/raid1/www/Hosts/bankrupt/TCR_Public/190317.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, March 17, 2019, Vol. 23, No. 75

                            Headlines

AMERICREDIT AUTOMOBILE 2019-1: Fitch Rates Class E Notes 'BBsf'
ARES CLO XXXIX: Moody's Gives '(P)Ba3' Rating on Class E-R Notes
BANK 2017-BNK4: Fitch Affirms B- Rating on 2 Tranches
BARINGS CLO 2019-II: Moody's Gives (P)Ba3 Rating on Class D Notes
BEAR STEARNS 2006-PWR11: Fitch Affirms D on $16.1MM Class E Debt

CARRINGTON MORTGAGE 2004-NC1: Moody's Hikes M-4 Debt Rating to Caa1
CITIGROUP COMMERCIAL 2014-GC21: DBRS Confirms B Rating on F Certs
CSAIL 2019-C15: DBRS Finalizes BB(high) Rating on Class F-RR Certs
CSFB MORTGAGE 2005-C3: Moody's Hikes Class C Certs Rating to 'Ba1'
DBUBS COMMERCIAL 2011-LC1: Moody's Affirms Class G Certs at 'B2'

ELLINGTON CLO IV: Moody's Assigns Ba3 Rating on 2 Tranches
FAIRSTONE FINANCIAL 2019-1: Moody's Gives (P)Ba3 Rating to D Notes
FREDDIE MAC 2019-1: DBRS Assigns (P)B(low) on $78MM Cl. M Certs
FREDDIE MAC 2019-1: Fitch Rates $78MM Class M Certs 'B-'
FREDDIE MAC 2019-DNA2: Fitch to Rate 15 Tranches 'B(EXP)'

HOUSTON GALLERIA 2015-HGLR: DBRS Confirms BB Rating on Cl. E Certs
JAMESTOWN CLO XII: Moody's Rates $27MM Class C Notes 'Ba3'
JP MORGAN 2004-CIBC9: Fitch Rates $8.5MM Class F Notes 'D'
JPMBB COMMERCIAL 2014-C21: DBRS Confirms B(high) on Cl. F Certs
KRR CLO 24: Moody's Assigns Ba3 Rating on $23MM Class E Notes

LB-UBS COMMERCIAL 2007-C6: Fitch Affirms CC Rating on Class B Certs
MORGAN STANLEY 2007-TOP25: DBRS Confirms C Rating on Class C Certs
MORGAN STANLEY 2019-L2: Fitch Rates $9.16MM Class G-RR Certs 'B-sf'
NEW RESIDENTIAL 2019-NQM2: Fitch to Rate Class B-2 Notes 'Bsf'
OCTAGON INVESTMENT: Moody's Rates $50MM Class E-S Notes 'Ba3'

READY CAPITAL 2018-4: DBRS Confirms B(low) Rating on Class G Certs
SECURITIZED ASSET 2006-OP1: Moody's Cuts Cl. M-3 Debt Rating to B1
SUDBURY MILL: Moody's Lowers Rating on Class E Notes to 'B1'
TERWIN MORTGAGE 2005-3SL: Moody's Hikes B-1 Debt Rating to Caa3
TOWD POINT 2019-SJ2: Fitch to Rate $45.62MM Class B2 Notes 'Bsf'

TRUPS FINANCIALS 2019-1: Moody's Rates Class B Notes 'Ba2'
WELLS FARGO 2019-C49: DBRS Finalizes BB Rating on Class G-RR Certs
[*] DBRS Reviews 605 Classes From 36 US RMBS Transactions
[*] Moody's Hikes $1.7BB of GSE CRT RMBS Issued 2015 to 2017

                            *********

AMERICREDIT AUTOMOBILE 2019-1: Fitch Rates Class E Notes 'BBsf'
---------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to the notes issued by AmeriCredit Automobile Receivables
Trust 2019-1 (AMCAR 2019-1):

  -- $223,000,000 class A-1 notes 'F1+sf';

  -- $305,000,000 class A-2-A notes 'AAAsf'; Outlook Stable;

  -- $70,000,000 class A-2-B notes 'AAAsf'; Outlook Stable;

  -- $267,240,000 class A-3 notes 'AAAsf'; Outlook Stable;

  -- $93,910,000 class B notes 'AAsf'; Outlook Stable;

  -- $116,570,000 class C notes 'Asf'; Outlook Stable;

  -- $114,640,000 class D notes 'BBBsf'; Outlook Stable;

  -- $30,430,000 class E notes 'BBsf'; Outlook Stable.

KEY RATING DRIVERS

Consistent Credit Quality: The 2019-1 pool has consistent credit
quality relative to recent pools based on the weighted average (WA)
Fair Isaac Corp. (FICO) score of 580 and internal credit scores.
Obligors with FICOs greater than 600 total 38%, slightly less than
40% in the 2018-3 transaction.

High Extended-Term Contracts: Extended-term (61+ month) contracts
total 93.0%, consistent with 2017-2018 pools but high relative to
the historical platform range. The 73-75 month contracts total
16.4%, up from 2018-3 at 11.3%. Performance data for these
contracts are limited due to lack of seasoning. However, these
73-75 month loans have obligors with stronger credit metrics; given
this and the small concentration, Fitch did not apply an additional
stress to these loans.

Payment Structure - Sufficient Credit Enhancement: Initial hard
credit enhancement (CE) is consistent with 2017-2018 transactions
and totals 35.20%, 27.95%, 18.95%, 10.10% and 7.75% for classes A,
B, C, D and E, respectively. Excess spread is expected to be 7.52%
per annum, slightly higher than 2018-3 (NR). Loss coverage for each
class of notes is sufficient to cover the respective multiples of
Fitch's base case credit net loss (CNL) proxy.

Moderating Performance: Losses on General Motors Financial Company,
Inc.'s (GMF's) managed portfolio and securitizations have been
moderating over the past two years, with 2015-2017 CNL vintages
tracking higher than the strong 2010-2014. Overall, performance
continues to be within Fitch's expectations, with CNLs normalizing
in recent years to higher levels. Consistent with 2018-2, Fitch
accounted for the weaker performance of recent vintages in the
derivation of its CNL proxy of 10.75%.

Macroeconomic and Auto Industry Risks: The economic environment can
have a material impact on U.S. auto loan ABS ratings. Fitch takes
into consideration the strength of the economy, as well as future
expectations, by assessing key macroeconomic indicators that are
correlated with asset performance, such as unemployment rate and
the wholesale vehicle market.

Seller/Servicer Operational Review - Consistent

Origination/Underwriting/Servicing: Fitch affirmed General Motors
and GMF's Issuer Default Rating at 'BBB' in June 2018 and revised
the Rating Outlook to Stable from Positive. The revision reflected
the ongoing fundamental improvement in the company's core business
over the past several years. GMF demonstrates adequate abilities as
originator, underwriter and servicer as evidenced by historical
portfolio and securitization performance. Fitch deems GMF capable
of adequately servicing the transaction.

Legal Structure Integrity: The legal structure of the transaction
should provide that a bankruptcy of GMF would not impair the
timeliness of payments on the securities.

RATING SENSITIVITIES

Unanticipated increases in the frequency of defaults and loss
severity on defaulted receivables could produce loss levels higher
than the base case. This, in turn, could result in Fitch taking
negative rating actions on the notes.

Fitch evaluated the sensitivity of the ratings assigned to AMCAR
2019-1 to increased credit losses over the life of the transaction.
Fitch's analysis found that the transaction displays some
sensitivity to increased defaults and credit losses. This shows a
potential downgrade of one to two rating categories under Fitch's
moderate (1.5x base case loss) scenario, especially for the
subordinate bonds. The notes could experience downgrades of three
or more rating categories, potentially leading to distressed
ratings (below Bsf) under Fitch's severe (2.5x base case loss)
scenario.


ARES CLO XXXIX: Moody's Gives '(P)Ba3' Rating on Class E-R Notes
----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to four
classes of CLO refinancing notes to be issued by Ares XXXIX CLO
Ltd.

Moody's rating action is as follows:

US$2,500,000 Class X-R Senior Floating Rate Notes Due 2031 (the
"Class X-R Notes"), Assigned (P)Aaa (sf)

US$298,500,000 Class A-1-R Senior Floating Rate Notes Due 2031 (the
"Class A-1-R Notes"), Assigned (P)Aaa (sf)

US$21,000,000 Class A-2-R Senior Floating Rate Notes Due 2031 (the
"Class A-2-R Notes"), Assigned (P)Aaa (sf)

US$18,800,000 Class E-R Mezzanine Deferrable Floating Rate Notes
Due 2031 (the "Class E-R Notes"), Assigned (P)Ba3 (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 Issuer intends to issue the Refinancing Notes on April 18, 2019
in connection with the refinancing of all classes of secured notes
previously issued on July 27, 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 three other
classes of secured notes and additional subordinated notes, to
redeem in full the Refinanced Original Notes.

In addition to the issuance of the Refinancing Notes, three other
classes of secured notes and additional subordinated notes, a
variety of other changes to the transaction's 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 March 2019.

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: $500,000,000

Defaulted par: $0

Diversity Score: 80

Weighted Average Rating Factor (WARF): 2985

Weighted Average Spread (WAS): 3.25%

Weighted Average Coupon (WAC): 7.5%

Weighted Average Recovery Rate (WARR): 48.0%

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
March 2019.

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.


BANK 2017-BNK4: Fitch Affirms B- Rating on 2 Tranches
-----------------------------------------------------
Fitch Ratings has affirmed 16 classes of BANK 2017-BNK4 commercial
mortgage pass-through certificates.

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The affirmations reflect
the overall stable performance and loss expectations with no
material changes to pool metrics since issuance. There are no
specially serviced or delinquent loans.

The largest loan in the pool is the D.C. Office Portfolio (7.01% of
the pool). The loan is secured by three office buildings totaling
328,319 sf located within the Washington, D.C. CBD known as the
Golden Triangle. The buildings are leased to approximately 100
tenants making for a granular rent roll. Approximately 85% of the
NRA rolls during the loan term. Since 2009, each of the buildings
has had an average occupancy of over 91.0%. The lowest occupancy
reported for the portfolio during this time was 86.9% in 2010.

While the deal is performing as expected, there are six loans
(10.83% of the pool) on the servicer's watchlist, but none are
considered Fitch Loans of Concern. The Davenport is the sixth
largest loan (5.01% of the pool) in the pool, and the largest loan
on the watchlist. The loan is secured by an office property located
in Cambridge, MA. The loan has been on the watchlist since April of
2018 due to performance declines. The drop in cashflow is
attributed to free rent periods associated with new leasing and was
expected at issuance. The rent abatements end in March of 2019 at
which point performance is expected to stabilize.

The second largest loan on the servicer's watchlist is the 18th
loan in the pool, Ralph's Food Warehouse Portfolio (2.38%). The
loan is secured by 11 properties located on the island of Puerto
Rico and was previously considered to be a Fitch Loan of Concern
(FLOC) due to damage sustained from Hurricane Maria in 2017. As of
February 2019, inspections have been completed on the properties
and all hurricane related damage has been repaired with only minor
deferred maintenance remaining. The loan is expected to be removed
from the watchlist as of the March reporting cycle.

Minimal Change to Credit Enhancement: There has been minimal change
to credit enhancement since issuance. As of the February 2019
distribution date, the pool's aggregate balance has been paid down
by 1.02% to $997.9 million from $1.008 billion at issuance. All
original 48 loans remain in the pool. Based on the scheduled
balance at maturity, the pool will pay down by only 8.8% at
maturity. Thirteen loans (49.2%) are full-term interest only and 13
loans (19.4%) are partial interest only.

RATING SENSITIVITIES

The Rating Outlooks for all classes remain Stable due to overall
stable collateral performance and loss expectations since issuance.
Fitch does not foresee positive or negative ratings migration
unless a material economic or asset level event changes the
underlying 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 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $88.4 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $235 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $268.4 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $44.8 million class A-SB at 'AAAsf'; Outlook Stable;

  -- $67 million class A-S at 'AAAsf'; Outlook Stable;

  -- $43.1 million class B at 'AA-sf'; Outlook Stable;

  -- $45.5 million class C at 'A-sf'; Outlook Stable;

  -- $56.3(b) million class D at 'BBB-sf'; Outlook Stable;

  -- $21.6(b) million class E at 'BB-sf'; Outlook Stable;

  -- $10.8(b) million class F at 'B-sf'; Outlook Stable;

  -- $660.6(a) million class X-A at 'AAAsf'; Outlook Stable;

  -- $155.6(a) million class X-B at 'A-sf'; Outlook Stable;

  -- $56.3(a)(b) million class X-D at 'BBB-sf'; Outlook Stable;

  -- $21.6(a)(b) million class X-E at 'BB-sf'; Outlook Stable;

  -- $10.8(a)(b) million class X-F at 'B-sf'; Outlook Stable.

Fitch does not rate the G, X-G, or RR Interest classes.

(a) Notional amount and interest-only.

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


BARINGS CLO 2019-II: Moody's Gives (P)Ba3 Rating on Class D Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to three
classes of notes to be issued by Barings CLO Ltd. 2019-II.

Moody's rating action is as follows:

US$298,750,000 Class A-1A Senior Secured Floating Rate Notes due
2031 (the "Class A-1A Notes"), Assigned (P)Aaa (sf)

US$25,000,000 Class A-1B Senior Secured Floating Rate Notes due
2031 (the "Class A-1B Notes"), Assigned (P)Aaa (sf)

US$20,000,000 Class D Secured Deferrable Mezzanine Floating Rate
Notes due 2031 (the "Class D Notes"), Assigned (P)Ba3 (sf)

The Class A-1A Notes, the Class A-1B 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

Barings 2019-II 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 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% ramped as of the closing date.

Barings 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 three other
classes 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 March 2019.

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

Par amount: $500,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2800

Weighted Average Spread (WAS): 3.30%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 46.50%

Weighted Average Life (WAL): 9.04 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
March 2019.

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.


BEAR STEARNS 2006-PWR11: Fitch Affirms D on $16.1MM Class E Debt
----------------------------------------------------------------
Fitch Ratings has affirmed 13 classes of commercial mortgage
pass-through certificates from Bear Stearns Commercial Mortgage
Securities Trust, series 2006-PWR11.

KEY RATING DRIVERS

Concentrated Pool/High Loss Expectations: Only four of the original
184 loans remain, two of which are Real Estate Owned (REO; 67.4%).
The second largest loan (30.7%), a Fitch Loan of Concern (FLOC),
was previously specially serviced. It is collateralized by a
424,700 sf interest in a 824,102sf regional mall in Forsyth, IL
with a reported occupancy of 33% as of year-end 2018. The extended
maturity date is in December 2019 and given the low occupancy,
refinance of the loan is unlikely. The distressed ratings reflect
the potential for losses.

Credit enhancement remained unchanged since the last rating action
as no loans were disposed. As of the February 2019 distribution
date, the pool's aggregate principal balance has been reduced by
95.2% to $89.5 million from $1.9 billion at issuance. Realized
losses since issuance total $121 million (6.5% of original pool
balance). Cumulative interest shortfalls totaling $10.1 million are
currently impacting classes C through P.

REO Assets: The largest asset, SBC - Hoffman Estates (62.2% of
pool), is a 1.69 million sf office property located in Hoffman
Estates, IL. The loan transferred to special servicing in June 2016
and has been REO since July 2017. The property has been fully
vacant since the sole tenant, AT&T vacated upon its 2016 lease
expiration. The loan is currently under contract for sale.

2970 Presidential Drive (5.1%) is a 59,070 sf office property
located in Fairborn, OH. Per the Dec. 2018 rent roll, the property
was 46% occupied. The loan was transferred to special servicing in
March 2015 has been REO since Aug 2017.

Alternative Loss Considerations: Fitch assumed base case losses on
the specially serviced assets. In addition, Fitch assumed stressed
losses on the two performing loans. Full losses were assumed on the
regional mall in Forsyth, IL given the low occupancy. If incurred,
all remaining classes will incur losses. The distressed ratings
reflect this analysis.

RATING SENSITIVITIES

Losses to classes C and D are expected based on Fitch's loss
expectations on the two specially serviced loans and stressed
losses on the remaining performing loans. Losses to class B are
possible. Upgrades are not likely due to the high concentration of
REO assets. The distressed classes are subject to further
downgrades as additional losses are realized or if losses exceed
Fitch's expectations.

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 affirmed the following ratings:

  -- $22.3 million class B at 'CCCsf'; RE 80%;

  --  $23.2 million class C at 'Csf'; RE 0%;

  -- $27.9 million class D at 'Csf'; RE0%;

  -- $16.1 million class E at 'Dsf''; RE0%.

Classes F through O have been depleted due to realized losses and
have been affirmed at 'Dsf'/RE 0%. Class A-1, A-2, A-3, A-AB, A-4,
A-1A, A-M and A-J have paid in full. Class P is not rated by Fitch.
Fitch has previously withdrawn the ratings of the interest-only
class X.


CARRINGTON MORTGAGE 2004-NC1: Moody's Hikes M-4 Debt Rating to Caa1
-------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of two tranches
from one transaction, backed by subprime loans, issued by
Carrington Mortgage Loan Trust, Series 2004-NC1.

