0001193125-16-523606.txt : 201603300001193125-16-523606.hdr.sgml : 2016033020160330152832ACCESSION NUMBER:0001193125-16-523606CONFORMED SUBMISSION TYPE:10-KPUBLIC DOCUMENT COUNT:51CONFORMED PERIOD OF REPORT:2015123100012583610001541001FILED AS OF DATE:20160330DATE AS OF CHANGE:20160330Commercial mortgages

FILER:

COMPANY DATA:COMPANY CONFORMED NAME:Citigroup Commercial Mortgage Trust 2012-GC8CENTRAL INDEX KEY:0001556811STANDARD INDUSTRIAL CLASSIFICATION:ASSET-BACKED SECURITIES [6189]STATE OF INCORPORATION:DE

FILING VALUES:FORM TYPE:10-KSEC ACT:1934 ActSEC FILE NUMBER:333-166711-02FILM NUMBER:161539212

BUSINESS ADDRESS:STREET 1:388 GREENWICH STREETCITY:NEW YORKSTATE:NYZIP:10013BUSINESS PHONE:2128166000

MAIL ADDRESS:STREET 1:388 GREENWICH STREETCITY:NEW YORKSTATE:NYZIP:10013

10-K1d139354d10k.htmFORM 10-K

Form 10-K

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K

xANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2015

or

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from to

Commission file number

333-166711-02

(Commission File Number of issuing entity)

0001556811

(CentralIndex Key Number of issuing entity)

Citigroup Commercial Mortgage Trust 2012-GC8

(Exact name of issuing entity as specified in its charter)

333-166711

(CommissionFile Number of depositor)

0001258361

(Central Index Key Number of depositor)

CitigroupCommercial Mortgage Securities Inc.

(Exact name of depositor as specified in its charter)

Citigroup Global Markets Realty Corp.

(Central Index Key Number: 0001541001)

Goldman Sachs Mortgage Company

(Central Index Key Number: 0001541502)

Natixis Real Estate Capital LLC

(Central Index Key Number: 0001542256)

(Exact name of sponsor as specified in its charter)

New York

90-6223187

90-6223322

90-6223352

(State or other jurisdiction of

organization of the issuing entity)

(I.R.S. Employer

Identification No.)

c/o Citibank, N.A.

388 Greenwich Street, 14th Floor

New York, New York 10013

(Address of principal executive offices of issuing entity)

(212) 816-5614

Registrants telephone number, including area code

Securities registered pursuant to Section 12(b) of the Act:

None

Securitiesregistered pursuant to section 12(g) of the Act:

None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.YesxNo

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.YesxNo

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90days.xYesNo

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File requiredto be submitted and posted pursuant to Rule 405 of Regulation S-T ( 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files).

Not Applicable

Indicate by check mark ifdisclosure of delinquent filers pursuant to Item 405 of Regulation S-K ( 229.405 of this chapter) is not contained herein, and will not be contained, to the best of registrants knowledge, in definitive proxy or information statementsincorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K.

Not Applicable

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or a smaller reporting company. Seethe definitions of large accelerated filer, accelerated filer and smaller reporting company in Rule 12b-2 of the Exchange Act.

LargeacceleratedfilerAcceleratedfiler

Non-accelerated filerx(Do not check if a smaller reporting company)Smallerreportingcompany

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of theAct).Yes xNo

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at which the commonequity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrants most recently completed second fiscal quarter.

Not Applicable

Indicate by check mark whetherthe registrant has filed all documents and reports required to be filed by Section 12, 13 or 15(d) of the Securities Exchange Act of 1934 subsequent to the distribution of securities under a plan confirmed by a court.

Not Applicable

Indicate the number of sharesoutstanding of each of the registrants classes of common stock, as of the latest practicable date.

Not Applicable

DOCUMENTS INCORPORATED BY REFERENCE

Listhereunder the following documents if incorporated by reference and the Part of the Form 10-K (e.g., Part I, Part II, etc.) into which the document is incorporated: (1) Any annual report to security holders; (2) Any proxy or information statement;and (3) Any prospectus filed pursuant to Rule 424(b) or (c) under the Securities Act of 1933. The listed documents should be clearly described for identification purposes (e.g., annual report to security holders for fiscal year ended December 24,1980).

See Item 15.

PART I

Item1.Business.

Omitted.

Item1A.Risk Factors.

Omitted.

Item1B.Unresolved Staff Comments.

None.

Item2.Properties.

Omitted.

Item3.Legal Proceedings.

Omitted.

Item4.Mine Safety Disclosures.

Not applicable.

PART II

Item5.Market for Registrants Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities.

Omitted.

Item6.Selected Financial Data.

Omitted.

Item7.Managements Discussion and Analysis of Financial Condition and Results of Operations.

Omitted.

Item7A.Quantitative and Qualitative Disclosures About Market Risk.

Omitted.

Item8.Financial Statements and Supplementary Data.

Omitted.

Item9.Changes in and Disagreements With Accountants on Accounting and Financial Disclosure.

Omitted.

Item9A.Controls and Procedures.

Omitted.

Item9B.Other Information.

None.

PART III

Item10.Directors, Executive Officers and Corporate Governance.

Omitted.

Item11.Executive Compensation.

Omitted.

Item12.Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters.

Omitted.

Item13.Certain Relationships and Related Transactions, and Director Independence.

Omitted.

Item14.Principal Accounting Fees and Services.

Omitted.

ADDITIONAL DISCLOSURE ITEMS REQUIRED BY GENERAL INSTRUCTION J(2)

Item 1112(b) of Regulation AB

The property securing theMiami Center mortgage loan constitutes a significant obligor within the meaning of Item 1101(k)(2) of Regulation AB and as disclosed in the Prospectus Supplement for Citigroup Commercial Mortgage Trust 2012-GC8 filed on September 24, 2012.Inaccordance with Item 1112(b) of Regulation AB, the most recent unaudited net operating income of the significant obligor was $13,688,159 for the twelve month period ended December 31, 2015.

Item 1114(b)(2) and Item 1115(b) of Regulation AB

Noentity or group of affiliated entities provides any external credit enhancement, uses any derivative instruments or other support for the certificates within this transaction.

Item 1117 of Regulation AB

Disclosure from Citibank,N.A., as Certificate Administrator:

On June 18, 2014, a civil action was filed against Citibank, N.A. (Citibank) in the Supreme Courtof the State of New York by a group of investors in 48 private-label RMBS trusts for which Citibank allegedly serves or did serve as trustee, asserting claims for purported violations of the Trust Indenture Act of 1939, breach of contract, breach offiduciary duty and negligence based on Citibanks alleged failure to perform its duties as trustee for the 48 RMBS trusts.On November 24, 2014, plaintiffs sought leave to withdraw this action.On the same day, a smaller subset ofsimilar plaintiff investors in 27 private-label RMBS trusts for which Citibank allegedly serves or did serve as trustee, filed a new civil action against Citibank in the United States District Court for the Southern District of New York assertingsimilar claims as the prior action filed in state court.In January 2015, the court closed plaintiffs original state court action.Citibanks motion to dismiss the federal complaint was fully briefed as of May 13, 2015.OnSeptember 8, 2015, the federal court dismissed all claims as to 24 of the 27 trusts and allowed certain of the claims to proceed as to the other three trusts. That case, involving the three remaining trusts, is pending.

On November 24, 2015, the same investors that brought the federal case brought a new civil action in the Supreme Court of the State of New York related to 25private-label RMBS trusts for which Citibank allegedly serves or did serve as trustee.This case includes

the 24 trusts previously dismissed in the federal action, and one additional trust.The investors assertclaims for breach of contract, breach of fiduciary duty, breach of duty to avoid conflicts of interest, and violation of New Yorks Streit Act.Citibank filed a motion to dismiss this case on February 26, 2016.

On August 19, 2015, the Federal Deposit Insurance Corporation (FDIC) as Receiver for a financial institution filed a civil action against Citibank in theSouthern District of New York.This action relates to one private-label RMBS trust for which Citibank formerly served as trustee.FDIC asserts claims for breach of contract, violation of the Streit Act, and violation of the Trust IndentureAct. Citibank is jointly briefing a motion to dismiss with The Bank of New York Mellon and U.S. Bank, entities that have also been sued by FDIC in their capacity as trustee, and whose cases are all in front of Judge Carter. Defendants jointmotion to dismiss was fully briefed as of March 22, 2016.

There can be no assurances as to the outcome of litigation or the possible impact of litigationon the trustee or the RMBS trusts.However, Citibank denies liability and continues to vigorously defend against these litigations.Furthermore, neither the above-disclosed litigations nor any other pending legal proceeding involvingCitibank will materially affect Citibanks ability to perform its duties as Certificate Administrator under the Pooling and Servicing Agreement for this CMBS transaction.

Item 1119 of Regulation AB

Provided previously in theprospectus supplement of the Registrant relating to the issuing entity and filed on September 24, 2012 pursuant to Rule 424(b)(5) of the Securities Act of 1933, as amended.

Item 1122 of Regulation AB

The reports on assessment ofcompliance with servicing criteria for asset-backed securities and related attestation reports are attached hereto under Item 15.

Item 1123 ofRegulation AB

The servicer compliance statements are attached hereto under Item 15.

PART IV

Item15.Exhibits, Financial Statement Schedules.

(a)List the following documents filed as a part of the report:

(1)Not Applicable

(2)Not Applicable

(3)Exhibits listed below are either included or incorporated by reference as indicated below:

Exhibit
Number

Description

4Pooling and Servicing Agreement, dated as of September 1, 2012, by and among Citigroup Commercial Mortgage Securities, Inc., as depositor, Wells Fargo Bank, National Association, as master servicer, LNR Partners, LLC (as success toMidland Loan Services, a Division of PNC Bank, National Association), as special servicer, Situs Holdings, LLC, as operating advisor, Citibank, N.A., as certificate administrator, and U.S. Bank National Association, as trustee (filed as Exhibit 4 tothe registrants Current Report on Form 8-K/A dated September 24, 2012, and filed by the registrant on October 1, 2012, and is incorporated by reference herein).

