/raid1/www/Hosts/bankrupt/TCR_Public/191027.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 27, 2019, Vol. 23, No. 299

                            Headlines

AIG CLO 2019-2: S&P Assigns Prelim BB- (sf) Rating to Cl. E Notes
ANGEL OAK 2019-5: DBRS Assigns Prov. B Rating on Class B-2 Certs
ANGEL OAK 2019-5: S&P Assigns B (sf) Rating to Class B-2 Certs
ASCENTIUM EQUIPMENT 2019-2: Moody's Rates Class E Notes Ba2(sf)
ASCENTIUM EQUIPMENT 2019-2: S&P Rates Class E Notes 'BB (sf)'

ATLAS SENIOR XV: S&P Assigns Prelim BB- (sf) Rating to Cl. E Notes
AVID AUTOMOBILE 2019-1: S&P Rates $10.44MM Class D Notes BB- (sf)
BAIN CAPITAL 2019-4: S&P Assigns Prelim BB- (sf) Rating to E Notes
BANK 2019-BNK21: Fitch Assigns B- Rating on 2 Tranches
BANK 2019-BNK22: Fitch to Rate 2 Tranches 'B-sf'

BCC FUNDING XVI: DBRS Finalizes BB Rating on Class D Notes
BENEFIT STREET XVIII: S&P Assigns Prelim BB-(sf) Rating to E Notes
BLACKROCK DLF IX 2019-G: DBRS Assigns B Rating on Class E Notes
BURNHAM PARK: Moody's Assigns Ba3 Rating on $21.45MM Cl. E-R Notes
CATHEDRAL LAKE IV: S&P Assigns BB- (sf) Rating to E-2-R Notes

CHASE HOME 2019-1: Fitch to Rate Cl. B-5 Debt 'BB-(EXP)'
CHURCHILL MIDDLE IV: DBRS Confirms BB Rating on 2 Cert. Classes
CITIGROUP COMMERCIAL 2019-GC43: Fitch to Rate Cl. J-RR Certs 'B-'
CSAIL 2017-CX10: Fitch Affirms BB-sf Rating on 3 Tranches
DRYDEN 76 CLO: S&P Rates $12MM Class E Notes 'BB- (sf)'

FIRST INVESTORS 2019-2: S&P Assigns B (sf) Rating to Cl. F Notes
FLAGSTAR MORTGAGE 2019-1INV: Moody's Rates Cl. B-5 Debt '(P)B2'
FORTRESS CREDIT VIII: S&P Rates $20MM Class E Notes 'BB- (sf)'
FREDDIE MAC 2019-DNA4: S&P Rates $74MM Cl. B-1 Notes 'B (sf)'
FREED ABS 2019-2: DBRS Finalizes BB(low) Rating on Class C Notes

GLS AUTO 2019-4: S&P Assigns Prelim BB- (sf) Rating to Cl. D Notes
GS MORTGAGE 2019-PJ3: DBRS Gives Prov. B(high) Rating on B-5 Certs
GSMS 2019-GSA1: Fitch to Rate $8.6MM Class G-RR Certs B-sf
JFIN CLO 2015: Moody's Lowers Rating on $7MM Class F Notes to B3
JP MORGAN 2006-CIBC16: Moody's Affirms C Rating on 3 Tranches

JP MORGAN 2019-8: Moody's Assigns (P)B3 Rating on 2 Tranches
LCM XXII LTD: S&P Affirms 'BB (sf)' Rating to Class D-R Notes
LENDMARK FUNDING 2019-2: S&P Assigns Prelim 'BB' Rating to D Notes
MELLO WAREHOUSE 2019-2: Moody's Assigns Ba2 Rating on Cl. E Debt
NRZ ADVANCE 2019-T5: S&P Assigns Prelim BB(sf) Rating to E-T5 Notes

PRIMA CAPITAL 2019-VII: Moody's Assigns B3 Rating on Cl. D Debt
PSMC TRUST 2019-2: Fitch Rates Class B-5 Debt 'Bsf'
PSMC TRUST 2019-3: Fitch to Rate Class B-5 Debt 'B(EXP)'
REPUBLIC FINANCE 2019-A: DBRS Finalizes BB Rating on Class C Notes
RITE AID 1999-1: Moody's Lowers Class A-2 Certs Rating to Caa1

SEQUOIA MORTGAGE 2019-4: Fitch Gives BB-sf Rating on Cl. B-4 Certs
SIERRA TIMESHARE 2019-3: Fitch Assigns BBsf Rating on Cl. D Notes
SIERRA TIMESHARE 2019-3: S&P Rates $26.78MM Class D Notes 'BB (sf)'
THL CREDIT 2017-1: Moody's Affirms $27MM Cl. E Notes at Ba3(sf)
TOWD POINT 2019-HY3: Moody's Assigns (P)B2 Rating on Cl. B2 Notes

TRIMARAN CAVU 2019-2: S&P Assigns Prelim BB- Rating to Cl. D Notes
VERUS SECURITIZATION 2019-4: DBRS Gives Prov. B Rating on B2 Certs
VOYA CLO 2012-4: S&P Assigns Prelim B- (sf) Rating to E-R-R Notes
WELLS FARGO 2019-C53: DBRS Gives Prov. B(low) Rating on KRR Certs
WESTLAKE AUTOMOBILE 2019-3: S&P Rates Class F Notes 'B+(sf)'

WFRBS COMMERCIAL 2012-C6: Fitch Affirms Bsf Rating on Cl. F Certs
WORLD OMNI 2018-1: Fitch Affirms BB Rating on Class E Debt

                            *********

AIG CLO 2019-2: S&P Assigns Prelim BB- (sf) Rating to Cl. E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to AIG CLO
2019-2 Ltd./AIG CLO 2019-2 LLC's floating-rate notes.

The note issuance is a collateralized loan obligation (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 preliminary ratings are based on information as of Oct. 22,
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, which consists primarily of
broadly syndicated speculative-grade (rated 'BB+' and lower) senior
secured term loans that are governed by collateral quality tests.

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  AIG CLO 2019-2 Ltd./AIG CLO 2019-2 LLC

  Class                Rating       Amount (mil. $)
  A                    AAA (sf)              310.00
  B-1                  AA (sf)                62.60
  B-2                  AA (sf)                 7.40
  C                    A (sf)                 30.00
  D                    BBB- (sf)              30.00
  E                    BB- (sf)               20.00
  Subordinated notes   NR                     48.00

  NR--Not rated.


ANGEL OAK 2019-5: DBRS Assigns Prov. B Rating on Class B-2 Certs
----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following
Mortgage-Backed Certificates, Series 2019-5 (the Certificates) to
be issued by Angel Oak Mortgage Trust 2019-5 (AOMT 2019-5 or the
Trust):

-- $218.4 million Class A-1 at AAA (sf)
-- $22.6 million Class A-2 at AA (sf)
-- $48.9 million Class A-3 at A (sf)
-- $27.3 million Class M-1 at BBB (sf)
-- $14.1 million Class B-1 at BB (sf)
-- $13.4 million Class B-2 at B (sf)

The AAA (sf) rating on the Class A-1 Certificates reflects 38.10%
of credit enhancement provided by subordinated Certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 31.70%, 17.85%, 10.10%, 6.10% and 2.30% 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 primarily
first-lien fixed- and adjustable-rate non-prime and prime
residential mortgages funded by the issuance of the Certificates.
The Certificates are backed by 969 loans with a total principal
balance of $352,770,946 as of the Cut-Off Date (October 1, 2019).

Angel Oak Home Loans LLC, Angel Oak Mortgage Solutions LLC (AOMS)
and Angel Oak Prime Bridge, LLC (collectively, Angel Oak)
originated 100.0% of the portfolio (969 loans). The Angel Oak
first-lien mortgages were mainly originated under the following
eight programs:

(1) Platinum (41.5%) – Made to borrowers that have prime or
near-prime credit scores, but who are unable to obtain financing
through conventional or governmental channels because (1) they fail
to satisfy credit requirements, (2) they are self-employed and need
alternative income calculations using 12 or 24 months of bank
statements or the most recent year income tax return or (3) they
may have been subject to a bankruptcy or foreclosure 48 or more
months prior to origination.

(2) Portfolio Select (38.7%) – Made to borrowers with near-prime
credit scores who are unable to obtain financing through
conventional or governmental channels because (a) they fail to
satisfy credit requirements, (b) they are self-employed and need an
alternate income calculation using 12 months or 24 months of bank
statements to qualify, (c) they may have a credit score that is
lower than that required by government-sponsored entity
underwriting guidelines or (d) they may have been subject to a
bankruptcy or foreclosure 24 or more months prior to origination.

(3) Investor Cash Flow (10.9%) – Made to real estate investors
who are experienced in purchasing, renting and managing investment
properties with an established five-year credit history and at
least 24 months of clean housing payment history, but who are
unable to obtain financing through conventional or governmental
channels because they (a) fail to satisfy the requirements of such
programs or (b) may be over the maximum number of properties
allowed. Loans originated under the Investor Cash Flow program are
considered business-purpose and are not covered by the
Ability-to-Repay (ATR) or TILA/RESPA Integrated Disclosure rules.

(4) Non-Prime General (7.1%) – Made to borrowers who have not
sustained a housing event in the past 24 months, but whose credit
reports show multiple 30+-day and/or 60+-day and/or 90+-day
delinquencies on any reported debt in the past 12 months.

(5) Non-Prime Recent Housing (1.1%) – Made to borrowers who have
completed or have had their properties subject to a short sale,
deed in lieu, notice of default or foreclosure. Borrowers who have
filed bankruptcy 12 or more months prior to origination or have
experienced severe delinquencies may also be considered for this
program.

(6) Non-Prime Foreign National (0.3%) – Made to investment
property borrowers who are citizens of foreign countries and who do
not reside or work in the United States. Borrowers may use
alternative income and credit documentation. Income is typically
documented by the employer or accountant and credit is verified by
letters from overseas credit holders.

(7) Asset Qualifier (0.3%) – Made to borrowers with prime credit
and significant assets who can purchase the property with their
assets, but choose to use a financing instrument for cash flow
purposes. Assets should cover the purchase of the home plus 60
months of debt service and four months of reserves. No income
documentation is obtained, but the borrower is qualified based on
certain credit requirements (minimum score 700) and significant
asset requirements, calculated as 60 times of all monthly debts and
new principal, interest, taxes, insurance and association payments
(minimum of $1,300 monthly disposable income). These loans are
available within both the Platinum and Portfolio Select programs.

(8) Non-Prime Investment Property (0.2%) – Made to real estate
investors who may have financed up to four mortgaged properties
with the originators (or 20 mortgaged properties with all
lenders).

In addition, the pool contains 0.2% second-lien mortgage loans,
which were originated under the guidelines established by the
Federal National Mortgage Association and overlaid by Angel Oak.

Select Portfolio Servicing, Inc. is the Servicer for all loans.
AOMS will act as Servicing Administrator and Wells Fargo Bank, N.A.
(rated AA with a Stable trend by DBRS Morningstar) will act as the
Master Servicer. U.S. Bank National Association (rated AA (high)
with a Stable trend by DBRS Morningstar) will serve as Trustee and
Custodian.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau (CFPB) ATR rules, they were made to
borrowers who generally do not qualify for agency, government or
private-label non-agency prime products for various reasons
described above. In accordance with the CFPB Qualified Mortgage
(QM) rules, 0.3% of the loans are designated as QM Rebuttable
Presumption and 84.5% as non-QM. Approximately 15.3% of the loans
are made to investors for business purposes and, thus, are not
subject to the QM rules.

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

On or after the two-year anniversary of the Closing Date, the
Depositor has the option to purchase all outstanding certificates
at a price equal to the outstanding class balance plus accrued and
unpaid interest, including any cap carryover amounts. After such
purchase, the Depositor then has the option to complete a
"qualified liquidation," which requires a complete liquidation of
assets within the trust and proceeds to be distributed to the
appropriate holders of regular or residual interests.

The transaction employs a sequential-pay cash flow structure with a
pro-rata principal distribution among the senior tranches.
Principal proceeds can be used to cover interest shortfalls on the
Certificates as the outstanding senior Certificates are paid in
full. Furthermore, excess spread can be used to cover realized
losses first before being allocated to unpaid cap carryover amounts
up to Class B-2.

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


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

The issuance is a residential mortgage-backed securities (RMBS)
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 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 framework; and
-- The mortgage originators.

  RATINGS ASSIGNED
  Angel Oak Mortgage Trust 2019-5

  Class       Rating                     Amount ($)
  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(i)
  XS          NR                           Notional(ii)
  R           NR                                N/A

(i)The notional amount equal to the aggregate scheduled principal
balance on servicing released mortgage loans.
(ii)The notional amount equal to the aggregate scheduled principal
balance of mortgage loans.
NR--Not rated.
N/A--Not applicable.


ASCENTIUM EQUIPMENT 2019-2: Moody's Rates Class E Notes Ba2(sf)
---------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to the notes
issued by Ascentium Equipment Receivables 2019-2 Trust, sponsored
by Ascentium Capital LLC. Ascentium is also the servicer of the
assets backing the transaction and the administrator for the
issuer.

The securitization is backed by leases secured by small-ticket
equipment, such as medical equipment, titled vehicles,
furniture/fixtures, computer equipment, etc.

The complete rating actions are as follows:

Issuer: Ascentium Equipment Receivables 2019-2 Trust

Class A-2 Notes, Definitive Rating Assigned Aaa (sf)

Class A-3 Notes, Definitive Rating Assigned Aaa (sf)

Class B Notes, Definitive Rating Assigned Aa2 (sf)

Class C Notes, Definitive Rating Assigned A1 (sf)

Class D Notes, Definitive Rating Assigned Baa2 (sf)

Class E Notes, Definitive Rating Assigned Ba2 (sf)

RATINGS RATIONALE

The ratings are based on (1) the credit quality of the pool of
equipment leases to be securitized and its expected performance,
(2) the historical performance of Ascentium's managed portfolio,
(3) the experience and expertise of Ascentium as the originator and
servicer, (4) the back-up servicing arrangement with U.S. Bank
National Association (Aa1/P-1; stable), (5) the strength of the
transaction structure including the sequential pay structure and
the amount of credit enhancement supporting the notes, and (6) the
legal aspects of the transaction.

Moody's cumulative net loss expectation for the ACER 2019-2
transaction is 2.75% and loss at a Aaa stress is 22.00%. Moody's
based its cumulative net loss expectation for the ACER 2019-2
transaction on an analysis of the credit quality of the securitized
pool; the historical performance of similar collateral, including
Ascentium's previous securitizations' performance and its managed
portfolio performance; the ability of Ascentium to perform the
servicing functions; and current expectations for the macroeconomic
environment during the life of the transaction.

At closing the Class A, Class B, Class C, Class D, and Class E
notes benefit from 21.75%, 16.70%, 11.95%, 8.70% and 5.15% of hard
credit enhancement respectively. Initial, hard credit enhancement
for the notes consists of a combination of overcollateralization of
4.15%, a 1.00% fully funded, non-declining, reserve account and
subordination, except for the Class E notes which do not benefit
from subordination. Excess spread may be available as additional
credit protection for the notes.

