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MANAGEMENT'S REPORT ON ASSESSMENT OF COMPLIANCE WITH SEC REGULATION AB SERVICING CRITERIA
1. Situs Holdings, LLC (the “Company”), a wholly-owned subsidiary of SitusAMC Holdings Corporation (“SitusAMC”), 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, 2023 (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 Holdings, LLC served in the capacity of special servicer 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 provide an assertion on the Company’s assessment of 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 wire disbursements sent or required to be sent, therefore the Company did not perform any servicing activities related to criteria 1122(d)(2)(ii) as of and for the year ended December 31, 2023.
5. During the Reporting Period, there were no active assets carrying an escrow balance maintained by Situs Holdings, LLC or escrow disbursements due to be paid by Situs Holdings, LLC 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, 2023.
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, 2023.
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 and the year ended December 31, 2023 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.
Situs Holdings, LLC
February 23, 2024
/s/ Lisa Wallace
Lisa Wallace, General Counsel/Chief Administrative Officer
Appendix A – Applicable Servicing Criteria
SERVICING CRITERIA |
APPLICABLE SERVICING CRITERIA |
INAPPLICABLE SERVICING CRITERIA | |||
Reference |
Criteria |
Performed Directly by Situs Holdings, LLC |
Performed by Vendor(s) for which Situs Holdings, LLC is the Responsible Party |
Performed by subservicer(s) or Vendor(s) for which Situs Holdings, LLC is NOT the Responsible Party |
NOT performed by Situs Holdings, LLC or by subservicer(s) or Vendor(s) retained by Situs Holdings, LLC |
General Servicing Considerations | |||||
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 |
|
|
|
1122(d)(1)(v) | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information. |
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 of receipt, or such other number of days specified in the transaction agreements. |
X |
|
|
|
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 |
|
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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 over collateralization, 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 §240.13k-1(b)(1) of this chapter. |
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: (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. |
X1 |
X1 |
|
|
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 |
|
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|
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 |
|
|
|
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 pool asset documents. |
X |
|
|
|
1122(d)(4)(ii) | Pool assets 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 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. |
|
|
|
X |
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 mortgage loans (e.g., loan modifications or re-aging's) 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, foreclosure 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 |
|
|
|
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) See following: (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 asset, 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 |
|
|
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1122(d)(4)(xv) | 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. |
|
|
|
X |
1 Servicing activities associated with criterion 1122(d)(2)(vii) are performed by Situs Holdings, LLC and a third party vendor for which Situs Holdings, LLC is the responsible party.
2 For criterion 1122(d)(3)(i)(B-D), Situs Holdings, LLC did not perform the activity described in this criterion for the Reporting Period as only 1122(d)(3)(i)(A) is applicable to the functions performed by Situs Holdings, LLC.