Complete rating actions are as follows:

Issuer: Carrington Mortgage Loan Trust, Series 2004-NC1

Cl. M-3, Upgraded to B1 (sf); previously on Dec 28, 2017 Upgraded
to Caa1 (sf)

Cl. M-4, Upgraded to Caa1 (sf); previously on Mar 13, 2011
Downgraded to C (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to improvement in pool
performance and credit enhancement available to the bonds. The
upgrade of Class M-4 also reflects the correction of a prior error.
In previous rating actions, the cash-flow model used by Moody's in
rating this transaction was duplicating certain fee payments
resulting in less principal available to the bonds. The model has
been corrected, and Moody's rating action reflects this change. The
rating actions also reflect recent performance and Moody's updated
loss expectations on the underlying pool.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in February 2019.

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 4.0% in January 2019 from 4.1% in
January 2018. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2019 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 2019. 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 this transaction.


CITIGROUP COMMERCIAL 2014-GC21: DBRS Confirms B Rating on F Certs
-----------------------------------------------------------------
DBRS Limited confirmed the ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2014-GC21 issued by Citigroup
Commercial Mortgage Trust 2014-GC21 as follows:

-- Class A-4 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-AB at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X-A at AAA (sf)
-- Class B at AA (sf)
-- Class X-B at A (high) (sf)
-- Class C at A (sf)
-- Class PEZ at A (sf)
-- Class D at BBB (low) (sf)
-- Class X-C at BB (high) (sf)
-- Class E at BB (sf)
-- Class X-D at BB (low) (sf)
-- Class F at B (high) (sf)

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. At issuance, the collateral
consisted of 70 fixed-rate loans secured by 111 commercial
properties with a trust balance of $1.0 billion. According to the
February 2019 remittance, there are 62 loans remaining in the pool
with a current trust balance of $820.0 million, representing a
collateral reduction of 21.2% since issuance as a result of
scheduled loan amortization and loan repayment. Four loans,
representing 22.3% of the pool balance (including the two largest
loans), are structured with full-term interest-only (IO) payments.
An additional three loans, representing 7.8% of the pool, have
partial-IO terms remaining, which are scheduled to convert to
amortizing payments by April 2019. Loans representing 94.8% of the
pool balance reported year-end (YE) 2017 financials, including a
weighted-average (WA) debt service coverage ratio (DSCR) and WA
debt yield of 1.64 times (x) and 10.5%, respectively, compared with
the DBRS Term DSCR and DBRS Debt Yield of 1.39x and 8.5%,
respectively. The largest 15 loans, representing 57.9% of the pool,
reported a WA DSCR and WA debt yield of 1.63x and 9.8%,
respectively, representing a WA net cash flow (NCF) improvement of
19.5% over the DBRS NCF figures derived at issuance. In addition,
41 loans, representing 76.2% of the pool balance, reported
partial-year 2018 financials that resulted in a WA DSCR of 1.64x.

The pool has a relatively high concentration of loans secured by
retail properties, which represent 44.0% of the pool balance. The
high concentration is a concern, given the volume of recent store
closures and chain bankruptcies in the retail sector. The pool has
already been affected by these store closings as one loan, Hairston
Village (Prospectus ID#13; 2.0% of the pool), transferred to the
special servicer and three additional loans, representing 18.7% of
the pool balance, were placed on the servicer's watchlist for this
reason. Retail properties reported a WA YE2017 DSCR and WA debt
yield of 1.53x and 9.1%, respectively. In addition, most of the
retail loans in the pool are secured by anchored-retail or regional
mall properties, which are generally more desirable than
unanchored-retail property types.

As of the February 2019 remittance, there was one loan in special
servicing and ten loans on the servicer's watchlist, representing
2.0% and 25.9% of the current pool balance, respectively. Of the
watchlisted loans, five are being monitored for performance-related
issues, two for upcoming loan maturities, two for large upcoming
lease expirations and one for deferred maintenance. The largest
loan in the pool, Maine Mall (Prospectus ID#1; 15.2% of the pool
balance), is being monitored for the early departure of an anchor
tenant, Bon-Ton Holdings Inc. (Bon-Ton; 16.5% of the net rentable
area (NRA)), which vacated in August 2017. As of February 2019, the
anchor store remains vacant and the borrower is continuing to
market the subject to national retailers for possible relocation
opportunities. Even with the loss of the collateral tenant, cash
flows have remained stable as a $5.0 million termination fee was
remitted to the servicer since the store closed, prior to Bon-Ton
filing bankruptcy in 2018. The loan benefits from a strong
sponsorship in Brookfield Property Partners L.P. (rated BBB with a
Stable trend by DBRS) and Maine Mall is considered to be the
prominent mall in the state, serving as a true destination center
for a relatively large geographic area.

Hairston Village transferred to the special servicer in November
2018 for imminent default resulting from the loss of grocery
anchor, the Kroger Co. (Kroger; 30.8% of the NRA) and major tenant,
Conway Stores Inc. (14.5% of the NRA), ahead of their respective
lease expirations. In addition, Pet Supermarket (5.2% of the NRA
through September 2019) exercised its co-tenancy provisions and
vacated the subject property in September 2018. With the loss of
these tenants, the physical occupancy rate for the property dropped
to 41.9%. The immediate risk is mitigated as Kroger will continue
to pay rent through its December 2019 lease expiration and, as
such, the projected cash flow should result in an in-place DSCR
above 1.0x until that time. For this review, DBRS analyzed the loan
with a stressed cash flow scenario and an elevated probability of
default as the occupancy rate unexpectedly decreased and there is a
short time period remaining on the Kroger lease payments.

Classes X-A, X-B, X-C, and X-D are 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.

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


CSAIL 2019-C15: DBRS Finalizes BB(high) Rating on Class F-RR Certs
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2019-C15 issued by CSAIL 2019-C15 Commercial Mortgage Trust:

-- 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-SB at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X-A at AAA (sf)
-- Class B at AA (sf)
-- Class X-B at AA (high) (sf)
-- Class C at A (sf)
-- Class X-D at A (low) (sf)
-- Class D at BBB (high) (sf)
-- Class E-RR at BBB (sf)
-- Class F-RR at BB (high) (sf)
-- Class G-RR at B (high) (sf)

All trends are Stable.

The collateral consists of 36 fixed-rate loans secured by 83
commercial and multifamily properties. The transaction is a
sequential-pay pass-through structure. The conduit pool was
analyzed to determine the ratings, reflecting the long-term
probability of loan default within the term and its liquidity at
maturity. Three loans, representing 15.6% of the pool, are shadow
rated investment grade by DBRS. Proceeds for the shadow-rated loans
are floored at their respective ratings within the pool. When 15.6%
of the loans in the pool have no proceeds assigned below the rated
floor, the resulting subordination is diluted or reduced below the
rated floor. When the cut-off loan balances were measured against
the DBRS Stabilized net cash flow and their respective actual
constants, nine loans, representing 26.3% of the pool balance, have
DBRS Term debt service coverage ratios (DSCRs) below 1.15 times
(x), a threshold indicative of a higher likelihood of mid-term
default. Additionally, to assess refinance risk given the current
low-interest rate environment, DBRS applied its refinance constants
to the balloon amounts. This action resulted in 22 loans,
representing 69.7% of the pool, having refinanced DSCRs below
1.00x, and 19 loans, representing 57.8% of the pool, having
refinanced DSCRs below 0.90x.

Six loans, representing 18.5% of the pool, have collateral in
super-dense urban and urban markets, with increased liquidity that
benefits from consistent investor demand even in times of stress.
Urban markets represented in the deal include New York City,
Brooklyn, Beverly Hills, Culver City, Seattle, and San Antonio.
Only two loans, totaling 10.2% of the transaction balance, are
secured by properties that are primarily leased to a single tenant.
The largest of these loans is the headquarters of Darden
Restaurants, Inc., a multi-brand restaurant operator headquartered
in Orlando, Florida, representing 9.7% of the pool balance and
95.7% of the single-tenant concentration. Loans secured by
properties occupied by single tenants have been found to suffer
higher loss severities in an event of default.

Fifteen loans, representing 47.4% of the pool, including eight of
the largest 15 loans, are structured with interest-only (IO)
payments for the full term. An additional 15 loans, representing
46.6% of the pool, have partial IO periods ranging from 23 months
to 60 months. The full-term IO concentration includes 2 North 6th
Place, SITE JV Portfolio and 787 Eleventh Avenue, the three
shadow-rated loans, which collectively represent 15.6% of the pool
and 33.0% of the full-term IO concentration. Of these 15 loans, six
loans, representing 18.5% of the transaction's full-IO
concentration, have excellent locations in super-dense urban and
urban markets that benefit from steep investor demand. The DBRS
Term DSCR is calculated using the amortizing debt service
obligation, and the DBRS refinance (Refi) DSCR is calculated
considering the balloon balance and lack of amortization when
determining to refinance risk. DBRS determines the probability of
default (POD) based on the lower of the DBRS Term DSCR or the DBRS
Refi DSCR; therefore, loans that lack amortization will be treated
more punitively.

The DBRS Refi DSCR is 0.92x, indicating a higher refinance risk on
an overall pool level. In addition, 22 loans, representing 69.7% of
the pool, have DBRS Refi DSCRs below 1.00x. Nineteen of these
loans, comprising 57.8% of the pool, have DBRS Refi DSCRs less than
0.90x, including five of the top ten loans. These metrics are based
on whole-loan balances. Two of the pool's loans with a DBRS Refi
DSCR below 0.90x -- 787 Eleventh Avenue and 2 North 6th Street,
which represent 9.6% of the transaction balance -- are shadow-rated
investment grade by DBRS and have a large piece of subordinate
mortgage debt outside the trust. Based on A-note balances only, the
deal's weighted-average (WA) DBRS Refi DSCR improves substantially
to 1.02x, and the concentration of loans with DBRS Refi DSCRs below
1.00x and 0.90x reduces to 59.8% and 48.0%, respectively. The
pool's DBRS Refi DSCRs for these loans are based on a WA stressed
refinance constant of 9.91%, which implies an interest rate of 9.4%
amortizing on a 30-year schedule. This represents a significant
stress of 4.2% over the WA contractual interest rate of the loans
in the pool. DBRS models the POD based on the more constraining of
the DBRS Term DSCR or the DBRS Refi DSCR.

Classes X-A, X-B, and X-D are 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.


CSFB MORTGAGE 2005-C3: Moody's Hikes Class C Certs Rating to 'Ba1'
------------------------------------------------------------------
Moody's Investors Service has upgraded the rating on one class and
affirmed the ratings on four classes in CSFB Mortgage Securities
Corp., Commercial Mortgage Pass-Through Certificates, Series
2005-C3.

Cl. A-X*, Affirmed C (sf); previously on Mar 2, 2018 Affirmed C
(sf)

Cl. A-Y*, Affirmed Aaa (sf); previously on Mar 2, 2018 Affirmed Aaa
(sf)

Cl. C, Upgraded to Ba1 (sf); previously on Mar 2, 2018 Affirmed B1
(sf)

Cl. D, Affirmed Caa3 (sf); previously on Mar 2, 2018 Affirmed Caa3
(sf)

Cl. E, Affirmed C (sf); previously on Mar 2, 2018 Affirmed C (sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

The rating on one principal and interest (P&I) class, Cl. C was
upgraded based primarily due to an increase in credit support
resulting from loan paydowns and amortization. The deal has paid
down 42% since Moody's last review and 98% since securitization.

The ratings on two P&I classes were affirmed because the ratings
are consistent with Moody's expected loss plus realized losses.

The rating on the interest-only (IO) class, Cl. A-X, was affirmed
based on the credit quality of its referenced classes.

The rating on the IO class, Cl. A-Y, was affirmed based on the
credit quality of its referenced loans (residential cooperatives).

Moody's rating action reflects a base expected loss of 21.0% of the
current pooled balance, compared to 36.1% at Moody's 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 methodologies used in rating all classes except interest-only
classes 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.
The methodologies used in rating interest-only classes were
"Approach to Rating US and Canadian Conduit/Fusion CMBS" published
in July 2017, "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 February 2019.

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 30% of the pool is in
special servicing and Moody's has identified an additional troubled
loan representing 11% of the pool. In this approach, Moody's
determines a probability of default for each specially serviced and
troubled loan that it expects will generate a loss and estimates a
loss given default based on a review of broker's opinions of value
(if available), other information from the special servicer,
available market data and Moody's internal data. The loss given
default for each loan also takes into consideration repayment of
servicer advances to date, estimated future advances and closing
costs. Translating the probability of default and loss given
default into an expected loss estimate, Moody's then applies the
aggregate loss from specially serviced and troubled loans to the
most junior classes and the recovery as a pay down of principal to
the most senior classes.

DEAL PERFORMANCE

As of the February 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $32.9 million
from $1.64 billion at securitization. The certificates are
collateralized by 12 mortgage loans ranging in size from less than
1% to 31% of the pool. Seven loans ($16.1 million; 49% of the pool)
are secured by residential co-ops located primarily in New York
City, and have structured credit assessments of aaa (sca.pd).

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 5, compared to 7 at Moody's last review.

Five loans, constituting 23% 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-nine loans have been liquidated from the pool, resulting in
an aggregate realized loss of $122 million (for an average loss
severity of 42%). One loan, constituting 30% of the pool, is
currently in special servicing. The specially serviced loan is the
University Park Loan ($9.7 million -- 30% of the pool), which is
secured by a 109,000 square feet (SF) retail center located in
Clive, Iowa. The loan transferred to special servicing in February
2014 for imminent payment default and became real estate owned
(REO) in November 2015.

Moody's has also assumed a high default probablity for one poorly
performing loan, constituting 11% of the pool, and has estimated an
aggregate loss of $6.8 million (a 52% expected loss on average)
from the specially serviced and troubled loans.

Moody's received full year 2017 operating results for 82% of the
pool, and full or partial year 2018 operating results for 18% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 78%, compared to 102% 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 10% 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 1.18X and 1.69X,
respectively, compared to 0.81X and 1.24X 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 remaining loans represent 10% of the pool balance. The loans
are secured by one multifamily property, an unanchored retail
property, and a single tenant retail property occupied by Duane
Reade.


DBUBS COMMERCIAL 2011-LC1: Moody's Affirms Class G Certs at 'B2'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on two classes
and affirmed the ratings on eight classes in DBUBS 2011-LC1
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2011-LC1 as follows:

Cl. A-2, Affirmed Aaa (sf); previously on Mar 23, 2018 Affirmed Aaa
(sf)

Cl. A-3, Affirmed Aaa (sf); previously on Mar 23, 2018 Affirmed Aaa
(sf)

Cl. B, Affirmed Aaa (sf); previously on Mar 23, 2018 Affirmed Aaa
(sf)

Cl. C, Upgraded to Aaa (sf); previously on Mar 23, 2018 Affirmed
Aa1 (sf)

Cl. D, Upgraded to Aa2 (sf); previously on Mar 23, 2018 Affirmed
Aa3 (sf)

Cl. E, Affirmed Baa2 (sf); previously on Mar 23, 2018 Affirmed Baa2
(sf)

Cl. F, Affirmed Ba1 (sf); previously on Mar 23, 2018 Affirmed Ba1
(sf)

Cl. G, Affirmed B2 (sf); previously on Mar 23, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Mar 23, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed Ba3 (sf); previously on Mar 23, 2018 Affirmed
Ba3 (sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on two principal and interest (P&I) classes were
upgraded due to a significant increase in defeasance, to 14% of the
current pool balance from 1% at the last review.

The ratings on six P&I classes 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 two interest only (IO) classes were affirmed based
on the credit quality of the referenced classes.

Moody's rating action reflects a base expected loss of 1.1% of the
current pooled balance, compared to 1.4% at Moody's last review.
Moody's base expected loss plus realized losses is now 0.5% of the
original pooled balance, compared to 0.6% 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 methodologies used in rating all classes except interest-only
classes 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.
The methodologies used in rating interest-only classes were
"Approach to Rating US and Canadian Conduit/Fusion CMBS" published
in July 2017, "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 February 2019.

DEAL PERFORMANCE

As of the February 12, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 59% to $892 million
from $2.18 billion at securitization. The certificates are
collateralized by 25 mortgage loans ranging in size from less than
1% to 23% of the pool, with the top ten loans (excluding
defeasance) constituting 76% of the pool. One loan, constituting
23% of the pool, has an investment-grade structured credit
assessment. Four loans, constituting 14% 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 seven, compared to a Herf of nine at Moody's
last review.

Seven loans, constituting 61% 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.

Moody's received full year 2017 operating results and full or
partial year 2018 operating results for 100% of the pool (excluding
specially serviced and defeased loans). Moody's weighted average
conduit LTV is 95%, the same as 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 23% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 9%.

