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         T R O U B L E D   C O M P A N Y   R E P O R T E R

              Sunday, August 18, 2019, Vol. 23, No. 229

                            Headlines

ACE SECURITIES 2006-2007: Moody's Hikes A-2D Debt Rating to Ba1
AMUR EQUIPMENT 2019-1: DBRS Finalizes B Rating on Class F Notes
BANK 2017-BNK7: Fitch Affirms B-sf Rating on Class F Certs
BANK 2019-BNK19: Fitch Assigns BBsf Rating on Class F Certs
BBCMS 2017-DELC: DBRS Confirms B Rating on Class HRR Certs

BENCHMARK 2019-B12: Fitch Rates $11.478MM Class G-RR Certs B-sf
BXP TRUST 2017-CC: DBRS Confirms BB Rating on Class E Certs
CITIGROUP 2019-GC41: DBRS Gives (P)B(high) Rating on GRR Certs
CITIGROUP COMMERCIAL 2017-B1: Fitch Affirms BB- Rating on X-E Certs
COMM 2012-CCRE5: Fitch Affirms Bsf Rating on Cl. G Certs

COMM 2017-COR2: Fitch Affirms B-sf Rating on Class G-RR Debt
CROWN POINT 8: Moody's Gives (P)Ba3 Rating on $23.45MM Cl. E Notes
CS MORTGAGE 2006-CF3: Moody's Cuts Class M-2 Certs Rating to Caa3
DT AUTO 2019-3: DBRS Finalizes BB Rating on $23.5MM Class E Notes
EATON VANCE 2013-1: S&P Assigns BB-(sf) Rating to Class D-RR Notes

GCAT TRUST 2019-RPL1: Moody's Assigns B3 Rating on Class B-2 Notes
GLS AUTO 2019-3: S&P Rates $37.8MM Class D Notes 'BB- (sf)'
GS MORTGAGE 2018-HULA: DBRS Confirms B(low) Rating on G Certs
GSAMP TRUST 2005-HE3: Moody's Hikes Class M-4 Debt Rating to B3
HERTZ VEHICLE 2015-3: Fitch Affirms BBsf Rating on Class D Notes

IMSCI 2013-3: Fitch Lowers Rating on Class G Certs to CCC
JMP CREDIT IV: Moody's Affirms Ba3 Rating on $22.5 Class E Notes
JP MORGAN 2018-WPT: DBRS Confirms B(low) Rating on 2 Tranches
JP MORGAN 2019-HYB1: Fitch to Rate Class B-5 Certs 'B(EXP)'
JP MORGAN 2019-LTV2: DBRS Finalizes B Rating on Class B-5 Certs

LCM XIII: S&P Affirms BB- (sf) Rating on Class E-R Notes
MASTR ASSET 2004-HE1: Moody's Lowers Ratings on 2 Tranches to B1
MORGAN STANLEY 2005-TOP19: Fitch Affirms D Rating on 4 Tranches
NASSAU LLC 2019: Fitch to Rate $75.2MM Class B Notes 'BB(EXP)'
NEUBERGER BERMAN 33: S&P Assigns Prelim BB- (sf) Rating to E Notes

NEW RESIDENTIAL 2019-RPL2: DBRS Finalizes B Rating on B-2 Notes
PALMER SQUARE 2019-3: Fitch Assigns B+ Rating on $5MM Cl. E Notes
PEAKS CLO 2: Moody's Assigns Ba3 Rating on $11MM Cl. E-R Notes
PREFERRED TERM XVII: Moody's Hikes $65.6MM Class C Notes to Caa2
SDART 2019-3: Moody's Assigns (P)B1 Rating on Class E Debt

SECURITIZED ASSET 2005-OP2: Moody's Cuts Class M-1 Debt to B1
SMALL BUSINESS 2019-A: Moody's Assigns (P)Ba3 Rating on Cl. C Notes
WACHOVIA BANK 2007-C30: Fitch Hikes Class E Certs to CCsf
WFRBS COMMERCIAL 2013-C18: Fitch Affirms B Rating on Class F Debt
WFRBS COMMERCIAL 2014-C22: Fitch Lowers Class D Certs Rating to B


                            *********

ACE SECURITIES 2006-2007: Moody's Hikes A-2D Debt Rating to Ba1
---------------------------------------------------------------
Moody's Investors Service upgraded the ratings of five tranches
from three transactions backed subprime loans, issued by multiple
issuers.

Complete rating actions are as follows:

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series
2006-OP1

Cl. A-1B, Upgraded to Aa1 (sf); previously on Mar 6, 2017 Upgraded
to A1 (sf)

Cl. A-2D, Upgraded to Ba1 (sf); previously on Nov 7, 2018 Upgraded
to B1 (sf)

Issuer: Ellington Loan Acquisition Trust 2007-1

Cl. A-2c, Upgraded to Aa1 (sf); previously on Dec 11, 2018 Upgraded
to A1 (sf)

Cl. A-2d, Upgraded to Aa2 (sf); previously on Dec 11, 2018 Upgraded
to A2 (sf)

Issuer: Washington Mutual Asset-Backed Certificates, WMABS Series
2006-HE3 Trust

Cl. I-A, Upgraded to B2 (sf); previously on Dec 17, 2018 Upgraded
to Caa1 (sf)

RATINGS RATIONALE

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

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in July 2019 from 3.9% in July
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.


AMUR EQUIPMENT 2019-1: DBRS Finalizes B Rating on Class F Notes
---------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of equipment contract-backed notes issued by Amur Equipment
Finance Receivables VII LLC (the Issuer):

-- $48,000,000 Series 2019-1, Class A-1 Notes at R-1 (high) (sf)
-- $170,802,000 Series 2019-1, Class A-2 Notes at AAA (sf)
-- $19,074,000 Series 2019-1, Class B Notes at AA (sf)
-- $8,696,000 Series 2019-1, Class C Notes at A (sf)
-- $11,081,000 Series 2019-1, Class D Notes at BBB (sf)
-- $6,311,000 Series 2019-1, Class E Notes at BB (sf)
-- $5,470,000 Series 2019-1, Class F Notes at B (sf)

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

-- Transaction capital structure, proposed ratings as well as the
sufficiency of available credit enhancement, which includes
over-collateralization (OC), subordination and amounts held in the
Reserve Account, to support the DBRS-projected cumulative net loss
assumption under various stressed cash flow scenarios.

-- The proposed concentration limits mitigating the risk of
material migration in the collateral pool's composition during the
approximately four-month funding period.

-- The capabilities of Amur Equipment Finance, Inc. (Amur EF) with
regard to origination, underwriting, and servicing. DBRS performed
an operational review of Amur EF and considers the company to be an
acceptable originator and servicer of equipment-backed lease and
loan contracts. In addition, Wells Fargo Bank, N.A. (rated AA with
a Stable trend by DBRS), an experienced servicer of equipment
lease-backed securitizations, will be the backup servicer for the
transaction.

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

Amur EF (formerly known as Axis Capital, Inc.) is a commercial
finance company providing equipment financing solutions to a broad
range of small- to medium-sized businesses across all 50 states of
the United States.

The rating on the Class A-1 Notes reflects 84.14% of initial hard
credit enhancement (as a percentage of the collateral balance)
provided by the subordinated notes in the pool (78.94%), the
Reserve Account (1.25%) and OC (3.95%). The rating on the Class A-2
Notes reflects 23.25% of initial hard credit enhancement provided
by the subordinated notes in the pool (18.05%), the Reserve Account
(1.25%) and OC (3.95%). The ratings on Class B, Class C, Class D,
Class E, and Class F Notes reflect 16.45%, 13.35%, 9.40%, 7.15% and
5.20% of initial hard credit enhancement, respectively.

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


BANK 2017-BNK7: Fitch Affirms B-sf Rating on Class F Certs
----------------------------------------------------------
Fitch Ratings has affirmed 17 classes of BANK 2017-BNK7 Commercial
Mortgage Pass-Through Certificates Series 2017-BNK7.

BANK 2017-BNK7

            Current Rating         Prior Rating
Class A-1  LT  AAAsf  Affirmed   previously at AAAsf
Class A-2  LT  AAAsf  Affirmed   previously at AAAsf
Class A-3  LT  AAAsf  Affirmed   previously at AAAsf
Class A-4  LT  AAAsf  Affirmed   previously at AAAsf
Class A-5  LT  AAAsf  Affirmed   previously at AAAsf
Class A-S  LT  AAAsf  Affirmed   previously at AAAsf
Class A-SB LT  AAAsf  Affirmed   previously at AAAsf
Class B    LT  AA-sf  Affirmed   previously at AA-sf
Class C    LT  A-sf   Affirmed   previously at A-sf
Class D    LT  BBB-sf Affirmed   previously at BBB-sf
Class E    LT  BB-sf  Affirmed   previously at BB-sf
Class F    LT  B-sf   Affirmed   previously at B-sf
Class X-A  LT  AAAsf  Affirmed   previously at AAAsf
Class X-B  LT  AA-sf  Affirmed   previously at AA-sf
Class X-D  LT  BBB-sf Affirmed   previously at BBB-sf
Class X-E  LT  BB-sf  Affirmed   previously at BB-sf
Class X-F  LT  B-sf   Affirmed   previously at B-sf

KEY RATING DRIVERS

Stable Loss Expectations: Overall pool performance has been stable
since issuance. There are no loans that are delinquent or in
special servicing and no loans have been designated as Fitch Loans
of Concern. Six loans (2.4% of the current pool balance) are on the
servicer's watchlist.

The largest loan in the pool is the pari passu portion of the
General Motors Building (9.3%), a 1,989,983 sf class A office
building built in 1968, renovated in 2017, and located in the Plaza
District submarket in Midtown Manhattan. Per the March 2019 rent
roll, the property is 91.2% occupied. Approximately 35% of NRA is
occupied by tenants that have been in occupancy since the
property's completion in 1968 and investment-grade or institutional
tenants occupy approximately 50% of NRA. The property's retail
space is currently undergoing a $100 million renovation and
expansion of the Apple "Cube" retail store. Apple is expected to
occupy their new space in September 2019 and the former FAO
Schwartz space should be delivered to Under Armour in March 2020.

Minimal Change to Credit Enhancement: As of the July 2019
distribution date, the pool's aggregate principal balance has been
reduced by 1.3% to $1.20 billion from $1.21 billion at issuance.
One loan, Summit Self Storage (0.4% of the pool balance at the
prior review) paid in full with a yield maintenance penalty in May
2019. Twenty-two loans (49.9%) are full-term interest-only loans
and thirteen loans (23.5%) are partial-term interest-only, three of
which (5.1%) have begun amortizing. There are no defeased loans or
interest shortfalls.

ADDITIONAL CONSIDERATIONS

Investment Grade Credit Opinion Loans: Four loans (21.7%) were
given investment-grade credit opinions at issuance. The General
Motors Building (9.3%), Westin Building Exchange (5.6%), The
Churchill (4.1%), and Moffett Place B4 (2.7%) were rated 'AAAsf',
'AAAsf', 'AAAsf', and 'BBB-sf', respectively, at issuance.

Multifamily Concentration: Loans secured by multifamily properties
make up 22.3% of the pool. Nineteen of these loans (9.5%) are
secured by cooperative housing, one (7.1%) is secured by student
housing, and the remaining five properties (5.7%) are secured by
traditional multifamily properties.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable. Fitch does not
foresee positive or negative ratings migration until a material
economic or asset-level event changes the transaction's overall
portfolio-level metrics.


BANK 2019-BNK19: Fitch Assigns BBsf Rating on Class F Certs
-----------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to BANK 2019-BNK19 Commercial Mortgage Pass-Through
Certificates, Series 2019-BNK19:

  -- $25,345,000 class A-1 'AAAsf'; Outlook Stable;

  -- $44,620,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $273,000,000 class A-2 'AAAsf'; Outlook Stable;

  --  $523,177,000 class A-3 'AAAsf'; Outlook Stable;

  -- $866,142,000a class X-A 'AAAsf'; Outlook Stable;

  -- $249,016,000a class X-B 'AA-sf'; Outlook Stable;

  -- $153,122,000 class A-S 'AAAsf'; Outlook Stable;

  -- $49,494,000 class B 'AA-sf'; Outlook Stable;

  -- $46,400,000 class C 'A-sf'; Outlook Stable;

  -- $51,041,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $27,840,000b class D 'BBBsf'; Outlook Stable;

  -- $23,201,000b class E 'BBB-sf'; Outlook Stable;

  -- $13,920,000b class F 'BBsf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $26,293,000ab class X-FG;

  -- $12,374,000ab class X-H;

  -- $32,480,575ab class X-J;

  -- $12,373,000b class G;

  -- $12,374,000b class H;

  -- $32,480,575b class J;

  -- $65,123,504c RR Interest.

(a) Notional amount and interest-only.

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

(c) Represents the eligible vertical credit risk retention
interest.

Since Fitch published its expected ratings on July 17, 2019, the
following changes occurred: The balances for class A-2 and class
A-3 were finalized. At the time that the expected ratings were
assigned, the exact initial certificate balances of class A-2 and
class A-3 were unknown and expected to be approximately
$796,711,000 in aggregate, subject to a 5% variance. The final
class balances for class A-2 and class A-3 are $273,000,000 and
$523,177,000, respectively. Additionally, based on final pricing of
the certificates, class C is a WAC class that provides no excess
cash flow that would affect the payable interest on the class X?B
certificates. Fitch's rating on class X-B has been updated to
'AA-sf' (from 'A-sf') to reflect the rating of the lowest
referenced tranche whose payable interest has an impact on the
interest-only payments. The classes reflect the final ratings and
deal structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 73 loans secured by 76
commercial properties having an aggregate principal balance of
$1,302,470,080 as of the cut-off date. The loans were contributed
to the trust by Wells Fargo Bank, National Association, Morgan
Stanley Mortgage Capital Holdings LLC, Bank of America, National
Association and National Cooperative Bank, N.A.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 80.2% of the properties
by balance, cash flow analysis of 87.6%, and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Lower Fitch Leverage: The pool's leverage is lower than that of
recent Fitch-rated multiborrower transactions. The pool's Fitch
debt service coverage ratio (DSCR) of 1.53x is higher than the 2018
and YTD 2019 averages of 1.22x and 1.21x, respectively. The pool's
loan-to-value (LTV) of 92.1% is lower than the 2018 and YTD 2019
averages of 102.0% and 101.8%, respectively. Excluding the co-op
and credit assessed collateral, the pool has a respective Fitch
DSCR and LTV of 1.15x and 108.0%.

Credit Opinion Loans: Four loans, representing 24.5% of the pool,
are credit assessed. This is significantly higher than the 2018 and
YTD 2019 averages of 13.6% and 13.2%, respectively. Two loans, 350
Bush Street (6.5% of the pool) and 30 Hudson Yards (6.5% of the
pool), each received stand-alone credit opinions of 'A-sf*'. Two
loans, Grand Canal Shoppes (7.7% of the pool) and Moffett Towers -
Buildings 3 & 4 (3.8% of the pool), each received stand-alone
credit opinions of 'BBB-sf*'.

Higher Collateral Quality: The pool's collateral quality is higher
than that of recent transactions. As a percentage of
Fitch-inspected properties, 34.4% received a property quality grade
of 'A-' or higher, which is higher than the 2018 and YTD 2019
averages of 20.5% and 21.3%, respectively. Four loans received a
property quality grade of 'A', including: Grand Canal Shoppes (7.7%
of the pool), 350 Bush Street (6.5% of the pool), 30 Hudson Yards
(6.5% of the pool), and Moffett Towers - Buildings 3 & 4 (3.8% of
the pool). As a percentage of Fitch-inspected properties, 83.8%
received a property quality grade of 'B+' or higher, which is
higher than the 2018 and YTD 2019 average of 48.9% and 48.9%,
respectively.


BBCMS 2017-DELC: DBRS Confirms B Rating on Class HRR Certs
----------------------------------------------------------
DBRS Limited confirmed the ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2017-DELC issued by BBCMS
2017-DELC Mortgage Trust as follows:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. This transaction closed in August
2017, at an original trust balance of $507.6 million, with three
mezzanine loans totaling $204.4 million held outside of the trust.
The collateral for this transaction is the Hotel del Coronado,
located on Coronado Island in the greater San Diego area. The
underlying trust loan is interest-only (IO) throughout the term,
structured with a two-year initial term with five one-year
extension options. The servicer has confirmed the sponsor has
exercised the first extension option, which will be effective on
August 2019. The loan is sponsored by Blackstone Real Estate
Partners VIII L.P., an affiliate of The Blackstone Group Inc., the
world's largest alternative asset manager and real estate advisory
firm. The hotel previously operated as an independent hotel but is
now managed by Hilton Worldwide Holdings Inc. (Hilton) under the
Curio Collection flag, which is one of Hilton's upscale brands. The
hotel management agreement with Hilton began on July 2017 and runs
through July 2027, containing two five-year extension options.

