/raid1/www/Hosts/bankrupt/TCR_Public/191020.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

              Sunday, October 20, 2019, Vol. 23, No. 292

                            Headlines

AASET TRUST 2019-2: Fitch Assigns BBsf Rating on Class C Debt
AMMC CLO 19: S&P Affirms BB (sf) Rating on Class E Notes
AMUR EQUIPMENT V: DBRS Confirms B Rating on Class F Notes
ANGEL OAK 2019-5: S&P Assigns Prelim B (sf) Rating to Cl. B-2 Certs
ARIVO ACCEPTANCE 2019-1: DBRS Finalizes BB Rating on Class C Notes

AUSTIN FAIRMONT 2019-FAIR: S&P Assigns B- (sf) Rating on F Certs
BCC FUNDING 2019-1: Moody's Assigns Ba2 Rating on Class D Notes
BEAR STEARNS 2007-PWR18: Fitch Lowers Class C Debt Rating to Csf
BELLEMEADE RE 2019-4: Fitch Assigns B+ Rating on Cl. M1C Debt
BENCHMARK 2019-B13: Fitch Assigns B-sf Rating on Cl. G-RR Certs

CF 2019-CF2: Fitch Assigns B-sf Ratings on 2 Tranches
CHASE MORTGAGE 2019-CL1: Fitch Rates $3.408MM Cl. M-4 Notes 'BBsf'
CIM TRUST 2019-R2: Moody's Assigns B3 Rating on Class B2 Notes
CITIGROUP COMMERCIAL 2016-C3: Fitch Affirms Class F Certs at B-sf
CLNC LTD 2019-FL1: DBRS Assigns Prov. B(low) Rating on G Notes

COMM 2014-CCRE16: Fitch Lowers Rating on Class F Debt to CCC
CPS AUTO 2019-D: S&P Assigns B (sf) Rating to Class F Notes
DRYDEN 76 CLO: S&P Assigns Prelim BB- Rating to $12MM Class E Notes
DT AUTO OWNER: DBRS Took 38 Ratings on 11 Transactions
EXETER AUTOMOBILE 2019-4: S&P Assigns BB (sf) Rating to Cl. E Notes

FALCON 2019-1: Fitch to Rate Series C Notes 'BB(EXP)'
GERMAN AMERICAN 2016-CD2: Fitch Affirms B-sf Rating on Cl. F Certs
GS MORTGAGE 2019-PJ3: Moody's Assigns (P)B2 Rating on Cl. B-5 Debt
HIGHER EDUCATION 2010-1: Fitch Lowers Class A-1 Debt Rating to BBsf
HORIZON AIRCRAFT III: Fitch to Rate $36MM Series C Notes 'BB(EXP)'

IMSCI 2016-7: Fitch Affirms Bsf Rating on Class G Certs
JP MORGAN 2003-ML1: Fitch Affirms 'Dsf' Rating on Class N Certs
JP MORGAN 2004-C3: Moody's Raises Rating on Class H Certs to B3(sf)
JP MORGAN 2017-FL11: DBRS Confirms BB(low) Rating on Cl. E Certs
JP MORGAN 2019-LTV3: DBRS Gives Prov. B Rating on Class B-5 Certs

JP MORGAN 2019-LTV3: Moody's Gives Prov. B3 Rating on Cl. B-5 Debt
JPMBB COMMERCIAL 2013-C12: Moody's Affirms B2 Rating on Cl. F Debt
JPMCC MORTGAGE 2019-BROOK: Fitch Rates $41.150MM Cl. F Certs B-sf
KKR CLO 27: S&P Assigns BB- (sf) Rating to Class E Notes
M360 LTD 2019-CRE2: DBRS Finalizes B(low) Rating on Class G Notes

MAGNETITE XXIII: S&P Assigns Prelim BB- (sf) Rating to Cl. E Notes
MELLO WAREHOUSE 2019-2: Moody's Gives (P)Ba2 Rating to Class E Debt
MERRILL LYNCH 2008-C1: Fitch Lowers Class H Certs Rating to Csf
MILL CITY 2019-GS1: Moody's Assigns Caa1 Ratings on 2 Tranches
MONROE CAPITAL IX: Moody's Gives (P)Ba3 Rating to Class E Notes

MORGAN STANLEY 2016-BNK2: Fitch Affirms B-sf Rating on 2 Tranches
MORGAN STANLEY 2016-C32: Fitch Affirms B-sf Rating on Cl. F Debt
NATIXIS COMMERCIAL 2019-1776: Moody's Gives (P)B3 on Cl. F Certs
NEW RESIDENTIAL 2019-5: DBRS Finalizes B Rating on 8 Note Classes
NRZ ADVANCE 2015-ON1: S&P Assigns BB (sf) Rating to Cl. E-T4 Notes

OBX TRUST 2019-EXP3: Fitch to Rate Class B-5 Debt 'B(EXP)'
PARK AVENUE 2019-2: S&P Assigns BB- (sf) Rating to Cl. D Notes
PAWNEE EQUIPMENT 2019-1: DBRS Finalizes BB Rating on Class E Notes
RAPTOR AIRCRAFT: S&P Assigns Prelim BB (sf) Rating to Class C Notes
RCKT MORTGAGE 2019-1: Moody's Assigns B1 Rating on Cl. B-5 Debt

REGATTA XII F: S&P Rates $15MM Class E Notes 'BB- (sf)'
RESIDENTIAL MORTGAGE 2019-3: DBRS Finalizes B Rating on B-2 Notes
SCF EQUIPMENT 2019-2: Moody's Assigns (P)B3 Rating on Cl. F Notes
SG COMMERCIAL 2019-PREZ: S&P Assigns B- (sf) Rating to Cl. F Certs
SKOPOS AUTO 2018-1: DBRS Confirms BB Rating on Class D Notes

STARWOOD MORTGAGE 2019-INV1: DBRS Finalizes BB(low) on B1 Certs
STARWOOD MORTGAGE 2019-INV1: S&P Assigns B- Rating to B-2 Certs
TOWD POINT 2019-HY3: Moody's Assigns (P)B2 Rating on Cl. B2 Notes
TRTX ISSUER 2019-FL3: DBRS Gives Prov. B(low) on Class G Notes
UBS COMMERCIAL 2019-C17: Fitch Assigns Bsf Rating on 2 Tranches

WELLS FARGO 2019-C53: Fitch to Rate $8.7MM Class H-RR Debt 'B-sf'
WESTLAKE AUTOMOBILE 2018-3: S&P Affirms B+ (sf) Rating to F Notes
WESTLAKE AUTOMOBILE 2019-3: DBRS Assigns Prov. B Rating on F Notes
[*] DBRS Reviews 439 Classes From 57 U.S. RMBS Transactions
[*] S&P Takes Various Actions on 141 Classes From 22 US RMBS Deals

[*] S&P Takes Various Actions on 200 Classes From 57 US RMBS Deals
[*] S&P Takes Various Actions on 300 Classes From 73 US RMBS Deals

                            *********

AASET TRUST 2019-2: Fitch Assigns BBsf Rating on Class C Debt
-------------------------------------------------------------
Fitch Ratings assigned ratings and Outlooks to AASET 2019-2 Trust.

AASET 2019-2

          Current Rating         Prior Rating

Class A; LT Asf New Rating;   previously at A(EXP)sf

Class B; LT BBBsf New Rating; previously at BBB(EXP)sf

Class C; LT BBsf New Rating;  previously at BB(EXP)sf

TRANSACTION SUMMARY

AASET 2019-2 expects to use proceeds of the initial notes to
acquire all the aircraft-owning entity series A, B and C notes
(initial series A, B and C AOE notes) issued by AASET 2019-2 US
Ltd. and AASET 2019-2 International Ltd., collectively, the AOE
issuers.

The notes will be secured by lease payments and disposition
proceeds on a pool of 29 mid- to end-of-life aircraft purchased
from certain funds (the SASOF Funds), managed by subsidiaries of
Carlyle Aviation Partners Ltd. (CAP) collectively with its
affiliates (Carlyle Aviation). Carlyle Aviation Management Limited
(CAML), an indirect subsidiary of CAP, will be the servicer. This
is the fifth public, Fitch-rated AASET transaction, and the eighth
issued since 2014 and serviced by CAML. Fitch does not rate CAP or
CAML.

KEY RATING DRIVERS

Stable Asset Quality: Mostly Liquid Narrowbody: The pool is
composed of 29 aircraft including 11 A320-200s (39.8%) and seven
B737-800s (24.8%). The pool contains four widebody aircraft, two
A330-200s (10.1%), and two B777-200ERs (5.5%). The pool has a
weighted average (WA) age of 11.9 years, which is at the older end
of the range for recent transactions but younger than recent AASET
transactions.

Lease Term and Maturity Schedule - Neutral: The WA remaining lease
term of 3.0 years is comparable to recently rated pools but on the
lower end compared to prior AASET transactions. One lease, totaling
3.4% of the pool, matures in 2019, four leases (17.8%) in 2020,
seven leases (23.0%) in 2021, and eight leases (28.3%) in 2022.
From 2019 to 2022, 20 leases (72.5%) come due.

Weaker Lessee Credits: Lessees assumed at 'CCC' by Fitch total
14.5%, significantly lower relative to AASET 2019-1 and 2018-2
(47.5% and 30.6%, respectively). Most of the 17 lessees are either
unrated or speculative-grade credits, typical of aircraft ABS.
Unrated or speculative airlines are assumed to perform consistent
with either a 'B' or 'CCC' Issuer Default Rating (IDR) to reflect
default risk in the pool. Ratings were further stressed during
future assumed recessions and once an aircraft reaches Tier 3
classification.

Country Credit Risk - Neutral: The largest country concentration is
Brazil (IDR BB-/Stable) with five aircraft (20.4%), and the second
largest is Vietnam (13.2%) with three aircraft. The next largest
country concentrations are the U.S. (10.7%), United Arab Emirates
(10.1%) and India (10.0%). The top five countries total 64.4%, with
25.5% of lessees concentrated in emerging APAC, reflective of
recent growth in the region.

Consistent Transaction Structure: Credit enhancement (CE) comprises
overcollateralization (OC), a liquidity facility and a cash
reserve. The initial loan to value (LTV) ratios for class A, B and
C notes are 66.5%, 78.5% and 83.5%, respectively, based on the
average of the maintenance-adjusted base values (MABVs). These
levels are consistent with prior AASET transactions.

Adequate Structural Protections: Each class of notes makes full
payment of interest and principal in the primary scenarios,
commensurate with their ratings after applying Fitch's stressed
asset and liability assumptions. Fitch has also created multiple
alternative cash flows to evaluate the structural sensitivity to
different scenarios, as detailed in the Rating Sensitivities
section.

Capable Servicing History and Experience: Fitch believes CAML has
the ability to collect lease payments, remarket and repossess
aircraft in an event of lessee default, and procure maintenance to
retain values and ensure stable performance. This is evidenced by
its prior securitization performance and servicing experience of
aviation assets and managed aviation funds. CAP's parent company,
The Carlyle Group (Carlyle) is rated 'BBB+'/Outlook Stable.

Aviation Market Cyclicality: Commercial aviation has been subject
to significant cyclicality due to macroeconomic and geopolitical
events. Fitch's analysis assumes multiple periods of significant
volatility over the life of the transaction. Downturns are
typically marked by reduced aircraft utilization rates, values and
lease rates, as well as deteriorating lessee credit quality. Fitch
employs aircraft value stresses in its analysis, which takes into
account age and marketability to simulate the decline in lease
rates expected over the course of an aviation market downturn and
the decrease to potential residual sales proceeds.

Rating Cap of 'Asf': Fitch limits aircraft operating lease ratings
to a maximum cap of 'Asf' due to the factors discussed above and
the potential volatility they produce.

RATING SENSITIVITIES

The performance of aircraft operating lease securitizations can be
affected by various factors, which, in turn, could have an impact
on the assigned ratings. Fitch conducted multiple rating
sensitivity analyses to evaluate the impact of changes to a number
of the variables in the analysis. These sensitivity scenarios were
also considered in determining Fitch's expected ratings.

Technological Cliff Stress Scenario

All aircraft in the pool face replacement programs over the next
decade. Fitch believes the current generation aircraft in the pool
remain well insulated due to large operator bases and long lead
times for full replacement. This scenario simulates a drop in
demand (and associated values). The first recession was assumed to
occur two years following close, and all recessionary value decline
stresses were increased by 10% at each rating category. Fitch
additionally utilized a 25% residual assumption rather than the
base level of 50% to stress end-of-life proceeds for each asset in
the pool. Lease rates drop under this scenario, and aircraft are
sold for scrap at end of useful lives.

Under this scenario, all classes fail 'Asf' and 'BBBsf' stresses.
All classes are able to pass at 'BBsf' category. As a result, such
a scenario could result in the downgrade of class A notes by up to
two categories, while class B notes could experience a downgrade of
up to one category. This is the most stressful sensitivity to this
transaction because of heavier reliance on residual proceeds.

'CCC' Unrated Lessee Assumption Stress Scenario

Airlines across the globe are generally viewed as speculative
grade. While Fitch gives credit to available ratings of the initial
lessees in the pool, assumptions must be made for the unrated
lessees in the pool, as well as all future unknown lessees. While
Fitch typically utilizes a 'B' assumption for most unrated lessees
with some assumed to be 'CCC', Fitch evaluated a scenario in which
all unrated airlines are assumed to carry a 'CCC' rating. This
scenario mimics a prolonged recessionary environment in which
airlines are susceptible to an increased likelihood of default.
This would subject the aircraft pool to increased downtime and
expenses, as repossession and remarketing events would increase.

Under this scenario, class A and class B notes pass at 'Asf'
stress. Class C notes pass at 'BBBsf' stress. This sensitivity is
less stressful to the transactions because 41.3% of the initial
lessees in the pool have public ratings, and rated lessees are
shielded from this sensitivity.

Lease Rate Factor Scenario

Increased competition, largely from newly established APAC lessors,
has contributed to declining lease rates in the aircraft leasing
market over the past few years. Additionally, certain variants have
been more prone to value declines and lease rates due to oversupply
issues. Fitch performed a sensitivity analysis assuming lease rate
factors (LRFs) would not increase after an aircraft reached 11
years of age, providing a material haircut to future lease cash
flow generation. Per Fitch's criteria LRF curve, no subsequent
leases were executed at a LRF greater than 1.13%. This scenario
highlights the effect of increased competition in the aircraft
leasing market, particularly for mid- to end-of-life aircraft over
the past few years, and stresses the pool to a higher degree by
assuming lease rates well below observed market rates.

Under this scenario, classes A, B and C pass at 'Asf', 'BBBsf', and
'BBsf' stresses, respectively.


AMMC CLO 19: S&P Affirms BB (sf) Rating on Class E Notes
--------------------------------------------------------
S&P Global Ratings assigned its ratings to the class AR, BR, and CR
replacement notes from AMMC CLO 19 Ltd., a CLO originally issued in
2016 that is managed by American Money Management Corp. S&P
withdrew its ratings on the original class A, B, and C notes
following payment in full on the Oct. 15, 2019 refinancing date. At
the same time, S&P affirmed its ratings on the class D and E notes,
which are not being refinanced.

On the Oct. 15, 2019, refinancing date, the proceeds from the class
AR, BR, and CR replacement note issuances were used to redeem the
original class A, B, and C notes as outlined in the transaction
document provisions. Therefore, S&P withdrew its ratings on the
original notes in line with their full redemption, and it is
assigning ratings to the replacement notes.

The replacement notes are being issued via a supplemental
indenture. Based on the supplemental indenture and the information
provided to S&P Global Ratings in connection with this review, the
replacement notes are expected to be issued at a lower spread over
LIBOR than the corresponding original notes and the balances of the
class A and B notes are expected to change.

  REPLACEMENT AND ORIGINAL NOTE ISSUANCES

  Table 1
  Replacement Notes

  Class                Amount        Interest
                     (mil. $)        rate (%)
  AR                   296.00        LIBOR + 1.14
  BR                   44.875        LIBOR + 1.80
  CR                   30.375        LIBOR + 2.55

  Table 2
  Original Notes

  Class                Amount        Interest
                     (mil. $)        rate (%)
  A                    288.00        LIBOR + 1.50
  B                    52.875        LIBOR + 1.90
  C                    30.375        LIBOR + 2.80

S&P's 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 its criteria,
S&P's cash flow scenarios applied forward-looking assumptions on
the expected timing and pattern of defaults, and recoveries upon
default, under various interest rate and macroeconomic scenarios.
In addition, the rating agency's 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 S&P's opinion that the credit support
available is commensurate with the associated rating levels.

In addition to outlining the terms of the replacement notes, the
supplemental indenture will also be:

-- Updating the S&P CDO Monitor language to conform to the latest
article released;

-- Updating the S&P Global Ratings recovery rate table to conform
to the latest criteria released; and

-- Adding LIBOR replacement language.

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 will take rating actions as it deems
necessary.

  RATINGS ASSIGNED
  AMMC CLO 19 Ltd./AMMC CLO 19 Corp.

  Replacement class    Rating      Amount (mil. $)
  AR                   AAA (sf)             296.00
  BR                   AA (sf)              44.875
  CR                   A (sf)               30.375
  Subordinated notes   NR                   45.850

  RATINGS AFFIRMED
  Class                Rating
  D                    BBB (sf)
  E                    BB (sf)

  RATINGS WITHDRAWN
                         Rating
  Class            To              From
  A                NR              AAA (sf)
  B                NR              AA (sf)
  C                NR              A (sf)

  NR--Not rated.


AMUR EQUIPMENT V: DBRS Confirms B Rating on Class F Notes
---------------------------------------------------------
DBRS, Inc. took rating actions on 20 outstanding ratings from three
Equipment Finance transactions. Of the rated classes reviewed, four
were upgraded, two were discontinued due to repayment and 14 were
confirmed. For the ratings that were upgraded, performance trends
are such that credit enhancement levels are sufficient to cover
DBRS Morningstar's expected losses at their new respective rating
levels. For the notes that were confirmed, performance trends are
such that credit enhancement levels are sufficient to cover DBRS
Morningstar's expected losses at their current respective rating
levels.

The Affected Ratings are:

Amur Equipment Finance Receivables V LLC

Series 2018-1, Class A-1 Notes    Disc.-Repaid Discontinued
Series 2018-1, Class A-2 Notes    Confirmed    AAA(sf)
Series 2018-1, Class B Notes      Confirmed    AA(sf)
Series 2018-1, Class C Notes      Confirmed    A(sf)
Series 2018-1, Class D Notes      Confirmed    BBB(sf)
Series 2018-1, Class E Notes      Confirmed    BB(sf)
Series 2018-1, Class F Notes      Confirmed    B(sf)

Amur Equipment Finance Receivables VI LLC

Series 2018-2, Class A-1 Notes    Disc.-Repaid Discontinued
Series 2018-2, Class A-2 Notes    Confirmed    AAA(sf)
Series 2018-2, Class B Notes      Confirmed    AA(sf)
Series 2018-2, Class C Notes      Confirmed    A(sf)
Series 2018-2, Class D Notes      Confirmed    BBB(sf)
Series 2018-2, Class E Notes      Confirmed    BB(sf)
Series 2018-2, Class F Notes      Confirmed    B(sf)

Amur Equipment Finance Receivables IV LLC, Series 2016-1

Series 2016-1, Class A         Confirmed     AAA(sf)
Series 2016-1, Class B         Confirmed     AAA(sf)
Series 2016-1, Class C         Upgraded      AAA(sf)
Series 2016-1, Class D         Upgraded      AA(sf)
Series 2016-1, Class E         Upgraded      A(sf)
Series 2016-1, Class F         Upgraded      BBB(sf)

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

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

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

-- The credit quality of the collateral pool and historical
performance.


ANGEL OAK 2019-5: S&P Assigns Prelim B (sf) Rating to Cl. B-2 Certs
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Angel Oak
Mortgage Trust 2019-5's mortgage pass-through certificates.

The issuance is a residential mortgage-backed securities
transaction backed by first-lien, second-lien, fixed- and
adjustable-rate, fully amortizing, and interest-only residential
mortgage loans secured by single-family residential properties,
townhouses, planned-unit developments, condominiums, and two- to
four-family residential properties to both prime and nonprime
borrowers. The pool has 969 loans, which are primarily nonqualified
mortgage loans.

The preliminary ratings are based on information as of Oct. 15,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

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

  PRELIMINARY RATINGS ASSIGNED

  Angel Oak Mortgage Trust 2019-5

  Class       Rating                  Amount ($)(i)
  A-1         AAA (sf)                  218,365,000
  A-2         AA (sf)                    22,578,000
  A-3         A (sf)                     48,858,000
  M-1         BBB- (sf)                  27,340,000
  B-1         BB (sf)                    14,111,000
  B-2         B (sf)                     13,405,000
  B-3         NR                          8,113,945
  A-IO-S      NR                           Notional(ii)
  XS          NR                           Notional(ii)
  R           NR                                N/A

(i)The collateral and structural information in this report
reflects the term sheet dated Oct. 10, 2019. The preliminary
ratings address the ultimate payment of interest and principal.
(ii)The notional amount equals the loans' stated principal balance.

NR--Not rated.
N/A--Not applicable.


ARIVO ACCEPTANCE 2019-1: DBRS Finalizes BB Rating on Class C Notes
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of notes issued by Arivo Acceptance Auto Loan Receivables
Trust 2019-1 (the Issuer):

-- $141,743,000 Class A at A (sf)
-- $18,147,000 Class B at BBB (sf)
-- $6,103,000 Class C at BB (sf)

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

-- Transaction capital structure, proposed ratings and form and
sufficiency of available credit enhancement. Credit enhancement is
in the form of overcollateralization (OC), subordination, amounts
held in the reserve fund and excess spread. Credit enhancement
levels are sufficient to support the DBRS Morningstar expected
cumulative net loss (CNL) assumption under various stress
scenarios. Please see the Credit Enhancement section in the related
rating report for more details.

-- The ability of the transaction to withstand stressed cash flow
assumptions and repay investors according to the terms under which
they have invested. For this transaction, the ratings address the
timely payment of interest on a monthly basis and principal by the
legal final maturity date. DBRS Morningstar assumptions for cash
flow modeling are described more fully under the Cash Flow Analysis
section in the related rating report.

-- DBRS Morningstar has performed an operational review of Arivo
Acceptance, LLC (Arivo) and considers the entity to be an
acceptable originator and servicer of subprime and non-prime auto
loans. The transaction structure provides for a transition of
servicing in the event a Servicer Termination Event occurs.
Wilmington Trust National Association (rated AA (low) with a Stable
trend by DBRS Morningstar) is the Backup Servicer, and Systems &
Services Technologies, Inc. is the Initial Successor Servicer.

-- The credit quality of the collateral and performance of Arivo's
auto loan portfolio. The weighted-average (WA) remaining life of
the collateral pool is 62 months. The non-zero WA FICO score of the
pool is 594. The transaction structure includes a Pre-Funding
Account in the amount of $20 million. DBRS Morningstar considered
the parameters surrounding the additional receivables that can be
purchased during the 60-day pre-funding period and believes the
characteristics of the receivables after giving effect to the
addition of any pre-funded receivables will not result in the final
receivables pool credit characteristics differing materially from
those of the receivables as of the Initial Cut-Off Date.

-- Loss performance for Arivo's loan originations is limited. As a
result, in addition to Arivo's loan performance data, DBRS
Morningstar incorporated proxy analysis to help determine an
expected CNL for the pool. The proxy analysis evaluated certain
demographic characteristics of Arivo's originations relative to
those of other issuers where DBRS Morningstar possessed more
extensive performance history.

-- 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 Arivo, that the Trust has a valid
first-priority security interest in the assets and the consistency
with DBRS Morningstar's "Legal Criteria for U.S. Structured
Finance" methodology.

This transaction is being structured as a public transaction
offering three classes of notes: Class A, Class B and Class C.
Initial Class A credit enhancement of 16.25% includes a reserve
account (1.00% of the initial pool balance, funded at inception and
non-declining); OC of 0.75%; and subordination of 14.50% of the
initial pool balance. Initial Class B enhancement of 5.40% includes
a 1.00% reserve account, 0.75% OC and 3.65% subordination. Initial
Class C enhancement of 1.75% includes OC of 0.75% and a reserve
account of 1.00%. OC will build to a target of 14.00% of the pool
balance, based on excess spread available in the structure, and is
subject to a floor of 1.00% of the initial pool balance. The
receivables securitized are subprime auto loan contracts secured by
new and used automobiles, light-duty trucks and vans.

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


AUSTIN FAIRMONT 2019-FAIR: S&P Assigns B- (sf) Rating on F Certs
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Austin Fairmont Hotel
Trust 2019-FAIR's commercial mortgage pass-through certificates.

The note issuance is a commercial mortgage-backed securities (CMBS)
transaction backed by the borrower's leasehold interest in the
1,048-guestroom Fairmont Austin, a full-service luxury hotel in
Austin.

The ratings reflect S&P's view of the collateral's historical and
projected performance, the sponsor's and manager's experience, the
trustee-provided liquidity, the loan's terms, and the transaction's
structure, among other factors.

S&P determined that the loan has a beginning and ending
loan-to-value ratio of 97.1%, based on its value of the property
backing the transaction.

  RATINGS ASSIGNED

  Austin Fairmont Hotel Trust 2019-FAIR
  Class          Rating             Amount ($)

  A              AAA (sf)           88,065,000
  X-CP           BBB-(sf)           90,440,000(i)
  X-EXT          BBB-(sf)           90,440,000(i)
  B              AA- (sf)           33,155,000
  C              A- (sf)            24,700,000
  D              BBB- (sf)          32,585,000
  E              BB- (sf)           51,395,000
  F              B- (sf)            45,505,000
  G              NR                  9,595,000
  RR interest    NR                 15,000,000

(i)Notional balance. The class X-CP and class X-EXT certificates
will not have certificate balances and will not be entitled to
distributions of principal. The notional amount of the class X-CP
and class X-EXT certificates will be equal to the aggregate
certificate balance of class B, C, and D certificates.
NR--Not rated.


BCC FUNDING 2019-1: Moody's Assigns Ba2 Rating on Class D Notes
---------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to the notes
to be issued by BCC Funding XVI LLC, Series 2019-1. This is Balboa
Capital Corporation's first transaction of the year. The notes will
be backed by a pool of small and mid-ticket equipment loans and
leases primarily originated by BCC, who is also the servicer and
administrator for the transaction.

The complete rating actions are as follows:

Issuer: BCC Funding XVI LLC, Series 2019-1

  $208,425,000, 2.46%, Equipment Contract Backed Notes, Series
  2019-1, Class A-2, Definitive Rating Assigned Aa2 (sf)

  $38,062,000, 2.64%, Equipment Contract Backed Notes, Series
  2019-1, Class B, Definitive Rating Assigned A1 (sf)

  $16,313,000, 2.95%, Equipment Contract Backed Notes, Series
  2019-1, Class C, Definitive Rating Assigned Baa2 (sf)

  $26,100,000, 3.94%, Equipment Contract Backed Notes, Series
  2019-1, Class D, Definitive Rating Assigned Ba2 (sf)

RATINGS RATIONALE

The ratings are based on the quality of the underlying equipment
contract pool and its expected performance, the strength of the
capital structure, and the experience and expertise of BCC as the
servicer.

The definitive rating for the Class D notes, Ba2 (sf), is one notch
higher than its provisional rating, (P)Ba3 (sf). This difference is
a result of the transaction closing with a lower weighted average
cost of funds (WAC) than Moody's modeled when the provisional
ratings were assigned. The WAC assumptions as well as other
structural features, were provided by the issuer.

Moody's median cumulative net loss expectation for the BCC 2019-1
collateral pool is 4.00%, 25 basis points higher than the initial
cumulative net loss expectation of the 2018-1 pool. Moody's based
its cumulative net loss expectation for the BCC 2019-1 pool on the
credit quality of the underlying collateral; the historical
securitization performance and managed portfolio performance of
similar collateral; the ability of BCC to perform the servicing
functions; and its expectations of the macroeconomic environment
during the life of the transaction.

At closing the Class A-2, Class B, Class C, and Class D notes will
benefit from 26.00%, 17.25%, 13.50% and 7.50% of hard credit
enhancement respectively. Hard credit enhancement for the notes
consists of initial overcollateralization of 6.00% and a
non-declining reserve account of 1.50% and subordination, except
for the Class D notes which do not benefit from subordination. The
notes may also benefit from excess spread.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's
Approach to Rating ABS Backed by Equipment Leases and Loans"
published in March 2019.

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

Up

Moody's could upgrade the ratings on the notes if levels of credit
protection are greater than necessary to protect investors against
current expectations of loss. Moody's updated expectations of loss
may be better than its original expectations because of lower
frequency of default by the underlying obligors or lower than
expected deterioration in the value of the equipment that secure
the obligor's promise of payment. As the primary drivers of
performance, positive changes in the US macro economy and the
performance of various sectors where the lessees operate could also
affect the ratings.

Down

Moody's could downgrade the ratings of the notes if levels of
credit protection are insufficient to protect investors against
current expectations of loss. Moody's updated expectations of loss
may be worse than its original expectations because of higher
frequency of default by the underlying obligors of the contracts or
a greater than expected deterioration in the value of the equipment
that secure the obligor's promise of payment. As the primary
drivers of performance, negative changes in the US macro economy
could also affect Moody's ratings. Other reasons for worse
performance than Moody's expectations could include poor servicing,
error on the part of transaction parties, lack of transactional
governance and fraud.


BEAR STEARNS 2007-PWR18: Fitch Lowers Class C Debt Rating to Csf
----------------------------------------------------------------
Fitch Ratings downgraded one and affirmed 14 classes of Bear
Stearns Commercial Mortgage Securities Trust, commercial mortgage
pass-through certificates, series 2007-PWR18.

Bear Stearns Commercial Mortgage Securities Trust 2007-PWR18

                    Current Rating    Prior Rating

Class B 07401DAL5; LT Bsf Affirmed;  previously at Bsf

Class C 07401DAM3; LT Csf Downgrade; previously at CCCsf

Class D 07401DAN1; LT Csf Affirmed;  previously at Csf

Class E 07401DAP6; LT Dsf Affirmed;  previously at Dsf

Class F 07401DAQ4; LT Dsf Affirmed;  previously at Dsf

Class G 07401DAR2; LT Dsf Affirmed;  previously at Dsf

Class H 07401DAS0; LT Dsf Affirmed;  previously at Dsf

Class J 07401DAT8; LT Dsf Affirmed;  previously at Dsf

Class K 07401DAU5; LT Dsf Affirmed;  previously at Dsf

Class L 07401DAV3; LT Dsf Affirmed;  previously at Dsf

Class M 07401DAW1; LT Dsf Affirmed;  previously at Dsf

Class N 07401DAX9; LT Dsf Affirmed;  previously at Dsf

Class O 07401DAY7; LT Dsf Affirmed;  previously at Dsf

Class P 07401DAZ4; LT Dsf Affirmed;  previously at Dsf

Class Q 07401DBA8; LT Dsf Affirmed;  previously at Dsf

KEY RATING DRIVERS

Specially Serviced Loan: The downgrade of class C reflects the
deteriorating performance of last remaining loan in the pool, the
specially serviced Marriott Houston Westchase. The loan is secured
by a 604-key, Marriott-flagged, full-service hotel located in
Houston, TX, approximately 10 miles west of the CBD. Property
performance has been negatively impacted by the economic conditions
in Houston, reliance on the energy/oil sector and new hotel supply
in the market. The loan previously transferred to special servicing
in July 2017 due to imminent maturity default and subsequently
matured in November 2017. In June 2018, the property was purchased
and the loan was modified and assumed by a new borrower, which paid
down 2.5% of the outstanding loan balance at closing and repaid
past-due franchising fees and trade payables. Debt service payments
were also converted to interest-only and the loan maturity was
extended through June 2021. The new borrower is required to pay
down the loan by an additional 2.5% on or by Dec. 31, 2019. The
loan briefly returned to the master servicer in December 2018 but
subsequently transferred to the special servicer again in March
2019 due to the new borrower's request to extend the loan term and
waive the principal paydown requirement. Modification negotiations
are underway.

As of the TTM August 2019 STR report, the property reported
occupancy, ADR and RevPAR of 70%, $119 and $83, respectively,
compared with 69%, $125 and $86 one year earlier. The property also
underwent a $21 million renovation in 2016 that was completed in
January 2017, which included the addition of a Marriott Rewards
Club Lounge, four new guest rooms, new bedding and furnishings,
guest room refrigerators and modernized elevators. The property's
franchise agreement with Marriott Hotels & Resorts expires in
December 2023 and has one 10-year renewal option.

The loan per key relative to the outstanding balance of class B is
low at $38,543; for classes C and D, the loan per key is $80,011
and $111,114, respectively. Fitch has ongoing concerns about the
overall recovery of the Houston market, the continued volatility in
oil prices and anticipated new supply, which may affect future loan
performance. The current hotel construction pipeline in Houston
equates to approximately 16% of the existing supply of available
rooms, which may put additional pressure on RevPAR sustainability.

No Changes to Credit Enhancement: As of the September 2019
distribution date, the pool's aggregate principal balance has been
reduced by 97.2% to $69.9 million from $2.5 billion at issuance.
There has been no pay down since Fitch's last rating action.
Realized losses to date totaled 8.5% of the original pool balance.
Interest shortfalls totaling $10.2 million are currently affecting
classes D through S.

RATING SENSITIVITIES

The Stable Outlook on class B reflects the low debt per key
relative to the outstanding class balance. Upgrades to class B may
be possible with sustained improved performance. Downgrades, though
unlikely, may occur if performance deteriorates significantly.


BELLEMEADE RE 2019-4: Fitch Assigns B+ Rating on Cl. M1C Debt
-------------------------------------------------------------
Fitch Ratings assigned final ratings to Bellemeade Re 2019-4 Ltd.

Bellemeade Re 2019-4 Ltd.

Class A;   LT NRsf New Rating;  previously at NR(EXP)sf

Class B1;  LT NRsf New Rating;  previously at NR(EXP)sf

Class B2;  LT NRsf New Rating;  previously at NR(EXP)sf

Class M1A; LT BB+sf New Rating; previously at BB+(EXP)sf

Class M1B; LT BBsf New Rating;  previously at BB(EXP)sf

Class M1C; LT B+sf New Rating;  previously at B+(EXP)sf

Class M2;  LT NRsf New Rating;  previously at NR(EXP)sf

TRANSACTION SUMMARY

This is the 10th transaction issued through Bellemeade's program,
which transfers the risk related to private mortgage insurance (MI)
in force on a reference mortgage pool and the third transaction
that Fitch will be rating. Investors will be exposed to the risk
that ceding insurers will need to pay on the related MI claims.

The notes will be issued from a Bermuda special-purpose insurer
whose security interest consists of the reinsurance trust account
and reinsurance agreement with the ceding insurers. Funds in the
reinsurance trust account will be subject to prior rights and
interest of the ceding insurers therein and will be used to pay
principal on the notes and make payments to the ceding insurers for
MI claims. The notes will be issued as LIBOR-based floaters and
carry a 10-year legal final maturity. The ceding insurers are
responsible for funding interest payments to the notes through
coverage premium payments.

KEY RATING DRIVERS

High-Quality Loans (Positive): The reference pool consists of
113,180 fully amortizing loans totaling $29.3 billion, of that
96.1% is fixed-rate. The pool has a weighted average (WA) original
credit score of 743 and a WA original combined loan to value ratio
(LTV) of 92.7%.

Newly Originated (Negative): The reference pool consists primarily
of newly originated loans seasoned on average just 6.1 months.
Newly originated MI policies have a higher probability of payout
compared to seasoned policies because the window through which MI
claims can be made is longer. As policies season and move closer to
automatic termination, the probability of claim payouts decreases.

Reliance on Ceding Insurers (Negative): The funding of payments of
interest on the notes through coverage premiums is an obligation of
the ceding insurers, which are wholly owned subsidiaries of Arch
Capital Group Ltd. (Arch). If the coverage premium is not paid, the
ceding insurers will have one month to remedy the missed payment.
If the missed payment remains unremedied, it will trigger a
mandatory termination event, where principal and interest will be
due on the notes. The counterparty risk is mitigated by the premium
deposit account established and fully funded with 70 days of
coverage premium payments at deal close. The premium deposit
account includes an additional 25bps for LIBOR during the two-month
period.

Mortgage Insurance Termination (Positive): The loans are covered
either by borrower-paid MI (BPMI; 97.3%) or lender-paid MI (LPMI;
2.7%). Fitch adjusted the projected MI losses to reflect the
automatic termination provision in BPMI policies as required by the
Homeowners Protection Act (HPA) when the loan balance is first
scheduled to reach 78%. In addition, roughly only 16.6% of the
mortgage loans (by count) have reinsurance that will cede 7.5% of
MI claims that are the ceding insurers' direct obligations. The
reinsurance had a neutral impact and did not affect Fitch's loss
expectation under its 'BB+sf', 'BBsf' or 'Bsf' rating stresses.

No Rescissions Assumed (Negative): While it is unlikely that 100%
of all claims filed will be paid due to factors such as material
origination errors, underwriting defects or claim submission
issues, Fitch assumed no claims would be rescinded or curtailed.
This is a conservative assumption since claim rescissions would
benefit the transaction by resulting in lower MI claim payouts by
the insurer.

10-Year Hard Maturity (Positive): The notes benefit from a 10-year
hard legal maturity, meaning any defaults that occur after year 10
do not affect the transactions. This resulted in a reduction in the
pool's projected probability of default (PD). The projected default
credit ranges from 21% at a 'BB+sf' rating to 23% at a 'B+sf'
rating.

Investment Losses (Negative): Proceeds from the sale of the notes
will be deposited into the reinsurance trust account, which can be
invested in eligible investments. Earnings on the investments can
be used to pay interest on the notes. However, investment losses
will be allocated in reverse-sequential order to the notes.
Mitigating this risk are the tight parameters around eligible
investments that are limited to U.S. government securities or money
market funds rated 'AAAmmf' or the equivalent by another major
rating agency.

Rescissions due to Loan Manufacturing Defects (Positive): The
mortgage loans making up the reference pool are not pledged to
secure the notes, and no representations and warranties regarding
the loans are being provided. Reliance is placed on the ability of
the mortgage insurer to rescind or cancel MI coverage if the MI was
not underwritten according to the MI policy agreement. The ceding
insurers' ability to rescind for fraud committed by the insured or
any party involved in the origination of the loans is viewed
positively by Fitch as the pool will not be exposed to systemic
material loan defects.

Low Operational Risk (Neutral): Fitch believes that operational
risk is well controlled for in this transaction. Arch has an
effective insurance underwriting and risk management process, and
the company's operational oversight of MI loans is closely aligned
with GSE policies. The due diligence review identified generally
good loan quality, and no adjustments to expected losses were made
for due diligence findings.

Solid Alignment of Interests (Positive): While the transaction is
designed to transfer MI risk to private investors, Fitch believes
the transaction benefits from solid alignment of interests. Arch
will initially retain credit risk in the transaction by holding
coverage levels A and B-2. Arch could transfer its holdings on a
future date but will be required to retain 50% of class B-2.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines (MVDs)
than assumed at both the metropolitan statistical area (MSA) and
national levels. The implied rating sensitivities are only an
indication of some of the potential outcomes and do not consider
other risk factors that the transaction may become exposed to or be
considered in the surveillance of the transaction.

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10%, 20% and 30%, in addition to the model
projected sMVD of 5.5%. It indicates there is some potential rating
migration with higher MVDs, compared with the model projection.

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

CRITERIA VARIATION

The transaction was analyzed with two variations to Fitch's 'RMBS
Rating Criteria.' Fitch's typical cash flow analysis was not
conducted for this analysis as it has no impact on the enhancement
levels. The transaction distributes principal sequentially and pays
interest from either the Ceding Insurer or from the Premium Deposit
Account. As a result the cash flow analysis does not result in an
increase to the credit enhancement above Fitch's projected loss and
there was no rating impact.

The second variation was that a compliance review was not performed
on this transaction; these reviews are not applicable for this type
of transaction. Focus was placed more on the MI policies
themselves. A violation by an insured of compliance law may be
cause for rescission depending on the nature and effect of the
violation on the underlying loan. MI covers credit defaults only,
and Arch is generally not responsible for regulatory or legal
compliance matters.


