/raid1/www/Hosts/bankrupt/TCR_Public/190505.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, May 5, 2019, Vol. 23, No. 124

                            Headlines

BICENTENNIAL TRUST 2017-1: DBRS Confirms B Rating on Class G Certs
CBAM LTD 2019-10: Moody's Rates $25.5MM Class E Notes 'Ba3'
CF 2019-CF1: S&P Assigns B- Rating to Two Classes of Certificates
CF MORTGAGE 2019-CF1: Fitch Assigns 'B-' Ratings on 2 Tranches
CHASE HOME 2019-ATR1: Fitch Rates $1.102MM Class B-5 Certs 'B+sf'

CHASE HOME 2019-ATR1: Moody's Rates Class B-5 Debt 'B3'
CHURCHILL MIDDLE: DBRS Hikes Rating on Class D Loans/Notes to BB
CITIGROUP MORTGAGE 2019-RP1: DBRS Gives (P)B Rating on B-2 Notes
CITIGROUP MORTGAGE 2019-RP1: Moody's Rates Class B-3 Debt 'C'
COMM MORTGAGE 2015-CCRE26: Fitch Affirms BB- on $13.6MM F Certs

DBWF MORTGAGE 2018-AMXP: Moody's Affirms Ba1 Rating on HRR Certs
DIAMOND CLO 2019-1: S&P Rates Class E Notes 'BB- (sf)'
DRYDEN 72 CLO: S&P Assigns Prelim BB- (sf) Rating to Class E Notes
EXANTAS CAPITAL 2019-RSO7: DBRS Finalizes B(low) Rating on F Certs
FINANCE OF AMERICA 2019-HB1: Moody's Rates Class M4 Debt 'B3'

FIRST FRANKLIN 2006-FFH1: Moody's Cuts Class M-1 Debt Rating to B1
FREDDIE MAC 2019-HQA2: S&P Assigns Ratings to 23 Classes of Notes
FREED ABS 2019-1: DBRS Gives Prov. BB(high) Rating on $56MM C Notes
J.P. MORGAN 2019-ICON: S&P Assigns Prelim B- Rating to Class F Cert
JP MORGAN 2006-LDP9: Moody's Cuts Class A-MS Certs Rating to 'B1'

JP MORGAN 2007-LDP10: Fitch Affirms Csf Rating on A-JFX Certs
JP MORGAN 2019-3: DBRS Gives Prov. B Rating on $775,000 B-5 Certs
JP MORGAN 2019-3: Moody's Assigns B3 Rating on Class B-5 Debt
KANYE CLO: Moody's Assigns Ba3 Rating on $16.95MM Class E Notes
MELLO WAREHOUSE 2019-1: Moody's Gives '(P)Ba2' Rating on E Debt

METLIFE SECURITIZATION 2019-1: DBRS Gives (P)B Rating on B2 Notes
METLIFE SECURITIZATION 2019-1: Fitch Rates $7.39MM B2 Notes 'Bsf'
PFP LTD 2019-5: DBRS Finalizes B(low) Rating on Class G Notes
PIKES PEAK 3: Moody's Rates $28.5MM Class E Notes 'Ba3'
REVELSTOKE CDO I: DBRS Confirms C Rating on 2 Note Classes

STEELE CREEK 2019-1: Moody's Rates $20MM Class E Notes 'Ba3'
TABERNA PREFERRED II: Moody's Hikes Ratings on 3 Tranches to Ba2
TOWD POINT 2015-4: Fitch Assigns 'Bsf' Rating on Class B-3 Notes
TOWD POINT 2015-6: Fitch Assigns 'Bsf' Rating on Class B-3 Notes
TOWD POINT 2016-5: Fitch Gives 'BBsf' Rating on Class B-3 Notes

TOWD POINT 2019-HY2: Moody's Assigns B1 Rating on Class B2 Notes
WFRBS COMMERCIAL 2013-UBS1: S&P Affirms B+ (sf) Rating on F Certs

                            *********

BICENTENNIAL TRUST 2017-1: DBRS Confirms B Rating on Class G Certs
------------------------------------------------------------------
DBRS Limited confirmed the ratings on the Mortgage Pass-Through
Certificates, Series 2017-1 issued by Bicentennial Trust as
follows:

-- Class A Certificates rated AAA (sf)
-- Class B Certificates rated AA (sf)
-- Class C Certificates rated A (sf)
-- Class D Certificates rated BBB (sf)
-- Class E Certificates rated BBB (low) (sf)
-- Class F Certificates rated BB (sf)
-- Class G Certificates rated B (sf)

The Class H Certificates and Class Z Certificates (collectively
with the Rated Certificates, the Certificates) are not rated by
DBRS.

The confirmation is part of DBRS's continued effort to provide
timely credit rating opinions and increased transparency to market
participants and is based on the following factors:

(1) The portfolio is a diversified pool of first-lien, fixed-rate,
conventional Canadian residential mortgages with a maximum
loan-to-value of 80% originated by Bank of Montreal (BMO). As of
March 2019, the pool balance amortized to approximately $1.03
billion. Current credit enhancement has been building since
issuance and continues to provide sufficient protection to the
Rated Certificates at their current rating levels. The portfolio
has performed well since inception, and the pass-through structure
of the Certificates has resulted in higher subordination across all
rated notes.

(2) Performance has been stable since issuance and as of March
2019, cumulative losses have remained less than one basis point.
Losses are allocated to the Notes in reverse order of their
priority payment. Year-to-date losses have been absorbed by the
non-rated Class Z Certificates.

(3) The performance history of the Seller and Administrator in the
residential mortgage market. BMO is rated AA (R-1 (high) with
Stable trends by DBRS as of June 22, 2018. BMO provides lifetime
representations and warranties.

DBRS monitors the performance of each transaction to identify any
deviation from DBRS's expectation at issuance and to ensure the
ratings remain appropriate. The review is predicated upon the
timely receipt of performance information from the related
providers.

Notes: All figures are in Canadian dollars unless otherwise noted.


CBAM LTD 2019-10: Moody's Rates $25.5MM Class E Notes 'Ba3'
-----------------------------------------------------------
Moody's Investors Service has assigned ratings to six classes of
notes issued by CBAM 2019-10, Ltd.

Moody's rating action is as follows:

  US$208,000,000 Class A-1A Floating Rate Notes due
  2032 (the "Class A-1A Notes"), Assigned Aaa (sf)

  US$40,000,000 Class A-1B Fixed Rate Notes due 2032
  (the "Class A-1B Notes"), Assigned Aaa (sf)

  US$39,500,000 Class B Floating Rate Notes due 2032
  (the "Class B Notes"), Assigned Aa2 (sf)

  US$20,500,000 Class C Deferrable Floating Rate Notes
  due 2032 (the "Class C Notes"), Assigned A2 (sf)

  US$25,750,000 Class D Deferrable Floating Rate Notes
  due 2032 (the "Class D Notes"), Assigned Baa3 (sf)

  US$25,500,000 Class E Deferrable Floating Rate Notes
  due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

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

RATINGS RATIONALE

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

CBAM 2019-10 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 up to 10.0% of the portfolio
may consist of second lien loans and senior unsecured loans. The
portfolio is approximately 90% ramped as of the closing date.

CBAM 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 five year reinvestment period. Thereafter, subject to
certain restrictions, the Manager may reinvest unscheduled
principal payments and proceeds from sales of credit risk assets.

In addition to the Rated Notes, the Issuer issued one class of
secured notes and one class of subordinated notes.

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in March 2019.

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

Par amount: $400,000,000

Diversity Score: 55

Weighted Average Rating Factor (WARF): 2850

Weighted Average Spread (WAS): 3.60%

Weighted Average Coupon (WAC): 7.00%

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 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.


CF 2019-CF1: S&P Assigns B- Rating to Two Classes of Certificates
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to CF 2019-CF1 Mortgage
Trust's commercial mortgage pass-through certificates.

The note issuance is a commercial mortgage-backed securities (CMBS)
transaction backed by 37 commercial mortgage loans with an
aggregate principal balance of $661.965 million ($757.965 million
including 65 Broadway trust subordinate companion loan; $586.667 of
offered certificates), secured by the fee and leasehold interests
in 60 properties across 25 states.

The ratings reflect:

-- The credit support provided by the transaction's structure;
-- S&P's view of the underlying collateral's economics;
-- The trustee-provided liquidity;
-- The collateral pool's relative diversity; and
-- S&P's overall qualitative assessment of the transaction.

RATINGS ASSIGNED
  CF 2019-CF1

  Class              Rating(i)       Amount (mil. $)
  A-1                AAA (sf)                  9.039
  A-2                AAA (sf)                 47.743
  A-SB               AAA (sf)                 18.934
  A-3                AAA (sf)                 50.595
  A-4                AAA (sf)                154.167
  A-5                AAA (sf)                182.898
  X-A                AAA (sf)           463.376(iii)
  X-B                NR                 123.291(iii)
  A-S                AA (sf)                  60.404
  B                  A (sf)                   32.271
  C                  NR                       30.616
  X-D(ii)            NR                  33.098(iii)
  X-F(ii)            NR                  13.239(iii)
  X-G(ii)            NR                   6.620(iii)
  D(ii)              NR                       19.031
  E(ii)              NR                       14.067
  F(ii)              NR                       13.239
  G(ii)              NR                        6.620
  NR-RR(ii)          NR                       22.341
  65A(iv)            A- (sf)                  15.698
  65B(iv)            BBB- (sf)                10.481
  65C(iv)            BB- (sf)                 14.240
  65D(iv)            B- (sf)                  13.784
  65E(iv)            NR                       35.597
  65RR(iv)           NR                        6.200
  65X1(iv)           BBB- (sf)                26.179(iii)
  65X2(iv)           B- (sf)                  28.024(iii)

(i)The certificates will be issued to qualified institutional
buyers according to Rule 144A of the Securities Act of 1933.
(ii)Non-offered certificates.
(iii)Notional balance.
(iv)Non-offered loan specific certificates tied to the 65 Broadway
trust subordinate companion loan.
NR--Not rated.


CF MORTGAGE 2019-CF1: Fitch Assigns 'B-' Ratings on 2 Tranches
--------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to CF 2019-CF1 Mortgage Trust commercial mortgage
pass-through certificates, series 2019-CF1:

  -- $9,039,000 class A-1 'AAAsf'; Outlook Stable;

  -- $47,743,000 class A-2 'AAAsf'; Outlook Stable;

  -- $18,934,000d class A-SB 'AAAsf'; Outlook Stable;

  -- $50,595,000d class A-3 'AAAsf'; Outlook Stable;

  -- $154,167,000 class A-4 'AAAsf'; Outlook Stable;

  -- $182,897,561 class A-5 'AAAsf'; Outlook Stable;

  -- $463,375,561a class X-A 'AAAsf'; Outlook Stable;

  -- $123,290,998a class X-B 'A-sf'; Outlook Stable;

  -- $60,404,315 class A-S 'AAAsf'; Outlook Stable;

  -- $32,270,798 class B 'AA-sf'; Outlook Stable;

  -- $30,615,885 class C 'A-sf'; Outlook Stable;

  -- $33,098,255ab class X-D 'BBB-sf'; Outlook Stable;

  -- $13,239,301ab class X-F 'BB-sf'; Outlook Stable;

  -- $6,619,651ab class X-G 'B-sf'; Outlook Stable;

  -- $19,031,496b class D 'BBBsf'; Outlook Stable;

  -- $14,066,759b class E 'BBB-sf'; Outlook Stable;

  -- $13,239,301b class F 'BB-sf'; Outlook Stable;

  -- $6,619,651b class G 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $22,341,322 class NR-RRbc.

  -- The transaction includes eight classes of non-offered,
     loan-specific certificates (non-pooled rake classes) related
     to the companion loan of 65 Broadway. Classes 65B-A, 65B-B,
     65B-C, 65B-D, 65B-E, 65B-HRR, 65B X-1, and 65B X-2 Interest
     are all not rated by Fitch.

(a) Notional amount and interest-only.

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

(c) Horizontal credit risk retention interest.

Since Fitch published its expected ratings on April 9, the
following changes occurred: the balanced for the A-4 and A-5
classes were finalized. At the time that the expected ratings were
assigned, the exact initial certificate balances of class A-4 and
class A-5 were unknown and expected to be within the range of
$78,000,000 - $154,167,000 and $182,897,561 - $259,064,561,
respectively. The final class balances for class A-4 and class A-5
are $154,167,000 and $182,897,561, respectively. The classes above
reflect the final ratings and deal structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 37 loans secured by 60
commercial properties having an aggregate principal balance of
$661,965,089 as of the cut-off date. The loans were contributed to
the trust by Cantor Commercial Real Estate Lending, L.P., KeyBank
National association, Starwood Mortgage Capital LLC, and CIBC,
Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 73.8% of the properties
by balance, cash flow analysis of 92.7% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Average Leverage Relative to Recent Transactions: The pool's Fitch
debt service coverage ratio (DSCR) of 1.17x is below average when
compared with the YTD 2019 average of 1.22x and the 2018 average of
1.22x. The pool's Fitch loan-to-value (LTV) of 98.6% is lower than
the YTD 2019 average of 103.4% and the 2018 average of 102.0%.

Investment-Grade Credit Opinion Loans: Four loans totaling 24.0% of
the pool have stand-alone investment-grade credit opinions. The
second largest loan, 3 Columbus Circle (7.6% of the pool), the
fourth largest loan, 65 Broadway, (6.0% of the pool), the sixth
largest loan, Fairfax Multifamily Portfolio (5.3% of the pool) and
the seventh largest loan, Amazon Distribution Livonia (5.1% of the
pool) all received a credit opinion of 'BBB-*sf' on a stand-alone
basis.

Highly Concentrated Pool: The pool has above average loan
concentration relative to other Fitch-rated transactions. The top
10 loans make up 56.3% of the pool, which exceeds the YTD 2019
average of 51.4% and the 2018 average of 50.6%.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow was 4.3% 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 CF
2019-CF1 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 'BBBsf'
could result.


CHASE HOME 2019-ATR1: Fitch Rates $1.102MM Class B-5 Certs 'B+sf'
-----------------------------------------------------------------
Fitch Ratings assigns ratings to Chase Home Lending Mortgage Trust
2019-ATR1 as follows:

  -- $414,110,000 class A-1 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $387,670,000 class A-2 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $348,903,000 class A-3 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $261,677,000 class A-4 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $87,226,000 class A-5 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $206,880,000 class A-6 certificates 'AAAsf'; Outlook Stable;

  -- $142,023,000 class A-7 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $54,797,000 class A-8 certificates 'AAAsf'; Outlook Stable;

  -- $68,887,000 class A-9 certificates 'AAAsf'; Outlook Stable;

  -- $18,339,000 class A-10 certificates 'AAAsf'; Outlook Stable;

  -- $38,767,000 class A-11 certificates 'AAAsf'; Outlook Stable;

  -- $38,767,000 class A-11-X notional certificates 'AAAsf';
Outlook Stable;

  -- $38,767,000 class A-12 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $38,767,000 class A-13 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $26,440,000 class A-14 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $26,440,000 class A-15 certificates 'AAAsf'; Outlook Stable;

  -- $372,699,000 class A-16 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $41,411,000 class A-17 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $414,110,000 class A-X-1 notional certificates 'AAAsf';
Outlook Stable;

  -- $414,110,000 class A-X-2 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $38,767,000 class A-X-3 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $26,440,000 class A-X-4 notional certificates 'AAAsf'; Outlook
Stable;

  -- $8,811,000 class B-1 certificates 'AAsf'; Outlook Stable;

  -- $7,489,000 class B-2 certificates 'A+sf'; Outlook Stable;

  -- $4,626,000 class B-3 certificates 'BBB+sf'; Outlook Stable;

  -- $2,863,000 class B-4 certificates 'BB+sf'; Outlook Stable;

  -- $1,102,000 class B-5 certificates 'B+sf'; Outlook Stable;

Fitch will not be rating the following class:

  -- $1,542,027 class B-6 certificates.

TRANSACTION SUMMARY

Fitch rates JPMorgan Chase Bank's first non-qualified mortgage
residential mortgage-backed transaction, Chase Home Lending
Mortgage Trust 2019-ATR1. The certificates are supported by 542
prime-quality non-QM loans with a total balance of $440.54 million
as of the cutoff date. The loans were originated to JPM Chase's
guidelines, which satisfy the Ability to Repay Rule but do not
qualify for QM status due to Appendix Q documentation exceptions.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The collateral consists
primarily of 30-year, fixed-rate mortgage loans. The borrowers have
strong credit profiles with a weighted average FICO score of 772
and 72% WA combined loan to value ratio. The WA loan size is almost
$813,000 and liquid reserves average $437,000. The loans were
originated through JPM Chase's, or its correspondents', retail
channel, which Fitch views positively. The largest MSA
concentrations are in Los Angeles (8.7%), San Francisco (7.8%) and
New York (6.5%). Fitch's 'AAAsf' expected loss of 4.25% reflects
the pool's very high quality attributes.

Non-Qualified Mortgage (Negative): All of the loans in this
transaction were underwritten to guidelines that satisfy the ATR
Rule, but do not qualify for QM status. A majority of the loans
were coded as non-QM due to the use of tax transcripts in lieu of
signed tax returns. The remaining loans had Appendix Q exceptions,
which in Fitch's view, are immaterial and unlikely to present any
additional default or loss risk to the transaction. Fitch's 'AAAsf'
loss was increased by roughly 30bps to account for the potential
risk of foreclosure challenges under the ATR Rule.

Underwriting Guideline Exceptions: About 16% of the pool, or 88
loans, contain an underwriting exception to JPM Chase's guidelines.
All these loans meet the industry accepted standards for full
documentation and were confirmed by the third-party due diligence
review firm as having income, assets and employment fully verified
and consistent with full documentation.

Minimal Operational Risk (Positive): JPM Chase has a long operating
history of originating and securitizing residential mortgage loans,
and is assessed as 'Above Average' by Fitch. JPM Chase is also the
servicer of this transaction; it is rated 'RPS1-' by Fitch. Loan
origination and servicer quality have an impact on performance, and
Fitch lowers its loss expectations for highly rated originators and
servicers (rated 1- or higher) due to their strong practices and
higher expected recoveries. Fitch reduced its 'AAAsf' loss
expectations, by 84bps, to account for the low operational risk
associated with this pool.

Representation and Warranty Framework (Positive): The
representation and warranty construct is viewed by Fitch as a Tier
2 framework due to inclusion of knowledge qualifiers without a
clawback provision and the narrow testing construct, which limits
the breach reviewers' ability to identify or respond to issues not
fully anticipated at closing. The R&Ws are being provided by JPM
Chase, rated 'AA'/'F1+'/Outlook Stable. There was no adjustment to
the loss expectation due to the R&W framework and financial
strength of JPM Chase as R&W provider.

Third-Party Due Diligence (Positive): Third-party due diligence was
performed by a Fitch-assessed 'Acceptable-Tier 2' due diligence
review firm on 100% of the loans. The review confirmed sound
operational quality with no incidence of material defects. While a
slightly higher percentage of loans were approved with non-material
credit exceptions compared to prime industry averages, the
exceptions are supported by strong mitigating factors and, in
Fitch's view, do not compromise the overall credit profile of the
borrowers or expected performance of the transaction.

Straightforward Deal Structure (Positive): The mortgage cash flow
and loss allocation are based on a senior-subordinate,
shifting-interest structure, whereby the subordinate classes
receive only scheduled principal and are locked out from receiving
unscheduled principal or prepayments for five years. The lockout
feature helps maintain subordination for a longer period should
losses occur later in the life of the deal. The applicable credit
support percentage feature redirects subordinate principal to
classes of higher seniority if specified credit enhancement levels
are not maintained.

To mitigate tail risk, which arises as the pool seasons and fewer
loans are outstanding, a subordination floor of 2.50% of the
original balance will be maintained for the senior certificates and
a subordination floor of 1.50% of the original balance will be
maintained for the subordinate certificates.

RATING SENSITIVITIES

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

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10%, 20% and 30%, in addition to the
model-projected 6.2%.

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


CHASE HOME 2019-ATR1: Moody's Rates Class B-5 Debt 'B3'
-------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to 22
classes of residential mortgage-backed securities issued by Chase
Home Lending Mortgage Trust 2019-ATR1. The ratings range from Aaa
(sf) to B3 (sf).

CHASE 2019-ATR1 is the fourth prime jumbo transaction of 2019
sponsored by J.P. Morgan Mortgage Acquisition Corporation, but is
the first transaction from the Chase Home Lending Mortgage Trust
platform. It is also the first JPMMAC-sponsored transaction backed
by 100% non-qualified mortgage (non-QM) loans. The certificates are
backed by 542 fully-amortizing fixed-rate mortgage loans with a
total balance of $440,543,028 as of the April 1, 2019 cut-off date.
The mortgage loans are non-conforming and are predominantly 30-year
term mortgages.

JPMorgan Chase Bank, N.A. is the originator and servicer for 100%
of the mortgage loans. In a departure from recent JPMMAC-sponsored
transactions, Chase is not representing that any of the mortgage
loans in the transaction is a 'qualified mortgage' under the
'ability to repay' rules in the Truth-in-Lending Act. Chase will
make a representation that the mortgage loans comply with the ATR
rules.

Wells Fargo Bank, N.A. will be the securities administrator and
U.S. Bank Trust National Association will be the Delaware trustee.
Pentalpha Surveillance LLC will be the representations and
warranties breach reviewer. Distributions of principal and interest
and loss allocations are based on a typical shifting interest
structure that benefits from senior and subordination floors.