The sponsor has exhibited a strong commitment to maintaining and
upgrading the property since acquiring an ownership interest in
2011. Since 2004, roughly $106.2 million ($156,363 per key on owned
rooms) has been invested into the property. As of the servicer's
March 2019 property inspection report, there was reported $330.0
million of CAPEX budgeted for improvements through year-end (YE)
2021. The massive project to be completed in two phases over the
next few years will include a complete refresh of all guest rooms
by 2021. The sponsor also plans to construct additional indoor and
outdoor meeting spaces, 149 new guest suites and a three-level
parking structure supplying an additional 750 spaces. This project
was under consideration at issuance but had not been finalized at
the time of the loan's closing; as such, there are no reserve funds
structured for these renovations. DBRS has requested confirmation
of the source of funding and is awaiting the servicer's response.

Per the trailing 12 months (T-12) ending May 31, 2019, the subject
reported an occupancy rate, average daily rate and revenue per
available room (RevPAR) of 75.0%, $438.78 and $329.22,
respectively. The subject is outperforming its competitive set,
with occupancy rate and RevPAR increases of 3.6% and 7.9% year over
year, respectively. In addition, RevPAR is up substantially from
issuance, when it was reported at $262.48 for the T-12 ending June
30, 2017. At issuance, DBRS noted that the new affiliation with
Hilton could improve overall performance as guests loyal to the
brand could be attracted to the property and rooms could be booked
within the Hilton system; given the RevPAR trends for the property
over the past few years, the affiliation certainly appears to be
contributing to increased bookings. In addition, with its unique
historic status and highly desirable location with over 1,400
linear feet of ocean frontage and a relatively substantial meeting
and event space footprint of over 135,000 square feet, the hotel
has no true direct competition in the vicinity or even in the
larger Southern California market overall.

According to the YE2018 financials, the servicer's calculated DSCR
for the trust portion of the loan was 1.80 times (x), compared with
the YE2017 DSCR of 1.76x and the DBRS Term DSCR at issuance of
1.63x. Although an in-place DSCR for the whole loan was not
reported, DBRS derived an estimate based on a stressed interest
rate scenario that implied a whole-loan DSCR of 1.45x as at YE2018
and 1.25x at YE2017.

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

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


BENCHMARK 2019-B12: Fitch Rates $11.478MM Class G-RR Certs B-sf
---------------------------------------------------------------
Fitch Ratings has assigned the following Ratings and Rating
Outlooks to Benchmark 2019-B12 Mortgage Trust commercial mortgage
pass-through certificates, Series 2019-B12:

  -- $16,310,000 class A-1 'AAAsf'; Outlook Stable;

  -- $221,930,000 class A-2 'AAAsf'; Outlook Stable;

  -- $5,920,000 class A-3 'AAAsf'; Outlook Stable;

  -- $215,000,000 class A-4 'AAAsf'; Outlook Stable;

  -- $321,699,000 class A-5 'AAAsf'; Outlook Stable;

  -- $22,612,000 class A-AB 'AAAsf'; Outlook Stable;

  -- $946,949,000a class X-A 'AAAsf'; Outlook Stable;

  -- $143,478,000 class A-S 'AAAsf'; Outlook Stable;

  -- $50,217,000 class B 'AA-sf'; Outlook Stable;

  -- $43,043,000 class C 'A-sf'; Outlook Stable;

  -- $93,260,000ab class X-B 'A-sf'; Outlook Stable;

  -- $41,608,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $24,391,000b class D 'BBBsf'; Outlook Stable;

  -- $17,217,000b class E 'BBB-sf'; Outlook Stable;

  -- $20,087,000b class F-RR 'BB-sf'; Outlook Stable;

  -- $11,478,000b class G-RR 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $34,435,107b class J-RR;

  -- $34,054,400c class VRR Interest.

(a) Notional amount and interest-only.

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

(c) Vertical credit risk retention interest, which represents
approximately 5.00% of the certificate balance, notional amount or
percentage interest of each class of certificates.

The expected ratings are based on information provided by the
issuer as of Aug. 8, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 47 loans secured by 117
commercial properties having an aggregate principal balance of
$1,181,871,508 as of the cut-off date. The loans were contributed
to the trust by Citi Real Estate Funding Inc., JPMorgan Chase Bank,
National Association, and German American Capital Corporation.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 68.1% of the properties
by balance, cash flow analysis of 87.0%, and asset summary reviews
on 100.0% of the pool.

KEY RATING DRIVERS

High Percentage of Loans with Investment-Grade Credit Opinions:
Nine loans, representing 38.7% of the pool, have investment-grade
credit opinions. This is significantly above the YTD 2019 and 2018
averages of 13.1% and 13.6%, respectively. The largest loan, 30
Hudson Yards (7.9% of the pool) received a credit opinion of
'A-sf*' on a stand-alone basis. The Woodlands Mall (6.4% of the
pool) received a credit opinion of 'BBB-sf*' on a stand-alone basis
and Osborn Triangle (4.2% of the pool) received a credit opinion of
'BBB-sf*' on a stand-alone basis. 1000 Santa Monica Boulevard (4.2%
of the pool) received a credit opinion of 'BBBsf*' on a stand-alone
basis, Three Columbus Circle (4.2% of the pool) received a credit
opinion of 'BBB-sf*' on a stand-alone basis and Grand Canal Shoppes
(4.2% of the pool) received credit opinion of 'BBB-sf*' on a
stand-alone basis. An additional three loans outside the top 10
representing 7.5% of the pool also have investment-grade credit
opinions.

Fitch Leverage: The pool's Fitch trust leverage is better compared
with other recent Fitch-rated, fixed-rate, multiborrower
transactions. The pool's Fitch debt service coverage ratio (DSCR)
of 1.29x is slightly better than the YTD 2019 and 2018 averages of
1.21x and 1.22x, respectively. The pool's Fitch loan-to-value (LTV)
ratio of 91.2% is significantly better than the YTD 2019 and 2018
averages of 101.8% and 102.0%, respectively. Excluding investment
grade credit opinion loans, the pool has a Fitch DSCR and LTV of
1.20x and 107.4%, respectively.

Limited Amortization: Based on the scheduled balance at maturity,
the pool will pay down by just 3.8%, which is below the YTD 2019
and 2018 averages of 6.1% and 7.2%, respectively. Twenty-seven
loans are full interest-only (76.4% of the pool), 11 (10.9% of the
pool) are partial interest-only and nine (12.6% of the pool) are
amortizing balloon loans.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 14.2% 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
Benchmark 2019-B12 certificates and found that the transaction
displays average sensitivities to further declines in NCF. In a
scenario in which NCF declined a further 20% from Fitch's NCF, a
downgrade of the junior 'AAAsf' certificates to 'A+sf' could
result. In a more severe scenario, in which NCF declined a further
30% from Fitch's NCF, a downgrade of the junior 'AAAsf'
certificates to 'BBB+sf' could result. Page 12 of the presale
report includes a detailed explanation of additional stresses and
sensitivities.

DUE DILIGENCE USAGE

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Ernst & Young LLP. The third-party due diligence
described in Form 15E focused on a comparison and re-computation of
certain characteristics with respect to each of the mortgage loans.
Fitch considered this information in its analysis and it did not
have an effect on Fitch's analysis or conclusions. A copy of the
ABS Due Diligence Form 15-E received by Fitch in connection with
this transaction may be obtained via the link at the bottom of the
related rating action commentary.


BXP TRUST 2017-CC: DBRS Confirms BB Rating on Class E Certs
-----------------------------------------------------------
DBRS Limited confirmed the ratings of Commercial Mortgage
Pass-Through Certificates, Series 2017-CC issued by BXP Trust
2017-CC as follows:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. This transaction consists of a
ten-year, fixed-rate $350.0 million loans secured by Colorado
Center in Santa Monica, California, that is interest-only (IO)
throughout the entire loan term. The trust loan is part of a
split-loan structure, with an aggregate outstanding whole-loan
balance of $550.0 million. The collateral is an office park
consisting of six Class A buildings totaling 1.2 million square
feet and a three-level underground parking garage situated on a
15.0-acre plot of land. The property is located approximately 1.5
miles northeast of downtown Santa Monica, in the heart of the
city's media and entertainment area. According to the Q1 2019
financials, the loan reported an annualized DSCR of 3.21 times (x),
compared with the YE2018 ratio of 2.60x and the DBRS Term DSCR
derived at issuance of 2.24x.

The office park was originally built in 1984 and underwent
renovations in 2004 and more recently in 2018. The sponsor, Boston
Properties, Inc., injected $18.0 million in improvements into the
property in 2018 to improve the overall marketability of the
subject within the submarket. Renovations included major updates to
Building B, including demolishing and redemising the ground floor;
constructing two new elevator lobbies; adding new common restrooms;
and relocating the mechanical, electrical and plumbing
infrastructure. Renovations also included the addition of patio
spaces, amphitheater, site lighting and improved wayfinding
throughout the site.

As of the March 2019 rent roll, the subject was 95.8% occupied, an
increase compared with the March 2018 occupancy rate of 83.9%. The
three largest tenants are Hulu (22.3% of NRA, lease expires in
November 2021), Edmunds.com Inc. (Edmunds; 16.6% of NRA, lease
expires in January 2028) and Rubin Postaer and Associates (RPA;
14.1% of NRA, lease expires in December 2025). HBO (10.9% of NRA)
recently signed an 18-month extension option to December 2020 at
which point it will most likely be moving to its location in Culver
City, California. The servicer has stated that Hulu is in deep
negotiations to potentially occupy HBO's space when it becomes
available at YE2020, but nothing has been confirmed at the time of
this press release. At issuance, DBRS noted that existing tenant,
Edmunds (which houses its headquarters at the subject), was
expected at last review to expand into the third floor of the 2401
Colorado Avenue building at a ten-year term beginning in August
2018 and has been confirmed by the servicer. In addition to
Edmunds, the subject also serves as the headquarters for Hulu, RPA
and Kite Pharma, Inc.

DBRS believes the property is well-positioned within the market
given the sponsor's recent capital investment and plans for
additional upgrades to improve the property's competitive standing.
The market dynamics remain stable from issuance, with REIS
reporting a Q1 2019 office vacancy rate of 10.9% with an average
rental rate of $61.91 per square foot in the Santa Monica
submarket.

Class X-A is an IO certificate that references a single rated
tranche or multiple rated tranches. The IO rating mirrors the
lowest-rated applicable reference obligation tranche adjusted
upward by one notch if senior in the waterfall.

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


CITIGROUP 2019-GC41: DBRS Gives (P)B(high) Rating on GRR Certs
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-GC41 to
be issued by Citigroup Commercial Mortgage Trust 2019-GC41:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-AB at AAA (sf)
-- Class AS at AAA (sf)
-- Class X-A at AAA (sf)
-- Class B as AA (high) (sf)
-- Class X-B at AA (low) (sf)
-- Class C at A (high) (sf)
-- Class D at BBB (high) (sf)
-- Class X-D at BBB (high) (sf)
-- Class E at BBB (sf)
-- Class F at BB (high) (sf)
-- Class X-F at BBB (low) (sf)
-- Class G-RR at B (high) (sf)

All trends are Stable.

Classes X-B, X-D, D, E, X-F, F, and G-RR will be privately placed.

The collateral consists of 43 fixed-rate loans secured by 64
commercial and multifamily properties. The transaction is of a
sequential-pay pass-through structure. The conduit pool was
analyzed to determine the provisional ratings, reflecting the
long-term probability of loan default within the term and its
liquidity at maturity. Four loans, representing a combined 18.0% of
the pool, are shadow-rated investment grade by DBRS. When the
cut-off loan balances were measured against the DBRS Stabilized Net
Cash Flow and their respective actual constants, two loans,
representing a combined 1.7% of the pool, had a DBRS Term Debt
Service Coverage Ratio below 1.15 times, a threshold indicative of
a higher likelihood of mid-term default. The pool additionally
includes seven loans, representing a combined 10.2% of the pool by
allocated loan balance, with issuance loan-to-values (LTVs) in
excess of 67.1%, a threshold historically indicative of
above-average default frequency. The weighted-average (WA) LTV of
the pool at issuance was 58.4%, and the pool is scheduled to
amortize down to a WA LTV of 56.5% at maturity.

The collateral features four loans, representing a combined 18.0%
of the pool, that is shadow-rated investment grade by DBRS: 30
Hudson Yards, Grand Canal Shoppes, Moffett Towers II Buildings 3 &
4 and The Centre. 30 Hudson Yards exhibit credit characteristics
consistent with an A (high) shadow rating, Grand Canal Shoppes
exhibits credit characteristics consistent with a BBB (high) shadow
rating, Moffett Towers II Buildings 3 & 4 exhibits credit
characteristics consistent with a AA shadow rating and The Centre
exhibits credit characteristics consistent with a BBB (high) shadow
rating.

Only one loan, representing 0.9% of the pool by allocated loan
balance, was assigned Average (-) property quality, while no
properties were deemed Below Average or Poor quality.

Additionally, 11 loans representing 46.6% of the pool by allocated
loan balance, exhibited either Average (+), Above Average or
Excellent property quality. The pool's largest loan, 30 Hudson
Yards, is secured by collateral that DBRS deems to be of Excellent
property quality. Additionally, ten loans, representing a combined
35.3% of the pool, are located in areas with a DBRS Market Rank of
6, 7 or 8, which are characterized as urbanized locations. These
markets benefit from increased liquidity that is driven by
consistently strong investor demand. Such markets, therefore, tend
to benefit from lower default frequencies than less dense suburban,
tertiary and rural markets. Areas with a DBRS Market Rank of 7 or 8
are especially densely urbanized and benefit from significantly
elevated liquidity. Nine loans, representing 30.6% of the pool by
allocated loan balance, are located in areas with a DBRS Market
Rank of 7 or 8.

Seven loans, representing 30.1% of the aggregate pool balance, are
secured by properties that are either fully or partially leased to
a single tenant. The largest single-tenant property by the
proportion of pool balance (30 Hudson Yards) represents 7.8% of the
aggregate pool balance, and five of the top ten loans by the
proportion of pool balance are either fully or partially leased to
a single tenant. DBRS sampled six of the seven loans secured by
single-tenant properties. Additionally, two of the seven loans
leased to a single-tenant are shadow-rated investment grade by DBRS
(30 Hudson Yards and Moffett Towers II Buildings 3 & 4). Six of the
seven identified properties are leased to single tenants that DBRS
considers to be investment-grade rated: 30 Hudson Yards, USAA
Office Portfolio, Moffett Towers II Buildings 3 & 4, Powered Shell
Portfolio – Manassas, Powered Shell Portfolio – Ashburn and
Comcast Building Tucson. The Zappettini Portfolio is secured by ten
individual real estate properties that, while individuals may be
either fully or partially leased to a single-tenant, are occupied
by 13 tenants across eight separate leases at the time of loan
closing.

The pool has a relatively high concentration of loans secured by
office properties, as evidenced by 11 loans, representing 33.3% of
the pool by allocated loan balance, being secured by such
properties. DBRS considers office properties to be a riskier
property type with a generally above-average default frequency. Of
the 11 loans secured by office properties, two loans, representing
9.5% of the pool by allocated loan balance, are shadow-rated
investment grade by DBRS: 30 Hudson Yards and Moffett Towers II
Buildings 3 & 4. Two of the 11 identified loans, representing 8.5%
of the pool by allocated loan balance, are secured by office
properties located in areas with a DBRS Market Rank of 8, which is
characterized as a highly dense, urbanized area such as New York or
San Francisco. These markets benefit from increased liquidity that
is driven by consistently strong investor demand. Such markets,
therefore, tend to benefit from lower default frequencies than less
dense suburban, tertiary and rural markets. The WA expected loss of
the nine loans secured by office properties that are not located in
DBRS Market Rank 8 or are shadow-rated investment grade is more
than two times the WA expected loss of the overall pool. As a
result, the risk of these loans is reflected in the credit
enhancement levels of the pool.

Twenty-seven loans, representing a combined 80.5% of the pool by
allocated loan balance, are structured with full-term interest-only
(IO) periods. Expected amortization for the pool is only 2.7%,
which is substantially less than recent conduit securitizations. Of
the 27 loans structured with full-term IO periods, eight loans,
representing 29.1% of the pool by allocated loan balance, are
located in areas with a DBRS Market Rank of 7 or 8. These markets
benefit from increased liquidity that is driven by consistently
strong investor demand. Such markets, therefore, tend to benefit
from lower default frequencies than less dense suburban, tertiary
and rural markets. Four of the 27 identified loans, representing
18.0% of the pool by allocated loan balance, are shadow-rated
investment grade by DBRS: 30 Hudson Yards, Grand Canal Shoppes,
Moffett Towers II Buildings 3 & 4 and The Centre. The full-term
loans are for the most part pre-amortized, as the WA issuance LTV
for these loans is low at 55.7%.

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

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


CITIGROUP COMMERCIAL 2017-B1: Fitch Affirms BB- Rating on X-E Certs
-------------------------------------------------------------------
Fitch Ratings has affirmed 15 classes of Citigroup Commercial
Mortgage Trust, commercial mortgage pass-through certificates,
series 2017-B1.