Moody's actual and stressed conduit DSCRs are 1.27X and 1.14X,
respectively, compared to 1.28X and 1.13X 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 loan with a structured credit assessment is the Kenwood Towne
Centre Loan ($203.3 million -- 22.8% of the pool), which is secured
by a super-regional mall located in Cincinnati, Ohio. The mall
contains approximately 1.16 million square feet (SF), of which
756,412 SF serves as collateral for the loan. Anchor tenants
include Macy's (non-collateral), Dillard's and Nordstrom
(non-collateral). As per the February 2019 rent roll, the mall was
98% leased, with inline space 93% leased, compared to 98% for the
mall and 95% for in-line space in September 2017. The September
2018 running-twelve month comparable in-line sales (tenants with
less than 10,000 SF) were $816 per-square foot (PSF). Excluding
Apple, the same comparable in-line sales were $592 PSF. Moody's
structured credit assessment and stressed DSCR are a1 (sca.pd) and
1.53X, respectively.

The top three conduit loans represent 38.6% of the pool balance.
The largest loan is the 7 Hanover Square Loan ($129.4 million --
14.5% of the pool), which is secured by a Class A office building
located within the South Ferry Financial District submarket of New
York City. The property offers 26 stories of rentable space for a
total of 846,415 SF. Guardian Life Insurance Company of America
leases more than 99% of the NRA through September 2019 and has
occupied the building as its headquarters since 1998. Since
Guardian did not renew by March 2017, the borrower was required to
post a letter-of-credit (LOC), or a cash flow sweep would commence.
Due to the single tenant concentration and the heightened risk that
Guardian will vacate upon lease expiration, Moody's valuation
reflects a lit/dark analysis. Moody's LTV and stressed DSCR are 94%
and 1.10X, respectively, compared to 95% and 1.08X at the last
review.

The second largest loan is the 1200 K Street Loan ($121.9 million
-- 13.7% of the pool), which is secured by a 389,561 SF, Class A
office building located within the East End submarket of
Washington, DC. The property offers twelve stories of rentable
space retrofitted for single tenant use. Pension Benefit Guaranty
Corporation leases over 97% of the NRA and has occupied the
building since its development. The tenant recently renewed its
lease for one year. Starting in September 2015, the borrower was
required to deliver a LOC in the amount of $13.1 million or all
excess cash flow would be swept into a rollover reserve account
until the $13.1 million figure was accumulated. Due to the single
tenant concentration and heightened risk of the near term lease
expiration, Moody's valuation reflects a lit/dark analysis. Moody's
LTV and stressed DSCR are 121% and 0.81X, respectively, compared to
123% and 0.79X at the last review.

The third largest loan is the Marriott Crystal Gateway Loan ($93.1
million -- 10.4% of the pool), which is secured by a 697-room, full
service hotel located in the Crystal City area of Arlington County,
Virginia. Hotel amenities include 11 meeting rooms containing
approximately 33,355 SF, indoor/outdoor heated pools, fitness
center, business center, and concierge lounge. Moody's LTV and
stressed DSCR are 100% and 1.16X, respectively, compared to 102%
and 1.14X at the last review.


ELLINGTON CLO IV: Moody's Assigns Ba3 Rating on 2 Tranches
----------------------------------------------------------
Moody's Investors Service has assigned ratings to nine classes of
notes issued by Ellington CLO IV, Ltd.

Moody's rating action is as follows:

US$237,500,000 Class A Senior Secured Floating Rate Notes due 2029
(the "Class A Notes"), Assigned Aaa (sf)

US$45,125,000 Class B Senior Secured Floating Rate Notes due 2029
(the "Class B Notes"), Assigned Aa2 (sf)

US$29,212,500 Class C Secured Deferrable Floating Rate Notes due
2029 (the "Class C Notes"), Assigned A2 (sf)

US$32,775,000 Class D-1 Secured Deferrable Floating Rate Notes due
2029 (the "Class D-1 Notes"), Assigned Baa3 (sf)

US$5,700,000 Class D-2 Secured Deferrable Fixed Rate Notes due 2029
(the "Class D-2 Notes"), Assigned Baa3 (sf)

US$44,450,000 Class E-1 Secured Deferrable Floating Rate Notes due
2029 (the "Class E-1 Notes"), Assigned Ba3 (sf)

US$3,050,000 Class E-2 Secured Deferrable Fixed Rate Notes due 2029
(the "Class E-2 Notes"), Assigned Ba3 (sf)

US$6,975,000 Class F-1 Secured Deferrable Floating Rate Notes due
2029 (the "Class F-1 Notes"), Assigned B3 (sf)

US$150,000 Class F-2 Secured Deferrable Fixed Rate Notes due 2029
(the "Class F-2 Notes"), Assigned B3 (sf)

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

RATINGS RATIONALE

Ellington IV is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 85.0% of the portfolio must consist of
first lien senior secured loans, cash, and eligible investments,
and up to 15.0% of the portfolio may consist of second lien loans
and unsecured loans. The portfolio is approximately 75% ramped as
of the closing date.

Ellington CLO Management 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 two year reinvestment period. Thereafter, the
Manager may not reinvest in new assets and all principal proceeds,
including sale proceeds, will be used to amortize the notes in
accordance with the priority of payments.

In addition to the Rated Notes, the Issuer issued subordinated
notes and combination 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: $475,000,000

Diversity Score: 35

Weighted Average Rating Factor (WARF): 4648

Weighted Average Spread (WAS): 5.60%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 42.50%

Weighted Average Life (WAL): 6.0 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 Ellington CLO IV, 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 Ellington CLO IV, Ltd.

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.


FAIRSTONE FINANCIAL 2019-1: Moody's Gives (P)Ba3 Rating to D Notes
------------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to the
Series 2019-1 notes to be issued by Fairstone Financial Issuance
Trust 1 (FFIT 2019-1). This is the first consumer loan-backed ABS
transaction issued by Fairstone Financial Inc. (Fairstone; NR) and
the first FFIT transaction to be rated by Moody's. The notes will
be backed by a pool of personal loans primarily originated through
Fairstone's branch network. Fairstone is also the servicer and
administrator of the transaction.

The complete rating actions are as follows:

Issuer: Fairstone Financial Issuance Trust I, Series 2019-1

Series 2019-1 Class A Notes, Assigned (P)Aa2 (sf)

Series 2019-1 Class B Notes, Assigned (P)A3 (sf)

Series 2019-1 Class C Notes, Assigned (P)Ba1 (sf)

Series 2019-1 Class D Notes, Assigned (P)Ba3 (sf)

RATINGS RATIONALE

The ratings are based on the quality of the underlying collateral
and its expected performance, the strength of the capital
structure, and the experience and expertise of Fairstone as the
servicer.

Moody's cumulative net loss expectation for the FFIT 2019-1 pool is
19.0%. Moody's based its cumulative net loss expectation on an
analysis of the credit quality of the underlying collateral; the
historical performance of similar collateral, including
securitization performance and managed portfolio performance; the
reinvestment criteria stipulated in the transaction document during
the revolving period; the ability of Fairstone to perform the
servicing functions; and current expectations for the macroeconomic
environment during the life of the transaction.

At closing, the Class A notes, Class B notes, Class C notes and
Class D notes benefit from 37.75%, 26.25%, 16.25% and 10.25% of
hard credit enhancement, respectively. Hard credit enhancement for
the notes consists of a combination of non-declining
overcollateralization, a non-declining reserve account and
subordination. The notes will also benefit from excess spread,
which is estimated to be at least 22% per annum.

The transaction has an initial revolving period of two years during
which cash collections in the principal distribution account will
be used to purchase additional loans from Fairstone instead of
paying down the notes. An early amortization event can terminate
the revolving period and cause amortization of the notes before the
end of the revolving period. An early amortization would be
triggered by the following events: (a) the average loss ratio
exceeds the loss ratio trigger; (b) the FFIT 2019-1 note balance is
greater than zero at the end of the revolving period, (c) a pool
deficiency exists on three consecutive settlement dates, (d) the
cash reserve is less than the required amount for two consecutive
business days, (e) the pool concentration limits remain unsatisfied
for three consecutive settlement dates, (f) backup servicing
agreement is not in place within 90 business days, (g) failure to
pay series principal and interest (h) insolvency of the issuer, (i)
series specific breach of rep and warranty, (j) failure to observe
or perform any material covenant or condition; or (k) a servicer
default occurs.

Operational risk exists in this transaction due to the
decentralized nature of the loan servicing obligations, the
reliance on Fairstone to continue to provide service and support to
its borrowers through its branch system, and the challenges
involved in transitioning servicing to a replacement servicer, if
required. These characteristics constrain the notes from achieving
the highest investment grade ratings at the time of deal closing.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's
Approach to Rating Consumer Loan-Backed ABS" published in September
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 consumer loan-backed ABS. If the
revised Methodology is implemented as proposed, the Credit Rating
on FFIT 2019-1 may be neutrally affected

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

Up

Moody's could upgrade the ratings of the notes if losses accumulate
below its original expectations as a result of better composition
of the collateral type and risk level than the reinvestment
criteria, better than expected improvements in the economy, changes
to servicing practices that enhance collections or refinancing
opportunities that result in prepayments.

Down

Moody's could downgrade the ratings of the notes if pool losses
exceed expectations. Losses may increase, for example, due to
performance deterioration stemming from a downturn in the Canadian
economy, deficient servicing, errors on the part of transaction
parties, inadequate transaction governance and fraud.


FREDDIE MAC 2019-1: DBRS Assigns (P)B(low) on $78MM Cl. M Certs
---------------------------------------------------------------
DBRS, Inc. assigned a provisional rating to the following
Mortgage-Backed Security, Series 2019-1 (the Certificate) to be
issued by Freddie Mac Seasoned Credit Risk Transfer Trust, Series
2019-1 (the Trust):

-- $78.6 million Class M at B (low) (sf)

The B (low) (sf) rating on the Certificate reflects 5.50% 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 12,185 loans with
a total principal balance of $2,096,796,997 as of the Cut-Off Date
(January 31, 2019).

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 (March 13, 2019).

The portfolio contains 100% modified loans. Each mortgage loan was
modified under either the government-sponsored enterprise (GSE)
Home Affordable Modification Program (HAMP) or GSE non-HAMP
modification programs. Within the pool, 5,007 mortgages have
forborne principal amounts as a result of a modification, which
equates to 12.2% of the total unpaid principal balance as of the
Cut-Off Date. For 90.6% of the modified loans, the modifications
happened more than two years ago. The loans are approximately 151
months seasoned, and all are current as of the Cut-Off Date.
Furthermore, 62.7% of the mortgage loans have been zero times 30
days delinquent for at least the past 24 months under the Mortgage
Bankers Association (MBA) delinquency methods. There are five loans
that are subject to the Consumer Financial Protection Bureau's
Qualified Mortgage (QM) rules. Four of them are QM Safe Harbor and
the last is Non-QM, according to the third-party due diligence
results. Additionally, there are 53 loans whose QM status is not
available; DBRS assumed these loans to be Non-QM.

The mortgage loans will be serviced by Specialized Loan Servicing
LLC. 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, Class
M55G and Class M55I certificates). Wilmington Trust National
Association (Wilmington Trust; rated A (high) with a Positive trend
by DBRS) will serve as the Trust Agent. Wells Fargo Bank, N.A.
(rated AA with a Stable trend by DBRS) will serve as the Custodian
for the Trust. U.S. Bank National Association (rated AA (high) with
a Stable trend by DBRS) 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&Ws) 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 March 11,
2022 (approximately three years from the Closing Date), for
substantially all R&Ws other than the real estate mortgage
investment conduit R&Ws, which will not expire.

The mortgage loans will be divided into three loan groups: Group H,
Group M, and Group M55. The Group H loans (8.1% of the pool) were
subject to step-rate modifications. Group M loans (83.6% of the
pool) and Group M55 loans (8.3% of the pool) were subject to either
fixed-rate modifications or step-rate modifications that have
reached their final step dates as of December 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 (62.7%
of the pool has remained consistently current in the past 24
months). 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 noteholders;
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.

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


FREDDIE MAC 2019-1: Fitch Rates $78MM Class M Certs 'B-'
--------------------------------------------------------
Fitch rates Freddie Mac's risk-transfer transaction, Seasoned
Credit Risk Transfer Trust Series 2019-1 (SCRT 2019-1) as follows:

  -- $78,630,000 class M certificates 'B-sf'; Outlook Stable.

Fitch will not be rating the following classes:

  -- $154,183,000 class HT exchangeable certificates;

  -- $115,637,000 class HA certificates;

  -- $38,546,000 class HB exchangeable certificates;

  -- $19,273,000 class HV certificates;

  -- $19,273,000 class HZ certificates;

  -- $1,590,781,000 class MT exchangeable certificates;

  -- $1,193,087,000 class MA certificates;

  -- $397,694,000 class MB exchangeable certificates;

  -- $198,847,000 class MV certificates;

  -- $198,847,000 class MZ certificates;

  -- $157,879,000 class M55D certificates;

  -- $157,879,000 class M55E exchangeable certificates;

  -- $157,879,000 class M55G exchangeable certificates;

  -- $28,705,272 class M55I notional exchangeable certificates;

  -- $115,323,997 class B certificates;

  -- $1,902,843,000 class A-IO notional certificates;

  -- $193,953,997 class B-IO notional certificates;

  -- $115,323,997 class BX exchangeable certificates;

  -- $115,323,997 class BBIO exchangeable certificates;

  -- $115,323,997 class BXS exchangeable certificates.

The 'B-sf' rating for the M certificates reflects the 5.50%
subordination provided by the class B.

SCRT 2019-1 represents Freddie Mac's 10th seasoned credit risk
transfer transaction issued. SCRT 2019-1 consists of three
collateral groups backed by 12,185 seasoned performing and
re-performing mortgages, with a total balance of approximately
$2.096 billion, of which $255.5 million, or 12.2%, was in
non-interest-bearing deferred principal amounts as of the cutoff
date. The three collateral groups represent loans that have
additional interest rate increases outstanding due to the terms of
the modification, and those that are expected to remain fixed for
the remainder of the term. Among the loans that are fixed, the
groups are further distinguished by loans that include a portion of
principal forbearance as well as the interest rate on the loans.
The distribution of principal and interest (P&I) and loss
allocations to the rated note is based on a senior subordinate,
sequential structure.

KEY RATING DRIVERS

Distressed Performance History (Negative): The collateral pool
comprises primarily peak-vintage re-performing loans (RPLs), all of
which have been modified. Roughly, 63% of the pool has been paying
on time for the past 24 months, per the Mortgage Bankers
Association (MBA) methodology, and none of the loans have
experienced a delinquency within the past 12 months. The pool has a
weighted average sustainable loan-to-value ratio (WA sLTV) of
79.9%. The WA model FICO score is 672.

Moderate Operational Risk (Negative): Fitch considers this
transaction to have moderate operational risk. FHLMC has an
established track record in residential mortgage activities and has
an 'Above Average' aggregator assessment from Fitch for newly
originated loans. The 'moderate' risk assessment for this
transaction reflects the relatively small due diligence sample size
for RPL and the diligence results. The due diligence was performed
by a Fitch Tier 1 third-party review (TPR) firm on 11% of the pool
and identified material compliance exceptions for approximately 37%
of the sample. The majority of these exceptions are due to missing
final documentation that prevented conclusive testing of predatory
lending. Loss adjustments were applied to account for loans that
could not be tested; however, it is expected that most of these
loans would not be in violation if the testing could be completed.
The adjustments add 10bps at 'B-sf'.

Interest Payment Risk (Negative): In Fitch's timing scenarios, the
M class incurs temporary shortfalls in the 'B-sf' rating category
but is ultimately repaid prior to maturity of the transaction. The
difference between Fitch's expected loss and the credit enhancement
(CE) on the rated classes is due to the repayment of interest
deferrals. Interest to the rated classes is subordinated to the
senior bonds as well as repayments made to Freddie Mac for prior
payments on the senior classes. Timely payments of interest are
also at potential risk as principal collections on the underlying
loans can only be used to repay interest shortfalls on the rated
classes after the balance of the senior classes are paid off. This
results in an extended period until potential shortfalls are
ultimately repaid in Fitch's stress scenarios.

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement (RW&E) mechanism construct
for this transaction as weaker than that of other Fitch-rated RPL
deals. The weakness is due to the exclusion of a number of reps
that Fitch views as consistent with a full framework as well as the
limited diligence that may have otherwise acted as a mitigant.
Additionally, Freddie Mac as rep provider will only be obligated to
repurchase a loan, pay an indemnity loss amount or cure the
material breach prior to March 11, 2022. However, Fitch believes
that the defect risk is lower relative to other RPL transactions
because the loans were subject to Freddie Mac's loan-level review
process in place at the time the loan became delinquent. Therefore,
Fitch treated the construct as Tier 3 and increased its 'B-sf'
expected loss expectations by 18bps to account for the weaknesses
in the reps.

Sequential-Pay Structure (Positive): The transaction's cash flow is
similar to that of Freddie Mac's STACR transactions. Once the
initial CE of the senior bonds has reached the target and if all
performance triggers are passing, principal is allocated pro rata
among the senior and subordinate classes with the most senior
subordinate bond receiving the full subordinate share. This
structure is a positive to the rated classes as it results in a
faster paydown and allows them to receive principal earlier than
under a fully sequential structure. However, to the extent any of
the performance triggers are failing, principal is distributed
sequentially to the senior classes until triggers pass.

