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Wells Fargo Bank, National Association 600 South 4th Street Minneapolis, MN 55415 |
ASSESSMENT OF COMPLIANCE WITH THE APPLICABLE SERVICING CRITERIA
CMBS Platform
The management (“Management”) of the Corporate Trust Services division of Wells Fargo Bank, National Association (the “Company” or “Wells Fargo”) 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 in regard to the servicing platform for the period as follows:
Sale of Corporate Trust Services Business. On November 1, 2021, Wells Fargo and certain of its affiliates sold substantially all of its Corporate Trust Services (“CTS”) division to Computershare Trust Company, N.A. (“Computershare Trust Company”), Computershare Delaware Trust Company (“CDTC”), and Computershare Limited (“Computershare Limited,” and collectively with Computershare Trust 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. See Appendix B for more information regarding such transition as it relates to the CMBS Platform (defined below).
Period: As of and for the twelve months ended 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 was appointed to perform trustee, securities administration, paying agent services, and/or related 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 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, (i) 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, and (ii) the platform excludes any transactions for which the offered securities were issued pursuant to a transaction that closed prior to January 1, 2006 and for which the Company outsources all material servicing activities (as defined by Regulation AB) to a party other than Computershare Trust Company or any affiliate thereof (the “CMBS Platform”). As a result of Wells Fargo’s sale of the CTS division to Computershare, Wells Fargo has not accepted any appointments to perform trustee, securities administration, paying agent services, and/or related services on new CMBS transactions after November 1, 2021, other than a few exceptions to facilitate the transition of the CTS business to Computershare. Appendix A identifies the individual transactions defined by Management as constituting the CMBS Platform for the Period.
Applicable Servicing Criteria for the Period: Management has determined that the following servicing criteria set forth in Item 1122(d) are relevant to the servicing activities performed by the Company with respect to the CMBS Platform transactions for the Period: 1122(d)(1)(ii), 1122(d)(1)(iv), and 1122(d)(2)(iii) (the “Applicable Servicing Criteria”). Management has determined that all other servicing criteria set forth in Item 1122(d) are not applicable to the Company’s servicing activities with respect to the CMBS Platform for the Period.
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. 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 Criterion 1122(d)(2)(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.
KPMG 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.
WELLS FARGO BANK, National Association
By: /s/ Robin A. Phelan
Robin A. Phelan
Title: Vice President
Dated: February 27, 2026
Appendix A to the Company’s Assessment of Compliance with the Applicable Servicing Criteria
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CMBS Platform Transactions |
Wells Fargo Deal Identifier |
Long Name |
36502021-PF1 |
3650R 2021-PF1 Commercial Mortgage Trust Commercial Mortgage Pass-Through Certificates Series 2021-PF1 |
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 |
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 |
Appendix B to the Company’s Assessment of Compliance with the Applicable Servicing Criteria
Wells Fargo’s transfer of its roles on the CMBS Platform transactions to Computershare is ongoing. As of the beginning of the Period, Wells Fargo had not transferred to Computershare the roles associated with its trustee, securities administration, paying agent services, and/or related services, and the duties, rights, and liabilities for such roles, under the relevant agreements for any of the CMBS Platform transactions. During all or a portion of the Period, for all the CMBS Platform transactions, Wells Fargo engaged Computershare as a subservicer1 to perform virtually all of Wells Fargo’s obligations pertaining to such roles under the transaction agreements. As a result, the Company has determined that Computershare is a party participating in the servicing function with respect to the CMBS Platform and the applicable servicing criteria relevant to the servicing activities performed by Computershare for the CMBS Platform (the “Computershare Applicable Servicing Criteria”). Accordingly, Computershare is taking, and Wells Fargo is not taking, responsibility for assessing Computershare’s compliance with the Computershare Applicable Servicing Criteria for the CMBS Platform, as of and for the twelve months ended December 31, 2025.