/raid1/www/Hosts/bankrupt/TCR_Public/181202.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

              Sunday, December 2, 2018, Vol. 22, No. 335

                            Headlines

AMERICAN CREDIT 2018-4: S&P Assigns Prelim B(sf) Rating on F Notes
AMERICREDIT AUTOMOBILE 2018-3: DBRS Finalizes BB Rating on E Notes
ANTARES CLO 2018-3: S&P Assigns Prelim BB- Rating on Class E Notes
APEX CREDIT 2016: Moody's Assigns Ba3 Rating on Class E-R Notes
ARES XL: Moody's Assigns (P)Ba3 Rating on $35MM Class D-R Notes

ATLAS SENIOR VII: S&P Assigns B- Rating on $7MM Cl. F-R Notes
BAIN CAPITAL 2018-3: Moody's Gives (P)B3 Rating on $10MM F Notes
BAMLL COMMERCIAL 2014-FL1: S&P Affirms BB- Rating on 3 Tranches
BARINGS MIDDLE 2018-I: S&P Assigns BB- Rating on Class D Notes
BBCMS MORTGAGE 2018-C2: Fitch Assigns B-sf Rating on 2 Tranches

BEAR STEARNS 2003-PWR2: Fitch Affirms D Rating on Class N Certs
BEAR STEARNS 2003-PWR2: S&P Affirms BB Rating on Class L Certs
BEAR STEARNS 2007-PWR17: S&P Raises Class C Certs Rating to B+
BEAR STEARNS 2007-PWR18: Fitch Hikes Class B Certs Rating to Bsf
BLUEMOUNTAIN CLO 2012-2: S&P Rates $25.25MM E-R2 Notes 'BB'

BLUEMOUNTAIN CLO XXIII: S&P Assigns BB-(sf) Rating on Cl. E Notes
BURNHAM PARK: Moody's Assigns Ba3 Rating on Class E-R Notes
CARLYLE US 2018-4: Moody's Assigns (P)Ba3 Rating on Class D Notes
CHT 2017-COSMO: DBRS Confirms BB(high) Rating on Class F Certs
CIFC FUNDING 2018-V: Moody's Gives (P)Ba3 Rating on Class D Notes

COLT 2018-4: DBRS Finalizes B(high) Rating on Class B-2 Certs
COLT 2018-4: Fitch Assigns BBsf Rating on Class B-1 Certs
COMM 2014-UBS2: DBRS Confirms B(low) Rating on Class F Certs
COMM 2016-CCRE28: DBRS Confirms B Rating on Class X-E Certs
CREDIT SUISSE 2007-C1: Fitch Affirms Bsf Rating on 3 Tranches

CREDIT SUISSE 2007-C5: Fitch Affirms CC on $77.8MM Class A-M Certs
CRESTLINE DENALI XIV: Moody's Rates $19.5MM Class E-R Notes Ba3(sf)
CROWN POINT 6: S&P Assigns B- Rating on $5.2MM Class F Notes
DEEPHAVEN RESIDENTIAL 2018-4: S&P Gives B Rating on Cl. B-2 Notes
ELEVATION CLO 2018-10: Moody's Rates $23.5MM Class E Notes 'Ba3'

FLAGSHIP CREDIT 2016: S&P Raises Class D Notes Rating to BB+
FLAGSHIP CREDIT 2018-4: DBRS Finalizes BB Rating on Class E Notes
FLAGSHIP CREDIT 2018-4: S&P Rates $20.9MM Cl. E Notes 'BB-'
FREDDIE MAC 2018-4: DBRS Finalizes B(low) Rating on Class M Certs
GALTON FUNDING 2018-2: DBRS Finalizes B(low) Rating on Cl. B5 Certs

GS MORTGAGE 2018-FBLU: DBRS Gives Prov. B Rating on Cl. HRR Certs
INSITE WIRELESS 2018-1: Fitch Rates $22MM Class C Debt 'BB-sf'
JP MORGAN 2005-CIB11: Moody's Affirms C Rating on Class J Debt
JP MORGAN 2005-LDP5: Moody's Lowers Class H Debt Rating to Caa2
JP MORGAN 2108-MINN: Moody's Assigns (P)B3 Rating on Cl. F Certs

LB-UBS COMMERCIAL 2005-C7: Fitch Hikes Class F Certs Rating to BBsf
LCM 28: S&P Assigns BB- Rating on $15.6MM Class E Notes
MILL CITY 2018-4: DBRS Gives Prov. B(low) Rating on Class B2 Notes
MORGAN STANLEY 2013-C11: Fitch Cuts $9.6MM Class G Debt Rating to D
MORGAN STANLEY 2014-C19: DBRS Confirms B Rating on Class X-F Certs

NASSAU LTD 2018-II: Moody's Rates $30.3MM Class E Notes Ba3
NATIONAL COLLEGIATE NCT-2003: S&P Keeps CCC- Rating on 2 Tranches
NATIONSTAR HECM 2018-3: Moody's Rates Class M4 Debt 'Ba3(sf)'
NEW RESIDENTIAL 2018-5: DBRS Gives Prov. B(high) on 10 Tranches
OCTAGON INVESTMENT 28: S&P Assigns BB-(sf) Rating on Cl. E-R Notes

OCTAGON INVESTMENT 29: Moody's Rates $12MM Class F Notes B3(sf)
OCTAGON LOAN: Moody's Assigns Ba3 Rating on Class E-RR Notes
PEAKS CLO 3: S&P Assigns Prelim. BB- Rating on Class E Notes
RAMP TRUST 2005-RS9: Moody's Hikes Class A-I-4 Debt to Caa3
RCO TRUST 2018-VFS1: S&P Assigns Prelim B Rating on B-2 Notes

RFC CDO 2006-1: S&P Withdraws D Ratings on 2 Tranches
RMF BUYOUT 2018-1: Moody's Assigns Ba3 Rating on Class M4 Debt
SALOMON BROTHERS 2000-C3: Moody's Affirms C Rating on Cl. X Certs
SSB RV TRUST 2001-1: S&P Affirms CC Rating on Class C Notes
STACR TRUST 2018-HRP2: S&P Rates 3 Tranches 'B(sf)'

STARWOOD MORTGAGE 2018-IMC2: S&P Gives (P)B+ Rating on B-2 Certs
TRAINER WORTHAM V: S&P Affirms CC Rating on 2 Tranches
TREMAN PARK: Moody's Rates $6.25MM Class F-RR Notes 'B3'
WELLS FARGO 2016-C37: Fitch Affirms B-sf Rating on 2 Tranches
WFRBS COMMERCIAL 2014-C25: DBRS Confirms B Rating on Cl. F Certs

ZAIS CLO 11: Moody's Assigns (P)Ba3 Rating on $19MM Class E Notes
[*] Moody's Takes Action on $1.35BB of RMBS Issued 2005-2007
[*] Moody's Takes Action on $103.2MM RMBS Issued 1998 & 2004
[*] Moody's Takes Action on $7.25BB of RMBS Issued 2005-2007
[*] S&P Takes Various Actions on 49 Classes From 15 US RMBS Deals

[*] S&P Takes Various Actions on 77 Classes From 29 US RMBS Deals

                            *********

AMERICAN CREDIT 2018-4: S&P Assigns Prelim B(sf) Rating on F Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to American
Credit Acceptance Receivables Trust 2018-4's asset-backed notes.

The note issuance is an asset-backed securities transaction backed
by subprime auto loan receivables.

The preliminary ratings are based on information as of Nov. 29,
2018. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The availability of approximately 64.7%, 58.1%, 47.9%, 39.5%,
35.0%, and 32.2% credit support for the class A, B, C, D, E, and F
notes, respectively, based on break-even stressed cash flow
scenarios (including excess spread). These credit support levels
provide coverage of approximately 2.35x, 2.10x, 1.70x, 1.37x,
1.20x, and 1.10x S&P's 27.00%-28.00%% expected net loss range for
the class A, B, C, D, E, and F notes, respectively.

-- The timely interest and principal payments made to the
preliminary rated notes by the assumed legal final maturity dates
under S&P's stressed cash flow modeling scenarios that it believes
are appropriate for the assigned preliminary ratings.

-- S&P said, "The expectation that under a moderate ('BBB') stress
scenario, all else being equal, our ratings on the class A, B, and
C notes would not be lowered from our preliminary 'AAA (sf)', 'AA
(sf)', and 'A (sf)' ratings during the first year; the rating on
the class D notes would remain within two rating categories of our
preliminary 'BBB (sf)' rating during the first year; and the rating
on the class E and F notes would remain within two categories of
the preliminary 'BB- (sf)' and 'B (sf)' rating, respectively, in
the first year, but the E and F notes are expected to default by
their legal final maturity date with approximately 49%-80% and 0%
of principal repayment, respectively. These potential rating
movements are within the limits specified in our credit stability
criteria."

-- The collateral characteristics of the subprime automobile loans
securitized in this transaction.

-- The backup servicing arrangement with Wells Fargo Bank N.A. The
transaction's payment and credit enhancement structures.

-- The transaction's legal structure.

  PRELIMINARY RATINGS ASSIGNED

  American Credit Acceptance Receivables Trust 2018-4
  Class       Rating       Amount (mil. $)(i)
  A           AAA (sf)                  93.58
  B           AA (sf)                   28.05
  C           A (sf)                    43.35
  D           BBB (sf)                  36.21
  E           BB- (sf)                  17.85
  F           B (sf)                    14.03

(i)The actual size of these tranches will be determined on the
pricing date.


AMERICREDIT AUTOMOBILE 2018-3: DBRS Finalizes BB Rating on E Notes
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of notes issued by AmeriCredit Automobile Receivables Trust
2018-3 (AMCAR 2018-3):

-- $161,000,000 of Class A-1 at R-1 (high) (sf)
-- $240,000,000 of Class A-2-A at AAA (sf)*
-- $65,000,000 of Class A-2-B at AAA (sf)*
-- $261,450,000 of Class A-3 at AAA (sf)
-- $78,950,000 of Class B at AA (sf)
-- $98,010,000 of Class C at A (sf)
-- $96,380,000 of Class D at BBB (sf)
-- $25,590,000 of Class E at BB (sf)

The total Class A-2 size is $305,000,000, split between Classes
A-2-A and A-2-B. Class A-2-B is floating rate.

The ratings are based on DBRS's review of the following analytical
considerations:

-- Transaction capital structure, proposed ratings and form and
sufficiency of available credit enhancement.

-- The ability of the transaction to withstand stressed cash flow
assumptions and repay investors according to the terms under which
they have invested. For this transaction, the ratings address the
timely payment of interest on a monthly basis and principal by the
legal final maturity date.

-- AmeriCredit's capabilities with regard to originations,
underwriting and servicing and ownership by General Motors
Company.

-- The credit quality of the collateral and performance of
AmeriCredit's auto loan portfolio.

-- The legal structure and presence of legal opinions that will
address the true sale of the assets to the Issuer, the
non-consolidation of the special-purpose vehicle with AmeriCredit,
and that the Trust has a valid first-priority security interest in
the assets and the consistency with DBRS's "Legal Criteria for U.S.
Structured Finance" methodology.

The receivables securitized in AMCAR 2018-3 will be subprime auto
loan contracts secured by new and used automobiles, light-duty
trucks and vans.

This transaction is being structured as a public transaction
offering four classes of notes: Class A (split into three
sequential tranches — Classes A-1, A-2 and A-3), Class B, Class C
and Class D. The Class E Notes are not being publicly offered and
will initially be retained by the Depositor or an affiliate
thereof. Initial Class A credit enhancement of 35.20% will include
a reserve account (2.00% of the initial pool balance, funded at
inception and non-declining), overcollateralization (OC) of 5.75%
and subordination of 27.45% of the initial pool balance. Initial
Class B enhancement of 27.95% will include a 2.00% reserve account,
5.75% OC and 20.20% subordination. Initial Class C enhancement of
18.95% will include OC of 5.75%, subordination of 11.20% and a
reserve account of 2.00%. Initial Class D enhancement of 10.10%
will include OC of 5.75%, subordination of 2.35% and a reserve
account of 2.00%. OC will build to a target of 14.75% of the pool
balance, less the amount on deposit in the reserve account, based
on excess spread available in the structure and will be subject to
a floor of 0.50% of the initial pool balance.


ANTARES CLO 2018-3: S&P Assigns Prelim BB- Rating on Class E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Antares CLO
2018-3 Ltd./Antares CLO 2018-3 LLC's floating-rate notes.

The note issuance is a collateralized loan obligation (CLO)
transaction backed by primarily middle-market speculative-grade
(rated 'BB+' and lower) senior secured term loans that are governed
by collateral quality tests.

The preliminary ratings are based on information as of Nov. 20,
2018. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The diversified collateral pool;

-- The credit enhancement provided through the subordination of
cash flows, excess spread, and overcollateralization;

-- The collateral manager's experienced team, which can affect the
performance of the rated notes through collateral selection,
ongoing portfolio management, and trading; and

-- The transaction's legal structure, which is expected to be
bankruptcy remote.

  PRELIMINARY RATINGS ASSIGNED

  Antares CLO 2018-3 Ltd./Antares CLO 2018-3 LLC

  Class                Rating    Amount (mil. $)
  A1                   AAA (sf)           575.00
  A2                   NR                  20.00
  B                    AA (sf)             95.00
  C (deferrable)       A (sf)              74.30
  D (deferrable)       BBB- (sf)           61.40
  E (deferrable)       BB- (sf)            59.00
  Subordinated notes   NR                 122.90

  NR--Not rated.


APEX CREDIT 2016: Moody's Assigns Ba3 Rating on Class E-R Notes
---------------------------------------------------------------
Moody's Investors Service has assigned ratings to seven classes of
CLO refinancing notes issued by Apex Credit CLO 2016 Ltd.:

Moody's rating action is as follows:

US$15,000,000 Class A-1-R Senior Secured Floating Rate Notes Due
2028 (the "Class A-1-R Notes"), Assigned Aaa (sf)

US$232,000,000 Class A-S-R Senior Secured Floating Rate Notes Due
2028 (the "Class A-S-R Notes"), Assigned Aaa (sf)

US$40,000,000 Class B-1-R Senior Secured Floating Rate Notes Due
2028 (the "Class B-1-R Notes"), Assigned Aa1 (sf)

US$10,000,000 Class B-F-R Senior Secured Fixed Rate Notes Due 2028
(the "Class B-F-R Notes"), Assigned Aa1 (sf)

US$27,000,000 Class C-R Secured Deferrable Floating Rate Notes Due
2028 (the "Class C-R Notes"), Assigned A2 (sf)

US$24,000,000 Class D-R Secured Deferrable Floating Rate Notes Due
2028 (the "Class D-R Notes"), Assigned Baa3 (sf)

US$20,000,000 Class E-R Secured Deferrable Floating Rate Notes Due
2028 (the "Class E-R Notes"), Assigned Ba3 (sf)

The Issuer is a managed cash flow collateralized loan obligation.
The issued notes are collateralized primarily by a portfolio of
broadly syndicated senior secured corporate loans.

Apex Credit Partners LLC manages the CLO. It directs the selection,
acquisition, and disposition of collateral on behalf of the Issuer.


RATINGS RATIONALE

The ratings reflect the risks due to defaults on the underlying
portfolio of assets, the transaction's legal structure, and the
characteristics of the underlying assets.

The Issuer has issued the Refinancing Notes on November 27, 2018 in
connection with the refinancing of all classes of the secured notes
and the senior subordinated notes previously issued on August 10,
2016. On the Refinancing Date, the Issuer used proceeds from the
issuance of the Refinancing Notes, along with the proceeds from the
issuance of senior-R subordinated notes, to redeem in full the
Refinanced Original Notes. The junior subordinated notes are not
being refinanced.

In addition to the issuance of the Refinancing Notes and senior-R
subordinated notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: the extension of the reinvestment period; extensions of
the stated maturity and non-call period; changes to certain
collateral quality tests; and changes to the overcollateralization
test levels.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. For modeling
purposes, Moody's used the following base-case assumptions:

Performing par and principal proceeds balance: $400,000,000

Diversity Score: 80

Weighted Average Rating Factor (WARF): 2759

Weighted Average Spread (WAS): 3.70%

Weighted Average Coupon (WAC): 6.50%

Weighted Average Recovery Rate (WARR): 46%

Weighted Average Life (WAL): 6.5 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Ratings for Apex Credit CLO 2016 Ltd. were assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Ratings on Apex Credit CLO 2016 Ltd. Please refer
to Moody's Request for Comment, titled "Proposed Update to Moody's
Global Approach to Rating Collateralized Loan Obligations," for
further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Refinancing Notes is subject to uncertainty.
The performance of the Refinancing Notes is sensitive to the
performance of the underlying portfolio, which in turn depends on
economic and credit conditions that may change. The Manager's
investment decisions and management of the transaction will also
affect the performance of the Refinancing Notes.


ARES XL: Moody's Assigns (P)Ba3 Rating on $35MM Class D-R Notes
---------------------------------------------------------------
Moody's Investors Service has assigned the following provisional
ratings to seven classes of CLO refinancing notes to be issued by
Ares XL CLO Ltd.:

Moody's rating action is as follows:

US$4,650,000 Class X Senior Floating Rate Notes Due 2029 (the
"Class X Notes"), Assigned (P)Aaa (sf)

US$424,900,000 Class A-1-R Senior Floating Rate Notes Due 2029 (the
"Class A-1-R Notes"), Assigned (P)Aaa (sf)

US$80,500,000 Class A-3-R Senior Floating Rate Notes Due 2029 (the
"Class A-3-R Notes"), Assigned (P)Aa2 (sf)

US$37,100,000 Class B-R Mezzanine Deferrable Floating Rate Notes
Due 2029 (the "Class B-R Notes"), Assigned (P)A2 (sf)

US$39,900,000 Class C-R Mezzanine Deferrable Floating Rate Notes
Due 2029 (the "Class C-R Notes"), Assigned (P)Baa3 (sf)

US$35,000,000 Class D-R Mezzanine Deferrable Floating Rate Notes
Due 2029 (the "Class D-R Notes"), Assigned (P)Ba3 (sf)

US$10,150,000 Class E-R Mezzanine Deferrable Floating Rate Notes
Due 2029 (the "Class E-R Notes"), Assigned (P)B3 (sf)

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions. Upon a conclusive review of a
transaction and associated documentation, Moody's will endeavor to
assign definitive ratings. A definitive rating, if any, may differ
from a provisional rating.

The Issuer is a managed cash flow collateralized loan obligation
(CLO). The issued notes are collateralized primarily by a portfolio
of broadly syndicated senior secured corporate loans.

Ares CLO Management LLC manages the CLO. It directs the selection,
acquisition, and disposition of collateral on behalf of the Issuer.


RATINGS RATIONALE

The provisional ratings reflect the risks due to defaults on the
underlying portfolio of assets, the transaction's legal structure,
and the characteristics of the underlying assets.

The Issuer intends to issue the Refinancing Notes on December 13,
2018 in connection with the refinancing of all classes of the
secured notes previously issued on October 18, 2016. On the
Refinancing Date, the Issuer will use proceeds from the issuance of
the Refinancing Notes, along with the proceeds from the issuance of
one other class of secured notes, to redeem in full the Refinanced
Original Notes. On the Original Closing Date, the issuer also
issued one class of subordinated notes that will remain
outstanding.

In addition to the issuance of the Refinancing Notes and the other
classes of secured notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: extension of the reinvestment period; extensions of the
stated maturity and non-call period; changes to certain collateral
quality tests and changes to the overcollateralization test levels.


Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. For modeling
purposes, Moody's used the following base-case assumptions:

Performing par and principal proceeds balance: $699,767,568

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2900

Weighted Average Spread (WAS): 3.20%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 48%

Weighted Average Life (WAL): 7.25 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Ratings for Ares XL CLO Ltd. were assigned in accordance
with Moody's existing Methodology entitled "Moody's Global Approach
to Rating Collateralized Loan Obligations," dated August 31, 2017.
Please note that on November 14, 2018, Moody's released a Request
for Comment, in which it has requested market feedback on potential
revisions to its Methodology for Collateralized Loan Obligations.
If the revised Methodology is implemented as proposed, Moody's does
not expect the changes to affect the Credit Ratings on Ares XL CLO
Ltd. Please refer to Moody's Request for Comment, titled "Proposed
Update to Moody's Global Approach to Rating Collateralized Loan
Obligations," for further details regarding the implications of the
proposed Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Refinancing Notes is subject to uncertainty.
The performance of the Refinancing Notes is sensitive to the
performance of the underlying portfolio, which in turn depends on
economic and credit conditions that may change. The Manager's
investment decisions and management of the transaction will also
affect the performance of the Refinancing Notes.


ATLAS SENIOR VII: S&P Assigns B- Rating on $7MM Cl. F-R Notes
-------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the
replacement class X-R, A-1-R, B-1-R, B-2-R, C-R, D-R, E-R, and F-R
notes from Atlas Senior Loan Fund VII Ltd., a collateralized loan
obligation (CLO) originally issued in November 2016 and managed by
Crescent Capital Group L.P. The replacement notes will be issued
via a proposed supplemental indenture. This is a proposed reset of
the November 2016 transaction.

The preliminary ratings reflect S&P's opinion that the credit
support available is commensurate with the associated rating
levels. Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

The preliminary ratings are based on information as of Nov. 29,
2018. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Nov. 30, 2018, refinancing date, the proceeds from the
issuance of the replacement notes are expected to redeem the
original notes. S&P said, "At that time, we anticipate withdrawing
the ratings on the original notes and assigning ratings to the
replacement notes. However, if the refinancing doesn't occur, we
may affirm the ratings on the original notes and withdraw our
preliminary ratings on the replacement notes."

The replacement notes are being issued via a proposed supplemental
indenture, which, in addition to outlining the terms of the
replacement notes, will also:

-- Issue the replacement class X-R, B-1-R, D-R, and E-R notes at  
lower spreads than the original notes.

-- Issue the replacement class B-2-R notes at a higher spread than
the original notes.

-- Replace the original floating-rate class A notes with the new
floating-rate class A-1-R and A-2-R notes.

-- Replace the original floating-rate class C-1 notes and
fixed-rate class C-2 notes with the new floating-rate class C-R
notes.

-- Issue new class F-R notes at a floating rate.

-- Extend the legal final maturity by three years to November
2031.

-- Extend the reinvestment period by three years to November
2023.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction as reflected in
the trustee report, to estimate future performance. In line with
our criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults, and
recoveries upon default, under various interest rate and
macroeconomic scenarios. In addition, our analysis considered the
transaction's ability to pay timely interest or ultimate principal,
or both, to each of the rated tranches. Updated S&P recoveries and
industry categories were used.

"We will continue to review whether, in our view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them, and we will take further rating actions
as we deem necessary."

  PRELIMINARY RATINGS ASSIGNED
  Atlas Senior Loan Fund VII Ltd./Atlas Senior Loan Fund VII LLC

  Class                 Rating         Amount mil. $)
  X-R                   AAA (sf)                 1.50
  A-1-R                 AAA (sf)               244.00
  A-2-R                 NR                      20.00
  B-1-R                 AA (sf)                 18.00
  B-2-R                 AA (sf)                 15.00
  C-R (deferrable)      A (sf)                  31.00
  D-R (deferrable)      BBB- (sf)               20.00
  E-R (deferrable)      BB- (sf)                17.00
  F-R (deferrable)      B- (sf)                  7.00
  Subordinated notes    NR                      42.50

  NR--Not rated.


BAIN CAPITAL 2018-3: Moody's Gives (P)B3 Rating on $10MM F Notes
----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to six
classes of notes to be issued by Bain Capital Credit CLO 2018-3,
Limited.

Moody's rating action is as follows:

US$320,000,000 Class A Senior Secured Floating Rate Notes due 2031
(the "Class A Notes"), Assigned (P)Aaa (sf)

US$59,000,000 Class B Senior Secured Floating Rate Notes due 2031
(the "Class B Notes"), Assigned (P)Aa2 (sf)

US$23,500,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2031 (the "Class C Notes"), Assigned (P)A2 (sf)

US$30,000,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2031 (the "Class D Notes"), Assigned (P)Baa3 (sf)

US$27,500,000 Class E Senior Secured Deferrable Floating Rate Notes
due 2031 (the "Class E Notes"), Assigned (P)Ba3 (sf)

US$10,000,000 Class F Senior Secured Deferrable Floating Rate Notes
due 2031 (the "Class F Notes"), Assigned (P)B3 (sf)

The Class A Notes, the Class B Notes, the Class C Notes, the Class
D Notes, the Class E Notes, and the Class F Notes are referred to
herein, collectively, as the "Rated Notes."

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions. Upon a conclusive review of a
transaction and associated documentation, Moody's will endeavor to
assign definitive ratings. A definitive rating, if any, may differ
from a provisional rating.

RATINGS RATIONALE

The provisional ratings reflect the risks due to defaults on the
underlying portfolio of assets, the transaction's legal structure,
and the characteristics of the underlying assets.

Bain Capital Credit CLO 2018-3 is a managed cash flow CLO. The
issued notes will be collateralized primarily by broadly syndicated
senior secured corporate loans. At least 90.0% of the portfolio
must consist of senior secured loans and eligible investments, and
up to 10.0% of the portfolio may consist of second lien loans and
senior unsecured loans. Moody's expects the portfolio to be
approximately 75% ramped as of the closing date.

Bain Capital Credit U.S. CLO Manager, LLC will direct the
selection, acquisition and disposition of the assets on behalf of
the Issuer and may engage in trading activity, including
discretionary trading, during the transaction's five year
reinvestment period. Thereafter, the Manager may reinvest
unscheduled principal payments and proceeds from sales of credit
risk assets, subject to certain restrictions.

In addition to the Rated Notes, the Issuer will issue subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $500,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2885

Weighted Average Spread (WAS): 3.33%

Weighted Average Coupon (WAC): 6.0%

Weighted Average Recovery Rate (WARR): 47.75%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Ratings for Bain Capital Credit CLO 2018-3, Limited were
assigned in accordance with Moody's existing Methodology entitled
"Moody's Global Approach to Rating Collateralized Loan Obligations"
dated August 31, 2017. Please note that on November 14, 2018,
Moody's released a Request for Comment, in which it has requested
market feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on Bain Capital Credit CLO 2018-3,
Limited. Please refer to Moody's Request for Comment, titled
"Proposed Update to Moody's Global Approach to Rating
Collateralized Loan Obligations," for further details regarding the
implications of the proposed Methodology revisions on certain
Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.


BAMLL COMMERCIAL 2014-FL1: S&P Affirms BB- Rating on 3 Tranches
---------------------------------------------------------------
S&P Global Ratings raised its ratings on the class B and C
commercial mortgage pass-through certificates from BAMLL Commercial
Mortgage Securities Trust 2014-FL1, a U.S. commercial
mortgage-backed securities (CMBS) transaction. In addition, S&P
affirmed its ratings on five other classes from the same
transaction.

For these classes, S&P's expectation of credit enhancement was
generally in line with the affirmed or raised rating levels. The
upgrades also reflect the reduced pool trust balance.

While available credit enhancement levels suggest further upward
rating movements on classes B and C, our analysis also considered
the transaction's significant exposure to a mortgage loan secured
by retail property ($235.0 million, 72.2%) and its susceptibility
to refinancing risk.

S&P said, "The affirmed 'BB- (sf)' rating on the PGA raked
certificates reflects our re-evaluation of the PGA National Resort
& Spa loan. The PGA raked certificates derive 100% of their cash
flow from a subordinate non-pooled component of this loan.

"The affirmation on the class X-EXT interest-only (IO) certificates
is based on our criteria for rating IO securities, in which the
ratings on the IO securities would not be higher than that of the
lowest-rated reference class. The notional balance on class X-EXT
references classes A, B, C, D, and E.

"This is a large-loan transaction backed by two floating-rate IO
mortgage loans. Our property-level analysis included a
re-evaluation of the two remaining loans in the pool, secured by
retail and lodging properties (details below on the remaining
loans)."

As of the Oct. 17, 2018, trustee remittance report, the trust
consisted of two floating-rate loans indexed to one-month LIBOR
with an aggregate pooled trust balance of $325.6 million and an
aggregate trust balance of $331.0 million, down from four loans
totaling $432.6 million at issuance. The pooled trust has incurred
no principal losses to date.

Details on the two remaining assets are as follows:

-- The Lynnhaven Mall loan is the largest loan remaining in the
pool with a loan balance of $235.0 million. The mortgage loan is
IO, pays a floating-rate interest rate of LIBOR plus 1.85% per
year, and is secured by 972,616 sq. ft. of a 1,154,949-sq.-ft.
enclosed regional mall in Virginia Beach, Va. The borrower
exercised the final extension option, and the loan will mature in
June 2019. The servicer, Wells Fargo Bank N.A. (Wells Fargo),
reported a 95.3% occupancy and 2.88x debt service coverage (DSC)
ratio as of June 30, 2018. S&P's expected-case valuation, using a
7.25% S&P Global Ratings capitalization rate, yielded an in-trust
83.0% S&P Global Ratings loan-to-value (LTV) ratio.

-- The PGA National Resort & Spa loan is the smallest loan
remaining in the pool. The loan has a trust and whole loan balance
of $96.0 million, which is divided into a $90.6 million senior
pooled component that makes up 27.8% of the pooled trust balance
and a $5.4 million subordinate nonpooled component that supports
the PGA raked certificates. The borrower exercised the final
extension option, and the loan will mature in September 2019. In
addition, there is $44.0 million in mezzanine debt. The mortgage
loan is IO, pays a floating-rate interest rate of LIBOR plus 1.775%
(pooled) and 4.761% (nonpooled) per year, and is secured by a
339-room, AAA-four-diamond-rated, full-service resort hotel in Palm
Beach Gardens, Fla. Wells Fargo reported a 71.3% occupancy, $199.20
average daily rate, and $142.08 revenue per available room as of
Dec. 31, 2017. S&P's expected case valuation, using a 9.64% S&P
Global Ratings weighted average capitalization rate, yielded an
in-trust 71.3% S&P Global Ratings LTV ratio.

  RATINGS RAISED

  BAMLL Commercial Mortgage Securities Trust 2014-FL1
  Commercial mortgage pass-through certificates series 2014-FL1
                  Rating
  Class       To              From
  B           AA (sf)         AA- (sf)
  C           A (sf)          A- (sf)

  RATINGS AFFIRMED
  BAMLL Commercial Mortgage Securities Trust 2014-FL1
  Commercial mortgage pass-through certificates series 2014-FL1

  Class       Rating
  A           AAA (sf)
  D           BBB- (sf)
  E           BB- (sf)
  PGA         BB- (sf)
  X-EXT       BB- (sf)


BARINGS MIDDLE 2018-I: S&P Assigns BB- Rating on Class D Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to Barings Middle Market
CLO Ltd. 2018-I's floating-rate notes.

The note issuance is a collateralized loan obligation transaction
backed primarily by middle-market speculative-grade (rated 'BB+'
and lower) senior secured term loans that are governed by
collateral quality tests.

The ratings reflect:

-- The diversified collateral pool.

-- The credit enhancement provided through the subordination of
cash flows, excess spread, and overcollateralization.

-- The collateral manager's experienced team, which can affect the
performance of the rated notes through collateral selection,
ongoing portfolio management, and trading.

-- The transaction's legal structure, which is expected to be
bankruptcy remote.

  RATINGS ASSIGNED

  Barings Middle Market CLO Ltd. 2018-I/Barings Middle Market CLO
  2018-I LLC

  Class                 Rating       Amount (mil. $)
  A-1                   AAA (sf)              226.00
  A-2                   AA (sf)                40.20
  B (deferrable)        A- (sf)                37.80
  C (deferrable)        BBB- (sf)              20.10
  D (deferrable)        BB- (sf)               28.00
  Subordinated notes    NR                     50.40

  NR--Not rated.


BBCMS MORTGAGE 2018-C2: Fitch Assigns B-sf Rating on 2 Tranches
---------------------------------------------------------------
Fitch Ratings has issued a presale report on BBCMS Mortgage Trust
2018-C2 Commercial Mortgage Pass-Through Certificates, Series
2018-C2.

Fitch expects to rate the transaction and assign Rating Outlooks as
follows:

  -- $12,286,000 class A-1 'AAAsf'; Outlook Stable;

  -- $10,000,000 class A-2 'AAAsf'; Outlook Stable;

  -- $29,000,000 class A-3 'AAAsf'; Outlook Stable;

  -- $170,000,000a class A-4 'AAAsf'; Outlook Stable;

  -- $346,100,000a class A-5 'AAAsf'; Outlook Stable;

  -- $33,000,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $600,386,000b class X-A 'AAAsf'; Outlook Stable;

  -- $157,601,000b class X-B 'A-sf'; Outlook Stable;

  -- $81,481,000 class A-S 'AAAsf'; Outlook Stable;

  -- $38,596,000 class B 'AA-sf'; Outlook Stable;

  -- $37,524,000 class C 'A-sf'; Outlook Stable;

  -- $41,812,000bc class X-D 'BBB-sf'; Outlook Stable;

  -- $19,298,000bc class X-F 'BB-sf'; Outlook Stable;

  -- $8,576,000bc class X-G 'B-sf'; Outlook Stable;

  -- $23,586,000c class D 'BBBsf'; Outlook Stable;

  -- $18,226,000c class E 'BBB-sf'; Outlook Stable;

  -- $19,298,000c class F 'BB-sf'; Outlook Stable;

  -- $8,576,000c class G 'B-sf'; Outlook Stable.

The following classes are not expected to be rated by Fitch:

  -- $7,504,000cd class H-RR;

  -- $22,514,000cd class J-RR;

  -- $34,162,554ce VRR Interest.

(a) The initial certificate balances of class A-4 and class A-5 are
unknown and expected to be $516,100,000 in aggregate plus or minus
5%. The certificate balances will be determined based on the final
pricing of those classes of certificates. The expected class A-4
balance range is $100,000,000 to $240,000,000 and the expected
class A-5 balance range is $276,100,000 to $416,100,000. Fitch's
certificate balances for classes A-4 and A-5 are assumed at the
midpoint of the range for each class.

(b) Notional amount and interest only.

(c) Privately placed and pursuant to Rule 144A.

(d) Horizontal credit-risk retention interest.

(e) Vertical credit-risk retention interest, which represents
approximately 3.83% of the certificate balance, notional amount or
percentage interest of each class of certificates.

The expected ratings are based on information provided by the
issuer as of Nov. 26 2018.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 44 loans secured by 87
commercial properties having an aggregate principal balance of
$891,853,554 as of the cut-off date. The loans were contributed to
the trust by Starwood Mortgage Capital LLC, Barclays Bank PLC,
Cantor Commercial Real Estate Lending, L.P. and KeyBank National
Association.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 73.1% of the properties
by balance, cash flow analysis of 85.9%, and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Average Fitch Leverage Relative to Recent Transactions: The pool's
Fitch DSCR of 1.19x is slightly lower than the YTD 2018 and 2017
averages of 1.23x and 1.26x, respectively. However, the pool's
Fitch LTV of 101.4% is better than the YTD 2018 LTV of 101.9% and
in-line with the 2017 average of 101.6%. Excluding investment-grade
credit opinion loans, the pool has a Fitch DSCR and LTV of 1.16x
and 107.0%, respectively.

Investment-Grade Credit Opinion Loans: Four loans, representing
12.6% of the pool, have an investment-grade credit opinion. This is
below the YTD 2018 average of 14.0%, but above the 2017 average of
11.7%. Christiana Mall (6.1% of the pool) received a credit opinion
of 'AA-sf'* on a stand-alone basis. Moffett Towers - Building E, F,
G (2.8%), Moffett Towers II - Building I (2.5%) and Fair Oaks Mall
(1.2%) each received stand-alone credit opinions of 'BBB-sf'*.

Weak Pool Amortization: There are 19 loans (36.2% of the pool) that
are partial interest-only, 17 loans are full interest-only (50.9%),
and eight loans (12.9%) are amortizing balloon loans. Based on the
scheduled balance at maturity, the pool will pay down by 5.8%,
which is below the YTD 2018 and 2017 averages of 7.3% and 7.9%,
respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 13.0% below
the most recent year's net operating income (NOI) for properties
for which a full-year NOI was provided, excluding properties that
were stabilizing during this period. Unanticipated further declines
in property-level NCF could result in higher defaults and loss
severities on defaulted loans and in potential rating actions on
the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the
BBCMS 2018-C2 certificates and found that the transaction displays
average sensitivities to further declines in NCF. In a scenario in
which NCF declined a further 20% from Fitch's NCF, a downgrade of
the junior 'AAAsf' certificates to 'BBB+sf' could result. In a more
severe scenario, in which NCF declined a further 30% from Fitch's
NCF, a downgrade of the junior 'AAAsf' certificates to 'BBB-sf'
could result.


BEAR STEARNS 2003-PWR2: Fitch Affirms D Rating on Class N Certs
---------------------------------------------------------------
Fitch Ratings has upgraded one and affirmed five classes of Bear
Stearns Commercial Mortgage Securities Trust, commercial mortgage
pass-through certificates, series 2003-PWR2.

KEY RATING DRIVERS

Increased Credit Enhancement: The upgrade of class M reflects
increased credit enhancement since Fitch's last rating action due
to five loan payoffs and one loan liquidation at a small loss. As
of the November 2018 remittance reporting, the pool's aggregate
principal balance has been reduced by 97.5% to $26.5 million from
$1.1 billion at issuance. Realized losses to date totaled $12
million (1.1% of the original pool balance). Credit enhancement
will continue to improve as the remaining loan is fully amortizing
and matures in October 2021.

3 Times Square; Low Leverage and High Property Quality: The
remaining loan in the pool, 3 Times Square, is secured by an
883,405 square foot, 30-story office building located in
Manhattan's Times Square, also known as the Reuters Building. The
loan is low leveraged and has a loan per square foot of $30 as of
the November 2018 distribution date. As of June 2018, the property
was 99.2% occupied and the servicer-reported year-to-date net
operating income debt service coverage ratio was 1.69x. Major
tenants at the property include Thomson Reuters (78.0% of NRA,
lease expiry in November 2021), BMO Harris Bank (17.6%; November
2021; tenant is subleasing space from Bain & Co.) and JPMorgan
Chase (1.9%; November 2021). There is limited upcoming roll as the
majority of the in-place leases expire in 2021.

Concentrated Pool: The rating of class M was capped at 'Asf' due to
pool concentration as only one loan remains in the pool. Cumulative
interest shortfalls are affecting classes M through P.

RATING SENSITIVITIES

Further rating changes are not expected as only one fully
amortizing, low leveraged loan remains in the pool.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

No third party due diligence was provided or reviewed by Fitch in
relation to this rating.

Fitch has upgraded the following ratings:

  -- $5.3 million class M to 'Asf' from 'BBBsf'; Outlook Stable.

In addition, Fitch has affirmed the following ratings:

  -- $3.9 million class H at 'AAAsf'; Outlook Stable;

  -- $5.3 million class J at 'AAAsf'; Outlook Stable;

  -- $5.3 million class K at 'AAAsf'; Outlook Stable;

  -- $4.0 million class L at 'AAAsf'; Outlook Stable;

  -- $2.6 million class N at 'Dsf'; RE 90%.

The class A-1, A-2, A-3, A-4, B, C, D, E, F and G certificates have
paid in full. Fitch does not rate the class P certificates. Fitch
previously withdrew the ratings on the interest-only class X-1 and
X-2 certificates.


BEAR STEARNS 2003-PWR2: S&P Affirms BB Rating on Class L Certs
--------------------------------------------------------------
S&P Global Ratings raised its ratings on three classes of
commercial mortgage pass-through certificates from Bear Stearns
Commercial Mortgage Securities Trust 2003-PWR2, a U.S. commercial
mortgage-backed securities (CMBS) transaction. In addition, S&P
affirmed its ratings on two other classes from the same
transaction.

