| UNITED STATES |
| SECURITIES AND EXCHANGE COMMISSION |
| Washington, D.C. 20549 |
| FORM 10-K |
| (Mark one) |
| ☑ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 |
| For the fiscal year ended December 31, 2014 |
| 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 of the issuing entity: 333-177354-02 |
| Central Index Key Number of the issuing entity: 0001552328 |
| UBS-Barclays Commercial Mortgage Trust 2012-C2 |
| (exact name of the issuing entity as specified in its charter) |
| Central Index Key Number of the depositor: 0001532799 |
| UBS Commercial Mortgage Securitization Corp. |
| (exact name of the depositor as specified in its charter) |
| Central Index Key Number of the sponsor: 0001541886 |
| UBS Real Estate Securities Inc. |
| (exact name of the sponsor as specified in its charter) |
| Central Index Key Number of the sponsor: 0000312070 |
| Barclays Bank PLC |
| (exact name of the sponsor as specified in its charter) |
Central Index Key Number of the sponsor: 0001548405
(The CIK provided is associated with Starwood Mortgage Capital LLC, the parent of the sponsor, which acts as securitizer for purposes of Rule 15Ga-1.) |
| Starwood Mortgage Funding II LLC (formerly known as Archetype Mortgage Funding II LLC) |
| (exact name of the sponsor as specified in its charter) |
| Central Index Key Number of the sponsor: 0001089877 |
| KeyBank National Association |
| (exact name of the sponsor as specified in its charter) |
| New York |
| (State or other jurisdiction of incorporation or organization of the issuing entity) |
| 46-0613665 |
| 46-0621519 |
| (I.R.S. Employer Identification Numbers) |
| c/o U.S. Bank National Association, as Certificate Administrator |
| 190 S. LaSalle Street |
| Chicago, Illinois |
| (Address of principal executive offices of the issuing entity) |
| Registrant’s telephone number, including area code: |
| (212) 713-2000 |
| Securities registered pursuant to Section 12(b) of the Act: None. |
| Securities registered 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. Yes ☐ No ☑ |
| Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes ☐ No ☑ |
| 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 1934 during 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 90 days. Yes ☑ No ☐ |
| Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (Section 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 if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is not contained herein, and will not be contained, to the best of registrant's knowledge, in definitive proxy or information statements incorporated 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. See the definitions of "large accelerated filer", "accelerated filer" and "smaller reporting company" in Rule 12b-2 of the Exchange Act. |
| Large accelerated filer ☐ | Accelerated filer ☐ |
| Non-accelerated filer ☑ | Smaller reporting company ☐ |
| Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act). Yes ☐ No ☑ |
| 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 common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrant's most recently completed second fiscal quarter. |
| Not applicable. |
| Indicate by check mark whether the 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. ☐Yes ☐No |
| Not applicable. |
|
| Indicate the number of shares outstanding of each of the registrant's classes of common stock, as of the latest practicable date. |
| Not applicable. |
| DOCUMENTS INCORPORATED BY REFERENCE |
| List hereunder 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). |
| Not applicable. |
|
| EXPLANATORY NOTE |
| This Annual Report on Form 10-K includes assessments of compliance with applicable servicing criteria and accountant’s attestation reports from CoreLogic Commercial Real Estate Services, Inc. and National Tax Search, LLC. These entities were engaged by the master servicer to remit tax payments received from the escrow accounts of borrowers to local taxing authorities, to report tax amounts due, to verify tax parcel information, and to verify non-escrow tax payments. These services are included within the servicing criteria set forth in Items 1122(d)(4)(xi) and 1122(d)(4)(xii). Therefore, under the principles-based definition of “servicer” set forth in Item 1101(j) that looks to the functions that an entity performs, these vendors are “servicers” for the purposes of Item 1122. See Compliance and Disclosure Interpretations, Section 301.01 (Item 1101(j)). |
| Item 1. Business. |
| Omitted. |
| Item 1A. Risk Factors. |
| Omitted. |
| Item 1B. Unresolved Staff Comments. |
| None. |
| Item 2. Properties. |
| Omitted. |
| Item 3. Legal Proceedings. |
| Omitted. |
| Item 4. Mine Safety Disclosures. |
| Not applicable. |
| Item 5. Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases of Equity
Securities. |
| Omitted. |
| Item 6. Selected Financial Data. |
| Omitted. |
| Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations. |
| Omitted. |
| Item 7A. Quantitative and Qualitative Disclosures About Market Risk. |
| Omitted. |
| Item 8. Financial Statements and Supplementary Data. |
| Omitted. |
| Item 9. Changes in and Disagreements With Accountants on Accounting and Financial Disclosure. |
| Omitted. |
| Item 9A. Controls and Procedures. |
| Omitted. |
| Item 9B. Other Information. |
| None. |
| Item 10. Directors, Executive Officers and Corporate Governance. |
| Omitted. |
| Item 11. Executive Compensation. |
| Omitted. |
| Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters. |
| Omitted. |
| Item 13. Certain Relationships and Related Transactions, and Director Independence. |
| Omitted. |
| Item 14. Principal Accounting Fees and Services. |
| Omitted. |
| ADDITIONAL DISCLOSURE ITEMS FOR REGULATION AB |
| Item 1112(b) of Regulation AB, Significant Obligors of Pool Assets (Financial Information). |
| The 110 William Street Mortgage Loan (Loan #1 on Annex A-1 to the Prospectus Supplement of the registrant relating to the issuing entity filed on July 16, 2012 pursuant to Rule 424 (b)(5)) constitutes a significant obligor within the meaning of Item 1101(k)(2) of Regulation AB, as disclosed in the Prospectus Supplement. In accordance with Item 1112 (b) of Regulation AB, the most recent unaudited net operating income of the significant obligor was $11,166,445.00 for the twelve-month period ended December 31, 2014. |
| Item 1114(b)(2) of Regulation AB, Credit Enhancement and Other Support, Except for Certain Derivatives Instruments (Information Regarding Significant Enhancement Providers Financial Information). |
| No entity or group of affiliated entities provides any external credit enhancement or other support for the certificates within this transaction as described under Item 1114 (a) of Regulation AB. |
| Item 1115(b) of Regulation AB, Certain Derivatives Instruments (Financial Information). |
| No entity or group of affiliated entities provides any derivative instruments or other support for the certificates within this transaction as described under Item 1115 of Regulation AB. |
| Item 1117 of Regulation AB, Legal Proceedings. |
| The registrant knows of no material pending legal proceeding involving the trust or any party related to the trust, other than routine litigation incidental to the duties of those respective parties, and the following, with respect to UBS Real Estate Securities Inc. (“UBSRES”), a sponsor and a mortgage loan seller, and U.S. Bank National Association (“U.S. Bank”), the certificate administrator, custodian, trustee, and paying agent: |
| UBSRES is currently engaged in litigation with respect to various legacy residential mortgage-backed securities transactions. Some litigants are seeking the repurchase of mortgage loans by UBSRES from certain residential mortgage securitization trusts, on the basis that the loans are allegedly in breach of contractual representations and warranties in governing transaction documents. Other litigants are alleging violations of federal and/or state securities or common law for alleged misrepresentations and omissions in offering documents in connection with the issuance and/or distribution of residential mortgage-backed securities. No assurance can be given that one or more of the foregoing actions will not result in material liability to UBSRES. |
| In June 2014, a civil complaint was filed in the Supreme Court of the State of New York, New York County, by a group of institutional investors against U.S. Bank, in its capacity as trustee or successor trustee (as the case may be) under certain residential mortgage backed securities (“RMBS”) trusts. The plaintiffs are investment funds formed by nine investment advisors (AEGON, BlackRock, Brookfield, DZ Bank, Kore, PIMCO, Prudential, Sealink and TIAA) that purport to be bringing suit derivatively on behalf of 841 RMBS trusts that issued $771 billion in original principal amount of securities between 2004 and 2008. According to the plaintiffs, cumulative losses for these RMBS trusts equal $92.4 billion as of the date of the complaint. The complaint is one of six similar complaints filed against RMBS trustees (Deutsche Bank, Citibank, HSBC, Bank of New York Mellon and Wells Fargo) by certain of these plaintiffs. The complaint against U.S. Bank alleges the trustee caused losses to investors as a result of alleged failures by the sponsors, mortgage loan sellers and servicers for these RMBS trusts and asserts causes of action based upon the trustee's purported failure to enforce repurchase obligations of mortgage loan sellers for alleged breaches of representations and warranties concerning loan quality. The complaint also asserts that the trustee failed to notify securityholders of purported events of default allegedly caused by breaches by mortgage loan servicers and that the trustee purportedly failed to abide by appropriate standards of care following events of default. Relief sought includes money damages in an unspecified amount and equitable relief. In November 2014, the plaintiffs sought leave to voluntarily dismiss their original state court complaint and filed a substantially similar complaint in the United States District Court for the Southern District of New York. The federal civil complaint added a class action allegation and a change in the total number of named trusts to 843 RMBS trusts. In December 2014, the plaintiffs’ motion to voluntarily dismiss their original state court complaint was granted. Other cases alleging similar causes of action have previously been filed against U.S. Bank and other trustees by RMBS investors in other transactions. |
| There can be no assurances as to the outcome of the litigation, or the possible impact of the litigation on the trustee or the RMBS trusts. However, U.S. Bank denies liability and believes that it has performed its obligations under the RMBS trusts in good faith, that its actions were not the cause of losses to investors and that it has meritorious defenses, and it intends to contest the plaintiffs’ claims vigorously. |
| Item 1119 of Regulation AB, Affiliations and Certain Relationships and Related Transactions. |
| The information regarding this Item has been previously provided in a prospectus supplement of the Registrant relating to the issuing entity filed on July 16, 2012 pursuant to Rule 424(b)(5). |
| Item 1122 of Regulation AB, Compliance with Applicable Servicing Criteria. |
| The reports on assessment of compliance with the servicing criteria for asset-backed securities and the related attestation reports on such assessments of compliance are attached hereto under Item 15. Attached as Schedule II to the Pooling and Servicing Agreement incorporated by reference as Exhibit 4 to this Annual Report on Form 10-K is a chart identifying the entities participating in a servicing function for the transaction responsible for each applicable servicing criterion set forth in Item 1122(d). |
| The assessment of compliance with applicable servicing criteria furnished pursuant to Item 1122 of Regulation AB by CWCapital Asset Management LLC ("CWAM") attached to this Annual Report on Form 10-K as Exhibit 33.2 discloses that a material instance of noncompliance occurred, as described below: |
