Management Assessment Report

Management of Wilmington Trust National Association (the Company) is responsible for assessing compliance with the applicable servicing criteria set forth in Item 1122(d)(2)(iii) of Regulation AB of the Securities and Exchange Commission relating to the servicing of mortgage related asset-backed transactions initiated or amended for purposes of Regulation AB on or after January 1, 2006, for which the Company provides trustee services (the Platform) as of and for the year ended December 31, 2025. Management has determined that all other criteria set forth in Item 1122(d) are not applicable to the servicing activities performed by the Company with respect to the Platform. Appendix A to this report identifies the mortgage related asset-backed transactions defined by management as constituting the Platform.

The Company’s management has assessed the Company’s compliance with the applicable servicing criteria as of and for the year ended December 31, 2025. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in criteria (d)(2)(iii) of Item 1122 of Regulation AB.

With respect to the Company’s obligation to advance funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such services for advances under applicable servicing criterion 1122(d)(2)(iii), there were no activities performed during the year ended December 31, 2025 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.

Based on such assessment, management believes that, as of and for the year ended December 31, 2025, the Company has complied in all material respects with the servicing criteria set forth in Item 1122(d)(2)(iii) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform.

PricewaterhouseCoopers LLP, a registered public accounting firm, has issued an attestation report with respect to management’s assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2025.

List of Transactions – Appendix A