No Servicer P&I Advances (Mixed): The servicer will not advance
delinquent monthly payments of P&I, which reduces liquidity to the
trust. However, as P&I advances made on behalf of loans that become
delinquent and eventually liquidate reduce liquidation proceeds to
the trust, the loan-level loss severities (LS) are less for this
transaction than for those where the servicer is obligated to
advance P&I. Structural provisions and cash flow priorities,
together with increased subordination, provide for ultimate
payments of interest to the rated classes.

CRITERIA APPLICATION

Fitch analyzed the transaction in accordance with its criteria, as
described in its October 2018 report, "U.S. RMBS Rating Criteria."
This incorporates a review of the aggregator's lending platforms,
as well as an assessment of the transaction's R&W and due diligence
results, which were found to be consistent with the ratings
assigned to the bonds.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines (MVDs)
than assumed at both the MSA and national levels. 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 be considered in the
surveillance of the transaction.

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 11% at the 'B-sf' level. The analysis indicates that
there is some potential rating migration with higher MVDs, compared
with the model projection.

Fitch also conducted defined rating sensitivities that determine
the stresses to MVDs that would reduce a rating by one full
category, to non-investment grade, and to 'CCCsf'. For example,
additional MVDs of 4% would potentially move the 'B-sf' rated class
down to 'CCCsf', respectively.

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

Fitch was provided with due diligence information from the
third-party diligence provider. The due diligence focused on
regulatory compliance, pay history, the presence of key documents
in the loan file and data integrity on a sample of the loans in the
pool. Additionally, an updated tax and title search was conducted
on all of the loans in the transaction. Fitch received
certifications indicating that the loan-level due diligence was
conducted in accordance with Fitch's published standards. The
certifications also stated that the company performed its work in
accordance with the independence standards, per Fitch's criteria,
and that the due diligence analysts performing the review met
Fitch's criteria of minimum years of experience. Fitch considered
this information in its analysis and based on the findings, Fitch
made the following adjustments:

Fitch made an adjustment on 383 loans that were subject to federal,
state and/or local predatory testing. Two of these loans were
marked as high cost and received a 200% LS adjustment. The
remaining loans contained material violations, including an
inability to test for high-cost violations or confirm compliance,
which could expose the trust to potential assignee liability. These
loans were marked as "indeterminate." Typically, the HUD issues are
related to missing the final HUD, illegible HUDs, incomplete HUDs
due to missing pages or only having estimated HUDs where the final
HUD1 was not used to test for high-cost loans. To mitigate this
risk, Fitch assumed a 100% LS for loans in the states that fall
under Freddie Mac's "do not purchase" list of high cost or "high
risk." Six loans were affected by this approach. For the remaining
375 loans, where the properties are not located in the states that
fall under Freddie Mac's do not purchase list, the likelihood of
all loans being high cost is lower. However, Fitch assumes the
trust could potentially incur additional legal expenses. Fitch
increased its LS expectations by 5% for these loans to account for
the risk.


FREDDIE MAC 2019-DNA2: Fitch to Rate 15 Tranches 'B(EXP)'
---------------------------------------------------------
Fitch Ratings expects to rate Freddie Mac's Structured Agency
Credit Risk Trust 2019-DNA2 (STACR 2019-DNA2).The reference pool
for STACR 2019-DNA2 will consist of loans with loan to value ratios
between 60% and 80% that were acquired by Freddie Mac between July
1, 2018 and Sept. 30, 2018 and originated on or after Jan. 1,
2015.

The notes will be issued from a special-purpose trust whose
security interest consists of the custodian account and a credit
protection agreement with Freddie Mac. Funds in the custodian
account will be used to pay principal on the notes and to make
payments to Freddie Mac for mortgage loans that experience certain
credit events. The notes will be issued as LIBOR-based floaters and
carry a 30-year legal final maturity. Freddie Mac is responsible
for making interest payments through a credit protection agreement
with the trust.

The ratings on the M-1, M-2A and M-2B notes are limited to the
lower of 1) the quality of the mortgage loan reference pool and
credit enhancement (CE) available through subordination and 2)
Freddie Mac's Issuer Default Rating.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The reference mortgage loan
pool consists of high-quality loans securitized into Freddie Mac's
participation certificates between July 1, 2018 and Sept. 30, 2018
and originated on or after Jan. 1, 2015. The reference pool will
consist of loans with original loan-to-value (LTV) ratios between
60% and 80%. Overall, the reference pool's collateral
characteristics are similar to recent STACR low-LTV transactions
and reflect the strong credit profile of post-crisis mortgage
originations.

Very Low Operational Risk (Positive): Fitch considers this
transaction to have very low operational risk. Freddie Mac is an
industry leader in residential mortgage activities and is assessed
as an 'Above Average' aggregator. The GSE maintains strong seller
oversight and implements a comprehensive risk management framework.
Due diligence for this transaction was performed by an Acceptable -
Tier 2 third-party review firm on a statistically random sample of
loans. The sampling scope and methodology are consistent with Fitch
criteria, and the results of the review confirm high quality loan
origination processes.

Collateral Drift (Negative): While the credit attributes remain
significantly stronger than any pre-crisis vintage, the STACR
credit attributes are weakening relative to STACR transactions
issued several years ago. Compared to the earlier post-crisis
vintages, this reference pool consists of weaker FICO scores and
debt-to-income (DTI) ratios. The credit migration has been a key
driver of Fitch's rising loss expectations, which have moderately
increased over time.

30-year Legal Maturity (Negative): As with recent deals, the M-1,
M-2A, M-2B, B-1A, B-1B, B-2A and B-2B notes have a 30-year legal
final maturity, instead of a 12.5 year maturity. Thus, life-of-loan
losses on the reference pool will be passed through to noteholders.
As a result, Fitch did not apply a maturity credit to reduce its
default expectations.

Clean Pay History for Loans in Disaster Areas (Positive): Freddie
Mac will not remove loans in counties designated as natural
disaster areas by the Federal Emergency Management Agency (FEMA) as
of the closing date. However, any loans with a prior delinquency
were removed from the reference pool. In addition, Freddie Mac will
remove loans that were on a disaster forbearance plan and become
delinquent between the deal closing date and the April 2019
distribution date if the loan is located in an area designated as a
major disaster area by FEMA and FEMA authorized individual
assistance to those homeowners prior to the closing date. As a
result, Fitch does not consider there to be additional risk to the
pool by including these loans.

Solid Alignment of Interests (Positive): While the transaction is
designed to transfer credit risk to private investors, Fitch
believes the transaction benefits from solid alignment of
interests. Freddie Mac will retain credit risk in the transaction
by holding the senior reference tranche A-H, which has 4.25% of
loss protection, as well as a minimum of 5% of the M-1, M-2A, M-2B,
B-1A, B-1B, B-2A and B-2B reference tranches, and 100% of the
first-loss B-3H reference tranche. Initially, Freddie Mac will
retain an approximately 28% vertical slice/interest through the
M-1H, M-2AH, M-2BH, B-1AH, B-1BH, B-2AH and B-2BH reference
tranches.

Receivership Risk Considered (Neutral): Under the Federal Housing
Finance Regulatory Reform Act, the Federal Housing Finance Agency
(FHFA) must place Freddie Mac into receivership if it determines
that the government-sponsored enterprise's (GSE) assets are less
than its obligations for longer than 60 days following the deadline
of its SEC filing. As receiver, FHFA could repudiate any contract
entered into by Freddie Mac if it is determined that such action
would promote an orderly administration of the GSE's affairs. Fitch
believes that the U.S. government will continue to support Freddie
Mac, as reflected in its current rating of the GSE. However, if, at
some point, Fitch views the support as being reduced and
receivership likely, the rating of Freddie Mac could be downgraded,
and ratings on the M-1, M-2A and M-2B notes, along with their
corresponding MAC notes, could be affected.

Home Possible Exposure (Negative): Approximately 4.2% of the
reference pool (versus 2% in 2018-DNA1) was originated under
Freddie Mac's Home Possible and Fannie Mae's HomeReady program.
These programs targets low- to moderate-income homebuyers or buyers
in high-cost or underrepresented communities, and provides
flexibility for a borrower's LTV, income, down payment and mortgage
insurance coverage requirements. Fitch anticipates higher default
risk for these loans due to measurable attributes (such as FICO,
LTV and property value), which is reflected in increased CE.

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. Two
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 10.0%, 20.0% and 30.0%, in addition to the
model projected 6.4% at the base case. 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'.

STACR 2019-DNA2
   
A-H NR(EXP)sf Expected Rating
  
B-1 NR(EXP)sf Expected Rating
  
B-1A NR(EXP)sf Expected Rating
  
B-1AH NR(EXP)sf Expected Rating
  
B-1AI NR(EXP)sf Expected Rating
  
B-1AR NR(EXP)sf Expected Rating
  
B-1B NR(EXP)sf Expected Rating
  
B-1BH NR(EXP)sf Expected Rating
  
B-2 NR(EXP)sf Expected Rating
  
B-2A NR(EXP)sf Expected Rating
  
B-2AH NR(EXP)sf Expected Rating
  
B-2AI NR(EXP)sf Expected Rating
  
B-2AR NR(EXP)sf Expected Rating

B-2B NR(EXP)sf Expected Rating
  
B-2BH NR(EXP)sf Expected Rating
  
B-3H NR(EXP)sf Expected Rating
  
M-1 BBB-(EXP)sf Expected Rating

M-1H NR(EXP)sf Expected Rating
  
M-2 B(EXP)sf Expected Rating
  
M-2A BB(EXP)sf Expected Rating

M-2AH NR(EXP)sf Expected Rating

M-2AI BB(EXP)sf Expected Rating
  
M-2AR BB(EXP)sf Expected Rating
  
M-2AS BB(EXP)sf Expected Rating

M-2AT BB(EXP)sf Expected Rating
  
M-2AU BB(EXP)sf Expected Rating
  
M-2B B(EXP)sf Expected Rating

M-2BH NR(EXP)sf Expected Rating
  
M-2BI B(EXP)sf Expected Rating

M-2BR B(EXP)sf Expected Rating
  
M-2BS B(EXP)sf Expected Rating

M-2BT B(EXP)sf Expected Rating

M-2BU B(EXP)sf Expected Rating

M-2I B(EXP)sf Expected Rating

M-2R B(EXP)sf Expected Rating

M-2RB B(EXP)sf Expected Rating

M-2S B(EXP)sf Expected Rating

M-2SB B(EXP)sf Expected Rating

M-2T B(EXP)sf Expected Rating

M-2TB B(EXP)sf Expected Rating

M-2U B(EXP)sf Expected Rating

M-2UB B(EXP)sf Expected Rating


HOUSTON GALLERIA 2015-HGLR: DBRS Confirms BB Rating on Cl. E Certs
------------------------------------------------------------------
DBRS, Inc. confirmed the ratings of the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2015-HGLR
issued by Houston Galleria Mall Trust 2015-HGLR:

-- Class A-1A1 at AAA (sf)
-- Class A-1A2 at AAA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class D at BBB (low) (sf)
-- Class X-CP at BB (high) (sf)
-- Class X-NCP at BB (high) (sf)
-- Class E at BB (sf)

All trends are Stable.

The rating confirmations reflect the stable performance of the
transaction since issuance, which is secured by the fee interest in
a 1.2 million square foot (sf) portion of the 2.1 million sf
super-regional Houston Galleria Mall (the Galleria) in Houston,
Texas. The property is encumbered by a $1.2 billion whole loan
split between the $1.05 billion note securitized in this
transaction, and a $150 million companion loan securitized in the
JPMBB 2015-C28 transaction, which is not rated by DBRS. The loan
has a ten-year term and is interest only throughout. The mall is
located approximately eight miles west of downtown Houston,
northwest of the intersection of I-610 and I-69. The tenant roster
includes approximately 400 retailers and restaurants, along with
non-collateral tenants: Macy's, Nordstrom, Neiman Marcus (Neiman)
and Saks Fifth Avenue (Saks). Macy's and Nordstrom own their sites
and spaces, while Neiman and Saks own their respective improvements
and are subject to ground leases. There is also an attached 469-key
Westin hotel, which recently completed a $30.0 million renovation
in Q4 2018. The Galleria is the largest shopping center in Texas
and is the fourth largest in the nation. It is owned by Simon
Property Group and Institutional Mall Investors.

According to the December 2018 rent roll, the collateral portion of
the mall was 92.0% occupied at an average base rental rate of
$82.52. The occupancy rate increased from the December 2017 rate of
89.7% but remains below the September 2016 rate of 96.8%. The
vacancy rate increased in 2017 at the completion of the 110,000 sf
expansion, which created a new luxury retail wing and relocated
Saks to an end-cap box. The renovation cost $250.0 million, and the
additional square footage is collateral for the subject loan.

According to the rent roll, Neiman renewed its lease for an
additional 25 years to January 2044, with its annual ground lease
payments increasing to $8.13 per square foot (psf) from $7.93 psf.
The three largest collateral tenants, representing 10.8% of the net
rentable area (NRA), are Lifetime Fitness (6.6% of the NRA,
expiring in March 2022), Forever 21 (2.3% of the NRA, expiring in
January 2023) and H&M (1.9% of the NRA, expiring in January 2025).
Tenant rollover throughout 2019 includes 29 tenants, collectively
occupying 9.5% of the collateral NRA. The largest tenant is Gap
(1.5% of the NRA), which had a scheduled lease expiration in
January 2019. The tenant appears to have signed a lease extension
as it remains on the mall's online tenant directory. In March 2019,
Gap announced it would close 230 underperforming stores over the
next two years; however, no official closure list has been provided
at this time with the first round of closures expected to occur in
Q4 2019. The subject location is quite large at 17,000 sf and has
reported flat annual sales of $300 psf over the past two years,
equal to an elevated occupancy cost of 33.0%. While the tenant
would likely continue to operate at the mall given the mall's
status as a premier retail destination, it is possible that the
tenant would reduce its footprint given the high-operating costs
relative to its recent sales volume.

According to the YE2018 tenant sales report, overall mall sales
performance remains strong. Saks reported sales of $591 psf;
in-line tenants occupying less than 10,000 sf (excluding Apple)
reported sales of $783 psf, and in-line tenants occupying more than
10,000 sf reported sales of $795 psf. Individual tenant
year-over-year (YOY) sales trends are generally positive; however,
select large in-line retailers showed YOY sales psf declines,
including H&M (-16.7% to $355 psf), TopShop (-0.6% to $295 psf) and
Express Women (-2.5% to $356 psf), which may indicate that these
tenants occupy retail suites too large for current operations as
the YE2018 individual occupancy cost figures were 30.5%, 35.1%, and
43.0%, respectively. In comparison, Forever 21 reported YE2018
sales of $296 psf (+8.3% YOY), which equated to an occupancy cost
of 20.4%.

At YE2018, the debt service coverage ratio was 2.43 times (x);
compared with the YE2017 figure of 2.47x and the YE2016 figure of
2.32x. Continued YOY performance has been stable as effective gross
income grew by 2.7%, driven by a 5.2% increase in base rental
revenue and a 35.7% increase in percentage rent. Expenses have
remained stable; however, the servicer-provided OSAR reported a
$4.1 million increase in debt service, netting out the revenue
gains.

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


JAMESTOWN CLO XII: Moody's Rates $27MM Class C Notes 'Ba3'
----------------------------------------------------------
Moody's Investors Service has assigned ratings to five classes of
notes issued by Jamestown CLO XII Ltd.

Moody's rating action is as follows:

US$270,000,000 Class A-1 Senior Secured Floating Rate Notes due
2032 (the "Class A-1 Notes"), Assigned Aaa (sf)

US$69,500,000 Class A-2 Senior Secured Floating Rate Notes due 2032
(the "Class A-2 Notes"), Assigned Aa2 (sf)

US$20,000,000 Class B Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class B Notes"), Assigned A2 (sf)

US$27,000,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class C Notes"), Assigned Baa3 (sf)

US$26,000,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class D Notes"), Assigned 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."

RATINGS RATIONALE

Jamestown CLO XII 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 and unsecured
loans. The portfolio is approximately 80% ramped as of the closing
date.

Investcorp Credit Management US 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 March 2019.

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

Par amount: $450,000,000

Diversity Score: 77

Weighted Average Rating Factor (WARF): 2788

Weighted Average Spread (WAS): 3.35%

Weighted Average Coupon (WAC): 6.50%

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
March 2019.

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.


JP MORGAN 2004-CIBC9: Fitch Rates $8.5MM Class F Notes 'D'
----------------------------------------------------------
Fitch Ratings has upgraded one and affirmed nine classes of JP
Morgan Chase Commercial Mortgage Securities Corp. 2004-CIBC9 (JPMCC
2004-CIBC9).

KEY RATING DRIVERS

Stable Loss Expectations: Loss expectations have remained
relatively stable since the last rating action due to the generally
stable performance of the pool. Fitch had previously capped the
rating of class E due to concerns about the binary risks associated
with the single-tenant lease expiry in March 2019 and ARD date of
June 2019 for the largest loan in the pool; Federal Express -
Windsor Locks (37.3% of the pool). Federal Express signed a lease
renewal in September 2018 extending the lease term through March
2029. The loan has a June 2019 ARD date, but the servicer does not
yet have an indication from the borrower about plans to refinance
the loan. The upgrade to class E in part reflects the lease
renewal, increasing the refinance prospects for this loan.