| Material Instance of Noncompliance by CWAM |
| CWAM's assessment of compliance with the Applicable Servicing Criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB as of December 31, 2014 and for the Reporting Period, disclosed a material instance of noncompliance that occurred with respect to the servicing criterion set forth in Item 1122(d)(1)(i), as follows: |
| • With respect to compliance with servicing criterion 1122(d)(1)(i), CWAM’s policies and procedures were not properly instituted to monitor loan performance or other triggers and events of defaults in accordance with the transaction agreements. |
| Management's Discussion on Material Instance of Noncompliance by CWAM |
| 1122(d)(1)(i): Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance of the transaction agreements. Timely reporting results of monitoring loan performance to the trusts, in accordance with the transaction agreements. |
| The instance of material noncompliance, for the Reporting Period included a failure to deliver required asset status reports ("ASRs") to the transaction parties in a timely manner with respect to certain agreements for the securitization transactions described in the table below (which do not include the securitization transaction to which this Annual Report on Form 10-K relates). The preparation and delivery of ASRs to the transaction parties are a component of CWAM's requirements under section 1122(d)(1)(i) of Regulation AB. The typical delivery timeframe ranges from 30 to 90 days and is dependent upon the related transaction agreements. Certain securitizations require ASRs upon transfer of a loan to CWAM. During the reporting period, CWAM prepared the required ASRs, but failed to deliver the ASRs within the timeframes specified in the transaction agreements. The ASRs for a total of 34 loans related to 17 securitizations were not delivered on time. CWAM remedied the issue in December 2014 by delivering all of the delinquent reports. |
| # | Securitization | Number of loans impacted |
| 1 | BACM 2006-3 | 1 |
| 2 | BACM 2008-1 | 3 |
| 3 | CD 2007-CD4 | 5 |
| 4 | CGCMT 2007-C6 | 4 |
| 5 | GSMS 2012-GCJ7 | 1 |
| 6 | JPMC 2006-CIBC17 | 3 |
| 7 | JPMC 2006-LDP9 | 3 |
| 8 | JPMC 2007-LDP11 | 2 |
| 9 | JPMCC 2006-CIBC14 | 1 |
| 10 | JPMCC 2008-C2 | 1 |
| 11 | MLCFC 2006-1 | 1 |
| 12 | MLCFC 2007-5 | 2 |
| 13 | MLCFC 2007-6 | 1 |
| 14 | MLMT 2006-C1 | 1 |
| 15 | WBCMT 2006-C25 | 1 |
| 16 | WBCMT 2006-C26 | 2 |
| 17 | WBCMT 2006-C28 | 2 |
| Total | 34 |
| In response to the procedural and system control weaknesses, CWAM's Compliance Committee conducted a process analysis and implemented various measures to prevent recurrence. The measures included additional task-specific training and development of a workflow chart with responsible parties including assignment of a senior manager responsible for the ASR process. |
| Item 1123 of Regulation AB, Servicer Compliance Statement. |
| The servicer compliance statements are attached as Exhibits to this Annual Report on Form 10-K. |
| Item 15. Exhibits, Financial Statement Schedules. |
| (a) Exhibits |
| (1) Not applicable |
| (2) Not applicable |
| (3) See below. |
| 4.1 Pooling and Servicing Agreement, dated as of July 1, 2012, among UBS Commercial Mortgage Securitization Corp., as depositor, Wells Fargo Bank, National Association, as master servicer, CWCapital Asset Management LLC, as special servicer, Pentalpha Surveillance LLC, as operating advisor, and U.S. Bank National Association, as certificate administrator, custodian, trustee, and paying agent (filed as Exhibit 4 to the registrant’s Current Report on Form 8-K filed on July 17, 2012 and incorporated by reference herein)
|
| 31 Rule 13a-14(d)/15d-14(d) Certification |
| 33 Reports on Assessment of Compliance with Servicing Criteria for Asset-Backed Securities |
| 33.1 Wells Fargo Bank, National Association, as Master Servicer |
| 33.2 CWCapital Asset Management LLC, as Special Servicer |
| 33.3 U.S. Bank National Association, as Certificate Administrator, Custodian, and Trustee |
| 33.4 Pentalpha Surveillance LLC, as Operating Advisor |
| 33.5 CoreLogic Commercial Real Estate Services, Inc., as Servicing Function Participant |
| 33.6 National Tax Search, LLC, as Servicing Function Participant |
| 34 Attestation Reports on Assessment of Compliance with Servicing Criteria for Asset-Backed Securities |
| 34.1 Wells Fargo Bank, National Association, as Master Servicer |
| 34.2 CWCapital Asset Management LLC, as Special Servicer |
| 34.3 U.S. Bank National Association, as Certificate Administrator, Custodian, and Trustee |
| 34.4 Pentalpha Surveillance LLC, as Operating Advisor |
| 34.5 CoreLogic Commercial Real Estate Services, Inc., as Servicing Function Participant |
| 34.6 National Tax Search, LLC, as Servicing Function Participant |
| 35 Servicer Compliance Statements |
| 35.1 Wells Fargo Bank, National Association, as Master Servicer |
| 35.2 CWCapital Asset Management LLC, as Special Servicer |
| 35.3 U.S. Bank National Association, as Certificate Administrator |
| 99.1 Mortgage Loan Purchase Agreement, dated July 17, 2012, among UBS Real Estate Securities Inc., UBS Commercial Mortgage Securitization Corp. and Barclays Bank PLC (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K, filed on July 17, 2012 and incorporated by reference herein) |
| 99.2 Mortgage Loan Purchase Agreement, dated July 17, 2012, between Barclays Bank PLC and UBS Commercial Mortgage Securitization Corp. (filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K, filed on July 17, 2012 and incorporated by reference herein) |
| 99.3 Mortgage Loan Purchase Agreement, dated July 17, 2012, between Archetype Mortgage Funding II LLC and UBS Commercial Mortgage Securitization Corp. (filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K, filed on July 17, 2012 and incorporated by reference herein) |
| 99.4 Mortgage Loan Purchase Agreement, dated July 17, 2012, between KeyBank National Association and UBS Commercial Mortgage Securitization Corp. (filed as Exhibit 99.4 to the registrant’s Current Report on Form 8-K, filed on July 17, 2012 and incorporated by reference herein) |
| (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. |
|
| 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 its behalf by the undersigned, thereunto duly authorized. |
| UBS Commercial Mortgage Securitization Corp. |
| (Depositor) |
| /s/David Nass |
| Name: David Nass |
| Title: President and Chief Executive Officer |
| (senior officer in charge of securitization of the depositor) |
| /s/Alfred Fernandez |
| Name: Alfred Fernandez |
| Title: Executive Director |
| 4.1 Pooling and Servicing Agreement, dated as of July 1, 2012, among UBS Commercial Mortgage Securitization Corp., as depositor, Wells Fargo Bank, National Association, as master servicer, CWCapital Asset Management LLC, as special servicer, Pentalpha Surveillance LLC, as operating advisor, and U.S. Bank National Association, as certificate administrator, custodian, trustee, and paying agent (filed as Exhibit 4 to the registrant's Current Report on Form 8-K filed on July 17, 2012 and incorporated by reference herein) |
| 31 Rule 13a-14(d)/15d-14(d) Certification |
| 33 Reports on Assessment of Compliance with Servicing Criteria for Asset-Backed Securities |
| 33.1 Wells Fargo Bank, National Association, as Master Servicer |
| 33.2 CWCapital Asset Management LLC, as Special Servicer |
| 33.3 U.S. Bank National Association, as Certificate Administrator, Custodian, and Trustee |
| 33.4 Pentalpha Surveillance LLC, as Operating Advisor |
| 33.5 CoreLogic Commercial Real Estate Services, Inc., as Servicing Function Participant |
| 33.6 National Tax Search, LLC, as Servicing Function Participant |
| 34 Attestation Reports on Assessment of Compliance with Servicing Criteria for Asset-Backed Securities |
| 34.1 Wells Fargo Bank, National Association, as Master Servicer |
| 34.2 CWCapital Asset Management LLC, as Special Servicer |
| 34.3 U.S. Bank National Association, as Certificate Administrator, Custodian, and Trustee |
| 34.4 Pentalpha Surveillance LLC, as Operating Advisor |
| 34.5 CoreLogic Commercial Real Estate Services, Inc., as Servicing Function Participant |
| 34.6 National Tax Search, LLC, as Servicing Function Participant |
| 35 Servicer Compliance Statements |
| 35.1 Wells Fargo Bank, National Association, as Master Servicer |
| 35.2 CWCapital Asset Management LLC, as Special Servicer |
| 35.3 U.S. Bank National Association, as Certificate Administrator |
| 99.1 Mortgage Loan Purchase Agreement, dated July 17, 2012, among UBS Real Estate Securities Inc., UBS Commercial Mortgage Securitization Corp. and Barclays Bank PLC (filed as Exhibit 99.1 to the registrant’s Current Report on Form 8-K, filed on July 17, 2012 and incorporated by reference herein) |
| 99.2 Mortgage Loan Purchase Agreement, dated July 17, 2012, between Barclays Bank PLC and UBS Commercial Mortgage Securitization Corp. (filed as Exhibit 99.2 to the registrant’s Current Report on Form 8-K, filed on July 17, 2012 and incorporated by reference herein) |
| 99.3 Mortgage Loan Purchase Agreement, dated July 17, 2012, between Archetype Mortgage Funding II LLC and UBS Commercial Mortgage Securitization Corp. (filed as Exhibit 99.3 to the registrant’s Current Report on Form 8-K, filed on July 17, 2012 and incorporated by reference herein) |
| 99.4 Mortgage Loan Purchase Agreement, dated July 17, 2012, between KeyBank National Association and UBS Commercial Mortgage Securitization Corp. (filed as Exhibit 99.4 to the registrant’s Current Report on Form 8-K, filed on July 17, 2012 and incorporated by reference herein) |
EX-31 Rule 13a-14(d)/15d-14(d) Certifications.
I, David Nass, 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 the UBS-Barclays Commercial Mortgage Trust 2012-C2 (the "Exchange 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
the circumstances 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 statements required in
this report under Item 1123 of Regulation AB, and except as disclosed in
the Exchange Act periodic reports, the servicers have fulfilled their
obligations under the servicing agreements 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 securities required
to be included in this report in accordance with Item 1122 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
instances of noncompliance described in such reports have been disclosed in
this report on Form 10-K.
In giving the certifications above, I have reasonably relied on information
provided to me by the following unaffiliated parties:
Wells Fargo Bank, National Association, as Master Servicer, CWCapital Asset Management
LLC, as Special Servicer, Pentalpha Surveillance LLC, as Operating Advisor, U.S. Bank
National Association, as Trustee, Certificate Administrator and Custodian, CoreLogic
Commercial Real Estate Services, Inc., as Servicing Function Participant, and National
Tax Search, LLC, as Servicing Function Participant.
Dated: March 27, 2015
/s/ David Nass
David Nass
President and Chief Executive Officer
(senior officer in charge of securitization of the depositor)
Wells Fargo Commercial Mortgage Servicing
Management's Assessment
P.O. Box:31388, Oakland, CA 94604
1901 Harrison St., 2nd Floor
Oakland, CA 94612
Tel:
800 986 9711
Management of Wells Fargo Commercial Mortgage Servicing, a division of Wells Fargo Bank, National
Association, (the "Company") is responsible for assessing 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 criteria 1122(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, 2014. Appendix A to this 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 to the 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, 2014 with respect to the Platform, because there were no occurrences of events
that would require the Company to perform such activities.
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 various vendors to perform the activities required by these servicing criteria. The
Company's management has determined that none of these vendors is considered a "servicer" as defined in
