Exhibit 33.2
419 Belle Air Ln.
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March 1, 2022
Management’s Report on Assessment of 2021 Compliance with Applicable Regulation AB Servicing Criteria
Greystone Servicing Company LLC and Subsidiaries (the Asserting Party) is responsible for assessing its compliance as of and for the year ended December 31, 2021 (the Reporting Period) with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations. The assessment concerns the Asserting Party's servicing efforts for its servicing “Platforms,” which consist of all the commercial and multifamily loans serviced by the Asserting Party as described in Appendix I.
The Asserting Party is responsible for assessing its compliance with the servicing criteria applicable to it. The Asserting Party used the criteria in paragraph (d) of Section 1122 of Regulation AB (17 C.F.R.229.1122) to assess its compliance. The servicing criteria applicable to the Platforms are listed in Appendix II as indicated.
The Asserting Party has engaged vendors to perform generalized work related to performing tax searches, payment on taxes, reporting of tax information, and issuance of flood insurance certifications. The Asserting Party has determined that these vendors are not considered “servicers” as defined in item 1101(j) of Regulation AB, and has elected to take responsibility for assessing compliance with the servicing criteria applicable to these vendors as permitted by Section 200.06 of the Compliance and Disclosure Interpretations (Section 200.06). The Asserting Party 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 those vendors. The Asserting Party requires these vendors to provide to the Asserting Party a Report on Assessment of Compliance With Regulation AB Servicing Criteria, as the means of assessing our compliance with Servicing Criterion (d)(1)(ii). The Asserting Party has not identified and is not aware of any material instances of noncompliance by the vendors.
The Asserting Party has assessed its compliance with the applicable servicing criteria for the Reporting Period and has concluded that the Asserting Party has complied, in all material respects, with the applicable servicing criteria as of December 31, 2021, and for the Reporting Period with respect to the Platforms taken as a whole.
RSM US LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the applicable servicing criteria for the reporting period as set forth in this assertion.
March 1, 2022 |
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/s/ Stephen Rosenberg Stephen Rosenberg, President and Chief Executive Officer
/s/ Marc Fox Marc Fox, Chief Financial Officer
/s/ Sharon Briskman Sharon Briskman, Executive Vice President – Servicing and Asset Management |
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Appendix I
Listing of Assets or Platforms Subject to the Servicing Criteria Specified in Paragraph (d) of Item
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Platform A | All loans, other than Platforms B, C, and D, serviced by Greystone Servicing Company LLC during the year ending December 31, 2021. | All issuers for loans, other than Platforms B, C, and D, serviced by Greystone Servicing Company LLC during the year ending December 31, 2021. | N/A | N |
Platform B | All loans serviced by Greystone Servicing Company LLC during the year ending December 31, 2021 held by Greystone Commercial Real Estate Notes 2018-HC1, Ltd., Greystone CRE Notes 2019-FL2, Ltd., Greystone CRE Notes 2021-FL3, Ltd., Greystone CRE Notes 2021- HC2, Ltd., securitized Freddie Mac loans and the following loans: #7218 - Bella Terra Apartments, #30072 - Huntington Ridge Apartments, #30085 - Renaissance Apartments, #30059 - Atlantic Sweetwater, #30062 - The Crossroads at Arlington Apartments, #30064 - Tacara at Stone Oak Apartments, #30097 - The Reserve at St. Johns River Apartments, #39000 - Seaview Estates, #39002 - Townhouse & Park Avenue, #39001 - Nassau & Throngs Neck, #3949 Bel Aire Apartments, #390020 - Veritas 23 Portfolio and #40000 - 808 N Cleveland Avenue | Greystone | N/A | N |