The complete rating actions are as follows:

Issuer: Chase Home Lending Mortgage Trust 2019-ATR1

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-4, Definitive Rating Assigned Aaa (sf)

Cl. A-5, Definitive Rating Assigned Aaa (sf)

Cl. A-6, Definitive Rating Assigned Aaa (sf)

Cl. A-7, Definitive Rating Assigned Aaa (sf)

Cl. A-8, Definitive Rating Assigned Aaa (sf)

Cl. A-9, Definitive Rating Assigned Aaa (sf)

Cl. A-10, Definitive Rating Assigned Aaa (sf)

Cl. A-11, Definitive Rating Assigned Aaa (sf)

Cl. A-12, Definitive Rating Assigned Aaa (sf)

Cl. A-13, Definitive Rating Assigned Aaa (sf)

Cl. A-14, Definitive Rating Assigned Aa1 (sf)

Cl. A-15, Definitive Rating Assigned Aa1 (sf)

Cl. A-16, Definitive Rating Assigned Aaa (sf)

Cl. A-17, Definitive Rating Assigned Aaa (sf)

Cl. B-1, Definitive Rating Assigned Aa3 (sf)

Cl. B-2, Definitive Rating Assigned A2 (sf)

Cl. B-3, Definitive Rating Assigned Baa3 (sf)

Cl. B-4, Definitive Rating Assigned Ba2 (sf)

Cl. B-5, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 0.30%
in a base scenario and reaches 4.65% at a stress level consistent
with the Aaa (sf) ratings.

It calculated losses on the pool using its US Moody's Individual
Loan Analysis model based on the loan-level collateral information
as of the cut-off date. Loan-level adjustments to the model results
included adjustments to probability of default for higher and lower
borrower debt-to-income ratios, for borrowers with multiple
mortgaged properties, self-employed borrowers, and for the default
risk of Homeownership association properties in super lien states.
Theginator quality and the financial strength of representation &
warranty provider.

Moody's bases its definitive ratings on the certificates on the
credit quality of the mortgage loans, the structural features of
the transaction, its assessments of the originator and servicer,
the strength of the third party due diligence and the
representations and warranties framework of the transaction.

Collateral Description

CHASE 2019-ATR1 is a securitization of a pool of 542
fully-amortizing fixed-rate mortgage loans with a total balance of
$440,543,028 as of the cut-off date, with a weighted average
remaining term to maturity of 349 months and a WA seasoning of 10
months. The borrowers in this transaction have high FICO scores and
sizeable equity in their properties. The WA current FICO score is
776 and the WA original combined loan-to-value ratio is 75.2%. The
characteristics of the loans underlying the pool are generally
comparable to other JPMMAC-sponsored transactions backed by prime
mortgage loans that Moody's has rated. Correspondent loans
represent 91% of the collateral pool. All the correspondent loans
were originated via the retail channel of the respective
correspondents and the majority did not undergo delegated
underwriting.

In this transaction, Chase is not representing that any of the
mortgage loans in the transaction is a 'qualified mortgage' under
the ATR rules in TILA. Chase will make a representation that the
mortgage loans comply with the ATR rules. Moody's made an
incremental adjustment to its expected loss to account for the
increased risk of legal challenges from defaulted borrowers, which
could result in the trust bearing the legal expenses associated
with defending against such claims. This risk is mitigated by the
strong credit quality of the borrowers, since they are less likely
to default.

The mortgage loans in the collateral pool were underwritten in
accordance with Chase's prime jumbo underwriting guidelines. The
third party review firm checked for ATR compliance as part of due
diligence on the collateral pool and did not find any issues. The
loans are considered non-QM primarily due to exceptions related to
income documentation where self-employment income and tax
transcripts were accepted in lieu of signed tax returns. In other
cases, sources used to determine the borrower's net income were not
compliant with Appendix Q regulations. In some instances, the
verified income or employment history was less than required under
Appendix Q. Exceptions to Appendix Q were flagged by the TPR firm
as part of the credit review since they were exceptions to Chase's
prime jumbo underwriting guidelines as well. The TPR firm noted
that the underwriting exceptions were approved by the lender and
compensating factors such as FICO score, LTV, DTI and/or reserves
that compared favorably with the underwriting guidelines were
noted.

Servicing Fee Framework

The servicing fee for the mortgage loans will be based on a step-up
incentive fee structure with a monthly base fee of $20 per loan and
additional fees for servicing delinquent and defaulted loans.

While this fee structure is common in non-performing mortgage
securitizations, it is unique to rated prime mortgage
securitizations which typically incorporate a flat 25 basis point
servicing fee rate structure. By establishing a base servicing fee
for performing loans that increases with the delinquency of loans,
the fee-for-service structure aligns monetary incentives to the
servicer with the costs of the servicer. The servicer receives
higher fees for labor-intensive activities that are associated with
servicing delinquent loans, including loss mitigation, than they
receive for servicing a performing loan, which is less
labor-intensive. The fee-for-service compensation is reasonable and
adequate for this transaction because it better aligns the
servicer's costs with the deal's performance. Furthermore, higher
fees for the more labor-intensive tasks make the transfer of these
loans to another servicer easier, should that become necessary. By
contrast, in typical RMBS transactions a servicer can take actions,
such as modifications and prolonged workouts, that increase the
value of its mortgage servicing rights.

The incentive structure includes an initial monthly base servicing
fee of $20 for all performing loans and increases according to a
pre-determined delinquent and incentive servicing fee schedule.

The delinquent and incentive servicing fees will be deducted from
the available distribution amount and Class B-6 net WAC. The
transaction does not have a servicing fee cap, so, in the event of
a servicer replacement, any increase in the base servicing fee
beyond the current fee will be paid out of the available
distribution amount.

Third-party Review and Reps & Warranties

A third party review firm verified the accuracy of the loan-level
information that Moody's received from the sponsor. The firm
conducted detailed credit, valuation, regulatory compliance and
data integrity reviews on 100% of the mortgage pool. The TPR
results indicated compliance with the originators' underwriting
guidelines for the vast majority of loans, no material compliance
issues, and no appraisal defects. The loans that had exceptions to
the originators' underwriting guidelines had strong documented
compensating factors such as low DTIs, low LTVs, high reserves,
high FICOs, or clean payment histories. The TPR firm also
identified minor compliance exceptions for reasons such as
inadequate RESPA disclosures (which do not have assignee liability)
and TILA/RESPA Integrated Disclosure violations related to fees
that were out of variance but then were cured and disclosed.
Moody's did not make any adjustments to its expected or Aaa (sf)
loss levels due to the TPR results.

CHASE 2019-ATR1's R&W framework is in line with that of other
JPMMAC-sponsored transactions where an independent reviewer is
named at closing, and costs and manner of review are clearly
outlined at issuance. Its review of the R&W framework takes into
account the financial strength of the R&W provider, scope of R&Ws
(including qualifiers and sunsets) and enforcement mechanisms.

JPMorgan Chase Bank, N.A. (rated Aa2) is the R&W provider for all
the mortgage loans in the collateral pool. Moody's made no
adjustments to its expected loss given the strong financial
standing of the R&W provider.

Other Transaction Parties

The Delaware trustee is U.S. Bank Trust National Association. The
custodian's functions will be performed by Chase. The paying agent
and cash management functions will be performed by Wells Fargo
Bank, N.A. as securities administrator.

There is no named back-up servicer or master servicer at closing.
In the event Chase is terminated as servicer, the issuing entity,
at the direction of a majority of the certificate holders, will
appoint a successor servicer. If the issuing entity is unable to
appoint a successor servicer, it may petition a court of competent
jurisdiction to appoint any established mortgage loan servicing
institution as the successor servicer.

While this servicing arrangement is weaker than in other
transactions which have a master servicer in place at closing,
Moody's considers the arrangement adequate given Chase's strong
financial durability and the relative ease of transferability of
the assets to another servicer. These two factors combine to
mitigate the risk of financial disruption from a servicing
transfer.

Tail Risk & Subordination Floor

This deal has a standard shifting-interest structure, with a
subordination floor to protect against losses that occur late in
the life of the pool when relatively few loans remain (tail risk).
When the total senior subordination is less than 2.50% of the
original pool balance, the subordinate bonds do not receive any
principal and all principal is then paid to the senior bonds. In
addition, if the subordinate percentage drops below 6.00% of
current pool balance, the senior distribution amount will include
all principal collections and the subordinate principal
distribution amount will be zero. The subordinate bonds themselves
benefit from a floor. When the total current balance of a given
subordinate tranche plus the aggregate balance of the subordinate
tranches that are junior to it amount to less than 1.50% of the
original pool balance, those tranches do not receive principal
distributions. The principal those tranches would have received is
directed to pay more senior subordinate bonds pro-rata.

Transaction Structure

The transaction uses the shifting interest structure in which the
senior bonds benefit from a number of protections. Funds collected,
including principal, are first used to make interest payments to
the senior bonds. Next, principal payments are made to the senior
bonds. Next, available distribution amounts are used to reimburse
realized losses and certificate write-down amounts for the senior
bonds (after subordinate bond have been reduced to zero I.e. the
credit support depletion date). Finally, interest and then
principal payments are paid to the subordinate bonds in sequential
order.

Realized losses are allocated in a reverse sequential order, first
to the lowest subordinate bond. After the balance of the
subordinate bonds is written off, losses from the pool begin to
write off the principal balance of the senior support bond, and
finally losses are allocated to the super senior bonds.

In addition, the pass-through rate on the bonds is based on the net
WAC as reduced by the sum of (i) the reviewer annual fee rate and
(ii) the capped trust expense rate. In the event that there is a
small number of loans remaining, the last outstanding bonds' rate
can be reduced to zero.

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 of the subordinate bonds 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.


CHURCHILL MIDDLE: DBRS Hikes Rating on Class D Loans/Notes to BB
----------------------------------------------------------------
DBRS, Inc. confirmed its ratings on the Class A-R Loans and Class
A-T Loans issued by Churchill Middle Market CLO IV Ltd. (Churchill)
at AA (sf). DBRS also upgraded its ratings on the Class B Loans and
Notes, the Class C Loans and Notes and the Class D Loans and Notes
(collectively, the Loans and Notes) as follows:

-- Class B Loans and Class B Notes upgraded to A (sf)
    from A (low) (sf)

-- Class C Loans and Class C Notes upgraded to BBB (sf)
    from BBB (low) (sf)

-- Class D Loans and Class D Notes upgraded to BB (sf)
    from BB (low) (sf)

The ratings on the Loans are assigned pursuant to the Credit
Agreement dated as of April 19, 2018, among Churchill as Borrower;
Natixis, New York Branch (Natixis) as Administrative Agent; The
Bank of New York Mellon Trust Company, N.A. (BNYM; rated AA with a
Positive trend by DBRS) as Collateral Agent, Collateral
Administrator, Information Agent, and Custodian; and the Lenders
referred to therein. The ratings on the Notes are assigned pursuant
to the Note Purchase Agreement dated as of April 19, 2018, among
Churchill as Issuer, BNYM as Collateral Agent and Note Agent as
well as the Purchasers referred to therein.

The ratings on the Class A-R Loans and Class A-T Loans address the
timely payment of interest (excluding any Capped Amounts and the
additional 2% of interest payable at the Post-Default Rate, as
defined in the Credit Agreement referred to above) and the ultimate
payment of principal on or before the Stated Maturity (as defined
in the Credit Agreement referred to above). The ratings on the
Class B Loans and Notes, Class C Loans and Notes and Class D Loans
and Notes address the ultimate payment of interest (excluding the
additional 2% of interest payable at the Post-Default Rate, as
defined in the Credit Agreement and the Note Purchase Agreement
referred to above) and the ultimate payment of principal on or
before the Stated Maturity (as defined in the Credit Agreement and
the Note Purchase Agreement referred to above).

The Loans and Notes issued by Churchill will be collateralized
primary by a portfolio of U.S. middle-market corporate loans.
Churchill will be managed by Nuveen Alternative Advisors, LLC
(Nuveen). Additionally, Churchill Asset Management LLC will act as
Sub-Advisor for this transaction. DBRS considers Nuveen and
Churchill Asset Management LLC to be acceptable collateralized loan
obligation managers.

To assess portfolio credit quality, DBRS provides a credit estimate
or internal assessment for each non-financial corporate obligor in
the portfolio that is not rated by DBRS. Credit estimates are not
ratings; rather, they represent a model-driven default probability
for each obligor that is used in assigning a rating to the
facility.


CITIGROUP MORTGAGE 2019-RP1: DBRS Gives (P)B Rating on B-2 Notes
----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following
Mortgage-Backed Notes, Series 2019-RP1 to be issued by Citigroup
Mortgage Loan Trust 2019-RP1 (the Trust):

-- $162.6 million Class A-1 at AAA (sf)
-- $14.7 million Class M-1 at AA (sf)
-- $16.8 million Class M-2 at A (low) (sf)
-- $15.9 million Class M-3 at BBB (low) (sf)
-- $7.5 million Class B-1 at BB (low) (sf)
-- $9.8 million Class B-2 at B (sf)

The AAA (sf) rating on the Class A-1 Notes reflects the 38.00% of
credit enhancement provided by subordinated Notes in the pool. The
AA (sf), A (low) (sf), BBB (low) (sf), BB (low) (sf) and B (sf)
ratings reflect credit enhancement of 32.40%, 26.00%, 19.95%,
17.10% and 13.35%, respectively.

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

This transaction is a securitization of a portfolio of seasoned
performing and re-performing first-lien residential mortgages. The
Notes are backed by 1,330 loans with a total principal balance of
$262,812,561 as of the Cut-Off Date (March 31, 2019).

The loans are approximately 150 months seasoned. As of the Cut-Off
Date, all loans are current, including 3.1% bankruptcy-performing
loans. Approximately 49.7% and 93.1% of the mortgage loans have
been zero times 30 days delinquent for the past 24 months and 12
months, respectively, under the Mortgage Bankers Association
delinquency method.

The portfolio contains 88.8% modified loans. The modifications
happened more than two years ago for 62.9% of the modified loans.
Within the pool, 687 mortgages have aggregate non-interest-bearing
deferred amounts of $29,577,691. Included in the deferred amounts
are proprietary principal forgiveness and Home Affordable
Modification Program principal reduction alternative amounts
(collectively, the PRA amounts) of $572,484. The non-PRA amounts of
$29,005,206 comprise approximately 11.1% of the total principal
balance.

There are no loans in the pool that are subject to the Consumer
Financial Protection Bureau Ability-to-Repay and Qualified Mortgage
rules.

The Sponsor and Seller, Citigroup Global Markets Realty Corp.
(CGMRC), acquired the mortgage loans from various sellers who
originated the loans between June 18, 1990, and June 6, 2014, and
will contribute the loans to the Trust through an affiliate,
Citigroup Mortgage Loan Trust Inc. (the Depositor). As the Sponsor,
CGMRC or one of its majority-owned affiliates will acquire and
retain a 5% eligible vertical interest in each class of Notes
(other than the Class R Notes) to satisfy the credit risk retention
requirements. The loans were originated and previously serviced by
various entities through purchases in the secondary market. As of
the Cut-Off Date, the loans are serviced by Fay Servicing, LLC.

There will not be any advancing of delinquent principal or interest
on any mortgages by the Servicer or any other party to the
transaction; however, the servicer is obligated to make advances in
respect of homeowner association fees, taxes, and insurance as well
as reasonable costs and expenses incurred in the course of
servicing and disposing of properties.

The transaction employs a sequential-pay cash flow structure.
Principal proceeds can be used to cover interest shortfalls on the
Notes, but such shortfalls on Class M-2 and more subordinate
principal and interest (P&I) bonds will not be paid from principal
proceeds until the more senior classes are retired.

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

The ratings reflect transactional strengths that include underlying
assets that demonstrate improving performance in the recent past
and strong representations and warranties (R&W) provider (CGMRC).
Additionally, a comprehensive third-party due diligence review was
performed on the portfolio with respect to regulatory compliance,
servicing comments, data integrity, payment histories, and title
and tax review. Updated broker price opinions, desk appraisals,
comparative market analyses or 2055 values were provided for 100%
of the pool; however, reconciliations were not performed on the
updated values.

The transaction employs an R&W framework that includes certain
weaknesses such as knowledge qualifiers, a fraud representation
that is limited to the time period when the Seller owned the loans
and carves outs for loans with known findings or unavailable
information. Mitigating factors include (1) a financially strong
R&W provider (CGMRC), (2) a comprehensive due diligence review, (3)
automatic or designated breach review triggers dependent on certain
conditions and (4) significant loan seasoning and relatively clean
performance history in recent years.

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

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


CITIGROUP MORTGAGE 2019-RP1: Moody's Rates Class B-3 Debt 'C'
-------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to seven
classes of notes issued by Citigroup Mortgage Loan Trust 2019-RP1,
which are backed by one pool of primarily re-performing residential
mortgage loans. As of the cut-off date of March 31, 2019, the
collateral pool is comprised of 1,330 first lien mortgage loans,
with a weighted average updated primary borrower FICO score of 662,
a WA current loan-to-value Ratio of 93.5% and a total unpaid
balance of $262,812,561. Total deal balance is $264,016,710 which
includes a pre-existing servicing advance of $1,204,150.
Approximately 11.3% of the pool balance is non-interest bearing,
which consists of both principal reduction alternative and non-PRA
deferred principal balance.

Fay Servicing, LLC will be the primary servicer and will not
advance any principal or interest on the delinquent loans. However,
it will be required to advance costs and expenses incurred in
connection with a default, delinquency or other event in the
performance of its servicing obligations.

The complete rating actions are as follows:

Issuer: Citigroup Mortgage Loan Trust 2019-RP1

Class A-1, Definitive Rating Assigned Aaa (sf)

Class M-1, Definitive Rating Assigned Aa2 (sf)

Class M-2, Definitive Rating Assigned A3 (sf)

Class M-3, Definitive Rating Assigned Baa3 (sf)

Class B-1, Definitive Rating Assigned Ba3 (sf)

Class B-2, Definitive Rating Assigned B3 (sf)

Class B-3, Definitive Rating Assigned C (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected losses on CMLTI 2019-RP1's collateral pool average
13.0% in its base case scenario. The loss estimates take into
account the historical performance of loans that have similar
collateral characteristics as the loans in the pool. The credit
opinion is the result of its analysis of a wide array of
quantitative and qualitative factors, a review of the third-party
review of the pool, servicing framework and the representations and
warranties framework.

The methodologies used in these ratings were "Moody's Approach to
Rating Securitisations Backed by Non-Performing and Re-Performing
Loans" published in February 2019 and "US RMBS Surveillance
Methodology" published in February 2019.

Collateral Description

CMLTI 2019-RP1's collateral pool is primarily comprised of
re-performing mortgage loans. About 88.8% of mortgage loans in the
pool have been previously modified.

Moody's based its expected losses on its estimates of 1) the
default rate on the remaining balance of the loans and 2) the
principal recovery rate on the defaulted balances. The two factors
that most strongly influence a re-performing mortgage loan's
likelihood of re-default are the length of time that the loan has
performed since a loan modification, and the amount of the
reduction in the monthly mortgage payment as a result of the
modification. The longer a borrower has been current on a
re-performing loan, the less likely the borrower is to re-default.
Approximately 49.7% of the borrowers have been current on their
payments for at least the past 24 months under the MBA method of
calculating delinquencies.

Moody's estimated expected losses for the pool using two approaches
-- (1) pool-level approach, and (2) re-performing loan level
analysis.

In the pool-level approach, Moody's estimates losses on the pool
using an approach similar to its surveillance approach whereby it
applies assumptions of future delinquencies, default rates, loss
severities and prepayments based on observed performance of similar
collateral. Moody's projects future annual delinquencies for eight
years by applying an initial annual default rate and delinquency
burnout factors. Based on the loan characteristics of the pool and
the demonstrated pay histories, it expects an annual delinquency
rate of 11% on the collateral pool for year one. It  then
calculated future delinquencies on the pool using its default
burnout and voluntary conditional prepayment rate assumptions. The
delinquency burnout factors reflect its future expectations of the
economy and the U.S. housing market. Moody's then aggregated the
delinquencies and converted them to losses by applying
pool-specific lifetime default frequency and loss severity
assumptions. Its loss severity assumptions are based off observed
severities on liquidated seasoned loans and reflect the lack of
principal and interest advancing on the loans.

Moody's also conducted a loan level analysis on CMLTI 2019-RP1's
collateral pool. Moody's applied loan-level baseline lifetime
propensity to default assumptions, and considered the historical
performance of seasoned loans with similar collateral
characteristics and payment histories. Moody's then adjusted this
base default propensity up for (1) adjustable-rate loans, (2) loans
that have the risk of coupon step-ups and (3) loans with high
updated loan to value ratios. It applied a higher baseline lifetime
default propensity for interest-only loans, using the same
adjustments. To calculate the expected loss for the pool, it
applied a loan-level loss severity assumption based on the loans'
updated estimated LTVs. It further adjusted the loss severity
assumption upwards for loans in states that give super-priority
status to homeowner association (HOA) liens, to account for
potential risk of HOA liens trumping a mortgage.

As of the cut-off date, approximately 11.3% of the pool balance is
non-interest bearing, which consists of both PRA and non-PRA
deferred principal balance. However, the PRA deferred amount of
$572,484 will be carved out as a separate Class PRA note.

For non-PRA forborne amounts, the deferred balance is the full
obligation of the borrower and must be paid in full upon (i) sale
of property (ii) voluntary payoff or (iii) final scheduled payment
date. Upon sale of the property, the servicer therefore could
potentially recover some of the deferred amount. For loans that
default in future or get modified after the closing date, the
servicer may opt for partial or full principal forgiveness to the
extent permitted under the servicing agreement. Based on
performance and information from servicers, it applied a slightly
higher default rate than what it assumed for the overall pool given
that these borrowers have experienced past credit events that
required loan modification, as opposed to borrowers who have been
current and have never been modified. In addition, it assumed
approximately 95% severity as the servicer may recover a portion of
the deferred balance. Its expected loss does not consider the PRA
deferred amount.

Transaction Structure

The securitization has a simple sequential priority of payments
structure without any cash flow triggers. The servicer will not
advance any principal or interest on delinquent loans. However, the
servicer will be required to advance costs and expenses incurred in
connection with a default, delinquency or other event in the
performance of its servicing obligations. Credit enhancement in
this transaction is comprised of subordination provided by
mezzanine and junior tranches and loss allocation to the
subordinate bonds. To the extent excess cashflow is available, it
will be used to pay down additional principal of the bonds
sequentially, building overcollateralization.

Moody's ran 96 different loss and prepayment scenarios through its
cash flow model. The scenarios encompass six loss levels, four loss
timing curves, and four prepayment curves. The structure allows for
timely payment of interest and ultimate payment of principal with
respect to the notes by the legal final maturity.

