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| Glen Peters Chief Financial Officer/Chief Operating Officer | 3500 Lenox Road, Suite G1 Atlanta, GA 30326 | trimontrea.com |
MANAGEMENT'S REPORT ON ASSESSMENT OF COMPLIANCE WITH SEC REGULATION AB SERVICING CRITERIA
Trimont Real Estate Advisors, LLC
February 28, 2023
Glen Peters, Chief Financial Officer / Chief Operating Officer
Trimont Real Estate Advisors Atlanta | Dallas | Kansas City | London | Sydney
Appendix A – Applicable Servicing Criteria
SERVICING CRITERIA | APPLICABLE SERVICING CRITERIA | INAPPLICABLE SERVICING | |||
Reference | Criteria | Performed | Performed by Vendor(s) for which Trimont is the Responsible Party | Performed by | NOT performed Vendor(s) retained by Trimont |
General Servicing Considerations | |||||
1122(d)(1)(i) | Policies and procedures are instituted to monitor any | 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 |
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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 | 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 |
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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. |
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| X |
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. | X1 |
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1 This criterion is only applicable to the COMM 2012-CCRE2, GSMS 2016-GS3, and GSMS 2018-GS10 portfolio servicing agreements. 1122(d)(2)(iii) is inapplicable to all other servicing agreements that make up the Platform.
Trimont Real Estate Advisors
SERVICING CRITERIA | APPLICABLE SERVICING CRITERIA | INAPPLICABLE SERVICING | |||
Reference | Criteria | Performed | Performed by Vendor(s) for which Trimont is the Responsible Party | Performed by | NOT performed |
1122(d)(2)(iv) | The related accounts for the transaction, such as cash | X |
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1122(d)(2)(v) | Each custodial account is maintained at a federally insured | X |
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1122(d)(2)(vi) | Unissued checks are safeguarded so as to prevent | X |
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1122(d)(2)(vii) | Reconciliations are prepared on a monthly basis for all | X2 | X2 |
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Investor Remittances and Reporting | |||||
1122(d)(3)(i) | Reports to investors, including those to be filed with the |
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| X |
2 Servicing activities associated with criterion 1122(d)(2)(vii) are performed by the Company and a third-party vendor for which the Company is the responsible party.
Trimont Real Estate Advisors
SERVICING CRITERIA | APPLICABLE SERVICING CRITERIA | INAPPLICABLE SERVICING | |||
Reference | Criteria | Performed | Performed by Vendor(s) for which Trimont is the Responsible Party | Performed by | NOT performed |
1122(d)(3)(ii) | Amounts due to investors are allocated and remitted in |
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| X |
1122(d)(3)(iii) | Disbursements made to an investor are posted within two |
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| X |
1122(d)(3)(iv) | Amounts remitted to investors per the investor reports |
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| X |
Pool Asset Administration | |||||
1122(d)(4)(i) | Collateral or security on pool assets is maintained as | X |
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1122(d)(4)(ii) | Pool assets and related documents are safeguarded as |
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| X |
1122(d)(4)(iii) | Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements. | X |
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1122(d)(4)(iv) | Payments on pool assets, including any payoffs, made in |
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| X |
1122(d)(4)(v) | The servicer's records regarding the pool assets agree |
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| X |
Trimont Real Estate Advisors
SERVICING CRITERIA | APPLICABLE SERVICING | INAPPLICABLE SERVICING | |||
Reference | Criteria | Performed | Performed by Vendor(s) for which Trimont is the Responsible Party | Performed by | NOT performed |
1122(d)(4)(vi) | Changes with respect to the terms or status of an obligor's mortgage loans (e.g., loan modifications or re-aging's) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents. | X |
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1122(d)(4)(vii) | Loss mitigation or recovery actions (e.g. forbearance plans, | X |
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1122(d)(4)(viii) | Records documenting collection efforts are maintained during | X |
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1122(d)(4)(ix) | Adjustments to interest rates or rates of return for pool assets |
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| X |
1122(d)(4)(x) | Regarding any funds held in trust for an obligor (such as |
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| X |
1122(d)(4)(xi) | Payments made on behalf of an obligor (such as tax or |
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| X |
Trimont Real Estate Advisors
1122(d)(4)(xii) | Any late payment penalties in connection with any payment to |
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| X |
SERVICING CRITERIA | APPLICABLE SERVICING | INAPPLICABLE SERVICING | |||
Reference | Criteria | Performed | Performed by Vendor(s) for which Trimont is the Responsible Party | Performed by | NOT performed |
1122(d)(4)(xiii) | Disbursements made on behalf of an obligor are posted within |
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| X |
1122(d)(4)(xiv) | Delinquencies, charge-offs and uncollectible accounts are |
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| X |
1122(d)(4)(xv) | Any external enhancement or other support, identified in Item |
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| X |
Trimont Real Estate Advisors
APPENDIX B – The Platform
Trimont Real Estate Advisors, LLC was named as the Special Servicer for all portfolios listed below. However, there was only activity requiring Trimont Real Estate Advisors, LLC to perform the role as Special Servicer for the portfolios designated with a “X” throughout the period in scope listed below.