Citigroup Commercial Mortgage Trust 2017-B1

              Current Rating      Prior Rating
Class A-1   LT AAAsf  Affirmed   previously at AAAsf
Class A-2   LT AAAsf  Affirmed   previously at AAAsf
Class A-3   LT AAAsf  Affirmed   previously at AAAsf
Class A-4   LT AAAsf  Affirmed   previously at AAAsf
Class A-AB  LT AAAsf  Affirmed   previously at AAAsf
Class A-S   LT AAAsf  Affirmed   previously at AAAsf
Class B     LT AA-sf  Affirmed   previously at AA-sf
Class C     LT A-sf   Affirmed   previously at A-sf
Class D     LT BBB-sf Affirmed   previously at BBB-sf
Class E     LT BB-sf  Affirmed   previously at BB-sf
Class F     LT B-sf   Affirmed   previously at B-sf
Class X-A   LT AAAsf  Affirmed   previously at AAAsf
Class X-B   LT AA-sf  Affirmed   previously at AA-sf
Class X-D   LT BBB-sf Affirmed   previously at BB-sf
Class X-E   LT BB-sf  Affirmed   previously at BB-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The affirmations are
based on the overall stable performance and loss expectations of
the pool with no material changes to pool metrics since issuance.
No loans are specially serviced, and one loan (0.2% of pool) was
designated a Fitch Loan of Concern (FLOC) because of performance
declines/concerns.

Minimal Change to Credit Enhancement: As of the July 2019
distribution date, the pool's aggregate balance has been reduced by
0.7% to $934.7 million from $941.6 million at issuance. Based on
the loans' scheduled maturity balances, the pool is expected to
amortize 6.7% during the term. Twenty loans (59.2% of pool) are
full-term, interest-only and 16 loans (19.7%) have a partial-term,
interest-only component.

ADDITIONAL CONSIDERATIONS

Pool Concentration: The top 10 loans make up 53.7% of the pool.
Loans maturities are concentrated in 2027 (91.1%). Two loans (5.8%)
mature in 2022, one (0.5%) in 2024 and one (2.6%) in 2026.

Regional Mall Exposure in Top 15: The second largest loan, Lakeside
Shopping Center (6.3% of pool), is secured by a 1.2 million sf
regional mall in Metairie, LA, approximately 8 miles northwest of
New Orleans. The collateral anchors are Dillard's, which recently
extended it lease for an additional 10 years through December 2029,
Macy's, which is on a ground lease and owns its own improvements,
and JCPenney. While recent tenant sales were requested but not
provided, at issuance and as of the TTM ended April 2017, in-line
sales excluding Apple were $651 sf. As of YE 2018, collateral
occupancy was 99%, and servicer-reported NOI DSCR was 2.59x.

Investment-Grade Credit Opinion Loans: At issuance, The General
Motors Building (9.9% of pool), Two Fordham Square (5.6%) and Del
Amo Fashion Center (2.2%) were assigned investment-grade credit
opinions of 'AAAsf', 'BBB-sf' and 'AA-sf', respectively.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable. Fitch does not
foresee positive or negative ratings migration until a material
economic or asset-level event changes the transaction's overall
portfolio-level metrics.

Deutsche Bank is the trustee for the transaction and also serves as
the backup advancing agent. Fitch's current Issuer Default rating
for Deutsche Bank is 'BBB'/'F2'. Fitch relies on the master
servicer, Wells Fargo & Company (A+/F1), which is currently the
primary advancing agent, as a direct counterparty.


COMM 2012-CCRE5: Fitch Affirms Bsf Rating on Cl. G Certs
--------------------------------------------------------
Fitch Ratings has affirmed 13 classes of Deutsche Bank Securities,
Inc., commercial pass-through certificates, series 2012-CCRE5.

COMM 2012-CCRE5

              Current Rating     Prior Rating
Class A-3   LT AAAsf  Affirmed  previously at AAAsf
Class A-4   LT AAAsf  Affirmed  previously at AAAsf
Class A-M   LT AAAsf  Affirmed  previously at AAAsf
Class A-SB  LT AAAsf  Affirmed  previously at AAAsf
Class B     LT AAsf   Affirmed  previously at AAsf
Class C     LT Asf    Affirmed  previously at Asf
Class D     LT BBB+sf Affirmed  previously at BBB+sf
Class E     LT BBB-sf Affirmed  previously at BBB-sf
Class F     LT BBsf   Affirmed  previously at BBsf
Class G     LT Bsf    Affirmed  previously at Bsf
PEZ         LT Asf    Affirmed  previously at Asf
Class X-A   LT AAAsf  Affirmed  previously at AAAsf
Class X-B   LT AAsf   Affirmed  previously at AAsf

KEY RATING DRIVERS

Stable Loss Expectations: The overall pool has exhibited relatively
stable performance, with loss expectations in line with Fitch's
prior rating action. There have been no realized losses to date.
Four loans (13.7% of pool) were designated as Fitch Loans of
Concern (FLOCs), including two retail loans in the top 15 (12.4%),
due to performance declines and refinance concerns.

Regional Mall Exposure; Fitch Loans of Concern: The largest FLOC is
the largest loan in the pool, Eastview Mall and Commons (10.5%),
which is secured by a regional mall and power center in Victor, NY.
The loan was designated as a FLOC due to declining collateral
occupancy since issuance, with the potential for further
performance deterioration due to lack of updated sales reporting
and lease rollover concerns during the loan term. The
non-collateral Sears, which is owned by Seritage Growth Properties,
closed in 4Q18; the borrower is currently working with prospects to
backfill the space, but nothing has been finalized.

The next largest FLOC in the top 15 is the Belvedere Plaza loan
(1.9%), which is secured by a grocery-anchored (Kroger) retail
center in Decatur, GA. The loan was flagged for declining cash
flow, primarily from declining occupancy since issuance.
Additionally, two smaller loans outside of the top 30 (1.3%), which
are secured by a multifamily and an industrial property, were
flagged for declining cash flow from increased operating expenses
or lower occupancy since issuance.

Increased Credit Enhancement: Credit enhancement has increased
since issuance from amortization and loan repayments. One
previously specially serviced loan (0.4%) was paid in full post
maturity since Fitch's prior rating action. As of the July 2019
distribution date, the pool's aggregate principal balance was paid
down by 24.3% to $858.1 million from $1.1 billion at issuance. Nine
loans (19.7%) are fully defeased. Two loans (11%) are full-term
interest only (IO). Nine loans (18.9%) that had a partial-term IO
period at issuance have all begun amortizing.

Pool/Maturity Concentrations: Forty-six of the original 63 loans
remain in the pool. Retail, office and multifamily properties
comprise 35.7%, 32.4% and 12.4% of the pool, respectively. All of
the remaining loans mature in 2022.

Alternative Loss Considerations: To factor in upcoming refinance
concerns, Fitch performed an additional sensitivity scenario on the
Eastview Mall and Commons and Belvedere Plaza loans, which assumed
potential outsized losses of 20% and 25% on their respective
balloon balances. The scenario also factored in the expected
paydown of the transaction from fully defeased loans. This scenario
contributed to maintaining the Negative Rating Outlook on class G.

RATING SENSITIVITIES

The Negative Rating Outlook on class G reflects refinance concerns
and additional sensitivity analysis performed on the two largest
FLOCs. This class could be downgraded should the performance at
Eastview Mall and Commons and Belvedere Plaza further decline or
these loans fail to pay off at maturity. The Stable Rating Outlooks
for classes A-SB through F reflect the stable performance of the
majority of the underlying pool and expected continued
amortization. Rating upgrades, although unlikely due to pool
concentrations, could occur with improved pool performance and
increased credit enhancement from additional paydown or defeasance.


COMM 2017-COR2: Fitch Affirms B-sf Rating on Class G-RR Debt
------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of COMM 2017-COR2 Commercial
Mortgage Trust, Series 2017-COR2.

COMM 2017-COR2

                         Current Rating     Prior Rating
Class A-1 12595EAA3   LT  AAAsf   Affirmed  previously at AAAsf
Class A-2 12595EAC9   LT  AAAsf   Affirmed  previously at AAAsf
Class A-3 12595EAD7   LT  AAAsf   Affirmed  previously at AAAsf
Class A-M 12595EAF2   LT  AAAsf   Affirmed  previously at AAAsf
Class A-SB 12595EAB1  LT  AAAsf   Affirmed  previously at AAAsf
Class B 12595EAG0     LT  AA-sf   Affirmed  previously at AA-sf
Class C 12595EAH8     LT  A-sf    Affirmed  previously at A-sf
Class D 12595EAN5     LT  BBBsf   Affirmed  previously at BBBsf
Class E-RR 12595EAQ8  LT  BBB-sf  Affirmed  previously at BBB-sf
Class F-RR 12595EAS4  LT  BBsf    Affirmed  previously at BBsf
Class G-RR 12595EAU9  LT  B-sf    Affirmed  previously at B-sf
Class X-A 12595EAE5   LT  AAAsf   Affirmed  previously at AAAsf
Class X-B 12595EAJ4   LT  AA-sf   Affirmed  previously at AA-sf
Class X-D 12595EAL9   LT  BBBsf   Affirmed  previously at BBBsf

KEY RATING DRIVERS

Stable Loss Expectations: The pool is performing in line with
Fitch's expectations. There are no delinquent or specially serviced
loans, and no loans have been designated as Fitch Loans of Concern.
One loan is on the servicer's watchlist for a dip in reported DSCR.
The asset is a multifamily property located in Bay City, TX that
experienced revenue decline when several companies pulled their
contracts at the property and occupancy declined. The borrower has
since marketed the vacant units to the general public and occupancy
has increased to 96% as of March 2019.

Minimal Changes to Credit Enhancement: The deal closed in September
2018. Since then, the pool has amortized 0.6%. Fourteen loans
representing 42.3% of the pool balance are interest-only for the
full term. An additional 17 loans representing 32.9% of the pool
were structured with partial interest-only periods, and as of the
July 2019 remittance none of these loans has begun amortizing. All
of the pooled loans are scheduled to mature between 2026 and 2027.


RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable. Fitch does not
foresee positive or negative ratings migration until a material
economic or asset-level event changes the transaction's overall
portfolio-level metrics.


CROWN POINT 8: Moody's Gives (P)Ba3 Rating on $23.45MM Cl. E Notes
------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to five
classes of notes to be issued by Crown Point CLO 8 Ltd.

Moody's rating action is as follows:

US$292,500,000 Class A Senior Secured Floating Rate Notes due 2032
(the "Class A Notes"), Assigned (P)Aaa (sf)

US$47,500,000 Class B Senior Secured Floating Rate Notes due 2032
(the "Class B Notes"), Assigned (P)Aa2 (sf)

US$21,000,000 Class C Secured Deferrable Mezzanine Floating Rate
Notes due 2032 (the "Class C Notes"), Assigned (P)A2 (sf)

US$27,300,000 Class D Secured Deferrable Mezzanine Floating Rate
Notes due 2032 (the "Class D Notes"), Assigned (P)Baa3 (sf)

US$23,450,000 Class E Secured Deferrable Junior Floating Rate Notes
due 2032 (the "Class E Notes"), Assigned (P)Ba3 (sf)

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

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

RATINGS RATIONALE

The 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.

Crown Point 8 is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90% of the portfolio must consist of
senior secured Loans, and up to 10% of the portfolio may consist of
second lien loans or unsecured loans. Moody's expects the portfolio
to be approximately 80% ramped as of the closing date.

Pretium Credit 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 will issue subordinated
notes.

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

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

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

Par amount: $450,000,000

Diversity Score: 60

Weighted Average Rating Factor (WARF): 2790

Weighted Average Spread (WAS): 3.45%

Weighted Average Coupon (WAC): 6.50%

Weighted Average Recovery Rate (WARR): 47.50%

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.


CS MORTGAGE 2006-CF3: Moody's Cuts Class M-2 Certs Rating to Caa3
-----------------------------------------------------------------
Moody's Investors Service upgraded the rating of Cl. M-2 from CS
Mortgage-Backed Pass-Through Certificates, Series 2006-CF3.

Complete rating actions are as follows:

Issuer: CS Mortgage-Backed Pass-Through Certificates, Series
2006-CF3

  Cl. M-2, Upgraded to Caa3 (sf); previously on May 24, 2011
  Downgraded to C (sf)

RATINGS RATIONALE

The rating upgrade is primarily due to the increase in credit
enhancement available to the bond, and reflects the improvement in
collateral performance and Moody's updated loss expectations on the
underlying pool.

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 3.7% in July 2019 from 3.9% in July
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 changes resulting from
servicing transfers, or other policy or regulatory shifts can
impact the performances of these transactions.


DT AUTO 2019-3: DBRS Finalizes BB Rating on $23.5MM Class E Notes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of Notes issued by DT Auto Owner Trust 2019-3 (DTAOT 2019-3
or the Issuer):

-- $215,020,000 Class A Notes at AAA (sf)
-- $49,090,000 Class B Notes at AA (sf)
-- $77,720,000 Class C Notes at A (sf)
-- $73,130,000 Class D Notes at BBB (sf)
-- $23,520,000 Class E Notes at BB (sf)

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

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

-- DTAOT 2019-3 provides for Class A, B, C, D and E coverage
multiples slightly below the DBRS range of multiples set forth in
the criteria for this asset class. DBRS believes that this is
warranted, given the magnitude of expected loss and structural
features of the transaction.

-- The transaction parties' capabilities with regard to
origination, underwriting, and servicing.

-- The quality and consistency of the provided historical static
pool data for DriveTime Automotive Group, Inc. (DriveTime)
originations and the performance of the DriveTime auto loan
portfolio.

-- A June 2019 letter delivered by the CFPB to DriveTime seeking
to determine whether lenders or associated persons may have
extended credit to covered persons on prohibited terms or without
the required disclosures in a manner that violated and is not
exempt from the Military Lender Act. The DTAOT 2019-3 transaction
has no collateral or accounts that could be considered in the scope
of the CFPB letter.

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

The DTAOT 2019-3 transaction represents a securitization of a
portfolio of motor vehicle retail installment sales contracts
originated by DriveTime Car Sales Company, LLC (the Originator).
The Originator is a direct, wholly-owned subsidiary of DriveTime.
DriveTime is a leading used vehicle retailer in the United States
that focuses primarily on the sale and financing of vehicles to the
subprime market.

The rating on the Class A Notes reflects the 59.45% of initial hard
credit enhancement provided by the subordinated Notes in the pool,
the Reserve Account (1.50%) and overcollateralization (14.25%). The
ratings on Class B, C, D and E Notes reflect 49.85%, 34.65%, 20.35%
and 15.75% of initial hard credit enhancement, respectively.
Additional credit support may be provided from excess spread
available in the structure.

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


EATON VANCE 2013-1: S&P Assigns BB-(sf) Rating to Class D-RR Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1-RR,
A-2-RR, B-RR, C-RR, and D-RR replacement notes, and the new class
A-X-RR note, from Eaton Vance CLO 2013-1 Ltd., a collateralized
loan obligation (CLO) originally issued in 2013, and subsequently
reset in 2016, that is managed by Eaton Vance Management. S&P
withdrew its ratings on the original class A-1-R, A-2-R, B-R, C-R,
and D-R notes following payment in full on the Aug. 9, 2019,
refinancing date. At the same time, S&P affirmed its ratings on the
class E-R notes.

On the Aug. 9, 2019, refinancing date, the proceeds from the
replacement notes issuance were used to redeem the original notes
as outlined in the transaction document provisions. Therefore, S&P
withdrew its ratings on the original notes in line with their full
redemption, and assigned ratings to the replacement notes.

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

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

S&P will continue to review whether, in its view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them, and it will take further rating actions
as it deems necessary.

  RATINGS ASSIGNED

  Eaton Vance CLO 2013-1 Ltd.

  Replacement class         Rating      Amount (mil. $)
  A-1-RR                    AAA (sf)             270.60
  A-2-RR                    AA (sf)               48.90
  B-RR                      A (sf)                27.50
  C-RR                      BBB- (sf)             21.00
  D-RR                      BB- (sf)              21.00

  New class                 Rating      Amount (mil. $)
  A-X-RR                    AAA (sf)               1.50

  RATINGS WITHDRAWN

  Eaton Vance CLO 2013-1 Ltd.

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

  RATING AFFIRMED
  
  Eaton Vance CLO 2013-1 Ltd.

  Class         Rating      
  E-R           B- (sf)             

  NR--Not rated.