10.1Mortgage Loan Purchase Agreement, dated as of September 1, 2012, between Citigroup Global Markets Realty Corp. and Citigroup Commercial Mortgage Securities, Inc., pursuant to which Citigroup Global Markets Realty Corp. sold certainmortgage loans to the depositor (filed as Exhibit 10.1 to the registrants Current Report on Form 8-K/A dated September 24, 2012, and filed by the registrant on October 1, 2012, and is incorporated by reference herein).

10.2Mortgage Loan Purchase Agreement, dated as of September 1, 2012, between Goldman Sachs Mortgage Company and Citigroup Commercial Mortgage Securities, Inc., pursuant to which Goldman Sachs Mortgage Company sold certain mortgage loansto the depositor (filed as Exhibit 10.2 to the registrants Current Report on Form 8-K/A dated September 24, 2012, and filed by the registrant on October 1, 2012, and is incorporated by reference herein).

10.3Mortgage Loan Purchase Agreement, dated as of September 1, 2012, between Natixis Real Estate Capital LLC and Citigroup Commercial Mortgage Securities, Inc., pursuant to which Natixis Real Estate Capital LLC sold certain mortgageloans to the depositor (filed as Exhibit 10.3 to the registrants Current Report on Form 8-K/A dated September 24, 2012, and filed by the registrant on October 1, 2012, and is incorporated by reference herein).

31Rule 15d-14(d) Certification

33.1Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer

33.2Report on assessment of compliance with servicing criteria for asset-backed securities, LNR Partners, LLC, as special servicer

33.3Report on assessment of compliance with servicing criteria for asset-backed securities, Situs Holdings, LLC, as operating advisor

33.4Report on assessment of compliance with servicing criteria for asset-backed securities, Citibank, N.A., as certificate administrator

33.5Report on assessment of compliance with servicing criteria for asset-backed securities, U.S. Bank National Association, as custodian

33.6Report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant

33.7Report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant

33.8Report on assessment of compliance with servicing criteria for asset-backed securities, Northmarq Capital, LLC, as servicing function participant

34.1Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer

34.2Attestation report on assessment of compliance with servicing criteria for asset-backed securities, LNR Partners, LLC, as special servicer

34.3Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Situs Holdings, LLC, as operating advisor

34.4Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Citibank, N.A., as certificate administrator

34.5Attestation report on assessment of compliance with servicing criteria for asset-backed securities, U.S. Bank National Association, as custodian

34.6Attestation report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant

34.7Attestation report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant

34.8Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Northmarq Capital, LLC, as servicing function participant

35.1Servicer compliance statement, Wells Fargo Bank, National Association, as master servicer

35.2Servicer compliance statement, LNR Partners, LLC, as special servicer

35.3Servicer compliance statement, Citibank, N.A., as certificate administrator

(b)The exhibits required to be filed by Registrant pursuant to Item 601 of Regulation S-K are listed above and in the Exhibit Index that immediately follows the signature page hereof.

(c)Not Applicable

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on itsbehalf by the undersigned, thereunto duly authorized.

Date: March 30, 2016

Citigroup Commercial Mortgage Securities Inc.

(Depositor)

/s/ Paul Vanderslice

Paul Vanderslice, President

EXHIBIT INDEX

Exhibit
Number

Description

4Pooling and Servicing Agreement, dated as of September 1, 2012, by and among Citigroup Commercial Mortgage Securities, Inc., as depositor, Wells Fargo Bank, National Association, as master servicer, LNR Partners, LLC (as success toMidland Loan Services, a Division of PNC Bank, National Association), as special servicer, Situs Holdings, LLC, as operating advisor, Citibank, N.A., as certificate administrator, and U.S. Bank National Association, as trustee (filed as Exhibit 4 tothe registrants Current Report on Form 8-K/A dated September 24, 2012, and filed by the registrant on October 1, 2012, and is incorporated by reference herein).

10.1Mortgage Loan Purchase Agreement, dated as of September 1, 2012, between Citigroup Global Markets Realty Corp. and Citigroup Commercial Mortgage Securities, Inc., pursuant to which Citigroup Global Markets Realty Corp. sold certainmortgage loans to the depositor (filed as Exhibit 10.1 to the registrants Current Report on Form 8-K/A dated September 24, 2012, and filed by the registrant on October 1, 2012, and is incorporated by reference herein).

10.2Mortgage Loan Purchase Agreement, dated as of September 1, 2012, between Goldman Sachs Mortgage Company and Citigroup Commercial Mortgage Securities, Inc., pursuant to which Goldman Sachs Mortgage Company sold certain mortgage loansto the depositor (filed as Exhibit 10.2 to the registrants Current Report on Form 8-K/A dated September 24, 2012, and filed by the registrant on October 1, 2012, and is incorporated by reference herein).

10.3Mortgage Loan Purchase Agreement, dated as of September 1, 2012, between Natixis Real Estate Capital LLC and Citigroup Commercial Mortgage Securities, Inc., pursuant to which Natixis Real Estate Capital LLC sold certain mortgageloans to the depositor (filed as Exhibit 10.3 to the registrants Current Report on Form 8-K/A dated September 24, 2012, and filed by the registrant on October 1, 2012, and is incorporated by reference herein).

31Rule 15d-14(d) Certification

33.1Report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer

33.2Report on assessment of compliance with servicing criteria for asset-backed securities, LNR Partners, LLC, as special servicer

33.3Report on assessment of compliance with servicing criteria for asset-backed securities, Situs Holdings, LLC, as operating advisor

33.4Report on assessment of compliance with servicing criteria for asset-backed securities, Citibank, N.A., as certificate administrator

33.5Report on assessment of compliance with servicing criteria for asset-backed securities, U.S. Bank National Association, as custodian

33.6Report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant

33.7Report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant

33.8Report on assessment of compliance with servicing criteria for asset-backed securities, Northmarq Capital, LLC, as servicing function participant

34.1Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Wells Fargo Bank, National Association, as master servicer

34.2Attestation report on assessment of compliance with servicing criteria for asset-backed securities, LNR Partners, LLC, as special servicer

34.3Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Situs Holdings, LLC, as operating advisor

34.4Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Citibank, N.A., as certificate administrator

34.5Attestation report on assessment of compliance with servicing criteria for asset-backed securities, U.S. Bank National Association, as custodian

34.6Attestation report on assessment of compliance with servicing criteria for asset-backed securities, CoreLogic Commercial Real Estate Services, Inc., as servicing function participant

34.7Attestation report on assessment of compliance with servicing criteria for asset-backed securities, National Tax Search, LLC, as servicing function participant

34.8Attestation report on assessment of compliance with servicing criteria for asset-backed securities, Northmarq Capital, LLC, as servicing function participant

35.1Servicer compliance statement, Wells Fargo Bank, National Association, as master servicer

35.2Servicer compliance statement, LNR Partners, LLC, as special servicer

35.3Servicer compliance statement, Citibank, N.A., as certificate administrator

EX-312d139354dex31.htmEX-31

EX-31

Exhibit 31

Rule 13a-14(d)/15d-14(d) Certification

I, Paul Vanderslice, certify that:

1.I have reviewed this report on Form 10-K, and all reports on Form 10-D required to be filed in respect of the period covered by this report on Form 10-K, of Citigroup Commercial Mortgage Trust 2012-GC8 (theExchange Act Periodic Reports);

2.Based on my knowledge, the Exchange Act Periodic Reports, taken as a whole, do not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of thecircumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.Based on my knowledge, all of the distribution, servicing and other information required to be provided under Form 10-D for the period covered by this report is included in the Exchange Act Periodic Reports;

4.Based on my knowledge and the servicer compliance statement(s) required in this report under Item1123 of Regulation AB, and except as disclosed in the Exchange Act Periodic Reports, the servicers have fulfilledtheir obligations under the servicing agreement(s) in all material respects; and

5.All of the reports on assessment of compliance with servicing criteria for asset-backed securities and their related attestation reports on assessment of compliance with servicing criteria for asset-backed securitiesrequired to be included in this report in accordance with Item1122 of Regulation AB and Exchange Act Rules 13a-18 and 15d-18 have been included as an exhibit to this report, except as otherwise disclosed in this report. Any material instancesof noncompliance described in such reports have been disclosed in this report on Form 10-K.

In giving the certifications above, I havereasonably relied on information provided to me by the following unaffiliated parties: Wells Fargo Bank, National Association, as master servicer; U.S. Bank National Association, as custodian; LNR Partners, LLC, as special servicer; Situs Holdings,LLC, as operating advisor; CoreLogic Commercial Real Estate Services, Inc., as servicing function participant; National Tax Search, LLC, as servicing function participant; and Northmarq Capital, LLC, as servicing function participant.

Date: March30, 2016

/s/ PaulVanderslice

PaulVanderslice

President, Citigroup Commercial Mortgage

Securities Inc.

(senior officer in charge of securitization of the depositor)

EX-33.13d139354dex331.htmEX-33.1

EX-33.1

Exhibit 33.1

Commercial Mortgage Servicing

P.O. Box 31388, Oakland, CA 94604

1901 HarrisonSt., 2nd Floor

Oakland, CA 94612

Tel: 800 986 9711

Managements Assessment

Management of Wells Fargo Commercial Mortgage Servicing, a division of Wells Fargo Bank, National Association, (the Company) is responsible forassessing compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of commercial loans (the Platform), except for servicing criteria1122(d)(1)(iii), 1122(d)(3)(i)(B-D), 1122(d)(3)(ii-iv), and 1122(d)(4)(xv), which the Company has determined are not applicable to the activities it performs with respect to the Platform, as of and for the year ended December 31, 2015. Appendix A tothis letter identifies the commercial mortgage pools and other structures involving the commercial loans constituting the Platform. Appendix B to this letter identifies the applicable servicing criteria with respect to the Platform.