Portfolio Name | Servicing | Period in Scope | Special Servicing 2022 |
GSMS 2021-ROSS | May 28, 2021 | January 1, 2022 - December 31, 2022 |
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BSREP 2021-DC | August 16, 2021 | January 1, 2022 - December 31, 2022 |
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225 Liberty Street Trust 2016 | February 6, 2016 | January 1, 2022 - December 31, 2022 |
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GSMS 2016-GS3 | September 1, 2016 | January 1, 2022 - December 31, 2022 |
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Bancorp 2017-CRE2 | August 30, 2017 | January 1, 2022 - December 31, 2022 | X |
CGMS 2017-MDDR | July 6, 2017 | January 1, 2022 - July 12, 2022 |
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MSC 2017-ASHF | December 9, 2017 | January 1, 2022 - December 31, 2022 |
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Trimont Real Estate Advisors
Portfolio Name | Servicing | Period in Scope | Special Servicing 2022 |
CSMC 2017-PFHP | December 19, 2017 | January 1, 2022 - December 31, 2022 | X |
GSMS 2018-GS10 | July 1, 2018 | January 1, 2022 - December 31, 2022 |
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Bancorp 2018-CRE4 | September 27, 2018 | January 1, 2022 - December 31, 2022 | X |
Bancorp 2018-CRE3 | March 29, 2018 | January 1, 2022 - December 31, 2022 |
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AHT1 2018-KEYS | July 16, 2018 | January 1, 2022 - December 31, 2022 | X |
GSMS 2018-TWR | July 31, 2018 | January 1, 2022 - December 31, 2022 |
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COMM 2012 CCRE2 | August 1, 2018 | January 1, 2022 - December 31, 2022 | X |
JPMCC 2018-MINN | December 7, 2018 | January 1, 2022 - December 31, 2022 | X |
CF 2019-BOSS | November 26, 2019 | January 1, 2022 - December 31, 2022 | X |
Trimont Real Estate Advisors
Portfolio Name | Servicing | Period in Scope | Special Servicing 2022 |
Bancorp 2019-CRE5 | March 28, 2019 | January 1, 2022 - December 31, 2022 | X |
BBCMS 2019-CORE | March 15, 2019 | January 1, 2022 - December 31, 2022 |
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BX 2019-MMP | August 29, 2019 | January 1, 2022 - December 22, 2022 |
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CAMB Trust 2019-LIFE | January 9, 2019 | January 1, 2022 - December 31, 2022 |
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MTRO 2019-TECH | February 9, 2019 | January 1, 2022 - April 15, 2022 |
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NOHT 2019-HNLA | May 15, 2019 | January 1, 2022 - February 19, 2022 |
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NYT 2019-NYT | January 30, 2019 | January 1, 2022 - December 31, 2022 |
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JPMCC 2020-ACE | February 20, 2020 | January 1, 2022 - December 31, 2022 |
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FRESB 2017-SB28 | June 1, 2017 | January 1, 2022 - December 31, 2022 | X |
Trimont Real Estate Advisors
Portfolio Name | Servicing | Period in Scope | Special Servicing 2022 |
FRESB 2017-SB32 | March 1, 2017 | January 1, 2022 - December 31, 2022 | X |
FREMF 2015-KF07 | April 1, 2015 | January 1, 2022 - December 31, 2022 |
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VMC FINANCE 2018-FL2 LLC | November 7, 2018 | January 1, 2022 - July 21, 2022 |
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VMC 2019-FL3 | October 3, 2019 | January 1, 2022 - December 31, 2022 | X |
VMC FINANCE 2021-FL4 LLC | May 25, 2021 | January 1, 2022 - December 31, 2022 |
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VMC 2021-HT1 LTD | December 8, 2021 | January 1, 2022 - December 31, 2022 |
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VMC 2022-FL5 LLC | March 10, 2022 | March 10, 2022 - December 31, 2022 |
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GPMT 2018-FL1 LTD | May 9, 2018 | January 1, 2022 to April 7, 2022 |
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GPMT 2019-FL2 | February 28, 2019 | January 1, 2022 - December 31, 2022 | X |
GPMT 2021-FL3 LTD | May 14, 2021 | January 1, 2022 - December 31, 2022 |
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GPMT 2021 FL4, LTD | November 16, 2021 | January 1, 2022 - December 31, 2022 |
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NLY 2019-FL2 ISSUER | February 28, 2019 | January 1, 2022 - December 31, 2022 |
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Trimont Real Estate Advisors