APPENDIX B – The Platform
Transaction |
Servicing Agreement | Servicing Agreement Date |
Period in Scope |
Situs Capacity |
ACRE 2022-Q018 | Pooling and Servicing Agreement | October 9, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
ACREC 2021-FL1 | Servicing Agreement | October 15, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
ACREC 2023-FL2 | Servicing Agreement | February 23, 2023 | February 23, 2023-December 31, 2023 | Special Servicer |
AFHT 2019-FAIR | Trust and Servicing Agreement | October 15, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
ARBOR 2022-Q021 | Pooling and Servicing Agreement | December 1, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
BACM 2015-UBS7 | Pooling and Servicing Agreement | September 1, 2015 | January 1, 2023-December 31, 2023 | Special Servicer (200 Helen Street Mortgage Loan) |
BACM 2017-BNK3 | Pooling and Servicing Agreement | February 1, 2017 | January 1, 2023-December 31, 2023 | Special Servicer (Platform Whole Loan) |
BAMLL 2013-WBRK | Trust and Servicing Agreement | April 1, 2013 | January 1, 2023-December 31, 2023 | Special Servicer |
BAMLL 2015-200P | Trust and Servicing Agreement | April 23, 2015 | January 1, 2023-December 31, 2023 | Special Servicer |
BAMLL 2015-ASTR | Trust and Servicing Agreement | August 18, 2015 | January 1, 2023-December 31, 2023 | Special Servicer |
BAMLL 2015-HAUL | Trust and Servicing Agreement | August 13, 2015 | January 1, 2023-December 31, 2023 | Special Servicer |
BAMLL 2016-SS1 | Trust and Servicing Agreement | February 17, 2016 | January 1, 2023-December 31, 2023 | Special Servicer |
BAMLL 2017-SCH | Trust and Servicing Agreement | December 15, 2017 | January 1, 2023-December 31, 2023 | Fee Mortgage Loan Special Servicer |
BAMLL 2018-PARK | Trust and Servicing Agreement | September 12, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
BAMLL 2019-BPR | Trust and Servicing Agreement | December 17, 2019 | January 1, 2023-December 31, 2023 | Special Servicer (Natick Mall Loan Group) |
Pooling and Servicing Agreement | May 1, 2018 | January 1, 2023-December 31, 2023 | Special Servicer (Fair Oaks Mall) | |
BANK 2019-BNK18 | Pooling and Servicing Agreement | May 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer (Newport Corporate Center) |
BANK 2022-BNK39 | Pooling and Servicing Agreement | February 1, 2022 | January 1, 2023-December 31, 2023 | Excluded Special Servicer |
BBCMS 2016-ETC | Trust and Servicing Agreement | August 1, 2016 | January 1, 2023-December 31, 2023 | Special Servicer |
BBCMS 2017-DELC | Trust and Servicing Agreement | August 29, 2017 | January 1, 2023-July 31, 2023 | Special Servicer |
BCP 2021-330N | Trust and Servicing Agreement | June 29, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BFLD 2019-DPLO | Trust and Servicing Agreement | October 9, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
BFLD 2020-EYP 3 | Trust and Servicing Agreement | October 7, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
BGME 2021-VR | Trust and Servicing Agreement | April 21, 2021 | January 1, 2023-December 31,2023 | Special Servicer |
BHR 2018-PRME | Trust and Servicing Agreement | June 6, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
BIG 2022-BIG | Trust and Servicing Agreement | February 9, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
BLOX 2021-BLOX | Trust and Servicing Agreement | August 31, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BMARK 2018-B5 3 | Pooling and Servicing Agreement | August 1, 2018 | January 1, 2023-December 31, 2023 | Special Servicer (eBay North First Commons and AON Center) |
BMARK 2020-IG3 | Pooling and Servicing Agreement | May 1, 2020 | January 1, 2023-December 31, 2023 | Special Servicer (1633 Broadway, BX Industrial Portfolio, and Tower 333) |
BMARK 2021-B23 | Pooling and Servicing Agreement | February 1, 2021 | January 1, 2023-December 31, 2023 | Special Servicer (MGM Grand & Mandalay Bay, The Grace Building, and Pittock Block) |
BMARK 2021-B25 | Pooling and Servicing Agreement | April 1, 2021 | January 1, 2023-December 31, 2023 | Special Servicer (Burlingame Point and Amazon Seattle) |
BMARK 2021-B26 | Pooling and Servicing Agreement | May 1, 2021 | January 1, 2023-December 31, 2023 | Special Servicer (Equus Industrial Portfolio) |
BMARK 2023-B39 | Pooling and Servicing Agreement | July 1, 2023 | July 1, 2023- December 31, 2023 | Special Servicer (Back Bay Office) |
BMO 2022-C1 | Pooling and Servicing Agreement | February 1, 2022 | January 1, 2023-December 31, 2023 | Special Servicer (360 Rosemary) |