S&P said, "For the upgrades and affirmations, our expectation of
credit enhancement was generally in line with the raised or
affirmed rating levels. The upgrades also reflect the trust
balance's significant reduction as well as our credit view on the
sole remaining 3 Times Square loan, for which we calculated a 2.00x
S&P Global Ratings debt service coverage and 8.7% S&P Global
Ratings loan-to-value ratio using a 6.50% S&P Global Ratings
capitalization rate."

While available credit enhancement suggests positive rating
movements on classes L and M, our analysis also considered the
recent interest shortfalls reported on the classes and the
possibility that such action may cause liquidity interruptions to
these classes. According to the Nov. 13, 2018, trustee remittance
report, the current monthly interest shortfalls totaled $14,918
and, per the master servicer, are related primarily to an
approximately $50,000 holdback last month for potential expenses
incurred by the trust as it winds down.

The current interest shortfalls affected classes subordinate to and
including class M.

TRANSACTION SUMMARY

As of the Nov. 13, 2018, trustee remittance report, the sole
remaining loan in the trust is 3 Time Square ($26.5 million, 2.5%),
down from 100 loans at issuance. The loan is not with the special
servicer, defeased, or on the master servicer's watchlist. To date,
the transaction has experienced $12.0 million in principal losses,
or 1.1% of the original pool trust balance.

  RATINGS RAISED

  Bear Stearns Commercial Mortgage Securities Trust 2003-PWR2
  Commercial mortgage pass-through certificates
                Rating
  Class     To          From
  H         AAA (sf)    AA- (sf)
  J         AA+ (sf)    A (sf)
  K         AA (sf)     BBB (sf)

  RATINGS AFFIRMED

  Bear Stearns Commercial Mortgage Securities Trust 2003-PWR2   
  Commercial mortgage pass-through certificates

  Class     Rating
  L         BB (sf)
  M         B- (sf)


BEAR STEARNS 2007-PWR17: S&P Raises Class C Certs Rating to B+
--------------------------------------------------------------
S&P Global Ratings raised its rating to 'B+ (sf)' from 'B- (sf)' on
the class C commercial mortgage pass-through certificates from Bear
Stearns Commercial Mortgage Securities Trust 2007-PWR17, a U.S.
commercial mortgage-backed securities (CMBS) transaction.

S&P said, "The upgrade reflects our expectation of credit
enhancement that was in line with the raised rating level, as well
as the significant reduction in trust balance. While the available
credit enhancement level suggests further positive rating movement
on class C, our analysis also considered the magnitude of six
assets with the special servicer ($69.1 million, 76.8%) and
susceptibility to reduced liquidity support from these specially
serviced assets."

TRANSACTION SUMMARY     

As of the Nov. 14, 2018, trustee remittance report, the collateral
pool balance was $90.0 million, which is 2.8% of the pool balance
at issuance. The pool currently includes eight loans and four real
estate-owned (REO) assets, down from 264 loans at issuance. Six of
these assets are with the special servicer, five ($18.0 million,
20.0%) are on the master servicers' combined watchlist, and no
loans are defeased.

S&P said, "Excluding the six specially serviced assets, we
calculated a 1.25x S&P Global Ratings weighted average debt service
coverage (DSC) and 81.1% S&P Global Ratings weighted average
loan-to-value ratio using an 8.03% S&P Global Ratings weighted
average capitalization rate for the six performing loans, each of
which are 100% leased to Rite Aid Corporation ('B/Negative').
Details on the two largest specially serviced assets are below.

"To date, the transaction has experienced $263.9 million in
principal losses, or 8.1% of the original pool trust balance. We
expect losses to reach approximately 9.0% of the original pool
trust balance in the near term, based on losses incurred to date
and additional losses we expect upon the eventual resolution of the
six specially serviced assets."

CREDIT CONSIDERATIONS

As of the Nov. 14, 2018, trustee remittance report, six assets in
the pool were with the special servicer, C-III Asset Management LLC
(C-III). Details of the two largest specially serviced assets are
as follows:

-- The City Center Englewood REO asset ($33.0 million, 36.7%) is
the largest asset in the pool and has a total reported exposure of
$34.1 million. The asset is a 218,076-sq.-ft. retail property,
built in 2001, and located in Englewood, Colo. The loan was
transferred to the special servicer on June 13, 2017. The property
became REO on Aug. 8, 2018. An appraisal reduction amount of $8.3
million is in effect against the asset. No recent reported
performance data was available on the asset. S&P expects a moderate
loss upon this asset's eventual resolution.     

-- The Montlimar Place REO asset ($13.4 million, 14.9%) is the
second-largest asset in the pool and has a total reported exposure
of $17.6 million. The asset is a 173,204-sq.-ft. office property,
built in 1984, and located in Mobile, Ala. The loan was transferred
to the special servicer on Jan. 18, 2013. The property became REO
on August 25, 2014. The master servicer has deemed the asset
nonrecoverable. C-III stated that the property is currently 82.0%
occupied. S&P expects a moderate loss upon this asset's eventual
resolution.      

The four remaining assets with the special servicer each have
individual balances that represent less than 9.1% of the total pool
trust balance. S&P estimated losses for the six specially serviced
assets, arriving at a weighted-average loss severity of 40.5%.

With respect to the specially serviced assets noted above, a
minimal loss is less than 25%, a moderate loss is 26%-59%, and a
significant loss is 60% or greater.


BEAR STEARNS 2007-PWR18: Fitch Hikes Class B Certs Rating to Bsf
----------------------------------------------------------------
Fitch Ratings has upgraded two and affirmed 13 classes of Bear
Stearns Commercial Mortgage Securities Trust, commercial mortgage
pass-through certificates, series 2007-PWR18.

KEY RATING DRIVERS

Increased Credit Enhancement: The upgrade of class B and C reflects
increased credit enhancement from loan repayments since Fitch's
last rating action. As of the November 2018 distribution date, the
pool's aggregate principal balance has been reduced by 97.2% to
$69.9 million from $2.5 billion at issuance. Since the last rating
action, 17 loans totaling $151 million (65% of the last rating
action pool balance) paid in full.

The affirmation of class D reflects minimal credit enhancement to
the class. Realized losses to date totaled 8.5% of the original
pool balance. Interest shortfalls totaling $10.1 million are
currently affecting classes C through S.

Ratings Capped: The ratings of class B and C were capped at 'Bsf'
and 'CCCsf', respectively, to reflect only one specially serviced
loan, Marriott Houston Westchase, remaining in the pool. The loan
is secured by a 604-key, Marriott-flagged, full-service hotel
located in Houston, TX, approximately 10 miles west of the CBD.

The loan per key relative to the outstanding balance of class B is
low at $38,543; for class C and D, the loan per key is $80,011 and
$111,114, respectively. Fitch has ongoing concerns about the
overall recovery of the Houston market, continued volatility in oil
prices and anticipated new supply, which may affect future loan
performance. The current hotel construction pipeline in Houston
exceeds 17% of the existing supply of available rooms, which may
put additional pressure on RevPAR sustainability.

Improved Loss Expectations: In June 2018, the property was
purchased and the loan was modified and assumed by a new borrower,
which paid down 2.5% of the outstanding loan balance at closing and
repaid past-due franchising fees and trade payables. The new
borrower will be required to pay down the loan by an additional
2.5% on or by Dec. 31, 2019. Debt service payments were also
converted to interest-only through the extended June 2021 maturity.


As of the TTM May 2018 STR report, the property reported occupancy,
ADR and RevPAR of 69%, $123 and $85, respectively, an improvement
from 62%, $124 and $76 one year earlier. The property also
underwent a $20 million renovation in 2016 that was completed in
January 2017, which included the addition of a Marriott Rewards
Club Lounge, four new guest rooms, new bedding and furnishings,
guest room refrigerators and modernized elevators. The property's
franchise agreement with Marriott Hotels & Resorts expires in
December 2023 and has one 10-year renewal option.

Property-level NOI in 2017 increased 54% from 2016, but still
remains 25% and 12% below 2014 and 2015 levels, respectively. The
loan had transferred to special servicing in July 2017 due to
imminent maturity default and subsequently matured in November
2017. The borrower had kept debt service current after the maturity
date. Property performance had been negatively impacted by the
economic conditions in Houston, reliance on the energy/oil sector
and new hotel supply in the market.

RATING SENSITIVITIES

The Stable Outlook on class B reflects increased credit enhancement
and the low debt per key relative to the outstanding class balance.
A further upgrade may be possible with sustained improved
performance. Downgrades to the distressed classes may occur if
performance deteriorates significantly.

DUE DILIGENCE USAGE

No third party due diligence was provided or reviewed in relation
to this rating action.

Fitch has upgraded the following classes and assigned Rating
Outlook as indicated:

  -- $23.3 million class B to 'Bsf' from 'CCsf'; Stable Outlook
assigned;

  -- $25.0 million class C to 'CCCsf' from 'Csf'; RE 100%.

In addition, Fitch has affirmed the following classes:

  -- $18.8 million class D at 'Csf'; RE 40%;

  -- $2.8 million class E at 'Dsf'; RE 0%.

Classes F through Q have been fully depleted due to realized losses
and are affirmed at 'Dsf'; RE 0%. The class A-1, A-2, A-3, A-AB,
A-4, A-1A, A-M, AM-A, A-J and AJ-A certificates have paid in full.
Fitch does not rate the class S certificates. Fitch previously
withdrew the ratings assigned to the interest-only class X-1 and
X-2 certificates.


BLUEMOUNTAIN CLO 2012-2: S&P Rates $25.25MM E-R2 Notes 'BB'
-----------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R2, B-R2,
C-R2, D-R2, and E-R2 replacement notes from BlueMountain CLO 2012-2
Ltd., a collateralized loan obligation (CLO) originally issued in
2012, which was refinanced in 2016 and is managed by BlueMountain
Capital Management LLC. S&P withdrew its ratings on the original
class A-R, B-R, C-R, D-R, and E-R notes following payment in full
on the Nov. 20, 2018, refinancing date.

On the Nov. 20, 2018, refinancing date, the proceeds from the class
A-R2, B-R2, C-R2, D-R2, and E-R2 replacement note issuances were
used to redeem the original class A-R, B-R, C-R, D-R, and E-R notes
as outlined in the transaction document provisions. Therefore, S&P
withdrew its ratings on the original notes in line with their full
redemption, and it is assigning ratings to the replacement notes.

The replacement notes are being issued via a supplemental
indenture, which, in addition to outlining the terms of the
replacement notes, will also reduce the floating spread on all of
the refinanced classes and extend the non-call period by one year.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction as reflected in
the trustee report, to estimate future performance. In line with
our criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults, and
recoveries upon default, under various interest rate and
macroeconomic scenarios. In addition, our analysis considered the
transaction's ability to pay timely interest or ultimate principal,
or both, to each of the rated tranches.

"The assigned ratings reflect our opinion that the credit support
available is commensurate with the associated rating levels.

"We will continue to review whether, in our view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them, and we will take rating actions as we
deem necessary."

  RATINGS ASSIGNED
  BlueMountain CLO 2012-2 Ltd.

  Replacement class          Rating        Amount (mil $)
  A-R2                       AAA (sf)              382.20
  B-R2                       AA (sf)                68.10
  C-R2                       A (sf)                 48.90
  D-R2                       BBB (sf)               30.10
  E-R2                       BB (sf)                25.25

  RATINGS WITHDRAWN
  BlueMountain CLO 2012-2 Ltd.
                             Rating
  Original class       To              From
  A-R                  NR              AAA (sf)
  B-R                  NR              AA (sf)
  C-R                  NR              A (sf)
  D-R                  NR              BBB (sf)
  E-R                  NR              BB (sf)

  NR--Not rated.


BLUEMOUNTAIN CLO XXIII: S&P Assigns BB-(sf) Rating on Cl. E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to BlueMountain CLO XXIII
Ltd./BlueMountain CLO XXIII LLC's floating-rate notes.

The note issuance is a collateralized loan obligation transaction
backed by primarily broadly syndicated speculative-grade senior
secured term loans that are governed by collateral quality tests.

The ratings reflect:

-- The diversified collateral pool, which consists primarily of
broadly syndicated speculative-grade (rated 'BB+' and lower) senior
secured term loans that are governed by collateral quality tests.

-- The credit enhancement provided through the subordination of
cash flows, excess spread, and overcollateralization.

-- The collateral manager's experienced team, which can affect the
performance of the rated notes through collateral selection,
ongoing portfolio management, and trading.

-- The transaction's legal structure, which is expected to be
bankruptcy remote.

  RATINGS ASSIGNED

  BlueMountain CLO XXIII Ltd./BlueMountain CLO XXIII LLC

  Class                Rating      Amount (mil. $)
  A-1                  AAA (sf)            291.000
  A-2                  NR                   29.000
  B                    AA (sf)              60.000
  C (deferrable)       A (sf)               28.750
  D (deferrable)       BBB- (sf)            31.000
  E (deferrable)       BB- (sf)             17.000
  Subordinated notes   NR                   52.825

  NR--Not rated.


BURNHAM PARK: Moody's Assigns Ba3 Rating on Class E-R Notes
-----------------------------------------------------------
Moody's Investors Service has assigned the following ratings to the
following notes issued by Burnham Park CLO, Ltd.:

US$63,250,000 Class B-R Senior Secured Floating Rate Notes Due 2029
(the "Class B-R Notes"), Assigned Aa2 (sf)

US$39,050,000 Class C-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class C-R Notes"), Assigned A2 (sf)

US$30,250,000 Class D-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class D-R Notes"), Assigned Baa3 (sf)

US$21,450,000 Class E-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class E-R Notes"), Assigned Ba3 (sf)

Additionally, Moody's has affirmed the rating on the following
outstanding notes issued by the Issuer on the original issuance
date (the "Original Closing Date"):

US$352,000,000 Class A Senior Secured Floating Rate Notes due 2029
(the "Class A Notes"), Affirmed Aaa (sf); previously on October 26,
2016 Assigned Aaa (sf)

The Issuer is a managed cash flow collateralized loan obligation
(CLO). The issued notes are collateralized primarily by a portfolio
of senior secured, broadly syndicated corporate loans.

GSO / Blackstone Debt Funds Management LLC manages the CLO. It
directs the selection, acquisition, and disposition of collateral
on behalf of the Issuer.

RATINGS RATIONALE

Moody's ratings reflect the risks due to defaults on the underlying
portfolio of assets, the transaction's legal structure, and the
characteristics of the underlying assets.

The Issuer has issued the Refinancing Notes on November 28, 2018 in
connection with the refinancing of certain classes of notes
previously issued on the Original Closing Date. On the Refinancing
Date, the Issuer used the proceeds from the issuance of the
Refinancing Notes to redeem in full the Refinanced Original Notes.


Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in "Moody's Global
Approach to Rating Collateralized Loan Obligations."

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score, weighted average
recovery rate, and weighted average spread, are based on its
published methodology and could differ from the trustee's reported
numbers. For modeling purposes, Moody's used the following
base-case assumptions:

Performing par and principal proceeds balance: $548,999,952

Defaulted par: $0

Diversity Score: 75

Weighted Average Rating Factor (WARF): 2770 (corresponding to a
weighted average default probability of 23.74%)

Weighted Average Spread (WAS): 3.39%

Weighted Average Recovery Rate (WARR): 47.98%

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Ratings on the notes issued by Burnham Park CLO, Ltd.
were assigned in accordance with Moody's existing Methodology
entitled "Moody's Global Approach to Rating Collateralized Loan
Obligations," dated August 31, 2017. Please note that on November
14, 2018, Moody's released a Request for Comment, in which it has
requested market feedback on potential revisions to its Methodology
for Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Ratings on notes issued by Burnham Park CLO, Ltd.
Please refer to Moody's Request for Comment, titled "Proposed
Update to Moody's Global Approach to Rating Collateralized Loan
Obligations," for further details regarding the implications of the
proposed Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the notes is subject to uncertainty. The
performance of the notes is sensitive to the performance of the
underlying portfolio, which in turn depends on economic and credit
conditions that may change. The Manager's investment decisions and
management of the transaction will also affect the performance of
the notes.


CARLYLE US 2018-4: Moody's Assigns (P)Ba3 Rating on Class D Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to six
classes of notes to be issued by Carlyle US CLO 2018-4, Ltd..

Moody's rating action is as follows:

US$372,000,000 Class A-1a Senior Secured Floating Rate Notes due
2031 (the "Class A-1a Notes"), Assigned (P)Aaa (sf)

US$18,000,000 Class A-1b Senior Secured Floating Rate Notes due
2031 (the "Class A-1b Notes"), Assigned (P)Aaa (sf)

US$66,000,000 Class A-2 Senior Secured Floating Rate Notes due 2031
(the "Class A-2 Notes"), Assigned (P)Aa2 (sf)

US$31,000,000 Class B Mezzanine Secured Deferrable Floating Rate
Notes due 2031 (the "Class B Notes"), Assigned (P)A2 (sf)

US$37,500,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes due 2031 (the "Class C Notes"), Assigned (P)Baa3 (sf)

US$27,500,000 Class D Junior Secured Deferrable Floating Rate Notes
due 2031 (the "Class D Notes"), Assigned (P)Ba3 (sf)

The Class A-1a Notes, the Class A-1b Notes, the Class A-2 Notes,
the Class B Notes, the Class C Notes and the Class D Notes are
referred to herein, collectively, as the "Rated Notes."

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions. Upon a conclusive review of a
transaction and associated documentation, Moody's will endeavor to
assign definitive ratings. A definitive rating, if any, may differ
from a provisional rating.

RATINGS RATIONALE

The provisional ratings reflect the risks due to defaults on the
underlying portfolio of assets, the transaction's legal structure,
and the characteristics of the underlying assets.

Carlyle 2018-4 is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90.0% of the portfolio must consist of
senior secured loans, and up to 10.0% of the portfolio may consist
of second lien loans and unsecured loans. Moody's expects the
portfolio to be approximately 80% ramped as of the closing date.

Carlyle CLO Management L.L.C. will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's five year reinvestment period.
Thereafter, the Manager may reinvest unscheduled principal payments
and proceeds from sales of credit risk assets, subject to certain
restrictions.

In addition to the Rated Notes, the Issuer will issue subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $600,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2775

Weighted Average Spread (WAS): 3.25%

Weighted Average Coupon (WAC): 6.5%

Weighted Average Recovery Rate (WARR): 47.0%

Weighted Average Life (WAL): 9.0 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for Carlyle US CLO 2018-4, Ltd. was assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on Carlyle US CLO 2018-4, Ltd. Please
refer to Moody's Request for Comment, titled "Proposed Update to
Moody's Global Approach to Rating Collateralized Loan Obligations,"
for further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.


CHT 2017-COSMO: DBRS Confirms BB(high) Rating on Class F Certs
--------------------------------------------------------------
DBRS Limited confirmed the ratings on all classes of Commercial
Mortgage Pass-Through Certificates, Series 2017-COSMO issued by CHT
2017-COSMO Mortgage Trust as follows:

-- Class A at AAA (sf)
-- Class B at AA (high) (sf)
-- Class C at A (high) (sf)
-- Class D at BBB (high) (sf)
-- Class E at BBB (low) (sf)
-- Class F at BB (high) (sf)

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. This transaction closed in November
2017 with an original trust balance of $1.38 billion fully secured
by a loan collateralized by The Cosmopolitan, a luxury hotel and
casino in Las Vegas. Whole-loan proceeds, along with $420.0 million
of mezzanine loans, refinanced existing debt of $1.55 billion and
returned equity of approximately $227.5 million to Blackstone Real
Estate Partners (the sponsor for the collateral). The interest-only
trust loan is structured with a two-year initial term with five
one-year renewal options. Per the October 2018 remittance, the loan
has performed as expected with no collateral reduction.

The Cosmopolitan was completed in 2010 and is situated in an
excellent mid-strip location between the Bellagio Hotel & Casino
and City Center. Collateral amenities include, but are not limited
to, 3,027 keys; over 250,000 square feet (sf) of convention and
banquet space facilities; 115,000 sf of casino space; 96,000 sf of
entertainment space; 23,500 sf of retail space; and spa/fitness
facilities. The Cosmopolitan hotel is a part of Marriott's
Autograph Collection and is subject to a license agreement that
expires in 2031 with termination options every five years.

In June 2017, the sponsor began a $135.0 million ($46,632 per key
renovated) renovation in June 2017 on 2,895 keys, which excluded
newly constructed rooms and penthouses. Per the servicer commentary
from October 2018, approximately 88.0% of the renovation has been
completed and the project is on track to be completed by December
31, 2018. Per the June 2018 financials, the subject reported a
trailing-12-month (T-12) occupancy, average daily rate and revenue
per available room of 92.6%, $326 and $312, respectively. In
comparison, the subject reported T-12 August 2017 figures of 94.8%,
$316 and $300, respectively, and YE2016 figures of 94.8%, $311 and
$295, respectively. Per the trailing-six-month June 2018
financials, the loan reported a debt service coverage ratio (DSCR)
of 2.76 times (x), in comparison with the DBRS Term DSCR at
issuance of 2.73x. There is low term-default risk, even though
hotels typically exhibit high cash flow volatility compared with
other property types. Per the June 2018 financials, 38.7% of
revenue was generated from guest rooms, 40.6% from food and
beverages and the remaining 20.7% was generated from gaming and
alternate sources.

Given the property's excellent quality and location, limited new
hotel casino supply anticipated before the end of 2020 and
sponsorship's continued emphasis and investment in improving gaming
performance, DBRS expects loan performance to remain strong during
the fully extended term, and the ability to refinance the mortgage
loan at maturity should be high as the property has been
successfully refinanced twice since 2016.


CIFC FUNDING 2018-V: Moody's Gives (P)Ba3 Rating on Class D Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to five
classes of notes to be issued by CIFC Funding 2018-V, Ltd.

Moody's rating action is as follows:

US$354,250,000 Class A-1 Senior Secured Floating Rate Notes due
2032 (the "Class A-1 Notes"), Assigned (P)Aaa (sf)

US$55,590,000 Class A-2 Senior Secured Floating Rate Notes due 2032
(the "Class A-2 Notes"), Assigned (P)Aa2 (sf)

US$26,700,000 Class B Mezzanine Secured Deferrable Floating Rate
Notes due 2032 (the "Class B Notes"), Assigned (P)A2 (sf)

US$35,430,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes due 2032 (the "Class C Notes"), Assigned (P)Baa3 (sf)

US$29,430,000 Class D Junior Secured Deferrable Floating Rate Notes
due 2032 (the "Class D Notes"), Assigned (P)Ba3 (sf)

The Class A-1 Notes, the Class A-2 Notes, the Class B Notes, the
Class C Notes and the Class D Notes are referred to herein,
collectively, as the "Rated Notes."

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions. Upon a conclusive review of a
transaction and associated documentation, Moody's will endeavor to
assign definitive ratings. A definitive rating, if any, may differ
from a provisional rating.

RATINGS RATIONALE

The provisional ratings reflect the risks due to defaults on the
underlying portfolio of assets, the transaction's legal structure,
and the characteristics of the underlying assets.

CIFC Funding 2018-V is a managed cash flow CLO. The issued notes
will be collateralized primarily by broadly syndicated senior
secured corporate loans. At least 95% of the portfolio must consist
of first lien senior secured loans and eligible investments, and up
to 5% of the portfolio may consist of second lien loans and
unsecured loans. Moody's expects the portfolio to be approximately
80% ramped as of the closing date.

CIFC CLO Management II LLC will direct the selection, acquisition
and disposition of the assets on behalf of the Issuer and may
engage in trading activity, including discretionary trading, during
the transaction's 5.1 year reinvestment period. Thereafter, the
Manager may reinvest unscheduled principal payments and proceeds
from sales of credit risk assets, subject to certain restrictions.


In addition to the Rated Notes, the Issuer will issue subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $545,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2880

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 6.50%

Weighted Average Recovery Rate (WARR): 46.50%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for CIFC Funding 2018-V, Ltd. was assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on CIFC Funding 2018-V, Ltd. Please refer
to Moody's Request for Comment, titled "Proposed Update to Moody's
Global Approach to Rating Collateralized Loan Obligations," for
further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.


COLT 2018-4: DBRS Finalizes B(high) Rating on Class B-2 Certs
-------------------------------------------------------------
DBRS, Inc. finalized the provisional ratings on the COLT 2018-4
Mortgage Pass-Through Certificates, Series 2018-4 issued by COLT
2018-4 Mortgage Loan Trust as follows:

-- $243.0 million Class A-1 at AAA (sf)
-- $34.4 million Class A-2 at AA (sf)
-- $26.1 million Class A-3 at A (sf)
-- $18.1 million Class M-1 at BBB (sf)
-- $3.0 million Class M-2 at BBB (low) (sf)
-- $10.3 million Class B-1 at BB (sf)
-- $5.0 million Class B-2 at B (high) (sf)

The AAA (sf) rating on the Certificates reflects the 31.45% of
credit enhancement (CE) provided by subordinated Certificates in
the pool. The AA (sf), A (sf), BBB (sf), BBB (low) (sf), BB (sf)
and B (high) (sf) ratings reflect 21.75%, 14.40%, 9.30%, 8.45%,
5.55% and 4.14% of CE, respectively.

Other than the specified classes above, DBRS does not rate any
other classes in this transaction.

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate prime and non-prime first-lien residential
mortgages. The Certificates are backed by 621 loans with a total
principal balance of $354,493,121 as of the Cut-Off Date (November
1, 2018).

Caliber Home Loans, Inc. (Caliber) is the Originator and Servicer
for 100.0% of the portfolio. The Caliber mortgages were originated
under the following five programs:

(1) Elite Access (42.0%) – Generally made to borrowers with
strong credit history seeking loans with non-conforming balances
who do not meet strict prime jumbo guidelines for various reasons.
These loans may have interest-only (IO) features, higher
debt-to-income (DTI) and loan-to-value (LTV) ratios or lower credit
scores compared with those in traditional prime jumbo
securitizations. This program has higher minimum FICO requirements
than Premier Access (as outlined below) and does not allow for
mortgage latest in the past 12 months.

(2) Premier Access (35.4%) – Generally made to borrowers with
unblemished credit. These loans may have IO features, higher DTI
and LTV ratios or lower credit scores compared with those in
traditional prime jumbo securitizations.

(3) Homeowner's Access (12.9%) – Made to borrowers who do not
qualify for agency or prime jumbo mortgages for various reasons,
such as loan size in excess of government limits, alternative or
insufficient credit or prior derogatory credit events that occurred
more than two years prior to origination.

(4) Fresh Start (8.5%) – Generally made to borrowers with lower
credit and borrowers who may have had significant recent credit
events within the past 24 months.

(5) Investor (1.2%) – Made to borrowers who finance investor
properties where the mortgage loan would not meet agency or
government guidelines because of such factors as property type,
number of financed properties, lower borrower credit score or a
seasoned credit event.

Wells Fargo Bank, N.A. (Wells Fargo; rated AA with a Stable trend
by DBRS) will act as the Master Servicer, Securities Administrator
and Certificate Registrar. U.S. Bank National Association (rated AA
(high) with a Stable trend by DBRS) will serve as Trustee.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau (CFPB) Ability-to-Repay (ATR) rules,
they were made to borrowers who generally do not qualify for
agency, government or private-label non-agency prime jumbo products
for the various reasons described above. In accordance with the
CFPB Qualified Mortgage (QM) rules, 29.9% of the loans are
designated as QM Safe Harbor, 13.0% as QM Rebuttable Presumption
and 55.9% as Non-QM. Approximately 1.2% of the loans is made to
investors for business purposes and is not subject to the QM
rules.

The Servicer will generally fund advances of delinquent principal
and interest on any mortgage until such loan becomes 180 days
delinquent and it is obligated to make advances in respect of
taxes, insurance premiums and reasonable costs incurred in the
course of servicing and disposing of properties.

On or after the earlier of (1) the two-year anniversary of the
Closing Date and (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, the Depositor has the option to purchase all outstanding
Certificates at a price equal to the outstanding class balance,
plus accrued and unpaid interest, including any cap carry-over
amounts.

The transaction employs a sequential-pay cash flow structure with a
pro rata principal distribution among the senior tranches.
Principal proceeds can be used to cover interest shortfalls on the
Certificates as the outstanding senior Certificates are paid in
full.

The ratings reflect transactional strengths that include the
following:

(1) ATR rules and Appendix Q compliance: All mortgage loans were
underwritten in accordance with the eight underwriting factors of
the ATR rules. In addition, Caliber's underwriting standards comply
with the Standards for Determining Monthly Debt and Income as set
forth in Appendix Q of Regulation Z with respect to income
verification and the calculation of DTI ratios. However, 180 loans
were permitted to have non-material deviations from Appendix Q.

(2) Strong underwriting standards: For prime or non-prime
mortgages, underwriting standards have improved significantly from
the pre-crisis era. The Caliber loans were underwritten to a full
documentation standard with respect to verification of income
(generally through two years of W-2 forms or tax returns),
employment and assets. Generally, fully executed 4506-Ts are
obtained and tax returns are verified with Internal Revenue Service
transcripts, if applicable.

(3) Robust loan attributes and pool composition:

-- Although the weighted-average combined LTV ratio has increased
from prior transactions, the mortgage loans in this portfolio
generally have robust loan attributes as reflected in the combined
LTV ratios, borrower household income and liquid reserves,
including the loans in Homeowner's Access and Fresh Start, the two
programs with weaker borrower credit.

-- The pool contains low proportions of cash-out and investor
properties.

-- As the programs move down the credit spectrum, certain
characteristics, such as lower LTV or DTI ratios, suggest the
consideration of compensating factors for riskier pools.

-- The pool comprises 68.8% fixed-rate mortgages, which have the
lowest default risk because of the stability of monthly payments.
The pool comprises 31.2% hybrid adjustable-rate mortgages with an
initial fixed period of five to seven years, allowing borrowers
sufficient time to credit cure before rates reset.

(4) Satisfactory third-party due diligence review: A third-party
due diligence firm conducted property valuation, credit and
compliance reviews on 100% of the loans in the pool. Data integrity
checks were also performed on the pool.

(5) Satisfactory loan performance to date (albeit short): Caliber
began originating similar loans in Q4 2014. Since the first
transaction issued in August 2015, the COLT shelf's historical
performance has been satisfactory, though short. For the previous
COLT Non-QM transactions rated by DBRS, as of October 2018, 60+ day
delinquency rates ranged between 0.3% and 5.1% and cumulative
losses are no higher than 0.01%. Additionally, one of the unrated
transactions (COLT 2015-1) exhibited a higher 60+ day delinquency
rate of 7.3%. Finally, voluntary prepayment rates have been
relatively high, as these borrowers tend to credit cure and
refinance into lower-rate mortgages. For details on the COLT
securitization performance, please refer to the "Historical
Performance" section of the related report.

The transaction also includes the following challenges and
mitigating factors:

(1) Representations and warranties (R&W) framework and provider:
The R&W framework is considerably weaker compared with that of a
post-crisis prime securitization. Instead of an automatic review
when a loan becomes seriously delinquent, this transaction employs
an optional review only when realized losses occur (unless the
alleged breach relates to an ATR or TILA-RESPA Integrated
Disclosure violation). In addition, rather than engaging a
third-party due diligence firm to perform the R&W review, the
Controlling Holder (initially the Sponsor or a majority-owned
affiliate of the Sponsor) has the option to perform the review in
house or use a third-party reviewer. Finally, the R&W provider (the
Originator) is an unrated entity; has limited performance history
of non-prime, Non-QM securitizations; and may potentially
experience financial stress that could result in the inability to
fulfill repurchase obligations. DBRS notes the following mitigating
factors:

-- The holders of Certificates representing 25% interest in the
Certificates may direct the Trustee to commence a separate review
of the related mortgage loan, to the extent they disagree with the
Controlling Holder's determination of a breach.

-- Third-party due diligence was conducted on 100% of the loans
included in the pool. A comprehensive due diligence review
mitigates the risk of future R&W violations.

-- DBRS conducted an on-site Originator (and Servicer) review of
Caliber and deems it to be acceptable.

-- The Sponsor or an affiliate of the Sponsor will retain certain
classes of Certificates, which represent at least 5% of the fair
value of all the Certificates, aligning Sponsor and investor
interest in the capital structure.

-- Notwithstanding the above, DBRS adjusted the originator score
downward to account for the potential inability to fulfill
repurchase obligations, the lack of performance history and the
weaker R&W framework. A lower originator score results in increased
default and loss assumptions and provides additional cushions for
the rated securities.

(2) Non-Prime, QM Rebuttable Presumption or Non-QM loans: Compared
with post-crisis prime transactions, this portfolio contains some
mortgages originated to borrowers with weaker credit and prior
derogatory credit events as well as QM Rebuttable Presumption or
Non-QM loans.

-- All loans were originated to meet the eight underwriting
factors as required by the ATR rules and were also generally
underwritten to comply with the standards set forth in Appendix Q,
although certain loans may have non-material exceptions with
respect to Appendix Q.

-- Underwriting standards have improved substantially since the
pre-crisis era.

-- The DBRS RMBS Insight model incorporates loss severity
penalties for Non-QM and QM Rebuttable Presumption loans as
explained further in the "Key Loss Severity Drivers" section of the
related report.

-- For loans in this portfolio that were originated through the
Homeowner's Access and Fresh Start programs, certain borrowers had
recent prior credit events. Such credit events generally happened,
on a non-zero average basis, 34 months (Homeowner's Access) and 20
months (Fresh Start) prior to origination. In its analysis, DBRS
applies additional penalties for borrowers with recent credit
events within the past two years.

(3) Servicer advances of delinquent principal and interest: The
Servicer will advance scheduled principal and interest on
delinquent mortgages until such loans become 180 days delinquent.
This will likely result in lower loss severities to the transaction
because advanced principal and interest will not have to be
reimbursed from the Trust upon liquidation of the mortgages but
will increase the possibility of periodic interest shortfalls to
the Certificate holders. Mitigating factors include the following:
(a) Principal proceeds can be used to pay interest shortfalls to
the Certificates as the outstanding senior Certificates are paid in
full and (b) DBRS ran cash flow scenarios that incorporated
principal and interest advancing up to 180 days for delinquent
loans. The cash flow scenarios are discussed in more detail in the
"Cash Flow Analysis" section of the related report.

(4) Servicer's financial capability: In this transaction, Caliber,
as the Servicer, is responsible for funding advances to the extent
required. The Servicer is an unrated entity and may face financial
difficulties in fulfilling its servicing advance obligations in the
future. Consequently, the transaction employs Wells Fargo as the
Master Servicer. If the Servicer fails in its obligation to make
advances, Wells Fargo will be obligated to fund such servicing
advances.

The DBRS ratings of AAA (sf) and AA (sf) address the timely payment
of interest and full payment of principal by the legal final
maturity date in accordance with the terms and conditions of the
related Certificates. The DBRS ratings of A (sf), BBB (sf), BBB
(low) (sf), BB (sf) and B (high) (sf) address the ultimate payment
of interest and full payment of principal by the legal final
maturity date in accordance with the terms and conditions of the
related Certificates.

Notes: All figures are in U.S. dollars unless otherwise noted.


COLT 2018-4: Fitch Assigns BBsf Rating on Class B-1 Certs
---------------------------------------------------------
Fitch Rates COLT 2018-4 Mortgage Loan Trust as follows:

  -- $243,005,000 class A-1 certificates 'AAAsf'; Outlook Stable;

  -- $34,385,000 class A-2 certificates 'AAsf'; Outlook Stable;

  -- $26,056,000 class A-3 certificates 'Asf'; Outlook Stable;

  -- $18,079,000 class M-1 certificates 'BBBsf'; Outlook Stable;

  -- $3,013,000 class M-2 certificates 'BBB-sf'; Outlook Stable;

  -- $10,280,000 class B-1 certificates 'BBsf'; Outlook Stable;

  -- $5,000,000 class B-2 certificates 'B+sf'; Outlook Stable.

Fitch will not be rating the following certificates:

  -- $14,675,121 class B-3 certificates.

KEY RATING DRIVERS

Non-Prime Credit Quality (Concern): The pool has a weighted average
(WA) model credit score of 720 and a WA combined loan to value
ratio (CLTV) of 82%. Of the pool, 31% consists of borrowers with
prior credit events (within the past seven years and received a
probability of default penalty) and 43% had a debt to income (DTI)
ratio of over 43%. Investor properties account for 1.2% of the
pool.

Fitch applied default penalties to account for these attributes,
and loss severity (LS) was adjusted to reflect the increased risk
of ATR challenges.

100% Full Income Documentation (Positive): All loans in the
mortgage pool were underwritten to the comprehensive Appendix Q
documentation standards defined by ATR, which is not typical for
non-prime RMBS. Mortgage pools of all other active non-prime RMBS
issuers include a significant percentage of non-traditional income
documentation. While a due diligence review identified roughly 27%
of loans (by count) as having minor variations to Appendix Q, Fitch
views those differences as immaterial and all loans as having full
income documentation. The COLT series transactions that are
comprised of 100% Caliber origination are the only non-prime RMBS
issued with 100% full income documentation.

Strong Operational and Data Quality (Positive): Caliber has one of
the largest and most established Non-QM programs in the sector.
Fitch views the visibility into the origination programs as a
strength relative to Non-QM transactions with a high number of
originators. Fitch reviewed Caliber and Hudson Americas L.P.'s
(Hudson's) origination and acquisition platforms and found them to
have sound underwriting and operational control environments,
reflecting industry improvements following the financial crisis.
These improvements are expected to reduce risk related to
misrepresentation and data quality and were reflected in strong
third-party due diligence results.

Alignment of Interests (Positive): The transaction benefits from an
alignment of interests between the issuer and investors. LSRMF
Acquisitions I, LLC (LSRMF), as sponsor and securitizer, or an
affiliate will retain a horizontal interest in the transaction
equal to not less than 5% of the aggregate fair market value of all
certificates in the transaction. Lastly, the representations and
warranties are provided by Caliber, which is owned by LSRMF
affiliates and, therefore, also aligns the interest of the
investors with those of LSRMF to maintain high-quality origination
standards and sound performance, as Caliber will be obligated to
repurchase loans due to rep breaches.

Modified Sequential Payment Structure (Mixed): The structure
distributes collected principal pro rata among the class A
certificates while shutting out the subordinate bonds from
principal until all three classes have been reduced to zero. To the
extent that any of the cumulative loss trigger event, the
delinquency trigger event or the credit enhancement trigger event
occurs in a given period, principal will be distributed
sequentially to the class A-1, A-2 and A-3 certificates until they
are reduced to zero.

R&W Framework (Concern): As originator, Caliber will be providing
loan-level representations and warranties to the trust. While the
reps for this transaction are substantively consistent with those
listed in Fitch's published criteria and provide a solid alignment
of interest, Fitch added approximately 169 bps to the expected loss
at the 'AAAsf' rating category to reflect the non-investment-grade
counterparty risk of the provider and the lack of an automatic
review of defaulted loans. The lack of an automatic review is
mitigated by the ability of holders of 25% of the total outstanding
aggregate class balance to initiate a review.

Servicing and Master Servicer (Positive): Servicing will be
performed on 100% of the loans by Caliber. Fitch rates Caliber
'RPS2-'/Outlook Negative due to its fast-growing portfolio and
regulatory scrutiny. Wells Fargo Bank, N.A. (Wells Fargo), rated
'RMS1-'/Outlook Stable, will act as master servicer and securities
administrator. Advances required but not paid by Caliber will be
paid by Wells Fargo.

Performance Triggers (Mixed): Credit enhancement, delinquency and
loan loss triggers convert principal distribution to a straight
sequential payment priority in the event of poor asset performance.
The delinquency trigger is based only on the current month and not
on a rolling six-month average.

RATING SENSITIVITIES

Fitch's analysis incorporates a sensitivity analysis to demonstrate
how the ratings would react to steeper market value declines (MVDs)
than assumed at the MSA level. The implied rating sensitivities are
only an indication of some of the potential outcomes and do not
consider other risk factors that the transaction may become exposed
to or may be considered in the surveillance of the transaction.
Three sets of sensitivity analyses were conducted at the state and
national levels to assess the effect of higher MVDs for the subject
pool.

