Management Assessment of Compliance with Applicable Servicing Criteria
Citibank, N.A., (the “Custodian”) is responsible for assessing compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission, as set forth in Exhibit A (the “Applicable Servicing Criteria”), hereto, in connection with the servicing of (i) residential mortgage loans included in publicly issued residential mortgage-backed securities issued on or after January 1, 2006, and certain publicly issued residential mortgage-backed securities issued prior to January 1, 2006, certain residential mortgage transactions for which the Custodian has agreed to apply the servicing criteria set forth in Item 1122(d) of Regulation AB, for which the Custodian performs a particular servicing function pursuant to a custodial agreement with a third party, except for Federal Home Loan Mortgage Corporation, Federal National Mortgage Association, and Government National Mortgage Association residential mortgage loan securitizations unless notified that the residential mortgage loans are part of a special bond program for which the Custodian has agreed to apply the servicing criteria set forth in Item 1122(d) of Regulation AB, and (ii) commercial mortgage loans included in publicly issued commercial mortgage-backed securities issued on or after January 1, 2006, and certain privately offered commercial mortgage-backed securities issued on or after January 1, 2006 for which the Custodian has an obligation under the applicable transaction agreements to deliver an assessment of compliance with the applicable servicing criteria under Item 1122(d) of Regulation AB, in each case for which the Custodian provides document custody services (the “Platform”) as of and for the year ended December 31, 2025. The transactions covered by this report as of and for the year ended December 31, 2025 are listed on Exhibit B.
1.Except as set forth in paragraph 2 below, the Custodian used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the Applicable Servicing Criteria as of and for the year ended December 31, 2025;
2.The criteria listed as Inapplicable Servicing Criteria in Exhibit A hereto are inapplicable to the Custodian based on the activities it performs with respect to asset-backed securities transactions as of and for the year ended December 31, 2025;
3.The Custodian has complied, in all material respects, with the Applicable Servicing Criteria as of and for the year ended December 31, 2025.
The Custodian has amended its Management Assessment of Compliance with Applicable Servicing Criteria previously issued and dated February 27, 2026 to include a previously inadvertently omitted transaction in its Platform as noted in Exhibit B. This assertion of compliance supersedes Management Assessment of Compliance with Applicable Servicing Criteria previously issued and dated February 27, 2026; and
4.KPMG LLP, an independent registered public accounting firm, has issued an attestation report on the Custodian’s assessment of compliance with the Applicable Servicing Criteria as of and for the year ended December 31, 2025.
March 19, 2026
Exhibit A – Citibank, N.A. Custody Platform
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SERVICING CRITERIA |
APPLICABLE SERVICING CRITERIA |
INAPPLICABLE SERVICING CRITERIA |
Reference |
Criteria |
Performed Directly by Citibank, N.A. |
Performed by Vendor(s) for which Citibank, N.A. is the Responsible Party |
Performed by subservicer(s) or Vendor(s) for which Citibank, N.A. is NOT the Responsible Party |
NOT performed by Citibank, N.A. or by subservicer(s) or Vendor(s) retained by Citibank, N.A. |
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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 |
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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. |
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X |
1122(d)(1)(iii) |
Any requirements in the transaction agreements to maintain a back-up servicer for the loans are maintained. |
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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 |
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1122(d)(1)(v) |
Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information. |
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X |
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Cash Collection and Administration |
1122(d)(2)(i) |
Payments on loans are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number of days specified in the transaction agreements. |
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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. |
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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. |
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X |
1122(d)(2)(iv) |
The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements. |
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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 criteria, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act. |
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X |
1122(d)(2)(vi) |
Unissued checks are safeguarded so as to prevent unauthorized access. |
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X |
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2025 Exhibit B
Transactions where Citibank is the Custodian
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Investor Code |
Bond Number |
Series |
Cenlar IC |
Security or Deal |
Party the Servicer Is Reporting To (Master Servicer or Trustee or Investor) |
Comments |
77014 |
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HY4 |
2008-WL32 |
HSBC MORTGAGE CORPORATION |
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20396 |
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JY1 |
BALLY'S PARK PLACE INC |
BALLY'S PARK PLACE INC |
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20877 |
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KN7 |
Bank of America-GSS - Participation Deal |
BANK OF AMERICA - GSS |
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20874 |
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KQ9 |
Bank of America-Participation Deal |