Item 1101(j) of Regulation AB, and the Company's management has elected to take responsibility for
assessing compliance with the servicing criteria applicable to each vendor as permitted by the SEC's
Compliance and Disclosure Interpretation ("C&DI") 200.06, Vendors Engaged by Services (C&DI
200.06) (formerly SEC Manual Telephone Interpretation 17.06). The Company has policies and
procedures in place designed to provide reasonable assurance that the vendors' activities comply in all
material respects with the servicing criteria applicable to each vendor. The Company's 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 Company's management has assessed the Company's compliance with the applicable servicing criteria
as of and for the year ended December 31, 2014. 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 ended December 31, 2014, 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 management's assessment of compliance with the applicable servicing criteria as of and for the
year ended December 31, 2014.
March 6, 2015
/S/ Daniel E. Bober
Daniel E. Bober
Executive Vice President
Commercial Mortgage Servicing
Wells Fargo Bank, National Association
APPENDIX A
COMMERCIAL MORTGAGES POOLS AND OTHER STRUCTURES
GOLDMAN SACHS 2005-ROCK
TIMES SQUARE HOTEL TRUST
BHMS 2014-ATLS
BB-UBS 2012-SHOW
DOLLAR GENERAL
DLJ 1999-CG2
BB-UBS 2012-TFT
GSMS 2012-BWTR
GREENWICH CCFC 2003-C2
BB 2013-TYSN
GREENWICH CCFC 2003-C1
COMM 2013-THL
DLJ 1999-CG1
GSMS 2012-SHOP
DLJ 1999-CG3
MS06TOP23
PCMT03PWRI
DLJ 1998-CG1
BSC03PWR2
BSCM06TOP24
BSC05PWR8
MSOSTOP19
MSCI06TOP21 (NONPOOLED)
MS06TOP21
BSC04PWR3
BSC04PWR4
BSCOSPWR7
MS07TOP25
BSCM04TOP14
BSC04PWR6
BSCM06TOP22
BSCMS05TOP20
BSC04PWR5
BSCM05TOP20 (NONPOOLED)
BA-FUNB 2001-3
BSCM07TOP26
BSC06PWR11
BSC06PWR13
BSC06PWR12
BSC07PWR15
BSC05PWR10
BSC05PWR9
ML 1997-C2
BSC06PWR14
BACM2005-6
MSDW03HQ2
BANC OF AMERICA COMM MTG
2006-1
BANC OF AMERICA COMM
MTG2005-6
BANC OF AMERICA COMM
MLMT 2005-CKI1
BANC OF AMERICA COMM
MTG 2006-5
MTG2007-3
BANC OF AMERICA COMM
GECMC 2007-C1
GREENWICH CCFC 2007-GG11
MTG 2006-2
JPMC 2003 CIBC6
GECC 2001-3
JPMC 2002 C2
ML-CFC 2006-1
GREENWICH CCFC 2007-GG9
CGCMT 2013-GC17
DBUBS 2011-LC2
DBUBS 2011-LC3
CGCMT 2014-GC21
COMM 2014-CCRE20
COMM 2014-277P
CITIGROUP 2007-C6
MLMT 2006-C2
COMM 2014-CCRE14
COMM 2013-CCRE12
MS03T0P11
GSMS 2012-GCJ9
GSMS 2013-GC10
GSMS 2010-C2
CITIGROUP 2013-GCJ11
GSMS 2011-GC3
JPMC 2003-Cl
ML-CFC 2006-2
GREENWICH CCFC 2005-GG5
GSMS 2013-GC13
GSMS 2014-GC18
COMM2014-UBS5
GRACE 2014-GRCE
GSMS 2012-ALOHA
CITIGROUP 2012-GC8
GSMS 2012-TMSQ
GE 2006 C1
JPMC 2003 MLl
GOLDMAN 2006-GG8
CGCMT 2013-GC15
GECC 2002-3
MLMT06C1
JPM06CIBC15
MS04TOP15
JPM07CIBC19
JPM06CIBC17
GSMSC04GG2
MLCFC06-4
COMM 2013-CCRE6
GOLDMAN 2006-GG6
COMM 2013-CCRE13
COMM 2014-LC17
COMM 2014-LC15
COMM 2014-UB6 PRIMARY ONLY
JPMC 2002 CIBC5
GE 2002 C2
GSMS 2013-GCJ14
CGCMT 2014-GC19
CGCMT 2014-GC25
GECC 2002-1
WFLD 2014-MONT
GSMS 2013-GCJ16
GSMS 2014-GC22
DBCCRE 2014-ARCP
MS05TOPI7
MSDW03TOP9
BSCM03TOP12
BAMLL 2013-WBRK
COMM 2013-WWP
BWAY2013-1515
COMM 2014-CCRE15 PRIMARY
TMSQ 2014-1500
JPMCC 2014-DSTY
JPM08C2
BSCM03TOP10
BSCM04TOP16
GECMC 2004 C2
GSMSC 2010-Cl
JPMC 2002 C1
COMM 2012-LC4
UBS 2012-C1
GREENWICH CCFC 2004-GGl
GOLDMAN 2007-GG10
GSMS 2012-GCJ7
CITIGROUP 2013-375P
GSMS 2014-GC26
COMM 2013-CCRE10
UBS-BARCLAYS 2012-C4
COMM 2010-C1
UBS-CITIGROUP 2011-C1
BSCM05TOP18
MS04TOP13
GSMS 2013-KING
UBS-BARCLAYS 2012-C2
GSMS 2011-GC5
GSMS 2013-GCJ12
COMM 2014-UBS3
DBUBS 2011-LC1
COMM 2012-9W57
JPM05LDP3
l345FB2005
GMAC 2003-C1
GCCFC 2005-GG3
NORTEL NETWORKS TRUST
JPM6LDP9
MSCI2003-IQ4
MSC05HQ6
2001-1
MSCI04HQ3
MS07TOP27 AW34
(NONPOOLED)
MS07TOP27
BSC07PWR18
CD 2007-CD4
MSC 2014-MP
BSC07PWR16
BSC07PWR17
QCMT13QC
GREENWICH CCFC 2002 C1
MS08TOP29
COMM2014-KYO
BSCM07TOP28
RBSCF 2013-SMV
BEAR 1999-Cl
MSCI2007IQ16
DMARC 1998-C1
MSC06HQ10
MSC05HQ7
MSC04HQ4
MSCI06HQ9
MSCI06HQ8
MSC07HQ12
MS01TOP1
MLCFC07-9
MSC07IQ13
MSCI03IQ6
FUNB 2001 C4
FUNB 2001 C2
MERRILL LYNCH 2008-Cl
ML-CFC 2007-7
BSCOOWF2
MSCI05IQ9
MLCFC07-6
MSD01TP3
MLCFC07-5
MDC02TP7
BSCM02TOP8
BSOITOP2
MLCFC07-8
MSC07IQ14
BSCOITP4
MSC07IQ16
MSC06IQ11
MSCI04IQ7
CITIGROUP 2013-SMP
COMM 2013-SFS
BSCOOWF1
MSCI04IQ8
MLMT07Cl
MDC01TP5
BSC99WF2
COUNTRYWIDE 2007-MF1
ML-CFC 2007-6
BSC02TP6
MLMT 2002 MW1
LB 1999 C1
LB 1999 C2
SRPT 2014-STAR
LB 1998 C4
SCG 2013-SRP1
COMMUNITY SOUTH BANK
JPMC 2005 LDP1
PORTFOLIO
1999-LIFE1
MSC99WF1
MSC98WF2
WACHOVIA 2003-C4
BAMLL 2014-IP
WACHOVIA 2003 C3
WACHOVIA 2002 Cl
CGCMT 2014-388G
JPMCC 2007-LDP11
RBSCF 2013-GSP
WACHOVIA 2003-C5
FUNB99Cl
MSC 2014-CPT
COMM2013-FL3
BAMLL 2014-8SPR
AMERICOLD 2010-ART
FUNB 2001 C3
CGWF 2013-RKWH
CGBAM 2013-BREH
BAMLL 2014-ICTS
WACHOVIA 2003-C7
JPMC 2006-LDP7
BAMLL 2014-INLD
MS2000LIFE1
JPMC03LN1
LCCM 2014-909
JPM2006LDP8
BAMLL 2013-DSNY
ONE LINCOLN 2004-C3
JPMC 2005-LDP2
VNO 2012-6AVE
JPMCC 2007-LDP10
JPMC 2001 CIBC3
VDNO 2013-PENN
CSMC 2014-USA
JPM2007LDP12
BBCMS 2014-BXO
BAMLL 2014-520M
COMM2014-BBG
CGRBS 2013-VNO5TH
LCCM2013GCP
WACHOVIA 2003-C6
COMM 2014-PAT
CGBAM 2014-HD
BLCP 2014-CLRN
ENERGY PLAZA LEASE TRUST
WPCM 2014-TISH
CD 2007-CD5
2002
WACHOVIA 2002 C2
ML 1998-C3
JPMC 2006-LDP9
JPMC 2006 FL2
COMM 2014-FL4
JPMCC 2014-FL5
COMM 2014-FL5
JPMC2011-PLSD
7 WORLD TRADE CENTER 2012-
WTC
FULB l997 C2
JPMC 2013-ALC
3 WORLD TRADE CENTER 2014
BAMLL 2014- FL1
BAMLL 2014-INLD MZ B
BACM2007-1
MSDWMC OWNER TRUST 2000-
JP MORGAN CB 2003-CIBC7
1166 AVENUE OF AMERICAS
Fl
2005-C6
FREMF 2012-K705- PRIMARY
FREMF 2013-KS01 PRIMARY
FOUR TIMES SQUARE 2006 -
ONLY
4TS
FREMF 2014 K39 PRIMARY
FREMF 2014 K37 (PRIMARY)
CSF99C01
COMM07FL14
COMM07FL14 (NONPOOLED)
GOLDMAN 2010-K5- PRIMARY ONLY
FREMF 2012-K709- PRIMARY ONLY
FREMF 2011-K14 PRIMARY ONLY
FREMF 2013 KF02 PRIMARY ONLY
FREMF 2013-K24 (PRIMARY ONLY)
CHASE-FUNB 1999-1
FREMF 2014-K38 PRIMARY
FREMF 2013-K502- PRIMARY
FREMF 2013-K712 PRIMARY
FREMF 2014-KX01 (PRIMARY)
ONLY
ONLY
FREMF 2012-KF0l PRIMARY
FREMF 2012-K710 PRIMARY
FREMF 2011-K10- PRIMARY
ONLY
ONLY
ONLY
FREMF 2011 Kl2 PRIMARY
FREMF 2014 KF03 (PRIMARY)
FREMF 2012- Kl9 PRIMARY
ONLY
ONLY
COMM 2009-K4 PRIMARY
FREMF 2012-K501- PRIMARY ONLY
FREMF 2012-K22 (PRIMARY ONLY)
LB UBS 2004 C6
WACHOVIA 2007-C33
LB-UBS 2007-C7
WFRBS 2011-C3
WACHOVIA 2006-C29
FREMF 2012-Kl8- PRIMARY
ONLY
COMM 2012-CCRE1
COMM 2012-CCRE2
FREMF 2013 K32 PRIMARY
ONLY
LB UBS 2002 C7
LB-UBS 2003-C3
WACHOVIA 2004-C12
WACHOVIA 2005-Cl6
FUNB 1999 C4
WACHOVIA 2006-C26
LB UBS 2006-C4
CSCMT 2007-C3
COBALT 2007- C3
MORGAN STANLEY 2007-HQ13
COBALT 2007-C2
LB UBS 2002 C1
CITIGROUP 2005 C3
WACHOVIA 2005-C22
TIAA 2007-C4
LB UBS 2006-C7
IRVINE CORE OFFICE TRUST
2013-IRV
WFCM 2014-LC16
WFRBS 2014-C22
LBUBS05C2
WFRBS 2012-C7
JPMCC 2012-C6
WFRBS 2012-C8
MSBAM 2013-C11
WACHOVIA 2005-C19
LB UBS 2004 C1
CS FIRST BOSTON 1998 C2
CITIGROUP 2006 C5
WACHOVIA 2004 C15
LB UBS 2003 C8
CSCMC 2007-C4
CHASE 2000-3
FREMF 2010-K6 PRIMARY
ONLY
FREMF 2011-KAIV PRIMARY
WACHOVIA 2005 C17
LB-UBS 2005 C7
ONLY
CSFB 2006-C2 COMM 2012-
CCRE4
CD 2006-CD3
WACHOVIA 2006-C24
LB-UBS 2006 C3
GECC 2000-1
MORGAN STANLEY 2011-C3
FREMF 2012-K17 PRIMARY AND
MSBAM 2014-C15
WACHOVIA 2007-WHALE 8
FUNB-BA 2001 C1
WACHOVIA 2003-C8
SPECIAL
LB-UBS 2003-C1
LB UBS 2004 C7
LB-UBS 2005 C5
WFRBS 2011-C5
WACHOVIA 2006-C25
WACHOVIA 2007-C34
WFRBS 2013-C14
JPMC 2014-C20
WFRBS 2014-C20
WFRBS 2013-C12
WFCM10C1
WFRBS 2014-LC14
WFRBS 2013-C16
JPMBB 2014-C25
MSBAM 2013-C8
JPMBB 20l3-C17
JPMBB 2014-C21
WFRBS 2013-Cl5
JPMCC 2013-C16
WFRBS 2014-C21
LB-UBS 2003 C5
LB UBS 2004 C4
LB UBS 2005 Cl
WACHOVIA 2004 C10
VORNADO DP LLC 2010-VNO
CSCMT 2007-C2
COMM2012-CCRE3
LB UBS 2001 C3
WACHOVIA 2005-C20
WACHOVIA 2007-C32
WACHOVIA 2007-C31
WACHOVIA 2006-C27
WACHOVIA 2006-C28
CHASE 1999-2
MSBAM 2014-C19
WACHOVIA 2004 C14
WFRBS 2012-C9
WFRBS 2012-C6
WFRBS 2012-C10
WFCM 2013-LC12
WFRBS 2013-C13
JPMBB 2013-C15
WFRBS 2014-C19
WFRBS 2014-C24
LBUBS05C3
WFRBS 2013-UBS1
JPMBB 2.014-C24
WFCM 2013-BTC
WFRBS 2013-C11
WFRBSI1C4
WFRBS 2013-C18
WFRBS 2014-C23
WFRBS 2014-C25
WFRBS11C2
RES 2010-MB1
WACHOVIA 2003-C9
WACHOVIA 2004 C11
1166 AVENUE OF THE
CD 2006-CD2
JPMC 2012-CIBX
AMERICAS 2002-C5
WFCM 2012-LC5
FREMF 2011-K16- PRIMARY
MEZZ CAP 2004-C2
ONLY
COBALT 2006-C1
LB-UBS 2007-C6
MEZZ CAP 2005-C3
MORGAN STANLEY BAML
MERRILL LYNCH 1998 C2
MSBAM 2014-C14
2012-C6
MSBAM 2013-Cl2
MSBAM 2014-C17
FREMF 2013-K35 (PRIMARY)
FREMF 2013 K28 (PRIMARY)
CITY CENTER 2011-CCHP
MEZZ CAP 2004-C 1
WACHOVIA 2005-C21
LB UBS 2008-C1
FUNBICHASE 1999 C2
LB UBS 2006-C6
ACRE 2013-FLl
ACRE 20l4-FL2
MEZZ CAP 2007-C5
MEZZ CAP 2006-C4
FREMF 2012-K21- PRIMARY
ONLY
FREMF 2012-KP01 PRIMARY
FREMF 2013-K27
WACHOVIA 2006-C23
ONLY
LB-UBS 2006 C1
WACHOVIA 2007-C30
FUNB 2000 C2
MSBAM 2014-C16
MSBAM 2014-Cl8
WFRBS 2013-C17
WFCM 2014-LC18
JPMBB 2014-C23
JPMBB 2014-C22
LB UBS 2000 C5
WACHOVIA 2005-C18
LB UBS 2004 C8
CITIGROUP CMT 2004 C1
FUNB 2000 C1
LB UBS 2002 C2
WACHOVIA 2006-WHALE 7
CITIGROUP 2006-FL2
LB-UBS 2007-C2
NLY 2014-FL1
RESOURCE 2013-CRE1
PFP III 2014-1
RESOURCE 2014-CRE2
MSBAM 2013-C13
FREMF 2010-K7
FREMF 2010-K8
FREMF 2014-KF06 PRIMARY
MERRILL LYNCH 1996 C2
FREMF 2014-K41
FREMF 2011-Kl3
COMM 2009-K3
FREMF 2010-K9
FREMF 2011-K11
FREMF 2014 K715
FREDDIE MAC 2010 K-SCT
FREMF 2011-K701
FREMF 2011-K702
FREMF 2011-K703
FREMF 2011-K15
FREMF 2014-K717 PRIMARY
FREMF 2013-K26
CMAT 1999 Cl
FREMF 2012-K707
FREMF 2014-K714
FREMF 2013-K31
FREMF 2013-K33
FREMF 2012-K711
FREMF 20l4-K36
FREMF 2014-K40
FREMF 2014-K716
FREMF 2011-K704
FREMF 2014-KF04
FREMF 2012-K23
FREMF 2012-K706
FREMF 2013-K25
FREMF 2013-K34
FREMF 2012-K20
FREMF 2013 K30 MASTER
FREMF 2013 K29 (MASTER)
FREMF 2014-KF05
FREMF 2014 KS02
FREMF 2013 K713
FREMF 2012-K708
MORGAN STANLEY 2005-HQ5
OBP DEPOSITOR, LLC TRUST
COMM 2012-MVP
GRAND PACIFIC BUSINESS
2010-OBP
LOAN TRUST 2005-1
WFCM 20I3-120B
2001-CMLB-l
MS2000PRIN
NORTHSTAR 2013-1 (CLO)
BSB06001
CREST 2003-2
CSFB94CFB1
NS 2012-1
UCB07-1
MAIDEN 2008-1
REXFORD INDUSTRIAL FUND V
SOUND MARK HORIZONS
LP WAREHOUSE
FUND LP WAREHOUSE
RESOURCE CAPITAL CORP.
SAS WAREHOUSE 2013 (H2)
PRIME FINANCE PARTNERS I,
WAREHOUSE
LP.
H2 WAREHOUSE 2013
JEMB MADISON AVE LLC (BASIS I-
292 MAD)
BROE WAREHOUSE
SAF FUNDING, LLC
H2 CREDIT PARTNERS
YELLOW BRICK REAL ESTATE
WAREHOUSE
CAPITAL I, LLC
LOANCORE (JEFFERIES)
JLC WAREHOUSE I LLC
JLC WAREHOUSE II LLC
WAREHOUSE
BICOASTAL (A BLACKSTONE
FII F DEBT ACCT PTE LTD
STARWOOD AND CITI REP
CREDIT FACILITY)
STARWOOD & GOLDMAN REPO
BELVEDERE CAPITAL
BASIS RE CAPITAL II (REPO)
WAREHOUSE
MODERN BANK, N.A.
LADDER WELLS FARGO REPO
LADDER CAPITAL LLC REPO
LADDER JPM REPO
LADDER DEUTSCHE REPO
RIALTO REPO WITH WF
BANK OF AMERICA
RIALTO REPO W/GS
TUEBOR WAREHOUSE
WAREHOUSE
(LADDER)
RIALTO WAREHOUSE 2013
GERMAN AMERICAN CAPITAL
KEARNY CREDIT FACILITY
CORPORATION WARE
WAREHOUSE
BARCLAYS WAREHOUSE
KGS-ALPHA REAL ESTATE
FORTRESS CREDIT CORP
WAREHOUSE
ROCKWOOD (375 PARK)
WAREHOUSE
OWS I ACQUISITIONS, LLC WH
OWS COF I MASTER WH
OWS CREDIT OPPORTUNITY I
ONE WILLIAM STREET CAP
SRE FW MEZZ WAREHOUSE
WH
MASTER FUND WH
(RIDGMAR MEZZ)
SINGERMAN (RIDGMAR MEZZ
NXT CAPITAL FUNDING II, LLC
SPREF WH II WF REPO
LOAN)
STARWOOD & DEUTSCHE
LADDER MET LIFE REPO
PRIME FINANCE PARTNERS III,
REPO
LP
SILVERPEAK RE FINANCE LLC
GERMAN AMERICAN I
LONESTAR (RELIUS)
WAREHOUSE
DEUTSCHE WAREHOUSE
WAREHOUSE 2013
SPREF WH I LLC (DEUTSCHE
JLC WAREHOUSE IV LLC
WACHOVIA GENERAL
REPO)
(DEUTSCHE REPO)
PARTICIPANT
WACHOVIA GENERAL
PRIME FINANCE PARTNERS II,
RLJ III -FINANCE HOLDINGS,
PARTICIPANT
L.P.
LLC
TRT LENDING REPO
STARWOOD PROPERTY
FORTRESS (CF TRANS HOLDCO
WAREHOUSE
MORTGAGE LLC WAREHOUSE
LLC) WAREHOUSE
TRT LENDING SUBSIDIARY
ACM TRAFFORD V LLC
LONE STAR REPO WITH WELLS
LLC
WAREHOUSE
FARGO
CITIGROUP GLOBAL MARKETS
CREXUS WAREHOUSE
WASHINGTON SUB, LLC
REALTY CORP
STARWOOD MORTGAGE
ARCHETYPE & BARCLAYS
MC FIVE MILE SPE B LLC
CAPITAL WAREHOUSE
REPO
(COLUMN REPO)
FIVE MILE WAREHOUSE (GS)
STARWOOD CITI REPO SUB 6
NRFC WAREHOUSE (SOHO
HOUSE)
PILLAR FUNDING LLC
PRIME REPO WITH U.S. BANK
PRIME REPO WITH METLIFE
WAREHOUSE
UBS WAREHOUSE
CF BRANCH WAREHOUSE
MKP CREDIT MASTER FUND
MEZZANINE
WESTIN TIME SQUARE
WESTIN TIME SQUARE
BLACKSTONE SELECT HOTEL
MEZZANINE
MEZZANINE 2
SRMEZZ
NBS REAL ESTATE CAPITAL
WAREHOUSE
LONESTAR REPO WITH CB
TEACHERS INSURANCE &
ANNUITY ASSOCIATION
STARWOOD PROPERTY
ACCORMEZZ WAREHOUSE
ALABAMASAVES WAREHOUSE
MORTGAGE SUB-2, L.L.C.