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

Down

Moody's could downgrade the notes if, given current expectations of
portfolio losses, levels of credit enhancement are consistent with
lower ratings. Moody's expectation of pool losses could rise as a
result of a higher number of obligor defaults or greater than
expected deterioration in the value of the equipment securing an
obligor's promise of payment. Portfolio losses also depend greatly
on the US economy, the market for used equipment, and poor
servicing. Other reasons for worse-than-expected performance
include error on the part of transaction parties, inadequate
transaction governance, and fraud.


ASCENTIUM EQUIPMENT 2019-2: S&P Rates Class E Notes 'BB (sf)'
-------------------------------------------------------------
S&P Global Ratings assigned its ratings to Ascentium Equipment
Receivables 2019-2 Trust's receivables-backed notes.

The note issuance is an ABS transaction backed by small-ticket
equipment leases and loans, associated equipment, and a special
unit of beneficial interest in lease contracts and underlying
vehicles.

The ratings reflect:

-- The availability of approximately 21.7%, 16.7%, 12.1%, 8.9%,
and 5.9% credit support to the class A, B, C, D, and E notes,
respectively, based on stressed break-even cash flow scenarios.
These credit support levels provide coverage (based on multiples in
S&P's equipment leasing criteria and, for ratings below the 'BBB'
category, its securitized consumer receivables criteria) of its
cumulative net loss range, which is consistent with the ratings.
S&P's cumulative net loss ranges from 3.60% to 4.30% because it
reflects its stressed recovery rate range of 15.00%-30.00%, with
higher recovery rates assumed for lower rating categories.

-- S&P's expectation that, under its credit stability analysis, in
a moderate stress ('BBB') scenario, all else being equal, the
ratings on the class A and B notes would not decline by more than
one rating from its 'AAA (sf)' and 'AA (sf)' ratings, respectively,
and the ratings on the class C, D, and E notes would not decline by
more than two rating categories from its 'A (sf)', 'BBB (sf)', and
'BB (sf)' ratings, respectively, in the first year. These potential
rating movements are consistent with S&P's credit stability
criteria.

-- S&P's expectation for the timely payment of periodic interest
and principal by the final maturity date according to the
transaction documents, based on stressed cash flow modeling
scenarios that it believes are appropriate for the assigned rating
categories.

-- The collateral characteristics of the securitized pool of
equipment leases and loans, including individual obligor
concentrations of less than 1.50%, a high percentage of contracts
with personal guarantees, and no residual values. Ascentium Capital
LLC's historical recovery rates, which are generally higher than
those of other small ticket commercial finance companies. S&P
believes this because of the high percentage of personal guarantees
and the servicer's pursuit of realizations on them.

-- The presence of a backup servicer, U.S. Bank N.A.

-- The transaction's legal structure.

  RATINGS ASSIGNED
  Ascentium Equipment Receivables 2019-2 Trust

  Class       Rating       Amount (mil. $)
  A-1         A-1+ (sf)            101.000
  A-2         AAA (sf)             110.000
  A-3         AAA (sf)             118.292
  B           AA (sf)               20.983
  C           A (sf)                19.737
  D           BBB (sf)              13.504
  E           BB (sf)               14.750


ATLAS SENIOR XV: S&P Assigns Prelim BB- (sf) Rating to Cl. E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Atlas Senior
Loan Fund XV Ltd.'s fixed- and floating-rate notes.

The note issuance is a collateralized loan obligation transaction
backed by primarily 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. 18,
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
  Atlas Senior Loan Fund XV Ltd./Atlas Senior Loan Fund XV LLC

  Class                      Rating       Amount (mil. $)
  X                          AAA (sf)                5.25
  A                          AAA (sf)              252.00
  B-1                        AA (sf)                35.00
  B-2                        AA (sf)                17.00
  C (deferrable)             A (sf)                 24.00
  D (deferrable)             BBB- (sf)              22.00
  E (deferrable)             BB- (sf)               16.00
  Subordinated notes         NR                     35.25
  Combination notes(i)       Ap (sf)                23.40

(i)Combination notes comprise $16.455 million of class C, $1.314
million of class D, and $7.231 million of the subordinated notes.
NR--Not rated.


AVID AUTOMOBILE 2019-1: S&P Rates $10.44MM Class D Notes BB- (sf)
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Avid Automobile
Receivables Trust 2019-1's automobile receivables-backed notes
series 2019-1.

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

The ratings reflect:

-- The availability of approximately 46.7%,34.1%, 26.6%, and 21.3%
of credit support for the class A, B, C, and D notes, respectively,
based on stressed cash flow scenarios (including excess spread).
These credit support levels provide coverage of approximately 2.3x,
2.13x, 1.75x, and 1.37x S&P's 13.75%-14.75% expected cumulative net
loss (ECNL) for the class A, B, C, and D notes, respectively.

-- The timely interest and full principal payments made under the
stressed cash flow modeling scenarios appropriate for the assigned
ratings.

-- The loss performance of Avid Acceptance LLC's origination
static pools and managed portfolio, its deal-level collateral
characteristics and comparison with its subprime auto finance
company peers, and S&P's forward-looking view of the economy.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal, the rating on the class A notes
would not likely be lowered from the assigned rating, the ratings
on the class B and C notes will not decline by more than two rating
categories over a one-year period (and over the life of the bonds),
and the rating on the class D notes would likely remain within two
rating categories of the assigned ratings during the first year but
would ultimately default under its 'BBB' moderate stress scenario,
which is within the bounds of the rating agency's credit stability
criteria.

-- The transaction's credit enhancement in the form of
subordinated notes; a nonamortizing reserve account of 1.35% of the
initial collateral balance; overcollateralization that is initially
0.50% and is expected to build to a target level of 9.00% of
current collateral balance, falling to a floor of 2.00% of initial
collateral balance; a cumulative net loss trigger, which, if
violated, causes the required overcollateralization percentage to
increase to 100% of current collateral balance; and excess spread.

-- S&P's view of the securitized pool of subprime auto loans,
which has a weighted average FICO score of 525 and weighted average
seasoning of approximately six months.

-- The collateral pool includes no loans with original maturity
terms greater than 72 months.

-- S&P's view of the prefunding eligibility criteria and the
expected collateral composition of the final pool under these
criteria.

-- S&P's view of the transaction's payment and legal structures.

  RATINGS ASSIGNED
  Avid Automobile Receivables Trust 2019-1
  
  Class       Rating            Amount
                              (mil. $)
  A           A (sf)            109.98
  B           A- (sf)            32.40
  C           BBB (sf)           19.26
  D           BB- (sf)           10.44
  E           NR                  7.02

  NR--Not rated.


BAIN CAPITAL 2019-4: S&P Assigns Prelim BB- (sf) Rating to E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Bain Capital
Credit CLO 2019-4 Ltd./Bain Capital Credit CLO 2019-4 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 preliminary ratings are based on information as of Oct. 22,
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, which consists primarily of
broadly syndicated speculative-grade (rated 'BB+' and lower) senior
secured term loans that are governed by collateral quality tests.

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

-- The experience of the collateral manager's 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

  Class             Preliminary rating     Balance (mil. $)

  A-1               AAA (sf)                         300.00
  A-2               NR                                25.00
  B                 AA (sf)                           55.00
  C (deferrable)    A (sf)                            32.50
  D (deferrable)    BBB- (sf)                         27.50
  E (deferrable)    BB- (sf)                          20.00
  Sub notes         NR                                45.10

  NR--Not rated.


BANK 2019-BNK21: Fitch Assigns B- Rating on 2 Tranches
------------------------------------------------------
Fitch Ratings assigned the following ratings and Rating Outlooks to
BANK 2019-BNK21 Commercial Mortgage Pass-Through Certificates,
Series 2019-BNK21.

  -- $20,194,000 class A-1 'AAAsf'; Outlook Stable;

  -- $9,516,000 class A-2 'AAAsf'; Outlook Stable;

  -- $31,582,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $20,143,000 class A-3 'AAAsf'; Outlook Stable;

  -- $230,500,000 class A-4 'AAAsf'; Outlook Stable;

  -- $473,428,000 class A-5 'AAAsf'; Outlook Stable;

  -- $785,363,000a class X-A 'AAAsf'; Outlook Stable;

  -- $84,146,000 class A-S 'AAAsf'; Outlook Stable;

  -- $63,110,000 class B 'AA-sf'; Outlook Stable;

  -- $58,902,000 class C 'A-sf'; Outlook Stable;

  -- $206,158,000a class X-B 'A-sf'; Outlook Stable;

  -- $32,256,000b class D 'BBBsf'; Outlook Stable;

  -- $23,842,000b class E 'BBB-sf'; Outlook Stable;

  -- $56,098,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $23,841,000b class F 'BB-sf'; Outlook Stable;

  -- $23,841,000ab class X-F 'BB-sf'; Outlook Stable;

  -- $11,219,000b class G 'B-sf'; Outlook Stable;

  -- $11,219,000ab class X-G 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $39,269,110b class H;

  -- $39,269,110ab class X-H;

  -- $59,049,901c RR Interest.

(a) Notional amount and interest-only.

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

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

Since Fitch published its expected ratings on Sept. 19, 2019, the
following changes occurred: The balances for classes A-4 and A5
were finalized. At the time that the expected ratings were
published, the initial certificate balances of classes A-4 and A-5
were unknown and expected to be approximately $703,928,000 in
aggregate, subject to a 5% variance. The final class balances for
classes A-4 and A-5 are $230,500,000 and $473,428,000,
respectively.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 49 loans secured by 87
commercial properties having an aggregate principal balance of
$1,180,998,012 as of the cut-off date. The loans were contributed
to the trust by Wells Fargo Bank, National Association, Morgan
Stanley Mortgage Capital Holdings LLC, and Bank of America,
National Association.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 77.1% of the properties
by balance, cash flow analysis of 85.9%, and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch debt service coverage ratio of
1.30x is better than the 2018 and 2019 YTD averages of 1.22x and
1.23x, respectively, for other Fitch-rated multi-borrower
transactions. The pool's Fitch loan-to-value of 104.9% is slightly
above the 2018 and 2019 YTD averages of 102.0% and 101.4%,
respectively.

Concentrated Pool: The pool is more concentrated than recent
Fitch-rated multiborrower transactions. The largest 10 loans
comprise 60.3% of the pool, greater than the average top 10
concentrations for 2018 and 2019 YTD of 50.6% and 51.7%,
respectively. The concentration results in an LCI of 469, which is
higher than the respective 2018 and 2019 YTD averages of 373 and
387. For this transaction, the losses estimated by Fitch's
deterministic test at 'AAAsf' exceeded the base model loss
estimate.

Above-Average Property Quality: Eight of the largest 10 loans in
the pool (48.9%), including the three largest loans, received
property quality scores of 'B+' or higher. Only 5.9% of the
inspected pool received a property quality grade of 'B-' or below,
compared with averages of 10.2% and 9.4% for 2018 and 2019 YTD,
respectively.

Credit Opinion Loans: Two loans, representing 13.1% of the pool,
are credit assessed. This is lower than the 2018 and YTD 2019
averages of 13.6% and 14.5%, respectively. The two credit assessed
loans, Park Tower at Transbay (9.7% of the pool) and Grand Canal
Shoppes (3.4% of the pool), each received standalone credit
opinions of 'BBB-sf*'.

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 BANK
2019-BNK21 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. The presale report includes a detailed explanation of
additional stresses and sensitivities on page 13.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Deloitte & Touche LLP. The third-party due diligence
described in Form 15E focused on a comparison and re-computation of
certain characteristics with respect to each of the mortgage loans.
Fitch considered this information in its analysis and the findings
did not have an impact on its analysis or conclusions.



BANK 2019-BNK22: Fitch to Rate 2 Tranches 'B-sf'
------------------------------------------------
Fitch Ratings issued a presale report on BANK 2019-BNK22 Commercial
Mortgage Pass-Through Certificates, Series 2019-BNK22.

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

  -- $16,733,000 class A-1 'AAAsf'; Outlook Stable;

  -- $6,119,000 class A-2 'AAAsf'; Outlook Stable;

  -- $19,728,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $225,000,000a class A-3 'AAAsf'; Outlook Stable;

  -- $531,848,000a class A-4 'AAAsf'; Outlook Stable;

  -- $799,428,000b class X-A 'AAAsf'; Outlook Stable;

  -- $117,060,000 class A-S 'AAAsf'; Outlook Stable;

  -- $48,536,000 class B 'AA-sf'; Outlook Stable;

  -- $49,965,000 class C 'A-sf'; Outlook Stable;

  -- $215,561,000b class X-B 'A-sf'; Outlook Stable;

  -- $31,406,000c class D 'BBBsf'; Outlook Stable;

  -- $22,841,000c class E 'BBB-sf'; Outlook Stable;

  -- $54,247,000bc class X-D 'BBB-sf'; Outlook Stable;

  -- $22,840,000c class F 'BB-sf'; Outlook Stable;

  -- $22,840,000bc class X-F 'BB-sf'; Outlook Stable;

  -- $11,421,000c class G 'B-sf'; Outlook Stable;

  -- $11,421,000bc class X-G 'B-sf'; Outlook Stable.

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

  -- $12,848,000c class H;

  -- $12,848,000bc class X-H;

  -- $25,696,287c class J;

  -- $25,696,287bc class X-J;

  -- $60,107,436d RR Interest.

(a) The initial certificate balances of classes A-3 and A-4 are
unknown and expected to be approximately $756,848,000 in aggregate,
subject to a 5% variance. The expected class A-3 balance range is
$75,000,000 to $375,000,000, and the expected class A-4 balance
range is $381,848,000 to $681,848,000. Fitch's certificate balances
for classes A-3 and A-4 are assumed at the midpoint of the range
for each class.

(b) Notional amount and interest-only.

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

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

The expected ratings are based on information provided by the
issuer as of Oct. 22, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 58 loans secured by 131
commercial properties having an aggregate principal balance of
$1,202,148,724 as of the cut-off date. The loans were contributed
to the trust by Morgan Stanley Mortgage Capital Holdings LLC, Bank
of America, National Association, Wells Fargo Bank, National
Association and National Cooperative Bank, National Association.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 68.5% of the properties
by balance, cash flow analysis of 86.7%, and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch debt service coverage ratio of
1.51x is better than the 2018 and 2019 YTD averages of 1.22x and
1.24x, respectively, for other Fitch-rated multi-borrower
transactions. The pool's Fitch loan-to-value of 99.1% is below the
2018 and 2019 YTD averages of 102.0% and 101.9%, respectively.

Concentrated Pool: The pool is more concentrated than recent
Fitch-rated multiborrower transactions. The largest 10 loans
comprise 60.7% of the pool, greater than the average top 10
concentrations for 2018 and 2019 YTD of 50.6% and 51.7%,
respectively. The concentration results in an LCI of 462, which is
higher than the respective 2018 and 2019 YTD averages of 373 and
381. For this transaction, the losses estimated by Fitch's
deterministic test at 'AAAsf' exceeded the base model loss
estimate.

Credit Opinion Loans: Two loans, representing 16.7% of the pool,
are credit assessed. This is lower than the 2018 and YTD 2019
averages of 14.5% and 13.6%, respectively. The two credit assessed
loans are Park Tower at Transbay (9.6% of the pool) which received
a stand-alone credit opinion of 'BBB-sf*'and Midtown Center (7.4%)
received a stand-alone credit opinion of 'BBBsf*'.