Third Party Review

The sponsor engaged third party diligence providers to conduct the
following due diligence reviews: (i) a title/lien review to confirm
the appropriate lien was recorded and the position of the lien and
to review for other outstanding liens and the position of those
liens; (ii) a state and federal regulatory compliance review on the
loans; (iii) a payment history review for the three year period (to
the extent available) to confirm that the payment strings matched
the data supplied by or on behalf of the third-party sellers; and
(iv) a data comparison review on certain characteristics of the
loans.

Based on its analysis of the TPR reports, Moody's determined that a
portion of the loans with some cited violations are at enhanced
risk of having violated TILA through an under-disclosure of the
finance charges or other disclosure deficiencies. Although the TPR
report indicated that the statute of limitations for borrowers to
rescind their loans has already passed, borrowers can still raise
these legal claims in defense against foreclosure as a set off or
recoupment and win damages that can reduce the amount of the
foreclosure proceeds. Such damages can include up to $4,000 in
statutory damages, borrowers' legal fees and other actual damages.
Moody's increased its base case losses for these loans to account
for such damages.

The seller will create a custodian exception report on the closing
date consisting of three major categories (i) mortgage notes
released to a bailee, (ii) missing mortgage and (iii) missing and
incomplete final assignments and note endorsements. The seller is
obligated to cure these exception or repurchase the loan within 24
months from the closing date. This is a change from the previously
rated CMLTI deals, in which the issuer will cure the exception
within 12 months from the closing date or will be obligated to
repurchase. Moody's is credit neutral about this change as it
anticipates lower percentage of loans to fall into serious
delinquency within the first 24 months. In addition, based on the
historical performance of three rated CMLTI transactions in 2018,
the seller has been actively clearing exceptions within the first
few months of closing.

The diligence provider noted 40 delinquent property tax exceptions.
Loans with these findings are not removed from the final pool,
however, the seller is obligated to cure the exception or
repurchase the loan within 12 months of the closing date. In
addition, the diligence provider noted 27 HOA lien exceptions and
71 municipal liens exceptions. If any of the mortgage loans with
these exceptions result in a Realized Loss to the trust then the
Seller will be obligated to make a "make whole" payment to the
trust which is the lower of (i) amount necessary to cure the
exception, and (ii) the amount of related realized loss. This is a
change from the previously rate CMLTI deals, in which the issuer
will be obligated to cure the exception or repurchase the loan
within 12 months from the closing date. Moody's considers this
change to be credit neutral as the total HOA and municipal lien
amount ($368,977) is a small percentage of the total pool balance
and if it is determined that a realized loss was caused by the HOA
or the municipal lien exception in existence on the Closing Date
and was not subsequently cured thereafter, the seller will be
obligated to make a "make whole" payment to the trust in amount
equal to the lesser of (i) the amount necessary to cure the
exception and (ii) the amount of the related realized loss.

The review also consisted of validating 42 data fields for each
loan in the pool which resulted in 740 loans having one or more
data variances. It was determined that such data variances were
attributable to missing or defective source documentation,
non-material variances within acceptable tolerances, allocation
between documented and undocumented deferred principal balances,
timing and data formatting differences. Moody's did not make any
adjustments for these findings.

Representations & Warranties (R&W)

The R&W framework for this transaction is adequate. The scope of
the R&Ws are somewhat weaker compared to prior CMLTI
securitizations rated by us owing mainly to items identified in the
TPR being excluded from the R&Ws. However, the overall framework is
still adequate as there are well-defined breach discovery and
enforcement mechanisms and provisions that obligate the R&W
provider despite lack of its knowledge (R&W knowledge clawback
provisions).

The R&W provider is Citigroup Global Markets Realty Corp. Although
it itself is unrated, it is affiliated with an investment grade
entity, Citigroup Inc., though Citigroup Inc. has no contractual
obligation with respect to R&W breaches.

There is a good chance that any R&W breaches will be discovered
because an independent party is obligated to review for R&W
breaches if:

(i) a loan was at least 120 days delinquent following a threshold
event, which is satisfied if the sum of cumulative realized loss
and unpaid principal balance of 120+ days delinquent loans (current
trigger amount) within the first three years exceeds 50% of
aggregate class B-3, class B-4 and class B-5 balance as of the
closing date or the current trigger amount exceeds 75% of aggregate
class B-3, class B-4 and class B-5 balance as of the closing date
thereafter.

(ii) a loan was liquidated at a loss if certain conditions
including but not limited to a reviewer waiver from controlling
holder or if the review fees and expenses were less than the loss
amount

(iii) the servicer has made a determination that it cannot
foreclose upon the loan

If the breach reviewer (an independent third party) identifies a
R&W breach, the R&W provider will be obligated to either cure the
breach, repurchase or substitute the loan, or pay for any loss if
the loan has been liquidated. The R&W provider will also cover
losses incurred due to a servicer's inability to foreclose on the
mortgage. If the R&W Provider disputes the findings, there is
binding arbitration to resolve the dispute. The loser of the
arbitration pays all the expenses.

There are a few weaknesses in the enforcement mechanisms. First,
the independent reviewer is not identified at closing and, if the
indenture trustee has difficulty engaging one on acceptable terms,
the controlling holder can direct the trustee not to engage one.
Furthermore, the review fees, which the trust pays, are not agreed
upon at closing and will be determined in the future. Second, the
remedies do not cover damages owing to TILA under-disclosures.
Moody's made adjustments to account for such damages in its
analysis. Finally, there will be no remedy for an insurance-related
R&W if there is an insurance policy rescission.

Trustee Indemnification

Moody's believes there is a very low likelihood that the rated
notes in CMLTI 2019-RP1 will incur any loss from extraordinary
expenses or indemnification payments owing to potential future
lawsuits against key deal parties. First, majority of the loans are
seasoned with demonstrated payment history, reducing the likelihood
of a lawsuit on the basis that the loans have underwriting defects.
Second, historical performance of loans aggregated by the sponsor
to date has been within expectation, with minimal losses on
previously issued CMLTI transactions. Third, the transaction has
reasonably well defined processes in place to identify loans with
defects on an ongoing basis. In this transaction a well-defined
breach discovery and enforcement mechanism reduces the likelihood
that parties will be sued for inaction.

Transaction Parties

Fay will be the primary servicer for all loans in the pool. Wells
Fargo Bank, N.A. and Deutsche Bank National Trust Company will act
as custodians. U.S. Bank National Association will be the trust
administrator, U.S. Bank Trust National Association will be the
owner trustee and Wilmington Savings Fund Society, FSB will be the
indenture trustee.

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

Factors that would lead to an upgrade of the ratings

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 its 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. Other reasons for
better-than-expected performance include changes to servicing
practices that enhance collections or refinancing opportunities
that result in prepayments.

Factors that would lead to a downgrade of the ratings

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 obligors defaulting 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.


COMM MORTGAGE 2015-CCRE26: Fitch Affirms BB- on $13.6MM F Certs
---------------------------------------------------------------
Fitch Ratings has affirmed 12 classes of Deutsche Bank Securities,
Inc.'s COMM 2015-CCRE26 Mortgage Trust commercial mortgage
pass-through certificates.

KEY RATING DRIVERS

Stable Loss Expectations/FLOCs: Overall pool performance and loss
expectations remain generally stable. One loan, Crossroads Office
Portfolio (4.1%), is specially serviced. The loan is secured by two
office properties located in Long Island, NY. The loan transferred
to special servicing in March 2018 after missing its monthly debt
service payments for January thru March 2018. Upon transferring to
special servicing, it was also determined the loan was in further
default as the guarantor passed away in 2015. Per the special
servicer, the loan has been recently assumed by Crest Group, who
was a partial owner in the original tenant-in-common (TIC)
ownership structure at issuance. As part of the assumption, Crest
Group was required to bring the loan current as well as place
$550,000 with the servicer as a TI/LC reserve. Per the special
servicer, they anticipate the loan will be transferred back to the
master servicer as a performing loan in the second half of 2019.
Fitch will continue to monitor the loan for further updates.

Fitch also identified three loans (5.6%) as Fitch Loans of Concern
(FLOCs) due to declining performance and upcoming lease rollover.
The largest FLOC and also the seventh largest loan in the pool,
Rosetree Corporate Center (4.3%), is secured by a 268,156 sf
suburban office building located in Media, PA (approximately 22
miles from Philadelphia, PA). Per the December 2018 rent roll,
approximately 43% of the NRA is expected to roll in 2019, including
top tenants FXI, Inc., Vista Underwriting Partners and a GSA
tenant. Per the servicer, FXI is currently in lease negotiations,
but lease terms have not been finalized. Additionally, both the GSA
tenant and Vista Underwriting Partners have downsized their space
by 4,800 sf and 2,800 sf ahead of their 2019 lease expirations;
respectively.

The second FLOC, 2210 Main Street (0.5%), is secured by a 8,550 sf
office space located in Santa Monica, CA. Per the servicer, the
property was 56% occupied as of YE 2018 after two major tenants
vacated at their 2018 lease expirations. The borrower has leased
the vacant space to two new tenants. Per the master servicer,
CoWork Main Street (56% of the NRA; September 2023) took occupancy
in October 2018 and Daversa Partners (44% of the NRA; June 2026) is
expected to take occupancy in April 2019. Although the YE 2018 NOI
DSCR was below 1.0x, it is expected to improve once Daversa
Partners takes occupancy.

The third largest FLOC, Lynnhaven Square (0.5%), is secured by a
retail center located in Virginia Beach, VA. As of December 2018,
occupancy has fallen to 75.5% from 93.5% as of YE 2017 and 93.0% as
of YE 2016. The declines in occupancy are related to the departure
of two tenants, Aquastill (formerly 6.5% of the NRA; August 2018)
and Verizon Wireless (11.5% of NRA; July 2018) at their 2018 lease
expirations. Per the servicer, the borrower is reviewing multiple
letters of intent (LOIs) for the vacant space and has expanded the
leasing team to market the vacant the space.

Increasing Credit Enhancement: As of the April 2019 remittance, the
pool's aggregate principal balance has been reduced by 4.6% to
$1.04 billion from $1.09 billion at issuance. Since Fitch's last
rating action, one loan, Park at Perimeter Center East (previously
2.4% of the pool balance) paid off in full with yield maintenance.
The paydown reduced the class A-1 certificates to zero and reduced
the A-2 certificates by $9.3 million (21.0%). One loan is defeased
(0.3%). Seven loans (16.5%) are interest-only for the full loan
term, including three loans in the top 15, 11 Madison Avenue
(6.7%), Portofino Plaza (4.3%) and Empire Plaza (3.1%). Twenty-two
loans (55.3%) have partial interest only terms, of which 14 loans
(23.7% of the pool) are currently amortizing. The remaining loans
are all amortizing. There are current interest shortfalls in the
amount of $11k impacting class H.

Credit Opinion Loan: The second largest loan, Eleven Madison Avenue
(6.7% of the pool), was assigned a stand-alone investment grade
credit opinion of 'A-' at issuance. The loan is secured by a 2.3
million sf office building located on Park Avenue South in
Manhattan. As of the December 2018 servicer provided rent roll, the
property was 99.9% occupied. The collateral serves as the North
American headquarters for Credit Suisse (rated A/F1/Positive).

RATING SENSITIVITIES

The Stable Outlooks reflect the stable pool performance. Fitch does
not foresee positive or negative ratings migration until a material
economic or asset-level event changes the transaction's
portfolio-level ratings.

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

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

Fitch has affirmed the ratings and revised the Outlooks as
follows:

  -- $30.7 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $225 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $381.1 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $76.8 million class A-SB at 'AAAsf'; Outlook Stable;

  -- $47.7 million class A-M at 'AAAsf'; Outlook Stable;

  -- $761.3 million class X-A* at 'AAAsf'; Outlook Stable;

  -- $61.4 million class X-C* at 'BBB-sf'; Outlook Stable;

  -- $72.3 million class B at 'AA-sf'; Outlook Stable;

  -- $54.5 million class C at 'A-sf'; Outlook Stable;

  -- $61.4 million class D at 'BBB-sf'; Outlook Stable;

  -- $15 million class E at 'BB+sf'; Outlook Stable;

  -- $13.6 million class F at 'BB-sf'; Outlook to Stable from
Negative.

  * Notional amount and interest only.

Class A-1 has paid in full. Fitch does not rate the class G, H,
X-D, X-E and X-F certificates. Ratings were previously withdrawn
for class X-B.


DBWF MORTGAGE 2018-AMXP: Moody's Affirms Ba1 Rating on HRR Certs
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on five classes of
securities issued by DBWF 2018-AMXP Mortgage Trust, Commercial
Mortgage Pass-Through Certificates, Series 2018-AMXP, as follows:

Cl. A, Affirmed Aaa (sf); previously on May 17, 2018 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on May 17, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on May 17, 2018 Definitive
Rating Assigned A3 (sf)

Cl. D, Affirmed Baa2 (sf); previously on May 17, 2018 Definitive
Rating Assigned Baa2 (sf)

Cl. HRR, Affirmed Ba1 (sf); previously on May 17, 2018 Definitive
Rating Assigned Ba1 (sf)

RATINGS RATIONALE

The affirmations of the five principal and interest classes are due
to key parameters, including Moody's loan to value ratio and
Moody's stressed debt service coverage ratio, remaining with
acceptable ranges.

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 pay downs or amortization, an increase
in defeasance or an improvement in loan performance.

Factors that could lead to a downgrade of the ratings include a
decline in the performance of the loan or interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in these ratings was "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017.

DEAL PERFORMANCE

As of the April 5, 2019 Distribution Date, the transaction's
certificate balance was $500 million, the same as at
securitization. The Certificates are collateralized by a single
fixed rate loan backed by a first lien commercial mortgage related
to the fee simple interest in the newly constructed Ala Moana
Expansion (also known as Ewa Wing totaling 672,581 SF) of the Ala
Moana Center (2.7 million SF) located in Honolulu on the island of
Oahu, Hawaii. The loan is interest-only for the five-year term
maturing in April 2023.

The Ala Moana Center is an open-air regional mall and one of the
best performing malls in the world. The Ala Moana Center is
situated on a 58-acre parcel across from the Ala Moana Beach Park,
one-mile from Waikiki and two miles from downtown Honolulu. The Ala
Moana Expansion is anchored by Nordstrom and Bloomingdale's. The
inline tenancy includes a mix of national and international
retailers, as well as dining and entertainment options. As of
December 2018, the Ala Moana Expansion was 98% leased. The
comparable in-line sales, for tenants with less than 10,000 square
feet, were $1,512 per SF during the trailing 12-month period ended
December 2018.

The Net Cash Flow for the loan was $39.8 million for the calendar
year 2018. Moody's NCF is also $39.8 million, the same as at
securitization. Moody's loan to value ratio is 88%, the same as at
securitization. Moody's stressed debt service coverage ratio is
0.86X, the same as at securitization. There are no interest
shortfalls outstanding as of the current Distribution Date.


DIAMOND CLO 2019-1: S&P Rates Class E Notes 'BB- (sf)'
-------------------------------------------------------
S&P Global Ratings assigned its ratings to Diamond CLO 2019-1
Ltd./Diamond CLO 2019-1 LLC's floating-rate notes.

The note issuance is a collateralized loan obligation (CLO)
transaction backed by middle market speculative-grade (rated 'BB+'
and lower) senior secured term loans managed by GSO Capital
Partners L.P., a subsidiary of The Blackstone Group L.P. This is
GSO Capital Partners L.P.'s second CLO backed primarily by middle
market loans.

The ratings reflect:

-- The diversified collateral pool.

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

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

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

  RATINGS ASSIGNED
  Diamond CLO 2019-1 Ltd./Diamond CLO 2019-1 LLC

  Class                  Rating         Amount (mil. $)
  A-1                    AAA (sf)               319.125
  A-2                    AAA (sf)                37.375
  B                      AA (sf)                 34.500
  C (deferrable)         A (sf)                  51.750
  D (deferrable)         BBB- (sf)               34.500
  E (deferrable)         BB- (sf)                31.625
  Subordinated notes     NR                      64.915
  NR--Not rated.


DRYDEN 72 CLO: S&P Assigns Prelim BB- (sf) Rating to Class E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Dryden 72
CLO Ltd./Dryden 72 CLO LLC's floating-rate notes.

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

The preliminary ratings are based on information as of April 30,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect SP&P's view of:

-- The diversified collateral pool;

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Dryden 72 CLO Ltd./Dryden 72 CLO LLC

  Class              Rating               Amount
                                      (mil. $)
  X                  AAA (sf)               1.50
  A                  NR                   256.00
  B                  AA (sf)               48.00
  C                  A (sf)                24.00
  D                  BBB- (sf)             22.80
  E                  BB- (sf)              13.20
  Subordinate notes  NR                    38.92

  NR--Not rated.


EXANTAS CAPITAL 2019-RSO7: DBRS Finalizes B(low) Rating on F Certs
------------------------------------------------------------------
DBRS, Inc. finalized the provisional ratings of the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2019-RS07 issued by Exantas Capital Corp. 2019-RSO7 (the Issuer):

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

All trends are Stable.

The initial collateral consists of 32 floating-rate mortgages
secured by 38 transitional properties totaling approximately $687.2
million, excluding approximately $59.4 million of future funding
commitments. Most loans are in a period of transition with plans to
stabilize and improve the asset value. Of these loans, 25 have
future funding participations that the Issuer may acquire with
principal repayment proceeds for a total of approximately $59.4
million in the future.

Because of the floating-rate nature of the loans, the index DBRS
used (one-month LIBOR) was the lower of a DBRS stressed rate that
corresponded to the remaining fully extended term of the loans or
the strike price of the interest rate cap with the respective
contractual loan spread added to determine a stressed interest rate
over the loan term. When the cut-off balances were measured against
the DBRS As-Is net cash flow (NCF), 27 loans, comprising 87.2% had
a DBRS As-Is debt service coverage ratio (DSCR) below 1.00 times
(x), a threshold indicative of default risk. Additionally, the DBRS
Stabilized DSCR for 22 loans, comprising 77.5% of the initial pool
balance, is below 1.00x, which is indicative of elevated refinance
risk. The properties are often transitioning with potential upside
in cash flow; however, DBRS does not give full credit to the
stabilization if there are no holdbacks or if other loan structural
features in place are insufficient to support such treatment.
Furthermore, even with the structure provided, DBRS generally does
not assume the assets to stabilize above market levels. The
transaction will have a sequential-pay structure.

The loans are generally secured by traditional property types
(i.e., retail, multifamily, office, hotel and industrial).
Additionally, only one of the multifamily loans in the pool is
currently secured by student or military housing properties that
often exhibit higher cash flow volatility than traditional
multifamily properties. Twenty-three loans, totaling 69.6% of the
initial pool balance, represent acquisition financing with
borrowers contributing cash equity to the transaction.

The properties are primarily located in core markets with the
overall pool's weighted-average DBRS Market Rank at 4.4. Four
loans, totaling 13.5% of the pool, are in markets with a DBRS
Market Rank of 7 and another two are within markets with a Market
Rank of 6, totaling 8.5% of the pool. Both of the ranks correspond
to zip codes that are more urbanized in nature.

The deal is concentrated by property type with 20 loans,
representing 62.1% of the mortgage loan cut-off date balance,
secured by multifamily properties. Of the multifamily property
concentration, one loan totaling 5.3% of the multifamily
concentration is located in a DBRS Market Rank of 7. Another four
loans, representing 18.6% of the concentration, are located in a
DBRS Market Rank of 5. Additionally, DBRS sampled 69.6% of the
pool, representing 69.1% coverage of the total multifamily loan
cut-off balance, thereby providing comfort for the DBRS NCF.
Multifamily properties benefit from staggered lease rollover and
generally low expense ratios compared with other property types.
While revenue is quick to decline in a downturn because of the
short-term nature of the leases, it is also quick to respond when
the market improves.

All loans have floating interest rates and all loans are
interest-only during the original term and have original term
ranges from 24 months to 36 months, creating interest rate risk.
All loans are short-term loans and, even with extension options,
have a fully extended loan term of maximum five years.
Additionally, all but one loan, representing 3.6% of the pool, have
extension options and in order to qualify for these options, the
loans must meet minimum DSCR and loan-to-value requirements.
Twenty-four loans, representing 77.4% of the total pool, amortize
during all or a portion of their extension period.

The DBRS sample included 17 loans and site inspections were
performed on 14 of the 32 properties in the pool, representing
59.4% of the pool by allocated cut-off loan balance. DBRS conducted
meetings with the on-site property manager, leasing agent or
representative of the borrowing entity for 14 loans.


FINANCE OF AMERICA 2019-HB1: Moody's Rates Class M4 Debt 'B3'
-------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to five
classes of residential mortgage-backed securities issued by Finance
of America Structured Securities Trust 2019-HB1. The ratings range
from Aaa (sf) to B3 (sf).

The certificates are backed by a pool that includes 1,377 inactive
home equity conversion mortgages and 188 real estate owned
properties. The servicer for the deal is Finance of America Reverse
LLC. The complete rating actions are as follows:

Issuer: Finance of America Structured Securities Trust 2019-HB1

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. M1, Definitive Rating Assigned Aa3 (sf)

Cl. M2, Definitive Rating Assigned A3 (sf)

Cl. M3, Definitive Rating Assigned Baa3 (sf)

Cl. M4, Definitive Rating Assigned B3 (sf)

The Cl. M5 notes are not rated by Moody's.

RATINGS RATIONALE

The collateral backing FASST 2019-HB1 consists of first-lien
inactive HECMs covered by Federal Housing Administration (FHA)
insurance secured by properties in the US along with Real-Estate
Owned (REO) properties acquired through conversion of ownership of
reverse mortgage loans that are covered by FHA insurance. If a
borrower or their estate fails to pay the amount due upon maturity
or otherwise defaults, the sale of the property is used to recover
the amount owed. FAR acquired the mortgage assets from Ginnie Mae
sponsored HECM mortgage backed (HMBS) securitizations. All of the
mortgage assets are covered by FHA insurance for the repayment of
principal up to certain amounts. There are 1,565 mortgage assets
with a balance of $309,015,957. The assets are in either default,
due and payable, referred, bankruptcy, foreclosure or REO status.
Loans that are in default may move to due and payable; due and
payable loans may move to foreclosure; and foreclosure loans may
move to REO. 20.2% of the assets are in default of which 0.9% (of
the total assets) are in default due to non-occupancy, 19.4% (of
the total assets) are in default due to taxes and insurance. 16.9%
of the assets are due and payable, 46.7% of the assets are in
foreclosure and 4.2% were in bankruptcy status. Finally, 11.5% of
the assets are REO properties and were acquired through foreclosure
or deed-in-lieu of foreclosure on the associated loan. If the value
of the related mortgaged property is greater than the loan amount,
some of these loans may be settled by the borrower or their
estate.