With respect to servicing criteria 1122(d)(4)(xi) and 1122(d)(4)(xii), the Company performs applicable activities covered by these criteria, with respect tothe Platform, except the Company has engaged various vendors to perform certain tax payment activities. Such vendors have provided separate Regulation AB Item 1122 management assessments and attestations for such activities.

With respect to applicable servicing criterion 1122(d)(4)(iii), there were no activities performed during the year ended December 31, 2015 with respect to thePlatform, because there were no occurrences of events that would require the Company to perform such activities.

With respect to applicable servicingcriterion 1122(d)(1)(v), the Company has assessed compliance for all transactions and securities in the Platform, including those issued on or before November 23, 2015 for which compliance was previously assessed under other servicing criteria inaccordance with the SEC Division of Corporation Finances Manual of Publicly Available Interpretations on Regulation AB and Related Rules, Interpretation 11.03, as applicable, for the entire assessment period as of and for the year endedDecember 31, 2015.

With respect to servicing criteria 1122(d)(l)(i), 1122(d)(3)(i)(A), 1122(d)(4)(i), and 1122(d)(4)(vi), the Company has engaged variousvendors to perform the activities required by these servicing criteria. The Companys management has determined that none of these vendors is considered a servicer as defined in Item 1101(j) of Regulation AB, and the Companysmanagement has elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by the SECs Compliance and Disclosure Interpretation (C&DI) 200.06, Vendors Engaged byServicers (C&DI 200.06) (formerly SEC Manual of Publicly Available Telephone Interpretations 17.06). The Company has policies and procedures in place designed to provide reasonable assurance that the vendors activities comply in allmaterial respects with the servicing criteria applicable to each vendor. The Companys management is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendors and related criteria.

The Companys management has assessed the Companys compliance with the applicable servicing criteria as of and for the year ended December 31,2015. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB. Based on such assessment, management believes that, as of and for the year endedDecember 31, 2015, the Company has complied in all material respects with the servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform.

KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to managements assessment of compliance withthe applicable servicing criteria as of and for the year ended December 31, 2015.

March 18, 2016

/s/ Daniel E. Bober

Daniel E. Bober

Executive Vice President,

Commercial Mortgage Servicing

Wells Fargo Bank, National Association

APPENDIX A

COMMERCIAL MORTGAGE POOLS AND OTHER STRUCTURES

1166 AVENUE OF AMERICAS 2005- C6BA-FUNB 2001-3BANC OF AMERICA COMM MTG 2006- 5

1166 AVENUE OF THE AMERICAS 2002-C5BALDR SHERWOOD FUND WHBANC OF AMERICA COMM MTG 2007- 3

1211 Avenue of the Americas 2015-1211BAMLL 2013-DSNYBANCORP BANK WAREHOUSE

1345FB2005BAMLL 2013-WBRKBANK OF AMERICA WAREHOUSE

1345FB2005 (COMPANION)BAMLL 2014 - FL1BANK OF NEW YORK MELLON

2001-CMLB-1BAMLL 2014-520MBARCLAYS WAREHOUSE

3 WORLD TRADE CENTER 2014BAMLL 2014-8SPRBASIS RE CAPITAL II (REPO)

7 WORLD TRADE CENTER 2012-WTCBAMLL 2014-FL1 COMPANIONBB 2013-TYSN

7 WORLD TRADE CENTER 2012-WTC COMPANIONBAMLL 2014-ICTSBB&T WAREHOUSE

A10 2013-1 BACK UP SERVICERBAMLL 2014-INLDBBCMS 2014-BXO

ACCOR MEZZ WAREHOUSEBAMLL 2014-INLD MZ BBBCMS 2015-MSQ

ACM TRAFFORD V LLC WAREHOUSEBAMLL 2014-IPBBCMS 2015-MSQ COMPANION

ACRE 2013-FL1BAMLL 2015-200PBBCMS 2015-SLP

ACRE 2014-FL2BAMLL 2015-ASHFBBCMS 2015-SLP MZ A

AG MIT CREL (ANGELO GORDON ENTITY) REPOBAMLL 2015-ASHF MZ ABBCRE 2015-GTP

ALL STATE_PPG (PARTICIPATION)BAMLL 2015-ASHF MZ BBB-UBS 2012-SHOW

ALTSHULER & FORETHOUGHT WAREHOUSEBAMLL 2015-ASTRBB-UBS 2012-TFT

AMERICOLD 2010-ARTBAMLL 2015-HAULBEAR 1999-C1

AOA 2015-1177BANC OF AMERICA COMM MTG 2005-6BELVEDERE CAPITAL WAREHOUSE

ARCHETYPE & BARCLAYS REPOBANC OF AMERICA COMM MTG 2006-1BERRY ENTERPRISES WAREHOUSE

BACM2007-1BANC OF AMERICA COMM MTG 2006-2BHMS 2014-ATLS

BLACKSTONE (BRE/MWT)BSC06PWR13BSCMS05TOP20

BLCP 2014-CLRNBSC06PWR14BSCMS05TOP20 (COMPANION) 1_NYLIFE

BMC MORTGAGES VIBSC07PWR15BSCMS05TOP20 (COMPANION) 2_HARTFORDLIFE

BROE WAREHOUSEBSC07PWR16BSCMS05TOP20 (COMPANION) 3_METLIFE

BS01TOP2BSC07PWR17BSCMS05TOP20 (COMPANION)_LANDESBANK

BSB06001BSC07PWR18BUCHANAN FUND V

BSC00WF2BSC99WF2BUCHANAN MORTGAGE CAPITAL

BSC01TP4BSCM02TOP8BWAY 2013-1515

BSC02TP6BSCM03TOP10BWAY 2015-1740

BSC03PWR2BSCM03TOP12BXHTL 2015-DRMZ MZ B

BSC04PWR3BSCM04TOP14BXHTL 2015-JWRZ

BSC04PWR4BSCM04TOP16CANTOR CRE LENDING LP

BSC04PWR5BSCM05TOP18CANTOR REPO WITH MET LIFE

BSC04PWR6BSCM05TOP20 (NONPOOLED)CAPITAL LEASE WAREHOUSE-398 & 526

BSC05PWR10BSCM06TOP22CAPITAL SOURCE RELT 2006-A

BSC05PWR7BSCM06TOP24CAPLEASE CDO 2005-1

BSC05PWR8BSCM07TOP26CD 2006-CD2

BSC05PWR9BSCM07TOP28CD 2006-CD3

BSC06PWR11BSCM07TOP28 (COMPANION) 1_BALDEAGLECD 2007-CD4

BSC06PWR12BSCM07TOP28 (COMPANION) 2_STARWOODCD 2007-CD4 COMPANION

CD 2007-CD5CGWF 2013-RKWHCOBALT 2007- C3

CFCRE 2015-RUMCGWF 2013-RKWH COMPANIONCOBALT 2007- C3 COMPANION

CGBAM 2014-HDCHASE 1999-2COBALT 2007-C2

CGBAM 2014-HD COMPANIONCHASE 2000-3COBALT 2007-C2 COMPANION

CGCMT 2013-GC15CHASE-FUNB 1999-1COMM 2009-K3

CGCMT 2013-GC17CITIGROUP 2005 C3COMM 2009-K4 PRIMARY

CGCMT 2014-388GCITIGROUP 2006 C5COMM 2010-C1

CGCMT 2014-GC19CITIGROUP 2006-FL2 COMPANIONCOMM 2010-C1 COMPANION

CGCMT 2014-GC19 COMPANIONCITIGROUP 2007-C6COMM 2012-9W57

CGCMT 2014-GC21CITIGROUP 2007-C6 (COMPANION)COMM 2012-CCRE1

CGCMT 2014-GC21 COMPANIONCITIGROUP 2012-GC8COMM 2012-CCRE2

CGCMT 2014-GC25CITIGROUP 2012-GC8 COMPANIONCOMM 2012-CCRE3

CGCMT 2015-101ACITIGROUP 2013-375PCOMM 2012-CCRE4

CGCMT 2015-GC27CITIGROUP 2013-375P COMPANIONCOMM 2012-LC4

CGCMT 2015-GC27 COMPANIONCITIGROUP 2013-GCJ11COMM 2012-MVP

CGCMT 2015-GC31CITIGROUP 2013-SMPCOMM 2013-CCRE10

CGCMT 2015-GC31 COMPANIONCITIGROUP CMT 2004 C1COMM 2013-CCRE10 COMPANION

CGCMT 2015-GC33CITIGROUP GLOBAL MARKETS REALTY CORPCOMM 2013-CCRE12

CGCMT 2015-P1CITY CENTER 2011-CCHPCOMM 2013-CCRE13

CGCMT 2015-P1 CompanionCITY CENTER 2011-CCHP COMPANIONCOMM 2013-CCRE6

CGCMT 2015-SSHPCMAT 1999 C1COMM 2013-CCRE6 COMPANION

CGRBS 2013-VNO5THCOBALT 2006-C1COMM 2013-FL3 COMPANION

COMM 2013-SFSCOMM 2014-UBS5CORE 2015-CALW

COMM 2013-THLCOMM 2014-UBS5 COMPANIONCORE 2015-WEST

COMM 2013-WWPCOMM 2015 -3BPCOUNTRYWIDE 2007-MF1

COMM 2013-WWP COMPANIONCOMM 2015 CCRE25 CompanionCRESS 2008-1 CDO_PLAZAELSEGUNDO

COMM 2014-277PCOMM 2015-3BP MEZZCREST 2003-2

COMM 2014-BBGCOMM 2015-CCRE22CS FIRST BOSTON 1998 C2

COMM 2014-CCRE14COMM 2015-CCRE22 COMPANIONCSAIL 2015-C2

COMM 2014-CCRE14 COMPANIONCOMM 2015-CCRE23CSAIL 2015-C2 COMPANION

COMM 2014-CCRE15 PRIMARYCOMM 2015-CCRE24CSCMC 2007-C4

COMM 2014-CCRE20COMM 2015-CCRE24 COMPANIONCSCMT 2007-C2

COMM 2014-FL4COMM 2015-CCRE25CSCMT 2007-C3

COMM 2014-FL4 COMPANIONCOMM 2015-CCRE26CSF99C01

COMM 2014-FL5COMM 2015-CCRE26 COMPANIONCSFB 2006-C2

COMM 2014-KYOCOMM 2015-LC23CSFB94CFB1

COMM 2014-LC15COMM 2015-LC23 COMPANIONCSMC 2014-USA

COMM 2014-LC15 COMPANIONCOMM 2015-PC1DAVIS COMPANIES WAREHOUSE

COMM 2014-LC17COMM 2015-PC1 COMPANIONDBCCRE 2014-ARCP

COMM 2014-LC17 COMPANIONCOMM07FL14DBUBS 2011- LC3

COMM 2014-PATCOMM07FL14 (COMPANION) 2_SOCIETE GENERALDBUBS 2011-LC1

COMM 2014-UB6 PRIMARY ONLYCOMM07FL14 (NONPOOLED)DBUBS 2011-LC1 COMPANION

COMM 2014-UBS3COMMUNITY SOUTH BANK PORTFOLIODBUBS 2011-LC2

COMM 2014-UBS3 COMPANIONCORE 2015- TEXWDBWF 2015-LCM

DBWF 2015-LCM COMPANIONFREDDIE MAC 2010 K-SCTFREMF 2012-K22 (PRIMARY ONLY)