BENCHMARK 2019-B13: Fitch Assigns B-sf Rating on Cl. G-RR Certs
---------------------------------------------------------------
Fitch Ratings assigned the following Ratings and Ratings Outlooks
to BENCHMARK 2019-B13 Mortgage Trust commercial mortgage
pass-through certificates, Series 2019-B13:

  -- $14,591,000 class A-1 'AAAsf'; Outlook Stable;

  -- $104,583,000 class A-2 'AAAsf'; Outlook Stable;

  -- $26,919,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $220,000,000 class A-3 'AAAsf'; Outlook Stable;

  -- $277,705,000 class A-4 'AAAsf'; Outlook Stable;

  -- $719,675,000a class X-A 'AAAsf'; Outlook Stable;

  -- $75,877,000 class A-M 'AAAsf'; Outlook Stable;

  -- $39,087,000 class B 'AA-sf'; Outlook Stable;

  -- $43,687,000 class C 'A-sf'; Outlook Stable;

  -- $82,774,000ab class X-B 'A-sf'; Outlook Stable;

  -- $48,285,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $22,992,000ab class X-F 'BB-sf'; Outlook Stable;

  -- $26,441,000b class D 'BBBsf'; Outlook Stable;

  -- $21,844,000b class E 'BBB-sf'; Outlook Stable;

  -- $22,992,000b class F 'BB-sf'; Outlook Stable;

  -- $9,198,000b class G-RR 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $36,788,563b class H-RR;

  -- $32,000,000bc 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 3.362% of the certificate balance, notional amount or
percentage interest of each class of certificates.

Since Fitch published its expected ratings on Sept. 16, 2019, the
balances for class A-3 and A-4 were finalized. When expected
ratings were assigned, the class A-3 and class A-4 balances were
estimated within the ranges of $100,000,000 to $248,000,000 and the
range of $249,705,000 to $397,705,000, respectively. The final
class sizes for class A-3 and class A-4 are $220,000,000 and
$277,705,000, respectively.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 40 loans secured by 48
commercial properties having an aggregate principal balance of
$951,712,563 as of the cut-off date. The loans were contributed to
the trust by JPMorgan Chase Bank, National Association, Citi Real
Estate Funding Inc., and German American Capital Corporation.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 79.5% of the properties
by balance, cash flow analysis of 82.3% of the pool, and asset
summary reviews on 100% of the pool.

KEY RATING DRIVERS

High Fitch Leverage: The pool's Fitch LTV is 106.8%, which is above
the 2018 and 2019 YTD average of 102.0% and 101.4% for other
Fitch-rated multiborrower transactions. Additionally, the pool's
Fitch DSCR of 1.17x is lower than the 2018 and 2019 YTD averages of
1.22x and 1.23x, respectively.

Investment-Grade Credit Opinion Loans: Five loans, representing
21.8% of the pool, received an investment-grade credit opinion on a
stand-alone basis. This is above the 2018 and 2019 YTD averages of
13.6% and 14.5%, respectively. Net of these loans, the Fitch LTV
and DSCR are 116.8% and 1.15x, respectively, for this transaction.
Loans with investment-grade credit opinions include Shoppes at
Grand Canal (5.3%), Osborn Triangle (5.3%), 30 Hudson Yards (4.2%),
3 Columbus Circle (3.9%), and Woodlands Mall (3.2%). Each of these
loans received an investment-grade credit opinion of 'BBB-sf*',
with the exception of 30 Hudson Yards, which received an
investment-grade credit opinion of 'A-sf*' on a stand-alone basis.

Pool Concentration: The top 10 loans in the pool comprise 51.3% of
the pool, reflecting concentration in line with the 2018 and 2019
YTD averages of 50.6% and 51.7%, respectively. Additionally, the
pool's LCI of 382 is also in line with the 2018 and 2019 YTD
averages of 373 and 387, respectively. The pool's SCI of 419 is
also above the 2018 average of 398 and 2019 YTD average of 406.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 11.4% 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
BMARK 2019-B13 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.


CF 2019-CF2: Fitch Assigns B-sf Ratings on 2 Tranches
-----------------------------------------------------
Fitch Ratings assigned ratings and Rating Outlooks to CF 2019-CF2
Mortgage Trust commercial mortgage pass-through certificates,
series 2019-CF2.

  -- $20,649,000 class A-1 'AAAsf'; Outlook Stable;

  -- $40,987,000 class A-2 'AAAsf'; Outlook Stable;

  -- $28,718,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $39,556,500 class A-3 'AAAsf'; Outlook Stable;

  -- $214,000,000 class A-4 'AAAsf'; Outlook Stable;

  -- $218,123,500 class A-5 'AAAsf'; Outlook Stable;

  -- $67,243,000 class A-S 'AAAsf'; Outlook Stable;

  -- $562,034,000a class X-A 'AAAsf'; Outlook Stable;

  -- $36,131,000 class B 'AA-sf'; Outlook Stable;

  -- $37,134,000 class C 'A-sf'; Outlook Stable;

  -- $140,508,000a class X-B 'A-sf'; Outlook Stable;

  -- $24,087,000b class D 'BBBsf'; Outlook Stable;

  -- $18,066,000b class E 'BBB-sf'; Outlook Stable;

  -- $42,153,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $19,069,000b class F 'BB-sf'; Outlook Stable;

  -- $19,069,000ab class X-F 'BB-sf'; Outlook Stable;

  -- $8,029,000b class G 'B-sf'; Outlook Stable;

  -- $8,029,000ab class X-G 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $31,113,052bc class NR-RR.

  -- The transaction includes seven classes of non-offered,
loan-specific certificates (non-pooled rake classes) related to the
companion loan of The Stanwix. Classes SWA, SWC, SWD, SWE, SWRR,
SWX1, and SWX2 are all not rated by Fitch.

(a) Notional amount and interest only.

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

(c) Horizontal credit-risk retention interest.

TRANSACTION SUMMARY

Since Fitch published its expected ratings on Sept. 19, 2019, the
following changes have occurred: The balances for class A-4 and A-5
were finalized. At the time the classes were assigned, the class
A-4 balance range was $100,000,000 - $214,000,000 and the class A-5
range was $218,123,500 to $332,123,500. The final class sizes for
class A-4 and A-5 are $214,000,000 and $218,123,500, respectively.
Additionally, class SWB is no longer part of the final deal
structure. The classes reflect the final ratings and deal
structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 48 loans secured by 136
commercial properties having an aggregate principal balance of
$802,906,053 as of the cut-off date. The loans were contributed to
the trust by Cantor Commercial Real Estate Lending, L.P., KeyBank
National Association, Starwood Mortgage Capital LLC, and German
American Capital Corporation.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 61.9% of the properties
by balance, cash flow analysis of 80.6% of the pool, and asset
summary reviews on 100% of the pool.

KEY RATING DRIVERS

High Fitch Leverage: The pool's Fitch loan-to-value (LTV) is
106.5%, which is above the 2018 and 2019 YTD averages of 102.0% and
105.0% for other Fitch-rated multiborrower transactions. The pool's
Fitch debt service coverage ratio (DSCR) of 1.22x is in line with
the 2018 and 2019 YTD averages of 1.22x and 1.20x, respectively,
however, the pool's average coupon was just 4.00%.

Investment-Grade Credit Opinion Loans: Five loans totaling 15.4% of
the pool have stand-alone investment-grade credit opinions. Net of
these loans, the conduit Fitch LTV and DSCR are 113.5% and 1.20x,
respectively, for this transaction. Loans with investment-grade
credit opinions include The Stanwix (4.1% of the pool), Southbridge
Park, (3.6%), Grand Canal Shoppes (3.1%), Woodlands Mall (2.7%) and
The Centre (1.9%). Each of these loans received an investment-grade
credit opinion of 'BBB-sf*', with the exception of Southbridge
Park, which received an investment-grade credit opinion of 'A-sf*'
on a stand-alone basis.

Above-Average Pool Diversification: The pool is more diverse than
recent Fitch-rated transactions. The largest 10 loans comprise
46.8% of the pool, which is lower than the average top 10
concentrations for 2018 and 2019 YTD of 52.0% and 52.2%,
respectively. The pool's concentration results in an LCI of 336,
which is lower than the 2018 and 2019 YTD averages of 373 and 397,
respectively. Additionally, the pool's SCI of 366 is lower than the
2018 average of 398 and 2019 YTD average of 450.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 11.8% below
the most recent year's NOI for properties for which a full-year NOI
was provided, excluding properties that were stabilizing during
this period. Unanticipated further declines in property-level NCF
could result in higher defaults and loss severities on defaulted
loans and in potential rating actions on the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the CF
2019-CF2 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 'Asf' could result. In a more
severe scenario, in which NCF declined a further 30% from Fitch's
NCF, a downgrade of the junior 'AAAsf' certificates to 'BBBsf'
could result.


CHASE MORTGAGE 2019-CL1: Fitch Rates $3.408MM Cl. M-4 Notes 'BBsf'
------------------------------------------------------------------
Fitch Ratings assigned the following ratings and Outlooks to Chase
Mortgage Reference Notes 2019-CL1 (Chase 2019-CL1):

  -- $35,969,000 class M-1 notes 'AAsf'; Outlook Stable;

  -- $10,222,000 class M-2 notes 'Asf'; Outlook Stable;

  -- $6,815,000 class M-3 notes 'BBBsf'; Outlook Stable;

  -- $3,408,000 class M-4 notes 'BBsf'; Outlook Stable;  

  -- $1,136,000 class M-5 notes 'BB-sf'; Outlook Stable.

Fitch will not be rating the following classes:

  -- $696,646,441 class A-R1 certificates;

  -- $3,029,000 class B notes.

TRANSACTION SUMMARY

Fitch rates the class M notes for JPMorgan Chase Bank, N.A.'s first
credit-linked note transaction, Chase Mortgage Reference Notes
2019-CL1, as indicated above. The notes are general unsecured debt
obligations of JPMCB (AA/F1+/Stable), and therefore the ratings are
directly linked to those of JPMCB.

The objective of the transaction is to transfer credit risk to
noteholders via the incorporation of tranched credit default swap
documentation. Principal payments on the notes are based on the
actual payments received and performance of a reference pool
consisting of 979 prime-quality residential mortgage loans with a
total balance of $757.23 million as of the cut-off date.

The loans were originated to JPMCB's guidelines, which satisfy the
Ability to Repay Rule but were not tested for qualified mortgage
status in the due diligence process. All loans in the reference
pool are serviced by JPMCB and are expected to remain in the
portfolio.

The notes are uncapped LIBOR floaters, and JPMCB will be solely
responsible for the payment of principal and interest to class M
and B noteholders. Given the structure and dependence on JPMCB,
Fitch's ratings on class M notes are capped at the lower of 1) the
quality of the mortgage loan reference pool and credit enhancement
(CE) available through subordination, and 2) Fitch's Issuer Default
Rating (IDR) of JPMCB.

Transaction documents provide mechanisms to replace LIBOR with an
alternative rate when a benchmark transition event occurs. The
issuer will solely determine an alternative rate in accordance with
the transaction documents. These mechanisms incorporate significant
elements of the ARRC recommendations regarding more robust fallback
language for new issuances of LIBOR securitizations published by
the Alternative Reference Rate Committee on May 31, 2019. LIBOR
replacement is applicable to the interest payments on the M and B
notes as their coupon rates are currently based on one-month LIBOR
plus a spread. The reference obligations are not affected by LIBOR
replacement since they are all fixed-rate loans.

KEY RATING DRIVERS

Very High Credit Quality (Positive): The referenced collateral
consists of 30-year, fixed-rate, fully amortizing loans, seasoned
approximately 48 months based on Fitch's calculation. All the loans
were originated through JPMCB's retail channel or correspondent's
retail channel. The borrowers in this pool have strong credit
profiles (Fitch model FICO score of 773) and low leverage -- 70%
combined loan to value ratio (CLTV).

Non-Qualified Mortgage (Negative): All the loans in this
transaction were underwritten to JPMCB's guidelines but may or may
not qualify for QM status. (QM status was not tested for in the due
diligence review.) None of the loans in the pool were underwritten
with an underwriting exception. As QM status was not tested for,
all loans were assumed to be non-QM in Fitch's analysis, and the
'AAsf' expected loss was increased by 14bps.

Counterparty Risk (Negative): Ratings on the notes are directly
linked to the Issuer Default Rating (IDR) of the counterparty,
JPMCB (AA/F1+/Stable). There is no transfer or sale of assets, and
the referenced collateral will remain on balance sheet as
unencumbered assets of the bank. Interest and principal payments on
the notes are unsecured debt obligations of JPMCB.

Prior to the monthly payment date, funds awaiting distribution and
deposited by JPMCB will be held at Wells Fargo Bank, N.A. (AA?/F1+)
in a segregated trust account for the benefit of the notes. Funds
in this account can be invested in eligible investments that are
consistent with Fitch's criteria and mature prior to the payment
date of the notes. Funds in the distribution account are held for
two business days.

Minimal Operational Risk (Positive): JPMCB has a long operating
history of originating and securitizing residential mortgage loans,
and is assessed as 'Above Average' by Fitch. JPMCB is also the
servicer of this transaction and is rated 'RPS1?' by Fitch. Fitch
reduces its loss expectations for highly rated originators and
servicers (rated 1- or higher) due to their strong practices and
higher expected recoveries. Fitch reduced its 'AAsf' loss
expectations by 43bps, to account for the low operational risk
associated with this pool.

Third-Party Due Diligence (Positive): Third-party due diligence was
performed by a Fitch-assessed 'Acceptable-Tier 1' third-party
review (TPR) firm on a representative sample of 547 loans, 163 of
which are included in the reference pool (17% of the loans in the
reference pool had a due diligence review). The review confirmed
sound operational quality with no incidence of material defects.
The loans are seasoned approximately 48 months based on Fitch's
analysis, and all have clean pay histories for the past 24 months.
The due diligence results are in line with industry averages, and
99% were graded 'A' or 'B'.

Property Value Variances (Negative): While the TPR firm reviewed
the original appraisal quality and found no material differences,
updated property valuations were obtained for 100% of the pool due
to the reference pool's seasoning. Of the updated valuations
obtained, 24% comprised broker price opinions (BPOs) and the
remainder received a value determined by the Clear Capital
Automated Valuation Model-Fully Supported (AVM) product value.
Compared to the original value, the BPO values showed a 7% average
negative variance, and the AVM values showed a 3% average positive
variance. As a result, Fitch applied a 7% haircut to the original
values for the loans without a BPO. The BPO values were used for
loans with a BPO.

Eligibility Criteria Framework (Positive): JPMCB has outlined
loan-level eligibility criteria with respect to the reference pool.
Fitch views the construct as a Tier 2 due to inclusion of knowledge
qualifiers without a clawback provision and the narrow testing
construct, which limits the reviewer's ability to identify or
respond to issues not fully anticipated at closing. The framework,
together with the financial strength of JPMCB as Eligibility
Criteria provider, resulted in no adjustment to Fitch's expected
loss.

Loans identified by the reviewer as having a material test failure
with respect to the eligibility criteria, and that the reviewer
determined to not be an eligible loan, and such determination by
the reviewer is not subject to arbitration, is not eligible to be
subject to an arbitration, and has not been overturned in an
arbitration will be deemed an "ineligible reference obligation" and
will be removed from the pool at par. Arbitration expenses will be
paid out of interest payable on the notes if JPMCB prevails in
arbitration proceedings; otherwise, JPMCB will be responsible for
all expenses.

Pro-Rata Pay Structure (Negative): The mortgage cash flows are
allocated based on a pro-rata pay structure. Scheduled and
unscheduled principal is allocated pro rata based on the respective
senior (class A-R1) and subordinate (classes M and B) percentages.
Distributions to the subordinated M and B classes are subject to
certain performance and CE tests; if the tests are not satisfied,
the senior class A-R1 certificate is allocated 100% of all
principal.

In addition, lower rated subordinated classes will be locked out of
principal entirely if the current CE for such a class is less than
the sum of the original CE plus 25% of the balance of loans that
are deemed nonperforming (i.e. 90+ days past due, in foreclosure or
bankruptcy, or real estate owned). The lockout feature helps
maintain subordination for a longer period should losses occur
later in the life of the deal. This feature redirects subordinate
principal to classes of higher seniority if specified CE levels are
not maintained. Losses are allocated reverse sequentially with the
unrated B class absorbing losses first.

CE Floor (Positive): To mitigate tail risk, which arises as the
pool seasons and fewer loans are outstanding, a subordinate CE
floor of $3,029,000 will be maintained for the subordinate notes.
There will not be a senior CE floor for this transaction. Not
having a senior CE floor benefits the M notes by allowing them to
receive principal sooner than if a senior CE floor was in place.

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.
Fitch conducted three sets of sensitivity analyses 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 3.6%.

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'.


CIM TRUST 2019-R2: Moody's Assigns B3 Rating on Class B2 Notes
--------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to eight
classes of notes issued by CIM Trust 2019-R2, which are backed by
one pool of primarily re-performing residential mortgage loans. As
of the cut-off date of August 31, 2019, the collateral pool is
comprised of 3,406 first lien mortgage loans, with a weighted
average updated primary borrower FICO score of 644, a WA current
loan-to-value Ratio for the first liens of 87.4% and a total unpaid
balance of $464,327,419. Approximately 10.6% of the pool balance is
non-interest bearing, which consists of both principal reduction
alternative (PRA) and non-PRA deferred principal balance.

Rushmore Loan Management Services 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: CIM Trust 2019-R2

Cl. A1, Definitive Rating Assigned Aaa (sf)

Cl. A1-A, Definitive Rating Assigned Aaa (sf)

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

Cl. B1, Definitive Rating Assigned Ba3 (sf)

Cl. B2, Definitive Rating Assigned B3 (sf)

Cl. M1, Definitive Rating Assigned Aa2 (sf)

Cl. M2, Definitive Rating Assigned A3 (sf)

Cl. M3, Definitive Rating Assigned Baa3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected losses on CIM 2019-R2's collateral pool is 14.00%
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 Securitizations Backed by Non-Performing and Re-Performing
Loans" published in February 2019, and "US RMBS Surveillance
Methodology" published in February 2019.

Collateral Description

CIM 2019-R2's collateral pool is primarily comprised of
re-performing mortgage loans. About 87.0% 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 43.0% 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 projects future annual delinquencies
for eight years by applying an initial annual default rate and
delinquency burnout factors. Based on the loan characteristics of
the pool and the demonstrated pay histories, Moody's expects an
annual delinquency rate of 11.5% on the collateral pool for year
one. 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 CIM 2019-R2'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) loans that have the risk of
coupon step-ups and (2) 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.

As of the statistical cut-off date, approximately 10.6% 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 $673,351 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, four
loss timing curves, and four 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 two 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 prepare a schedule based upon the custodian's
exception report. The seller will have 90 days to cure any
exceptions related to missing mortgages or lost note affidavit. If
the seller is unable to cure, then it will repurchase such loans
within 90 days. Similarly, if the seller is unable to cure any
exceptions related to missing intervening assignments of mortgage
and/ or missing intervening endorsements of the note within a year
from closing date, then the seller will be obligated to repurchase
such loans. The absence of an intervening assignment of mortgage,
original note or endorsement can delay or prevent the servicer from
foreclosing on the property or could reduce the value of the loan.
Similarly other document exceptions can increase the severity upon
liquidation.

The diligence provider conducted a review of the title policies,
mortgages and lien searches (within twelve months of the cut-off
date) on loans with an unpaid principal balance of over $5,000 in
the initial pool to confirm the first lien position of the
mortgages and to identify other amounts owed on the mortgage. Based
on the results title and tax review, Moody's adjusted its expected
loss for loans where title search was not performed or loans which
were flagged having serious title defects and not indemnified by
title insurance. Moody's did not increase losses for any
outstanding lien because the remedy provider will extinguish the
liens within 150 days of closing date. If the liens are not
extinguished, then remedy provider will be obligated to repurchase
the loans.

The review also consisted of validating 29 data fields for each
loan in the pool which resulted in 2,831 loans having one or more
data variances. It was determined that such data variances were
attributable to missing or defective source documentation,
non-material variances within acceptable tolerances, allocation
between documented and undocumented deferred principal balances,
timing and data formatting differences. Moody's did not make any
adjustments for these findings.

Representations & Warranties (R&W)

The R&W provider is Chimera Funding TRS LLC, wholly-owned
subsidiary of Chimera Investment Corporation (NYSE: CIM) and is not
an investment grade rated entity. 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 loan becomes 120 days delinquent (MBA
method) or (2) loan has been liquidated and upon such liquidation
has incurred a realized loss.

There are a few weaknesses in the enforcement mechanisms. First,
the independent reviewer is not identified at closing and, if the
owner trustee (on behalf of controlling holder) 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).

Overall, Moody's considers the R&W framework to be relatively
stronger compared to recent RPL securitizations rated by us because
every seriously delinquent loan is automatically reviewed, there is
a well-defined process in place to identify loans with defects on
an ongoing basis and the R&Ws do not sunset.

Trustee Indemnification

Moody's believes there is a very low likelihood that the rated
notes in CIM 2019-R2 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

Rushmore will servicer 100% of the loans in the pool. In the event
of a termination of the Servicer under the Servicing Agreement, a
successor servicer that is reasonably acceptable to the Class C
holder will be appointed by the Depositor on behalf of the Issuer.
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. Moody's considers the overall servicing
arrangement to be credit neutral.

Other Considerations

The servicer will not commence foreclosure proceedings on a
mortgage loan unless the servicer has notified the Class C holder
(which, as of the closing date, will be the sponsor or one of its
affiliate) at least five (5) business days in advance of the
foreclosure and the Class C holder has not objected to such action.
If the Class C holder objects, the servicer has to obtain three
appraisals from the appraisal firms as listed in the pooling and
servicing agreement. The cost of the appraisals are borne by the
Class C holder. The Class C holder will be required to purchase
such mortgage loan at a price equal to the highest of the three
appraisals plus accrued and unpaid interest on such mortgage loan
as of the purchase date. If the servicer cannot obtain three
appraisals there are alternate methods for determining the purchase
price. If the Class C holder fails to purchase the mortgage loan
within the time frame, the Class C holder forfeits any foreclosure
rights thereafter. Moody's considers this credit neutral because a)
the appraiser is chosen by the servicer from the approved list of
appraisers, b) the fair value of the property is decided by the
servicer, based on third party appraisals, and c) the Class C
holder will pay the fair price and accrued interest.

Transaction Parties

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

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

Factors that would lead to an upgrade of the ratings

Levels of credit protection that are higher than necessary to
protect investors against current expectations of loss could drive
the ratings up. Losses could decline from its original expectations
as a result of a lower number of obligor defaults or appreciation
in the value of the mortgaged property securing an obligor's
promise of payment. Transaction performance also depends greatly on
the US macro economy and housing market. Other reasons for
better-than-expected performance include changes to servicing
practices that enhance collections or refinancing opportunities
that result in prepayments.

Factors that would lead to a downgrade of the ratings

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


CITIGROUP COMMERCIAL 2016-C3: Fitch Affirms Class F Certs at B-sf
-----------------------------------------------------------------
Fitch Ratings has affirmed 16 classes of Citigroup Commercial
Mortgage Trust, commercial mortgage pass-through certificates,
series 2016-C3.

CGCMT 2016-C3

                        Current Rating      Prior Rating

Class A-1 17325GAA4;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 17325GAB2;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 17325GAC0;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 17325GAD8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-AB 17325GAE6; LT AAAsf Affirmed;  previously at AAAsf

Class A-S 17325GAF3;  LT AAAsf Affirmed;  previously at AAAsf

Class B 17325GAG1;    LT AA-sf Affirmed;  previously at AA-sf

Class C 17325GAH9;    LT A-sf Affirmed;   previously at A-sf

Class D 17325GAL0;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 17325GAN6;    LT BB-sf Affirmed;  previously at BB-sf

Class F 17325GAQ9;    LT B-sf Affirmed;   previously at B-sf

Class X-A 17325GAJ5;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 17325GAK2;  LT AA-sf Affirmed;  previously at AA-sf

Class X-D 17325GAU0;  LT BBB-sf Affirmed; previously at BBB-sf

Class X-E 17325GAW6;  LT BB-sf Affirmed;  previously at BB-sf

Class X-F 17325GAY2;  LT B-sf Affirmed;   previously at B-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The affirmations reflect
the overall stable performance and loss expectations with no
material changes to pool metrics since issuance. There are no
delinquent loans and no loans have transferred to special
servicing. Fitch designated two loans (7.8% of pool), including one
(7.6%) in the top 15, as a Fitch Loans of Concern (FLOCs) due to
occupancy declines/concerns.

Minimal Change to Credit Enhancement: There has been minimal change
to credit enhancement since issuance. As of the September 2019
distribution date, the pool's aggregate balance has been reduced by
2.1% to $740.4 million from $756.5 million at issuance. All
original 44 loans remain in the pool. Eleven loans (42% of pool)
are full-term, interest-only, and seven loans (16.6%) have a
partial-term, interest-only component of which three have begun to
amortize.

ADDITIONAL CONSIDERATIONS

Fitch Loan of Concern: The largest FLOC, 101 Hudson Street (7.6% of
pool), which is secured by a 1.3 million sf office property located
in downtown Jersey City, NJ, was designated a FLOC due to
significant occupancy declines since issuance. The property was 64%
occupied as of March 2019, down from 85.1% (although 98.3% leased)
in September 2016 around the time of issuance. Fitch's analysis at
issuance accounted for two tenants with partial dark space at the
property, including the second largest tenant, National Union Fire
Insurance (previously 20% NRA), which subsequently vacated at its
April 2018 lease expiration. Per servicer updates, the borrower is
actively marketing the vacant space. At YE 2018, servicer-reported
NOI debt service coverage ratio (DSCR) was 3.48x.

Regional Mall Exposure: Loans secured by retail properties comprise
23.1% of the pool, including two regional malls (13.5%) in the top
10. The largest loan, Briarwood Mall (8.8%), is secured by
approximately 370,000 sf of a one million sf regional mall located
in Ann Arbor, MI, approximately 2.5 miles from the University of
Michigan. A non-collateral Sears closed at the end of 2018, and the
space remains vacant. Per servicer updates, the borrower is
formulating a plan and there is strong interest in the space, which
is owned by a Seritage/Simon Property Group joint venture. In-line
sales at YE 2018 were $568 psf ($376 psf excluding Apple) compared
with $583 psf ($437 psf excluding Apple) at issuance. As of March
2019, collateral occupancy was 89%, and as of YE 2018,
servicer-reported NOI DSCR was 3.33x.

Potomac Mills (4.7% of pool) is secured by approximately 1.46
million sf of a 1.84 million sf regional outlet mall in Woodbridge,
VA along the I-95 corridor between Washington D.C. and Richmond,
VA. IKEA and Burlington Coat Factory are non-collateral anchors and
larger collateral anchors include Costco Warehouse, JCPenney and an
18-screen AMC movie theatre. In-line sales as of the TTM ended
August 2019 were $414 psf compared with $448 at issuance. At YE
2018, collateral occupancy was 97%, and servicer-reported NOI DSCR
was 4.44x. At issuance, this loan received an investment-grade
credit opinion of 'BBBsf' on a stand-alone basis.

Pool/Maturity Concentration: The top 10 loans comprise 57% of the
pool. Based on the loans' scheduled maturity balances, the pool is
expected to amortize 9.7% during the term. Loan maturities are
concentrated in 2026 (88.9%). Four loans (10.2%) mature in 2021,
and one (0.9%) matures in 2025.

RATING SENSITIVITIES

Rating Outlooks for all classes remain Stable due to relatively
stable performance with no material changes to pool metrics since
issuance. 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.


CLNC LTD 2019-FL1: DBRS Assigns Prov. B(low) Rating on G Notes
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Notes to be issued by CLNC 2019-FL1, Ltd. (the Issuer):

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

All trends are Stable. Classes A, A-S, B, C and D represent the
offered certificates. Classes E, F, G and the Preferred Shares are
non-offered certificates and will be retained by the Issuer.
Classes F-E and G-E represent the principal and interest MASCOT
notes that will be exchangeable with the Class F and Class G notes,
respectively. The combined interest rate on the notes will be equal
to the original note interest rate, with the interest rates of the
MASCOT notes determined by the holder of the original notes being
exchanged.

The initial collateral consists of 21 floating-rate mortgages
secured by 39 mostly transitional properties with a cut-off balance
totaling $1.01 billion, excluding approximately $124.9 million of
future funding commitments attributed to 16 loans. Most loans are
in a period of transition with plans to stabilize and improve the
asset value. During the 24-month Reinvestment Period, the Issuer
may acquire future funding commitments and additional eligible
loans subject to the Eligibility Criteria. The transaction
stipulates a $5.0 million threshold on pari passu participation
acquisitions before a Rating Agency Condition is required if there
is already a participation of the underlying loan in the trust.

For the floating-rate loans, DBRS Morningstar used the one-month
LIBOR index, which is based on the lower of a DBRS Morningstar
stressed rate that corresponded with the remaining fully extended
term of the loans or the strike price of the interest-rate cap with
the respective contractual loan spread added to determine a
stressed interest rate over the loan term. When the cut-off
balances were measured against the DBRS Morningstar As-Is NCF, 19
loans, comprising 81.2% of the initial pool, had a DBRS Morningstar
As-Is Debt-Service Coverage Ratio (DSCR) below 1.00 times (x), a
threshold indicative of default risk. Additionally, the DBRS
Morningstar Stabilized DSCR for five loans, comprising 28.4% of the
initial pool balance, is below 1.00x, which is indicative of
elevated refinance risk. The properties are often transitioning
with a potential upside in cash flow; however, DBRS Morningstar
does not give full credit to the stabilization if there are no
holdbacks or if other loan structural features in place are
insufficient to support such treatment. Furthermore, even with the
structure provided, DBRS Morningstar generally does not assume the
assets to stabilize above market levels.

The loans are generally secured by traditional property types
(i.e., retail, multifamily, office and industrial), though there
are two loans, representing 19.9% of the pool that are secured by
hotels. Additionally, only one of the multifamily loans (Aspen
Heights Trio; representing 2.5% of the initial pool balance) in the
pool is currently secured by a student-housing property, which
often exhibit higher cash flow volatility than traditional
multifamily properties.

Nine loans in the pool, totaling 56.0% of the DBRS Morningstar
sample by cut-off date pool balance, are backed by a property with
a quality deemed to be Above Average or Average (+) by DBRS
Morningstar. Fifteen loans, representing 60.6% of the pool,
represent acquisition financing wherein sponsors contributed
material cash equity as a source of funding in conjunction with the
mortgage loan, resulting in a moderately high sponsor cost basis in
the underlying collateral.

The Weighted-Average (WA) DBRS Morningstar As-Is Loan-to-Value
(LTV), which includes all future funding in the calculation, is
moderately high at 76.1%, reflecting the highly transitional nature
of the pool with substantial future funding as well as the
generally high leverage. The high LTV results in a WA DBRS
Morningstar Expected Loss of 4.8% for the pool, which translates to
credit-enhancement levels at each rating category that are
generally in line with other commercial real estate (CRE)
collateralized loan obligations (CLOs).

The pool is heavily concentrated geographically. Seven loans,
representing 52.5% of the pool, are located in California. Further,
of those loans located in California, there is a high concentration
in northern California, with six loans representing 46.5% of the
pool. The particular MSAs represented in this concentration are
considered to be strong markets with good liquidity.

All 21 loans have floating interest rates and all loans are
interest only during the original term with original terms ranging
from 12 months to 36 months, creating interest-rate risk. All loans
are short-term loans and, even with extension options, they have a
fully extended maximum loan term of five years.

Additionally, for the floating-rate loans, DBRS Morningstar used
the one-month LIBOR index, which is based on the lower of a DBRS
Morningstar Stressed Rate that corresponded with the remaining
fully extended term of the loans or the strike price of the
interest-rate cap with the respective contractual loan spread added
to determine a stressed interest rate over the loan term.
Additionally, all have extension options and, in order to qualify
for these options, the loans must meet minimum leverage
requirements.

The participations conveyed to the Issuer will not include record
title to the underlying mortgage in the name of the Issuer, but
instead will include help from the Seller. This is contrary to
standard CRE CLO structures, where the issuer or institutional
custodian generally holds title to the participation loans. In the
case of a bankruptcy, the Issuer has a lesser claim to the loan
since it does not own the title. As a result, the Issuer's ability
to recover under such participation is subject to the credit risk
of the entity that holds legal title to the underlying collateral.
Payments to the Issuer will be affected if the legal title holder
of the participated assets files bankruptcy or is declared
insolvent. Added language will be provided in the seller's
organization documents to limit the seller to only acquiring
mortgage loans and participations therein and not engaging in any
other business through the entity. Additionally, there will be
language on limitations on indebtedness to only that debt arising
in connection with the loan participations.

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

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


COMM 2014-CCRE16: Fitch Lowers Rating on Class F Debt to CCC
------------------------------------------------------------
Fitch Ratings downgraded three classes and affirmed 10 classes of
Deutsche Bank Securities, Inc.'s COMM 2014-CCRE16 Mortgage Trust
commercial mortgage pass-through certificates. The Rating Outlook
for two classes has been revised to Negative from Stable.

COMM 2014-CCRE16 Mortgage Trust

                        Current Rating      Prior Rating

Class A-3 12591VAD3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 12591VAE1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-M 12591VAG6;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 12591VAC5; LT AAAsf Affirmed;  previously at AAAsf

Class B 12591VAH4;    LT AA-sf Affirmed;  previously at AA-sf

Class C 12591VAK7;    LT A-sf Affirmed;   previously at A-sf

Class D 12591VAQ4;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 12591VAS0;    LT Bsf Downgrade;   previously at BBsf

Class F 12591VAU5;    LT CCCsf Downgrade; previously at Bsf

Class PEZ 12591VAJ0;  LT A-sf Affirmed;   previously at A-sf

Class X-A 12591VAF8;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 12591VAL5;  LT AA-sf Affirmed;  previously at AA-sf

Class X-C 12591VAN1;  LT Bsf Downgrade;   previously at BBsf

KEY RATING DRIVERS

Increased Loss Expectations: Fitch's projected base case losses for
the pool have increased since the last rating action, primarily due
to transfer of the fifth largest loan in the pool, West Ridge Mall
and Plaza (5.7%) to special servicing. Fitch considered the default
and transfer of this loan at the time of the last rating action in
a sensitivity scenario. The property's appraised value has been cut
significantly, and the lender is pursuing foreclosure. Given the
lack of liquidity available for struggling malls in tertiary
markets, Fitch believes losses associated with this loan could be
significant. The projected base case loss represents a conservative
stress to the most recent appraised value, to reflect the
possibility that the asset could languish in special servicing.

In addition to the recent transfer, two other loans that were Fitch
Loans of Concern (FLOCs) at the last rating action are still being
flagged. They include one loan (2.4% of the pool) backed by an
office property in Tempe, AZ. Occupancy declined significantly
after the largest tenant vacated at lease expiration. Submarket
vacancy suggests that there may be challenges backfilling the
space. The smallest FLOC (0.7% of the pool) has been in special
servicing since November 2014. The collateral is a portfolio of
three limited-service hotels in Indiana, and the loan was
originally transferred for a technical default. According to the
servicer, litigation proceedings are delaying the resolution
process.

Alternative Loss Consideration; West Ridge Mall & Plaza: The
largest FLOC is West Ridge Mall and Plaza. The loan transferred to
special servicing in November 2018 for imminent default and a
receiver was appointed in May 2019. The collateral includes
approximately 392,000 sf of inline space within the 1.0 million sf
enclosed West Ridge Mall and an adjacent anchored retail center,
both of which are located in Topeka, Kansas. In the last two years,
the mall has lost two anchor tenants, and inline occupancy has
declined to 53.9%. Between the mall and retail center, leases
representing 17.1% of the NRA are scheduled to roll in 2020. In
addition to occupancy declines, the asset's sales have also
declined since issuance. Based on a September 2018 sales report,
the mall's estimated inline sales were $234 psf, which is down from
$298 psf at issuance. An updated sales report was requested but not
received.

As part of its analysis, Fitch ran an additional sensitivity test
that assumed a 100% loss on the loan based on the assets' declines
in occupancy and sales, its market location and additional upcoming
tenant roll. This sensitivity serves as the basis for the Negative
Outlooks.

Changes to Credit Enhancement: Since the last rating action, 12
loans have repaid from the pool contributing $139.5 million in
principal paydown. The increased credit enhancement helps to offset
some concerns regarding the pool's increased loss expectations, but
future scheduled payoffs are limited until 2024. The pool has
experienced 19.3% collateral reduction since issuance.

RATING SENSITIVITIES

The downgrades follow an increase to Fitch's projected losses,
driven by the fifth largest loan in the pool, West Ridge Mall and
Plaza. Fitch believes the property value will continue to
deteriorate as the asset is not expected to stabilize and dispose
in the near term. The Rating Outlooks remain Negative for lasses D,
E and X-C, and the Outlooks for classes C and PEZ have been revised
to Negative from Stable based on the additional sensitivity
scenario for this loan. Further downgrades are possible should the
West Ridge Mall and Plaza loan languish in special servicing or if
other loans default. Upgrades, while not considered likely, are
possible with additional unscheduled paydown or defeasance.


CPS AUTO 2019-D: S&P Assigns B (sf) Rating to Class F Notes
-----------------------------------------------------------
S&P Global Ratings assigned its ratings to CPS Auto Receivables
Trust 2019-D's asset-backed notes.

The note issuance is an ABS transaction backed by subprime auto
loan receivables.

The ratings reflect:

-- The availability of approximately 59.02%, 50.38%, 41.65%,
33.07%, 25.39% and 23.04% of credit support for the class A, B, C,
D, E, and F notes, respectively, based on stressed cash flow
scenarios (including excess spread). These credit support levels
provide coverage of approximately 3.10x, 2.60x, 2.10x, 1.60x, 1.23x
and 1.1x S&P's 18.50%-19.50% expected cumulative net loss range for
the class A, B, C, D, E, and F notes, respectively. Additionally,
credit enhancement, including excess spread for classes A, B, C, D,
E, and F covers breakeven cumulative gross losses of approximately
95%, 81%, 69%, 55%, 42% and 38%, respectively;

-- S&P's expectation that under a moderate stress scenario of
1.60x its expected net loss level, all else equal, the ratings on
the class A through C notes would not decline by more than one
rating category while they are outstanding, and the rating on the
class D notes would not decline by more than two rating categories
within its life. The ratings on the class E and F notes would
remain within two rating categories during the first year, but each
class would eventually default under the 'BBB' stress scenario:
class E after receiving 41%-65% of its principal and class F
without receiving any principal payments. These rating migrations
are consistent with S&P's credit stability criteria;

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

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

-- The transaction's payment and credit enhancement structure,
which includes an incurable performance trigger.

  RATINGS ASSIGNED
  CPS Auto Receivables Trust 2019-D

  Class       Rating       Amount (mil. $)   Coupons (%)
  A           AAA (sf)             118.250          2.17
  B           AA (sf)               47.300          2.35
  C           A (sf)                40.288          2.54
  D           BBB (sf)              34.237          2.72
  E           BB- (sf)              29.013          3.86
  F           B (sf)                 5.225          6.55


DRYDEN 76 CLO: S&P Assigns Prelim BB- Rating to $12MM Class E Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Dryden 76
CLO Ltd.'s fixed- and floating-rate notes.

The note issuance is a collateralized loan obligation (CLO)
transaction backed by broadly syndicated speculative-grade (rated
'BB+' and lower) senior secured term loans managed by PGIM Inc.

The preliminary ratings reflect:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  Dryden 76 CLO Ltd./Dryden 76 CLO LLC

  Class                  Rating       Amount (mil. $)
  A-1                    AAA (sf)              235.00
  A-2                    AAA (sf)               25.00
  B                      AA (sf)                44.00
  C (deferrable)         A (sf)                 26.00
  D-1 (deferrable)       BBB- (sf)              17.80
  D-2 (deferrable)       BBB- (sf)               3.00
  D-3 (deferrable)       BBB- (sf)               5.20
  E (deferrable)         BB-                    12.00
  Subordinated notes     NR                     33.30

  NR--Not rated.


DT AUTO OWNER: DBRS Took 38 Ratings on 11 Transactions
------------------------------------------------------
DBRS, Inc., on Oct. 10, 2019, took rating actions on 38 ratings
from 11 DT Auto Owner Trust transactions. Of the rated classes
reviewed, 15 were upgraded, seven were discontinued due to
repayment and 16 were confirmed. For the ratings that were
upgraded, performance trends are such that credit enhancement
levels are sufficient to cover DBRS Morningstar's expected losses
at their new respective rating levels. For the notes that were
confirmed, performance trends are such that credit enhancement
levels are sufficient to cover DBRS Morningstar's expected losses
at their current respective rating levels.