High Concentration of Interest-Only Loans with Minimal
Amortization: Twenty-five loans representing 61.9% of the pool are
full-term, interest only (IO), four loans (22.5%) are IO plus ARD
Structure and three loans representing (1.2%) are partial IO. The
concentration of full-term, IO loans is above the YTD 2019 and 2018
averages of 57.4% and 50.4%, respectively. The concentration of
partial IO loans is below the YTD 2019 and 2018 averages of 24.2%
and 27.1%, respectively. The pool is scheduled to amortize by just
3.3% of the initial pool balance by maturity, which is below the
YTD 2019 and 2018 averages of 6.1% and 7.2%, respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 14.8% 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). The following rating sensitivities describe how the
ratings would react to further NCF declines below Fitch's NCF. The
implied rating sensitivities are only indicative of some of the
potential outcomes and do not consider other risk factors to which
the transaction is exposed. Stressing additional risk factors may
result in different outcomes. Furthermore, the implied ratings,
after the further NCF stresses are applied, are more akin to what
the ratings would be at deal issuance had those further stressed
NCFs been in place at that time.

Fitch evaluated the sensitivity of the ratings assigned to BANK
2019-BNK22 certificates and found that the transaction displays
average sensitivity to further declines in NCF. In a scenario in
which NCF declines a further 20% from Fitch's NCF, a downgrade of
the 'AAAsf' certificates to 'A+sf' could result. A more severe
scenario, in which NCF declines a further 30% from Fitch's NCF,
could result in a downgrade of the 'AAAsf' certificates to
'BBB+sf'.


BCC FUNDING XVI: DBRS Finalizes BB Rating on Class D Notes
----------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of equipment contract backed notes issued by BCC Funding
XVI LLC (the Issuer):

-- $120,000,000 Series 2019-1, Class A-1 Notes at R-1 (high) (sf)
-- $208,425,000 Series 2019-1, Class A-2 Notes at AAA (sf)
-- $38,062,000 Series 2019-1, Class B Notes at A (sf)
-- $16,313,000 Series 2019-1, Class C Notes at BBB (sf)
-- $26,100,000 Series 2019-1, Class D 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 (OC), subordination and amounts held in the
reserve account, to support the DBRS Morningstar-projected
cumulative net loss assumption under various stressed cash flow
scenarios.

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

-- The capabilities of Balboa Capital Corporation (BCC) with
regard to originations, underwriting and servicing. DBRS
Morningstar has performed an operational review of BCC and
considers it an acceptable originator and servicer of
equipment-backed lease and loan contracts. Portfolio Financial
Servicing Company, an experienced servicer of equipment
lease-backed securitizations, will be the Back-Up Servicer for the
transaction.

-- The expected collateral for the transaction is granular with
respect to obligor, vendor and geographical concentrations. More
than 81% of the obligors (by aggregate Statistical Discounted
Contract Balance) have been in business for six or more years and
approximately 43% have been in business for 16 or more years. The
weighted-average Small Business Scoring Service credit score for
the businesses in the expected collateral pool will be at least
199. In addition, obligations comprising approximately 76.6% of an
aggregate Statistical Discounted Contract Balance are supported by
personal guarantees, and the payments on obligations accounting for
approximately 93.4% are collected through Automated Clearing
House.

-- 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 BCC and the
grant to the trustee of a valid first-priority security interest in
the assets. The legal structure is reviewed for the consistency
with the DBRS Morningstar "Legal Criteria for U.S. Structured
Finance."

BCC provides equipment and working capital financing to small- and
mid-sized companies in the United States. It originates leases and
loans through three principal channels: (1) vendor financing
through partnerships with equipment vendors, (2) small-ticket
originations through direct calling and (3) larger small-ticket
direct originations to middle-market obligors. This transaction
will include a small portion (0.49% of an aggregate Statistical
Discounted Contract Balance) of working capital loans.

The rating on the Class A-1 Notes reflects 73.9% of initial hard
credit enhancement (as a percentage of collateral balance) provided
by the subordinated notes in the pool (66.4%), the Reserve Account
(1.5%) and OC (6.0%). The rating on the Class A-2 Notes reflects
26.0% of initial hard credit enhancement provided by the
subordinated notes in the pool (18.5%), the Reserve Account (1.5%)
and OC (6.0%). The ratings on the Class B, Class C and Class D
Notes reflect 17.3%, 13.5% and 7.5% of initial hard credit
enhancement, respectively.

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


BENEFIT STREET XVIII: S&P Assigns Prelim BB-(sf) Rating to E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Benefit
Street Partners CLO XVIII Ltd./Benefit Street Partners CLO XVIII
LLC's floating-rate notes.

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

The preliminary ratings are based on information as of Oct. 18,
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, which consists primarily of
broadly syndicated speculative-grade (rated 'BB+' and lower) senior
secured term loans that are governed by collateral quality tests;

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Benefit Street Partners CLO XVIII Ltd./Benefit Street Partners  
  CLO XVIII LLC

  Class                Rating      Amount (mil. $)
  A                    AAA (sf)             315.00
  B                    AA (sf)               62.50
  C (deferrable)       A (sf)                30.00
  D (deferrable)       BBB- (sf)             30.00
  E (deferrable)       BB- (sf)              19.50
  Subordinated notes   NR                    50.85

  NR--Not rated.


BLACKROCK DLF IX 2019-G: DBRS Assigns B Rating on Class E Notes
---------------------------------------------------------------
DBRS, Inc. assigned new ratings of AAA (sf) to the Class A-1 Notes,
AA (sf) to the Class A-2 Notes, A (sf) to the Class B Notes, BBB
(sf) to the Class C Notes, BB (sf) to the Class D Notes, B (sf) to
the Class E Notes and BBB (low) (sf) to the Combination Notes
issued by BlackRock DLF IX 2019-G CLO, LLC (the Issuer), pursuant
to the Note Purchase and Security Agreement (NPSA) dated as of
October 16, 2019, among the Issuer, U.S. Bank National Association
(rated AA (high) with a Stable trend by DBRS Morningstar) as
Collateral Agent, Custodian, Document Custodian, Collateral
Administrator, Information Agent and Note Agent, and the Purchasers
referred to therein.

The ratings on the Class A-1 Notes and on the Class A-2 Notes
address the timely payment of interest (excluding the interest
payable at the Post-Default Rate, as defined in the NPSA referred
to above) and the ultimate payment of principal on or before the
Stated Maturity of October 16, 2029. The ratings on the Class B
Notes, the Class C Notes, the Class D Notes and the Class E Notes
address the ultimate payment of interest (excluding the interest
payable at the Post-Default Rate, as defined in the NPSA referred
to above) and the ultimate payment of principal on or before the
Stated Maturity of October 16, 2029.

The rating on the Combination Notes addresses the ultimate
repayment of the Combination Note Rated Principal Balance (which is
equal to the Commitment amount for the Combination Notes) on or
before the Stated Maturity of October 16, 2029. The Combination
Notes have no stated coupon. The Components of the Combination
Notes include portions of the Class A-2 Notes, Class B Notes, Class
C Notes, Class D Notes, Class E Notes and Subordinated Notes (or
equity) of the Issuer (for more information, see the Components and
Combination Notes section in the related report).

All interest and principal amounts paid on the Secured Notes and
any distributions made to the Subordinated Notes are the only
sources of payment for the Combination Notes. All payments made on
the Component Notes (whether interest, principal or otherwise) to
the Combination Notes shall reduce the Combination Note Rated
Principal Balance. The Combination Notes shall remain outstanding
until the earlier of (1) the payment in full and redemption of each
Component and (2) the Stated Maturity of each Component.

The principal methodology used to rate the Secured Notes and
Combination Notes is "Rating CLOs and CDOs of Large Corporate
Credit," which can be found on dbrs.com under Methodologies &
Criteria. The Combination Notes were stressed by applying the BBB
(low) stress scenario under the "Rating CLOs and CDOs of Large
Corporate Credit" methodology to the loans securing the Component
Notes.

The notes are collateralized primarily by a portfolio of U.S.
middle-market corporate loans. The Issuer will be managed by
BlackRock Capital Investment Advisors, LLC (BCIA), which is a
wholly owned subsidiary of BlackRock, Inc. DBRS Morningstar
considers BCIA to be an acceptable collateralized loan obligation
(CLO) manager.

The ratings reflect the following:

(1) The NPSA dated as of October 16, 2019;
(2) The integrity of the transaction structure;
(3) DBRS Morningstar's assessment of the portfolio quality;
(4) Adequate credit enhancement to withstand projected collateral
    loss rates under various cash flow stress scenarios; and
(5) DBRS Morningstar's assessment of the origination, servicing
    and CLO management capabilities of BCIA.

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


BURNHAM PARK: Moody's Assigns Ba3 Rating on $21.45MM Cl. E-R Notes
------------------------------------------------------------------
Moody's Investors Service assigned a rating to one class of CLO
refinancing notes issued by Burnham Park CLO, Ltd.

Moody's rating action is as follows:

US$352,000,000 Class A-R Senior Secured Floating Rate Notes Due
2029 (the "Class A-R Notes"), Assigned Aaa (sf)

Additionally, Moody's has affirmed the ratings on the following
outstanding notes previously issued by the Issuer on November 28,
2018 (the "First Refinancing Date"):

US$63,250,000 Class B-R Senior Secured Floating Rate Notes Due 2029
(the "Class B-R Notes"), Affirmed Aa2 (sf); previously on November
28, 2018 Assigned Aa2 (sf)

US$39,050,000 Class C-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class C-R Notes"), Affirmed A2 (sf); previously on
November 28, 2018 Assigned A2 (sf)

US$30,250,000 Class D-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class D-R Notes"), Affirmed Baa3 (sf); previously on
November 28, 2018 Assigned Baa3 (sf)

US$21,450,000 Class E-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class E-R Notes"), Affirmed Ba3 (sf); previously on
November 28, 2018 Assigned Ba3 (sf)

RATINGS RATIONALE

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

The Issuer is a managed cash flow collateralized loan obligation
(CLO). The issued notes are collateralized primarily by a portfolio
of broadly syndicated senior secured corporate loans. At least 90%
of the portfolio must consist of senior secured loans (excluding
any second lien loans), cash, and eligible investments, and up to
10% of the portfolio may consist of collateral obligations that are
not senior secured loans, cash or eligible investments.

GSO / Blackstone Debt Funds 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 remaining two year
reinvestment period. Thereafter, subject to certain restrictions,
the Manager may reinvest unscheduled principal payments and
proceeds from sales of credit risk assets.

The Issuer has issued the Refinancing Notes on October 21, 2019 in
connection with the refinancing of one class of secured notes
originally issued on October 26, 2016. On the Refinancing Date, the
Issuer used the proceeds from the issuance of the Refinancing Notes
to redeem in full the Refinanced Original Notes. On the Original
Closing Date, the issuer also issued one class of subordinated
notes that remains outstanding.

In addition to the issuance of the Refinancing Notes, a variety of
other changes to transaction features will occur in connection with
the refinancing. These include: extension of the non-call period
for the Refinancing Notes and changes to certain collateral quality
tests.

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

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

Performing par and principal proceeds balance: $547,933,131

Defaulted par: $1,800,779

Diversity Score: 79

Weighted Average Rating Factor (WARF): 2852 (corresponding to a
weighted average default probability of 25.22%)

Weighted Average Spread (WAS): 3.38%

Weighted Average Recovery Rate (WARR): 47.53%

Weighted Average Life (WAL): 7.01 Years

Methodology Underlying the Rating Action:

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

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

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


CATHEDRAL LAKE IV: S&P Assigns BB- (sf) Rating to E-2-R Notes
-------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R, B-R, C-R,
and E-2-R replacement notes from Cathedral Lake IV Ltd., a
collateralized loan obligation (CLO) originally issued in 2016 that
is managed by Carlson Capital. S&P withdrew its ratings on the
original class A, B, C, and E-2 notes following payment in full on
the Oct. 21, 2019, refinancing date. At the same time, S&P affirmed
its ratings on the class D and E-1 notes.

On the Oct. 21, 2019, refinancing date, the proceeds from the class
A-R, B-R, C-R, and E-2-R replacement note issuances were used to
redeem the original class A, B, C and E-2 notes as outlined in the
transaction document provisions. Therefore, S&P withdrew its
ratings on the original notes in line with their full redemption,
and it is assigning ratings to the replacement notes.

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

   -- Modify the reference rate to allow for amendments from LIBOR
to an alternative designated reference rate;

   -- Re-establish the non-call period to end in October 2020; and

   -- Extend of the weighted average life test to October 2026.

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,
the rating agency'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, S&P'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.

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

   RATINGS ASSIGNED

   Replacement class          Rating        Amount (mil $)
   A-R                        AAA (sf)              239.00
   B-R                        AA (sf)                64.00
   C-R                        A (sf)                 25.00
   E-2-R                      BB- (sf)                9.00

   RATINGS AFFIRMED

   Class                      Rating   
   D                          BBB (sf)
   E-1                        BB- (sf)

   RATINGS WITHDRAWN

                              Rating
   Original class       To              From
   A                    NR              AAA (sf)
   B                    NR              AA (sf)
   C                    NR              A (sf)
   E-2                  NR              BB- (sf)

   NR--Not rated.


CHASE HOME 2019-1: Fitch to Rate Cl. B-5 Debt 'BB-(EXP)'
--------------------------------------------------------
Fitch Ratings expects to rate Chase Home Lending Mortgage Trust
2019-1.

