<?xml version="1.0" encoding="UTF-8"?>
<comments>
  <commentData>
    <itemNumber>Item 2(c)(4)</itemNumber>
    <fieldName>Original Loan Term Number</fieldName>
    <comment>For the anticipated repayment date mortgage loan (Asset No. 31): the original loan term number represents the term of the mortgage loan through the anticipated repayment date, rather than the final maturity date of March 6, 2027.</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(c)(5)</itemNumber>
    <fieldName>Maturity Date</fieldName>
    <comment>For anticipated repayment date mortgage loans (Asset No. 31): the Maturity Date represents the anticipated repayment date, rather than the final maturity date of March 6, 2027.</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(c)(15)</itemNumber>
    <fieldName>Loan Structure Code</fieldName>
    <comment>With respect to Asset No. 1, Asset No. 2, Asset No. 3, Asset No. 4, Asset No. 5, Asset No. 8, Asset No. 10, Asset No. 12, Asset No. 15,  Asset No. 21, Asset No. 22, and Asset No. 32, the related mortgage loan is part of a mortgage loan structure evidenced by multiple senior pari-passu notes and, if applicable, one or more subordinate notes. In each case, one or more of the other notes evidencing the mortgage loan are not included in the trust. With respect to Asset No. 7, the related mortgage loan is part of a mortgage loan structure evidenced by (a) one senior note with a Cut-off Date balance of $33,000,000 which evidences the Stanwix Mortgage Loan and (b) one subordinate note with a Cut-Off Date balance of $30,000,000 which evidences the Stanwix Trust Subordinate Companion Loan. Both the Stanwix Mortgage Loan and the Stanwix Trust Subordinate Companion Loan are included in the trust. The Stanwix Trust Subordinate Companion Loan solely backs the loan-specific certificates and is not part of the pool of mortgage loans backing the pooled certificates.</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(c)(18)</itemNumber>
    <fieldName>Scheduled Principal Balance Securitization Amount</fieldName>
    <comment>With respect to each mortgage loan, the principal balance shown reflects the principal balance as of the Cut-off Date, assuming that any payment due on the Cut-off Date is made, and that no voluntary principal prepayments or casualty or condemnation proceeds are received.</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(d)(2)</itemNumber>
    <fieldName>Property Address</fieldName>
    <comment>With respect to each mortgage loan secured by multiple properties, for property address and similar property-specific information, the information is provided for each related property but the response for the mortgage loan will be blank.</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(d)(28)(xiv)</itemNumber>
    <fieldName>Most Recent Debt Service Amount</fieldName>
    <comment>With respect to any &quot;Interest Only/Balloon&quot; mortgage loan, the value shown reflects the annual interest-only debt service payment. With respect to any &quot;Interest Only/Amortizing/Balloon&quot; mortgage loan, the value shown reflects the annual amortizing debt service payment. With respect to the anticipated repayment date mortgage loan (Asset No.31), after the related anticipated repayment date, if the related borrower has not prepaid such mortgage loan in full, then (i) any principal outstanding on that date will accrue interest at an increased interest rate rather than the original interest rate, (ii) interest at the initial interest rate will continue to accrue and be payable on a current basis, and (iii) interest accrued at the revised rate in excess of interest accrued at the initial interest rate is to be deferred and will be required to be paid only after the outstanding principal balance of the anticipated repayment date mortgage loan has been paid in full.  With respect to any mortgage loan that is part of a mortgage loan structure evidenced by multiple pari-passu notes (including notes outside the trust), the value shown is inclusive of debt service related to the entirety of the mortgage loan structure (or, if the mortgage loan is part of the senior portion of a mortgage loan structure that also includes a subordinate companion loan, the entirety of the senior portion of such mortgage loan structure).</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(d)(28)(xv)</itemNumber>
    <fieldName>Debt Service Coverage Net Operating Income Securitization Percentage</fieldName>
    <comment>With respect to any mortgage loan that is part of a mortgage loan structure evidenced by multiple pari-passu notes (including notes outside the trust), the value shown is inclusive of debt service related to the entirety of the mortgage loan structure (or, if the mortgage loan is part of the senior portion of a mortgage loan structure that also includes a subordinate portion, the entirety of the senior portion of such mortgage loan structure).</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(d)(28)(xvii)</itemNumber>
    <fieldName>Debt Service Coverage Net Cash Flow Securitization Percentage</fieldName>
    <comment>With respect to any mortgage loan that is part of a mortgage loan structure evidenced by multiple pari-passu notes (including notes outside the trust), the value shown is inclusive of debt service related to the entirety of the mortgage loan structure (or, if the mortgage loan is part of the senior portion of a mortgage loan structure that also includes a subordinate portion, the entirety of the senior portion of such mortgage loan structure).</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(e)(3)</itemNumber>
    <fieldName>Report Period Beginning Scheduled Loan Balance Amount</fieldName>
    <comment>With respect to each mortgage loan, the principal balance shown reflects the principal balance as of the mortgage loan payment due date in September 2019 (or for loans originated after such date, as of the loan origination date).</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(e)(6)</itemNumber>
    <fieldName>Servicer Trustee Fee Rate Percentage</fieldName>
    <comment>It should be noted that the rate presented consists of (i) the master servicing fee rate, which includes any primary servicing fee rate payable to an outside servicer (for a loan combination) or other primary servicer, and any subservicing fee rate, (ii) the certificate administrator / trustee fee rate payable to the certificate administrator and the trustee, (iii) the operating advisor fee rate, (iv) the asset representations reviewer fee rate and (v) the CREFC(R) intellectual property royalty license fee rate.</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(e)(12)</itemNumber>
    <fieldName>Report Period End Actual Balance Amount</fieldName>
    <comment>With respect to each mortgage loan, the principal balance shown reflects the principal balance as of the Cut-off Date, assuming that any payment due on the Cut-off Date is made, and that no voluntary principal prepayments or casualty or condemnation proceeds are received.</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(e)(13)</itemNumber>
    <fieldName>Report Period End Scheduled Balance Amount</fieldName>
    <comment>With respect to each mortgage loan, the principal balance shown reflects the principal balance as of the Cut-off Date, assuming that any payment due on the Cut-off Date is made, and that no voluntary principal prepayments or casualty or condemnation proceeds are received.</comment>
  </commentData>
  <commentData>
    <itemNumber>Item 2(f)(1)</itemNumber>
    <fieldName>Primary Servicer Name</fieldName>
    <comment>The primary servicer names have been truncated due to EDGAR constraints. The full name for Wells Fargo Bank is Wells Fargo Bank, National Association, and the full name for Midland Loan Services is Midland Loan Services, a Division of PNC Bank, National Association.</comment>
  </commentData>
</comments>