CANTOR CRE LENDING LP
MORGAN STANLEY
MACQUARIE WAREHOUSE
GACC/DEUTSCHE FLOATING
GCCP H-1, LLC (GROSSMAN)
MKP CREDIT MASTER FUND
WAREHOUSE
WAREHOUSE
BANCORP BANK WAREHOUSE
ROCKWOOD CAPITAL, LLC
(NORTHROCK)
CAPITAL LEASE WAREHOUSE-
398 & 526
RAITH WAREHOUSE
BUCHANAN FUND V
BMC MORTGAGES VI
BUCHANAN MORTGAGE
FIVE MILE WAREHOUSE
NRFC II REPO WAREHOUSE
CAPITAL
NORTHSTAR-DORAL
WAREHOUSE (NRFC)
NORTHSTAR-DORAL
WAREHOUSE (NSREIT)
NORTHSTAR-CITI REPO
WAREHOUSE
NRFC REPO WAREHOUSE
NORTHSTAR (CB LOAN NT- II,LLC)
SQUARE MILE/RAM ACQ, LLC
CB REPO
OWS ABS MASTER FUND II, LP
GOLDMAN SACHS
LVS II SPE III LLC (AFFILIATE
WAREHOUSE
OFPIMCO)
TOCU II LLC (PIMCO ENTITY)
GS COMMERCIAL REAL
PIMCO (GCCU I LLC)
ESTATE WAREHOUSE
PIMCO (TOCU I LLC)
LIBREMAX WAREHOUSE
ROC DEBT STRATEGY FUND
MANAGERLLC
BLACKSTONE (BRE/MWT)
RBS WAREHOUSE
GREENWICH CAPITAL
FINANCIAL PRODUCTS INC
JP MORGAN CHASE
PFP II SUB I, LLC
PRIME AND METLlFE REPO
RESOURCE CAPITAL REPO
BREDS LOAN CAPITAL REPO
BREDS LOAN CAPITAL IV REPO
WAREHOUSE
WAREHOUSE
WAREHOUSE
BREDS LOAN CAPITAL II REPO
MORGAN STANLEY
NORTHSTAR(NS
WAREHOUSE
HEALTHCARELOANHOLDING LLC)
NS RE INCOME OPERATING
NORTHSTAR DB LOAN NT-II
WFB REPO WITH LVSI
PARTNESHIP II, LP
REPO
NORTHSTAR (NS HEALTHCARE
NORTHSTAR-DB REPO
NORTHSTAR-DB REPO
PT 2) WAREHOUSE
WAREHOUSE (NSINCOME)
WAREHOUSE (NRFC)
CANTOR REPO WITH MET LIFE
PFP III SUB I, LLC
MARATHON STRUCTURED FINANCE
FUND LP
MARATHON STRUCTURED
MARATHON STRUCTURED
TRIANGLE WAREHOUSE
FINANCE FUND LP
FINANCE FUND LP
ONE WEST BANK REPO
MEZZ CAP LLC (FKA CBA
MEZZ CAP REIT I, INC
MEZZ)
RESOURCES REPO WITH DB
SL GREEN REALTY
CORP/GRAMERCY
H2-WF REPO WAREHOUSE
SL GREEN WAREHOUSE
SL GREEN - JPM REPO
DEXIA REAL ESTATE
PORTFOLIO
DEXIA REAL ESTATE CAPITAL
BB&T WAREHOUSE
NORTHSTAR WAREHOUSE
MARKETS
LEHMAN BROTHERS
LEHMAN BROTHERS
AG MIT CREL (ANGELO
WAREHOUSE
WAREHOUSE
GORDON ENTITY) REPO
WEST RIVER WAREHOUSE
VALSTONE WAREHOUSE
WACHOVIA RED - TAX CREDIT
WACHOVIA RED- TAX CREDIT
RIVER MARKET BROE
VORNADO REALTY L.P.
WAREHOUSE
WAREHOUSE
CD 2007-CD4 COMPANION
LB-UBS 2006 Cl COMPANION
GREENWICH CCFC 2003 C1
(COMPANION)
BSCMS05TOP20
MS06TOP23
COBALT 2007- C3 COMPANION
(COMPANION)_LANDESBANK
(COMPANION)_LANDESBANK
LB UBS 2006-C4 COMPANION
CITIGROUP 2007-C6
WACHOVIA 2006-C27 -
(COMPANION)
COMPANION
MSBAM 2013-Cl2 COMPANION
JPMC 2006-LDP9 COMPANION
GREENWICH CCFC 2007-GG11
COMPANION
MORGAN STANLEY 2007 IQ14
CITIGROUP 2012-GC8
COMM 2014-LC17 COMPANION
COMPANION
GSMS 2013-GC10
COMM 2013-WWP COMPANION
GSMS 2011-GC5 COMPANION
GOLDMAN 2006-GG6
GREENWICH CCFC 2007-GG9
CGCMT2014-GC21 COMPANION
COMPANIONS
COMPANION
COMM 2014-CCRE14
GSMS 2011-GC3 COMPANION
GSMS 2010-C2 COMPANION
COMPANION
GREENWICH CCFC 05 GG5
(COMPANION)
GOLDMAN 2006-GG8
COMPANIONS
GSMS 2014-GC18 COMPANION
COMM 2014-UBS5 COMPANION
CGCMT2013-GC15 COMPANION
COMM 2013-CCRE13
COMM 2014-LC15 COMPANION
COMM 2013-CCRE6
COMPANION
GSMSC04GG2 (COMPANION)
1_VARIABLELIFE
CGCMT 2014-GC25
CGCMT 2014-GC19 COMPANION
GSMS 2014-GC22 COMPANION
COMPANION
GSMSC 2010-C1 COMPANION
GOLDMAN 2007-GG10
GSMS 2012-GCJ7 COMPANION
COMPANION
CITIGROUP 2013-375P
GSMS 2014-GC26 COMPANION
COMM 2013-CCRE10
COMPANION
COMPANION
COMM 2010-Cl COMPANION
COMM 2014-UBS3 COMPANION
DBUBS 2011-LC1 COMPANION
BSCM07TOP28 (COMPANION)
MSC05HQ6
ML-CFC 2007-7 COMPANION
1_BALDEAGLE
(COMPANION)_PRUDENTIAL
FUNB 2001 C2 B NOTES
BSCM07TOP28 (COMPANION)
MLCFC07-6
2_STARWOOD
(COMPANION)_ASTAR
1345FB2005 (COMPANION)
BSCMS05TOP20 (COMPANION)
BSCMS05TOP20 (COMPANION)
2_HARTFORDLIFE
3_METLIFE
BSCMS05TOP20 (COMPANION)
MSC07HQ12 (COMPANION)
MSC07HQ12 (COMPANION)
1_NYLIFE
2_DEUTSCHEAG
1_CIT
JPMCC 2007-LDPI1
JPMC 2006-LDP7 COMPANION
FUNB 2001 C3 B NOTES
COMPANION
CGWF 2013-RKWH COMPANION
JPMCC 2007-LDP10
7 WORLD TRADE CENTER 2012-
COMPANION
WTC COMPANION
COMM 2006-FL12 COMPANION
COMM2013-FL3 COMPANION
BRE SELECT HOTELS MEZZ
WAREHOUSE
3 WORLD TRADE CENTER 2014
BAMLL 2014-FL1 COMPANION
CGBAM 2014-HD COMPANION
COMPANION
LEHMAN 2006 LLF-C5C
LEHMAN 2005-LLF C4
JPMCC 2014-FL5 COMPANION
(COMPANIONS)
COMM 2014-FL4 COMPANION
LB UBS 2004 C6 COMPANION
MSBAM 2013-C11 COMPANION
WACHOVIA 2004-Cl5
LB-UBS 2005-C7 COMPANION
WACHOVIA 2007-WHALE 8
COMPANION
NON TRUST
FOUR TIMES SQUARE 2006-
4TS COMPANION
COMM07FLl4 (COMPANION)
2_SOCIETE GENERAL
WACHOVIA 2007-C31
COMPANION
WACHOVIA 2007-C32
COBALT 2007-C2 COMPANION
WACHOVIA 2007-C34
COMPANION
COMPANION
MSBAM 2013-C8 COMPANION
JPM 2012-CIBX COMPANION
LB UBS 2004 C8 COMPANION
WACHOVIA 2006-C29
WACHOVIA 2006-C24
LEHMAN-UBS 2005 C5
COMPANION
(COMPANION)
COMPANION
WACHOVIA 2006-C25
(COMPANION)
WACHOVIA 2005-C20
(COMPANION)
WACHOVIA 2007-C30
COMPANION
WACHOVIA 2007-C33
WFCM 2013-LC12 COMPANION
MORGAN STANLEY 2007-HQ13
COMPANION
COMPANION
LB UBS 2006-C7 COMPANION
WFRBS 2014-C22 COMPANION
MSBAM 2014-C15 COMPANION
LB-UBS 2006-C3 COMPANION
JPMC 2014-C20 COMPANION
WFRBS 2014-C20 COMPANION
WFRBS 2014-LC14 COMPANION
WFRBS 2013-C16 COMPANION
JPMBB 2013-Cl7 COMPANION
WFRBS 2013-C15 COMPANION
JPMCC 2013-C16 COMPANION
JPMBB 2014- C21 COMPANION
WACHOVIA 2004-C10
LB UBS 2005 C1 COMPANION
LBUBS05C3 (COMPANION)
(COMPANION)
1_SORINRE
LBUBS05C3 (COMPANION)
LBUBS05C3 (SENIOR MEZZ)
LBUBS05C3 (SENIOR MEZZ)
4_QUADRANTFUND
5_BAYERISCHE
4_AIBDEBT
LBUBS05C3 (SENIOR MEZZ)
3_LRP
LBUBS05C3 (SENIOR MEZZ)
2_ING
LBUBS05C3 (SENIOR MEZZ)
l_METLIFE
WFRBS 2013-C11 COMPANION
WFRBS11C2 (PARTICIPATION)_WEST
RIVER
MSBAM 2014-Cl9 COMPANION
JPMBB 2013-C15 COMPANION
WFRBS 2014-C19 COMPANION
WFRBS2013-UBS1 COMPANION
WFRBS 2014-C25 COMPANION
WFRBS 2014-C23 COMPANION
RBS 2010-MB1 COMPANION
WACHOVIA 2004-C11
(COMPANION)
LB-UBS 2007-C6 (COMPANION)
CITY CENTER 2011-CCHP
COMPANION
MSBAM 2014-C14 COMPANION
MSBAM 2014-C17 COMPANION
WACHOVIA 2005-C21
(COMPANION)
LB-UBS 2006-C6 COMPANION
MSBAM 2014-C16 COMPANION
MSBAM 2014-C18 COMPANION
WFRBS 2013- C17 COMPANION
WFCM 2014- LC18 COMPANION
JPMBB 2014-C22 COMPANION
LB UBS 2007-C2 COMPANION
WACHOVIA 2006 WHALE 7 NON TRUST
CITIGROUP 2006-FL2
COMPANION
JPMC 2005-LDP2 COMPANIONS
MORGAN GUARANTY TRUST
STRATEGIC LAND JOINT
CO. OF NY
VENTURE 2
MLFT 2006-1
(COMPANION)_CAPTRUST
VERTICAL CRE CDO 2006-
1_ROYAL HOLIDAY
CONCORD REAL ESTATE CDO
2006-1 (CERRITOS)
CRESS 2008-1
CDO_PLAZAELSEGUNDO
CBA-MEZZANINE CAPITAL FINANCE
MLCFC07-5
(COMPANION)_LEXINGTON
ALL STATE_PPG
(PARTICIPATION)
WFRBS11C4
(COMPANION)_LIBERTYLIFE
WFCM10C1
(PARTICIPATION)_BASIS
NORTHSTAR CDO VIII
NORTHSTAR CDO IX PRIMARY
(MEMORIAL MALL)
NEWCASTLE CDO IX
CONCORD REAL ESTATE CDO
2006-1
MARATHON REAL ESTATE CDO
2006-1
CAPLEASE CDO 2005-1
RESOURCE REAL ESTATE
FUNDING CDO 2006-1
WACHOVIA CRE CDO 2006-1
RESOURCE REF CDO 2007-1
CAPITAL SOURCE RELT 2006-A
NORTHSTAR CDO IV LTD
NORTHSTAR CDO VI
SUNTRUST BANK_KINGPLAZA
(PARTICIPATION)
PEOPLE'S UNITED BANK_COLE
MTANDPPG
FMBT12FBLU
JPMC07FL1
HMAC99PHI
WB05WHALE6
GCCFC04FL2
GCCFC03C2C
LB06LLFC5
DDR09DDR1
COMM06FL12
CSFB06TFL2
CSF7C2
CSFB97C1
MSDOOLIFE2
1998-WF1
1997-WF1
GCCFC06FL4
LBUBS2001C2
LBUBS2000C3
GECC2001-1
COMM12FL2
LBUBS03C7
LBUBS2002C4
GECC 2003-C2
FUNB2002Cl
WB06C28C
CHASE 2000-2
CGBAM13BREH
BSCOOWF1
COMM11FL1
MS2000LIFE1
CGCMTJ4GC25C
APPENDIX B
APPLICABLE SERVICING CRITERIA WITH RESPECT TO COMMERCIAL LOANS
(THE PLATFORM)
SERVICING CRITERIA
APPLICABLE
SERVICING
CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
the
Company
Performed
by
Vendor(s)
for which
the
Company is
the
Responsible
Party
Performed by
vendor(s) for
which the
Company is
NOT the
Responsible
Party
NOT
performed by
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company
General Servicing Considerations
1122(d)(I)(i)
Policies and procedures are instituted to monitor
any performance or other triggers and events of
default in accordance with the transaction
agreements.
X
X
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
1122(d)(l)(iii)
Any requirements in the transaction agreements to
maintain a back-up servicer for the pool assets are
maintained.
X
1122(d)(l)(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
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
X
SERVICING CRITERIA
APPLICABLE
SERVICING
CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
the
Company
Performed
by
Vendor(s)
for which
the
Company is
the
Responsible
Party
Performed by
vendor(s) for
which the
Company is
NOT the
Responsible
Party
NOT
performed by
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company
days specified in the transaction agreements.
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 the transaction 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 a foreign financial
institution means a foreign financial institution
that meets the requirements of Rule 13k-l (b)(l) of
the Securities Exchange Act.
X
1122(d)(2)(vi)
Unissued checks are safeguarded so as to prevent
unauthorized access.
X
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
X
SERVICING CRITERIA
APPLICABLE
SERVICING
CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
the
Company
Performed
by
Vendor(s)
for which
the
Company is
the
Responsible
Party
Performed by
vendor(s) for
which the
Company is
NOT the
Responsible
Party
NOT
performed by
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company
(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) contain
explanations for reconciling items. These
reconciling items are resolved within 90 calendar
days of their original identification, or such other
number of days specified in the transaction
agreements.
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
accordance with timeframes and other terms set
forth in the transaction agreements;
X
X
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
1122(d)(3)(i)(D)
(D) agree with investors' or the trustee's records as
to the total unpaid principal balance and number
of pool assets serviced by the Servicer.
X
1122(d)(3)(ii)
Amounts due to investors are allocated and
X
SERVICING CRITERIA
APPLICABLE
SERVICING
CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
the
Company
Performed
by
Vendor(s)
for which
the
Company
is the
Responsible
Party
Performed by
vendor(s) for
which the
Company is
NOT the
Responsible
Party
NOT
performed by
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company
remitted in accordance with timeframes,
distribution priority and other terms set forth in
the transaction agreements.