The Affected Ratings are Available at https://bit.ly/2MeG5wA

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

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

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

-- The credit quality of the collateral pool and historical
    performance.




EXETER AUTOMOBILE 2019-4: S&P Assigns BB (sf) Rating to Cl. E Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Exeter Automobile
Receivables Trust 2019-4's automobile receivables-backed notes.

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

The ratings reflect:

-- The availability of approximately 60.1%,53.4%, 44.5%, 34.6% and
29.1% credit support for the class A, B, C, D, and E notes,
respectively, based on stressed cash flow scenarios (including
excess spread). This credit support provides coverage of
approximately 2.85x, 2.50x, 2.05x, 1.55x, and 1.27x S&P's
20.50%-21.50% expected cumulative net loss (CNL) range. These
break-even scenarios withstand cumulative gross losses (CGLs) of
approximately 92.5%, 82.2%, 71.2%, 55.3%, and 46.5% respectively.

-- S&P's expectation for timely interest and principal payments on
the notes, based on stressed cash flow modeling scenarios, which,
in its view, are appropriate for the assigned ratings.

-- The expectations 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 notes will remain at the assigned 'AAA (sf)'
rating; the ratings on the class B and C notes will remain within
one rating category of the assigned 'AA (sf)' and 'A (sf)' ratings,
respectively, for the deal's life; and the rating on the class D
notes will remain within two rating categories of the assigned 'BBB
(sf)' rating over the deal's life. S&P expects the class E notes to
remain within two rating categories of the assigned 'BB (sf)'
rating over the first year, but it expects them to eventually
default under this stress scenario. These rating movements are
within the limits specified by S&P's credit stability criteria.

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

-- The transaction's payment, credit enhancement, and legal
structures.

  RATINGS ASSIGNED
  Exeter Automobile Receivables Trust 2019-4

  Class       Rating       Amount (mil. $)

  A           AAA (sf)              392.84
  B           AA (sf)               118.92
  C           A (sf)                129.48
  D           BBB (sf)              142.69
  E           BB (sf)                66.07


FALCON 2019-1: Fitch to Rate Series C Notes 'BB(EXP)'
-----------------------------------------------------
Fitch Ratings expects to rate the aircraft ABS notes issued by
Falcon 2019-1 Aerospace Limited and Falcon 2019-1 Aerospace USA
LLCThe Cayman issuer is an exempted company incorporated with
limited liability under the laws of the Cayman Islands, and
resident in Ireland for tax purposes. The U.S. issuer, a wholly
owned subsidiary of Falcon Cayman, is a special-purpose Delaware
LLC.

The notes are secured by lease payments and disposition proceeds on
a pool of 23 mid-life aircraft purchased and owned by Falcon,
managed and serviced by Dubai Aerospace Enterprise (DAE) Ltd. This
is the second public, Fitch-rated transaction sponsored/serviced by
DAE, and the fourth serviced by DAE. The prior sponsored/serviced
DAE ABS were Kestrel Aircraft Funding Limited (Kestrel), Falcon
Aerospace Limited (Falcon 2017-1) issued in 2017 and Diamond Head
Aviation 2015 Limited (DHA), both NR by Fitch. DHA was initially
serviced by AWAS, which was purchased by DAE in 2017, and is
currently serviced by DAE. DAE is rated 'BBB-'/Stable by Fitch.

Falcon 2019-1

Series A; LT A(EXP)sf;   Expected Rating

Series B; LT BBB(EXP)sf; Expected Rating

Series C; LT BB(EXP)sf;  Expected Rating

KEY RATING DRIVERS

Unsecured Exposure to DAE Credit - Optional Standby Letters of
Credit: The sellers will have the option to obtain standby letters
of credit (LCs) for any or all of the undelivered aircraft over the
delivery period. The pre-delivery payment amount covered by the LCs
will then be transferred to the sellers out of the aircraft
acquisition account. Any LC providers will be required to maintain
a minimum rating of 'A' or higher by Fitch.  

Stable Asset Quality - Mostly Liquid Narrowbody: The pool is
largely composed of liquid narrowbody, mid-life A320, A321 and B737
family current-generation aircraft with a weighted average (WA) age
of 10.4 years. There are three A330-300 widebody aircraft totaling
34.5%. Although widebodies are typically prone to higher transition
costs, two of the widebodies (27.1%) are young A330-300s with a WA
age of 5 years and long remaining lease terms through 2026.  

Lease Term and Maturity Schedule - Neutral: The WA remaining lease
term is 4.5 years, in line with Kestrel and comparable to recently
rated pools. One lease comes due in 2020 totaling 2.7%, one (3.2%)
in 2021, eight (32.1%) in 2022, and seven (20.6%) in 2023.
Furthermore, DAE is proactive in working with lessees on lease
extensions, which is a positive, as longer lease terms contract
more cash flows.

Lessee Credits - Weak Credits: Lessees assumed at 'CCC' by Fitch
total 23.4%, higher than Kestrel (11.6%), but on the lower end
compared to recently rated transactions. Most of the 17 lessees are
either unrated or speculative-grade credits, typical of aircraft
ABS. The pool does include three lessees rated by Fitch: Wizz Air
(BBB/Stable), American Airlines (BB-/Stable) and Alaska Airlines
(BBB-/Stable), totaling six leases at 19.2%. Fitch assumed a 'B' or
'CCC' Issuer Default Rating (IDR) for unrated lessees, and stressed
IDRs downward in recessions to reflect pool default risk. Ratings
were further stressed for future assumed recessions and once
aircraft reach Tier 3 classification.

Country Credit Risk - Neutral: The largest country concentration is
the Philippines (BBB/Stable) totaling 13.7% comprised of one
widebody. The second largest is South Korea (13.4%) with three
aircraft followed by Malaysia (13.4%), Hungary (12.2%) and Russia
(9.2%). The top five countries total 61.9%, with 27.1% of lessees
concentrated in emerging Asia Pacific. All countries in the pool
have an investment-grade sovereign rating, including three rated
'AAA', namely the U.S., the Netherlands and Denmark totaling
14.2%.

Consistent Transaction Structure: Credit enhancement (CE) comprises
overcollateralization (OC), a liquidity facility and a cash
reserve. The initial loan to value (LTV) ratios for the series A, B
and C notes are 66.0%, 78.0% and 84.0%, respectively, based on the
average of the maintenance-adjusted base values (MABV), which are
consistent with Kestrel.

Adequate Structural Protections: The notes make full payment of
interest and principal in the primary scenarios, commensurate with
their recommended ratings after applying Fitch's stressed asset and
liability assumptions. Fitch derived multiple alternative cash
flows to evaluate the structural sensitivity to different
scenarios.

Capable Servicing History and Experience: Fitch believes DAE has
the ability to collect lease payments, remarket and repossess
aircraft in an event of lessee default, and procure maintenance to
retain values and ensure stable performance. Fitch considers DAE to
be a capable servicer, evidenced by prior securitization
performance and its servicing experience of aviation assets and
managed aviation funds. DAE is rated 'BBB-'/Stable.

Aviation Market Cyclicality: Commercial aviation has been subject
to significant cyclicality due to macroeconomic and geopolitical
events. Fitch's analysis assumes multiple periods of significant
volatility over the life of the transaction. Downturns are
typically marked by reduced aircraft utilization rates, values and
lease rates, as well as deteriorating lessee credit quality. Fitch
employs aircraft value stresses in its analysis, which takes into
account age and marketability to simulate the decline in lease
rates expected over the course of an aviation market downturn, and
the decrease to potential residual sales proceeds.

Rating Cap of 'Asf': Fitch limits aircraft operating lease ratings
to a maximum cap of 'Asf' due to the factors discussed, and the
potential volatility they produce.

RATING SENSITIVITIES

The performance of aircraft ABS can be affected by various factors,
which, in turn, could have an impact on the assigned ratings. Fitch
conducted multiple rating sensitivity analyses to evaluate the
impact of changes to a number of the variables in the analysis.
These sensitivity scenarios were also considered in determining
Fitch's recommended ratings.

Technological Obsolescence Stress Scenario

All aircraft in the pool face replacement programs over the next
decade, particularly the A320ceo and B737 NG aircraft in the form
of A320neo and B737 MAX aircraft. Deliveries of these models have
begun and will increase in the coming years. While commercial
flights have not yet begun, the first A330neo was delivered. If
received well, the increase in future deliveries could affect the
existing A330 fleet. Certain appraisers have started to adjust MVs
in response to this replacement risk; a majority of the pool's
market value appraisals are slightly lower than HL BVs. Fitch
believes current-generation aircraft are well insulated due to
large operator bases and the long lead time for full replacement,
particularly when considering conservative retirement ages and
aggressive production schedules for Airbus and Boeing new
technology.

However, Fitch believes a sensitivity scenario is warranted to
address these risks. Therefore, Fitch utilized a scenario in which
demand, and thus values, of existing aircraft would fall
significantly due to the replacement technology. The first
recession was assumed to occur two years following close. However,
all recessionary value decline stresses were increased 10% at each
rating category. Fitch additionally utilized a 25% residual
assumption, rather than the base level of 50%, to stress EOL
proceeds for each asset in the pool. Lease rates drop fairly
significantly under this scenario, and aircraft are essentially
sold for scrap at the end of their useful lives.

This scenario is stressful, as 'Asf' net cash flow including sales
proceeds drops to $530 million, compared with $593 million in the
primary scenario. The class A notes fail the 'Asf' and 'BBBsf'
scenarios, but are able to pass the 'BBsf' scenario. Meanwhile the
class B and C notes fail all scenarios; however, the unpaid balance
under the 'Bsf' scenario is relatively small. Such a scenario is
likely to result in a downgrade of class A, B and C notes by up to
two categories.

CCC Stress Scenario

Fitch assumed that all unrated airlines had a default probability
in line with a 'CCC' credit. This rating was assumed to decline to
'CC' during recessionary periods. Furthermore, Fitch's assumed
repossession time was increased by one month under all scenarios.
Such assumptions are materially conservative, as the default rate
and aircraft downtime significantly increase over the primary
scenarios. Net cash flow under the 'Asf' scenario declines to $509
million, while average utilization falls to 80.2%.

Under this scenario, class A fails the 'Asf' stress. Under Fitch's
'BBBsf' and 'BBsf' scenarios, class A is able to pay in full with
no principal shortfalls, while the class B and C notes fail. Under
the 'Bsf' scenario, class B notes pass and class C notes fail. Such
a stress to the transaction would likely result in a downgrade of
up to one to two categories for all classes of notes.

Widebody Stress Scenario

This pool contains a large concentration of A330s (34.5%). Although
the A330-300 variant is one of the most marketable variants on the
market, Fitch created a scenario in which the widebody aircraft in
the pool encounter a considerable amount of stress to their
residual values. First, Fitch assumed all were initially considered
to be Tier 3 aircraft to stress depreciation rates and recessionary
value declines. In addition, Fitch decreased its residual credit to
25% from 50% of stressed future market values. Essentially under
this scenario, A330-300s encounter severe value decline stresses
and are only granted part-out value at the end of their useful
lives.

Net cash flow under the 'Asf' scenario declines to $527 million,
while average utilization falls to 86.6%. All classes fail under
the 'Asf' and 'BBBsf' scenarios. Class A passes at 'BBsf', class B
passes at 'Bsf', and class C fails 'Bsf'.


GERMAN AMERICAN 2016-CD2: Fitch Affirms B-sf Rating on Cl. F Certs
------------------------------------------------------------------
Fitch Ratings affirmed all classes of German American Capital
Corp.'s CD 2016-CD2 Mortgage Trust commercial mortgage pass-through
certificates, series 2016-CD2.

CD 2016-CD2

                         Current Rating     Prior Rating

Class A-1 12515ABA7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 12515ABB5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 12515ABD1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 12515ABE9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-M 12515ABG4;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 12515ABC3; LT AAAsf Affirmed;  previously at AAAsf

Class B 12515ABH2;    LT AA-sf Affirmed;  previously at AA-sf

Class C 12515ABJ8;    LT A-sf Affirmed;   previously at A-sf

Class D 12515AAN0;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 12515AAQ3;    LT BB-sf Affirmed;  previously at BB-sf

Class F 12515AAS9;    LT B-sf Affirmed;   previously at B-sf

Class V1-A 12515ABK5; LT AAAsf Affirmed;  previously at AAAsf

Class V1-B 12515ABL3; LT AA-sf Affirmed;  previously at AA-sf

Class V1-C 12515ABW9; LT A-sf Affirmed;   previously at A-sf

Class V1-D 12515ABQ2; LT BBB-sf Affirmed; previously at BBB-sf

Class X-A 12515ABF6;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 12515AAA8;  LT AA-sf Affirmed;  previously at AA-sf

Class X-D 12515AAE0;  LT BBB-sf Affirmed; previously at BBB-sf

Class X-E 12515AAG5;  LT BB-sf Affirmed;  previously at BB-sf

Class X-F 12515AAJ9;  LT B-sf Affirmed;   previously at B-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The affirmations reflect
the overall stable performance and loss expectations with no
material changes to pool metrics since issuance. There are no
delinquent loans and no loans in special servicing. While four
loans (9.9%) were on the servicer watchlist primarily due to
concerns with large tenants, one loan (7.7%), was considered a
Fitch Loan of Concern (FLOC). 229 West 43rd Street Retail Condo is
secured by a 248,457 SF retail condominium located in New York, NY.
The loan remains current but has been placed on the master
servicer's watchlist for the occurrence of multiple lease sweep
periods related to large tenants, which have triggered a cash flow
sweep since December 2017. Two tenants (43% NRA) remain in
occupancy despite their leases being terminated prior to their
expiration dates. Occupancy has fluctuated since issuance but has
remained stable at 95% since 2018. Fitch will continue to monitor
the loan as leasing updates are received.

Limited Change to Credit Enhancement: There has been minimal change
to credit enhancement since issuance. As of the September 2019
distribution date, the pool's aggregate balance has been reduced by
0.67% to $968.8 million from $975.4 million at issuance. All
original 30 loans remain in the pool. Twelve loans (62.2% of the
pool) are full term interest-only, and seven loans (26% of the
pool) are partial interest-only period; two loans (12.3%) have
exited their interest only period. Based on the scheduled balance
at maturity, the pool will pay down by only 5.5%

ADDITIONAL CONSIDERATIONS

Pool Concentrations: The top 10 loans represent 67.3% of the pool.
The largest property type in the transaction is office,
representing 35.9% of the pool, followed by retail and mixed use at
23.5% each, industrial at 13.8%, hotel properties at 2.6% and
self-storage at 0.8%.

Pari Passu Loans: Twelve loans (66.8%) including seven (51.95) of
the top 10, are pari passu loans.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable given the
relatively stable performance of the transaction since issuance.
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.


GS MORTGAGE 2019-PJ3: Moody's Assigns (P)B2 Rating on Cl. B-5 Debt
------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to 15
classes of residential mortgage-backed securities issued by GS
Mortgage-Backed Securities Trust 2019-PJ3. The ratings range from
(P)Aaa (sf) to (P)B2 (sf).

GSMBS 2019-PJ3 is the third prime jumbo transaction of 2019 issued
by Goldman Sachs Mortgage Company. GSMC is a wholly owned
subsidiary of Goldman Sachs Bank USA and Goldman Sachs. The
certificates are backed by 394 30-year, fully-amortizing fixed-rate
mortgage loans with a total balance of $271,016,060 as of the
October 1, 2019 cut-off date. Government sponsored enterprises
eligible loans (GSE-eligible loans) comprise $110,160,694 of the
pool balance, representing 40.65% of the total pool. All the loans
are subject to the Qualified Mortgage (QM) and Ability-to-Repay
(ATR) rules and are categorized as QM-Safe Harbor or QM-Agency Safe
Harbor.

The mortgage loans for this transaction were acquired by the seller
and sponsor, GSMC, from HomeBridge Financial Services, Inc.
(25.33%), loanDepot.com, LLC (loanDepot) (19.86%) and Caliber Home
Loans, Inc. (Caliber) (13.57%). The remaining originators have less
than 10% by loan balance of the pool.

The weighted average (WA) loan-to-value ratio of the mortgage pool
is 73.08%, which is in line with the previous GSMBS 2019-PJ1 and
GSMBS 2019-PJ2 transaction (collectively, GSMBS PJ1 and PJ2) and
also with other prime jumbo J.P. Morgan Mortgage Trust (JPMMT) and
Sequoia Mortgage Trust (SEMT) transactions which had WA LTVs of
approximately 70%. Similar to GSMBS PJ1 and PJ2, JPMMT and SEMT
prime jumbo transactions, the borrowers in the pool have a WA FICO
score of 762 and a WA debt-to-income ratio of 36.2%. The WA
mortgage rate of the pool is 4.41%. In addition, 1 loan in the pool
has mortgage insurance. Certain loan characteristics may differ
from the data provided by GSMC because the calculations reflect its
assumptions or adjustments based either on third-party review
results or other information provided.

NewRez LLC (formerly known as New Penn Financial, LLC) d/b/a
Shellpoint Mortgage Servicing will service 100% of the pool. The
servicing fee for loans serviced by Shellpoint will be 0.030%.
Moody's considers the servicing fee charged by Shellpoint low
compared to the industry standard of 0.25% for prime fixed rate
loans and in the event of a servicing transfer, the successor
servicer may not accept such an arrangement. However, the
transaction documents provide that any successor servicer to
Shellpoint will be paid the successor servicing fee rate of 0.25%,
which is not limited to the Shellpoint servicing fee rate.

Wells Fargo Bank, N.A. will be the master servicer and securities
administrator (rated Aa1 by Moody's). U.S. Bank Trust National
Association will be the trustee. Pentalpha Surveillance LLC will be
the representations and warranties breach reviewer.

Distributions of principal and interest and loss allocations are
based on a typical shifting interest structure that benefits from a
senior and subordination floor.

The complete rating actions are as follows:

Issuer: GS Mortgage-Backed Securities Trust 2019-PJ3

Cl. A-1, Assigned (P)Aaa (sf)

Cl. A-2, Assigned (P)Aaa (sf)

Cl. A-3, Assigned (P)Aa1 (sf)

Cl. A-4, Assigned (P)Aa1 (sf)

Cl. A-5, Assigned (P)Aaa (sf)

Cl. A-6, Assigned (P)Aaa (sf)

Cl. A-7, Assigned (P)Aaa (sf)

Cl. A-8, Assigned (P)Aaa (sf)

Cl. A-9, Assigned (P)Aaa (sf)

Cl. A-10, Assigned (P)Aaa (sf)

Cl. B-1, Assigned (P)Aa2 (sf)

Cl. B-2, Assigned (P)A2 (sf)

Cl. B-3, Assigned (P)Baa2 (sf)

Cl. B-4, Assigned (P)Ba1 (sf)

Cl. B-5, Assigned (P)B2 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 0.60%
in a base scenario and reaches 6.95% at a stress level consistent
with the Aaa (sf) ratings.

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

Its ratings on the certificates take into consideration the credit
quality of the mortgage loans, the structural features of the
transaction, the origination quality, the servicing arrangement,
the strength of the third party due diligence and the
representations and warranties (R&W) framework of the transaction.

Collateral Description

GSMBS 2019-PJ3 is a securitization of a pool of 394 30-year
fully-amortizing fixed-rate mortgage loans with a total balance of
$271,016,060 as of the cut-off date, with a WA remaining term to
maturity of 356 months and a WA seasoning of 4 months. The WA
current FICO score of the borrowers in the pool is 762. The WA LTV
ratio of the mortgage pool is 73.08%, which is in line with GSMBS
PJ1 and PJ2, JPMMT and SEMT prime jumbo transactions which had WA
LTVs of about 70% on average. Other characteristics of the loans in
the pool are also generally comparable to that of GSMBS PJ1 and
PJ2, recent JPMMT and SEMT prime jumbo transactions. The mortgage
loans in the pool were originated mostly in California (47.36% by
loan balance). In addition, 1 loan in the pool has mortgage
insurance.

Aggregator/Origination Quality

GSMC is the loan aggregator and mortgage seller for the
transaction. GSMC is overseen by the mortgage capital markets group
within Goldman Sachs. Senior management averages 16 years of
mortgage experience and 15 years of Goldman Sachs tenure. The loans
sold to the trust come from bulk purchases and from unaffiliated
third-party originators.

Moody's considers GSMC's aggregation platform to be relatively
weaker than that of peers due to the lack of sufficient historical
performance and limited quality control process. Nevertheless,
since these loans were originated to the originators' underwriting
guidelines and Moody's reviewed each of the originators which
contributed at least 10% of the loans to the transaction
(HomeBridge, loanDepot and Caliber), among other considerations,
their underwriting guidelines, performance history, policies and
documentation (to the extent available, respectively), Moody's did
not apply a separate loss-level adjustment for aggregation quality.
Instead, Moody's based its loss-level adjustments on its reviews of
each of the originators.

HomeBridge, loanDepot and Caliber originated 25.33%, 19.86% and
13.57%, respectively. The remaining originators have less than 10%
by loan balance of the pool. Furthermore, because Moody's consider
Provident and Caliber to have stronger residential prime jumbo loan
origination practices than their peers due to their strong
underwriting processes and solid loan performance, Moody's
decreased its base case and Aaa (sf) loss expectations for
non-conforming loans originated by Provident and Caliber.
Furthermore, because Moody's considers Flagstar, loanDepot and
PenFed adequate originators of prime jumbo loans, Moody's did not
make any adjustments to its base case and Aaa (sf) loss
expectations for non-conforming loans originated by these three
originators. Finally, Moody's increased its base case and Aaa (sf)
loss assumption for the loans originated by Home Point Financial
Corporation (3.48% by balance) due to limited historical
performance data, reduced retail footprints which limits the
originator's oversight on originations, and lack of strong controls
to support recent rapid growth.

Of note, Moody's did not make an adjustment for GSE-eligible loans,
regardless of the originator, since those loans were underwritten
in accordance with GSE guidelines.

Servicing Arrangement

Shellpoint will be the named primary servicer for this transaction
and will service 100% of the pool. Shellpoint is an approved
servicer in good standing with Ginnie Mae, Fannie Mae and Freddie
Mac. Shellpoint's primary servicing location is located in
Greenville, South Carolina. Shellpoint services residential
mortgage assets for investors that include banks, financial
services companies, GSEs and government agencies.

Shellpoint will be paid a flat servicing fee of 0.030% per annum.
Moody's considers the servicing fee charged by Shellpoint as low
compared to the industry standard of 0.25% for prime fixed rate
loans. In the event of a servicing transfer, the successor servicer
may not accept such an arrangement. However, the transaction
documents provide that any successor servicer to Shellpoint will be
paid the successor servicing fee rate of 0.25%, which is not
limited to the Shellpoint servicing fee rate. The holder of 100% of
the voting interests in the Class A-IO-S certificates will have the
right to terminate Shellpoint and any successor servicer of the
mortgage loans at any time subject to the terms of the servicing
agreement, the consent of the master servicer and certain other
conditions.

Third-party Review

AMC Diligence, LLC (AMC), Clayton Services LLC (Clayton) and
Digital Risk, LLC (Digital Risk), which are third party review
(TPR) firms, verified the accuracy of the loan-level information
that Moody's received from the sponsor. The TPR firms conducted
detailed credit, regulatory compliance, property valuation and data
integrity reviews on 100% of the mortgage pool. The TPR results
indicated compliance with the originators' underwriting guidelines
for the vast majority of loans, no material compliance issues and
no material appraisal defects. The loans that had exceptions to the
originators' underwriting guidelines had strong documented
compensating factors such as significant liquid assets, low LTVs
and consistent long-term employment. The TPR firms also identified
minor compliance exceptions for reasons such as inadequate RESPA
disclosures (which do not have assignee liability) and TILA/RESPA
Integrated Disclosure (TRID) violations related to fees that were
out of variance but then were cured and disclosed. Moody's did not
make any adjustments to its expected or Aaa (sf) loss levels due to
the TPR results.

Representations & Warranties

GSMBS 2019-PJ3's R&W framework is in line with that of recent GSMBS
PJ1 and PJ2 and JPMMT transactions where an independent reviewer is
named at closing, and costs and manner of review are clearly
outlined at issuance. Its review of the R&W framework takes into
account the financial strength of the R&W providers, scope of R&Ws
(including qualifiers and sunsets) and enforcement mechanisms.

Pursuant to the related purchase agreement, each of the originators
in this pool will make certain R&Ws concerning the mortgage loans
(R&W providers). The R&W providers vary in financial strength. 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.
Because the R&W providers in this transaction are unrated and/or
exhibit limited financial flexibility Moody's applied an adjustment
to the loans for which these entities provided R&Ws. With respect
to certain R&Ws made by these originators, GSMC will make a "gap"
representation covering the period from the date on which the
related originator made the related representation and warranty to
the cut-off date or closing date, as applicable. GSMC will not
backstop any R&W providers who may become financially incapable of
repurchasing mortgage loans. In fact, none of the mortgage loan
seller, the depositor, the servicer or any other party will
backstop the obligations of any originator or aggregator with
respect to breaches of the mortgage loan representations and
warranties.

The loan-level R&Ws are strong and, in general, either meet or
exceed the baseline set of credit-neutral R&Ws Moody's identified
for US RMBS. Among other considerations, the R&Ws address property
valuation, underwriting, fraud, data accuracy, regulatory
compliance, the presence of title and hazard insurance, the absence
of material property damage, and the enforceability of the
mortgage. The transaction has a number of knowledge qualifiers,
which do not appear material. While a few R&Ws sunset after three
years, all of these provisions are subject to performance triggers
which extend the R&W an additional three years based on the
occurrence of certain events of delinquency.

The R&W enforcement mechanisms are adequate. Moody's analyzed the
triggers for breach review, the scope of the review, the
consistency and transparency of the review, and the likelihood that
a breached R&W would be put back to the R&W provider. The breach
review is systematic, transparent, consistent and independent. The
transaction documents prescribe a comprehensive set of tests that
the reviewer will perform to test whether the R&Ws are breached.
The tests, for the most part, are thorough, transparent and
consistent because the same tests will be performed for each loan
and the reviewer will report the results.

In accordance with the representations and warranties review
procedures undertaken by the breach reviewer, if the breach
reviewer determines that there has been a material test failure of
a test in respect of a representation and warranty, a repurchase
request will be made of the related responsible party. In such
case, the related responsible party may (1) dispute the repurchase
request, (2) cure the breach, (3) repurchase the affected mortgage
loan from the issuing entity or pay the loss amount with respect to
such affected mortgage loan, as applicable, or (4) in some
circumstances, substitute another mortgage loan. Overall, this
remedy mechanism is consistent with GSMBS 2019-PJ2, JPMMT and SEMT
prime jumbo transactions. Because third-party review was conducted
on 100% of the pool with adequate results, this mitigates the risk
of future R&W violations.

Trustee and Master Servicer

The transaction trustee is U.S. Bank Trust National Association
(U.S. Bank Trust). U.S. Bank Trust is a national banking
association and a wholly owned subsidiary of U.S. Bank National
Association, the fifth largest commercial bank in the United
States. U.S. Bank Trust has provided owner trustee services since
the year 2000.

Wells Fargo will act as master servicer and securities
administrator under the sale and servicing agreement and as
custodian under the custodial agreement. Wells Fargo is a national
banking association and a wholly-owned subsidiary of Wells Fargo &
Company. A diversified financial services company, Wells Fargo &
Company is a U.S. bank holding company with approximately $1.9
trillion in assets and approximately 263,000 employees as of June
30, 2019. As master servicer, Wells Fargo is responsible for
servicer oversight, the termination of servicers and the
appointment of successor servicers. Moody's considers the presence
of an experienced master servicer such as Wells Fargo to be a
mitigant for any servicing disruptions. Wells Fargo is committed to
act as successor servicer if no other successor servicer can be
engaged.

Tail Risk and Locked Out Percentage

The securitization is a single pool which has a shifting interest
structure that benefits from a senior subordination floor and a
subordinate floor. For deals in which the issuer does not exercise
a clean-up call option, the remaining subordination at the tail end
of transaction's life could become insufficient to support high
ratings on senior bonds as tranche performance depends highly on
the performance of a small number of loans. To address this risk,
the transaction has a senior floor of 2.35% and a locked out
percentage of 1.60%, both expressed as a percentage of the closing
pool balance. The subordinate locked out amount protects both the
senior tranches and non-locked subordinate tranches. It diverts
allocable principal payments from locked out subordinate tranches
to the non-locked subordinate tranches. Of note, other than the
Class B1, a subordinate tranche is locked out if its outstanding
balance plus the outstanding balance of all classes subordinate to
it. Class B1 will not be subject to the locked out amount. If the
Class B1 is paid to zero and the aggregate amount of outstanding
subordinate tranches is equal to or less than the locked out
amount, than the allocable principal payments from all subordinate
tranches are diverted to pay senior tranches until they are paid
off.

Transaction Structure

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

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

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

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

Down

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

Up

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

Methodology

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


HIGHER EDUCATION 2010-1: Fitch Lowers Class A-1 Debt Rating to BBsf
-------------------------------------------------------------------
Fitch Ratings takes various actions on Higher Education Loan
Authority of the State of Missouri Trusts.

Higher Education Loan Authority of the State of Missouri Series
2010-2
   
- Class A-1 606072KS4; LT AAAsf Affirmed; previously at AAAsf

Higher Education Loan Authority of the State of Missouri Series
2013-1
   
- Class A 606072LB0;   LT Asf Downgrade;  previously at AAsf

Higher Education Loan Authority of the State of Missouri Series
2010-1
   
- Class A-1 606072KP0; LT BBsf Downgrade; previously at AAsf

Higher Education Loan Authority of the State of Missouri Series
2010-3
   
- Class A-1 606072KV7; LT AAsf Downgrade; previously at AAAsf

TRANSACTION SUMMARY

The downgrades and outlook revisions on all of the notes are mainly
driven by the deterioration of the transactions' maturity profile
due to increasing income-based repayment (IBR) and extended
weighted average loan term.

MOHELA 2010-1: The notes fail Fitch's 'Bsf' maturity stress
scenario due to missing the legal final maturity date. According to
the criteria, If note ratings fail Fitch's 'Bsf' cash flow
scenarios marginally under the maturity stresses, Fitch may rate
the notes 'BBsf', as a slight change in the future economic
environment could result in full repayment of bonds by maturity
dates. Weighted average loan terms increased seven months in the
last year ending July 2019. The transaction is structured to
release cash as long as it maintains it target parity of 110%. The
transaction reached its target parity in 2013 and has been
releasing excess cash since then.

MOHELA 2010-2: Fitch's student loan ABS cash flow model indicates
the notes pass all stress scenarios. The Negative Outlook reflects
the deteriorating maturity profile. Weighted average loan terms
increased seven months in the last year ending July 2019. The
transaction has a full turbo structure that uses excess cash to pay
down the outstanding series. Parity was 133.4% on the same date.

MOHELA 2010-3: Fitch's student loan ABS cash flow model indicates
the notes fail the 'AAA' maturity stress scenarios. The Negative
Outlook reflects the deteriorating maturity profile. Weighted
average loan terms increased seven months in the last year ending
July 2019. The transaction has a full turbo structure that uses
excess cash to pay down the bond. Parity was 120.6% on same date.

MOHELA 2013-1: Fitch's student loan ABS cash flow model indicates
the notes fail the 'BBB' through 'AAA' maturity stress scenarios
due to deterioration maturity profile. The failure at the 'Asf' and
'BBBsf' scenarios are marginal and a slight change in the future
economic environment could result in full repayment of bonds by
maturity dates. Weighted average loan terms increased seven months
in the last year ending August 2019. The transaction is structured
to release cash as long as it maintains its target
overcollateralization (OC), which is the greater of $30,000,000 or
9.1% of the pool balance. The transaction reached its target in
June 2018 and has been releasing excess cash since then.

KEY RATING DRIVERS

U.S. Sovereign Risk: The trusts' collateral comprises 100% Federal
Family Education Loan Program (FFELP) loans with guaranties
provided by eligible guarantors and reinsurance provided by the
U.S. Department of Education (ED) for at least 97% of principal and
accrued interest. The U.S. sovereign rating is currently
'AAA'/Outlook Stable.

Collateral Performance:

MOHELA 2010-1: As of July 2019, the maturity profile is worsening
highlighted by the weighted average remaining loan term increasing
seven months in the past year. Fitch assumes a base case default
rate of 34.3% and 100% under the 'AAA' credit stress scenario and a
constant default rate of 6.0%. Fitch applies the standard default
timing curve in its credit stress cash flow analysis. The claim
reject rate is assumed to be 0.50% in the base case and 3.0% in the
'AAA' case. The TTM levels of deferment, forbearance and IBR are
6.0%, 8.4%, and 13.3% respectively, and are used as the starting
point in cash flow modelling. The sustainable constant prepayment
rate (voluntary and involuntary) is assumed to be 11.0%. Subsequent
declines or increases are modelled as per criteria. The borrower
benefit is assumed to be approximately 0.08%, based on information
provided by the sponsor.

MOHELA 2010-2: As of July 2019, the maturity profile is worsening,
highlighted by the weighted average remaining loan term increasing
seven months in the past year. Fitch assumes a base case default
rate of 34% and 100% under the 'AAA' credit stress scenario and a
constant default rate of 6.0%. Fitch applies the standard default
timing curve in its credit stress cash flow analysis. The claim
reject rate is assumed to be 0.50% in the base case and 3.0% in the
'AAA' case. The TTM levels of deferment, forbearance and IBR 6.1%,
9.3%, and 11.8% respectively, and are used as the starting point in
cash flow modelling. The sustainable constant prepayment rate
(voluntary and involuntary) is assumed to be 11.0%. Subsequent
declines or increases are modelled as per criteria. The borrower
benefit is assumed to be approximately 0.08%, based on information
provided by the sponsor.

MOHELA 2010-3: As of July 2019, the maturity profile is worsening,
highlighted by the weighted average remaining loan term increasing
seven months in the past year. Fitch assumes a base case default
rate of 35.8% and 100% under the 'AAA' credit stress scenario and a
constant default rate of 6.0%. Fitch applies the standard default
timing curve in its credit stress cash flow analysis. The claim
reject rate is assumed to be 0.50% in the base case and 3.0% in the
'AAA' case. The TTM levels of deferment, forbearance and IBR are
7.5%, 8.6%, and 15.1% respectively, and are used as the starting
point in cash flow modelling. The sustainable constant prepayment
rate (voluntary and involuntary) is assumed to be 11.0%. Subsequent
declines or increases are modelled as per criteria. The borrower
benefit is assumed to be approximately 0.06%, based on information
provided by the sponsor.

MOHELA 2013-1: As of September 2019, the maturity profile is
worsening, highlighted by the weighted average remaining loan term
increasing seven months in the past year. Fitch assumes a base case
default rate of 34.5% and 100% under the 'AAA' credit stress
scenario and a constant default rate of 6.0%. Fitch applies the
standard default timing curve in its credit stress cash flow
analysis. The claim reject rate is assumed to be 0.50% in the base
case and 3.0% in the 'AAA' case. TTM levels of deferment,
forbearance and IBR are 6.3%, 8.1%, and 13.9% respectively, and are
used as the starting point in cash flow modelling. The sustainable
constant prepayment rate (voluntary and involuntary) is assumed to
be 11.0%. Subsequent declines or increases are modelled as per
criteria. The borrower benefit is assumed to be approximately
0.07%, based on information provided by the sponsor.

Basis and Interest Rate Risk:

MOHELA 2010-1: Basis risk for this transaction arises from any rate
and reset frequency mismatch between interest rate indices for
Special Allowance Payments (SAP) and the securities. As of July
2019, 94.63% of the principal balance is indexed to one-month LIBOR
with the rest indexed to 91 Day T-Bills. All notes are indexed to
three-month LIBOR.

MOHELA 2010-2: Basis risk for this transaction arises from any rate
and reset frequency mismatch between interest rate indices for SAP
and the securities. As of July 2019, 94.99% of the principal
balance is indexed to one-month LIBOR with the rest indexed to 91
Day T-Bills. All notes are indexed to three-month LIBOR.

MOHELA 2010-3: Basis risk for this transaction arises from any rate
and reset frequency mismatch between interest rate indices for SAP
and the securities. As of July 2019, 96.92% of the principal
balance is indexed to one-month LIBOR with the rest indexed to 91
Day T-Bills. All notes are indexed to three-month LIBOR.

MOHELA 2013-1: Basis risk for this transaction arises from any rate
and reset frequency mismatch between interest rate indices for SAP
and the securities. As of September 2019, 95.48% of the principal
balance is indexed to one-month LIBOR with the rest indexed to 91
Day T-Bills. All notes are indexed to three-month LIBOR.

Payment Structure:

MOHELA 2010-1: Credit enhancement (CE) is provided by OC and excess
spread. As of July 2019, parity was at 110.0%. Liquidity support is
provided by a specified reserve account sized at the greater of
0.25% of the pool balance or $1,191,568. The reserve account is
currently at its floor of $1,191,568. The transaction is currently
releasing cash and will continue to do so as long as it maintains
its target parity of 110%.

MOHELA 2010-2: CE is provided by OC and excess spread. As of July
2019, parity was at 133.4%. Liquidity support is provided by a
specified reserve account sized at the greater of 0.25% of the pool
balance or $ 1,247,713. The reserve account is currently at its
floor of $ 1,247,713. The transaction will not release cash until
all bonds are paid in full.

MOHELA 2010-3: CE is provided by OC and excess spread. As of July
2019, parity was at 120.6%. Liquidity support is provided by a
specified reserve account sized at the greater of 0.25% of the pool
balance or $ 765,485. The reserve account is currently at its floor
of $ 765,485. The transaction will not release cash until all bonds
are paid in full.

MOHELA 2013-1: CE is provided by OC and excess spread. As of
September 2019, parity was at 110.0%. Liquidity support is provided
by a specified reserve account sized at the greater of 0.25% of the
pool balance or $1,449,864. The reserve account is currently at its
floor of $1,449,864. The transaction is currently releasing cash
and will continue to do so as long as it maintains its target OC of
9.09%.

Operational Capabilities: Day-to-day servicing is provided by
Missouri Higher Education Loan Authority (MOHELA) with PHEAA acting
as the backup servicer. Fitch believes both entities to be
acceptable servicers, due to their extensive track record of
servicing FFELP loans.

RATING SENSITIVITIES

Fitch's rating sensitivity is focused on how ratings could be
affected when the agency's assumptions change. The ratings assigned
to senior tranches of most FFELP securitizations will likely move
in tandem with the U.S. sovereign rating given the strong linkage
to the U.S. sovereign, by nature of the reinsurance provided by the
ED, unless Fitch determines the deal's CE sufficient to cover
defaults and the losses of SAP and ISP from ED on its own.
Sovereign risks are not addressed in Fitch's sensitivity analysis.

Fitch conducted a CE sensitivity analysis by stressing both the
related lifetime default rate and basis spread assumptions. In
addition, Fitch conducted a maturity sensitivity analysis by
running different assumptions for the IBR usage and prepayment
rate. The results should only be considered as one potential model
implied outcome as the transaction is exposed to multiple risk
factors that are all dynamic variables. Additionally, the results
do not take into account any rating floor considerations.

MOHELA 2010-1

Credit Stress Rating Sensitivity

  -- Default increase 25%: class A 'CCCsf';

  -- Default increase 50%: class A 'CCCsf';

  -- Basis Spread increase 0.25%: class A 'CCCsf';

  -- Basis Spread increase 0.5%: class A 'CCCsf'.

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'CCCsf';

  -- CPR decrease 50%: class A 'CCCsf';

  -- IBR Usage increase 25%: class A 'CCCsf';

  -- IBR Usage increase 50%: class A 'CCCsf'.

MOHELA 2010-2

Credit Stress Rating Sensitivity

  -- Default increase 25%: class A 'AAAsf';

  -- Default increase 50%: class A 'AAAsf';

  -- Basis Spread increase 0.25%: class A 'AAAsf';

  -- Basis Spread increase 0.5%: class A 'AAAsf'.

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'AAAsf';

  -- CPR decrease 50%: class A 'AAAsf';

  -- IBR Usage increase 25%: class A 'AAAsf';

  -- IBR Usage increase 50%: class A 'AAAsf'.

MOHELA 2010-3

Credit Stress Rating Sensitivity

  -- Default increase 25%: class A 'AAAsf';

  -- Default increase 50%: class A 'AAAsf';

  -- Basis Spread increase 0.25%: class A 'AAAsf';

  -- Basis Spread increase 0.5%: class A 'AAAsf'.