GCAT TRUST 2019-RPL1: Moody's Assigns B3 Rating on Class B-2 Notes
------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to seven
classes of notes issued by GCAT 2019-RPL1 Trust, which are backed
by one pool of primarily re-performing residential mortgage loans.
As of the statistical cut-off date of June 30, 2019, the collateral
pool is comprised of 1,754 first and junior lien mortgage loans,
with a weighted average updated primary borrower FICO score of 649,
a WA current loan-to-value Ratio for the first liens of 85.0% and a
total unpaid balance of $297,685,029. The deal balance is
$298,862,557, which includes pre-existing servicing advances of
$1,177,529. Approximately 8.7% of the pool balance is non-interest
bearing, which consists of both principal reduction alternative and
non-PRA deferred principal balance. Of note, approximately 5.6% of
the loans by balance are backed by manufactured housing. Moody's
took these loans into account in its loss analysis based on
historical performance data of loans backed by MH collateral.

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: GCAT 2019-RPL1 Trust

Class A-1, Assigned (P)Aaa (sf)

Class M-1, Assigned (P)Aa2 (sf)

Class M-2, Assigned (P)A3 (sf)

Class M-3, Assigned (P)Baa3 (sf)

Class B-1, Assigned (P)Ba3 (sf)

Class B-2, Assigned (P)B3 (sf)

Class B-3, Assigned (P)C (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected losses on GCAT 2019-RPL1's collateral pool is
16.50% in its base case scenario. Its loss estimates take into
account the historical performance of loans that have similar
collateral characteristics as the loans in the pool. Its 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

GCAT 2019-RPL1's collateral pool is primarily comprised of
re-performing mortgage loans. About 88.1% 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 24.1% 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
Moody's applies assumptions of future delinquencies, default rates,
loss severities and prepayments based on observed performance of
similar collateral. Moody's project 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, Moody's expects an
annual delinquency rate of 14% on the collateral pool for year one,
for non-manufactured homes portion. Moody's then calculated future
delinquencies on the pool using its default burnout and voluntary
conditional prepayment rate (CPR) 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 GCAT 2019-RPL1'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 (LTVs). Moody's applied a higher
baseline lifetime default propensity for interest-only loans, using
the same adjustments. To calculate the expected loss for the pool,
Moody's applied a loan-level loss severity assumption based on the
loans' updated estimated LTVs. Moody's 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.

In addition, Moody's assumed higher losses for loans backed by
manufactured houses (MH) based on the historical performance
observed on the performance of MH loans.

As of the statistical cut-off date, approximately 8.7% 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 $512,746 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, Moody's applied a
slightly higher default rate than what Moody's 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, Moody's 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. 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 analysis. The scenarios encompass six loss levels, fourr
loss timing curves, and fourr prepayment curves.

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 baliee, (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.

The diligence provider noted 53 delinquent property tax exceptions,
16 property tax exceptions and two municipal lien sales 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.

The diligence provider also noted 90 prior mortgages, 8 prior liens
and 25 deed vesting issues. 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 or
repurchase the mortgage loan.

In addition, the diligence provider noted 28 HOA liens and 49
municipal liens. 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 in an amount
equal to the lesser of (i) the amount necessary to cure the
exception and (ii) such realized loss. This is slightly weaker
compared to other RPL transactions, 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 difference to
be credit neutral as the total HOA and municipal lien amount
($455,631) 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 41 data fields for each
loan in the pool which resulted in 1,529 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)

Moody's considers the overall R&W framework to be relatively weaker
compared to CMLTI transactions, as the sponsor or its affiliate can
also be the controlling holder, in GCAT 2019-RPL1, which could
create potential conflict of interest. In addition, Moody's
considers the seller's financial capacity and lack of a track
record in rated transactions of observed repurchasing to be a
weakness. Moody's increased its loss expectations to account for a
portion of the defaults that may have unremedied breaches.

The R&W providers are the sellers, MITT RPL TRS LLC and MITT RPL
LLC, wholly-owned subsidiaries of AG Mortgage Investment Trust
(MITT). Although the R&W provider is affiliated with MITT, a
publicly traded REIT, MITT has no contractual obligation with
respect to R&W breaches or duty to maintain the sound financial
condition of the R&W provider and cause it to be well capitalized
at all times in light of its obligations under the transaction
documents. The creditworthiness of the R&W provider determines the
probability that the R&W provider will be available and have the
financial strength to repurchase defective loans upon identifying a
breach. An investment-grade-rated R&W provider lends substantial
strength to its R&Ws. For financially weaker entities, Moody's
looks for other offsetting factors, such as a strong alignment of
interest and enforcement mechanisms, to derive the same level of
protection. Moody's analyzes the impact of less creditworthy R&W
providers case by case, in conjunction with other aspects of the
transaction. Mortgage loans will be reviewed for a breach of R&Ws
only if one of the following occurs (1) a Trigger Event has
occurred following a Threshold Event or (2) a Controlling Holder
Review Event has occurred. Furthermore, no breach will be remedied
unless (1) a Trigger Event has occurred and (2) the Remedial
Conditions have been satisfied.

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 (i.e. any reduction in the amount paid by a mortgage insurer or
title insurer) .

Trustee Indemnification

Moody's believes there is a very low likelihood that the rated
notes in GCAT 2019-RPL1 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, 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.

Servicing arrangement

Although operationally capable, Moody's views Fay's stability as
weak due to its size and private ownership structure. Since the
transaction lacks a master or a backup servicer, if Fay were to
encounter financial or operational difficulties, there could be a
disruption of cash flow to the bondholders due to higher
delinquencies or failure by the servicer to remit payments to the
trust. Mitigants to address this risk include the trust
administrator's obligation (at the written direction of the
controlling holder) to appoint another servicer upon a servicer
event of default, and the fact that servicing transfers in RMBS are
relatively common. In addition, the servicer does not advance
principal and interest on delinquent loans in this transaction
which would make servicing transfer easier as the replacement
servicer will not be obligated to make P&I advances. In addition
the program administrator, Red Creek Asset Management LLC, will
oversee the servicer. Moody's considers the overall servicing
arrangement to be credit neutral.

Transaction Parties

Fay will be the primary servicer for all loans in the pool. Wells
Fargo Bank, will act as the custodian. Wells Fargo Bank, N.A., will
be the trust administrator, and Wilmington Savings Fund Society,
FSB will be the indenture trustee and owner 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.


GLS AUTO 2019-3: S&P Rates $37.8MM Class D Notes 'BB- (sf)'
-----------------------------------------------------------
S&P Global Ratings assigned its ratings to GLS Auto Receivables
Issuer Trust 2019-3's automobile receivables-backed notes series
2019-3.

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

The ratings reflect:

-- The availability of approximately 50.5%, 41.3%, 32.9%, and
25.5% of credit support for the class A, B, C, and D notes,
respectively, based on stressed cash flow scenarios (including
excess spread). These credit support levels provide coverage of
approximately 2.50x, 2.00x, 1.55x, and 1.22x S&P's 19.25%-20.25%
expected cumulative net loss (CNL) for the class A, B, C, and D
notes, respectively;

-- The expectation that under a moderate ('BBB') stress scenario
(1.55x S&P's expected loss level), all else being equal, S&P's
rating on the class A and B notes will remain within one rating
category of the assigned 'AA (sf)' and 'A (sf)' ratings and its
rating on the class C notes will remain within two rating
categories of the assigned 'BBB (sf)' rating. The class D notes
will remain within two rating categories of the assigned 'BB- (sf)'
rating during the first year but will eventually default under the
'BBB' stress scenario. These rating movements are within the limits
specified by S&P's credit stability criteria;

-- S&P's analysis of over five years of origination static pool
data and securitization performance data on Global Lending Services
LLC's six Rule 144A securitizations;

-- The collateral characteristics of the subprime automobile loans
securitized in this transaction, including the representation in
the transaction documents that all contracts in the pool have made
a least one payment;

-- The notes' underlying credit enhancement in the form of
subordination, overcollateralization, a reserve account, and excess
spread for the class A, B, C, and D notes; and

-- The timely interest and principal payments made to the notes
under S&P's stressed cash flow modeling scenarios, which it
believes are appropriate for the assigned ratings.

  RATINGS ASSIGNED

  GLS Auto Receivables Issuer Trust 2019-3

  Class     Rating          Amount (mil. $)

  A         AA (sf)                  225.40
  B         A (sf)                    62.80
  C         BBB (sf)                  48.00
  D         BB- (sf)                  37.80


GS MORTGAGE 2018-HULA: DBRS Confirms B(low) Rating on G Certs
-------------------------------------------------------------
DBRS Limited confirmed all classes of Commercial Mortgage
Pass-Through Certificates, Series 2018-HULA issued by GS Mortgage
Securities Corporation Trust 2018-HULA as follows:

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

All trends are Stable.

The rating confirmations reflect the continued stable performance
of the collateral since the transaction closed in July 2018. The
loan is secured by the fee simple and leasehold interests in three
distinct components of the master-planned luxury resort community
at the Four Seasons Resort Hualālai, situated along Kohala Coast
in Kailua-Kona on the Big Island of Hawaii. Loan proceeds of $450.0
million were used to retire outstanding debt of $373.3 million
($300.0 million CMBS mortgage loan securitized in GSCCRE
2015-HULA), to return $62.2 million of equity to the sponsor and to
cover reserves as well as closing and origination costs. The whole
loan originally consisted of a $350 million trust note and a
subordinate note of $100.0 million. As of the July 2019 remittance,
there has been principal repayment of $2.3 million, as portions of
undeveloped land that had been included in the collateral were sold
for residential development. The loan is structured with an initial
two-year interest-only (IO) term with five one-year extension
options.

The collateral consists of a 243-key resort spread across 39 acres,
a private membership club, and at issuance, 250 acres of
residential land planned to become a 483-unit community. The
five-star resort and membership club offer eight restaurants, a
30,700-square foot (sf) world-class spa and sports club, seven
pools, over 37,000 sf of indoor and outdoor meeting and event
space, five retail outlets and two golf courses. The loan was added
to the servicer's watchlist in June 2019, as the debt yield on the
whole loan decreased to 5.0% in Q1 2019. As a result, the loan will
be subject to a cash trap until the debt yield exceeds 6.25% for
two consecutive quarters.

According to the trailing 12-month (T-12) March 2019 STR report,
the property's occupancy, average daily rate (ADR) and revenue per
available room (RevPAR) were 69.2%, $1,268 and $877, respectively,
compared with the competitive set's reported figures of 70.4%, $370
and $261, respectively. The subject is in line with the competitive
set in terms of occupancy; however, it did experience a 19.4%
year-over-year occupancy decline primarily driven by the May 2018
volcano eruption. Although the property is 55 miles away from the
volcano and was not directly affected, many guests canceled or
postponed their trips to the resort. The subject is drastically
outperforming its competitive set in terms of ADR and RevPAR,
consistent with its elite brand and offerings. It is DBRS's opinion
that the true competitive set for the subject consists of other
luxury resorts found on Hawaii's other islands.

According to YE2018 financials, the debt service coverage ratio
(DSCR) was 1.79 times (x) compared with the DBRS Term DSCR of
1.86x, with the difference mainly driven by a decline in room
revenue. The Big Island is a severely supply-constrained market
with high barriers to entry given the lack of available zoned
resort land and arduous entitlement process. Since the subject was
constructed in the 1990s, there have been no new luxury hotels
constructed, and there are no new developments planned in the near
future. Although the property did experience a substantial decline
in occupancy compared with the previous period, due to the
subject's impressive accreditations and high barriers to entry on
the Big Island, DBRS expects the property to remain the premier
hotel destination for the foreseeable future.

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

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


GSAMP TRUST 2005-HE3: Moody's Hikes Class M-4 Debt Rating to B3
---------------------------------------------------------------
Moody's Investors Service upgraded the rating of three tranches
from two transactions backed by Subprime loans, issued by GSAMP
Trust.

The complete rating actions are as follows:

Issuer: GSAMP Trust 2005-HE3

Cl. M-4, Upgraded to B3 (sf); previously on Feb 21, 2014 Upgraded
to Caa3 (sf)

Issuer: GSAMP Trust 2007-HE2

Cl. A-1, Upgraded to Caa2 (sf); previously on Jun 21, 2010
Downgraded to Caa3 (sf)

Cl. A-2D, Upgraded to Caa3 (sf); previously on Jun 21, 2010
Downgraded to Ca (sf)

RATINGS RATIONALE

The rating actions are a result of the recent performance of the
underlying pools and reflect Moody's updated loss expectation on
the pools. The ratings upgrades are a result of improving
performance of the related pools and/or an increase in the credit
enhancement available to the bonds.

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

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


Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in July 2019 from 3.9% in July
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.


HERTZ VEHICLE 2015-3: Fitch Affirms BBsf Rating on Class D Notes
----------------------------------------------------------------
Fitch Ratings has affirmed the outstanding rental car ABS notes
issued by Hertz Vehicle Financing II LP as a result of its annual
review of the trust series.

Hertz Vehicle Financing II LP, Series 2015-3

                      Current Rating   Previous Rating
Class A 42806DAH2  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DAJ8  LT Asf   Affirmed  previously at Asf
Class C 42806DAK5  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DAL3  LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2016-2

Class A 42806DAU3  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DAV1  LT Asf   Affirmed  previously at Asf
Class C 42806DAW9  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DAX7  LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2016-3

Class A 42806DAY5  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DAZ2  LT Asf   Affirmed  previously at Asf
Class C 42806DBA6  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DBB4  LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2016-4

Class A 42806DBC2  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DBD0  LT Asf   Affirmed  previously at Asf
Class C 42806DBE8  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DBF5  LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2017-1

Class A 428040CU1  LT AAAsf Affirmed  previously at AAAsf
Class B 428040CV9  LT Asf   Affirmed  previously at Asf
Class C 428040CW7  LT BBBsf Affirmed  previously at BBBsf
Class D 428040CX5  LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2017-2

Class A 42806DBG3  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DBH1  LT Asf   Affirmed  previously at Asf
Class C 42806DBJ7  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DBK4  LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2018-1

Class A 42806DBQ1; LT AAAsf Affirmed  previously at AAAsf
Class B 42806DBR9; LT Asf   Affirmed  previously at Asf
Class C 42806DBS7; LT BBBsf Affirmed  previously at BBBsf
Class D 42806DBT5; LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2018-2

Class A 42806DBV0  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DBW8  LT Asf   Affirmed    previously at Asf
Class C 42806DBX6  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DBY4  LT BBsf  Affirmed   previously at BBsf

Hertz Vehicle Financing II LP, Series 2018-3

Class A 42806DBZ1  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DCA5  LT Asf   Affirmed  previously at Asf
Class C 42806DCB3  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DCC1  LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2019-1

Class A 42806DCD9  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DCE7  LT Asf   Affirmed  previously at Asf
Class C 42806DCF4  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DCG2  LT BBsf  Affirmed  previously at BBsf

Hertz Vehicle Financing II LP, Series 2019-2

Class A 42806DCH0  LT AAAsf Affirmed  previously at AAAsf
Class B 42806DCJ6  LT Asf   Affirmed  previously at Asf
Class C 42806DCK3  LT BBBsf Affirmed  previously at BBBsf
Class D 42806DCL1  LT BBsf  Affirmed  previously at BBsf

KEY RATING DRIVERS

Transaction Analysis: Fitch analyzed the structural features
present in each series, including monthly mark-to-market vehicle
value tests and minimum monthly vehicle depreciation, by stressing
the liquidation timing, vehicle depreciation, disposition losses
and expected carrying costs of the transaction at various rating
levels to determine an expected loss level (ELL) for each rating
category. Credit enhancement consists of subordination, letter(s)
of credit and dynamic overcollateralization that will shift
according to the fleet mix. The levels for each series cover or are
well within range of Fitch's maximum and minimum ELL for each class
under the respective ratings.

Collateral Analysis - Diverse Vehicle Fleet: HVF II's fleet is
deemed diverse under Fitch's criteria due to the high degree of
manufacturer, model, segment and geographic diversification in the
Hertz, Dollar and Thrifty rental fleets. Concentration limits,
based on a number of characteristics, are present to help mitigate
risks related to overconcentrations. Original Equipment
Manufacturers (OEMs) with PV concentrations in HVF II have all
improved their financial position in recent years and are well
positioned to meet repurchase agreement obligations. As of the
cutoff date, 96.1% of the fleet is from OEMs with an
investment-grade Issuer Default Rating (IDR).

Vehicle Value Risks - Fluctuating Fleet Performance: Depreciation
experience within Hertz's fleet has been volatile since 2014 for
risk vehicles and remains elevated due to weak wholesale values for
compact cars, a segment that comprises the significant majority of
the HVF II fleet. Despite this, vehicle disposition losses have
been minimal for both risk and program vehicles and depreciation
for 2018 and 2019 to date were relatively less volatile than recent
years.

Adequate Fleet Servicer and Fleet Management: Hertz is deemed an
adequate servicer and administrator, as evidenced by its historical
fleet management and securitization performance to date. Sagent
Auto, LLC, which is wholly owned by Fiserv, Inc., is the backup
disposition agent, while Lord Securities Corporation (Lord
Securities) is the backup administrator.

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


IMSCI 2013-3: Fitch Lowers Rating on Class G Certs to CCC
---------------------------------------------------------
Fitch Ratings has downgraded two classes and affirmed five classes
of Institutional Mortgage Securities Canada Inc.'s (IMSCI)
Commercial Mortgage Pass-Through Certificates series 2013-4.