In addition, there are 170 loans that are Optional Delay Mortgages
in the pool, 7.7% by asset balance, that have remained in the same
liquidation status since the first half of 2017 or earlier. Based
on HUD rules, servicers may delay calling loans due and payable if
the total amount owed for missed taxes and insurance is less than
$2,000 and meet certain criteria. Such loans will likely remain in
the pool for a significant period of time without liquidating and
may experience large losses, in cases where UPB is greater than
MCA, if they eventually cure and get assigned to HUD. HUD only
reimburses mortgagees up to 100% of the MCA no matter what the UPB
is when the loan becomes eligible for assignment to HUD. Therefore,
if the UPB is greater than the MCA at the time of assignment, there
will be a loss. This risk is present for all inactive HECMs but is
a particular concern for Optional Delay Mortgages because these
loans are likely to cure from default only after a significant
delay, at which point their UPB could be far greater than their MCA
due to negative amortization.

It is highly likely that such loans will not proceed to foreclosure
and that the loans will not be liquidated until the borrower or
borrowers die. As such, there is a significant likelihood that no
proceeds will be received on certain of these loans within the ten
year stated final maturity of the transaction. Due to the high
likelihood that no proceeds will be received for Optional Delay
Mortgages within the next 10 years, Moody's did not give credit to
such loans in its rating analysis.

Compared to the other inactive HECM transactions rated by Moody's,
FASST 2019-HB1 has a significantly higher concentration of mortgage
assets in Puerto Rico at 23.9%. Puerto Rico HECMs pose additional
risk due to the poor state of the Puerto Rico economy, the
uncertainty in the housing market, the aftermath of Hurricane Maria
that led to a population outflow, and the bureaucratic foreclosure
process. In addition, Puerto Rico has a tax exoneration policy that
exempts many seniors from property taxes. Due to the territory's
bureaucratic tax exoneration process, it may require a significant
amount of time to liquidate Puerto Rico HECMs with tax
delinquencies. Moody's applied additional stress in its analysis to
account for the risk posed by properties in Puerto Rico.

Moody's credit ratings reflect state-specific foreclosure timeline
stresses as well as potential extended timelines for loans in
bankruptcy.

Servicing

Finance of America Reverse LLC (FAR) will be the named servicer
under the sale and servicing agreement. FAR has the necessary
processes, staff, technology and overall infrastructure in place to
effectively oversee the servicing of this transaction. FAR will use
Reverse Mortgage Solutions, Inc. (RMS) and Compu-Link Corporation,
d/b/a Celink (Celink) as sub-servicers to service the mortgage
assets. RMS will subservice 49.75% of the pool and Celink 50.25%.
Based on an operational review of FAR, it has strong sub-servicing
monitoring processes, a seasoned servicing oversight team and
direct system access to the sub-servicers core systems.

On February 11, 2019, RMS's corporate parent Ditech Holding Corp.
(Ditech) filed for Chapter 11 of the United States Bankruptcy Code.
Unlike Ditech's previous bankruptcy, which concluded in February
2018, RMS was included in the current bankruptcy filing. The
bankruptcy filing and the company's weak financial condition create
uncertainty with regard to the future of RMS and the effectiveness
of its sub-servicing operations.

To mitigate the risk, FAR has engaged Celink as a backup
subservicer for RMS and Celink will assume RMS's sub-servicing
duties should RMS fail to perform its obligations under its
sub-servicing agreement. The sub-servicing agreement between FAR
and RMS will automatically terminate at the end of each thirty (30)
day period reducing the operational risk should RMS go into
bankruptcy. If RMS is terminated as sub-servicer, Celink will
complete a servicing transfer of the loans in the pool from RMS
within 90 days following termination. Celink has mapped RMS'
portfolio for easier transfer. Moody's has taken these factors into
consideration in its analysis and increased foreclosure timelines
by three months for loans subserviced by RMS.

Transaction Structure

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

The transaction is callable on or after six months with a 1.0%
premium and on or after 12 months without a premium. The mandatory
call date for the Class A notes is in April 2021. For the Class M1
notes, the expected final payment date is in August 2021. For the
Class M2 notes, the expected final payment date is in October 2021.
For the Class M3 notes, the expected final payment date is in
December 2021. For the Class M4 notes, the expected final payment
date is in June 2022. For the Class M5 notes, the expected final
payment date is in February 2023. For each of the subordinate
notes, there are various target amortization periods that conclude
on the respective expected final payment dates. The legal stated
maturity of the transaction is 10 years.

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

Certain aspects of the waterfall are dependent upon FAR remaining
as servicer. Servicing fees and servicer related reimbursements are
subordinated to interest and principal payments while FAR is
servicer. However, servicing advances (i.e. taxes, insurance and
property preservation) will instead have priority over interest and
principal payments in the event that FAR defaults and a new
servicer is appointed. The transaction provides a strong mechanism
to ensure continuous advancing for the assets in the pool.
Specifically, if the servicer fails to advance and such failure is
not remedied for a period of 15 days, the sub-servicers can fund
their advances from collections and from an interim advancing
reserve account. Given the significant amount of advancing required
to service inactive HECMs with tax delinquencies, this provision
helps to minimize operational disruption in the event FAR
encounters financial difficulties.

The analysis considers the expected loss to investors by the legal
final maturity date, which is ten years from closing, and not by
certain acceleration dates that may occur earlier. Moody's noted
the presence of automatic acceleration events for failure to pay
the Class A notes by the Class A mandatory call date, failure to
pay the classes of Class M notes by their expected final payment
dates, and the failure to pay the classes of Class M notes their
targeted amortization amounts. The occurrence of any of these
acceleration events would not by itself lead us to bring the
outstanding rating to a level consistent with impairment, because
such event would not necessarily be indicative of any economic
distress. Furthermore these acceleration events lack effective
legal consequences other than changing payment priorities and
interest rates, which are modeled in its analysis. Liquidation of
the collateral would require 100% consent of any class of notes
that would not be paid in full.

Third-Party Review

Unlike prior inactive HECM transactions issued by FAR, in FASST
2019-HB1 a firm of independent accountants or a due-diligence
review firm experienced in validation and auditing of reporting of
similar assets (the verification agent) will perform quarterly
procedures with respect to the monthly servicing reports delivered
by the servicer to the trustee. These procedures will include
comparison of the underlying records relating to the subservicers'
servicing of the loans and determination of the mathematical
accuracy of calculations of loan balances stated in the monthly
servicing reports delivered to the trustee. Any exceptions
identified as a result of the procedures will be described in the
verification agent's report. To the extent the verification agent
identifies errors in the monthly servicing reports, the servicer
will be obligated to correct them.

A third party firm conducted a review of certain characteristics of
the mortgage assets on behalf of FAR. The review focused on data
integrity, FHA insurance coverage verification, accuracy of
appraisal recording, accuracy of occupancy status recording,
borrower age documentation, identification of excessive corporate
advances, documentation of servicer advances, and identification of
tax liens. Also, broker price opinions (BPOs) were ordered for 303
properties in the pool.

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

Moody's accounted for the additional risk in its analysis
associated with taxes and insurance exceptions and the foreclosure
and bankruptcy fee exceptions.

Reps & Warranties (R&W)

FAR is the loan-level R&W provider and is unrated. This risk is
mitigated by the fact that a third-party due diligence firm
conducted a review on the loans for evidence of FHA insurance.

FAR represents that the mortgage loans are covered by FHA insurance
that is in full force and effect. FAR provides further R&Ws
including those for title, first lien position, enforceability of
the lien, regulatory compliance, and the condition of the property.
FAR provides a no fraud R&W covering the origination of the
mortgage loans, determination of value of the mortgaged properties,
and the sale and servicing of the mortgage loans. Although certain
representations are knowledge qualified, the transaction documents
contain language specifying that if a representation would have
been breached if not for the knowledge qualifier then FAR will
repurchase the relevant asset as if the representation had been
breached.

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

When analyzing the transaction, Moody's reviewed the transaction's
exposure to large potential indemnification payments owed to
transaction parties due to potential lawsuits. In particular, it
assessed the risk that the acquisition trustee would be subject to
lawsuits from investors for a failure to adequately enforce the
R&Ws against the Seller. Moody's believes that FASST 2019-HB1 is
adequately protected against such risk in part because a
third-party data integrity review was conducted on a significant
random sample of the loans. In addition, the third-party due
diligence firm verified that all of the loans in the pool are
covered by FHA insurance.

Trustees

The acquisition and owner trustee for the FASST 2019-HB1
transaction is Wilmington Savings Fund Society, FSB. The paying
agent and cash management functions will be performed by U.S. Bank
National Association. U.S. Bank National Association will also
serve as the claims payment agent and as such will be the HUD
mortgagee of record for the mortgage assets in the pool.

Methodology

The methodologies used in these ratings were "Moody's Approach to
Rating Securitizations Backed by Non-Performing and Re-Performing
Loans" published in February 2019 and "Moody's Global Approach to
Rating Reverse Mortgage Securitizations" published in May 2015.

The credit ratings for FASST 2019-HB1 were assigned in accordance
with Moody's existing methodologies entitled "Moody's Approach to
Rating Securitizations Backed by Non-Performing and Re-Performing
Loans," dated February 22, 2019 and "Moody's Global Approach to
Rating Reverse Mortgage Securitizations," dated May 27, 2015. Note
that on March 12, 2019, Moody's released a request for comment, in
which it has requested market feedback on potential revisions to
its methodology for securitizations backed by reverse mortgages. If
the revised methodologies are implemented as proposed, the credit
ratings on FASST 2019-HB1 may be neutrally affected.

Its quantitative asset analysis is based on a loan-by-loan modeling
of expected payout amounts and timing of payouts given the
structure of FHA insurance and with various stresses applied to
model parameters depending on the target rating level. However, the
modeling assumptions are different for the Puerto Rico portion of
the pool and the portion of the pool that are in bankruptcy.

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

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

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

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

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

Liquidation process: Each asset is categorized into one of four
categories: default, due and payable, foreclosure and REO. In its
analysis, Moody's assumes loans that are in referred status to be
either in the foreclosure or REO category. The loans are assumed to
move through each of these stages until being sold out of REO.
Moody's assumed that loans would be in default status for six to
nine months depending on the default reason. Due and payable status
is expected to last six to 12 months depending on the default
reason. REO disposition is assumed to take place in six months for
SBCs and 12 months for ABCs.

The timeline for foreclosure status is based on the state in which
the related property is located. To arrive at the base case
foreclosure timeline, Moody's considered the FHA foreclosure
diligence time frames (per HUD guidelines as of February 5, 2016).
It stresses state foreclosure timelines by a multiplicative factor
for various rating levels (e.g., state foreclosure timelines are
multiplied by 1.6x for its Aaa level rating stress).

Debenture interest: The receipt of debenture interest is dependent
upon performance of certain actions within certain timelines by the
servicer. If these timeline and performance benchmarks are not met
by the servicer, debenture interest is subject to curtailment. Its
base case assumption is that 90.0% of debenture interest will be
received by the trust. Moody's stressed the amount of debenture
interest that will be received at higher rating levels. The
debenture interest assumptions reflect the requirement that FAR
reimburse the trust for debenture interest curtailments due to
servicing errors or failures to comply with HUD guidelines.
However, the transaction documents do not specify a required time
frame within which the servicer must reimburse the trust for
debenture interest curtailments. As such, there may be a delay
between when insurance payments are received and when debenture
interest curtailments are reimbursed. The debenture interest
assumptions take this into consideration. Its assumption for
recovered debenture interest is low compared to prior FASST
transactions due to the relatively high percentage of missed
servicing milestone mortgage assets in the pool.

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

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

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

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

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

Moody's also ran additional stress scenarios that were designed to
mimic expected cash flows in the scenario where FAR is no longer
the servicer. It assumed the following in such a scenario:

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

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

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

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

Furthermore, to account for risks posed by Puerto Rico loans,
Moody's considered the following for mortgage assets backed by
properties in Puerto Rico:

  - To account for delays in the foreclosure process in Puerto Rico
due to the hurricanes, Moody's used five years as its full stress
foreclosure timeline and scaled the impact down the rating levels.

  - Moody's assumed that all insurance claims would be submitted as
ABCs under its Aaa rating stress and scaled this percentage down at
lower rating levels. In addition, for ABCs Moody's assumed that
properties will sell for significantly lower than their appraised
values.

  - Due to the significant Puerto Rico concentration for this
transaction, Moody's also applied haircuts to the modeled cash
flows for Puerto Rico mortgage assets.

To account for potential extension of timelines due to Chapter 13
bankrupt loans, Moody's extended the foreclosure timeline by an
additional 24 months in the base case scenario and scaled this
extension up for higher rating levels.

In addition, for high rating scenarios, Moody's increased
foreclosure timelines by three months for RMS sub-serviced loans in
its analysis. Celink is a backup servicer for RMS. If RMS is
terminated as sub-servicer by FAR it will take 90 days to transfer
sub-servicing from RMS to Celink.

Moody's also applied a small adjustment in its analysis to account
for the risks associated with certain damaged properties that are
located in areas impacted by recent hurricanes.

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

Up

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

Down

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


FIRST FRANKLIN 2006-FFH1: Moody's Cuts Class M-1 Debt Rating to B1
------------------------------------------------------------------
Moody's Investors Service has downgraded the rating of Cl. M-1 from
First Franklin Mortgage Loan Trust 2006-FFH1, backed by subprime
loans.

Complete rating actions are as follows:

Issuer: First Franklin Mortgage Loan Trust 2006-FFH1

Cl. M-1, Downgraded to B1 (sf); previously on May 18, 2017 Upgraded
to Ba2 (sf)

RATINGS RATIONALE

The rating downgrade on Cl. M-1 is primarily due to outstanding
interest shortfall incurred during the February 2019 remittance
cycle, which is not expected to be recouped as the bond has a weak
structural mechanism to reimburse unpaid interest shortfalls. The
rating actions also reflect the recent performance and Moody's
updated loss expectation on the underlying 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 3.8% in March 2019 from 4.0% in March
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.


FREDDIE MAC 2019-HQA2: S&P Assigns Ratings to 23 Classes of Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Freddie Mac
STACR Trust 2019-HQA2's notes.

The note issuance is a residential mortgage-backed securities
transaction backed by fully amortizing high loan-to-value
first-lien fixed-rate residential mortgage loans secured by one- to
four-family residences, planned-unit developments, condominiums,
cooperatives, and manufactured housing, to mostly prime borrowers.

The preliminary ratings are based on information as of April 26,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The credit enhancement provided by the subordinated reference
tranches, as well as the associated structural deal mechanics;

-- The credit quality of the collateral included in the reference
pool--a majority of such collateral is covered by mortgage
insurance backstopped by Freddie Mac;

-- A credit-linked note structure that reduces the counterparty
exposure to Freddie Mac for periodic principal payments but, at the
same time, relies on credit premium payments from Freddie Mac (a
highly rated counterparty) to make monthly interest payments and to
make up for any investment losses;

-- The issuer's aggregation experience and alignment of interests
between the issuer and noteholders in the deal's performance,
which, in S&P's view, enhances the notes' strength; and

-- The enhanced credit risk management and quality control
processes Freddie Mac uses in conjunction with the underlying
representations and warranties framework.

  PRELIMINARY RATINGS ASSIGNED

  Freddie Mac STACR Trust 2019-HQA2

  Class       Rating                Amount ($)
  A-H(i)      NR                18,626,873,629
  M-1         BBB (sf)             140,000,000
  M-1H(i)     NR                    55,045,797
  M-2         B+ (sf)              280,000,000
  M-2R        B+ (sf)              280,000,000
  M-2S        B+ (sf)              280,000,000
  M-2T        B+ (sf)              280,000,000
  M-2U        B+ (sf)              280,000,000
  M-2I        B+ (sf)              280,000,000
  M-2A        BB+ (sf)             140,000,000
  M-2AR       BB+ (sf)             140,000,000
  M-2AS       BB+ (sf)             140,000,000
  M-2AT       BB+ (sf)             140,000,000
  M-2AU       BB+ (sf)             140,000,000
  M-2AI       BB+ (sf)             140,000,000
  M-2AH(i)    NR                    55,045,797
  M-2B        B+ (sf)              140,000,000
  M-2BR       B+ (sf)              140,000,000
  M-2BS       B+ (sf)              140,000,000
  M-2BT       B+ (sf)              140,000,000
  M-2BU       B+ (sf)              140,000,000
  M-2BI       B+ (sf)              140,000,000
  M-2RB       B+ (sf)              140,000,000
  M-2SB       B+ (sf)              140,000,000
  M-2TB       B+ (sf)              140,000,000
  M-2UB       B+ (sf)              140,000,000
  M-2BH(i)    NR                    55,045,797
  B-1         NR                   125,000,000
  B-1A        NR                    62,500,000
  B-1AR       NR                    62,500,000
  B-1AI       NR                    62,500,000
  B-1AH(i)    NR                    25,270,609
  B-1B        NR                    62,500,000
  B-1BH(i)    NR                    25,270,609
  B-2         NR                    70,000,000
  B-2A        NR                    35,000,000
  B-2AR       NR                    35,000,000
  B-2AI       NR                    35,000,000
  B-2AH(i)    NR                    13,761,449
  B-2B        NR                    35,000,000
  B-2BH(i)    NR                    13,761,449
  B-3H(i)     NR                    19,504,580

(i)Reference tranche only and will not have corresponding notes.
Freddie Mac retains the risk of each of these tranches.
NR--Not rated.


FREED ABS 2019-1: DBRS Gives Prov. BB(high) Rating on $56MM C Notes
-------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
notes (the Notes) to be issued by FREED ABS Trust 2019-1 (FREED
2019-1):

-- $249,550,000 Class A Notes at A (sf)
-- $102,090,000 Class B Notes at BBB (high) (sf)
-- $56,710,000 Class C Notes at BB (high) (sf)

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

(1) The transaction's form and sufficiency of available credit
enhancement.

   -- Subordination, over-collateralization, amounts held in the
      Reserve Fund and excess spread creates credit enhancement
levels
      that are commensurate with the proposed ratings.

   -- Transaction cash flows are sufficient to repay investors
under
      all A (sf), BBB (high) (sf) and BB (high) (sf) stress
scenarios
      in accordance with the terms of the FREED 2019-1 transaction

      documents.

(2) Structural features of the transaction that requires the Notes
to enter into full turbo principal amortization if certain triggers
are breached or if credit enhancement deteriorates.

(3) The experience, underwriting and servicing capabilities of
Freedom Financial Asset Management, LLC (FFAM).

(4) The experience, underwriting and origination capabilities of
Cross River Bank.

(5) The ability of Wilmington Trust National Association (rated A
(high) with a Positive trend by DBRS) to perform duties as a Backup
Servicer and the ability of Portfolio Financial Servicing Company
to perform duties as a Backup Servicer Subcontractor.

(6) The annual percentage rate (APR) charged on the loans and CRB's
status as the true lender.

  -- All loans included in FREED 2019-1 are originated by CRB, a
     New Jersey state-chartered FDIC-insured bank.

  -- Loans originated by CRB are all within the New Jersey state
     usury limit of 30.00%.

  -- The weighted-average (WA) APR of the loans in the pool is
     22.11%.

  -- Loans may be in excess of individual state usury laws;
     however, CRB as the true lender is able to export rates
     that preempt state usury rate caps.

  -- Loans originated to borrowers in states with active
     litigation (Second Circuit (New York, Connecticut,
     Vermont), Colorado, and West Virginia) are excluded
     from the pool.

  -- The FREED 2019-1 loan pool includes loans originated
     to borrowers in Maryland, a state with active litigation.
     DBRS incorporated an additional stressed cash flow
     analysis assuming that loans to borrowers in Maryland
     with APR's above the state usury cap of 24% were
     subsequently reduced to the state usury cap. Transaction
     cash flows are sufficient to repay investors under all
     A (sf), BBB (high) (sf) and BB (high) (sf) stress scenarios.

  -- Under the Loan Sale Agreement, FFAM is obligated to
     repurchase any loan if there is a breach of representation
     and warranty that materially and adversely affects the
     interests of the purchaser.

(7) The legal structure and expected legal opinions that will
address the true sale of the personal loans, the non-consolidation
of the trust, that the trust has a valid first-priority security
interest in the assets and consistency with the DBRS "Legal
Criteria for U.S. Structured Finance."


J.P. MORGAN 2019-ICON: S&P Assigns Prelim B- Rating to Class F Cert
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to J.P. Morgan
Chase Commercial Mortgage Securities Trust 2019-ICON UES'
commercial mortgage pass-through certificates.

The certificate issuance is a CMBS transaction backed by the fee
interest in 19 multifamily properties located throughout the Upper
East Side neighborhood of Manhattan in New York City.

The preliminary ratings are based on information as of April 29,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect S&P Global Ratings' view of the
collateral's historic and projected performance; the sponsor's and
the manager's experience; the trustee-provided liquidity; the loan
terms; and the transaction's structure.

  PRELIMINARY RATINGS ASSIGNED
  J.P. Morgan Chase Commercial Mortgage Securities Trust 2019-ICON

  UES

  Class              Rating(i)   Amount (mil. $)
  A                  AAA (sf)               6.71
  X-A                AAA (sf)               6.71(ii)
  X-B                A- (sf)               11.21(ii)
  B                  AA- (sf)               3.03
  C                  A- (sf)                8.18
  D                  BBB- (sf)              8.37
  E                  BB- (sf)               9.74
  F                  B- (sf)               10.22
  G                  NR                    16.16
  RR interest(iii)   NR                     3.29

(i)The issuer will issue the certificates to qualified
institutional buyers in line with Rule 144A of the Securities Act
of 1933.
(ii)Notional balance. The notional amount of the class X-A
certificates will equal the certificate balance of the class A
certificates and the notional amount of the class X-B certificates
will equal the aggregate certificate balances of the class B and C
certificates.
(iii)Non-offered vertical risk retention certificates, which will
be retained by JPMorgan Chase Bank N.A. as the retaining sponsor.
NR--Not rated.