Improved Credit Enhancement to Class E: Credit enhancement to class
E has continued to improve due to paydown and defeasance. Defeased
collateral represents 39.8% of the pool balance. Class E is 79%
covered by defeasance, up from 75% at the last rating action. The
pool has experienced 98.4% pay down since issuance. Since the last
rating action, the deal balance has been reduced by 12.6% of the
prior balance, or $2.5 million. The upgrade to class E also
reflects that the class balance is now 95.6% covered by defeased
collateral and a fully amortizing loan that is collateralized by a
single-tenant retail store leased to Walgreens through September
2028.

Upcoming Maturities: In addition to the ARD date for the largest
loan in the pool, one additional loan (1.3% of the pool) is
scheduled to mature in 2019. The remainder of the pool matures in
2022 (7.3% of the pool) and 2024 (54.1% of the pool).

Pool Concentration: The pool is highly concentrated with only seven
of the original 98 loans remaining and the largest loan represents
37% of the pool. Fitch performed a sensitivity analysis to address
the potential class payoff and potential losses. A loan level loss
of up to 83% of the non-defeased loans would be contained to class
F, which is already rated 'Dsf'.

Additional Considerations; Fitch Loans of Concern (FLOCs): Two
fully amortizing loans (14.7% of the pool) have been flagged as
FLOCs for risks related to lease rollover. Stillwater Place CDH
(9.7% of the pool) is a 26,491 square foot (sf) retail property
comprised of three buildings built in 1905 and renovated in 2001
and is located in Naperville, IL with scheduled lease rollover of
45% of net rentable area (NRA) in 2020 and 25% in 2021. Stillwater
Place B (5.0% of the pool) is a 12,127 sf retail center built in
2000 and is located in Naperville, IL with scheduled lease rollover
of 35.9% of NRA in 2019, 13.4% in 2020, and 13.4% in 2021.

RATING SENSITIVITIES

The Rating Outlook for class E remains Positive. The Positive
Outlook reflects the significant defeasance coverage, the continued
benefit from paydown as loans amortize, and the anticipated
repayment of the largest loan in the pool at its June 2019 ARD.
Further upgrade to class E is probable should the largest loan
repay. Downgrades are not considered likely, but could be possible
with significant performance declines.

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 upgraded the following class:

  -- $8,651,051 class E notes to 'Asf' from 'BBBsf'; Outlook
Positive.

Fitch has affirmed the following classes:

  -- $8,557,225 class F notes at 'Dsf'; RE 85%;

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

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

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

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

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

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

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

  -- $0 class P notes at 'Dsf'; RE 0%.

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


JPMBB COMMERCIAL 2014-C21: DBRS Confirms B(high) on Cl. F Certs
---------------------------------------------------------------
DBRS Limited confirmed all classes of Commercial Mortgage
Pass-Through Certificates, Series 2014-C21 (the Certificates)
issued by JPMBB Commercial Mortgage Securities Trust 2014-C21 as
follows:

-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X-A at AAA (sf)
-- Class X-B at AA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class EC at A (low) (sf)
-- Class D at BBB (low) (sf)
-- Class X-C at BB (high) (sf)
-- Class E at BB (sf)
-- Class X-D at BB (low) (sf)
-- Class F at B (high) (sf)

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance when the transaction consisted of 73
fixed-rate loans secured by 84 commercial properties with an
original trust balance of $1.3 billion. Per the February 2019
remittance, 67 loans remain in the pool with a current trust
balance of $1.2 billion, representing a collateral reduction of
6.4% due to scheduled loan amortization and the repayment of seven
loans. The pool also benefits from defeasance as five loans (8.0%
of the pool) are fully defeased. There is only one loan scheduled
to mature in 2019 in Prospectus ID#49, LaQuinta Inn – Lake
Charles (0.5% of the pool), which is secured by a limited service
hotel in southwest Louisiana. The loan is scheduled to mature in
June 2019, and although the year-end (YE) 2018 DSCR of 2.04 times
(x) is below historical performance trends that showed the debt
service coverage ratio (DSCR) hovering near or just below 2.50x,
the exit debt yield of approximately 15.8% implies a successful
refinance is likely. The remaining loans in the pool are scheduled
to mature in 2021 and 2024. There are eight loans, representing
25.9% of the pool, that are fully interested only (IO) and 11 loans
(31.6% of the pool) with partial IO structures, ranging between two
and four months of IO remaining. In general, these loans are
performing in line with expectations at issuance.

To date, approximately 96.8% of the pool (excluding defeased loans)
reported YE2017 financials. Based on the most recent year-end
reporting, the pool reported a weighted average (WA) DSCR and debt
yield of 1.52x and 8.9%, respectively. At issuance, the WA DBRS
Term DSCR and Debt Yield for the remaining loans was 1.43x and
8.5%, respectively. Based on the most recent reporting, the 14
largest non-defeased loans (58.8% of the pool) in the pool reported
a WA DSCR and debt yield of 1.62x and 9.0%, respectively,
reflective of 21.4% cash flow growth from DBRS net cash flow
figures at issuance.

According to the February 2019 remittance, there are nine loans
(13.5% of the pool) on the servicer's watchlist and one loan,
Lockport Professional Park (Prospectus ID#46, 0.6% of the pool), in
special servicing. The Lockport Professional Park loan is secured
by 19 Class B office buildings that, combined, account for 82,292
square feet (sf) and are all located in Lockport, New York, within
the Buffalo metropolitan statistical area. The loan has been in
special servicing since 2015 and property performance has
precipitously declined since the loan's transfer. Based on the most
recent appraised value of $4.6 million, dated August 2017, DBRS
expects the loan to take a loss greater than 75.0% of the current
trust balance.

Of the nine loans on the servicer's watchlist, the largest two are
secured by regional malls and combined account for 6.6% of the pool
balance. The pool is concentrated in retail properties as five
loans (23.3% of the pool) are secured by regional malls and larger
anchored retail properties, including three loans (18.2% of the
pool) in the top ten. The largest loan on the watchlist,
Westminster Mall (Prospectus ID#6, 4.3% of the pool), is secured by
a regional mall located in Westminster, California, approximately
30 miles southwest of the Los Angeles central business district.
The loan is being monitored for the property's loss of
non-collateral anchors Sears (16.2% of the total net rentable area
(NRA)). DBRS also notes that cash flows have declined significantly
since issuance, resulting in an in-place DSCR of 1.21x, down from
the DBRS Term DSCR at issuance of 1.69x, largely a factor of
revenue declines since 2014. Simon spun off this asset to
Washington Prime Group (WPG) in 2014, shortly after closing for the
subject loan, a move that is perhaps telling given that the entity
has typically held non-core assets and/or malls considered for
redevelopment. Although the cash flow declines are noteworthy, DBRS
believes the property's prime location within close proximity to
transportation arteries within a densely populated area would lend
well to repurposing the Sears and perhaps other spaces at the
property. The trust exposure at $102 per sf (psf) is considered
reasonable. For additional information on this loan, please see the
DBRS Viewpoint platform, for which information has been provided
below.

More concerning is the second-largest loan on the watchlist in
Charlottesville Fashion Square (Prospectus ID#16, 2.3% of the
pool), which is secured by a regional mall in Charlottesville,
Virginia, a tertiary area that is home to the University of
Virginia. This mall is also owned and operated by WPG and is also
losing an anchor in Sears (28.8% of collateral NRA) in March 2019.
Once Sears vacates the property, DBRS expects the property's
physical occupancy rate will fall to 65.6%, down from 94.5% in
September 2018. These developments combine with continued trends of
declining inline sales for the property, which have generally
hovered below $300 psf, and recent announcement by WPG as part of
its annual 10K filing for 2019, that the property has been
downgraded from a Tier II property to a "non-core property" in the
firm's portfolio. Previously, properties receiving this
classification have been sold by WPG or given back to lenders. DBRS
assumed a highly stressed cash flow for the purposes of this
review, significantly increasing the probability of default and is
currently monitoring this loan on the DBRS Hotlist. For additional
information on this loan, please see the DBRS Viewpoint platform.

DBRS also notes increased risk for the pool in the third-largest
loan on the servicer's watchlist, 200 West Monroe (Prospectus
ID#18, 2.1% of the pool). This loan is secured by an office
property in Chicago, Illinois, and the cash flows and occupancy
rate have both been sustained at levels well below the issuance
figures. Although there has been some recent leasing activity that
will move the property's occupancy rate up to approximately 72.0%,
that figure remains well below the issuance figure of 82.4% and the
loan's five-year IO period will expire in June 2019, further
stressing the sponsor's ability to fund debt service shortfalls out
of pocket. DBRS has placed the loan on the DBRS Hotlist. For
additional information, please see the extended loan commentary in
the DBRS Viewpoint platform.

At issuance, DBRS shadow-rated Miami International Mall (Prospectus
ID#3, 5.1% of the pool) investment grade and with this review, DBRS
confirms the credit characteristics of the loan remain in line with
the investment-grade 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.

All ratings are subject to surveillance, which could result in
ratings being upgraded, downgraded, and placed under review,
confirmed or discontinued by DBRS.

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


KRR CLO 24: Moody's Assigns Ba3 Rating on $23MM Class E Notes
-------------------------------------------------------------
Moody's Investors Service has assigned ratings to six classes of
notes issued by KKR CLO 24 Ltd.

Moody's rating action is as follows:

US$247,000,000 Class A-1 Senior Secured Floating Rate Notes due
2032 (the "Class A-1 Notes"), Assigned Aaa (sf)

US$13,200,000 Class A-2 Senior Secured Floating Rate Notes due 2032
(the "Class A-2 Notes"), Assigned Aaa (sf)

US$40,000,000 Class B Senior Secured Floating Rate Notes due 2032
(the "Class B Notes"), Assigned Aa2 (sf)

US$19,600,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class C Notes"), Assigned A2 (sf)

US$23,200,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class D Notes"), Assigned Baa3 (sf)

US$23,000,000 Class E Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

The Class A-1 Notes, the Class A-2 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

KKR CLO 24 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 100% ramped as
of the closing date.

KKR Financial Advisors 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 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 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 March 2019.

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

Par amount: $400,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2977

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 49.25%

Weighted Average Life (WAL): 9.11 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
March 2019.

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.


LB-UBS COMMERCIAL 2007-C6: Fitch Affirms CC Rating on Class B Certs
-------------------------------------------------------------------
Fitch Ratings affirms 18 classes of LB-UBS Commercial Mortgage
Trust commercial mortgage pass-through certificates series
2007-C6.

KEY RATING DRIVERS

Minimal Change to Credit Enhancement: The affirmations reflect the
overall stable credit enhancement and performance since Fitch's
prior rating action. As of the February 2019 distribution date, the
pool's aggregate principal balance has been reduced by 85.8% to
$422.6 million from $2.98 billion at issuance. Since Fitch's prior
rating action, three loans were liquidated resulting in $21 million
in losses. To date, the pool has experienced $178.4 million in
realized losses with interest shortfalls impacting classes F
through T.

Concentrated Pool: The pool is adversely selected with only 14
individual loans or assets, and one cross-collateralized portfolio
of 39 loans remaining. The remaining pool is either REO (65.1%), in
foreclosure (10.5%), or a Fitch Loan of Concern (24.3%). Due to the
highly concentrated nature of the pool, Fitch performed a
sensitivity and liquidation analysis, which grouped the remaining
loans based on their current status and collateral quality and
ranked them by their perceived likelihood of repayment and/or loss
expectations. The ratings reflect this sensitivity analysis.

Largest Asset in Special Servicing: The largest asset in the pool,
the PECO Portfolio, is an REO retail portfolio accounting for 55.7%
of the pool balance. The loan was originally secured by 39
cross-collateralized and cross-defaulted retail properties across
13 states. As of the February 2019 distribution date, 14 of the
properties have been sold and the proceeds were applied pro-rata
across all properties. The portfolio transferred to special
servicing in August 2012 when the borrower requested a loan
modification. The borrower later agreed to a deed-in-lieu of
foreclosure and the portfolio became REO in two stages between June
2014 and March 2015. The servicer is currently completing capital
improvement projects and working to increase occupancy at the
remaining properties. The servicer plans to sell properties as they
are stabilized.

The largest performing loan is the Islandia Shopping Center (A
Note: 14%; B Note: 2%), which is collateralized by a 376,774 sf
grocery-anchored shopping center in Islandia, NY on Long Island.
The loan was previously in special servicing and in 2015 the loan
was modified. Terms of the modification included a four year
extension (new maturity date of July 15, 2021), changing of the IO
period and interest rate and the creation of a hope note. The
property is currently performing at 96% occupancy and a 1.36x DSCR
for the A note, as of 3Q 2018. Fitch's analysis assumed the A note
to take a loss, and a full loss of the B note.

RATING SENSITIVITIES

The Stable Rating Outlooks on classes A-M and A-MFL reflect high
credit enhancement. Future upgrades are unlikely given the
concentrated nature of the pool and large percentage of the pool in
special servicing; however payoff of these classes is likely
through continued amortization of the performing loans and/or
dispositions. The remaining performing loans mature in 2021 and
2022. Distressed classes are subject to further downgrades as
losses on specially serviced loans are realized.

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 affirms the following ratings:

  -- $4.0 million class A-M at 'Asf'; Outlook Stable;

  -- $1.2 million class A-MFL at 'Asf'; Outlook Stable;

  -- $156.4 million class A-J at 'CCCsf'; RE 95%;

  -- $33.5 million class B at 'CCsf'; RE 0%;

  -- $37.2 million class C at 'CCsf'; RE 0%;

  -- $33.5 million class D at 'CCsf'; RE 0%;

  -- $29.8 million class E at 'Csf' RE 0%;

  -- $29.8 million class F at 'Csf'; RE 0%;

  -- $33.5 million class G at 'Csf'; RE 0%;

  -- $37.2 million class H at 'Csf'; RE 0%;

  -- $26.4 million 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-2FL, A-3, A-AB, A-4, and A-1A certificates
have been paid in full. Fitch does not rate the class T
certificates. Fitch previously withdrew the rating on the
interest-only class X certificates.


MORGAN STANLEY 2007-TOP25: DBRS Confirms C Rating on Class C Certs
------------------------------------------------------------------
DBRS Limited confirmed the ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2007-TOP25 issued by Morgan
Stanley Capital I Trust, Series 2007-TOP25 as follows:

-- Class A-J at BBB (low) (sf)
-- Class B at B (sf)
-- Class C at C (sf)

All trends are Stable with the exception of Class C, which has a
rating that does not carry a trend.

The rating confirmations reflect the overall stable performance of
the transaction. As of the February 2019 remittance, ten of the
original 204 loans remain in the trust, with an aggregate principal
balance of $119.6 million. Since issuance, the pool has experienced
a collateral reduction of 92.3% as a result of scheduled loan
amortization and successful loan repayment, in addition to
principal recovered from liquidated loans and realized losses from
liquidated loans. To date, 25 loans have been liquidated from the
trust, resulting in realized losses of $99.3 million. Two loans
were recently liquidated from the trust with no losses incurred and
contributed to a collateral reduction of 0.6% since the last
review.

The pool is concentrated by loan size, with the largest three loans
representing 82.0% of the pool. Two of the three largest loans,
Shoppes at Park Place (Prospectus ID#3; 58.7% of the pool) and
Romeoville Towne Center (Prospectus ID#16; 15.0% of the pool), are
currently in special servicing.

Shoppes at Park Place are secured by a 325,270-square-foot (sf)
retail power center located in Pinellas Park, Florida. The loan
transferred to special servicing in January 2017 due to maturity
default and has struggled to obtain refinancing since, which may be
a result of the sponsor's poor credit history. Although no 2017 or
2018 financials have been received, the property benefits from
strong historical occupancy trends. As of December 2018, occupancy
remained above 95.0%. In addition, the property had an appraised
value of $103.0 million as of February 2018, well above the
issuance value of $90.0 million and the current outstanding loan
balance of $70.1 million. DBRS expects the resolution for this loan
to be relatively positive, given the healthy occupancy rate, the
property's strong location, and the most recent valuation, which
suggests that a successful refinance is possible. The servicer has
ordered an updated appraisal and indicated that a foreclosure trial
is expected to occur sometime during Q4 2019. DBRS will continue to
monitor the loan closely for developments.

The second-largest loan, Romeoville Towne Center, is secured by a
108,242 sf grocery-anchored shopping center located in the Chicago
suburb of Romeoville, Illinois. This loan was also transferred to
special servicing in January 2017 due to maturity default, and
according to the servicer, a foreclosure sale occurred in January
2019. The property's largest space, formerly occupied by Dominick's
Pizza (60.5% of the net rentable area), has been dark for several
years, following the closure of all the chain's stores located
throughout the Chicago area. As of January 2019, the property had a
physical vacancy rate of 32.0%. Per the October 2018 appraisal, the
property was valued at $9.1 million, a significant decline from
$27.2 million at issuance, reflecting a 66.5% decline in value.
DBRS analyzed the loan with a loss severity in excess of 70.0% as
part of this review.