IMSCI 2013-3

                      Current Rating      Prior Rating
Class A-3 45779BBA6 LT AAAsf  Affirmed   previously at AAAsf
Class B 45779BBB4   LT AAsf   Affirmed   previously at AAsf
Class C 45779BBC2   LT Asf    Affirmed   previously at Asf
Class D 45779BBD0   LT BBBsf  Affirmed   previously at BBBsf
Class E 45779BBE8   LT BBB-sf Affirmed   previously at BBB-sf
Class F 45779BAV1   LT Bsf    Downgrade  previously at BBsf
Class G 45779BAW9   LT CCCsf  Downgrade  previously at Bsf

KEY RATING DRIVERS

Increasing Loss Expectations: Loss expectations have increased
since issuance as a result of collateral underperformance of
several loans in the pool including three Fitch Loans of Concern
(FLOCs) (12.8%). All three of these loans are collateralized by
multifamily properties in Fort McMurray, AB, and the most recently
reported financial information reflects negative or near-zero cash
flow. The downgrades and Negative Outlooks on classes D and E
reflect the increase in expected losses.  The decline in
performance is somewhat mitigated by several factors. These include
increased credit enhancement, low historical delinquency and loss
rates associated with Canadian CMBS loans and strong lending
environment. All of the FLOCs are structured with recourse, and the
sponsor has continued to fund debt service shortfalls, but it is
unclear if the sponsor can continue to do so indefinitely.

Improved Credit Enhancement: Credit enhancement has improved since
issuance due to loan amortization and payoffs. The pool has paid
down approximately 50.4% since issuance. Credit enhancement will
continue to improve given above-average amortization with the loans
in the pool scheduled to amortize 19.0% by maturity.  In addition,
the largest loan in the pool (15.7%) matures in February 2020, and
collateral performance remains strong.

Pool and Sponsor Concentration: The pool has become concentrated,
with only 14 of the original 29 loans remaining when accounting for
cross-collateralized and cross-defaulted loans. Additionally, five
loans totaling 28.4% of the loans in the pool are sponsored by
Lanesborough REIT. This includes all three of the FLOCS, which
account for 12.8% of the pool.

Energy Market Concentration: Three loans totaling 12.8% of the pool
have experienced substantial performance declines as a result of a
sustained decline in oil and gas prices. All three of these are
collateralized by multifamily properties in Fort McMurray, AB, and
reflect negative or near-zero cash flow. All three failed to pay
off at their May 2018 maturity dates and have been extended through
May 2021 in the hopes that the oil and gas market would improve.
Improvement in the sector has negligible and the real estate market
has continued to decline.

RATING SENSITIVITIES

The Negative Rating Outlooks and downgrades on classes E and F
reflect the sustained underperformance of the several collateral
properties located in oil and gas exposed markets, specifically
Fort McMurray in Alberta. These loans failed to pay off at their
original maturity dates and have been extended for an additional
three-year term, with the sponsor, Lanesborough REIT, and its
parent entities covering operating and debt service shortfalls.

Further downgrades are possible in the event the sponsor is unable
or unwilling to cover shortfalls, if the loans default, or given a
worsening outlook on the real estate and oil and gas markets in the
region.

Upgrades are unlikely, given the sustained underperformance of
these assets, a marked decline in the real estate market in this
region, and waning financial capacity of the sponsor.


JMP CREDIT IV: Moody's Affirms Ba3 Rating on $22.5 Class E Notes
----------------------------------------------------------------
Moody's Investors Service assigned a rating to one class of CLO
refinancing notes issued by JMP Credit Advisors CLO IV Ltd.

Moody's rating action is as follows:

US$285,750,000 Class A-R Senior Secured Floating Rate Notes Due
2029 (the "Class A-R Notes"), Assigned Aaa (sf)

Additionally, Moody's has taken rating actions on the following
outstanding notes originally issued by the Issuer on June 29, 2017
(the "Original Closing Date"):

US$54,000,000 Class B Senior Secured Floating Rate Notes Due 2029
(the "Class B Notes"), Affirmed Aa2 (sf); previously on June 30,
2017 Assigned Aa2 (sf)

US$27,000,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes Due 2029 (the "Class C Notes"), Affirmed A2 (sf); previously
on June 30, 2017 Assigned A2 (sf)

US$24,750,000 Class D Mezzanine Secured Deferrable Floating Rate
Notes Due 2029 (the "Class D Notes"), Affirmed Baa3 (sf);
previously on June 30, 2017 Assigned Baa3 (sf)

US$22,500,000 Class E Mezzanine Secured Deferrable Floating Rate
Notes Due 2029 (the "Class E Notes"), Affirmed Ba3 (sf); previously
on June 30, 2017 Assigned Ba3 (sf)

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. Additionally, the rating actions on
the Class B, Class C, Class D, and Class E Notes is supported by
the refinancing, which increases excess spread available as credit
enhancement to the notes.

The Issuer is a managed cash flow collateralized loan obligation
(CLO). The issued notes are collateralized primarily by a portfolio
of broadly syndicated senior secured corporate loans. At least
92.5% of the portfolio must consist of senior secured loans and
eligible investments representing principal proceeds, and up to
7.5% of the portfolio may consist of second liens loans and
unsecured loans.

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

The Issuer has issued the Refinancing Notes on August 8, 2019 (the
"Refinancing Date") in connection with the refinancing of one class
of secured notes (the "Refinanced Original Notes") originally
issued on June 29, 2017 (the "Original Closing Date"). On the
Refinancing Date, the Issuer used the proceeds from the issuance of
the Refinancing Notes to redeem in full the Refinanced Original
Notes. On the Original Closing Date, the issuer also issued four
classes of secured notes and two classes of subordinated notes that
remain outstanding.

In addition to the issuance of the Refinancing Notes, a variety of
other changes to transaction features will occur in connection with
the refinancing. This includes extension of the non-call period for
the Class A-R Notes.

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

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

Performing par and principal proceeds balance: $447,635,195

Defaulted par: $380,265

Diversity Score: 87

Weighted Average Rating Factor (WARF): 2876 (corresponding to a
weighted average default probability of 23.88%)

Weighted Average Spread (WAS): 3.63%

Weighted Average Recovery Rate (WARR): 46.96%

Weighted Average Life (WAL): 5.95 Years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
March 2019.

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

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


JP MORGAN 2018-WPT: DBRS Confirms B(low) Rating on 2 Tranches
-------------------------------------------------------------
DBRS Limited confirmed the ratings of the Commercial Mortgage
Pass-Through Certificates, Series 2018-WPT issued by J.P. Morgan
Chase Commercial Mortgage Securities Trust 2018-WPT as follows:

-- Class A-FL at AAA (sf)
-- Class A-FX at AAA (sf)
-- Class XA-FX at AAA (Sf)
-- Class B-FL at AA (low) (sf)
-- Class B-FX at AA (low) (sf)
-- Class C-FL at A (low) (sf)
-- Class C-FX at A (low) (sf)
-- Class X-FL at BBB (high) (sf)
-- Class XB-FX at BBB (high) (sf)
-- Class D-FL at BBB (sf)
-- Class D-FX at BBB (sf)
-- Class E-FL at BBB (low) (sf)
-- Class E-FX at BBB (low) (sf)
-- Class F-FL at BB (low) (sf)
-- Class F-FX at BB (low) (sf)
-- Class G-FL at B (low) (sf)
-- Class G-FX at B (low) (sf)

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. The transaction closed in August
2018 with an original trust balance of $1.275 billion. This loan is
secured by a portfolio of 147 commercial properties, comprising
nearly 9.9 million square feet of office and flex space. Of the 147
properties, 88 assets are office (72.7% of the loan balance) and 59
(27.2% of the loan balance) are flex. The portfolio is located
across four different states and five distinct metropolitan
statistical areas, including Philadelphia (69 properties; 40.3% of
the loan balance), Tampa (34 properties; 16.5% of the loan
balance), Minneapolis (19 properties; 13.0% of the loan balance),
Phoenix (14 properties; 12.9% of the loan balance) and Southern
Florida (11 properties; 17.3% of the loan balance).

The underlying loan is interest-only (IO) throughout the entire
loan term and is split into two components: (1) a floating-rate
component of approximately $255.0 million, structured with a
two-year initial term and three one-year extension options, and (2)
a five-year fixed-rate loan totaling $1.02 billion, comprising the
$850.0 million trust balance and three companion loans totaling
$170.0 million. The companion loans are secured across three other
DBRS-rated deals, BMARK 2018-5, BMARK 2018-6, and BMARK 2018-7, as
well as a fourth deal, BMARK 2018-8, which is not rated by DBRS.
Loan proceeds of $1.28 billion were primarily used to refinance
existing debt of $827.5 million and an existing credit line of
$227.6 million. An upfront reserve of $32.9 million was established
at closing, which included $13.3 million for an outstanding tenant
improvement/leasing commission reserve, $11.8 million for an
upfront tax reserve and a $3.5 million free rent reserve. The loan
is sponsored by Workspace Property Trust, L.P., a private
full-service commercial real estate company specializing in
acquisition, development, management and the operation of office
and flex properties.

As of the March 2019 rent rolls provided by the servicer, the
portfolio reported an average occupancy rate of 87.7%, compared
with 88.6% as of June 2018. There is moderate rollover in the near
term, with 50 tenants across the portfolio expiring by year-end
(YE) 2019, which accounts for 6.7% of the net rentable area (NRA).
This is typical for flex property types and no near-term expiry
exceeds 1.0% of the total portfolio NRA. The portfolio's top five
tenants represent a combined 13.4% of the NRA, and include United
Healthcare Services, Inc (3.3% of the NRA), Aetna (3.3% of the
NRA), Siemens (2.3% of the NRA), Express Scripts (2.1% of the NRA)
and Kroll Ontrack (2.0% of the NRA). Siemens, the portfolio's
third-largest tenant, recently renewed leases through January 2023
at three properties, with a weighted average rental rate of $16.42,
compared with the former rate of $16.17.

According to the YE2018 financials, the loan reported a net cash
flow (NCF) figure of $103.5 million, generally in line with the
DBRS Term NCF of $101.9 million, with reimbursements and base rents
up slightly from the DBRS figures. At issuance, the portfolio was
noted to be in generally good condition with no major deferred
maintenance noted for the older vintage properties.

Classes XA-FX, X-FL, and XB-FX are IO certificates that reference a
single rated tranche or multiple rated tranches. The IO rating
mirrors the lowest-rated applicable reference obligation tranche
adjusted upward by one notch if senior in the waterfall.

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


JP MORGAN 2019-HYB1: Fitch to Rate Class B-5 Certs 'B(EXP)'
-----------------------------------------------------------
Fitch Ratings expects to rate the residential mortgage-backed
certificates issued by J.P. Morgan Mortgage Trust 2019-HYB1. The
transaction is expected to close on Aug. 29, 2019.

The certificates are supported by 703 adjustable rate mortgage
(ARM) loans with a total balance of $557.47 million as of the
cutoff date. Of the loans, 27.1% were originated by First Republic
Bank, 25.7% by Banc of California N.A., 10.1% by loanDepot.com,
LLC, and the remaining by various originators that each contributed
less than 10% to the transaction.

JPMMT 2019-HYB1

                Current Rating   Prior Rating
Class A-1      LT  AA+(EXP)sf   Expected Rating
Class A-1-A    LT  AA+(EXP)sf   Expected Rating
Class A-1-IO   LT  AA+(EXP)sf   Expected Rating
Class A-2      LT  AAA(EXP)sf   Expected Rating
Class A-2-A    LT  AAA(EXP)sf   Expected Rating
Class A-2-IO   LT  AAA(EXP)sf   Expected Rating
Class A-3      LT  AAA(EXP)sf   Expected Rating
Class A-3-A    LT  AAA(EXP)sf   Expected Rating
Class A-3-IO   LT  AAA(EXP)sf   Expected Rating
Class A-4      LT  AAA(EXP)sf   Expected Rating
Class A-4-A    LT  AAA(EXP)sf   Expected Rating
Class A-4-IO   LT  AAA(EXP)sf   Expected Rating
Class A-5      LT  AA+(EXP)sf   Expected Rating
Class A-5-A    LT  AA+(EXP)sf   Expected Rating
Class A-5-IO   LT  AA+(EXP)sf   Expected Rating
Class B-1      LT  AA(EXP)sf    Expected Rating
Class B-2      LT  A(EXP)sf     Expected Rating
Class B-3      LT  BBB(EXP)sf   Expected Rating
Class B-4      LT  BB(EXP)sf    Expected Rating
Class B-5      LT B(EXP)sf      Expected Rating
Class B-6      LT NR(EXP)sf     Expected Rating

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The pool consists of
high-quality loans seasoned approximately 19 months (per Fitch's
calculations). The loans were originated by various originators and
aggregated by J.P. Morgan Mortgage Acquisition Corp. (JPMMAC). The
borrowers have strong credit profiles (Fitch derived WA FICO of
758) and relatively low leverage (67.8% sustainable loan-to-value
ratio [sLTV]).

100% ARM Collateral (Negative): The collateral consists of 100%
10-year, 7-year, 5-year, 3-year and 1-month fully amortizing ARMs.
The 100% ARM concentration increases the risk of payment shock once
the fixed period has ended. As a result, a 1.544x probability of
default (PD) penalty was applied.

Investor Risk (Negative): Per Fitch's calculations, approximately
21.8% of the collateral pool consists of investor loans, which
Fitch has found to have a relatively higher PD. Fitch increased its
loss expectations (60bps at the 'AAAsf' rating category) to
mitigate the investor risk.

Geographic Concentration (Negative): Approximately 62% of the pool
is concentrated in California, with roughly 21% located in the San
Francisco MSA, 20% located in the Los Angeles MSA and 7.9% in the
New York MSA. The top three MSAs account for 49.3% of the pool. As
a result, there was a 1.07x adjustment for geographic
concentration.

High Non-QM Status Concentration (Negative): Approximately 44% is
of the pool consists of loans classified as non-qualified mortgages
(non-QMs). Roughly 23% are interest only (IO) loans, 13% did not
qualify for QM status due to exceptions to Appendix Q of the
Ability to Repay Rule (ATR), 5.5% had debt to income ratios (DTIs)
over 43%, and 2.0% did not qualify for various reasons. Fitch
increased its loss expectations (15bps at the 'AAAsf' rating
category) to account for the increase in ATR risk due to the non-QM
status of the loans.

Low Operational Risk (Positive): The operational risk is well
controlled for in this transaction. JPMMAC has an extensive
operating history in mortgage aggregations and is assessed as an
'Above Average' aggregator. The aggregator has a robust sourcing
strategy and maintains well developed internal risk controls. The
results of the 100% third-party due diligence confirm high loan
quality with 97.7% receiving a due diligence grade of 'A' or 'B'.

Master Servicer and Primary Servicer (Positive): The majority of
the loans (approximately 70%) will be serviced by J.P. Morgan Chase
Bank, N.A. (JP Morgan Chase), rated 'RPS1-' by Fitch, and First
Republic Bank (approximately 27%), rated 'RPS2-' by Fitch. Highly
rated primary servicers have a positive impact on the performance
of the loans due to their servicing practices and capabilities to
increase recoveries. As a result, Fitch reduced its loss severity
(LS) by 62bps to the 'AAAsf' expected loss. In addition, Nationstar
Mortgage LLC, rated 'RMS2+' by Fitch, will be the master servicer
for this transaction.

Full advancing (Mixed): The primary servicers will be advancing
full principal and interest (P&I) payments until the advance is
deemed non-recoverable. If the servicers fail to remit P&I advance
amounts, the master servicer, Nationstar Mortgage LLC, will be
obligated to advance. Additionally, the securities administrator,
Citibank, N.A. rated A+/F1/Stable, will make advances if the master
servicer fails to do so. While the full advancing structure
provides for liquidity, it results in higher projected loss
severities compared to a non-advancing structure due to the
reimbursement of amounts advanced by the servicer.

Representations and Warranties (Negative): The representation and
warranty (R&W) 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. Fitch increased its loss expectations
(23bps at the 'AAAsf' rating category) to mitigate the limitations
of the framework and the non-investment-grade counterparty risk of
the providers.

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 (CE)
levels are not maintained.

To mitigate tail risk, which arises as the pool seasons and fewer
loans are outstanding, a subordination floor of 1.50% of the
original balance will be maintained for the senior certificates and
a subordination floor of 1.00% 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 (MVDs)
than assumed at the MSA level. The implied rating sensitivities are
only an indication of some of the potential outcomes and do not
consider other risk factors that the transaction may become exposed
to or may be considered in the surveillance of the transaction.
Three sets of sensitivity analyses were conducted at the state and
national levels to assess the effect of higher MVDs for the subject
pool.

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper market value declines at the
national level. The analysis assumes market value declines of 10%,
20% and 30%, in addition to the model-projected 4.3%.
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'.

CRITERIA VARIATION

This transaction had two variations from Fitch's "U.S. RMBS Rating
Criteria."

