July 30, 2019
Via E-mail
Kunal K. Singh
President and Chief Executive Officer
J.P. Morgan Chase Commercial Mortgage Securities Corp.
4 New York Plaza, 21st Floor
New York, New York 10004-2413
Re: JPMDB Commercial Mortgage Securities Trust 2017-C7
Benchmark 2018-B2 Mortgage Trust
Forms 10-K for Fiscal Year Ended December 31, 2018
Filed March 21, 2019
File Nos. 333-206361-12 and 333-206361-13
Dear Mr. Singh:
We have reviewed your filings and have the following comments. In some
of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.
After reviewing your response to these comments, we may have additional
comments.
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.
Attestation Reports of Ernst & Young LLP for Cohen Financial, as special
servicer
Exhibits 34.52, 34.97, 34.102, 34.107, 34.112, 34.117 and 34.122 to Form 10-K
of Benchmark
2018-B2 Mortgage Trust
2. We note that the attestation reports prepared by Ernst & Young LLP for
Cohen Financial,
a division of SunTrust Bank, state that:
Kunal K. Singh
J.P. Morgan Chase Commercial Mortgage Securities Corp.
July 30, 2019
Page 2
no servicing activities were performed by Cohen Financial with
respect to the
servicing criterion set forth in Item 1122(d)(4)(ii) during
the subject reporting
period; and
"[a]s described in management's assertion," Cohen Financial
engaged a vendor to
perform servicing activities with respect to the servicing
criterion set forth in Item
1122(d)(4)(xi) during the subject reporting period.
However, the corresponding servicer assessments of Cohen Financial,
filed as Exhibits
33.52, 33.97, 33.102, 33.107, 33.112, 33.117 and 33.122 to your Form
10-K, do not
indicate either of the above statements. Please revise either exhibit,
as necessary, to
reconcile these reports.
3. In addition, the Ernst & Young attestation reports reference "Appendix
A" of the Cohen
Financial servicer assessments for a list of the asset-backed
transactions covered by its
servicing platform. However, there is no "Appendix A" mentioned in or
included with
Cohen Financial's servicer assessments. It is not clear to us whether
Ernst & Young
erroneously referenced "Appendix A" or whether Cohen Financial should
have included
"Appendix A" with its servicer assessments to identify the scope of
its servicing platform
(see Instruction 1 to Item 1122 of Regulation AB). Please revise
either exhibit, as
necessary, to reconcile these reports.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Lulu Cheng at 202-551-3811 or me at 202-551-3850 if you
have any
questions.
Sincerely,
/s/ Katherine
Hsu
Katherine Hsu
Office Chief
Office of
Structured Finance
cc: Brad Horn, JPMorgan Chase
David Burkholder, Cadwalader, Wickersham & Taft LLP