Computershare
9062 Old Annapolis Road
Columbia, Maryland 21045
www.computershare.com
ASSESSMENT OF COMPLIANCE WITH THE APPLICABLE SERVICING CRITERIA
Computershare Corporate Trust- CMBS Platform
The management (“Management”) of the Computershare Corporate Trust division of Computershare Trust Company, National Association (the “Company”) is responsible for assessing the Company’s compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission. Management has determined that the servicing criteria are applicable to the servicing platform for the period as follows:
Purchase of corporate trust business. On November 1, 2021, Wells Fargo Bank, N.A. (“Wells Fargo”) and certain of its affiliates sold substantially all of its Corporate Trust Services (“CTS”) division to the Company, Computershare Delaware Trust Company (“CDTC”), and Computershare Limited (“Computershare Limited,” and collectively with the Company and CDTC, “Computershare”). Virtually all CTS employees of Wells Fargo, along with most existing CTS systems, technology, and offices transferred to Computershare as part of the sale.
For the CMBS Platform (defined below) transactions and during the Period (defined below), the Company either (i) served directly in the related trustee, securities administration, paying agent, and/or related roles (collectively, the “CMBS Platform Roles”), or (ii) served as agent for Wells Fargo who remained in the related CMBS Platform Roles. More specifically, since its acquisition of the Wells Fargo CTS business on November 1, 2021, including during the Period, the Company has (i) closed new CMBS transactions and (ii) completed the transfer of certain CMBS transaction roles from Wells Fargo CTS to Computershare, for which, in each case, during all or a portion of the Period, the Company performed the related CMBS Platform Roles directly (the “Company’s Direct Role Transactions”). The Company’s Direct Role Transactions comprise a small percentage of the overall CMBS Platform transactions for the Period. For a significant majority of CMBS Platform transactions, the Company served, during all or a portion of the Period, as agent for Wells Fargo who remained in the related CMBS Platform Roles (the “Company’s Agent Role Transactions”). For the Company’s Agent Role Transactions, Wells Fargo had not, as of the beginning of the Period, transferred to Computershare the CMBS Platform Roles for the Company’s Agent Role Transactions, and therefore the Company performed, during all or a portion of the Period, virtually all of Wells Fargo’s contractual duties for such transactions as its agent. As a result, for the Company’s Agent Role Transactions, the Company and Wells Fargo have determined that the Company is a party participating in the servicing function with respect to the CMBS Platform, and accordingly, the Company is taking responsibility for assessing its compliance with the Applicable Servicing Criteria (defined below) relevant to the servicing activities performed by the Company for the CMBS Platform, as of and for the twelve months ended December 31, 2025.
Period: As of January 1, 2025 through and including December 31, 2025 (the “Period”).
Platform: The platform consists of commercial mortgage-backed securities (“CMBS”) transactions backed by pools of commercial mortgage loans and/or backed by CMBS for which the Company provides trustee, securities administration, paying agent services, and/or related roles, either directly in the related role for such services or as the agent of the party performing such services, and for which either (a) some or all of the issued securities for such CMBS transactions were publicly offered pursuant to a registration statement delivered under the Securities Act of 1933, as amended, or (b) the issued securities for such CMBS transactions were privately offered pursuant to an exemption from registration and the Company (and/or the party for whom it acts agent) has an obligation under the transaction agreements to deliver an assessment of compliance with the applicable servicing criteria under Item 1122(d) of Regulation AB; provided however that, the platform excludes any transactions for which the offered
securities were issued, sponsored and/or guaranteed by any agency or instrumentality of the U.S. government or any government-sponsored entity (the “CMBS Platform”). Appendix A identifies the individual transactions defined by Management as constituting the CMBS Platform for the Period.