JP MORGAN 2006-LDP9: Moody's Cuts Class A-MS Certs Rating to 'B1'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on three
classes, downgraded the rating on one class and affirmed the
ratings on three classes in J.P. Morgan Chase Commercial Mortgage
Securities Corp., Commercial Pass-Through Certificates, Series
2006-LDP9.

Cl. A-3SFL, Upgraded to Aaa (sf); previously on Mar 30, 2018
Affirmed Aa1 (sf)

Cl. A-3SFX, Upgraded to Aaa (sf); previously on Mar 30, 2018
Affirmed Aa1 (sf)

Cl. A-M, Upgraded to Baa2 (sf); previously on Mar 30, 2018 Affirmed
Ba1 (sf)

Cl. A-MS, Downgraded to B1 (sf); previously on Mar 30, 2018
Affirmed Ba1 (sf)

Cl. A-J, Affirmed Ca (sf); previously on Mar 30, 2018 Affirmed Ca
(sf)

Cl. A-JS, Affirmed Ca (sf); previously on Mar 30, 2018 Affirmed Ca
(sf)

Cl. X*, Affirmed C (sf); previously on Mar 30, 2018 Affirmed C
(sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on Cl. A-3SFL and Cl. A-3SFX were upgraded based
primarily on an increase in credit support resulting from loan
paydowns as well as expected recoveries from the remaining loans in
loan group S.

The rating on Cl. A-M was upgraded due to an increase in credit
support from loan paydowns as well as the distribution priority
from the remaining loans included in loan group R. The balance of
Cl. A-M has already been paid down 96% from securitization.

The rating on Cl. A-MS was downgraded based on collateral metrics
of loan group S, including Moody's loan-to-value (LTV) ratio, and
the class's exposure to modified and special serviced loans. The
principal paydown of Cl. A-MS is primarily dependent on the
remaining collateral in loan group S, which includes only the
Sugarloaf Mills loan (formerly known as Discover Mills) and the
Colony IV Portfolio. Additionally, Cl. A-MS has experienced monthly
interest shortfalls for the past three months.

The ratings on Cl. A-J and A-JS were affirmed because the ratings
are consistent with Moody's expected loss plus realized losses.

The rating on the IO class, Cl. X, was affirmed based on the credit
quality of its referenced classes.

Moody's rating action reflects a base expected loss of 41.5% of the
current pooled balance, compared to 44.5% at Moody's last review.
Moody's base expected loss plus realized losses is now 16.7% of the
original pooled balance, the same as 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, an increase in realized and
expected losses from specially serviced and troubled loans or
interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in rating all classes except
interest-only classes was "Moody's Approach to Rating Large Loan
and Single Asset/Single Borrower CMBS" published in July 2017. The
methodologies used in rating interest-only classes were "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

DEAL PERFORMANCE

As of the April 15, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 89% to $527.9
million from $4.85 billion at securitization. The certificates are
collateralized by 11 mortgage loans ranging in size from less than
1% to 37.9% of the pool. The remaining pool is divided into two
loan groups, Group S and Group R. The Sugarloaf Mills Loan
(formerly known as Discover Mills) and the Colony IV Portfolio are
the only remaining loans in loan group S.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 4, compared to the 9 at Moody's last review.

Four loans, constituting 20.3% 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.

Sixty-five loans have been liquidated from the pool at a loss,
contributing to an aggregate realized loss of $589.9 million. Loans
representing 34.7% of the pool are currently in special servicing.
The largest specially serviced exposure is the Colony IV Portfolio
($144.1 million -- 27.3% of the pool), which was originally secured
by a twenty-five property portfolio, totaling 2.4 million SF and
located across six states. The loan transferred to the special
servicer in September 2014 due to imminent default. The special
servicer indicated all twenty-five properties are now sold, with
the sale of the last property closing in April 2019.

The second largest specially serviced exposure represents 7.2% of
the pool and is secured by an anchored retail center in Las Vegas,
Nevada. The third largest specially serviced loan is secured by a
multifamily property and represents only 0.2% of the pool.

In addition to the specially serviced loans, Moody's has also
identified one troubled loan representing 6.8% of the pool. Moody's
estimates an aggregate $177 million loss for the specially serviced
and troubled loans (81% expected loss on average).

Moody's received full year 2017 operating results for 64% of the
pool, and full or partial year 2018 operating results for 75% of
the pool. Moody's weighted average conduit LTV is 124%, essentially
the same as at Moody's last review. Moody's conduit component
includes seven loans and excludes specially serviced and troubled
loans.

The top three performing loans represent 57.6% of the pool balance.
The largest loan is the 131 South Dearborn A-Note Loan ($200.0
million -- 37.9% of the pool), which is secured by a 1.5 million
SF, 37-story, Class A office building (also known as the Citadel
Center) located in Chicago's Central Loop office submarket. The
A-note represents a pari passu portion of a $400.0 million first
mortgage loan. The property is situated along the east-side of
South Dearborn Street, between Adams and Marble Place. The property
has large 64,000 SF floor plates on floors 1-10 and 34,000 SF floor
plates between floors 11-37. In May 2014, the property was
transferred to the special servicer due to imminent default and the
loan was subsequently modified in June 2016. The modification
included an A-Note/ B-Note split, which carved out a $72.0 million
B-note from the original $472.0 million first mortgage loan. The
modification also resulted in the formation of a new ownership
structure, a joint-venture between Angelo Gordon and Hines. A $100
million capital improvement plan that includes lobby and elevator
renovations and construction of a new conference center was
completed in 2018. The property was 86% leased as of November 2018,
compared to 75% in September 2017. Moody's identified the B-Note as
a troubled loan and assumed a significant loss. Moody's LTV on the
A-note is 124%, the same as at Moody's last review.

The second largest performing loan is the Sugarloaf Mills loan
(formerly known as Discover Mills) ($101.1 million -- 19.1% of the
pool), which is secured by 1.2 million SF regional mall in
Lawrenceville, Georgia approximately 20 miles northeast of the
Atlanta CBD. The property's anchors include Bass Pro Shops
Outdoors, Medieval Times, Burlington Coat Factory, an 18-screen AMC
Theatre and Dave & Busters. Other major tenants include Last Call
by Neiman Marcus, Saks Off Fifth Avenue, Old Navy and Nike Factory
Store. The loan has transferred to specially servicing and was
modified multiple times but most recently transferred to September
2018 due to an imminent monetary default. The most recent
modification included a maturity extension through December 2021.
The property was 85% leased as of December 2018, however, inline
occupancy stands at only 67%. Inline sales (tenants


JP MORGAN 2007-LDP10: Fitch Affirms Csf Rating on A-JFX Certs
-------------------------------------------------------------
Fitch Ratings has affirmed 24 classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust, commercial mortgage
pass-through certificates series 2007-LDP10 (JPMCC 2007-LDP10).

KEY RATING DRIVERS

High Expected Losses and Specially Serviced Loan Concentrations:
Eleven of the remaining 15 loans, representing 97.1% of the pool,
have transferred to special servicing. Repayment of the senior most
class is largely reliant on proceeds from dispositions of the
specially serviced loans/assets, and losses are considered
inevitable on the remaining classes. The remaining non-specially
serviced loans mature in 2022.

Increasing Credit Enhancement: While the senior class has
experienced increased credit enhancement since Fitch's prior rating
action, repayment is reliant on dispositions of the specially
serviced loans. The ultimate timing of dispositions and recovery
remain uncertain.

Pool Concentration/Adverse Selection: The pool is concentrated with
15 loans remaining, compared to 223 loans at issuance. Eleven of
these are in special servicing, which includes one loan (43.26% of
the pool) that was previously modified into an A/B note structure
and another loan (6.44% of the pool) previously modified into an
A/B/C note structure. Six loans have disposed since Fitch's last
rating action resulting in paydown of $33.84 million and losses of
$6.99 million.

RATING SENSITIVITIES

Downgrades to the distressed classes to 'Dsf' are likely as losses
are incurred. While credit enhancement for class A-M remains high,
upgrades are not expected unless recoveries exceed current loss
projections.

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:

  -- $43,412,244 class A-M at 'CCCsf'; RE 90%;

  -- $200,694,000 class A-J at 'Csf'; RE 0%;

  -- $55,388,333 class A-JS at 'Csf'; RE 0%;

  -- $100,000,000 class A-JFX at 'Csf'; RE 0%;

  -- $47,278,064 class B at 'Dsf'; RE 0%;

  -- $22,927,306 class B-S at 'Dsf'; RE 0%;

  -- $0 class C at 'Dsf'; RE 0%;

  -- $0 class C-S at 'Dsf'; RE 0%;

  -- $0 class D at 'Dsf'; RE 0%;

  -- $0 class D-S at 'Dsf'; RE 0%;

  -- $0 class E at 'Dsf'; RE 0%;

  -- $0 class E-S at 'Dsf'; RE 0%;

  -- $0 class F at 'Dsf'; RE 0%;

  -- $0 class F-S at 'Dsf'; RE 0%;

  -- $0 class G at 'Dsf'; RE 0%;

  -- $0 class G-S at 'Dsf'; RE 0%;

  -- $0 class H at 'Dsf'; RE 0%;

  -- $0 class H-S at 'Dsf'; RE 0%;

  -- $0 class J at 'Dsf'; RE 0%;

  -- $0 class K at 'Dsf'; RE 0%;

  -- $0 class L at 'Dsf'; RE 0%;

  -- $0 class M at 'Dsf'; RE 0%;

  -- $0 class N at 'Dsf'; RE 0%;

  -- $0 class P at 'Dsf'; RE 0%.

The class A-1, A-1S, A-2, A-2S, A-2SFX, A-2SFL, A-3, A-3S, A-1A and
A-MS certificates have paid in full. Fitch does not rate the fully
depleted class NR certificates. Fitch previously withdrew the
rating on the interest-only class X certificates and the class
A-JFL certificates.


JP MORGAN 2019-3: DBRS Gives Prov. B Rating on $775,000 B-5 Certs
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following Mortgage
Pass-Through Certificates, Series 2019-3 to be issued by J.P.
Morgan Mortgage Trust 2019-3:

-- $364.1 million Class A-1 at AAA (sf)
-- $340.8 million Class A-2 at AAA (sf)
-- $272.7 million Class A-3 at AAA (sf)
-- $204.5 million Class A-4 at AAA (sf)
-- $68.2 million Class A-5 at AAA (sf)
-- $160.6 million Class A-6 at AAA (sf)
-- $112.0 million Class A-7 at AAA (sf)
-- $43.9 million Class A-8 at AAA (sf)
-- $54.5 million Class A-9 at AAA (sf)
-- $13.7 million Class A-10 at AAA (sf)
-- $68.2 million Class A-11 at AAA (sf)
-- $68.2 million Class A-11-X at AAA (sf)
-- $68.2 million Class A-12 at AAA (sf)
-- $68.2 million Class A-13 at AAA (sf)
-- $23.2 million Class A-14 at AAA (sf)
-- $23.2 million Class A-15 at AAA (sf)
-- $291.3 million Class A-16 at AAA (sf)
-- $72.8 million Class A-17 at AAA (sf)
-- $364.1 million Class A-X-1 at AAA (sf)
-- $364.1 million Class A-X-2 at AAA (sf)
-- $68.2 million Class A-X-3 at AAA (sf)
-- $23.2 million Class A-X-4 at AAA (sf)
-- $4.6 million Class B-1 at AA (sf)
-- $7.7 million Class B-2 at A (sf)
-- $4.8 million Class B-3 at BBB (sf)
-- $3.3 million Class B-4 at BB (sf)
-- $775.0 thousand Class B-5 at B (sf)

Classes A-11-X, A-X-1, A-X-2, A-X-3 and A-X-4 are interest-only
notes. The class balances represent notional amounts.

Classes A-1, A-2, A-3, A-4, A-5, A-7, A-12, A-13, A-14, A-16, A-17,
A-X-2 and A-X-3 are exchangeable certificates. These classes can be
exchanged for a combination of depositable certificates as
specified in the offering documents.

Classes A-2, A-3, A-4, A-5, A-6, A-7, A-8, A-9, A-10, A-11, A-12
and A-13 are super-senior certificates. These classes benefit from
additional protection from the senior support certificates (Classes
A-14 and A-15) with respect to loss allocation.

The AAA (sf) ratings on the Certificates reflect the 6.00% of
credit enhancement provided by subordinated certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 4.80%, 2.80%, 1.55%, 0.70% and 0.50% of credit enhancement,
respectively.

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

The Certificates are backed by 591 loans with a total principal
balance of $387,326,703 as of the Cut-Off Date (April 1, 2019).

The pool consists of fully amortizing fixed-rate mortgages with
original terms to maturity of 30 years. Approximately 39.2% of the
loans in the pool are conforming mortgage loans predominantly
originated by JPMorgan Chase Bank, N.A. (JPMCB; rated AA with a
Stable trend by DBRS) and AmeriHome Mortgage Company, LLC
(AmeriHome), which were eligible for purchase by Fannie Mae or
Freddie Mac. JPMCB generally delegates conforming loan underwriting
authority to correspondent lenders and does not subsequently review
those loans. Details on the underwriting of conforming loans can be
found in the Key Probability of Default Drivers section of the
related presale report.

The originators for the aggregate mortgage pool are United Shore
Financial Services, LLC doing business as (dba) United Wholesale
Mortgage and Shore Mortgage (24.3%), JPMCB (22.3%), AmeriHome
(15.8%), loanDepot.com, LLC (10.1%), Quicken Loans Inc. (7.2%) and
various other originators, each comprising less than 5.0% of the
mortgage loans. Approximately 14.0% of the loans sold to the
mortgage loan seller were acquired by MAXEX Clearing LLC, which
purchased such loans from the related originators or an
unaffiliated third party that directly or indirectly purchased such
loans from the related originators.

The mortgage loans will be serviced or sub-serviced by NewRez LLC
formerly known as New Penn Financial, LLC dba Shellpoint Mortgage
Servicing, LLC (SMS, 60.0%), JPMCB (22.3%), Cenlar FSB (15.8%) and
Nationstar Mortgage LLC (Nationstar, 1.8%). Servicing will be
transferred from SMS to JPMCB on the servicing transfer date (June
1, 2019, or a later date) as determined by the issuing entity and
JPMCB. For this transaction, the servicing fee payable for mortgage
loans serviced by JPMCB and SMS (which will be subsequently
serviced by JPMCB), is composed of three separate components: the
aggregate base servicing fee, the aggregate delinquent servicing
fee, and the aggregate additional servicing fee. These fees vary
based on the delinquency status of the related loan and will be
paid from interest collections before distribution to the
securities.

Nationstar will act as the Master Servicer. Citibank, N.A. (rated
AA (low) with a Stable trend by DBRS) will act as Securities
Administrator and Delaware Trustee. JPMCB and Wells Fargo Bank,
N.A. (rated AA with a Stable trend by DBRS) will act as Custodians.
Pentalpha Surveillance LLC will serve as the representations and
warranties (R&W) Reviewer.

The transaction employs a senior-subordinate, shifting-interest
cash flow structure that is enhanced from a pre-crisis structure.

The ratings reflect transactional strengths that include
high-quality underlying assets, well-qualified borrowers and a
satisfactory third-party due diligence review.

This transaction employs an R&W framework that contains certain
weaknesses, such as materiality factors, some unrated R&W
providers, knowledge qualifiers and sunset provisions that allow
for certain R&Ws to expire within three to six years after the
Closing Date. The framework is perceived by DBRS to be limiting
compared with traditional lifetime R&W standards in certain
DBRS-rated securitizations. To capture the perceived weaknesses in
the R&W framework, DBRS reduced the originator scores in this pool.
A lower originator score results in increased default and loss
assumptions and provides additional cushions for the rated
securities.


JP MORGAN 2019-3: Moody's Assigns B3 Rating on Class B-5 Debt
-------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to 22
classes of residential mortgage-backed securities issued by J.P.
Morgan Mortgage Trust 2019-3. The ratings range from Aaa (sf) to B3
(sf).

The certificates are backed by 591 30-year, fully-amortizing
fixed-rate mortgage loans with a total balance of $387,326,703 as
of the April 1, 2019 cut-off date. Similar to prior JPMMT
transactions, JPMMT 2019-3 includes conforming mortgage loans (39%
by loan balance) mostly originated by United Shore Financial
Services, LLC d/b/a United Wholesale Mortgage and Shore Mortgage,
JPMorgan Chase Bank, National Association, AmeriHome Mortgage
Company, LLC and LoanDepot.com, LLC underwritten to the government
sponsored enterprises guidelines in addition to prime jumbo
non-conforming mortgages purchased by J.P. Morgan Mortgage
Acquisition Corp., sponsor and mortgage loan seller, from various
originators and aggregators. United Shore, Chase, AmeriHome and
LoanDepot originated 24%, 22%, 16% and 10% of the mortgage pool,
respectively.

Chase, New Penn Financial, LLC d/b/a Shellpoint Mortgage Servicing,
USAA Federal Savings Bank and AmeriHome will be the servicers for
majority of the pool. Shellpoint will act as interim servicer for
these mortgage loans from April 30, 2019 until the servicing
transfer date, which is expected to occur on or about June 1, 2019.
After the servicing transfer date, these mortgage loans will be
serviced by Chase. With respect to the Mortgage Loans serviced by
AmeriHome, Cenlar FSB will be the subservicer and with respect to
the Mortgage Loans serviced by USAA, Nationstar Mortgage LLC will
be the subservicer.

The servicing fee for loans serviced by Chase and Shellpoint will
be based on a step-up incentive fee structure with a monthly base
fee of $20 per loan and additional fees for delinquent or defaulted
loans. All other servicers will be paid a monthly flat servicing
fee equal to one-twelfth of 0.25% of the remaining principal
balance of the mortgage loans. Nationstar will be the master
servicer and Citibank, National Association will be the securities
administrator and Delaware trustee. Pentalpha Surveillance LLC will
be the representations and warranties breach reviewer.
Distributions of principal and interest and loss allocations are
based on a typical shifting interest structure that benefits from
senior and subordination floors.

The complete rating actions are as follows:

Issuer: J.P. Morgan Mortgage Trust 2019-3

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-4, Definitive Rating Assigned Aaa (sf)

Cl. A-5, Definitive Rating Assigned Aaa (sf)

Cl. A-6, Definitive Rating Assigned Aaa (sf)

Cl. A-7, Definitive Rating Assigned Aaa (sf)

Cl. A-8, Definitive Rating Assigned Aaa (sf)

Cl. A-9, Definitive Rating Assigned Aaa (sf)

Cl. A-10, Definitive Rating Assigned Aaa (sf)

Cl. A-11, Definitive Rating Assigned Aaa (sf)

Cl. A-12, Definitive Rating Assigned Aaa (sf)

Cl. A-13, Definitive Rating Assigned Aaa (sf)

Cl. A-14, Definitive Rating Assigned Aa2 (sf)

Cl. A-15, Definitive Rating Assigned Aa2 (sf)

Cl. A-16, Definitive Rating Assigned Aaa (sf)

Cl. A-17, Definitive Rating Assigned Aaa (sf)

Cl. B-1, Definitive Rating Assigned A1 (sf)

Cl. B-2, Definitive Rating Assigned A3 (sf)

Cl. B-3, Definitive Rating Assigned Baa3 (sf)

Cl. B-4, Definitive Rating Assigned Ba2 (sf)

Cl. B-5, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 0.40%
in a base scenario and reaches 6.10% at a stress level consistent
with the Aaa (sf) ratings.

Moody's calculated losses on the pool using its US Moody's
Individual Loan Analysis model based on the loan-level collateral
information as of the cut-off date. Loan-level adjustments to the
model results included adjustments to probability of default for
higher and lower borrower debt-to-income ratios, for borrowers with
multiple mortgaged properties, self-employed borrowers, and for the
default risk of Homeownership association properties in super lien
states. The final loss estimates also incorporate adjustments for
origination quality and the financial strength of representation &
warranty providers.

Moody's bases its definitive ratings on the certificates on the
credit quality of the mortgage loans, the structural features of
the transaction, the origination quality, the servicing
arrangement, the strength of the third party due diligence and the
R&W framework of the transaction.

Aggregation/Origination Quality

Moody's considers JPMMAC's aggregation platform to be adequate and
it did not apply a separate loss-level adjustment for aggregation
quality. In addition to reviewing JPMMAC as an aggregator, it has
also reviewed the originators contributing a significant percentage
of the collateral pool. For these originators, it reviewed their
underwriting guidelines and their policies and documentation (where
available). Moody's increased its base case and Aaa (sf) loss
expectations for certain originators of non-conforming loans, such
as United Shore and AmeriHome, where it does not have clear insight
into the underwriting practices, quality control and credit risk
management. Moody's did not make an adjustment for GSE-eligible
loans, regardless of the originator, since those loans were
underwritten in accordance with GSE guidelines.

Servicing arrangement

Moody's considers the overall servicing arrangement for this pool
to be adequate given the strong servicing arrangement of the
servicers, as well as the presence of a strong master servicer to
oversee the servicers. In this transaction, Nationstar Mortgage LLC
will act as the master servicer. The servicers are required to
advance principal and interest on the mortgage loans. To the extent
that the servicers are unable to do so, the master servicer will be
obligated to make such advances. In the event that the master
servicer, Nationstar (rated B2), is unable to make such advances,
the securities administrator, Citibank (rated Aa3) will be
obligated to do so.

JPMorgan Chase Bank, National Association (servicer): Chase is a
seasoned servicer with over 20 years of experience servicing
residential mortgage loans and has demonstrated adequate servicing
ability as a primary servicer of prime residential mortgage loans.
As of June 30, 2018, Chase was servicing a portfolio of about $762
billion.

Shellpoint Mortgage Servicing (servicer): Shellpoint has
demonstrated adequate servicing ability as a primary servicer of
prime residential mortgage loans. Shellpoint has the necessary
processes, staff, technology and overall infrastructure in place to
effectively service the transaction.