1) Per the criteria, Fitch expects to have an originator review of
any entity originating more than 15% of a transaction. Banc of
California originated 25.66% of the loans in this transaction.
Fitch had previously conducted reviews of Banc of California's
operations; however, the assessment has lapsed. Additionally, Banc
of California recently exited its mortgage origination business.
For operational risk pertaining to originator quality, Fitch
assumed that the loans were contributed by an originator not
reviewed by Fitch. As a result, the 'Above Average' assessment of
JPMMAC as aggregator was applied, as is Fitch's approach to
non-reviewed originators. Fitch's expected loss from this treatment
did not change, and therefore, it had no rating impact.

2) Per the criteria, AVM values are not accepted as a secondary
value when performing TPR firms of the original property value.
However, AVMs were used for the secondary valuation for six loans
in this transaction. Clear Capital provided the AVM, which Fitch
has reviewed and believes no additional risk is present. As such,
there was no impact to the gross loss levels or the ratings.

This transaction also had one variation to Fitch's "U.S. RMBS
Seasoned, Re-Performing and Non-Performing Loan Rating Criteria."
Per criteria, Fitch expects an updated tax, title and lien search
conducted on seasoned loans. Otherwise Fitch would look for
additional reporting from either a Fitch-reviewed servicer or a
third-party vendor reflecting the status of taxes, HOA and muni
liens, or a life-of-loan rep from an investment-grade counterparty.
None was received, and while a representation addressing the
enforceability of the loans, clean title and taxes paid was
provided, not all of the counterparties currently have an
investment-grade rating. In addition, all loans except for two have
been current since origination, minimizing the risk of any
impairment to the title and outstanding lien amounts. As such,
there is no impact to the gross loss levels or the ratings.


JP MORGAN 2019-LTV2: DBRS Finalizes B Rating on Class B-5 Certs
---------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the Mortgage
Pass-Through Certificates, Series 2019-LTV2 (the Certificates)
issued by J.P. Morgan Mortgage Trust 2019-LTV2 as follows:

-- $339.0 million Class A-1 at AAA (sf)
-- $308.2 million Class A-2 at AAA (sf)
-- $200.3 million Class A-3 at AAA (sf)
-- $150.3 million Class A-4 at AAA (sf)
-- $50.1 million Class A-5 at AAA (sf)
-- $125.2 million Class A-6 at AAA (sf)
-- $75.2 million Class A-7 at AAA (sf)
-- $25.1 million Class A-8 at AAA (sf)
-- $35.0 million Class A-9 at AAA (sf)
-- $15.1 million Class A-10 at AAA (sf)
-- $107.9 million Class A-11 at AAA (sf)
-- $107.9million Class A-11-X at AAA (sf)
-- $107.9 million Class A-12 at AAA (sf)
-- $107.9 million Class A-13 at AAA (sf)
-- $30.8 million Class A-14 at AAA (sf)
-- $30.8 million Class A-15 at AAA (sf)
-- $220.4 million Class A-16 at AAA (sf)
-- $118.7 million Class A-17 at AAA (sf)
-- $240.4 million Class A-18 at AAA (sf)
-- $308.2 million Class A-19 at AAA (sf)
-- $339.0 million Class A-X-1 at AAA (sf)
-- $339.0 million Class A-X-2 at AAA (sf)
-- $107.9 million Class A-X-3 at AAA (sf)
-- $30.8 million Class A-X-4 at AAA (sf)
-- $308.2 million Class A-X-5 at AAA (sf)
-- $11.9 million Class B-1 at AA (sf)
-- $11.2 million Class B-2 at A (sf)
-- $9.2 million Class B-3 at BBB (sf)
-- $7.1 million Class B-4 at BB (sf)
-- $1.7 million Class B-5 at B (sf)

Classes A-X-1, A-X-2, A-X-3, A-X-4, A-X-5 and A-11-X 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-18, A-19, A-X-2, A-X-3 and A-X-5 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,
A-13, A-18 and A-19 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 12.00% of
credit enhancement provided by subordinated certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 8.90%, 6.00%, 3.60%, 1.75% and 1.30% 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 607 loans with a total principal
balance of $385,276,468 as of the Cut-Off Date (July 1, 2019).

Compared with other post-crisis prime pools, this portfolio
consists of higher loan-to-value (LTV), fully amortizing fixed-rate
mortgages with original terms to maturity of 30 years. The
weighted-average original combined LTV (CLTV) for the portfolio is
87.9%, and almost the entire pool (99.3%) comprises loans with
current CLTV ratios greater than 79.0%. The high LTV attribute of
this portfolio is mitigated by certain strengths, such as high FICO
scores, a low debt-to-income ratio, and robust income and reserves,
as well as other strengths detailed in the Key Probability of
Default Drivers section of the related rating report.

The mortgage loans were originated by United Shore Financial
Services (77.1%) and various other originators, each comprising
less than 5.0% of the mortgage loans. Approximately 3.28% 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 are serviced or sub-serviced by Shellpoint
Mortgage Servicing (SMS; 99.5%) and USAA Federal Savings Bank
(0.5%). Servicing will be transferred from SMS to JPMorgan Chase
Bank, N.A. (JPMCB; rated AA with a Stable trend by DBRS) on the
servicing transfer date (September 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 SMS (and
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 Mortgage LLC 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. Wells Fargo Bank,
N.A. (rated AA with a Stable trend by DBRS) will act as Custodian.
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&W 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.

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


LCM XIII: S&P Affirms BB- (sf) Rating on Class E-R Notes
--------------------------------------------------------
S&P Global Ratings assigned its ratings to the class X-RR, A-RR,
and B-RR replacement notes from LCM XIII Limited Partnership, a
collateralized loan obligation (CLO) originally issued in 2013 and
refinanced in 2016 that is managed by LCM Asset Management LLC. S&P
withdrew its ratings on the original class X-R, A-R, and B-R notes
following payment in full on the Aug. 9, 2019, refinancing date. At
the same time, S&P affirmed its ratings on the class C-R, D-R, and
E-R notes, which were not refinanced.

On the Aug. 9, 2019, refinancing date, the proceeds from the class
X-RR, A-RR, and B-RR replacement note issuances were used to redeem
the original class X-R, A-R, and B-R notes as outlined in the
transaction document provisions. Therefore, S&P withdrew its
ratings on the original notes in line with their full redemption,
and S&P assigned ratings to the replacement notes.

"Our review of this transaction included a cash flow analysis,
based on the portfolio and transaction as reflected in the trustee
report, to estimate future performance. In line with our criteria,
our cash flow scenarios applied forward-looking assumptions on the
expected timing and pattern of defaults, and recoveries upon
default, under various interest rate and macroeconomic scenarios,"
S&P said.

"In addition, our analysis considered the transaction's ability to
pay timely interest and/or ultimate principal to each of the rated
tranches. In our view, the results of the cash flow analysis, and
other qualitative factors as applicable, demonstrated that all of
the rated outstanding classes have adequate credit enhancement
available at the rating levels associated with these rating
actions," the rating agency said.

"The assigned ratings reflect our opinion that the credit support
available is commensurate with the associated rating levels," S&P
said.

S&P will continue to review whether, in its view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them, and it will take rating actions as it
deems necessary.

  RATINGS ASSIGNED
  LCM XIII Limited Partnership

  Replacement class          Rating        Amount
                                          (mil $)
  X-RR                       AAA(sf)         0.55
  A-RR                       AAA(sf)       322.50
  B-RR                       AA (sf)        52.50

  RATINGS AFFIRMED
  LCM XIII Limited Partnership

  Class                      Rating
  C-R                        A(sf)
  D-R                        BBB(sf)
  E-R                        BB-(sf)  

  RATINGS WITHDRAWN
  LCM XIII Limited Partnership

                             Rating
  Original class       To              From
  X-R                  NR              AAA (sf)
  A-R                  NR              AAA (sf)
  B-R                  NR              AA (sf)

  NR--Not rated.


MASTR ASSET 2004-HE1: Moody's Lowers Ratings on 2 Tranches to B1
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of two tranches
from MASTR Asset Backed Securities Trust 2004-HE1 backed by
Subprime mortgage loans.

The complete rating actions are as follows:

Issuer: MASTR Asset Backed Securities Trust 2004-HE1

Cl. M-4, Downgraded to B1 (sf); previously on Mar 5, 2013 Affirmed
Baa1 (sf)

Cl. M-5, Downgraded to B1 (sf); previously on Mar 5, 2013
Downgraded to Ba1 (sf)

RATINGS RATIONALE

The ratings downgrades are primarily due to the outstanding
interest shortfalls on the bonds which are not expected to be
recouped. The interest shortfalls are a result of reimbursement of
servicer advances from two mortgage loans with very large losses.
As of July 25, 2019, the Class M-4 and M-5 have $22.3K and $51.9K
of remaining unpaid interest shortfall, respectively. In the
transaction's waterfall structure, interest shortfalls are
reimbursed from excess interest only after the
overcollateralization has built to a pre-specified target amount.
Due to the transaction's performance and its level of
overcollateralization, the shortfalls are unlikely to be reimbursed
and could be permanent. The action also reflects the recent
performance of the underlying pools and Moody's updated loss
expectations on the pools.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in July 2019 from 3.9% in July
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 changes resulting from servicing
transfers, or other policy or regulatory shifts can impact the
performances of these transactions.


MORGAN STANLEY 2005-TOP19: Fitch Affirms D Rating on 4 Tranches
---------------------------------------------------------------
Fitch Ratings has upgraded four and affirmed seven classes of
Morgan Stanley Capital I Trust, commercial mortgage pass-through
certificates, series 2005-TOP19.

Morgan Stanley Capital I Trust 2005-TOP19

          Current Rating        Prior Rating
Class D  LT  AAAsf  Affirmed  previously at AAAsf
Class E  LT  AAAsf  Upgrade   previously at Asf
Class F  LT  AAAsf  Upgrade   previously at BBBsf
Class G  LT  Asf    Upgrade   previously at BBsf
Class H  LT  BBBsf  Upgrade   previously at Bsf
Class J  LT  Bsf    Affirmed  previously at Bsf
Class K  LT  CCCsf  Affirmed  previously at CCCsf
Class L  LT  Dsf    Affirmed  previously at Dsf
Class M  LT  Dsf    Affirmed  previously at Dsf
Class N  LT  Dsf    Affirmed  previously at Dsf
Class O  LT  Dsf    Affirmed  previously at Dsf

KEY RATING DRIVERS

Increased Credit Enhancement: The upgrades reflect increased credit
enhancement since Fitch's last rating action due to the prepayment
of two loans with yield maintenance penalties (19.8% of last rating
action pool balance) prior to their scheduled maturities, as well
as continued scheduled amortization. As of the July 2019
distribution date, the pool's aggregate pool balance has been
reduced by 94.7% to $64.8 million from $1.2 billion at issuance.
Realized losses to date totaled 1.2% of the original pool balance.
Cumulative interest shortfalls totaling approximately $520,000 are
currently affecting classes N through P.

High Defeasance Percentage: Six loans (55% of pool) have been fully
defeased.

Stable Loss Expectations: Overall performance and loss expectations
for the remaining pool are stable. All loans are current and none
are considered Fitch Loans of Concern.

Concentrated Pool: Only 13 loans remain in the pool. Due to the
concentrated nature of the pool, Fitch performed a sensitivity
analysis that grouped the remaining loans based on structural
features, collateral quality and performance, then ranked them by
their perceived likelihood of repayment. The ratings and Rating
Outlooks reflect this analysis. Of the seven non-defeased loans,
three (16% of pool) are secured by single-tenant properties and
four (29%) are secured by retail properties in secondary markets.

Additional Sensitivity: Fitch performed an additional sensitivity
scenario that applied a potential outsized loss of 50% on the
Santana Village loan (15.1% of pool), which is secured by an
85,766sf grocery-anchored neighborhood retail center in Santee, CA
(San Diego County). Fitch has refinance concerns due to the grocer
anchor tenant, Smart & Final, having a lease rolling in July 2021,
which is one year after the loan's July 2020 maturity. The rating
of class K was capped at 'CCCsf' based upon this sensitivity
scenario.

Significant Upcoming Loan Maturities: 83% of the pool matures in
2020, with the remaining 17% maturing in 2025.

Strong Amortization: All loans in the pool are amortizing,
including seven (21.7% of pool) which are fully-amortizing.

RATING SENSITIVITIES

The Positive Rating Outlook on class H reflects a potential future
multi-category upgrade should the Santana Village loan, which Fitch
has refinance concerns due to the grocer anchor tenant rolling one
year after loan maturity, repay in full at its 2020 maturity. Full
repayment of all loans with 2020 maturities would result in class H
being the most senior class and being fully covered by defeased
collateral. The Stable Rating Outlooks on classes D through G and
class J reflect the increasing credit enhancement and overall
stable pool performance. Downgrades are unlikely, but may be
possible if pool performance deteriorates significantly.


NASSAU LLC 2019: Fitch to Rate $75.2MM Class B Notes 'BB(EXP)'
--------------------------------------------------------------
Fitch Ratings has assigned Nassau 2019 CFO LLC (Nassau 2019 CFO)
expected ratings as follows:

  -- Undrawn liquidity facility 'A+(EXP)sf';

  -- $187.8 million class A notes 'A(EXP)sf';

  -- $75.2 million class B notes 'BB(EXP)sf'.

Nassau 2019 CFO is a private equity collateralized fund obligation
(PE CFO) managed by Nassau Alternative Investments (NAI). The
manager is an affiliate of Nassau Financial Group. Nassau 2019 CFO
owns interests in a diversified pool of private equity (PE) funds
(buyout, mezzanine, debt and venture). The issuance consists of
notes backed by the cash flows generated by the funds.

The transaction consists of approximately $375.7 million net asset
value (NAV) of funded commitments and $79.3 million of unfunded
capital commitments across 109 funds.

Final ratings are contingent on the receipt of final documents
conforming to information already received.

KEY RATING DRIVERS

NAV Overcollateralization

The rated notes will make up approximately 70% of the NAV at
issuance, providing a sufficient level of credit enhancement (CE)
at the indicated rating levels, per Fitch's rating criteria. The
50% of CE for class A and 30% of CE for class B provide the notes
with a cushion in case PE distributions are realized at lower
levels than expected. The rating of the class B notes reflects its
subordination and the lower level of CE available to this class.

Structural Features

Key structural features include a liquidity loan facility to fund
capital calls, interest payments and other expenses in the event of
a cash shortfall; amortization triggers tied to loan to value (LTV)
levels; and long final maturities of the notes to support the
structure's ability to weather a down market.

Diversified Portfolio

Nassau CFO's portfolio of PE interests is diversified by strategy,
vintage, managers, funds, underlying holdings and sectors. The
portfolio comprises 109 funds managed by 69 fund managers, with
1,273 underlying investments. The high portfolio diversification is
counterbalanced by a focus on funds run by smaller and mid-sized
managers, and a higher allocation to third- and fourth-quartile
funds relative to other PE CFO portfolios.

Cash Flow Analysis

Fitch measured the ability of the structure to withstand weak
performance in its underlying funds in combination with adverse
market cycles. Class A notes are expected to be rated 'Asf', and
class B notes are expected to be rated 'BBsf', reflecting their
ability to withstand fourth-quartile- and third-quartile-level
performance, respectively, in the underlying funds under Fitch's
scenario analysis.

Counterparty Exposure

Certain structural features of the transaction involve reliance on
counterparties, such as the liquidity lender and account banks. The
ratings of the notes could be negatively affected in the event that
key counterparties fail to perform their duties. Fitch believes
this risk is mitigated by counterparty rating requirements and
replacement provisions in the transaction documents that align with
Fitch's criteria.

Capabilities of the Manager

Fitch believes the manager (NAI) has the capabilities and resources
required to manage this transaction. NAI's management team has
extensive experience in the PE industry, although the team is
comparably smaller than for other Fitch-rated PE CFOs.

Alignment of Interests

The sponsor and noteholders' interests are sufficiently aligned, as
the sponsor and its affiliates are expected to hold at least a
majority of the equity stake (approximately 15%-30% of NAV) in
Nassau CFO, and absorb any losses before noteholders. However, the
degree of alignment of interest is lower than for other PE CFOs
where sponsors retained a greater portion of the transaction
through the equity and/or debt tranches.

Asset Isolation and Legal Structure
Fitch expects that the issuer will be structured as a
special-purpose, bankruptcy-remote entity, the issuer will have
100% member interests in Nassau 2019 CFO Fund LLC (AssetCo) and the
assets held by AssetCo will have been transferred to it as a true
sale. Fitch has not yet received legal opinions on the transaction,
but expects the opinions to address true sale, non-consolidation
and other items customary for similar transactions.

Rating Cap at 'Asf' Category

Fitch has a rating cap at the 'Asf' category for PE CFO
transactions, primarily driven by the uncertain nature of PE fund
cash flows. An additional rating cap at the 'Asf' category applies
to class B notes as their interest payment is deferrable.