Applicable Servicing Criteria: All servicing criteria set forth in Item 1122(d) are applicable to either the Company’s obligations, or the obligations of the party for whom the Company ultimately acts as agent, in either case under the related transaction agreements with respect to the CMBS Platform for the Period (as applicable, the “Company’s Obligations”), except for the following servicing criteria: 1122(d)(4)(ii), 1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(vi), 1122(d)(4)(vii), 1122(d)(4)(viii), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii) and
1122(d)(4)(xiv), which Management has determined are not applicable to the Company’s Obligations with respect to the CMBS Platform for the Period; provided however that, with respect to the CMBS Platform (a) servicing criterion 1122(d)(1)(v) is applicable only to the Company’s Obligations related to the aggregation of information received and the conveyance of such information, in each case, as required by the transaction agreements, and (b) servicing criterion 1122(d)(4)(iii) is applicable only to the Company’s Obligations related to the process of making or effecting an addition, removal or substitution to the asset pool in accordance with the transaction agreements (the “Applicable Servicing Criteria”).
Third parties classified as vendors: With respect to servicing criterion 1122(d)(4)(i), the Company engaged a vendor to handle certain Uniform Commercial Code filing obligations required by the servicing criterion. With respect to servicing criterion 1122(d)(2)(vi) for certain transactions in the CMBS Platform, the Company engaged a vendor to make certain payments by check to investors and/or third parties, and such vendor also safeguards certain unissued checks. In each case, Management has determined that the vendor is not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and Management elects to take responsibility for assessing compliance with the portion of the servicing criterion applicable to each vendor as permitted by the SEC’s Compliance and Disclosure Interpretation (“C&DI”) 200.06, Vendors Engaged by Servicers (“C&DI 200.06”). The Company has policies and procedures in place designed to provide reasonable assurance that the activities of each vendor comply in all material respects with the servicing criterion applicable to the vendor. Management is solely responsible for determining that the Company meets the SEC requirements to apply C&DI 200.06 for each vendor and the related servicing criterion.
With respect to the CMBS Platform and the Period, Management provides the following assessment of the Company’s
compliance with respect to the Applicable Servicing Criteria:
1.Management is responsible for assessing the Company’s compliance with the Applicable Servicing Criteria.
2.Management has assessed the Company’s compliance with the Applicable Servicing Criteria, including the servicing criteria for which compliance is determined based on C&DI 200.06, as described above. In performing this assessment, Management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.
3.With respect to Applicable Servicing Criteria 1122(d)(1)(iii), 1122(d)(2)(iii), and 1122(d)(4)(iii), Management has determined that there were no activities performed during the Period with respect to the CMBS Platform, because there were no occurrences of events that would require the Company to perform such activities.
4.Based on such assessment for the Period, the Company has complied in all material respects with the Applicable Servicing Criteria for the Period.
PricewaterhouseCoopers LLP, an independent registered public accounting firm, has issued an attestation report with respect to Management’s assessment of the Company’s compliance with the Applicable Servicing Criteria for the Period.
Computershare Trust Company, National Association
By: /s/ Kristen Ann Cronin