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'Asf';

  -- CPR decrease 50%: class A 'Bsf';

  -- IBR Usage increase 25%: class A 'AAsf';

  -- IBR Usage increase 50%: class A 'Asf'.

MOHELA 2013-1

Credit Stress Rating Sensitivity

  -- Default increase 25%: class A 'AAAsf';

  -- Default increase 50%: class A 'AAAsf';

  -- Basis Spread increase 0.25%: class A 'AAAsf';

  -- Basis Spread increase 0.5%: class A 'AAAsf'.

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'CCCsf';

  -- CPR decrease 50%: class A 'CCCsf';

  -- IBR Usage increase 25%: class A 'Bsf';

  -- IBR Usage increase 50%: class A 'Bsf'.

Stresses are intended to provide an indication of the rating
sensitivity of the notes to unexpected deterioration in trust
performance. Rating sensitivity should not be used as an indicator
of future rating performance.


HORIZON AIRCRAFT III: Fitch to Rate $36MM Series C Notes 'BB(EXP)'
------------------------------------------------------------------
Fitch Ratings expects to assign the following ratings and Outlooks
to the Horizon Aircraft Finance III Limited notes:

  -- $343,000,000 series A notes 'A(EXP)sf'; Outlook Stable;

  -- $61,000,000 series B notes 'BBB(EXP)sf'; Outlook Stable;

  -- $36,000,000 series C notes 'BB(EXP)sf'; Outlook Stable.

TRANSACTION SUMMARY

The notes will be issued by Horizon Aircraft Finance III Limited
(Horizon III Cayman), a Cayman Islands limited company with tax
residency in Ireland, which will co-issue the notes with Horizon
Aircraft Finance III LLC (Horizon III USA) (collectively Horizon
III). Horizon III USA is a special purpose Delaware LLC and wholly
owned subsidiary of Horizon III Cayman. Horizon III expects to use
the rated note and equity proceeds to acquire the initial 18
aircraft, fund the maintenance reserve account (MRA), security
deposit and series C reserve accounts, pay certain expenses and
fund the expense account.

The pool will be serviced by BBAM US LP (BBAM US; U.S. servicer)
and BBAM Aviation Services Limited (Irish servicer; collectively
the Servicers), both wholly owned subsidiaries of BBAM LP (BBAM;
not rated [NR] by Fitch), with the notes secured by each aircraft's
future lease and residual cash flows. This is the fourth
Fitch-rated aircraft ABS serviced by BBAM, and the company has
serviced four prior aircraft ABS (BBAIR NR by Fitch; ECAF I,
Horizon I and Horizon III rated by Fitch). BBAM is one of the
largest aircraft servicing and management companies in the world.

KEY RATING DRIVERS

Strong Collateral Quality - 100% Liquid Narrowbody (NB) Aircraft:
The pool consists solely of 18 narrowbody (NB), Tier 1 aircraft
including 11 B737-800 (58.1%) and seven A320-200 (41.9%). The WA
age is 8.4 years, similar to Horizon II and recent transactions.

Lease Term/Maturity Schedule - Positive: The WA original lease term
is 9.9 years with 5.1 years remaining. This is a credit positive as
longer lease terms give more certainty to the cash flows, and
aircraft coming off leases will be subject to remarketing costs and
downtime. 54.8% of the leases mature in 2020-2023, with threeleases
(13.6%) maturing in 2020, risks that Fitch took into account when
applying asset assumptions and stresses.

Lessee Credit Risk - Diverse/Weaker Credits: There are 15 airline
lessees with a significant amount of unrated/speculative-grade
airlines, typical of aircraft ABS. The pool is diverse with the top
three totaling 36.1% and 24.2% flag-carriers. Fitch assumed unrated
lessees would perform consistently with a 'B' or lower Issuer
Default Rating (IDR) to accurately reflect the default risk in the
pool. Lessee ratings were further stressed during assumed future
recessions and as aircraft reach Tier 3 classification. The
concentration of assumed 'CCC'or lower lessees total 44.5%,
consistent with Horzion II and on the higher end of recent ABS
transactions.

Operational and Servicing Risk - Adequate Servicing Capability:
BBAM was founded in 1989 and is a very experienced/tenured aircraft
servicer/manager. Fitch believes BBAM is a capable servicer as
evidenced by its experienced team, the servicing of their managed
fleet and prior serviced/managed securitizations. Horizon Aircraft
Manager III Co., Ltd. (Asset Manager), a wholly owned subsidiary of
BBAM and affiliate of the Servicers, will be the Asset Manager
which Fitch views positively.

Transaction Structure - Consistent: Credit enhancement (CE)
comprises overcollateralization (OC), a liquidity facility and a
cash reserve. The initial loan to value (LTV) ratios for the class
A, B and C notes are 67.0%, 78.9% and 86.0%, respectively, slightly
higher than Horizon II and based on the average of
maintenance-adjusted base value. Structural features include DSCR
trigger, utilization thresholds, concentration limits and tiered
disposition limits, consistent with recent aircraft ABS
transactions.

Aviation Market Cyclicality: Commercial aviation has been subject
to significant cyclicality due to macroeconomic and geopolitical
events. Fitch's analysis assumes multiple periods of significant
volatility over the life of the transaction.

Asset Value and Lease Rate Volatility: Downturns are typically
marked by reduced aircraft utilization rates, values and lease
rates, as well as deteriorating lessee credit quality. Fitch
employs aircraft value stresses in its analysis, which takes into
account age and marketability to simulate the decline in lease
rates expected over the course of an aviation market downturn, and
the decrease to potential residual sales proceeds.

Rating Cap of 'Asf': Fitch limits aircraft operating lease ratings
to a maximum cap of 'Asf' due to the factors and the potential
volatility they produce.

RATING SENSITIVITIES

The performance of aircraft ABS can be affected by various factors,
which, in turn, could have an impact on the assigned ratings. Fitch
conducted multiple rating sensitivity analyses to evaluate the
impact of changes to a number of the variables in the analysis.
These sensitivity scenarios were also considered in determining
Fitch's recommended ratings.

LRF Stress Scenario

Increased competition, largely from newly established APAC lessors,
has contributed to declining lease rates in the aircraft leasing
market over the past few years. Additionally, certain variants have
been more prone to declines in values and lease rates due to
oversupply issues. For current aircraft fleet, this may be
exacerbated in the coming years due to the introduction of
replacement technology. Reflecting the LRFs represented in the
Horizon III pool as discussed earlier, Fitch performed a
sensitivity analysis assuming that LRFs would plateau after 11
years of age. Per Fitch's criteria LRF curve, this results in no
lease being executed at a LRF greater than 1.13%.

Under this scenario, total lifetime net cash flow declined by 7%
and expenses remained flat relative to the primary runs. This
scenario is more taxing in the latter stages of the transaction's
life as aircraft are assumed to not receive increasing LRFs as they
age into mid- and end-of-life status. Across the rating scenarios,
gross lease cash flow collected decreases approximately $37
million-$43 million.

Despite the declines, the increased stress is only like to cause a
downgrade to the series A notes, as the other series remain able to
pay in full by legal final maturity at their respective rating
stress levels. Series A may be downgraded by up to one rating
category.

Obligor Stress Scenario

Airlines across the globe are generally viewed as speculative
grade. While Fitch gives credit to available ratings of the initial
lessees in the pool, assumptions must be made for the unrated
lessees in the pool as well as all future unknown lessees. While
Fitch typically utilizes a 'B' assumption for most unrated lessees,
with some assumed to be 'CCC', Fitch evaluated a scenario in which
all current unrated airlines and all future airlines were assumed
to carry a 'CCC' rating and decline to 'CC' during recessionary
periods.

This scenario mimics a recessionary environment in which airlines
become susceptible to increased likelihood of default. This would
subject the aircraft in the pool to increased downtime and
expenses, as repossession and remarketing events would increase.

Under this scenario, total lifetime net cash flow declined by
12%-18% and expenses increased by approximately $17 million-$22
million from Fitch's primary scenarios.  Under this level of
stress, both the series A and series C may be downgraded by up to
one rating category each.

Technological Obsolescence Stress Scenario

All aircraft in the pool face replacement programs over the next
decade, particularly the A320ceo and B737 NG aircraft in the form
of A320neo and B737 MAX aircraft. Deliveries of these models have
begun and will be increasing in the coming years. While commercial
flights have not yet begun, the first A330neo has been delivered.
If received well, the increase in future deliveries could affect
the existing A330 fleet.

Certain appraisers have started to adjust MVs in response to this
replacement risk; the majority of the pool's market value
appraisals are slightly lower than HL BVs. Fitch believes current
generation aircraft are well insulated due to large operator bases
and the long lead time for full replacement, particularly when
considering conservative retirement ages and aggressive production
schedules for Airbus and Boeing new technology.

However, Fitch believes a sensitivity scenario is warranted to
address these risks. Therefore, Fitch utilized a scenario in which
demand, and thus values, of existing aircraft would fall
significantly due to the replacement technology. The first
recession was assumed to occur two years following close and all
recessionary value decline stresses were increased 10% at each
rating category. Fitch additionally utilized a 25% residual
assumption rather than the base level of 50% to stress end-of-life
proceeds for each asset in the pool. Lease rates drop fairly
significantly under this scenario, and aircraft are essentially
sold for scrap at the end of their useful lives.

Under this scenario, total lifetime net cash flow declined by
9%-11% and expected sales proceeds were less than half of amounts
under Fitch's primary runs. This scenario is more severe than the
others, resulting in two-category downgrades of series A and B, and
a one category downgrade of series C.


IMSCI 2016-7: Fitch Affirms Bsf Rating on Class G Certs
-------------------------------------------------------
Fitch Ratings affirmed eight classes of Institutional Mortgage
Securities Canada Inc.'s IMSCI 2016-7 commercial mortgage
pass-through certificates. All currencies are denominated in
Canadian dollars.

IMSCI 2016-7

                      Current Rating       Prior Rating

Class A-1 45779BEA3; LT AAAsf Affirmed;  previously at AAAsf

Class A-2 45779BEB1; LT AAAsf Affirmed;  previously at AAAsf

Class B 45779BED7;   LT AAsf Affirmed;   previously at AAsf

Class C 45779BDX4;   LT Asf Affirmed;    previously at Asf

Class D 45779BDY2;   LT BBBsf Affirmed;  previously at BBBsf

Class E 45779BDZ9;   LT BBB-sf Affirmed; previously at BBB-sf

Class F 45779BDU0;   LT BBsf Affirmed;   previously at BBsf

Class G 45779BDV8;   LT Bsf Affirmed;    previously at Bsf

KEY RATING DRIVERS

Overall Stable Loss Expectations: The ratings reflect strong
Canadian commercial real estate loan performance, including a low
delinquency rate and low historical losses of less than 0.1%, as
well as positive loan attributes such as short amortization
schedules, recourse to the borrower, and additional guarantors.
Overall pool performance continues exhibit stable performance, and
in line issuance expectations. As of the September 2019
distribution period, over 79.8% of the loans feature full or
partial recourse to the borrowers and/or sponsors. Four loans (6.1%
of total pool loan balance) are on the servicer's watchlist;
however, all of these loans have some form of recourse or exhibit
improving performance. An additional four loans (21%) are Fitch
Loans of Concern (FLOC).

During Fitch's prior rating action in 2018, the Innovation
Portfolio (5.9%) was flagged as a FLOC due to uncertainty regarding
largest tenant Blackberry's (47.1% NRA) lease expiration in May
2019. Blackberry vacated its space at lease expiration and the
borrower entered into a new lease agreement with Mitel Networks
Corporation. The new lease is for a 15-year term at a higher base
rent than the previous lease. Given the borrower has backfilled the
space at near-market rent, the loan is no longer considered a
FLOC.

Limited Change In Credit Enhancement: Credit enhancement has
improved slightly since the last rating action due to amortization
and the prepayment of two loans in January 2019. As of the
September 2019 distribution date, the pool's aggregate principal
balance has been reduced 11.5% to $311.7 million from $352.4
million at issuance with 36 loans remaining. The next scheduled
maturity is not until October 2021. The pool has no full or partial
interest only loans in the pool and no loans have been defeased.

Fitch Loans of Concern: Four loans have been flagged as Fitch Loans
of Concern.

Fitch is monitoring the number one loan in the pool, Portage Place
(8.1%), for delinquency. The loan is due for the August 2019
payment and is likely to transfer to the special servicer if not
made current. The loan has a history of late payments and has been
30 days delinquent several times in the past. The loan is full
recourse to the borrowing entity and 50% recourse to the sponsor,
Ron McCowan. Fitch will continue to monitor the loan.

The loan is secured by a 228,000-sf grocery anchored retail center
in Peterborough, ON. As of September 2018 the subject was 92.5%
occupied, down from 100% at YE 2016. The drop in occupancy is due
to a number of small tenants vacating the property at their
respective lease expirations. Due to fluctuating occupancy during
the 2017 fiscal year, subject revenue declined and resulted in a
June 2017 annualized NOI DSCR of 1.27x, a decline from 1.79x at YE
2016. Dundas & Lenworth Plaza (4.9%) is secured by a community
shopping center property located in Mississauga, ON. According to
the May 2019 rent roll the largest tenant, Elite Tile Imports
(17.3% NRA) lease is scheduled to expire in March 2020.
Additionally, between September 2019 and September 2020, 59.4% of
NRA is scheduled to rollover. Tenant rollover notwithstanding,
subject performance has been stable historically, maintaining 100%
occupancy on average since issuance. The NOI DSCR at YE 2018 was
1.51x, slightly above YE 2016 NOI DSCR of 1.41x. This loan has a
recourse carve out guarantee of $5 million.

Fortier Industrial Portfolio (4.9%) is secured by an
industrial/warehouse property located in the Pilon Industrial Park
of Saint Hubert, QC. According to a January 2019 Rent Roll, 47.7%
of NRA has tenants with expiring leases between January 2019 and
September 2020, including the largest tenant. The lease rollover is
very granular with 36 of the 37 expiring leases accounting for less
than 4% of NRA. The subject has historically exhibited stable
performance, maintaining 90.5% occupancy on average since issuance.
The NOI DSCR at YE 2018 was 1.77x, slightly above YE 2017 NOI DSCR
of 1.69x. This loan has no recourse.

The fourteenth largest loan in the pool, The Duke of Devonshire
(3.0%), is securitized by a 105-key, assisted senior living
property located in Ottawa, Ontario. As of the July 2019 rent roll,
the property was 52% occupied down from 95% at issuance and NOI has
fallen 72.6% since issuance, based on YE 2018 reporting. The YE
2018 NOI DSCR was 0.59x, down from 1.75x at issuance. According to
the borrower, the decline in occupancy is due to high rental rates
relative to the subject's market. The borrower is reportedly
developing a new sales strategy to improve performance. The sponsor
is Chartwell Retirement Residences (Chartwell), which assumed the
loan from the original sponsor in 2016. A lawsuit commenced between
Chartwell and the original sponsor regarding inconstancies in the
rent roll when the loan was assumed. Litigation is currently in
discovery. The loan has full recourse.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable due to generally
stable pool performance and expected continued paydown. The FLOCs
have been flagged for concerns related to potential and realized
occupancy decline. Additionally, Fitch remains concerned about the
delinquency history of the largest loan in the pool. Rating
downgrades are possible in the event of a significant decline in
overall pool performance or further deterioration in the FLOCs.
Future upgrades may be possible with stabilization of the FLOCs and
additional paydown.


JP MORGAN 2003-ML1: Fitch Affirms 'Dsf' Rating on Class N Certs
---------------------------------------------------------------
Fitch Ratings affirms three classes of J.P. Morgan Chase Commercial
Mortgage Securities Corp., commercial mortgage pass-through
certificates, series 2003-ML1.

J. P. Morgan Chase Commercial Mortgage Securities Corp. 2003-ML1
   
Class L 46625MWF2; LT BBsf Affirmed; previously at BBsf

Class M 46625MWG0; LT Csf Affirmed;  previously at Csf

Class N 46625MWH8; LT Dsf Affirmed;  previously at Dsf

KEY RATING DRIVERS

Specially Serviced Loan: The pool is highly concentrated with only
five of the original 123 loans remaining, the largest of which
(77.24% of the pool) remains in special servicing and is REO. The
asset is a 264,560 sf community shopping center located in Racine,
WI. The loan was transferred to special servicing in December 2012
due to the borrower's request for loan modification stemming from
cash flow issues. The asset became REO in February 2015. As of YE
2018, the asset was 42% occupied by only one tenant, Home Depot,
with an April 2024 lease expiration. The servicer reported NOI
decreased 51% from YE 2017 to YE 2018 and 33% from YE 2016 to YE
2017. The NOI debt service coverage ratio decreased to 0.31x at YE
2018 from 0.62x at YE 2017 and 0.93x at YE 2016. The property is
not currently listed for sale at this time.

Fitch performed a sensitivity analysis with regard to this loan,
given the pool's concentration. Assuming a full loss to this loan,
class L would not experience a loss.

Decreased Loss Expectations: Fitch's expected losses for the trust
have decreased since the last rating action as a result of an
updated appraisal value for the REO asset, which is the primary
contributor to loss expectations. This loan was in special
servicing at the last rating action and remains the only loan in
special servicing. The property occupancy remains unchanged from
the last rating action. Despite the decrease in Fitch's overall
loss expectations, losses associated with this loan are still
expected to inevitably impact classes M and N.

Increased Credit Enhancement: Offsetting some of the concern
regarding exposure to the largest loan, credit enhancement has
increased due to continued amortization. Since issuance, the
transaction has paid down 98.66%, and 0.16% since the last rating
action.

RATING SENSITIVITIES

The Rating Outlook for class L remains Stable. Approximately 38% of
this class is covered by fully defeased collateral and repayment of
the remainder of the class balance is reliant on low-leverage,
fully amortizing loans. Future upgrades are not considered likely
due to the collateral quality of the remaining loans in the pool.
In the unlikely event that the specially serviced loan experiences
a loss greater than 100%, class L could be downgraded.

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

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


JP MORGAN 2004-C3: Moody's Raises Rating on Class H Certs to B3(sf)
-------------------------------------------------------------------
Moody's Investors Service upgraded the rating on one class and
affirmed the rating on one class in J.P. Morgan Chase Commercial
Mortgage Securities Corp. 2004-C3, Commercial Mortgage Pass-Through
Certificates, Series 2004-C3 as follows:

Cl. H, Upgraded to B3 (sf); previously on Apr 19, 2018 Upgraded to
Caa2 (sf)

Cl. J, Affirmed C (sf); previously on Apr 19, 2018 Affirmed C (sf)

RATINGS RATIONALE

The rating on principal and interest class, Cl. H, was upgraded
based primarily on an increase in credit support resulting from
loan paydowns and amortization. The deal has paid down 25% since
Moody's last review.

The rating on P&I class, Cl. J, was affirmed because the ratings
are consistent with Moody's expected loss plus realized losses. Cl.
J has already experienced a 74% realized loss as result of
previously liquidated loans.

Moody's rating action reflects a base expected loss of 16.5% of the
current pooled balance, compared to 11.3% at Moody's last review.
Moody's base expected loss plus realized losses is now 5.1% of the
original pooled balance, compared to 5.2% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the September 15, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 99% to $14.0 million
from $1.52 million at securitization. The certificates are
collateralized by six mortgage loans ranging in size from 1% to 56%
of the pool. Two loans, constituting 11% of the pool, have defeased
and are secured by US government securities.

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

One loan, constituting 16% of the pool, is on the master servicer's
watchlist. The watchlist includes loans that meet certain portfolio
review guidelines established as part of the CRE Finance Council
(CREFC) monthly reporting package. As part of Moody's ongoing
monitoring of a transaction, the agency reviews the watchlist to
assess which loans have material issues that could affect
performance.

Twenty-two loans have been liquidated from the pool, contributing
to an aggregate realized loss of $75.4 million (for an average loss
severity of 58%).

Moody's received full year 2017 operating results for 100% of the
pool, and full or partial year 2018 operating results for 85% of
the pool (excluding specially serviced and defeased loans).

The top three conduit loans represent 84% of the pool balance. The
largest loan is the 9601 Renner Boulevard Loan, formerly known as
the T-Mobile -- Lenexa KS Loan ($7.8 million -- 55.8% of the pool),
which is secured by a suburban office property subleased to Quest
Diagnostics through October 2019 (two months prior to the loan's
maturity date in December 2019). Quest Diagnostic vacated in
February 2019 and has sublet the space. The property was previously
operated as a 600-seat call center by T-Mobile US Inc. Moody's
value incorporated a lit/dark analysis on the property to account
for single tenancy risk. Moody's LTV and stressed DSCR are 159% and
0.63X, respectively.

The second largest loan is the Shops at Whitestone Loan ($2.2
million -- 15.8% of the pool), which is secured by a 36,000 square
foot (SF) unanchored retail center in Cedar Park, Texas
(approximately 20 miles north of Austin). The property was 82%
leased as of December 2018, compared to 72% leased as of September
2017. The fully amortizing loan has amortized 61% since
securitization and matures in January 2025. Moody's LTV and
stressed DSCR are 46% and 2.06X, respectively, compared to 48% and
1.99X at the last review.

The third largest loan is the Sandalwood MHP Loan ($1.7 million --
12.4% of the pool), which is secured by a 183-unit manufactured
housing community located in Santa Ana, California. The property
was 94% leased as of September 2018, compared to 95% leased as of
December 2017. The fully amortizing loan has amortized 66% since
securitization and matures in December 2023. Moody's LTV and
stressed DSCR are 18% and greater than 4.00X, respectively,
compared to 22% and greater than 4.00X at the last review.


JP MORGAN 2017-FL11: DBRS Confirms BB(low) Rating on Cl. E Certs
----------------------------------------------------------------
DBRS Limited changed the trends on two classes of Commercial
Mortgage Pass-Through Certificates, Series 2017-FL11 (the
Certificates) issued by J.P. Morgan Chase Commercial Mortgage
Securities Trust 2017-FL11. DBRS Morningstar also confirmed the
ratings on all classes of the Certificates as follows:

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

All trends are now Stable as Classes B and C have been changed to
Stable from Positive. Stable trends were assigned as Cooper Hotel
Portfolio (Prospectus ID#2, representing 27.0% of the current trust
balance) as the reported net cash flow (NCF) remained below the
DBRS Morningstar Term NCF derived at issuance. Additionally, One
Westchase Center (Prospectus ID#6, 12.2% of the current trust
balance) failed to meet the minimum debt yield requirement in 2018
and is located in a weak office submarket of the Houston
metropolitan statistical area (MSA).

The ratings confirmations reflect the overall stable performance
exhibited since issuance. The collateral consisted of seven
floating-rate mortgages secured by 20 commercial properties with a
total mortgage loan amount of $519.1 million, which was divided up
into two collateral groups. DBRS Morningstar only rated one of the
collateral groups that consisted of six loans secured by 19
commercial properties with a collective mortgage balance of $496.6
million. As of the September 2019 remittance, five of the original
six loans remain in the trust with an aggregate principal balance
$386.6 million, representing a collateral reduction of 22.2% since
issuance due to loan repayment. All loans in the trust are
structured with two-year terms and three one-year extension
options. Four of the loans within the trust exercised the first
one-year extension and the One Westchase Center is in the process
of exercising the extension.

All loans within the trust reported year-end (YE) 2018 financials
and partial year 2019 financials. The partial year 2019 financials
reported a weighted average (WA) debt service coverage ratio (DSCR)
of 2.52 times (x) compared with the WA YE2018 DSCR of 2.76x and WA
DBRS Morningstar Term DSCR of 2.30x. The improvement over the DBRS
Morningstar Term DSCR derived at issuance was primarily due to the
performances of Bank of America Campus (Prospectus ID#4; 18.9% of
the trust balance), Hyatt Regency Jacksonville Riverfront
(Prospectus ID#5; 17.7% of the trust balance) and The Centre at
Purchase (Prospectus ID#3; 24.3% of trust balance). The partial
year 2019 DSCRs were lower primarily due to an increase in interest
rates. The pool benefits from all properties being in core suburban
markets and all loans reporting high DSCRs. In addition to being
concentrated by loan size, the pool is also concentrated by
property type, as two loans (44.6% of the current trust balance)
are secured by hotel properties, while the remaining three loans
(55.4% of the current trust balance) are secured by office
properties.

As of the September 2019 remittance, two loans (Cooper Hotel
Portfolio and One Westchase Center), representing 39.1% of the
current trust balance, are on the servicer's watchlist due to
upcoming loan maturities. Both loans have either been extended or
in the process of being extended, and DBRS Morningstar is
monitoring the One Westchase Center loan as the property failed to
achieve a minimum debt yield requirement and a cash sweep has been
activated. The 12-story office structure is in the Westchase office
submarket of the Houston MSA, which reported a high vacancy rate of
31.9% for Class A office properties, per a Q2 2019 Reis report. The
property reported an August 2019 occupancy rate of 83.4%; however,
14 tenants (14.3% of net rentable area) have lease expirations
prior to YE2021. The YE2018 NCF of $3.9 million was well below the
YE2017 NCF of $4.4 million due to rent abatements from recent lease
renewals, indicating the borrower is providing concessions to
tenants to remain at the property. The upcoming lease rollover and
declining submarket conditions are being monitored by DBRS
Morningstar.

At issuance, DBRS Morningstar shadow-rated one loan, the Cooper
Hotel Portfolio, as investment grade. With this review, DBRS
Morningstar confirms that the performance of the loan remains
consistent with the investment-grade shadow rating.

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


JP MORGAN 2019-LTV3: DBRS Gives Prov. B Rating on Class B-5 Certs
-----------------------------------------------------------------
DBRS, Inc. assigned the following provisional ratings to the
Mortgage Pass-Through Certificates, Series 2019-LTV3 (the
Certificates) to be issued by J.P. Morgan Mortgage Trust
2019-LTV3:

-- $375.8 million Class A-1 at AAA (sf)
-- $341.6 million Class A-2 at AAA (sf)
-- $244.8 million Class A-3 at AAA (sf)
-- $244.8 million Class A-3-A at AAA (sf)
-- $244.8 million Class A-3-X at AAA (sf)
-- $183.6 million Class A-4 at AAA (sf)
-- $183.6 million Class A-4-A at AAA (sf)
-- $183.6 million Class A-4-X at AAA (sf)
-- $61.2 million Class A-5 at AAA (sf)
-- $61.2 million Class A-5-A at AAA (sf)
-- $61.2 million Class A-5-X at AAA (sf)
-- $153.3 million Class A-6 at AAA (sf)
-- $153.3 million Class A-6-A at AAA (sf)
-- $153.3 million Class A-6-X at AAA (sf)
-- $91.5 million Class A-7 at AAA (sf)
-- $91.5 million Class A-7-A at AAA (sf)
-- $91.5 million Class A-7-X at AAA (sf)
-- $30.3 million Class A-8 at AAA (sf)
-- $30.3 million Class A-8-A at AAA (sf)
-- $30.3 million Class A-8-X at AAA (sf)
-- $46.0 million Class A-9 at AAA (sf)
-- $46.0 million Class A-9-A at AAA (sf)
-- $46.0 million Class A-9-X at AAA (sf)
-- $15.2 million Class A-10 at AAA (sf)
-- $15.2 million Class A-10-A at AAA (sf)
-- $15.2 million Class A-10-X at AAA (sf)
-- $96.8 million Class A-11 at AAA (sf)
-- $96.8 million Class A-11-X at AAA (sf)
-- $96.8 million Class A-12 at AAA (sf)
-- $96.8 million Class A-13 at AAA (sf)
-- $34.2 million Class A-14 at AAA (sf)
-- $34.2 million Class A-15 at AAA (sf)
-- $269.3 million Class A-16 at AAA (sf)
-- $106.5 million Class A-17 at AAA (sf)
-- $375.8 million Class A-X-1 at AAA (sf)
-- $375.8 million Class A-X-2 at AAA (sf)
-- $96.8 million Class A-X-3 at AAA (sf)
-- $34.2 million Class A-X-4 at AAA (sf)
-- $6.8 million Class B-1 at AA (sf)
-- $6.8 million Class B-1-A at AA (sf)
-- $6.8 million Class B-1-X at AA (sf)
-- $15.6 million Class B-2 at A (sf)
-- $15.6 million Class B-2-A at A (sf)
-- $15.6 million Class B-2-X at A (sf)
-- $10.7 million Class B-3 at BBB (sf)
-- $10.7 million Class B-3-A at BBB (sf)
-- $10.7 million Class B-3-X at BBB (sf)
-- $8.5 million Class B-4 at BB (sf)
-- $1.9 million Class B-5 at B (sf)

Classes A-3-X, A-4-X, A-5-X, A-6-X, A-7-X, A-8-X, A-9-X, A-10-X,
A-11-X, A-X-1, A-X-2, A-X-3, A-X-4, B-1-X, B-2-X, B-3-X, B-X, B-6-Y
and B-6-Z are interest-only notes. The class balances represent
notional amounts.

Classes A-1, A-2, A-3, A-3-X, A-3-A, A-4, A-4-A, A-4-X, A-5, A-5-A,
A-5-X, A-6, A-6, A-7, A-7-A, A-7-X, A-8, A-9, A-10, A-12, A-13,
A-14, A-16, A-17, A-X-2, A-X-3, B-1, B-2, B-3, B-X, B-6-Y and B-6-Z
are exchangeable notes. These classes can be exchanged for
combinations of exchange notes as specified in the offering
documents.

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

The AAA (sf) rating on the Class A-1 Notes reflects 10.65% of
credit enhancement provided by subordinated notes in the pool. The
AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect
8.00%, 5.50%, 3.25%, 1.55% and 0.85% of credit enhancement,
respectively.

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

The Certificates are backed by 675 loans with a total principal
balance of $426,992,185 as of the Cut-Off Date (October 1, 2019).

Compared with other post-crisis prime pools, this portfolio
consists of higher loan-to-value (LTV), first-lien, fully
amortizing fixed-rate mortgages with original terms to maturity of
30 years. The weighted-average original combined LTV (CLTV) for the
portfolio is 88.5%, and almost the entire pool (90.5%) 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, low debt-to-income ratios, robust income and
reserves and other strengths detailed in the Key Probability of
Default Drivers section of the report.

The mortgage loans were originated by United Shore Financial
Services LLC (83.1%) and various other originators, each comprising
less than 5.0% of the mortgage loans. Approximately 2.73% of the
loans sold to the mortgage loan seller were acquired by MAXEX
Clearing LLC, which purchased such loans from the related
originators or an unaffiliated third party that directly or
indirectly purchased such loans from the related originators.

The mortgage loans will be serviced or sub-serviced by Shellpoint
Mortgage Servicing (SMS; 87.4%); Cenlar, FSB (12.5%); and
Nationstar Mortgage LLC (Nationstar; 0.1%). Servicing will be
transferred from SMS to JPMorgan Chase Bank, N.A. (JPMCB; rated AA
with a Stable trend by DBRS Morningstar) on the servicing transfer
date (December 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 will act as the Master Servicer. Citibank, N.A. (rated
AA (low) with a Stable trend by DBRS Morningstar) will act as
Securities Administrator and Delaware Trustee. Wells Fargo Bank,
N.A. (rated AA with a Stable trend by DBRS Morningstar) 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&Ws to expire within three to six years after the
Closing Date. The framework is perceived by DBRS Morningstar to be
limiting compared with traditional lifetime R&W standards in
certain DBRS Morningstar-rated securitizations. To capture the
perceived weaknesses in the R&W framework, DBRS Morningstar 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.


JP MORGAN 2019-LTV3: Moody's Gives Prov. B3 Rating on Cl. B-5 Debt
------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to 33
classes of residential mortgage-backed securities issued by J.P.
Morgan Mortgage Trust 2019-LTV3. The ratings range from (P)Aaa (sf)
to (P)B3 (sf).

The certificates are backed by 675 30-year, fully-amortizing
fixed-rate mortgage loans with a total balance of $426,992,185 as
of the October 1st cut-off date. GSE-eligible loans comprise only
2.06% of the pool balance. All the loans are subject to the
Qualified Mortgage and Ability-to-Repay rules and are categorized
as either QM-Safe Harbor or QM-Agency Safe Harbor.

JPMMT 2019-LTV3 is the fourth JPMMT transaction with the LTV
designation. The weighted average loan-to-value ratio of the
mortgage pool is approximately 88.4%, which is in line with those
of the other JPMMT LTV transactions, but higher than those of
previous JPMMT transactions which had WA LTVs of about 78.6% on
average. All loans have LTVs of between 80% and 90%, and about
83.7% of the loans by balance have LTVs greater than 85%. None of
the loans in the pool have mortgage insurance. The other credit
characteristics of the loans in the pool are generally comparable
to that of recent JPMMT transactions.

United Shore Financial Services, LLC d/b/a United Wholesale
Mortgage and Shore Mortgage (United Shore) originated 83.1% of the
mortgage loans by balance. The remaining originators each account
for less than 3.0% of the aggregate principal balance of the loans
in the pool. About 79.5% of the mortgage pool was originated under
United Shore's High Balance Nationwide program, in which, using the
Desktop Underwriter (DU) automated underwriting system, loans are
underwritten to Fannie Mae guidelines with overlays. The loans
receive a DU Approve Ineligible feedback due to the loan amount
exceeding the GSE limit for certain markets.

At closing, NewRez LLC f/k/a New Penn Financial, LLC d/b/a
Shellpoint Mortgage Servicing (Shellpoint) will service
approximately 87.4% of the pool and United Shore will service 12.6%
of the pool. With respect to the Mortgage Loans serviced by United
Shore, either Cenlar, FSB or Nationstar Mortgage LLC d/b/a Mr.
Cooper Group Inc. (Mr. Cooper) will act as the subservicer. A
subservicer performs substantially all of the servicing obligations
(other than advancing obligations) for certain of the mortgage
loans under a subservicing agreement with the related servicer. The
servicing fee for loans serviced by Shellpoint and United Shore
will be based on a step-up incentive fee structure with a $40 base
servicing fee and additional fees for servicing delinquent and
defaulted loans. Shellpoint will be an interim servicer from the
closing date until the servicing transfer date, which is expected
to occur on or about December 1st, 2019 (or such later date as
determined by the issuing entity and JPMCB). After the servicing
transfer date, JPMorgan Chase Bank, National Association will
assume servicing responsibilities for the mortgage loans previously
serviced by Shellpoint.

Nationstar Mortgage LLC will be the master servicer and Citibank,
N.A. will be the securities administrator and Delaware trustee.
Pentalpha Surveillance LLC will be the representations and
warranties breach reviewer. Distributions of principal and interest
and loss allocations are based on a typical shifting interest
structure that benefits from senior and subordination floors.

The complete rating actions are as follows:

Issuer: J.P. Morgan Mortgage Trust 2019-LTV3

Cl. A-1, Assigned (P)Aaa (sf)

Cl. A-2, Assigned (P)Aaa (sf)

Cl. A-3, Assigned (P)Aaa (sf)

Cl. A-3-A, Assigned (P)Aaa (sf)

Cl. A-4, Assigned (P)Aaa (sf)

Cl. A-4-A, Assigned (P)Aaa (sf)

Cl. A-5, Assigned (P)Aaa (sf)

Cl. A-5-A, Assigned (P)Aaa (sf)

Cl. A-6, Assigned (P)Aaa (sf)

Cl. A-6-A, Assigned (P)Aaa (sf)

Cl. A-7, Assigned (P)Aaa (sf)

Cl. A-7-A, Assigned (P)Aaa (sf)

Cl. A-8, Assigned (P)Aaa (sf)

Cl. A-8-A, Assigned (P)Aaa (sf)

Cl. A-9, Assigned (P)Aaa (sf)

Cl. A-9-A, Assigned (P)Aaa (sf)

Cl. A-10, Assigned (P)Aaa (sf)

Cl. A-10-A, Assigned (P)Aaa (sf)

Cl. A-11, Assigned (P)Aaa (sf)

Cl. A-12, Assigned (P)Aaa (sf)

Cl. A-13, Assigned (P)Aaa (sf)

Cl. A-14, Assigned (P)Aa1 (sf)

Cl. A-15, Assigned (P)Aa1 (sf)

Cl. A-16, Assigned (P)Aaa (sf)

Cl. A-17, Assigned (P)Aaa (sf)

Cl. B-1, Assigned (P)Aa3 (sf)

Cl. B-1-A, Assigned (P)Aa3 (sf)

Cl. B-2, Assigned (P)A2 (sf)

Cl. B-2-A, Assigned (P)A2 (sf)

Cl. B-3, Assigned (P)Baa3 (sf)

Cl. B-3-A, Assigned (P)Baa3 (sf)

Cl. B-4, Assigned (P)Ba3 (sf)

Cl. B-5, Assigned (P)B3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 1.45%
in a base scenario and reaches 13.35% at a stress level consistent
with the Aaa (sf) ratings.

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

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

Aggregation/Origination Quality

Moody's considers J.P. Morgan Mortgage Acquisition Corp.'s (JPMMAC)
aggregation platform to be adequate and Moody's did not apply a
separate loss-level adjustment for aggregation quality. In addition
to reviewing JPMMAC as an aggregator, Moody's has also reviewed the
originators contributing a significant percentage of the collateral
pool (above 10%). For these originators, Moody's reviewed their
underwriting guidelines and their policies and documentation (where
available). Moody's increased its base case and Aaa (sf) loss
expectations for certain originators of non-conforming loans where
Moody's does not have clear insight into the underwriting
practices, quality control and credit risk management. Moody's did
not make an adjustment for GSE-eligible loans, regardless of the
originator, since those loans were underwritten in accordance with
GSE guidelines.

United Shore: Its originator quality analysis generally consists of
a review of the originator's past loan performance, and its
policies and practices, which could affect future loan performance.
While USFS' guidelines are generally in line with its credit
neutral criteria, Moody's considers the origination quality of
United Shore to be relatively weaker than that of peers due to lack
of loan performance information by product type and information
related to United Shore's quality control policies and procedures
with reference to how they evaluate a borrower's ability and
willingness to repay the loan, and assess the collateral value,
particularly with respect to its High Balance Nationwide program.
The loans originated by United Shore were mostly underwritten in
accordance with Fannie Mae guidelines through DU (High Balance
Nationwide program) with overlays and a few were underwritten to
their prime jumbo guidelines. Moody's notes that United Shore
originated loans have been included in several prime jumbo
securitizations that Moody's has rated. Performance of prime jumbo
securitizations to date shows minimal delinquencies and even less
cumulative losses. United Shore's guidelines are generally in line
with its credit neutral criteria. All prime jumbo loans must be
manually underwritten and fully documented, and no streamline
documentation or documentation waivers based on agency AUS
decisions are permitted. United Shore has overlays for loan amount,
income and employment. Underwriting guidelines require adherence to
CFPB rules for ATR.

Servicing arrangement

Moody's considers the overall servicing arrangement for this pool
to be adequate given the strong servicing arrangement of the
servicers, as well as the presence of a strong master servicer to
oversee the servicers. The servicers are contractually obligated to
the issuing entity to service the related mortgage loans. However,
the servicers may perform their servicing obligations through
sub-servicers. In this transaction, Nationstar (rated B2) will act
as the master servicer. The servicers are required to advance
principal and interest on the mortgage loans. To the extent that
the servicers are unable to do so, the master servicer will be
obligated to make such advances. In the event that the master
servicer, Nationstar, is unable to make such advances, the
securities administrator, Citibank (rated Aa3) will be obligated to
do so to the extent such advance is determined by the securities
administrator to be recoverable.

JPMCB (servicer): JPMCB, a wholly-owned bank subsidiary of JPMorgan
Chase & Co., is a seasoned servicer with over 20 years of
experience servicing residential mortgage loans and has
demonstrated adequate servicing ability as a primary servicer of
prime residential mortgage loans. JPMCB also is the originator with
respect to the JPMCB serviced mortgage loans and is an affiliate of
the mortgage loan seller, of the depositor and of J.P. Morgan
Securities LLC, an initial purchaser. Third-party mortgage loans
(including those serviced by JPMCB for certain unconsolidated
affiliates of JPMCB) serviced by JPMCB (by aggregate unpaid
principal balance) were $519.6 billion as of December 31, 2018. In
addition to servicing mortgage loans securitized by the depositor,
JPMCB also services mortgage loans that are held in its portfolio
and whole loans that are sold to a variety of investors.