BOCA 2022-BOCA | Trust and Servicing Agreement | May 9, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
BPCRE 2022-FL2 | Servicing Agreement | May 25, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
BPR 2021-KEN | Trust and Servicing Agreement | February 25, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BSPDF 2021-FL1 | Servicing Agreement | October 15, 2021 | January 1, 2023-December 31, 2023 | Affiliated Loan Special Servicer (Academy Distribution Center and Aster Buckhead) |
BSPRT 2019-FL5 | Servicing Agreement | May 30, 2019 | January 1, 2023- August 30, 2023 | Special Servicer |
BSPRT 2021-FL6 | Servicing Agreement | March 25, 2021 | June 12, 2023- December 31, 2023 | Special Servicer (Augusta Flats) |
BSPRT 2022-FL9 | Servicing Agreement | June 29, 2022 | June 12, 2023- December 31, 2023 | Special Servicer (Jones & Rio) |
BWAY 2019-1633 | Trust and Servicing Agreement | December 20, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2018-BILT | Trust and Servicing Agreement | May 24, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2018-EXCL | Trust and Servicing Agreement | October 15, 2018 | January 1, 2023- July 31, 2023 | Special Servicer |
BX 2018-GW | Trust and Servicing Agreement | May 22, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2019-OC11 | Trust and Servicing Agreement | December 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2019-RP | Trust and Servicing Agreement | June 27, 2019 | January 1, 2023-November 15, 2023 | Special Servicer |
BX 2019-XL | Trust and Servicing Agreement | October 9, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2020-VIVA | Trust and Servicing Agreement | May 5, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2021-21M | Trust and Servicing Agreement | November 8, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2021-ARIA | Trust and Servicing Agreement | October 28, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2021-PAC | Trust and Servicing Agreement | November 2, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2021-VINO | Trust and Servicing Agreement | May 27, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2021-VOLT | Trust and Servicing Agreement | September 9, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2022-AHP | Trust and Servicing Agreement | February 15, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2022-FOX2 | Trust and Servicing Agreement | December 12, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2022-MVRK | Trust and Servicing Agreement | March 23, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2022-VAMF | Trust and Servicing Agreement | February 3, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
BX 2023-DELC | Trust and Servicing Agreement | June 9, 2023 | June 9, 2023- December 31, 2023 | Special Servicer |
BXHPP 2021-FILM | Trust and Servicing Agreement | August 26, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BXP 2021-601L | Trust and Servicing Agreement | December 29, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
BXSC 2022-WSS | Trust and Servicing Agreement | March 24, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2018-1 3 | Pooling and Servicing Agreement | June 9, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2019-1 3 | Pooling and Servicing Agreement | April 9, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2019-2 3 | Pooling and Servicing Agreement | July 9, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2019-3 3 | Pooling and Servicing Agreement | November 9, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2020-1 3 | Pooling and Servicing Agreement | March 9, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2020-2 3 | Pooling and Servicing Agreement | May 9, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2020-3 3 | Pooling and Servicing Agreement | September 9, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2020-4 | Pooling and Servicing Agreement | December 9, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2020-P1 3 | Pooling and Servicing Agreement | November 19, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2021-1 3 | Pooling and Servicing Agreement | April 9, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2021-2 3 | Pooling and Servicing Agreement | July 9, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2021-3 3 | Pooling and Servicing Agreement | October 9, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2022-1 3 | Pooling and Servicing Agreement | June 9, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2022-P2 3 | Pooling and Servicing Agreement | September 9, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