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10%, 20% and 30%, in addition to the
model-projected 8.9%. The analysis indicates that there is some
potential rating migration with higher MVDs, compared with the
model projection.

Fitch also conducted sensitivities to determine the stresses to
MVDs that would reduce a rating by one full category, to
non-investment-grade, and to 'CCCsf'.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC Diligence, LLC. The third-party due diligence
described in Form 15E was conducted on 100% of the loans in the
pool and focused on three areas: a compliance review, a credit
review, and a valuation review. Fitch considered this information
in its analysis and believes the overall results of the review
generally reflected strong underwriting controls. No adjustments
were made to Fitch's loss expectations as a result of the findings.


COMM 2014-UBS2: DBRS Confirms B(low) Rating on Class F Certs
------------------------------------------------------------
DBRS Limited confirmed the ratings on all classes of Commercial
Mortgage Pass-Through Certificates, Series 2014-UBS2 issued by COMM
2014-UBS2 Mortgage Trust as follows:

-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-M at AAA (sf)
-- Class X-A at AAA (sf)
-- Class B at AA (sf)
-- Class C at A (low) (sf)
-- Class PEZ at A (low) (sf)
-- Class X-B at BBB (sf)
-- Class D at BBB (low) (sf)
-- Class E at BB (low) (sf)
-- Class F at B (low) (sf)

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction. At issuance, the pool consisted of 59 loans,
secured by 95 commercial and multifamily properties, with an
original trust balance of $1.24 billion. Per the November 2018
remittance, there are 56 loans remaining in the pool with a current
trust balance of $1.10 billion, representing a collateral reduction
of 11.1% due to loan repayment and scheduled loan amortization.
Approximately 89.5% of the pool is reporting year-end (YE) 2017
financials and based on the most recent year-end reporting, the
pool reported a weighted-average (WA) debt-service coverage ratio
(DSCR) and debt yield of 1.59 times (x) and 10.6%, respectively.
The top 15 loans (72.7% of the pool) reported a WA DSCR and debt
yield of 1.60x and 10.4%, respectively, reflective of a WA net cash
flow (NCF) growth of 20.5% from DBRS Term NCF figures at issuance.
The pool also benefits from defeasance as four loans (3.0% of the
pool) are fully defeased.

Per the November 2018 remittance, there are 11 loans (28.6% of the
pool) on the servicer's watch list, including three loans in the
Top 15. Based on the YE2017 financials, loans on the servicer's
watch list reported a WA DSCR of 1.62x, reflective of a 32.4% NCF
growth over the DBRS Term NCF figures at issuance. There are two
loans (5.0% of the pool) in special servicing, including Tops
Markets Grocery Anchored Portfolio (Prospectus ID#11, 2.9% of the
pool) and Creekside Mixed Use Development (Prospectus ID#15, 2.1%
of the pool).

Tops Markets Grocery Anchored Portfolio was transferred to the
special servicer in April 2018 due to Tops Markets (Tops) filing
for Chapter 11 bankruptcy. Local news reports from August 2018
indicated that Tops Elmira (formerly 10.9% of portfolio net
rentable area, expiry June 2027) will be closed in November 2018 as
part of the restructuring effort; however, the other Tops locations
in the portfolio remain operational. A bankruptcy court approved
the company's restructuring plan in November 2018 and the special
servicer noted that it expects the borrower to be able to refinance
the loan at its upcoming February 2019 maturity date. Creekside
Mixed Use Development has been with the special servicer since
November 2014 and was transferred for imminent default when the
borrower's request for a release of holdback funds was denied and,
subsequently, the borrower stopped making payments. The property is
not currently listed for sale and the asset summary report provided
suggests that litigation to pursue damages from the sponsor was
under consideration. The loan has been real-estate owned since
April 2015. Given the sharp value reduction since issuance, and the
significant advances outstanding, DBRS expects the trust to
experience a significant loss upon loan resolution.

Classes X-A and X-B are interest-only (IO) certificates that
reference a single rated tranche or multiple rated tranches. The IO
rating mirrors the lowest-rated applicable reference obligation
tranche adjusted upward by one notch if senior in the waterfall.


COMM 2016-CCRE28: DBRS Confirms B Rating on Class X-E Certs
-----------------------------------------------------------
DBRS Limited confirmed the ratings for all classes of Commercial
Mortgage Pass-Through Certificates, Series 2016-CCRE28 issued by
COMM 2016-CCRE28 Mortgage Trust as follows:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-HR at AAA (sf)
-- Class A-M at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class X-A at AAA (sf)
-- Class X-HR at AAA (sf)
-- Class XP-A at AAA (sf)
-- Class B at AA (sf)
-- Class X-B at A (high) (sf)
-- Class C at A (sf)
-- Class D at BBB (high) (sf)
-- Class X-C at BBB (sf)
-- Class E at BBB (low) (sf)
-- Class X-D at BBB (low) (sf)
-- Class F at BB (high) (sf)
-- Class G at BB (low) (sf)
-- Class X-E at B (sf)
-- Class H at B (low) (sf)

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. The collateral consists of 49 loans
secured by 119 commercial and multifamily properties. As of the
November 2018 remittance, the pool had an aggregate trust balance
of approximately $1.02 billion, representing a collateral reduction
of 1.0% since issuance due to scheduled loan amortization. To date,
46 loans, representing 95.2% of the current pool balance, have
reported year-end (YE) 2017 financials. Based on the most recent YE
financials, the pool reported a weighted-average (WA) debt service
coverage ratio (DSCR) and debt yield of 1.71 times (x) and 9.7%,
respectively, compared with the DBRS Term DSCR and DBRS Debt Yield
figures of 1.51x and 8.4% at issuance, respectively. The top 15
loans, representing 66.8% of the current pool balance, reported a
WA DSCR of 1.74x compared with the WA DBRS Term DSCR of 1.55x,
representing a WA net cash flow (NCF) growth of 12.4% over the DBRS
NCF figures derived at issuance.

As of the November 2018 remittance, there is one loan in special
servicing (1.2% of the pool) and three loans (5.7% of the pool) on
the servicer's watch list. All three loans on the servicer watch
list were flagged because of non-performance-related reasons. Based
on YE2017 financials, these loans reported a WA DSCR of 1.51x
compared with the WA DBRS Term DSCR figure of 1.35x, representing a
WA NCF growth of 12.5% since issuance.

The Holiday Inn Fort Worth North Fossil Creek loan (Prospectus
ID#24) was transferred to special servicing in February 2018 due to
imminent monetary default, as the borrower cited an inability to
fund cash flow shortfalls and complete a required property
improvement plan (PIP) that was due in June 2018 as part of the
franchise agreement with the InterContinental Hotels Group plc
(IHG). As the PIP was not completed by the due date, and in light
of other issues with the franchise agreement, IHG issued a
termination notice for the agreement but has since provided an
extension of the cure date and has agreed to a repayment plan with
the borrower for past due franchise fees. The servicer confirms
that a forbearance is in negotiations to allow the borrower time to
complete the PIP and bring the franchise agreement back into good
standing. It is noteworthy that a PIP reserve was established at
issuance for guest room renovations that included case and soft
goods replacements, with a total of $837,694 ($6,648 per key)
collected. According to the information obtained by the Special
Servicer, the full scope of the required PIP appears to be much
higher than contemplated at issuance, with the borrower estimating
that $1.2 million in work remained outstanding as of October 2018.
The source of the discrepancy is unclear and the Special Servicer
is working with the borrower to confirm the details of the required
project.

Classes X-A, X-HR, XP-A, X-B, X-C, X-D and X-E are interest-only
(IO) certificates that reference a single rated tranche or multiple
rated tranches. The IO rating mirrors the lowest-rated applicable
reference obligation tranche adjusted upward by one notch if senior
in the waterfall.


CREDIT SUISSE 2007-C1: Fitch Affirms Bsf Rating on 3 Tranches
-------------------------------------------------------------
Fitch Ratings has affirmed all 20 classes of Credit Suisse
Commercial Mortgage Trust series 2007-C1 commercial mortgage
pass-through certificates.

KEY RATING DRIVERS

Increased Credit Enhancement: The Rating Outlook revision for
classes A-M, A-MFL and A-MFX reflects increased credit enhancement
since Fitch's last rating action due to the liquidation of the
real-estate owned (REO) Wells Fargo Place asset (18% of last rating
action pool balance) at better than expected recoveries and
continued scheduled loan amortization. In addition, further paydown
is expected from the largest remaining loan, City Place (41.4%).
The loan is secured by a 698,472 square foot (sf) mixed use
property located in West Palm Beach, FL. It was modified into an
A/B note structure in July 2017 and granted a maturity extension
through December 2018. According to media reports, the sponsor
plans to redevelop a former Macy's store into a mixed-use building
containing retail, office and residential uses. The servicer has
reported that the borrower intends to pay off both notes at
maturity. Despite the report that the loan will pay off, the
ratings are being affirmed due to the binary risk associated with
this loan.

As of the October 2018 distribution date, the pool's aggregate
principal balance has been reduced by 88.8% to $378.6 million from
$3.4 billion at issuance. Realized losses to date total $405
million (12% of original pool).

Modified Loans: There are three performing loans remaining, all of
which have been modified and granted maturity extensions. The
second-largest remaining loan is Koger Center (30.1%), which is an
849,765-sf office complex located in Tallahassee, FL. The loan was
modified in July 2017 and its maturity was extended to February
2020. The State of Florida is the largest tenant occupying 63% of
the net rentable area (NRA) and has a lease expiration in October
2019. The servicer reports that the State of Florida is expected to
renew their lease. The property was 88% occupied as of June 2018.

Concentrated Pool; Alternative Loss Consideration: The pool is
highly concentrated with three performing loans, two loans in
foreclosure and two REO assets. Due to the concentrated nature of
the pool, Fitch performed a sensitivity analysis that grouped the
remaining loans based on structural features, collateral quality
and performance, then ranked them by their perceived likelihood of
repayment. The ratings and outlooks reflect this sensitivity
analysis.

RATING SENSITIVITIES

The Outlooks on the A-M classes have been revised to Stable to
reflect the expectation that the City Place loan will pay off at
maturity. In addition, losses from the specially serviced
loans/assets will be absorbed by the subordinate class A-J.
However, as there is binary risk associated with the two largest
loans, downgrades are possible if either loan fails to pay off at
maturity. Upgrades are unlikely given the concentrated nature of
the pool and the aforementioned binary risks.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

No third-party due diligence was provided or reviewed in relation
to this rating.

Fitch has affirmed the following classes and revised Outlooks at
indicated:

  -- $68.7 million class A-M at 'Bsf'; Outlook to Stable from
Negative;

  -- $29.2 million class A-MFL at 'Bsf'; Outlook to Stable from
Negative;

  -- $11.3 million class A-MFX at 'Bsf'; Outlook to Stable from
Negative;

  -- $269.3 million class A-J at 'Dsf'; RE 0%;

  -- $0 million class B at 'Dsf'; RE 0%;

  -- $0 million class C at 'Dsf'; RE 0%;

  -- $0 million class D at 'Dsf'; RE 0%;

  -- $0 million class E at 'Dsf'; RE 0%;

  -- $0 million class F at 'Dsf'; RE 0%;

  -- $0 million class G at 'Dsf'; RE 0%;

  -- $0 million class H at 'Dsf'; RE 0%;

  -- $0 million class J at 'Dsf'; RE 0%;

  -- $0 million class K at 'Dsf'; RE 0%;

  -- $0 million class L at 'Dsf'; RE 0%;

  -- $0 million class M at 'Dsf'; RE 0%;

  -- $0 million class N at 'Dsf'; RE 0%;

  -- $0 million class O at 'Dsf'; RE 0%;

  -- $0 million class P at 'Dsf'; RE 0%;

  -- $0 million class Q at 'Dsf'; RE 0%;

  -- $0 million class S at 'Dsf'; RE 0%.


CREDIT SUISSE 2007-C5: Fitch Affirms CC on $77.8MM Class A-M Certs
------------------------------------------------------------------
Fitch Ratings has affirmed 15 classes of Credit Suisse Commercial
Mortgage Trust, series 2007-C5 commercial mortgage pass-through
certificates.

KEY RATING DRIVERS

Loss Expectations Remain High: The majority of outstanding assets
are in default and in special servicing. Losses are expected to
reach class A-M based on concerns related to continued performance
decline, weak occupancy, upcoming tenant roll, secondary and
tertiary market locations, over-leverage and below-average property
quality for these assets. Given that repayment of this class is
reliant on proceeds from the disposition of these assets and that
proceeds are not expected to be sufficient to repay the class in
full, Fitch has affirmed the distressed rating.

Insufficient Credit Support: There has been minimal change to
credit enhancement since the last rating action. Paydown of class
A-M is attributed to the repayment of two loans since the last
rating action as well as a one-time recovery of advances that had
previously been deemed non-recoverable. Future amortization is
limited to four performing loans, which represent 13% of the pool,
two of which have previously defaulted and could transfer to
special servicing again. Fitch's projected losses exceed the credit
support available to the senior-most class.

Pool Concentration: As performing loans have continued to
refinance, the pool has become more concentrated with
non-performing assets representing 87% of the deal. Based on this
concentration, Fitch relied on a sensitivity analysis of the
remaining loans. Fitch expects that adverse selection will continue
to create concentration concerns as performing loans are able to
repay, leaving only non-performing assets outstanding.

RATING SENSITIVITIES

The majority of the pool remains in special servicing, with future
amortization limited. Based on the pool's concentration, Fitch
utilized a sensitivity analysis and determined that repayment of
the senior bond is reliant on proceeds from specially serviced
assets. As the timing of dispositions in uncertain, future upgrades
are unlikely.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

No third-party due diligence was provided or reviewed in relation
to this rating action.

Fitch has affirmed the following ratings:

  -- $77.8 million class A-M at 'CCsf'; RE 90%;

  -- $85.6 million class A-J at 'Dsf'; RE 0%;

  -- $32 million class A-1-AJ at 'Dsf'; RE 0%;

  -- $0 class B at 'Dsf'; RE 0%;

  -- $0 class C at 'Dsf'; RE 0%;

  -- $0 class D at 'Dsf'; RE 0%;

  -- $0 class E at 'Dsf'; RE 0%;

  -- $0 class F at 'Dsf'; RE 0%;

  -- $0 class G at 'Dsf'; RE 0%;

  -- $0 class H at 'Dsf'; RE 0%;

  -- $0 class J at 'Dsf'; RE 0%;

  -- $0 class K at 'Dsf'; RE 0%;

  -- $0 class L at 'Dsf'; RE 0%;

  -- $0 class M at 'Dsf'; RE 0%;

  -- $0 class N at 'Dsf'; RE 0%.


CRESTLINE DENALI XIV: Moody's Rates $19.5MM Class E-R Notes Ba3(sf)
-------------------------------------------------------------------
Moody's Investors Service has assigned ratings to seven classes of
CLO refinancing notes issued by Crestline Denali CLO XIV, Ltd.

Moody's rating action is as follows:

US$239,600,000 Class A-1R Senior Secured Floating Rate Notes due
2031 (the "Class A-1R Notes"), Definitive Rating Assigned Aaa (sf)


US$10,000,000 Class A-2R Senior Secured Fixed Rate Notes due 2031
(the "Class A-2R Notes"), Definitive Rating Assigned Aaa (sf)

US$46,800,000 Class B-R Senior Secured Floating Rate Notes due 2031
(the "Class B-R Notes"), Definitive Rating Assigned Aa2 (sf)

US$19,500,000 Class C-R Senior Secured Deferrable Floating Rate
Notes due 2031 (the "Class C-R Notes"), Definitive Rating Assigned
A2 (sf)

US$23,400,000 Class D-R Senior Secured Deferrable Floating Rate
Notes due 2031 (the "Class D-R Notes"), Definitive Rating Assigned
Baa3 (sf)

US$19,500,000 Class E-R Secured Deferrable Floating Rate Notes due
2031 (the "Class E-R Notes"), Definitive Rating Assigned Ba3 (sf)

US$3,000,000 Class F-R Secured Deferrable Floating Rate Notes due
2031 (the "Class F-R Notes"), Definitive Rating Assigned B3 (sf)

The Issuer is a managed cash flow collateralized loan obligation
(CLO). The issued notes are collateralized primarily by a portfolio
of senior secured, broadly syndicated corporate loans.

Crestline Denali Capital, L.P. will manage the CLO. It directs the
selection, acquisition, and disposition of collateral on behalf of
the Issuer.

RATINGS RATIONALE

The ratings reflect the risks due to defaults on the underlying
portfolio of assets, the transaction's legal structure, and the
characteristics of the underlying assets.

The Issuer has issued the Refinancing Notes on November 20, 2018 in
connection with the refinancing of all classes of secured notes
previously issued on October 13, 2016. On the Refinancing Date, the
Issuer used the proceeds from the issuance of the Refinancing Notes
and one other class of secured notes to redeem in full the
Refinanced Original Notes.

In addition to the issuance of the Refinancing Notes and one other
class of secured notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: extension of the reinvestment period; extensions of the
stated maturity and non-call period; changes to certain collateral
quality tests; changes to the collateral quality matrix and
modifiers; and changes to the overcollateralization test levels.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. For modeling
purposes, Moody's used the following base-case assumptions:

Par amount: $390,000,000

Defaulted par: $0

Diversity Score: 80

Weighted Average Rating Factor (WARF): 2836

Weighted Average Spread (WAS): 3.35%

Weighted Average Recovery Rate (WARR): 48%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for Crestline Denali CLO XIV, Ltd. was assigned
in accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on the notes issued by Crestline Denali
CLO XIV, Ltd. Please refer to Moody's Request for Comment, titled
"Proposed Update to Moody's Global Approach to Rating
Collateralized Loan Obligations," for further details regarding the
implications of the proposed Methodology revisions on certain
Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Refinancing Notes is subject to uncertainty.
The performance of the Refinancing Notes is sensitive to the
performance of the underlying portfolio, which in turn depends on
economic and credit conditions that may change. The Manager's
investment decisions and management of the transaction will also
affect the performance of the Refinancing Notes.


CROWN POINT 6: S&P Assigns B- Rating on $5.2MM Class F Notes
------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class X, A-1, A-2,
B, C, D, E, and F replacement notes from Crown Point CLO 6 Ltd., a
collateralized loan obligation (CLO) that is a reset of Newmark
Capital Funding 2014-2 CLO Ltd., which was originally issued in
June 2014 and is managed by Pretium Credit Management LLC. The
replacement notes were issued via a supplemental indenture.

The ratings reflect S&P's opinion that the credit support available
is commensurate with the associated rating levels.

On the Nov. 27, 2018, refinancing date, the proceeds from the class
X, A-1, A-2, B, C, D, E, and F replacement note issuances were used
to redeem the original class A-1-R, A-2A-R, A-2B-R, A-F-R, B-1-R,
B-F-R, C-R, D, and E notes as outlined in the transaction document
provisions. Therefore, S&P withdrew its ratings on the original
notes in line with their full redemption, and it is assigning
ratings to the replacement notes.

The replacement notes are being issued via a supplemental
indenture, which, in addition to outlining the terms of the
replacement notes, will also:

-- Issue the replacement class A-1, C, and D notes at a lower
spread than the original notes.

-- Issue the replacement class A-2, B, and E notes at a higher
spread than the original notes.

-- Issue all the replacement class notes at a floating spread,
replacing the current fixed coupon classes of the original notes.

-- Issue the replacement class E notes with a step-up spread that
will increase after the October 2020 payment date.

-- Issue new class F and X notes at a floating rate.

-- Extend the stated maturity from June 30, 2026, to Oct. 20,
2028.

-- Extend the reinvestment period from June 18, 2018, to Oct. 20,
2020.

-- Extend the non-call period to Oct. 20, 2019.

-- Extend the weighted average life test date to Oct. 20, 2024.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction as reflected in
the trustee report, to estimate future performance (see table). In
line with our criteria, our cash flow scenarios applied
forward-looking assumptions on the expected timing and pattern of
defaults, and recoveries upon default, under various interest rate
and macroeconomic scenarios. In addition, our analysis considered
the transaction's ability to pay timely interest or ultimate
principal, or both, to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them, and we will take further rating actions
as we deem necessary."

  RATINGS ASSIGNED

  Crown Point CLO 6 Ltd.

  Replacement class                  Rating      Amount (mil. $)
  X                                  AAA (sf)               2.50
  A-1                                AAA (sf)             221.50
  A-2                                AAA (sf)              14.00
  B                                  AA (sf)               34.00
  C (deferrable)                     A (sf)                22.50
  D (deferrable)                     BBB- (sf)             19.50
  E (deferrable)                     BB- (sf)              17.00
  F (deferrable)                     B- (sf)                5.20
  Subordinated notes (deferrable)    NR                    37.00

  RATINGS WITHDRAWN
  Newmark Capital Funding 2014-2 CLO Ltd.

                                      Rating
  Class                           To          From
  A-1-R                           NR          AAA (sf)
  A-2A-R                          NR          AAA (sf)
  A-2B-R                          NR          AAA (sf)
  A-F-R                           NR          AAA (sf)
  B-1-R                           NR          AA (sf)
  B-F-R                           NR          AA (sf)
  C-R                             NR          A (sf)
  D                               NR          BBB (sf)
  E                               NR          BB- (sf)

  NR--Not rated.


DEEPHAVEN RESIDENTIAL 2018-4: S&P Gives B Rating on Cl. B-2 Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Deephaven Residential
Mortgage Trust 2018-4's mortgage-backed notes.

The note issuance is first-lien, fixed- and adjustable-rate,
amortizing (with some interest-only and principal balloon payments)
residential mortgage loans secured by single-family residences,
planned-unit developments, two- to four-family residences, and
condominiums to both prime and nonprime borrowers. The pool has 857
loans, which are primarily non-qualified mortgage loans.

The ratings reflect:

-- The pool's collateral composition;
-- The credit enhancement provided for this transaction;
-- The transaction's associated structural mechanics;
-- The transaction's representation and warranty (R&W) framework;
and
-- The mortgage aggregator.

  RATINGS ASSIGNED
  Deephaven Residential Mortgage Trust 2018-4

  Class     Rating       Amount (mil. $)
  A-1       AAA (sf)         232,625,000
  A-2       AA+ (sf)          15,000,000
  A-3       A (sf)            58,736,000
  M-1       BBB (sf)          23,955,000
  B-1       BB (sf)           17,405,000
  B-2       B (sf)            14,410,000
  B-3       NR                12,165,627
  XS        NR                  Notional(i)
  A-IO-S    NR                  Notional(i)
  R         NR                       N/A

(i)Notional amount equals the loans' aggregate stated principal
balance.
NR--Not rated.
N/A--Not applicable.


ELEVATION CLO 2018-10: Moody's Rates $23.5MM Class E Notes 'Ba3'
----------------------------------------------------------------
Moody's Investors Service has assigned ratings to six classes of
notes issued by Elevation CLO 2018-10, Ltd.

Moody's rating action is as follows:

US$1,000,000 Class X Senior Secured Floating Rate Notes due 2031
(the "Class X Notes"), Assigned Aaa (sf)

US$256,000,000 Class A Senior Secured Floating Rate Notes due 2031
(the "Class A Notes"), Assigned Aaa (sf)

US$42,700,000 Class B Senior Secured Floating Rate Notes due 2031
(the "Class B Notes"), Assigned Aa2 (sf)

US$20,500,000 Class C Secured Deferrable Floating Rate Notes due
2031 (the "Class C Notes"), Assigned A2 (sf)

US$25,300,000 Class D Secured Deferrable Floating Rate Notes due
2031 (the "Class D Notes"), Assigned Baa3 (sf)

US$23,500,000 Class E Secured Deferrable Floating Rate Notes due
2031 (the "Class E Notes"), Assigned Ba3 (sf)

The Class X Notes, the Class A Notes, the Class B Notes, the Class
C Notes, the Class D Notes and the Class E Notes are referred to
herein, collectively, as the "Rated Notes."

RATINGS RATIONALE

The ratings reflect the risks due to defaults on the underlying
portfolio of assets, the transaction's legal structure, and the
characteristics of the underlying assets.

Elevation CLO 2018-10 is a managed cash flow CLO. The issued notes
will be collateralized primarily by broadly syndicated senior
secured corporate loans. At least 92.5% of the portfolio must
consist of first lien senior secured loans, cash, and eligible
investments, and up to 7.5% of the portfolio may consist of second
lien loans and unsecured loans. The portfolio is approximately 80%
ramped as of the closing date.

ArrowMark Colorado Holdings LLC will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's five year reinvestment period.
Thereafter, the Manager may reinvest unscheduled principal payments
and proceeds from sales of credit risk assets, subject to certain
restrictions.

In addition to the Rated Notes, the Issuer issued subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $400,000,000

Diversity Score: 60

Weighted Average Rating Factor (WARF): 2806

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.00%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for Elevation CLO 2018-10, Ltd. was assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on Elevation CLO 2018-10, Ltd.. Please
refer to Moody's Request for Comment, titled "Proposed Update to
Moody's Global Approach to Rating Collateralized Loan Obligations,"
for further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.


FLAGSHIP CREDIT 2016: S&P Raises Class D Notes Rating to BB+
------------------------------------------------------------
S&P Global Ratings raised its ratings on 15 classes and affirmed
its ratings on three classes from five Flagship Credit Auto Trust
(FCAT) transactions.

S&P said, "The rating actions reflect collateral performance to
date and our expectations regarding future collateral performance,
as well as each transaction's structure and credit enhancement.
Additionally, we incorporated secondary credit factors, including
credit stability, payment priorities under various scenarios, and
sector- and issuer-specific analysis. Considering all these
factors, we believe the creditworthiness of the notes remains
consistent with the raised and affirmed ratings.

"FCAT's series 2014-2, 2015-1, and 2015-2 are performing better
than our previous revised loss expectations. As a result, we
lowered our loss expectations on these transactions. In addition,
we maintained our loss expectations on FCAT's series 2015-3 and
2016-1, which are performing in line with our initial
expectations."

  Table 1
  Collateral Performance (%)
  As of the November 2018 distribution date

                                Pool    Current    60+ day
  Series                Mo.   factor        CNL    delinq.
  FCAT 2014-2           49     14.22      11.31       5.61
  FCAT 2015-1           44     20.50      11.09       5.93
  FCAT 2015-2           39     25.92      10.07       4.58
  FCAT 2015-3           36     30.72       9.74       4.42
  FCAT 2016-1           33     34.90       8.99       4.21

  Mo.--Month.
  CNL--cumulative net loss.
  FCAT-- Flagship Credit Auto Trust.

  Table 2
  CNL Expectations (%)

                                      Revised           Revised
                   Original          lifetime          lifetime
                   lifetime          CNL exp.          CNL exp.
  Series           CNL exp.       (Aug. 2017)       (Nov. 2018)
  FCAT 2014-2   12.50-13.00       12.00-12.50       Up to 12.00
  FCAT 2015-1   12.50-13.00       12.75-13.25       12.50-13.00
  FCAT 2015-2   11.25-11.75       12.75-13.25       12.25-12.75
  FCAT 2015-3   11.25-11.75       12.75-13.25       12.75-13.25
  FCAT 2016-1   11.75-12.25       12.75-13.25       12.75-13.25
  
  CNL exp.--Cumulative net loss expectations.
  FCAT-- Flagship Credit Auto Trust.

Each transaction contains a sequential principal payment structure
in which the notes are paid principal by seniority. Each also has
credit enhancement in the form of a non-amortizing reserve account,
overcollateralization, subordination for the higher-rated tranches,
and excess spread. Each transaction's reserve amount and
overcollateralization are at the specified target or floor.

In addition, since the transactions closed, the credit support for
each series has increased as a percentage of the amortizing pool
balance. The raised and affirmed ratings reflect our view that the
total credit support as a percentage of the amortizing pool
balance, compared with S&P's expected remaining losses, is
commensurate with each raised or affirmed rating.

  Table 3
  Hard Credit Support (%)
  As of the November 2018 distribution date
                               Total hard      Current total hard
                           credit support          credit support
  Series         Class     at issuance(i)       (% of current)(i)
  FCAT 2014-2    C                   8.75                   57.69
  FCAT 2014-2    D                   5.00                   31.33
  FCAT 2014-2    E                   3.50                   20.81
  FCAT 2015-1    B                  18.25                   88.45
  FCAT 2015-1    C                   8.75                   42.10
  FCAT 2015-1    D                   5.00                   23.81
  FCAT 2015-1    E                   3.50                   16.51
  FCAT 2015-2    B                  17.75                   71.38
  FCAT 2015-2    C                   8.90                   37.23
  FCAT 2015-2    D                   2.50                   12.54
  FCAT 2015-3    A                  28.50                   95.14
  FCAT 2015-3    B                  18.75                   63.40
  FCAT 2015-3    C                   9.90                   34.59
  FCAT 2015-3    D                   3.50                   13.76
  FCAT 2016-1    A                  30.75                   89.10
  FCAT 2016-1    B                  19.85                   57.86
  FCAT 2016-1    C                   9.95                   29.49
  FCAT 2016-1    D                   4.75                   14.59

(i)Calculated as a percentage of the total gross receivable pool
balance, consisting of a reserve account, overcollateralization
and, if applicable, subordination.
FCAT-- Flagship Credit Auto Trust.

S&P said, "We incorporated an analysis of the current hard credit
enhancement compared to the remaining expected cumulative net
losses for those classes in which hard credit enhancement alone
without credit to the expected excess spread was sufficient in our
opinion to upgrade the notes to, or affirm at, 'AAA (sf)'. For the
other classes, we incorporated a cash flow analysis to assess the
loss coverage level, giving credit to excess spread. Our various
cash-flow scenarios included forward-looking assumptions on
recoveries, timing of losses, and voluntary absolute prepayment
speeds that we believe are appropriate given each transaction's
performance to date. Aside from our break-even cash flow analysis,
we also conducted sensitivity analyses for these series to
determine the impact that a moderate ('BBB') stress scenario would
have on our ratings if losses began trending higher than our
revised base-case loss expectation.

"In our view, the results demonstrated that all of the classes have
adequate credit enhancement at the current rating levels. We will
continue to monitor the performance of all of the outstanding
transactions to ensure that the credit enhancement remains
sufficient, in our view, to cover our cumulative net loss
expectations under our stress scenarios for each of the rated
classes."

  RATINGS RAISED

  Flagship Credit Auto Trust
                                Rating
  Series      Class          To            From
  2014-2      C              AAA (sf)      AA (sf)
  2014-2      D              AAA (sf)      A- (sf)
  2014-2      E              AA+ (sf)      BBB (sf)
  2015-1      C              AAA (sf)      A (sf)
  2015-1      D              AA- (sf)      BBB (sf)
  2015-1      E              A (sf)        BB (sf)
  2015-2      B              AAA (sf)      AA+ (sf)
  2015-2      C              AAA (sf)      A- (sf)
  2015-2      D              BBB- (sf)     BB- (sf)
  2015-3      B              AAA (sf)      AA+ (sf)
  2015-3      C              AA+ (sf)      A- (sf)
  2015-3      D              BBB- (sf)     BB- (sf)
  2016-1      B              AAA (sf)      AA (sf)
  2016-1      C              A+ (sf)       BBB (sf)
  2016-1      D              BB+ (sf)      BB- (sf)

  RATINGS AFFIRMED

  Flagship Credit Auto Trust
  Series      Class          Rating
  2015-1      B              AAA (sf)
  2015-3      A              AAA (sf)
  2016-1      A              AAA (sf)


FLAGSHIP CREDIT 2018-4: DBRS Finalizes BB Rating on Class E Notes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of notes issued by Flagship Credit Auto Trust 2018-4 (the
Issuer):

-- $190,780,000 Class A Notes at AAA (sf)
-- $25,480,000 Class B Notes at AA (sf)
-- $33,750,000 Class C Notes at A (sf)
-- $27,300,000 Class D Notes at BBB (sf)
-- $20,090,000 Class E Notes at BB (sf)

The ratings are based on a review by DBRS of the following
analytical considerations:

-- Transaction capital structure, proposed ratings and form and
sufficiency of available credit enhancement.

-- Credit enhancement is in the form of overcollateralization
(OC), subordination, amounts held in the reserve fund and excess
spread. Credit enhancement levels are sufficient to support the
DBRS-projected cumulative net loss assumption under various stress
scenarios.

-- The ability of the transaction to withstand stressed cash flow
assumptions and repay investors according to the terms under which
they have invested. For this transaction, the ratings address the
timely payment of interest on a monthly basis and the payment of
principal by the legal final maturity date.

-- The capabilities of Flagship with regard to originations,
underwriting and servicing.

-- DBRS has performed an operational review of Flagship and
considers the entity to be an acceptable originator and servicer of
subprime automobile loan contracts with an acceptable backup
servicer.

-- The consistent operational history of Flagship and the strength
of the overall company and its management team.

-- The Flagship senior management team has considerable experience
and a successful track record within the auto finance industry.

-- DBRS exclusively used the static-pool approach because Flagship
has enough data to generate a sufficient amount of static-pool
projected losses.

-- DBRS was conservative in the loss forecast analysis that was
performed on the static-pool data, and no seasoning was given to
this collateral.

-- The legal structure and presence of legal opinions that address
the true sale of the assets to the Issuer, the non-consolidation of
the special-purpose vehicle with Flagship, that the trust has a
valid first-priority security interest in the assets and the
consistency with the DBRS "Legal Criteria for U.S. Structured
Finance."

Flagship is an independent full-service automotive financing and
servicing company that provides (1) financing to borrowers who do
not typically have access to prime credit-lending terms for the
purchase of late-model vehicles and (2) refinancing of existing
automotive financing.

The rating on the Class A Notes reflects the 41.00% of initial hard
credit enhancement provided by the subordinated notes in the pool
(37.75%), the reserve account (2.00%) and OC (1.25%). The initial
Class B enhancement is expected to be 30.50% and will include a
2.00% reserve account (funded at inception and non-declining),
initial OC of 1.25% and subordination of 27.25% of the initial pool
balance. The initial Class C enhancement is expected to be 18.25%
and will include a 2.00% reserve account (funded at inception and
non-declining), initial OC of 1.25% and subordination of 15.00% of
the initial pool balance. The initial Class D enhancement is
expected to be 9.00% and will include a 2.00% reserve account
(funded at inception and non-declining), initial OC of 1.25% and
subordination of 5.75% of the initial pool balance. The initial
Class E enhancement is expected to be 3.25% and will include a
2.00% reserve account (funded at inception and non-declining) and
initial OC of 1.25%. Additional credit support may be provided from
excess spread available in the structure.


FLAGSHIP CREDIT 2018-4: S&P Rates $20.9MM Cl. E Notes 'BB-'
-----------------------------------------------------------
S&P Global Ratings assigned its ratings to Flagship Credit Auto
Trust 2018-4's automobile receivables-backed notes.

The note issuance is an asset-backed securities transaction backed
by automobile receivables-backed notes.

The ratings reflect:

-- The availability of approximately 44.7%, 38.6%, 30.1%, 23.3%,
and 19.1% credit support (including excess spread) for the class A,
B, C, D, and E notes, respectively, based on stressed cash flow
scenarios. These credit support levels provide coverage of
approximately 3.50x, 3.00x, 2.30x, 1.75x, and 1.40x S&P's
12.25%-12.75% expected cumulative net loss (CNL) range for the
class A, B, C, D, and E notes, respectively. These break-even
scenarios cover total cumulative gross defaults (using a recovery
assumption of 40%) of approximately 74%, 64%, 50%, 39%, and 32%,
respectively.

-- The timely interest and principal payments made under stressed
cash flow modeling scenarios that are appropriate to the assigned
ratings.

-- S&P said, "The expectation that under a moderate ('BBB') stress
scenario, all else being equal, our ratings on the class A and B
notes would not be lowered by more than one rating category from
our 'AAA (sf)' and 'AA (sf)' ratings, respectively, and our ratings
on the class C and D notes would not be lowered more than two
rating categories from our 'A (sf)' and 'BBB (sf)' ratings,
respectively, throughout the transaction's life. The rating on the
class E notes would remain within two rating categories of our 'BB-
(sf)' rating within the first year, but the class would eventually
default under the 'BBB' stress scenario after receiving 34%-46% of
its principal. The above rating movements are within the
one-category rating tolerance for 'AAA' and 'AA' rated securities
during the first year and three-category tolerance over three
years; a two-category rating tolerance for 'A', 'BBB', and 'BB'
rated securities during the first year; and a three-category
tolerance for 'A' and 'BBB' rated securities over three years. 'BB'
rated securities are permitted to default under a 'BBB' stress
scenario."

-- The credit enhancement in the form of subordination,
overcollateralization, a reserve account, and excess spread.

-- The characteristics of the collateral pool being securitized.

-- The transaction's payment and legal structures.

  RATINGS ASSIGNED

  Flagship Credit Auto Trust 2018-4

  Class      Rating         Amount
                          (mil. $)
  A          AAA (sf)       190.78
  B          AA (sf)         25.48
  C          A (sf)          33.75
  D          BBB (sf)        27.30
  E          BB- (sf)        20.09


FREDDIE MAC 2018-4: DBRS Finalizes B(low) Rating on Class M Certs
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional rating on the following
Mortgage-Backed Security, Series 2018-4 (the Certificate) issued by
Freddie Mac Seasoned Credit Risk Transfer Trust, Series 2018-4 (the
Trust):

-- $63.4 million Class M at B (low) (sf)

The B (low) (sf) rating on the Certificate reflects 4.50% of credit
enhancement provided by subordinated certificates in the pool.

Other than the specified class above, DBRS does not rate any other
classes in this transaction.

This transaction is a securitization of a portfolio of seasoned
re-performing first-lien residential mortgages funded by the
issuance of the certificates, which are backed by 9,782 loans with
a total principal balance of $1,952,043,342 as of the Cut-Off Date
(September 30, 2018).

The mortgage loans were either purchased by Freddie Mac from
securitized Freddie Mac Participation Certificates or retained by
Freddie Mac in whole-loan form since their acquisition. The loans
are currently held in Freddie Mac's retained portfolio and will be
deposited into the Trust on the Closing Date (November 15, 2018).

The portfolio contains 100% modified loans. Each mortgage loan was
modified under either a government-sponsored enterprise (GSE) Home
Affordable Modification Program (HAMP) or a GSE non-HAMP
modification program. Within the pool, 4,631 mortgages have
forborne principal amounts as a result of modification, which
equates to 13.2% of the total unpaid principal balance as of the
Cut-Off Date. For 95% of the modified loans, the modifications
happened more than two years ago. The loans are approximately 143
months seasoned, and all are current as of the Cut-Off Date.
Furthermore, 86.3% of the mortgage loans have been zero times 30
days delinquent for at least the past 24 months under the Mortgage
Bankers Association delinquency methods. None of the loans are
subject to the Consumer Financial Protection Bureau's Qualified
Mortgage rules.

The mortgage loans will be serviced by Specialized Portfolio
Servicing, Inc. There will not be any advancing of delinquent
principal or interest on any mortgages by the Servicer; however,
the Servicer is obligated to advance to third parties any amounts
necessary for the preservation of mortgaged properties or
real-estate¬-owned properties acquired by the Trust through
foreclosure or a loss mitigation process.

Freddie Mac will serve as the Sponsor, Seller and Trustee of the
transaction, as well as Guarantor of the senior certificates (the
Class HT, Class HA, Class HB, Class HV, Class HZ, Class MT, Class
MA, Class MB, Class MV, Class MZ, Class M55D, Class M55E and Class
M55I Certificates). Wilmington Trust, National Association will
serve as the Trust Agent. Wells Fargo Bank, N.A. will serve as the
Custodian for the Trust. U.S. Bank National Association will serve
as the Securities Administrator for the Trust and will act as
Paying Agent, Registrar, Transfer Agent, and Authenticating Agent.

Freddie Mac, as the Seller, will make certain representations and
warranties (R&W) with respect to the mortgage loans. It will be the
only party from which the Trust may seek indemnification (or, in
certain cases, a repurchase) as a result of a breach of R&Ws. If a
breach review trigger occurs during the warranty period, the Trust
Agent, Wilmington Trust, will be responsible for the enforcement of
R&Ws. The warranty period will only be effective through November
12, 2021 (approximately three years from the Closing Date), for
substantially all R&Ws other than the REMIC R&Ws, which will not
expire.