RATING SENSITIVITIES

PE CFOs have many inherent risks, including the uncertainty of the
amount and timing of distributions, illiquid nature of investments,
the degree of transaction leverage and the subjective nature of NAV
calculations.

The expected ratings for the notes may be subject to downgrade if
cash flows are lower than modeled in stress scenarios, creating a
risk that the funds will not generate enough overall cash to repay
the issuer's obligations. A material decline in NAV that, in
Fitch's view, would indicate insufficient forthcoming cash
distributions to support the notes could also lead to rating
downgrades.

The ratings of class B notes may be upgraded in the future if
distributions are strong and CE on the class B notes increases. The
ratings uplift on class B notes will be subject to the rating cap
for PE CFO transactions and the rating cap of the 'Asf' category
owing to the deferred interest feature of the class B notes.

A ratings downgrade of a counterparty may also materially affect
the ratings of the notes, given the reliance of the issuer on
counterparties to provide functions, including providers of the
liquidity loan facility and bank accounts.

Fitch relied in its analysis on the legal documentation and
opinions for the transaction. If any relevant party to the
transaction does not follow its responsibilities and procedures as
described in the documentation, the ratings on the notes may be
affected.


NEUBERGER BERMAN 33: S&P Assigns Prelim BB- (sf) Rating to E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Neuberger
Berman Loan Advisers CLO 33 Ltd./Neuberger Berman Loan Advisers CLO
33 LLC's floating-rate notes.

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

The preliminary ratings are based on information as of Aug. 12,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect S&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

  Neuberger Berman Loan Advisers CLO 33 Ltd./Neuberger Berman Loan

  Advisers CLO 33 LLC

  Class                Rating        Amount (mil. $)
  A                    AAA (sf)               372.00
  B                    AA (sf)                 84.00
  C (deferrable)       A (sf)                  36.00
  D (deferrable)       BBB- (sf)               36.00
  E (deferrable)       BB- (sf)                24.00
  Subordinated notes   NR                      54.00

  NR--Not rated.


NEW RESIDENTIAL 2019-RPL2: DBRS Finalizes B Rating on B-2 Notes
---------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage-Backed Notes, Series 2019-RPL2 (the Notes) issued by New
Residential Mortgage Loan Trust 2019-RPL2 (NRMLT or the Trust):

-- $272.7 million Class A-1 at AAA (sf)
-- $25.7 million Class A-2 at AA (sf)
-- $24.9 million Class M-1 at A (sf)
-- $20.4 million Class M-2 at BBB (sf)
-- $15.4 million Class B-1 at BB (sf)
-- $10.7 million Class B-2 at B (sf)
-- $298.5 million Class A-3 at AA (sf)
-- $323.3 million Class A-4 at A (sf)

Classes A-3 and A-4 are exchangeable notes. These classes can be
exchanged for combinations of initial exchangeable notes as
specified in the offering documents.

The AAA (sf) rating on the Class A-1 Notes reflects the 36.40% of
credit enhancement provided by the subordinated Notes in the pool.
The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect
30.40%, 24.60%, 19.85%, 16.25% and 13.75% of credit enhancement,
respectively.

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

This transaction is a securitization of a portfolio of seasoned
performing and re-performing first-lien residential mortgages. The
Notes are backed by 2,667 loans with a total principal balance of
$428,820,751 as of the Cut-Off Date (June 30, 2019).

The portfolio is approximately 152 months seasoned and contains
91.0% modified loans. The modifications happened more than two
years ago for 79.2% of the modified loans. Within the pool, 825
mortgages have non-interest-bearing deferred amounts, which equate
to 7.7% of the total principal balance.

As of the Cut-off Date, 68.7% of the pool is current, 24.4% is 30
days delinquent and 1.3% is 60 days delinquent under the Mortgage
Bankers Association (MBA) delinquency method. Additionally, 5.6% of
the pool is in bankruptcy (all bankruptcy loans are performing, 30
days delinquent or 60 days delinquent under the MBA delinquency
method). Approximately 26.2% and 54.1% of the loans have been zero
times 30 days delinquent (0 x 30) for at least 24 months and 12
months, respectively, under the MBA delinquency method. All but
0.4% of the pool is exempt from the Ability-to-Repay/Qualified
Mortgage (QM) rules. These loans are designated as Temporary QM
Safe Harbor.

The Seller, NRZ Sponsor VII LLC (NRZ), acquired the loans in a
whole loan purchase or in connection with the termination of a
securitization trust prior to the Closing Date and, through an
affiliate, New Residential Funding 2019-RPL2 LLC (the Depositor),
will contribute the loans to the Trust. As the Sponsor, New
Residential Investment Corp., or a majority-owned affiliate, will
acquire and retain a 5.0% eligible vertical interest to satisfy the
credit risk retention requirements under Section 15G of the
Securities Exchange Act of 1934 and the regulations promulgated
thereunder. These loans were originated and previously serviced by
various entities through purchases in the secondary market.

The loans will be serviced by NewRez, LLC doing business as
Shellpoint Mortgage Servicing (60.3%), Fay Servicing LLC (Fay
Servicing, 36.0%) and Nationstar Mortgage LLC doing business as Mr.
Cooper Group, Inc. (Mr. Cooper, 3.7%). Approximately 35.1% of the
aggregate pool serviced by Mr. Cooper as of the Cut-Off Date was
scheduled to transfer to Fay Servicing on August 1, 2019.

There will not be any advancing of delinquent principal or interest
on any mortgages by the servicers or any other party to the
transaction; however, the servicers are obligated to make advances
with respect to the preservation, inspection, restoration,
protection and repair of a mortgaged property, including delinquent
tax and insurance payments, the enforcement or judicial proceedings
associated with a mortgage loan and the management and liquidation
of properties (to the extent such advances are deemed recoverable
by the related servicer).

NRZ, as the Seller, will have the option to repurchase any loan
that becomes 60 or more days delinquent under the MBA method or any
real estate-owned property acquired in respect of a mortgage loan
at a price equal to the principal balance of the loan (Optional
Repurchase Price), provided that such repurchases will be limited
to 10.0% of the principal balance of the mortgage loans as of the
Cut-Off Date.

As a loss mitigation alternative, each Servicer has the right to
sell (or cause to be sold) mortgage loans that become 60 or more
days delinquent under the MBA method to any party in the secondary
market in an arms-length transaction at fair market value to
maximize proceeds on such loan on a present value basis.

The transaction employs a sequential-pay cash flow structure.
Principal proceeds and excess interest can be used to cover
interest shortfalls on the Notes, but such shortfalls on Class M-1
and more subordinate bonds will not be paid from principal proceeds
until the more senior classes are retired.

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

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.

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


PALMER SQUARE 2019-3: Fitch Assigns B+ Rating on $5MM Cl. E Notes
-----------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Palmer Square Loan Funding 2019-3, Ltd.:

  -- $340,000,000 class A-1 notes 'AAAsf'; Outlook Stable;

  -- $60,000,000 class A-2 notes 'AAsf'; Outlook Stable;

  -- $32,500,000 class B notes 'Asf'; Outlook Stable;

  -- $15,000,000 class C notes 'BBB-sf'; Outlook Stable;

  -- $17,500,000 class D notes 'BBsf'; Outlook Stable;

  -- $5,000,000 class E notes 'B+sf'; Outlook Stable.

Fitch does not rate the subordinated notes.

TRANASACTION SUMMARY

Palmer Square Loan Funding 2019-3, Ltd. is a collateralized loan
obligation that will be serviced by Palmer Square Capital
Management LLC. Net proceeds from the issuance of the secured and
subordinated notes were used to purchase a static pool of primarily
senior secured leveraged loans totaling approximately $500 million.


KEY RATING DRIVERS

Asset Credit Quality: The average credit quality of the portfolio
is 'B+'/'B', which is in line with that of recent CLOs. Issuers
rated in the 'B' rating category denote a highly speculative credit
quality; however, the notes benefit from appropriate credit
enhancement and standard U.S. CLO structural features.

Asset Security: The portfolio consists of 98.5% first lien senior
secured loans and has a weighted average recovery assumption of
80.9%.

Portfolio Composition: The largest three industries compose 38.6%
of the portfolio balance in aggregate, while the top five obligors
represent 3.3% of the portfolio balance in aggregate. The level of
diversity by industry, obligor and geographic concentrations is in
line with that of other recent U.S. CLOs.

Portfolio Management: The transaction does not have a reinvestment
period and discretionary sales are not permitted. Fitch's analysis
was based on the purchased portfolio, with consideration given for
a stressed scenario incorporating potential maturity amendments on
the underlying loans.

Cash Flow Analysis: Fitch used a customized proprietary cash flow
model to replicate the principal and interest waterfalls and assess
the effectiveness of various structural features of the
transaction. Each class of notes was able to withstand default
rates in excess of its respective rating hurdle.

RATING SENSITIVITIES

Fitch evaluated the notes' sensitivity to the potential variability
of key model assumptions, including decreases in recovery rates and
increases in default rates. Results under the sensitivity scenarios
ranged between 'A-sf' to 'AAAsf' for the class A-1 notes; between
'BB+sf' to 'AA+sf' for the class A-2 notes; between 'B-sf' to
'A+sf' for the class B notes; between less than 'CCCsf' and
'BBB+sf' for the class C notes; between less than 'CCCsf' to
'BB+sf' for the class D notes; and between less than 'CCCsf' to
'BB+sf' for the class E notes.



PEAKS CLO 2: Moody's Assigns Ba3 Rating on $11MM Cl. E-R Notes
--------------------------------------------------------------
Moody's Investors Service assigned ratings to six classes of CLO
refinancing notes issued by Peaks CLO 2, Ltd.

Moody's rating action is as follows:

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

US$44,000,000 Class A-1a-R Senior Secured Floating Rate Notes Due
2031 (the "Class A-1a-R Notes"), Assigned Aaa (sf)

US$18,000,000 Class B-R Senior Secured Floating Rate Notes Due 2031
(the "Class B-R Notes"), Assigned Aa2 (sf)

US$9,000,000 Class C-R Secured Deferrable Floating Rate Notes Due
2031 (the "Class C-R Notes"), Assigned A2 (sf)

US$11,000,000 Class D-R Secured Deferrable Floating Rate Notes Due
2031 (the "Class D-R Notes"), Assigned Baa3 (sf)

US$11,000,000 Class E-R Secured Deferrable Floating Rate Notes Due
2031 (the "Class E-R Notes"), Assigned Ba3 (sf)

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.

The Issuer is a managed cash flow collateralized loan obligation.
The issued notes are collateralized by a portfolio of broadly
syndicated senior secured corporate loans and small and medium
enterprise loans. At least 85.0% of the portfolio must consist of
senior secured loans and eligible investments, and up to 15.0% of
the portfolio may consist of senior unsecured loans, second lien
loans and first-lien last-out loans.

The CMA will be assigned by the current manager, 325 Fillmore LLC,
to its affiliate ArrowMark Colorado Holdings LLC (the "Manager"),
who 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 four year
reinvestment period. Thereafter, the Manager may not reinvest in
new assets and all principal proceeds, including sale proceeds,
will be used to amortize the notes in accordance with the priority
of payments.

The Issuer has issued the Refinancing Notes on August 9, 2019 (the
"Refinancing Date") in connection with the refinancing of all
classes of the secured notes (the "Refinanced Original Notes")
originally issued on May 18, 2017 (the "Original Closing Date"). On
the Refinancing Date, the Issuer used proceeds from the issuance of
the Refinancing Notes, along with the proceeds from the issuance of
three other classes of secured notes to redeem in full the
Refinanced Original Notes. On the Original Closing Date, the issuer
also issued two classes of subordinated notes that remain
outstanding.

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

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

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

Portfolio par: $149,500,000

Diversity Score: 52

Weighted Average Rating Factor (WARF): 3317

Weighted Average Spread (WAS): 4.91%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 43.85%

Weighted Average Life (WAL): 8.0 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
March 2019.

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

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


PREFERRED TERM XVII: Moody's Hikes $65.6MM Class C Notes to Caa2
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by Preferred Term Securities XVII, Ltd.:

US$270,800,000 Floating Rate Class A-1 Senior Notes due June 23,
2035 (current balance of $110,355,881.95), Upgraded to Aa1 (sf);
previously on January 22, 2018 Upgraded to Aa2 (sf)

US$62,000,000 Floating Rate Class A-2 Senior Notes due June 23,
2035, Upgraded to A1 (sf); previously on June 19, 2017 Affirmed A2
(sf)

US$58,400,000 Floating Rate Class B Mezzanine Notes due June 23,
2035 (current balance of $53,293,282.24), Upgraded to Baa3 (sf);
previously on June 19, 2017 Affirmed Ba2 (sf)

US$65,600,000 Floating Rate Class C Mezzanine Notes due June 23,
2035 (current balance of $60,768,398.81), Upgraded to Caa2 (sf);
previously on June 19, 2017 Upgraded to Caa3 (sf)

Preferred Term Securities XVII, Ltd., issued in March 2005, is a
collateralized debt obligation backed by a portfolio of bank and
insurance trust preferred securities (TruPS).

RATINGS RATIONALE

The rating actions are primarily a result of the deleveraging of
the notes and an increase in the transaction's
over-collateralization ratios since August 2018.

The Class A-1, Class B, and Class C notes have paid down by
approximately 3.0% or $3.4 million, 1.6% or $0.9 million, and 1.6%
or $1.0 million, respectively, since August 2018, using principal
proceeds from the redemption of the underlying assets (in the case
of Class A-1 notes) and the diversion of excess interest proceeds.
Based on Moody's calculations, the OC ratios for the Class A-1,
Class A-2, Class B, and Class C notes have improved to 271.62%,
173.91%, 132.84%, and 104.65%, respectively, from August 2018
levels of 250.86%, 165.08%, 127.03%, and 100.58%, respectively. The
Class A-1, Class B, and Class C notes will continue to benefit from
the diversion of excess interest so long as the Class C OC test is
failing (current level of 104.65% versus trigger of 107.00%), and
the Class A-1 notes will benefit from the use of proceeds from
redemptions of any assets in the collateral pool.

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 of $299.7 million,
defaulted/deferring par of $85.6 million, a weighted average
default probability of 13.2% (implying a WARF of 1317), and a
weighted average recovery rate upon default of 10.0%.

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.


SDART 2019-3: Moody's Assigns (P)B1 Rating on Class E Debt
----------------------------------------------------------
Moody's Investors Service assigned provisional ratings to the notes
to be issued by Santander Drive Auto Receivables Trust 2019-3. This
is the third SDART auto loan transaction of the year for Santander
Consumer USA Inc. (SC; unrated). The notes will be backed by a pool
of retail automobile loan contracts originated by SC, who is also
the servicer and administrator for the transaction.

The complete rating actions are as follows:

Issuer: Santander Drive Auto Receivables Trust 2019-3

Class A-1, Assigned (P)P-1 (sf)

Class A-2A, Assigned (P)Aaa (sf)

Class A-2B, Assigned (P)Aaa (sf)

Class A-3, Assigned (P)Aaa (sf)

Class B, Assigned (P)Aa1 (sf)

Class C, Assigned (P)Aa2 (sf)

Class D, Assigned (P)Baa1 (sf)

Class E, Assigned (P) B1 (sf)

RATINGS RATIONALE

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


Moody's median cumulative net loss expectation for SDART 2019-3 is
15.0% and loss at a Aaa stress is 47.0%, both of which are the same
as the prior rated transaction, SDART 2019-2. Moody's based its
cumulative net loss expectation and loss at a Aaa stress on an
analysis of the credit quality of the underlying collateral; the
historical performance of similar collateral, including
securitization performance and managed portfolio performance; the
ability of SC to perform the servicing functions; and current
expectations for the macroeconomic environment during the life of
the transaction.

At closing the Class A notes, Class B notes, Class C notes, Class D
notes, and Class E are expected to benefit from 52.60%, 41.20%,
25.70%, 15.45%, and 7.25% of hard credit enhancement, respectively.
Hard credit enhancement for the notes consists of a combination of
overcollateralization, a non-declining reserve account and
subordination, except for Class E notes which does not have
subordination. The notes may also benefit from excess spread.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Auto Loan- and Lease-Backed ABS" published in
March 2019.

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


Up

Moody's could upgrade the subordinate notes if, given current
expectations of portfolio losses, levels of credit enhancement are
consistent with higher ratings. In sequential pay structures, such
as the one in this transaction, credit enhancement grows as a
percentage of the collateral balance as collections pay down senior
notes. Prepayments and interest collections directed toward note
principal payments will accelerate this build of enhancement.
Moody's expectation of pool losses could decline as a result of a
lower number of obligor defaults or appreciation in the value of
the vehicles securing an obligor's promise of payment. Portfolio
losses also depend greatly on the US job market, the market for
used vehicles, and changes in servicing practices.