CAF 2023-P1 3 | Pooling and Servicing Agreement | August 9, 2023 | August 9, 2023- December 31, 2023 | Special Servicer |
CAMB 2021-CX2 | Trust and Servicing Agreement | November 9, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
CENT 2023-CITY | Trust and Servicing Agreement | August 29, 2023 | August 29, 2023- December 31, 2023 | Special Servicer |
CFCRE 2016-C6 | Pooling and Servicing Agreement | November 1, 2016 | January 1, 2023-December 31, 2023 | Special Servicer (Potomac Mills) |
CFCRE 2018-TAN | Trust and Servicing Agreement | February 6, 2018 | January 1, 2023- March 31, 2023 | Special Servicer |
CGCMT 2018-TBR | Trust and Servicing Agreement | January 9, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
CGCMT 2020-420K | Trust and Servicing Agreement | November 6, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
CGCMT 2021-PRM2 | Trust and Servicing Agreement | October 9, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
COLD 2020-ICE5 | Trust and Servicing Agreement | October 29, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
COMM 2013-CCRE7 3 | Pooling and Servicing Agreement | April 1, 2013 | January 1, 2023- August 15, 2023 | Special Servicer |
COMM 2016-667M | Trust and Servicing Agreement | October 6, 2016 | January 1, 2023-December 31, 2023 | Special Servicer |
COMM 2018-HOME | Pooling and Servicing Agreement | June 1, 2018 | January 1, 2023-December 31, 2023 | Special Servicer (TriBeCa House Whole Loan and The Gateway Whole Loan) |
COMM 2019-WCM | Trust and Servicing Agreement | October 30, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
COMM 2020-CX | Trust and Servicing Agreement | November 5, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
COMM 2020-SBX | Trust and Servicing Agreement | December 30, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
COMM 2021-2400 | Trust and Servicing Agreement | December 15, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
CRBT 2023-Q024 | Pooling and Servicing Agreement | November 1, 2023 | November 1, 2023- December 31, 2023 | Special Servicer |
CSAIL 2015-3 | Pooling and Servicing Agreement | August 1, 2015 | January 1, 2023-December 31, 2023 | Special Servicer (Charles River Plaza North Whole Loan) |
CSMC 2006-C1 | Pooling and Servicing Agreement | March 1, 2006 | January 1, 2023-December 31, 2023 | Special Servicer |
CSMC 2017-CALI | Trust and Servicing Agreement | November 6, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
CSMC 2019-ICE4 | Trust and Servicing Agreement | June 5, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
CSMC 2019-UVIL | Trust and Servicing Agreement | December 6, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
CSMC 2021-BHAR | Trust and Servicing Agreement | November 23, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
DAFC 2017-AMO | Trust and Servicing Agreement | June 20, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
DATA 2023-CNTR | Trust and Servicing Agreement | July 20, 2023 | July 20, 2023- December 31, 2023 | Special Servicer |
DBGS 2018-BIOD | Trust and Servicing Agreement | June 26, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
DBGS 2019-1735 | Trust and Servicing Agreement | April 6, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
DBUBS 2017-BRBK | Trust and Servicing Agreement | October 1, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
DBWF 2016-85T | Trust and Servicing Agreement | December 21, 2016 | January 1, 2023-December 31, 2023 | Special Servicer |
DC 2023-DC | Trust and Servicing Agreement | August 30, 2023 | August 30, 2023- December 31, 2023 | Special Servicer |
DOLP 2021-NYC | Trust and Servicing Agreement | April 20, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
ESA 2021-ESH | Trust and Servicing Agreement | July 8, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
FFB 2018-Q007 3 | Pooling and Servicing Agreement | September 1, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
FFB 2019-Q011 3 | Pooling and Servicing Agreement | September 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
FFB 2020-Q013 | Pooling and Servicing Agreement | September 1, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
FFB 2021-Q016 | Pooling and Servicing Agreement | September 1, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
FMBT 2019-FBLU | Trust and Servicing Agreement | December 6, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
FRB 2018-Q008 | Pooling and Servicing Agreement | December 1, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
FREMF 2019-Q010 | Pooling and Servicing Agreement | July 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