This transaction removes a breach review trigger for loans that are
180 days or more delinquent that existed in previous
securitizations. Other breach review triggers with respect to
foreclosure sale, short sale, deed-in-lieu, charge-off or
modifications are still in effect.

The mortgage loans will be divided into three loan groups: Group H,
Group M and Group M55. The Group H loans (20.6% of the pool) were
subject to step-rate modifications. Group M loans (75.3% of the
pool) and Group M55 loans (4.1% of the pool) were subject to either
fixed-rate modifications or step-rate modifications that have
reached their final step dates as of August 31, 2018, and the
borrowers have made at least one payment after such loans reached
their final step dates as of the Cut-Off Date. Each Group M loan
has a mortgage interest rate less than or equal to 5.5% or has
forbearance. Each Group M55 loan has a mortgage interest rate
greater than 5.5% and has no forbearance. Principal and interest
(P&I) on the senior certificates (the Guaranteed Certificates) will
be guaranteed by Freddie Mac. The Guaranteed Certificates will be
backed by collateral from each group, respectively. The remaining
Certificates (including the subordinate, non-guaranteed,
interest-only mortgage insurance and residual Certificates) will be
cross-collateralized among the three groups.

The transaction employs a pro rata pay cash flow structure with a
sequential-pay feature among the subordinate certificates. Certain
principal proceeds can be used to cover interest shortfalls on the
rated Class M certificates. Senior classes benefit from guaranteed
P&I payments by the Guarantor, Freddie Mac; however, such
guaranteed amounts, if paid, will be reimbursed to Freddie Mac from
the P&I collections prior to any allocation to the subordinate
certificates. The senior principal distribution amounts vary
subject to the satisfaction of a step-down test. Realized losses
are allocated sequentially in reverse order.

The rating reflects transactional strengths that include underlying
assets that have generally performed well through the crisis (86.3%
of the pool has remained consistently current in the past 24
months), good credit quality relative to other re-performing pools
reviewed by DBRS and a strong servicer. Additionally, a third-party
due diligence review, albeit on less than 100% of the portfolio
with respect to regulatory compliance and payment histories, was
performed on a sample that exceeds DBRS's criteria. The due
diligence results and findings on the sampled loans were
satisfactory.

This transaction employs a weak R&W framework that includes a
36-month sunset without an R&W reserve account, substantial
knowledge qualifiers and fewer mortgage loan representations
relative to DBRS's criteria for seasoned pools. In addition, a
breach review trigger for loans that are 180 days or more
delinquent (delinquency review trigger) that existed in previous
securitizations has been removed from this transaction. DBRS
increased loss expectations from the model results to capture the
weaknesses in the R&W framework. Other mitigating factors include
(1) significant loan seasoning and very clean performance history
in the past two years, (2) Freddie Mac as the R&W provider and (3)
a satisfactory third-party due diligence review.

The lack of P&I advances on delinquent mortgages may increase the
possibility of periodic interest shortfalls to the note holders;
however, certain principal proceeds can be used to pay interest to
the rated Certificate, and subordination levels are greater than
expected losses, which may provide for interest payments to the
rated Certificate.


GALTON FUNDING 2018-2: DBRS Finalizes B(low) Rating on Cl. B5 Certs
-------------------------------------------------------------------
DBRS, Inc. finalized the following provisional ratings on the
Mortgage Pass-Through Certificates, Series 2018-2 (the
Certificates) issued by Galton Funding Mortgage Trust 2018-2 (GFMT
2018-2):

-- $411.5 million Class A11 at AA (high) (sf)
-- $411.5 million Class AX11 at AA (high) (sf)
-- $411.5 million Class A12 at AA (high) (sf)
-- $411.5 million Class AX12 at AA (high) (sf)
-- $411.5 million Class A13 at AA (high) (sf)
-- $411.5 million Class AX13 at AA (high) (sf)
-- $362.1 million Class A21 at AAA (sf)
-- $362.1 million Class AX21 at AAA (sf)
-- $362.1 million Class A22 at AAA (sf)
-- $362.1 million Class AX22 at AAA (sf)
-- $362.1 million Class A23 at AAA (sf)
-- $362.1 million Class AX23 at AAA (sf)
-- $49.3 million Class A31 at AA (high) (sf)
-- $49.3 million Class AX31 at AA (high) (sf)
-- $49.3 million Class A32 at AA (high) (sf)
-- $49.3 million Class AX32 at AA (high) (sf)
-- $49.3 million Class A33 at AA (high) (sf)
-- $49.3 million Class AX33 at AA (high) (sf)
-- $289.7 million Class A41 at AAA (sf)
-- $289.7 million Class AX41 at AAA (sf)
-- $289.7 million Class A42 at AAA (sf)
-- $289.7 million Class AX42 at AAA (sf)
-- $289.7 million Class A43 at AAA (sf)
-- $289.7 million Class AX43 at AAA (sf)
-- $72.4 million Class A51 at AAA (sf)
-- $72.4 million Class AX51 at AAA (sf)
-- $72.4 million Class A52 at AAA (sf)
-- $72.4 million Class AX52 at AAA (sf)
-- $72.4 million Class A53 at AAA (sf)
-- $72.4 million Class AX53 at AAA (sf)
-- $54.3 million Class A61 at AAA (sf)
-- $54.3 million Class AX61 at AAA (sf)
-- $54.3 million Class A62 at AAA (sf)
-- $54.3 million Class AX62 at AAA (sf)
-- $54.3 million Class A63 at AAA (sf)
-- $54.3 million Class AX63 at AAA (sf)
-- $18.1 million Class A71 at AAA (sf)
-- $18.1 million Class AX71 at AAA (sf)
-- $18.1 million Class A72 at AAA (sf)
-- $18.1 million Class AX72 at AAA (sf)
-- $18.1 million Class A73 at AAA (sf)
-- $18.1 million Class AX73 at AAA (sf)
-- $411.5 million Class AX at AA (high) (sf)
-- $7.0 million Class B1 at AA (sf)
-- $7.0 million Class BX1 at AA (sf)
-- $13.4 million Class B2 at A (low) (sf)
-- $13.4 million Class BX2 at A (low) (sf)
-- $9.1 million Class B3 at BBB (low) (sf)
-- $5.0 million Class B4 at BB (sf)
-- $3.8 million Class B5 at B (low) (sf)

Classes AX11, AX12, AX13, AX21, AX22, AX23, AX31, AX32, AX33, AX41,
AX42, AX43, AX51, AX52, AX53, AX61, AX62, AX63, AX71, AX72, AX73,
AX, BX1 and BX2 are interest-only (IO) certificates. The class
balances represent notional amounts.

Classes A11, AX11, A12, AX12, A13, AX13, A21, AX21, A22, AX22, A23,
AX23, A31, A32, A41, A42, A51, AX51, A52, AX52, A53, AX53, A61,
A62, A71 and A72 are exchangeable certificates. These classes can
be exchanged for combinations of exchange certificates as specified
in the offering documents.

Classes A41, A42, A43, A61, A62, A63, A71, A72 and A73 are Super
Senior Certificates. These classes benefit from additional
protection from Senior Support Certificates (Classes A31, A32 and
A33) with respect to loss allocation.

The AAA (sf) ratings on the Super Senior Certificates reflect the
20.00% of credit enhancement provided by the Senior Support
Certificates and the Subordinate Certificates in the pool. The AA
(high) (sf), AA (sf), A (low) (sf), BBB (low) (sf), BB (sf) and B
(low) (sf) ratings reflect 9.10%, 7.55% 4.60%, 2.60%, 1.50% and
0.65% of credit enhancement, respectively.

Other than the classes specified above, DBRS does not rate any
other classes in this transaction.

This transaction is a securitization of a portfolio of mostly
expanded prime qualified mortgage (QM), non-QM first-lien
residential mortgages and investor loans. The Certificates are
backed by 583 loans with a total principal balance of $452,664,294
as of the Cut-Off Date (October 1, 2018).

The originators for the mortgage pool are JMAC Lending (25.0%);
LendUS, LLC (9.9%); American Pacific Mortgage Corp. (9.5%);
loanDepot.com, LLC (9.3%); and various other originators, each
comprising less than 5.0% of the mortgage loans.

The loans will be serviced by New Penn Financial, LLC doing
business as Shellpoint Mortgage Servicing. Nationstar Mortgage LLC
will act as the Master Servicer. Galton Mortgage Loan Seller LLC
(the Seller) will act as the Servicing Administrator. Wilmington
Savings Fund Society, FSB, will serve as Trustee. Citibank, N.A.
will act as Securities Administrator. U.S. Bank National
Association will serve as the Custodian.

The mortgages were generally originated pursuant to underwriting
standards that conform to Galton Funding (Galton) acquisition
criteria. Galton has established product matrices for different
loan programs. The majority of the loans in this securitization
(98.5%) are Credit Grade A+ borrowers with unblemished credit who
may not meet prime jumbo or agency/government guidelines. While
certain loan attributes are comparable to those in post-crisis
prime transactions, the loans in the GFMT 2018-2 portfolio may have
IO features, higher debt-to-income (DTI) and loan-to-value (LTV)
ratios, lower credit scores and barbelled distribution of certain
characteristics as compared with recent prime securitizations.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's (CFPB) ability-to-repay rules, they
were made to borrowers who generally do not qualify for agency,
government or private-label non-agency prime jumbo products for
various reasons described above. In accordance with the CFPB QM
rules, 24.4% of the loans are designated as QM Safe Harbor, 7.3% as
QM Rebuttable Presumption and 39.8% as non-QM. Approximately 28.5%
of the loans are not subject to the QM rules.

The transaction employs a senior-subordinate shifting-interest cash
flow structure that incorporates a unique feature in the
calculation of interest entitlements of the Certificates. The
interest entitlements, through the calculation of the net
weighted-average coupon rate, are reduced by the delinquent
interest that would have accrued on the stop advance loans (loans
that become 120 days or more delinquent or loans where the servicer
determines that the principal and interest advance would not be
recoverable). In other words, investors are not entitled to any
interest on such severely delinquent mortgages.

The Servicing Administrator will generally fund advances (to the
extent the available aggregate servicing rights strip has first
been reduced to zero to fund such amounts) of delinquent principal
and interest on any mortgage until such loan becomes 120 days
delinquent or until the servicer determines that an advance is not
recoverable and is obligated to make advances in respect of taxes,
insurance premiums and reasonable costs incurred in the course of
servicing and disposing of properties.

The Sponsor intends to retain 5% of the fair value of all the
Certificates issued by the Issuer (other than the residual
certificates) to satisfy the credit risk retention requirements
under Section 15G of the “Securities Exchange Act of 1934” and
the regulations promulgated thereunder.

The Seller and Sponsor will have the option, but not the
obligation, to repurchase any mortgage loan that becomes 90 or more
days delinquent under the Mortgage Bankers Association delinquency
method until the date on which the Representations and Warranties
(R&W) Enforcement Party delivers the enforcement initiation report,
provided that such repurchases in aggregate do not exceed 10% of
the total principal balance as of the Cut-Off Date.

STRENGTHS

-- Satisfactory Underwriting Standards
-- Robust Pool Composition
-- Third-Party Due Diligence Review
-- Satisfactory Loan Performance to Date (Albeit Short)

CHALLENGES

-- Geographic Concentration
-- Non-QM, QM Rebuttable Presumption and Investor Loans
-- R&W Framework
-- Servicing Administrator's Financial Capability

The DBRS ratings of AAA (sf), AA (high) (sf) and AA (sf) address
the timely payment of interest and full payment of principal by the
legal final maturity date in accordance with the terms and
conditions of the related Certificates. The DBRS ratings of A (low)
(sf), BBB (low) (sf), BB (sf) and B (low) (sf) address the ultimate
payment of interest and full payment of principal by the legal
final maturity date in accordance with the terms and conditions of
the related Certificates.


GS MORTGAGE 2018-FBLU: DBRS Gives Prov. B Rating on Cl. HRR Certs
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2018-FBLU to
be issued by GS Mortgage Securities Corporation Trust 2018-FBLU:

-- Class A at AAA (sf)
-- Class X-CP at AAA (sf)
-- Class X-NCP at AAA (sf)
-- Class B at AAA (sf)
-- Class C at AA (low) (sf)
-- Class D at A (high) (sf)
-- Class E at BBB (low) (sf)
-- Class F at BB (low) (sf)
-- Class G at B (high) (sf)
-- Class HRR at B (sf)

All classes will be privately placed. The Class X-CP and X-NCP
balances are notional. All trends are Stable.

The Fontainebleau Miami Beach is a four-diamond, 1,594-room luxury
resort situated along 15.52 acres of oceanfront property at 4441
Collins Avenue in the mid-beach area of Miami Beach, Florida.
Collateral includes the fee-simple interest in the land and resort
improvements. The total room count includes 748 non-owned
condominium-hotel units, which are not collateral for the loan.
However, historical participation in the hotel's unit rental
program has averaged 84.4% since 2011 up to and including the most
recent trailing 12-month (T-12) period ending September 2018, which
reports a current participation rate of 86.6%. Two major airports
are proximate to the subject, including the Miami International
Airport located ten miles west and Fort Lauderdale-Hollywood
International Airport approximately 21 miles north. Originally
constructed in 1954, the property serves as one of the most
recognizable and architecturally significant resorts in the world,
rich with historical relevance and well known for its extensive
amenity offering. Designed by the distinguished architect, Morris
Lapidus, the resort was added to the U.S. National Register of
Historic Places in December 2008. The subject boasts an impressive
amenity package, including 12 food and beverage (F&B) outlets, 11
pools, 199,763 square feet (sf) of indoor and outdoor meeting
space, six retail shops, a 40,000-sf spa, 5,800-sf fitness center
and 23-slip deep-water marina along the intracoastal side of the
resort. The financing package totals $1.05 billion with $850.0
million structured as first-mortgage debt and $200.0 million
structured as mezzanine debt. The sponsor, Turnberry Associates,
Inc. (Turnberry), originally acquired the subject in 2005 and later
brought in an equity partner, Istithmar Hotels FB Miami LLC
(Istithmar), which took on a 50.0% stake in 2008 for $375.0 million
just prior to completing an extensive $571.8 million ($397,079 per
key) renovation. The collateral was refinanced with subsequent
commercial mortgage-backed security loans in 2012 and again in 2013
with first-mortgage amounts of $412.0 million and $535.0 million,
respectively. The 2013 transaction facilitated the buyout of
Istithmar's 50.0% equity interest, reconsolidating sole ownership
to Turnberry. The subject financing package will retire outstanding
debt of $950.0 million, cover approximately $21.0 million in
closing costs and return $79.0 million of equity to the sponsor.

The property experienced a performance decline in 2016 and 2017,
primarily as a result of the combination of the Zika virus and
Hurricane Irma. This affected the overall Miami Beach submarket and
was not specific to the subject asset. After experiencing 9.4% in
average year-over-year net operating income (NOI) growth from 2011
through 2015, NOI was down 9.9% and 14.5% for 2016 and 2017,
respectively, compared with the 2015 figure. The Centers for
Disease Control and Prevention issued a travel alert in August 2016
identifying numerous cases of Zika reported in several Miami
neighborhoods and recommended avoiding travel to the Miami area.
The travel alert remained in place until June 2017, but the stigma
lingered and continued to affect performance at the subject.
Hurricane Irma, who made landfall in south Florida in September
2017, also severely affected performance at the property. The Smith
Travel Research report indicates that property occupancy and
revenue per available room (RevPAR) in September 2017 declined
41.4% and 32.1%, respectively, compared with metrics reported for
September 2015. The impact was less in October 2017, but still
quite substantial. The sponsor identified more than 11,206 room
nights, equating to $8.0 million in lost revenue, associated with
Irma. As it relates to Zika, the sponsor's insurance policy covered
up to $15.0 million in damages for a single instance of an
infectious disease. As a result, the sponsor performed a thorough
analysis outlining lost business, which was submitted to the
insurance companies. The analysis revealed more than 48,000 lost
room nights, or approximately $26.0 million in lost revenue,
attributed to Zika and the adverse impact on the property. Notably,
the analysis took place at the end of 2016 and, therefore, does not
capture the full impact of 2017 cancellations. Furthermore, neither
analysis accounts for lost F&B revenue associated with the lost
room nights. Insurance proceeds amounting to $15.4 million were
paid out to the sponsor as a result of the Zika and Irma impact.
Performance has bounced back through the T-12 period ending
September 2018 period with RevPAR up 8.8% over the YE2017 figure.
Similarly, NOI has increased 10.1% over the same period. Moderate
RevPAR growth should continue as Zika concerns have curtailed and
as the Miami Beach Convention Center is slated to reopen in
December 2018.

No new incoming supply is identified in the appraisal that would
compete directly with the subject, but the appraiser references the
Turnberry Isle Resort, which is being converted to a JW Marriott by
December 2018, as secondarily competitive, given the conversion.
However, given the non-beachfront location in Aventura, Florida,
and the lower daily rate, Turnberry Isle Resort has been deemed
only 25% competitive with the subject. November 2018 news reports
indicate that Miami Beach voters approved the development of an
800-key hotel that will be constructed adjacent to the Miami Beach
Convention Center. Because of the proposed hotel's non-beachfront
location, convention-based targeted guests and location
approximately two miles south; DBRS does not consider the new
supply a primary competitor to the subject.

At 0.95 times (x), the DBRS refinance debt service coverage ratio
(DSCR) on the mortgage debt is moderately low for a hotel loan,
even one with a high-end product offering and excellent location
such as the subject. Term default risk is considered modest, as
reflected in the DBRS Term DSCR of 1.95x, based on a 2.81% loan
margin and a LIBOR of 2.07% based on the DBRS "Interest Rate
Stresses for U.S. Structured Finance Transactions" methodology,
which is lower than the 3.0% LIBOR strike of the interest-rate cap
in place at closing. The DBRS value of $829.0 million represents a
considerable 53.7% discount to the appraiser's as-is concluded
value of $1.54 billion. Furthermore, the appraisal estimates an
as-stabilized valuation of $1.71 billion by November 2021, which
suggests further upside as capital renovations continue to have a
positive impact on performance at the subject. The DBRS cap rate of
9.75% is well above the cap-rate range between 1.8% and 6.3% in the
appraiser's sales comparable and is likely approximately 400 basis
points above a current market cap rate for the subject. This allows
for a significant buffer against market volatility in the near term
that could result in a widening cap rate and lower trading
activity.

The implied DBRS loan-to-value (LTV) ratio on the full $1.05
billion debt load is high at 126.7%, falling to a still-relatively
high level of 102.5% based on the senior mortgage debt of $850.0
million; however, the cumulative investment-grade-rated proceeds of
$676.0 million reflect a more reasonable LTV of 79.5%. As a result
of the property's irreplaceable location, continued anticipated
increase in RevPAR from the elimination of Zika concerns and
detrimental impact of Irma, lack of competitive new supply and
extensive amenity offerings, including upscale restaurants and a
world-renowned nightclub, DBRS anticipates that the mortgage loan
will perform well during its fully extended five-year term. At
refinance, the highly desirable location, which generates increased
demand for trophy-caliber assets such as the subject, should
provide insulation from market volatility to property value over
the loan term.

Classes X-CP and X-NCP are interest-only (IO) certificates that
reference a single rated tranche or multiple rated tranches. The IO
rating mirrors the lowest-rated applicable reference obligation
tranche adjusted upward by one notch if senior in the waterfall.


INSITE WIRELESS 2018-1: Fitch Rates $22MM Class C Debt 'BB-sf'
--------------------------------------------------------------
Fitch Ratings has issued a presale report on InSite Wireless
Group's InSite Issuer LLC and InSite Co-Issuer Corp. Secured
Cellular Site Revenue Notes, Series 2018-1.

Fitch expects to rate the following classes:

  -- $219,000,000 2018-1 class A 'Asf'; Outlook Stable;

  -- $57,000,000 2018-1 class B 'BBB-sf'; Outlook Stable;

  -- $22,000,000 2018-1 class C 'BB-sf'; Outlook Stable.

It is expected that upon the closing of the 2018 series that the
2018-1 class A is pari passu with the 2016-1 class A; the 2018-1
class B is pari passu with the 2016-1 class B; and the 2018-1 class
C is pari passu with the 2016-1 class C. The new series of
securities will be issued pursuant to a supplement to the indenture
dated Aug. 26, 2013.

The expected ratings are based on information provided by the
issuer as of Nov. 28, 2018.

The transaction is an issuance of notes backed by mortgaged
cellular sites representing approximately 81% of the annualized run
rate net cash flow (excluding DAS assets) and guaranteed by the
direct parent of the co-issuers. The guarantees are secured by a
pledge and first-priority-perfected security interest in 100% of
the equity interest of the co-issuers and their subsidiaries. The
co-issuers and their subsidiaries own or lease 1,568 wireless
communication sites (which includes the rights to operate 21
distributed antennae system networks).

KEY RATING DRIVERS

Trust Leverage: Fitch Ratings' NCF on the pool is $68.1 million
(inclusive of expected cash from the site acquisition account),
implying a Fitch stressed debt service coverage ratio (DSCR) of
1.22x. The debt multiple relative to Fitch's NCF is 8.8x, which
equates to a debt yield of 11.4%.

Technology-Dependent Credit; Rating Cap: Due to the specialized
nature of the collateral and potential for changes in technology to
affect long-term demand for tower space, similar to most wireless
tower transactions, the senior classes of this transaction do not
achieve ratings above 'Asf'. The securities have rated final
payment date 30 years after closing, and the long-term tenor of the
certificates increases the risk that an alternative technology --
rendering obsolete the current transmission of wireless signals
through cellular sites -- will be developed. Currently, wireless
service providers (WSPs) depend on towers to transmit their signals
and continue to invest in this technology.

DAS Networks: The collateral pool contains 21 DAS networks
representing 9.0% of the ARRR. DAS sites are located within
buildings or other structures or venues for which an asset entity
has rights under a lease or license to install and operate a DAS on
the premises or to manage a DAS network on the premises.

Fitch limited proceeds from the DAS networks to the 'BBsf' category
(i.e. applied a 'BBsf' rating cap), based on the uncertainty
surrounding the licensing agreements in a venue-bankruptcy scenario
and the limited history of these networks. (See DAS Sites under the
Asset Analysis section.)

RATING SENSITIVITIES

Fitch evaluated the sensitivity of the ratings for the offered
certificates, and found a 9% decline in NCF would result in a
downgrade of the series 2018-1 class A certificates to 'BBBsf',
while a 18% decline would result in a downgrade to below investment
grade and a 37% decline would result in a downgrade to 'CCCsf'. The
Rating Sensitivity section in the presale report includes a
detailed explanation of additional stresses and sensitivities.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

No third-party due diligence was provided or reviewed in relation
to this rating.


JP MORGAN 2005-CIB11: Moody's Affirms C Rating on Class J Debt
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on three
classes, downgraded the ratings on one class, and affirmed the
ratings on five classes in J.P. Morgan Chase Commercial Mortgage
Securities Corp. Series 2005-CIBC11:

Cl. B, Affirmed Aaa (sf); previously on Nov 22, 2017 Affirmed Aaa
(sf)

Cl. C, Affirmed Aaa (sf); previously on Nov 22, 2017 Affirmed Aaa
(sf)

Cl. D, Affirmed Aaa (sf); previously on Nov 22, 2017 Upgraded to
Aaa (sf)

Cl. E, Upgraded to Aaa (sf); previously on Nov 22, 2017 Upgraded to
Aa1 (sf)

Cl. F, Upgraded to Aa2 (sf); previously on Nov 22, 2017 Upgraded to
A3 (sf)

Cl. G, Upgraded to Baa3 (sf); previously on Nov 22, 2017 Upgraded
to B1 (sf)

Cl. H, Affirmed Caa2 (sf); previously on Nov 22, 2017 Affirmed Caa2
(sf)

Cl. J, Affirmed C (sf); previously on Nov 22, 2017 Affirmed C (sf)


Cl. X-1*, Downgraded to Caa3 (sf); previously on Nov 22, 2017
Affirmed Caa2 (sf)

  * Reflects interest-only classes

RATINGS RATIONALE

The ratings on three principal and interest (P&I) classes Cl. E,
Cl. F and Cl. G were upgraded primarily due to an increase in
credit support since Moody's last review, resulting from paydowns
and amortization. The pool has paid down by 16% since Moody's last
review. In addition, loans which are defeased now constitute 75% of
the pool, up from 65% at Moody's last review.

The ratings on the P&I classes, Cl. B, Cl. C and Cl. D were
affirmed because the transaction's key metrics, including Moody's
loan-to-value (LTV) ratio, Moody's stressed debt service coverage
ratio (DSCR) and the transaction's Herfindahl Index (Herf), are
within acceptable ranges.

The ratings on the P&I classes, Cl. H and Cl. J were affirmed
because the ratings are consistent with Moody's expected loss plus
realized losses.

The rating on the interest-only (IO) class, Cl. X-1, was downgraded
based on the credit quality of the referenced classes following the
paydown of the higher-rated reference classes. The pool has paid
down by 16% since Moody's last review.


Moody's rating action reflects a base expected loss of 2.8% of the
current pooled balance, compared to 6.6% at Moody's last review.
Moody's base expected loss plus realized losses is now 3.4% of the
original pooled balance, compared to 3.5% at the last review.

FACTORS THAT WOULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS:


The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range can
indicate that the collateral's credit quality is stronger or weaker
than Moody's had previously expected.

Factors that could lead to an upgrade of the ratings include a
significant amount of loan paydowns or amortization, an increase in
the pool's share of defeasance or an improvement in pool
performance.

Factors that could lead to a downgrade of the ratings include a
decline in the performance of the pool, loan concentration, an
increase in realized and expected losses from specially serviced
and troubled loans or interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in rating all classes except
interest-only classes was "Moody's Approach to Rating Large Loan
and Single Asset/Single Borrower CMBS" published in July 2017. The
methodologies used in rating interest-only classes were "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in June
2017.

The Credit Rating for J.P. Morgan Chase Commercial Mortgage
Securities Corp. Series 2005-CIBC11, Cl. X-1 was assigned in
accordance with Moody's existing Methodology entitled "Moody's
Approach to Rating Structured Finance Interest-Only (IO)
Securities" dated June 2017. Please note that on November 14, 2018,
Moody's released a Request for Comment, in which it has requested
market feedback on potential revisions to its Methodology for
rating structured finance interest-only (IO) securities. If the
revised Methodology is implemented as proposed, the Credit Rating
on J.P. Morgan Chase Commercial Mortgage Securities Corp. Series
2005-CIBC11, Cl. X-1 may be positively affected. Please refer to
Moody's Request for Comment, titled "Proposed Update to Moody's
Approach to Rating Structured Finance Interest-Only (IO)
Securities" for further details regarding the implications of the
proposed Methodology revisions on certain Credit Ratings.

DEAL PERFORMANCE

As of the November 13, 2018 distribution date, the transaction's
aggregate certificate balance has decreased by 92% to $143 million
from $1.80 billion at securitization. The certificates are
collateralized by 14 mortgage loans ranging in size from less than
1% to 11% of the pool, with the top ten loans (excluding
defeasance) constituting 25% of the pool. Four loans, constituting
75% of the pool, have defeased and are secured by US government
securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 4, compared to 7 at Moody's last review.

Five loans, constituting 9% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Twenty-eight loans have been liquidated from the pool, contributing
to an aggregate realized loss of $57 million (for an average loss
severity of 34%). One loan, constituting 11% of the pool, is
currently in special servicing. The specially serviced loan is the
Shoppes at IV Loan ($15 million) which is secured by a 134,000
square foot (SF) retail center in Paramus, New Jersey. The property
is anchored by Macy's Furniture. The property was 80% occupied as
of December 2017.

Moody's has also assumed a high default probability for one poorly
performing loan, constituting 1% of the pool. Moody's has estimated
a loss of $3.9 million (24% expected loss on average) for the
troubled loan and specially serviced loan.

Moody's received full year 2017 operating results for 100% of the
pool, and full or partial year 2018 operating results for 55% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 61%, compared to 84% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 20% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 9.6%.

Moody's actual and stressed conduit DSCRs are 1.29X and 2.36X,
respectively, compared to 1.32X and 1.70X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 8% of the pool balance. The
largest loan is the Stone Oak Shopping Center Loan ($4 million --
3% of the pool), which is secured by a 35,000 SF retail property
located in San Antonio, Texas. As of December 2017, the property
was 83% leased. The largest tenant, occupying approximately 16% of
the property's net rentable area, operated a restaurant at the
property which is now closed. The lease on the space runs through
May 2020. The loan is on the servicer's watchlist. Moody's LTV and
stressed DSCR are 102% and 1.06X, respectively, compared to 87% and
1.22X at last review.

The second largest loan is the 1075 Northfield Court Loan ($4
million -- 3% of the pool), which is secured by a 152,000 SF
industrial property located in Roswell, Georgia. The property is
currently 100% leased. The loan is on the watchlist due to upcoming
tenant lease expirations. Two tenants occupy the entire leasable
space at the property, occupying approximately 65% and 35% of the
rentable area, respectively. The loan has amortized approximately
24% since securitization. Moody's LTV and stressed DSCR are 70% and
1.39X, respectively, compared to 67% and 1.45X at last review.

The third largest loan is the Arlington Plaza Loan ($3 million --
2% of the pool), which is secured by a 91,000 SF retail center
located in Greenville, North Carolina. Moody's LTV and stressed
DSCR are 57% and 1.99X, respectively, compared to 47% and 2.25X at
the last review.


JP MORGAN 2005-LDP5: Moody's Lowers Class H Debt Rating to Caa2
---------------------------------------------------------------
Moody's Investors Service has downgraded the rating on one class in
J.P. Morgan Chase Commercial Mortgage Securities Corp. Series
2005-LDP5 as follows

Cl. H, Downgraded to Caa2 (sf); previously on Nov 21, 2017
Downgraded to Caa1 (sf)

RATINGS RATIONALE

The rating on the Cl. H was downgraded due to Moody's expected plus
realized losses. Cl. H has experienced a 15% loss following the
recent liquidation of one loan that resulted in a $57.1 million
realized loss to the pool.

Moody's rating action reflects a base expected loss of 2.6% of the
current pooled balance, compared to 36.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 5.8% of the
original pooled balance.

FACTORS THAT WOULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATING:

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range can
indicate that the collateral's credit quality is stronger or weaker
than Moody's had previously expected.

Factors that could lead to an upgrade of the ratings include a
significant amount of loan paydowns or amortization, an increase in
the pool's share of defeasance or an improvement in pool
performance.

Factors that could lead to a downgrade of the ratings include a
decline in the performance of the pool, loan concentration, an
increase in realized and expected losses from specially serviced
and troubled loans or interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in this rating were " Approach to Rating US
and Canadian Conduit/Fusion CMBS" published in July 2017 and
"Moody's Approach to Rating Large Loan and Single Asset/Single
Borrower CMBS" published in July 2017.

DEAL PERFORMANCE

As of the November 15, 2018 distribution date, the transaction's
aggregate certificate balance has decreased by 99.4% to $26.0
million from $4.2 billion at securitization. The certificates are
collateralized by 10 mortgage loans ranging in size from less than
2% to 20% of the pool.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of seven, compared to three at Moody's last review.


Four loans, constituting 24.8% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Twenty-three loans have been liquidated from the pool, resulting in
an aggregate realized loss of $243.8 million (for an average loss
severity of 59%). There are currently no loans in special
servicing.

Moody's received full year 2017 and partial year 2018 operating
results for 100% of the pool (excluding specially serviced and
defeased loans). Moody's weighted average conduit LTV is 66%,
compared to 108% at Moody's last review. Moody's conduit component
excludes loans with structured credit assessments, defeased and CTL
loans, and specially serviced and troubled loans. Moody's net cash
flow (NCF) reflects a weighted average haircut of 22% to the most
recently available net operating income (NOI). Moody's value
reflects a weighted average capitalization rate of 9.4%.

Moody's actual and stressed conduit DSCRs are 1.15X and 1.69X,
respectively, compared to 0.98X and 1.05X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 55.2% of the pool balance.
The largest loan is the Precise Technology, Inc. - Buffalo Grove,
IL Loan ($5.3 million -- 20.2% of the pool), which is secured by a
265,000 SF industrial building located in Buffalo Grove, Illinois
(33 miles north west of the Chicago CBD). The property is fully
leased to Berry Plastics Group through January 31, 2025. The loan
is fully-amortizing, has amortized 50% since securitization and
matures in December 2025. Due to the single tenant exposure,
Moody's utilized a lit/dark analysis. Moody's LTV and stressed DSCR
are 42% and 2.44X, respectively.

The second largest loan is the CVS -- Scottsdale, AZ Loan ($4.7
million -- 18.1% of the pool), which is secured by a 14,000 SF
retail property located in Scottsdale, Arizona. The entire property
is fully leased to CVS Health through January 2025. Due to the
single tenant exposure, Moody's utilized a lit/dark analysis.
Moody's LTV and stressed DSCR are 111% and 0.95X, respectively.

The third largest loan is the Allyne Parke Loan ($4.4 million --
16.9% of the pool), which is secured by a 92,000 SF retail property
located in Greenwood, Indiana. As of October 2018, the property was
97% leased compared to 86% in December 2017. The largest tenant is
Stein Mart, which occupies 36,000 square feet (39% of NRA), with
the lease expiration in May 2019. The loan is on the servicer's
watchlist due low DSCR. The loan is fully-amortizing, has amortized
50% since securitization and matures in December 2025. Moody's LTV
and stressed DSCR are 63% and 1.58X, respectively.


JP MORGAN 2108-MINN: Moody's Assigns (P)B3 Rating on Cl. F Certs
----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to seven
classes of CMBS securities, issued by J.P. Morgan Chase Commercial
Mortgage Securities Trust 2018-MINN, Commercial Mortgage
Pass-Through Certificates, Series 2018-MINN:

Cl. A, Assigned (P)Aaa (sf)

Cl. B, Assigned (P)Aa3 (sf)

Cl. C, Assigned (P)A3 (sf)

Cl. D, Assigned (P)Baa3 (sf)

Cl. E, Assigned (P)Ba3 (sf)

Cl. F, Assigned (P)B3 (sf)

Cl. X-CP*, Assigned (P)A2 (sf)

  * Reflects interest-only class

RATINGS RATIONALE

The Certificates are collateralized by the borrower's leasehold
interest in an 821-room, 24-story full-service hotel known as
Hilton Minneapolis located within the central business district of
Minneapolis, MN, approximately three blocks from the Minneapolis
Convention Center. Its ratings are based on the credit quality of
the loan and the strength of the securitization structure.

Moody's approach to rating this transaction involved the
application of both its Large Loan and Single Asset/Single Borrower
CMBS methodology and its IO Rating methodology. The rating approach
for securities backed by a single loan compares the credit risk
inherent in the underlying collateral with the credit protection
offered by the structure. The structure's credit enhancement is
quantified by the maximum deterioration in property value that the
securities are able to withstand under various stress scenarios
without causing an increase in the expected loss for various rating
levels. In assigning single borrower ratings, Moody's also
considers a range of qualitative issues as well as the
transaction's structural and legal aspects.

The credit risk of commercial real estate loans is determined
primarily by two factors: 1) the probability of default, which is
largely driven by the DSCR, and 2) and the severity of loss in the
event of default, which is largely driven by the LTV of the
underlying loan.

The first mortgage balance of $180,000,000 represents a Moody's LTV
ratio of 151.5% while the Moody's Total Debt Actual DSCR is 1.20X
and Moody's Total Debt Stressed DSCR is 0.77X.

Moody's also considers both loan level diversity and property level
diversity when selecting a ratings approach. The subject
transaction is secured by a single property.

As of the trailing twelve month period ending September 30, 2018,
the property's occupancy rate was 75.9%, average daily rate ("ADR")
was $162.02, and revenue per available room ("RevPAR") was $123.03.
Additionally, the property's occupancy, ADR, and RevPAR penetration
relative to its primary competitive set for the same period were
109.2%, 110.8%, and 120.9%, respectively.

Moody's also grades properties on a scale of 0 to 5 (best to worst)
and considers those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The property's quality
grade is 2.25.

Notable strengths of the transaction include: asset's quality,
strong location, recent renovations, improved operating
performance, strong forward bookings and sponsorship.

Notable concerns of the transaction include: future supply,
leasehold interest, the lack of asset diversification, floating
rate/interest-only mortgage loan profile, property type and credit
negative legal features.

The principal methodology used in rating all classes except
interest-only classes was "Moody's Approach to Rating Large Loan
and Single Asset/Single Borrower CMBS" published in July 2017. The
methodologies used in rating interest-only classes were "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in June
2017.

The Credit Rating for J.P. Morgan Chase Commercial Mortgage
Securities Trust 2018-MINN, Cl. X-CP was assigned in accordance
with Moody's existing Methodology entitled "Moody's Approach to
Rating Structured Finance Interest-Only (IO) Securities" dated June
2017. Please note that on November 14th, 2018, Moody's released a
Request for Comment, in which it has requested market feedback on
potential revisions to its Methodology for rating structured
finance interest-only (IO) securities. If the revised Methodology
is implemented as proposed, the Credit Rating on J.P. Morgan Chase
Commercial Mortgage Securities Trust 2018-MINN, Cl. X-CP may be
neutrally affected. Please refer to Moody's Request for Comment,
titled "Proposed Update to Moody's Approach to Rating Structured
Finance Interest-Only (IO) Securities," for further details
regarding the implications of the proposed Methodology revisions on
certain Credit Ratings.

Moody's approach for single borrower and large loan multi-borrower
transactions evaluates credit enhancement levels based on an
aggregation of adjusted loan level proceeds derived from its
Moody's loan level LTV ratios. Major adjustments to determining
proceeds include leverage, loan structure, and property type. These
aggregated proceeds are then further adjusted for any pooling
benefits associated with loan level diversity, other concentrations
and correlations.

Moody's analysis considers the following inputs to calculate the
proposed IO rating based on the published methodology: original and
current bond ratings and credit estimates; original and current
bond balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology.

These ratings: (a) are based solely on information in the public
domain and/or information communicated to Moody's by the issuer at
the date it was prepared and such information has not been
independently verified by Moody's; (b) must be construed solely as
a statement of opinion and not a statement of fact or an offer,
invitation, inducement or recommendation to purchase, sell or hold
any securities or otherwise act in relation to the issuer or any
other entity or in connection with any other matter. Moody's does
not guarantee or make any representation or warranty as to the
correctness of any information, rating or communication relating to
the issuer. Moody's shall not be liable in contract, tort,
statutory duty or otherwise to the issuer or any other third party
for any loss, injury or cost caused to the issuer or any other
third party, in whole or in part, including by any negligence (but
excluding fraud, dishonesty and/or willful misconduct or any other
type of liability that by law cannot be excluded) on the part of,
or any contingency beyond the control of Moody's, or any of its
employees or agents, including any losses arising from or in
connection with the procurement, compilation, analysis,
interpretation, communication, dissemination, or delivery of any
information or rating relating to the issuer.

Factors that would lead to an upgrade or downgrade of the ratings:


The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range may
indicate that the collateral's credit quality is stronger or weaker
than Moody's had previously anticipated. Factors that may cause an
upgrade of the ratings include significant loan pay downs or
amortization, an increase in the pool's share of defeasance or
overall improved pool performance. Factors that may cause a
downgrade of the ratings include a decline in the overall
performance of the pool, loan concentration, increased expected
losses from specially serviced and troubled loans or interest
shortfalls.

Moody's ratings address only the credit risks associated with the
transaction. Other non-credit risks have not been addressed and may
have a significant effect on yield to investors.

The ratings do not represent any assessment of (i) the likelihood
or frequency of prepayment on the mortgage loans, (ii) the
allocation of net aggregate prepayment interest shortfalls, (iii)
whether or to what extent prepayment premiums might be received, or
(iv) in the case of any class of interest-only certificates, the
likelihood that the holders thereof might not fully recover their
investment in the event of a rapid rate of prepayment of the
mortgage loans.