1122(d)(3)(iii)
Disbursements made to an investor are posted
within two business days to the Servicer's
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.
X
X
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)
1122(d)(4)(iv)
Payments on pool assets, including any payoffs,
made in accordance with the related [pool asset]
documents are posted to the Servicer's obligor
records maintained no more than two business
days after receipt, or such other number of days
specified in the transaction agreements, and
allocated to principal, interest or other items (e.g.,
X
SERVICING CRITERIA
APPLICABLE
SERVICING
CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
the
Company
Performed
by
Vendor(s)
for which
the
Company
is the
Responsible
Party
Performed by
vendor(s) for
which the
Company is
NOT the
Responsible
Party
NOT
performed by
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company
Escrow in accordance with the related mortgage
loan documents.
1122(d)(4)(v)
The Servicer's records regarding the pool assets
agree with the Servicer's records with respect to
an obligor's unpaid principal balance.
X
1122(d)(4)(vi)
Changes with respect to the terms or status of an
obligor's pool assets (e.g., loan modifications or
re-aging) are made, reviewed and approved by
authorized personnel in accordance with the
transaction agreements and related pool asset
documents.
X
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
timeframes or other 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 period
specified in the transaction agreements, and
describe the entity's activities in monitoring
delinquent pool assets including for example,
phone calls, letters and payment rescheduling
plans in cases where delinquency is deemed
X
:
SERVICING CRITERIA
APPLICABLE
SERVICING
CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
the
Company
Performed
by
Vendor(s)
for which
the
Company
is the
Responsible
Party
Performed by
vendor(s) for
which the
Company is
NOT the
Responsible
Party
NOT
performed by
the Company
or by
subservicer(s)
or vendor(s)
retained by
the Company
temporary (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 obligor's pool
asset documents, on at least an annual basis, or
such other period specified in the transaction
agreements
X
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 support 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
X(2)
SERVICING CRITERIA
APPLICABLE
SERVICING
CRITERIA
INAPPLICABLE
SERVICING
CRITERIA
Reference
Criteria
Performed
Directly
by
the
Company
Performed
by
Vendor(s)
for which
the
Company is
the
Responsible
Party
Performed by
vendor(s) for
which the
Company is
NOT the
Responsible
Party
NOT
performed by
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 Servicer's funds and not charged to
the obligor, unless the late payment was due to the
obligor .s error or omission.
X
X(2)
1122(d)(4)(xiii)
Disbursements made on behalf of an obligor are
posted within two business days to the obligor's
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)(l) through (3) or Item
1115 of Regulation AB, is maintained as set forth
in the transaction agreements.
X
(1) There were no activities performed during the year ended December 31, 2014 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).
CWCapital Asset Management(Logo)
March 4, 2015
Management's Report on Assessment of Compliance with Regulation AB Servicing Criteria
1.
CWCapital Asset Management LLC ("CWAM") is responsible for assessing compliance with
applicable servicing criteria, set forth in Item 1122(d) of Regulation AB of the Securities and Exchange
Commission, for all commercial mortgage-backed securitization transactions publicly-issued pursuant to
a registration statement under the Securities Act of 1933 on or after January 1, 2006 wherein the
Company provides special servicer activities (the Platform), except for servicing criteria
1122(d)(1)(iii),1122(d)(3)(i)(b),1122(d)(3)(i)(c),1122(d)(3)(i)(d),1122(d)(3)(ii),1122(d)(3)(iii),
1122(d)(3)(iv),1122(d)(4)(v),1122(d)(4)(ix),1122(d)(4)(x),1122(d)(4)(xi),1122(d)(4)(xii),1122(d)(4)(xiii),
1122(d)(4)(xiv), 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 twelve months ended December 31,
2014 (Applicable Servicing Criteria). With respect to applicable servicing criteria 1122(d)(1)(ii),
1122(d)(2)(vi),1122(d)(4)(i),1122(d)(4)(iii), and 1122(d)(4)(iv), the Company has determined that there
were no activities performed during the twelve months ended December 31, 2014, with respect to the
Platform, because there were no occurrences of events that would require the Company to perform
such activities. Appendix A to Management's Report on Assessment of Compliance with Regulation
AB Servicing Criteria identifies the individual asset-backed transactions and securities defined by
management as constituting the Platform.
2.
CWCAM has assessed its compliance with the Applicable Servicing Criteria as of December 31, 2014
and for the period from January 1 2014 to December 31, 2014 ("the Reporting Period"). 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.
3.
Based on such assessment, management believes that as of December 31, 2014 and for Reporting
Period, CWAM has complied in all material respects with the Applicable Servicing Criteria set forth in
Item 1122(d) with respect to the Platform, except for a material instance of noncompliance described in
Schedule A hereto.
4.
Schedule B hereto includes Management's Discussion of the Material Instance of Noncompliance
noted in Schedule A.
KPMG LLP, an independent registered public accounting firm, has issued an attestation report on
CWAM's compliance with the Applicable Servicing Criteria as of December 31, 2014 and for the
Reporting Period.
CWCapital Asset Management LLC
By:_/s/ David B. Iannarone ____ Date:____________________
David B. Iannarone
President
By:_/s/Bruce Cunningham______ Date:___March 4, 2015______
Bruce Cunningham
Chief Financial Officer
Schedule A
Material Instance of Noncompliance
CWAM's assessment of compliance with the Applicable Servicing Criteria set forth by the Securities and
Exchange Commission in paragraph (d) of Item 1122 of Regulation AB as of December 31, 2014 and for the
Reporting Period, disclosed a material instance of noncompliance occurred with respect to the servicing
criterion set forth in Item 1122(d)(1)(i), as follows:
With respect to compliance with servicing criterion 1122(d)(1)(i), the Company's policies and
procedures were not properly instituted to monitor loan performance or other triggers and events of
defaults in accordance with the transaction agreements.
Schedule B
Management's Discussion on Material Instance of Noncompliance
1122(d)(1)(i), Policies and procedures are instituted to monitor any performance or other triggers and events
of default in accordance of the transaction agreements. Timely reporting results of monitoring loan
performance to the trusts, in accordance with the transaction agreements.
Noncompliance:
The instance of material noncompliance, for the Reporting Period included a failure to deliver required asset
status reports ("ASRs") to the transaction parties in a timely manner with respect to certain transaction
agreements described in the table below. The preparation and delivery of ASRs to the transaction parties are a
component of CWAM's requirements under section 1122(d)(1)(i) of Regulation AB. The typical delivery
timeframe ranges from 30 to 90 days and is dependent upon the related transaction agreements. Certain
securitizations require ASRs upon transfer of a loan to CWAM. During the reporting period, CWAM
prepared the required ASRs, but failed to deliver the ASRs within the timeframes specified in the transaction
agreements. The ASRs for a total of 34 loans related to 17 securitizations were not delivered on time. CWAM
remedied the issue in December 2014 by delivering all of the delinquent reports.
#
Securitization
Number of loans impacted
1
BACM 2006-3
1
2
BACM 2008-1
3
3
CD 2007-CD4
5
4
CGCMT 2007-C6
4
5
GSMS 2012-GCJ7
1
6
JPMC 2006-CIBC17
3
7
JPMC 2006-LDP9
3
8
JPMC 2007-LDP11
2
9
JPMCC 2006-CIBC14
1
10
JPMCC 2008-C2
1
11
MLCFC 2006-1
1
12
MLCFC 2007-5
2
13
MLCFC 2007-6
1
14
MLMT 2006-C1
1
15
WBCMT 2006-C25
1
16
WBCMT 2006-C26
2
17
WBCMT 2006-C28
2
Total
34
Remediation:
In response to the procedural and system control weaknesses, CWAM's Compliance Committee conducted a
process analysis and implemented various measures to prevent recurrence. The measures included additional
task-specific training and development of a workflow chart with responsible parties including assignment of
senior manager responsible for the ASR process.
Appendix A
BACM 2006-3
Banc of America Commercial Mortgage Inc., Commercial Mortgage Pass-Through Certificates, Series 2006-3
BACM 2006-6
Banc of America Commercial Mortgage Inc., Commercial Mortgage Pass-Through Certificates, Series 2006-6
BACM 2007-1
Banc of America Commercial Mortgage Inc., Commercial Mortgage Pass-Through Certificates, Series 2007-1
BACM 2008-1
Banc of America Commercial Mortgage Inc., Commercial Mortgage Pass-Through Certificates, Series 2008-1
CD 2007-CD4
CD 2007-CD4 Commercial Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series CD 2007-CD4
CGCMT 2007-C6
Citigroup Commercial Mortgage Trust 2007-C6, Commercial Mortgage Pass-Through Certificates, Series 2007-C6
COBALT 2006-C1
COBALT CMBS Commercial Mortgage Trust 2006-C1, Commercial Mortgage Pass-Through Certificates,
Series 2006-C1
COBALT 2007-C2
COBALT CMBS Commercial Mortgage Trust 2007-C2, Commercial Mortgage Pass-Through Certificates,
Series 2007-C2
COBALT 2007-C3
COBALT CMBS Commercial Mortgage Trust 2007-C3, Commercial Mortgage Pass-Through Certificates,
Series 2007-C3
COMM 2006-C7
Deutsche Mortgage & Asset Receiving Corporation, COMM 2006-C7 Commercial Mortgage Pass-Through Certificates
COMM 2012-LC4
Deutsche Mortgage & Asset Receiving Corporation, COMM 2012-LC4 Commercial Mortgage Pass-Through
Certificates
DBUBS 2011-LC3
U.S Bank National Association, as Trustee for the registered holders of DBUBS 2011-LC3 Commercial Mortgage Pass
through Certificates
GMAC 2006-C1
GMAC Commercial Mortgage Securities, Inc., Mortgage Pass-Through Certificates, Series 2006-C1
GSMSC 2006-GG8
GS Mortgage Securities Corporation II, Commercial Mortgage Pass-Through Certificates, Series 2006-GG8 and
Companion Loan Noteholders
GSMSC 2007-GG10
GS Mortgage Securities Corporation II, Commercial Mortgage Pass-Through Certificates, Series 2007-GG10
GSMSC 2014-GC26
GS Mortgage Securities Corporation II, Commercial Mortgage Pass-Through Certificates, Series 2014-GC26 and
Companion Loan Noteholders
GSMSC 2014-GC22
GS Mortgage Securities Corporation II, Commercial Mortgage Pass-Through Certificates, Series 2014-GC22 and
Companion Loan Noteholders
GSMS 2012-GCJ7
GS Mortgage Securities Corporation II, Commercial Mortgage Pass-Through Certificates, Series 2014-GCJ7 and
Companion Loan Noteholders
JPMBB 2014-C23
J.P. Morgan Chase Commercial Mortgage Securities Corp., Mortgage Pass-Through Certificates, Series 2014-C23
JPMC 2006-CIBC17
J.P. Morgan Chase Commercial Mortgage Securities Corp., Mortgage Pass-Through Certificates, Series 2006-CIBC17
JPMC 2006-LDP9
J.P. Morgan Chase Commercial Mortgage Securities Trust 2006-LDP9, Commercial Mortgage Pass-Through
Certificates, Series 2006-LDP9
JPMC 2007-LDP11
J.P. Morgan Chase Commercial Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series
2007-LDP11
JPMCC 2006-CIBC14
J.P. Morgan Chase Commercial Mortgage Securities Corp., Mortgage Pass-Through Certificates, Series 2006-CIBC14
JPMCC 2008-C2
J.P. Morgan Chase Commercial Mortgage Securities Trust 2008-C2, Commercial Mortgage Pass-Through Certificates,
Series 2008-C2
JPMCC 2013-C10
Wells Fargo, National Association, as trustee for the registered holders of J.P. Morgan Chase Commercial Mortgage
Securities Trust 2013-C10, Commercial Mortgage Pass-Through Certificates, Series 2013-C10
JPMCC 2013-LC11
Wells Fargo, National Association, as trustee for the registered holders of J.P. Morgan Chase Commercial Mortgage
Securities Trust 2013-LC11, Commercial Mortgage Pass-Through Certificates, Series 2013-LC11
LBCMT 2007-3
LB Commercial Mortgage Trust 2007-C3, Commercial Mortgage Pass-Through Certificates, Series 2007-C3
LBUBS 2006-C4
LB-UBS Commercial Mortgage Trust 2006-C4, Commercial Mortgage Pass-Through Certificates, Series 2006-C4
LBUBS 2007-C1
LB-UBS Commercial Mortgage Trust 2007-C1, Commercial Mortgage Pass-Through Certificates, Series 2007-C1
LBUBS 2007-C2
LB-UBS Commercial Mortgage Trust 2007-C1, Commercial Mortgage Pass-Through Certificates, Series 2007-C1
LBUBS 2008-C1
LB-UBS Commercial Mortgage Trust 2008-C1, Commercial Mortgage Pass-Through Certificates, Series 2008-C1
MLCFC 2006-1
ML-CFC Commercial Mortgage Trust 2006-2, Commercial Mortgage Pass-Through Certificates, Series 2006-1
MLCFC 2006-2
ML-CFC Commercial Mortgage Trust 2006-2, Commercial Mortgage Pass-Through Certificates, Series 2006-2
MLCFC 2007-5
ML-CFC Commercial Mortgage Trust 2007-5, Commercial Mortgage Pass-Through Certificates, Series 2007-5
MLCFC 2007-6
ML-CFC Commercial Mortgage Trust 2007-6, Commercial Mortgage Pass-Through Certificates, Series 2007-6
MLMT 2006-C1
Merrill Lynch Mortgage Trust 2006-C1, Commercial Mortgage Pass-Through Certificates, Series 2006-C1
MSCI 2007-HQ12
Morgan Stanley Capital I Inc., Commercial Mortgage Pass-Through Certificates, Series 2007-HQ13
MSCI 2007-HQ13
Morgan Stanley Capital I Inc., Commercial Mortgage Pass-Through Certificates, Series 2007-HQ13
UBS 2012-C2
UBS-Barclays Commercial Mortgage Trust 2012-C2., Series 2012-C2
WBCMT 2006-C23
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2006-C23
WBCMT 2006-C25
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2006-C25
WBCMT 2006-C26
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2006-C26
WBCMT 2006-C28
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2006-C2
WBCMT 2007-C30
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2007-C30
WBCMT 2007-C32
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2007-C32
WBCMT 2007-C34
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-Through Certificates, Series 2007-C34
WFRBS 2013-C15
Wells Fargo Bank, National Association, Commercial Mortgage Pass-Through Certificates, Series 2013-C15
WFRBS 2013-C18
Wells Fargo Bank, National Association, Commercial Mortgage Pass-Through Certificates, Series 2013-C18
WFRBS 2013-C19
Wells Fargo Bank, National Association, Commercial Mortgage Pass-Through Certificates, Series 2013-C19
WFRBS 2013-UBS1
Wells Fargo Bank, National Association, Commercial Mortgage Pass-Through Certificates, Series 2013-UBS1
WFRBS 2014-C21
Wells Fargo Bank, National Association, Commercial Mortgage Pass-Through Certificates, Series 2014-C21
WFRBS 2014-C22
Wells Fargo Bank, National Association, Commercial Mortgage Pass-Through Certificates, Series 2014-C22
WFRBS 2014-C23
Wells Fargo Bank, National Association, Commercial Mortgage Pass-Through Certificates, Series 2014-C23
WFRBS 2014-C25
Wells Fargo Bank, National Association, Commercial Mortgage Pass-Through Certificates, Series 2014-C25
MSBAM 2014-C19
Morgan Stanley, Bank of America, Merrill Lynch Trust, Commercial Mortgage Pass-Through Certificates, Series 2014-
C19
Management's Assertion
Report on Assessment of Compliance with Applicable Servicing Criteria
U.S. Bank National Association ("U.S. Bank") is responsible for assessing compliance as of and
for the year ended December 31, 2014 with the servicing criteria set forth in Item 1122 (d) of
Regulation AB applicable to it as set forth on Exhibit A hereto. This report covers asset backed
securities transactions within the U.S. Bank Corporate Trust Asset-Backed Securities
Platform
1
(the "Platform")
U.S. Bank hereby provides the following report on its assessment of compliance with the
servicing criteria set forth in Item 1122 of Regulation AB applicable to it and as described on
Exhibit A hereto:
1.