RATING ACTIONS

Chase Home Lending Mortgage Trust 2019-1

Class A-1;    LT AAA(EXP)sf Expected Rating

Class A-10;   LT AAA(EXP)sf Expected Rating

Class A-10-A; LT AAA(EXP)sf Expected Rating

Class A-10-X; LT AAA(EXP)sf Expected Rating

Class A-11;   LT AAA(EXP)sf Expected Rating

Class A-11-X; LT AAA(EXP)sf Expected Rating

Class A-12;   LT AAA(EXP)sf Expected Rating

Class A-13;   LT AAA(EXP)sf Expected Rating

Class A-14;   LT AAA(EXP)sf Expected Rating

Class A-15;   LT AAA(EXP)sf Expected Rating

Class A-16;   LT AAA(EXP)sf Expected Rating

Class A-17;   LT AAA(EXP)sf Expected Rating

Class A-2;    LT AAA(EXP)sf Expected Rating

Class A-3;    LT AAA(EXP)sf Expected Rating

Class A-3-A;  LT AAA(EXP)sf Expected Rating

Class A-3-X;  LT AAA(EXP)sf Expected Rating

Class A-4;    LT AAA(EXP)sf Expected Rating

Class A-4-A;  LT AAA(EXP)sf Expected Rating

Class A-4-X;  LT AAA(EXP)sf Expected Rating

Class A-5;    LT AAA(EXP)sf Expected Rating

Class A-5-A;  LT AAA(EXP)sf Expected Rating

Class A-5-X;  LT AAA(EXP)sf Expected Rating

Class A-6;    LT AAA(EXP)sf Expected Rating

Class A-6-A;  LT AAA(EXP)sf Expected Rating

Class A-6-X;  LT AAA(EXP)sf Expected Rating

Class A-7;    LT AAA(EXP)sf Expected Rating

Class A-7-A;  LT AAA(EXP)sf Expected Rating

Class A-7-X;  LT AAA(EXP)sf Expected Rating

Class A-8;    LT AAA(EXP)sf Expected Rating

Class A-8-A;  LT AAA(EXP)sf Expected Rating

Class A-8-X;  LT AAA(EXP)sf Expected Rating

Class A-9;    LT AAA(EXP)sf Expected Rating

Class A-9-A;  LT AAA(EXP)sf Expected Rating

Class A-9-X;  LT AAA(EXP)sf Expected Rating

Class A-X-1;  LT AAA(EXP)sf Expected Rating

Class A-X-2;  LT AAA(EXP)sf Expected Rating

Class A-X-3;  LT AAA(EXP)sf Expected Rating

Class A-X-4;  LT AAA(EXP)sf Expected Rating

Class B-1;    LT AA(EXP)sf Expected Rating

Class B-1-A;  LT AA(EXP)sf Expected Rating

Class B-1-X;  LT AA(EXP)sf Expected Rating

Class B-2;    LT A+(EXP)sf Expected Rating

Class B-2-A;  LT A+(EXP)sf Expected Rating

Class B-2-X;  LT A+(EXP)sf Expected Rating

Class B-3;    LT BBB+(EXP)sf Expected Rating

Class B-3-A;  LT BBB+(EXP)sf Expected Rating

Class B-3-X;  LT BBB+(EXP)sf Expected Rating

Class B-4;    LT BBB-(EXP)sf Expected Rating

Class B-5;    LT BB-(EXP)sf Expected Rating

Class B-5-Y;  LT BB-(EXP)sf Expected Rating

Class B-6;    LT NR(EXP)sf Expected Rating

Class B-6-Y;  LT NR(EXP)sf Expected Rating

Class B-6-Z;  LT NR(EXP)sf Expected Rating

Class B-X;    LT BBB+(EXP)sf Expected Rating

TRANSACTION SUMMARY

Fitch Ratings expects to rate JPMorgan Chase Bank's first Temporary
Safe Harbor Qualified Mortgage residential mortgage-backed
transaction, Chase Home Lending Mortgage Trust 2019-1. The
certificates are supported by 669 prime-quality conforming loans
with a total balance of $393.72 million as of the cutoff date. The
loans were originated by JPMorgan Chase and underwritten using
Fannie Mae's Desktop Underwriter or Freddie Mac's Loan Prospector.
All loans are GSE eligible as confirmed by a third-party review,
and therefore qualify as TQM. The loans will be serviced by JPM
Chase.

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 A-11
class as its coupon rate is currently based on one-month LIBOR plus
a spread. The loans in the collateral pool are not affected by
LIBOR replacement since they are all fixed-rate loans.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The collateral consists of
30-year (100%) fully amortizing fixed-rate conforming mortgage
loans. The borrowers have strong credit profiles with a Fitch
calculated weighted average (WA) FICO score of 768 and 69.9% WA
combined loan to value ratio (CLTV). The WA loan size is $588,524
and liquid reserves average $146,508. The loans were originated
through JPM Chase's, or its correspondents', retail channel, which
Fitch views positively. The largest MSA concentration is in New
York (32.9%). Fitch's 'AAAsf' expected loss of 4.75% reflects the
pool's very high quality attributes.

Geographic Concentration (Negative): Approximately 49% of the pool
is concentrated in California with moderate MSA concentration. The
largest MSA concentration is in the New York MSA (32.9%) followed
by the Los Angeles MSA (18.9%) and the San Francisco MSA (13.2%).
The top three MSAs account for 65.1% of the pool. As a result, the
'AAAsf' expected loss was increased by 65 bps to account for the
geographic concentration risk.

Temporary Safe Harbor Qualified Mortgage (Neutral): All of the
loans in this transaction are conforming loans that were
underwritten using DU/LP. The loans are agency eligible as
confirmed by a third-party review and therefore qualify as TQM. The
GSE QM patch allows for conforming loans to have a debt to Income
(DTI) ratio over 43% and still meet the QM standard. 49% of the
loans in the pool have a DTI over 43%, but receive TQM status
because they are GSE eligible. As a result of their TQM status, no
adjustment was made to the losses.

Minimal Operational Risk (Positive): JPM Chase has a long operating
history of originating and securitizing residential mortgage loans,
and is assessed as "Above Average" by Fitch. JPM Chase is also the
servicer of this transaction; and is rated 'RPS1-' by Fitch. Loan
origination and servicer quality have an impact on performance, and
Fitch lowers its loss expectations for highly rated originators and
servicers (rated 1- or higher) due to their strong practices and
higher expected recoveries. Fitch reduced its 'AAAsf' loss
expectations by 88 bps to account for the low operational risk
associated with this pool.

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

Third-Party Due Diligence (Positive): Third-party due diligence was
performed by a Fitch-assessed 'Acceptable-Tier 1' due diligence
review firm on 100% of the loans. The review confirmed sound
operational quality with no incidence of material defects. All
loans were graded either 'A' or 'B'. The results of the due
diligence review reduced the 'AAAsf' loss by 21bps.

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

To mitigate tail risk, which arises as the pool seasons and fewer
loans are outstanding, a subordination floor of 0.80% of the
original balance will be maintained for senior certificates and a
subordination floor of 0.50% of the original balance will be
maintained for the subordinate certificates.

RATING SENSITIVITIES

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

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper market value declines at the
national level. The analysis assumes market value declines of 10%,
20% and 30%, in addition to the model-projected 1.5%.

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'.

CASH FLOW ANLYSIS RATING SENSITIVITIES

As part of Fitch's cash flow anlaysis, Fitch applied delinquency
timing scenarios to the cash flow analysis to test the delinquency
triggers in the transaction and tested the 120-day delinquent
servicing fee to confirm that the structure would support a high
delinquency stress.

For Chase 2019-1, there is no servicer replacement provision if JPM
Chase as primary servicer fails to meet Fitch's 'A'/'F1' minimum
counterparty threshold. However, Fitch determined that the
transaction's subordinated cash flows will be sufficient to pay
timely interest to the 'AAAsf' and 'AAsf' certificates under the
related stress scenarios. Fitch analyzed its six cash flow timing
scenarios using its default timing curves and observed that timely
interest was paid to the 'AAAsf' and 'AAsf' certificates in all
scenarios. Fitch believes the certificates are adequately protected
against counterparty risk.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC Diligence, LLC (AMC). The third-party due diligence
focused on three areas: a compliance review; a credit review; and a
valuation review; and was conducted on 100% of the loans in the
pool. Fitch considered this information in its analysis and
believes the overall results of the review generally reflected
strong underwriting controls.

Fitch received certifications indicating that the loan-level due
diligence was conducted in accordance with its published standards
for reviewing loans and in accordance with the independence
standards outlined in its criteria.


CHURCHILL MIDDLE IV: DBRS Confirms BB Rating on 2 Cert. Classes
---------------------------------------------------------------
DBRS, Inc. confirmed the following ratings of the Class A-R Loans,
the Class A-T Loans, the Class B Loans, the Class B Notes, the
Class C Loans, the Class C Notes, the Class D Loans and the Class D
Notes (collectively, the Loans and Notes) issued by Churchill
Middle Market CLO IV, Ltd. (Churchill):

-- Class A-R Loans rated AA (sf)
-- Class A-T Loans rated AA (sf)
-- Class B Loans rated A (sf)
-- Class B Notes rated A (sf)
-- Class C Loans rated BBB (sf)
-- Class C Notes rated BBB (sf)
-- Class D Loans rated BB (sf)
-- Class D Notes rated BB (sf)

The ratings on the Loans are being confirmed pursuant to the
execution of the First Amendment to Credit Agreement (the
Amendment), dated as of October 16, 2019 (the Amendment Date),
which modifies and amends the Credit Agreement dated as of April
19, 2018, among Churchill as Borrower; Natixis, New York Branch as
Administrative Agent; The Bank of New York Mellon Trust Company,
N.A. (BNYM; rated AA with a Positive trend by DBRS Morningstar) as
Collateral Agent, Collateral Administrator, Information Agent and
Custodian; and the Lenders referred to therein.

The ratings on the Notes are being confirmed pursuant to the Note
Purchase Agreement dated as of April 19, 2018, among Churchill as
Issuer, BNYM as Collateral Agent and Note Agent as well as the
Purchasers referred to therein.

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

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

The above rating actions reflect the following primary
considerations:

(1) The Credit Agreement dated April 19, 2018, as amended and
    modified by the First Amendment to Credit Agreement, dated
    as of October 16, 2019.
(2) The Note Purchase Agreement dated as of April 19, 2018.
(3) The integrity of the transaction structure.
(4) DBRS Morningstar's assessment of the portfolio quality.
(5) Adequate credit enhancement to withstand projected collateral
    loss rates under various cash flow stress scenarios.
(6) DBRS Morningstar's assessment of the origination, servicing
    and collateralized loan obligation management capabilities
    of Nuveen Alternative Advisors LLC and Churchill Asset
    Management LLC as Sub-Advisor. DBRS Morningstar considers
    the Collateral Manager to be an acceptable collateralized
    loan obligation servicer.

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


CITIGROUP COMMERCIAL 2019-GC43: Fitch to Rate Cl. J-RR Certs 'B-'
-----------------------------------------------------------------
Fitch Ratings issued a presale report on Citigroup Commercial
Mortgage Trust 2019-GC43 commercial mortgage pass-through
certificates, series 2019-GC43.

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

  -- $8,955,000 class A-1 'AAAsf'; Outlook Stable;

  -- $41,294,000 class A-2 'AAAsf'; Outlook Stable;

  -- $185,000,000e class A-3 'AAAsf'; Outlook Stable;

  -- $382,302,000e class A-4 'AAAsf'; Outlook Stable;

  -- $13,585,000 class A-AB 'AAAsf'; Outlook Stable;

  -- $685,233,000b class X-A 'AAAsf'; Outlook Stable;

  -- $54,097,000 class A-S 'AAAsf'; Outlook Stable;

  -- $57,479,000 class B 'AA-sf'; Outlook Stable;

  -- $42,827,000 class C 'A-sf'; Outlook Stable;

  -- $100,306,000ab class X-B 'A-sf'; Outlook Stable;

  -- $47,335,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $15,778,000ab class X-F 'BB+sf'; Outlook Stable;

  -- $11,271,000ab class X-G 'BB-sf'; Outlook Stable;

  -- $27,048,000a class D 'BBBsf'; Outlook Stable;

  -- $20,287,000a class E 'BBB-sf'; Outlook Stable;

  -- $15,778,000a class F 'BB+sf'; Outlook Stable;

  -- $11,271,000a class G 'BB-sf'; Outlook Stable;

  -- $9,016,000ac class J-RR 'B-sf'; Outlook Stable.

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

  -- $32,684,165ac class K-RR 'NR';

  -- $35,250,000ad class VRR 'NR'.

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

(b) Notional amount and interest-only.

(c) Horizontal credit risk retention interest representing
approximately 1.28% of the estimated fair value of all classes of
regular certificates issued by the issuing entity as of the closing
date.

(d) Eligible vertical credit-risk retention interest (VRR) will
consist of approximately 3.76% of the certificate balance, notional
amount, or percentage interest of each class of certificates.

(e) The initial certificate balances of classes A-3 and A-4 are
unknown and expected to be $567,320,000 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 $100,000,000 to $270,000,000, and the expected class A-4
balance range is $297,302,000 to $467,302,000.

The expected ratings are based on information provided by the
issuer as of Oct. 21, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 34 loans secured by 75
commercial properties with an aggregate principal balance of
$936,873,165 as of the cut-off date. The loans were contributed to
the trust by Goldman Sachs Mortgage Company and Citi Real Estate
Funding, Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 75.2% of the properties
by balance, cash flow analysis of 90.4%, and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS
Higher Pool Concentration Relative to Recent Transactions: The top
10 loans represent 67.4% of the pool by balance, which is higher
than the 2018 and 2019 YTD multiborrower transaction averages of
50.6% and 51.0%, respectively. The pool's loan concentration index
(LCI) score of 541 and sponsor concentration index (SCI) score of
649 are also above the YTD 2019 averages of 381 and 402,
respectively.

Fitch Leverage: The pool's Fitch debt service coverage ratio (DSCR)
of 1.26x is higher than average when compared to the 2018 and 2019
YTD averages of 1.22x and 1.24x, respectively. In addition, the
pool's loan to value (LTV) of 105.5% is higher than the 2018 and
2019 YTD average of 102.0% and 101.4%, respectively.

Credit Opinion Loans: Two loans representing 16.5% of the pool are
credit assessed. The 30 Hudson Yards loan (9.0% of the pool)
received a stand-alone credit opinion of 'A-sf*' and the Grand
Canal Shoppes loan (7.5% of the pool) received a stand-alone credit
opinion of 'BBB-sf*'. Excluding the credit opinion loans, the Fitch
DSCR and LTV are 1.27x and 112.1%, respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 9.0% 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
CGCMT 2019-GC43 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.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Ernst & Young LLP and PricewaterhouseCoopers LLP. The
third-party due diligence described in Form 15E focused on a
comparison and re-computation of certain characteristics with
respect to each of the mortgage loans. Fitch considered this
information in its analysis and the findings did not have an impact
on its analysis or conclusions.


CSAIL 2017-CX10: Fitch Affirms BB-sf Rating on 3 Tranches
---------------------------------------------------------
Fitch Ratings affirmed 19 classes of CSAIL 2017-CX10 Commercial
Mortgage Trust Commercial Mortgage Pass-Through Certificates,
series 2017-CX10.

RATING ACTIONS

CSAIL 2017-CX10

                      Current Rating      Prior Rating

Cl. A-1 12595JAA2;  LT AAAsf Affirmed;  previously at AAAsf

Cl. A-2 12595JAC8;  LT AAAsf Affirmed;  previously at AAAsf

Cl. A-3 12595JAE4;  LT AAAsf Affirmed;  previously at AAAsf

Cl. A-4 12595JAG9;  LT AAAsf Affirmed;  previously at AAAsf

Cl. A-5 12595JAJ3;  LT AAAsf Affirmed;  previously at AAAsf

Cl. A-S 12595JAS3;  LT AAAsf Affirmed;  previously at AAAsf

Cl. A-SB 12595JAL8; LT AAAsf Affirmed;  previously at AAAsf

Cl. B 12595JAU8;    LT AA-sf Affirmed;  previously at AA-sf

Cl. C 12595JAW4;    LT A-sf Affirmed;   previously at A-sf

Cl. D 12595JBA1;    LT BBB-sf Affirmed; previously at BBB-sf

Cl. E 12595JBC7;    LT BB-sf Affirmed;  previously at BB-sf

Cl. F 12595JBE3;    LT B-sf Affirmed;   previously at B-sf

Cl. V1-A 12595JBL7; LT AAAsf Affirmed;  previously at AAAsf

Cl. V1-B 12595JBN3; LT A-sf Affirmed;   previously at A-sf

Cl. V1-D 12595JBQ6; LT BBB-sf Affirmed; previously at BBB-sf

Cl. V1-E 12595JBS2; LT BB-sf Affirmed;  previously at BB-sf

Cl. X-A 12595JAN4;  LT AAAsf Affirmed;  previously at AAAsf

Cl. X-B 12595JAQ7;  LT AA-sf Affirmed;  previously at AA-sf

Cl. X-E 12595JAY0;  LT BB-sf Affirmed;  previously at BB-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The overall pool
performance remains stable from issuance. There are no delinquent
or specially serviced loans. Three loans (11.0% of the current pool
balance) are on the servicer's watchlist, but none are considered
Fitch Loans of Concern. The Standard Highline (5.3%) is on the
servicer's watchlist due to a decline in NCF DSCR to 1.18x as of YE
2018. Servicer commentary indicates that food and beverage revenue
has declined by $8 million due to ongoing remodeling, including a
new chef experience. As 1Q 2019 TTM NCF DSCR was 1.28x, and food
and beverage revenue should improve further after renovations are
complete.