LB-UBS COMMERCIAL 2005-C7: Fitch Hikes Class F Certs Rating to BBsf
-------------------------------------------------------------------
Fitch Ratings upgrades one class of LB-UBS Commercial Mortgage
Trust commercial mortgage pass-through certificates series
2005-C7.

KEY RATING DRIVERS

Increased Credit Enhancement: The upgrade to class F reflects the
additional paydown with increased credit enhancement since Fitch's
last rating action due to the payoff of the second and third
largest loans totaling $13.5 million; one which prepaid with yield
maintenance and the other prepaid at its open period. As of the
November 2018 distribution date, the pool's aggregate principal
balance has been reduced by 98.7% to $31.3 million from $2.3
billion at issuance. The transaction has realized losses in the
amount of $138.8 million (5.9% of original pool balance).
Cumulative interest shortfalls in the amount of $5.2 million are
currently affecting classes J thru T.

Stable Performance: Overall pool performance and loss expectations
have remained stable since Fitch's last rating action. There are
currently no specially serviced or delinquent loans. Three pooled
loans remain, each of which is a balloon loan collateralized by a
retail property. There is one non-pooled loan collateralized by an
office property; however, Fitch does not rate the non-pooled
classes.

The largest pooled loan, Chesterfield Commons East is secured by an
118,963 sf neighborhood retail center in Chesterfield, MO (St.
Louis County). The shopping center is anchored by Target
(non-collateral), Golf Galaxy, Old Navy, and Pier 1 Imports. The
property is 99.4% occupied as of September 2018 with upcoming
rollover of 2.0% in 2020, 3.3% in 2021, 4.3% in 2022, 3.6% in 2023,
and 29.3% in 2024. The YE 2017 servicer reported debt service
coverage ratio is 1.38x, stable to YE 2016 at 1.36x. The most
recent DSCR as of year-to-date September 2018 is 1.17x.

The second largest loan, Gleneagles is a 38,948 sf neighborhood
retail center in Plano, TX. The largest tenants are Spec's Wine,
Spirits & Finer Foods, Vitamin Shoppe, and Sushi/Japanese
Restaurant. The shopping center is 83.7% occupied as of September
2018 with upcoming rollover of 3.3% in 2019, 20.4% in 2021, 6.6% in
2022, 4.1% in 2023, and 3.2% in 2024. The YE 2017 servicer reported
DSCR is 1.35x up from 1.17x YE 2016. The most recent DSCR as of
September 2018 is 1.33x.

Rating Cap/Increased Pool Concentration: The pool is extremely
concentrated with only three loans remaining, each of which is
collateralized by a retail center located in secondary markets. In
addition, the remaining loans each mature in 2020. The rating of
class F was capped at 'BB' to reflect the pool concentration,
collateral quality of the remaining loans, as well as the refinance
risk in 2020. Fitch's analysis was based on the expected recovery
likelihood of the remaining loans.

RATING SENSITIVITIES

The Stable Outlook on class F reflects sufficient credit
enhancement to the class. Future upgrades are not likely as the
ratings are capped due to the concentrated nature of the pool,
underlying collateral quality and refinance risk in 2020.
Downgrades are possible if pool performance deteriorates or loans
default at maturity.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

No third-party due diligence was provided or reviewed in relation
to this rating action.

Fitch has upgraded the following rating:

  -- $13.9 million class F to 'BBsf' from 'Bsf'; Outlook Stable.

Fitch also affirmed the following ratings:

  -- $17.4 million class G at 'Dsf'; RE 80%;

  -- $0 class H at 'Dsf'; RE 0%;

  -- $0 class J at 'Dsf'; RE 0%;

  -- $0 class K at 'Dsf'; RE 0%;

  -- $0 class L at 'Dsf'; RE 0%;

  -- $0 class M at 'Dsf'; RE 0%;

  -- $0 class N at 'Dsf'; RE 0%;

  -- $0 class P at 'Dsf'; RE 0%;

  -- $0 class Q at 'Dsf'; RE 0%;

  -- $0 class S at 'Dsf'; RE 0%.

The class A-1, A-2, A-3, A-AB, A-4, A-1A, A-M, A-J, B, C, D, E,
CM-1, CM-2, CM-3, and CM-4 certificates have paid in full. Fitch
does not rate the class T certificates. Fitch previously withdrew
the ratings on the interest-only class X-CP and X-CL certificates.

Fitch also does not rate the SP-1 through SP-7 rake classes, which
are specific to the Station Place I $63 million B-note. The senior
A-note for Station Place I was part of the pooled portion of the
trust, which is paid in full.


LCM 28: S&P Assigns BB- Rating on $15.6MM Class E Notes
-------------------------------------------------------
S&P Global Ratings assigned its ratings to LCM 28 Ltd./LCM 28 LLC's
floating-rate notes.

The note issuance is a collateralized loan obligation transaction
backed primarily by broadly syndicated senior secured term loans.

The ratings reflect:

-- The diversified collateral pool, which consists primarily of
broadly syndicated speculative-grade senior secured term loans that
are governed by collateral quality tests.

-- The credit enhancement provided through the subordination of
cash flows, excess spread, and overcollateralization.

-- The collateral manager's experienced team, which can affect the
performance of the rated notes through collateral selection,
ongoing portfolio management, and trading.

-- The transaction's legal structure, which is expected to be
bankruptcy remote.

  RATINGS ASSIGNED

  LCM 28 Ltd./LCM 28 LLC  
  Class                 Rating       Amount (mil. $)
  X                     AAA (sf)                1.50
  A                     AAA (sf)              244.00
  B                     AA (sf)                58.00
  C (deferrable)        A (sf)                 26.00
  D (deferrable)        BBB- (sf)              24.00
  E (deferrable)        BB- (sf)               15.60
  Subordinated notes    NR                     40.80

  NR--Not rated.


MILL CITY 2018-4: DBRS Gives Prov. B(low) Rating on Class B2 Notes
------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the Mortgage Backed
Securities, Series 2018-4 (the Notes) to be issued by Mill City
Mortgage Loan Trust 2018-4 (the Trust) as follows:

-- $302.3 million Class A1A at AAA (sf)
-- $75.5 million Class A1B at AAA (sf)
-- $377.9 million Class A1 at AAA (sf)
-- $410.8 million Class A2 at AA (sf)
-- $450.3 million Class A3 at A (sf)
-- $485.8 million Class A4 at BBB (sf)
-- $33.0 million Class M1 at AA (sf)
-- $39.5 million Class M2 at A (sf)
-- $35.5 million Class M3 at BBB (sf)
-- $41.7 million Class B1 at BB (low) (sf)
-- $36.7 million Class B2 at B (low) (sf)

Classes A1, A2, A3 and A4 are exchangeable notes. These classes can
be exchanged for combinations of exchange notes as specified in the
offering documents.

The AAA (sf) ratings on the Notes reflect 39.80% of credit
enhancement provided by subordinated notes in the pool. The AA
(sf), A (sf), BBB (sf), BB (low) (sf) and B (low) (sf) ratings
reflect 34.55%, 28.25%, 22.60%, 15.95% and 10.10% of credit
enhancement, respectively.

Other than the specified classes above, DBRS does not rate any
other classes in this transaction.

This transaction is a securitization of a portfolio of primarily
first-lien, seasoned, performing and re-performing residential
mortgages funded by the issuance of asset-backed notes (the Notes).
The Notes are backed by 3,214 loans with a total principal balance
of approximately $627,658,650 as of the Cut-Off Date (October 31,
2018).

The loans are approximately 132 months seasoned. As of the Cut-Off
Date, 90.7% of the pool is current, 4.4% is 30 days delinquent,
1.0% is 60 days to 89 days delinquent and 0.5% is 90+ days
delinquent under the Mortgage Bankers Association delinquency
method; 3.3% are in bankruptcy. Approximately 35.1% of the pool has
been zero times 30 (0 x 30) days delinquent for the past 24 months,
61.2% has been 0 x 30 for the past 12 months and 75.0% has been 0 x
30 for the past six months.

Modified loans comprise 78.5% of the portfolio. The modifications
happened more than two years from the Cut-Off Date for 71.4% of the
modified loans. Within the pool, 1,310 loans have
non-interest-bearing deferred amounts, which equates to 10.1% of
the total principal balance. In accordance with the Consumer
Financial Protection Bureau Qualified Mortgage (QM) rules, 7.1% of
the loans are designated as QM Safe Harbor, 0.1% as QM Rebuttable
Presumption and 0.9% as Non-QM. Approximately 91.8% of the loans
are not subject to the QM rules.

Approximately 4.7% of the pool comprises non-first-lien loans.

Through a series of transactions, Mill City Holdings, LLC (Mill
City) will acquire the mortgage loans on the Closing Date. Prior to
the Closing Date, the loans are being held in one or more trusts
that acquired the mortgage loans between May 2012 and September
2018. Such trusts are entities of which the Representation Provider
or an affiliate thereof holds an indirect interest. Upon acquiring
the loans, Mill City, through a wholly owned subsidiary (the
Depositor), will contribute loans to the Trust. As the Sponsor,
Mill City, through a majority-owned affiliate, will acquire and
retain a 5.0% eligible vertical interest in each class of
securities to be issued (other than any residual certificates) to
satisfy the credit risk retention requirements under Section 15G of
the Securities Exchange Act of 1934 and the regulations promulgated
thereunder. These loans were originated and previously serviced by
various entities through purchases in the secondary market.

As of the Cut-Off Date, the loans are serviced by Shellpoint
Mortgage Servicing (81.8%); Fay Servicing, LLC (15.4%); and Select
Portfolio Servicing, Inc. (2.9%). There will not be any advancing
of delinquent principal or interest on any mortgages by the
servicers or any other party to the transaction; however, the
servicers are obligated to make advances in respect of taxes and
insurance, reasonable costs and expenses incurred in the course of
servicing and disposing of properties.

The transaction employs a sequential-pay cash flow structure.
Principal proceeds can be used to cover interest shortfalls on the
Notes, but such shortfalls on Class M2 and more subordinate bonds
will not be paid until the more senior classes are retired.

The lack of principal and interest advances on delinquent mortgages
may increase the possibility of periodic interest shortfalls to the
Note holders; however, principal proceeds can be used to pay
interest to the Notes sequentially, and subordination levels are
greater than expected losses, which may provide for timely payment
of interest to the rated Notes.

A satisfactory third-party due diligence review was performed on
the portfolio with respect to regulatory compliance, payment
history and data capture as well as a title and lien review.
Updated broker price opinions or exterior appraisals were provided
for all but 21 loans in the pool; however, a reconciliation was not
performed on the updated values.

The transaction employs a relatively weak representations and
warranties framework that includes a 13-month sunset, an unrated
provider (CVI CVF III Lux Master S.à.r.l.), certain knowledge
qualifiers and fewer mortgage loan representations relative to DBRS
criteria for seasoned pools. Mitigating factors include (1)
significant loan seasoning, (2) a comprehensive due diligence
review and (3) a representations and warranties enforcement
mechanism, including a loss review trigger and a breach reserve
account.

The DBRS ratings of AAA (sf) and AA (sf) address the timely payment
of interest and full payment of principal by the legal final
maturity date in accordance with the terms and conditions of the
related Notes. The DBRS ratings of A (sf), BBB (sf), BB (low) (sf)
and B (low) (sf) address the ultimate payment of interest and full
payment of principal by the legal final maturity date in accordance
with the terms and conditions of the related Notes.


MORGAN STANLEY 2013-C11: Fitch Cuts $9.6MM Class G Debt Rating to D
-------------------------------------------------------------------
Fitch Ratings has downgraded one and affirms twelve classes of
Morgan Stanley Bank of America Merrill Lynch Trust commercial
mortgage pass-through certificates, series 2013-C11.

KEY RATING DRIVERS

Decline in Credit Enhancement: The affirmations are based on the
overall stable performance of the remaining underlying collateral.
The downgrade of class G is due to losses realized from Matrix
Corporate Center's liquidation as expected. Subsequently, credit
enhancement for the subordinate classes has been sharply reduced
due to losses affecting classes G through J. The largest driver to
losses at the prior rating action was Matrix Corporate Center and
after its liquidation, loss expectations for the pool have also
declined significantly.

One loan (1.3% of the current pool balance) has transferred to
special servicing since Fitch's prior rating action, and six loans
(30.0%), including two regional malls (21.6%), have been designated
as Fitch Loans of Concern. As of the November 2018 distribution
date, the pool's aggregate principal balance has been reduced by
23.2% to $657.6 million from $856.3 million at issuance. Four loans
(8.9%) are currently defeased. Interest shortfalls are currently
affecting the non-rated class J.

Liquidation of Matrix Corporate Center: Matrix Corporate Center,
previously the third largest loan in the pool, was liquidated in
October 2018 with a significant loss after the REO asset sold for
$17.8 million. At the time of the REO sale, the property was 17%
occupied compared with 72% at issuance. After removing expenses and
servicer advances, $46 million in losses were passed through to the
trust. Class balances for classes H and J have been reduced to zero
and class G has also realized losses.

Regional Malls: Three loans (36.7%) are collateralized by regional
malls. The largest loan in the pool, Westfield Countryside (15.1%),
is a regional mall located in Clearwater, FL where Sears, a
non-collateral anchor, closed in July 2018. The box is owned by
Seritage Growth Properties. Sears had previously downsized their
space to accommodate a 37,000 sf Whole Foods, but more than 100,000
sf of space in the box is still vacant. Per the 2Q 2018 rent roll,
the collateral is 81% occupied compared with 92% at YE 2017, 93% at
YE 2016, and 95% at YE 2015. Occupancy has declined due to the
departure of LA Fitness, New York and Company, and several other
small inline tenants.

The Mall at Tuttle Crossing (13.8%) is a 1.1 million sf regional
mall in Dublin, OH in the Columbus metro area and a Fitch Loan of
Concern. Macy's previously operated two non-collateral anchor
stores at this mall but closed one in 2017. Scene 75, an arcade and
entertainment tenant, has leased the vacant box and plans to open
in early 2019. Comparable in-line sales for tenants occupying less
than 10,000 sf were $337 psf in 2017, down from $365 psf in 2016,
and $367 psf at issuance.

Southdale Center (7.8%) is a 1.2 million sf mall in Edina, MN in
the Minneapolis-St. Paul metro area and a Fitch Loan of Concern.
Herberger's (an affiliate of Bon-Ton and collateral anchor) closed
in August 2018 as part of Bon-Ton's bankruptcy proceedings. JC
Penney, a non-collateral anchor, closed in June 2017, leaving only
one anchor (Macy's) open at the mall. Per the June 2018 rent roll
and taking Herberger's vacancy into account, the collateral is
57.4% occupied and the total mall is 71.5% occupied. Despite the
dark anchor spaces, the borrower has undertaken an extensive
redevelopment plan at the property. The former JC Penney box has
been demolished and a 120,000-sf Life Time Fitness and
approximately 35,000 sf of office space will deliver in late 2019.
Additional development on outparcels includes a 146-key Homewood
Suites by Hilton that opened in September 2018; a four-story
Restoration Hardware showroom that is being developed; a 3,800 sf
Shake Shack, which is expected to open in December 2018; and a
three-building, 232-unit multifamily property that opened in July
2015.

Specially Serviced Loan: One loan (1.3%) is in special servicing.
Toys R Us/Babies R Us is a 58,341 sf single-tenant retail building
built in 2012 and located in Royal Palm Beach, FL in the Miami-Fort
Lauderdale metro area. The loan transferred to special servicing in
May 2018 for payment default. Toys 'R' Us previously occupied 100%
of the collateral space but vacated and ceased making rent payments
in April 2018 after filing Chapter 7 bankruptcy in March 2018. The
special servicer is dual-tracking foreclosure and a potential sale
to a third-party owner/user.

Fitch Loans of Concern: Other Fitch Loans of Concern include
Bridgewater Campus (6.3%), a mixed-use property in Bridgewater, NJ
where two of the largest tenants (20.5% of NRA) have leases
expiring in 2019; Autumn Sunrise Apartments (0.6%), an apartment
complex in Houston that sustained significant damage during
Hurricane Harvey; and Walgreens - McAllen, TX (0.3%), a
single-tenant retail building where Walgreens, the single tenant,
has gone dark.

Additional Loss Considerations: Fitch applied an additional
sensitivity scenario of 20% on the Mall at Tuttle Crossing and 25%
on Southdale Center to reflect the potential for outsized losses
given additional vacancy, loss of anchor tenants and weak inline
sales. The Negative Rating Outlooks reflect this scenario.

RATING SENSITIVITIES

The Negative Rating Outlooks on classes B, C, D and E reflect the
potential for outsized losses on the regional malls and specially
serviced loans. Rating Outlooks on classes A-2 through A-S remain
Stable due to the relatively stable performance of the pool.
Downgrades are possible if the performance of the Fitch Loans of
Concern deteriorates or loss expectations increase. Upgrades are
not likely in the near term due to the decline in credit
enhancement, but are possible in the future with additional
defeasance or paydown.

Deutsche Bank is the trustee for the transaction, and also serves
as the backup advancing agent. Fitch's Issuer Default Rating for
Deutsche Bank is currently 'BBB+'/'F2'/Outlook Negative. Fitch
relies on the master servicer, Wells Fargo Bank, N.A., a division
of Wells Fargo & Company (A+/F1/Stable), which is currently the
primary advancing agent, as counterparty. Fitch provided ratings
confirmation on Jan. 24, 2018.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

No third party due diligence was provided to or reviewed by Fitch
in relation to this rating action.

Fitch has downgraded the following rating:

  -- $9.6 million class G to 'Dsf' from 'Csf'; RE 50%.

Fitch has affirmed the following ratings:

  -- $46.1 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $69.2 million class A-AB at 'AAAsf'; Outlook Stable;

  -- $125.0 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $206.4 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $446.8 million class X-A* at 'AAAsf'; Outlook Stable;

  -- $49.2 million class A-S at 'AAAsf'; Outlook Stable;

  -- $61.0 million class B at 'AA-sf'; Outlook Negative;

  -- $144.5 million class PST at 'A-sf'; Outlook Negative;

  -- $34.3 million class C at 'A-sf'; Outlook Negative;

  -- $38.5 million class D at 'BBB-sf'; Outlook Negative;

  -- $9.6 million class E at 'BBsf'; Outlook Negative;

  -- $8.6 million class F at 'CCCsf'; RE: 100%.

  * Notional amount and interest only.

Class A-1 has paid in full. Fitch does not rate the class H, J or
X-B certificates. The class A-S, B, and C certificates may be
exchanged for class PST certificates, and the class PST
certificates may be exchanged for the class A-S, B, and C
certificates.


MORGAN STANLEY 2014-C19: DBRS Confirms B Rating on Class X-F Certs
------------------------------------------------------------------
DBRS, Inc. confirmed the ratings for all classes of Commercial
Mortgage Pass-Through Certificates, Series 2014-C19 issued by
Morgan Stanley Bank of America Merrill Lynch Trust 2014-C19 as
follows:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-S at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class X-A at AAA (sf)
-- Class X-B at AA (high) (sf)
-- Class B at AA (sf)
-- Class X-C at A (sf)
-- Class C at A (low) (sf)
-- Class PST at A (low) (sf)
-- Class X-D at BBB (sf)
-- Class D at BBB (low) (sf)
-- Class X-E at BB (sf)
-- Class E at BB (low) (sf)
-- Class X-F at B (sf)
-- Class F at B (low) (sf)

All trends are Stable. DBRS does not rate the first loss piece,
Class G

The rating confirmations reflect the overall stable performance of
the transaction. As of the November 2018 remittance, 76 of the
original 77 loans remain in the pool with an aggregate principal
balance of $1.43 billion, representing a collateral reduction of
2.7% since issuance as a result of the unscheduled repayment of one
loan and scheduled loan amortization. The transaction benefits from
defeasance, as five loans (including the largest), representing
11.1% of the current pool balance, are secured by defeasance
collateral.

Excluding defeasance collateral, all loans reported YE2017
financials, while 66 loans (79.5% of the pool) have reported
partial-year 2018 financials. Based on the most recent year-end
financial reporting, the transaction had a weighted-average (WA)
debt service coverage ratio (DSCR) and WA Debt Yield of 1.71 times
(x) and 9.5%, respectively, compared with the DBRS WA Term DSCR and
WA Debt Yield of 1.55x and 8.6%, respectively. The largest loans
continue to exhibit stable performance, as excluding defeasance
collateral, the Top 15 loans reported these figures at 1.52x and
7.6%, respectively, which remains unchanged from the previous
year.

As of the November 2018 remittance, there are two loans in special
servicing and 12 loans on the servicer's watch list, representing
2.3% and 20.8% of the current pool balance, respectively. The
Oriental Plaza and Villa Marina Portfolio loan (Prospectus ID#18)
transferred to special servicing in August 2018, as the loan became
delinquent during the prolonged clean up and repair process as the
properties are located in Puerto Rico and suffered severe damage as
a result of Hurricane Maria. The 333 North belt Houston loan
(Prospectus ID#24) transferred to the Special Servicer in September
2018, after the borrower did not comply with the cash sweep
provision, which was triggered after the trailing six-month DSCR
fell below 1.25x. The office property is located in the North belt
submarket of Houston, which has been particularly hit hard by the
decline in the regional oil and gas sector with vacancy rates above
30.0%. The loan remains current at this time.

The two largest loans on the servicer's watch list, TKG Retail
Portfolio (Prospectus ID#3) and the One & Only Ocean Club
(Prospectus ID#8), have been incorrectly flagged for tax payments
in arrears and will be removed, according to the servicer. The
other loans are being monitored for large tenant vacancies,
upcoming tenant rollover, deferred maintenance or declines in
financial performance.

At issuance DBRS shadow-rated the 300 North Lasalle loan
(Prospectus ID#2) as investment grade. DBRS confirmed that the
performance of the loan remains consistent with investment grade
loan characteristics.

Classes X-A, X-B, X-C, X-D, X-E and X-F are interest-only (IO)
certificates that reference a single rated tranche or multiple
rated tranches. The IO rating mirrors the lowest-rated applicable
reference obligation tranche adjusted upward by one notch if senior
in the waterfall.


NASSAU LTD 2018-II: Moody's Rates $30.3MM Class E Notes Ba3
-----------------------------------------------------------
Moody's Investors Service has assigned ratings to five classes of
notes issued by Nassau 2018-II Ltd.

Moody's rating action is as follows:

US$384,000,000 Class A Senior Secured Floating Rate Notes due 2031
(the "Class A Notes"), Assigned Aaa (sf)

US$69,600,000 Class B Senior Secured Floating Rate Notes due 2031
(the "Class B Notes"), Assigned Aa2 (sf)

US$29,400,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2031 (the "Class C Notes"), Assigned A2 (sf)

US$38,700,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2031 (the "Class D Notes"), Assigned Baa3 (sf)

US$30,300,000 Class E Secured Deferrable Floating Rate Notes due
2031 (the "Class E Notes"), Assigned Ba3 (sf)

The Class A Notes, the Class B Notes, the Class C Notes, the Class
D Notes and the Class E Notes are referred to herein, collectively,
as the "Rated Notes."

RATINGS RATIONALE

The ratings reflect the risks due to defaults on the underlying
portfolio of assets, the transaction's legal structure, and the
characteristics of the underlying assets.

Nassau 2018-II is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90% of the portfolio must consist of
senior secured loans, cash, and eligible investments, and up to 10%
of the portfolio may consist of second lien loans, unsecured loans
and first lien last out loans. The portfolio is approximately 80%
ramped as of the closing date.

NCC CLO Manager LLC (the "Manager") will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's five year reinvestment period.
Thereafter, the Manager may reinvest unscheduled principal payments
and proceeds from sales of credit risk assets, subject to certain
restrictions.

In addition to the Rated Notes, the Issuer issued subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $600,000,000

Diversity Score: 75

Weighted Average Rating Factor (WARF): 2898

Weighted Average Spread (WAS): 3.70%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 46.5%

Weighted Average Life (WAL): 9.0 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for Nassau 2018-II Ltd. was assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on Nassau 2018-II Ltd. Please refer to
Moody's Request for Comment, titled "Proposed Update to Moody's
Global Approach to Rating Collateralized Loan Obligations," for
further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.


NATIONAL COLLEGIATE NCT-2003: S&P Keeps CCC- Rating on 2 Tranches
-----------------------------------------------------------------
S&P Global Ratings affirmed its ratings on two classes from
National Collegiate Master Student Loan Trust I's (Master Trust
I's) series NCT-2003. S&P also removed these classes from
CreditWatch, where it placed them with positive implications on
Aug. 22, 2018. The trust is backed by a pool of private student
loans issued between 2001 and 2007.

The affirmations reflect the trust's collateral performance and
relevant structural features--in particular, the trust's cost of
funds, capital structure, payment waterfalls, and available credit
enhancement.

Structural Features

The trust was originally structured with a bond insurance policy
from Ambac Assurance Corp. (Ambac). Since S&P does not rate Ambac,
it does not assume the bond insurance policy provides any support
to the notes. The notes also benefit from a reserve account, which
is currently amortizing. It is available to pay note interest and
fees, as well as principal at final maturity.

At issuance, the trust was structured to provide excess spread over
the transaction's life as additional credit enhancement. Excess
spread levels have been under pressure primarily because of
under-collateralization. Additionally, the trust contains higher
cost auction-rate notes. Coupons on auction-rate notes have been
based on the maximum rate definitions in the indenture (generally
LIBOR plus a rating dependent margin) since the auction-rate market
failed.

Trust Performance

Since S&P's May 2016 full review, the pace of increasing cumulative
defaults has slowed. Additionally, the percentage of loans in
repayment and current has remained stable, holding at approximately
96% as of September 2018. The performance, in terms of the pace of
defaults and the percentage of loans in repayment, indicates that
the trust is likely past its peak default period. The current
performance largely reflects the seasoning of the collateral pools
but also may be partially attributed to stabilization since U.S.
Bank N.A. became special servicer after First Marblehead resigned
in 2012.

  Table 1
  Cumulative Default Rate (%)(i)
                  As of       12-month    As of       12-month
                  March 2016  change(ii)  Sept. 2018  change(ii)
  Master Trust I   27.2          0.7        28.3        0.4

(i)Reported cumulative defaults as a percentage of initial student
loans financed.
(ii)Calculated as the 12-month absolute change in the cumulative
default rate. Master Trust I--National Collegiate Master Student
Loan Trust I.

The historical impact of poor collateral performance, as measured
by high percentages of realized cumulative net losses, has led to a
high level of under-collateralization for the trust. However, for
the two senior most classes (2003-AR-12 and 2003-AR-13), hard
enhancement has grown since our May 2016 review and currently
exceeds 100% for both classes.

  Table 2
  Parity (%)
  Class         March 2016                     September 2018
  AR-12              179.5                              288.4
  AR-13              124.2                              125.8
  AR-14               95.0                               80.4
  AR-15               76.9                               59.1
  AR-16               64.6                               46.8

Cash Flow Modeling Assumptions

S&P ran break-even cash flows that maximized its cumulative net
losses under various interest rate scenarios and rating stress
assumptions. The following are some of the major assumptions S&P
modeled:

-- A five to eight year default curve;

-- Recovery rates ranging from 20% to 25%, taken evenly over 10
years;

-- Flat prepayment speeds of 2% constant prepayment rate (CPR; an
annualized prepayment speed stated as a percentage of the current
loan balance) for the deal's life, and ramped prepayment speeds
starting at 2% CPR and increasing 1% per year to a maximum rate of
5%-7% depending on the rating scenario (constant for the remainder
of the deal's life);

-- Forbearance as percentage of the loan pool of 7.50% for a
maximum 12 months;

-- Stressed interest rate vectors for the various indices; and

-- Auctions that failed for the transaction's life, with
auction-rate coupons based on the maximum rate definitions in the
indenture and the current ratings assigned to the notes.

Rating Rationale

Negative excess spread, due primarily to the level of
under-collateralization, has resulted in continued declines in
total credit enhancement as measured by total parity. S&P placed
the class AR-12 and AR-13 notes on CreditWatch with positive
implications on Aug. 22, 2018, due to growth in class credit
enhancement as measured by class parity and improvements in
collateral performance. Despite the increase in class parity
supporting the class AR-12 and AR-13 notes, the current level of
under-collateralization for all of the notes and the coupon rates
on auction-rate securities affects all of the notes in its stressed
cash flow scenarios. This is primarily because the trust is a
single class structure and accordingly is required to pay interest
pro rata to all of the notes each distribution period. As a result
of the under-collateralization of the notes and resulting negative
excess spread, all of the notes experienced interest shortfalls in
its stressed scenarios.  

S&P said, "Per our criteria, we view an obligation that is
currently vulnerable to repayment and dependent upon favorable
business conditions to meet its financial commitments as falling
within the 'CCC' category. Based on our cash flow results, we
believe the class AR-12 and AR-13 notes are vulnerable to repayment
but not currently under-collateralized. Accordingly, we affirmed
the current 'CCC- (sf)' ratings for these classes. We previously
affirmed the 'CC (sf)' ratings on the remaining notes as we expect
default to be virtually certain given the current
under-collateralization, which is consistent with our criteria.

"We will continue to monitor the ongoing performance of these
trusts. In particular, we will continue to review available credit
enhancement, which is primarily a function of the pace of defaults,
principal amortization, and excess spread."

  RATINGS AFFIRMED AND REMOVED FROM CREDITWATCH POSITIVE

  National Collegiate Master Student Loan Trust I series NCT-2003
                         Rating
  Class         To               From
  AR-12         CCC- (sf)        CCC- (sf)/Watch Pos
  AR-13         CCC- (sf)        CCC- (sf)/Watch Pos


NATIONSTAR HECM 2018-3: Moody's Rates Class M4 Debt 'Ba3(sf)'
-------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to five
classes of residential mortgage-backed securities issued by
Nationstar HECM Loan Trust 2018-3. The ratings range from Aaa (sf)
to Ba3 (sf).

The certificates are backed by a pool that includes 1,369 inactive
home equity conversion mortgages and 200 real estate owned
properties. The servicer for the deal is Nationstar Mortgage LLC.
The complete rating actions are as follows:

Issuer: Nationstar HECM Loan Trust 2018-3

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. M1, Definitive Rating Assigned Aa3 (sf)

Cl. M2, Definitive Rating Assigned A3 (sf)

Cl. M3, Definitive Rating Assigned Baa3 (sf)

Cl. M4, Definitive Rating Assigned Ba3 (sf)

RATINGS RATIONALE

The collateral backing NHLT 2018-3 consists of first-lien inactive
HECMs covered by Federal Housing Administration (FHA) insurance
secured by properties in the US along with Real-Estate Owned (REO)
properties acquired through conversion of ownership of reverse
mortgage loans that are covered by FHA insurance. If a borrower or
their estate fails to pay the amount due upon maturity or otherwise
defaults, the sale of the property is used to recover the amount
owed. Nationstar acquired the mortgage assets from Ginnie Mae
sponsored HECM mortgage backed securitizations. All of the mortgage
assets are covered by FHA insurance for the repayment of principal
up to certain amounts.

There are 1,569 mortgage assets with a balance of $364,327,641. The
assets are in either default, due and payable, referred,
foreclosure or REO status. Loans that are in default may move to
due and payable; due and payable loans may move to foreclosure; and
foreclosure loans may move to REO. 33.3% of the assets are in
default of which 0.04% (of the total assets) are in default due to
non-occupancy and the remaining are in default due to delinquent
taxes and insurance. 19.2% of the assets are due and payable, 32.9%
of the assets are in foreclosure and 1.7% of the assets are in
referred status. Finally, 12.3% of the assets are REO properties
and were acquired through foreclosure or deed-in-lieu of
foreclosure on the associated loan. If the value of the related
mortgaged property is greater than the loan amount, some of these
loans may be settled by the borrower or their estate.

The collateral composition of NHLT 2018-3 is different from that of
NHLT 2018-2 in several key respects. First, NHLT 2018-3 has a lower
percentage of loans in default and due-and-payable status and a
higher percentage of loans in REO status. In addition, a relatively
large percentage of the collateral in NHLT 2018-3 is inactive due
to tax and/or insurance delinquencies (67.7%). Furthermore, the
weighted average loan-to-value ratio, at 126.1%, is significantly
higher than NHLT 2018-2 transaction. This suggests that borrowers
in this pool tend to have lower equity in their homes compared
which may lead to lower cure and repayment rates.

As with most NHLT transactions Moody's has rated, the pool has a
significant concentration of mortgage assets backed by properties
in New York, New Jersey and Florida. Such states are judicial
foreclosure states with long foreclosure timelines. Also, there are
14 assets (0.7% of the asset balance) in NHLT 2018-3 that are
backed by properties in Puerto Rico, which is still recovering from
Hurricane Maria and suffering from poor economic conditions due to
a public debt crisis and continued out-migration. Its credit
ratings reflect state-specific foreclosure timeline stresses as
well as adjustments for risks associated with the real estate
market in Puerto Rico.

Nationstar has noted that six properties in the pool were in
hurricane Michael and Florence disaster areas. Of these six, five
properties had no damage from the property inspection reports and
one property is still unknown. Moody's made a small adjustment to
account for this property. There are 20 loans backed by properties
located in FEMA declared disaster counties affected by the recent
wildfires in California, representing 2.4% by balance and 1.3% by
loan count of the total pool. Nationstar will order property
inspection reports for properties in FEMA designated areas. In
addition, there are property level representations & warranties
that no mortgaged property has suffered damages due to fire, flood,
windstorm, earthquake, tornado, hurricane, or any other damages.

Transaction Structure

The securitization has a sequential liability structure amongst six
classes of notes with structural subordination. All funds
collected, prior to an acceleration event, are used to make
interest payments to the notes, then principal payments to the
Class A notes, then to a redemption account until the amount on
deposit in the redemption account is sufficient to cover future
principal and interest payments for the subordinate notes up to
their expected final payment dates. The subordinate notes will not
receive principal until the beginning of their respective target
amortization periods (in the absence of an acceleration event). The
notes benefit from structural subordination as credit enhancement,
and an interest reserve account funded with cash received from the
initial purchasers of the notes for liquidity and credit
enhancement.

The transaction is callable on or after six months with a 1.0%
premium and on or after 12 months without a premium. The mandatory
call date for the Class A notes is in November 2020. For the Class
M1 notes, the expected final payment date is in June 2021. For the
Class M2 notes, the expected final payment date is in September
2021. For the Class M3 notes, the expected final payment date is in
November 2021. For the Class M4 notes, the expected final payment
date is in March 2022. Finally, for the Class M5 notes, the
expected final payment date is in October 2022. For each of the
subordinate notes, there are target amortization periods that
conclude on the respective expected final payment dates. The legal
final maturity of the transaction is 10 years.

Available funds to the transaction are expected to primarily come
from the liquidation of REO properties and receipt of FHA insurance
claims. These funds will be received with irregular timing. In the
event that there are insufficient funds to pay interest in a given
period, the interest reserve account may be utilized. Additionally,
any shortfall in interest will be classified as an available funds
cap shortfall. These available funds cap carryover amounts will
have priority of payments in the waterfall and will also accrue
interest at the respective note rate.

Certain aspects of the waterfall are dependent upon Nationstar
remaining as servicer. Servicing fees and servicer related
reimbursements are subordinated to interest and principal payments
while Nationstar is servicer. However, servicing advances will
instead have priority over interest and principal payments in the
event that Nationstar defaults and a new servicer is appointed.

Third-Party Review

A third party firm conducted a review of certain characteristics of
the mortgage assets on behalf of Nationstar. The review focused on
data integrity, FHA insurance coverage verification, accuracy of
appraisal recording, accuracy of occupancy status recording,
borrower age documentation, identification of excessive corporate
advances, documentation of servicer advances, and identification of
tax liens with first priority in Texas. Also, broker price opinions
(BPOs) were ordered for 286 properties in the pool.

The TPR firm conducted an extensive data integrity review. Certain
data tape fields, such as the mortgage insurance premium (MIP)
rate, the current UPB, current interest rate, and marketable title
date were reviewed against Nationstar's servicing system. However,
a significant number of data tape fields were reviewed against
imaged copies of original documents of record, screen shots of
HUD's HERMIT system, or HUD documents. Some key fields reviewed in
this manner included the original note rate, the debenture rate,
foreclosure first legal date, and the called due date.

The results of the third-party review are comparable to previous
NHLT transactions in many respects. However, the number of
exceptions related to the accuracy of reported valuations, and
foreclosure and bankruptcy attorney fees was higher than in most
other recently rated NHLT transactions. NHLT 2018-3's TPR results
showed an 7.8% initial-tape exception rate related to the accuracy
of reported valuations and a 36.2% initial-tape exception rate
related to foreclosure and bankruptcy attorney fees. In its
analysis of the pool, Moody's applied adjustments to account for
the TPR results in certain areas.

Reps & Warranties (R&W)

Nationstar is the loan-level R&W provider and is rated B2 (Stable).
This relatively weak financial profile is mitigated by the fact
that Nationstar will subordinate its servicing advances, servicing
fees, and MIP payments in the transaction and thus has significant
alignment of interests. Another factor mitigating the risks
associated with a financially weak R&W provider is that a
third-party due diligence firm conducted a review on the loans for
evidence of FHA insurance.

Nationstar represents that the mortgage loans are covered by FHA
insurance that is in full force and effect. Nationstar provides
further R&Ws including those for title, first lien position,
enforceability of the lien, and the condition of the property.
Although Nationstar provides a no fraud R&W covering the
origination of the mortgage loans, determination of value of the
mortgaged properties, and the sale and servicing of the mortgage
loans, the no fraud R&W is made only as to the initial mortgage
loans. Aside from the no fraud R&W, Nationstar does not provide any
other R&W in connection with the origination of the mortgage loans,
including whether the mortgage loans were originated in compliance
with applicable federal, state and local laws. Although certain
representations are knowledge qualified, the transaction documents
contain language specifying that if a representation would have
been breached if not for the knowledge qualifier then Nationstar
will repurchase the relevant asset as if the representation had
been breached.

Upon the identification of an R&W breach, Nationstar has to cure
the breach. If Nationstar is unable to cure the breach, Nationstar
must repurchase the loan within 90 days from receiving the
notification. Moody's believes the absence of an independent third
party reviewer who can identify any breaches to the R&W makes the
enforcement mechanism weak in this transaction. Also, Nationstar,
in its good faith, is responsible for determining if a R&W breach
materially and adversely affects the interests of the trust or the
value the collateral. This creates the potential for a conflict of
interest.

When analyzing the transaction, Moody's reviewed the transaction's
exposure to large potential indemnification payments owed to
transaction parties due to potential lawsuits. In particular,
Moody's assessed the risk that the acquisition trustee would be
subject to lawsuits from investors for a failure to adequately
enforce the R&Ws against the seller. Moody's believes that NHLT
2018-3 is adequately protected against such risk in part because a
third-party data integrity review was conducted on a significant
random sample of the loans. In addition, the third-party due
diligence firm verified that all of the loans in the pool are
covered by FHA insurance.

Trustee & Master Servicer

The acquisition and owner trustee for the NHLT 2018-3 transaction
is Wilmington Savings Fund Society, FSB. The paying agent and cash
management functions will be performed by U.S. Bank National
Association. U.S. Bank National Association will also serve as the
claims payment agent and as such will be the HUD mortgagee of
record for the mortgage assets in the pool.

Methodology

The methodologies used in these ratings were "Moody's Approach to
Rating Securitisations Backed by Non-Performing and Re-Performing
Loans" published in August 2016 and "Moody's Global Approach to
Rating Reverse Mortgage Securitizations" published in May 2015.