U.S. Bank is responsible for assessing its compliance with the servicing criteria
applicable to it as noted on the accompanying Exhibit A;
2.
Except as set forth in paragraph 3 below, U.S. Bank used the criteria set forth in
paragraph (d) of Item 1122 of Regulation AB to assess its compliance with the applicable
servicing criteria;
3.
The criteria listed in the column titled "Inapplicable Servicing Criteria" on Exhibit A
hereto are inapplicable to U.S. Bank based on the servicing activities it performs directly
with respect to the Platform;
4.
U.S. Bank has complied, in all material respects, with the applicable servicing criteria as
of and for the year ended December 31, 2014; and
5. Ernst & Young, LLP, a registered public accounting firm, has issued an attestation report
on U.S. Bank's assessment of compliance with the applicable servicing criteria as of and
for the year ended December 31, 2014.
U.S. BANK NATIONAL ASSOCIATION
/s/ Bryan R. Calder
Name: Bryan R. Calder
Title: Executive Vice President
Date: February 27, 2015
1
The U.S. Bank Corporate Trust Asset-Backed Securities Platform (the "Platform") consists of the
activities involved in the performance of servicing functions for which the Company provides trustee,
securities administration, registrar, paying agent or document custody services for (i) publicly issued asset-
backed and mortgage backed transactions the securities of which were offered on or after January 1, 2006
and (ii) certain asset backed transactions for which the Issuer has voluntarily elected to make Regulation
AB compliant filings under the Securities Exchange Act of 1934, as amended.
Corporate Trust ABS Platform (B)
1
EXHIBIT A to Management's Assertion
Reference
Servicing Criteria
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
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 party's 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 of the
transaction 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 transaction agreements.
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 over collateralization, are separately maintained (e.g., with
respect to commingling of cash) as set forth in the transaction 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 a foreign 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
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) contain
explanations for reconciling items. These reconciling items are resolved within 90
calendar days of their original identification, or such other number of days specified
in the transaction agreements.
X
Corporate Trust ABS Platform (B)
2
Reference
Servicing Criteria
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
Investor Remittances and Reporting
1122(d)(3)(i)
Reports to investors, including those to be filed with the Commission, are
maintained in accordance with the transaction agreements and applicable
Commission requirements. Specifically, such reports (A) are prepared in accordance
with timeframes and other terms set forth in the transaction agreements; (B) provide
information calculated in accordance with the terms specified in the transaction
agreements; (C) are filed with the Commission as required by its rules and
regulations; and (D) agree with investors' or the trustee's records as to the total
unpaid principal balance and number of Pool Assets serviced by the Servicer.
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
Servicer's 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 pool asset documents.
X
1122(d)(4)(ii)
Pool assets and related documents are safeguarded as required by the transaction
agreements.
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
1122(d)(4)(iv)
Payments on pool assets, including any payoffs, made in accordance with the
related pool asset documents are posted to the Servicer's obligor records maintained
no more than two business days after receipt, or such other number 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.
X
1122(d)(4)(v)
The Servicer's records regarding the pool assets agree with the Servicer's records
with respect to an obligor's unpaid principal balance.
X
1122(d)(4)(vi)
Changes with respect to the terms or status of an obligor's pool assets (e.g., loan
modifications or re-agings) are made, reviewed and approved by authorized
personnel in accordance with the transaction agreements and related 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 timeframes or other
requirements established by the transaction agreements.
X
Corporate Trust ABS Platform (B)
3
Reference
Servicing Criteria
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
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 period specified in the
transaction agreements, and describe the entity's 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 obligor's pool asset documents, on at
least an annual basis, or such other period specified in the 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 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 support 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 Servicer's funds and not charged to the obligor, unless
the late payment was due to the obligor's error or omission.
X
1122(d)(4)(xiii)
Disbursements made on behalf of an obligor are posted within two business days to
the obligor's 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
PENTALPHA SURVEILLANCE
i
March 4, 2015
Management's Report on Assessment of 2014 Compliance by Pentalpha
Surveillance, LLC With Applicable Regulation AB Servicing Criteria
Pentalpha Surveillance, LLC (the Asserting Party) is responsible for assessing its compliance, as of and
for the year ended December 31, 2014, 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 "Platform," which
consists of its servicing activities encompassed by contractual obligations to perform Regulation AB
reporting (see the Exhibit for a list of the Asserting Party's Platform of required reporting
by the servicing
agreements).
The Asserting Party has assessed its compliance with the applicable servicing criteria as of and for the
year ended December 31, 2014. 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.
Based on such assessment, the Asserting Party believes that as of and for the year ended December 31,
2014, the Asserting Party has complied in all material respects with the servicing criteria set forth in
Item 1122(d) of Regulation AB relating to its operational advisor role in the servicing of the Platform,
except for servicing criteria 1122(d)(1)(i-iv), 1122(d)(2)(i-vii), 1122(d)(3)(i)(C-D) 1122(d)(3)(ii-iv),
1122(d)(4)(i-vi) and 1122(d)(4)(viii-xv), which the Asserting Party has determined as being inapplicable to
the activities it performs with respect to the Platform being serviced (the "applicable servicing criteria").
McGladrey 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.
PENTALPHA SURVEILLANCE
2
Appendix A
Regulation AB Reference
Servicing Criterion
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.
Applicability/Compliance:
Not applicable.
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.
Applicability/Compliance:
Not applicable.
1122(d)(1)(iii)
Any requirements in the transaction agreements to maintain a
backup servicer for the pool assets are maintained.
Applicability/Compliance:
Not applicable.
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.
Applicability/Compliance:
Not applicable.
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.
Applicability/Compliance:
Not applicable.
1122(d)(2)(ii)
Disbursements made via wire transfer on behalf of an obligor or to
an investor are made only by authorized personnel.
Applicability/Compliance:
Not applicable.
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.
Applicability/Compliance:
Not applicable.
PENTALPHA SURVEILLANCE
3
Regulation AB Reference
Servicing Criterion
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 the transaction agreements.
Applicability/Compliance:
Not applicable.
1122(d)(2)(v)
Each custodial account is maintained at a federally insured
depository institution as set forth in the transaction agreements.
For purposes of this criterion, "federally insured depository
institution" with respect to a foreign financial institution means a
foreign financial institution that meets the requirements of
§240.13k-1(b)(1) of this chapter.
Applicability/Compliance:
Not applicable.
1122(d)(2)(vi)
Unissued checks are safeguarded so as to prevent unauthorized
access.
Applicability/Compliance:
Not applicable.
1122(d)(2)(vii)
Reconciliations are prepared on a monthly basis for all asset-
backed securities-related bank accounts, including custodial
accounts and related bank clearing accounts. These
reconciliations: (A) are mathematically accurate; (B) are prepared
within 30 calendar days after the bank statement cutoff date, or
such other number of days specified in the transaction agreements;
(C) are reviewed and approved by someone other than the person
who prepared the reconciliation; and (D) contain explanations for
reconciling items. These reconciling items are resolved within
90 calendar days of their original identification, or such other
number of days specified in the transaction agreements.
Applicability/Compliance:
Not applicable.
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 are prepared in accordance with time frames and
other terms set forth in the transaction agreements.
Applicability/Compliance:
Applicable.
1122(d)(3)(i)(B)
Reports to investors, including those to be filed with the
Commission, are maintained in accordance with the transaction
PENTALPHA SURVEILLANCE
4
Regulation AB Reference
Servicing Criterion
agreements and applicable Commission requirements. Specifically,
such reports provide information calculated in accordance with the
terms specified in the transaction agreements.
Applicability/Compliance:
Applicable.
1122(d)(3)(i)(C)
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 are filed with the Commission as required by its rules
and regulations.
Applicability/Compliance:
Not Applicable.
1122(d)(3)(i)(D)
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 agree with investors' or the trustee's records as to the
total unpaid principal balance and number of pool assets serviced
by the servicer.
Applicability/Compliance:
Not Applicable.
1122(d)(3)(ii)
Amounts due to investors are allocated and remitted in accordance
with time frames, distribution priority and other terms set forth in
the transaction agreements.
Applicability/Compliance:
Not applicable.
1122(d)(3)(iii)
Disbursements made to an investor are posted within two business
days to the servicer's investor records, or such other number of
days specified in the transaction agreements.
Applicability/Compliance:
Not applicable.
1122(d)(3)(iv)
Amounts remitted to investors per the investor reports agree with
canceled checks, or other form of payment, or custodial bank
statements.
Applicability/Compliance:
Not applicable.
1122(d)(4)(i)
Collateral or security on pool assets is maintained as required by
the transaction agreements or related pool asset documents.
Applicability/Compliance:
Not applicable.
PENTALPHA SURVEILLANCE
5
Regulation AB Reference
Servicing Criterion
1122(d)(4)(ii)
Pool assets and related documents are safeguarded as required
by the transaction agreements.
Applicability/Compliance:
Not applicable.
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.
Applicability/Compliance:
Not applicable.
1122(d)(4)(iv)
Payments on pool assets, including any payoffs, made in
accordance with the related pool asset documents are posted to
the applicable servicer's obligor records maintained no more than
two business days after receipt, or such other number 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.
Applicability/Compliance:
Not applicable.
1122(d)(4)(v)
The servicer's records regarding the pool assets agree with the
servicer's records with respect to an obligor's unpaid principal
balance.
Applicability/Compliance:
Not applicable.
1122(d)(4)(vi)
Changes with respect to the
terms or status of an obligor's pool
asset (e.g., loan modifications or re-agings) are made, reviewed
and approved by authorized personnel in accordance with the
transaction agreements and related pool asset documents.
Applicability/Compliance:
Not applicable.
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 time frames or other
requirements established by the transaction agreements.
Applicability/Compliance:
Applicable.
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 period specified in the transaction agreements,
and describe the entity's activities in monitoring delinquent pool
assets including, for example, phone calls, letters and payment
PENTALPHA SURVEILLANCE
6
Regulation AB Reference
Servicing Criterion
rescheduling plans in cases where delinquency is deemed
temporary (e.g., illness or unemployment).
Applicability/Compliance:
Not applicable.
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.
Applicability/Compliance:
Not applicable.
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
obligor's pool asset documents, on at least an annual basis, or
such other period specified in the 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 were returned to the obligor within 30 calendar
days of full repayment of the related pool asset, or such other
number of days specified in the transaction agreements.
Applicability/Compliance:
Not applicable.
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 support 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.
Applicability/Compliance:
Not applicable.
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 servicer's funds and
not charged to the obligor, unless the late payment was due to the
obligor's error or omission.
Applicability/Compliance:
Not applicable.
1122(d)(4)(xiii)
Disbursements made on behalf of an obligor are posted within two
business days to the obligor's records maintained by
the servicer,
or such other number of days specified in the transaction
agreements.
Applicability/Compliance:
Not applicable.
1122(d)(4)(xiv)
Delinquencies, charge-offs and uncollectible accounts are
recognized and recorded in accordance with the transaction
PENTALPHA SURVEILLANCE
7
Regulation AB Reference
Servicing Criterion
agreements.
Applicability/Compliance:
Not applicable.
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.
Applicability/Compliance:
Not applicable.
March 4, 2015
_/s/____James Callahan____________________________
James Callahan, Executive Director
/s/____Don Simon_________________________________
Don Simon, Chief Operating Officer
PENTALPHA SURVEILLANCE
8
Appendix B
Issuer
Platform and Public Name of
Securitization
Master Servicer
UBS Commercial Mortgage
Securitization Corp.
UBS-Barclays Commercial
Mortgage Trust 2012-C2,
Commercial Mortgage Pass-
Through Certificates, Series 2012-
C2
Wells Fargo Bank, National
Association
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2012-
C8
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities Corp.
J.P. Morgan Chase Commercial
Mortgage Securities Trust 2012-C8
Commercial Mortgage Pass-
Through Certificates, Series 2012-
C-8
Keycorp Real Estate Capital
Markets, Inc.
GS Mortgage Securities
Corporation II
Commercial Mortgage Pass-
Through Certificates, Series 2012-
GCJ9
Wells Fargo Bank, National
Association
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2012-
C10
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities Corp.
J.P. Morgan Chase Commercial
Mortgage Securities Trust 2012-
LC9 Commercial Mortgage Pass-
Through Certificates, Series 2012-
LC9
Midland Loan Services, a
division of PNC Bank, National
Association
PENTALPHA SURVEILLANCE
9
Issuer
Platform and Public Name of
Securitization
Master Servicer
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2013-
C12
Wells Fargo Bank, National
Association
Citigroup Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2013-
GCJ11
Wells Fargo Bank, National
Association
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2013-
C14
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
J.P. Morgan Chase Commercial
Mortgage Securities Trust 2013-
LC11 Commercial Mortgage Pass-
Through Certificates, Series 2013-
LC11
Midland Loan Services, a
division of PNC Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2013-C12
Commercial Mortgage Pass-
Through Certificates, Series 2013-
C12
Midland Loan Services, a
division of PNC Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
J.P. Morgan Chase Commercial
Mortgage Securities Trust 2013-
C13 Commercial Mortgage Pass-
Through Certificates, Series 2013-
C13
Midland Loan Services, a
division of PNC Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2013-C14
Commercial Mortgage Pass-
Through Certificates, Series 2013-
C14
Midland Loan Services, a
division of PNC Bank, National
Association
GS Mortgage Securities
Corporation II
Commercial Mortgage Pass-
Through Certificates, Series 2013-
GCJ14
Wells Fargo Bank, National
Association
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2013-
C16
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2013-C15
Commercial Mortgage Pass-
Through Certificates, Series 2013-
C15
Wells Fargo Bank, National
Association
Platform and Public Name of
PENTALPHA SURVEILLANCE
10
Issuer
Securitization
Master Servicer
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
J.P. Morgan Chase Commercial
Mortgage Securities Trust 2013-
C16 Commercial Mortgage Pass-
Through Certificates, Series 2013-
C16
Wells Fargo Bank, National
Association
Citigroup Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2013-
GC17
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2013-C17
Commercial Mortgage Pass-
Through Certificates, Series 2013-
C17
Wells Fargo Bank, National
Association
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2013-
C18
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2014-C18
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C18
Midland Loan Services, a
division of PNC Bank, National
Association
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C20
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2014-C19
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C19
KeyBank, National Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMCC Commercial Mortgage
Securities Trust 2014-C20
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C20
Wells Fargo Bank, National
Association
GS Mortgage Securities
Corporation II
Commercial Mortgage Pass-
Through Certificates, Series 2014-
GC22
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2014-C21
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C21
Wells Fargo Bank, National
Association
Issuer
Platform and Public Name of
Securitization
Master Servicer
PENTALPHA SURVEILLANCE
11
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2014-C22
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C22
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2014-C23
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C23
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2014-C24
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C24
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2014-C25
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C25
Wells Fargo Bank, National
Association
J.P. Morgan Chase
Commercial Mortgage
Securities, Corp.
