MANAGEMENT'S REPORT ON ASSESSMENT OF COMPLIANCE WITH SEC REGULATION AB SERVICING CRITERIA
1. |
Situs Holdings, LLC (the “Company”), a wholly-owned subsidiary of SitusAMC Holdings Corporation (“SitusAMC”), is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB of the Securities and Exchange Commission (“SEC”), as of and for the year ended December 31, 2025 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report (collectively referred to as the “Special Servicing Platform” or the “Platform”) include asset-backed transactions and securities for which the Company served in the capacity of special servicer as defined in Appendix B. |
2. |
Except as set forth in paragraph 3 below, the Company used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to provide an assertion on the Company’s assessment of compliance with the applicable servicing criteria. |
3. |
The criteria listed in the column titled “Inapplicable Servicing Criteria” in Appendix A hereto are inapplicable to the Company based on the activities it performed, directly or through its Vendors, with respect to the Platform for the Reporting Period. |
4. |
With respect to servicing criterion 1122(d)(2)(vii), the Company has engaged various vendors to perform some or all of the activities required by these servicing criteria. Management has determined that these vendors are not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and has elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by the SEC’s Compliance & Disclosure Interpretation 200.06, Vendors Engaged by Servicers (“C&DI 200.06”), formerly Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations. As permitted by C&DI 200.06, management asserts that it has policies and procedures in place designed to provide reasonable assurance that the vendor’s activities comply in all material respects with the servicing criteria applicable to each vendor. Management is not aware of any material deficiencies in such policies and procedures or any material instances of non-compliance of the servicing criteria as relates to the Company by such vendors. Management is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendors and related criteria. |
5. |
During the Reporting Period, there were no payments on pool assets on the Platform, therefore the Company did not perform any servicing activities related to criterion 1122(d)(2)(i) as of and for the year ended December 31, 2025. |
6. |
During the Reporting Period, there were no wire disbursements made on behalf of the obligor for pool assets on the Platform, therefore the Company did not perform any servicing activities related to criterion 1122(d)(2)(ii) as of and for the year ended December 31, 2025. |
7. |
During the Reporting Period, there were no additions, removals, or substitutions made on behalf of the obligor for pool assets on the Platform, therefore the Company did not perform any servicing activities related to criterion 1122(d)(4)(iii) as of and for the year ended December 31, 2025. |
8. |
During the Reporting Period, there were no active assets carrying an escrow balance maintained by the Company or escrow disbursements paid on behalf of an obligor by the Company, therefore the Company did not perform any servicing activities related to criteria 1122(d)(4)(x-xiii) as of and for the year ended December 31, 2025. |
9. |
During the Reporting Period, there were no assets charged off or accounts determined to be uncollectible on the Platform, therefore the Company did not perform any servicing activities related to criterion 1122(d)(4)(xiv) as of and for the year ended December 31, 2025. |