Shellpoint (interim servicer): Shellpoint has demonstrated adequate
servicing ability as a primary servicer of prime residential
mortgage loans. Shellpoint, an approved servicer in good standing
with Ginnie Mae, Fannie Mae and Freddie Mac, has the necessary
processes, staff, technology and overall infrastructure in place to
effectively service the transaction.

Nationstar (master servicer): Nationstar is the master servicer for
the transaction and provides oversight of the servicers. Nationstar
is a mortgage servicer and lender formed in 1994 originally under
the name Nova Credit Corporation that engages in servicing
activities for itself as well as various third parties, primarily
as a "high touch" servicer and originating primarily GSE-eligible
residential mortgage loans. On August 21, 2017 Nationstar Mortgage
became known as Mr. Cooper for its mortgage servicing and
originations operations. Moody's considers Nationstar's master
servicing operation to be above average compared to its peers.
Nationstar has strong reporting and remittance procedures and
strong compliance and monitoring capabilities. The company's senior
management team has on average more than 20 years of industry
experience, which provides a solid base of knowledge and
leadership. Nationstar's oversight encompasses loan administration,
default administration, compliance, and cash management. Nationstar
is an indirectly held, wholly owned subsidiary of Nationstar
Mortgage Holdings Inc. Moody's rates Nationstar at B2.

Collateral Description

JPMMT 2019-LTV3 is a securitization of a pool of 675 30-year,
fully-amortizing fixed-rate mortgage loans with a total balance of
$426,992,185 as of the cut-off date, with a WA remaining term to
maturity of 356 months and a WA seasoning of 4 months. The WA
current FICO score of the borrowers in the pool is 758. The WA LTV
ratio of the mortgage pool is 88.4%, which is in line with those of
the other JPMMT LTV transactions, but higher than those of previous
JPMMT transactions which had WA LTVs of about 78.6% on average. All
loans have LTVs of between 75% and 90%, and about 83.7% of the
loans by balance have LTVs greater than 85%. None of the loans in
the pool have mortgage insurance. The WA mortgage rate of the pool
is 4.7%. The mortgage loans in the pool were originated mostly in
California (28.4% by loan balance).

United Shore originated 83.1% of the mortgage loans by balance. The
remaining originators each account for less than 3.0% of the
aggregate principal balance of the loans in the pool. About 79.5%
of the mortgage pool was originated under United Shore's High
Balance Nationwide program, in which, using the Desktop Underwriter
(DU) automated underwriting system, loans are underwritten to
Fannie Mae guidelines with overlays. The loans receive a DU Approve
Ineligible feedback due to the loan amount exceeding the GSE limit
for certain markets.

Servicing Fee Framework

The servicing fee will be based on a step-up incentive fee
structure with a monthly base fee of $40 per loan and additional
fees for servicing delinquent and defaulted loans. Shellpoint will
act as interim servicer for the JPMCB mortgage loans until the
servicing transfer date.

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

The incentive structure includes an initial monthly base servicing
fee of $40 for all performing loans and increases according to a
pre-determined delinquent and incentive servicing fee schedule. The
delinquent and incentive servicing fees will be deducted from the
available distribution amount and Class B-6 net WAC. The Class B-6
is first in line to absorb any increase in servicing costs above
the base servicing fee. Once the Class B-6 is written off, the
Class B-5 will absorb any increase in servicing costs. The
transaction does not have a servicing fee cap, so, in the event of
a servicer replacement, any increase in the base servicing fee
beyond the current fee will be paid out of the available
distribution amount.

Third-party Review

Three third-party review (TPR) firms verified the accuracy of the
loan-level information that Moody's received from the sponsor.
These firms conducted detailed credit, regulatory compliance,
property valuation and data integrity reviews on 100% of the
mortgage pool.

The TPR results indicated compliance with the originators'
underwriting guidelines for the majority of loans, no material
compliance issues, and no appraisal defects. The loans that had
exceptions to the originators' underwriting guidelines had strong
documented compensating factors such as low DTIs, low LTVs, high
reserves, high FICOs, or clean payment histories. The TPR firms
also identified minor compliance exceptions for reasons such as
inadequate RESPA disclosures (which do not have assignee liability)
and TILA/RESPA Integrated Disclosure (TRID) violations related to
fees that were out of variance but then were cured and disclosed.
Besides the adjustment for loans for which the only third-party
valuation check was an AVM or a CU risk score for prime jumbo
non-conforming loans, Moody's did not make any adjustments to its
expected or Aaa (sf) loss levels due to the TPR results.

The TPR firms compared third-party valuation products to the
original appraisals. Property valuation was conducted using, among
other things, a field review, a third-party collateral desk
appraisal (CDA), broker price opinion (BPO), automated valuation
model (AVM) or a Collateral Underwriter (CU) risk score. In some
cases, for loans that had a CU risk score of 2.5 or less, a third
party valuation product was not ordered. Of note, Moody's considers
the use of only a CU risk score for non-conforming loans to be
credit negative due to (1) the lack of human intervention which
increases the likelihood of missing emerging risk trends, (2) the
limited track record of the software and limited transparency into
the model and (3) GSE focus on non-jumbo loans which may lower
reliability on jumbo loan appraisals. Moody's applied an adjustment
to the loss for such loans since the sample size and valuation
result of the loans that were reviewed using a third-party
valuation product such as a CDA and field review (excluding AVMs)
were insufficient. In addition, there were loans for which the
original appraisal was evaluated using only an AVM. Moody's applied
an adjustment to the loss for such loans, since Moody's considers
AVM valuations to be less accurate than desk reviews and field
reviews due to inherent data limitations that could adversely
impact the reliability of AVM results. Besides the adjustment for
loans for which the only third-party valuation check was an AVM or
a CU risk score for prime jumbo non-conforming loans, Moody's did
not make any other adjustments to its loss levels for appraisal
quality issues.

Reps & Warranties

JPMMT 2019-LTV3's R&W framework is in line with that of other JPMMT
transactions where an independent reviewer is named at closing, and
the costs and manner of review are clearly outlined at issuance.
Its review of the R&W framework considers the financial strength of
the R&W providers, scope of R&Ws (including qualifiers and sunsets)
and enforcement mechanisms.

The R&W providers vary in financial strength. Moody's made no
adjustments to the loans for which JPMMAC (an affiliate of JPMorgan
Chase Bank, N.A. which is rated Aa2) provided R&Ws since they are
affiliates of highly rated entities. In contrast, the rest of the
R&W providers are unrated and/or financially weaker entities and
Moody's applied an adjustment to the loans for which these entities
provided R&Ws. JPMMAC will not backstop any R&W providers who may
become financially incapable of repurchasing mortgage loans.

For loans that JPMMAC acquired via the MaxEx platform, MaxEx under
the assignment, assumption and recognition agreement with JPMMAC,
will make the R&Ws. The R&Ws provided by MaxEx to JPMMAC and
assigned to the trust are in line with the R&Ws found in the JPMMT
transactions. No other party will backstop or be responsible for
backstopping the representations and warranties of any originator.
Additionally, no party will be required to repurchase or substitute
any mortgage loan until such loan has gone through the review
process described.

Other Transaction Parties

The Delaware trustee and securities administrator is Citibank. The
custodian is Wells Fargo Bank, N.A. As master servicer, Nationstar
is responsible for servicer oversight, the termination of servicers
and the appointment of successor servicers. Nationstar is committed
to act as successor servicer if no other successor servicer can be
engaged.

Transaction Structure

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

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

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

The floating rate note coupons reference LIBOR which is earmarked
for withdrawal after 2021. Intending to facilitate transition to an
alternative reference rate, the transaction documents incorporate
fallback language addressing both the timing of transition and the
choice of alternative reference rate. The fallback language is
generally consistent with the Federal Reserve's Alternative
Reference Rates Committee (ARRC) template language, published on
May 31, 2019. As such, if the securities administrator notifies the
depositor or that it cannot determine one-month LIBOR in accordance
with the methods prescribed in the sale and servicing agreement and
a benchmark transition event has not yet occurred, one-month LIBOR
for such accrual period will be one-month LIBOR as calculated for
the immediately preceding accrual period. Following the occurrence
of a benchmark transition event, a benchmark other than one-month
LIBOR will be determined by the depositor for purposes of
calculating the pass-through rate on the class A-11 certificates,
and such benchmark replacement will replace one-month LIBOR and
will be the benchmark for the next following accrual period and
each accrual period thereafter (unless and until a subsequent
benchmark transition event is determined to have occurred). Any
determination made by the depositor with respect to the occurrence
of a benchmark transition event or a benchmark replacement, and any
calculation by the securities administrator of the applicable
benchmark for an accrual period, will be final and binding on the
certificate holders in the absence of manifest error.

Tail Risk & Subordination Floor

This deal has a standard shifting-interest structure, with a
subordination floor to protect against losses that occur late in
the life of the pool when relatively few loans remain (tail risk).
When the total senior subordination is less than 1.40% of the
original pool balance, the subordinate bonds do not receive any
principal and all principal is then paid to the senior bonds. In
addition, if the subordinate percentage drops below 12.00% of
current pool balance, the senior distribution amount will include
all principal collections and the subordinate principal
distribution amount will be zero. The subordinate bonds themselves
benefit from a floor. When the total current balance of a given
subordinate tranche plus the aggregate balance of the subordinate
tranches that are junior to it amount to less than approximately
0.90% of the original pool balance, those tranches do not receive
principal distributions. Principal those tranches would have
received are directed to pay more senior subordinate bonds
pro-rata.

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

Down

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

Up

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

Methodology

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


JPMBB COMMERCIAL 2013-C12: Moody's Affirms B2 Rating on Cl. F Debt
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings on 10 classes in
JPMBB Commercial Mortgage Securities Trust 2013-C12 as follows:

Cl. A-4, Affirmed Aaa (sf); previously on Apr 12, 2018 Affirmed Aaa
(sf)

Cl. A-5, Affirmed Aaa (sf); previously on Apr 12, 2018 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Apr 12, 2018 Affirmed
Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on Apr 12, 2018 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa3 (sf); previously on Apr 12, 2018 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on Apr 12, 2018 Affirmed A3
(sf)

Cl. D, Affirmed Baa3 (sf); previously on Apr 12, 2018 Affirmed Baa3
(sf)

Cl. E, Affirmed Ba2 (sf); previously on Apr 12, 2018 Affirmed Ba2
(sf)

Cl. F, Affirmed B2 (sf); previously on Apr 12, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Apr 12, 2018 Affirmed
Aaa (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

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

The rating on one interest only (IO) class was affirmed based on
the credit quality of the referenced classes.

Moody's rating action reflects a base expected loss of 3.7% of the
current pooled balance, compared to 3.6% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.8% of the
original pooled balance, compared to 3.1% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the September 15, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 29% to $957 million
from $1.34 billion at securitization. The certificates are
collateralized by 65 mortgage loans ranging in size from less than
1% to 12% of the pool, with the top ten loans (excluding
defeasance) constituting 53% of the pool. One loan, constituting
10% of the pool, has an investment-grade structured credit
assessment. Eleven loans, constituting 8% of the pool, have
defeased and are secured by US government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 19, compared to a Herf of 26 at Moody's last
review.

Four loans, constituting 2% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

One loan, constituting 1% of the pool, is currently in special
servicing. The specially serviced loan is the Park 50 Loan ($12.3
million -- 1.3% of the pool), which is secured by 13 flex/office
and flex/industrial buildings located approximately 16 miles
northeast of downtown Cincinnati, Ohio. The loan transferred to
special servicing in August 2017 for delinquent payments and the
REO title date was in October 2018.

Moody's has also assumed a high default probability for one poorly
performing loan, constituting 1% of the pool. Moody's has estimated
an aggregate loss of $8 million from the specially serviced and
troubled loans (35% expected loss on average).

Moody's received full year 2017 operating results for 83% of the
pool, and full or partial year 2018 operating results for 80% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 94%, compared to 96% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 17% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 9.6%.

Moody's actual and stressed conduit DSCRs are 1.66X and 1.16X,
respectively, compared to 1.67X and 1.13X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The loan with a structured credit assessment is the Americold Cold
Storage Portfolio ($91.5 million -- 9.6% of the pool), which
represents a pari-passu portion of a $183.1 million mortgage loan.
The loan is secured by a portfolio of 15 cold storage facilities
located across nine U.S. states, with a total storage capacity of
3.6 million square feet (SF). The loan sponsor is Americold Realty
Trust, the largest US operator of cold storage facilities. The
property is also encumbered by $102 million of mezzanine debt. The
loan benefits from amortization and Moody's structured credit
assessment and stressed DSCR are a2 (sca.pd) and 1.92X,
respectively.

The top three conduit loans represent 26% of the pool balance. The
largest loan is the Legacy Place Loan ($117.6 million -- 12.3% of
the pool), which represents a pari-passu portion of a $188.1
million mortgage loan. The loan is secured by a 484,000 SF
lifestyle retail center in Dedham, Massachusetts, a suburb of
Boston. The property was developed in 2009 and consists of six
buildings and parking for approximately 2,800 vehicles. The
property was 94% leased as of June 2019, down from 99% leased as of
December 2017. Moody's LTV and stressed DSCR are 96% and 0.93X,
respectively, compared to 99% and 0.90X at the last review.

The second largest loan is the IDS Center Loan ($82.9 million --
8.7% of the pool), which represents a pari-passu portion of a
$168.1 million mortgage loan. The loan is secured by a 1.4 million
SF mixed-use property located in downtown Minneapolis, Minnesota.
The collateral consists of a 57-story skyscraper office tower, an
eight-story annex building, a 100,000 SF retail center, and an
underground garage. The largest tenant, a law firm, renewed their
lease through May 2021. Moody's LTV and stressed DSCR are 99% and
1.01X, respectively, compared to 102% and 0.98X at the last
review.

The third largest loan is the Southridge Mall Loan ($46.0 million
-- 4.8% of the pool), which represents a pari-passu portion of a
$115.1 million senior mortgage loan. The loan is secured by a
550,000 SF portion of a 1.1 million SF regional mall in Greendale,
Wisconsin, a suburb of Milwaukee. At securitization, the mall was
anchored by Boston Store(non-collateral), Sears(non-collateral),
JCPenney(non-collateral), Macy's and Kohl's. However, Sears and
Boston Store closed their store at the property in 2017 and 2018,
respectively. Kohl's also moved their store to a new retail
development in late 2018. The former Sears store has been
redeveloped into a Dick's Sporting Goods, Golf Galaxy and a Round 1
Bowling and Amusement Complex. A T.J. Maxx store is also expected
to open in 2019. The property faces additional competition as it is
one of four regional or super-regional malls in the Milwaukee MSA.
Moody's LTV and stressed DSCR are 141% and 0.79X, respectively,
compared to 138% and 0.76X at the last review.


JPMCC MORTGAGE 2019-BROOK: Fitch Rates $41.150MM Cl. F Certs B-sf
-----------------------------------------------------------------
Fitch Ratings assigned the following ratings and Rating Outlooks to
JPMCC Mortgage Securities Trust 2019-BROOK, Commercial Mortgage
Pass-Through Certificates.

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

  -- $178,200,000 class A 'AAAsf'; Outlook Stable;

  -- $268,200,000a class X-CP 'BBB-sf'; Outlook Stable;

  -- $268,200,000a class X-EXT 'BBB-sf'; Outlook Stable;

  -- $33,000,000 class B 'AA-sf'; Outlook Stable;

  -- $22,100,000 class C 'A-sf'; Outlook Stable;

  -- $34,900,000 class D 'BBB-sf'; Outlook Stable;

  -- $53,900,000 class E 'BB-sf'; Outlook Stable;

  -- $41,150,000 class F 'B-sf'; Outlook Stable.

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

  -- $19,250,000b class HRR.

(a) Notional amount and interest-only.

(b) Horizontal credit risk retention interest.

The expected ratings are based on information provided by the
issuer as of Oct. 15, 2019.

The JPMCC Commercial Mortgage Trust 2019-BROOK, Commercial Mortgage
Pass-Through Certificates represent the beneficial interest in a
trust that holds a single, three-year with two one-year extensions,
floating-rate, interest-only mortgage loan in the amount of $382.5
million secured by fee simple interests in the Brookwood
Portfolio.

BROOK is a 4.3 million sf portfolio consisting of 25 office
properties and two industrial properties located across six states.
Proceeds of the loan were used to recapitalize the property and
cover closing costs. The certificates will follow a sequential pay
structure; however, any prepayments will be applied pro rata
between the trust and the future funding note.

KEY RATING DRIVERS

Fitch Leverage: The $382.5 million initially funded loan has a
Fitch debt service coverage ratio and loan to value ratio of 0.86x
and 104.1%, respectively. The sponsor acquired the portfolio
through multiple acquisitions between 2007 and 2016 for a total
purchase price of $430.0 million.

Diverse Portfolio: The loan is secured by 25 office properties and
two industrial properties located in six states. The three states
with the largest concentrations are Pennsylvania (13 properties;
29.3% of the total appraised value), Texas (five properties; 26.5%)
and Florida (three properties; 15.4%). The portfolio consists of
more than 400 unique tenants. The largest tenant within the
portfolio is 2.2% of NRA and the top 10 tenants are approximately
12.6% of NRA.

Suburban Office Locations: The portfolio properties are generally
located in suburban office markets in major metro areas. The
properties are located outside of the following major markets:
Philadelphia, San Diego, Boston, Providence, Dallas, San Antonio
and Fort Lauderdale.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 14.9% below
the most recent TTM NCF and 12.2% below the issuer's underwritten
NCF. Unanticipated further declines in property-level NCF could
result in higher defaults and loss severities on defaulted loans,
and could result in potential rating actions on the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the
2019-BROOK 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 'AAAsf' certificates to 'Asf' could result. In a more severe
scenario, in which NCF declined a further 30% from Fitch's NCF, a
downgrade of the 'AAAsf' certificates to 'BBB-sf' could result.


KKR CLO 27: S&P Assigns BB- (sf) Rating to Class E Notes
--------------------------------------------------------
S&P Global Ratings assigned its ratings to KKR CLO 27 Ltd.'s fixed-
and floating-rate notes.

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

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

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

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

  RATINGS ASSIGNED
  KKR CLO 27 Ltd./KKR CLO 27 LLC

  Class                Rating           Amount (mil. $)
  A                    AAA (sf)                  288.00
  B-1(i)               AA (sf)                    41.75
  B-2                  AA (sf)                    10.00
  C (deferrable)       A (sf)                     32.65
  D (deferrable)       BBB- (sf)                  20.25
  E (deferrable)       BB- (sf)                   19.15
  Subordinated notes   NR                         37.40

  Exchangeable note combinations(i)
  Class                Rating        Maximum principal
                                     amount (mil. $)
  Combination 1(iv)
  B-1A(ii)             AA (sf)                   41.75
  B-1AX(iii)           AA (sf)                     N/A
  Combination 2(iv)
  B-1B(ii)             AA (sf)                   41.75
  B-1BX(iii)           AA (sf)                     N/A
  Combination 3(iv)
  B-1C(ii)             AA (sf)                   41.75
  B-1CX(iii)           AA (sf)                     N/A
  Combination 4(iv)
  B-1D(ii)             AA (sf)                   41.75
  B-1DX(iii)           AA (sf)                     N/A

(i)The class B-1 notes will be exchangeable for proportionate
interest in combinations of principal notes and interest-only notes
of the same class, called modifiable and splittable/combinable
tranche (MASCOT) P&I notes. In aggregate, the cost of debt,
outstanding balance, stated maturity, subordination levels, and
payment priority following such an exchange would remain the same.

(ii)MASCOT P&I notes will have the same principal balance as the
class B-1 notes, as applicable, surrendered in such exchange.
(iii)Interest-only notes earn a fixed interest rate on the notional
balance, and are not entitled to any principal payments. The
notional balance will equal the principal balance of the
corresponding MASCOT P&I note of such combination.
NR--Not rated.
P&I--Principal and interest.
N/A--Not applicable.


M360 LTD 2019-CRE2: DBRS Finalizes B(low) Rating on Class G Notes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of floating-rate notes issued by M360 2019-CRE2, Ltd. (the
Issuer):

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

All trends are Stable.

Classes A, A-S, B, C, D and E represent the offered certificates.
Classes F and G and are non-offered certificates and will be
retained by the Issuer.

The initial collateral consists of 32 floating-rate mortgages
secured by 32 mostly transitional properties with a cut-off balance
totaling $306.0 million, excluding approximately $71.7 million of
future funding commitments. Included in the loan count and cut-off
balance are two Targeted Mortgage Assets, representing $18.8
million, which have not yet closed. In addition, there is a 90-day
Ramp-Up Period during which the Issuer may acquire additional
eligible loans subject to the Eligibility Criteria, resulting in a
maximum pool balance of $360.0 million. Most loans are in a period
of transition with plans to stabilize and improve the asset value.
During the Reinvestment Period, the Issuer may acquire future
funding commitments and additional eligible loans subject to the
Eligibility Criteria. The transaction stipulates a $1.0 million
threshold on pari passu participation acquisitions before a Rating
Agency Condition is required if there is already a participation of
the underlying loan in the trust.

For the floating-rate loans, DBRS Morningstar used the one-month
LIBOR index, which is based on the lower of a DBRS Morningstar
stressed rate that corresponded with the remaining fully extended
term of the loans or the strike price of the interest rate cap with
the respective contractual loan spread added to determine a
stressed interest rate over the loan term. When the cut-off
balances were measured against the DBRS Morningstar As-Is Net Cash
Flow, 27 loans, comprising 87.6% of the initial pool, had a DBRS
Morningstar As-Is Debt Service Coverage Ratio (DSCR) below 1.00
times (x), a threshold indicative of default risk. Additionally,
the DBRS Morningstar Stabilized DSCR for 13 loans, comprising 45.5%
of the initial pool balance, is below 1.00x, which is indicative of
elevated refinance risk. The properties are often transitioning
with potential upside in cash flow; however, DBRS Morningstar does
not give full credit to the stabilization if there are no holdbacks
or if other loan structural features in place are insufficient to
support such treatment. Furthermore, even with the structure
provided, DBRS Morningstar generally does not assume the assets
will stabilize above market levels. The transaction will have a
sequential-pay structure.

The pool is fairly diverse by commercial real estate collateralized
loan obligation (CRE CLO) standards with a diversity profile
equivalent to that of a pool with 25 equally sized loans (including
three projected ramp-up loans). The loans are generally secured by
traditional property types (i.e., retail, multifamily, office and
industrial) with only 7.5% of the pool secured by hotels.
Additionally, only one of the multifamily loans (Lafayette
University Place, representing 3.1% of initial pool balance) in the
pool is currently secured by a student housing property, which
often exhibit higher cash flow volatility than traditional
multifamily properties. Six loans, representing 19.2% of the
initial pool balance, are represented by properties that are
primarily located in core markets with a DBRS Morningstar Market
Rank of 5 to 7. These higher DBRS Morningstar Market Ranks
correspond with zip codes that are more urbanized or densely
suburban in nature. Four loans in the pool, totaling 22.5% of the
DBRS Morningstar sample by cut-off date pool balance, are backed by
a property with a quality deemed to be Average (+) by DBRS
Morningstar.

The weighted-average (WA) DBRS Morningstar As-Is Loan-to-Value
(LTV) ratio, which includes all future funding in the calculation,
is high at 9.5%, reflecting the highly transitional nature of the
pool with substantial future funding as well as the general high
leverage. The high LTV results in a very high WA DBRS Morningstar
expected loss of 9.5% for the pool, which translates to credit
enhancement levels at each rating category that are relatively high
compared with other CRE CLOs.

The pool consists of mostly transitional assets. Given the nature
of the assets, DBRS Morningstar determined a sample size that
represents 74.9% of the pool cut-off-date balance. Physical site
inspections were also performed, including management meetings. In
addition, DBRS Morningstar notes that when its analysts are
visiting the markets, they may actually visit properties more than
once to follow the progress (or lack thereof) toward
stabilization.

Nine of the sampled loans, comprising 31.4% of the pool balance,
were analyzed with Weak or Bad (Litigious) sponsorship strengths.
Three of the loans — Brushy Creek Corporate Center, Hughes Plaza
Office and The Park at Riverwoods — are among the pool's top ten
largest loans. DBRS Morningstar applied a probability of default
(POD) penalty to loans analyzed with Weak or Bad (Litigious)
sponsorship strength. Additionally, for all non-sampled loans in
the pool, DBRS Morningstar applied a Weak sponsorship strength to
account for the pool's overall exposure. In total, 23 loans,
representing 60.8% of the pool cut-off-date balance, were analyzed
with Weak or Bad (Litigious) sponsorship and received POD
adjustments.

All 32 loans have floating interest rates, and all loans are
interest only during the original term, which range from 12 months
to 36 months, creating interest rate risk. All loans are short-term
loans, and even with extension options, they have a fully extended
maximum loan term of five years. Additionally, for the
floating-rate loans, DBRS Morningstar used the one-month LIBOR
index, which is based on the lower of a DBRS Morningstar stressed
rate that corresponded with the remaining fully extended term of
the loans or the strike price of the interest rate cap with the
respective contractual loan spread added to determine a stressed
interest rate over the loan term. Additionally, all have extension
options, and in order to qualify for these options, the loans must
meet minimum leverage requirements.

The participations conveyed to the Issuer will not include record
title to the underlying mortgage in the name of the Issuer but
instead will include help from the Seller. This is contrary to
standard CRE CLO structures, where the issuer or institutional
custodian generally holds title to the participation loans. In the
case of a bankruptcy, the issuer has a lesser claim to the loan
since it does not own the title. As a result, the issuer's ability
to recover under such participation is subject to the credit risk
of the entity that holds legal title to the underlying collateral.
Payments to the issuer will be affected if the legal titleholder of
the participated assets files for bankruptcy or is declared
insolvent. DBRS Morningstar has been informed by the Issuer that
the risk of M360 2019-CRE2 Seller, LLC becoming involved in a
bankruptcy is diminished because the entity will be limited to only
acquiring mortgage loans and participations therein and not
engaging in other business. Furthermore, it will be limited on
indebtedness to only that debt arising in connection with the loan
participations.

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

Twenty-six loans, totaling only 89.3% of the initial pool balance,
represent refinance financing. The refinance financings within this
securitization generally do not require the respective sponsor(s)
to contribute material cash equity as a source of funding in
conjunction with the mortgage loan, resulting in a lower sponsor
cost basis in the underlying collateral. Of the 26 refinance loans,
13 loans, representing 39.8% of the pool, have a current occupancy
of less than 80.0% and four of the refinance loans account for
$26.6 million of the $71.7 million of future funding (37.1%). This
suggests that at least one-third of the refinance loans are near
stabilization, which would partially mitigate the higher risk
associated with a sponsor's lower cost basis.

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


MAGNETITE XXIII: S&P Assigns Prelim BB- (sf) Rating to Cl. E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Magnetite
XXIII Ltd.'s floating-rate notes.

The note issuance is a collateralized loan obligation transaction
backed by primarily of 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 Oct. 16,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The diversified collateral pool.

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Magnetite XXIII Ltd. /Magnetite XXIII LLC

  Class                 Rating       Amount (mil. $)
  A                     AAA (sf)              330.70
  B                     AA (sf)                62.00
  C (deferrable)        A (sf)                 31.00
  D (deferrable)        BBB- (sf)              28.40
  E (deferrable)        BB- (sf)               23.00
  Subordinated notes    NR                     47.40

  NR--Not rated.


MELLO WAREHOUSE 2019-2: Moody's Gives (P)Ba2 Rating to Class E Debt
-------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to five
classes of residential mortgage-backed securities issued by Mello
Warehouse Securitization Trust 2019-2. The ratings range from
(P)Aaa (sf) to (P)Ba2 (sf).

Mello Warehouse Securitization Trust 2019-2 is a securitization
backed by a revolving warehouse facility sponsored by
loanDepot.com, LLC (unrated). The securities are backed by a
revolving pool of newly originated first-lien, fixed rate and
adjustable rate, residential mortgage loans which are eligible for
purchase by Fannie Mae and Freddie Mac or in accordance with the
criteria of Ginnie Mae for the guarantee of securities backed by
mortgage loans to be pooled in connection with the issuance of
Ginnie Mae securities. The pool may also include FHA Streamline
mortgage loans or VA-IRRR mortgage Loans, which may have limited
valuation and documentation. The collateral pool balance is
$300,000,000.

The complete rating actions are as follows:

Issuer: Mello Warehouse Securitization Trust 2019-2

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

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

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

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

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

RATINGS RATIONALE

Moody's bases its Aaa expected losses of 34.85% and base case
expected losses of 6.40% on a scenario in which loanDepot does not
pay the aggregate repurchase price to pay off the notes at the end
of the facility's two-year revolving term, and the repayment of the
notes will depend on the credit performance of the remaining static
pool of mortgage loans. To assess the credit quality of the static
pool, Moody's created a hypothetical adverse pool based on the
facility's eligibility criteria, which includes no more than 15%
(by unpaid balance) adjustable rate mortgage loans. Moody's
analyzed the pool using its US MILAN model and made additional pool
level adjustments to account for risks related to (i) weaknesses in
the representation and warranty enforcement framework and (ii)
compliance with the TILA-RESPA Integrated Disclosure (TRID) Rule,
based on findings in third-party diligence reports from loanDepot's
prior warehouse securitizations, Mello Warehouse Securitization
Trust 2018-1 and loanDepot Station Place Agency Securitization
Trust 2017-1.

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

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

Collateral Description:

The mortgage loans will be newly originated, first-lien, fixed-rate
and adjustable rate mortgage loans that also comply with the
eligibility criteria set forth in the master repurchase agreement.
The aggregate principal balance of the purchased loans at closing
will be $300,000,000. Per the transaction documents, the mortgage
pool will have a minimum weighted average FICO of 715 and a maximum
weighted average LTV of 87%.

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

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

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

Transaction Structure:

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

The transaction is structured as a master repurchase agreement
between loanDepot (the repo seller) and the Mello Warehouse
Securitization Trust 2019-2 (the trust or issuer). The U.S.
Bankruptcy Code provides repurchase agreements, security contracts
and master netting agreements a "safe harbor" from the Bankruptcy
Code automatic stay. Due to this safe harbor, in the event of a
bankruptcy of loanDepot, the issuer will be exempt from the
automatic stay and thus, the issuer will be able to exercise
remedies under the master repurchase agreement, which includes
seizing the collateral.

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

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

Ongoing Due Diligence

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

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

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

Representation and Warranties

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

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

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above its original expectations as
a result of a weaker collateral composition than that in the
adverse pool, financial distress of any of the counterparties.
Transaction performance also depends greatly on the US macro
economy and housing market.

Significant Influences

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

Methodology

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


MERRILL LYNCH 2008-C1: Fitch Lowers Class H Certs Rating to Csf
---------------------------------------------------------------
Fitch Ratings downgraded one class and affirmed 10 classes of
Merrill Lynch Mortgage Trust, commercial mortgage pass-through
certificates, series 2008-C1.

Merrill Lynch Mortgage Trust 2008-C1

Class F 59025WAU0; LT Bsf Affirmed;  previously at Bsf

Class G 59025WAV8; LT CCsf Affirmed; previously at CCsf

Class H 59025WAW6; LT Csf Downgrade; previously at CCsf

Class J 59025WAX4; LT Dsf Affirmed;  previously at Dsf

Class K 59025WAY2; LT Dsf Affirmed;  previously at Dsf

Class L 59025WAZ9; LT Dsf Affirmed;  previously at Dsf

Class M 59025WBA3; LT Dsf Affirmed;  previously at Dsf

Class N 59025WBB1; LT Dsf Affirmed;  previously at Dsf

Class P 59025WBC9; LT Dsf Affirmed;  previously at Dsf

Class Q 59025WBD7; LT Dsf Affirmed;  previously at Dsf

Class S 59025WBE5; LT Dsf Affirmed;  previously at Dsf

KEY RATING DRIVERS

Greater Certainty of Losses: The downgrade to class H reflects loss
expectations associated with the specially serviced loans which are
expected to impact this class. The pool remains highly concentrated
with only four of the original 97 loans remaining. Two loans (88%)
are specially serviced, one (7.3%) is defeased and one (4.7%) is
fully amortizing. Due to the concentrated nature of the pool, Fitch
performed a sensitivity analysis that grouped the remaining loans
based on collateral quality, performance, and perceived likelihood
of repayment.

The largest loan in the pool, Landmark Towers (47%), is secured by
a 213,000 sf office tower in St. Paul, MN. The loan was transferred
to special servicing in June 2017 for imminent default due to the
property's largest tenant, Green Tree Servicing/Ditech (59% of
NRA), giving notice they would vacate upon lease expiration in
December 2017 as they were relocating. However, the tenant
subsequently downsized and occupied a portion of their space (10%
of NRA) on a month-to-month basis from 2018 through 2019; the
property's occupancy declined to approximately 40% in 2018 from 90%
at YE 2017. The tenant has since vacated their entire space and the
property is now 24% occupied. A receiver was appointed in June 2018
and a foreclosure sale was held in April 2019. The borrower is
currently in a six month redemption period ending Oct. 25, 2019.
The special servicer continues to evaluate a resolution strategy.

The second largest loan in the pool, Stony Brook South (41%), is
secured by 148,000 sf anchored retail property located in
Louisville, KY. The property is anchored by Dick's Sporting Goods
(30%) and Planet Fitness (17%). The loan transferred to special
servicing in August 2017 due to imminent default as it did not pay
off at maturity. The property's former anchor tenant, Marshall's
(20%), extended their lease for six months in March 2019 but
vacated upon its September 2019 lease expiration causing a drop in
occupancy to 79% from 99% as of June 2019. A receiver was appointed
in January 2018 and is currently marketing the property for sale.

Increased Credit Enhancement: Credit enhancement has improved since
Fitch's last rating action primarily due to the disposition of two
previously specially serviced loans with higher than expected
recoveries, in addition to expected proceeds from the payoff of a
previously modified loan. As of the September 2019 distribution
date, the pool's aggregate principal balance has been reduced by
96.4%, up from 93.6% at last review. The trust has realized losses
of $57.5 million (6.1%) since issuance.

RATING SENSITIVITIES

The downgrade to the distressed class H reflects a greater
certainty of loss expectations associated with the specially
serviced loans; losses are considered inevitable and expected to
impact the class. The remaining classes were affirmed as repayment
to the classes is ultimately reliant on proceeds from specially
serviced assets. Upgrades, while unlikely, are possible should the
two specially serviced loans be disposed in the near term with
higher than expected recoveries. Further downgrades are likely if
pool performance continues to deteriorate and realized losses
exceed Fitch's loss expectations.


MILL CITY 2019-GS1: Moody's Assigns Caa1 Ratings on 2 Tranches
--------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to eighteen
classes of notes issued by Mill City Mortgage Loan Trust 2019-GS1.

The certificates are backed by one pool of 2,356 seasoned
performing and modified re-performing loans which includes a small
portion of junior liens mortgage loans (13.66%) and loans that are
currently 60+ days MBA delinquent (5.14%). The collateral pool has
a non-zero updated weighted average FICO score of 642 and a
weighted average current LTV of 93.91% (including the deferred
balance for calculation).

Similar to MCMLT 2019-1, this pool does not have any HELOC loans.
In addition, approximately 12.33% of the loans are originated on or
after January 1, 2010. 78.62% of the loans in the collateral pool
were also previously modified and the remaining loans have never
been modified.

Fay Servicing LLC and Shellpoint Mortgage Servicing, are the
servicers for the loans in the pool. The servicers will not advance
any principal or interest on the delinquent loans. However, the
servicers 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.

Goldman Sachs Mortgage Company is acquiring the collateral from a
CarVal Investors limited fund. GSMC as a sponsor and loan seller is
structuring the transaction. This arrangement is weaker than the
alignment of interests in the prior MCMLT transactions where the
sponsor, the depositor and the R&W provider are affiliates of
CarVal Investors. A mitigating factor is that GSMC will retain at
least 5% of the notes to satisfy U.S. risk retention requirements.
Similar to other MCMLT transactions, a non-rated limited fund from
Carval Investors will be the R&W provider.

The complete rating actions are as follows:

Issuer: Mill City Mortgage Loan Trust 2019-GS1

Cl. A1, Definitive Rating Assigned Aaa (sf)

Cl. A1A, Definitive Rating Assigned Aaa (sf)

Cl. A1B1, Definitive Rating Assigned Aaa (sf)

Cl. A1B2, Definitive Rating Assigned Aaa (sf)

Cl. A2, Definitive Rating Assigned Aa3 (sf)

Cl. A3, Definitive Rating Assigned A1 (sf)

Cl. A4, Definitive Rating Assigned A3 (sf)

Cl. B1, Definitive Rating Assigned Ba3 (sf)

Cl. B1A, Definitive Rating Assigned Ba1 (sf)

Cl. B1B, Definitive Rating Assigned Ba3 (sf)

Cl. B2, Definitive Rating Assigned Caa1 (sf)

Cl. B2A, Definitive Rating Assigned B1 (sf)

Cl. B2B, Definitive Rating Assigned Caa1 (sf)

Cl. M1, Definitive Rating Assigned Aa3 (sf)

Cl. M2, Definitive Rating Assigned A3 (sf)

Cl. M3, Definitive Rating Assigned Baa3 (sf)

Cl. M3A, Definitive Rating Assigned Baa3 (sf)

Cl. M3B, Definitive Rating Assigned Baa3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected losses on MCMLT 2019-GS1's collateral pool average
17.25% 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.

For the non-modified portion of this pool, Moody's analyzed data on
delinquency rates for always current (including self-cured) loans.
Similarly, for the modified portion of this pool, Moody's analyzed
data on delinquency rates for modified loans. Its final loss
estimates also incorporates adjustments for the strength of the
third party due diligence, the servicing arrangement and the
representations and warranties (R&W) framework of the transaction.

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

Collateral Description

MCMLT 2019-GS1 is a securitization of 2,356 loans and is primarily
comprised of seasoned performing and modified re-performing
mortgage loans. Approximately 78.62% of the loans in the collateral
pool have been previously modified (including the deferred balance
for calculation).

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 57.67% of the borrowers have been current (OTS method
of delinquency) on their payments for at least the past 24 months.

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 by
using a approach similar to its surveillance approach wherein
Moody's applies assumptions on expected future delinquencies,
default rates, loss severities and prepayments as observed from its
surveillance of similar collateral. Moody's projects future annual
delinquencies for eight years by applying an initial annual default
rate and delinquency burnout factors. Based on the loan
characteristics of the pool and the demonstrated pay histories,
Moody's expects an annual delinquency rate of 12.88% on the first
lien portion of the collateral pool for year one. Moody's then
calculated future delinquencies on the pool using its default
burnout and voluntary conditional prepayment rate (CPR)
assumptions. Its assumptions also factor in the high delinquency
rates expected in the early stages of the transaction due to
payment shock expected for step-rate loans. 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 MCMLT 2019-GS1's
collateral pool. Moody's applied loan-level baseline lifetime
propensity to default assumptions based on the historical
performance of 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 final 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. The
deferred balance in this transaction is approximately $45.45
million, representing approximately 11.77% of the total unpaid
principal balance.

Three loans in the pool currently feature an active HAMP Principal
Reduction Alternative (HAMP-PRA). Under HAMP-PRA, the principal of
the borrower's mortgage may be reduced by a predetermined amount
called the PRA forbearance amount if the borrower satisfies certain
conditions during a trial period. If the borrower continues to make
timely payments on the loan for three years, the entire PRA
forbearance amount is forgiven. Also, if the loan is in good
standing and the borrower voluntary pays off the loan, the entire
forbearance amount is forgiven.

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 data and information from servicers, Moody's
assumes that 100% of the remaining PRA amount would be forgiven and
not recovered. For non-PRA deferred balance, Moody's applied a
slightly higher default rate for these loans 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. Also, for non-PRA loans, based on performance data from
an RPL servicer, Moody's assumed approximately 95% severity as
servicers may recover a portion of the deferred balance. For this
pool, non-PRA deferred balance account for 100.00% of the deferred
balance. The final expected loss for the collateral pool reflects
the due diligence scope and findings of the independent third party
review (TPR) firms as well as its assessment of MCMLT 2019-GS1's
representations & warranties (R&Ws) framework.

Transaction Structure

Similar to other MCMLT transactions, MCMLT 2019-GS1 has a simple
sequential priority of payments structure without any cash flow
triggers. The transaction allocates excess cash flow (net of
realized losses and certain unreimbursed amounts) sequentially to
the senior notes A1A, A1B1 and A1B2 and then to the subordinated
tranches, class M1 through class B6B up to a target payment amount.
This arrangement is weaker than previous MCMLT transactions (except
for MCMLT 2019-1) where all the remaining excess cash flow (net of
realized losses, certain unreimbursed amount and payment to senior
notes) is distributed to the subordinated tranches. In this
transaction, after the excess cash flow is used to pay the
subordinated tranches the target payment amount, the remaining
excess cash flow will be distributed to the residual certificates.
Moody's took into consideration the change in the monthly excess
cashflow waterfall in its modeling of the transaction's cash
flows.