JPMBB Commercial Mortgage
Securities Trust 2014-C26
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C26
Midland Loan Services, a
division of PNC Bank, National
Association
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C22
Wells Fargo Bank, National
Association
Wells Fargo Commercial
Mortgage Securities, Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C24
Wells Fargo Bank, National
Association
GS Mortgage Securities
Corporation II
Commercial Mortgage Pass-
Through Certificates, Series 2014-
GC26
Wells Fargo Bank, National
Association
Deutsche Mortgage & Asset
Receiving Corporation
Commercial Mortgage Pass-
Through Certificates, Series 2014-
UBS6
KeyBank, National Association
Morgan Stanley Capital I Inc.
Commercial Mortgage Pass-
Through Certificates, Series 2014-
C17
Wells Fargo Bank, National
Association
CoreLogic
1 Corelogic Dr.
Westlake,
TX 76262
REPORT ON ASSESSMENT OF COMPLIANCE
CoreLogic Commercial Real Estate Services, Inc. (the "Asserting Party"), an indirect
subsidiary of CoreLogic, Inc., is responsible for assessing compliance as of December 31,
2014, and for the period from January 1, 2014 through December 31, 2014 (the
"Reporting Period") with the applicable servicing criteria set forth in Title 17, Sections
229 as identified in Appendix A (the "Applicable Servicing Criteria"). The servicing
activities covered by this report include all
loans for commercial mortgage loan outsourcing
customers for which the Asserting Party served as the commercial tax service provider (the
"Platform").
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, 2014, and for the
Reporting Period with respect to the Platform taken as a whole.
PricewaterhouseCoopers LLP, an independent registered public accounting firm, has issued
an attestation report on the assessment of compliance with the Applicable Servicing Criteria as
of December 31, 2014, and for the Reporting Period.
CORELOGIC COMMERCIAL REAL ESTATE SERVICES, INC.
/s/ Vicki Chenault
Vicki Chenault,
Senior Vice President
February 11, 2015
Page 1 of 1
APPENDIX A
SERVICING CRITERIA for TITLE 17,SECTION 229
REFERENCE
CRITERIA
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
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 party's 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
mortgage loans 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 of the transaction agreements.
X
CASH COLLECTION AND ADMINISTRATION
1122(d)(2)(i)
Payments on mortgage loans 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 transaction agreements.
X
1122(d)(2)(ii)
Disbursements made via wire transfer on behalf of an obligor or to an investor are made
only by the authorized personnel.
X(i)
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 over collateralization, are separately maintained (e.g., with
respect to commingling of cash) as set forth in the transaction 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 a foreign financial institution means a foreign
financial institution that meets the requirements of Rule 13-k-1(b)(1) of the Securities
Exchange Act.
X
1122(d)(2)(vi)
Unissued checks are safeguarded so as to prevent unauthorized access.
X
1122(d)(2)(vii)
Reconciliations are prepared on a monthly basis for all assetbacked securities related bank
accounts, including custodial ac counts 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) contain explanations for reconciling items.
These reconciling items are resolved within 90 calendar days of their original
identification, or such other number of days specified in the transaction agreements.
X
APPENDIX A
SERVICING CRITERIA for TITLE 17, SECTION 229
REFERENCE
CRITERIA
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
INVESTOR REMITTANCES AND REPORTING
1122(d)(3)(i)
Reports to investors, including those to be filed with the Commission, are maintained in
accordance with the transaction agreements and applicable Commission requirements.
Specifically, such reports (A) are prepared in accordance with timeframes and other
terms set forth in the transaction agreements; (B) provide information calculated in
accordance with terms specified in the transaction agreements; (C) are filed with the
Commission as required by its rules and regulations; and (D) agree with investors' or
the trustee's records as to the total unpaid principal balance and number of mortgage
loans 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
Servicer's 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 mortgage loans is maintained as required by the transaction
agreements or related mortgage loan documents.
X
1122(d)(4)(ii)
Mortgage loan and related documents are safeguarded as required by the transaction
agreements.
X
1122(d)(4)(iii)
Any additions, removals or substitutions to the asset pool are made, reviewed and
approved in the accordance with any conditions. or requirements in the transaction
agreements.
X
1122(d)(4)(iv)
Payments on mortgage loans, including any payoffs, made in accordance with the
related mortgage loan documents are posted to the Servicer's obligor records
maintained no more than two business days after receipt, or such other number 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 Servicer's records regarding the mortgage loans agree with the Servicer's
records with respect to an obligor's unpaid principal balance.
X
1122(d)(4)(vi)
Changes with respect to the terms or status of an obligor's mortgage loans (e.g., loan
modifications or re-agings) are made, reviewed and approved by authorized
personnel in accordance with the transaction agreements and related 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 timeframes or other 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 period specified in the
transaction agreements, and describe the entity's activities in monitoring delinquent
mortgage loans including, for example, phone calls, letters and payment
rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or
unemployment).
X
APPENDIX A
SERVICING CRITERIA for TITLE 17, SECTION 229
REFERENCE
CRITERIA
Applicable
Servicing
Criteria
Inapplicable
Servicing
Criteria
1122(d)(4)(ix)
Adjustments to interest rates or rates of return for mortgage loans with variable rates are
computed based on the related mortgage loan documents.
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 obligor's mortgage loan documents, on at least an annual basis,
or such other period specified in the transaction agreements; (B) interest on such funds is paid,
or credited, to obligors in accordance with applicable mortgage loan documents and state laws;
and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the
related mortgage loans, 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 support 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 !ate payment penalties in connection with any payment to be made on behalf of an obligor
are paid from the servicer's funds and not charged to the obligor, unless the late payment was
due to the obligor's error or omission.
X
1122( d)(4)(xiii)
Disbursements made on behalf of an obligor are posted within two business days to the
obligor's records maintained by the servicer, or such other number of days specified in the
transaction agreement.
X(ii)
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
(i) - All wires issued by Corelogic from client custodial accounts are made by authorized Corelogic personnel.
(ii) -
ln certain instances Corelogic has the responsibility for posting disbursements related to tax payments made on behalf of an obligor to the
obligor's records maintained by the servicer within two business days, or such other number of days specified by the contract with the servicer. In
other instances, Corelogic is not responsible for posting disbursements related to tax payments made on behalf of an obligor to the obligor's
records maintained by the servicer. In such instances, Corelogic provides information regarding disbursements related to tax payments made on
behalf of an obligor to the servicers within two business days, or such other number of days specified by the contract with the servicer.
NATIONAL
Tax Search, LLC
303 E Wacker Drive, Suite 900
Chicago, IL 60601
(312) 233
-
6440
REPORT ON ASSESSMENT OF COMPLIANCE WITH APPLICABLE SECURITIES AND
EXCHANGE COMMISSION'S REGULATION AB SERVICING CRITERIA
For the calendar year ending December 31, 2014, National Tax Search, LLC has been a Tax Service
Vendor for Wells Fargo Bank (the "Servicer").
National Tax Search, LLC ("NTS") is responsible for assessing compliance as of December 31, 2014 and for
the period from January 1, 2014 through December 31, 2014 (the "Reporting Period") with the servicing
criteria set forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations (the "CFR"). NTS
has used the servicing criteria communicated to NTS by the Servicer to assess compliance with the applicable
servicing criteria. Only servicing criteria 1122 (d) (1)(ii), 1122 (d)1(iv), 1122 (d)2(ii),
1122 (d)2(v), 1122(d)2(vi), 1122 (d)2(vii), 1122(d)(4)(xi), and 1122(d)(4)(xii) (the "Applicable Servicing
Criteria") are applicable to the activities NTS performs with respect to the transactions covered by this
report. NTS has determined that the remaining servicing criteria set forth in Item 1122 (d) of the SEC
Regulation AB are not applicable to the activities it performs with respect to the transactions covered by this
report. The transactions covered by this report include all tax payments made on behalf of the Servicer
using NTS's TaxQ system (the "Platform Transactions").
NTS, as a vendor, has assessed its compliance with the Applicable Servicing Criteria for the Reporting Period
and has concluded that the NTS has complied, in all material respects, with the Applicable Servicing
Criteria as of December 31, 2014 and for the Reporting Period with respect to the Platform Transactions taken
as a whole.
Plante & Moran, PLLC, an independent registered public accounting firm, has issued an attestation report on
the assessment of compliance with the Applicable Servicing Criteria as of December 31, 2014 and for the
Reporting Period as set forth in this assertion.
National Tax Search, LLC, as Vendor to Servicer
/s/ Lori D. Eshoo
Lori D. Eshoo, President/CEO
January 12, 2015
KPMG
(Logo)
KPMG LLP
Suite 1400
55 Second Street
San Francisco, CA 94105
Report of Independent Registered Public Accounting Firm
The Board of Directors
Wells Fargo Bank, National Association:
We have examined management's assessment, included in the accompanying Management's Assessment,
that Wells Fargo Commercial Mortgage Servicing, a division of Wells Fargo Bank, National Association,
(the "Company") complied with the servicing criteria set forth in Item 1122(d) of the Securities and
Exchange Commission's Regulation AB for the servicing of commercial loans (the "Platform"), except for
servicing criteria 1122(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, 2014. The Company has determined that servicing criteria
1122(d)(4)(xi) and 1122(d)(4)(xii) are applicable to the activities the Company performs with respect to the
Platform, except for certain tax payment activities which the Company has engaged various vendors to
perform. With respect to applicable servicing criterion 1122(d)(4)(iii), the Company has determined that
there were no activities performed during the year ended December 31, 2014 with respect to the Platform,
because there were no occurrences of events that would require the Company to perform such activities.
Appendix A to the accompanying Management's Assessment identifies the commercial mortgage pools and
other structures involving the commercial loans defined by management as constituting the Platform.
Management is responsible for the Company's compliance with the servicing criteria. Our responsibility is to
express an opinion on management's assessment about the Company's compliance based on our examination
.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the
Company's compliance with the servicing criteria specified above and performing such other procedures as we
considered necessary in the circumstances. Our examination included testing selected asset-backed transactions
and securities that comprise the Platform, testing selected servicing activities related to the Platform, and
determining whether the Company processed those selected transactions and performed those selected activities
in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions
and servicing activities performed by the Company during the period covered by this report. Our procedures
were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that
may have affected the balances or amounts calculated or reported by the Company during the period covered by
this report for the selected transactions or any other transactions. We believe that our examination provides a
reasonable basis for our opinion. Our examination does not provide a legal determination on the Company's
compliance with the servicing criteria.
As described in the accompanying Management's Assessment, for servicing criteria 1122(d)(l)(i),
1122(d)(3)(i)(A), 1122(d)(4)(i), and 1122(d)(4)(vi), the Company has engaged various vendors to perform the
activities required by these servicing criteria. The Company has determined that none of these vendors
is considered a "servicer" as defined in Item 1101(j)
of Regulation AB, and the Company has elected to take
responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by the
SEC's
Compliance and Disclosure Interpretation ("C&DI'') 200.06, Vendors Engaged by Servicers
KPMG
LLP
is a
Delaware limited ability partnership,
the
U.S. member firm of KPMG international Cooperative ("KPMG
International"), a Swiss entity.
(C&DI 200.06) (formerly SEC Manual Telephone Interpretation 17.06). As permitted by C&DI 200.06, the
Company has asserted that it has policies and procedures in place designed to provide reasonable assurance
that the vendors' activities comply in all material respects with the servicing criteria applicable to each
vendor. The Company is solely responsible for determining that it meets the SEC requirements to apply
C&DI 200.06 for the vendors and related criteria as described in its assertion, and we performed no
procedures with respect to the Company's eligibility to apply C&DI 200.06.
In our opinion, management's assessment that the Company complied with the aforementioned servicing
criteria, including servicing criteria 1122(d)(l)(i), 1122(d)(3)(i)(A), 1122(d)(4)(i), and 1122(d)(4)(vi), for
which compliance is determined based on
C&DI
200.06 as described above, as of and for the year ended
December 31, 2014 is fairly stated, in all material respects.
/s/ KPMG LLP
San Francisco, California
March 6, 2015
2
KPMG(Logo)
KPMG LLP
1676 International Drive
McLean, VA 22102
Report of Independent Registered Public Accounting Firm
The Members of
CWCapital Asset Management LLC:
We have examined CWCapital Asset Management LLC's (the Company) compliance with the servicing
criteria set forth in Item 1122(d) of the Securities and Exchange Commission's Regulation AB for all
commercial mortgage-backed securitization transactions publicly issued pursuant to a registration
statement under the Securities Act of 1933 on or after January 1, 2006 wherein the Company provides
special servicer activities (the Platform), except for servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(b),
1122(d)(3)(i)(c), 1122(d)(3)(i)(d), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(v),
1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv), 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 twelve months ended December 31, 2014. With respect to the
applicable servicing criteria 1122(d)(1)(ii), 1122(d)(2)(vi), 1122(d)(4)(i), 1122(d)(4)(iii), and
1122(d)(4)(iv),the Company has determined that there were no activities performed during the twelve
months ended December 31, 2014, with respect to the Platform, because there were no occurrences of
events that would require the Company to perform such activities. Appendix A to Management's Report on
Assessment of Compliance with Regulation AB Servicing Criteria identifies the individual asset-backed
transactions and securities defined by management as constituting the Platform. Management is
responsible for the Company's compliance with the servicing criteria. Our responsibility is to express an
opinion on management's assessment about the Company's compliance based on our examination.
Our examination was conducted in accordance with the attestation standards of the Public Company
Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis,
evidence about the Company's compliance with the servicing criteria specified above and performing such
other procedures as we considered necessary in the circumstances. Our examination included testing
selected asset-backed transactions and securities that comprise the Platform, testing selected servicing
activities related to the Platform, and determining whether the Company processed those selected
transactions and performed those selected activities in compliance with the servicing criteria. Furthermore,
our procedures were limited to the selected transactions and servicing activities performed by the Company
during the period covered by this report. Our procedures were not designed to determine whether errors
may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts
calculated or reported by the Company during the period covered by this report for the selected
transactions or any other transactions. We believe that our examination provides a reasonable basis for our
opinion. Our examination does not provide a legal determination on the Company's compliance with the
servicing criteria.