DELPHI CRE FUNDING (ACORE WAREHOUSE)FREMF 2010-K6 PRIMARY ONLYFREMF 2012-K23

DESERT RIDGE MEZZ A WAREHOUSEFREMF 2010-K7FREMF 2012-K501 - PRIMARY ONLY

DEXIA REAL ESTATE PORTFOLIOFREMF 2010-K8FREMF 2012-K705 - PRIMARY ONLY

DLJ 1998-CG1FREMF 2010-K9FREMF 2012-K706

DLJ 1999-CG1FREMF 2011 K12 PRIMARY ONLYFREMF 2012-K707

DLJ 1999-CG2FREMF 2011-K10 - PRIMARY ONLYFREMF 2012-K708

DLJ 1999-CG3FREMF 2011-K11FREMF 2012-K709 - PRIMARY ONLY

DMARC 1998-C1FREMF 2011-K13FREMF 2012-K710 PRIMARY ONLY

DOLLAR GENERALFREMF 2011-K14 PRIMARY ONLYFREMF 2012-K711

ELLIOTT WAREHOUSEFREMF 2011-K15FREMF 2012-KF01 PRIMARY ONLY

ENERGY PLAZA LEASE TRUST 2002FREMF 2011-K16 - PRIMARY ONLYFREMF 2012-KP01 PRIMARY ONLY

FII F DEBT ACCT PTE LTDFREMF 2011-K701FREMF 2013 K28 (PRIMARY)

FIVE MILE WAREHOUSEFREMF 2011-K702FREMF 2013 K29 (MASTER)

FIVE MILE WAREHOUSE (GS)FREMF 2011-K703FREMF 2013 K30 MASTER

FKL 2015-SFR1FREMF 2011-K704FREMF 2013 K32 PRIMARY ONLY

FKL SELLER 1 LLC -WF REPOFREMF 2011-KAIV PRIMARY ONLYFREMF 2013 K713

FORTRESS (CF TRANS HOLDCO LLC) WAREHOUSEFREMF 2012 - K19 PRIMARY ONLYFREMF 2013-K24 (PRIMARY ONLY)

FORTRESS CREDIT CORP WAREHOUSEFREMF 2012-K17 PRIMARY AND SPECIALFREMF 2013-K25

FORTRESS REPO WITH NATIXISFREMF 2012-K18 - PRIMARY ONLYFREMF 2013-K26

FOUR TIMES SQUARE 2006 - 4TSFREMF 2012-K20FREMF 2013-K27

FOUR TIMES SQUARE 2006 - 4TS COMPANIONFREMF 2012-K21 - PRIMARY ONLYFREMF 2013-K31

FREMF 2013-K33FREMF 2015-K1501 PRIMARYFUNB 2000 C2

FREMF 2013-K34FREMF 2015-K42FUNB 2001 C2

FREMF 2013-K35 (PRIMARY)FREMF 2015-K43 (PRIMARY)FUNB 2001 C2 B NOTES

FREMF 2013-K712 PRIMARY ONLYFREMF 2015-K44FUNB 2001 C3

FREMF 2013-KS01 PRIMARYFREMF 2015-K45FUNB 2001 C3 B NOTES

FREMF 2014 K37 (PRIMARY)FREMF 2015-K46 PRIMARYFUNB 2001 C4

FREMF 2014 K39 PRIMARYFREMF 2015-K47FUNB/CHASE 1999 C2

FREMF 2014 K715FREMF 2015-K48FUNB99C1

FREMF 2014 KS02FREMF 2015-K49FUNB-BA 2001 C1

FREMF 2014-K36FREMF 2015-K50 (PRIMARY)GAHR 2015-NRF

FREMF 2014-K38 PRIMARYFREMF 2015-K720GCCP H-1, LLC (GROSSMAN)

FREMF 2014-K40FREMF 2015-KF07 (PRIMARY)GE 2002 C2

FREMF 2014-K41 (PRIMARY)FREMF 2015-KF09 (Primary Only)GE 2006 C1

FREMF 2014-K714FREMF 2015-KF10 (PRIMARY)GECC 2001-3

FREMF 2014-K716FREMF 2015-KJ01 (PRIMARY)GECC 2002-1

FREMF 2014-K717 PRIMARYFREMF 2015-KKA PRIMARYGECC 2002-3

FREMF 2014-KF04FREMF 2015-KP02 (Primary Only)GECMC 2004 C2

FREMF 2014-KF05FREMF 2015-KS03GECMC 2007-C1

FREMF 2014-KF06 PRIMARYFULB 1997 C2GEMINI ALTO CENTERVILLE WAREHOUSE

FREMF 2014-KX01 (PRIMARY)FUNB 1999 C4GERMAN AMERICAN CAPITAL CORPORATION WARE

FREMF 2015 - K718FUNB 2000 C1GOLDMAN 2006-GG6

GOLDMAN 2006-GG6 COMPANIONSGSMS 2010-C2GSMS 2014-GC26

GOLDMAN 2006-GG8GSMS 2010-C2 COMPANIONGSMS 2015-590M

GOLDMAN 2006-GG8 COMPANIONSGSMS 2011-GC3GSMS 2015-590M COMPANION

GOLDMAN 2007-GG10GSMS 2011-GC5GSMS 2015-GC28

GOLDMAN 2007-GG10 COMPANIONGSMS 2011-GC5 COMPANIONGSMS 2015-GC34

GOLDMAN 2010-K5 - PRIMARY ONLYGSMS 2012-ALOHAGSMSC 2010-C1

GOLDMAN SACHS 2005-ROCKGSMS 2012-BWTRGSMSC 2010-C1 COMPANION

GOLDMAN SACHS WAREHOUSEGSMS 2012-GCJ7GSMSC04GG2

GRACE 2014-GRCEGSMS 2012-GCJ7 COMPANIONGSMSC04GG2 (COMPANION) 1_VARIABLELIFE

GRAND PACIFIC BUSINESS LOAN TRUST 2005-1GSMS 2012-GCJ9HBST 2015-HBS

GREENWICH CCFC 05 GG5 (COMPANION)GSMS 2012-SHOPInland Mortgage Capital LLC Warehouse

GREENWICH CCFC 2002 C1GSMS 2012-TMSQInland Mortgage Lending REPO

GREENWICH CCFC 2003-C1GSMS 2013-GC10IRVINE CORE OFFICE TRUST 2013-IRV

GREENWICH CCFC 2003-C2GSMS 2013-GC13JEMB MADISON AVE LLC (BASIS I - 292 MAD)

GREENWICH CCFC 2004-GG1GSMS 2013-GCJ12JLC VII WAREHOUSE

GREENWICH CCFC 2005-GG5GSMS 2013-GCJ14JLC WAREHOUSE I LLC

GREENWICH CCFC 2007-GG11GSMS 2013-GCJ16JLC WAREHOUSE II LLC

GREENWICH CCFC 2007-GG11 COMPANIONGSMS 2013-KINGJLC WAREHOUSE IV LLC (DEUTSCHE REPO)

GREENWICH CCFC 2007-GG9GSMS 2014-GC18JLC WH & MEZZ VI LLC (JEFFRIES REPO)

GREENWICH CCFC 2007-GG9 COMPANIONGSMS 2014-GC22JLC WH & MEZZ VI LLC PT2 (JEFFRIES REPO)