Nationstar Mortgage LLC (master servicer): Nationstar is the master
servicer for the transaction and provides oversight of the
servicers. Moody's considers Nationstar's master servicing
operation to be above average compared to its peers. Nationstar has
strong reporting and remittance procedures and strong compliance
and monitoring capabilities. The company's senior management team
has on average more than 20 years of industry experience, which
provides a solid base of knowledge and leadership. Nationstar's
oversight encompasses loan administration, default administration,
compliance, and cash management. Nationstar is an indirectly held,
wholly owned subsidiary of Nationstar Mortgage Holdings Inc.
Moody's rates  Nationstar Mortgage Holdings Inc. at B2 stable.

Collateral Description

JPMMT 2019-3 is a securitization of a pool of 591 30-year,
fully-amortizing fixed-rate mortgage loans with a total balance of
$387,326,703 as of the cut-off date, with a weighted average
remaining term to maturity of 356 months, and a WA seasoning of 4
months. The borrowers in this transaction have high FICO scores and
sizeable equity in their properties. The WA current FICO score is
767 and the WA original combined loan-to-value ratio is 72.2%. The
characteristics of the loans underlying the pool are generally
comparable to other JPMMT transactions backed by prime mortgage
loans that it has rated.

In this transaction, about 39% of the pool by loan balance was
underwritten to Fannie Mae's and Freddie Mac's guidelines
(conforming loans). The conforming loans in this transaction have a
high average current loan balance at $575,141. The high conforming
loan balance of loans in JPMMT 2019-3 is attributable to the large
number of properties located in high-cost areas, such as the metro
areas of Los Angeles (18%), New York City (10%) and San Francisco
(10%). United Shore, Chase, AmeriHome and LoanDepot originated 24%,
22%, 16% and 10% of the mortgage pool, respectively. The remaining
originators each account for less than 10% of the principal balance
of the loans in the pool.

Servicing Fee Framework

The servicing fee for loans serviced by Chase and Shellpoint will
be based on a step-up incentive fee structure with a monthly base
fee of $20 per loan and additional fees for servicing delinquent
and defaulted loans. The other servicers, AmeriHome and USAA, will
be paid a monthly flat servicing fee equal to one-twelfth of 0.25%
of the remaining principal balance of the mortgage loans.
Shellpoint will act as interim servicer until the servicing
transfer date, June 1, 2019 or such later date as determined by the
issuing entity and Chase.

While this fee structure is common in non-performing mortgage
securitizations, it is relatively new to rated prime mortgage
securitizations which typically incorporate a flat 25 basis point
servicing fee rate structure. By establishing a base servicing fee
for performing loans that increases with the delinquency of loans,
the fee-for-service structure aligns monetary incentives to the
servicer with the costs of the servicer. The servicer receives
higher fees for labor-intensive activities that are associated with
servicing delinquent loans, including loss mitigation, than they
receive for servicing a performing loan, which is less
labor-intensive. The fee-for-service compensation is reasonable and
adequate for this transaction because it better aligns the
servicer's costs with the deal's performance. Furthermore, higher
fees for the more labor-intensive tasks make the transfer of these
loans to another servicer easier, should that become necessary. By
contrast, in typical RMBS transactions a servicer can take actions,
such as modifications and prolonged workouts, that increase the
value of its mortgage servicing rights.

The incentive structure includes an initial monthly base servicing
fee of $20 for all performing loans and increases according to a
pre-determined delinquent and incentive servicing fee schedule.

The delinquent and incentive servicing fees will be deducted from
the available distribution amount and Class B-6 net WAC. The
transaction does not have a servicing fee cap, so, in the event of
a servicer replacement, any increase in the base servicing fee
beyond the current fee will be paid out of the available
distribution amount.

Third-party Review and Reps & Warranties

Four third party review firms verified the accuracy of the
loan-level information that itreceived from the sponsor. These
firms conducted detailed credit, valuation, regulatory compliance
and data integrity reviews on 100% of the mortgage pool. The TPR
results indicated compliance with the originators' underwriting
guidelines for the vast majority of loans, no material compliance
issues, and no appraisal defects. The loans that had exceptions to
the originators' underwriting guidelines had strong documented
compensating factors such as low DTIs, low LTVs, high reserves,
high FICOs, or clean payment histories. The TPR firms also
identified minor compliance exceptions for reasons such as
inadequate RESPA disclosures (which do not have assignee liability)
and TILA/RESPA Integrated Disclosure violations related to fees
that were out of variance but then were cured and disclosed.
Moody's did not make any adjustments to its expected or Aaa (sf)
loss levels due to the TPR results.

JPMMT 2019-3's R&W framework is in line with that of other JPMMT
transactions where an independent reviewer is named at closing, and
costs and manner of review are clearly outlined at issuance. Its
review of the R&W framework takes into account the financial
strength of the R&W providers, scope of R&Ws (including qualifiers
and sunsets) and enforcement mechanisms.

The R&W providers vary in financial strength. JPMorgan Chase Bank,
National Association (rated Aa2) is the R&W provider for
approximately 22% (by loan balance) of the pool. Moody's made no
adjustments to the loans for which Chase and USAA Federal Savings
Bank (a subsidiary of USAA Capital Corporation which is rated Aa1)
provided R&Ws since they are highly rated entities. In contrast,
the rest of the R&W providers are unrated and/or financially weaker
entities. Moody's applied an adjustment to the loans for which
these entities provided R&Ws. No party will backstop or be
responsible for backstopping any R&W providers who may become
financially incapable of repurchasing mortgage loans.

For loans that JPMMAC acquired via the MAXEX platform, MAXEX under
the assignment, assumption and recognition agreement with JPMMAC,
will make the R&Ws. The R&Ws provided by MAXEX to JPMMAC and
assigned to the trust are in line with the R&Ws found in the JPMMT
transactions. Five Oaks Acquisition Corp. will backstop the
obligations of MaxEx with respect to breaches of the mortgage loan
representations and warranties made by MaxEx.

Trustee and Master Servicer

The transaction Delaware trustee is Citibank. The custodian's
functions will be performed by Wells Fargo Bank, N.A. and Chase.
The paying agent and cash management functions will be performed by
Citibank. Nationstar Mortgage LLC, as master servicer, is
responsible for servicer oversight, and termination of servicers
and for the appointment of successor servicers. In addition,
Nationstar is committed to act as successor if no other successor
servicer can be found. The master servicer is required to advance
principal and interest if the servicer fails to do so. If the
master servicer fails to make the required advance, the securities
administrator is obligated to make such advance.

Tail Risk & Subordination Floor

This deal has a standard shifting-interest structure, with a
subordination floor to protect against losses that occur late in
the life of the pool when relatively few loans remain (tail risk).
When the total senior subordination is less than 1.70% of the
original pool balance, the subordinate bonds do not receive any
principal and all principal is then paid to the senior bonds. In
addition, if the subordinate percentage drops below 6.00% of
current pool balance, the senior distribution amount will include
all principal collections and the subordinate principal
distribution amount will be zero. The subordinate bonds themselves
benefit from a floor. When the total current balance of a given
subordinate tranche plus the aggregate balance of the subordinate
tranches that are junior to it amount to less than 1.20% of the
original pool balance, those tranches do not receive principal
distributions. The principal those tranches would have received is
directed to pay more senior subordinate bonds pro-rata.

Transaction Structure

The transaction uses the shifting interest structure in which the
senior bonds benefit from a number of protections. Funds collected,
including principal, are first used to make interest payments to
the senior bonds. Next, principal payments are made to the senior
bonds. Next, available distribution amounts are used to reimburse
realized losses and certificate write-down amounts for the senior
bonds (after subordinate bond have been reduced to zero i.e. the
credit support depletion date). Finally, interest and then
principal payments are paid to the subordinate bonds in sequential
order.

Realized losses are allocated in a reverse sequential order, first
to the lowest subordinate bond. After the balance of the
subordinate bonds is written off, losses from the pool begin to
write off the principal balance of the senior support bond, and
finally losses are allocated to the super senior bonds.

In addition, the pass-through rate on the bonds (other than the
Class A-R Certificates) is based on the net WAC as reduced by the
sum of (i) the reviewer annual fee rate and (ii) the capped trust
expense rate. In the event that there is a small number of loans
remaining, the last outstanding bonds' rate can be reduced to
zero.

The Class A-11 Certificates will have a pass-through rate that will
vary directly with the rate of one-month LIBOR and the Class A-11-X
Certificates will have a pass-through rate that will vary inversely
with the rate of one-month LIBOR.

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 of the subordinate bonds 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.

Methodology

The principal methodology used in these ratings was "Moody's
Approach to Rating US Prime RMBS" published in November 2018.


KANYE CLO: Moody's Assigns Ba3 Rating on $16.95MM Class E Notes
---------------------------------------------------------------
Moody's Investors Service has assigned ratings to six classes of
debt issued by Kayne CLO 4, Ltd.

Moody's rating action is as follows:

US$192,000,000 Class A Loans due 2032 (the "Class A Loans"),
Assigned Aaa (sf)

US$21,950,000 Class B-1 Senior Secured Floating Rate Notes due 2032
(the "Class B-1 Notes"), Assigned Aa2 (sf)

US$10,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2032
(the "Class B-2 Notes"), Assigned Aa2 (sf)

US$13,950,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes due 2032 (the "Class C Notes"), Assigned A2 (sf)

US$17,700,000 Class D Mezzanine Secured Deferrable Floating Rate
Notes due 2032 (the "Class D Notes"), Assigned Baa3 (sf)

US$16,950,000 Class E Junior Secured Deferrable Floating Rate Notes
due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

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

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 its methodology.

Kayne CLO 4, Ltd. is a managed cash flow CLO. The issued debt will
be collateralized primarily by broadly syndicated senior secured
corporate loans. At least 95% of the portfolio must consist of
first lien senior secured loans, cash, and eligible investments,
and up to 5% of the portfolio may consist of second lien loans and
unsecured loans. The portfolio is approximately 80% ramped as of
the closing date.

Kayne Anderson Capital Advisors, L.P. 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, subject to certain restrictions, the Manager may
reinvest unscheduled principal payments and proceeds from sales of
credit risk assets.

In addition to the Rated Debt, 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 debt 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: $300,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2900

Weighted Average Spread (WAS): 3.25%

Weighted Average Coupon (WAC): 7.00%

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 Rated Debt is subject to uncertainty. The
performance of the Rated Debt 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 Debt.



MELLO WAREHOUSE 2019-1: Moody's Gives '(P)Ba2' Rating on E Debt
---------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to five
classes of residential mortgage-backed securities issued by Mello
Warehouse Securitization Trust 2019-1. The ratings range from
(P)Aaa (sf) to (P)Ba2 (sf).

Mello Warehouse Securitization Trust 2019-1 is a securitization
backed by a revolving warehouse facility sponsored by
loanDepot.com, LLC (loanDepot, the repo seller, unrated). The
securities are backed by a revolving pool of newly originated
first-lien, fixed rate and adjustable rate, residential mortgage
loans which are eligible for purchase by Fannie Mae and Freddie Mac
or in accordance with the criteria of Ginnie Mae for the guarantee
of securities backed by mortgage loans to be pooled in connection
with the issuance of Ginnie Mae securities. The pool may also
include FHA Streamline mortgage loans or VA-IRRR mortgage Loans,
which may have limited valuation and documentation. The collateral
pool balance is $300,000,000.

The complete rating actions are as follows:

Issuer: Mello Warehouse Securitization Trust 2019-1

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

Cl. B, Assigned (P)Aa2 (sf)

Cl. C, Assigned (P)A2 (sf)

Cl. D, Assigned (P)Baa2 (sf)

Cl. E, Assigned (P)Ba2 (sf)

RATINGS RATIONALE

Moody's bases its Aaa expected losses of 37.95% and base case
expected losses of 4.60% on a scenario in which loanDepot does not
pay the aggregate repurchase price to pay off the notes at the end
of the facility's two-year revolving term, and the repayment of the
notes will depend on the credit performance of the remaining static
pool of mortgage loans. To assess the credit quality of the static
pool, Moody's created a hypothetical adverse pool based on the
facility's eligibility criteria, which includes no more than 25%
(by unpaid balance) adjustable rate mortgage loans. Moody's
analyzed the pool using its US MILAN model and made additional pool
level adjustments to account for risks related to (i) weaknesses in
the representation and warranty enforcement framework and (ii)
compliance with the TILA-RESPA Integrated Disclosure (TRID) Rule,
based on findings in third-party diligence reports from loanDepot's
prior warehouse securitization, loanDepot Station Place Agency
Securitization Trust 2017-1.

The ratings on the notes during the revolving period will be the
rating of the notes based on the credit quality of the mortgage
loans backing the notes. If the notes are not repaid at the
two-year repo agreement term or loanDepot otherwise defaults on its
obligations as repo seller under the master repurchase agreement,
the ratings on the notes will only reflect the credit of the
mortgage loans backing the notes.

The final rating levels are based on Moody's evaluation of the
credit quality of the collateral as well as the transaction's
structural and legal framework.

Collateral Description:

The mortgage loans will be newly originated, first-lien, fixed-rate
and adjustable rate mortgage loans that also comply with the
eligibility criteria set forth in the master repurchase agreement.
The aggregate principal balance of the purchased loans at closing
will be $300,000,000. Per the transaction documents, the mortgage
pool will have a minimum weighted average FICO of 715 and a maximum
weighted average LTV of 85%.

The ultimate composition of the pool of mortgage loans remaining in
the facility at the end of the two-year term upon default of
loanDepot is unknown. Moody's modeled this risk through evaluating
the credit risk of an adverse pool constructed using the
eligibility criteria. In generating the adverse pool: 1) Moody's
assumed the worst numerical value from the criteria range for each
loan characteristic. For example, the credit score of the loans is
not less than 620 and the weighted average credit score of the
purchased mortgage loans is not less than 715; the maximum
debt-to-income ratio is 55% in the adverse pool (per eligibility
criteria); 2) It assumed risk layering for the loans in the pool
within the eligibility criteria. For example, loans with the
highest LTV also had the lowest FICO to the extent permitted by the
eligibility criteria; and 3) It took into account the specified
restrictions in the eligibility criteria such as the weighted
average LTV and FICO; and 4) Since these loans are eligible for
purchase by Fannie Mae and Freddie Mac, it also took into account
the specified restrictions in the GSE underwriting criteria. For
example, no more than 97% LTV for fixed rate purchased loans and
95% for adjustable rate purchase loans.

The transaction also allows the inclusion of loans whose collateral
documents have not yet been delivered to the custodian. Warehouse
lenders, in general, are more vulnerable to the risk of losses
owing to fraud from wet loans during the time when they do not hold
the collateral documents. However, this transaction includes
several operational mitigants to reduce such risk, including (i) no
more than 25% of the facility may consist of wet loans, (ii)
collateral documents must be delivered to the custodian within
seven business days of a wet loan's origination or it becomes
ineligible, (iii) the transaction will only fund a wet loan if the
custodian receives a closing protection letter indemnifying the
transaction against fraud and misappropriation from one of four
highly rated title insurance companies, whose agents act as the
loan's closing agent, (iv) the transaction will only fund a wet
loan to a pre-approved list of bank account numbers to guard
against the risk of wire hacking, and (v) Deutsche Bank National
Trust Company (Baa1), a highly rated independent counterparty, acts
as the mortgage loan custodian.

The loans will be originated and serviced by loanDepot. U.S. Bank
National Association will be the standby servicer. Moody's
considers the overall servicing arrangement for this pool to be
adequate. At the transaction closing date, the servicer
acknowledges that it is servicing the purchased loans for the joint
benefit of the issuer and the indenture trustee.

Transaction Structure:

Its analysis of the securitization structure includes reviewing
bankruptcy remoteness, assessing the ability of the indenture
trustee to take possession of the collateral in an event of
default, conformity of the collateral with the eligibility criteria
as well as allocation of funds to the notes.

The transaction is structured as a master repurchase agreement
between loanDepot and the Mello Warehouse Securitization Trust
2019-1. The U.S. Bankruptcy Code provides repurchase agreements,
security contracts and master netting agreements a "safe harbor"
from the Bankruptcy Code automatic stay. Due to this safe harbor,
in the event of a bankruptcy of loanDepot, the issuer will be
exempt from the automatic stay and thus, the issuer will be able to
exercise remedies under the master repurchase agreement, which
includes seizing the collateral.

During the revolving period, the repo seller's obligations will
include making timely payments of interest accrued on the notes as
well as the aggregate monthly fees. Failure to make such payments
will constitute a repo trigger event whereby the indenture trustee
will seize the collateral and terminate the repo agreement. It is
expected that the notes will not receive payments of principal
until the expected maturity date or after the occurrence and
continuance of an event of default under the indenture unless the
repo seller makes an optional prepayment. In an event of default,
principal will be distributed sequentially amongst the classes.
Realized losses will be allocated in a reverse sequential order.

In addition, since the pool may consist of both fixed rate and
adjustable rate mortgages, the transaction may be exposed to
potential risk from interest rate mismatch. To account for the
mismatch, Moody's assumed a stressed LIBOR curve by increasing the
one-month LIBOR rate incrementally for a certain period until it
reaches the maximum allowable interest rate as described in the
transaction documents.

Ongoing Due Diligence

During the revolving period, Clayton Services LLC will conduct due
diligence every 90 days on 100 randomly selected loans. The first
sample will be drawn 30 days after the Closing Date. The scope of
the review will include credit underwriting, regulatory compliance,
valuation and data integrity.

Because Moody's analysis is based on a scenario in which the
facility terms out, due diligence reviews provide some control on
the credit quality of the collateral. The due diligence framework
in this transaction combined with the collateral eligibility
controls help mitigate the risks of adverse selection in this
transaction.

While the due diligence review will provide some validation on the
quality of the loans, it may not be fully representative of the
collateral quality of the facility at all times. This is mainly due
to the frequency of the due diligence review, the revolving nature
of the collateral pool, and that the review will be conducted on a
sample basis. Also, by the time the due diligence review is
completed, some of the sampled loans may no longer be in the pool.

Representation and Warranties

For a mortgage loan to qualify as an eligible mortgage loan, the
loan must meet loanDepot's representations and warranties. The
substance of the representations and warranties are consistent with
those in its published criteria for representations and warranties
for U.S. RMBS transactions. After a repo event of default, which
includes the repo seller or buyer's failure to purchase or
repurchase mortgage loans from the facility, the repo seller or
buyer's failure to perform its obligations or comply with
stipulations in the master repurchase agreement, bankruptcy or
insolvency of the buyer or the repo seller, any breach of covenant
or agreement that is not cured within the required period of time,
as well as the repo seller's failure to pay price differential when
due and payable pursuant to the master repurchase agreement, a
delinquent loan reviewer will conduct a review of loans that are
more than 120 days delinquent to identify any breaches of the
representations and warranties provided by the underlying sellers.
Loans that breach the representations and warranties will be put
back to the repo seller for repurchase.

While the transaction has the above described representation and
warranties enforcement mechanism, in the amortization period, after
an event of default where the repo seller did not pay the notes in
full, it is unlikely that the repo seller will repurchase the
loans. In addition, the noteholders (holding 100% of the aggregate
principal amount of all notes) may waive the requirement to appoint
such delinquent loan reviewer.

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

Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of 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 the state of the housing
market.

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 its original expectations as
a result of a weaker collateral composition than that in the
adverse pool, financial distress of any of the counterparties.
Transaction performance also depends greatly on the US macro
economy and housing market.

Significant Influences

Deterioration in economic conditions greater than its current
expectations can have a significant impact on the transaction's
ratings. In addition, this transaction has a high degree of
operational complexity. The failure of any party to perform its
duties can expose the transaction to losses.


METLIFE SECURITIZATION 2019-1: DBRS Gives (P)B Rating on B2 Notes
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following
Residential Mortgage-Backed Notes, Series 2019-1 (the Securities)
to be issued by MetLife Securitization Trust 2019-1 (the Trust):

-- $403.1 million Class A1 at AAA (sf)
-- $324.5 million Class A1A at AAA (sf)
-- $78.5 million Class A1B at AAA (sf)
-- $16.9 million Class M1 at AA (sf)
-- $12.4 million Class M2 at A (sf)
-- $15.3 million Class M3 at BBB (sf)
-- $11.5 million Class B1 at BB (sf)
-- $7.4 million Class B2 at B (sf)

Class A1 is an exchangeable note. This class can be exchanged for
combinations of exchange notes as specified in the offering
documents.

Class A1A is a super-senior note. This class benefits from
additional protection from the senior support note (Class A1B) with
respect to loss allocation.

The AAA (sf) ratings on the Securities reflect the 15.55% of credit
enhancement provided by subordinated notes in the pool. The AA
(sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect 12.00%,
9.40%, 6.20%, 3.80% and 2.25% of credit enhancement, respectively.

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

This transaction is a securitization of a portfolio of seasoned
performing and re-performing first-lien residential mortgages. The
Securities are backed by 2,096 loans with a total principal balance
of $477,272,970 as of the Cut-Off Date (March 31, 2019).
The portfolio is approximately 146 months seasoned, and 84.1% of
the loans are modified. Within the pool, 847 mortgages have
non-interest-bearing deferred amounts, which equate to
approximately 6.0% of the total principal balance.

All the loans were current as of the Cut-Off Date and have all been
zero times 30 days delinquent (0 x 30) for at least the past 24
months under the Mortgage Bankers Association (MBA) delinquency
method. Additionally, 99.98% of the loans have been 0 x 30 for at
least the past 36 months under the MBA delinquency method. None of
the loans are subject to the Consumer Financial Protection Bureau's
Qualified Mortgage rules.

Prior to the Closing Date, Metropolitan Life Insurance Company
(MetLife), in its capacity as the Sponsor and as the Seller,
acquired the loans from various unaffiliated third-party sellers.
As the Sponsor, MetLife and/or one or more majority-owned
affiliates of the Sponsor will collectively acquire and retain a 5%
eligible vertical interest in each class of securities to be issued
(other than the Class R certificates) to satisfy credit risk
retention requirements.

As of the Closing Date, the loans will be serviced by Select
Portfolio Servicing, Inc.

There will not be any advancing of delinquent principal or interest
on any mortgages by the Servicer or any other party to the
transaction; however, the Servicer is obligated to make advances in
respect of homeowner association fees, taxes and insurance,
installment payments on energy improvement liens and reasonable
costs and expenses incurred in the course of servicing and
disposing of properties.