The Credit Rating for NHLT 2018-3 was assigned in accordance with
Moody's existing Methodologies entitled "Moody's Approach to Rating
Securitizations Backed by Non-Performing and Re-Performing Loans,"
dated August 2, 2016 and "Moody's Global Approach to Rating Reverse
Mortgage Securitizations," dated May 27, 2015. Please note that on
November 14, 2018, Moody's released a Request for Comment, in which
it has requested market feedback on potential revisions to its
Methodology for securitizations backed by non-performing and
re-performing loans. If the revised Methodology is implemented as
proposed, the Credit Rating on NHLT 2018-3 may be neutrally
affected. Please refer to Moody's Request for Comment, titled
"Proposed Update to Moody's Approach to Rating Securitizations
Backed by Non-Performing and Re-Performing Loans," for further
details regarding the implications of the proposed Methodology
revisions on certain Credit Ratings.

Its quantitative asset analysis is based on a loan-by-loan modeling
of expected payout amounts given the structure of FHA insurance and
with various stresses applied to model parameters depending on the
target rating level.

FHA insurance claim types: funds come into the transaction
primarily through the sale of REO properties and through FHA
insurance claim receipts. There are uncertainties related to the
extent and timing of insurance proceeds received by the trust due
to the mechanics of the FHA insurance. HECM mortgagees may suffer
losses if a property is sold for less than its appraised value.

The amount of insurance proceeds received from the FHA depends on
whether a sales based claim (SBC) or appraisal based claim (ABC) is
filed. SBCs are filed in cases where the property is successfully
sold within the first six months after the servicer has acquired
marketable title to the property. ABCs are filed six months after
the servicer has obtained marketable title if the property has not
yet been sold. For an SBC, HUD insurance will cover the difference
between (i) the loan balance and (ii) the higher of the sales price
and 95.0% of the latest appraisal, with the transaction on the hook
for losses if the sales price is lower than 95.0% of the latest
appraisal. For an ABC, HUD only covers the difference between the
loan amount and 100% of appraised value, so failure to sell the
property at the appraised value results in loss.

Moody's expects ABCs to have higher levels of losses than SBCs. The
fact that there is a delay in the sale of the property usually
implies some adverse characteristics associated with the property.
FHA insurance will not protect against losses to the extent that an
ABC property is sold at a price lower than the appraisal value
taken at the six month mark of REO. Additionally, ABCs do not cover
the cost to sell properties (broker fees) while SBCs do cover these
costs. For SBCs, broker fees are reimbursable up to 6.0%
ordinarily. Its base case expectation is that properties will be
sold for 13.5% less than their appraisal value for ABCs. This is
based on the historical experience of Nationstar. Moody's stressed
this percentage at higher credit rating levels. At a Aaa rating
level, Moody's assumed that ABC appraisal haircuts could reach up
to 30.0%.

In its asset analysis, Moody's also assumed there would be some
losses for SBCs, albeit lower amounts than for ABCs. Based on
historical performance, in the base case scenario Moody's assumed
that SBCs would suffer 1.0% losses due to a failure to sell the
property for an amount equal to or greater than 95.0% of the most
recent appraisal. Moody's stressed this percentage at higher credit
rating levels. At a Aaa rating level, Moody's assumed that SBC
appraisal haircuts could reach up to 11.0% (i.e., 6.0% below
95.0%).

Under its analytical approach, each loan is modeled to go through
both the ABC and SBC process with a certain probability. Each loan
will thus have both of the sales disposition payments and
associated insurance payments (four payments in total). All
payments are then probability weighted and run through a modeled
liability structure. Based on the historical experience of
Nationstar, for the base case scenario Moody's assumed that 85% of
claims would be SBCs and the rest would be ABCs. Moody's stressed
this assumption and assumed higher ABC percentages for higher
rating levels. At a Aaa rating level, Moody's assumed that 85% of
insurance claims would be submitted as ABCs.

Liquidation process: each mortgage asset is categorized into one of
four categories: default, due and payable, foreclosure and REO. In
its analysis, Moody's assumes loans that are in referred status to
be either in foreclosure or REO category. The loans are assumed to
move through each of these stages until being sold out of REO.
Moody's assumed that loans would be in default status for six
months. Due and payable status is expected to last six to 12 months
depending on the default reason. Foreclosure status is based on the
state in which that the related property is located and is further
stressed at higher rating levels. The base case foreclosure
timeline is based on FHA timeline guidance. REO disposition is
assumed to take place in six months with respect to SBCs and 12
months with respect to ABCs.

Debenture interest: the receipt of debenture interest is dependent
upon performance of certain actions within certain timelines by the
servicer. If these timeline and performance benchmarks are not met
by the servicer, debenture interest is subject to curtailment. Its
base case assumption is that 95.0% of debenture interest will be
received by the trust. Moody's stressed the amount of debenture
interest that will be received at higher rating levels. Its
debenture interest assumptions reflect the requirement that
Nationstar (B2, Stable) reimburse the trust for debenture interest
curtailments due to servicing errors or failures to comply with HUD
guidelines.

Additional model features: Moody's incorporated certain additional
considerations into its analysis, including the following:

  -- In most cases, the most recent appraisal value was used as the
property value in its analysis. However, for seasoned appraisals
Moody's applied a 15.0% haircut to account for potential home price
depreciation between the time of the appraisal and the cut-off
date.

  -- Mortgage loans with borrowers that have significant equity in
their homes are likely to be paid off by the borrowers or their
heirs rather than complete the foreclosure process. Moody's
estimated which loans would be bought out of the trust by comparing
each loans' appraisal value (post haircut) to its UPB.

  -- Moody's assumed that foreclosure costs will average $4,500 per
loan, two thirds of which will be reimbursed by the FHA. Moody's
then applied a negative adjustment to this amount based on the TPR
results.

  -- Moody's estimated monthly tax and insurance advances based on
cumulative tax and insurance advances to date.

Moody's ran additional stress scenarios that were designed to mimic
expected cash flows in the case where Nationstar is no longer the
servicer. Moody's assumes the following in the situation where
Nationstar is no longer the servicer:

  -- Servicing advances and servicing fees: While Nationstar
subordinates their recoupment of servicing advances, servicing
fees, and MIP payments, a replacement servicer will not subordinate
these amounts.

  -- Nationstar indemnifies the trust for lost debenture interest
due to servicing errors or failure to comply with HUD guidelines.
In the event of a bankruptcy, Nationstar will not have the
financial capacity to do so.

  -- A replacement servicer may require an additional fee and thus
Moody's assumes a 25 bps strip will take effect if the servicer is
replaced.

  -- One third of foreclosure costs will be removed from sales
proceeds to reimburse a replacement servicer (one third of
foreclosure costs are not reimbursable under FHA insurance). This
is typically on the order of $1,500 per loan.

Factors that would lead to an upgrade or downgrade of the ratings:


Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of stress could
drive the ratings up. Transaction performance depends greatly on
the US macro economy and housing market. Property markets could
improve from its original expectations resulting in appreciation in
the value of the mortgaged property and faster property sales.

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of stresses could drive the
ratings down. Transaction performance depends greatly on the US
macro economy and housing market. Property markets could
deteriorate from its original expectations resulting in
depreciation in the value of the mortgaged property and slower
property sales.


NEW RESIDENTIAL 2018-5: DBRS Gives Prov. B(high) on 10 Tranches
---------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following
Mortgage-Backed Notes, Series 2018-5 (the Notes) to be issued by
New Residential Mortgage Loan Trust 2018-5 (NRMLT or the Trust):

-- $290.7 million Class A at AAA (sf)
-- $290.7 million Class A-1 at AAA (sf)
-- $290.7 million Class A-IO at AAA (sf)
-- $290.7 million Class A-1A at AAA (sf)
-- $290.7 million Class A-1B at AAA (sf)
-- $290.7 million Class A-1C at AAA (sf)
-- $290.7 million Class A1-IOA at AAA (sf)
-- $290.7 million Class A1-IOB at AAA (sf)
-- $290.7 million Class A1-IOC at AAA (sf)
-- $317.6 million Class A-2 at AA (high) (sf)
-- $26.9 million Class B-1 at AA (high) (sf)
-- $26.9 million Class B1-IO at AA (high) (sf)
-- $26.9 million Class B-1A at AA (high) (sf)
-- $26.9 million Class B-1B at AA (high) (sf)
-- $26.9 million Class B-1C at AA (high) (sf)
-- $26.9 million Class B-1D at AA (high) (sf)
-- $26.9 million Class B1-IOA at AA (high) (sf)
-- $26.9 million Class B1-IOB at AA (high) (sf)
-- $26.9 million Class B1-IOC at AA (high) (sf)
-- $20.9 million Class B-2 at A (high) (sf)
-- $20.9 million Class B2-IO at A (high) (sf)
-- $20.9 million Class B-2A at A (high) (sf)
-- $20.9 million Class B-2B at A (high) (sf)
-- $20.9 million Class B-2C at A (high) (sf)
-- $20.9 million Class B-2D at A (high) (sf)
-- $20.9 million Class B2-IOA at A (high) (sf)
-- $20.9 million Class B2-IOB at A (high) (sf)
-- $20.9 million Class B2-IOC at A (high) (sf)
-- $21.6 million Class B-3 at BBB (high) (sf)
-- $21.6 million Class B3-IO at BBB (high) (sf)
-- $21.6 million Class B-3A at BBB (high) (sf)
-- $21.6 million Class B-3B at BBB (high) (sf)
-- $21.6 million Class B-3C at BBB (high) (sf)
-- $21.6 million Class B-3D at BBB (high) (sf)
-- $21.6 million Class B3-IOA at BBB (high) (sf)
-- $21.6 million Class B3-IOB at BBB (high) (sf)
-- $21.6 million Class B3-IOC at BBB (high) (sf)
-- $12.1 million Class B-4 at BB (high) (sf)
-- $12.1 million Class B-4A at BB (high) (sf)
-- $12.1 million Class B-4B at BB (high) (sf)
-- $12.1 million Class B-4C at BB (high) (sf)
-- $12.1 million Class B4-IOA at BB (high) (sf)
-- $12.1 million Class B4-IOB at BB (high) (sf)
-- $12.1 million Class B4-IOC at BB (high) (sf)
-- $8.4 million Class B-5 at B (high) (sf)
-- $8.4 million Class B-5A at B (high) (sf)
-- $8.4 million Class B-5B at B (high) (sf)
-- $8.4 million Class B-5C at B (high) (sf)
-- $8.4 million Class B-5D at B (high) (sf)
-- $8.4 million Class B5-IOA at B (high) (sf)
-- $8.4 million Class B5-IOB at B (high) (sf)
-- $8.4 million Class B5-IOC at B (high) (sf)
-- $8.4 million Class B5-IOD at B (high) (sf)
-- $20.5 million Class B-7 at B (high) (sf)

Classes A-IO, A1-IOA, A1-IOB, A1-IOC, B1-IO, B1-IOA, B1-IOB,
B1-IOC, B2-IO, B2-IOA, B2-IOB, B2-IOC, B3-IO, B3-IOA, B3-IOB,
B3-IOC, B4-IOA, B4-IOB, B4-IOC, B5-IOA, B5-IOB, B5-IOC and B5-IOD
are interest-only notes. The class balances represent notional
amounts.

Classes A, A-1A, A-1B, A-1C, A1-IOA, A1-IOB, A1-IOC, A-2, A-3, A-4,
A-5, A-6, IO, B-1A, B-1B, B-1C, B-1D, B1-IOA, B1-IOB, B1-IOC, B-2A,
B-2B, B-2C, B-2D, B2-IOA, B2-IOB, B2-IOC, B-IO, B-3A, B-3B, B-3C,
B3-IOA, B3-IOB, B3-IOC, B-4A, B-4B, B-4C, B4-IOA, B4-IOB, B4-IOC,
B-5A, B-5B, B-5C, B-5D, B5-IOA, B5-IOB, B5-IOC, B5-IOD and B-7 are
exchangeable notes. These classes can be exchanged for combinations
of initial exchangeable notes as specified in the offering
documents.

The AAA (sf) ratings on the Notes reflect the 29.20% of credit
enhancement provided by subordinated notes in the pool. The AA
(high) (sf), A (high) (sf), BBB (high) (sf), BB (high) (sf) and B
(high) (sf) ratings reflect 22.65%, 17.55%, 12.30%, 9.35% and 7.30%
of credit enhancement, respectively.

Other than the specified classes above, DBRS does not rate any
other classes in this transaction.

This transaction is a securitization of a portfolio of seasoned
performing and re-performing first-lien residential mortgages. The
Notes are backed by 3,263 loans with a total principal balance of
$410,632,671 as of the Statistical Calculation Date (October 1,
2018).

The loans are significantly seasoned with a weighted-average age of
160 months. As of the Statistical Calculation Date, 88.3% of the
pool is current, 10.4% is 30 days delinquent under the Mortgage
Bankers Association (MBA) delinquency method and 1.3% is in
bankruptcy (all bankruptcy loans are performing or 30 days
delinquent). Approximately 71.0% and 76.3% of the mortgage loans
have been zero times 30 days delinquent for the past 24 months and
12 months, respectively, under the MBA delinquency method. The
portfolio contains 36.6% modified loans. The modifications happened
more than two years ago for 76.0% of the modified loans. As a
result of the seasoning of the collateral, none of the loans are
subject to the Consumer Financial Protection Bureau
Ability-to-Repay/Qualified Mortgage rules.

The Seller, NRZ Sponsor V LLC (NRZ), acquired the loans prior to
the Closing Date in connection with the termination of various
securitization trusts. Upon acquiring the loans, NRZ, through an
affiliate, New Residential Funding 2018-5 LLC (the Depositor), will
contribute the loans to the Trust. As the Sponsor, New Residential
Investment Corp., through a majority-owned affiliate, will acquire
and retain a 5% eligible vertical interest in each class of
securities to be issued (other than the residual notes) to satisfy
the credit risk retention requirements under Section 15G of the
“Securities Exchange Act of 1934” and the regulations
promulgated thereunder. These loans were originated and previously
serviced by various entities through purchases in the secondary
market.

As of the Statistical Calculation Date, 37.6% of the pool is
serviced by Nationstar Mortgage LLC (Nationstar), 29.1% of the pool
is serviced by Shellpoint Mortgage Servicing (SMS), 10.6% by Ocwen
Loan Servicing, 8.5% by TIAA Bank, FSB, 5.8% Wells Fargo Bank, N.A.
(rated AA with a Stable trend by DBRS), 3.7% by Specialized Loan
Servicing, LLC, 2.9% by Select Portfolio Servicing, Inc. and 1.9%
by PNC Mortgage. Nationstar will also act as the Master Servicer
and SMS will act as the Special Servicer.

The Seller will have the option to repurchase any loan that becomes
60 or more days delinquent under the MBA method or any real estate
owned property acquired in respect of a mortgage loan at a price
equal to the principal balance of the loan (Optional Repurchase
Price), provided that such repurchases will be limited to 10% of
the principal balance of the mortgage loans as of the Statistical
Calculation Date.

Unlike other seasoned re-performing loan securitizations, the
Servicers in this transaction will advance principal and interest
on delinquent mortgages to the extent such advances are deemed
recoverable.

The transaction employs a senior-subordinate, shifting-interest
cash flow structure that is enhanced from a pre-crisis structure.

The ratings reflect transactional strengths that include underlying
assets that have significant seasoning, relatively clean payment
histories and robust loan attributes with respect to credit scores,
product types and loan-to-value ratios. Additionally, historically,
NRMLT securitizations have exhibited fast voluntary prepayment
rates.

The transaction employs a relatively weak representations and
warranties framework that includes an unrated representation
provider (NRZ), certain knowledge qualifiers and fewer mortgage
loan representations relative to DBRS criteria for seasoned pools.

Satisfactory third-party due diligence was performed on the pool
for regulatory compliance, title/lien, payment history and data
integrity. Updated Home Data Index and/or broker price opinions
were provided for the pool; however, a reconciliation was not
performed on the updated values.

Certain loans have missing assignments or endorsements as of the
Closing Date. Given the relatively clean performance history of the
mortgages and the operational capability of the servicers, DBRS
believes the risk of impeding or delaying foreclosure is remote.


OCTAGON INVESTMENT 28: S&P Assigns BB-(sf) Rating on Cl. E-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1-R, B-R,
C-1-R, C-2-R, D-R, and E-R replacement notes and new class X-R
notes from Octagon Investment Partners 28 Ltd., a collateralized
loan obligation (CLO) originally issued in 2016 that is managed by
Octagon Credit Investors LLC. The replacement notes were issued via
a supplemental indenture.

The ratings reflect S&P's opinion that the credit support available
is commensurate with the associated rating levels.

On the Nov. 29, 2018, refinancing date, the proceeds from the
issuance of the replacement notes redeemed the original notes.
Subsequently, S&P withdrew its rating on the original notes and
assigned ratings to the replacement notes.

The replacement notes were issued via a supplemental indenture,
which, in addition to outlining the terms of the replacement notes,
also:

-- Split the original class A notes into replacement class A-1-R
and A-2-R notes.

-- Combined the original class B-1 (floating rate) and B-2
(fixed-rate) notes into replacement class B-R notes with a lower
spread than that of the class B-1 notes.

-- Combined the original class E-1 and E-2 floating-rate notes
into replacement class E-R notes with a lower spread than that of
both of the previous class E notes.

-- Issued class X-R notes that will pay down on the first or
second payment date.

-- Issued the replacement class C-R and D-R notes at a lower
spread than the original notes.

-- Extended the non-call period to October 2020.

-- Extended the reinvestment period to October 2023.

-- Extended the maturity date to October 2030.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction as reflected in
the trustee report, to estimate future performance (see table). In
line with our criteria, our cash flow scenarios applied
forward-looking assumptions on the expected timing and pattern of
defaults, and recoveries upon default, under various interest rate
and macroeconomic scenarios. In addition, our analysis considered
the transaction's ability to pay timely interest or ultimate
principal, or both, to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them, and we will take further rating actions
as we deem necessary."

  RATINGS ASSIGNED

  Octagon Investment Partners 28 Ltd.
  Replacement class         Rating      Amount (mil. $)
  X-R                       AAA (sf)               2.20
  A-1-R                     AAA (sf)             434.00
  A-2-R                     NR                    24.50
  B-R                       AA (sf)               73.50
  C-1-R (deferrable)        A (sf)                30.50
  C-2-R (deferrable)        A (sf)                15.00
  D-R (deferrable)          BBB- (sf)             38.50
  E-R (deferrable)          BB- (sf)              28.00
  Subordinated notes        NR                    61.50

  RATING WITHDRAWN
  Octagon Investment Partners 28 Ltd.
                                  Rating
  Original class                To      From
  A                             NR      AAA (sf)

  NR--Not rated.




OCTAGON INVESTMENT 29: Moody's Rates $12MM Class F Notes B3(sf)
---------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to seven
classes of notes issued by Octagon Investment Partners 39, Ltd.

Moody's rating action is as follows:

US$372,000,000 Class A-1 Senior Secured Floating Rate Notes due
2030 (the "Class A-1 Notes"), Definitive Rating Assigned Aaa (sf)

US$15,000,000 Class A-2 Senior Secured Floating Rate Notes due 2030
(the "Class A-2 Notes"), Definitive Rating Assigned Aaa (sf)

US$69,000,000 Class B Senior Secured Floating Rate Notes due 2030
(the "Class B Notes"), Definitive Rating Assigned Aa2 (sf)

US$27,600,000 Class C Secured Deferrable Floating Rate Notes due
2030 (the "Class C Notes"), Definitive Rating Assigned A2 (sf)

US$37,800,000 Class D Secured Deferrable Floating Rate Notes due
2030 (the "Class D Notes"), Definitive Rating Assigned Baa3 (sf)

US$30,600,000 Class E Secured Deferrable Floating Rate Notes due
2030 (the "Class E Notes"), Definitive Rating Assigned Ba3 (sf)

US$12,000,000 Class F Secured Deferrable Floating Rate Notes due
2030 (the "Class F Notes"), Definitive Rating Assigned B3 (sf)

The Class A-1 Notes, Class A-2 Notes, the Class B Notes, the Class
C Notes, the Class D Notes, the Class E Notes, and the Class F
Notes are referred to herein, collectively, as the "Rated Notes."

RATINGS RATIONALE

The ratings reflect the risks due to defaults on the underlying
portfolio of assets, the transaction's legal structure, and the
characteristics of the underlying assets.

Octagon 39 is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90% of the portfolio must consist of
senior secured loans and eligible investments, and up to 10% of the
portfolio may consist of second lien loans and unsecured loans. The
portfolio is approximately 85% ramped as of the closing date.

Octagon Credit Investors, LLC will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's five year reinvestment period.
Thereafter, the Manager may reinvest unscheduled principal payments
and proceeds from sales of credit risk assets, subject to certain
restrictions.

In addition to the Rated Notes, the Issuer issued subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $600,000,000

Diversity Score: 60

Weighted Average Rating Factor (WARF): 2780

Weighted Average Spread (WAS): 3.25%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 47.5%

Weighted Average Life (WAL): 8.9 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for Octagon Investment Partners 39, Ltd. was
assigned in accordance with Moody's existing Methodology entitled
"Moody's Global Approach to Rating Collateralized Loan
Obligations," dated August 31, 2017. Please note that on November
14, 2018, Moody's released a Request for Comment, in which it has
requested market feedback on potential revisions to its Methodology
for Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on Octagon Investment Partners 39, Ltd.
Please refer to Moody's Request for Comment, titled "Proposed
Update to Moody's Global Approach to Rating Collateralized Loan
Obligations," for further details regarding the implications of the
proposed Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.


OCTAGON LOAN: Moody's Assigns Ba3 Rating on Class E-RR Notes
------------------------------------------------------------
Moody's Investors Service assigns ratings to five classes of CLO
refinancing notes issued by Octagon Loan Funding, Ltd.

Moody's rating action is as follows:

US$252,000,000 Class A-RR Senior Secured Floating Rate Notes due
2031 (the "Class A-RR Notes"), Assigned Aaa (sf)

US$49,700,000 Class B-RR Senior Secured Floating Rate Notes due
2031 (the "Class B-RR Notes"), Assigned Aa2 (sf)

US$30,700,000 Class C-RR Mezzanine Secured Deferrable Floating Rate
Notes due 2031 (the "Class C-RR Notes"), Assigned A3 (sf)

US$14,800,000 Class D-RR Mezzanine Secured Deferrable Floating Rate
Notes due 2031 (the "Class D-RR Notes"), Assigned Baa3 (sf)

US$20,700,000 Class E-RR Junior Secured Deferrable Floating Rate
Notes due 2031 (the "Class E-RR Notes"), Assigned Ba3 (sf)

The Issuer is a managed cash flow collateralized loan obligation.
The issued notes are collateralized primarily by a portfolio of
broadly syndicated senior secured corporate loans.

Octagon Credit Investors, LLC manages the CLO. It directs the
selection, acquisition, and disposition of collateral on behalf of
the Issuer.

RATINGS RATIONALE

The ratings reflect the risks due to defaults on the underlying
portfolio of assets, the transaction's legal structure, and the
characteristics of the underlying assets.

The Issuer has issued the Refinancing Notes on November 19, 2018 in
connection with the refinancing of all classes of the secured notes
previously refinanced in part on May 18, 2017 originally issued on
September 17, 2014. On the Refinancing Date, the Issuer used
proceeds from the issuance of the Refinancing Notes and additional
subordinated notes to redeem in full the Refinanced Notes.

In addition to the issuance of the Refinancing Notes and additional
subordinated notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: extension of the reinvestment period; extensions of the
stated maturity and non-call period; changes to certain collateral
quality tests; changes to the overcollateralization test levels;
and changes to concentration limitations.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. For modeling
purposes, Moody's used the following base-case assumptions:

Performing par and principal proceeds balance: $400,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2723

Weighted Average Spread (WAS): 3.15%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 47.0%

Weighted Average Life (WAL): 9.0 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Ratings for Octagon Loan Funding, Ltd. were assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on the Refinancing Notes issued by Octagon
Loan Funding, Ltd. Please refer to Moody's Request for Comment,
titled "Proposed Update to Moody's Global Approach to Rating
Collateralized Loan Obligations," for further details regarding the
implications of the proposed Methodology revisions on certain
Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Refinancing Notes is subject to uncertainty.
The performance of the Refinancing Notes is sensitive to the
performance of the underlying portfolio, which in turn depends on
economic and credit conditions that may change. The Manager's
investment decisions and management of the transaction will also
affect the performance of the Refinancing Notes.


PEAKS CLO 3: S&P Assigns Prelim. BB- Rating on Class E Notes
------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Peaks CLO 3
Ltd./Peaks CLO 3 LLC's fixed- and floating-rate notes.

The note issuance is a collateralized loan obligation transaction
backed primarily by speculative-grade (rated 'BB+' and lower)
senior secured term loans that are governed by collateral quality
tests.

The preliminary ratings are based on information as of Nov. 29,
2018. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The collateral pool.

-- The credit enhancement provided through the subordination of
cash flows, excess spread, and overcollateralization.

-- The collateral manager's experienced team, which can affect the
performance of the rated notes through collateral selection,
ongoing portfolio management, and trading.

-- The transaction's legal structure, which is expected to be
bankruptcy remote.

  PRELIMINARY RATINGS ASSIGNED

  Peaks CLO 3 Ltd./Peaks CLO 3 LLC

  Class                 Rating      Amount (mil. $)
  X                     AAA (sf)               1.50
  A-1                   AAA (sf)              56.00
  A-2                   AAA (sf)              17.00
  B-1                   AA (sf)               18.00
  B-2                   AA (sf)                7.00
  B-3                   AA (sf)                2.50
  C (deferrable)        A (sf)                11.25
  D (deferrable)        BBB- (sf)              9.75
  E (deferrable)        BB- (sf)               6.25
  Subordinated notes    NR                    24.45

  NR--Not rated.


RAMP TRUST 2005-RS9: Moody's Hikes Class A-I-4 Debt to Caa3
-----------------------------------------------------------
Moody's Investors Service has upgraded the rating of two tranches
from RAMP Series 2005-RS9 Trust, backed by Subprime RMBS.

Complete rating actions are as follows:

Issuer: RAMP Series 2005-RS9 Trust

Cl. A-I-4, Upgraded to Caa3 (sf); previously on Apr 6, 2010
Downgraded to Ca (sf)

Underlying Rating: Upgraded to Caa3 (sf); previously on Apr 6, 2010
Downgraded to Ca (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn 3/25/2009)

Cl. A-II, Upgraded to Caa2 (sf); previously on Apr 6, 2010
Downgraded to Ca (sf)

Underlying Rating: Upgraded to Caa2 (sf); previously on Apr 6, 2010
Downgraded to Ca (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn 3/25/2009)

RATINGS RATIONALE

The rating upgrades are primarily due to the total credit
enhancement available to the bonds. The rating action for RAMP
Series 2005-RS9 Trust Class A-I-4 also reflects a correction to the
cash-flow model previously used by Moody's in rating this
transaction. In prior rating actions, realized losses were not
allocated on a pro-rata basis between the Group I and Group II
bonds, thereby underestimating the losses for Class A-I-4. This
error has now been corrected, and the rating action reflects this
change. The actions reflect the recent performance of the
underlying pools and Moody's updated loss expectations on the
pools.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in January 2017.

The Credit Ratings for RAMP Series 2005-RS9 Trust were assigned in
accordance with Moody's existing Methodology entitled "US RMBS
Surveillance Methodology," dated 1/31/2017. Please note that on
November 14, 2018, Moody's released a Request for Comment, in which
it has requested market feedback on potential revisions to its
Methodology for pre-2009 US RMBS Prime Jumbo, Alt-A, Option ARM,
Subprime, Scratch and Dent, Second Lien and Manufactured Housing
transactions. If the revised Methodology is implemented as
proposed, the Credit Ratings on RAMP Series 2005-RS9 Trust are not
expected to be affected. Please refer to Moody's Request for
Comment, titled "Proposed Update to US RMBS Surveillance
Methodology," for further details regarding the implications of the
proposed Methodology revisions on certain Credit Ratings.

Factors that would lead to an upgrade or downgrade of the ratings:


Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in October 2018 from 4.1% in
October 2017. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2018 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2018. Lower increases than
Moody's expects or decreases could lead to negative rating actions.
Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions.


RCO TRUST 2018-VFS1: S&P Assigns Prelim B Rating on B-2 Notes
-------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to RCO
2018-VFS1 Trust's $199.467 million mortgage pass-through notes.

The note issuance is a residential mortgage-backed securities
transaction backed by first-lien, fixed- and adjustable-rate, fully
amortizing, investment property mortgage loans secured by
single-family residential properties, planned-unit developments,
condominiums, and two- to four-family residential properties to
both prime and nonprime borrowers. The pool has 1,180 loans; all
loans are business-purpose investor loans and are exempt from the
qualified mortgage/ability-to-repay rules.

The preliminary ratings are based on information as of Nov. 19,
2018. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The pool's collateral composition;
-- The credit enhancement provided for this transaction;
-- The transaction's associated structural mechanics;
-- The representation and warranty framework for this transaction;
and
-- The mortgage originator, Visio Financial Services Inc.

  PRELIMINARY RATINGS ASSIGNED

  RCO 2018-VFS1 Trust

  Class       Rating(i)          Amount ($)
  A-1         AAA (sf)          130,751,000
  A-2         AA (sf)            13,564,000
  A-3         A (sf)             22,440,000
  M-1         BBB (sf)           11,669,000
  B-1         BB (sf)             9,375,000
  B-2         B (sf)              7,180,000
  B-3         NR                  4,488,485
  XS          NR                   Notional(ii)
  R           NR                        N/A

(i)The rating on each class of securities is preliminary and
subject to change at any time. The collateral and structural
information in this report reflect the term sheet dated Nov. 14,
2018; the preliminary ratings assigned to the classes address the
ultimate payment of interest and principal.
(ii)Notional amount equals the loans' stated principal balance.
N/A--Not applicable.
NR--Not rated.


RFC CDO 2006-1: S&P Withdraws D Ratings on 2 Tranches
-----------------------------------------------------
S&P Global Ratings lowered its ratings on the class B and C notes
from RFC CDO 2006-1 Ltd., a CRE-CDO transaction. S&P subsequently
withdrew its ratings on the class B and C notes.

The rating action follows S&P's review of the transaction's
performance using data from the Oct. 25, 2018, payment date report
from the trustee, and the event of default notice issued by the
trustee on Nov. 2, 2018.

There is only one credit-impaired asset remaining in the
transaction and there were inadequate proceeds to pay the current
interest on the Oct. 25, 2018, payment date on the class B note,
which is the most senior note. As a result, the class B notes
experienced an interest shortfall and this triggered an event of
default as per the terms of the transaction. The class C notes
continue to defer their interest.

Since S&P does not expect the recovery on the asset to repay both
classes par balance and their respective interest (including
deferred), it lowered their ratings to 'D (sf)' according to its
criteria and subsequently withdrew the ratings.

  RATINGS LOWERED

  RFC CDO 2006-1 Ltd.
                    Rating
  Class         To          From
  B             D (sf)      CCC- (sf)
  C             D (sf)      CCC- (sf)

  RATINGS WITHDRAWN

  RFC CDO 2006-1 Ltd.
                    Rating
  Class         To          From
  B             NR          D (sf)
  C             NR          D (sf)



RMF BUYOUT 2018-1: Moody's Assigns Ba3 Rating on Class M4 Debt
--------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to five
classes of residential mortgage-backed securities issued by RMF
Buyout Issuance Trust 2018-1. The ratings range from Aaa (sf) to
Ba3 (sf).

The certificates are backed by a pool that includes 1,239 inactive
home equity conversion mortgages and 110 real estate owned
properties. The servicer for the deal is Reverse Mortgage Funding,
LLC. The complete rating actions are as follows:

Issuer: RMF Buyout Issuance Trust 2018-1

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. M1, Definitive Rating Assigned Aa3 (sf)

Cl. M2, Definitive Rating Assigned A3 (sf)

Cl. M3, Definitive Rating Assigned Baa3 (sf)

Cl. M4, Definitive Rating Assigned Ba3 (sf)

RATINGS RATIONALE

The collateral backing RBIT 2018-1 consists of first-lien inactive
HECMs covered by Federal Housing Administration insurance secured
by properties in the US along with Real-Estate Owned properties
acquired through conversion of ownership of reverse mortgage loans
that are covered by FHA insurance. If a borrower or their estate
fails to pay the amount due upon maturity or otherwise defaults,
the sale of the property is used to recover the amount owed. The
mortgage assets were acquired from Ginnie Mae sponsored HECM
mortgage backed (HMBS) securitizations or the purchase of whole
loan pools. All of the mortgage assets are covered by FHA insurance
for the repayment of principal up to certain amounts.

There are 1,349 mortgage assets with a balance of $333,718,195. The
assets are in either default, due and payable, referred for deed in
lieu, bankruptcy, foreclosure or REO status. Loans that are in
default may cure or move to due and payable; due and payable loans
may cure or move to foreclosure; and foreclosure loans may cure or
move to REO. 6.9% of the assets are in default of which 0.5% (of
the total assets) are in default due to non-occupancy and 6.3% (of
the total assets) are in default due to delinquent taxes and
insurance. 9.4% of the assets are due and payable, 0.3% are in
referred for deed in lieu status, 16.5% are in bankruptcy status
and 60.3% are in foreclosure. Finally, 6.6% of the assets are REO
properties and were acquired through foreclosure or deed-in-lieu of
foreclosure on the associated loan. This transaction has a
relatively low percentage of REO properties. All else equal, a
lower percentage of REO properties suggests that a smaller
percentage of assets will be liquidated shortly after closing and
therefore the weighted average life may be longer.

Compared to other inactive HECM transactions Moody's has rated,
RBIT 2018-1 has a high percentage of loans in bankruptcy status.
There are 197 loans, representing 16.5% of the pool balance, that
are in bankruptcy. Based on information provided by RMF, the
majority of these loans are in chapter 13 bankruptcy where timeline
to resolution can take up to five years. Moody's extended its
assumed liquidation timelines for these loans to account for this.


The initial weighted average loan-to-value-plus-insurance ratio is
59.1%, which is high compared to most other inactive HECM
transactions Moody's has rated. This implies that, all else equal,
more loans in this pool will have their insurance claims capped by
the MCA. Also, the weighted average LTV ratio is 149.2% which is
higher than in most other inactive HECM transactions Moody's has
rated. As such, borrowers in this pool tend to have less equity in
their homes compared to most prior transactions which may lead to
lower cure and repayment rates.

There are 221 loans in this transaction, 12.7% of the asset
balance, backed by properties in Puerto Rico. Puerto Rican HECMs
pose additional risk due to the poor state of the Puerto Rican
economy, declining population, and bureaucratic foreclosure
process. Furthermore, Puerto Rico is still struggling to recover
from Hurricane Maria. In August 2018, HUD extended the foreclosure
moratorium in areas affected by Hurricane Maria for an additional
month. The moratorium ended on September 15, 2018. Even though the
moratorium has now been lifted, there are likely to be additional
delays due to court related backlogs, additional foreclosure
procedures for impacted properties, and difficulties in tracking
down borrowers or their heirs.

Servicing

RMF will be the named servicer for the portfolio under the sale and
servicing agreement. RMF has the necessary processes, staff,
technology and overall infrastructure in place to effectively
oversee the servicing of this transaction. RMF will use Reverse
Mortgage Solutions, Inc. and Compu-Link Corporation, d/b/a Celink
as subservicers to service the mortgage assets. RMS will
sub-service 67.3% of the pool and Celink will sub-service 32.7%.
Based on an operational review of RMF, it has adequate
sub-servicing monitoring processes, a seasoned servicing oversight
team and direct system access to the sub-servicers' core systems.
In addition, a third party will review RMF's monthly servicing
reports on a quarterly basis to ensure data accuracy throughout the
life of the transaction.

RMS' corporate parent, Ditech Holding Corporation (Ditech),
recently emerged from chapter 11 bankruptcy. Although RMS was not
included in the bankruptcy filing, there is still uncertainty as to
the overall impact Ditech's financial condition going forward may
have on RMS and its servicing operations. To address this risk, RMF
has engaged Celink as a backup sub-servicer for RMS and Celink has
mapped RMS' portfolio for easier transfer. In addition, the
sub-servicing agreement between RMF and RMS automatically
terminates at the end of each successive 30-calendar-day period,
and will renew at RMF's discretion, reducing the potential
operational risk if RMS becomes bankrupt.

Unlike other inactive HECM transactions Moody's has rated, in RBIT
2018-1 a firm of independent accountants or a due-diligence review
firm (the verification agent) will perform quarterly procedures
with respect to the monthly servicing reports delivered by the
servicer to the trustee. These procedures will include comparison
of the underlying records relating to the subservicers' servicing
of the loans and determination of the mathematical accuracy of
calculations of loan balances stated in the monthly servicing
reports delivered to the trustee. Any material exceptions
identified as a result of the procedures will be described in the
verification agent's report. To the extent the verification agent
identifies errors in the monthly servicing reports, the servicer
will be obligated to correct them.

Transaction Structure

The securitization has a sequential liability structure amongst six
classes of notes with structural subordination. All funds
collected, prior to an acceleration event, are used to make
interest payments to the notes, then principal payments to the
Class A notes, then to a redemption account until the amount on
deposit in the redemption account is sufficient to cover future
principal and interest payments for the subordinate notes up to
their expected final payment dates. The subordinate notes will not
receive principal until the beginning of their respective target
amortization periods (in the absence of an acceleration event). The
notes benefit from structural subordination as credit enhancement,
and an interest reserve account funded with cash received from the
initial purchasers of the notes for liquidity and credit
enhancement.

The transaction is callable on or after six months with a 1.0%
premium and on or after 12 months without a premium. The mandatory
call date for the Class A notes is in August 2020. For the Class M1
notes, the expected final payment date is in December 2020. For the
Class M2 notes, the expected final payment date is in January 2021.
For the Class M3 notes, the expected final payment date is in
February 2021. For the Class M4 notes, the expected final payment
date is in March 2021. Finally, for the Class M5 notes, the
expected final payment date is in July 2021. For each of the
subordinate notes, there are target amortization periods that
conclude on the respective expected final payment dates. The legal
final maturity of the transaction is 10 years.

Available funds to the transaction are expected to primarily come
from the liquidation of REO properties and receipt of FHA insurance
claims. These funds will be received with irregular timing. In the
event that there are insufficient funds to pay interest in a given
period, the interest reserve account may be utilized. Additionally,
any shortfall in interest will be classified as an available funds
cap shortfall. These available funds cap carryover amounts will
have priority of payments in the waterfall and will also accrue
interest at the respective note rate.

Certain aspects of the waterfall are dependent upon RMF remaining
as servicer. Servicing fees and servicer related reimbursements are
subordinated to interest and principal payments while RMF is
servicer. However, servicing advances will instead have priority
over interest and principal payments in the event that RMF defaults
and a new servicer is appointed.

The transaction provides a strong mechanism to ensure continuous
advancing for the assets in the pool. Specifically, if the servicer
fails to advance and such failure is not remedied for a period of
15 days, the sub-servicers can fund their advances from collections
and from an interim advancing reserve account. Given the
significant amount of advancing required to service inactive HECMs
with tax delinquencies, this provision helps to minimize
operational disruption in the event RMF encounters financial
difficulties.

In addition, the transaction establishes a clear and efficient
process for choosing a successor servicer following the removal of
the servicer. Specifically, unlike other inactive HECM transactions
Moody's has rated, the servicer will provide a list of eligible
successor servicers to the indenture trustee on a quarterly basis
and a successor servicer will be selected based on a voting process
that does not require a supermajority of the senior noteholders to
actively consent.

Third-Party Review

A third party firm conducted a review of certain characteristics of
the mortgage assets on behalf of RMF. The review focused on data
integrity, FHA insurance coverage verification, accuracy of
appraisal recording, accuracy of occupancy status recording,
borrower age documentation, identification of excessive corporate
advances, documentation of servicer advances, and identification of
tax liens with first priority in Texas. Also, broker price opinions
(BPOs) were ordered for 215 properties in the pool.