MORGAN STANLEY 2019-L2: Fitch Rates $9.16MM Class G-RR Certs 'B-sf'
-------------------------------------------------------------------
Fitch Ratings has assigned the following ratings to Morgan Stanley
Capital I Trust 2019-L2 commercial mortgage pass-through
certificates, series 2019-L2:

  -- $16,200,000 class A-1 'AAAsf'; Outlook Stable;

  -- $17,100,000 class A-2 'AAAsf'; Outlook Stable;

  -- $28,400,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $218,300,000 class A-3 'AAAsf'; Outlook Stable;

  -- $361,191,000 class A-4 'AAAsf'; Outlook Stable;

  -- $641,191,000b class X-A 'AAAsf'; Outlook Stable;

  -- $82,438,000 class A-S 'AAAsf'; Outlook Stable;

  -- $44,655,000 class B 'AA-sf'; Outlook Stable;

  -- $127,093,000b class X-B 'AA-sf'; Outlook Stable;

  -- $41,219,000 class C 'A-sf'; Outlook Stable;

  -- $25,190,000a class D 'BBBsf'; Outlook Stable;

  -- $15,343,000a class E 'BBB-sf'; Outlook Stable;

  -- $40,533,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $24,731,000ac class F-RR 'BB-sf'; Outlook Stable;

  -- $9,160,000ac class G-RR 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $32,060,275ac class H-RR;

  -- $18,884,408ad class VRR.

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

(b) Notional amount and interest-only.

(c) Horizontal credit risk retention interest.

(d) Vertical credit risk retention interest.

Since Fitch published its expected ratings on Feb. 20, 2019, the
balance of class A-3 increased to $218,300,000 (from Fitch's
assumed balance of $167,500,000) and class A-4 decreased to
$361,191,000 (from Fitch's assumed balance of $411,991,000). The
balances reflect the final pricing for each certificate and the
aggregate balance of class A-3 and class A-4 is unchanged at
$579,491,000. Additionally, based on the final pricing of the
certificates, class C is a WAC class that provides no excess cash
flow that would affect the payable interest on the class X-B
certificates. Fitch's rating on class X-B has been updated to
'AA-sf' from 'A-sf' to reflect the rating of the lowest referenced
tranche whose payable interest has an impact on the interest-only
payments. The balance of the X-B class has been updated to
$127,093,000, as it no longer references class C. There are no
other changes since Fitch published its expected ratings. The
classes above reflect the final ratings and deal structure.

The ratings are based on information provided by the issuer as of
March 12, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 50 loans secured by 68
commercial properties having an aggregate principal balance of
$934,871,683 as of the cut-off date. The loans were contributed to
the trust by Morgan Stanley Mortgage Capital Holdings LLC, Argentic
Real Estate Finance LLC, Starwood Mortgage Capital LLC, Cantor
Commercial Real Estate Lending, L.P. and BSPRT CMBS Finance, LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 76.1% of the properties
by balance, cash flow analysis of 85.7% and asset summary reviews
on 100.0% of the pool.

KEY RATING DRIVERS

Lower Fitch Leverage: Overall, the pool's Fitch debt service
coverage ratio (DSCR) of 1.27x is better than average when compared
with the 2017 average of 1.26x and 2018 average of 1.22x for other
recent Fitch-rated multiborrower transactions. The pool's Fitch
loan-to-value (LTV) of 98.5% is also better than average when
compared with the 2017 average of 101.6% and 2018 average of
102.0%.

Single-Tenant Concentration: Ten loans comprising approximately
20.4% of the pool are backed by properties designated single-tenant
properties by Fitch, including properties backing five of the 20
largest loans. This is greater than the 2017 single-tenant property
concentration average of 19.3% and lower than the 2018 average of
22.6%. Fitch was comfortable the dark value covers the implied high
investment-grade proceeds for the single-tenant properties sampled,
except for NTT-Quincy. Fitch increased the 'AAAsf' loss estimate to
account for the shortfall allocable to the NTT-Quincy loan.

Better Pool Diversity: The pool is more diverse than recent
Fitch-rated multiborrower transactions. The 10 largest loans
account for 44.5% of the pool, compared to the 2017 and 2018
averages of 53.1% and 50.6%, respectively. The pool's loan
concentration index (LCI) is 319, which better than average when
compared with the 2017 average of 398 and 2018 average of 373 for
other Fitch-rated multiborrower transactions.

RATING SENSITIVITIES

For this transaction, Fitch's NCF was 15.8% below the most recent
year's 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 MSC
2019-L2 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 'A-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.


NEW RESIDENTIAL 2019-NQM2: Fitch to Rate Class B-2 Notes 'Bsf'
--------------------------------------------------------------
Fitch Ratings expects to rate New Residential Mortgage Loan Trust
2019-NQM2 (NRMLT 2019-NQM2) as follows:

  -- $213,924,000 class A-1 notes 'AAAsf'; Outlook Stable;

  -- $27,219,000 class A-2 notes 'AAsf'; Outlook Stable;

  -- $27,524,000 class A-3 notes 'Asf'; Outlook Stable;

  -- $13,609,000 class M-1 notes 'BBBsf'; Outlook Stable;

  -- $11,316,000 class B-1 notes 'BBsf'; Outlook Stable;

  -- $6,575,000 class B-2 notes 'Bsf'; Outlook Stable.

Fitch will not be rating the following classes:

  -- $5,658,065 class B-3 notes;

  -- $305,825,065 class XS-1 notional notes;

  -- $305,825,065 class XS-2 notional notes.

The 'AAAsf' for NRMLT 2019-NQM2 reflects the satisfactory
operational review conducted by Fitch of the originator, 100%
loan-level due diligence review with no material findings, a Tier 2
representation and warranty framework, and the transaction's
structure.

TRANSACTION SUMMARY

Fitch expects to rate the residential mortgage-backed notes to be
issued by New Residential Mortgage Loan Trust 2019-NQM2 (NRMLT
2019-NQM2). The notes are supported by 591 loans with a balance of
$305.83 million as of the cutoff date. This will be the second
Fitch-rated expanded prime transaction consisting of loans solely
originated by NewRez LLC (NewRez), who was formerly known as New
Penn Financial, LLC.

The notes are secured mainly by nonqualified mortgages (NQMs) as
defined by the Ability to Repay (ATR) Rule. Approximately 75% of
the pool is designated as NQM, and the remaining 25% is investor
properties, which are not subject to the ATR Rule.

Initial credit enhancement (CE) for the class A-1 notes of 30.05%
is higher than Fitch's 'AAAsf' rating stress loss of 22.75%. The
additional initial CE is primarily driven by the pro rata principal
distribution between the A-1, A-2 and A-3 notes, which will result
in a significant reduction of the class A-1 subordination over time
through principal payments to the A-2 and A-3.

KEY RATING DRIVERS

Expanded Prime Credit Quality (Positive): The collateral consists
of 30-year fixed rate (48%) and five-, seven-, and 10-year
adjustable rate mortgage (ARM) loans (36%). Roughly 6.91% is
five-year ARM interest only (IO) loans and roughly 5.5% are
seven-year ARM IO loans. The weighted average (WA) credit score is
730, and the WA combined loan-to-value ratio (CLTV) is 74%. While
only 4% consists of borrowers with prior credit events in the past
seven years, which is lower than that observed in other Fitch-rated
NQM transactions, over 74% of the pool is made to self-employed
borrowers.

Alternative Income Documentation (Negative): Approximately 63% of
the loans in the pool were self-employed borrowers underwritten
using bank statements to verify income (61.7% was underwritten
using 12 months of statements and 1.7% using 24 months). Fitch
views the use of bank statements as a less reliable method of
calculating income than the traditional method of two-years of tax
returns. Fitch applied approximately a 1.4x increase in default
probability for bank-statement loans in the base-case to reflect
the higher risk. This adjustment assumes slightly less relative
risk than a "stated income" loan.

Investor Loans (Negative): Approximately 25% of the pool is
investment property loans, including 7% of the pool that was
underwritten to a cash flow ratio rather than the borrower's
debt-to-income ratio. Investor property loans exhibit a higher
default probability and higher loss-severity than owner-occupied
homes. The borrowers of the investor properties in the pool have a
WA FICO of 740 and an original combined LTV of 66.4% (the loans
underwritten to cash flow ratio have a WA FICO of 730 and an
original combined LTV of 60.9%). Fitch increased the default
probability by more than 2x for the cash flow ratio loans (relative
to a traditional income documentation investor loan) to account for
the increased risk.

Geographic Concentration (Negative): Approximately 38% of the pool
is concentrated in California with relatively moderate MSA
concentrations. The largest MSAs are New York (25%) followed by the
Los Angeles (19%) and San Francisco MSA (4%). The top three MSAs
account for 48% of the pool. As a result, Fitch applied a 1.08x PD
penalty to account for the NY and LA MSA concentrations.

Low Operational Risk (Positive): Operational risk is low for this
transaction. NewRez, a wholly owned subsidiary of NRZ, contributed
100% of the loans in the securitization pool. NewRez employs robust
sourcing and underwriting processes and is assessed by Fitch as an
'Average' originator. Fitch believes NRZ has solid RMBS experience
despite their limited non-QM issuance, and is an 'Acceptable'
aggregator. Strong loan quality was evidenced by the third-party
due diligence performed on 100% of the pool by AMC Diligence, LLC -
a Tier 1 diligence firm. The results of the diligence showed less
than 3% loans with 'C credit'. The issuer's retention of at least
5% of each class of bonds helps to ensure an alignment of interest
between the issuer and investors.

R&W Framework (Negative): The seller is providing loan-level
representations (reps) and warranties (R&W) with respect to the
loans in the trust. The R&W framework for this transaction is
classified as a Tier 2 due to the lack of an automatic review for
loans other than those with ATR realized losses.

While the seller, NRZ Sponsor VI LLC, is not rated by Fitch, its
parent, NRZ, has an internal credit opinion from Fitch. Through an
agreement, NRZ ensures that the seller will meet its obligations
and remain financially viable. Fitch increased its loss
expectations 85bps at the 'AAAsf' rating category to account for
the limitations of the Tier 2 framework and the counterparty risk.

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

Servicer and Master Servicer: Shellpoint Mortgage Servicing
(Shellpoint), rated 'RPS3+'/Stable by Fitch, will be the primary
servicer for the loans. Nationstar Mortgage, LLC (Nationstar/Mr.
Cooper), rated 'RMS2+'/Stable, will act as master servicer.
Delinquent principal and interest (P&I) advances required but not
paid by Shellpoint will be paid by Nationstar, and if Nationstar is
unable to advance, advances will be made by Citibank, N.A., the
transaction's paying agent. The servicer will be responsible for
advancing P&I for 180 days of delinquency.


OCTAGON INVESTMENT: Moody's Rates $50MM Class E-S Notes 'Ba3'
-------------------------------------------------------------
Moody's Investors Service has assigned ratings to five classes of
CLO refinancing notes issued by Octagon Investment Partners 24,
Ltd.

Moody's rating action is as follows:

US$522,700,000 Class A-1-S Senior Secured Floating Rate Notes Due
2031 (the "Class A-1-S Notes"), Definitive Rating Assigned Aaa
(sf)

US$88,400,000 Class B-S Senior Secured Floating Rate Notes Due 2031
(the "Class B-S Notes"), Definitive Rating Assigned Aa2 (sf)

US$41,200,000 Class C-S Secured Deferrable Floating Rate Notes Due
2031 (the "Class C-S Notes"), Definitive Rating Assigned A2 (sf)

US$51,900,000 Class D-S Secured Deferrable Floating Rate Notes Due
2031 (the "Class D-S Notes"), Definitive Rating Assigned Baa3 (sf)

US$50,100,000 Class E-S Secured Deferrable Floating Rate Notes Due
2031 (the "Class E-S Notes"), Definitive Rating Assigned Ba3 (sf)

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.

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

RATINGS RATIONALE

The rationale for the rating is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in Moody's methodology.

The Issuer has issued the Refinancing Notes on March 14, 2019 in
connection with the refinancing of all classes of secured notes
previously refinanced on October 10, 2017 or originally issued on
May 21, 2015. On the Second Refinancing Date, the Issuer used
proceeds from the issuance of the Refinancing Notes, along with the
proceeds from the issuance of one other class of secured notes and
additional subordinated notes, to redeem in full the Refinanced
Notes.

In addition to the issuance of the Refinancing Notes, one other
class of secured notes and additional subordinated notes, a variety
of other changes to the transaction's 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 March 2019.

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: $850,000,000

Defaulted par: $1,418,252

Diversity Score: 75

Weighted Average Rating Factor (WARF): 2700

Weighted Average Spread (WAS): 3.20%

Weighted Average Coupon (WAC): 7.5%

Weighted Average Recovery Rate (WARR): 46.0%

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
March 2019.

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.


READY CAPITAL 2018-4: DBRS Confirms B(low) Rating on Class G Certs
------------------------------------------------------------------
DBRS Limited confirmed the ratings on the following classes of
Ready Capital Mortgage Trust 2018-4 Commercial Mortgage
Pass-Through Certificates issued by Ready Capital Mortgage Trust
2018-4:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. At issuance, the collateral
consisted of 50 fixed-rate loans secured by commercial and
multifamily properties. The transaction is a sequential-pay
pass-through structure. As of the February 2019 remittance, 47
loans remain in the pool, representing a collateral reduction of
3.7% as three loans prepaid from the trust. An additional three
loans, which represent 14.7% of the fully funded pool balance, are
structured with future funding components that include the largest
loan, Prospectus ID#1 – Vernazza Apartments (9.3% of the fully
funded pool balance). According to the most recent financials, the
pool reported a weighted-average debt service coverage ratio
(WADSCR) and a debt yield of 1.38 times (x) and 7.7%, respectively.
This compares favorably with the DBRS Term figures at issuance of
1.18x and 8.5%, respectively. The top 15 loans reported a WADSCR
and a debt yield of 1.36x and 23.9%, respectively, representing a
weighted-average net cash flow (NCF) growth of 23.9% over the DBRS
issuance NCF figures.

As of the February 2019 remittance, there are seven loans on the
servicer's watchlist, representing 13.8% of the fully funded pool
balance. Most of these loans were flagged for occupancy and NCF
declines.

Classes IO-A and IO-B/C 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.


SECURITIZED ASSET 2006-OP1: Moody's Cuts Cl. M-3 Debt Rating to B1
------------------------------------------------------------------
Moody's Investors Service has downgraded the rating of Cl. M-3 from
Securitized Asset Backed Receivables LLC Trust 2006-OP1.

Complete rating action is as follows:

Issuer: Securitized Asset Backed Receivables LLC Trust 2006-OP1

Cl. M-3, Downgraded to B1 (sf); previously on Jun 25, 2015 Upgraded
to Ba3 (sf)

RATINGS RATIONALE

The rating downgrade of Cl. M-3 is due to the outstanding interest
shortfalls on the bond which are not expected to be recouped. In
the transaction's waterfall structure, interest shortfalls are
reimbursed from excess interest only after the
overcollateralization has built to a pre-specified target amount.
Due to the transaction's performance and its level of
overcollateralization, the shortfalls are unlikely to be reimbursed
and could be permanent. The action also reflects the recent
performance of the underlying pools and Moody's updated loss
expectations on the pools.

The principal methodology used in this rating was "US RMBS
Surveillance Methodology" published in February 2019.

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

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 4.0% in January 2019 from 4.1% in
January 2018. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2019 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 2019. 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 this transaction.


SUDBURY MILL: Moody's Lowers Rating on Class E Notes to 'B1'
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by Sudbury Mill CLO Ltd.:

US$38,000,000 Class B-1-R Senior Floating Rate Notes due 2026,
Upgraded to Aaa (sf); previously on April 17, 2017 Assigned Aa1
(sf)

US$15,000,000 Class B-2-R Senior Fixed Rate Notes due 2026,
Upgraded to Aaa (sf); previously on April 17, 2017 Assigned Aa1
(sf)

Moody's also downgraded the rating on the following notes:

US$18,000,000 Class E Deferrable Mezzanine Floating Rate Notes due
2026, Downgraded to B1 (sf); previously on December 5, 2013
Definitive Rating Assigned Ba3 (sf)

Sudbury Mill CLO Ltd., issued in December 2013, is a collateralized
loan obligation (CLO) backed primarily by a portfolio of senior
secured loans. The transaction's reinvestment period ended in
January 2018.

RATINGS RATIONALE

The upgrade actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's
over-collateralization (OC) ratios since March 2018. The Class
A-1-R and A-2-R notes jointly have been paid down by approximately
26.4% or $66.0 million since that time. Based on the trustee's
February 2019 report, the OC ratio for the Class A/B notes is
reported at 135.46% versus March 2018 level of 128.70%.

On the other hand, the downgrade action on the Class E notes
reflects the weighted average spread (WAS) compression observed in
the underlying CLO portfolio. Based on the trustee's February 2019
report, WAS is reported at 3.29%, compared to 3.68% reported at the
deal's refinancing in April 17, 2017.

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 and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base case,
Moody's analyzed the collateral pool as having a performing par and
principal proceeds balance of $320.7 million, defaulted par of $2.2
million, a weighted average default probability of 22.00% (implying
a WARF of 3097), a weighted average recovery rate upon default of
47.94%, a diversity score of 63 and a weighted average spread of
3.29% (before accounting for LIBOR floors).

