MANAGEMENT’S REPORT ON ASSESSMENT OF COMPLIANCE WITH SEC REGULATION AB SERVICING CRITERIA
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1. |
Berkadia Commercial Mortgage LLC (the “Company” or “Berkadia”), 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 “Primary Servicing Platform” or the “Platform”) are all asset-backed securities and transactions for which the Company was named as primary servicer of commercial mortgage loans. |
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. |
During the reporting period, there we no additions, removals, or substitutions to the asset pool on the platform, therefore the Company did not perform any servicing activities related to criteria 1122(d)(4)(iii) during the reporting period. |
5. |
During the reporting period, there were no charge-offs on the Platform, therefore the Company did not perform any servicing activities related to criteria 1122(d)(4)(xiv) during the reporting period. |
6. |
With respect to servicing criteria 1122(d)(2)(i), 1122(d)(2)(iii), 1122(d)(4)(i), 1122(d)(4)(xi), and through 1122(d)(4)(xiii), 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 it 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. |
7. |
The Company has complied, in all material respects, with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB, as of and for the year ended December 31, 2025 with respect to the Platform taken as a whole. |
8. |
Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on the Company’s assertion on compliance with the applicable servicing criteria for the Reporting Period. |
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Berkadia Commercial Mortgage LLC February 13, 2026 2/13/2026
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Damon Rankin, Chief Financial Officer |
Appendix A – Applicable Servicing Criteria
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SERVICING CRITERIA |
APPLICABLE SERVICING CRITERIA |
INAPPLICABLE SERVICING CRITERIA |
Reference |
Criteria |
Performed Directly by Berkadia |
Performed by Vendor(s) for which Berkadia is the Responsible Party |
Performed by Subservicer(s) or Vendor(s) for which Berkadia is NOT the Responsible Party |
NOT performed by Berkadia or by Subservicer(s) or Vendor(s) retained by Berkadia |
General Servicing Considerations |
1122(d)(1)(i) |
Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements. |
X |
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1122(d)(1)(ii) |
If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities. |
X |
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1122(d)(1)(iii) |
Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained. |
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X |
1122(d)(1)(iv) |
A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements. |
X |
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1122(d)(1)(v) |
Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information. |
X |
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Cash Collection and Administration |
1122(d)(2)(i) |
Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of days specified in the transaction agreements. |
X |
X |
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1122(d)(2)(ii) |
Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel. |
X |
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1122(d)(2)(iii) |
Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements. |
X |
X |
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SERVICING CRITERIA |
APPLICABLE SERVICING CRITERIA |
INAPPLICABLE SERVICING CRITERIA |
Reference |
Criteria |
Performed Directly by Berkadia |
Performed by Vendor(s) for which Berkadia is the Responsible Party |
Performed by Subservicer(s) or Vendor(s) for which Berkadia is NOT the Responsible Party |
NOT performed by Berkadia or by Subservicer(s) or Vendor(s) retained by Berkadia |
1122(d)(2)(iv) |
The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements. |
X |
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1122(d)(2)(v) |
Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of §240.13k-1(b)(1) of this chapter. |
X |
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1122(d)(2)(vi) |
Unissued checks are safeguarded so as to prevent unauthorized access. |
X |
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1122(d)(2)(vii) |
Reconciliations are prepared on a monthly basis for all asset- backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations: (A) Are mathematically accurate; (B) Are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) Are reviewed and approved by someone other than the person who prepared the reconciliation; and (D) Contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements. |
X |
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Investor Remittances and Reporting |
1122(d)(3)(i) |
Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports: (A) Are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) Provide information calculated in accordance with the terms specified in the transaction agreements; (C) Are filed with the Commission as required by its rules and regulations; and (D) Agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the servicer. |
X1 |
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1 Specifically, as it relates to criterion 1122(d)(3)(i)(C), Berkadia did not perform the activity described in this criterion for the Reporting Period as this component of 1122(d)(3)(i) is inapplicable to the functions performed by Berkadia.