The transaction will benefit from overcollateralization but it will
experience spread compression due to deleveraging, prepayment and
modification. Moody's took this into account in its analysis. The
servicer will not advance any principal or interest on delinquent
loans. However, the servicer will be required to advance costs and
expenses incurred in connection with a default, delinquency or
other event in the performance of its servicing obligations.

Credit enhancement in this transaction is comprised of
subordination provided by mezzanine and junior tranches and the
buildup of overcollateralization from available excess interest.
The principal payment received from excess interest collections
will limit the faster pay down on the senior notes as a smaller
percentage of the excess cash flow would be allocated to the
seniors due to structural features mentioned previously.

To the extent that the overcollateralization amount is zero or
insufficient monthly excess cash flow, realized losses will be
allocated to the notes in a reverse sequential order starting with
the lowest subordinate bond. The Class A1A, Class A1B1, Class A1B2,
Class A1, Class A2, Class A3, Class A4, Class M1, Class M2, Class
M3A, Class M3B, Class M3, Class B1A, Class B1B, Class B1, Class
B2A, Class B2B and Class B2 notes carry a fixed-rate coupon subject
to the collateral adjusted net weighted average coupon (WAC) and
applicable available funds cap. The Class B3A, Class B3B, Class B3,
Class B4A, Class B4B, Class B4, Class B5A, Class B5B, Class B5,
Class B6A, Class B6B and Class B6 are variable rate notes where the
coupon is equal to the lesser of adjusted net WAC-0.25% and
applicable available funds cap.

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

Third Party Review

Three third party review (TPR) firms conducted due diligence on all
but few loans in MCMLT 2019-GS1's collateral pool. The TPR firms
reviewed compliance, data integrity and key documents, to verify
that loans were originated in accordance with federal, state and
local anti-predatory laws. The TPR firms also conducted audits of
designated data fields to ensure the accuracy of the collateral
tape. An independent firm also reviewed the title and tax reports
for all the loans in the pool.

Based on its analysis of the third-party review 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. In addition, the diligence
providers were unable to determine if four loans were originated in
accordance with ATR rules. Moody's has made adjustments consistent
with its approach to account for the rating impact of ATR rules
that could cause future losses to the trust. Moody's incorporated
an additional hit to the loss severities for these loans to account
for this risk. The title review includes confirming the recordation
status of the mortgage and the intervening chain of assignments,
the status of real estate taxes and validating the lien position of
the underlying mortgage loan. Once securitized, delinquent taxes
will be advanced on behalf of the borrower and added to the
borrower's account. The servicer will be reimbursed for delinquent
taxes from the top of the waterfall, as a servicing advance. The
representation provider has deposited collateral of $650,000 in the
Assignment Reserve Account (ARA) to ensure one or more third
parties monitored by the Depositor completes all assignment and
endorsement chains and record an intervening assignment of mortgage
as necessary. The amount deposited in the ARA at the closing date
is lower than the previous Mill City transaction, MCMLT 2019-GS1.
Moody's has considered the ARA deposit and factors such as: (i) the
high historical cure rate in the previous Mill City transactions
and(ii) the low delinquency rate of the previous Mill City
transactions. Moody's did not make any additional adjustment for
this.

Representations & Warranties

Its ratings also factor in MCMLT 2019-GS1's weak representations
and warranties (R&Ws) framework because they contain many knowledge
qualifiers and the regulatory compliance R&W does not cover
monetary damages that arise from TILA violations whose right of
rescission has expired. The breach discovery process for this
transaction is also weaker than previous Mill City securitizations
(except MCMLT 2017-3,MCMLT 2018-3 and MCMLT 2018-4) and other rated
RPL transactions. Previously, with the exception of MCMLT 2017-3,
MCMLT 2018-3 and MCMLT 2018-4, an independent party reviewed R&W
breaches for every loan that became 120 days delinquent. For this
transaction similar to MCMLT 2017-3, MCMLT 2018-3 and MCMLT 2018-4,
an independent party reviews R&W breaches for every loan that
incurs a realized loss.

While the transaction provides for a Breach Reserve Account to
cover for any breaches of R&Ws, the size of the account is slightly
smaller for MCMLT 2019-GS1 ($775,000 relative to aggregate
collateral balance of $386.29 million) compared to MCMLT 2019-1
($0.9 million relative to aggregate collateral pool $440.2
million). An initial deposit of $775,000 will be remitted to the
Breach Reserve Account on the closing date, with an initial Breach
Reserve Account target amount of $1.2 million. Moody's did not make
any adjustment for this as it was not much different in terms of
percentage of balance.

Trustee Indemnification

Moody's believes there is a very low likelihood that the rated
notes in MCMLT 2019-GS1 will incur any loss from extraordinary
expenses or indemnification payments owing to potential future
lawsuits against key deal parties. First, majority of the loans are
seasoned with demonstrated payment history, reducing the likelihood
of a lawsuit on the basis that the loans have underwriting defects.
Second, historical performance of loans aggregated by the sponsor
to date has been within expectation, with minimal losses on
previously issued Mill City transactions. Third, the transaction
has reasonably well defined processes in place to identify loans
with defects on an ongoing basis. In this transaction, an
independent breach reviewer must review loans for breaches of
representations and warranties when a realized loss is incurred on
a loan, which reduces the likelihood that parties will be sued for
inaction. Furthermore, the issuer has performed nearly 73.4% due
diligence by independent third parties with respect to compliance
and payment history and has disclosed the results of the review.

Transaction Parties

The transaction benefits from an adequate servicing arrangement.
Shellpoint will service 73.95% of the pool, Fay will service 26.05%
of the pool. Wells Fargo Bank, N.A. is the Custodian of the
transaction. MCMLT 2019-GS1's Indenture Trustee is U.S. Bank
National Association.

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

Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of loss could drive
the ratings up. Losses could decline from its original expectations
as a result of a lower number of obligor defaults or appreciation
in the value of the mortgaged property securing an obligor's
promise of payment. Transaction performance also depends greatly on
the US macro economy and housing market. Other reasons for
better-than-expected performance include changes to servicing
practices that enhance collections or refinancing opportunities
that result in prepayments.

Down

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


MONROE CAPITAL IX: Moody's Gives (P)Ba3 Rating to Class E Notes
----------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to five
classes of notes to be issued by Monroe Capital MML CLO IX, Ltd.

Moody's rating action is as follows:

US$252,000,000 Class A Senior Floating Rate Notes Due 2031 (the
"Class A Notes"), Assigned (P)Aaa (sf)

US$45,000,000 Class B Floating Rate Notes Due 2031 (the "Class B
Notes"), Assigned (P)Aa2 (sf)

US$40,500,000 Class C Deferrable Mezzanine Floating Rate Notes Due
2031 (the "Class C Notes"), Assigned (P)A2 (sf)

US$27,000,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2031 (the "Class D Notes"), Assigned (P)Baa3 (sf)

US$29,250,000 Class E Deferrable Mezzanine Floating Rate Notes Due
2031 (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.

Monroe Capital MML IX is a managed cash flow CLO. The issued notes
will be collateralized primarily by small and medium enterprise
loans. At least 95% of the portfolio must consist of first lien
senior secured loans and eligible investments, and up to 5% of the
portfolio may consist of second lien loans and unsecured loans.
Moody's expects the portfolio to be approximately 70% ramped as of
the closing date.

Monroe Capital Asset 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 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.

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: 45

Weighted Average Rating Factor (WARF): 3500

Weighted Average Spread (WAS): 4.45%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 46.5%

Weighted Average Life (WAL): 8.00 years

Methodology Underlying the Rating Action:

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

The CLO permits the manager to determine RiskCalc-derived rating
factors, based on modifications to certain pre-qualifying
conditions applicable to the use of RiskCalc, for obligors
temporarily ineligible to receive Moody's credit estimates. Such
determinations are limited to a small portion of the portfolio and
permits certain modifications for a limited time. Its rating
analysis included rating factor stress scenarios.

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.


MORGAN STANLEY 2016-BNK2: Fitch Affirms B-sf Rating on 2 Tranches
-----------------------------------------------------------------
Fitch Ratings affirmed 17 classes of Morgan Stanley Capital I
Trust, commercial mortgage pass-through certificates, series
2016-BNK2.

MSC 2016-BNK2

                       Current Rating       Prior Rating

Class A-1 61690YBQ4;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 61690YBR2;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 61690YBT8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 61690YBU5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 61690YBX9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 61690YBS0; LT AAAsf Affirmed;  previously at AAAsf

Class B 61690YBY7;    LT AA-sf Affirmed;  previously at AA-sf

Class C 61690YBZ4;    LT A-sf Affirmed;   previously at A-sf

Class D 61690YAC6;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 61690YAL6;    LT BB-sf Affirmed;  previously at BB-sf

Class E-1 61690YAE2;  LT BB+sf Affirmed;  previously at BB+sf

Class E-2 61690YAG7;  LT BB-sf Affirmed;  previously at BB-sf

Class EF 61690YAU6;   LT B-sf Affirmed;   previously at B-sf

Class F 61690YAS1;    LT B-sf Affirmed;   previously at B-sf

Class X-A 61690YBV3;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 61690YBW1;  LT AA-sf Affirmed;  previously at AA-sf

Class X-D 61690YAA0;  LT BBB-sf Affirmed; previously at BBB-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The affirmations reflect
the overall stable performance and loss expectations with no
material changes to pool metrics since issuance. There are no
delinquent loans and no loans have transferred to special
servicing. Fitch designated one loan (10.2% of pool), the largest
loan, as a Fitch Loan of Concern (FLOC) due to a recent tenant
vacancy.

Minimal Change to Credit Enhancement: There has been minimal change
to credit enhancement since issuance. As of the September 2019
distribution date, the pool's aggregate balance has been reduced by
2.3% to $708.8 million from $725.6 million at issuance. All
original 40 loans remain in the pool. Eight loans (37.6% of pool)
are full-term, interest-only and nine loans (23.2%) have a
partial-term, interest-only component of which three have begun to
amortize. One loan (0.3%) is fully defeased.

ADDITIONAL CONSIDERATIONS

Fitch Loan of Concern: The largest loan, 101 Hudson Street (10.2%
of pool), which is secured by a 1.3 million sf office property
located in downtown Jersey City, NJ, was designated a FLOC due to
significant occupancy declines since issuance. The property was 64%
occupied as of March 2019, down from 85.1% (although 98.3% leased)
in September 2016 around the time of issuance. Fitch's analysis at
issuance accounted for two tenants with partial dark space at the
property, including the second largest tenant, National Union Fire
Insurance(previously 20% NRA), which subsequently vacated at its
April 2018 lease expiration. Per servicer updates, the borrower is
actively marketing the vacant space. At YE 2018, servicer-reported
NOI DSCR was 3.48x.

Retail Concentration: Loans secured by retail properties comprise
41% of the pool, including two of the three largest loans in the
pool. Harlem USA (9.6% of pool), the second largest loan in the
pool, is secured by a 245,849 sf retail property located on West
125th Street between St. Nicholas Avenue and Frederick Douglas
Boulevard in Harlem. Larger tenants include a nine-screen Magic
Johnson Theater (27.7% NRA), Old Navy (14.2% NRA) and K&G Fashion
Superstore (9.5% NRA). At YE 2018, occupancy was 98%, and
servicer-reported NOI DSCR was 2.96x.

Cole Retail Portfolio (6.6% of pool), the third largest loan in the
pool, is secured by a portfolio of three cross-collateralized power
centers totaling 544,503 sf; Lawton Marketplace located in Lawton,
OK, Shops at Abilene located in Abilene, TX and Houma Crossing
located in Houma, LA. Larger tenants in the portfolio include
Academy Sports (11.4% portfolio NRA), which is located at Lawton
Marketplace and Hobby Lobby (10.4% portfolio NRA), which is located
at Houma Crossing. Kohl's, (previously 10.2% portfolio NRA), which
was located at Houma Crossing, closed this location in 2019 prior
to its 2034 lease expiration. The terms of the ground lease did not
require the store to remain open. Per servicer updates, the space
remains dark and Kohl's is continuing to pay rent per the lease. As
of June 2019, portfolio occupancy was 83.5%, and at YE 2018,
servicer-reported NOI DSCR was 3.21x.

Pool/Maturity Concentration: The top 10 loans comprise 60.5% of the
pool. Based on the loans' scheduled maturity balances, the pool is
expected to amortize 11.5% during the term. Loan maturities are
concentrated in 2026 (92.3%).

RATING SENSITIVITIES

Rating Outlooks for all classes remain Stable due to relatively
stable performance with no material changes to pool metrics since
issuance. 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.


MORGAN STANLEY 2016-C32: Fitch Affirms B-sf Rating on Cl. F Debt
----------------------------------------------------------------
Fitch Ratings affirmed 14 classes of Morgan Stanley Bank of America
Merrill Lynch Trust Series 2016-C32.

MSBAM 2016-C32

                        Current Rating      Prior Rating

Class A-1 61691GAN0;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 61691GAP5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 61691GAR1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 61691GAS9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 61691GAV2;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 61691GAQ3; LT AAAsf Affirmed;  previously at AAAsf

Class B 61691GAW0;    LT AA-sf Affirmed;  previously at AA-sf

Class C 61691GAX8;    LT A-sf Affirmed;   previously at A-sf

Class D 61691GAC4;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 61691GAE0;    LT BB-sf Affirmed;  previously at BB-sf

Class F 61691GAG5;    LT B-sf Affirmed;   previously at B-sf

Class X-A 61691GAT7;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 61691GAU4;  LT AA-sf Affirmed;  previously at AA-sf

Class X-D 61691GAA8;  LT BBB-sf Affirmed; previously at BBB-sf

KEY RATING DRIVERS

Stable Loss Expectations: The affirmations are based on the stable
performance of the underlying collateral. No loans have transferred
to special servicing since issuance and Fitch has designated one
loan (0.85%) as a Fitch Loan of Concern (FLOC). There have been no
material changes to the pool since issuance; therefore, the
original rating analysis was considered in affirming the
transaction.

Minimal Change to Credit Enhancement: There has been a minimal
change to credit enhancement since issuance. As of the September
2019 distribution date, the pool's aggregate balance has been paid
down by 1.8% to $890.6 million from $907 million at issuance. All
56 of the original loans remain in the pool. Eight loans
representing 31.7% of the pool are full-term interest-only loans
and 10 loans representing 18.4% of the pool remain in their partial
interest-only period.

Fitch Loan of Concern: One loan (0.85%) has been designated as a
FLOC. The Whisper Creek loan, which is secured by a manufactured
housing community located in Labelle, FL, which has struggled with
performance issues since sustaining damage from Hurricane Irma. As
of YE 2018 the property reported occupancy of 78% with a NOI DSCR
of 1.12x.

Additional Considerations

Investment-Grade Credit Opinion Loan: Two loans, representing 12.7%
of the pool, had investment-grade credit opinions at issuance.
Hilton Hawaiian Village (6.9%), the largest loan in the pool, had
an investment-grade credit opinion of 'BBB-' on a stand-alone
basis, and Potomac Mills (5.7%) had an investment-grade credit
opinion of 'BBB' on a stand-alone basis.

Property Type Concentration: The largest property type in the
transaction is retail at 40.7% of the pool, followed by office at
16.3%, industrial at 12.4% and Multifamily at 11.1%.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable given the
relatively stable performance of the transaction since issuance.
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.


NATIXIS COMMERCIAL 2019-1776: Moody's Gives (P)B3 on Cl. F Certs
-----------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to eleven
classes of CMBS securities, issued by Natixis Commercial Mortgage
Securities Trust 2019-1776, Commercial Mortgage Pass-Through
Certificates, Series 2019-1776:

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

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

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

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

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

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

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

Cl. X-BCP*, Assigned (P)Ba3 (sf)

Cl. V-A**, Assigned (P)Aaa (sf)

Cl. V-B2F**, Assigned (P)Ba3 (sf)

Cl. V2**, Assigned (P)Ba3 (sf)

* Reflects interest-only classes

** Reflects exchangeable classes

RATINGS RATIONALE

The certificates are collateralized by a single loan secured by the
borrower's fee simple interest in Patriots Park, a suburban office
campus with three office buildings and two parking garages in
Reston, Virginia. Its ratings are based on the credit quality of
the loans and the strength of the securitization structure.

More specifically the trust assets consist of a $218,070,000
non-recourse first mortgage financing to a bankruptcy-remote,
special purpose entity, a Delaware limited liability company that
the sponsor indirectly owns and controls. The trust loan was
originated on October 2, 2019 and is secured by the borrower's fee
simple interest in Patriots Park. The borrower, Hyundai Able
Patriots Park, LLC, is controlled by KB Financial Group, Inc.

The mortgage loan has a five-year term with no extension options,
and calls for monthly interest-only payments during the entire loan
term at a fixed rate of 3.35%. The mortgage loan will be serviced
and administered by the servicer, the special servicer and the
trustee under the trust and servicing agreement for this
transaction.

The Patriots Park campus is primarily comprised of three, five- to
seven-story Class A office buildings, across a highly secure
22.7-acre campus. The office layouts are suitable for either single
or multiple tenants, with floor plans averaging 50,000 SF to 53,000
SF for Patriots Park I and II and 27,400 SF for Patriots Park III
(respectively). Individual buildings range in size from 129,370 SF
to 363,556 SF. As of September 27, 2019 the property was 100.0%
occupied by the General Services Administration ("GSA"), though the
exact tenants occupying the property purposely remain unknown. The
GSA leases contain no termination or appropriations clauses and can
only be ended if the landlord was disclose the identity of the
tenants at the property.

Amenities at Patriots Park include a large cafeteria with
commercial seating that can seat over 500 employees, numerous break
rooms, as well as a convenience store, coffee counter, and two full
fitness centers. The park also contains two freestanding parking
structures with 2,660 total spaces for a parking ratio of
approximately 3.7 per 1,000 SF (990 in the PP1 garage, 1,155 in the
PP2 garage and 416 surface spaces).

Buildings I and II were built in 1987 and fully renovated in
2012/2013. The full renovation included new façade replacement and
renovation of all building systems including a new HVAC system, new
elevators, and refurbishment of the electrical systems and all
manner of system upgrades to achieve LEED Silver certification by
the US Green Building Council (USGBC). Building III was developed
in 2006 with minor renovations completed in 2013 upon the GSA's
lease execution including site work and building upgrades to
achieve LEED Silver certification by the USGBC. The campus also
received significant security upgrades commensurate with GSA
protocol.

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

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

The trust loan balance of $218,070,000 represents a Moody's LTV of
116.4%. The Moody's loan trust actual DSCR is 2.37x and Moody's
loan trust stressed DSCR at a 9.25% stressed constant is 0.86x.
There is currently no subordinate or mezzanine debt outside of the
trust.

Notable strengths of the transaction include: superior asset
quality, long term investment grade leases, and experienced
sponsorship.

Notable concerns of the transaction include: a lack of diversity
for this single asset transaction, tenant concentration, high
leverage, and a lack of amortization.

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

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

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

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

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

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


NEW RESIDENTIAL 2019-5: DBRS Finalizes B Rating on 8 Note Classes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage-Backed Notes, Series 2019-5 (the Notes) issued by New
Residential Mortgage Loan Trust 2019-5 (NRMLT or the Trust):

-- $478.8 million Class A-1 at AAA (sf)
-- $478.8 million Class A-IO at AAA (sf)
-- $478.8 million Class A-1A at AAA (sf)
-- $478.8 million Class A-1B at AAA (sf)
-- $478.8 million Class A-1C at AAA (sf)
-- $478.8 million Class A-1D at AAA (sf)
-- $478.8 million Class A1-IOA at AAA (sf)
-- $478.8 million Class A1-IOB at AAA (sf)
-- $478.8 million Class A1-IOC at AAA (sf)
-- $478.8 million Class A1-IOD at AAA (sf)
-- $536.5 million Class A-2 at AAA (sf)
-- $478.8 million Class A at AAA (sf)
-- $57.6 million Class B-1 at AAA (sf)
-- $57.6 million Class B1-IO at AAA (sf)
-- $57.6 million Class B-1A at AAA (sf)
-- $57.6 million Class B-1B at AAA (sf)
-- $57.6 million Class B-1C at AAA (sf)
-- $57.6 million Class B-1D at AAA (sf)
-- $57.6 million Class B1-IOA at AAA (sf)
-- $57.6 million Class B1-IOB at AAA (sf)
-- $57.6 million Class B1-IOC at AAA (sf)
-- $30.9 million Class B-2 at AA (sf)
-- $30.9 million Class B2-IO at AA (sf)
-- $30.9 million Class B-2A at AA (sf)
-- $30.9 million Class B-2B at AA (sf)
-- $30.9 million Class B-2C at AA (sf)
-- $30.9 million Class B-2D at AA (sf)
-- $30.9 million Class B2-IOA at AA (sf)
-- $30.9 million Class B2-IOB at AA (sf)
-- $30.9 million Class B2-IOC at AA (sf)
-- $48.3 million Class B-3 at BBB (high) (sf)
-- $48.3 million Class B3-IO at BBB (high) (sf)
-- $48.3 million Class B-3A at BBB (high) (sf)
-- $48.3 million Class B-3B at BBB (high) (sf)
-- $48.3 million Class B-3C at BBB (high) (sf)
-- $48.3 million Class B-3D at BBB (high) (sf)
-- $48.3 million Class B3-IOA at BBB (high) (sf)
-- $48.3 million Class B3-IOB at BBB (high) (sf)
-- $48.3 million Class B3-IOC at BBB (high) (sf)
-- $13.8 million Class B-4 at BBB (sf)
-- $13.8 million Class B-4A at BBB (sf)
-- $13.8 million Class B-4B at BBB (sf)
-- $13.8 million Class B-4C at BBB (sf)
-- $13.8 million Class B4-IOA at BBB (sf)
-- $13.8 million Class B4-IOB at BBB (sf)
-- $13.8 million Class B4-IOC at BBB (sf)
-- $19.3 million Class B-5 at BB (sf)
-- $19.3 million Class B-5A at BB (sf)
-- $19.3 million Class B-5B at BB (sf)
-- $19.3 million Class B-5C at BB (sf)
-- $19.3 million Class B-5D at BB (sf)
-- $19.3 million Class B5-IOA at BB (sf)
-- $19.3 million Class B5-IOB at BB (sf)
-- $19.3 million Class B5-IOC at BB (sf)
-- $19.3 million Class B5-IOD at BB (sf)
-- $27.9 million Class B-6 at B (sf)
-- $27.9 million Class B-6A at B (sf)
-- $27.9 million Class B-6B at B (sf)
-- $27.9 million Class B-6C at B (sf)
-- $27.9 million Class B6-IOA at B (sf)
-- $27.9 million Class B6-IOB at B (sf)
-- $27.9 million Class B6-IOC at B (sf)
-- $61.0 million Class B-8 at B (sf)

Classes A-IO, A1-IOA, A1-IOB, A1-IOC, A1-IOD, B1-IO, B1-IOA,
B1-IOB, B1-IOC, B2-IO, B2-IOA, B2-IOB, B2-IOC, B3-IO, B3-IOA,
B3-IOB, B3-IOC, B4-IOA, B4-IOB, B4-IOC, B5-IOA, B5-IOB, B5-IOC,
B5-IOD, B6-IOA, B6-IOB and B6-IOC are interest-only notes. The
class balances represent notional amounts.

Classes A-1A, A-1B, A-1C, A-1D, A1-IOA, A1-IOB, A1-IOC, A1-IOD,
A-2, A, B-1A, B-1B, B-1C, B-1D, B1-IOA, B1-IOB, B1-IOC, B-2A, B-2B,
B-2C, B-2D, B2-IOA, B2-IOB, B2-IOC, B-3A, B-3B, B-3C, B-3D, B3-IOA,
B3-IOB, B3-IOC, B-4A, B-4B, B-4C, B4-IOA, B4-IOB, B4-IOC, B-5A,
B-5B, B-5C, B-5D, B5-IOA, B5-IOB, B5-IOC, B5-IOD, B-6A, B-6B, B-6C,
B6-IOA, B6-IOB, B6-IOC and B-8 are exchangeable notes. These
classes can be exchanged for combinations of initial exchangeable
notes as specified in the offering documents.

The AAA (sf) ratings on the Notes reflect 27.85% of credit
enhancement provided by subordinated notes in the pool. The AA
(sf), BBB (high) (sf), BBB (sf), BB (sf) and B (sf) ratings reflect
23.70%, 17.20%, 15.35%, 12.75% and 9.00% 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 seasoned portfolio of
performing and re-performing first-lien residential mortgages
funded by the issuance of the Notes. The Notes are backed by 6,300
loans with a total principal balance of $743,535,298 as of the
Cut-Off Date (September 1, 2019).

The loans are significantly seasoned with a weighted-average (WA)
age of 175 months. As of the Cut-Off Date, 88.5% of the pool is
current, 10.5% is 30 days delinquent under the Mortgage Bankers
Association (MBA) delinquency method and 1.0% is in bankruptcy (all
bankruptcy loans are performing or 30 days delinquent).
Approximately 60.4% and 67.1% of the mortgage loans have been zero
times 30 days delinquent for the past 24 months and 12 months,
respectively, under the MBA delinquency method. The portfolio
contains 62.8% modified loans and the modifications happened more
than two years ago for 83.2% of the modified loans. The majority of
the pool, 99.5%, is exempt from the Ability-to-Repay
(ATR)/Qualified Mortgage (QM) rules because of seasoning. In
accordance with the Consumer Financial Protection Bureau's QM/ATR
rules, 0.2% of the loans are designated as QM Safe Harbor, 0.1% as
Rebuttable Presumption and 0.2% as non-QM.

The Seller, NRZ Sponsor VII LLC (NRZ), acquired the loans prior to
the Closing Date in connection with the termination of various
securitization trusts and from a whole-loan purchase. Upon
acquiring the loans, NRZ, through an affiliate, New Residential
Funding 2019-5 LLC (the Depositor), will contribute the loans to
the Trust. As the Sponsor, New Residential Investment Corp.,
through a majority-owned affiliate, will acquire and retain a 5%
eligible vertical interest in each class of securities to be issued
(other than the residual notes) to satisfy the credit risk
retention requirements under Section 15G of the Securities Exchange
Act of 1934 and the regulations promulgated thereunder. These loans
were originated and previously serviced by various entities through
purchases in the secondary market.

As of the Cut-Off Date, 45.8% of the pool is serviced by PHH
Mortgage Corporation, 43.5% by Nationstar Mortgage LLC doing
business as (d/b/a) Mr. Cooper Group, Inc. (Nationstar), 5.1% by
NewRez LLC d/b/a Shellpoint Mortgage Servicing (SMS), 4.4% by
Select Portfolio Servicing, Inc., 0.8% by PNC Mortgage and 0.5% by
Fay Servicing, LLC. Nationstar will also act as the Master Servicer
and SMS will act as the Special Servicer.

The Seller, NRZ, will have the option to repurchase any loan that
becomes 60 or more days delinquent under the MBA method or any real
estate owned property acquired in respect of a mortgage loan at a
price equal to the principal balance of the loan (Optional
Repurchase Price), provided that such repurchases will be limited
to 10% of the principal balance of the mortgage loans as of the
Cut-Off Date.

Unlike other seasoned re-performing loan securitizations, the
servicers in this transaction will advance principal and interest
on delinquent mortgages to the extent that such advances are deemed
recoverable.

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

The ratings reflect transactional strengths that include underlying
assets with significant seasoning, relatively clean payment
histories and robust loan attributes with respect to credit scores,
product types and loan-to-value ratios. Additionally, historically,
NRMLT securitizations have exhibited fast voluntary prepayment
rates.

The transaction employs a relatively weak representations and
warranties framework that includes an unrated representation
provider (NRZ), certain knowledge qualifiers and fewer mortgage
loan representations relative to DBRS Morningstar criteria for
seasoned pools.

Satisfactory third-party due diligence was performed on the pool
for regulatory compliance, title/lien and payment history. Updated
Home Data Index and/or broker price opinions were provided for the
pool; however, a reconciliation was not performed on the updated
values.

Certain loans have missing assignments or endorsements as of the
Closing Date. Given the relatively clean performance history of the
mortgages and the operational capability of the servicers, DBRS
Morningstar believes that the risk of impeding or delaying
foreclosure is remote.

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


NRZ ADVANCE 2015-ON1: S&P Assigns BB (sf) Rating to Cl. E-T4 Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to NRZ Advance Receivables
Trust 2015-ON1's advance receivables-backed notes 2019-T4.

The note issuance is a servicer advance transaction backed by
servicer advance reimbursements and accrued and unpaid servicing
fees.

The ratings reflect:

-- The strong likelihood of reimbursement of servicer advance
receivables given the priority of such reimbursement payments;

-- The transaction's revolving period, during which collections or
draws on the outstanding variable-funding note may be used to fund
additional advance receivables, and the specified eligibility
requirements, collateral value exclusions, credit enhancement test
(the collateral test), and amortization triggers intended to
maintain pool quality and credit enhancement during this period;

-- The transaction's use of predetermined, rating
category-specific advance rates for each receivable type in the
pool that discount the receivables, which are non-interest bearing,
to satisfy the interest obligations on the notes, as well as
provide for dynamic overcollateralization;

-- The projected timing of reimbursements of the servicer advance
receivables, which, in the 'AAA', 'AA', and 'A' scenarios, reflects
S&P's assumption that the servicer would be replaced, while in the
'BBB' and 'BB' scenarios, reflects the servicer's historical
reimbursement experience;

-- The credit enhancement in the form of overcollateralization,
subordination, and the series reserve accounts;

-- The timely interest and full principal payments made under
S&P's stressed cash flow modeling scenarios consistent with the
assigned ratings; and

-- The transaction's sequential turbo payment structure that
applies during any full amortization period.

  RATINGS ASSIGNED
  NRZ Advance Receivables Trust 2015-ON1 (Series 2019-T4)

  Class       Rating       Amount (mil. $)
  A-T4        AAA (sf)             330.780
  B-T4        AA (sf)               12.703
  C-T4        A (sf)                14.595
  D-T4        BBB (sf)              36.252
  E-T4        BB (sf)                5.670


OBX TRUST 2019-EXP3: Fitch to Rate Class B-5 Debt 'B(EXP)'
----------------------------------------------------------
Fitch Ratings assigned expected ratings to OBX 2019-EXP3 Trust.

OBX 2019-EXP3

Class 1-A-1;    LT AAA(EXP)sf; Expected Rating

Class 1-A-10;   LT AAA(EXP)sf; Expected Rating

Class 1-A-11;   LT AAA(EXP)sf; Expected Rating

Class 1-A-11X;  LT AAA(EXP)sf; Expected Rating

Class 1-A-12;   LT AAA(EXP)sf; Expected Rating

Class 1-A-2;    LT AAA(EXP)sf; Expected Rating

Class 1-A-3;    LT AAA(EXP)sf; Expected Rating

Class 1-A-4;    LT AAA(EXP)sf; Expected Rating

Class 1-A-5;    LT AAA(EXP)sf; Expected Rating

Class 1-A-6;    LT AAA(EXP)sf; Expected Rating  

Class 1-A-7;    LT AAA(EXP)sf; Expected Rating

Class 1-A-8;    LT AAA(EXP)sf; Expected Rating

Class 1-A-9;    LT AAA(EXP)sf; Expected Rating

Class 1-A-IO1;  LT AAA(EXP)sf; Expected Rating

Class 1-A-IO2;  LT AAA(EXP)sf; Expected Rating  

Class 1-A-IO3;  LT AAA(EXP)sf; Expected Rating

Class 1-A-IO4;  LT AAA(EXP)sf; Expected Rating

Class 1-A-IO5;  LT AAA(EXP)sf; Expected Rating

Class 1-A-IO6;  LT AAA(EXP)sf; Expected Rating

Class 1-A-IO71; LT AAA(EXP)sf; Expected Rating

Class 1-A-IO72; LT AAA(EXP)sf; Expected Rating

Class 1-A-IO81; LT AAA(EXP)sf; Expected Rating

Class 1-A-IO82; LT AAA(EXP)sf; Expected Rating

Class 2-A-1;    LT AAA(EXP)sf; Expected Rating

Class 2-A-1A;   LT AAA(EXP)sf; Expected Rating

Class 2-A-1B;   LT AAA(EXP)sf; Expected Rating

Class 2-A-2;    LT AAA(EXP)sf; Expected Rating

Class 2-A-3;    LT AAA(EXP)sf; Expected Rating

Class 2-A-IO;   LT AAA(EXP)sf; Expected Rating

Class B-1;      LT AA-(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

Class B1-A;     LT AA-(EXP)sf; Expected Rating

Class B1-IO;    LT AA-(EXP)sf; Expected Rating

Class B2-1;     LT A+(EXP)sf;  Expected Rating

Class B2-1-A;   LT A+(EXP)sf;  Expected Rating

Class B2-1-IO;  LT A+(EXP)sf;  Expected Rating

Class B2-2;     LT A(EXP)sf;   Expected Rating

Class B2-2-A;   LT A(EXP)sf;   Expected Rating

Class B2-2-IO;  LT A(EXP)sf;   Expected Rating

TRANSACTION SUMMARY

The notes are supported by 735 loans with a total unpaid principal
balance of approximately $465.5 million as of the cut-off date. The
pool consists of fixed-rate mortgages (FRMs) and adjustable-rate
mortgages (ARMs) acquired by Annaly Capital Management, Inc. from
various originators and aggregators. Distributions of principal and
interest and loss allocations are based on a traditional
senior-subordinate, shifting-interest Y-structure.

The 'AAAsf' rating on the class A notes reflects the 12.60%
subordination provided by the 1.60% class B-1, 3.50% class B2-1,
2.00% class B2-2, 2.15% class B-3, 1.50% class B-4, 0.65% class B-5
and 1.20% class B-6 notes.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The pool consists primarily
of 30-year fixed-rate and adjustable-rate fully amortizing loans to
borrowers with strong credit profiles, relatively low leverage and
large liquid reserves. The loans are seasoned an average of 15
months.

The pool has a weighted average (WA) model FICO score of 757, high
average balance of $633,322 and a low sustainable loan-to-value
(sLTV) ratio of 65.8%.

Bank Statement and Investor property Concentration (Negative): The
pool also contains a meaningful amount of investor properties
(32.3%), non-qualified mortgage (non-QM) or higher-priced qualified
mortgage (HPQM) loans (60.6%), and non-full documentation loans
(62.8%). Fitch's loss expectations reflect the higher default risk
associated with these attributes as well as loss severity
adjustments for potential ability-to-repay (ATR) challenges. Higher
LS assumptions are assumed for the investor property product to
reflect potential risk of a distressed sale or disrepair.

Low Operational Risk (Positive): Operational risk is
well-controlled in this transaction. Annaly employs an effective
loan aggregation process and has an 'Average' assessment from
Fitch. Approximately 78.6% of the loans are being serviced by
Select Portfolio Servicing, Inc. (SPS), which is rated 'RPS1-', and
the remaining 21.4% is being serviced by Specialized Loan
Servicing, LLC (SLS), which is rated 'RPS2' for this product. The
issuer's retention of at least 5% of the bonds helps ensure an
alignment of interest between issuer and investor.

Representation and Warranty Framework (Negative): Fitch considers
the transaction's representation, warranty and enforcement (RW&E)
mechanism framework to be consistent with Tier 2 quality. The RW&Es
are being provided by Onslow Bay Financial, LLC, which does not
have a financial credit opinion or public rating from Fitch. While
an automatic review can be triggered by loan delinquencies and
losses, the triggers can toggle on and off from period to period.
Additionally, a high threshold of investors is needed to direct the
trustee to initiate a review. The Tier 2 framework and non-rated
counterparty resulted in a loss penalty of 73 bps AAAsf.

Third-Party Due Diligence (Positive): A very low incidence of
material defects was found in the third-party credit, compliance
and valuation due diligence performed on 100% of loans where
applicable. A third party review (TPR) was conducted by AMC,
Clayton and IngletBlair; both AMC and Clayton are assessed by Fitch
as 'Acceptable - Tier 1' and IngletBlair is assessed as 'Acceptable
- Tier 2'. The due diligence results are in line with industry
averages, and based on loan count, 99% were graded 'A' or 'B'.
Since loan exceptions either had strong mitigating factors or were
accounted for in Fitch's loan loss model, no additional adjustments
were made. The model credit for the high percentage of loan level
due diligence combined with the adjustments for loan exceptions
reduced the 'AAAsf' loss expectation by 31 bps.

Servicing Advancing (Neutral): Advances of delinquent P&I will be
made on the mortgage loans for the first 120 days of delinquency to
the extent such advances are deemed recoverable. P&I advances will
be made from amounts on deposit for future distribution, the excess
servicing strip fee that would otherwise be allocable to the class
A-IO-S notes and the P&I advancing party fee. If such amounts are
insufficient, the P&I advancing party (Onslow Bay Financial LLC)
will be responsible for any remaining amounts. In the event the
underlying obligations are not fulfilled, Wells Fargo Bank, N.A.,
as master servicer, will be required to make advances.

High California Concentration (Negative): Approximately 48.% of the
pool is located in California, which is higher than many other
recent Fitch-rated transactions. In addition, the metropolitan
statistical area (MSA) concentration is large, as the top three
MSAs (Los Angeles, New York and San Francisco) account for 58.8% of
the pool. As a result, a geographic concentration penalty of 1.14x
was applied to the probability of default (PD).

Straightforward Deal Structure (Positive): The mortgage cash flow
and loss allocations are based on a traditional senior-subordinate,
shifting-interest Y-structure, whereby the subordinate classes
receive only scheduled principal and are locked out from receiving
unscheduled principal or prepayments for five years. The applicable
credit support percentage feature redirects subordinate principal
to classes of higher seniority if specified credit enhancement (CE)
levels are not maintained.

CE Floor (Positive): To mitigate tail risk, which arises as the
pool seasons and fewer loans are outstanding, a subordination floor
of 1.90% of the original balance will be maintained for the notes.
Additionally, there is no early stepdown test that might allow
principal prepayments to subordinate bondholders earlier than the
five-year lockout schedule.

Extraordinary Expense Treatment (Neutral): The trust provides for
expenses, including indemnification amounts and costs of
arbitration, to be paid by the net WA coupon of the loans, which
does not affect the contractual interest due on the notes.
Furthermore, the expenses to be paid from the trust are capped at
$275,000 per annum, which can be carried over each year, subject to
the cap until paid in full.

RATING SENSITIVITIES

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

Fitch conducted sensitivity analysis determining how the ratings
would react to steeper MVDs at the national level. The analysis
assumes MVDs of 10.0%, 20.0%, and 30.0%, in addition to the
model-projected 3.1%. The analysis indicates there is some
potential rating migration with higher MVDs, compared with the
model projection.

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


PARK AVENUE 2019-2: S&P Assigns BB- (sf) Rating to Cl. D Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to Park Avenue
Institutional Advisers CLO Ltd. 2019-2/Park Avenue Institutional
Advisers CLO LLC 2019-2's floating-rate notes.

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

The ratings reflect:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED

  Park Avenue Institutional Advisers CLO Ltd. 2019-2/Park Avenue
  Institutional Advisers CLO LLC 2019-2

  Class                Rating       Amount (mil. $)
  A-1                  AAA (sf)              255.00
  A-2                  AA (sf)                49.00
  B (deferrable)       A (sf)                 24.00
  C (deferrable)       BBB- (sf)              23.00
  D (deferrable)       BB- (sf)               14.00
  Subordinated notes   NR                     34.65

  NR--Not rated.


PAWNEE EQUIPMENT 2019-1: DBRS Finalizes BB Rating on Class E Notes
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of asset-backed notes issued by Pawnee Equipment
Receivables (Series 2019-1) LLC (the Issuer):

-- $67,000,000 Series 2019-1, Class A-1 Notes at R-1 (high) (sf)
-- $144,430,000 Series 2019-1, Class A-2 Notes at AAA (sf)
-- $11,510,000 Series 2019-1, Class B Notes at AA (sf)
-- $10,150,000 Series 2019-1, Class C Notes at A (sf)
-- $12,180,000 Series 2019-1, Class D Notes at BBB (sf)
-- $8,934,000 Series 2019-1, Class E Notes at BB (sf)

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

-- Transaction capital structure, proposed ratings and sufficiency
of available credit enhancement, which includes
overcollateralization, subordination and amounts held in the
reserve account to support the DBRS Morningstar-projected
cumulative net loss (CNL) 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
three-month prefunding period.