FREMF 2020-Q012 3 | Pooling and Servicing Agreement | August 1, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
FRESB 2015-SB8 | Pooling and Servicing Agreement | November 1, 2015 | January 1, 2023-December 31, 2023 | Special Servicer |
FRESB 2016-SB19 | Pooling and Servicing Agreement | July 1, 2016 | January 1, 2023-December 31, 2023 | Special Servicer |
FRETE 2022-ML13 | Pooling and Servicing Agreement | November 1, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
FS 2023-4SZN | Trust and Servicing Agreement | November 1, 2023 | November 1, 2023- December 31, 2023 | Special Servicer |
GACM 2019-FL1 3 | Servicing Agreement | June 6, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
GCT 2021-GCT 3 | Trust and Servicing Agreement | February 5, 2021 | January 1, 2023- August 17, 2023 | Special Servicer |
GRACE 2020-GRCE | Trust and Servicing Agreement | November 18, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
GSMS 2017-375H | Trust and Servicing Agreement | September 6, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
GSMS 2017-485L | Trust and Servicing Agreement | February 6, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
GSMS 2017-FARM | Trust and Servicing Agreement | December 29, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
GSMS 2019-70P | Trust and Servicing Agreement | October 23, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
GSMS 2022-GTWY | Trust and Servicing Agreement | August 30, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
GSMS 2023-FUN | Trust and Servicing Agreement | March 28, 2023 | March 28, 2023- December 31, 2023 | Special Servicer |
GSMS 2022-SHIP | Trust and Servicing Agreement | July 29, 2022 | January 1, 2023- August 30, 2023 | Special Servicer |
GWT 2019-WOLF | Trust and Servicing Agreement | December 30, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
HAMLET 2020-CRE1 | Pooling and Servicing Agreement | May 1, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
HFX 2017-1 3 | Amended and Restated Servicing Agreement | March 30, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
HONO 2021-LULU | Trust and Servicing Agreement | October 15, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
HY 2016-10HY | Trust and Servicing Agreement | August 6, 2016 | January 1, 2023-December 31, 2023 | Special Servicer |
HY 2019-30HY | Trust and Servicing Agreement | July 6, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
ILPT 2022-LPFX | Trust and Servicing Agreement | March 6, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
IMT 2017-APTS | Trust and Servicing Agreement | July 9, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
IPT 2018-INDP | Trust and Servicing Agreement | June 11, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
JAX 2019-LIC | Trust and Servicing Agreement | November 15, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2017-245P | Trust and Servicing Agreement | May 30, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2018-AON 3 | Trust and Servicing Agreement | June 29, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2018-BCON | Pooling and Servicing Agreement | February 1, 2018 | January 1, 2023- April 17, 2023 | Special Servicer |
JPMCC 2018-PHH | Trust and Servicing Agreement | August 7, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2018-PTC | Trust and Servicing Agreement | May 16, 2018 | January 1, 2023-November 30, 2023 | Special Servicer |
JPMCC 2019-ICON | Pooling and Servicing Agreement | April 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2019-MARG | Trust and Servicing Agreement | May 30, 2019 | January 1, 2023- October 31, 2023 | Special Servicer |
JPMCC 2019-MFP | Trust and Servicing Agreement | July 18, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2019-OSB | Trust and Servicing Agreement | June 13, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2020-LOOP | Trust and Servicing Agreement | February 5, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2021-1MEM | Trust and Servicing Agreement | October 14, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2021-2NU | Trust and Servicing Agreement | January 29, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2021-410T | Trust and Servicing Agreement | March 12, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2022-DATA | Trust and Servicing Agreement | June 16, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
JPMCC 2022-NXSS | Trust and Servicing Agreement | September 29, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