KPMG LLP is a Delaware limited ability partnership,
the U.S. member firm of KPMG international Cooperative
("KPMG International"), a Swiss entity.
Our examination disclosed the following material noncompliance with servicing criterion 1122(d)(1)(i), as
applicable to the Company during the twelve months ended December 31, 2014:
With respect to compliance with servicing criterion 1122(d)(1)(i), the Company's policies and
procedures were not properly instituted to monitor loan performance or other triggers and events of
defaults in accordance with the transaction agreements.
In our opinion, except for the material noncompliance described above, the Company complied, in all
material respects, with the aforementioned servicing criteria as of and for the twelve months ended
December 31, 2014.
We do not express an opinion or any form of assurance on Schedule B, Management's Discussion of the
Material Noncompliance, included in Management's Report on Assessment of Compliance with
Regulation AB Servicing Criteria.
/s/ KPMG LLP
McLean, Virginia
March 4, 2015
Ernst & Young(Logo)
Ernst & Young LLP
Tel: +612 343 1000
Suite 1400
ey.com
220 South Sixth Street
Minneapolis, MN 55402-4509
Report of Independent Registered Public Accounting Firm
The Board of Directors
U.S. Bank National Association
We have examined management's assertion, included in the accompanying Report on Assessment for
Compliance with Applicable Servicing Criteria, that U.S. Bank National Association (the "Company")
complied with the servicing criteria set forth in Item 1122 (d) of the Securities and Exchange
Commission's Regulation AB for the U.S. Bank Corporate Trust Asset-Backed Securities Platform (the
"Platform"), for which the Company provides trustee, registrar, paying agent, securities administrator,
and custodian services, as of and for the year ended December 31, 2014, except for servicing criteria 1122
(d)(1)(iii) and 1122 (d)(4)(iv)-(xiv), which the Company has determined are not applicable to the
activities performed by them with respect to the servicing platform covered by this report. Management is
responsible for the Company's compliance with those servicing criteria. Our responsibility is to express
an opinion on management's assertion about the Company's compliance with the servicing criteria based
on our examination.
Our examination was conducted in accordance with attestation standards established by the American
Institute of Certified Public Accountants, as adopted by the Public Company Accounting Oversight Board
(United States) and, accordingly, included examining, on a test basis, evidence about the Company's
compliance with the applicable servicing criteria and performing such other procedures as we considered
necessary in the circumstances. Our examination included testing of less than all of the individual asset-
backed transactions and securities that comprise the Platform, testing of less than all of the servicing
activities related to the Platform, and determining whether the Company processed those selected
transactions and performed those selected activities in compliance with the servicing criteria.
Furthermore, our procedures were limited to the selected transactions and servicing activities performed
by the Company during the period covered by this report. Our procedures were not designed to determine
whether errors may have occurred either prior to or subsequent to our tests that may have affected the
balances or amounts calculated or reported by the Company during the period covered by this report for
the selected transactions or any other transactions. Although the Company is responsible for assessing
compliance with Items 1122 (d)(1)(ii) and 1122 (d)(2)(iii) of Regulation AB, there were no servicing
activities performed by the Company during the period from January 1, 2014 through December 31, 2014,
that required these servicing criteria to be complied with. We believe that our examination provides a
reasonable basis for our opinion. Our examination does not provide a legal determination on the
Company's compliance with the servicing criteria.
In our opinion, management's assertion that the Company complied with the aforementioned servicing
criteria as of and for the year ended December 31, 2014, for the U.S. Bank Corporate Trust Asset-Backed
Securities Platform is fairly stated, in all material respects.
/s/ Ernst & Young
Minneapolis, Minnesota
February 27, 2015
A member firm of Ernst & Young Global Limited
McGladrey
McGladrey LLP
Report of Independent Registered Public Accounting Firm
To the Board of Directors
Pentalpha Surveillance, LLC
We have examined management's assertion, included in the accompanying Management's Report on Assessment of
2014 Compliance with Applicable Regulation AB Servicing Criteria (Management's Assertion), that Pentalpha
Surveillance, LLC (the Company) complied with the servicing criteria set forth in Item 1122(d) of the Securities and
Exchange Commission's (SEC) Regulation AB for services by the Company that are encompassed by contractual
obligations to perform Regulation AB reporting (the Platform), including only those asset-backed securities
transactions defined below, as of and for the year ended December 31, 2014, excluding the following criteria set
forth in Items 1122(d)(1)(i-iv), 1122(d)(2)(i-vii), 1122(d)(3)(i)(C-D) 1122(d)(3)(ii-iv), 1122(d)(4)(i-vi) and
1122(d)(4)(viii-xv), which management has determined are not applicable to the activities performed by the
Company with respect to the Platform covered by this report. The Appendix B to management's assertion identifies
the individual asset-backed transactions defined by management as constituting the Platform. Management is
responsible for the Company's compliance with the applicable servicing criteria. Our responsibility is to express an
opinion on management's assertion about the Company's compliance with the applicable servicing criteria based on
our examination.
Our examination was conducted in accordance with attestation standards established by the American Institute of
Certified Public Accountants, as adopted by the Public Company Accounting Oversight Board (United States) and,
accordingly, included examining, on a test basis, evidence about the Company's compliance with the applicable
servicing criteria, including tests on a sample basis of the servicing activities related to the Platform, determining
whether the Company performed those activities in compliance with the servicing criteria during the specified
period and performing such other procedures as we considered necessary in the circumstances. Our procedures were
limited to selected servicing activities performed by the Company during the period covered by this report and,
accordingly, such samples may not have included servicing activities related to each asset-backed transaction in the
Platform. Further, an examination is not designed to detect noncompliance arising from errors that may have
occurred prior to the period specified above that may have affected the balances or amounts calculated or reported
by the Company during the period covered by this report. We believe that our examination provides a reasonable
basis for our opinion. Our examination does not provide a legal determination on the Company's compliance with
the servicing criteria.
In our opinion, management's assertion that Pentalpha Surveillance, LLC complied with the aforementioned
applicable servicing criteria as of and for the year ended December 31, 2014 for the Platform is fairly stated, in all
material respects.
/s/ McGladrey LLP
Irvine, California
March 4, 2015
PWC
Report of Independent Registered Public Accounting Firm
To the Board of Directors and shareholders of
CoreLogic, Inc.:
We have examined management's assertion, included in the accompanying Report on
Assessment of Compliance, that CoreLogic Commercial Real Estate Services, Inc. (the
"Company"), an indirect subsidiary of CoreLogic, Inc. complied with the servicing criteria set
forth in Item 1122(d) of the Securities and Exchange Commission's Regulation AB for all
loans for commercial mortgage loan outsourcing customers for which the Company served
as the commercial tax service provider (the "Platform"), as of December 31, 2014 and for the
year then ended, only including 1122(d)(1)(iv), 1122(d)(2)(ii), 1122(d)(2)(v), 1122(d)(2)(vi),
1122(d)(2)(vii), 1122(d)(4)(xi), 1122(d)(4)(xii) and 1122(d)(4)(xiii), which the Company has
determined are applicable to the servicing activities performed by it with respect to the
Platform. Management is responsible for the Company's compliance with the servicing
criteria. Our responsibility is to express an opinion on management's assertion based on our
examination.
Our examination was conducted in accordance with attestation standards of the Public
Company Accounting Oversight Board (United States) and, accordingly, included
examining, on a test basis, evidence about the Company's compliance with the applicable
servicing criteria and performing such other procedures as we considered necessary in the
circumstances. Our examination included testing of selected servicing activities related to the
Platform, and determining whether the Company performed those selected activities in
compliance with the applicable servicing criteria. Our procedures were limited to the selected
servicing activities performed by the Company during the period covered by this report. Our
procedures were not designed to detect noncompliance arising from errors that may have
occurred prior to or subsequent to our tests that may have affected the balances or amounts
calculated or reported by the Company during the period covered by this report. We believe
that our examination provides a reasonable basis for our opinion. Our examination does not
provide a legal determination on the Company's compliance with the servicing criteria.
In our opinion, management's assertion that the Company complied with the
aforementioned applicable servicing criteria as of and for the year ended December 31, 2014
for all loans for commercial mortgage loan outsourcing customers for which the Company
served as the commercial tax service provider is fairly stated, in all material respects.
/s/ PriceWaterhouseCoopers
Februrary 11, 2015
PricewaterhouseCoopers LLP,
2001
Ross Avenue, Suite 1800, Dallas, TX
75201-2997
T: (214) 9991400, F: (214)754 7991,
www.pwc.com/us
Plante Moran
Plante
&
Moran, PLLC
10 South Riverside Plaza
9th Floor
Chicago, IL 60606
Tel: 312.207.1040
Fax: 312 .207.1066
plantemotan.com
Report of Independent Registered Public Accounting Firm
To the Board of Directors
National Tax Search, LLC
We have examined National Tax Search's compliance with Securities and Exchange Commission's
Regulation AB Servicing Criteria, set forth in Item 1122(d) of the Security and Exchange Commission's
Regulation AB for the National Tax Search TaxQ system (the "Platform") as of and for the year ended
December 31, 2014. The Company has determined that only certain servicing criteria, 1122(d)(l)(ii),
1122(d) 1 (iv), 1122(d)2(ii), 1122(d)2(v), 1122(d)2(vi), 1122(d)2(vii), 1122(d)(4)(xi), and 1122(d)(4)(xii),
are applicable to the activities performed by it with respect to the Platform covered by this report. The
Company has determined that the remaining servicing criteria set forth in Item 1122(d) of the SEC
Regulation AB are not applicable to the activities performed by it with respect to the Platform covered by
this report.
Management is responsible for the Company's compliance with those servicing criteria. Our responsibility
is to express an opinion on management's assertion about the Company's compliance with the servicing
criteria based on our examination. Our examination was conducted in accordance with standards of the
Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a
test basis, evidence about the Company's compliance with the applicable servicing criteria and performing
such other procedures as we considered necessary in the circumstances. Our examination included a
selection of a sample of transactions and compliance activities related to the Platform during the
examination period and determining whether the Company processed those transactions and performed
those activities in compliance with the servicing criteria. Our testing of selected transactions and
compliance activities was limited to calculations, reports, and activities performed by the Company during
the period covered by this report. Our procedures did not include determining whether errors may have
occurred prior to our tests that may have affected the balances or amounts calculated or reported by the
Company during the period covered by this report for the selected transactions or any other transactions.
We believe that our examination provides a reasonable basis for our opinion. Our examination does not
provide a legal determination on the Company's compliance with the servicing criteria.
In our opinion, management's assertion that the Company complied with the aforementioned servicing
criteria as of and for the year ended December 31, 2014 for the Platform is fairly stated in all material
respects.
/s/ Plante & Moran PLLC
Chicago, IL
January 12, 2015
Pravity Member
Global Alliance of
Independent Firms
Wells Fargo(Logo)
Commercial Mortgage Servicing
D1086-120, 12th Floor
550 South Tryon Street
Charlotte, NC 28202
1-800-326-1334
ANNUAL STATEMENT OF COMPLIANCE
Reference is hereby made to that certain Pooling and Servicing Agreement dated
as of July 1, 2012, by and among UBS Commercial Mortgage Securitization Corp., as Depositor,
Wells Fargo Bank, National Association, as Master Servicer, CW Capital Asset Management, LLC,
as Special Servicer, Pentalpha Surveillance, LLC, as Operating Advisor and U.S. Bank, National
Association as Trustee, Certificiate Administrator, Paying Agent and Custodian, with respect to
Commercial Mortgage Pass-Through Certificates Series 2012-C2 (the "Agreement"). Capitalized
terms used herein not otherwise defined shall have the meanings assigned in the Agreement.
Pursuant to Section 10.11 of this Agreement, I, Daniel Bober, Executive Vice President of
Commercial Mortgage Services do hereby certify that:
1.
A review of the activities of the Master Servicer during the period from January 1,
2014 through December 31, 2014 (the "Reporting Period"), and of its performance
per the Agreement during such period has been made under my supervision, and
2.
To the best of my knowledge, based on such review, the Master Servicer has fulfilled
all of its obligations under the Agreement in all material respects throughout the
Reporting Period.
IN WITNESS WHEREOF, the undersigned has executed this Certificate as of the 6th day of March 2015.
/s/Daniel Bober
Daniel Bober
Executive Vice President
Wells Fargo Bank
Wells Fargo Bank, N.A
CWCapital Asset Management(Logo)
7501 Wisconsin Avenue, Suite 500 West, Bethesda, MD 20814
www.cwcapital.com
Annual Statement as to Compliance
For the Period of January 1, 2014 to December 31, 2014
UBS 2012-C2
In accordance with Item 1123 of Regulation AB and with the requirements detailed in §10.11 of the
Pooling and Servicing Agreement
(the "Agreement") for
the above-mentioned CMBS pool,
(the
"CMBS Pool"), CWCapital Asset Management LLC ("CWCAM"), in its capacity as Special Servicer, is
providing this Officer's Certificate with respect to the following:
(A)
a review of CWCAM's activities during the preceding calendar year or portion thereof
(the "Reporting Period") and of CWCAM's performance under the Agreement has been
made under such officer's supervision and;
(B)
that, to the best of such officer's knowledge, based on such review, CWCAM has
fulfilled all its obligations under the Agreement in all material respects throughout the
Reporting Period.
Should you have any questions, please do not hesitate to contact us.
Sincerely,
CWCapital Asset Management LLC
/s/ David B. Iannarone
David B. Iannarone
President
U.S. Bank(Logo)
Annual Statement of Compliance
UBS-Barclays Commercial Mortgage Trust 2012-C2
VIA: EMAIL
UBS Commercial Mortgage Securitization Corp.
1285 Avenue of the Americas
New York, New York 10019
Attention: Nicholas G. Galeone
Re:
The Pooling and Servicing Agreement (the "Agreement") dated as of July 1, 2012 among UBS
Commercial Mortgage Securitization Corp., as depositor, Wells Fargo Bank, National
Association, as master servicer, CWCapital Asset Management LLC, as special servicer,
Pentalpha Surveillance LLC, as operating advisor, and U.S. Bank National Association, as
trustee, certificate administrator, paying agent and custodian
I, Nancie J. Arvin, a Senior Vice President of U.S. Bank National Association, as Certificate
Administrator hereby certify that:
(1) A review of the activities of the Certificate Administrator during the preceding calendar year
(the "Reporting Period") and of the performance of the Certificate Administrator under the Agreement
has been made under my supervision; and
(2) To the best of my knowledge, based on such review, the Certificate Administrator has fulfilled
all its obligations under the Agreement in all material respects throughout such Reporting Period.
Capitalized terms used but not defined herein have the meanings set forth in the Agreement.
Date: March 20, 2015
U.S. Bank National Association, as Certificate Administrator
By: _/s/ Nancie J. Arvin _____________
Nancie J. Arvin
Senior Vice President
Tweet
Share
E-mail