GS COMMERCIAL REAL ESTATE WAREHOUSEGSMS 2014-GC22 COMPANIONJP MORGAN CHASE

JPM 2012-CIBX COMPANIONJPMBB 2015-C28JPMC 2014-C20 COMPANION

JPM06CIBC15JPMBB 2015-C28 COMPANIONJPMC03LN1

JPM06CIBC17JPMBB 2015-C29JPMCC 2007-LDP10

JPM07CIBC19JPMBB 2015-C30JPMCC 2007-LDP10 COMPANION

JPM08C2JPMBB 2015-C30 COMPANIONJPMCC 2007-LDP11

JPM2006LDP8JPMBB 2015-C32JPMCC 2007-LDP11 COMPANION

JPM2007LDP12JPMBB 2015-C32 COMPANIONJPMCC 2012-C6

JPM6LDP9JPMC 2002 C1JPMCC 2013-C16

JPMBB 2013-C15JPMC 2002 C2JPMCC 2013-C16 COMPANION

JPMBB 2013-C15 COMPANIONJPMC 2002 CIBC5JPMCC 2014-DSTY

JPMBB 2013-C17JPMC 2003 CIBC6JPMCC 2014-FL5

JPMBB 2013-C17 COMPANIONJPMC 2003 ML1JPMCC 2014-FL5 COMPANION

JPMBB 2014 - C21 COMPANIONJPMC 2003-C1JPMCC 2015-COSMO

JPMBB 2014-C21JPMC 2005-LDP2KGS-ALPHA REAL ESTATE

JPMBB 2014-C22JPMC 2006 FL2KGS-ALPHA RECM WH REPO W/ CITIBANK

JPMBB 2014-C22 COMPANIONJPMC 2006 FL2 COMPANIONLADDER CAPITAL LLC REPO

JPMBB 2014-C23JPMC 2006-LDP7LADDER DEUTSCHE REPO

JPMBB 2014-C23 COMPANIONJPMC 2006-LDP9LADDER JPM REPO

JPMBB 2014-C24JPMC 2006-LDP9 COMPANIONLADDER MET LIFE REPO

JPMBB 2014-C24 COMPANIONJPMC 2011-PLSDLADDER WELLS FARGO REPO

JPMBB 2014-C25JPMC 2012-CIBXLB 1998 C4

JPMBB 2014-C25 COMPANIONJPMC 2014-C20LB 1999 C1

LB 1999 C2LB-UBS 2003 C5LBUBS05C3 (SENIOR MEZZ) 5_BAYERISCHE

LB UBS 2000 C5LB-UBS 2003-C1LCCM 2014-909

LB UBS 2001 C3LB-UBS 2003-C3LCCM2013GCP

LB UBS 2002 C2LB-UBS 2005 C5LCRT HOLDINGS LLC WAREHOUSE

LB UBS 2002 C7LB-UBS 2005 C7LEHMAN BROTHERS WAREHOUSE

LB UBS 2003 C8LB-UBS 2005-C7 COMPANIONLEHMAN-UBS 2005 C5 COMPANION

LB UBS 2004 C1LB-UBS 2006 C1LIBREMAX WAREHOUSE

LB UBS 2004 C4LB-UBS 2006 C1 COMPANIONLOANCORE (JEFFERIES) WAREHOUSE

LB UBS 2004 C6LB-UBS 2006 C3LONE STAR REPO WITH WELLS FARGO

LB UBS 2004 C6 COMPANIONLB-UBS 2006-C3 COMPANIONLONESTAR (RELIUS) WAREHOUSE 2013

LB UBS 2004 C7LB-UBS 2006-C6 COMPANIONLONESTAR REPO WITH CB

LB UBS 2004 C8LB-UBS 2007-C2LSTAR 2015-3

LB UBS 2004 C8 COMPANIONLB-UBS 2007-C6LVS II SPE III LLC (AFFILIATE OF PIMCO)

LB UBS 2005 C1LB-UBS 2007-C6 (COMPANION)MAIDEN 2008-1

LB UBS 2005 C1 COMPANIONLB-UBS 2007-C7MARATHON REAL ESTATE CDO 2006-1

LB UBS 2006-C4LBUBS05C2MC FIVE MILE SPE B LLC (COLUMN REPO)

LB UBS 2006-C4 COMPANIONLBUBS05C3MDC01TP5

LB UBS 2006-C6LBUBS05C3 (COMPANION) 1_SORINREMDC02TP7

LB UBS 2006-C7LBUBS05C3 (SENIOR MEZZ) 1_METLIFEMERRILL LYNCH 1996 C2

LB UBS 2006-C7 COMPANIONLBUBS05C3 (SENIOR MEZZ) 2_INGMERRILL LYNCH 1998 C2

LB UBS 2007-C2 COMPANIONLBUBS05C3 (SENIOR MEZZ) 3_LRPMERRILL LYNCH 2008-C1

LB UBS 2008-C1LBUBS05C3 (SENIOR MEZZ) 4_AIBDEBTMEZZ CAP 2004-C1

MEZZ CAP 2004-C2MLCFC07-9MS06TOP23 (COMPANION)_LANDESBANK

MEZZ CAP 2005-C3MLMT 2002 MW1MS07TOP25

MEZZ CAP 2006-C4MLMT 2005-CKI1MS07TOP27

MEZZ CAP 2007-C5MLMT 2006-C2MS07TOP27 AW34 (NONPOOLED)

MEZZ CAP LLC (FKA CBA MEZZ)MLMT06C1MS08TOP29

MEZZ CAP REIT I, INCMLMT07C1MS2000PRIN

MKP CREDIT MASTER FUND MEZZANINEMORGAN GUARANTY TRUST CO. OF NYMSBAM 2013-C11

MKP CREDIT MASTER FUND WAREHOUSEMORGAN STANLEYMSBAM 2013-C11 COMPANION

ML 1997-C2MORGAN STANLEYMSBAM 2013-C12

ML 1998-C3MORGAN STANLEY 2007 IQ14MSBAM 2013-C12 COMPANION

ML-CFC 2006-1MORGAN STANLEY 2007-HQ13MSBAM 2013-C13

ML-CFC 2006-2MORGAN STANLEY 2007-HQ13 COMPANIONMSBAM 2013-C8

ML-CFC 2007-6MORGAN STANLEY 2011-C3MSBAM 2013-C8 COMPANION

ML-CFC 2007-7MORGAN STANLEY BAML 2012-C6MSBAM 2014-C14

ML-CFC 2007-7 COMPANIONMS03TOP11MSBAM 2014-C15

MLCFC06-4MS04TOP13MSBAM 2014-C15 COMPANION

MLCFC07-5MS04TOP15MSBAM 2014-C16

MLCFC07-5 (COMPANION)_LEXINGTONMS05TOP17MSBAM 2014-C17

MLCFC07-6MS05TOP19MSBAM 2014-C18

MLCFC07-6 (COMPANION)_ASTARMS06TOP21MSBAM 2014-C19

MLCFC07-8MS06TOP23MSBAM 2014-C19 COMPANION

MSBAM 2015-C22MSC07HQ12MSDWMC OWNER TRUST 2000-F1

MSBAM 2015-C22 COMPANIONMSC07HQ12 (COMPANION) 1_CITMSJP 2015-HAUL

MSBAM 2015-C23MSC07HQ12 (COMPANION) 2_DEUTSCHEAGNBS REAL ESTATE CAPITAL WAREHOUSE

MSBAM 2015-C23 COMPANIONMSC07IQ13NLY 2014-FL1

MSBAM 2015-C24MSC07IQ14NORTEL NETWORKS TRUST 2001-1

MSBAM 2015-C24 COMPANIONMSC07IQ16NORTHSTAR (CB LOAN NT-II,LLC) CB REPO

MSBAM 2015-C25MSC98WF2NORTHSTAR (NS HEALTHCARE PT 2) WAREHOUSE

MSBAM 2015-C25 COMPANIONMSC99WF1NORTHSTAR 2013-1 (CLO)

MSBAM 2015-C26MSCI03IQ6NORTHSTAR CDO IV LTD

MSC 2014-CPTMSCI04IQ7NORTHSTAR CDO IX PRIMARY (MEMORIAL MALL)

MSC 2014-MPMSCI04IQ8NORTHSTAR CDO VI

MSC 2015-420MSCI05IQ9NORTHSTAR CDO VIII

MSC 2015-420 COMPANIONMSCI06HQ8NORTHSTAR DB LOAN NT-II REPO

MSC04HQ4MSCI06HQ9NORTHSTAR WAREHOUSE

MSC05HQ6MSCI06TOP21 (NONPOOLED)NORTHSTAR-CITI REPO WAREHOUSE

MSC05HQ6 (COMPANION)_PRUDENTIALMSCI2007IQ16NORTHSTAR-DB REPO WAREHOUSE (NRFC)

MSC05HQ7MSD01TP3NORTHSTAR-DB REPO WAREHOUSE (NSINCOME)

MSC06HQ10MSDW03HQ2NS INCOME REIT HOLDINGS LLC WH

MSC06IQ11MSDW03TOP9NS RE INCOME OPERATING PARTNESHIP II, LP

NStar (MS Loan NT-I, LLC) MS RepoPFP III SUB I, LLCRESOURCE CAPITAL CORP. WAREHOUSE

NSTAR (MS LOAN NT-II, LLC) MS REPOPILLAR FUNDING (COLUMN FINANCIAL REPO)RESOURCE CAPITAL REPO WAREHOUSE

NXT CAPITAL FUNDING II, LLCPILLAR FUNDING LLC WAREHOUSERESOURCE REAL ESTATE FUNDING CDO 2006-1

OBP DEPOSITOR, LLC TRUST 2010- OBPPIMCO (GCCU I LLC)RESOURCE REF CDO 2007-1

OMEGA WAREHOUSEPIMCO (TOCU I LLC)RESOURCES REPO WITH DB

ONE LINCOLN 2004-C3PRIME AND METLIFE REPOREXFORD INDUSTRIAL FUND V LP WAREHOUSE

ONE WEST BANK REPOPRIME FINANCE PARTNERS II, L.P.RIALTO REPO W/ GS

ONE WILLIAM STREET CAP MASTER FUND WHPRIME FINANCE PARTNERS III, LPRIALTO REPO WITH WF

OWS ABS MASTER FUND II, LPPRIME REPO WITH METLIFERIALTO WAREHOUSE 2013

OWS CF II SPV LLC WarehousePRIME REPO WITH U.S. BANKRIVER MARKET BROE WAREHOUSE

OWS CF SUB I WAREHOUSEPROPHET WAREHOUSERLJ III - FINANCE HOLDINGS, LLC

OWS COF I MASTER WHPROSIRIS WarehouseRMF SUB LLC WF REPO

OWS CREDIT OPPORTUNITY I WHPSBAmherst Finance Construction WHRMF SUB2 LLC (RIALTO REPO)

OWS I ACQUISITIONS, LLC WHQCMT13QCROC DEBT STRATEGY FUND MANAGER LLC

OXFORD PROPERTIES WAREHOUSERAITH RE FUND I LP WAREHOUSEROCKWOOD (375 PARK) WAREHOUSE

OXFORD PROPERTIES WAREHOUSE 2RAITH WAREHOUSEROCKWOOD CAPITAL, LLC (NORTHROCK)