KNDL 2019-KNSQ | Trust and Servicing Agreement | May 30, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
LAQ 2022-LAQ | Trust and Servicing Agreement | March 30, 2022 | January 1, 2023- March 31, 2023 | Special Servicer |
LBS 2017-Q004 | Pooling and Servicing Agreement | September 1, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
LCCM 2021-FL2 | Servicing Agreement | July 13, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
LCCM 2021-FL3 | Servicing Agreement | December 2, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
LIFE 2021-BMR | Trust and Servicing Agreement | March 30, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
LIFE 2022-BMR2 | Trust and Servicing Agreement | May 24, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
LNCR 2018-CRE1 3 | Servicing Agreement | June 5, 2018 | January 1, 2023- October 16, 2023 | Special Servicer |
LNCR 2019-CRE2 3 | Servicing Agreement | May 30, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
LNCR 2019-CRE3 3 | Servicing Agreement | May 30, 2019 | January 1, 2023- October 16, 2023 | Special Servicer |
LNCR 2021-CRE4 3 | Servicing Agreement | February 5, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
LNCR 2021-CRE5 3 | Servicing Agreement | June 3, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
LNCR 2021-CRE6 3 | Servicing Agreement | November 4, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
LNCR 2022-CRE7 3 | Servicing Agreement | February 23, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
LUX 2023-LION | Trust and Servicing Agreement | August 17, 2023 | August 17, 2023- December 31, 2023 | Special Servicer |
LUXE 2021-TRIP | Trust and Servicing Agreement | October 19, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
MBRT 2019-MBR | Trust and Servicing Agreement | December 19, 2019 | January 1, 2023- July 31, 2023 | Special Servicer |
MBI 2022-Q017 | Pooling and Servicing Agreement | May 1, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
MFTII 2019-B3B4 | Trust and Servicing Agreement | July 11, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
MHP 2022-MHIL | Trust and Servicing Agreement | January 9, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
MKT 2020-525M | Trust and Servicing Agreement | February 26, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
MSC 2011-C2 | Pooling and Servicing Agreement | June 1, 2011 | January 1, 2023-December 31, 2023 | Special Servicer |
MSC 2018-SUN | Trust and Servicing Agreement | August 2, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
MSC 2019-H7 | Pooling and Servicing Agreement | July 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer (Grand Canal Shoppes Whole Loan) |
MSC 2019-L3 | Pooling and Servicing Agreement | November 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer (ILPT Industrial Portfolio) |
MSCI 2013-ALTM | Trust and Servicing Agreement | March 1, 2013 | January 1, 2023-December 31, 2023 | Special Servicer |
MTK 2021-GRNY | Trust and Servicing Agreement | December 15, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
NCMF 2022-MFP | Trust and Servicing Agreement | March 30, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
NCMS 2018-ALXA | Trust and Servicing Agreement | February 23, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
NCMS 2018-FL1 3 | Pooling and Servicing Agreement | July 6, 2018 | January 1, 2023-December 31, 2023 | Special Servicer (Wanamaker Building Whole Loan) |
NCMS 2019-LVL | Trust and Servicing Agreement | April 23, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
NCMS 2019-NEMA 3 | Trust and Servicing Agreement | March 29, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
NYO 2021-1290 | Trust and Servicing Agreement | November 16, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
OAKST 2023-NLP | Pooling and Servicing Agreement | February 28, 2023 | February 28, 2023- December 31, 2023 | Special Servicer |
OMW 2020-1MW | Trust and Servicing Agreement | August 28, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
OPUS 2016-Q003 | Pooling and Servicing Agreement | December 1, 2016 | January 1, 2023-December 31, 2023 | Special Servicer |
ORL 2023-GLKS | Trust and Servicing Agreement | October 26, 2023 | October 26, 2023- December 31, 2023 | Special Servicer |
PATH 2021-1 | Trust and Servicing Agreement | August 13, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
PFP 2021-7 | Servicing Agreement | March 25, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
PFP 2021-8 | Servicing Agreement | September 30, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
PFP 2022-9 | Servicing Agreement | September 30, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