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 on the notes issued by Sudbury Mill 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 Rating on notes issued by Sudbury Mill CLO Ltd.

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

This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings:

1) Macroeconomic uncertainty: CLO performance is subject to
uncertainty about credit conditions in the general economy.

2) Collateral Manager: Performance can also be affected positively
or negatively by a) the manager's investment strategy and behavior
and b) differences in the legal interpretation of CLO documentation
by different transactional parties owing to embedded ambiguities.

3) Collateral credit risk: A shift towards collateral of better
credit quality, or better credit performance of assets
collateralizing the transaction than Moody's current expectations,
can lead to positive CLO performance. Conversely, a negative shift
in credit quality or performance of the collateral can have adverse
consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace. Deleveraging of the CLO
could accelerate owing to high prepayment levels in the loan market
and/or collateral sales by the manager, which could have a
significant impact on the notes' ratings. Note repayments that are
faster than Moody's current expectations will usually have a
positive impact on CLO notes, beginning with those with the highest
payment priority.

5) Recovery of defaulted assets: Fluctuations in the market value
of defaulted assets could result in volatility in the deal's
overcollateralization levels. Further, the timing of recovery
realization and whether the manager decides to work out or sell
defaulted assets create additional uncertainty. Realization of
recoveries that are either materially higher or lower than assumed
in Moody's analysis would impact the CLO positively or negatively,
respectively.

6) Post-Reinvestment Period Trading: Subject to certain
requirements, the deal can reinvest certain proceeds after the end
of the reinvestment period, and as such the manager has the ability
to erode some of the collateral quality metrics to the covenant
levels. Such reinvestment could affect the transaction either
positively or negatively.

7) Weighted Average Spread (WAS): CLO performance can be sensitive
to WAS, which is a key factor driving the amount of excess spread
available as credit enhancement when a deal fails its
over-collateralization or interest coverage tests. A decrease in
excess spread, including as a result of losing the net interest
benefit of LIBOR floors, or because market conditions make it
difficult for the deal to source assets of appropriate credit
quality in order to maintain its WAS target, would reduce the
effective credit enhancement available for the notes.



TERWIN MORTGAGE 2005-3SL: Moody's Hikes B-1 Debt Rating to Caa3
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of five tranches
from four transactions, backed by Second Lien loans, issued by
multiple issuers.

Complete rating actions are as follows:

Issuer: Morgan Stanley Mortgage Loan Trust 2005-8SL

Cl. A-1, Upgraded to Baa2 (sf); previously on May 16, 2018 Upgraded
to Ba2 (sf)

Cl. A-2b, Upgraded to Baa2 (sf); previously on May 16, 2018
Upgraded to Ba2 (sf)

Issuer: SunTrust Acquisition Closed-End Seconds Trust, Series
2007-1

Cl. A, Upgraded to Baa3 (sf); previously on May 16, 2018 Upgraded
to Ba3 (sf)

Issuer: Terwin Mortgage Trust 2005-1SL

Cl. B-1, Upgraded to Caa3 (sf); previously on Oct 30, 2008
Downgraded to C (sf)

Issuer: Terwin Mortgage Trust 2005-3SL

Cl. M-2, Upgraded to Caa1 (sf); previously on May 18, 2018 Upgraded
to Caa2 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance and Moody's
updated loss expectations on the underlying pools. The ratings
upgraded are primarily due to an improvement in the underlying
pools' performance and an increase in credit enhancement available
to the bonds.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in February 2019.

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 3.8% in February 2019 from 4.1% in
February 2018. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2019 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 2019. 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.


TOWD POINT 2019-SJ2: Fitch to Rate $45.62MM Class B2 Notes 'Bsf'
----------------------------------------------------------------
Fitch Ratings expects to assign the following ratings and Rating
Outlooks to Towd Point Mortgage Trust 2019-SJ2 (TPMT 2019-SJ2):

  -- $546,390,000 class A1 notes 'AAAsf'; Outlook Stable;

  -- $81,469,000 class A2 notes 'AAsf'; Outlook Stable;

  -- $76,039,000 class M1 notes 'Asf'; Outlook Stable;

  -- $72,779,000 class M2 notes 'BBBsf'; Outlook Stable;

  -- $58,658,000 class B1 notes 'BBsf'; Outlook Stable;

  -- $45,624,000 class B2 notes 'Bsf'; Outlook Stable;

  -- $627,859,000 class A3 exchangeable notes 'AAsf'; Outlook
Stable;

  -- $703,898,000 class A4 exchangeable notes 'Asf'; Outlook
Stable;

  -- $776,677,000 class A5 exchangeable notes 'BBBsf'; Outlook
Stable.

Fitch will not be rating the following classes:

  -- $59,744,000 class B3 notes;

  -- $58,658,000 class B4 notes;

  -- $86,901,656 class B5 notes;

  -- $1,086,262,656 class A6 exchangeable notes;

  -- $54,400,000 class XA notes.

The notes are supported by one collateral group that consists of
26,869 seasoned performing and re-performing mortgages with a total
balance of approximately $1.09 billion, which includes $5.2
million, or 0.5%, of the aggregate pool balance in
non-interest-bearing deferred principal amounts, as of the
statistical calculation date.

KEY RATING DRIVERS

Closed-End Second Liens (Negative): The collateral pool consists of
100% closed-end, second lien, seasoned performing loans and
re-performing loans (RPLs) with a weighted average (WA) model
credit score of 706.8, sustainable loan to value ratio (sLTV) of
83.5%, 65.5% 36 months of clean pay history (under the MBA method)
and seasoning of approximately 147 months. Fitch assumes 100% loss
severity (LS) on all defaulted second lien loans. Fitch assumes
second lien loans default at a rate comparable to first lien loans,
after controlling for credit attributes, no additional default
penalty was applied.

Re-Performing Loans (Negative): No loans were delinquent as of the
statistical calculation date, and 73.8% of the pool have been
"current" for over two years. 26.2% of loans are current but have
recent delinquencies or incomplete pay strings. Of the total pool,
23.5% have received modifications. The average time since loan
modification is approximately 58 months.

Sequential-Pay Structure With Higher CE (Positive): The
transaction's cash flow is based on a sequential-pay structure
whereby the subordinate classes do not receive principal until the
senior classes are repaid in full. Losses are allocated in
reverse-sequential order. Furthermore, a provision to re-allocate
principal to pay interest on the 'AAAsf' and 'AAsf' rated notes
prior to other principal distributions is supportive of timely
interest payments to those classes. Notably, the bonds benefit from
credit enhancement (CE) 100-200 basis points (bps) above the
minimum needed for each respective rating category. While the
additional CE is not enough to warrant a higher initial rating, it
will provide added protection against downgrades and losses for
investors.

Realized Loss and Writedown Feature (Positive): Loans that are
delinquent for 150 days or more under the OTS method will be
considered a realized loss and, therefore, will cause the most
subordinated class to be written down. Despite the 100% LS assumed
for each defaulted loan, Fitch views the writedown feature
positively as cash flows will not be needed to pay timely interest
to the 'AAAsf' and 'AAsf' notes during loan resolution by the
servicers. In addition, subsequent recoveries realized after the
writedown at 150 days delinquent will be passed on to bondholders
as principal.

Moderate Operational Risk (Negative): Operational risk is
considered to be moderate for this transaction since not all loans
were subject to a due diligence review by a third party review
(TPR) firm. Approximately 35% of loans by UPB (22% by loan count)
were reviewed. The due diligence was performed by Tier 1 TPR firms
and the results were consistent with the sponsor's prior
transactions. FirstKey Mortgage, LLC (FirstKey) has a
well-established track record as an aggregator of seasoned
performing and RPL mortgages and has an 'Average' aggregator
assessment from Fitch. Most of the loans were originated by two
large bank sellers, and the sponsor's (or its affiliate's)
retention of at least 5% of the bonds should help mitigate the
operational risk of the transaction.

Low Aggregate Servicing Fee (Negative): Fitch determined that the
initial servicing fee of 32 bps may be insufficient to attract
subsequent servicers under a period of poor performance and high
delinquencies. In the event that a successor servicer is appointed,
the servicing fee can be increased to an amount greater than the
cap. To reflect the risk of an increased servicing fee, Fitch
assumed a 75-bp servicing fee in its cash flow analysis to test the
adequacy of CE and excess spread.

Third-Party Due Diligence (Neutral): A third-party due diligence
sample review of 22% by loan count and 35% by unpaid principal
balance (UPB) was conducted and focused on regulatory compliance,
pay history (Clayton and AMC, both assessed by Fitch as Tier 1
third-party review firms) and a tax and title lien search (WestCor
and AMC). The diligence findings and lack of 100% tax and title
review did not result in an additional adjustment due to the 100%
LS assumption applied by Fitch.

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement (RW&E) mechanism construct
for this transaction to generally be consistent with what it views
as a Tier 2 framework, due to the inclusion of knowledge qualifiers
and the exclusion of certain reps that Fitch typically expects for
RPL transactions. After a threshold event (which occurs when
realized loss exceeds the class principal balance of the B3, B4 and
B5 notes), loan reviews for identifying breaches will be conducted
on loans that experience a realized loss of $10,000 or more. To
account for the Tier 2 framework, Fitch increased its 'AAAsf' loss
expectations by roughly 346 bps to account for a potential increase
in defaults and losses arising from weaknesses in the reps.

Limited Life of Rep Provider (Negative): FirstKey, as rep provider,
will only be obligated to repurchase a loan due to breaches prior
to the payment date in April 2020. Thereafter, a reserve fund will
be available to cover amounts due to noteholders for loans
identified as having rep breaches. Amounts on deposit in the
reserve fund, as well as the increased level of subordination, will
be available to cover additional defaults and losses resulting from
rep weaknesses or breaches occurring on or after the payment date
in April 2020.

Deferred Amounts (Negative): Non-interest-bearing principal
forbearance amounts totaling $5.2 million (0.5%) of the UPB are
outstanding on 762 loans. Fitch included the deferred amounts when
calculating the borrower's loan to value ratio (LTV) and sLTV,
despite the lower payment and amounts not being owed during the
term of the loan. The inclusion resulted in a higher probability of
default (PD) than if there were no deferrals. Because deferred
amounts are due and payable by the borrower at maturity, Fitch
believes that borrower default behavior for these loans will
resemble that of the higher LTVs, as exit strategies (that is, sale
or refinancing) will be limited relative to those borrowers with
more equity in the property.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines (MVDs)
than assumed at both the metropolitan statistical area (MSA) and
national levels. 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 be
considered in the surveillance of the transaction.

Fitch conducted sensitivity analysis determining 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 38.1% at 'AAAsf'. The analysis indicates there is
some potential rating migration with higher MVDs, compared with the
model projection.

Fitch also conducted sensitivity analysis 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 WestCor Land Title Insurance Company (WestCor), Clayton
Services LLC and AMC Diligence, LLC (AMC). The third-party due
diligence described in Form 15E focused on regulatory compliance,
pay history, servicing comments, the presence of key documents in
the loan file and data integrity. In addition, AMC and Westcor were
retained to perform an updated title and tax search, as well as a
review to confirm that the mortgages were recorded in the relevant
local jurisdiction and the related assignment chains. A regulatory
compliance and data integrity review was completed on 34.6% of the
pool by balance.

611 of the reviewed loans received either a 'C' or 'D' grade. For
357 of these loans, this was due to missing documents that
prevented testing for predatory lending compliance. The inability
to test for predatory lending may expose the trust to potential
assignee liability, which creates added risk for bond investors.
Typically, Fitch makes an LS adjustment to account for this;
however, all loans in the pool are already receiving 100% LS;
therefore, no adjustments were made. Reasons for the remaining 254
'C' and 'D' grades include missing final HUD1s that are not subject
to predatory lending, missing state disclosures and other
compliance-related documents. Fitch believes these issues do not
add material risk to bondholders, since the statute of limitations
has expired. No adjustment to loss expectations were made for any
of the 611 loans that received either a 'C' or 'D' grade.

CRITERIA VARIATION

Fitch's analysis incorporated two criteria variations from the
"U.S. RMBS Seasoned, Re-Performing and Non-Performing Loan Rating
Criteria" and one variation from the "U.S. RMBS Loan Loss Model
Criteria." The first variation relates to the tax/title review. An
updated tax/title review was not completed on 21,614 loans. While a
tax/title review was not completed, Fitch's analysis already
assumed that these loans were not in first-lien position, and Fitch
assumes 100% LS for all second liens. There was no rating impact
due to this variation.

The second variation is that a due diligence compliance and data
integrity review was not completed on 20,992 loans. Fitch's model
assumes 100% LS for all second liens and therefore no additional
adjustment was made to Fitch's expected losses. There was no rating
impact from application of this variation.


TRUPS FINANCIALS 2019-1: Moody's Rates Class B Notes 'Ba2'
----------------------------------------------------------
Moody's Investors Service has assigned ratings to three classes of
notes issued by TruPS Financials Note Securitization 2019-1 Ltd.

Moody's rating action is as follows:

US$188,300,000 Class A-1 Senior Secured Floating Rate Notes due
2039 (the "Class A-1 Notes"), Definitive Rating Assigned Aa2 (sf)

US$24,300,000 Class A-2 Mezzanine Deferrable Floating Rate Notes
due 2039 (the "Class A-2 Notes"), Definitive Rating Assigned A3
(sf)

US$44,800,000 Class B Mezzanine Deferrable Floating Rate Notes due
2039 (the "Class B Notes"), Definitive Rating Assigned Ba2 (sf)

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

RATINGS RATIONALE

TFINS 2019-1 is a static cash flow CDO. The issued notes will be
collateralized primarily by a portfolio of (1) trust preferred
securities ("TruPS") issued by US community banks and their holding
companies and (2) TruPS, senior notes and surplus notes issued by
insurance companies and their holding companies. The portfolio is
100% ramped as of the closing date.

EJF CDO Manager LLC, an affiliate of EJF Capital LLC, will direct
the selection, acquisition and disposition of the assets on behalf
of the Issuer. The Manager will direct the disposition of any
defaulted securities or credit risk securities. The transaction
prohibits any asset purchases or substitutions at any time.

In addition to the Rated Notes, the Issuer issued one class of
preferred shares.

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. The transaction also includes an
interest diversion feature beginning on the February 2027 payment
date whereby 60% of the interest at a junior step in the priority
of interest payments is used to pay the principal on the Class A-1
Notes until the Class A-1 Notes' principal has been paid in full.

The portfolio of this CDO consists of (1) TruPS issued by 32 US
community banks, (2) TruPS and surplus notes issued by 19 insurance
companies and (3) a surplus note-backed trust certificate issued by
an irrevocable trust, the majority of which Moody's does not rate.
Moody's assesses the default probability of bank obligors that do
not have public ratings through credit scores derived using
RiskCalc, an econometric model developed by Moody's Analytics.
Moody's evaluation of the credit risk of the bank obligors in the
pool relies on FDIC Q2-2018 financial data. Moody's assesses the
default probability of insurance company obligors that do not have
public ratings through credit assessments provided by its insurance
ratings team based on the credit analysis of the underlying
insurance companies' annual statutory financial reports. Moody's
assumes a fixed recovery rate of 10% for both the bank and
insurance obligations.

Moody's ratings on the Rated Notes took into account a stress
scenario for highly levered bank holding company issuers. The
transaction's portfolio includes subordinated debt issued by a
number of bank holding companies with significant amounts of other
debt on their balance sheet which may increase the risk presented
by their subsidiaries. To address the risk from higher debt burden
at the bank holding companies, Moody's conducted a stress scenario
in which it made adjustments to the RiskCalc credit scores for
these highly leveraged holding companies. This stress scenario was
an important consideration in the assigned ratings.

In addition, Moody's analysis considered the concentrated nature of
the portfolio. There are 11 issuers that each constitute
approximately 2.8% to 2.9% of the portfolio par. Moody's ran a
stress scenario in which it assumed a two notch downgrade for up to
30% of the portfolio par.

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

Par amount: $312,104,883

Weighted Average Rating Factor (WARF): 744

Weighted Average Spread (WAS): 3.19%

Weighted Average Coupon (WAC): 6.96%

Weighted Average Recovery Rate (WARR): 10.0%

Weighted Average Life (WAL): 10.6 years

In addition to the quantitative factors that Moody's explicitly
models, qualitative factors were part of the rating committee
consideration. Moody's considers the structural protections in the
transaction, the risk of an event of default, the legal environment
and specific documentation features. All information available to
rating committees, including macroeconomic forecasts, inputs from
other Moody's analytical groups, market factors, and judgments
regarding the nature and severity of credit stress on the
transaction, influenced the final rating decision.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's
Approach to Rating TruPS CDOs" published in October 2016.

The Credit Ratings for TruPS Financials Note Securitization 2019-1
Ltd were assigned in accordance with Moody's existing Methodology
entitled "Moody's Approach to Rating TruPS CDOs," dated October 7,
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 TruPS CDOs. If the
revised Methodology is implemented as proposed, Moody's does not
expect the changes to affect the Credit Ratings on TruPS Financials
Note Securitization 2019-1 Ltd.

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

This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings:

1) Macroeconomic uncertainty: The transaction's performance could
be negatively affected by uncertainty about credit conditions in
the general economy. Moody's currently has a stable outlook on the
US banking sector and the US P&C insurance sector.