379 West Broadway (3.8%) is on the servicer's watchlist for a
decline in NCF DSCR to 1.03x as of 2Q 2019, compared to 1.59x at YE
2018. NCF is down due to increased expenses for repairs/maintenance
and general/administrative. Per the borrower, some of these
expenses were for non-recurring repairs. The servicer is in the
process of amending the OSAR to remove non-recurring items. WeWork
represents 80.9% of the NRA and 65.6% of the total base rent, with
a lease expiration in 2024 prior to the loan maturity in 2027.
WeWork pays approximately $64 psf in rent, which is slightly below
the submarket average of $70 psf, per the 2Q 2019 Reis report.

332 East 6th Street (0.6%) is on the servicer's watchlist for a
decline in DSCR to 1.02x as of 2Q 2019, compared to 1.40x at YE
2018. NCF at this property also declined due to increased expenses
for repairs/maintenance and general/administrative. The property
continues to perform at 100% occupancy.

Minimal Change to Credit Enhancement: As of the September 2019
distribution date, the pool's aggregate balance has been reduced by
0.51% to $850.9 million, from $855.3 million at issuance. Sixteen
full-term, interest-only loans account for 61.5% of the pool, and
six loans representing 11.1% of the pool are partial interest only.
Two ARD loans represent 6.9% of the pool and the remainder of the
pool consists of seven balloon loans representing 20.5% of the
pool. Interest shortfalls are currently affecting class NR.

ADDITIONAL CONSIDERATIONS

Credit Opinion Loans: At issuance, Fitch considered four loans
(23.4%) to have investment-grade characteristics. These include
Yorkshire & Lexington Towers ('BBBsf'), One California Plaza
('A-sf'), The Standard Highline NYC ('Asf'), and Centre 425
Bellevue ('BBB+sf').

Low Hotel & Retail Loan Concentration: Loans backed by hotel
properties represent only 7.9% of the pool, including one (5.3%) in
the top 15. Loans backed by retail properties represent 11.0% of
the pool, one of which is backed by a regional mall, Lehigh Valley
Mall (5.7%), which has exposure to JC Penney, Boscov's, and
Macy's.

RATING SENSITIVITIES

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

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

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


DRYDEN 76 CLO: S&P Rates $12MM Class E Notes 'BB- (sf)'
-------------------------------------------------------
S&P Global Ratings assigned its 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) mostly senior secured term loans managed by PGIM
Inc.

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 experience of the collateral manager's 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- (sf)               12.00
  Subordinated notes     NR                     33.30

  NR--Not rated.


FIRST INVESTORS 2019-2: S&P Assigns B (sf) Rating to Cl. F Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to First Investors Auto
Owner Trust 2019-2's (FIAOT 2019-2's) asset-backed notes.

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

The ratings reflect:

-- The availability of approximately 39.3%, 33.9%, 26.4%, 20.7%,
16.8%, and 13.6% 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
approximately 3.50x, 3.00x, 2.30x, 1.75x, 1.40x, and 1.10x coverage
of S&P's 10.75%-11.25% expected cumulative net loss range for the
class A, B, C, D, E, and F notes, respectively.

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

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal, the ratings on the class A, B, and
C notes would not drop by more than one rating category, and the
ratings on the class D notes would not drop by more than two rating
categories. The class E and F notes (rated 'BB- (sf)' and 'B (sf)',
respectively) will remain within two rating categories of the
assigned ratings during the first year, but will eventually default
under the 'BBB' stress scenario. These potential rating movements
are consistent with S&P's rating stability criteria.

-- The collateral characteristics of the pool being securitized,
with direct loans accounting for approximately 43% of the
statistical pool. These loans historically have lower losses than
the indirect-originated loans.

-- Prefunding will be used in this transaction in the amount of
approximately $35 million--about 16% of the pool. The subsequent
receivables are expected to be transferred into the trust within
three months of the closing date.

-- First Investors Financial Services Inc.'s (First Investors)
30-year history of originating and underwriting auto loans, 18-year
history of self-servicing auto loans, and track record of
securitizing auto loans since 2000.

-- First Investors' 14 years of origination static pool data,
segmented by direct and indirect loans. Wells Fargo Bank N.A.'s
experience as the committed back-up servicer.

-- The transaction's sequential payment structure, which builds
credit enhancement based on a percentage of receivables as the pool
amortizes.

  RATINGS ASSIGNED

  First Investors Auto Owner Trust 2019-2

  Class      Rating      Amount (mil. $)       Coupon (%)

  A          AAA (sf)            150.890           2.21
  B          AA (sf)              15.640           2.47
  C          A (sf)               20.360           2.71
  D          BBB (sf)             14.360           2.80
  E          BB- (sf)              7.400           3.88
  F          B (sf)                5.670           5.69


FLAGSTAR MORTGAGE 2019-1INV: Moody's Rates Cl. B-5 Debt '(P)B2'
---------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to twenty
six classes of residential mortgage-backed securities issued by
Flagstar Mortgage Trust 2019-1INV. The ratings range from (P)Aaa
(sf) to (P)B2 (sf).

Issuer: Flagstar Mortgage Trust 2019-1INV

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

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

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

Cl. A-4, Assigned (P)Aaa (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. 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)Aa2 (sf)

Cl. A-15, Assigned (P)Aa2 (sf)

Cl. A-16, Assigned (P)Aa1 (sf)

Cl. A-17, Assigned (P)Aa1 (sf)

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

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

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

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

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

Cl. B-4, Assigned (P)Ba2 (sf)

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

Cl. RR-A, Assigned (P)Aa3 (sf)

Cl. RR-A2, Assigned (P)A2 (sf)

RATINGS RATIONALE

Summary credit analysis

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
originator assessments, third-party review scope and results, and
the financial strength of representation & warranty provider. Its
expected loss for this pool in a base case scenario is 1.15% and
reaches 10.60% at a stress level consistent with its Aaa (sf)
scenario.

Collateral description

Flagstar Mortgage Trust 2019-1INV (FSMT 2019-1INV) is the first
issue from Flagstar Mortgage Trust in 2019 and the third under the
FSMT-INV shelf. Flagstar Bank, FSB (Flagstar) is the sponsor of the
transaction.

FSMT 2019-1INV is a securitization of GSE eligible first-lien
investment purpose mortgage loans (97.6% of the aggregate pool) and
Jumbo Advantage fixed rate mortgages (2.4% of the aggregate pool).
48.9% of the pool by loan balance were originated by loanDepot.com,
LLC and 51.1% Flagstar Bank, FSB. Majority of the loans are
underwritten in accordance with Freddie Mac or Fannie Mae
guidelines, which take into consideration, among other factors, the
income, assets, employment and credit score of the borrower as well
as loan-to-value (LTV). The loans were run through one of the
government-sponsored enterprises' (GSE) automated underwriting
systems (AUS) and received an "Approve" or "Accept" recommendation.
Other loans consists of Jumbo Advantage fixed rate mortgages, which
are loans originated under Flagstar's expanded credit prime loan
program called "Jumbo Advantage". Flagstar's Jumbo Advantage
program is a prime program with credit parameters outside of
Flagstar's traditional prime jumbo program, "Jumbo Fixed." The
Jumbo Advantage program expands the low end of Flagstar's FICO
range to 661 from 700, while increasing the high end of eligible
loan-to-value ratios from 85% to 90%.

The mortgage loans are not subject to the Truth in Lending Act and
therefore, are not subject to the ability-to-repay rules, unless
they are cash-out loans used for personal use. The majority of the
mortgage loans in FSMT 2019-1INV are not subject to TILA because
each mortgage loan is an extension of credit primarily for a
business or commercial purpose and is not a "covered transaction"
as defined in Section 1026.43(b)(1) of Regulation Z.

The sponsor has represented that none of the mortgage loans (except
for cash-out loans used for personal use) in FSMT 2019-1INV are
subject to the Truth in Lending Act (TILA) or the Ability-To Prepay
(ATR) rules because each mortgage loan is an extension of credit
primarily for a business or commercial purpose and is not a
"covered transaction" as defined in Section 1026.43(b)(1) of
Regulation Z.

As of the cut-off date of October 1, 2019, the $365,569,043.46 pool
consisted of 1,064 mortgage loans secured by first liens on
residential investment properties. The average stated principal
balance is $343,580 and the weighted average (WA) current mortgage
rate is 4.8%. The majority of the loans have a 30-year term, with 3
loans with terms ranging from 20 to 25 years. All of the loans have
a fixed rate. The WA original credit score is 765 and the WA
combined original LTV (CLTV) is 67.2%. The WA original
debt-to-income (DTI) ratio is 35.1%. Approximately, 9.0% of the
borrowers have more than one mortgage loan in the mortgage pool.
The mortgage loans have a WA seasoning of three months.

All of the mortgage loans originated by Flagstar were either
directly or indirectly through correspondents.

Almost half of the mortgage loans by loan balance (49.5%) are
backed by properties located in California. The next two largest
geographic concentration of properties are New York and Colorado,
which represents 7.5% and 5.6% by loan balance, respectively. All
other states each represent less than 5% by loan balance.
Approximately 25.9% (by loan balance) of the pool is backed by
properties that are 2-4 unit residential properties whereas loans
backed by single family residential properties represent 43.5% (by
loan balance) of the pool.

Third-party review and representation & warranties

The credit, compliance, property valuation, and data integrity
portion of the third party review (TPR) was conducted on a total of
approximately 70% of the pool (by loan count) random sample of
Flagstar originated loans of 233 loans (21%) and on all of the 513
loans originated by loanDepot (48%). With sampling, there is a risk
that loans with grade C or grade D issues remain in the pool and
that data integrity issues were not corrected prior to
securitization for all of the loans in the pool. Moreover,
vulnerabilities of the R&W framework, such as the financial
condition of the R&W provider, may be amplified due to the TPR
sample. Moody's did not make an adjustment to loss levels to
account for this risk as the sample size meets its credit neutral
criteria, but Moody's made adjustments to loss levels to account
for TPR results.

Although the loan-level R&Ws themselves meet or exceed its baseline
set of R&Ws, Moody's took into account the financial condition of
the R&W provider. Furthermore, a cash-out refinance investor loan
could be subject to TILA and ATR if the borrower uses the cash
proceeds for non-business purposes. This issue is mitigated by the
tests related to TILA, which require the independent reviewer to
test all the loans for TILA compliance. As a result, a breach of
TILA related representations would require the Sponsor to
repurchase the loans if a cash-out refinance loan incurs a TILA or
ATR violation. Moody's made an adjustment to its loss levels to
account for financial condition of the R&W provider.

Servicing arrangement

Moody's considers the overall servicing arrangement for this pool
to be adequate. Flagstar will service the mortgage loans. Servicing
compensation is subject to a step-up incentive fee structure. Wells
Fargo Bank, N.A. will be the master servicer. Flagstar will be
responsible for principal and interest advances as well as
servicing advances. The master servicer will be required to make
principal and interest advances if Flagstar is unable to do so.

Servicing compensation for loans in this transaction is based on a
fee-for-service incentive structure. The fee-for-service incentive
structure includes an initial monthly base fee of $20.5 for all
performing loans and increases according to certain delinquent and
incentive fee schedules. 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 fee-for-service
compensation is reasonable and adequate for this transaction. It
also better aligns the servicer's costs with the deal's performance
and structure. The Class B-6-C (NR) is first in line to absorb any
increase in servicing costs above the base servicing costs.
Delinquency and incentive fees will be deducted from the Class
B-6-C interest payment amount first and could result in interest
shortfall to the certificates depending on the magnitude of the
delinquency and incentive fees.

Trustee and master servicer

The transaction trustee is Wilmington Savings Fund Society, FSB.
The custodian functions will be performed by Wells Fargo Bank, N.A.
The paying agent and cash management functions will be performed by
Wells Fargo Bank, N.A., rather than the trustee. In addition, Wells
Fargo, as master servicer, is responsible for servicer oversight,
and termination of servicers and for the appointment of successor
servicers. In addition, Wells Fargo is obligated to make servicing
advances if the servicer is unable to do so.

Tail risk & subordination floor

This deal has a 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 1.80% 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 11.20% 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 0.75% 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.

Moody's stressed the tail risk by assuming that the last five to 10
remaining loans are the largest loans in the pool. Given that FSMT
2019-1INV includes borrowers with more than one mortgage loan in
the pool, Moody's considered in its analysis of tail risk the
combined balance of the loans made to each unique borrower to
determine the largest loans in the pool. Based on an analysis of
scenarios where the largest five to 10 loans in the pool default
late in the life of the transaction, Moody's viewed the 1.80%
senior floor as credit neutral. Moody's viewed the 0.75%
subordination floor as credit neutral in its rating analysis.

Transaction structure

The securitization has a shifting interest structure that benefits
from a senior subordination floor and a subordinate floor. Funds
collected, including principal, are first used to make interest
payments and then principal payments on pro rata basis up to the
senior bonds principal distribution amount, and then interest and
principal payments on sequential basis up to each subordinate bond
principal distribution amount. As in all transactions with shifting
interest structures, the senior bonds benefit from a cash flow
waterfall that allocates all prepayments to the senior bond for a
specified period of time, and increasing amounts of prepayments to
the subordinate bonds thereafter, but only if loan performance
satisfies delinquency and loss tests.

The senior support certificates will only receive their pro-rata
share of scheduled principal payments allocated to the senior bonds
for five years, whereas all prepayments allocated to the senior
bonds will be paid to the super senior certificates, leading to a
faster buildup of super senior credit enhancement. After year five,
the senior support bond will receive an increasing share of
prepayments in accordance with the shifting percentage schedule.

All certificates (except Class B-6-C) in this transaction are
subject to a net WAC cap. Class B-6-C will accrue interest at the
net WAC minus the aggregate delinquent servicing and aggregate
incentive servicing fee. For any distribution date, the net WAC
will be the greater of (1) zero and (2) the weighted average net
mortgage rates minus the capped trust expense rate.

Realized losses are allocated reverse sequentially among the
subordinate, starting with most junior, and senior support
certificates and on a pro-rata basis among the super senior
certificates.

Exposure to extraordinary expenses

Certain extraordinary trust expenses (such as fees paid to the
reviewer, servicing transfer costs) in the FSMT 2019-1INV
transaction are deducted directly from the available distribution
amount. The remaining trust expenses (which have an annual cap of
$550,000 per year) are deducted from the net WAC. Moody's believes
there is a very low likelihood that the rated certificates in FSMT
2019-1INV will incur any losses from extraordinary expenses or
indemnification payments from potential future lawsuits against key
deal parties. First, the loans are 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. Second, 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), named at closing must review loans
for breaches of representations and warranties when certain clear
defined triggers have been breached, which reduces the likelihood
that parties will be sued for inaction. Furthermore, the issuer has
disclosed the results of a compliance, credit, valuation and data
integrity review covering a sample of the mortgage loans by an
independent third party (AMC and Opus). Moody's did not make an
adjustment for extraordinary expenses because most of the trust
expenses will reduce the net WAC as opposed to the available
funds.

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

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.