PFP 2023-10 | Servicing Agreement | July 31, 2023 | July 31, 2023- December 31, 2023 | Special Servicer |
PGA 2023-RSRT | Trust and Servicing Agreement | April 21, 2023 | April 21, 2023- December 31, 2023 | Special Servicer |
PRIMA 2013-III | Servicing Agreement | September 30, 2013 | January 1, 2023-December 31, 2023 | Special Servicer |
PRIMA 2015-IV | Servicing Agreement | March 17, 2015 | January 1, 2023-December 31, 2023 | Special Servicer |
PRIMA 2016-VI | Servicing Agreement | December 16, 2016 | January 1, 2023-December 31, 2023 | Special Servicer |
PRIMA 2019-1S | Indenture | August 23, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
PRIMA 2019-RK1 | Indenture | June 27, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
PRIMA 2019-VII | Servicing Agreement | October 22, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
PRIMA 2020-VIII | Indenture | July 15, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
PRIMA 2021-IX | Servicing Agreement | February 26, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
PRIMA 2021-X | Indenture | November 16, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
SFO 2021-555 | Trust and Servicing Agreement | May 10, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
SGCMS 2019-787E | Trust and Servicing Agreement | February 20, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
SGCMS 2019-PREZ | Trust and Servicing Agreement | September 6, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
SGCP 2021-FL3 3 | Servicing Agreement | September 27, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
SGCP 2022-FL4 | Servicing Agreement | June 27, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
SGCP 2023-FL5 | Servicing Agreement | June 15, 2023 | June 15, 2023- December 31, 2023 | Special Servicer |
SHOPS 2016-CSTL | Trust and Servicing Agreement | July 20, 2016 | January 1, 2023- April 3, 2023 | Special Servicer |
SLG 2021-OVA | Trust and Servicing Agreement | June 24, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
SLIDE 2018-FUN | Trust and Servicing Agreement | September 28, 2018 | January 1, 2023- March 31, 2023 | Special Servicer |
TRTX 2019-FL3 3 | Servicing Agreement | October 25, 2019 | January 1, 2023-December 31, 2023 | Special Servicer |
TRTX 2021-FL4 3 | Servicing Agreement | March 31, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
TRTX 2022-FL5 3 | Servicing Agreement | February 16, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
TYSN 2023-CRNR | Trust and Servicing Agreement | December 12, 2023 | December 12, 2023- December 31, 2023 | Special Servicer |
UBS 2018-NYCH 3 | Trust and Servicing Agreement | February 26, 2018 | January 1, 2023-December 31, 2023 | Special Servicer |
UBSCM 2017-C4 | Pooling and Servicing Agreement | October 1, 2017 | January 1, 2023-December 31, 2023 | Special Servicer (Fairmount at Brewerytown) |
UBSCM 2018-C9 | Pooling and Servicing Agreement | March 1, 2018 | January 1, 2023-December 31, 2023 | Special Servicer (DreamWorks Campus) |
UBSCM 2019-C16 | Pooling and Servicing Agreement | April 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer (Skyloft Austin Whole Loan) |
VASA 2021-VASA | Trust and Servicing Agreement | April 15, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
VLS 2020-LAB | Trust and Servicing Agreement | November 6, 2020 | January 1, 2023-December 31, 2023 | Special Servicer |
WFCM 2019-C50 | Pooling and Servicing Agreement | May 1, 2019 | January 1, 2023-December 31, 2023 | Special Servicer (Great Wolf Lodge Southern California Whole Loan) |
WFCM 2021-FCMT | Trust and Servicing Agreement | May 14, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
WFCM 2021-SAVE | Trust and Servicing Agreement | February 17, 2021 | January 1, 2023-December 31, 2023 | Special Servicer |
WFCM 2022-JS2 | Trust and Servicing Agreement | January 27, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
WFLD 2014-MONT | Trust and Servicing Agreement | August 1, 2014 | January 1, 2023-December 31, 2023 | Special Servicer |
WMRK 2022-WMRK | Trust and Servicing Agreement | November 9, 2022 | January 1, 2023-December 31, 2023 | Special Servicer |
WWPT 2017-WWP | Trust and Servicing Agreement | November 10, 2017 | January 1, 2023-December 31, 2023 | Special Servicer |
3 Situs Holding’s LLC was named as the Special Servicer for all portfolios listed within Appendix B. However, there was only activity requiring the Company to perform the role of Special Servicer throughout the Reporting Period for the transaction agreements in the designated portfolios.