-- The capabilities of Pawnee Leasing Corporation (Pawnee) with
regard to originations, underwriting and servicing. DBRS
Morningstar has performed an operational review of Pawnee and
considers the entity to be an acceptable originator and servicer of
equipment-backed lease and loan contracts. In addition, Portfolio
Financial Servicing Company, an experienced servicer of equipment
lease-backed securitizations, will be the Backup Servicer for the
transaction.

-- The expected Asset Pool does not contain any significant
concentrations of obligors, brokers or geographies and consists of
a diversified mix of the equipment types similar to those included
in other small-ticket lease and loan securitizations rated by DBRS
Morningstar.

-- 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 Pawnee and that the Indenture
Trustee has a valid first-priority security interest in the assets.
The transaction terms are also reviewed for consistency with the
DBRS Morningstar "Legal Criteria for U.S. Structured Finance."

-- The Company focuses on small-ticket financing ($250,000 cap for
prime credits and lower for near-prime and non-prime credits). No
non-prime credits will be included in the collateral for the Notes;
however, up to 17.95% of the collateral may comprise B+ credits
(weighted-average non-zero guarantor Beacon Score of 708 as of the
Statistical Calculation Date compared with a score of 752 for A
credits as of the same date). Automated Clearing House is required
on approximately 100% of B+ credit contracts (compared with about
68% for A credit contracts). In addition, as of the Statistical
Calculation Date, close to 100% of B+ collateral in the Statistical
Asset Pool was supported by personal guarantees (compared with
approximately 89% for A credits).

-- Under various stressed cash flow scenarios, credit enhancement
can withstand the expected loss using DBRS Morningstar multiples of
5.55 times (x) with respect to the Class A Notes and 4.55x, 3.65x,
2.60x and 1.90x with respect to the Class B Notes, the Class C
Notes, the Class D Notes and the Class E Notes, respectively. DBRS
Morningstar assumes a 4.00% expected base case CNL for the
transaction.

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


RAPTOR AIRCRAFT: S&P Assigns Prelim BB (sf) Rating to Class C Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the series
2019-1 series A, B, and C fixed-rate notes issued by Raptor
Aircraft Finance I Ltd. (the Cayman issuer), an exempted Cayman
Islands limited liability company, and Raptor Aircraft Finance I
LLC (the U.S. issuer), a Delaware limited liability company
(collectively, Raptor).

The note issuance is an ABS transaction backed by 19 aircraft, and
the related leases, shares, and beneficial interests in an entity
that directly and indirectly receives aircraft portfolio lease
rental and residual cash flows, among others.

The preliminary ratings are based on information as of Oct. 11,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The likelihood of timely interest on the series A notes
(excluding step up interest) on each payment date, timely interest
on the series B notes (excluding step-up interest) when the series
A notes are no longer outstanding on each payment date prior to the
subordination date (14 years from the closing date), and ultimate
interest and principal payment on the series A, B, and C notes on
or before the legal final maturity date at the respective 'A',
'BBB', and 'BB' rating stress scenarios.

-- The approximately 67% loan-to-value (LTV) ratio on the series A
notes, the 81% LTV on the series B notes, and the 88% LTV on the
series C notes. The LTV ratio is based on the lower of the mean and
median (LMM) of the half-life base value and the half-life current
market value.

-- The aircraft portfolio consists of approximately 67%
narrow-body aircraft (39% from the Airbus A320 family and 28% from
the Boeing B737 family) and 33% wide-body aircraft (20% from the
A330 family and 12% from the B787 family) by the LMM of the
half-life value. All of the aircraft models are in production.

-- The weighted average age (by value) of the aircraft in the
portfolio is 3.92 years. Currently, all 19 of the aircraft are on
lease, with a weighted average remaining term of approximately 6.78
years.

-- Some of the lessees are in emerging markets where the
commercial aviation market is growing. The existing and future
lessees' estimated credit quality and diversification. The 19
aircraft are currently leased to 14 airlines in 12 countries. Some
of the initial lessees have low credit quality, and approximately
80% of the lessees (by aircraft value) are domiciled in emerging
markets. Three of the 19 aircraft are leased to flag carriers
internationally.

-- Each series' scheduled amortization profile, which is a
straight line over 14 years for series A and B and a straight line
over seven years for series C.

-- The transaction's debt service coverage ratio (DSCRs) and
utilization triggers--a failure of which will result in the series
A and B notes' turbo amortization. Turbo amortization for the
series A and B notes will also occur if they are outstanding after
year seven.

-- The subordination of series C principal and interest to series
A and B principal and interest.

-- A revolving credit facility that BNP Paribas will provide and
that will be available to cover senior expenses, including hedge
payments and interest on the series A and, prior to the
subordination date, series B notes.

-- Alton Aviation Consulting LLC (Alton) performed a maintenance
analysis before closing. After closing, the servicer will perform a
forward-looking 27-month maintenance analysis at least annually,
which Alton will review and confirm for reasonableness and
achievability.

-- The maintenance reserve account (funded to $1.0 million balance
at closing), which receives senior payments from the waterfall,
based on the projected maintenance expenses during the next six
months of the transaction, and junior payments, based on the
projected maintenance expenses during the next 12 months of the
transaction. After month 84, the senior payments will be based on
the next 16 months of projected expenses.

-- The expense reserve account, which will be funded at closing
with approximately $500,000 from the note proceeds and is expected
to cover the next three months of expenses. The series C reserve
account, which will be funded at closing with approximately
$500,000 from the note proceeds. The initial average lease rate
factor of 0.95%, (based on the LMM of half-life values), as
measured by the portfolio's weighted average lease rate factor
based on aircraft half-life value.

-- The senior indemnification (excluding indemnification amounts
to lessees under leases entered into before the transaction closing
date) is capped at $10 million and modeled to occur during the
first 12 months.

-- The junior indemnification (uncapped) is subordinated to the
rated series' principal payment.

-- Seraph, an aircraft lessor, is the servicer for this
transaction.

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

  PRELIMINARY RATINGS ASSIGNED
  Raptor Aircraft Finance I Ltd./Raptor Aircraft Finance I LLC

  Series     Rating     Amount (mil. $)
  A          A (sf)             553.000
  B          BBB (sf)           116.500
  C          BB (sf)             56.500


RCKT MORTGAGE 2019-1: Moody's Assigns B1 Rating on Cl. B-5 Debt
---------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to 23 classes
of residential mortgage-backed securities issued by RCKT Mortgage
Trust 2019-1. The ratings range from Aaa (sf) to B1 (sf).

RCKT Mortgage Trust 2019-1 is a securitization of prime jumbo and
agency-eligible mortgage loans originated and serviced by Quicken
Loans Inc. (rated long-term senior unsecured Ba1). The assets of
the trust consist of 464 first lien, fully amortizing, fixed-rate
qualified mortgage (QM) loans, each with an original term to
maturity of 30 years.

The transaction will be sponsored by Woodward Capital Management
LLC and will be the first transaction for which Quicken Loans is
the sole originator and servicer. There is no master servicer in
this transaction. Citibank, N.A. (Citibank, rated long-term senior
unsecured Aa3) will be the securities administrator and the trustee
will be Wilmington Savings Fund Society, FSB.

The transaction benefits from a collateral pool that is of high
credit quality and is further supported by an unambiguous
representation and warranty (R&W) framework and a shifting interest
structure that incorporates a subordination floor.

Transaction credit strengths include the high credit quality of the
collateral pool, the strong third-party review results, and the
prescriptive, unambiguous R&W framework. Transaction credit
weaknesses include having no master servicer to oversee the primary
servicer, unlike typical prime jumbo transactions, as well as
limited performance history for Quicken Loans' prime jumbo
originations.

The complete rating actions are as follows:

Issuer: RCKT Mortgage Trust 2019-1

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

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

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

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

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

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

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

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

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

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

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

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

Cl. A-13, Definitive Rating Assigned Aa1 (sf)

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

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

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

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

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

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

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

Cl. B-3, Definitive Rating Assigned Baa2 (sf)

Cl. B-4, Definitive Rating Assigned Ba1 (sf)

Cl. B-5, Definitive Rating Assigned B1 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 0.45%
in a base scenario and is 5.30% at a stress level consistent with
the Aaa (sf) ratings.

Its loss estimates are based on a loan-by-loan assessment of the
securitized collateral pool as of the cut-off date using Moody's
Individual Loan Level Analysis model. Loan-level adjustments to the
model included adjustments to borrower probability of default for
higher and lower borrower debt-to-income ratios, for borrowers with
multiple mortgaged properties, self-employed borrowers, origination
channels and for the default risk of Homeownership association
(HOA) properties in super lien states. The model combines
loan-level characteristics with economic drivers to determine the
probability of default for each loan, and hence for the portfolio
as a whole. Severity is also calculated on a loan-level basis. The
pool loss level is then adjusted for borrower, zip code, and MSA
level concentrations.

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

Collateral Description

The RCKT 2019-1 transaction is a securitization of 464 first lien
residential mortgage loans with an unpaid principal balance of
$350,114,606. The collateral pool includes 362 prime jumbo mortgage
loans comprising 82.6% of the aggregate pool balance underwritten
to Quicken Loans' prime jumbo guidelines. The remaining 102
mortgage loans comprising 17.4% of the collateral pool balance are
agency-eligible loans underwritten to either or both of the Fannie
Mae or Freddie Mac guidelines.

The loans in this transaction have strong borrower characteristics
with a weighted average original FICO score of 767 and a
weighted-average original loan-to-value ratio (LTV) of 71.4%. In
addition, approximately 23.1% of the borrowers are self-employed
and refinance loans comprise 49.8% of the aggregate pool. The pool
has a high geographic concentration with 42.9% of the aggregate
pool related to mortgages originated in California.

Origination Quality

Quicken Loans (rated long-term senior unsecured Ba1), founded in
1985 and headquartered in Detroit, Michigan, is the second-largest
overall US residential mortgage originator and the largest retail
originator.

Quicken Loans' origination of agency-eligible loans is designed to
be executed in accordance with underwriting guidelines established
by the Fannie Mae Single Family Selling Guide and the Freddie Mac
Single Family Seller/Servicer Guide.

Quicken Loans' prime jumbo guidelines are comparable with those of
other prime jumbo originators. The guidelines generally adhere to
the underwriting guidelines established by Fannie Mae and Qualified
Mortgage Appendix Q, except for loan amount, certain underwriting
ratios, and certain documentation requirements.

Moody's considers Quicken Loans an adequate originator of prime
jumbo and agency-eligible mortgage loans based on its staff and
processes for underwriting, quality control and risk management.

However, Moody's applied an adjustment to its expected losses for
the prime jumbo mortgage loans due to the limited performance
history for Quicken Loans' prime jumbo mortgage originations. While
the performance of such loans was strong and comparable to that of
other originators such as JPMorgan Chase and Wells Fargo, the
volume of Quicken Loans' originations is much lower. Moody's also
notes that the available performance data of such prime jumbo loans
covers a recent period in a relatively benign economic environment
and Moody's has less insight into how such loans may perform in a
stressed economic environment than Moody's does for other
originators.

Servicing Arrangement

Quicken Loans has been servicing residential mortgage loans since
2009 and retains the mortgage servicing rights on the majority of
its mortgage loan originations. Quicken Loans primarily services
mortgages for Fannie Mae, Freddie Mac and Ginnie Mae and is a
Fannie Mae 5-star servicer for General Servicing and Solutions
Delivery.

Quicken Loans has the necessary processes, staff, technology and
overall infrastructure in place to effectively service this
securitized pool. Quicken Loans is responsible for advancing
delinquent interest and principal for loans that are less than 120
days delinquent. In the event Quicken Loans is unable to make such
advances, Citibank as securities administrator is required to do
so.

Moody's assesses the overall servicing arrangement for this pool as
adequate, given the ability, scale and experience of Quicken Loans
as a servicer, while noting that the servicing arrangement is
weaker than other prime jumbo transactions which typically have a
master servicer.

While the lack of a master servicer is not unique to transactions
backed by seasoned performing and re-performing mortgage loans, it
is unique to post-crisis transactions backed by newly originated
prime mortgage loans. Furthermore, the servicers in such seasoned
performing and re-performing transactions are third-parties,
whereas the servicer, originator, and R&W provider are the same
party in RCKT 2019-1. RCKT 2019-1's unique servicing arrangement
presents risks such as (1) weaker servicer oversight and (2) weaker
alignment of interest compared to the typical prime jumbo
transactions, since the originator, servicer and R&W provider are
the same party.

Though a third-party review of Quicken Loans' servicing operations,
performance and regulatory compliance will be conducted at least
annually by an independent accounting firm, as well as by the
government-sponsored entities, the Consumer Financial Protection
Bureau and state regulators, such oversight lacks the depth and
frequency that a master servicer would provide for this
transaction.

Given that Quicken Loans is the loan originator, R&W provider and
the servicer in this transaction, a potential conflict of interest
could arise if Quicken Loans were to modify delinquent loans prior
to 120 day delinquency in order to avoid triggering the R&W review.
However, this risk is mitigated by the inclusion of a breach review
trigger if a mortgage loan is modified before becoming 120 days
delinquent.

However, Moody's did not apply an adjustment to its expected losses
for the weaker servicing arrangement due to the following:

(1) Quicken Loans' relative financial strength, scale, franchise
value, experience and demonstrated ability as a servicer. Also,
Quicken Loans is a Fannie Mae 5-star servicer for General Servicing
and Solutions Delivery.

(2) Citibank is an experienced securities administrator and will be
responsible for making advances of delinquent interest and
principal if Quicken Loans is unable to do so and for reconciling
monthly remittances of cash by Quicken Loans.

(3) The R&W framework is strong and includes triggers for
delinquency and modification, which ensure that poorly performing
mortgage loans will be reviewed by a third-party and mitigates the
risk from misalignment of interest.

(4) The mortgage pool is of high credit quality and a third-party
review firm has conducted due diligence on 100% of the mortgage
loans in the pool with satisfactory results.

Third-Party Due Diligence Review

One independent third-party review firm, AMC Diligence LLC (AMC),
was engaged to conduct due diligence for the credit, regulatory
compliance, property valuation, and data accuracy for the 464 loans
in the initial population of this transaction.

The credit review consisted of a review of the documentation in
each loan file relating to the creditworthiness of the borrowers,
and an assessment of whether the characteristics of the mortgage
loans and the borrowers reasonably conformed to Quicken Loans'
underwriting guidelines. Where there were exceptions to guidelines,
the TPR firm noted compensating factors. Additionally, the TPR firm
evaluated evidence of the borrower's willingness and ability to
repay the obligation. AMC did not identify any material credit
issues.

AMC's regulatory compliance review consisted of a review of
compliance with the Truth-in-Lending Act and the Real Estate
Settlement Procedures Act among other federal, state and local
regulations. Additionally, the TPR firm applied SFIG's enhanced
RMBS 3.0 TRID Compliance Review Scope. AMC did not identify any
material compliance issues.

AMC's property valuation review consisted of reviewing the
valuation materials utilized at origination to ensure the appraisal
report was complete and in conformity with the underwriting
guidelines. The TPR firm also compared third-party valuation
products to the original appraisals. The appraisals for the
agency-eligible loans were checked using Fannie Mae's Collateral
Underwriter and those for the prime jumbo loans were checked using
desktop review and/or field reviews. Negative variances greater
than 10% were reported and in some cases additional appraisals were
performed which eventually showed immaterial or no variance.

AMC also sought to identify data discrepancies in comparing the
data tape to the information utilized during their reviews. Most of
the data integrity findings in the initial population were due to
refinance purpose discrepancies which were subsequently revised in
the collateral tape.

Representations & Warranties (R&W)

Moody's assessed RCKT 2019-1's R&W framework for this transaction
as adequate, consistent with that of other prime jumbo transactions
for which an independent reviewer is named at closing, the breach
review process is thorough, transparent and objective, and the
costs and manner of review are clearly outlined at issuance. An
effective R&W framework protects a transaction against the risk of
loss from fraudulent or defective loans.

Moody's assessed the R&W framework based on three factors: (a) the
financial strength of the R&W provider; (b) the strength of the
R&Ws (including qualifiers and sunsets) and (c) the effectiveness
of the enforcement mechanisms. Moody's applied an adjustment to its
expected losses to account for the risk that Quicken Loans may be
unable to repurchase defective loans in a stressed economic
environment, given that it is a non-bank entity with a monoline
business (mortgage origination and servicing) that is highly
correlated with the economy. However, Moody's tempered this
adjustment by taking into account Quicken Loans' relative financial
strength and the strong TPR results which suggest a lower
probability that poorly performing mortgage loans will be found
defective following review by the independent reviewer.

Transaction Structure

The securitization has a shifting interest structure that benefits
from a senior floor and a subordinate floor. Funds collected,
including principal, are first used to make interest payments and
then principal payments to the senior bonds, and then interest and
principal payments to each subordinate bond. As in all transactions
with shifting interest structures, the senior bonds benefit from a
cash flow waterfall that allocates all unscheduled principal
collections to the senior bond for a specified period and
increasing amounts of unscheduled principal collections to the
subordinate bonds thereafter, but only if loan performance
satisfies delinquency and loss tests.

Realized losses are allocated reverse sequentially among the
subordinate and senior support certificates and on a pro-rata basis
among the super senior certificates.

Structural Considerations

Similar to recently rated Sequoia transactions, RCKT 2019-1
contains a structural deal mechanism that will control stop
advances on delinquent loans. The stated rationale for the proposed
mechanism is to remove ambiguity and servicer discretion in
advancing. Although this feature lowers the risk of high advances
that may negatively affect the recoveries on liquidated loans, the
reduction in interest distribution amount is credit negative to the
subordinate bonds but credit positive for the senior bonds.

The servicer and the securities administrator will not advance
principal and interest to loans that are 120 days or more
delinquent. The balance and the interest accrued on such stop
advance mortgage loans (SAML) will be removed from the calculation
of the principal and interest distribution amounts with respect to
the seniors and subordinate bonds. The interest distribution amount
will be reduced by the interest accrued on the SAML loans. This
reduction will be allocated first to the class of certificates with
the lowest payment priority and then to the class of certificates
with the next lowest payment priority, and so on. Net interest
shortfalls will be allocated among all classes of the senior
certificates pro rata. Once a SAML is liquidated, the net recovery
from that loan's liquidation is allocated first to pay down the
loan's outstanding principal amount and then to repay its accrued
interest. The recovered accrued interest on the loan is used to
repay the interest reduction incurred by the bonds that resulted
from that SAML. There may be scenarios where a senior bond may have
an outstanding interest shortfall, but a junior bond continues to
receive its principal distribution.

While the transaction is backed by collateral with strong credit
characteristics and, as such, Moody's expects strong performance
similar to other prime jumbo deals, Moody's considered scenarios in
which the delinquency pipeline rises, and interest distribution
amounts are reduced. The final ratings on the bonds reflect the
additional loss that the bonds may incur due to interest shortfall
on the bonds from SAML.

Exposure to Extraordinary Trust Expenses

Extraordinary trust expenses in the RCKT 2019-1 transaction are
deducted directly from the available distribution amount with a
reduction to the Net WAC Rate. Although some of the expenses are
capped ($575,000 per year, out of which amount the trustee may only
be reimbursed in an aggregate amount of $200,000), the unpaid
amount will carry forward and constitute trust expenses on all
future distribution dates until they are paid in full. Moody's
believes there is a very low likelihood that the rated certificates
in RCKT 2019-1 will incur any losses from extraordinary expenses or
indemnification payments from potential future lawsuits against key
deal parties. Firstly, the loans are qualified mortgages of prime
quality and were originated under a regulatory environment that
requires tighter controls for originations than pre-crisis, which
reduces the likelihood that the loans have defects that could form
the basis of a lawsuit. Secondly, the transaction has reasonably
well-defined processes in place to identify loans with defects on
an ongoing basis. In this transaction, an independent breach
reviewer (Pentalpha Surveillance LLC) engaged at closing must
review loans for breaches of representations and warranties when
certain clearly defined triggers have been breached, which reduces
the likelihood that parties will be sued for inaction. Thirdly, the
issuer has disclosed the results of a credit, compliance and
valuation review of all the mortgage loans by an independent
third-party (AMC) and results are satisfactory. Finally, since the
extraordinary trust expenses are deducted from the available funds
with a reduction to net WAC, Moody's did not make any adjustment to
its expected losses.

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

Down

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

Up

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

Methodology

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


REGATTA XII F: S&P Rates $15MM Class E Notes 'BB- (sf)'
-------------------------------------------------------
S&P Global Ratings assigned its ratings to Regatta XII Funding
Ltd./Regatta XII Funding LLC's floating-rate notes.

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

The 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.

  RATINGS ASSIGNED
  Regatta XII Funding Ltd./Regatta XII Funding LLC

  Class                Rating     Amount (mil. $)
  A-1                  AAA (sf)            248.00
  A-2                  AAA (sf)             13.00
  B                    AA (sf)              43.00
  C (deferrable)       A (sf)               24.00
  D (deferrable)       BBB- (sf)            22.60
  E (deferrable)       BB- (sf)             15.00
  Subordinated notes   NR                   43.00

  NR--Not rated.


RESIDENTIAL MORTGAGE 2019-3: DBRS Finalizes B Rating on B-2 Notes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the Mortgage-Backed
Notes, Series 2019-3 (the Notes) issued by Residential Mortgage
Loan Trust 2019-3 (the Issuer) as follows:

-- $165.5 million Class A-1 at AAA (sf)
-- $16.5 million Class A-2 at AA (sf)
-- $30.4 million Class A-3 at A (sf)
-- $17.2 million Class M-1 at BBB (sf)
-- $14.3 million Class B-1 at BB (sf)
-- $11.1 million Class B-2 at B (sf)

The AAA (sf) rating on the Notes reflects the 36.80% of credit
enhancement provided by subordinated Notes in the pool. The AA
(sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect 30.50%,
18.90%, 12.35%, 6.90% and 2.65% of credit enhancement,
respectively.

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

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate, expanded prime and non-prime, primarily first-lien
residential mortgages funded by the issuance of the Notes. The
Notes are backed by 633 mortgage loans with a total principal
balance of $261,945,031 as of the Cut-Off Date (September 1,
2019).

The originators for the mortgage pool are HomeXpress Mortgage Corp.
(49.5%); Athas Capital Group Inc. (19.4%); GreenBox Loans, Inc.
(18.3%); and other originators, which comprise 12.9% of the
mortgage loans. The Servicer of the loans is Servis One, Inc. doing
business as BSI Financial Services.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's Qualified Mortgage (QM) and
Ability-to-Repay (ATR) rules, they were made to borrowers who
generally do not qualify for agency, government or private-label
non-agency prime jumbo products for various reasons. In accordance
with the QM/ATR rules, 69.6% of the loans are designated as non-QM
and 1.0% as QM-Rebuttable Presumption. Approximately 29.4% of the
loans are made to investors for business purposes and, hence, are
not subject to the QM/ATR rules.

The Sponsor, directly or indirectly through a majority-owned
affiliate, will retain an eligible horizontal residual interest
consisting of the Class B-3 and Class XS Notes representing at
least 5% of the Notes to satisfy the credit risk-retention
requirements under Section 15G of the Securities Exchange Act of
1934 and the regulations promulgated thereunder.

On or after the earlier of (1) the two-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, the Administrator, at the Issuer's option, may redeem all
of the outstanding Notes at a price equal to the class balances of
the related Notes plus accrued and unpaid interest, including any
cap carryover amounts. After such purchase, the Depositor must
complete a qualified liquidation, which requires (1) a complete
liquidation of assets within the Trust and (2) proceeds to be
distributed to the appropriate holders of regular or residual
interests.

The Representation Provider will have the option, but not the
obligation, to repurchase any mortgage loan that becomes 90 or more
days delinquent at the repurchase price (par plus interest),
provided that such repurchases in aggregate do not exceed 10% of
the total principal balance as of the Cut-Off Date.

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

The transaction employs a sequential-pay cash flow structure with a
pro rata principal distribution among the senior tranches.
Principal proceeds can be used to cover interest shortfalls on the
Notes as the outstanding senior Notes are paid in full.
Furthermore, excess spread can be used to cover realized losses
first before being allocated to unpaid cap carryover amounts up to
Class B-2.

The DBRS Morningstar 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 Morningstar 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.


SCF EQUIPMENT 2019-2: Moody's Assigns (P)B3 Rating on Cl. F Notes
-----------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to the
Equipment Contract Backed Notes, Series 2019-2, Class A, Class B,
Class C, Class D, Class E, and Class F to be issued by SCF
Equipment Leasing 2019-2 LLC and SCF Equipment Leasing Canada
2019-2 Limited Partnership. Stonebriar Commercial Finance LLC
(unrated) along with its Canadian counterpart - Stonebriar
Commercial Finance Canada Inc. (unrated) are the originators and
Stonebriar alone will be the servicer of the assets backing this
transaction. The issuers are wholly-owned, limited purpose
subsidiaries of Stonebriar and Stonebriar Commercial Finance Canada
Inc. The assets in the pool will consist of loan and lease
contracts, secured primarily by railcars, corporate aircraft, and
manufacturing and assembly equipment. The Series 2019-2 transaction
will be the sixth securitization sponsored by Stonebriar and fifth
that Moody's rates. Stonebriar was founded in 2015 and is led by a
management team with an average of over 25 years of experience in
equipment financing.

The complete rating actions are as follows:

Issuer: SCF Equipment Leasing 2019-2 LLC/SCF Equipment Leasing
Canada 2019-2 L.P.

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

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

Class B Notes, Assigned (P)Aa2 (sf)

Class C Notes, Assigned (P)A3 (sf)

Class D Notes, Assigned (P)Baa2 (sf)

Class E Notes, Assigned (P)Ba3 (sf)

Class F Notes, Assigned (P)B3 (sf)

RATINGS RATIONALE

The provisional ratings are based on; the experience of
Stonebriar's management team and the company as servicer; U.S. Bank
National Association (long-term deposits Aa1/ long-term CR
assessment Aa2(cr), short-term deposits P-1, BCA aa3) as backup
servicer for the contracts; the weak credit quality and
concentration of the obligors backing the loans and leases in the
pool; the assessed value of the collateral backing the loans and
leases in the pool; the credit enhancement, including
overcollateralization, excess spread and non-declining reserve
account and the sequential pay structure.

At closing the Class A, Class B, Class C, Class D, Class E and
Class F notes benefit from 35.00%, 26.00%, 18.25%, 16.50%, 12.00%
and 6.50% of hard credit enhancement, respectively. Hard credit
enhancement for the notes consists of a combination of initial
overcollateralization of 3.50% which will build to a target of
7.50% of the outstanding pool balance with a floor of 5.50% of the
initial pool balance, a 1.50% fully funded, non-declining reserve
account and subordination. The notes will also benefit from excess
spread.

The equipment loans and leases that will back the notes were
extended primarily to middle market obligors and are secured by
various types of equipment including; aircraft, railcars,
manufacturing and assembly equipment, and a training facility.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's
Approach to Rating ABS Backed by Equipment Leases and Loans"
published in March 2019.

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

Up

Moody's could upgrade the ratings on the notes if levels of credit
protection are greater than necessary to protect investors against
current expectations of loss. Moody's updated expectations of loss
may be better than its original expectations because of lower
frequency of default by the underlying obligors or lower than
expected depreciation in the value of the equipment that secure the
obligor's promise of payment. As the primary drivers of
performance, positive changes in the US macro economy and the
performance of various sectors where the obligors operate could
also affect the ratings.

Down

Moody's could downgrade the ratings of the notes if levels of
credit protection are insufficient to protect investors against
current expectations of loss. Moody's updated expectations of loss
may be worse than its original expectations because of higher
frequency of default by the underlying obligors of the contracts or
a greater than expected deterioration in the value of the equipment
that secure the obligor's promise of payment. As the primary
drivers of performance, negative changes in the US macro economy
could also affect Moody's ratings. Other reasons for worse
performance than Moody's expectations could include poor servicing,
error on the part of transaction parties, lack of transaction
governance and fraud.


SG COMMERCIAL 2019-PREZ: S&P Assigns B- (sf) Rating to Cl. F Certs
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to SG Commercial Mortgage
Securities Trust 2019-PREZ's commercial mortgage pass-through
certificates.

The certificate issuance is a commercial mortgage-backed securities
transaction backed by the $157.6 million portion of a $217.6
million, 10-year, fixed-rate, interest-only mortgage loan secured
by the fee simple interest in a four-building apartment complex
with 1,015 units (Presidential City) and in an adjacent office
building located in Philadelphia, Pa. The commercial mortgage loan
will be serviced and administered according to the trust and
servicing agreement for this securitization.

The ratings reflect S&P's view of the collateral's historical and
projected performance, the sponsors' and managers' experience, the
trustee-provided liquidity, the loan's terms, and the transaction's
structure.

  RATINGS ASSIGNED
  SG Commercial Mortgage Securities Trust 2019-PREZ

  Class       Rating(i)        Amount ($)
  A           AAA (sf)         48,469,000
  X           A- (sf)          86,060,500(ii)
  B           AA- (sf)         19,019,000
  C           A- (sf)          18,572,500
  D           BBB- (sf)        19,009,500
  E           BB- (sf)         22,116,000
  F           B- (sf)          22,534,000
  VRR(iii)    NR                7,880,000

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



SKOPOS AUTO 2018-1: DBRS Confirms BB Rating on Class D Notes
------------------------------------------------------------
DBRS, Inc. took rating actions on four outstanding ratings from
Skopos Auto Receivables Trust 2018-1. Of the four classes, two were
upgraded and two were confirmed. For the ratings that were
upgraded, performance trends are such that credit enhancement
levels are sufficient to cover DBRS Morningstar's expected losses
at their new respective rating levels. For the notes that were
confirmed, performance trends are such that credit enhancement
levels are sufficient to cover DBRS Morningstar's expected losses
at their current respective rating levels.

The ratings are:

Skopos Auto Receivables Trust 2018-1

                  Action      Rating

Class A Notes     Upgraded    AAA(sf)
Class B Notes     Upgraded    AA(sf)
Class C Notes     Confirmed   BBB(sf)
Class D Notes     Confirmed   BB(sf)

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

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

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

  -- The credit quality of the collateral pool and historical
performance.


STARWOOD MORTGAGE 2019-INV1: DBRS Finalizes BB(low) on B1 Certs
---------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the Mortgage
Pass-Through Certificates, Series 2019-INV1 (the Certificates)
issued by Starwood Mortgage Residential Trust 2019-INV1 (the
Issuer) as follows:

-- $233.0 million Class A-1 at AAA (sf)
-- $31.0 million Class A-2 at AA (sf)
-- $47.1 million Class A-3 at A (low) (sf)
-- $19.8 million Class M-1 at BBB (low) (sf)
-- $20.8 million Class B-1 at BB (low) (sf)

DBRS Morningstar also discontinued and withdrew its provisional
rating on the Mortgage Pass-Through Certificates, Series 2019-INV1,
Class B-2.

The AAA (sf) rating on the Certificates reflects the 38.35% of
credit enhancement provided by subordinated Certificates in the
pool. The AA (sf), A (low) (sf), BBB (low) (sf) and BB (low) (sf)
ratings reflect 30.15%, 17.70%, 12.45% and 6.95% of credit
enhancement, respectively.

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

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate, expanded prime and non-prime first-lien
residential mortgages funded by the issuance of the Certificates.
This transaction marks the first issuance on the Starwood Mortgage
Residential Trust shelf backed entirely by loans originated to
investors under debt service coverage ratio (DSCR) programs. The
Certificates are backed by 919 mortgage loans with a total
principal balance of $370,293,937 as of the Cut-Off Date (September
1, 2019).

The originators for the mortgage pool are HomeBridge Financial
Services, Inc. (HomeBridge; 41.6%); Impac Mortgage Corp. (Impac;
20.3%); Luxury Mortgage Corp. (Luxury; 19.8%); FM Home Loans, LLC
(FM Home; 13.8%); and other originators, each comprising less than
5% of the mortgage pool. The Servicer of the loans is Select
Portfolio Servicing, Inc. (SPS).

The mortgage loans were underwritten to program guidelines for
business-purpose loans that are designed to rely on property value,
the mortgagor's credit profile and the DSCR, where applicable.
Since the loans were made to investors for business purposes, they
are exempt from the Consumer Financial Protection Bureau's
Ability-to-Repay rules and the TILA-RESPA Integrated Disclosure
rule.

The Sponsor, directly or indirectly through a majority-owned
affiliate, will retain an eligible horizontal residual interest
consisting of the Class B-3 and Class XS Certificates representing
at least 5% of the Certificates to satisfy the credit
risk-retention requirements under Section 15G of the Securities
Exchange Act of 1934 and the regulations promulgated thereunder.

On or after the earlier of (1) the three-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, Starwood Non-Agency Lending, LLC, as Optional Redemption
Holder, may redeem all outstanding Certificates at a price equal to
the class balances of the mortgage loans and the fair market value
of all real estate-owned properties plus accrued and unpaid
interest.

The Seller (SMRF TRS, LLC) will have the option, but not the
obligation, to repurchase any mortgage loan that becomes 90 or more
days delinquent under the Mortgage Bankers Association method at
the repurchase price (par plus interest), provided that such
repurchases in aggregate do not exceed 10% of the total principal
balance as of the Cut-Off Date.

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

The transaction employs a sequential-pay cash flow structure with a
pro rata principal distribution among the senior tranches.
Principal proceeds can be used to cover interest shortfalls on the
Certificates as the outstanding more senior Certificates are paid
in full. Furthermore, excess spread can be used to cover realized
losses first before being allocated to unpaid cap carryover amounts
up to Class B-1.

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

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


STARWOOD MORTGAGE 2019-INV1: S&P Assigns B- Rating to B-2 Certs
---------------------------------------------------------------
S&P Global Ratings assigned its ratings to Starwood Mortgage
Residential Trust 2019-INV1's mortgage pass-through certificates.

The certificate issuance is an RMBS transaction backed by
first-lien fixed- and adjustable-rate fully amortizing residential
non-owner occupied business purpose mortgage loans (some with
interest-only periods) secured by single-family residential
properties, planned-unit developments, condominiums, and two- to
four-family residential properties to both prime and nonprime
borrowers. The pool has 919 business-purpose investor loans backed
by 919 properties, which are exempt from the qualified
mortgage/ability-to-pay rules.

Since S&P assigned preliminary ratings and published its presale
report on Oct. 7, 2019, the sponsor (Starwood Non-Agency Lending
LLC) removed nine mortgage loans from the collateral pool as a
result of its ongoing portfolio management. Such loans are not
reflected in the final collateral pool, though they were included
in the collateral pool and characteristics at the time S&P assigned
preliminary ratings. As a result of dropping these loans, the
sponsor decreased the sizes of the class A-1, A-2, A-3, M-1, B-1,
B-2, and B-3 certificates.

The sponsor then increased the size of the class B-2 certificates
while reducing the size of the class B-3 certificates, which
resulted in a decline in class B-2 credit enhancement to 1.90% from
2.80%. After analyzing the revised bond sizes and credit
enhancement, S&P assigned a 'B- (sf)' rating to the class B-2
certificates, while S&P's preliminary rating on the class was 'B
(sf)' at the time it published its presale report.

The ratings reflect:

-- The pool's collateral composition;
-- The credit enhancement provided for this transaction;
-- The transaction's associated structural mechanics;
-- The representation and warranty (R&W) framework for this
transaction;
-- The geographic concentration; and
-- The mortgage aggregator, Starwood Non-Agency Lending LLC, and
the mortgage originators.

  RATINGS ASSIGNED

  Starwood Mortgage Residential Trust 2019-INV1

  Class       Rating          Amount ($)

  A-1         AAA (sf)       228,286,000
  A-2         AA (sf)         30,364,000
  A-3         A (sf)          46,101,000
  M-1         BBB (sf)        19,441,000
  B-1         BB (sf)         20,366,000
  B-2         B- (sf)         18,700,000
  B-3         NR               7,035,937
  A-IO-S      NR                Notional(i)
  XS          NR                Notional(i)

(i)The notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period.
NR--Not rated.


TOWD POINT 2019-HY3: Moody's Assigns (P)B2 Rating on Cl. B2 Notes
-----------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to ten
classes of notes issued by Towd Point Mortgage Trust 2019-HY3.

The notes are backed by one pool of 2,846 predominantly seasoned
performing adjustable-rate residential mortgage loans. The
borrowers have a non-zero updated weighted average FICO score of
699 and a weighted average current combined LTV of 62.3% as of
August 31, 2019 (the statistical calculation date). First lien
loans comprise about 100% of the pool by balance and about 86% of
the pool by balance consists of non-modified seasoned performing
loans. Select Portfolio Servicing, Inc. and Specialized Loan
Servicing LLC will be the primary servicer for 95.7% and 4.3% of
the collateral pool by balance, respectively. FirstKey Mortgage,
LLC will be the asset manager for the transaction.

The complete rating actions are as follows:

Issuer: Towd Point Mortgage Trust 2019-HY3

Cl. A1, Assigned (P)Aaa (sf)

Cl. A1A, Assigned (P)Aaa (sf)

Cl. A1B, Assigned (P)Aaa (sf)

Cl. A2, Assigned (P)Aa2 (sf)

Cl. A3, Assigned (P)Aa1 (sf)

Cl. A4, Assigned (P)A1 (sf)

Cl. M1, Assigned (P)A1 (sf)

Cl. M2, Assigned (P)Baa3 (sf)

Cl. B1, Assigned (P)Ba2 (sf)

Cl. B2, Assigned (P)B2 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected loss on TPMT 2019-HY3's collateral pool is 1.70%
in its base case scenario and 10.65% at a stress level consistent
with the Aaa (sf) rating. Its loss estimate takes into account the
historical performance of the loans that have similar collateral
characteristics as the loans in the pool, and also incorporate an
expectation of a continued strong credit environment for RMBS,
supported by a current strong housing price environment.

Moody's estimated expected losses using two approaches -- (1)
pool-level approach, and (2) re-performing loan level analysis. In
the pool-level approach, Moody's estimated losses on the pool by
applying its assumptions on expected future delinquencies, default
rates, loss severities and prepayments as observed on similar
seasoned collateral. Moody's projected future annual delinquencies
for eight years by applying an initial annual default rate
assumption adjusted for future years through delinquency burnout
factors. The delinquency burnout factors reflect its future
expectations of the economy and the U.S. housing market. Based on
the loan characteristics of the pool and the demonstrated pay
histories, Moody's applied an initial expected annual delinquency
rate of 4.6% for first lien loans for year one. Moody's then
calculated future delinquencies using default burnout and voluntary
conditional prepayment rate (CPR) assumptions. Moody's aggregated
the delinquencies and converted them to losses by applying pool
specific lifetime default frequency and loss severity assumptions.
Its default, CPR and loss severity assumptions are based on actual
observed performance of seasoned performing, re-performing modified
loans and prior TPMT deals. In applying its loss severity
assumptions, Moody's accounted for the lack of principal and
interest advancing in this transaction. Of note, since the overall
profile of this pool is more similar to seasoned performing pools,
Moody's applied seasoned performing loss assumptions to this pool
to derive collateral losses.

Moody's also conducted a loan level analysis on TPMT 2019-HY3'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, if any, (1) adjustable-rate loans,
(2) loans that have the risk of coupon step-ups and (3) loans with
high updated loan to value ratios (LTVs). Moody's applied a higher
baseline lifetime default propensity for interest-only loans, using
the same adjustments. To calculate the final 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.

The final expected loss for the collateral pool also reflects the
due diligence findings of three independent third-party review
(TPR) firms as well as its assessment of TPMT 2019-HY3's
representations & warranties (R&Ws) framework.

Unlike previous TPMT transactions Moody's has rated, FirstKey, as
seller, is not required to pay by the 18th month after the closing
date unpaid property taxes (or any resulting liens from such unpaid
taxes) or overdue payments for energy lien deficiency that exist at
closing and that may have priority over the lien of the related
mortgage, unless FirstKey, as asset manager, verifies, based on
information provided by the servicer, that all such unpaid property
taxes or energy lien deficiency either: (i) have been extinguished
by the related servicer or have otherwise been satisfied, (ii) have
been previously paid, (iii) are invalid, or (iv) constitute a lien
or charge that is subordinate to that of the related mortgage.
Consequently, the seller is no longer required to repurchase
mortgage loans for which it has not paid such delinquent taxes and
liens by the end of the 18th month after the closing date or for
which none of the conditions in clauses (i) to (iv) above have been
satisfied.