PCMT03PWR1RBSCF 2013-GSPRSO 2015-CRE3

PEOPLES UNITED BANK_COLE MT AND PPG (PARBSCF 2013-SMVRSO 2015-CRE3 Companion

PFP 2015-2RECM AND COMPASS (KR OFFICE 2)RSO 2015-CRE4

PFP II SUB I, LLCRESOURCE 2013-CRE1RSO 2015-CRE4 (Companion)

PFP III 2014-1RESOURCE 2014-CRE2SAS WAREHOUSE 2013 (H2)

SCG 2013-SRP1STARWOOD PROPERTY MORTGAGE SUB-2, L.L.C.UCB07-1

Seer Capital Management LPSTRATEGIC LAND JOINT VENTURE 2VALSTONE WAREHOUSE

SFAVE 2015-5AVETEACHERS INSURANCE & ANNUITY ASSOCIATIONVDNO 2013-PENN

SILVERPEAK RE FINANCE LLC WAREHOUSETIAA 2007-C4VNO 2012-6AVE

SINGERMAN (RIDGMAR MEZZ LOAN)TIMES SQUARE HOTEL TRUSTVORNADO DP LLC 2010-VNO

SL GREEN - JPM REPOTISHMAN TFO II LLC WAREHOUSEVORNADO REALTY L.P. WAREHOUSE

SL GREEN REALTY CORP/GRAMERCYTMSQ 2014-1500WACHOVIA 2003 C3

SL GREEN WAREHOUSETOCU II LLC (PIMCO ENTITY)WACHOVIA 2003-C4

SOCIETE GENERALE WAREHOUSETRIANGLE (NORTHSIDE- ROSSER DEBT HOLDING)WACHOVIA 2003-C5

SOUND MARK HORIZONS FUND LP WAREHOUSETRIANGLE WAREHOUSEWACHOVIA 2003-C6

SPREF WH I LLC (DEUTSCHE REPO)TRT LENDING REPO WAREHOUSEWACHOVIA 2003-C7

SPREF WH II WF REPOTRT LENDING SUBSIDIARY II LLC WAREHOUSEWACHOVIA 2003-C9

SPREF WH III (SILVERPEAK) COLUMN REPOTRT LENDING SUBSIDIARY LLCWACHOVIA 2004 C10

SRE FW MEZZ WAREHOUSE (RIDGMAR MEZZ)TUEBOR WAREHOUSE (LADDER)WACHOVIA 2004 C11

SRPT 2014-STARUBS 2012-C1WACHOVIA 2004 C15

STARWOOD CITI REPO SUB 6UBS WAREHOUSEWACHOVIA 2004-C11 (COMPANION)

STARWOOD MORT FUNDING- MORGAN STANLEY REPUBS-BARCLAYS 2012-C2WACHOVIA 2004-C12

STARWOOD MORTGAGE CAPITAL WAREHOUSEUBS-BARCLAYS 2012-C4WACHOVIA 2005 C17

STARWOOD PROPERTY MORTGAGE LLC WAREHOUSEUBS-CITIGROUP 2011-C1WACHOVIA 2005-C16

WACHOVIA 2005-C18WACHOVIA 2007-C32WFCM 2014-LC16 COMPANION

WACHOVIA 2005-C19WACHOVIA 2007-C32 COMPANIONWFCM 2014-LC18

WACHOVIA 2005-C20WACHOVIA 2007-C33WFCM 2014-TISH

WACHOVIA 2005-C21WACHOVIA 2007-C33 COMPANIONWFCM 2015-BXRP

WACHOVIA 2005-C21 (COMPANION)WACHOVIA 2007-C34WFCM 2015-C26

WACHOVIA 2005-C22WACHOVIA 2007-C34 COMPANIONWFCM 2015-C27

WACHOVIA 2006 WHALE 7 NON TRUSTWACHOVIA 2007-WHALE 8WFCM 2015-C28

WACHOVIA 2006-C23WACHOVIA 2007-WHALE 8 NON TRUSTWFCM 2015-C28 COMPANION

WACHOVIA 2006-C24WACHOVIA GENERAL PARTICIPANTWFCM 2015-C29

WACHOVIA 2006-C25WACHOVIA RED - TAX CREDITWFCM 2015-C29 COMPANION

WACHOVIA 2006-C25 (COMPANION)WASHINGTON SUB, LLCWFCM 2015-C30

WACHOVIA 2006-C26WEST RIVER WAREHOUSEWFCM 2015-C30 COMPANION

WACHOVIA 2006-C27WESTERN ALLIANCE BANK WAREHOUSEWFCM 2015-C31

WACHOVIA 2006-C27 - COMPANIONWESTIN TIME SQUARE MEZZANINEWFCM 2015-C31 Companion

WACHOVIA 2006-C28WESTIN TIME SQUARE MEZZANINE 2WFCM 2015-LC20

WACHOVIA 2006-C29WFCM 2012-LC5WFCM 2015-LC22

WACHOVIA 2006-C29 COMPANIONWFCM 2013-120BWFCM 2015-NXS1

WACHOVIA 2006-WHALE 7WFCM 2013-BTCWFCM 2015-NXS1 COMPANION

WACHOVIA 2007-C30WFCM 2013-LC12WFCM 2015-NXS2

WACHOVIA 2007-C30 COMPANIONWFCM 2013-LC12 COMPANIONWFCM 2015-NXS2 COMPANION

WACHOVIA 2007-C31WFCM 2014- LC18 COMPANIONWFCM 2015-NXS3

WACHOVIA 2007-C31 COMPANIONWFCM 2014-LC16WFCM 2015-NXS3 COMPANION

WFCM 2015-SG1WFRBS 2013-C13WFRBS 2014-C22 COMPANION

WFCM 2015-SG1 CompanionWFRBS 2013-C14WFRBS 2014-C23

WFCM10C1WFRBS 2013-C15WFRBS 2014-C23 COMPANION

WFCM10C1 (PARTICIPATION)_BASISWFRBS 2013-C15 COMPANIONWFRBS 2014-C24

WFLD 2014-MONTWFRBS 2013-C16WFRBS 2014-C24 COMPANION

WFRBS 2011-C3WFRBS 2013-C16 COMPANIONWFRBS 2014-C25

WFRBS 2011-C5WFRBS 2013-C17WFRBS 2014-C25 COMPANION

WFRBS 2012-C10WFRBS 2013-C18WFRBS 2014-LC14

WFRBS 2012-C6WFRBS 2013-UBS1WFRBS11C2

WFRBS 2012-C7WFRBS 2014-C19 COMPANIONWFRBS11C2 (PARTICIPATION)_WEST RIVER

WFRBS 2012-C8WFRBS 2014-C19WWFRBS11C4

WFRBS 2012-C9WFRBS 2014-C20WFRBS11C4 (COMPANION)_LIBERTYLIFE

WFRBS 2013 - C17 COMPANIONWFRBS 2014-C21YELLOW BRICK REAL ESTATE CAPITAL I, LLC

WFRBS 2013-C11WFRBS 2014-C21 COMPANIONMSFMSFF WH

WFRBS 2013-C12WFRBS 2014-C22CGCMT 2015-GC33 Companion

LCF UBS Bank RepoFREMF 2015-KJ02FREMF 2015-KF11

MSBAM 2015-C27CSAIL 2015-C4JPMBB 2015-C33

JPMBB 2015-C33 CompanionFREMF 2015-KF12WFCM 2015-NXS4

(Pearlmark) Prep Investment Advisors WHFREMF 2015-K721FREMF 2015-K51

WFCM 2015-P2JPMCC 2015-JP1CITIGROUP UK WAREHOUSE

GOLDMAN SACHS UK WAREHOUSEWELLS FARGO BANK- PARTICIPATIONWFB - PORTFOLIO SLAM

WFB - PORTFOLIOWFB - HELD FOR SALEWFB - BRIDGE LOANS

RECM WFFL SELF STORAGERECM WFFL SELF STORAGEWFBCREAM

WFB - WFRF PORTFOLIOWFB - WFRF MCDONALDSMLFT 2006-1

CIBCRAYMOND JAMES BANKVERTICAL CRE CDO

CAPITAL TRUST, INCPNC BankWELLS FARGO IMMG

SOVEREIGN BANK NATD BANKUNION BANK

CBA-MEZZANINE CAPITAL FINANCE,LBUBS2005C2 COMPANIONLBUBS2005C3 COMPANION

CRE/AFS ESCROW ONLY LOANSMLCFC 2007 C7RECM NUVEEN

FNMA World SavingsRECM GUGGENHEIMWorld Savings

RECM FANNIE MAE IIRBS CitizensRECM FANNIE MAE TRANSFER

MUFG UNION BANK WAREHOUSEWACHOVIA STRUCTURED FINANCEWACHOVIA STRUCTURED FINANCE

COMM 2014-CCRE20 COMPANIONOWS BCA FUNDING WAREHOUSEWFCM 2015-LC20 COMPANION

OWS BACF SPV LLC (OWS WH)COMM 2015-CCRE23 COMPANIONTRIANGLE (NORTHSIDE-ROSSER DEB

REGIONS BANKFIRSTKEY MASTER SELLER 1 LLC (RESOURCE (RCC REAL ESTATE SPE

MSBAM 2015-C27 COMPANIONWFBNA ITF CITIBANK NAGSMS 2015-GC34 COMPANION

LOGISTICS UK 2015-PLCSBL 2015-KINDCMTG/CN MORTGAGE REIT LLC (MA

CONCORD REAL ESTATE CDO 2006- 1 (CERITOSMARATHON STRUCTURED FINANCE FUND LPMLFT 2006-1 (COMPANION)_CAPTRUST

WACHOVIA 2004 C14GECC 2000-11999-LIFE1

WACHOVIA 2002 C2COMM 2013-FL3MSCI04HQ3

FREMF 2013-K502 - PRIMARY ONLYFREMF 2013 KF02 PRIMARY ONLYJPM05LDP3

JPMC 2006-LDP7 COMPANIONFREMF 2014 KF03 (PRIMARY)WACHOVIA 2002 C1

CONCORD REAL ESTATE CDO 2006-1NS 2012-1WACHOVIA 2003-C8

JPMC 2001 CIBC3BREDS LOAN CAPITAL REPO WAREHOUSEWACHOVIA CRE CDO 2006-1

LB UBS 2002 C1RBS 2010-MB1WACHOVIA 2005-C20 (COMPANION)