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

The ratings reflect transactional strengths that include underlying
assets that generally performed well through the crisis and an
experienced Servicer. Additionally, a satisfactory third-party due
diligence review was performed on the portfolio with respect to
regulatory compliance, payment history, and data capture as well as
title and tax review. Updated broker price opinions or exterior
appraisals were provided for 100.0% of the pool; however,
reconciliation was not performed on the updated values.

The transaction employs relatively strong representations and
warranties (R&W) framework, but it has a few limitations such as
certain knowledge qualifiers and fewer mortgage loan
representations relative to DBRS criteria for seasoned pools.

The transaction employs an R&W framework that includes a trigger
review event that may result in potential breaches of R&Ws being
reviewed at a much later date, certain knowledge qualifiers and
fewer mortgage loan representations relative to DBRS criteria for
seasoned pools. Mitigating factors include (1) a financially strong
counterparty, MetLife, which is providing mortgage loan R&Ws for
the life of the transaction; (2) significant loan seasoning and
clean performance history in recent years; (3) a comprehensive due
diligence review; (4) a relatively strong R&W enforcement
mechanism, including directing noteholder review and binding
arbitration; and (5) for R&Ws with knowledge qualifiers, even if
the Seller did not have actual knowledge of the breach, the Seller
is still required to remedy the breach in the same manner as if no
knowledge qualifier had been made.

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


METLIFE SECURITIZATION 2019-1: Fitch Rates $7.39MM B2 Notes 'Bsf'
-----------------------------------------------------------------
Fitch Ratings assigns ratings to MetLife Securitization Trust
2019-1 as follows:

  -- $403,057,000 class A1 exchangeable notes 'AAAsf'; Outlook
Stable;

  -- $324,546,000 class A1A notes 'AAAsf'; Outlook Stable;

  -- $78,511,000 class A1B notes 'AAAsf'; Outlook Stable;

  -- $16,943,000 class M1 notes 'AAsf'; Outlook Stable;

  -- $12,409,000 class M2 notes 'Asf'; Outlook Stable;

  -- $15,273,000 class M3 notes 'BBBsf'; Outlook Stable;

  -- $11,455,000 class B1 notes 'BBsf'; Outlook Stable;

  -- $7,397,000 class B2 notes 'Bsf'; Outlook Stable.

Fitch will not be rating the following class:

  -- $10,738,970 class B3 notes.

The notes and certificates are supported by 2,096 seasoned
performing and re-performing mortgages with a total balance of
$477.3 million, which includes $28.5 million, or 6.0%, of the
aggregate pool balance in non-interest-bearing deferred principal
amounts, as of the cutoff date. Principal and interest (P&I) and
loss allocations are based on a traditional senior subordinate,
sequential structure.

The 'AAAsf' rating on the class A1A notes reflects the 32.00%
subordination provided by the 16.45% class A1B, 3.55% class M1,
2.60% class M2, 3.20% class M3, 2.40% class B1, 1.55% class B2, and
2.25% class B3 notes and certificates.

Fitch's ratings on the notes and certificates reflect the credit
attributes of the underlying collateral, the quality of the
representation (rep) and warranty framework, minimal due diligence
findings and the sequential pay structure.

KEY RATING DRIVERS

High Credit Quality (Positive): The notes and certificates are
backed by a pool of high-quality RPL mortgage loans. The weighted
average primary borrower's most recent FICO score of 718 is higher
than most typical RPL RMBS rated by Fitch to date. In addition, the
pool has a current loan-to-value ratio of 75.9%, a sustainable LTV
of 79.6%. The positive attributes are reflected in Fitch's 'AAAsf'
loss expectation of 13.25%.

Clean Current Loans (Positive): Although 84.1% of the pool has been
modified, almost 100% has been clean for 36 months. Borrowers that
have been current for at least three years receive a 35% reduction
to Fitch's 'AAAsf' probability of default while those that have
been current between 24 and 36 months received a 26.25% reduction.

Low Operational Risk (Positive): Operational risk is well
controlled for in this transaction. MetLife Insurance Company is a
global insurance company that is assessed as an 'Average'
aggregator by Fitch based on its ability to meet industry standards
to effectively purchase RPLs. Select Portfolio Servicing, Inc. is
the named servicer for this transaction and is rated 'RPS1-' and
'RSS1' for primary and special servicing functions. MetLife's
retention of at least 5% of the bonds helps to ensure an alignment
of interest between the issuer and investors.

Tier 1 Representation and Warranty (R&W) Framework (Positive):
Fitch assessed the R&W construct for this transaction as a Tier 1.
The framework benefits from an automatic breach review after
certain performance triggers are met, as well as the ability for
over 50% of unaffiliated noteholders to initiate a review. Life of
loan representations and warranties are being provided by MetLife
Insurance Company (rated A+/Stable/F1+ by Fitch). Given the
financial rating and framework of MLIC, Fitch decreased its 'AAAsf'
loss expectations by approximately 55 bps.

Third-Party Due Diligence (Negative): Third-party due diligence was
conducted on 100% of loans in the pool by an 'Acceptable - Tier 1'
TPR firm. Approximately 8% of loans received a grade of 'C' or 'D'
for compliance exceptions; roughly half of these exceptions
received a loss adjustment due to an inability to test for
predatory lending. The remaining exceptions did not receive
adjustments primarily due to expired statute of limitations, or the
loans were not subject to predatory lending testing. Loss
expectations were increased by 19 bps at 'AAAsf' to account for the
findings.

Sequential-Pay Structure (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, the provision to re-allocate principal to pay interest
on the 'AAAsf' and 'AAsf' rated notes prior to other principal
distributions is highly supportive of timely interest payments to
those classes in the absence of servicer advancing.

Deferred Amounts (Negative): Non-interest-bearing principal
forbearance amounts totaling $28.5 million (6%) of the unpaid
principal balance are outstanding on 847 loans. Fitch included the
deferred amounts when calculating the borrower's LTV and sLTV
despite the lower payment and amounts not being owed during the
term of the loan. The inclusion resulted in higher PDs and loss
severity (LS) than if there were no deferrals. 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.

No Servicer P&I Advances (Neutral): The servicer will not be
advancing 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 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 timely payments
of interest to the 'AAAsf' and 'AAsf' rated classes.

CRITERIA APPLICATION

Fitch analyzed the transaction in accordance with its criteria, as
described in its 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 notes.

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 5.6% at the base case. The analysis indicates there
is some potential rating migration with higher MVDs, compared with
the model projection.

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC Diligence, LLC (AMC) who was engaged to perform a
regulatory compliance, data integrity, and pay history third-party
due diligence review on the loans. The third-party due diligence
described in Form 15E focused on the following: regulatory
compliance review, 24-month pay-history review, and data integrity
review on all of the loans. In addition, AMC was engaged to perform
an updated tax and title search and a review for recordation of the
mortgage note and subsequent assignments for the entire pool.

Approximately 8% of the loans reviewed were assigned a compliance
grade 'C' or 'D'. For roughly half of these loans, Fitch adjusted
its loss expectation at the 'AAAsf' by approximately 19bps to
reflect missing documents that prevented the testing for predatory
lending compliance. Inability to test for predatory lending may
expose the trust to potential assignee liability, which creates
added risk for bond investors. The remaining loans graded 'C' and
'D' include exceptions for loans that are not subject to predatory
lending, loans with missing disclosures and other compliance
defects which were considered non-material by the Fitch analyst.
Loss adjustments were not applied for these loans.


PFP LTD 2019-5: DBRS Finalizes B(low) Rating on Class G Notes
-------------------------------------------------------------
DBRS, Inc. finalized the provisional ratings on the following
classes of secured floating-rate notes issued by PFP 2019-5, Ltd.
(the Issuer):

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

All trends are Stable.

All classes have been privately placed.

The initial collateral consists of 35 floating-rate mortgages
secured by 39 transitional properties totaling $764.2 million
(87.4% of the total fully funded balance), excluding the $109.9
million of remaining future funding commitments. The loans are
secured by currently cash flowing assets, most of which are in a
period of transition with plans to stabilize and improve the asset
value. Of these loans, 29 have remaining future funding
participations that may be acquired by the Issuer in the future
with principal repayment proceeds for a total of $109.9 million.
The initial future funding commitments totaled $115.5 million, of
which approximately $5.6 million has been funded to date. If the
acquisition by the Issuer of all or a portion of a future funding
participation results in a downgrade of the ratings by DBRS, then
PFP Holding Company VI, LLC will be required to promptly repurchase
such related funded companion participation at the same price as
the Issuer paid to acquire it.

The loans were all sourced by an affiliate of the Issuer that has
strong origination practices. PFP 2019-5 Depositor, LLC, a wholly
owned subsidiary of PFP Holding Company VI, LLC, will retain 100.0%
of the Class F notes, Class G notes and Preferred Shares,
accounting for approximately 13.5% of the initial pool balance.
Additionally, an affiliate of PFP Holding Company VI, LLC is
expected to retain 100.0% of the Class E notes.

Given the floating-rate nature of the loans, the index DBRS used
(one-month LIBOR) was the lower of a DBRS stressed rate that
corresponded to the remaining fully extended term of the loans or
the strike price of the interest rate cap with the respective
contractual loan spread added to determine a stressed interest rate
over the loan term. When the cut-off balances were measured against
the DBRS As-Is Net Cash Flow (NCF), 24 loans (79.1% of the mortgage
loan cut-off date balance) had a DBRS As-Is Debt Service Coverage
Ratio (DSCR) below 1.00 times (x), a threshold indicative of
default risk. Additionally, the DBRS Stabilized DSCR for 16 loans,
comprising 53.1% of the initial pool balance, is below 1.00x, which
is indicative of elevated refinance risk. The properties are often
transitioning with potential upside in the cash flow; however, DBRS
does not give full credit to the stabilization if there are no
holdbacks or if other loan structural features in place are
insufficient to support such treatment. Furthermore, even with the
structure provided, DBRS generally does not assume the assets will
stabilize above market levels. The transaction will have a
sequential-pay structure.

The deal is concentrated by property type with 15 loans,
representing 44.7% of the mortgage loan cut-off date balance,
secured by multifamily properties. Four of these loans, comprising
8.9% of the trust balance, are backed by student housing
properties, which often exhibit higher cash flow volatility than
traditional multifamily properties. Multifamily properties benefit
from staggered lease rollover and generally low expense ratios
compared with other property types. While revenue is quick to
decline in a downturn because of the short-term nature of the
leases, it is also quick to respond when the market improves. Four
loans, totaling 18.9% of the total multifamily cut-off balance, are
secured by properties located in a DBRS Market Rank of 7. An
additional loan, representing 2.7% of the multifamily
concentration, is located in a DBRS Market Rank of 6. More
importantly, DBRS sampled 69.5% of the pool, representing 79.0%
coverage of the total multifamily loan cut-off balance, thereby
providing comfort for the DBRS NCF. Student housing properties are
modeled with an elevated probability of default compared with
traditional multifamily properties. No loans are secured by
military housing properties, which also often exhibit higher cash
flow volatility than traditional multifamily properties.

Nine loans, totaling 27.6% of the trust balance, are secured by
properties in a DBRS Market Rank of 2. An additional loan,
representing 0.9% of the pool, is backed by a property in a DBRS
Market Rank of 1. Compared with sought-after gateway markets, these
locations often suffer from lower investor demand and liquidity,
particularly during times of economic stress. The properties
securing the loans are primarily located in core markets with the
overall pool's weighted-average (WA) DBRS Market Rank at 4.0.
Furthermore, six loans, totaling 19.6% of the trust balance, are in
markets with a DBRS Market Rank of 7, and another three are within
markets with a Market Rank of 6, totaling 8.3% of the pool. Both of
the ranks correspond to zip codes that are more urbanized in
nature.

DBRS has analyzed the loans to a stabilized cash flow that is, in
some instances, above the current in-place cash flow. There is a
possibility that the sponsors will not execute their business plans
as expected and that the higher stabilized cash flow will not
materialize during the loan term. Failure to execute the business
plan could result in a term default or the inability to refinance
the fully funded loan balance. DBRS made relatively conservative
stabilization assumptions and, in each instance, considered the
business plan to be rational and the future funding amounts to be
sufficient to execute such plans. In addition, DBRS analyzes loss
given default (LGD) based on the As-Is Loan-to-Value (LTV) ratio.

Based on the weighted initial pool balances, the overall WA DBRS
As-Is DSCR and DBRS Stabilized DSCR of 0.73x and 1.00x,
respectively, are reflective of high-leverage financing. The DBRS
As-Is DSCR is based on the DBRS In-Place NCF and debt service
calculated using a stressed interest rate. The WA stressed rate
used is 6.56%, which is greater than the current WA interest rate
of 5.85% (based on a WA mortgage spread and an assumed 2.5%
one-month LIBOR index). The assets are generally well positioned to
stabilize, and any realized cash flow growth would help to offset a
rise in interest rates and improve the overall debt yield of the
loans. DBRS associates its LGD based on the assets' As-Is LTV,
which does not assume that the stabilization plan and cash flow
growth will ever materialize. The As-Is LTV is considered
reasonable at 78.7% given the credit enhancement levels at each
rating category.

All loans have floating interest rates, and there are 30 loans,
comprising 87.6% of the trust balance, that are IO during the
initial term that range from 24 months to 36 months, creating
interest rate risk. The borrowers of all 35 loans have purchased
LIBOR rate caps that have a range of 2.75% to 3.50% to protect
against a rise in interest rates over the term of the loan. All
loans are short term and, even with extension options, have a fully
extended loan term of five years maximum. Additionally, all loans
have extension options, and in order to qualify for these options,
the loans must meet minimum DSCR and LTV requirements. Twenty-nine
of the loans, representing 88.6% of the total pool, amortize on
fixed schedules during all or a portion of their extension period.

The DBRS sample included 18 loans, and site inspections were
performed on 20 of the 39 properties in the pool, representing
65.1% of the pool by allocated cut-off loan balance. DBRS conducted
meetings with the on-site property manager, leasing agent or
representative of the borrowing entity for 19 properties,
comprising 63.9% of the initial pool balance.

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


PIKES PEAK 3: Moody's Rates $28.5MM Class E Notes 'Ba3'
-------------------------------------------------------
Moody's Investors Service has assigned ratings to six classes of
notes issued by Pikes Peak CLO 3.

Moody's rating action is as follows:

US$304,000,000 Class A Senior Secured Floating Rate Notes due 2030
(the "Class A Notes"), Assigned Aaa (sf)

US$46,000,000 Class B-1 Senior Secured Floating Rate Notes due 2030
(the "Class B-1 Notes"), Assigned Aa2 (sf)

US$7,400,000 Class B-2 Senior Secured Fixed Rate Notes due 2030
(the "Class B-2 Notes"), Assigned Aa2 (sf)

US$21,350,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes due 2030 (the "Class C Notes"), Assigned A2 (sf)

US$27,300,000 Class D Mezzanine Secured Deferrable Floating Rate
Notes due 2030 (the "Class D Notes"), Assigned Baa3 (sf)

US$28,500,000 Class E Junior Secured Deferrable Floating Rate Notes
due 2030 (the "Class E Notes"), Assigned Ba3 (sf)

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

RATINGS RATIONALE

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

Pikes Peak 3 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
first lien 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 70% ramped as of
the closing date.

Partners Group US Management CLO 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 three-year reinvestment period.
Thereafter, subject to certain restrictions, the Manager may
reinvest unscheduled principal payments and proceeds from sales of
credit risk assets.

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: $475,000,000

Diversity Score: 60

Weighted Average Rating Factor (WARF): 2897

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 47.5%

Weighted Average Life (WAL): 7.0 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.


REVELSTOKE CDO I: DBRS Confirms C Rating on 2 Note Classes
----------------------------------------------------------
DBRS Limited confirmed the ratings of the Class A-1 Notes, Class
A-2 Notes and Class A-3 Notes issued by Revelstoke CDO I Limited
(the Transaction) at CC (sf), C (sf) and C (sf), respectively, as
follows:

-- Class A-1 Senior Variable Rate Secured Notes due 2020
    (Class A-1 Notes) at CC (sf)

-- Class A-2 Senior Variable Rate Secured Notes due 2026
    (Class A-2 Notes) at C (sf)

-- Class A-3 Senior Variable Rate Secured Notes due 2033
    (Class A-3 Notes) at C (sf)

The Transaction is exposed to pools of U.S. non-prime residential
mortgages and other collateralized debt obligations backed by
residential mortgages, among other assets. Because of the
decreasing quality of the underlying portfolio, DBRS expects that
the Class A-1 Notes will have a partial recovery of principal. DBRS
also expects that holder of both the Class A-2 Notes and the Class
A-3 Notes will not receive any return of initial principal over the
remaining term of the Transaction.

Notes: All figures are in Canadian dollars unless otherwise noted.


STEELE CREEK 2019-1: Moody's Rates $20MM Class E Notes 'Ba3'
------------------------------------------------------------
Moody's Investors Service has assigned ratings to five classes of
debt issued by Steele Creek CLO 2019-1, Ltd.

Moody's rating action is as follows:

  US$260,000,000 Class A Loans maturing in 2032 (the "Class A
  Loans"), Assigned Aaa (sf)

  US$44,000,000 Class B Senior Secured Floating Rate Notes due
  2032 (the "Class B Notes"), Assigned Aa2 (sf)

  US$20,100,000 Class C Mezzanine Secured Deferrable Floating
  Rate Notes due 2032 (the "Class C Notes"), Assigned A2 (sf)

  US$23,800,000 Class D Mezzanine Secured Deferrable Floating
  Rate Notes due 2032 (the "Class D Notes"), Assigned Baa3 (sf)

  US$20,000,000 Class E Mezzanine Secured Deferrable Floating
  Rate Notes due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

The Class A Loans, 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 Debt."

RATINGS RATIONALE

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

Steele Creek 2019-1 is a managed cash flow CLO. The issued debt
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 and eligible
investments, and up to 7.5% of the portfolio may consist of second
lien loans and unsecured loans. The portfolio is approximately 90%
ramped as of the closing date.

Steele Creek Investment 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 five year reinvestment period.
Thereafter, subject to certain restrictions, the Manager may
reinvest unscheduled principal payments and proceeds from sales of
credit risk assets.

In addition to the Rated Debt, 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 debt 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: 68

Weighted Average Rating Factor (WARF): 2682

Weighted Average Spread (WAS): 3.45%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.75%

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 Debt is subject to uncertainty. The
performance of the Rated Debt 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 Debt.


TABERNA PREFERRED II: Moody's Hikes Ratings on 3 Tranches to Ba2
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by Taberna Preferred Funding II, Ltd.:

  US$400,000,000 Class A-1A First Priority Delayed Draw
  Senior Secured Floating Rate Notes Due 2035 (current
  balance of $95,605,094), Upgraded to Ba2 (sf);
  previously on July 24, 2018 Upgraded to B1 (sf)

  US$106,500,000 Class A-1B First Priority Senior
  Secured Floating Rate Notes Due 2035 (current
  balance of $25,454,856), Upgraded to Ba2 (sf);
  previously on July 24, 2018 Upgraded to B1 (sf)

  UD$10,000,000 Class A-1C First Priority Senior Secured
  Fixed/Floating Rate Notes Due 2035 (current balance
  of $2,390,127), Upgraded to Ba2 (sf); previously on
  July 24, 2018 Upgraded to B1 (sf)

Taberna Preferred Funding II, Ltd., issued in June 2005, is a
collateralized debt obligation backed mainly by a portfolio of REIT
trust preferred securities.

RATINGS RATIONALE

The rating actions are primarily a result of the deleveraging of
the Class A-1A, Class A-1B and Class A-1C notes, an increase in the
transaction's over-collateralization (OC) ratio, and the
improvement in the credit quality of the underlying portfolio since
July 2018.

The Class A-1A, Class A-1B and Class A-1C notes have paid down
collectively by approximately 32.8% or $60.1 million since July
2018, using principal proceeds from the redemption of the
underlying assets and the diversion of excess interest proceeds.
Based on Moody's calculations, the OC ratio for the Class A-1 notes
has improved to 225.8% from July 2018 level of 179.8%. The Class
A-1 notes will continue to benefit from the diversion of excess
interest and the use of proceeds from redemptions of any assets in
the collateral pool.

The deal has also benefited from improvement in the credit quality
of the underlying portfolio. According to Moody's calculations, the
weighted average rating factor improved to 4168 from 4699 in July
2018.

The rating actions also took into consideration an Event of Default
and subsequent acceleration of the transaction in 2009. The
transaction declared an EoD because of missed interest payments on
the Class A-1, Class A-2 and Class B notes, according to Section
5.1(a) of the indenture. As a result of the acceleration of the
deal, the Class A-1 notes have been receiving all proceeds after
Class A-1 and Class A-2 interest, and will continue to receive
until they are paid in full.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, and weighted average recovery rate,
are based on its methodology and could differ from the trustee's
reported numbers. In its base case, Moody's analyzed the underlying
collateral pool as having a performing par and principal proceeds
balance of $278.8 million, defaulted/deferring par of $271.7
million, a weighted average default probability of 53.14% (implying
a WARF of 4168), and a weighted average recovery rate upon default
of 9.95%.

Methodology Underlying the Rating Action:

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


TOWD POINT 2015-4: Fitch Assigns 'Bsf' Rating on Class B-3 Notes
----------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Outlooks to
three previously unrated classes from three Towd Point Mortgage
Trust transactions issued between 2015 and 2016:

  -- Series 2015-4 class B-3 notes 'Bsf'; Outlook Stable;

  -- Series 2015-6 class B-3 notes 'Bsf'; Outlook Stable;

  -- Series 2016-5 class B-3 notes 'BBsf'; Outlook Stable.

Fitch has rated other classes within these transactions since deal
close. The three classes with ratings assigned are more junior than
the classes with existing ratings and were unrated at deal close.
All of the transactions have performed well since closing with many
of the previously rated bonds upgraded or assigned a Positive
Rating Outlook. All of the transactions are U.S. RMBS transactions
collateralized by pools of re-performing loans in which the
majority have been modified.

KEY RATING DRIVERS

Performance Better than Projections (Positive): Serious delinquency
has increased since issuance for each transaction under review with
an average of under 5.5% with the highest delinquency of 6.1%.
These values are materially lower than Fitch's base case default
expectations at initial rating. Realized losses have also been
limited with losses as a percentage of original balance less than
2%.