Kristen Ann Cronin
Title: Senior Vice President
Dated: February 18, 2026
Appendix A to the Company’s Assessment of Compliance with the Applicable Servicing Criteria
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CMBS Platform Transactions |
Deal Key |
Long Name |
36502021-PF1 |
3650R 2021-PF1 Commercial Mortgage Trust Commercial Mortgage Pass-Through Certificates Series 2021-PF1 |
3650R2022-PF2 |
3650R 2022-PF2 Commercial Mortgage Trust Commercial Mortgage Pass-Through Certificates Series 2022-PF2 |
AHPT2024-ATRM |
Atrium Hotel Portfolio Trust 2024-ATRM Commercial Mortgage Pass- Through Certificates, Series 2024-ATRM |
AMMST2021-MF2 |
Arbor Multifamily Mortgage Securities Trust 2021-MF2 Multifamily Mortgage Pass-Through Certificates Series 2021-MF2 |
AMMST2021-MF3 |
Arbor Multifamily Mortgage Securities Trust 2021-MF3 Multifamily Mortgage Pass-Through Certificates Series 2021-MF3 |
AMMST2022-MF4 |
Arbor Multifamily Mortgage Securities Trust 2022-MF4 Multifamily Mortgage Pass-Through Certificates Series 2022-MF4 |
BAC 2006-4 |
Banc of America Commercial Mortgage Inc., Commercial Mortgage Pass-Through Certificates, Series 2006-4 |
BACM2016-UBS10 |
Bank of America Merrill Lynch Commercial Mortgage Trust 2016-UBS10, Commercial Mortgage Pass-Through Certificates, Series 2016-UBS10 |
BACM-2017-BNK3 |
Bank of America Merrill Lynch Commercial Mortgage Trust 2017-BNK3, Commercial Mortgage Pass-Through Certificates, Series 2017-BNK3 |
BACM2017-BNK6 |
BANK 2017-BNK6 Commercial Mortgage Pass-Through Certificates, Series 2017-BNK6 |
BACM2017-BNK9 |
BANK 2017-BNK9 Commercial Mortgage Pass-Through Certificates, Series 2017-BNK9 |
BACM2018-BNK12 |
BANK 2018-BNK12 Commercial Mortgage Pass-Through Certificates, Series 2018-BNK12 |
BACM2018-BNK15 |
BANK 2018-BNK15 Commercial Mortgage Pass-Through Certificates, Series 2018-BNK15 |
BACM2019-BNK18 |
BANK 2019-BNK18 Commercial Mortgage Pass-Through Certificates, Series 2019-BNK18 |
BACM2019-BNK21 |
BANK 2019-BNK21 Commercial Mortgage Pass-Through Certificates, Series 2019-BNK21 |
BACM2019-BNK24 |
BANK 2019-BNK24 Commercial Mortgage Pass-Through Certificates, Series 2019-BNK24 |
BACM2020-BNK27 |
BANK 2020-BNK27 Commercial Mortgage Pass-Through Certificates, Series 2020-BNK27 |
BACM2020-BNK30 |
BANK 2020-BNK30 Commercial Mortgage Pass-Through Certificates, Series 2020-BNK30 |
BACM2021-BNK33 |
BANK 2021-BNK33 Commercial Mortgage Pass-Through Certificates, Series 2021-BNK33 |
BACM2021-BNK36 |
BANK 2021-BNK36 Commercial Mortgage Pass-Through Certificates, Series 2021-BNK36 |
BAMLL2016-ISQR |
BAMLL Commercial Mortgage Securities Trust 2016-ISQR, Commercial Mortgage Pass-Through Certificates, Series 2016-ISQR |
BAMLL2017-AMO |
Del Amo Fashion Center Trust 2017-AMO Commercial Mortgage Pass- Through Certificates, Series 2017-AMO |
BAMLL2019-LIC |
Jackson Park Trust 2019-LIC, Commercial Mortgage Pass-Through Certificates, Series 2019-LIC |
BAMLL2020-BHP3 |
BAMLL Commercial Mortgage Securities Trust 2020-BHP3, Commercial Mortgage Pass-Through Certificates, Series 2020-BHP3 |
BAMLL2020-BOC |
BAMLL Commercial Mortgage Securities Trust 2020-BOC, Commercial Mortgage Pass-Through Certificates, Series 2020-BOC |
BAMLL2020-GRCE |
Grace Trust 2020-GRCE Commercial Mortgage Pass-Through Certificates, Series 2020-GRCE |
BANK2018-BNK11 |
BANK 2018-BNK11 Commercial Mortgage Pass-Through Certificates, Series 2018-BNK11 |
BANK2019-BNK23 |
BANK 2019-BNK23 Commercial Mortgage Pass-Through Certificates, Series 2019-BNK23 |
BANK2020-BNK26 |
BANK 2020-BNK26 Commercial Mortgage Pass Through Certificates, Series 2020-BNK26 |
BANK2020-BNK28 |
BANK 2020-BNK28 Commercial Mortgage Pass-Through Certificates, Series 2020-BNK28 |
BANK2020-BNK29 |
BANK 2020-BNK29 Commercial Mortgage Pass-Through Certificates, Series 2020-BNK29 |
BANK2021-BNK31 |
BANK 2021- BNK31 Commercial Mortgage Pass-Through Certificates, Series 2021-BNK31 |