BANK OF AMERICA |
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BMARK 2024-V10 |
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BMARK 2025-V13 |
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BMARK 2025-V16 |
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BMARK 2025-V19 |
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BMO 2024-C10 |
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BMO 2024-C8 |
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BMO 2025-5C10 |
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BMO 2025-C12 |
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BMO 2025-C13 |
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28164 |
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KK0 |
BOFA FHLBI BUYBACKS |
BOFA FHLBI BUYBACKS |
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29000 |
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KK3 |
Broward HF P&I |
BANK OF NEW YORK |
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BSARM 2007-2 |
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7504 |
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DQ2 |
CA Public Employees Retirement System |
CA Public Employees Retirement |
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2312 |
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JQ3 |
CAL RURAL PLAT RURAL ALLIANC |
WELLS FARGO BANK, N.A. (CA Rua |
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2420 |
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JQ9 |
CALPERS - PERSONAL |
CALPERS - PERSONAL |
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60105 |
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GZ3 |
CCO MORTGAGE |
CCO MORTGAGE |
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7628 |
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DT4 |
CENTERSTATE BANK OF FL |
CENTERSTATE BANK OF FL, N.A. |
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2799 |
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CQ0 |
CENTRAL MORTGAGE CO |
CENTRAL MORTGAGE CO |
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6187 |
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CV8 |
CHARTER ONE MORTGAGE |
CCO MORTGAGE |
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28123 |
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KJ4 |
CITIGROUP TRUST INVESTOR |
CITIGROUP GLOBAL MARKETS REALI |
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2434 |
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JR2 |
CITY OF SANTA CLARA |
Housing Authority of the City |
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CMLTI 2004 - HYB4 |
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CMLTI 2004-2 |
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CMLTI 2004-HYB1 |
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CMLTI 2004-HYB2 |
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CMLTI 2004-HYB3 |
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9009 |
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EA0 |
CMLTI 2005 01 |
U.S. BANK NATIONAL ASSOCIATION |
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9009 |
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PW0 |
CMLTI 2005 02 |
U.S. BANK NATIONAL ASSOCIATION |
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CMLTI 2005 03 |
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CMLTI 2005 04 |
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CMLTI 2005 05 |
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CMLTI 2005 06 |
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CMLTI 2005 07 |
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CMLTI 2005 08 |
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CMLTI 2005 09 |
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CMLTI 2005 10 |
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CMLTI 2005 11 |
Wells Fargo |
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CMLTI 2005 HE1 |
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CMLTI 2005 HE3 |
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CMLTI 2005 HE4 |
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CMLTI 2005 WF1 |
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CMLTI 2005 WF2 |
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CMLTI 2005-SHL1 |
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CMLTI 2006 04 |
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CMLTI 2006 AR1 |
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CMLTI 2006 AR2 |
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9063 |
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EG3 |
CMLTI 2006 AR3 |
U.S. BANK NATIONAL ASSOCIATION |
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9063 |
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PW1 |
CMLTI 2006 AR5 |
U.S. BANK NATIONAL ASSOCIATION |
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9063 |
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PW2 |
CMLTI 2006 AR6 |
U.S. BANK NATIONAL ASSOCIATION |
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9063 |
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PW3 |
CMLTI 2006 AR7 |
U.S. BANK NATIONAL ASSOCIATION |
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CMLTI 2006 AR9 |
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CMLTI 2006-AMC1 |
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77416 |
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JH8 |
CMLTI 2006-FX1 |
WELLS FARGO CORPORATE TRUST SV |
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CMLTI 2006-HE1 |
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CMLTI 2006-HE2 |
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CMLTI 2006-HE3 |
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CMLTI 2006-NC1 |
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CMLTI 2006-NC2 |
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CMLTI 2006-SHL1 |
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CMLTI 2006-WF1 |
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CMLTI 2006-WF2 |
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CMLTI 2006-WFHE1 |
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CMLTI 2006-WFHE2 |
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