While Moody's considers this change to the roles of the asset
manager and seller to be credit negative, Moody's did not make an
adjustment to its loss levels because: (1) the amount of such
delinquent taxes and liens is small relative to the aggregate
unpaid principal balance of the pool at 0.13% and (2) the related
servicer will make a servicing advance for the payment of HOA
liens, energy lien deficiencies, real estate property taxes and
other municipal charges, but only to the extent necessary to
protect the lien of the related mortgage.

Collateral Description

TPMT 2019-HY3's collateral pool is primarily comprised of seasoned
performing first lien adjustable-rate mortgage loans. Approximately
14% of the loans in the collateral pool have been previously
modified. The majority of the loans underlying this transaction
exhibit collateral characteristics similar to that of seasoned
Alt-A mortgages.

This transaction has a higher proportion of loans for which the
value of the related underlying property was updated through an
automated valuation model (AVM) at 23% of the collateral balance.
Moody's applied a haircut to the AVM valuations since Moody's
considers AVM valuations to be less precise than broker price
opinions (BPOs). BPOs were used to update the property valuations
for 77% of the collateral pool.

Moody's based its expected loss on the pool 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 modification, and the amount of the reduction in
monthly mortgage payments as a result of modification. The longer a
borrower has been current on a re-performing loan, the less likely
they are to re-default. Approximately 83.5% of the borrowers of the
loans in the collateral pool have been current on their payments
for the past 72 months or more under the OTS method.

Transaction Structure

TPMT 2019-HY3 has a sequential priority of payments structure, in
which a given class of notes can only receive principal payments
when all the classes of notes above it have been paid off.
Similarly, losses will be applied in the reverse order of priority.
The Class A1A, A1B, A2, M1, M2, B1, B2, B3 and B4 notes carry a
floating-rate coupon indexed to one-month LIBOR and subject to the
collateral adjusted net WAC and applicable available funds cap. The
Class A1, A3, and A4 notes are floating-rate notes where the coupon
is equal to the weighted average of the note rates of the related
exchange notes. The Class B5 notes are principal-only notes. There
are no performance triggers in this transaction. Additionally, the
servicer will not advance any principal or interest on delinquent
loans.

Moody's coded TPMT 2019-HY3's cashflows using its proprietary
cashflow tool. To assess the final rating on the notes, Moody's ran
96 different loss and prepayment scenarios through SFW. The
scenarios encompass six loss levels, four loss timing curves, and
four prepayment curves.

Third-Party Review

Three independent third-party review (TPR) firms -- Clayton
Services, LLC, AMC Diligence, LLC and Westcor Land Title Insurance
Company -- conducted due diligence for the transaction. Due
diligence was performed on about 71.0% of the loans by unpaid
principal balance in TPMT 2019-HY3's collateral pool for regulatory
compliance, 71.0% for data integrity, 70.2% for pay string history,
and 100% for title and tax review. The TPR firms reviewed
compliance, data integrity and key documents to verify that loans
were originated in accordance with federal, state and local
anti-predatory laws. The TPR firms conducted audits of designated
data fields to ensure the accuracy of the collateral tape.

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

Representations & Warranties

Its ratings reflect TPMT 2019-HY3's weak representations and
warranties (R&Ws) framework. The representation provider, FirstKey
Mortgage, LLC is unrated by Moody's. Moreover, FirstKey's
obligations will be in effect for only thirteen months after
transaction settlement. The R&Ws themselves are weak because they
contain many knowledge qualifiers and the regulatory compliance R&W
does not cover monetary damages that arise from TILA violations
whose right of rescission has expired. While the transaction
provides a breach reserve account to cover for any breaches of
R&Ws, the target size of the account (0.25% of the current balance
of the Class A1A, A1B, A2, M1 and M2s) is small relative to TPMT
2019-HY3's aggregate collateral pool.

Similar to recent TPMT transactions, the sponsor will not be
funding the breach reserve account at closing. On each payment
date, the paying agent will fund the reserve account from the Class
XS2 each month up to target balance based on the outstanding
principal balance of the Class A1A, A1B, A2, M1 and M2 notes. Since
its loss analysis already takes into account the weak R&W
framework, Moody's did not apply an additional penalty.

Transaction Parties

The transaction benefits from a strong servicing arrangement. SPS
and SLS will service 95.7% and 4.3% of TPMT 2019-HY3's collateral
pool, respectively. Moody's considers the overall servicing
arrangement for this pool to be better than average given the
ability and experience of the servicers, and the servicer oversight
from an experienced asset manager in FirstKey Mortgage, LLC. This
arrangement strengthens the overall servicing framework in the
transaction. U.S. Bank National Association is the indenture
trustee and custodian of the transaction. The Delaware Trustee is
Wilmington Trust, National Association.

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

Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of loss could drive
the ratings up. Losses could decline from its original expectations
as a result of a lower number of obligor defaults or appreciation
in the value of the mortgaged property securing an obligor's
promise of payment. Transaction performance also depends greatly on
the US macro economy and housing market. Other reasons for
better-than-expected performance include changes to servicing
practices that enhance collections or refinancing opportunities
that result in prepayments.

Down

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


TRTX ISSUER 2019-FL3: DBRS Gives Prov. B(low) on Class G Notes
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Notes to be issued by TRTX 2019-FL3 Issuer, Ltd. (the Issuer):

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

All trends are Stable. Classes F and G will be privately placed.

The initial collateral consists of 22 floating-rate mortgage loans
secured by 98 mostly transitional real estate properties, with a
cut-off pool balance totaling more than $1.2 billion, excluding
approximately $231.8 million of future funding commitments. Most
loans are in a period of transition with plans to stabilize and
improve the asset value. During the Permitted Funded Companion
Participation Acquisition Period, the Issuer may acquire future
funding commitments and additional eligible loans subject to the
Eligibility Criteria. The transaction stipulates a $5.0 million
threshold on pari passu acquisitions before a rating agency
confirmation is required if there is already a participation of the
underlying loan in the trust.

For all floating-rate loans, DBRS Morningstar used the one-month
LIBOR index, which is based on the lower of a DBRS Morningstar
Stressed Rate that corresponded to the remaining fully extended
term of the loans or the strike price of the interest rate cap with
the respective contractual loan spread added to determine a
stressed interest rate over the loan term. The pool exhibited a
relatively modestly high weighted-average (WA) issuance loan to
value ratio (LTV) of 69.4%, though the WA issuance LTV is estimated
to improve to 64.4% through stabilization. When the cut-off date
balances were measured against the DBRS Morningstar As-Is Net Cash
Flow (NCF), ten loans, representing 47.7% of the cut-off date pool
balance, had a DBRS Morningstar As-Is Debt Service Coverage Ratio
(DSCR) below 1.00 times (x), a threshold indicative of high default
risk. Additionally, the DBRS Morningstar Stabilized DSCR for four
loans, representing 18.5% of the initial pool balance, was below
1.00x, a threshold indicative of elevated refinance risk. The
properties are often transitional with potential upside in cash
flow. However, DBRS Morningstar does not give full credit to the
stabilization if there are no holdbacks or if other loan structural
features are insufficient to support such treatment. Furthermore,
even with the structure provided, DBRS Morningstar generally does
not assume the assets to stabilize above market levels.

The loans are generally secured by traditional property types
(i.e., retail, multifamily and office). Additionally, none of the
multifamily loans in the pool are currently secured by
student-housing properties, which often exhibit higher cash flow
volatility than traditional multifamily properties. Eight loans,
representing 44.9% of the cut-off date pool balance, exhibited
either Average (+) or Above Average property quality. Six of the
loans were within the top ten loans. Additionally, only two loans,
representing 7.7% of the cut-off date pool balance, exhibited
either Average (-) or Below Average property quality. These loans
were the Jersey Portfolio II and Alister and Emerson Apartments,
respectively.

Eight loans, comprising nearly 39.0% of the cut-off date pool
balance, are secured by properties located in areas with a DBRS
Market Rank of 6, 7 or 8, which are characterized as urbanized
locations. These markets generally 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 or rural markets. Areas with a DBRS Market
Rank of 7 or 8 are especially densely urbanized and benefit from
significantly elevated liquidity. Five loans, comprising 24.5% of
the cut-off date pool balance. are secured by properties located in
these areas.

The borrowers of all 22 floating-rate loans have purchased LIBOR
rate caps that range from 2.5% to 4.5% to protect against rising
interest rates through the duration of the loan term. In addition
to the fulfillment of certain minimum performance requirements,
exercise of any extension options would also require the repurchase
of interest-rate cap protection through the duration of the
respectively exercised option.

The pool consists of transitional assets. Given the nature of the
assets, DBRS Morningstar determined a sample size, representing
79.2% of the cut-off date pool balance. This is higher than the
typical sample size for a traditional conduit commercial
mortgage-backed securities (CMBS) transaction. Physical site
inspections were also performed, including management meetings.
DBRS Morningstar also notes that when DBRS Morningstar analysts are
visiting the markets in the future, they may visit properties more
than once to follow the progress (or lack thereof) toward
stabilization. The servicer is also in constant contact with the
borrowers to track progress.

Based on the weighted initial pool balances, the overall WA DBRS
Morningstar As-Is DSCR of 1.00x is generally reflective of
high-leverage financing. Fortunately, the assets are generally
well-positioned to stabilize, and any realized cash flow growth
would help to offset a rise in interest rates and also improve the
overall debt yield of the loans. DBRS Morningstar associates its
loss given default based on the assets' as-is LTV that does not
assume that the stabilization plan and cash flow growth will ever
materialize.

The pool is heavily concentrated by property type with nine loans,
comprising 41.9% of the cut-off date pool balance, secured by
multifamily properties and eight loans, comprising 33.5% of the
cut-off date pool balance, secured by office properties. However,
loans secured by multifamily properties generally exhibit lower
average default frequencies relative to other commercial property
types. Additionally, no loans are secured by student-housing
multifamily properties, which often exhibit higher cash flow
volatility than traditional multifamily properties. As well,
traditional property types such as office, retail, industrial and
multifamily benefit from more readily available conventional
take-out financing than non-traditional property types such as
hospitality, self-storage and manufactured housing. The pool
features only two loans, comprising 10.6% of the cut-off date pool
balance, that are secured by hospitality properties, exclusive of
the Rockville Town Center loan, which is secured by a mixed-use
multifamily, hotel and retail property.

Twenty-two loans, comprising 100.0% of the cut-off date pool
balance, have floating interest rates. The aforementioned loans are
interest only during the original term and have original terms
ranging from 23 to 48 months, creating interest-rate risk.

All but one of the identified floating rate loans are short-term
loans with fully extended maximum loan terms of five years or less.
The single outlier (Lenox Park Portfolio) also has a relatively
short six-year fully extended loan term. Additionally, for all
floating-rate loans, DBRS Morningstar used the one-month LIBOR
index, which is based on the lower of a DBRS Morningstar Stressed
Rate that corresponded to the remaining fully extended term of the
loans or the strike price of the interest-rate cap with the
respective contractual loan spread added to determine a stressed
interest rate over the loan term. All identified floating-rate
loans have extension options and, in order to qualify for these
options, the loans must generally meet minimum leverage
requirements.

Twelve loans comprising 62.0% of the cut-off date pool balance
represent refinance financing. The refinance financings within this
securitization generally do not require the respective sponsor(s)
to contribute material cash equity as a source of funding in
conjunction with the mortgage loan, resulting in a lower sponsor
cost basis in the underlying collateral.

Of the 12 refinance loans, only three loans, comprising 19.5% of
the pool, reported occupancy of less than 80.0%. Additionally, the
12 refinance loans exhibited a WA growth between as-is and
stabilized appraised value estimates of 7.1% compared with the
overall WA appraised value growth of 20.5% for the pool. This
suggests that the refinance loans are generally closer to
stabilization than the acquisition loans, partially mitigating the
higher risk associated with a sponsor's lower cost basis.

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


UBS COMMERCIAL 2019-C17: Fitch Assigns Bsf Rating on 2 Tranches
---------------------------------------------------------------
Fitch Ratings assigned the following ratings and Rating Outlooks to
UBS Commercial Mortgage Trust 2019-C17 Commercial Mortgage
Pass-Through Certificates, Series 2019-C17:

UBS 2019-C17

               Current Rating         Prior Rating

Class A-1;   LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-2;   LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-3;   LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-4;   LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-S;   LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-SB;  LT AAAsf New Rating;  previously at AAA(EXP)sf

Class B;     LT AA-sf New Rating;  previously at AA-(EXP)sf

Class C;     LT A-sf New Rating;   previously at A-(EXP)sf

Class D;     LT BBBsf New Rating;  previously at BBB(EXP)sf

Class E;     LT BBB-sf New Rating; previously at BBB-(EXP)sf

Class F;     LT BBsf New Rating;   previously at BB(EXP)sf

Class G;     LT Bsf New Rating;    previously at B(EXP)sf

Class NR-RR; LT NRsf New Rating;   previously at NR(EXP)sf

Class X-A;   LT AAAsf New Rating;  previously at AAA(EXP)sf

Class X-B;   LT A-sf New Rating;   previously at A-(EXP)sf

Class X-D;   LT BBB-sf New Rating; previously at BBB-(EXP)sf

Class X-F;   LT BBsf New Rating;   previously at BB(EXP)sf

Class X-G;   LT Bsf New Rating;    previously at B(EXP)sf

(a) Notional amount and interest-only.

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

(c) Includes the eligible horizontal risk retention (HRR)
interest.

The eligible vertical risk retention (VRR) interest will consist of
approximately 3.75% of the certificate balance, notional amount, or
percentage interest of each class of certificates.

The balances for class A-3 and A-4 were finalized since Fitch
published its expected ratings on Sept. 19, 2019. At the time the
classes were assigned, the class A-3 balance range was $75,000,000
- $230,000,000 and the class A-4 range was $245,181,000 -
$400,181,000. The final class sizes for class A-3 and A-4 are
$204,676,000 and $270,505,000, respectively. There are no further
changes to Fitch's expected ratings. The classes above reflect the
final ratings and deal structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 70 loans secured by 97
commercial properties having an aggregate principal balance of
$807,336,117 as of the cut-off date. The loans were contributed to
the trust by UBS AG, Inc., Wells Fargo Bank, National Association,
Rialto Mortgage Finance, LLC, Ladder Capital Finance LLC, Rialto
Real Estate Fund III-Debt, LP and CIBC, Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 70.3% of the properties
by balance, cash flow analysis of 77.6%, and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch debt service coverage ratio (DSCR)
of 1.18x is lower than average when compared to the 2018 and 2019
YTD averages of 1.22x and 1.23x, respectively. In addition, the
pool's loan-to-value (LTV) of 108.1% is higher than the 2018 and
2019 YTD average of 102.0% and 101.4%, respectively.

Credit Opinion Loans: Two loans representing 9.3% of the pool are
credit assessed. The Grand Canal Shoppes loan (6.2% of the pool)
received a stand-alone credit opinion of 'BBB-sf*' and the 10000
Santa Monica Boulevard loan (3.1% of the pool) received a
stand-alone credit opinion of 'BBBsf*'. Excluding the credit
opinion loans, the Fitch DSCR and LTV are 1.20x and 107.4%,
respectively.

Lower Pool Concentration Relative to Recent Transactions: The top
10 loans represent 37.4% of the pool by balance, which is lower
than the 2018 and 2019 YTD multiborrower transaction averages of
50.6% and 51.7%, respectively. The pool's loan concentration index
(LCI) of 242 and sponsor concentration index (SCI) score of 306 are
also below the YTD 2019 averages of 387 and 406, respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 8.7% 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 UBS
2019-C17 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.


WELLS FARGO 2019-C53: Fitch to Rate $8.7MM Class H-RR Debt 'B-sf'
-----------------------------------------------------------------
Fitch Ratings issued a presale report on Wells Fargo Commercial
Mortgage Trust 2019-C53 commercial mortgage pass-through
certificates, series 2019-C53.

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

  -- $20,689,000 class A-1 'AAAsf'; Outlook Stable;

  -- $45,608,000 class A-2 'AAAsf'; Outlook Stable;

  -- $33,381,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $135,000,000 class A-3 'AAAsf'; Outlook Stable;

  -- $256,842,000 class A-4 'AAAsf'; Outlook Stable;

  -- $491,520,000b class X-A 'AAAsf'; Outlook Stable;

  -- $105,325,000b class X-B 'A-sf'; Outlook Stable;

  -- $29,842,000 class A-S 'AAAsf'; Outlook Stable;

  -- $36,864,000 class B 'AA-sf'; Outlook Stable;

  -- $38,619,000 class C 'A-sf'; Outlook Stable;

  -- $25,535,000a class D 'BBB-sf'; Outlook Stable;

  -- $25,535,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $17,473,000ac class E-RR 'BBB-sf'; Outlook Stable;

  -- $10,533,000ac class F-RR 'BBsf'; Outlook Stable;

  -- $8,777,000ac class G-RR 'BB-sf'; Outlook Stable;

  -- $8,777,000ac class H-RR 'B-sf'; Outlook Stable.

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

  -- $7,022,000ac class J-RR 'NR';

  -- $7,899,000ac class K-RR 'NR';

  -- $19,310,519ac class L-RR 'NR'.

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

(b) Notional amount and interest-only.

(c) Horizontal credit risk retention interest representing no less
than 5% of the estimated fair value of all classes of regular
certificates issued by the issuing entity as of the closing date.

(d) The initial certificate balances of class A-3 and A-4 are
unknown and expected to be $391,842,000 in aggregate. The
certificate balances will be determined based on the final pricing
of those classes of certificates. The expected class A-3 balance
range is $75,000,000 to $195,000,000, and the expected class A-4
balance range is $196,842,000 to $316,842,000.

The expected ratings are based on information provided by the
issuer as of Oct. 11, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 58 loans secured by 85
commercial properties with an aggregate principal balance of
$702,171,519 as of the cut-off date. The loans were contributed to
the trust by Wells Fargo Bank, National Association, Ladder Capital
Finance LLC, Rialto Mortgage Finance, LLC, Barclays Capital Real
Estate Inc. and C-III Commercial Mortgage LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 70.2% of the properties
by balance, cash flow analysis of 85.3%, and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch DSCR of 1.21x is below the 2018
and 2019 YTD averages of 1.22x and 1.25x, respectively, for other
Fitch-rated multiborrower transactions. In addition, the pool's LTV
of 113.1% is higher than the 2018 and 2019 YTD averages of 102.0%
and 101.4%, respectively. The pool does not contain any credit
opinion loans. After removing credit opinion loans and loans
secured by residential cooperatives from the leverage metrics for
other Fitch-rated transactions, the respective 2018 and 2019 YTD
average DSCR is 1.16x and 1.18x, while the respective average LTV
is 108.6% and 108.1%.

Mortgage Coupons: The pool's weighted average (WA) mortgage rate of
3.96% is well below historical averages and much lower than the
2018 and 2019 YTD averages of 4.77% and 4.57%, respectively. Fitch
accounted for increased refinance risk in a higher interest rate
environment by incorporating an interest rate sensitivity that
assumes an interest rate floor of 5.0% for the term risk of most
property types, 4.5% for multifamily properties and 6.0% for hotel
properties, in conjunction with its stressed refinance rates, which
were 9.58% on a WA basis.

Concentrated Pool: The 10 largest loans represent 52.3% of the pool
by balance, slightly higher than the 2018 and 2019 YTD averages of
50.6% and 51.6%, respectively. The pool's loan concentration index
(LCI) of 377 is between the respective 2018 and 2019 YTD averages
of 373 and 387. The pool's sponsor concentration index (SCI) of 432
is higher than the 2018 and 2019 YTD averages of 398 and 405,
respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 15.3% below
the most recent year's net operating income (NOI) for properties
for which a full-year NOI was provided, excluding properties that
were stabilizing during this period. Unanticipated further declines
in property-level NCF could result in higher defaults and loss
severities on defaulted loans and in potential rating actions on
the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the WFCM
2019-C53 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 'Asf' 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.


WESTLAKE AUTOMOBILE 2018-3: S&P Affirms B+ (sf) Rating to F Notes
-----------------------------------------------------------------
S&P Global Ratings raised its ratings on 12 classes from Westlake
Automobile Receivables Trust 2016-3, 2017-1, 2018-2, and 2018-3.
S&P also affirmed its ratings on eight classes from the
transactions.

The rating actions reflect each series' collateral performance to
date and S&P's expectations regarding each transaction's future
collateral performance, structure, and credit enhancement.
Additionally, S&P incorporated secondary credit factors, including
credit stability, payment priorities under various scenarios, and
sector- and issuer-specific analyses.

Series 2016-3, 2017-1, 2018-2, and 2018-3 are performing in-line to
slightly better than S&P's prior cumulative net loss (CNL)
expectations, and the rating agency has revised its loss
expectations accordingly.

  Table 1
  Collateral Performance (%)(i)

                       Pool    Current    60-plus day
  Series     Month   factor        CNL        delinq.
  2016-3        35    16.46      13.17           1.85
  2017-1        30    21.78      11.35           1.76
  2018-2        16    53.37       6.09           1.49
  2018-3        13    64.83       4.44           1.42

  (i)As of the September 2019 distribution date.
  Delinq.--Delinquencies.
  CNL--Cumulative net loss.

  Table 2
  CNL Expectations (%)

                 Original              Prior         Current
                 lifetime           lifetime        lifetime
  Series         CNL exp.           CNL exp.        CNL exp.
  2016-1      12.75-13.25     13.75-14.25(i)     up to 14.00
  2017-1      13.00-13.50     13.00-13.50(i)     12.50-13.00
  2018-2      13.00-13.50                N/A     12.50-13.00
  2018-3      13.00-13.50                N/A     12.50-13.00

  (i)Previously revised in May 2018.
  CNL exp.--Cumulative net loss expectations.
  N/A–-Not applicable.

Each transaction contains a sequential principal payment structure
in which the notes are paid principal by seniority. Each
transaction also has credit enhancement in the form of a
nonamortizing reserve account, overcollateralization, subordination
for the higher-rated tranches, and excess spread. The credit
enhancement is at the specified target or floor, and each class'
credit support continues to increase as a percentage of the
amortizing collateral balance.

The raised and affirmed ratings reflect S&P's view that the total
credit support as a percentage of the amortizing pool balance,
compared with its expected remaining losses, is commensurate with
the raised and affirmed ratings.

  Table 3
  Hard Credit Support (%)(i)

                                Total hard     Current total hard
                            credit support         credit support
  Series         Class     at issuance(ii)     (% of current)(ii)
  2016-3         C                   20.25                  98.31
  2016-3         D                   10.75                  40.61
  2016-3         E                    7.00                  17.82
  2017-1         C                   21.00                  78.56
  2017-1         D                   11.75                  36.08
  2017-1         E                    7.50                  16.59
  2018-2         A                   43.50                  82.88
  2018-2         B                   34.90                  66.77
  2018-2         C                   24.00                  46.34
  2018-2         D                   13.80                  27.23
  2018-2         E                    9.50                  19.18
  2018-2         F                    4.00                   8.87
  2018-3         A                   43.25                  69.22
  2018-3         B                   34.65                  55.95
  2018-3         C                   23.75                  39.14
  2018-3         D                   13.55                  23.41
  2018-3         E                    9.25                  16.78
  2018-3         F                    3.75                   8.29

(i)As of the September 2019 distribution date.
(ii)Calculated as a percentage of the total gross receivable pool
balance, consisting of a reserve account, overcollateralization,
and, if applicable, subordination.

S&P compared the current hard credit enhancement with the remaining
expected CNLs. There were certain classes for which hard credit
enhancement alone, without giving credit to the excess spread, was
sufficient to raise or affirm the ratings to or at 'AAA (sf)'. For
the other classes, S&P incorporated cash flow analyses to assess
the loss coverage level, giving credit to excess spread. S&P's cash
flow scenarios included forward-looking assumptions on recoveries,
the timing of losses, and voluntary absolute prepayment speeds that
the rating agency believes are appropriate given the transaction's
performance to date.

In addition to its break-even cash flow analysis, S&P also
conducted sensitivity analyses to determine the impact that a
moderate ('BBB') stress scenario would have on its ratings if
losses began trending higher than its revised base-case loss
expectation.

S&P will continue to monitor the performance of the outstanding
transactions to ensure that the credit enhancement remains
sufficient, in the rating agency's view, to cover its CNL
expectations under its stress scenarios for each of the rated
classes.

  RATINGS RAISED
  Westlake Automobile Receivables Trust

                             Rating
  Series    Class     To              From
  2016-3    D         AAA (sf)        AA- (sf)
  2016-3    E         AA (sf)         BBB (sf)
  2017-1    D         AAA (sf)        A (sf)
  2017-1    E         A+ (sf)         BBB- (sf)
  2018-2    B         AAA (sf)        AA (sf)
  2018-2    C         AA+ (sf)        A (sf)
  2018-2    D         A+ (sf)         BBB (sf)
  2018-2    E         BBB+ (sf)       BB (sf)
  2018-3    B         AAA (sf)        AA (sf)
  2018-3    C         AA+ (sf)        A (sf)
  2018-3    D         A (sf)          BBB (sf)
  2018-3    E         BBB+ (sf)       BB (sf)
  
  RATINGS AFFIRMED
  Westlake Automobile Receivables Trust

  Series    Class     Rating
  2016-3    C         AAA (sf)
  2017-1    C         AAA (sf)
  2018-2    A-2-A     AAA (sf)
  2018-2    A-2-B     AAA (sf)
  2018-2    F         B+ (sf)
  2018-3    A-2-A     AAA (sf)
  2018-3    A-2-B     AAA (sf)
  2018-3    F         B+ (sf)


WESTLAKE AUTOMOBILE 2019-3: DBRS Assigns Prov. B Rating on F Notes
------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
notes (the Notes) to be issued by Westlake Automobile Receivables
Trust 2019-3 (Westlake 2019-3 or the Issuer):

-- $213,500,000 Class A-1 Notes at R-1 (high) (sf)
-- Class A-2-A Notes at AAA (sf)
-- Class A-2-B Notes at AAA (sf)
-- $88,830,000 Class B Notes at AA (sf)
-- $115,740,000 Class C Notes at A (sf)
-- $103,550,000 Class D Notes at BBB (sf)
-- $45,180,000 Class E Notes at BB (sf)
-- $54,310,000 Class F Notes at B (sf)

The combination of Classes A-2-A and A-2-B is expected to equal
$378.89 million.

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

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

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

-- The credit quality of the collateral and performance of the
auto loan portfolio by origination channel.

-- The capabilities of Westlake Services, LLC (Westlake) with
regard to originations, underwriting and servicing.

-- The quality and consistency of provided historical static pool
data for Westlake originations and performance of the Westlake auto
loan portfolio.

-- Wells Fargo Bank, N.A. (rated AA/R-1 (high) with Stable trends
by DBRS Morningstar) has served as a backup servicer for Westlake
since 2003, when a conduit facility was put in place.

-- Westlake 2019-3 provides for Class F Notes with an assigned
rating of B (sf). While the DBRS Morningstar "Rating U.S. Retail
Auto Loan Securitizations" methodology does not set forth a range
of multiples for this asset class for the B (sf) level, the
analytical approach for this rating level is consistent with that
contemplated in the methodology. The typical range of multiples
applied in the DBRS Morningstar stress analysis for a B (sf) rating
is 1.00 times (x) to 1.25x.

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

DISCONTINUATION OF LIBOR

-- The Westlake 2019-3 transaction documents include provisions
based on the recommended contractual fallback language for
U.S.-dollar LIBOR-denominated securitizations published by the
Federal Reserve's Alternative Reference Rates Committee (ARRC) on
May 31, 2019.

-- In the event that the LIBOR-denominated Class A-2-B Notes are
issued and LIBOR is discontinued, the Class A-2-B Notes will be
allowed to transition to ARRC's recommended alternative reference
rate (which is the secured overnight financing rate (SOFR)).
-- DBRS Morningstar assumes that because the sum of the new
benchmark replacement rate and the benchmark replacement adjustment
(as further defined in the transaction documents) is intended to be
a direct replacement for LIBOR, the contemplation of SOFR as a
benchmark replacement rate is not a material deviation from the
framework provided under the "Interest Rate Stresses for U.S.
Structured Finance Transactions" and related methodologies.

-- Document provisions will provide for prior notification to DBRS
Morningstar of any subsequent change to the benchmark.

The collateral securing the Notes consists entirely of a pool of
retail automobile contracts secured by predominantly used vehicles
that typically have high mileage. The loans are primarily made to
obligors who are categorized as subprime, largely because of their
credit history and credit scores.

The ratings on the Class A-1, Class A-2-A and Class A-2-B Notes
reflect the 42.65% of initial hard credit enhancement provided by
the subordinated Notes in the pool, the Reserve Account (1.00%) and
overcollateralization (1.50%). The ratings on the Class B, Class C,
Class D, Class E and Class F Notes reflect 33.90%, 22.50%, 12.30%,
7.85% and 2.50% 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.


[*] DBRS Reviews 439 Classes From 57 U.S. RMBS Transactions
-----------------------------------------------------------
DBRS, Inc. reviewed 439 classes from 57 U.S. residential
mortgage-backed security (RMBS) transactions. Of the 439 classes
reviewed, DBRS Morningstar upgraded three ratings, confirmed 339
ratings and discontinued 97 ratings.

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

The rating actions are a result of DBRS Morningstar's application
of the "U.S. RMBS Surveillance Methodology" published in September
2018.

The pools backing these RMBS transactions consist of prime,
non–qualified mortgage, agency credit, subprime, reperforming and
resecuritization of real estate mortgage investment conduit
collateral.

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

  -- Agate Bay Mortgage Trust 2014-2, Mortgage Pass-Through
Certificates, Series 2014-2, Class B-4

  -- Agate Bay Mortgage Trust 2015-3, Mortgage Pass-Through
Certificates, Series 2015-3, Class B-2

  -- CSMC Trust 2014-OAK1, Mortgage Pass-Through Certificates,
Series 2014-OAK1, Class B-3

  -- CSMC Trust 2014-OAK1, Mortgage Pass-Through Certificates,
Series 2014-OAK1, Class B-4

  -- CSMLT 2015-2 Trust, Mortgage Pass-Through Certificates, Series
2015-2, Class A-IO-S

  -- J.P. Morgan Mortgage Trust 2014-OAK4, Mortgage Pass-Through
Certificates, Series 2014-OAK4, Class B-4

  -- Shellpoint Co-Originator Trust 2015-1, Mortgage Pass-Through
Certificates, Series 2015-1, Class B-3

  -- Shellpoint Co-Originator Trust 2015-1, Mortgage Pass-Through
Certificates, Series 2015-1, Class B-4

  -- Wells Fargo Mortgage Backed Securities 2005-AR3 Trust,
Mortgage Pass-Through Certificates, Series 2005-AR3, Class B-1

  -- LVII Resecuritization Trust 2009-1, Mortgage Resecuritization
Notes, Series 2009-1, Class M-4

  -- LVII Resecuritization Trust 2009-1, Mortgage Resecuritization
Notes, Series 2009-1, Class M-5

  -- LVII Resecuritization Trust 2009-1, Mortgage Resecuritization
Notes, Series 2009-1, Class M-6

Notes: The principal methodology is the U.S. RMBS Surveillance
Methodology, which can be found on dbrs.com under Methodologies &
Criteria.

The Affected Rating is Available at https://bit.ly/2Bd6h4v


[*] S&P Takes Various Actions on 141 Classes From 22 US RMBS Deals
------------------------------------------------------------------
S&P Global Ratings completed its review of 141 classes from 22 U.S.
RMBS transactions issued between 2002 and 2007. The transactions
are backed by prime jumbo and Alternative-A collateral. The review
yielded 10 upgrades, 33 downgrades, 72 affirmations, six
withdrawals, and 20 discontinuances.

ANALYTICAL CONSIDERATIONS

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes.

Some of these considerations may include:

-- Collateral performance or delinquency trends,
-- Historical missed interest payments,
-- Available subordination and/or overcollateralization,
-- Erosion of or increases in credit support, and
-- Tail risk.

RATING ACTIONS

The rating actions reflect S&P's view of the associated
transaction-specific collateral performance and structural
characteristics, and/or the application of specific criteria
applicable to these classes.

The affirmations reflect S&P's view that its projected credit
support and collateral performance on these classes have remained
relatively consistent with its prior projections.

S&P raised its ratings on Banc of America Funding 2004-C Trust's
classes 2-A-1 and 2-A-2 to 'AA (sf)' from 'BBB (sf)' due to
increased credit support. The credit support increased to 92.66% in
September 2019 from 23.64% during the rating agency's last review.
S&P also raised its ratings on class 4-A-1 to 'AAA (sf)' from 'A+
(sf)' and class 4-A-3 (sf) to 'AAA' (sf) from 'A (sf)' due to
increased credit support. Since S&P's last review, the credit
support increased to 60.55% in September 2019 from 46.53% for class
4-A-1 and increased to 56.68% from 41.28% for class 4-A-3. The
upgrades reflect the classes' ability to withstand a higher level
of projected loss than previously anticipated.

S&P lowered its ratings on Citigroup Mortgage Loan Trust Series
2004-HYB3's class I-A to 'BB (sf)' from 'A+ (sf)', class II-A to
'B+ (sf)' from 'BB+ (sf)' and class III-A to 'BB+ (sf)' from 'A+
(sf)' due to erosion of hard dollar credit support. Passing
triggers continue to divert principal to subordinate classes,
eroding the credit support available to cover S&P's projected
losses at higher rating levels. The subordinate classes received
approximately $775,000 in principal during the past 12 months,
reducing the credit support available for the senior classes to
$1.08 million from $1.86 million a year ago.

S&P withdrew its ratings on classes 7-A-1 and 5-A-1 from MASTR
Alternative Loan Trust 2004-2. As of September 2019, there are no
loans remaining in group seven as they have either paid off or
liquidated, and class 7-A-1 is now dependent on
cross-collateralized principal from other groups. However, it is
uncertain if the class will receive this remaining principal. With
regards to group five, there are only two loans left, both of which
are currently severely delinquent. As such, it is uncertain when or
if this class will receive all of its remaining outstanding
principal.

S&P also withdrew its ratings on classes 15-PO and C-A-X from MASTR
Alternative Loan Trust 2004-2. Class 15-PO is a strip
principal-only class that is tied to discount loans from groups
four, five, six, and seven. As of September 2019, there are no
discount loans remaining outstanding in these groups, as such there
is uncertainty if the class will receive its remaining principal.
Class C-A-X is an interest-only (IO) class whose notional amount is
determined based on the principal balances of classes 4-A-1, 5-A-1,
and 6-A-1. The rating action on this class reflects the application
of S&P's IO criteria, which provides that the rating agency will
maintain the current rating on an IO class until the ratings on all
of the classes that the IO security references in the determination
of its notional balance are either lowered to below 'AA- (sf)' or
have been retired; at which time the rating agency will withdraw
these IO ratings. S&P had previously withdrawn its ratings on
classes 4-A-1 and 6-A-1 and are withdrawing its rating on class
5-A-1 as part of this review.

A list of Affected Ratings can be viewed at:

           https://bit.ly/2ORwyNR


[*] S&P Takes Various Actions on 200 Classes From 57 US RMBS Deals
------------------------------------------------------------------
S&P Global Ratings completed its review of 200 classes from 57 U.S.
RMBS transactions, including four U.S. RMBS re-securitized real
estate mortgage investment conduits (re-REMIC), issued between 1998
and 2010. The review yielded 56 upgrades, eight downgrades, 123
affirmations, seven withdrawals, and six discontinuances.

The non-re-REMIC transactions are backed by prime jumbo,
Alternative-A, subprime, document deficient, small balance
commercial, re-performing, outside the guidelines, first-lien high
LTV, and negative-amortization collateral. The re-REMIC
transactions are backed by prime jumbo, Alternative-A, and option
adjustable-rate mortgages.

ANALYTICAL CONSIDERATIONS

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes.

Some of these considerations may include:

-- Collateral performance or delinquency trends,
-- Underlying collateral performance or delinquency trends,
-- Historical interest shortfalls or missed interest payments,
-- Available subordination and/or overcollateralization,
-- Increases in credit support, Small loan count, and
-- Expected short duration.

RATING ACTIONS

The rating actions reflect S&P's view of the associated
transaction-specific collateral performance and structural
characteristics, and/or the application of specific criteria
applicable to these classes.

The affirmations reflect S&P's view that its projected credit
support and collateral performance on these classes have remained
relatively consistent with its prior projections.

S&P lowered its ratings on classes M-2 and M-3 from 2005-CB3 Trust
due to ultimate interest repayments not being likely at the
previous rating levels, based on its assessment of missed interest
payments during recent remittance periods. The lowered ratings were
derived by applying S&P's interest shortfall criteria, which impose
a maximum rating threshold on classes that have incurred missed
interest payments resulting from credit or liquidity erosion. In
applying the criteria, S&P looked to see if the applicable classes
received additional compensation beyond the imputed interest due as
direct economic compensation for the delay in interest payment,
which these classes have. Additionally, these classes have delayed
reimbursement provisions. As such, S&P used its projections in
determining the likelihood that the shortfalls would be reimbursed
under various scenarios.

S&P withdrew its ratings on five classes from two transactions due
to the small number of loans remaining in the related group or
structure. Once a pool has declined to a de minimis amount, their
future performance becomes more difficult to project. As such, S&P
believes there is a high degree of credit instability that is
incompatible with any rating level.

A list of Affected Ratings can be viewed at:

          https://bit.ly/2qhcgD3


[*] S&P Takes Various Actions on 300 Classes From 73 US RMBS Deals
------------------------------------------------------------------
S&P Global Ratings completed its review of 300 classes from 73 U.S.
RMBS transactions issued between 1997 and 2007. All of these
transactions are backed by alternative-A, HELOC, negative
amortization, outside the guidelines, re-performing, small balance
commercial, and subprime collateral. The review yielded 72
upgrades, 30 downgrades, 197 affirmations, and one withdrawal.

ANALYTICAL CONSIDERATIONS

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes. Some of these considerations may include:

-- Collateral performance and delinquency trends;
-- Historical missed interest payments;
-- Available subordination and/or overcollateralization;
-- The erosion of or increases in credit support; and
-- Expected short duration;

RATING ACTIONS

S&P lowered its rating on class M-1 from Bear Stearns Asset Backed
Securities I Trust 2004-HE6 due to ultimate interest repayments not
being likely at the previous rating levels, based on its assessment
of missed interest payments to the affected class during recent
remittance periods. The lowered ratings were derived by applying
S&P's interest shortfall criteria, which impose a maximum rating
threshold on classes that have incurred missed interest payments
resulting from credit or liquidity erosion. In applying the
criteria, S&P looked to see if the applicable class received
additional compensation beyond the imputed interest due as direct
economic compensation for the delay in interest payment, which this
class has. Additionally, per the transaction documents, this class
has a provision that states that once the class balance reduces to
zero, it will no longer be entitled to distributions. As such, S&P
used its projections in determining the likelihood that the
shortfall would be reimbursed prior to the class balance reducing
to zero, and the rating agency determined interest repayments were
not likely at higher rating scenarios.

S&P lowered its ratings on classes IA-5 from Chase Funding Trust
series 2003-4 to reflect the impact of passing triggers, which
continue to divert principal to subordinate classes, eroding the
credit support available to cover the rating agency's projected
losses at higher rating levels. Credit support decreased to 18.93%
(as of August 2019) from 26.96% during S&P's last review.

S&P withdrew its rating on class VII-A from American Home Mortgage
Investment Trust 2004-4. This class is insured by a bond insurer
that S&P no longer rates. The withdrawal reflects the absence of
relevant information regarding the insurer's creditworthiness that
is needed to maintain a rating on this class. To date, there is a
current draw amount on the insurance policy. Additionally, the
rating on this class depends solely on whether the insurer
continues to make payments when required, and S&P does not have the
relevant information to make such a determination.

The rating changes reflect S&P's opinion regarding the associated
transaction-specific collateral performance and/or structural
characteristics and the application of specific criteria applicable
to these classes.

The ratings affirmations reflect S&P's opinion that its projected
credit support and collateral performance on these classes has
remained relatively consistent with its prior projections.

A list of Affected Ratings can be viewed at:

          https://bit.ly/2VOxjsA


                            *********

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

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

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

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

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

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

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

                            *********

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

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

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

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

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

                   *** End of Transmission ***