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August 13, 2019
Katherine Hsu
Office Chief
Office of Structured Finance
Office Chief
Office of Structured Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
| Re: | JPMDB Commercial Mortgage Securities Trust 2017-C7 |
| Benchmark 2018-B2 Mortgage Trust | |
| JPMDB Commercial Mortgage Securities Trust 2018-C8 | |
| Forms 10-K for Fiscal Year Ended December 31, 2018 | |
| Filed March 21, 2019 | |
| File Nos. 333-206361-12, 333-206361-13 and 333-206361-14 |
Dear Ms. Hsu:
We are acting as counsel to J.P. Morgan Chase Commercial Mortgage Securities Corp. (“JPMCC”) in connection with your letter dated July 30, 2019 transmitting comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) and the comment provided to me by Ms. Lulu Cheng by telephone on August 2, 2019 (collectively, the “Comments”) relating to the above-captioned Form 10-K filings (the “Filings”). We have reviewed the Comments and the Filings and have discussed the Comments with various representatives of JPMCC.
For your convenience, the Staff’s comments are repeated in italics below, followed by the responses of JPMCC.
Form 10-K of JPMDB Commercial Mortgage Securities Trust 2017-C7
Part IV – Item 15. Exhibits, Financial Statement Schedules
1. | We note that Exhibits 33.64, 33.113, 34.64 and 34.113 (servicer assessments of and corresponding attestation reports for Park Bridge Lender Services LLC, as operating advisor of the EIP Logistics Portfolio and Lightstone Portfolio Mortgage Loans) were omitted with cross references to the Explanatory Notes section of the Form 10-K for an explanation of the omissions. However, the Explanatory Notes section did not discuss these omissions. Please provide an explanation for these omissions. |
The EIP Logistics Portfolio Mortgage Loan and the Lightstone Portfolio Mortgage Loan collectively constitute approximately 3.4% of the asset pool of the issuing entity as of its cut-off
David S. Burkholder Tel +1 704 348-5309 Fax +1 704 348-5200 david.burkholder@cwt.com
Katherine Hsu
August 13, 2019
date. Because Park Bridge Lender Services, LLC is performing activities that address servicing criteria relating to 5% or less of the assets of the issuing entity, the related servicer assessment and attestation report are not required to be included in the related Filing per Instruction 3 to Item 1122 of Regulation AB. In future filings, we will revise the Explanatory Notes to describe why the servicer assessment and attestation report are not required to be included.