FORTRESS CREDIT VIII: S&P Rates $20MM Class E Notes 'BB- (sf)'
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to Fortress Credit BSL VIII
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
  Fortress Credit BSL VIII Ltd./Fortress Credit BSL VIII LLC  

  Class                 Rating       Amount (mil. $)
  A-1A                  AAA (sf)              191.00
  A-1F                  AAA (sf)               25.00
  A-2                   NR                     32.00
  B                     AA (sf)                48.00
  C (deferrable)        A (sf)                 24.00
  D (deferrable)        BBB- (sf)              24.00
  E (deferrable)        BB- (sf)               20.00
  Subordinated notes    NR                     37.00

  NR--Not rated.


FREDDIE MAC 2019-DNA4: S&P Rates $74MM Cl. B-1 Notes 'B (sf)'
-------------------------------------------------------------
S&P Global Ratings assigned its ratings to Freddie Mac STACR REMIC
Trust 2019-DNA4's notes.

The note issuance is an RMBS transaction backed by a reference pool
of 100% conforming residential mortgage loans.

The ratings reflect:

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

-- The credit quality of the collateral included in the reference
pool;

-- A REMIC structure that reduces the counterparty exposure to
Freddie Mac for periodic principal and interest payments but, at
the same time, pledges the support of Freddie Mac (a highly rated
counterparty) to cover shortfalls, if any, on interest payments and
to make up for any investment losses;

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

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

  RATINGS ASSIGNED
  Freddie Mac STACR REMIC Trust 2019-DNA4

  Class      Rating          Amount ($)
  A-H(i)     NR          19,727,912,806
  M-1        BBB+ (sf)      148,000,000
  M-1H(i)    NR              57,499,091
  M-2        BB- (sf)       280,000,000
  M-2R       BB- (sf)       280,000,000
  M-2S       BB- (sf)       280,000,000
  M-2T       BB- (sf)       280,000,000
  M-2U       BB- (sf)       280,000,000
  M-2I       BB- (sf)       280,000,000
  M-2A       BBB- (sf)      140,000,000
  M-2AR      BBB- (sf)      140,000,000
  M-2AS      BBB- (sf)      140,000,000
  M-2AT      BBB- (sf)      140,000,000
  M-2AU      BBB- (sf)      140,000,000
  M-2AI      BBB- (sf)      140,000,000
  M-2AH(i)   NR              55,224,137
  M-2B       BB- (sf)       140,000,000
  M-2BR      BB- (sf)       140,000,000
  M-2BS      BB- (sf)       140,000,000
  M-2BT      BB- (sf)       140,000,000
  M-2BU      BB- (sf)       140,000,000
  M-2BI      BB- (sf)       140,000,000
  M-2RB      BB- (sf)       140,000,000
  M-2SB      BB- (sf)       140,000,000
  M-2TB      BB- (sf)       140,000,000
  M-2UB      BB- (sf)       140,000,000
  M-2BH(i)   NR              55,224,137
  B-1        B (sf)          74,000,000
  B-1A       B+ (sf)         37,000,000
  B-1AR      B+ (sf)         37,000,000
  B-1AI      B+ (sf)         37,000,000
  B-1AH(i)   NR              14,374,772
  B-1B       B (sf)          37,000,000
  B-1BH(i)   NR              14,374,772
  B-2        NR              87,000,000
  B-2A       NR              43,500,000
  B-2AR      NR              43,500,000
  B-2AI      NR              43,500,000
  B-2AH(i)   NR               7,874,772
  B-2B       NR              43,500,000
  B-2BH(i)   NR               7,874,772
  B-3H(i)    NR              20,549,913

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



FREED ABS 2019-2: DBRS Finalizes BB(low) Rating on Class C Notes
----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of notes (the Notes) issued by FREED ABS Trust 2019-2
(FREED 2019-2):

-- $343,820,000 Class A Notes at A (high) (sf)
-- $90,410,000 Class B Notes at BBB (high) (sf)
-- $84,470,000 Class C Notes at BB (low) (sf)

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

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

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

-- Transaction cash flows are sufficient to repay investors under
all A (high) (sf), BBB (high) (sf) and BB (low) (sf) stress
scenarios in accordance with the terms of the FREED 2019-2
transaction documents.

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

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

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

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

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

-- All loans included in FREED 2019-2 are originated by CRB, a New
Jersey state-chartered Federal Deposit Insurance
Corporation-insured bank.

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

-- The weighted-average APR of the loans in the pool is 22.75%.

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

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

-- The FREED 2019-2 loan pool includes loans originated to
borrowers in Maryland, a state with active litigation. DBRS
Morningstar incorporated an additional stressed cash flow analysis
assuming that loans to borrowers in Maryland with APRs above the
state usury cap of 24% were subsequently reduced to the state usury
cap. Transaction cash flows are sufficient to repay investors under
all A (high) (sf), BBB (high) (sf) and BB (low) (sf) stress
scenarios.

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

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

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


GLS AUTO 2019-4: S&P Assigns Prelim BB- (sf) Rating to Cl. D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to GLS Auto
Receivables Issuer Trust 2019-4's automobile receivables-backed
notes series 2019-4.

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

The preliminary ratings are based on information as of Oct. 23,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The availability of approximately 49.10%, 40.10%, 31.80%, and
25.20% of credit support for the class A, B, C, and D notes,
respectively, based on stressed cash flow scenarios (including
excess spread). These credit support levels provide coverage of
approximately 2.55x, 2.05x, 1.60x, and 1.25x S&P's 18.50%-19.50%
expected cumulative net loss for the class A, B, C, and D notes,
respectively.

-- The expectation that under a moderate ('BBB') stress scenario
(1.60x S&P's expected loss level), all else being equal, S&P's
rating on the class A and B notes will remain within one rating
category of the assigned preliminary 'AA (sf)' and 'A (sf)'
ratings, and its rating on the class C notes will remain within two
rating categories of the assigned preliminary 'BBB (sf)' rating.
The class D notes will remain within two rating categories of the
assigned preliminary 'BB- (sf)' rating during the first year, but
will eventually default under the 'BBB' stress scenario. These
rating movements are within the limits specified by S&P's credit
stability criteria.

-- S&P's analysis of over six years of origination static pool
data and securitization performance data on Global Lending Services
LLC's (GLS') seven Rule 144A securitizations.

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

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

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

  PRELIMINARY RATINGS ASSIGNED

  GLS Auto Receivables Issuer Trust 2019-4

  Class       Rating           Amount (mil. $)(i)
  A           AA (sf)                  204.70
  B           A (sf)                    51.35
  C           BBB (sf)                  41.35
  D           BB- (sf)                  32.60


(i)The interest rates and actual sizes of these tranches will be
determined on the pricing date.


GS MORTGAGE 2019-PJ3: DBRS Gives Prov. B(high) Rating on B-5 Certs
------------------------------------------------------------------
DBRS, Inc. assigned the following provisional ratings to the
Mortgage Pass-Through Certificates, Series 2019-PJ3 (the
Certificates) to be issued by GS Mortgage-Backed Securities Trust
2019-PJ3 (GSMBS 2019-PJ3):

-- $230.4 million Class A-1 at AAA (sf)
-- $230.4 million Class A-2 at AAA (sf)
-- $16.9 million Class A-3 at AAA (sf)
-- $16.9 million Class A-4 at AAA (sf)
-- $172.8 million Class A-5 at AAA (sf)
-- $172.8 million Class A-6 at AAA (sf)
-- $57.6 million Class A-7 at AAA (sf)
-- $57.6 million Class A-8 at AAA (sf)
-- $247.3 million Class A-9 at AAA (sf)
-- $247.3 million Class A-10 at AAA (sf)
-- $247.3 million Class A-X-1 at AAA (sf)
-- $16.9 million Class A-X-3 at AAA (sf)
-- $172.8 million Class A-X-5 at AAA (sf)
-- $57.6 million Class A-X-7 at AAA (sf)
-- $5.4 million Class B-1 at AA (high) (sf)
-- $9.2 million Class B-2 at A (sf)
-- $3.1 million Class B-3 at BBB (high) (sf)
-- $2.6 million Class B-4 at BB (high) (sf)
-- $1.5 million Class B-5 at B (high) (sf)

Classes A-X-1, A-X-3, A-X-5 and A-X-7 are interest-only notes. The
class balances represent notional amounts.

Classes A-1, A-2, A-4, A-6, A-8, A-9 and A-10 are exchangeable
notes. These classes can be exchanged for combinations of exchange
notes as specified in the offering documents.

Classes A-5, A-6, A-7 and A-8 are super-senior certificates. These
classes benefit from additional protection from the senior support
certificates (Classes A-3 and A-4) with respect to loss
allocation.

The AAA (sf) rating on the Class A-1 Notes reflects 8.75% of credit
enhancement provided by subordinated notes in the pool. The AA
(high) (sf), A (sf), BBB (high) (sf), BB (high) (sf) and B (high)
(sf) ratings reflect 6.75%, 3.35%, 2.20%, 1.25% and 0.70% of credit
enhancement, respectively.

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

GSMBS 2019-PJ3 is a securitization of a portfolio of first-lien,
fixed-rate, prime residential mortgages funded by the issuance of
the Certificates. The Certificates are backed by 394 loans with a
total principal balance of $271,016,060 as of the Cut-Off Date
(October 1, 2019).

The originators for the mortgage pool are HomeBridge Financial
Services, Inc. (25.3%), loanDepot.com, LLC (19.9%) and various
other originators, each comprising less than 15.0% of the mortgage
loans. Goldman Sachs Mortgage Company is the Sponsor and the
Mortgage Loan Seller of the transaction. For certain originators,
the related loans (8.9%) were sold to MAXEX Clearing LLC and were
subsequently acquired by the Mortgage Loan Seller.

NewRez LLC doing business as Shellpoint Mortgage Servicing will
service all mortgage loans within the pool. Wells Fargo Bank, N.A.
(rated AA with a Stable trend by DBRS Morningstar) will act as the
Master Servicer, Securities Administrator and Custodian. U.S. Bank
Trust National Association will serve as Delaware Trustee.
Pentalpha Surveillance LLC will serve as the representations and
warranties File Reviewer.

The pool consists of fully amortizing fixed-rate mortgages with
original terms to maturity of 30 years and a weighted-average (WA)
loan age of four months. Approximately 40.6% of the pools are
conforming, high-balance mortgage loans that were underwritten
using an automated underwriting system designated by Fannie Mae or
Freddie Mac and were eligible for purchase by such agencies. The
remaining 59.4% of the pool are traditional, non-agency, prime
jumbo mortgage loans.

Compared with prior GSMBS prime securitizations, the GSMBS 2019-PJ3
pool exhibits a similar WA original loan-to-value (LTV) ratio;
however, the portfolio contains a more barbelled distribution of
LTV ratios with larger concentrations in the higher LTV buckets.
For this transaction, 20.2% of the pool have current combined LTV
ratios over 80.0% but are generally below 95.0%.

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


GSMS 2019-GSA1: Fitch to Rate $8.6MM Class G-RR Certs B-sf
----------------------------------------------------------
Fitch Ratings issued a presale report on GSMS 2019-GSA1 commercial
mortgage pass-through certificates, series 2019-GSA1.

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

  -- $14,908,000 class A-1 'AAAsf'; Outlook Stable;

  -- $26,937,000 class A-2 'AAAsf'; Outlook Stable;

  -- $171,631,000a class A-3 'AAAsf'; Outlook Stable;

  -- $370,947,000a class A-4 'AAAsf'; Outlook Stable;

  -- $20,542,000 class A-AB 'AAAsf'; Outlook Stable;

  -- $679,505,000b class X-A 'AAAsf'; Outlook Stable;

  -- $76,701,000b class X-B 'A-sf'; Outlook Stable;

  -- $74,540,000 class A-S 'AAAsf'; Outlook Stable;

  -- $39,971,000 class B 'AA-sf'; Outlook Stable;

  -- $36,730,000 class C 'A-sf'; Outlook Stable;

  -- $24,847,000c class D 'BBBsf'; Outlook Stable;

  -- $44,292,000bc class X-D 'BBB-sf'; Outlook Stable;

  -- $19,445,000c class E 'BBB-sf'; Outlook Stable;

  -- $21,606,000cde class F-RR 'BB-sf'; Outlook Stable;

  -- $8,642,000cde class G-RR 'B-sf'; Outlook Stable.

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

  -- $33,489,960cde class H-RR.

(a) The initial certificate balances of classes A-3 and A-4 are
unknown and expected to be $542,578,000 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 $102,466,000 to $240,796,000, and the expected class A-4
balance range is $301,782,000 to $440,112,000. Fitch's certificate
balances for classes A-3 and A-4 are assumed at the midpoint of the
range for each class.

(b) Notional amount and interest only.

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

(d) Horizontal credit-risk retention interest.

(e) The initial certificate balance of each of the class F-RR,
class G-RR and class H-RR certificates is subject to change based
on final pricing of all certificates and the final determination of
the class F-RR, class G-RR and class H-RR certificates.

TRANSACTION SUMMARY

The expected ratings are based on information provided by the
issuer as of Oct. 18, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 49 loans secured by 84
commercial properties having an aggregate principal balance of
$864,235,961 as of the cut-off date. The loans were contributed to
the trust by Argentic Real Estate Finance LLC, Goldman Sachs
Mortgage Securities, Starwood Mortgage Capital LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 74.0% of the properties
by balance, cash flow analysis of 86.2% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

High Fitch Leverage: The pool's Fitch LTV is 109.6%, which is above
the 2018 and 2019 YTD averages of 102.0% and 101.8%, respectively,
for other Fitch-rated multiborrower transactions. The pool's Fitch
DSCR of 1.27x is higher than both the 2018 and 2019 YTD averages of
1.22x and 1.25x, respectively; however, the pool's weighted average
coupon was just 3.82%.

Low Mortgage Coupons: The pool's weighted average (WA) mortgage
rate is 3.82%, which is well below historical averages and lower
than the YTD 2019 average of 4.56%, for Fitch-rated conduit
multiborrower transactions. Fitch accounted for increased refinance
risk in a higher interest rate environment by reviewing an interest
rate sensitivity that assumes an interest rate floor of 5.0% for
the term risk for most property types, 4.5% for multifamily
properties and 6.0% for hotel properties, in conjunction with
Fitch's stressed refinance rates, which were 9.47% on a WA basis.

Above-Average Multifamily Exposure: The pool's multifamily
concentration is 27.1%, which is significantly above the 2018 and
YTD 2019 averages of 11.6% and 13.6%, respectively. Loans secured
by multifamily properties have a lower than average probability of
default in Fitch's multiborrower model, all else equal.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 9.7% 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 GSMS
2019-GSA1 certificates and found that the transaction displays
average sensitivities to further declines in NCF. In a scenario in
which NCF declined a further 20% from Fitch's NCF, a downgrade of
the junior 'AAAsf' certificates to 'A+sf' could result. In a more
severe scenario, in which NCF declined a further 30% from Fitch's
NCF, a downgrade of the junior 'AAAsf' certificates to 'BBBsf'
could result.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Ernst & Young LLP. The third-party due diligence
described in Form 15E focused on a comparison and re-computation of
certain characteristics with respect to each of the mortgage loans.
Fitch considered this information in its analysis and the findings
did not have an impact on the agency's analysis or conclusions.