WACHOVIA 2006-C24 (COMPANION)NEWCASTLE CDO IXMS01TOP1

GREENWICH CAPITAL FINANCIAL PRODUCTS INCRBS WAREHOUSECITIGROUP 2006-FL2

NORTHSTAR-DORAL WAREHOUSE (NRFC)SAF FUNDING, LLCBREDS LOAN CAPITAL II REPO WAREHOUSE

KEARNY CREDIT FACILITY WAREHOUSENRFC WAREHOUSE (SOHO HOUSE)MS2000LIFE1

JPMC 2005-LDP2 COMPANIONSGSMS 2015-GS1FREMF 2015-K719

APPENDIX B

APPLICABLE SERVICING CRITERIA WITH RESPECT TO COMMERCIAL LOANS

(THE PLATFORM)

SERVICING CRITERIA

APPLICABLE
SERVICING
CRITERIAINAPPLICABLE
SERVICING
CRITERIA

Reference

Criteria

Performed
Directly
by
the
CompanyPerformed
by
Vendor(s)
forwhich
the
Companyis
the
Responsible
PartyPerformedby
vendor(s)for
whichthe
Companyis
NOTthe
Responsible
PartyNOT
performedby
theCompany
orby
subservicer(s)
orvendor(s)
retainedby
theCompany

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.XX

1122(d)(1)(ii)

If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third partys performance and compliance with such servicing activities.X

1122(d)(1)(iii)

Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.

X

I122(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 ofthe transaction agreements.X

I122(d)(1)(v)

Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.X

SERVICING CRITERIA

APPLICABLE
SERVICING
CRITERIAINAPPLICABLE
SERVICING
CRITERIA

Reference

Criteria

Performed
Directly
by
the
CompanyPerformed
by
Vendor(s)
forwhich
the
Companyis
the
Responsible
PartyPerformedby
vendor(s)for
whichthe
Companyis
NOTthe
Responsible
PartyNOT
performedby
theCompany
orby
subservicer(s)
orvendor(s)
retainedby
theCompany

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 following receipt, or such other number of days specified in the transactionagreements.X

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

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

1122(d)(2)(iv)

The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in thetransaction agreements.X

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 aforeign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.X

1122(d)(2)(vi)

Unissued checks are safeguarded so as to prevent unauthorized access.X

SERVICING CRITERIA

APPLICABLE
SERVICING
CRITERIAINAPPLICABLE
SERVICING
CRITERIA

Reference

Criteria

Performed
Directly
by
the
CompanyPerformed
by
Vendor(s)
forwhich
the
Companyis
the
Responsible
PartyPerformedby
vendor(s) for
which the
Company is
NOT the
Responsible
PartyNOT
performed by
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company

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 are (A) mathematically accurate; (B)prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; and (D) containexplanations 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

Investor Remittances and Reporting

1122(d)(3)(i)(A)

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 accordancewith timeframes and other terms set forth in the transaction agreements;XX

1122(d)(3)(i)(B)

(B) provide information calculated in accordance with the terms specified in the transaction agreements;

X

1122(d)(3)(i)(C)

(C) are filed with the Commission as required by its rules and regulations;

X

SERVICING CRITERIA

APPLICABLE
SERVICING
CRITERIAINAPPLICABLE
SERVICING
CRITERIA

Reference

Criteria

Performed
Directly
by
the
CompanyPerformed
by
Vendor(s)
for which
the
Company is
the
Responsible
PartyPerformedby
vendor(s) for
which the
Company is
NOT the
Responsible
PartyNOT
performed by
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company

1122(d)(3)(i)(D)

(D) agree with investors or the trustees records as to the total unpaid principal balance and number of pool assets serviced by the Servicer.

X

1122(d)(3)(ii)

Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

X

1122(d)(3)(iii)

Disbursements made to an investor are posted within two business days to the Servicers investor records, or such other number of days specified in the transaction agreement

X

1122(d)(3)(iv)

Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

X

Pool Asset Administration

1122(d)(4)(i)

Collateral or security on pool assets is maintained as required by the transaction agreement or related mortgage loan documents.XX

1122(d)(4)(ii)

Pool assets and related documents are safeguarded as required by the transaction agreement.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(1)

SERVICING CRITERIA

APPLICABLE
SERVICING
CRITERIAINAPPLICABLE
SERVICING
CRITERIA

Reference

Criteria

Performed
Directly
by
the
CompanyPerformed
by
Vendor(s)
for which
the
Company is
the
Responsible
PartyPerformedby
vendor(s) for
which the
Company is
NOT the
Responsible
PartyNOT
performedby
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company

1122(d)(4)(iv)

Payments on pool assets, including any payoffs, made in accordance with the related [pool asset] documents are posted to the Servicers obligor records maintained no more than two business days after receipt, or such othernumber of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related mortgage loan documents.X

1122(d)(4)(v)

The Servicers records regarding the pool assets agree with the Servicers records with respect to an obligors unpaid principal balance.X

1122(d)(4)(vi)

Changes with respect to the terms or status of an obligors pool assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and relatedpool asset documents.XX

1122(d)(4)(vii)

Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes orother requirements established by the transaction agreements.X

1122(d)(4)(viii)

Records documenting collection efforts are maintained during the period a mortgage loan is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other periodX

SERVICING CRITERIA

APPLICABLE
SERVICING
CRITERIAINAPPLICABLE
SERVICING
CRITERIA

Reference

Criteria

Performed
Directly
by
the
CompanyPerformed
by
Vendor(s)
for which
the
Company is
the
Responsible
PartyPerformedby
vendor(s) for
which the
Company is
NOT the
Responsible
PartyNOT
performedby
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company

specified in the transaction agreements, and describe the entitys activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemedtemporary (e.g., illness or unemployment).

1122(d)(4)(ix)

Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related mortgage loan documents.X

1122(d)(4)(x)(A)

Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligors pool asset documents, on at least an annual basis, or such other period specified in thetransaction agreementsX

1122(d)(4)(x)(B)

(B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws;X

1122(d)(4)(x)(C)

(C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements.X

1122(d)(4)(xi)

Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such supporthas been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.X

X(2)

SERVICING CRITERIA

APPLICABLE
SERVICING
CRITERIAINAPPLICABLE
SERVICING
CRITERIA

Reference

Criteria

Performed
Directly
by
the
CompanyPerformed
by
Vendor(s)
for which
the
Company is
the
Responsible
PartyPerformedby
vendor(s) for
which the
Company is
NOT the
Responsible
PartyNOT
performedby
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company

1122(d)(4)(xii)

Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicers funds and not charged to the obligor, unless the late payment was due to the obligors error oromission.X

X(2)

1122(d)(4)(xiii)

Disbursements made on behalf of an obligor are posted within two business days to the obligors records maintained by the Servicer, or such other number of days specified in the transaction agreements.X

1122(d)(4)(xiv)

Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.X

1122(d)(4)(xv)

Any external enhancement or other support, identified in Item1114(a)(1) through (3) or Item1115 of Regulation AB, is maintained as set forth in the transaction agreements.

X

(1)There were no activities performed during the year ended December31, 2015 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.

(2)The vendors, CoreLogic, Inc. and National Tax Search, LLC, provided separate Reg. AB 1122(d) attestations for their tax payment activities as they relate to criteria 1122(d) (4)(xi)and (xii).

EX-33.24d139354dex332.htmEX-33.2

EX-33.2

Exhibit 33.2

Certification Regarding Compliance with Applicable Servicing Criteria

1.LNR Partners, LLC. (the Asserting Party) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d)of Item1122 of Regulation AB, as of and for the12-month period ending December31, 2015 (the Reporting Period), as set forth in Appendix A hereto. The transactions covered by this report, include commercial mortgage-asset-backed securities transactions for which the AssertingParty served as special servicer, and that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933 (the Platform);

2.The Asserting Party has engaged certain vendors, which are not servicers as defined in Item1101(j) of Regulation AB (the Vendors), to perform specific, limited or scripted activities, and the AssertingParty elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors activities as set forth in Appendix A hereto;

3.Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in paragraph (d)of Item1122 of Regulation AB to assess the compliance with the applicable servicing criteria;

4.The criteria listed in the column titled Inapplicable Servicing Criteria on Appendix A hereto are inapplicable to the Asserting Party based on the activities it performs, directly or through its Vendors,with respect to the Platform;

5.The Asserting Party has complied, in all material respects, with the applicable servicing criteria as of December31, 2015 and for the Reporting Period with respect to the Platform taken as a whole;

6.The Asserting Party has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria as of December31, 2015 and for the Reporting Period withrespect to the Platform taken as a whole;

7.The Asserting Party has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria as of December31, 2015 and for theReporting Period with respect to the Platform taken as a whole; and

8.Deloitte& Touche LLP, a registered public accounting firm, has issued an attestation report on the Asserting Partys assessment of compliance with the applicable servicing criteria for the ReportingPeriod.

February23, 2016

LNR Partners, LLC

By:

/s/ Job Warshaw

Name:Job Warshaw

Title:

President

1601 Washington Avenue Suite 700 Miami Beach, Florida 33139-3164

Telephone: (305)695-5600 Fax: (305)695-5601

APPENDIX A

SERVICING CRITERIA

APPLICABLE

SERVICINGCRITERIA

INAPPLICABLE

SERVICING

CRITERIA

Reference

Criteria

Performed

Directly

by

Asserting

Party

Performed

by

Vendor(s)

for which

Asserting

Party is the

Responsible

Party

Performedby

subservicer(s)

orvendor(s)

for which

Asserting

Party isNOT

the

Responsible

Party

NOT

performedby

Asserting

Party orby

subservicer(s)

or vendor(s)
retained by
Asserting

Party

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

1122(d)(1)(ii)If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third partys performance and compliance with such servicing activities.X

1122(d)(1)(iii)Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.