2) Portfolio credit risk: Credit performance of the assets
collateralizing the transaction that is better than Moody's current
expectations could have a positive impact on the transaction's
performance. Conversely, asset credit performance weaker than
Moody's current expectations could have adverse consequences on the
transaction's performance.

3) Deleveraging: One source of uncertainty in this transaction is
whether deleveraging from unscheduled principal proceeds due to
redemptions will occur and at what pace. Note repayments that are
faster than Moody's current expectations could have an impact on
the notes' ratings.

4) Exposure to non-publicly rated assets: The portfolio consists
primarily of unrated assets whose default probability Moody's
assesses through credit scores derived using RiskCalc or credit
assessments. Because these are not public ratings, they are subject
to additional estimation uncertainty.

Moody's obtained a loss distribution for this CDO's portfolio by
simulating defaults using Moody's CDOROM, which used Moody's
assumptions for asset correlations and fixed recoveries in a Monte
Carlo simulation framework. Moody's then used the resulting loss
distribution, together with structural features of the CDO, as an
input in its CDOEdge cash flow model.


WELLS FARGO 2019-C49: DBRS Finalizes BB Rating on Class G-RR Certs
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2019-C49 issued by Wells Fargo Commercial Mortgage Trust 2019-C49:

-- Class A-1 at AAA (sf)
-- 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 X-A at AAA (sf)
-- Class A-S at AAA (sf)
-- Class B at AA (sf)
-- Class X-B at A (high) (sf)
-- Class C at A (sf)
-- Class X-D at A (low) (sf)
-- Class D at BBB (high) (sf)
-- Class E-RR at BBB (low) (sf)
-- Class F-RR at BB (high) (sf)
-- Class G-RR at BB (sf)
-- Class H-RR at B (high) (sf)
-- Class J-RR at B (low) (sf)

All trends are Stable. Classes X-D, D, E-RR, F-RR, G-RR, H-RR, and
J-RR have been privately placed. The Class X-A, X-B, and X-D
balances are notional.

The collateral consists of 64 fixed-rate loans secured by 71
commercial and multifamily properties. The transaction is a
sequential-pay pass-through structure. The conduit pool was
analyzed to determine the provisional ratings, reflecting the
long-term probability of loan default within the term and its
liquidity at maturity. When the cut-off loan balances were measured
against the DBRS Stabilized net cash flow (NCF), six loans,
representing a combined 7.9% of the aggregate pool balance,
exhibited a DBRS Term debt service coverage ratio (DSCR) at or
below 1.15 times (x), a threshold indicative of a higher likelihood
of mid-term default. To assess refinance risk given the current
low-interest rate environment, DBRS applied its refinance constants
to the balloon amounts. This resulted in 36 loans, representing a
combined 57.4% of the aggregate pool balance, exhibiting a DBRS
Refi DSCR at or below 1.00x and 21 loans, representing 35.8% of the
pool, having a DBRS Refi DSCR below 0.90x. These credit metrics are
based on whole loan balances.

Only ten loans representing 8.9% of the aggregate pool balance are
secured by properties that are either fully or partially leased to
a single tenant. No individual single-tenant property accounts for
more than 1.9% of the aggregate pool balance and the largest
single-tenant property by a proportion of pool balance (Tristone
Flowtech USA) was sampled by DBRS. Loans secured by properties
occupied by single tenants have been found to suffer higher loss
severities in an event of default.

Term default risk is low, as evidenced by a relatively strong DBRS
Term DSCR of 1.56x. When the cut-off balances were measured against
the DBRS Stabilized NCF, 15 loans, representing 29.0% of the
aggregate pool balance, exhibited a favorable DBRS Term DSCR equal
to or greater than 1.75x. Excluding hospitality properties, 12
loans, representing 19.5% of the aggregate pool balance, exhibited
a favorable DBRS Term DSCR of 1.75x or above.

The pool is also relatively diverse based on loan size, as the
64-loan pool has a concentration profile similar to a pool of 32
equally sized loans. The ten largest loans represent a combined
46.0% of the pool by allocated loan balance and the three largest
loans represent 20.5% of the allocated loan balance. Excluding the
top four loans, which represent a combined 25.7% of the pool, no
single loan accounts for more than 4.6% of the pool by allocated
loan balance.

The pool has a relatively high concentration of loans secured by
non-traditional property types such as self-storage, hospitality
and manufactured housing community (MHC) assets, which, on a
combined basis, represent 34.5% of the pool by allocated loan
balance across 23 loans. There are eight loans, representing a
combined 21.9% of the pool by allocated loan balance, secured by
hospitality properties; eight loans, representing a combined 8.8%
of the pool by allocated loan balance, secured by self-storage
properties; and seven loans, representing a combined 3.9% of the
pool by allocated loan balance, secured by MHC properties. These
assets are vulnerable to higher NCF volatility due to the
relatively short-term nature of their respective leases compared
with other commercial properties, which can cause NCF to
deteriorate quickly in a declining market. Hospitality properties
account for the second-largest property concentration in the pool.
Eleven of these loans, representing 51.6% of all non-traditional
property types in the pool by allocated loan balance, are
structured without interest-only (IO) periods and benefit from
full-term amortization. While not historically considered core
property types, commercial mortgage-backed security (CMBS) loans
secured by MHC and self-storage properties have performed better
than other property types over the past two decades.

Seven loans, representing a combined 51.7% of the pool by allocated
loan balance, are structured with full-term IO periods. An
additional 20 loans, representing 23.8% of the pool by allocated
loan balance, are structured with partial IO terms ranging from 12
to 60 months. Of the 47 loans structured with either full or
partial-term IO, seven loans, representing 15.1% of the pool and
20.0% of the IO concentration, are located in either urban or super
dense urban markets with strong investor demand. Expected
amortization for the pool is 7.6%, which is generally in line with
recent conduit securitizations. Additionally, 17 loans,
representing 24.5% of the pool by allocated loan balance, are
scheduled to amortize by 15.0% or more.

The weighted-average DBRS Refi DSCR of 0.99x is indicative of
significant refinance risk at the overall pool level. Fifteen
loans, representing 28.7% of the pool by allocated loan balance,
exhibit DBRS Refi DSCRs of 0.85x or less. Of the 15 loans
exhibiting a DBRS Refi DSCR of 0.85x or less, nine loans,
representing 16.0% of the pool and 55.7% of the identified
concentration, are structured with going-in loan-to-value ratios of
less than 65.0%. Many of these loans are located in primary markets
with low cap rates, which depress traditional credit metrics.

Classes X-A, X-B, and X-D are 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.

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


[*] DBRS Reviews 605 Classes From 36 US RMBS Transactions
---------------------------------------------------------
DBRS, Inc. reviewed 605 classes from 36 U.S. residential
mortgage-backed security (RMBS) transactions. Of the 605 classes
reviewed, DBRS upgraded 12 ratings, confirmed 590 ratings and
discontinued three ratings.

The rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new rating levels. For transactions where the ratings have
been confirmed, current asset performance and credit-support levels
are consistent with the current ratings. The discontinued ratings
are the result of full repayment of principal to bondholders.

The rating actions are a result of DBRS's application of the "RMBS
Insight 1.3: U.S. Residential Mortgage-Backed Securities Model and
Rating Methodology" published in September 2018.

The pools backing these RMBS transactions consist of prime,
subprime, Alt-A, option adjustable-rate mortgage, second lien and
agency reperforming collateral.

The ratings assigned to the securities below differ from the
ratings implied by the quantitative model. DBRS considers this
difference to be a material deviation, but in this case, the
ratings of the subject notes reflect actual deal or tranche
performance that is not fully reflected in the projected cash flows
or model output.

-- Aegis Asset Backed Securities Trust 2005-3, Mortgage-Backed
Notes, Series 2005-3, Class M2

-- Asset Backed Funding Corporation Series 2004-OPT5, ABFC
Asset-Backed Certificates, Series 2004-OPT5, Class M-1

-- Asset Backed Funding Corporation Series 2004-OPT5, ABFC
Asset-Backed Certificates, Series 2004-OPT5, Class M-2

-- Asset Backed Securities Corporation Home Equity Loan Trust,
Series NC 2006-HE2, Asset-Backed Pass-Through Certificates, Series
NC 2006-HE2, Class A1

-- Asset Backed Securities Corporation Home Equity Loan Trust,
Series NC 2006-HE4, Asset-Backed Pass-Through Certificates, Series
NC 2006-HE4, Class A5

-- Asset Backed Securities Corporation Home Equity Loan Trust,
Series NC 2006-HE4, Asset-Backed Pass-Through Certificates, Series
NC 2006-HE4, Class A6

-- Accredited Mortgage Loan Trust 2005-4, Asset-Backed Notes,
Series 2005-4, Class M-1

-- Accredited Mortgage Loan Trust 2005-4, Asset-Backed Notes,
Series 2005-4, Class M-2

-- ACE Securities Corp. Home Equity Loan Trust, Series 2006-ASAP1,
Asset-Backed Pass-Through Certificates, Series 2006-ASAP1, Class
M-1

-- ACE Securities Corp. Home Equity Loan Trust, Series 2006-HE2,
Asset-Backed Pass-Through Certificates, Series 2006-HE2, Class A-1

-- Carrington Mortgage Loan Trust, Series 2007-HE1, Asset-Backed
Pass-Through Certificates, Series 2007-HE1, Class A-2

-- Carrington Mortgage Loan Trust, Series 2007-HE1, Asset-Backed
Pass-Through Certificates, Series 2007-HE1, Class A-3

-- Citigroup Mortgage Loan Trust 2006-HE2, Asset-Backed
Pass-Through Certificates, Series 2006-HE2, Class M-1

-- CWABS Asset-Backed Certificates Trust 2006-SPS1, Asset-Backed
Certificates, Series 2006-SPS1, Class A

-- Freddie Mac Seasoned Credit Risk Transfer Trust, Series 2018-1,
Series 2018-1, Class M

The Affected Ratings are available at https://bit.ly/2SYFkb1


[*] Moody's Hikes $1.7BB of GSE CRT RMBS Issued 2015 to 2017
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 29 tranches
from 3 Agency Risk Transfer transactions issued from 2015 to 2017.

Structured Agency Credit Risk (STACR) Debt Notes, Series 2015-DNA1,
Structured Agency Credit Risk (STACR) Debt Notes, Series 2016-DNA2
and Structured Agency Credit Risk (STACR) Debt Notes, Series
2017-HQA1 are actual-loss credit risk transfer (CRT) transactions.
Furthermore, STACR 2017-HQA1 is a high-LTV transaction which
benefits from mortgage insurance (MI).

Complete rating actions are as follows:

Issuer: STACR 2017-HQA1

Cl. M-1, Upgraded to A3 (sf); previously on May 11, 2018 Upgraded
to Baa2 (sf)

Cl. M-2, Upgraded to Ba2 (sf); previously on May 11, 2018 Upgraded
to B1 (sf)

Cl. M-2A, Upgraded to Baa3 (sf); previously on May 11, 2018
Upgraded to Ba1 (sf)

Cl. M-2AR, Upgraded to Baa3 (sf); previously on May 11, 2018
Upgraded to Ba1 (sf)

Cl. M-2AS, Upgraded to Baa3 (sf); previously on May 11, 2018
Upgraded to Ba1 (sf)

Cl. M-2AT, Upgraded to Baa3 (sf); previously on May 11, 2018
Upgraded to Ba1 (sf)

Cl. M-2AU, Upgraded to Baa3 (sf); previously on May 11, 2018
Upgraded to Ba1 (sf)

Cl. M-2AI*, Upgraded to Baa3 (sf); previously on May 11, 2018
Upgraded to Ba1 (sf)

Cl. M-2R, Upgraded to Ba2 (sf); previously on May 11, 2018 Upgraded
to B1 (sf)

Cl. M-2S, Upgraded to Ba2 (sf); previously on May 11, 2018 Upgraded
to B1 (sf)

Cl. M-2T, Upgraded to Ba2 (sf); previously on May 11, 2018 Upgraded
to B1 (sf)

Cl. M-2U, Upgraded to Ba2 (sf); previously on May 11, 2018 Upgraded
to B1 (sf)

Cl. M-2I*, Upgraded to Ba2 (sf); previously on May 11, 2018
Upgraded to B1 (sf)

Issuer: Structured Agency Credit Risk (STACR) Debt Notes, Series
2015-DNA1

Cl. MA, Upgraded to Aa3 (sf); previously on May 11, 2018 Upgraded
to A2 (sf)

Cl. M-2, Upgraded to Aa1 (sf); previously on May 11, 2018 Upgraded
to Aa2 (sf)

Cl. M-2F, Upgraded to Aa1 (sf); previously on May 11, 2018 Upgraded
to Aa2 (sf)

Cl. M-2I*, Upgraded to Aa1 (sf); previously on May 11, 2018
Upgraded to Aa2 (sf)

Cl. M-3, Upgraded to Aa3 (sf); previously on May 11, 2018 Upgraded
to A3 (sf)

Cl. M-3F, Upgraded to Aa3 (sf); previously on May 11, 2018 Upgraded
to A3 (sf)

Cl. M-3I*, Upgraded to Aa3 (sf); previously on May 11, 2018
Upgraded to A3 (sf)

Cl. M-12, Upgraded to Aa1 (sf); previously on May 11, 2018 Upgraded
to Aa2 (sf)

Issuer: Structured Agency Credit Risk (STACR) Debt Notes, Series
2016-DNA2

Cl. M-2, Upgraded to Aa1 (sf); previously on May 11, 2018 Upgraded
to A1 (sf)

Cl. M-2I*, Upgraded to Aa1 (sf); previously on May 11, 2018
Upgraded to A1 (sf)

Cl. M-2F, Upgraded to Aa1 (sf); previously on May 11, 2018 Upgraded
to A1 (sf)

Cl. M-3, Upgraded to Baa2 (sf); previously on May 11, 2018 Upgraded
to Baa3 (sf)

Cl. M-3A, Upgraded to A2 (sf); previously on May 11, 2018 Upgraded
to Baa1 (sf)

Cl. M-3AI*, Upgraded to A2 (sf); previously on May 11, 2018
Upgraded to Baa1 (sf)

Cl. M-3AF, Upgraded to A2 (sf); previously on May 11, 2018 Upgraded
to Baa1 (sf)

Cl. M-3B, Upgraded to Baa3 (sf); previously on May 11, 2018
Upgraded to Ba1 (sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

The rating upgrades are due to an increase in credit enhancement
available to the bonds and a reduction in the expected losses on
the underlying pools owing to strong collateral performance. The
outstanding rated bonds have continued to benefit from a steady
increase in credit enhancement as a result of sequential principal
distributions among the subordinate bonds. The actions reflect the
recent strong performance of the underlying pools with minimal, if
any, serious delinquencies to date. As of February 2019, the
percentage of loans 60 days or more delinquent as a percentage of
original balance was 0.09% for STACR 2015-DNA1, .23% for STACR
2016-DNA2 and .40% STACR 2017-HQA1. Additionally, there are very
limited cumulative net losses on all transactions. Although
prepayments have slowed down in recent months, with three month
average conditional prepayment rates (CPR) in the 6-10% range for
all transactions as of February 2019, the transactions have
benefitted from high prepayments historically.

These risk transfer transactions provide credit protection against
the performance of "reference pools" of mortgages guaranteed by
Freddie Mac. The notes are direct, unsecured obligations of Freddie
Mac and are not guaranteed by nor are they obligations of the
United States Government. Unlike a typical RMBS transaction, note
holders are not entitled to receive any cash from the mortgage
loans in the reference pools. Instead, the timing and amount of
principal and interest that Freddie Mac is obligated to pay on the
Notes is linked to the performance of the mortgage loans in the
reference pool. Principal payments to the notes relate only to
actual principal received from the reference pool with pro-rata
payments between senior and subordinate bonds, provided some
performance triggers are met, and sequential among subordinate
bonds.

The principal methodology used in rating all deals except
interest-only classes was "Moody's Approach to Rating US Prime
RMBS" published in November 2018. The methodologies used in rating
interest-only classes were "Moody's Approach to Rating US Prime
RMBS" published in November 2018 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's original expectations
as a result of a higher number of obligor defaults or deterioration
in the value of the mortgaged property securing an obligor's
promise of payment. Transaction performance also depends greatly on
the US macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of loss could drive
the ratings up. Losses could decline from Moody's original
expectations as a result of a lower number of obligor defaults or
appreciation in the value of the mortgaged property securing an
obligor's promise of payment. Transaction performance also depends
greatly on the US macro-economy and housing market.

Finally, performances 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.

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.


                            *********

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
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
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
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

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
the e-mail address to which your TCR is delivered to login.

                            *********

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.
Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Valerie Udtuhan, Howard C. Tolentino, Carmel Paderog,
Meriam Fernandez, Joel Anthony G. Lopez, Cecil R. Villacampa,
Sheryl Joy P. Olano, Psyche A. Castillon, Ivy B. Magdadaro, Carlo
Fernandez, Christopher G. Patalinghug, and Peter A. Chapman,
Editors.

Copyright 2019.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $975 for 6 months delivered via
e-mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Peter A.
Chapman at 215-945-7000.

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