Down

Moody's could downgrade the notes if, given current expectations of
portfolio losses, levels of credit enhancement are consistent with
lower ratings. Credit enhancement could decline if excess spread is
not sufficient to cover losses in a given month. Moody's
expectation of pool losses could rise as a result of a higher
number of obligor defaults or deterioration in the value of the
vehicles securing an obligor's promise of payment. Portfolio losses
also depend greatly on the US job market, the market for used
vehicles, and poor servicing. Other reasons for worse-than-expected
performance include error on the part of transaction parties,
inadequate transaction governance, and fraud. Additionally, Moody's
could downgrade the Class A-1 short-term rating following a
significant slowdown in principal collections that could result
from, among other things, high delinquencies or a servicer
disruption that impacts obligor's payments.


SECURITIZED ASSET 2005-OP2: Moody's Cuts Class M-1 Debt to B1
-------------------------------------------------------------
Moody's Investors Service downgraded the rating of Class M-1 from
Securitized Asset Backed Receivables LLC Trust 2005-OP2.

The complete rating action is as follows:

Issuer: Securitized Asset Backed Receivables LLC Trust 2005-OP2

  Cl. M-1, Downgraded to B1 (sf); previously on Nov 25,
  2014 Upgraded to Ba1 (sf)

RATINGS RATIONALE

The rating downgrade of Class M-1 from Securitized Asset Backed
Receivables LLC Trust 2005-OP2 is due to the outstanding interest
shortfalls on the bond which are not expected to be reimbursed.
Class M-1 missed two interest payments: in November 2016 and July
2019. As of July 2019 remittance report, the Class M-1 has an
outstanding interest shortfall of $83.6K.

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 3.7% in July 2019 from 3.9% in July
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, the
performance of RMBS continues to remain highly dependent on
servicer procedures. Any changes resulting from servicing
transfers, or other policy or regulatory shifts can impact the
performance of this transaction.


SMALL BUSINESS 2019-A: Moody's Assigns (P)Ba3 Rating on Cl. C Notes
-------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to the notes
to be issued by Small Business Lending Trust 2019-A, a
securitization backed by loans granted to small- and medium-sized
enterprises and sponsored by FC Marketplace, LLC. The transaction
is Funding Circle's inaugural U.S. SME ABS issuance and the company
originated the collateral through its online lending platform in
the U.S. Funding Circle will also act as the administrator and the
servicer of the underlying assets.

The complete rating actions are as follows:

Issuer: Small Business Lending Trust 2019-A

  Class A Notes, Assigned (P)A3 (sf)

  Class B Notes, Assigned (P)Baa3 (sf)

  Class C Notes, Assigned (P)Ba3 (sf)

RATINGS RATIONALE

The provisional ratings are based on the credit quality of the
small business loans to be securitized and their expected
performance, available credit enhancement, the transaction
structure, the back-up servicing arrangement with Portfolio
Financial Servicing Company (PFSC), and the legal aspects of the
transaction.

Moody's expected cumulative gross default rate assumption for the
SBIZ 2019-A transaction is 14.5%; the expected net loss rate
assumption is 13.8% after considering a 5% recovery rate
assumption. In arriving at a probability distribution for projected
pool losses, Moody's also assumed a portfolio credit enhancement
(PCE, or the level of credit enhancement consistent with a Aaa (sf)
rating for a security) of 55%.

In arriving at these assumptions, Moody's considered the credit
quality and tenor of the securitized pool and the historical
performance of Funding Circle's managed portfolio and other similar
collateral. Moody's also considered its expectations for the
macroeconomic environment during the life of the transaction.

Key credit strengths of the transaction include i) strong
structural features that result in the build-up of credit
enhancement as the pool amortizes, ii) the granularity of the
portfolio, iii) the short weighted average lives of the pool and
rated certificates, and iii) the back-up servicing arrangement with
PFSC intended to mitigate payment disruption in the event Funding
Circle can no longer perform its duties.

Key credit challenges of the transaction include i) a small,
relatively new sponsor with no prior securitization experience in
the U.S., ii) the company's evolving underwriting model, iii)
relatively high industry concentrations, iv) the potential for
misalignment of interests between the sponsor and the noteholders,
v) and comparative weaknesses in certain originator representations
and warranties.

At closing, the Class A, Class B and Class C notes will benefit
from 32.5%, 25.0%, and 16.0% of hard credit enhancement,
respectively. Hard credit enhancement for the notes at close will
consist of subordination, initial over-collateralization of 5.5%
which will build to a target amount of 11.0% of the performing pool
balance, and a fully funded, non-declining reserve account of 0.5%.
Excess spread may also be available as additional credit protection
for the notes.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's Global
Approach to Rating SME Balance Sheet Securitizations" published in
July 2019.

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


Up

Levels of credit protection that are greater than necessary to
protect investors against current expectations of loss could lead
to an upgrade of the ratings of the notes. Moody's then current
expectations of loss may be lower than its original expectations
because of lower frequency of default by the underlying obligors.
As a primary driver of performance, positive changes in the US
macro economy could also affect the ratings.

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could lead to a
downgrade of the ratings of the notes. Moody's then current
expectations of loss may be higher than its original expectations
because of higher frequency of default by the underlying obligors
of the loans. As a primary driver of performance, negative changes
in the US macro economy could also affect the ratings.


WACHOVIA BANK 2007-C30: Fitch Hikes Class E Certs to CCsf
---------------------------------------------------------
Fitch Ratings has affirmed five and upgraded one class of Wachovia
Bank Commercial Mortgage Trust's commercial mortgage pass-through
certificates, series 2007-C30.

Wachovia Bank Commercial Mortgage Trust 2007-C30

           Current Rating      Prior Rating
Class E   LT CCsf  Upgrade    previously at Csf
Class F   LT Csf   Affirmed   previously at Csf
Class G   LT Dsf   Affirmed   previously at Dsf
Class H   LT Dsf   Affirmed   previously at Dsf
Class J   LT Dsf   Affirmed   previously at Dsf
Class K   LT Dsf   Affirmed   previously at Dsf

KEY RATING DRIVERS

Increased Credit Enhancement: The upgrade to class E reflects
increased credit enhancement due to better than expected recoveries
on the specially serviced Twin Oaks Pool asset that was liquidated
since the prior rating action. As of the July 2019 remittance
report, the pool's aggregate principal balance has been reduced by
98.8% to $94.4 million from $7.9 billion at issuance. Realized
losses total $581.1 million (7.4% of original pool balance).
Cumulative interest shortfalls in the amount of $108.5 million are
currently affecting classes F and G and J through S.

Loss Expectations Remain High: Although loss expectations remain
high, they are slightly less certain to impact class E. All of the
remaining loans have been previously modified or are in special
servicing.

Concentrated Pool/Alternative Loss Considerations: The pool is
highly concentrated with only four assets remaining.   Two
performing loans have been bifurcated into an A and B Note (61.9%),
one specially serviced loan is considered a non-performing maturity
default (16.1%), and the remaining specially serviced loan is past
maturity but performing (22%). Due to the concentrated nature of
the pool, Fitch performed a sensitivity and liquidation analysis
that included the expected losses and potential payoff proceeds of
the remaining loans. The ratings reflect this analysis.

Fitch Loans of Concern: The largest performing loan is the NJ
Office Pool A/B Note (41.8%), which is secured by three office
properties located in Parsippany and East Hanover NJ. The loan had
previously been transferred to the special servicer twice and was
also modified each time. The first modification included a
bifurcation into an A and B note, and the second modification in
April 2017 included extending the maturity date until February
2020. The largest property in the portfolio, 1255 Broad Street,
sold from the portfolio in 2018. As of YE 2018 the NCF DSCR was
0.90x and portfolio occupancy was 58%.

The largest specially serviced loan is the Mercedes-Benz Central
Parts Warehouse (22%), which is secured by a 518,400 sf industrial
property located in Vance, AL that has been 100% occupied by
Mercedes Benz USA International since issuance. The loan
transferred to the special servicer in May 2016 before the loans
January 2017 maturity date. The tenant's lease expires in October
2020, and they are not required to notify the landlord of a lease
renewal until February 2020. Discussions with the tenant for an
earlier lease renewal have not been successful, and efforts to
refinance the property also have not been successful. In January
2019 the second 12-month forbearance term expired, and in June 2019
the borrower proposed a discounted payoff or continuing to operate
the property while working towards a lease renewal or finding a new
tenant. The YE 2018 NOI DSCR was 1.23x.


WFRBS COMMERCIAL 2013-C18: Fitch Affirms B Rating on Class F Debt
-----------------------------------------------------------------
Fitch Ratings has affirmed 13 classes in WFRBS Commercial Mortgage
Trust series 2013-C18 commercial mortgage pass through
certificates.

WFRBS 2013-C18

                        Current Rating      Prior Rating
Class A-2 96221QAB9;  LT AAAsf  Affirmed  previously at AAAsf
Class A-3 96221QAC7;  LT AAAsf  Affirmed  previously at AAAsf
Class A-4 96221QAD5;  LT AAAsf  Affirmed  previously at AAAsf
Class A-5 96221QAE3;  LT AAAsf  Affirmed  previously at AAAsf
Class A-S 96221QAG8;  LT AAAsf  Affirmed  previously at AAAsf
Class A-SB 96221QAF0; LT AAAsf  Affirmed  previously at AAAsf
Class B 96221QAJ2;    LT AA-sf  Affirmed  previously at AA-sf
Class C 96221QAK9;    LT A-sf   Affirmed  previously at A-sf
Class D 96221QAM5;    LT BBB-sf Affirmed  previously at BBB-sf
Class E 96221QAP8;    LT BBsf   Affirmed  previously at BBsf
Class F 96221QAR4;    LT Bsf    Affirmed  previously at Bsf
Class PEX 96221QAL7;  LT A-sf   Affirmed  previously at A-sf
Class X-A 96221QAH6;  LT AAAsf  Affirmed  previously at AAAsf

KEY RATING DRIVERS

Loss Expectations Remain High: Performance for the Fitch Loans of
Concern (FLOCs) has not improved. There have been no new defaults
since the last rating action, and one loan that was previously in
special servicing has since been modified and transferred back to
the master servicer. Fitch's modeling approach included a
pool-level sensitivity stress, in which a higher Probability of
Default was assigned to all loans modeled as maturity defaults.
This approach was taken to reflect the possibility that FLOCs and
other assets with concentrated term rollover, low DSCR and debt
yield may not be able to refinance in the wave of loan maturities
in 2023.

Increased Credit Enhancement: Concerns related to the FLOCs and
specially serviced asset are somewhat mitigated by the increased
credit enhancement. Since the last rating action, three loans have
repaid, contributing to the paydown of class A-2. These loan
payoffs were contemplated in Fitch's analysis at the time of the
last rating action. The second largest loan in the pool is
scheduled to mature by YE2020 and is considered likely to
refinance, based on the asset's performance and location. No other
loans are scheduled to mature prior to 2023.

RATING SENSITIVITIES

The Outlooks for classes E and F remain Negative as Fitch's loss
projections remain high. Although one loan that was previously in
special servicing has transferred back to the master servicer since
the last rating action, the performance of this loan and other
Fitch Loans of Concern has not improved. Additionally, another Top
15 loan that was in special servicing at the last rating action has
since become REO. Improved credit enhancement helps to mitigate the
concern surrounding the recent performance declines. However,
additional defaults or continued performance issues could result in
downgrades to the bonds. Classes could be upgraded with marked
improvement in asset-level performance and continued paydown of the
senior bonds.


WFRBS COMMERCIAL 2014-C22: Fitch Lowers Class D Certs Rating to B
-----------------------------------------------------------------
Fitch Ratings has downgraded one class and affirmed 13 classes of
Wells Fargo Bank, N.A.'s WFRBS Commercial Trust series 2014-C22
commercial mortgage trust pass-through certificates. A Negative
Rating Outlook has been maintained for the downgraded class and a
Negative Rating Outlook has been assigned to two of the classes
that have been affirmed.

WFRBS 2014-C22

                        Current Rating     Prior Rating
Class A-2 92890KAX3;  LT AAAsf Affirmed;  previously at AAAsf
Class A-4 92890KAZ8;  LT AAAsf Affirmed;  previously at AAAsf
Class A-5 92890KBA2;  LT AAAsf Affirmed;  previously at AAAsf
Class A-S 92890KBC8;  LT AAAsf Affirmed;  previously at AAAsf
Class A-SB 92890KBB0; LT AAAsf Affirmed;  previously at AAAsf
Class B 92890KBF1;    LT AA-sf Affirmed;  previously at AA-sf
Class C 92890KBG9;    LT A-sf  Affirmed;  previously at A-sf
Class E 92890KAL9;    LT CCCsf Affirmed;  previously at CCCsf
Class F 92890KAN5;    LT CCCsf Affirmed;  previously at CCCsf
Class X-A 92890KBD6;  LT AAAsf Affirmed;  previously at AAAsf
Class X-C 92890KAA3;  LT CCCsf Affirmed;  previously at CCCsf
Class X-D 92890KAC9;  LT CCCsf Affirmed;  previously at CCCsf
Class D 92890KAJ4;    LT Bsf   Downgrade; previously at BBsf

KEY RATING DRIVERS

Increased Loss Expectations: The downgrade and Negative Rating
Outlooks reflect increased expected losses, in large part due to
the continued underperformance of the Stamford Plaza Portfolio
(7.36% of the pool), the third largest loan.  The loan is secured
by two, 15-story, class A office buildings and two, 16-story, class
A office buildings containing 982,483 square feet located in
Stamford, CT. This loan is the largest Fitch Loan of Concern
(FLOC). Occupancy for the Portfolio declined to 65% as of year-end
2018 (YE18) from 83% as of YE17 resulting in a YE18 NOI Debt
Service Coverage Ratio of 0.95x compared with 1.71x at YE17. The
loan is structured with a partial interest-only period that ends in
August 2019, at which time the loan will begin amortizing. The
Stamford office market remains soft with submarket vacancy of
approximately 27%. Fitch's value for this loan in the base case did
not rely on the reported net cash flow, as it is not considered
representative of the property's value. While occupancy and cash
flow have declined, the loan remains current and is not scheduled
to mature until 2024, leaving some time for lease-up and improved
performance.

Four loans (4.1% of the pool) are in special servicing including
one loan (0.6% of the pool) that transferred to special servicing
since the last rating action. There are six additional
non-specially serviced loans (3.03% of the pool) flagged as FLOCs
due to performance deterioration.

Alternative Loss Consideration:  Fitch modeled a base case loss of
25% for the Stamford Portfolio, which equates to a value of $205
per square foot (psf), which is in-line with recent sales in the
submarket.  In addition to the base case loss for the loan, Fitch
also included an additional sensitivity, which assumed a loss of
50%, based on a more conservative recovery estimate of $135 psf.
The sensitivity analysis contributed to the downgrade of class D
and Negative Outlooks on classes B and C.

Minimal Changes to Credit Enhancement:  The rating affirmations of
the senior classes reflect the relatively stable performance for
the majority of the pool. As of the July 2019 distribution date,
the pool's aggregate principal balance has paid down by 8.61% to
$1.36 billion from $1.488 billion at issuance compared with paydown
of 4.33% at the last rating action. Three loans have repaid since
the last rating action including one loan (2.0% of the pool at the
last rating action) that was previously flagged as a FLOC. One loan
representing 0.7% of the pool is scheduled to mature in 2019 and
four loans representing 2.9% of the pool are scheduled to mature in
2020. There are no other scheduled maturities until 2024. Three
loans have fully defeased since the last rating action, bringing
the total of defeased loans to eight ($69 million, 5.1% of the
pool).

Property Concentrations: Of the top 20 loans, five (10.0% of the
pool) are secured by properties leased to a single tenant. These
include CSM Bakery Supplies Portfolio I & II (5.1%), Preferred
Freezer Houston (1.9%), 400 Atlantic (1.8%) and Lincoln Plaza
(1.2%). These particular loans are considered to be more prone to
cash flow disruption in the event of changes in occupancy in
comparison with multitenant properties.

RATING SENSITIVITIES

Rating Outlooks on classes A-2 through A-S remain Stable due to
relatively stable performance for the majority of the pool and
expected continued paydown. The Rating Outlooks for Classes B and C
were revised to Negative from Stable to reflect increased loss
expectations associated with the third largest loan in the pool:
Stamford Plaza Portfolio. Should the portfolio not stabilize prior
to maturity or the sponsor be unwilling to cover shortfalls,
downgrades are possible.

Barring any significant paydown event or substantial increase in
defeased collateral, Fitch expects future upgrades to be limited.


                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

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

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

TCR subscribers have free access to our on-line news archive.
Point your Web browser to http://TCRresources.bankrupt.com/and use
the e-mail address to which your TCR is delivered to login.

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S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.
Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Valerie Udtuhan, Howard C. Tolentino, Carmel Paderog,
Meriam Fernandez, Joel Anthony G. Lopez, Cecil R. Villacampa,
Sheryl Joy P. Olano, Psyche A. Castillon, Ivy B. Magdadaro, Carlo
Fernandez, Christopher G. Patalinghug, and Peter A. Chapman,
Editors.

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

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

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

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