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 ofthe transaction agreements.X

1122(d)(1)(v)Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information to the extent you are required to report on that servicing criteria pursuant to thetransaction agreements.X

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 following receipt, or such other number of days specified in the transactionagreements.XX

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

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

1122(d)(2)(iv)The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in thetransaction agreements.X

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 aforeign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.X

1122(d)(2)(vi)Unissued checks are safeguarded so as to prevent unauthorized access.X

SERVICING CRITERIA

APPLICABLE
SERVICINGCRITERIAINAPPLICABLE
SERVICING
CRITERIA

Reference

Criteria

Performed
Directly
by
Asserting
PartyPerformed
by
Vendor(s)
for which
Asserting
Party is the
Responsible
PartyPerformed by
subservicer(s)
or vendor(s)
for which
Asserting
Party isNOT
the
Responsible
PartyNOT
performed by
Asserting
Party or by
subservicer(s)
or vendor(s)
retainedby
Asserting
Party

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 are (A) mathematically accurate; (B)prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) reviewed and approved by someone other than the person who prepared the reconciliation; and (D) containexplanations 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.XX

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 accordancewith 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 andregulations; and (D) agree with investors or the trustees records as to the total unpaid principal balance and number of pool assets serviced by the Servicer.XI

XI

1122(d)(3)(ii)Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.

X

1122(d)(3)(iii)Disbursements made to an investor are posted within two business days to the Servicers investor records, or such other number of days specified in the transaction agreements.

X

1122(d)(3)(iv)Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.

X

Pool Asset Administration

1122(d)(4)(i)Collateral or security on pool assets is maintained as required by the transaction agreements or related mortgage loan documents.X

1122(d)(4)(ii)Pool asset and related documents are safeguarded as required by the transaction agreementsX

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

1122(d)(4)(iv)Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the Servicers obligor records maintained no more than two business days after receipt, or such othernumber of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related pool asset documents.X2

1Excludes the criteria as set forth on 3(i)(C) and 3(i)(D) which is not applicable to the Asserting Party.

2The processing of payments within 2 business day criteria is not applicable as the Asserting Party does not routinely accept or process payments.

SERVICING CRITERIA

APPLICABLE

SERVICINGCRITERIA

INAPPLICABLE

SERVICING

CRITERIA

Reference

Criteria

Performed

Directly

by

Asserting

Party

Performed

by

Vendor(s)

for which

Asserting

Party is the

Responsible

Party

Performed by

subservicer(s)

orvendor(s)

for which

Asserting

Party isNOT

the

Responsible

Party

NOT

performed by

Asserting

Party orby

subservicer(s)

or vendor(s)
retained by
Asserting

Party

1122(d)(4)(v)The Servicers records regarding the pool assets agree with the Servicers records with respect to an obligors unpaid principal balance.

X

1122(d)(4)(vi)Changes with respect to the terms or status of an obligors pool assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements andrelated pool asset documents.X

1122(d)(4)(vii)Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframesor other requirements established by the transaction agreements.X

1122(d)(4)(viii)Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other periodspecified in the transaction agreements, and describe the entitys activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g.,illness or unemployment).X

1122(d)(4)(ix)Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.

X

1122(d)(4)(x)Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligors pool asset documents, on at least an annual basis, or such other period specified inthe transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment ofthe related pool assets, or such other number of days specified in the transaction agreements.

X

1122(d)(4)(xi)Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that suchsupport has been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements.

X

1122(d)(4)(xii)Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicers funds and not charged to the obligor, unless the late payment was due to the obligors error oromission.

X

1122(d)(4)(xiii)Disbursements made on behalf of an obligor are posted within two business days to the obligors records maintained by the Servicer, or such other number of days specified in the transaction agreements.

X

1122(d)(4)(xiv)Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.

X

1122(d)(4)(xv)Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.

X

EX-33.35d139354dex333.htmEX-33.3

EX-33.3

Exhibit 33.3

Situs Holdings, LLC

2 Embarcadero Center,Suite 1300

San Francisco, CA 94111

Phone: 415.374.2820

Fax: 415.374.2704

Certification Regarding Compliance with Applicable Servicing Criteria

1.Situs Holdings, LLC (the Company or Situs), is responsible for assessing compliance with the servicing criteria applicable to it in Item1117, 1119, 1122(d)(3)(i), Item1122(d)(4)(i)and 1122(d)(4)(vii) of Regulation AB, as of and for the year ended December31, 2015 (the Reporting Period), as set forth in Appendix A hereto. The deals covered by this report include deals in which Situs acted in the capacity ofOperating or Trust Advisor, as listed in Appendix B;

2.Situs used the criteria set forth in Item1122(d)(3)(i), 1122(d)(4)(i) and Item1122(d)(4)(vii) of Regulation AB (defined in Appendix A) to assess the compliance with the applicable servicing criteria;

3.Pursuant to Item1117 of Regulation AB (defined in Appendix A), the Company has determined that there are no pending legal proceedings or proceedings by governmental authorities against the Company that arematerial to security owners of the deals as listed in Appendix B;

4.Pursuant to Item1119 of Regulation AB (defined in Appendix AB), the Company has determined that there are no affiliate relationships, as defined in paragraph 230.405 of Item1119, that currently exist, orexisted within the past two years, between Situs Holdings, LLC and any of the named Servicers, Special Servicers, Trustees, or Originators included in the deals as listed in Appendix B;

5.During the reporting period, there were only two loans within the deals listed in Appendix B referred to Special Servicing, however nothing was submitted to Situs during the reporting period that would require action asthe Operating Advisor. Therefore, Situs did not perform any Operating or Trust Advisor activities related to Item1122(d)(3)(i), Item1122(d)(4)(i), or Item1122(d)(4)(vii) of Regulation AB;

6.Situs has complied in all material aspects, with the applicable servicing criteria as of December31, 2015 and for the Reporting Period with respect to the deals listed in Appendix B taken as a whole;

7.Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on Situs assessment of compliance with the applicable servicing criteria for the Reporting Period.

Situs Holdings, LLC

February 18, 2016

By:

/s/ George Wisniewski

George Wisniewski

Executive Managing Director

Situs Holdings, LLC

2 Embarcadero Center,Suite 1300

San Francisco, CA 94111

Phone: 415.374.2820

Fax: 415.374.2704

APPENDIX A

SERVICING CRITERIA

Reference

Criteria

Item1117Describe briefly any legal proceedings pending against the sponsor, depositor, trustee, issuing entity, servicer contemplated by Item 1108(a)(3) of this Regulation AB, originator contemplated by Item 1110(b) of this RegulationAB, or other party contemplated by Item 1100(d)(1) of this Regulation AB, or of which any property of the foregoing is the subject, that is material to security holders. Include similar information as to any such proceedings known to be contemplatedby governmental authorities.

Item1119

(a) Describe if so, and how, the sponsor, depositor or issuing entity is an affiliate (as defined in 230.405 of this chapter) of anyof the following parties as well as, to the extent known and material, if so, and how, any of the following parties are affiliates of any of the other following parties:

(1) Servicer contemplated by Item 1108(a)(3) of this Regulation AB.

(2) Trustee.

(3) Originator contemplated by Item 1110 of this Regulation AB.

(4) Significant obligor contemplated by Item 1112 of this Regulation AB.

(5) Enhancement or support provider contemplated by Items 1114 or 1115 of this Regulation AB.

(6) Any other material parties related to the asset-backed securities contemplated by Item1100(d)(1) of this Regulation AB.

(b) Describe whether there is, and if so the generalcharacter of, any business relationship, agreement, arrangement, transaction or understanding that is entered into outside the ordinary course of business or is on terms other than would be obtained in an arms length transaction with anunrelated third party, apart from the asset-backed securities transaction, between the sponsor, depositor or issuing entity and any of the parties in paragraphs (a)(1) through (a)(6) of this section, or any affiliates of such parties, that currentlyexists or that existed during the past two years and that is material to an Investors understanding of the asset-backed securities.

(c) Notwithstanding paragraph (b) of this section, describe, to the extent material, any specific relationships involving or relating to the asset-backedsecurities transaction or the pool assets, including the material terms and approximate dollar amount involved, between the sponsor, depositor or issuing entity and any of the parties in paragraphs (a)(1) through (a)(6) of this section, or anyaffiliates of such parties, that currently exists or that existed during the past two years.

Item1122(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 inaccordance 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 rulesand regulations; and (D) Agree with investors or the trustees records as to the total unpaid principal balance and number of pool assets serviced by the servicer.

Item1122(d)(4)(i)Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.

Item1122(d)(4)(vii)Loss mitigation or recovery actions (e.g. forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframesor other requirements established by the a transaction agreements.

Situs Holdings, LLC

2 Embarcadero Center,Suite 1300

San Francisco, CA 94111

Phone: 415.374.2820

Fax: 415.374.2704

APPENDIX B

Operating or Trust Advisor

CMBS Transactions

Deal Name

Servicing
Agreement
Date

CGCMT 2012-GC8

09/01/12

CGCMT 2013-GC15

09/01/13

CGCMT 2014-GC19

03/01/14

CGCMT 2015-SSHP

03/09/15

CGCMT 2015-GC29

04/01/15

CGCMT 2015-GC33

09/01/15

COMM 2012-CCRE3

10/01/12

COMM 2013-CCRE13

12/01/13

COMM 2014-CCRE18

06/01/14

COMM 2014-LC15

03/01/14

COMM 2014-UBS5

09/01/14

GSMS 2012-GCJ7

06/01/12

GSMS 2013-GCJ12

05/01/13

GSMS 2013-GCJ16

11/01/13

GSMS 2014-GC24

09/01/14

GSMS 2015-GS1

11/01/15

MSBAM 2012-C5

07/01/12