JFIN CLO 2015: Moody's Lowers Rating on $7MM Class F Notes to B3
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings on the following
notes issued by JFIN CLO 2015 Ltd.:

US$7,000,000 Class F Mezzanine Secured Deferrable Floating Rate
Notes Due 2026, Downgraded to B3 (sf); previously on April 23, 2015
Definitive Rating Assigned B2 (sf)

JFIN CLO 2015 Ltd., issued in April 2015 and partially refinanced
in December 2017 is a managed cashflow CLO. The notes are
collateralized primarily by a portfolio of broadly syndicated
senior secured corporate loans. The transaction's reinvestment
period ended in March 2019.

RATINGS RATIONALE

The downgrade rating action on the Class F notes reflects the
specific risks to the junior notes posed by credit deterioration
and par loss observed in the underlying CLO portfolio. Based on the
trustee's September 2019 report, the weighted average rating factor
(WARF) was reported at 3113, versus the January 2019 level of 2978,
and is currently failing the maximum WARF test level. Based on
Moody's calculations, the weighted average spread (WAS) has
decreased to 3.73% versus the January 2019 level of 3.80%.
Furthermore, based on Moody's calculations, the
over-collateralization ratio for the Class F notes has fallen to
105.11% versus the January 2019 level of 106.45%.

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

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base case,
Moody's analyzed the collateral pool as having a performing par and
principal proceeds balance of $466.6 million, defaulted par of $9.3
million, a weighted average default probability of 21.73% (implying
a WARF of 3122), a weighted average recovery rate upon default of
47.31%, a diversity score of 78 and a weighted average spread of
3.73%.

Methodology Used for the Rating Action

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

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

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 CLO manager's investment
decisions and management of the transaction will also affect the
performance of the rated notes.


JP MORGAN 2006-CIBC16: Moody's Affirms C Rating on 3 Tranches
-------------------------------------------------------------
Moody's Investors Service, affirmed the ratings on four classes in
J.P. Morgan Chase Commercial Mortgage Securities Corp. Series
2006-CIBC16, Commercial Mortgage Pass-Through Certificates, and
Series 2006-CIBC16 as follows:

Cl. A-J, Affirmed Caa2 (sf); previously on Jul 19, 2018 Affirmed
Caa2 (sf)

Cl. B, Affirmed C (sf); previously on Jul 19, 2018 Affirmed C (sf)

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

Cl. X-1*, Affirmed C (sf); previously on Jul 19, 2018 Affirmed C
(sf)

* Reflects Interest Only classes

RATINGS RATIONALE

The ratings on three P&I classes were affirmed because the ratings
are consistent with Moody's expected loss plus realized losses. Cl.
C has already experienced a 65% realized loss as a result of
previously liquidated loans.

The rating on the IO Class, Cl. X-1, was affirmed based on the
credit quality of its referenced classes.

Moody's rating action reflects a base expected loss of 73.1% of the
current pooled balance, compared to 61.9% at Moody's last review.
Moody's base expected loss plus realized losses is now 13.5% of the
original pooled balance, compared to 13.8% 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 or an
improvement in pool performance.

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 90% of the pool is in
special servicing. In this approach, Moody's determines a
probability of default for each specially serviced loan and
estimates a loss given default based on a review of broker's
opinions of value (if available), other information from the
special servicer, available market data and Moody's internal data.
The loss given default for each loan also takes into consideration
repayment of servicer advances to date, estimated future advances
and closing costs. Translating the probability of default and loss
given default into an expected loss estimate, Moody's then applies
the aggregate loss from specially serviced to the most junior
classes and the recovery as a pay down of principal to the most
senior classes.

DEAL PERFORMANCE

As of the October 15, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 95% to $104 million
from $2.15 billion at securitization. The certificates are
collateralized by six mortgage loans ranging in size from less than
3% to 48% of the pool. Four loans, constituting 90.4% of the pool,
are currently in special servicing and all of them are already real
estate owned ("REO").

Twenty-six loans have been liquidated from the pool with losses,
resulting in an aggregate realized loss of $214.4 million (for an
average loss severity of 64.0%).

The largest specially serviced loan is the REPM Portfolio ($50.0
million -- 48.1% of the pool), which was originally secured by the
fee interest in a portfolio of ten industrial/flex projects located
across eight states. Nine of the ten properties have been sold with
the proceeds already applied to the aggregate loan balance. The
sole remaining property is a 231,000 SF industrial property located
in Palm Bay, Florida. The special servicer indicates the property
was recently marketed for sale and is now under contract. A
significant loss is anticipated on this loan due to ongoing
environmental issues and the property's location in a tertiary
market.

The second largest specially serviced loan is the Fountain Place
Shopping Center loan ($21.9 million -- 21.1% of the pool), which is
secured by a retail center anchored by Lowes and shadow-anchored by
a Wal-Mart Supercenter. The property is located in Logan, West
Virginia. The property was 93% occupied as of March 2018, compared
to 99% in December 2016. The borrower initially transferred to
special servicing in July 2016 due to maturity default and after an
extension, the borrower was still unable to pay off the loan at the
extended maturity date in September 2018. The property was
foreclosed in November 2018. Current occupancy is approximately
90%. The special servicer indicates the property was recently
marketed for sale and is now under contract.

The remaining two specially serviced loans are secured by one
office and one retail property. Moody's estimates an aggregate $76
million loss for the specially serviced loans (81% expected loss on
an average).

The two performing loans represent 9.6% of the pool balance. The
largest performing loan is the Infor Global Solutions Office
Building Loan ($7.4 million -- 7.1% of the pool), which is secured
by a suburban office property located in Greenville, South
Carolina. The building is 100% leased to Infor Global Solutions
Corp. through March 2021. The loan is on the servicer's watchlist
because the primary lease has not been replaced with an acceptable
replacement lease that extends five years beyond the loan term and
a cash trap event has occurred. Due to the single tenant risk,
Moody's incorporated a lit/dark analysis. The loan matures in June
2021 and has amortized by 32% since securitization. Moody's LTV and
stressed DSCR are 100% and 1.02X, respectively.

The other performing loan is the Wythe Creek Plaza Loan ($2.6
million -- 2.5% of the pool), which is secured by 51,064 square
feet retail center located in Poquoson, Virginia. As of December
2018, the property was 91% occupied, the same as of December 2017.
The loan has amortized by 20% since securitization and Moody's LTV
and stressed DSCR are 82% and 1.15X, respectively.


JP MORGAN 2019-8: Moody's Assigns (P)B3 Rating on 2 Tranches
------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to 34
classes of residential mortgage-backed securities issued by J.P.
Morgan Mortgage Trust 2019-8. The ratings range from (P)Aaa (sf) to
(P)B3 (sf).

The certificates are backed by 872 30-year, fully-amortizing
fixed-rate mortgage loans with a total balance of $638,226,330 as
of the October 1, 2019 cut-off date. Similar to prior JPMMT
transactions, JPMMT 2019-8 includes agency-eligible mortgage loans
(11.4% by loan balance) underwritten to the government sponsored
enterprises (GSE) guidelines in addition to prime jumbo non-agency
eligible mortgages purchased by J.P. Morgan Mortgage Acquisition
Corp. (JPMMAC), the sponsor and mortgage loan seller, from various
originators and aggregators. United Shore Financial Services, LLC
d/b/a United Wholesale Mortgage and Shore Mortgage (United Shore)
originated approximately 79% of the mortgage pool by balance. All
other originators accounted for less than 10% of the pool by
balance. With respect to the mortgage loans, each originator or the
aggregator, as applicable, made a representation and warranty that
the mortgage loan constitutes a qualified mortgage (QM) under the
qualified mortgage rule.

The primary servicers for majority of the pool are JPMorgan Chase
Bank, N.A. and United Shore. JPMCB will ultimately be the servicer
for majority of the pool (57.5% by balance) and United Shore will
account for 35.7% by balance. Shellpoint will act as interim
servicer for the JPMorgan Chase Bank, N.A. (JPMCB) mortgage loans
until the servicing transfer date, which is expected to occur on or
about December 1, 2019, but may occur on a later date as determined
by the issuing entity. After the servicing transfer date, these
mortgage loans will be serviced by JPMCB. The servicing fee for
loans serviced by United Shore and JPMCB will be based on a step-up
incentive fee structure with a monthly base fee of $40 per loan and
additional fees for delinquent or defaulted loans (variable fee
framework). All other servicers will be paid a monthly flat
servicing fee equal to one-twelfth of 0.25% of the remaining
principal balance of the mortgage loans (fixed fee framework).
Nationstar Mortgage LLC d/b/a Mr. Cooper (Nationstar) will be the
master servicer and Citibank, National Association (Citibank) 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 2019-8

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)Aa2 (sf)

Cl. A-15, Assigned (P)Aa2 (sf)

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

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

Cl. B-1, Assigned (P)A1 (sf)

Cl. B-1-A, Assigned (P)A1 (sf)

Cl. B-2, Assigned (P)A3 (sf)

Cl. B-2-A, Assigned (P)A3 (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)

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

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 0.55%
in a base scenario and reaches 5.90% 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. Its final loss
estimates also incorporate adjustments for origination quality,
third party due diligence results 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, the origination quality, the servicing
arrangement, the strength of the third-party due diligence and the
R&W framework of the transaction.

Collateral Description

JPMMT 2019-8 is a securitization of a pool of 872 30-year,
fully-amortizing fixed-rate mortgage loans with a total balance of
$638,226,330 as of the cut-off date, with a weighted average (WA)
remaining term to maturity of 360 months, and a WA seasoning of 3.4
months. The WA current FICO score is 773 and the WA original
combined loan-to-value ratio (CLTV) is 72.0%. The characteristics
of the loans underlying the pool are generally comparable to those
of other JPMMT transactions backed by prime mortgage loans that
Moody's have rated.

Aggregation/Origination Quality

Moody's considers  JPMMAC's 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 (originator): Loans originated by United Shore have
been included in several prime jumbo securitizations that Moody's
have rated. United Shore originated approximately 79% of the
mortgage loans by pool balance (compared with about 11% by pool
balance in JPMMT 2018-9, an exposure by pool balance which has been
steadily increasing over the past year). The majority of these
loans were originated under United Shore's High Balance Nationwide
program which are processed using the Desktop Underwriter (DU)
automated underwriting system, and are therefore underwritten to
Fannie Mae guidelines. The loans receive a DU Approve Ineligible
feedback due to the loan amount only. Moody's made a negative
origination adjustment (i.e. Moody's increased its loss
expectations) for United Shore's loans due mostly to 1) the lack of
statistically significant program specific loan performance data
and 2) the fact that United Shore's High Balance Nationwide program
is unique and fairly new and no performance history has been
provided to Moody's on these loans. Under this program, the
origination criteria rely on the use of GSE tools (DU/LP) for
prime-jumbo non-conforming loans, subject to Qualified Mortgage
(QM) overlays. More time is needed to assess United Shore's ability
to consistently produce high-quality prime jumbo residential
mortgage loans under this program.

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 Mortgage LLC (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.

Servicing Fee Framework

The servicing fee for loans serviced by United Shore and JPMCB 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. The other servicers will be paid a monthly
flat servicing fee equal to one-twelfth of 0.25% of the remaining
principal balance of the mortgage loans. Shellpoint will act as
interim servicer for the JPMCB mortgage loans until the servicing
transfer date, December1, 2019 or such later date as determined by
the issuing entity and JPMCB.

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
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

Five third party review firms, AMC Diligence, LLC (AMC), Clayton
Services LLC (Clayton), Inglet Blair, Digital Risk and Opus Capital
Markets Consultants, LLC (Opus) (collectively, TPR firms) verified
the accuracy of the loan-level information that Moody's received
from the sponsor. These firms conducted detailed credit, valuation,
regulatory compliance and data integrity reviews on 100% of the
mortgage pool. The TPR results indicated compliance with the
originators' underwriting guidelines for majority of loans, no
material compliance issues, and no appraisal defects. Overall, 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.

The 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 firms also reviewed each loan to determine whether a
third-party valuation product was required and if required, that
the third-party product value was compared to the original
appraised value to identify a value variance. In some cases, if a
variance of more than 10% was noted, the TPR firms ensured any
required secondary valuation product was ordered and reviewed. The
property valuation portion of the TPR was conducted using, among
other methods, 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, a CDA, BPO or AVM was not provided because these loans were
originated under United Shore's High Balance Nationwide program
(i.e. non-conforming loans underwritten using Fannie Mae's Desktop
Underwriter Program) and had a CU risk score less than or equal to
2.5. Moody's considers  the use of 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
statistically significant sample size and valuation results of the
loans that were reviewed using a CDA or a field review (which
Moody's considers  to be a more accurate third-party valuation
product) were insufficient.

In addition, there were loans for which the original appraisal was
evaluated using only AVMs. Moody's believes that utilizing only
AVMs as a comparison to verify the original appraisals is much
weaker and less accurate than utilizing CDAs for the entire pool.
Moody's took this framework into consideration and applied an
adjustment to its expected or Aaa loss levels for such loans.

R&W Framework

JPMMT 2019-8's R&W framework is in line with that of other JPMMT
transactions where an independent reviewer is named at closing, and
costs and manner of review are clearly outlined at issuance. Its
review of the R&W framework 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. 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. Moody's analyzes the impact of less
creditworthy R&W providers case by case, in conjunction with other
aspects of the transaction.

Moody's made no adjustments to the loans for which JPMCB (Aa2), its
affiliate, JPMMAC and USAA Federal Savings Bank (a subsidiary of
USAA Capital Corporation, rated Aa1) provided R&Ws since they are
highly rated and/or financially stable entities. In contrast, the
rest of the R&W providers are unrated and/or financially weaker
entities. Moody's applied an adjustment to the loans for which
these entities provided R&Ws. JPMMAC will make the mortgage loan
representations and warranties with respect to mortgage loans
originated by certain originators (approx. 2.4% by loan balance).
For loans that JPMMAC acquired via the MAXEX Clearing LLC (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 other JPMMT transactions.

No other party will backstop or be responsible for backstopping any
R&W providers who may become financially incapable of repurchasing
mortgage loans. With respect to the mortgage loan R&Ws made by such
originators or the aggregator, as applicable, as of a date prior to
the closing date, JPMMAC will make a "gap" representation covering
the period from the date as of which such R&W is made by such
originator or the aggregator, as applicable, to the cut-off date or
closing date, as applicable. Additionally, no party will be
required to repurchase or substitute any mortgage loan until such
loan has gone through the review process.

Trustee and Master Servicer

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

Tail Risk & Subordination Floor

This deal has a standard shifting interest structure, with a
subordination floor to protect against losses that occur late in
the life of the pool when relatively few loans remain (tail risk).
When the total senior subordination is less than 1.00% of the
original pool balance, the subordinate bonds do not receive any
principal and all principal is then paid to the senior bonds. The
subordinate bonds benefit from a floor as well. 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 0.75% of the original pool balance, those tranches that
are junior to it do not receive principal distributions. The
principal those tranches would have received is directed to pay
more senior subordinate bonds pro-rata.

In addition, until the aggregate class principal amount of the
senior certificates (other than the interest only certificates) is
reduced to zero, if on any distribution date, the aggregate
subordinate percentage for such distribution date drops below 6.00%
of current pool balance, the senior distribution amount will
include all principal collections and the subordinate principal
distribution amount will be zero.