Lower Loss Expectations (Positive): The expected losses for the
underlying pools backing the rated notes have decreased since
issuance. On average the 'Bsf' expected loss has fallen by 5.5
points. The reduced loss expectation is driven by home price
appreciation over the past few years, continued borrower
performance and criteria changes. Since the initial rating, Fitch
has expanded its application of a seasoned performing credit for
borrowers that have been current for at least three years. This has
led to both a higher credit as well as more borrowers receiving the
benefit as they have continued to perform since transaction close.

Increased Subordination (Positive): Since the transactions have
closed, the subordination on the classes assigned ratings has
increased by 2.5 points on average. The increase in subordination
has been driven by limited losses to date, steady pay down of the
senior classes due to the sequential structure and the use of
excess spread to build up additional protection to the rated
notes.

No Servicer P&I Advances (Mixed): The servicer will not be
advancing 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, loan-level LS is less for this
transaction than for those where the servicer is obligated to
advance P&I.

CRITERIA APPLICATION

Fitch analyzed the transaction in accordance with its criteria, as
described in its report, "U.S. RMBS Rating Criteria." This
incorporates a review of the originators' lending platforms, as
well as an assessment of the transaction's R&Ws provided by the
originators and arranger, which were found to be consistent with
the ratings assigned to the certificates.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines than
assumed at both the metropolitan statistical area 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 also conducted defined rating sensitivities, which 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

Third-party due diligence was reviewed as part of Fitch's rating of
the more senior classes at deal issuance. The due diligence focused
on regulatory compliance, pay history, servicing comments, the
presence of key documents in the loan file and data integrity.
Because Fitch rated these transactions at issuance, Fitch relied on
the tax and title search results, 100% loan-level due diligence and
updated property valuations conducted at deal issuance. Fitch
regularly surveils these transactions and believes that the
servicing practices and oversight mitigates the risk of senior
property liens being placed on the property and that pay histories
are accurately reported. Fitch also believes the property values
provided at deal closing are still relevant given the positive home
price environment over the past several years. 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 the adjustments made as a
result of the findings at initial rating analysis were applied for
this rating assignment for all loans still outstanding in the
pools.


TOWD POINT 2015-6: Fitch Assigns 'Bsf' Rating on Class B-3 Notes
----------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Outlooks to
three previously unrated classes from three Towd Point Mortgage
Trust transactions issued between 2015 and 2016:

  -- Series 2015-4 class B-3 notes 'Bsf'; Outlook Stable;

  -- Series 2015-6 class B-3 notes 'Bsf'; Outlook Stable;

  -- Series 2016-5 class B-3 notes 'BBsf'; Outlook Stable.

Fitch has rated other classes within these transactions since deal
close. The three classes with ratings assigned are more junior than
the classes with existing ratings and were unrated at deal close.
All of the transactions have performed well since closing with many
of the previously rated bonds upgraded or assigned a Positive
Rating Outlook. All of the transactions are U.S. RMBS transactions
collateralized by pools of re-performing loans in which the
majority have been modified.

KEY RATING DRIVERS

Performance Better than Projections (Positive): Serious delinquency
has increased since issuance for each transaction under review with
an average of under 5.5% with the highest delinquency of 6.1%.
These values are materially lower than Fitch's base case default
expectations at initial rating. Realized losses have also been
limited with losses as a percentage of original balance less than
2%.

Lower Loss Expectations (Positive): The expected losses for the
underlying pools backing the rated notes have decreased since
issuance. On average the 'Bsf' expected loss has fallen by 5.5
points. The reduced loss expectation is driven by home price
appreciation over the past few years, continued borrower
performance and criteria changes. Since the initial rating, Fitch
has expanded its application of a seasoned performing credit for
borrowers that have been current for at least three years. This has
led to both a higher credit as well as more borrowers receiving the
benefit as they have continued to perform since transaction close.

Increased Subordination (Positive): Since the transactions have
closed, the subordination on the classes assigned ratings has
increased by 2.5 points on average. The increase in subordination
has been driven by limited losses to date, steady pay down of the
senior classes due to the sequential structure and the use of
excess spread to build up additional protection to the rated
notes.

No Servicer P&I Advances (Mixed): The servicer will not be
advancing 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, loan-level LS is less for this
transaction than for those where the servicer is obligated to
advance P&I.

CRITERIA APPLICATION

Fitch analyzed the transaction in accordance with its criteria, as
described in its report, "U.S. RMBS Rating Criteria." This
incorporates a review of the originators' lending platforms, as
well as an assessment of the transaction's R&Ws provided by the
originators and arranger, which were found to be consistent with
the ratings assigned to the certificates.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines than
assumed at both the metropolitan statistical area 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 also conducted defined rating sensitivities, which 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

Third-party due diligence was reviewed as part of Fitch's rating of
the more senior classes at deal issuance. The due diligence focused
on regulatory compliance, pay history, servicing comments, the
presence of key documents in the loan file and data integrity.
Because Fitch rated these transactions at issuance, Fitch relied on
the tax and title search results, 100% loan-level due diligence and
updated property valuations conducted at deal issuance. Fitch
regularly surveils these transactions and believes that the
servicing practices and oversight mitigates the risk of senior
property liens being placed on the property and that pay histories
are accurately reported. Fitch also believes the property values
provided at deal closing are still relevant given the positive home
price environment over the past several years. 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 the adjustments made as a
result of the findings at initial rating analysis were applied for
this rating assignment for all loans still outstanding in the
pools.


TOWD POINT 2016-5: Fitch Gives 'BBsf' Rating on Class B-3 Notes
---------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Outlooks to
three previously unrated classes from three Towd Point Mortgage
Trust transactions issued between 2015 and 2016:

  -- Series 2015-4 class B-3 notes 'Bsf'; Outlook Stable;

  -- Series 2015-6 class B-3 notes 'Bsf'; Outlook Stable;

  -- Series 2016-5 class B-3 notes 'BBsf'; Outlook Stable.

Fitch has rated other classes within these transactions since deal
close. The three classes with ratings assigned are more junior than
the classes with existing ratings and were unrated at deal close.
All of the transactions have performed well since closing with many
of the previously rated bonds upgraded or assigned a Positive
Rating Outlook. All of the transactions are U.S. RMBS transactions
collateralized by pools of re-performing loans in which the
majority have been modified.

KEY RATING DRIVERS

Performance Better than Projections (Positive): Serious delinquency
has increased since issuance for each transaction under review with
an average of under 5.5% with the highest delinquency of 6.1%.
These values are materially lower than Fitch's base case default
expectations at initial rating. Realized losses have also been
limited with losses as a percentage of original balance less than
2%.

Lower Loss Expectations (Positive): The expected losses for the
underlying pools backing the rated notes have decreased since
issuance. On average the 'Bsf' expected loss has fallen by 5.5
points. The reduced loss expectation is driven by home price
appreciation over the past few years, continued borrower
performance and criteria changes. Since the initial rating, Fitch
has expanded its application of a seasoned performing credit for
borrowers that have been current for at least three years. This has
led to both a higher credit as well as more borrowers receiving the
benefit as they have continued to perform since transaction close.

Increased Subordination (Positive): Since the transactions have
closed, the subordination on the classes assigned ratings has
increased by 2.5 points on average. The increase in subordination
has been driven by limited losses to date, steady pay down of the
senior classes due to the sequential structure and the use of
excess spread to build up additional protection to the rated
notes.

No Servicer P&I Advances (Mixed): The servicer will not be
advancing 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, loan-level LS is less for this
transaction than for those where the servicer is obligated to
advance P&I.

CRITERIA APPLICATION

Fitch analyzed the transaction in accordance with its criteria, as
described in its report, "U.S. RMBS Rating Criteria." This
incorporates a review of the originators' lending platforms, as
well as an assessment of the transaction's R&Ws provided by the
originators and arranger, which were found to be consistent with
the ratings assigned to the certificates.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines than
assumed at both the metropolitan statistical area 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 also conducted defined rating sensitivities, which 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

Third-party due diligence was reviewed as part of Fitch's rating of
the more senior classes at deal issuance. The due diligence focused
on regulatory compliance, pay history, servicing comments, the
presence of key documents in the loan file and data integrity.
Because Fitch rated these transactions at issuance, Fitch relied on
the tax and title search results, 100% loan-level due diligence and
updated property valuations conducted at deal issuance. Fitch
regularly surveils these transactions and believes that the
servicing practices and oversight mitigates the risk of senior
property liens being placed on the property and that pay histories
are accurately reported. Fitch also believes the property values
provided at deal closing are still relevant given the positive home
price environment over the past several years. 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 the adjustments made as a
result of the findings at initial rating analysis were applied for
this rating assignment for all loans still outstanding in the
pools.


TOWD POINT 2019-HY2: Moody's Assigns B1 Rating on Class B2 Notes
----------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to nine
classes of notes issued by Towd Point Mortgage Trust 2019-HY2.

The notes are backed by one pool of 4,215 predominantly seasoned
performing adjustable-rate residential mortgage loans. The
borrowers have a non-zero updated weighted average FICO score of
756 and a weighted average current combined LTV of 61% (using
current senior loan balance where available) as of March 31, 2019
(the cut-off date). First lien loans comprise about 97% of the pool
by balance and about 95% of the pool by balance consists of
non-modified seasoned performing loans. Select Portfolio Servicing,
Inc. (SPS) will be the primary servicer for 100% of the collateral.
FirstKey Mortgage, LLC will be the asset manager for the
transaction.

The complete rating actions are as follows:

Issuer: Towd Point Mortgage Trust 2019-HY2

Cl. A1, Definitive Rating Assigned Aaa (sf)

Cl. A1A, Definitive Rating Assigned Aaa (sf)

Cl. A2, Definitive Rating Assigned Aa2 (sf)

Cl. A3, Definitive Rating Assigned Aa1 (sf)

Cl. A4, Definitive Rating Assigned A1 (sf)

Cl. M1, Definitive Rating Assigned A1 (sf)

Cl. M2, Definitive Rating Assigned Baa2 (sf)

Cl. B1, Definitive Rating Assigned Ba2 (sf)

Cl. B2, Definitive Rating Assigned B1 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected loss on TPMT 2019-HY2's collateral pool is 1.75%
in its base case scenario. The loss estimate takes into account the
historical performance of the loans that have similar collateral
characteristics as the loans in the pool, and also incorporate an
expectation of a continued strong credit environment for RMBS,
supported by a current strong housing price environment.

Moody's estimated expected losses using two approaches -- (1)
pool-level approach, and (2) re-performing loan level analysis. In
the pool-level approach, it estimated losses on the pool by
applying its assumptions on expected future delinquencies, default
rates, loss severities and prepayments as observed on similar
seasoned collateral. Moody's projected future annual delinquencies
for eight years by applying an initial annual default rate
assumption adjusted for future years through delinquency burnout
factors. The delinquency burnout factors reflect its future
expectations of the economy and the U.S. housing market. Based on
the loan characteristics of the pool and the demonstrated pay
histories, it applied an initial expected annual delinquency rate
of 3.50% for first lien loans and 4.25% for junior lien loans for
year one. Moody's then calculated future delinquencies using
default burnout and voluntary conditional prepayment rate
assumptions. It aggregated the delinquencies and converted them to
losses by applying pool specific lifetime default frequency and
loss severity assumptions. The default, CPR and loss severity
assumptions are based on actual observed performance of seasoned
performing, re-performing modified loans and prior TPMT deals. In
applying its loss severity assumptions, Moody's accounted for the
lack of principal and interest advancing in this transaction.
Junior lien loans, which represent about 3% of the pool, are likely
to experience high severity in the event of default. In its
analysis, it assumes these loans would experience 100% severity.
Empty lot loans, which account for about 4% of the pool, are likely
to experience high severity should the borrower default due to a
low average loan balance of approximately $80,000 and a high
current LTV of over 100%. Moody's significantly increased its
severity assumption for these loans in the analysis. Of note, since
the overall profile of this pool is more similar to seasoned
performing pools, it applied similar seasoned performing loss
assumptions to this pool to derive collateral losses.

Moody's also conducted a loan level analysis on TPMT 2019-HY2's
collateral pool. It applied loan-level baseline lifetime propensity
to default assumptions, and considered the historical performance
of seasoned loans with similar collateral characteristics and
payment histories. It then adjusted this base default propensity up
for, if any, (1) adjustable-rate loans, (2) loans that have the
risk of coupon step-ups and (3) loans with high updated loan to
value ratios (LTVs). It applied a higher baseline lifetime default
propensity for interest-only loans, using the same adjustments. To
calculate the final expected loss for the pool, it applied a
loan-level loss severity assumption based on the loans' updated
estimated LTVs. Itfurther adjusted the loss severity assumption
upwards for loans in states that give super-priority status to
homeowner association liens, to account for potential risk of HOA
liens trumping a mortgage.

The final expected loss for the collateral pool also reflects the
due diligence findings of three independent third party review
firms as well as its assessment of TPMT 2019-HY2's representations
& warranties framework.

Collateral Description

TPMT 2019-HY2's collateral pool is primarily comprised of seasoned
performing first lien adjustable-rate mortgage loans. Approximately
5% of the loans in the collateral pool have been previously
modified, junior loans make up about 3% of the pool and fixed-rate
mortgages make up about 3% of the pool. The majority of the loans
underlying this transaction exhibit collateral characteristics
similar to that of seasoned Alt-A mortgages.

Unlike previous TPMT transactions, the collateral pool contains a
higher proportion of first lien mortgage loans backed by empty lot
properties (4.4% by balance) with an average unpaid principal
balance of about $80,000, WA FICO of 755 and WA current LTV of
150%. Moody's addressed the risk posed by the empty lots by
adjusting the severity for the related loans upward.

Also, this transaction has a higher proportion of loans for which
the value of the related underlying property was updated through an
automated valuation model at 57% of the collateral balance. Moody's
applied a haircut to the AVM valuations since it  considers AVM
valuations to be less precise than broker price opinions. BPOs were
used to update the property valuations for 41% of the collateral
pool.

Moody's based its expected loss on the pool on the estimates of 1)
the default rate on the remaining balance of the loans and 2) the
principal recovery rate on the defaulted balances. The two factors
that most strongly influence a re-performing mortgage loan's
likelihood of re-default are the length of time that the loan has
performed since modification, and the amount of the reduction in
monthly mortgage payments as a result of modification. The longer a
borrower has been current on a re-performing loan, the less likely
they are to re-default. Approximately 97% of the borrowers of the
loans in the collateral pool have been current on their payments
for the past 72 months or more under the OTS method.

Transaction Structure

TPMT 2019-HY2 has a sequential priority of payments structure, in
which a given class of notes can only receive principal payments
when all the classes of notes above it have been paid off.
Similarly, losses will be applied in the reverse order of priority.
The Class A1, A1A, A2, M1, M2, B1, B2, B3 and B4 notes carry a
floating-rate coupon indexed to one-month LIBOR and subject to the
collateral adjusted net WAC and applicable available funds cap. The
Class A3 and A4 notes are floating-rate notes where the coupon is
equal to the weighted average of the note rates of the related
exchange notes. The Class B5 notes are principal-only notes. There
are no performance triggers in this transaction. Additionally, the
servicer will not advance any principal or interest on delinquent
loans.

Moody's coded TPMT 2019-HY2's cashflows using its proprietary
cashflow tool. To assess the final rating on the notes, it ran 96
different loss and prepayment scenarios through SFW. The scenarios
encompass six loss levels, four loss timing curves, and four
prepayment curves.

Third Party Review

Three independent third party review firms -- Clayton Services,
LLC, AMC Diligence, LLC and Westcor Land Title Insurance Company --
conducted due diligence for the transaction. As of the statistical
calculation date (February 28, 2019), due diligence was performed
on about 32% of the loans by unpaid principal balance in TPMT
2019-HY2's collateral pool for compliance, 32% for data capture,
31% for pay string history, and 99% for title and tax review. The
TPR firms reviewed compliance, data integrity and key documents to
verify that loans were originated in accordance with federal, state
and local anti-predatory laws. The TPR firms conducted audits of
designated data fields to ensure the accuracy of the collateral
tape.

Based on its analysis of the third-party review reports, Moody's
determined that a portion of the loans had legal or compliance
exceptions that could cause future losses to the trust. Moody's
incorporated an additional increase to its expected losses for
these loans to account for this risk. FirstKey Mortgage, LLC
retained AMC and Westcor to review the title and tax reports for
the loans in the pool, and will oversee AMC and Westcor and monitor
the loan sellers in the completion of the assignment of mortgage
chains. In addition, FirstKey expects a significant number of the
assignment and endorsement exceptions to be cleared within the
first eighteen months following the closing date of the
transaction. Moody's took these loans into account in the loss
analysis.

Representations & Warranties

The ratings reflect TPMT 2019-HY2's weak representations and
warranties framework. The representation provider, FirstKey
Mortgage, LLC is unrated by Moody's. Moreover, FirstKey's
obligations will be in effect for only thirteen months after
transaction settlement. The R&Ws themselves are weak because they
contain many knowledge qualifiers and the regulatory compliance R&W
does not cover monetary damages that arise from TILA violations
whose right of rescission has expired. While the transaction
provides a breach reserve account to cover for any breaches of
R&Ws, the target size of the account (0.25% of the current balance
of the Class A1, A2, M1 and M2s) is small relative to TPMT
2019-HY2's aggregate collateral pool.

Similar to recent TPMT transactions, the sponsor will not be
funding the breach reserve account at closing. On each payment
date, the paying agent will fund the reserve account from the Class
XS2 each month up to target balance based on the outstanding
principal balance of the Class A1, A2, M1 and M2 notes. Since its
loss analysis already takes into account the weak R&W framework,
Moody's did not apply an additional penalty.

Transaction Parties

The transaction benefits from a strong servicing arrangement. SPS
will service 100% of TPMT 2019-HY2's collateral pool. Moody's
considers the overall servicing arrangement for this pool to be
better than average given the strength of the servicer, SPS, and
the existence of an asset manager, FirstKey Mortgage, LLC, which
will oversee the servicer. This arrangement strengthens the overall
servicing framework in the transaction. U.S. Bank National
Association is the indenture trustee and custodian of the
transaction. Wells Fargo Bank, N.A. will also be a custodian. The
Delaware Trustee is Wilmington Trust, National Association.

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

Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of loss could drive
the ratings up. Losses could decline from its 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. Other reasons for
better-than-expected performance include changes to servicing
practices that enhance collections or refinancing opportunities
that result in prepayments.

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 obligors defaulting 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.


WFRBS COMMERCIAL 2013-UBS1: S&P Affirms B+ (sf) Rating on F Certs
-----------------------------------------------------------------
S&P Global Ratings raised its ratings on three classes of
commercial mortgage pass-through certificates from WFRBS Commercial
Mortgage Trust 2013-UBS1, a U.S. commercial mortgage-backed
securities (CMBS) transaction. In addition, S&P affirmed its
ratings on eight other classes from the same transaction.

For the upgrades and affirmations, S&P's credit enhancement
expectations were in line with the raised or affirmed rating
levels. The upgrades also reflect sizable reduction in the trust
balance.

While available credit enhancement levels suggest positive rating
movements on classes E and F, S&P's analysis also considered the
concentration of loans  maturing in the second half of 2023 ($397.9
million, 73.5%) and these classes' subordinate positions in the
transaction.

S&P affirmed its 'AAA (sf)' rating on the class X-A interest-only
(IO) certificates based on its criteria for rating IO securities,
in which the ratings on the IO securities would not be higher than
that of the lowest-rated reference class. The notional balance on
class X-A references classes A-1, A-2, A-3, A-4, A-SB, and A-S.

TRANSACTION SUMMARY

As of the April 17, 2019, trustee remittance report, the collateral
pool balance was $541.5 million, which is 74.5% of the pool balance
at issuance. The pool currently includes 49 loans and one real
estate-owned (REO) asset, down from 57 loans at issuance. One of
these assets ($3.7 million, 0.7%) is with the special servicer,
five ($55.7 million, 10.3%) are defeased, and two ($38.8 million,
7.2%) are on the master servicer's watchlist.

S&P calculated a 1.84x S&P Global Ratings weighted average debt
service coverage (DSC) and 74.4% S&P Global Ratings weighted
average loan-to-value (LTV) ratio using a 7.73% S&P Global Ratings
weighted average capitalization rate. The DSC, LTV, and
capitalization rate calculations exclude the specially serviced
asset and five defeased loans.

The top 10 nondefeased loans have an aggregate outstanding pool
trust balance of $293.2 million (54.1%). Adjusting the
servicer-reported numbers, S&P calculated an S&P Global Ratings
weighted average DSC and LTV of 2.00x and 74.8%, respectively, for
the top 10 nondefeased loans.

To date, the transaction has experienced no principal losses. S&P
expects losses to reach approximately 0.2% of the original pool
trust balance in the near term, based on expected losses upon the
eventual resolution of the specially serviced asset.

CREDIT CONSIDERATIONS

As of the April 17, 2019, trustee remittance report, the Gander
Mountain Tuscaloosa REO asset was the sole asset with the special
servicer, CWCapital Asset Management LLC (CWCapital). The asset has
a total reported exposure of $5.7 million and consists of a
42,310-sq.-ft. retail property in Tuscaloosa, Ala. The loan was
transferred to the special servicer on Aug. 17, 2017, because the
single tenant filed for bankruptcy in March 2017 and rejected the
lease. The property became REO on April 5, 2018. CWCapital stated
that the property is fully leased as of March 2019 and expected to
be marketed for sale in the second quarter of 2019. A $1.1 million
appraisal reduction amount is in effect against this asset. S&P
expects a moderate (26-59%) loss upon its eventual resolution.

  RATINGS RAISED

  WFRBS Commercial Mortgage Trust 2013-UBS1
  Commercial mortgage pass-through certificates
                Rating
  Class     To          From         
  B         AA+ (sf)    AA (sf)
  C         A+ (sf)     A- (sf)
  D         BBB (sf)    BBB- (sf)

  RATINGS AFFIRMED

  WFRBS Commercial Mortgage Trust 2013-UBS1
  Commercial mortgage pass-through certificates
  Class     Rating    A-2       AAA (sf)
  A-3       AAA (sf)
  A-4       AAA (sf)
  A-SB      AAA (sf)
  A-S       AAA (sf)
  E         BB (sf)
  F         B+ (sf)
  X-A       AAA (sf)


                            *********

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