September 9, 2020
Arthur Sandel
Special Counsel
Office of Structured Finance
Special Counsel
Office of Structured Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | BBCMS Mortgage Trust 2019-C4 Form 10-K for Fiscal Year Ended December 31, 2019 Filed March 23, 2020 File No. 333-226850-03 |
Dear Mr. Sandel:
We are acting as counsel to Barclays Commercial Mortgage Securities LLC (“Barclays”) in connection with your letter dated August 26, 2020 transmitting the comment (the “Comment”) of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the above-captioned Form 10-K filing (the “Filing”). We have reviewed the Comment and the Filing and have discussed the Comment with representatives of Barclays.
For your convenience, the Staff’s comment is repeated in italics below, followed by the response of Barclays.
Exhibit 33.47
1. | We note that Exhibit 33.47, the assessment of compliance with servicing criteria by Situs Holdings, LLC, states that inapplicable servicing criteria are listed in an Appendix A. However, there is no Appendix A attached to the exhibit. Please amend your Form 10-K with a revised Exhibit 33.47 that includes Appendix A, or otherwise disclose which servicing criteria are applicable to the Situs Holdings, LLC platform. |
Appendix A was inadvertently omitted from the version of the exhibit included as part of the Filing. We will file an amended report on Form 10-K that includes the entire exhibit.
In responding to the Staff’s comment with respect to the Filing, Barclays has authorized us to acknowledge on their behalf, and we hereby acknowledge, that:
Anna H. Glick Tel +1 212 504-6309 Fax +1 212 504-6666 anna.glick@cwt.com
Arthur Sandel September 9, 2020 |
• | Barclays is responsible for the adequacy and accuracy of the disclosure in the Filing; |
• | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Filing; and |
• | Barclays may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please contact me with any questions you have regarding the foregoing.
Very truly yours, | |||
| /s/ Anna H. Glick | ||
Anna H. Glick | |||
cc: | Daniel Vinson Steven Glynn, Esq. Melissa Roosevelt, Esq. Molly Coffey, Esq. |
Page 2