The third party review (TPR) firm conducted an extensive data
integrity review. Certain data tape fields, such as the mortgage
insurance premium (MIP) rate, the current UPB, current interest
rate, and marketable title date were reviewed against RMF's
servicing system. However, a significant number of data tape fields
were reviewed against imaged copies of original documents of
record, screen shots of HUD's HERMIT system, or HUD documents. Some
key fields reviewed in this manner included the original note rate,
the debenture rate, foreclosure first legal date, and the called
due date.

Certain of the TPR results were in line with recent inactive HECM
transactions that Moody's has rated including the results related
to the accuracy of reported valuations, the presence of FHA
insurance, the existence of property preservation expenses in
excess of FHA reimbursement thresholds, and the accuracy of
reported disbursements. However, other TPR results were weak
compared to previous inactive HECM transactions such as the high
rate of exceptions related to the accuracy of tape values,
recording of occupancy status, borrower age documentation, liens on
properties in Texas, and foreclosure and bankruptcy attorney fees
in excess of FHA reimbursement thresholds. RBIT 2018-1's TPR
results showed a 2.0% initial-tape exception rate related to the
accuracy of tape values and a 35.7% initial-tape exception rate
related to foreclosure and bankruptcy attorney fees. In its
analysis, Moody's applied adjustments to account for the TPR
results in certain areas.

Reps & Warranties (R&W)

RMF is the loan-level R&W provider and is not rated. This
relatively weak financial profile is mitigated by the fact that RMF
will subordinate its servicing advances, servicing fees, and MIP
payments in the transaction and thus has significant alignment of
interests. Another factor mitigating the risks associated with a
financially weak R&W provider is that a third-party due diligence
firm conducted a review on the loans for evidence of FHA insurance.


RMF represents that the mortgage loans are covered by FHA insurance
that is in full force and effect. RMF provides further R&Ws
including those for title, first lien position, enforceability of
the lien, and the condition of the property. Although RMF provides
a no fraud R&W covering the origination of the mortgage loans,
determination of value of the mortgaged properties, and the sale
and servicing of the mortgage loans, the no fraud R&W is made only
as to the initial mortgage loans. Aside from the no fraud R&W, RMF
does not provide any other R&W in connection with the origination
of the mortgage loans, including whether the mortgage loans were
originated in compliance with applicable federal, state and local
laws. Although certain representations are knowledge qualified, the
transaction documents contain language specifying that if a
representation would have been breached if not for the knowledge
qualifier then RMF will repurchase the relevant asset as if the
representation had been breached.

Upon the identification of an R&W breach, RMF has to cure the
breach. If RMF is unable to cure the breach, RMF must repurchase
the loan within 90 days from receiving the notification. Moody's
believes the absence of an independent third party reviewer who can
identify any breaches to the R&W makes the enforcement mechanism
weak in this transaction. Also, RMF, in its good faith, is
responsible for determining if a R&W breach materially and
adversely affects the interests of the trust or the value the
collateral. This creates the potential for a conflict of interest.


When analyzing the transaction, Moody's reviewed the transaction's
exposure to large potential indemnification payments owed to
transaction parties due to potential lawsuits. In particular,
Moody's assessed the risk that the acquisition trustee would be
subject to lawsuits from investors for a failure to adequately
enforce the R&Ws against the seller. Moody's believes that RBIT
2018-1 is adequately protected against such risk in part because a
third-party data integrity review was conducted on a significant
random sample of the loans. In addition, the third-party due
diligence firm verified that all of the loans in the pool are
covered by FHA insurance.

Trustee & Master Servicer

The acquisition and owner trustee for the RBIT 2018-1 transaction
is Wilmington Savings Fund Society, FSB. The paying agent and cash
management functions will be performed by U.S. Bank National
Association. U.S. Bank National Association will also serve as the
claims payment agent and as such will be the HUD mortgagee of
record for the mortgage assets in the pool.

Methodology

The methodologies used in these ratings were "Moody's Approach to
Rating Securitisations Backed by Non-Performing and Re-Performing
Loans" published in August 2016 and "Moody's Global Approach to
Rating Reverse Mortgage Securitizations" published in May 2015.

The Credit Rating for RBIT 2018-1 was assigned in accordance with
Moody's existing Methodology entitled "Moody's Approach to Rating
Securitisations Backed by Non-Performing and Re-Performing Loans,"
dated August 2, 2016. Please note that on November 14, 2018,
Moody's released a Request for Comment, in which it has requested
market feedback on potential revisions to its Methodology for
securitizations backed by non-performing and re-performing loans.
If the revised Methodology is implemented as proposed, the Credit
Rating on RBIT 2018-1 may be neutrally affected. Please refer to
Moody's Request for Comment, titled "Proposed Update to Moody's
Approach to Rating Securitizations Backed by Non-Performing and
Re-Performing Loans," for further details regarding the
implications of the proposed Methodology revisions on certain
Credit Ratings.

Our quantitative asset analysis is based on a loan-by-loan modeling
of expected payout amounts given the structure of FHA insurance and
with various stresses applied to model parameters depending on the
target rating level.

FHA insurance claim types: funds come into the transaction
primarily through the sale of REO properties and through FHA
insurance claim receipts. There are uncertainties related to the
extent and timing of insurance proceeds received by the trust due
to the mechanics of the FHA insurance. HECM mortgagees may suffer
losses if a property is sold for less than its appraised value.

The amount of insurance proceeds received from the FHA depends on
whether a sales based claim (SBC) or appraisal based claim (ABC) is
filed. SBCs are filed in cases where the property is successfully
sold within the first six months after the servicer has acquired
marketable title to the property. ABCs are filed six months after
the servicer has obtained marketable title if the property has not
yet been sold. For an SBC, HUD insurance will cover the difference
between (i) the loan balance and (ii) the higher of the sales price
and 95.0% of the latest appraisal, with the transaction on the hook
for losses if the sales price is lower than 95.0% of the latest
appraisal. For an ABC, HUD only covers the difference between the
loan amount and 100% of appraised value, so failure to sell the
property at the appraised value results in loss.

Moody's expects ABCs to have higher levels of losses than SBCs. The
fact that there is a delay in the sale of the property usually
implies some adverse characteristics associated with the property.
FHA insurance will not protect against losses to the extent that an
ABC property is sold at a price lower than the appraisal value
taken at the six month mark of REO. Additionally, ABCs do not cover
the cost to sell properties (broker fees) while SBCs do cover these
costs. For SBCs, broker fees are reimbursable up to 6.0%
ordinarily. Its base case expectation is that properties will be
sold for 13.5% less than their appraisal value for ABCs. To make
this assumption, Moody's considered industry data and the
historical experience of RMF. Moody's stressed this percentage at
higher credit rating levels. At a Aaa rating level, Moody's assumed
that ABC appraisal haircuts could reach up to 30.0%.

In its asset analysis, Moody's also assumed there would be some
losses for SBCs, albeit lower amounts than for ABCs. Based on
historical performance, in the base case scenario Moody's assumed
that SBCs would suffer 1.0% losses due to a failure to sell the
property for an amount equal to or greater than 95.0% of the most
recent appraisal. Moody's stressed this percentage at higher credit
rating levels. At a Aaa rating level, Moody's assumed that SBC
appraisal haircuts could reach up to 11.0% (i.e., 6.0% below
95.0%).

Under its analytical approach, each loan is modeled to go through
both the ABC and SBC process with a certain probability. Each loan
will thus have both of the sales disposition payments and
associated insurance payments (four payments in total). All
payments are then probability weighted and run through a modeled
liability structure. For the base case scenario Moody's assumed
that 85% of claims would be SBCs and the rest would be ABCs.
Moody's stressed this assumption and assumed higher ABC percentages
for higher rating levels. At a Aaa rating level, Moody's assumed
that 85% of insurance claims would be submitted as ABCs.

Liquidation process: each mortgage asset is categorized into one of
four categories: default, due and payable, foreclosure and REO. In
its analysis, Moody's assumes loans that are in referred status to
be either in foreclosure or REO category. The loans are assumed to
move through each of these stages until being sold out of REO.
Moody's assumed that loans would be in default status for six
months. Due and payable status is expected to last six to 12 months
depending on the default reason. Foreclosure status is based on the
state in which that the related property is located and is further
stressed at higher rating levels. The base case foreclosure
timeline is based on FHA timeline guidance. REO disposition is
assumed to take place in six months with respect to SBCs and 12
months with respect to ABCs.

Debenture interest: the receipt of debenture interest is dependent
upon performance of certain actions within certain timelines by the
servicer. If these timeline and performance benchmarks are not met
by the servicer, debenture interest is subject to curtailment. Its
base case assumption is that 90.0% of debenture interest will be
received by the trust. Moody's stressed the amount of debenture
interest that will be received at higher rating levels. Its
debenture interest assumptions reflect the requirement that RMF
(not rated) reimburse the trust for debenture interest curtailments
due to servicing errors or failures to comply with HUD guidelines.


Additional model features: Moody's incorporated certain additional
considerations into its analysis, including the following:

  -- In most cases, the most recent appraisal value was used as the
property value in its analysis. However, for seasoned appraisals
Moody's applied a 15.0% haircut to account for potential home price
depreciation between the time of the appraisal and the cut-off
date.

  -- Mortgage loans with borrowers that have significant equity in
their homes are likely to be paid off by the borrowers or their
heirs rather than complete the foreclosure process. Moody's
estimated which loans would be bought out of the trust by comparing
each loans' appraisal value (post haircut) to its UPB.

  -- Moody's assumed that foreclosure costs will average $4,500 per
loan, two thirds of which will be reimbursed by the FHA. Moody's
then applied a negative adjustment to this amount based on the TPR
results.

  -- Moody's estimated monthly tax and insurance advances based on
cumulative tax and insurance advances to date.

Moody's ran additional stress scenarios that were designed to mimic
expected cash flows in the case where RMF is no longer the
servicer. Moody's assumes the following in the situation where RMF
is no longer the servicer:

  -- Servicing advances and servicing fees: While RMF subordinates
their recoupment of servicing advances, servicing fees, and MIP
payments, a replacement servicer will not subordinate these
amounts.

  -- RMF indemnifies the trust for lost debenture interest due to
servicing errors or failure to comply with HUD guidelines. In the
event of a bankruptcy, RMF will not have the financial capacity to
do so.

  -- A replacement servicer may require an additional fee and thus
Moody's assumes a 25 bps strip will take effect if the servicer is
replaced.

  -- One third of foreclosure costs will be removed from sales
proceeds to reimburse a replacement servicer (one third of
foreclosure costs are not reimbursable under FHA insurance). This
is typically on the order of $1,500 per loan.

Furthermore, to account for risks posed by Puerto Rican loans,
Moody's considered the following for loans backed by properties
located in Puerto Rico:

  -- To account for delays in the foreclosure process in Puerto
Rico due to the hurricanes, Moody's assumed extended foreclosure
timelines across rating levels and assumed five years as its Aaa
foreclosure timeline.

  -- Moody's assumed that all insurance claims will be submitted as
ABCs. In addition, Moody's assumed that properties will sell for
significantly lower than their appraised values.

To account for a potential extension of timelines due to loans with
borrowers in bankruptcy, Moody's extended the assumed timelines for
these loans in the base case scenario and scaled this assumption up
for higher rating levels.

In addition, for high rating scenarios, Moody's increased
foreclosure timelines by three months for RMS sub-serviced loans.
Celink is a backup servicer for RMS. If RMS is terminated as
sub-servicer by RMF Moody's assumed it will take 90 days to
transfer servicing from RMS to Celink and liquidation timelines
will be extended as a result.

Moody's also applied a small adjustment in its analysis to account
for the risks associated with certain damaged properties that are
located in areas impacted by Hurricane Florence or Hurricane
Michael.

Factors that would lead to an upgrade or downgrade of the ratings:


Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of stress could
drive the ratings up. Transaction performance depends greatly on
the US macro economy and housing market. Property markets could
improve from its original expectations resulting in appreciation in
the value of the mortgaged property and faster property sales.

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of stresses could drive the
ratings down. Transaction performance depends greatly on the US
macro economy and housing market. Property markets could
deteriorate from its original expectations resulting in
depreciation in the value of the mortgaged property and slower
property sales.


SALOMON BROTHERS 2000-C3: Moody's Affirms C Rating on Cl. X Certs
-----------------------------------------------------------------
Moody's Investors Service has affirmed the rating of one
interest-only class in Salomon Brothers Commercial Mortgage Trust
2000-C3, Commercial Mortgage Pass-Through Certificates Series
2000-C3, as follows:

Cl. X, Affirmed C (sf); previously on Nov 17, 2017 Affirmed C (sf)


RATINGS RATIONALE

The rating on the IO class, Cl. X, was affirmed based on the credit
quality of its referenced classes.

Moody's rating action reflects a base expected loss of 23.4% of the
current pooled balance, compared to 22.8% at Moody's last review.
Moody's base expected loss plus realized losses is now 5.8% of the
original pooled balance, the same as at the last review.

FACTORS THAT WOULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATING:

An IO class may be subject to ratings upgrades if there is an
improvement in the credit quality of its referenced classes,
subject to the limits and provisions of the updated IO methodology.


An IO class may be subject to ratings downgrades if there is (i) a
decline in the credit quality of the reference classes and/or (ii)
paydowns of higher quality reference classes, subject to the limits
and provisions of the updated IO methodology.

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in this rating were "Moody's Approach to
Rating Large Loan and Single Asset/Single Borrower CMBS" published
in July 2017 and "Moody's Approach to Rating Structured Finance
Interest-Only (IO) Securities" published in June 2017.

The Credit Rating for Salomon Brothers Commercial Mortgage Trust
2000-C3, Cl. X was assigned in accordance with Moody's existing
Methodology entitled "Moody's Approach to Rating Structured Finance
Interest-Only (IO) Securities" published in June 2017. Please note
that on November 14, 2018, Moody's released a Request for Comment,
in which it has requested market feedback on potential revisions to
its Methodology for rating structured finance interest-only (IO)
securities. If the revised Methodology is implemented as proposed,
the Credit Rating on Salomon Brothers Commercial Mortgage Trust
2000-C3, Cl. X may be positively affected. Please refer to Moody's
Request for Comment, titled "Proposed Update to Moody's Approach to
Rating Structured Finance Interest-Only (IO) Securities" for
further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

DEAL PERFORMANCE

As of the October 18, 2018 distribution date, the transaction's
aggregate certificate balance has decreased by 99% to $14.1 million
from $915 million at securitization. The Certificates are
collateralized by five mortgage loans. One loan, representing less
than 1% of the pool, has defeased and is secured by US Government
securities. There is currently one loan representing 3.6% of the
pool on the master servicer's watchlist.

Thirty-eight loans have been liquidated from the pool, resulting in
an aggregate realized loss of approximately $49.9 million (26% loss
severity on average). Two loans, representing 96% of the pool, are
in special servicing.

The two specially serviced loans are the A-Note and B-Note for the
Granite State Marketplace Loan, which was previously modified to
include an A/B note split. The A-Note is a $10.3 million loan
(representing 72.4% of the pool) and the B-Note is a $3.3 million
loan (representing 23.4% of the pool). The mortgage loan is secured
by a 250,000 square foot anchored retail center located in
Hooksett, New Hampshire. The loan originally transferred to special
servicing in September 2008 for maturity default and a loan
modification was subsequently executed that included a note split
and maturity date extension. The loan did not pay off at the
extended maturity date in November 2012 and the asset is currently
real estate owned.

There are two performing non-defeased loans that represent 3.9% of
the pool balance. Both loans are fully amortizing. The largest loan
is the Kmart Shopping Center -- Salt Lake City Loan
($510,421—3.6% of the pool), which is secured by a single tenant
retail center located in Murray, Utah. The property was 100% leased
to the Kmart Corporation until May 2020. The store is now dark,
however, the loan is fully amortizing loan and has amortized 79%
since securitization. Moody's LTV and stressed DSCR are 18% and
greater than 4.00X, respectively.

The second largest loan is the Edgewood Apartments Loan ($43,529 --
0.3% of the pool), which is secured by a 24-unit multifamily
property in Duluth, Minnesota, approximately 160 miles northeast of
Minneapolis - St. Paul. The property was 100% leased as of June
2018. The loan is a fully amortizing loan and has amortized 93%
since securitization. Moody's LTV and stressed DSCR are 4.6% and
greater than 4.00X, respectively.


SSB RV TRUST 2001-1: S&P Affirms CC Rating on Class C Notes
-----------------------------------------------------------
S&P Global Ratings raised its rating on the class C notes from
E*Trade RV and Marine Trust 2004-1 (E*Trade). S&P said, "In
addition, we affirmed our ratings on the class D and E notes from
E*Trade, the certificate notes from CIT Marine Trust 1999-A (CIT),
the class A-2 notes from JPMorgan RV Marine Trust 2004-A
(JPMorgan), and the class C notes from the SSB RV Trust 2001-1
(SSB) transaction."

S&P said, "The rating actions reflect the transactions' collateral
performance to date, our views regarding future collateral
performance, each transaction's structure, and the respective
credit enhancement levels supporting the notes. In addition, our
analysis incorporated secondary credit factors, such as credit
stability, payment priorities under various scenarios, and sector-
and issuer-specific analysis.

"The upgrade on class C from E*Trade reflects the class' most
senior position and our view of the available hard credit
enhancement in the form of subordination benefiting the class
compared with the expected remaining losses. We maintained our loss
expectation for the E*Trade transaction at 9.90%-10.10% based on
our view of future collateral performance.  

"The affirmed 'CCC (sf)' rating on the E*Trade class D reflects our
view that the available credit support may remain insufficient to
cover our projected losses for this class. The affirmed 'CC (sf)'
ratings reflect the classes' undercollateralized position where the
current pool balance is lower than the outstanding note balance for
that class. As defined in our criteria, the 'CCC (sf)' rating
reflects our view that the class is still vulnerable to nonpayment
and is dependent upon favorable business, financial, and economic
conditions in order to be paid interest and/or principal according
to the terms of the transaction. Additionally, the 'CC (sf)'
ratings reflect our view that the related classes remain virtually
certain to default."

  COLLATERAL PERFORMANCE (%)(i)

                       Pool    Current    60-plus-day
  Deal     Month     factor        CNL        delinq.
  E*Trade    167       3.65       9.29           1.60
  CIT        236       0.04       6.77           0.00
  JPMorgan   167       0.45      12.68          25.31
  SSB        202       0.28       9.43          11.21

(i) As of the November 2018 distribution date.
CNL--Cumulative net loss.
E*Trade--E*Trade RV and Marine Trust 2004-1.
CIT--CIT Marine Trust 1999-A.
JPMorgan--JPMorgan RV Marine Trust 2004-A
SSB--SSB RV Trust 2001-1.

Each transaction was originally structured with credit enhancement
in the form of some combination of overcollateralization,
subordination, cash reserves, and excess spread. However, higher
than originally expected losses have reduced the amount of
available credit enhancement for each transaction. As of the
November 2018 distribution date, all forms of hard credit
enhancement have been depleted for the CIT, JPMorgan, and SSB
transactions. For E*Trade, the most senior class benefits from hard
credit enhancement in the form of subordination.

S&P will continue to monitor performance on this transaction and
take rating action to the extent appropriate.

  RATING RAISED

  E*Trade RV and Marine Trust 2004-1
                   Rating
  Class      To          From
  C          AAA (sf)    BBB (sf)

  RATINGS AFFIRMED

  CIT Marine Trust 1999-A

  Class    Rating
  Certificate        CC (sf)

  E*Trade RV and Marine Trust 2004-1

  Class    Rating
  D        CCC (sf)
  E        CC (sf)

  JPMorgan RV Marine Trust 2004-A

  Class    Rating
  A-2      CC (sf)

  SSB RV Trust 2001-1

  Class    Rating
  C        CC (sf)


STACR TRUST 2018-HRP2: S&P Rates 3 Tranches 'B(sf)'
---------------------------------------------------
S&P Global Ratings assigned its ratings to Freddie Mac STACR Trust
2018-HRP2's notes.

The note issuance is a residential mortgage-backed securities
(RMBS) transaction backed by prime, high original LTV, seasoned,
fully amortizing, fixed-rate residential mortgage loans secured by
one- to four-family residences, planned-unit developments,
condominiums, cooperatives, and manufactured housing.

The ratings reflect:

-- The credit enhancement provided by the subordinated reference
tranches, as well as the associated structural deal mechanics;

-- The credit quality of the collateral included in the reference
pool, which consists of prime, high original LTV, seasoned, fully
amortizing, fixed-rate mortgages partly covered by mortgage
insurance backstopped by Freddie Mac;

-- A credit-linked note structure that reduces the counterparty
exposure to Freddie Mac for periodic principal payments but, at the
same time, relies on credit premium payments from Freddie Mac (a
highly rated counterparty) to make monthly interest payments and to
make up for any investment losses;

-- The issuer's aggregation experience and alignment of interests
between the issuer and noteholders in the deal's performance,
which, in S&P's view, enhances the notes' strength; and

-- The enhanced credit risk management and quality control
processes Freddie Mac uses in conjunction with the underlying
representations and warranties framework.

  RATINGS ASSIGNED

  Freddie Mac STACR Trust 2018-HRP2

  Class       Rating         Amount (mil. $)
  A-H(i)      NR              22,499,052,472
  M-1         A+ (sf)            170,000,000
  M-1H(i)     NR                   9,513,717
  M-2         A (sf)             226,000,000
  M-2R        A (sf)             226,000,000
  M-2S        A (sf)             226,000,000
  M-2T        A (sf)             226,000,000
  M-2U        A (sf)             226,000,000
  M-2I        A (sf)             226,000,000
  M-2A        A+ (sf)            113,000,000
  M-2AR       A+ (sf)            113,000,000
  M-2AS       A+ (sf)            113,000,000
  M-2AT       A+ (sf)            113,000,000
  M-2AU       A+ (sf)            113,000,000
  M-2AI       A+ (sf)            113,000,000
  M-2AH(i)    NR                   6,675,812
  M-2B        A (sf)             113,000,000
  M-2BR       A (sf)             113,000,000
  M-2BS       A (sf)             113,000,000
  M-2BT       A (sf)             113,000,000
  M-2BU       A (sf)             113,000,000
  M-2BI       A (sf)             113,000,000
  M-2RB       A (sf)             113,000,000
  M-2SB       A (sf)             113,000,000
  M-2TB       A (sf)             113,000,000
  M-2UB       A (sf)             113,000,000
  M-2BH(i)    NR                   6,675,812
  M-3         BBB- (sf)          452,000,000
  M-3R        BBB- (sf)          452,000,000
  M-3S        BBB- (sf)          452,000,000
  M-3T        BBB- (sf)          452,000,000
  M-3U        BBB- (sf)          452,000,000
  M-3I        BBB- (sf)          452,000,000
  M-3A        BBB+ (sf)          226,000,000
  M-3AR       BBB+ (sf)          226,000,000
  M-3AS       BBB+ (sf)          226,000,000
  M-3AT       BBB+ (sf)          226,000,000
  M-3AU       BBB+ (sf)          226,000,000
  M-3AI       BBB+ (sf)          226,000,000
  M-3AH(i)    NR                  13,351,623
  M-3B        BBB- (sf)          226,000,000
  M-3BR       BBB- (sf)          226,000,000
  M-3BS       BBB- (sf)          226,000,000
  M-3BT       BBB- (sf)          226,000,000
  M-3BU       BBB- (sf)          226,000,000
  M-3BI       BBB- (sf)          226,000,000
  M-3RB       BBB- (sf)          226,000,000
  M-3SB       BBB- (sf)          226,000,000
  M-3TB       BBB- (sf)          226,000,000
  M-3UB       BBB- (sf)          226,000,000
  M-3BH(i)    NR                 $13,351,623
  B-1         BB- (sf)           226,000,000
  B-1A        BB+ (sf)           113,000,000
  B-1AR       BB+ (sf)           113,000,000
  B-1AI       BB+ (sf)           113,000,000
  B-1AH(i)    NR                   6,675,812
  B-1B        BB- (sf)           113,000,000
  B-1BH(i)    NR                   6,675,812
  B-2         NR                 226,000,000
  B-2A        B (sf)             113,000,000
  B-2AR       B (sf)             113,000,000
  B-2AI       B (sf)             113,000,000
  B-2AH(i)    NR                   6,675,812
  B-2B        NR                 113,000,000
  B-2BH(i)    NR                   6,675,812
  B-3H(i)     NR                  59,837,906

(i)Reference tranche only and will not have corresponding notes.
Freddie Mac retains the risk of each of these tranches.
NR--Not rated.


STARWOOD MORTGAGE 2018-IMC2: S&P Gives (P)B+ Rating on B-2 Certs
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Starwood
Mortgage Residential Trust 2018-IMC2's mortgage pass-through
certificates.

The note issuance is a residential mortgage-backed securities
(RMBS) transaction backed by first-lien fixed- and adjustable-rate
fully amortizing residential mortgage loans (some with
interest-only periods) secured by single-family residential
properties, planned-unit developments, condominiums, and two- to
four-family residential properties to both prime and nonprime
borrowers. The loans are primarily nonqualified mortgage loans.

The preliminary ratings are based on information as of Nov. 20,
2018. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The pool's collateral composition;
-- The credit enhancement provided for this transaction;
-- The transaction's associated structural mechanics;
-- The representation and warranty framework for this
transaction;
-- The geographic concentration; and
-- The mortgage aggregator, Starwood Non-Agency Lending LLC, and
the mortgage originator, Impac Mortgage Corp.  

  PRELIMINARY RATINGS ASSIGNED

  Starwood Mortgage Residential Trust 2018-IMC2
  Class       Rating          Amount (mil. $)
  A-1         AAA (sf)            193,162,000
  A-2         AA (sf)              16,656,000
  A-3         A (sf)               33,454,000
  M-1         BBB (sf)             13,997,000
  B-1         BB (sf)              10,218,000
  B-2         B+ (sf)               4,479,000
  B-3         NR                    7,979,063
  A-IO-S      NR                     Notional(i)
  XS          NR                     Notional(ii)
  A-R         NR                          N/A

(i)The notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period.
(ii)The notional amount will equal the aggregate class principal
balance of the class A-1, A-2, A-3, M-1, B-1, B-2, and B-3
certificates as of the related distribution date.
NR--Not rated.
N/A--Not applicable.


TRAINER WORTHAM V: S&P Affirms CC Rating on 2 Tranches
------------------------------------------------------
S&P Global Ratings withdrew its ratings on the class C and D notes
from Trainer Wortham CBO V Ltd., a cash flow collateralized debt
obligation (CDO) transaction backed by structured finance
securities. At the same time, S&P affirmed its ratings on the class
A-2 and B notes from the same transaction.

The rating action follows S&P's review of the transaction's
performance using data from the Sept. 28, 2018, monthly trustee
report and the Oct. 4, 2018, payment date report.

S&P said, "Since we do not expect the recovery on the assets to
repay the class C and D notes par balance and their respective
deferred interest upon the transaction's legal final maturity date,
we withdrew our 'D (sf)' ratings according to our criteria.

"At the same time, we affirmed our 'CC (sf)' ratings on the class
A-2 and B notes. Both classes fail our top obligor test at the
'CCC' category and are undercollateralized. The class A-2 note is
currently the most senior note and is expected to continue
receiving the paydowns because all coverage tests in the
transaction are failing. Since the transaction's coverage ratios
are tested first at the class B level, this allows the class B note
to be current in its interest even though the existing assets do
not cover its note balance. Because both notes remain current in
their interest and are yet to defer, we affirmed their 'CC (sf)'
ratings.

"Our review of this transaction included a cash flow analysis,
based on the portfolio and transaction as reflected in the
aforementioned trustee report, to estimate future performance. In
line with our criteria, our cash flow scenarios applied
forward-looking assumptions on the expected timing and pattern of
defaults, and recoveries upon default, under various interest rate
and macroeconomic scenarios. In addition, our analysis considered
the transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis, as well as other qualitative factors as applicable,
demonstrated, in our view, that all of the rated outstanding
classes have adequate credit enhancement available at the rating
levels associated with these rating actions.

"We will continue to review whether, in our view, the rating
assigned to the notes remains consistent with the credit
enhancement available to support them and will take further rating
actions as we deem necessary."

  RATINGS WITHDRAWN

  Trainer Wortham CBO V Ltd.

                    Rating
  Class         To          From
  C             NR          D (sf)
  D             NR          D (sf)  

  RATINGS AFFIRMED

  Trainer Wortham CBO V Ltd.

  Class     Rating
  A-2       CC (sf)
  B         CC (sf)


TREMAN PARK: Moody's Rates $6.25MM Class F-RR Notes 'B3'
--------------------------------------------------------
Moody's Investors Service has assigned ratings to nine classes of
CLO refinancing notes issued by Treman Park CLO, Ltd.:

Moody's rating action is as follows:

US$390,000,000 Class A-RR Senior Secured Floating Rate Notes due
2028 (the "Class A-RR Notes"), Assigned Aaa (sf)

US$9,000,000 Class B-1RR Senior Secured Floating Rate Notes due
2028 (the "Class B-1RR Notes"), Assigned Aa2 (sf)

US$48,000,000 Class B-2RR Senior Secured Floating Rate Notes due
2028 (the "Class B-2RR Notes"), Assigned Aa2 (sf)

US$0 Class C-1RR Secured Deferrable Floating Rate Notes due 2028
(the "Class C-1RR Notes"), Assigned A2 (sf)

US$30,600,000 Class C-2RR Secured Deferrable Floating Rate Notes
due 2028 (the "Class C-2RR Notes"), Assigned A2 (sf)

US$4,000,000 Class C-3RR Secured Deferrable Floating Rate Notes due
2028 (the "Class C-3RR Notes"), Assigned A2 (sf)

US$34,000,000 Class D-RR Secured Deferrable Floating Rate Notes due
2028 (the "Class D-RR Notes"), Assigned Baa3 (sf)

US$32,250,000 Class E-RR Secured Deferrable Floating Rate Notes due
2028 (the "Class E-RR Notes"), Assigned Ba3 (sf)

US$6,250,000 Class F-RR Secured Deferrable Floating Rate Notes due
2028 (the "Class F-RR Notes"), Assigned B3 (sf)

The Issuer is a managed cash flow collateralized loan obligation.
The issued notes are collateralized primarily by a portfolio of
broadly syndicated senior secured corporate loans.

GSO / Blackstone Debt Funds Management LLC manages the CLO. It
directs the selection, acquisition, and disposition of collateral
on behalf of the Issuer.

RATINGS RATIONALE

The ratings reflect the risks due to defaults on the underlying
portfolio of assets, the transaction's legal structure, and the
characteristics of the underlying assets.

The Issuer has issued the Refinancing Notes on November 20, 2018 in
connection with the refinancing of all classes of the secured notes
previously refinanced in part on December 22, 2016 and originally
issued on April 9, 2015. On the Refinancing Date, the Issuer used
proceeds from the issuance of the Refinancing Notes to redeem in
full the Refinanced Notes.

In addition to the issuance of the Refinancing Notes, a variety of
other changes to transaction features will occur in connection with
the refinancing. These include: extension of the reinvestment
period; changes to certain collateral quality tests; changes to the
overcollateralization test levels; and changes to certain
concentration limits.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. For modeling
purposes, Moody's used the following base-case assumptions:

Performing par and principal proceeds balance: $592,200,000

Defaulted par: $0

Diversity Score: 75

Weighted Average Rating Factor (WARF): 2937

Weighted Average Spread (WAS): 3.15%

Weighted Average Coupon (WAC): 7.5%

Weighted Average Recovery Rate (WARR): 47.7%

Weighted Average Life (WAL): 6.91 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for Treman Park CLO, Ltd. was assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on Treman Park CLO, Ltd. Please refer to
Moody's Request for Comment, titled "Proposed Update to Moody's
Global Approach to Rating Collateralized Loan Obligations," for
further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Refinancing Notes is subject to uncertainty.
The performance of the Refinancing Notes is sensitive to the
performance of the underlying portfolio, which in turn depends on
economic and credit conditions that may change. The Manager's
investment decisions and management of the transaction will also
affect the performance of the Refinancing Notes.


WELLS FARGO 2016-C37: Fitch Affirms B-sf Rating on 2 Tranches
-------------------------------------------------------------
Fitch Ratings has affirmed 18 classes of Wells Fargo Commercial
Mortgage Trust 2016-C37 commercial mortgage pass-through
certificates.

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The affirmations are
based on the stable performance of the underlying collateral, which
continues to perform as expected. There are no specially serviced
or delinquent loans. The servicer has nine loans on its watchlist
for tenant bankruptcy, deferred maintenance and other issues. Two
of these loans are considered Fitch Loans of Concern.

The largest loan on the servicer's watchlist, Franklin Square III
(fifth largest loan by pool balance), had the second largest
tenant, Gander Mountain (16% of net rentable area [NRA]), filed for
chapter 11 bankruptcy in March, 2017. Camping World then acquired
Gander Mountain's IP and leases with intention of liquidating the
inventory and reopening select stores. In March 2018, the servicer
approved a 10 year lease agreement with Camping World for the space
formerly occupied by Gander Mountain. The property continues to
exhibit stable performance; and therefore, is not considered a
FLOC.

Minimal Change to Credit Enhancement Since Issuance: No material
changes due to minimal amortization. As of the October 2018
distribution date, the pool's aggregate principal balance has been
reduced by 2.2% to $739.7 million from $750.5 million at issuance.
There has been no defeasance. At the time of Fitch's review, 56% of
the pool is either full or partial interest-only (IO).

ADDITIONAL CONSIDERATIONS

Fitch Loans of Concern: The 11th largest loan, The Lodge &
Waterfall Park Apartments Portfolio, is collateralized by two
multifamily properties in Houston, TX. The loan is on the
servicer's watchlist due to a major fire at one of the residential
buildings. According to the servicer, there was one casualty which
resulted in a $25 million lawsuit pending with the lawsuit
scheduled to go to trial in October 2018. The building has been
restored and tenants began moving back in mid-September. The
building that burned down represented 6% of NRA. The property
continues to exhibit stable performance.

Macgregor Place is an 87,914 square foot office property located in
Cary, NC. The loan is considered a FLOC due to an impending vacancy
by the second largest tenant, Staples (25% NRA). According to the
servicer, the tenant does not intend to renew its lease which
expires at the end of March 2019. Additionally, 100% of the
tenant's leases roll in the next three years. Occupancy is expected
to decline to approximately 70% unless a new tenant is found.

Concentration: 29% of the pool balance is classified as retail
properties and 19% as multi-family. There are 48 properties in the
top 25 MSAs including two properties in Washington DC (12%) and
three properties in New York (8%).

RATING SENSITIVITIES

The Rating Outlooks for all classes remain Stable due to the
overall stable performance of the pool. Fitch does not foresee
positive or negative ratings migration until a material economic or
asset-level event changes the transaction's portfolio level
metrics.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO SEC RULE 17G-10

No third-party due diligence was provided or reviewed in relation
to this rating action.

Fitch has affirmed the following ratings:

  -- $24.7 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $105.7 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $28.5 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $120 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $188.1 million class A-5 at 'AAAsf'; Outlook Stable;

  -- $47.6 million class A-SB at 'AAAsf'; Outlook Stable;

  -- $58.2 million class A-S at 'AAAsf'; Outlook Stable;

  -- $38.5 million class B at 'AA-sf'; Outlook Stable;

  -- $34.7 million class C at 'A-sf'; Outlook Stable;

  -- $37.5 million class D at 'BBB-sf'; Outlook Stable;

  -- $10.3 million class E at 'BB+sf'; Outlook Stable;

  -- $7.5 million class F at 'BB-sf'; Outlook Stable;

  -- $8.4 million class G at 'B-sf'; Outlook Stable;

  -- $514.5* million class X-A at 'AAAsf'; Outlook Stable;

  -- $96.6* million class X-B at 'AA-sf'; Outlook Stable;

  -- $37.5* million class X-D at 'BBB-sf'; Outlook Stable;

  -- $17.8* million class X-EF at 'BB-sf'; Outlook Stable;

  -- $8.4* million class X-G at 'B-sf'; Outlook Stable.

  * Notional amount and IO.

Fitch does not rate the class H, J, X-H and X-J certificates.


WFRBS COMMERCIAL 2014-C25: DBRS Confirms B Rating on Cl. F Certs
----------------------------------------------------------------
DBRS Limited confirmed all classes of Commercial Mortgage
Pass-Through Certificates, Series 2014-C25 issued by WFRBS
Commercial Mortgage Trust 2014-C25 as follows:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-S at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class X-A at AAA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class PEX at A (low) (sf)
-- Class X-B at BBB (sf)
-- Class D at BBB (low) (sf)
-- Class X-C at BB (high) (sf)
-- Class E at BB (sf)
-- Class X-D at B (high) (sf)
-- Class F at B (sf)

All trends are Stable.

Up to the full certificate balance of the Class A-S, Class B and
Class C certificates may be exchanged for the Class PEX
certificates and vice versa.

The rating confirmations are reflective of the overall stable
performance of the transaction since issuance. The transaction
closed in December 2014, with 59 loans secured by 73 properties and
a trust balance of $875.7 million. As of the October 2018
remittance, the pool has seen a collateral reduction of 2.5% since
issuance, with all loans remaining in the pool. The DBRS Term debt
service coverage ratio (DSCR) and DBRS Debt Yield at issuance were
1.61 times (x) and 9.0%, respectively. As of the YE2017 financials,
the weighted-average (WA) in-place DSCR and in-place debt yield
were 1.83x and 10.8%, respectively, with 94.4% of the pool
reporting. Additionally, 48 loans (representing 90.6% of pool) are
reporting partial 2018 financials. The largest 15 loans represent
66.9% of the pool balance and reported a WA DSCR at YE2017 of 1.95x
and a WA cash flow growth of 17.5% over the DBRS issuance figures.
In addition to the overall healthy cash flow growth from issuance,
the pool benefits from defeasance, as six loans (representing 5.6%
of the pool) are fully defeased.

There are challenges in one loan in special servicing and seven
loans on the servicer's watch list, which represent 1.4% and 20.3%
of the current pool balance, respectively. Of the loans on the
watch list, three are being monitored for performance-related
issues. The largest loan on the watch list is Colorado Mills
(Prospectus ID#2, 11.4% of pool), secured by an outlet mall in
Lakewood, Colorado, that was significantly damaged by a hail storm
in May 2017. The damage was so significant that the mall was
essentially closed for several months following the event, with
approximately half of the stores open by Thanksgiving 2017 and
approximately 140 of 230 stores open as of August 2018, according
to online news stories reviewed by DBRS. As a result of the damage,
some tenants have vacated the property, including Neiman Marcus
Last Call, a junior anchor who closed its doors for good shortly
after the hailstorm hit. In the analysis for this loan, a stressed
cash flow scenario was assumed to increase the probability of
default to a level reflective of the increased risks given the
extended length of time to get the property fully back online and
the occupancy declines resulting from these events. A DBRS analyst
will be in the area in mid-November and will visit the property to
gather information on the number of stores open and evidence of new
leasing activity. Those findings will be available on the DBRS
Viewpoint platform shortly thereafter, with registration
information provided below.

The loan in special servicing, Elsinore Courtyard Apartments
(Prospectus ID#20, 1.36% of the pool), was transferred to special
servicing for delinquency in May 2017, and as of the October 2018
remittance, has remained delinquent for 19 months. The sponsor was
cited for numerous code violations at the property and the Special
Servicer has appointed a receiver, E&G Group, who has taken over
other properties for the sponsor in the past. The Special Servicer
reports that the court has provided approval for the receiver to
market the property for sale, a process that has been initiated.
The January 2018 appraisal estimated an as-is value of $12.0
million, suggesting a loss is likely at resolution. For this
review, DBRS assumed a loss severity in excess of 50%, stressed
beyond the severity implied by the current trust exposure and the
appraised value, as it is expected buyers will significantly
discount bids given the property's history and the outstanding
issues remaining to be resolved. For further information on this
loan and the pivotal watch list loans in the pool, please see the
loan commentary in the DBRS Viewpoint platform.

At issuance, DBRS shadow-rated one loan, St. Johns Town Center
(Prospectus ID #1, 11.4% of the pool balance), as investment grade,
supported by the loan's strong credit metrics, strong sponsorship
strength and historically stable collateral performance. With this
review, DBRS confirms that the characteristics of this loan remain
consistent with the investment-grade shadow rating.