Platform C | All loans that name Greystone Servicing Company LLC (or its predecessor, C-III Asset Management LLC) as Special Servicer during the year ended December 31, 2021. | All issuers of mortgage-backed securities for which Greystone Servicing Company LLC (or its predecessor, C-III Asset Management LLC) acted as Special Servicer involving first lien commercial mortgage loans. | BA FUNB 2001-3* BACM 2005-1 BACM 2006-2* BACM 2006-4* BAMLL 2019-BPR* BANK 2020-BNK30* BANK 2021-BNK34* BMARK 2021-B24* BSCMI 2006-PWR14* BSCMS 2004-PWR3* BSCMS 2004-PWR6* BSCMS 2005-PWR7* BSCMS 2006-PWR11* BSCMS 2006-PWR12* BSCMS 2006-PWR13 BSCMS 2007-PWR15 BSCMS 2007-PWR16 BSCMSI 2006-TOP22* BSCMSI 2006-TOP24* BSCMSI 2007-TOP26* | Y |
Appendix I
Listing of Assets or Platforms Subject to the Servicing Criteria Specified in Paragraph (d) of Item
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Platform C | All loans that name Greystone Servicing Company LLC (or its predecessor, C-III Asset Management LLC) as Special Servicer during the year ended December 31, 2021. | All issuers of mortgage-backed securities for which Greystone Servicing Company LLC (or its predecessor, C-III Asset Management LLC) acted as Special Servicer involving first lien commercial mortgage loans. | BSCMSI 2007-TOP28* CD 2006-CD2* CD 2006-CD3* CSFB 2004-C4* CSFB 2005-C3* GCC 2021-3* GMAC 2004-C1* JPMCC 2006-CB16 JPMCC 2007-LDP11 | Y |
Appendix I
Listing of Assets or Platforms Subject to the Servicing Criteria Specified in Paragraph (d) of Item
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Platform C (Continued) | All loans that name Greystone Servicing Company LLC (or its predecessor, C-III Asset Management LLC) as Special Servicer during the year ended December 31, 2021. | All issuers of mortgage-backed securities for which Greystone Servicing Company LLC (or its predecessor, C-III Asset Management LLC) acted as Special Servicer involving first lien commercial mortgage loans. | JPMCC 2013-LC11 LBUBS 2006-C3* LBUBS 2007-C7 MLCFC 2006-3* MLMT 2005-CKI1 MSC 2007 HQ11* MSC 2016-BNK2 MSCI 2006-IQ12 MSCI 2006-TOP23 MSCI 2007-IQ15* MSCI 2007-TOP25* NCMS 2018-FL1 SGCMS 2020-COVE* SOV 2007-C1* TIAA 2007-C4 WFCM 2016-C36 WFCM 2019-C51 | Y |
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Platform D | All loans serviced by Greystone Servicing Company LLC during the year ending December 31, 2021 held by Exantas Capital Corp. 2019-RSO7, Ltd., Exantas Capital Corp. 2020-RSO8, Ltd., Exantas Capital Corp. 2020- RSO9, Ltd., ACRES Commercial Realty 2021-FL1 Issuer, Ltd. and ACRES Commercial Realty 2021- FL2 Issuer, Ltd. | Exantas Capital Corp. 2019- RSO7, Ltd., Exantas Capital Corp. 2020-RSO8, Ltd., Exantas Capital Corp. 2020-RSO9, Ltd., ACRES Commercial Realty 2021-FL1 Issuer, Ltd., ACRES Commercial Realty 2021-FL2 Issuer, Ltd. | N/A | N |
*There were no loans related to these securitizations that were specially serviced by Greystone Servicing Company LLC during 2021.
Appendix II
Applicable Servicing Criteria Specified in Paragraph (d) of Item 1122 of Regulation AB for the
Following Platforms
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Appendix II
Applicable Servicing Criteria Specified in Paragraph (d) of Item 1122 of Regulation AB for the
Following Platforms
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Appendix II
Applicable Servicing Criteria Specified in Paragraph (d) of Item 1122 of Regulation AB for the
Following Platforms
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Appendix II
Applicable Servicing Criteria Specified in Paragraph (d) of Item 1122 of Regulation AB for the
Following Platforms
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*There were no activities performed during the year ended December 31, 2021 with respect to the Platform because there were no occurrences of events that would require the Company to perform such activities.