019,forthecommercial mortgageloanplatform, is fairly stated, in all material respects.
/s/ Deloitte & Touche LLP
February 28,2020
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