Classes X-A, X-B, X-C and X-D are interest-only (IO) certificates
that reference a single rated tranche or multiple rated tranches.
The IO rating mirrors the lowest-rated applicable reference
obligation tranche adjusted upward by one notch if senior in the
waterfall.


ZAIS CLO 11: Moody's Assigns (P)Ba3 Rating on $19MM Class E Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to five
classes of notes to be issued by ZAIS CLO 11, Limited.

Moody's rating action is as follows:

US$240,000,000 Class A-1 Senior Secured Floating Rate Notes due
2032 (the "Class A-1 Notes"), Assigned (P)Aaa (sf)

US$48,000,000 Class B Senior Secured Floating Rate Notes due 2032
(the "Class B Notes"), Assigned (P)Aa2 (sf)

US$21,000,000 Class C Deferrable Mezzanine Floating Rate Notes due
2032 (the "Class C Notes"), Assigned (P)A2 (sf)

US$24,000,000 Class D Deferrable Mezzanine Floating Rate Notes due
2032 (the "Class D Notes"), Assigned (P)Baa3 (sf)

US$19,000,000 Class E Deferrable Mezzanine Floating Rate Notes due
2032 (the "Class E Notes"), Assigned (P)Ba3 (sf)

The Class A-1 Notes, the Class B Notes, the Class C Notes, the
Class D Notes and the Class E Notes are referred to herein,
collectively, as the "Rated Notes."

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions. Upon a conclusive review of a
transaction and associated documentation, Moody's will endeavor to
assign definitive ratings. A definitive rating, if any, may differ
from a provisional rating.

RATINGS RATIONALE

The provisional ratings reflect the risks due to defaults on the
underlying portfolio of assets, the transaction's legal structure,
and the characteristics of the underlying assets.

ZAIS CLO 11 is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90.0% of the portfolio must consist of
first lien senior secured loans, cash, and eligible investments,
and up to 10.0% of the portfolio may consist of second lien loans
and unsecured loans. Moody's expects the portfolio to be
approximately 80.0% ramped as of the closing date.

ZAIS Leveraged Loan Master Manager, LLC (the "Manager") will direct
the selection, acquisition and disposition of the assets on behalf
of the Issuer and may engage in trading activity, including
discretionary trading, during the transaction's five year
reinvestment period. Thereafter, the Manager is not permitted to
engage in any trading activity.

In addition to the Rated Notes, the Issuer will issue one other
class of secured notes and one class of subordinated notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in August 2017.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $400,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2777

Weighted Average Spread (WAS): 3.85%

Weighted Average Coupon (WAC): 7.5%

Weighted Average Recovery Rate (WARR): 46.00%

Weighted Average Life (WAL): 9.00 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for ZAIS CLO 11, Limited was assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for
Collateralized Loan Obligations. If the revised Methodology is
implemented as proposed, Moody's does not expect the changes to
affect the Credit Rating on ZAIS CLO 11, Limited. Please refer to
Moody's Request for Comment, titled "Proposed Update to Moody's
Global Approach to Rating Collateralized Loan Obligations" for
further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

Factors That Would Lead to an Upgrade or Downgrade of the Ratings:


The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.


[*] Moody's Takes Action on $1.35BB of RMBS Issued 2005-2007
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 47 tranches
and downgraded the ratings of two tranches from 26 transactions,
backed by subprime RMBS loans, issued by multiple issuers.

Complete rating actions are as follows:

Issuer: J.P. Morgan Mortgage Acquisition Corp. 2006-ACC1

Cl. M-2, Upgraded to Caa3 (sf); previously on Jul 14, 2010
Downgraded to C (sf)

Issuer: J.P. Morgan Mortgage Acquisition Corp. 2006-CW1

Cl. A-5, Upgraded to Aaa (sf); previously on Mar 26, 2018 Upgraded
to Aa2 (sf)

Cl. M-2, Upgraded to Caa3 (sf); previously on Nov 5, 2010
Downgraded to C (sf)

Issuer: J.P. Morgan Mortgage Acquisition Corp. 2006-FRE2

Cl. M-2, Upgraded to Caa3 (sf); previously on Jul 14, 2010
Downgraded to C (sf)

Issuer: J.P. Morgan Mortgage Acquisition Trust 2007-CH4,
Asset-Backed Pass-Through Certificates, Series 2007-CH4

Cl. A1, Upgraded to Aaa (sf); previously on Mar 16, 2018 Upgraded
to Aa3 (sf)

Cl. A4, Upgraded to Aa2 (sf); previously on Mar 16, 2018 Upgraded
to A3 (sf)

Cl. A5, Upgraded to Aa3 (sf); previously on Mar 16, 2018 Upgraded
to Baa2 (sf)

Cl. M2, Upgraded to Caa3 (sf); previously on Jun 12, 2009
Downgraded to C (sf)

Issuer: MASTR Asset Backed Securities Trust 2005-HE2

Cl. M-2, Downgraded to B1 (sf); previously on Oct 8, 2015 Upgraded
to Ba2 (sf)

Cl. M-4, Upgraded to Caa1 (sf); previously on Mar 4, 2013 Affirmed
C (sf)

Issuer: MASTR Asset Backed Securities Trust 2005-NC1

Cl. M-2, Downgraded to B1 (sf); previously on Apr 3, 2013
Downgraded to Ba3 (sf)

Cl. M-4, Upgraded to Caa3 (sf); previously on Apr 3, 2013 Affirmed
Ca (sf)

Issuer: MASTR Asset Backed Securities Trust 2005-WF1

Cl. M-2, Upgraded to Baa3 (sf); previously on Sep 8, 2014 Upgraded
to Ba1 (sf)

Cl. M-3, Upgraded to Baa3 (sf); previously on Sep 8, 2014 Upgraded
to Ba3 (sf)

Cl. M-7, Upgraded to B1 (sf); previously on Mar 24, 2017 Upgraded
to B2 (sf)

Cl. M-8, Upgraded to B1 (sf); previously on Mar 24, 2017 Upgraded
to Caa2 (sf)

Cl. M-9, Upgraded to Caa2 (sf); previously on Mar 20, 2009
Downgraded to C (sf)

Issuer: MASTR Asset Backed Securities Trust 2006-FRE1

Cl. A-4, Upgraded to Aa3 (sf); previously on Mar 6, 2018 Upgraded
to Baa1 (sf)

Cl. M-1, Upgraded to Ca (sf); previously on May 5, 2010 Downgraded
to C (sf)

Issuer: Meritage Mortgage Loan Trust 2005-3

Cl. A-5, Upgraded to Caa2 (sf); previously on Apr 29, 2010
Downgraded to Ca (sf)

Issuer: Merrill Lynch Mortgage Investors Trust 2006-OPT1

Cl. A-1, Upgraded to B3 (sf); previously on Feb 27, 2018 Upgraded
to Caa1 (sf)

Cl. A-2C, Upgraded to B3 (sf); previously on Feb 27, 2018 Upgraded
to Caa2 (sf)

Issuer: Merrill Lynch Mortgage Investors Trust Series 2005-HE1

Cl. M-2, Upgraded to Caa1 (sf); previously on Feb 23, 2015 Upgraded
to Ca (sf)

Issuer: Merrill Lynch Mortgage Investors Trust Series 2006-HE5

Cl. A-1, Upgraded to Ba3 (sf); previously on Jun 20, 2017 Upgraded
to B2 (sf)

Issuer: Merrill Lynch Mortgage Investors, Inc. 2005-WMC1

Cl. B-1, Upgraded to Caa1 (sf); previously on Feb 3, 2017 Upgraded
to Ca (sf)

Cl. B-2, Upgraded to Caa1 (sf); previously on Jul 19, 2010
Downgraded to C (sf)

Cl. M-3, Upgraded to Ba2 (sf); previously on Feb 24, 2016 Upgraded
to B1 (sf)

Cl. M-4, Upgraded to Ba3 (sf); previously on Feb 3, 2017 Upgraded
to Caa1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-HE6

Cl. M-3, Upgraded to Caa3 (sf); previously on Jul 15, 2010
Downgraded to C (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2005-NC2

Cl. M-5, Upgraded to Caa2 (sf); previously on Jul 15, 2010
Downgraded to Ca (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2006-HE2

Cl. A-1, Upgraded to Aaa (sf); previously on Mar 16, 2018 Upgraded
to A1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2006-HE3

Cl. A-1, Upgraded to Aaa (sf); previously on Mar 16, 2018 Upgraded
to A1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2006-NC3

Cl. A-1, Upgraded to Aa1 (sf); previously on Mar 16, 2018 Upgraded
to A2 (sf)

Cl. A-2d, Upgraded to A3 (sf); previously on Mar 16, 2018 Upgraded
to Baa2 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2007-HE6

Cl. A-1, Upgraded to Caa2 (sf); previously on Apr 19, 2013
Downgraded to Ca (sf)

Cl. A-2, Upgraded to Caa2 (sf); previously on Jul 15, 2010
Downgraded to Ca (sf)

Cl. A-3, Upgraded to Caa2 (sf); previously on Jul 15, 2010
Downgraded to Ca (sf)

Cl. A-4, Upgraded to Caa2 (sf); previously on Jul 15, 2010
Downgraded to Ca (sf)

Issuer: Morgan Stanley Home Equity Loan Trust 2005-1

Cl. M-5, Upgraded to Caa3 (sf); previously on Jul 15, 2010
Downgraded to C (sf)

Issuer: Morgan Stanley Home Equity Loan Trust 2006-2

Cl. A-4, Upgraded to Aaa (sf); previously on Mar 19, 2018 Upgraded
to Aa3 (sf)

Cl. M-1, Upgraded to B1 (sf); previously on Mar 19, 2018 Upgraded
to B3 (sf)

Issuer: Nationstar Home Equity Loan Trust 2006-B

Cl. M-2, Upgraded to B1 (sf); previously on Mar 27, 2018 Upgraded
to B2 (sf)

Cl. M-3, Upgraded to Caa3 (sf); previously on May 5, 2010
Downgraded to C (sf)

Issuer: New Century Home Equity Loan Trust 2005-4

Cl. M-4, Upgraded to B1 (sf); previously on Apr 10, 2017 Upgraded
to B2 (sf)

Cl. M-5, Upgraded to Ca (sf); previously on Jun 1, 2010 Downgraded
to C (sf)

Issuer: New Century Home Equity Loan Trust, Series 2005-1

Cl. M-4, Upgraded to B1 (sf); previously on Apr 10, 2017 Upgraded
to B3 (sf)

Issuer: Newcastle Mortgage Securities Trust 2006-1

Cl. M-4, Upgraded to B2 (sf); previously on Mar 16, 2018 Upgraded
to Caa1 (sf)

Issuer: Nomura Home Equity Loan Trust 2006-HE2

Cl. A-3, Upgraded to Aaa (sf); previously on Dec 16, 2016 Upgraded
to Aa2 (sf)

Cl. A-4, Upgraded to Aaa (sf); previously on Dec 16, 2016 Upgraded
to A1 (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to improvement in pool
performances and credit enhancement available to the bonds. In
addition, the rating upgrades on Morgan Stanley ABS Capital I Inc.
Trust 2007-HE6 Classes A-1, A-2, A-3 and A-4 are due to significant
funds distributed to the bonds in December 2017 as part of a
settlement in relation to a breach of representations and
warranties. The rating downgrades on MASTR Asset Backed Securities
Trust 2005-HE2 Cl. M-2 and MASTR Asset Backed Securities Trust
2005-NC1 Cl. M-2 are due to outstanding interest shortfalls on the
bonds which are not expected to be recouped as the bonds have a
weak reimbursement mechanism for interest shortfalls. The rating
actions reflect the recent performance of the underlying pools and
Moody's updated loss expectations on those pools.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in January 2017.

The Credit Ratings were assigned in accordance with Moody's
existing Methodology entitled "US RMBS Surveillance Methodology,"
dated 1/31/2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for pre-2009 US
RMBS Prime Jumbo, Alt-A, Option ARM, Subprime, Scratch and Dent,
Second Lien and Manufactured Housing transactions. If the revised
Methodology is implemented as proposed, these Credit Ratings are
not expected to be affected. Please refer to Moody's Request for
Comment, titled "Proposed Update to US RMBS Surveillance
Methodology," for further details regarding the implications of the
proposed Methodology revisions on certain Credit Ratings.

Factors that would lead to an upgrade or downgrade of the ratings:


Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in October 2018 from 4.1% in
October 2017. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2018 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2018. Lower increases than
Moody's expects or decreases could lead to negative rating actions.
Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions.


[*] Moody's Takes Action on $103.2MM RMBS Issued 1998 & 2004
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 29 tranches
and downgraded the ratings of four tranches from 17 transactions,
backed by subprime RMBS loans, issued by multiple issuers.

Complete rating actions are as follows:

Issuer: ABSC Home Equity Loan Trust Pass-Through Certificates,
Series 2001-HE3

Cl. A-1, Upgraded to A1 (sf); previously on Aug 18, 2016 Upgraded
to A2 (sf)

Cl. M2, Upgraded to Baa3 (sf); previously on Sep 18, 2015 Upgraded
to B1 (sf)

Issuer: ACE Securities Corp. Home Equity Loan 1999-LB2

A, Upgraded to Aa1 (sf); previously on May 11, 2012 Downgraded to
A1 (sf)

Issuer: Aegis Asset Backed Securities Trust 2004-2

Cl. M1, Upgraded to Aa1 (sf); previously on Mar 26, 2018 Upgraded
to A1 (sf)

Cl. M2, Upgraded to Baa3 (sf); previously on Mar 26, 2018 Upgraded
to B1 (sf)

Cl. M3, Upgraded to B1 (sf); previously on Mar 26, 2018 Upgraded to
Caa1 (sf)

Issuer: AFC Mtg Loan AB Certs 1999-01

1A, Upgraded to Caa2 (sf); previously on May 2, 2012 Downgraded to
Caa3 (sf)

Underlying Rating: Upgraded to Caa2 (sf); previously on May 2, 2012
Downgraded to Caa3 (sf)

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Issuer: AMRESCO Residential Mortgage Loan Trust 1998-3

A-5, Upgraded to Caa1 (sf); previously on Mar 23, 2018 Upgraded to
Caa3 (sf)

A-6, Upgraded to Caa1 (sf); previously on Mar 23, 2018 Upgraded to
Caa3 (sf)

A-7, Upgraded to Aa2 (sf); previously on Dec 12, 2012 Downgraded to
A1 (sf)

Issuer: Argent Securities Inc., Series 2003-W2

Cl. M-4, Downgraded to B3 (sf); previously on Mar 18, 2013 Affirmed
B2 (sf)

Issuer: Argent Securities Inc., Series 2003-W9

Cl. M-3, Upgraded to Ba3 (sf); previously on Sep 18, 2015 Upgraded
to B3 (sf)

Cl. M-3B, Upgraded to Ba3 (sf); previously on Sep 18, 2015 Upgraded
to B3 (sf)

Cl. M-6, Upgraded to Ca (sf); previously on Mar 18, 2011 Downgraded
to C (sf)

Issuer: Asset Backed Securities Corporation Home Equity Loan Trust,
Series 2001-HE1

Cl. M-2, Upgraded to Caa2 (sf); previously on Apr 12, 2012
Downgraded to C (sf)

Issuer: Bear Stearns Asset Backed Securities Trust 2003-3

Cl. A-2, Upgraded to A2 (sf); previously on Dec 2, 2013 Downgraded
to Baa2 (sf)

Issuer: Carrington Mortgage Loan Trust, Series 2004-NC2

Cl. M-2, Upgraded to B3 (sf); previously on Feb 27, 2018 Upgraded
to Caa3 (sf)

Cl. M-3, Upgraded to B3 (sf); previously on Mar 13, 2011 Downgraded
to C (sf)

Issuer: Chase Funding Loan Acquisition Trust 2004-AQ1

Cl. M-1, Upgraded to Baa2 (sf); previously on Jun 11, 2015 Upgraded
to Baa3 (sf)

Cl. M-2, Upgraded to Ba3 (sf); previously on Apr 26, 2016 Upgraded
to B3 (sf)

Cl. M-3, Upgraded to Caa1 (sf); previously on Jun 11, 2015 Upgraded
to Caa2 (sf)

Cl. B-1, Upgraded to Caa2 (sf); previously on Apr 10, 2012
Downgraded to C (sf)

Issuer: Citigroup Mortgage Loan Trust, Series 2003-HE3

Cl. A, Upgraded to Aaa (sf); previously on Jul 7, 2016 Upgraded to
Aa2 (sf)

Underlying Rating: Upgraded to Aaa (sf); previously on Jul 7, 2016
Upgraded to Aa2 (sf)*

Financial Guarantor: Ambac Assurance Corporation (Segregated
Account - Unrated)

Cl. M-3, Upgraded to B1 (sf); previously on Jul 7, 2016 Upgraded to
B2 (sf)

Cl. M-4, Upgraded to Ca (sf); previously on Apr 9, 2012 Confirmed
at C (sf)

Issuer: CWABS, Inc. Asset-Backed Certificates, Series 2002-5

Cl. MV-2, Upgraded to Baa3 (sf); previously on Feb 26, 2018
Downgraded to B1 (sf)

Issuer: Equifirst Mortgage Loan Trust 2003-1

Cl. M-2, Upgraded to Baa3 (sf); previously on May 5, 2014
Downgraded to Ba3 (sf)

Issuer: Equifirst Mortgage Loan Trust 2004-2

Cl. M-7, Upgraded to B1 (sf); previously on Feb 27, 2018 Upgraded
to B3 (sf)

Cl. M-8, Upgraded to Caa2 (sf); previously on Mar 7, 2011
Downgraded to C (sf)

Issuer: Equifirst Mortgage Loan Trust 2004-3

Cl. M-7, Upgraded to B1 (sf); previously on Apr 26, 2016 Upgraded
to B2 (sf)

Issuer: GE Capital Mtg Services Inc 1999-HE1

A6, Downgraded to Ba1 (sf); previously on Jun 9, 2014 Downgraded to
Baa1 (sf)

S*, Downgraded to Caa2 (sf); previously on Oct 27, 2017 Confirmed
at Caa1 (sf)

A7, Downgraded to Baa3 (sf); previously on Jun 9, 2014 Downgraded
to Baa1 (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to an improvement in
underlying pool performance and credit enhancement available to the
bonds. The rating downgrade on Argent Securities Inc., Series
2003-W2, Cl. M-4 is due to outstanding interest shortfalls on the
bond which are not expected to be recouped as the bond has a weak
reimbursement mechanism for interest shortfalls. The rating
downgrades on GE Capital Mtg Services Inc 1999-HE1, Cl. A6, Cl. A7
and Cl. S are due to the weak performance of the underlying
collateral. The rating actions reflect Moody's updated loss
expectations on the pools.

The principal methodology used in rating all bonds except
interest-only classes was "US RMBS Surveillance Methodology"
published on January 2017. The methodologies used in rating
interest-only classes were "US RMBS Surveillance Methodology"
published on January 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published on June
2017.

The Credit Ratings were assigned in accordance with Moody's
existing Methodology entitled "US RMBS Surveillance Methodology,"
dated 1/31/2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for pre-2009 US
RMBS Prime Jumbo, Alt-A, Option ARM, Subprime, Scratch and Dent,
Second Lien and Manufactured Housing transactions. If the revised
Methodology is implemented as proposed, these Credit Ratings are
not expected to be affected. Please refer to Moody's Request for
Comment, titled "Proposed Update to US RMBS Surveillance
Methodology," for further details regarding the implications of the
proposed Methodology revisions on certain Credit Ratings.

"The Credit Rating for GE Capital Mtg Services Inc 1999-HE1 Cl. S
was assigned in accordance with Moody's existing Methodology
entitled "Moody's Approach to Rating Structured Finance
Interest-Only (IO) Securities," dated 6/8/2017. Please note that on
November 14, 2018, Moody's released a Request for Comment, in which
it has requested market feedback on potential revisions to its
Methodology for Structured Finance Interest-Only (IO) Securities.
If the revised Methodology is implemented as proposed, the Credit
Rating on GE Capital Mtg Services Inc 1999-HE1 Cl. S may be
positively affected. Please refer to Moody's Request for Comment,
titled "Proposed Update to Moody's Approach to Rating Structured
Finance Interest-Only (IO) Securities," for further details
regarding the implications of the proposed Methodology revisions on
certain Credit Ratings."

Factors that would lead to an upgrade or downgrade of the ratings:


Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in October 2018 from 4.1% in
October 2017. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2018 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2018. Lower increases than
Moody's expects or decreases could lead to negative rating actions.
An IO bond may be upgraded or downgraded, within the constraints
and provisions of the IO methodology, based on lower or higher
realized and expected loss due to an overall improvement or decline
in the credit quality of the reference bonds and/or pools. Finally,
performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


[*] Moody's Takes Action on $7.25BB of RMBS Issued 2005-2007
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 97 tranches
from 36 transactions, backed by subprime RMBS loans, issued by
multiple issuers.

Complete rating actions are as follows:

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series
2006-ASAP3

Cl. A-2C, Upgraded to A1 (sf); previously on Dec 29, 2016 Upgraded
to Ba1 (sf)

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series
2006-ASAP4

Cl. A-1, Upgraded to Ba3 (sf); previously on May 25, 2017 Upgraded
to Caa1 (sf)

Cl. A-2C, Upgraded to Ba1 (sf); previously on May 25, 2017 Upgraded
to Caa1 (sf)

Cl. A-2D, Upgraded to Ba3 (sf); previously on May 25, 2017 Upgraded
to Caa2 (sf)

Issuer: Argent Securities Trust 2006-W1

Cl. A-1, Upgraded to A3 (sf); previously on Sep 2, 2015 Upgraded to
Ba1 (sf)

Cl. A-2C, Upgraded to Caa2 (sf); previously on Mar 5, 2014
Downgraded to Ca (sf)

Cl. A-2D, Upgraded to Caa2 (sf); previously on Mar 5, 2014
Downgraded to Ca (sf)

Issuer: Asset Backed Securities Corporation Home Equity Loan Trust
2005-HE1

Cl. M4, Upgraded to B2 (sf); previously on Apr 27, 2017 Upgraded to
Caa2 (sf)

Issuer: Asset Backed Securities Corporation Home Equity Loan Trust
Series MO 2006-HE6

Cl. A1, Upgraded to A1 (sf); previously on Nov 17, 2017 Upgraded to
Baa1 (sf)

Cl. A4, Upgraded to Baa1 (sf); previously on Nov 17, 2017 Upgraded
to Ba1 (sf)

Cl. A5, Upgraded to Baa3 (sf); previously on Nov 17, 2017 Upgraded
to Ba2 (sf)

Issuer: Asset Backed Securities Corporation Home Equity Loan Trust,
Series RFC 2007-HE1

Cl. A1A, Upgraded to Ba1 (sf); previously on Mar 26, 2018 Upgraded
to Ba3 (sf)

Cl. A1B, Upgraded to Ba1 (sf); previously on Mar 26, 2018 Upgraded
to Ba3 (sf)

Cl. A4, Upgraded to Caa2 (sf); previously on Sep 2, 2015 Upgraded
to Caa3 (sf)

Cl. A5, Upgraded to Caa3 (sf); previously on Jul 12, 2010
Downgraded to Ca (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2005-HE11

Cl. M-1, Upgraded to Baa3 (sf); previously on Jun 27, 2013 Upgraded
to B1 (sf)

Cl. M-3, Upgraded to B2 (sf); previously on Feb 27, 2018 Upgraded
to Caa1 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2005-TC1

Cl. M-4, Upgraded to B1 (sf); previously on Feb 27, 2018 Upgraded
to B2 (sf)

Cl. M-5, Upgraded to B2 (sf); previously on Feb 27, 2018 Upgraded
to Caa3 (sf)

Cl. M-6, Upgraded to Caa1 (sf); previously on May 21, 2010
Downgraded to C (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2005-TC2

Cl. M-7, Upgraded to B1 (sf); previously on Feb 27, 2018 Upgraded
to B2 (sf)

Cl. M-8, Upgraded to B1 (sf); previously on Feb 27, 2018 Upgraded
to B3 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2006-HE3

Cl. A-3, Upgraded to Aaa (sf); previously on Apr 27, 2017 Upgraded
to Aa3 (sf)

Cl. M-1, Upgraded to B1 (sf); previously on Apr 27, 2017 Upgraded
to B2 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2006-HE9

Cl. I-A-2, Upgraded to B2 (sf); previously on Mar 27, 2018 Upgraded
to B3 (sf)

Cl. I-A-3, Upgraded to Caa1 (sf); previously on Mar 27, 2018
Upgraded to Caa2 (sf)

Cl. II-A, Upgraded to B3 (sf); previously on Mar 27, 2018 Upgraded
to Caa2 (sf)

Cl. III-A, Upgraded to B3 (sf); previously on Mar 27, 2018 Upgraded
to Caa2 (sf)

Issuer: Bravo Mortgage Asset Trust 2006-1

Cl. A-2, Upgraded to Aaa (sf); previously on May 25, 2017 Upgraded
to Aa2 (sf)

Cl. A-3, Upgraded to Aaa (sf); previously on May 25, 2017 Upgraded
to Aa3 (sf)

Cl. M-1, Upgraded to B1 (sf); previously on May 25, 2017 Upgraded
to B3 (sf)

Issuer: Carrington Home Equity Loan Trust Series 2005-NC4

Cl. M-3, Upgraded to B1 (sf); previously on Apr 12, 2016 Upgraded
to B2 (sf)

Cl. M-4, Upgraded to Caa3 (sf); previously on Apr 29, 2010
Downgraded to C (sf)

Issuer: Carrington Mortgage Loan Trust, Series 2005-OPT2

Cl. M-5, Upgraded to B1 (sf); previously on Apr 12, 2016 Upgraded
to B3 (sf)

Cl. M-6, Upgraded to Ca (sf); previously on Mar 12, 2013 Affirmed C
(sf)

Issuer: Carrington Mortgage Loan Trust, Series 2006-NC3
Cl. A-4, Upgraded to Caa2 (sf); previously on Apr 29, 2010
Downgraded to Ca (sf)

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2005-CB1

Cl. B-1, Upgraded to B1 (sf); previously on Jun 25, 2015 Upgraded
to Caa3 (sf)

Cl. B-2, Upgraded to B1 (sf); previously on Mar 10, 2011 Downgraded
to Ca (sf)

Cl. M-2, Upgraded to Ba1 (sf); previously on Apr 18, 2016 Upgraded
to B1 (sf)

Cl. M-3, Upgraded to Ba3 (sf); previously on Apr 18, 2016 Upgraded
to Caa1 (sf)

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2005-CB2

Cl. B-1, Upgraded to B1 (sf); previously on Feb 27, 2018 Upgraded
to Caa1 (sf)

Cl. B-2, Upgraded to Caa1 (sf); previously on Mar 10, 2011
Downgraded to C (sf)

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2006-CB6

Cl. A-I, Upgraded to Aaa (sf); previously on Mar 16, 2018 Upgraded
to A3 (sf)

Cl. A-II-3, Upgraded to Baa1 (sf); previously on Mar 16, 2018
Upgraded to Ba2 (sf)

Cl. A-II-4, Upgraded to Baa3 (sf); previously on Mar 16, 2018
Upgraded to Ba2 (sf)

Cl. M-1, Upgraded to Ca (sf); previously on Apr 12, 2010 Downgraded
to C (sf)

Issuer: Centex Home Equity Loan Trust 2005-A

Cl. M-4, Upgraded to Ba3 (sf); previously on Jun 8, 2017 Upgraded
to B3 (sf)

Cl. M-5, Upgraded to B1 (sf); previously on Jun 8, 2017 Upgraded to
Caa2 (sf)

Issuer: Centex Home Equity Loan Trust 2005-D

Cl. M-6, Upgraded to B1 (sf); previously on Mar 19, 2018 Upgraded
to B3 (sf)

Issuer: Centex Home Equity Loan Trust 2006-A

Cl. AV-4, Upgraded to Aaa (sf); previously on Apr 10, 2017 Upgraded
to Aa3 (sf)

Cl. M-3, Upgraded to B2 (sf); previously on Apr 10, 2017 Upgraded
to Caa3 (sf)

Issuer: Citicorp Residential Mortgage Trust Series 2006-3

Cl. A-4, Upgraded to Aaa (sf); previously on Mar 16, 2018 Upgraded
to A1 (sf)

Cl. A-5, Upgraded to Aa1 (sf); previously on Mar 16, 2018 Upgraded
to A2 (sf)

Cl. A-6, Upgraded to Aa1 (sf); previously on Mar 16, 2018 Upgraded
to A1 (sf)

Cl. M-1, Upgraded to B1 (sf); previously on Mar 16, 2018 Upgraded
to Caa2 (sf)

Issuer: Citicorp Residential Mortgage Trust Series 2007-1

Cl. A-4, Upgraded to Aa1 (sf); previously on Nov 17, 2017 Upgraded
to Baa2 (sf)

Cl. A-5, Upgraded to Aa3 (sf); previously on Nov 17, 2017 Upgraded
to Baa3 (sf)

Cl. A-6, Upgraded to Aa2 (sf); previously on Nov 17, 2017 Upgraded
to Baa2 (sf)

Cl. M-1, Upgraded to B3 (sf); previously on Nov 17, 2017 Upgraded
to Ca (sf)

Issuer: Citigroup Mortgage Loan Trust 2007-AMC3

Cl. A-1, Upgraded to Caa1 (sf); previously on Apr 6, 2010
Downgraded to Ca (sf)

Cl. A-2B, Upgraded to Caa2 (sf); previously on Apr 6, 2010
Downgraded to Ca (sf)

Cl. A-2C, Upgraded to Caa2 (sf); previously on Apr 6, 2010
Confirmed at Ca (sf)

Cl. A-2D, Upgraded to Caa2 (sf); previously on Apr 6, 2010
Confirmed at Ca (sf)

Issuer: Citigroup Mortgage Loan Trust, Series 2005-OPT3

Cl. M-5, Upgraded to B1 (sf); previously on May 5, 2017 Upgraded to
B3 (sf)

Cl. M-6, Upgraded to Caa3 (sf); previously on Feb 26, 2013 Affirmed
C (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2005-10

Cl. AF-4, Upgraded to A1 (sf); previously on Jun 26, 2017 Upgraded
to Ba1 (sf)

Cl. AF-5, Upgraded to Ba1 (sf); previously on Jun 26, 2017 Upgraded
to B1 (sf)

Cl. AF-6, Upgraded to Baa3 (sf); previously on Jun 26, 2017
Upgraded to Ba3 (sf)

Cl. MV-5, Upgraded to B2 (sf); previously on Jun 26, 2017 Upgraded
to Caa1 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2005-11

Cl. AF-4, Upgraded to Baa1 (sf); previously on Jun 26, 2017
Upgraded to Ba2 (sf)

Cl. AF-5A, Upgraded to Baa2 (sf); previously on Jun 26, 2017
Upgraded to Ba3 (sf)

Cl. AF-5B, Upgraded to Baa2 (sf); previously on Jun 26, 2017
Upgraded to Ba3 (sf)

Underlying Rating: Upgraded to Baa2 (sf); previously on Jun 26,
2017 Upgraded to Ba3 (sf)

Financial Guarantor: MBIA Insurance Corporation (Affirmed at Caa1,
Outlook Developing on Jan 17, 2018)

Cl. AF-6, Upgraded to Baa1 (sf); previously on Jun 26, 2017
Upgraded to Ba2 (sf)

Cl. MF-1, Upgraded to Ca (sf); previously on Apr 14, 2010
Downgraded to C (sf)

Cl. MV-5, Upgraded to Ca (sf); previously on Apr 14, 2010
Downgraded to C (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2005-AB2

Cl. 1-A-1, Upgraded to Aaa (sf); previously on Jun 26, 2017
Upgraded to Aa3 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2005-AB4

Cl. 2-A-1, Upgraded to Caa2 (sf); previously on Oct 13, 2016
Confirmed at Ca (sf)

Cl. 2-A-3, Upgraded to Caa2 (sf); previously on Oct 13, 2016
Confirmed at Ca (sf)

Cl. 2-A-4, Upgraded to Caa2 (sf); previously on Oct 13, 2016
Confirmed at Ca (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2006-14

Cl. 2-A-2, Upgraded to A3 (sf); previously on Jun 26, 2017 Upgraded
to Ba1 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2006-2

Cl. 2-A-3, Upgraded to Aa2 (sf); previously on Oct 26, 2016
Upgraded to A2 (sf)

Cl. 2-A-4, Upgraded to Aa2 (sf); previously on Oct 26, 2016
Upgraded to A2 (sf)

Cl. M-2, Upgraded to Ca (sf); previously on Mar 25, 2009 Downgraded
to C (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2006-21

Cl. 1-A, Upgraded to B3 (sf); previously on Oct 17, 2016 Upgraded
to Caa2 (sf)

Cl. 2-A-3, Upgraded to B2 (sf); previously on Oct 17, 2016 Upgraded
to Caa2 (sf)

Cl. 2-A-4, Upgraded to Caa2 (sf); previously on Oct 17, 2016
Upgraded to Ca (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2006-25

Cl. 2-A-3, Upgraded to Ba2 (sf); previously on Jun 26, 2017
Upgraded to B1 (sf)

Cl. 2-A-4, Upgraded to B2 (sf); previously on Jun 26, 2017 Upgraded
to Caa2 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2006-6

Cl. 1-A-1, Upgraded to A2 (sf); previously on Jun 26, 2017 Upgraded
to Baa1 (sf)

Cl. 1-A-1M, Upgraded to A3 (sf); previously on Jun 26, 2017
Upgraded to Baa2 (sf)

Cl. 2-A-3, Upgraded to Aa1 (sf); previously on Jun 26, 2017
Upgraded to A1 (sf)

Cl. M-1, Upgraded to Ca (sf); previously on Mar 25, 2009 Downgraded
to C (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2006-8

Cl. 2-A-3, Upgraded to B1 (sf); previously on Oct 19, 2016 Upgraded
to Caa1 (sf)

Cl. 2-A-4, Upgraded to B3 (sf); previously on Oct 19, 2016 Upgraded
to Caa3 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2006-BC5

Cl. 1-A, Upgraded to Caa2 (sf); previously on Oct 19, 2016
Confirmed at Ca (sf)

Cl. 2-A-3, Upgraded to Caa1 (sf); previously on Oct 19, 2016
Upgraded to Caa3 (sf)

Cl. 2-A-4, Upgraded to Caa3 (sf); previously on Oct 19, 2016
Upgraded to Ca (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to improvement in pool
performances and credit enhancement available to the bonds. The
rating actions reflect the recent performance of the underlying
pools and Moody's updated loss expectations on those pools.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in January 2017.

The Credit Ratings were assigned in accordance with Moody's
existing Methodology entitled "US RMBS Surveillance Methodology,"
dated 1/31/2017. Please note that on November 14, 2018, Moody's
released a Request for Comment, in which it has requested market
feedback on potential revisions to its Methodology for pre-2009 US
RMBS Prime Jumbo, Alt-A, Option ARM, Subprime, Scratch and Dent,
Second Lien and Manufactured Housing transactions. If the revised
Methodology is implemented as proposed, these Credit Ratings are
not expected to be affected. Please refer to Moody's Request for
Comment, titled "Proposed Update to US RMBS Surveillance
Methodology," for further details regarding the implications of the
proposed Methodology revisions on certain Credit Ratings.

Factors that would lead to an upgrade or downgrade of the ratings:


Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in October 2018 from 4.1% in
October 2017. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2018 year. Deviations from this central
scenario could lead to rating actions in the sector.House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2018. Lower increases than
Moody's expects or decreases could lead to negative rating
actions.Finally, performance of RMBS continues to remain highly
dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can impact
the performance of these transactions.


[*] S&P Takes Various Actions on 49 Classes From 15 US RMBS Deals
-----------------------------------------------------------------
S&P Global Ratings completed its review of 49 classes from 15 U.S.
residential mortgage-backed securities (RMBS) transactions issued
between 2003 and 2008. All of these transactions are backed by
subprime and Federal Housing Administration/Veterans Affairs
collateral, as well as "scratch and dent" subtypes document
deficient and non-performing loans. The review yielded eight
upgrades, three downgrades, 37 affirmations, and one
discontinuance.

Analytical Considerations

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes. Some of these considerations include:

-- Collateral performance/delinquency trends;
-- Historical interest shortfalls;
-- Priority of principal payments;
-- Proportion of reperforming loans in the pool; and
-- Available subordination and/or overcollateralization.

Rating Actions

S&P said, "The affirmations of ratings reflect our opinion that our
projected credit support and collateral performance on these
classes has remained relatively consistent with our prior
projections.

"We raised our ratings on five classes as a result of increased
credit support. These classes have benefitted from the failure of
performance triggers and/or reduced subordinate class principal
distribution amounts, which has built credit support for these
classes as a percent of their respective deal balance. Ultimately,
we believe these classes have credit support that is sufficient to
withstand losses at higher rating levels.

"We raised our rating on class A4 from Structured Asset Securities
Corporation Mortgage Loan Trust 2006-EQ1 by 10 notches due to
expected short duration. Based on the class' average recent
principal allocation, this class is projected to pay down in a
short period of time relative to projected loss timing, limiting
its exposure to potential losses.

"We lowered our ratings on classes A-1 and A-2 from Option One
Mortgage Loan Trust 2003-4 due to reduced projected excess interest
resulting from rising interest rates. A majority of the respective
pools are comprised of fixed-rate loans, while A-1 and A-2 are
floating rate classes based on LIBOR. Rising interest rates have
caused the spread between the pool's weighted average coupons and
the class' coupon to tighten. As a result, the amount of projected
excess interest available to absorb credit losses has decreased."

A list of Affected Ratings can be viewed at:

          https://bit.ly/2TvTBxJ


[*] S&P Takes Various Actions on 77 Classes From 29 US RMBS Deals
-----------------------------------------------------------------
S&P Global Ratings completed its review of 77 classes from 29 U.S.
residential mortgage-backed securities (RMBS) transactions issued
between 1998 and 2007. All of these transactions are backed by
subprime and re-performing collateral. The review yielded 14
upgrades, six downgrades, and 57 affirmations.

Analytical Considerations

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes. Some of these considerations include:

-- Collateral performance/delinquency trends;
-- Historical missed interest payments;
-- Priority of principal payments; Loan modifications; and
-- Available subordination and/or overcollateralization.

Rating Actions

S&P said, "The affirmations of ratings reflect our opinion that our
projected credit support and collateral performance on these
classes has remained relatively consistent with our prior
projections.

"We raised five ratings by five or more notches due to increased
credit support. The upgrades on these classes reflect the classes'
ability to withstand a higher level of projected losses than
previously anticipated.

"We lowered our rating on class B-1 from C-BASS Mortgage Loan
Asset-Backed Certificates series 2002-CB1 to 'B (sf)' from 'BBB
(sf)' after assessing the impact of missed interest payments on
this class. We applied our interest shortfall criteria as stated in
"Criteria - Structured Finance - General: Structured Finance
Temporary Interest Shortfall Methodology," published Dec. 15, 2015,
which impose a maximum rating threshold on classes that have
incurred missed interest payments resulting from credit or
liquidity erosion. In applying the criteria, we looked to see if
this class received additional compensation beyond the imputed
interest due as direct economic compensation for the delay in
interest payments, which this class did. Additionally, this class
has a delayed reimbursement provision. The downgrade is based on
our cash flow projections used in determining the likelihood that
the missed interest payments would be reimbursed under various
scenarios."

A list of Affected Ratings can be viewed at:

          https://bit.ly/2PJbwSY


                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
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equity securities trade in public market are determined by more
than a balance sheet solvency test.

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
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Each Friday's edition of the TCR includes a review about a book of
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Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

TCR subscribers have free access to our on-line news archive.
Point your Web browser to http://TCRresources.bankrupt.com/and use
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                            *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.  
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Copyright 2018.  All rights reserved.  ISSN: 1520-9474.

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