Transaction Structure

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

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

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

The Class A-11 Certificates will have a pass-through rate that will
vary directly with the rate of one-month LIBOR and the Class A-11-X
Certificates will have a pass-through rate that will vary inversely
with the rate of one-month LIBOR. If the securities administrator
notifies the depositor 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 selected for purposes of calculating
the pass-through rate on the class A-11 certificates.

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.


LCM XXII LTD: S&P Affirms 'BB (sf)' Rating to Class D-R Notes
-------------------------------------------------------------
S&P Global Ratings assigned its rating to the class A-1-R
replacement note from LCM XXII Ltd., a collateralized loan
obligation (CLO) originally issued in 2016 and partially refinanced
in November 2018 that is managed by LCM Asset Management. At the
same time, S&P withdrew its rating on the original class A-1 note
following its payment in full on the Oct. 21, 2019, refinancing
date, and it affirmed its ratings on the class X-R, A-2-R, B-R,
C-R, and D-R notes.

On the Oct. 21, 2019, refinancing date, the proceeds from the class
A-1-R replacement note issuance was used to redeem the original
class A-1 note as outlined in the transaction document provisions.
Therefore, S&P withdrew its rating on the original note in line
with its full redemption, and it assigned a rating to the
replacement note.

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 and affirmed ratings reflect S&P's view that the
credit support available is commensurate with the associated rating
levels.

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 take rating actions as it deems
necessary.

  RATING ASSIGNED
  LCM XXII Ltd.

  Replacement class     Rating        Amount (mil $)
  A-1-R                 AAA (sf)              277.20

  RATING WITHDRAWN
  LCM XXII Ltd.

                             Rating
  Original class        To              From
  A-1                   NR              AAA (sf)

  RATINGS AFFIRMED
  LCM XXII Ltd.

  Class                 Rating
  X-R                   AAA (sf)
  A-2-R                 AA (sf)
  B-R                   A (sf)
  C-R                   BBB (sf)
  D-R                   BB (sf)


LENDMARK FUNDING 2019-2: S&P Assigns Prelim 'BB' Rating to D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Lendmark
Funding Trust 2019-2's personal consumer loan-backed notes.

The note issuance is an ABS transaction backed by personal consumer
loan receivables.

The preliminary ratings are based on information as of Oct. 21,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The availability of approximately 47.9%, 42.2%, 36.2%, and
31.2% credit support to the class A, B, C, and D notes,
respectively, in the form of subordination, overcollateralization,
a reserve account, and excess spread. These credit support levels
are sufficient to withstand stresses commensurate with the notes'
preliminary ratings, based on S&P's stressed cash flow scenarios.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal, its ratings on the class A, B, C,
and D notes will remain within two rating categories of the
assigned preliminary 'A (sf)', 'A- (sf)', 'BBB- (sf)', and 'BB
(sf)' ratings, respectively, in the next 12 months, based on its
credit stability criteria.

-- The timely interest and full principal payments expected to be
made under stressed cash flow modeling scenarios appropriate to the
assigned preliminary ratings.

-- The characteristics of the pool being securitized and the
receivables expected to be purchased during the revolving period.

-- The operational risks associated with Lendmark Financial
Services LLC's decentralized business model.

-- The transaction's payment and legal structures.

  PRELIMINARY RATINGS ASSIGNED
  Lendmark Funding Trust 2019-2

  Class       Rating       Amount (mil. $)(i)
  A           A (sf)                  278.900
  B           A- (sf)                  21.570
  C           BBB- (sf)                27.420
  D           BB (sf)                  22.660

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


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

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

The complete rating actions are as follows:

Issuer: Mello Warehouse Securitization Trust 2019-2

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa2 (sf)

Cl. C, Definitive Rating Assigned A2 (sf)

Cl. D, Definitive Rating Assigned Baa2 (sf)

Cl. E, Definitive Rating Assigned 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. 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 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.


NRZ ADVANCE 2019-T5: S&P Assigns Prelim BB(sf) Rating to E-T5 Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to NRZ Advance
Receivables Trust 2015-ON1's advance receivables-backed notes
series 2019-T5.

The note issuance is a servicer advance transaction backed by
servicer advance reimbursements and accrued and unpaid servicing
fees.

The preliminary ratings are based on information as of Oct. 24,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary 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 preliminary ratings; and

-- The transaction's sequential turbo payment structure that
applies during any full amortization period.

  PRELIMINARY RATINGS ASSIGNED
  NRZ Advance Receivables Trust 2015-ON1 (Series 2019-T5)

  Class       Rating          Amount ($)
  A-T5        AAA (sf)       249,877,000
  B-T5        AA (sf)          9,261,000
  C-T5        A (sf)          10,028,000
  D-T5        BBB (sf)        26,655,000
  E-T5        BB (sf)          4,179,000


PRIMA CAPITAL 2019-VII: Moody's Assigns B3 Rating on Cl. D Debt
---------------------------------------------------------------
Moody's Investors Service assigned ratings to four classes of notes
issued by Prima Capital CRE Securitization 2019-VII Ltd.:

Moody's rating action is as follows:

Cl. A, Assigned Aaa (sf)

Cl. B, Assigned Aa3 (sf)

Cl. C, Assigned Baa3 (sf)

Cl. D, Assigned B3 (sf)

The Cl. A, B, C, and D notes are referred to herein as the "Rated
Notes."

RATINGS RATIONALE

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

Prima Capital CRE Securitization 2019-VII Ltd. is a cash flow
commercial real estate CLO ("CRE CLO") that does not have a
reinvestment option; and 100% of the assets are identified and
closed as of the transaction closing date. The closing date pool is
collateralized by 20 collateral interests (17 obligors) in the form
of: i) single asset/single borrower commercial real estate bonds
(CMBS), primarily secured by office and multifamily properties
(50.7% of the initial pool balance); ii) whole loans on commercial
real estate, secured by industrial and multifamily properties
(34.1%); iii) real estate investment trust (REIT) bonds, primarily
backed by retail properties (7.8%); and iv) mezzanine interests in
commercial real estate, secured by industrial properties (7.4%).
Approximately 24.4% of the collateral assets are currently rated by
Moody's and the other 75.6% of the collateral assets were provided
an assessment of credit. The total closing date par amount is
$283,361,165. The closing date portfolio consists of 56.3% fixed
rate obligations with a 4.11% weighted average coupon. There are
six floating rate assets (43.7% of the portfolio balance) with a
weighted average spread of 2.24% over 1-month LIBOR.

The transaction closed on October 22, 2019.

PMIT Master Fund, LLC is the collateral seller of all the assets in
the pool. Prima Capital Advisors LLC will act as trust advisor
pursuant to the indenture and will perform certain reporting duties
for the benefit of the noteholders. As the transaction is static,
unscheduled principal payments and sale proceeds of credit risk and
defaulted assets will be used to pay down the notes per the
transaction waterfall.

The transaction incorporates a par coverage test which, if
triggered, diverts interest proceeds to pay down the notes in order
of seniority.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CLO transactions: weighted average
rating factor (WARF), a primary measure of credit quality with
credit assessments completed for all of the collateral, weighted
average life (WAL), weighted average recovery rate (WARR), number
of asset obligors; and pair-wise asset correlation. These
parameters are typically modeled as actual parameters for static
deals and as covenants for managed deals.

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

Par amount: $283,361,165

Number of obligors: 17

Weighted Average Rating Factor (WARF): 2663

Weighted Average Recovery Rate (WARR): 39.7%

Weighted Average Life (WAL): 6.1 years

Weighted Average Spread (WAS): 2.2%

Weighted Average Coupon (WAC): 4.1%

Pair-wise asset correlation: 32.5%

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's
Approach to Rating SF CDOs" published in March 2019.

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

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

Together with the set of modeling assumptions, Moody's conducted an
additional sensitivity analysis, which was a component in
determining the ratings assigned to the Rated Notes. This
sensitivity analysis includes increased default probability
relative to the base-case.

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment. Commercial real estate
property values are continuing to move in a positive direction
along with a rise in investment activity and stabilization in core
property type performance. Limited new construction, moderate job
growth and the decreased cost of debt and equity capital have aided
this improvement.


PSMC TRUST 2019-2: Fitch Rates Class B-5 Debt 'Bsf'
---------------------------------------------------
Fitch Ratings assigned final ratings to American International
Group, Inc.'s (AIG) PSMC 2019-2 Trust (PSMC 2019-2).

RATING ACTIONS

PSMC 2019-2 Trust

Class A-1;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-10;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-11;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-12;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-13;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-14;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-15;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-16;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-17;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-18;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-19;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-2;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-20;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-21;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-22;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-23;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-24;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-25;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-26;  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-5;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-6;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-7;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-8;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-9;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X1;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X10; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X11; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X2;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X3;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X4;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X5;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X6;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X7;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X8;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-X9;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class B-1;L  LT AAsf New Rating;   previously at AA(EXP)sf

Class B-2;   LT Asf New Rating;   previously at A(EXP)sf

Class B-3;   LT BBBsf New Rating; previously at BBB(EXP)sf

Class B-4;   LT BBsf New Rating;  previously at BB(EXP)sf

Class B-5;   LT Bsf New Rating;   previously at B(EXP)sf

Class B-6;   LT NRsf New Rating;  previously at NR(EXP)sf

TRANSACTION SUMMARY

The notes are supported by one collateral group that consists of
568 prime fixed-rate mortgages (FRMs) acquired by subsidiaries of
AIG from various mortgage originators with a total balance of
approximately $397.10 million as of the cut-off date.

The 'AAAsf' rating on the class A notes reflects the 4.75%
subordination provided by the 1.90% class B-1, 1.00% class B-2,
1.10% class B-3, 0.35% class B-4, 0.20% class B-5 and 0.20% class
B-6 notes.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The pool consists of very
high-quality 30-year & 20-year fixed-rate fully amortizing Safe
Harbor Qualified Mortgage (SHQM) loans to borrowers with strong
credit profiles, relatively low leverage and large liquid reserves.
The loans are seasoned an average of four months. The pool has a
weighted average (WA) original FICO score of 776, which is
indicative of very high credit-quality borrowers. Approximately 85%
has an original FICO score above 750. In addition, the original WA
CLTV ratio of 71.9% represents substantial borrower equity in the
property and reduced default risk.

Low Operational Risk (Neutral): Operational risk is well controlled
for in this transaction. AIG has strong operational practices and
is assessed by Fitch as an 'Above Average' aggregator. AIG has
experienced senior management and staff, strong risk management and
corporate governance controls and a robust due diligence process.
Primary and master servicing will be performed by Cenlar, FSB
(RPS2/Stable) and Wells Fargo Bank, N.A. (RMS1-/Stable).

Third-Party Due Diligence Results (Positive): Third-party due
diligence was performed on 100% of loans in the transaction by
American Mortgage Consultants, Inc. (AMC) and Opus Capital Markets
Consultants LLC (Opus), respectively assessed as Acceptable - Tier
1 and Acceptable - Tier 2 by Fitch. The results of the review
identified no material exceptions. Credit exceptions (3.7% by loan
count) were supported by strong mitigating factors and compliance
exceptions due to TRID were primarily cured with subsequent
documentation. Fitch applied a credit for the high percentage of
loan level due diligence, which reduced the 'AAAsf' loss
expectation by 20 bps.

Top Tier Representation and Warranty Framework (Positive): The
loan-level representation, warranty and enforcement (RW&E)
framework is consistent with Tier I quality. Fitch reduced its loss
expectations by 18 bps at the 'AAAsf' rating category as a result
of the Tier 1 framework and the 'A' Fitch-rated counterparty
supporting the repurchase obligations of the RW&E providers.

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

CE Floor (Positive): To mitigate tail risk, which arises as the
pool seasons and fewer loans are outstanding, a subordination floor
of 1.25% of the original balance will be maintained for the
certificates. The floor is sufficient to protect against the seven
largest loans defaulting at Fitch's 'AAAsf' average loss severity
of 47.61%. Additionally, the stepdown tests do not allow principal
prepayments to subordinate bondholders in the first five years
following deal closing.

Geographic Concentration (Neutral): The pool is geographically
diverse, and, as a result, no geographic concentration penalty was
applied. Approximately 45% of the pool is located in California,
which is in line with other recent Fitch-rated transactions. The
top three Metropolitan Statistical Areas (MSAs) account for 33.5%
of the pool. The largest MSA concentration is in the San Francisco
MSA (16.9%), followed by the Los Angeles MSA (10.0%) and the
Seattle MSA (6.6%).

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 certificates.
Furthermore, the expenses to be paid from the trust are capped at
$300,000 per annum, which can be carried over each year, subject to
the cap until paid in full.

RATING SENSITIVITIESs

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%, 20% and 30%, in addition to the
model-projected 5.2%. 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'.


PSMC TRUST 2019-3: Fitch to Rate Class B-5 Debt 'B(EXP)'
--------------------------------------------------------
Fitch Ratings expects to rate American International Group, Inc.'s
(AIG) PSMC 2019-3 Trust.

RATING ACTIONS

PSMC 2019-3 Trust

Class A-1;   LT AAA(EXP)sf; Expected Rating

Class A-10;  LT AAA(EXP)sf; Expected Rating

Class A-11;  LT AAA(EXP)sf; Expected Rating

Class A-12;  LT AAA(EXP)sf; Expected Rating

Class A-13;  LT AAA(EXP)sf; Expected Rating

Class A-14;  LT AAA(EXP)sf; Expected Rating

Class A-15;  LT AAA(EXP)sf; Expected Rating

Class A-16;  LT AAA(EXP)sf; Expected Rating

Class A-17;  LT AAA(EXP)sf; Expected Rating

Class A-18;  LT AAA(EXP)sf; Expected Rating

Class A-19;  LT AAA(EXP)sf; Expected Rating

Class A-2;   LT AAA(EXP)sf; Expected Rating

Class A-20;  LT AAA(EXP)sf; Expected Rating

Class A-21;  LT AAA(EXP)sf; Expected Rating

Class A-22;  LT AAA(EXP)sf; Expected Rating

Class A-23;  LT AAA(EXP)sf; Expected Rating

Class A-24;  LT AAA(EXP)sf; Expected Rating

Class A-25;  LT AAA(EXP)sf; Expected Rating

Class A-26;  LT AAA(EXP)sf; Expected Rating

Class A-3;   LT AAA(EXP)sf; Expected Rating

Class A-4;   LT AAA(EXP)sf; Expected Rating

Class A-5;   LT AAA(EXP)sf; Expected Rating

Class A-6;   LT AAA(EXP)sf; Expected Rating

Class A-7;   LT AAA(EXP)sf; Expected Rating

Class A-8;   LT AAA(EXP)sf; Expected Rating

Class A-9;   LT AAA(EXP)sf; Expected Rating

Class A-X1;  LT AAA(EXP)sf; Expected Rating

Class A-X10; LT AAA(EXP)sf; Expected Rating

Class A-X11; LT AAA(EXP)sf; Expected Rating

Class A-X2;  LT AAA(EXP)sf; Expected Rating

Class A-X3;  LT AAA(EXP)sf; Expected Rating

Class A-X4;  LT AAA(EXP)sf; Expected Rating

Class A-X5;  LT AAA(EXP)sf; Expected Rating  

Class A-X6;  LT AAA(EXP)sf; Expected Rating  

Class A-X7;  LT AAA(EXP)sf; Expected Rating  

Class A-X8;  LT AAA(EXP)sf; Expected Rating  

Class A-X9;  LT AAA(EXP)sf; Expected Rating  

Class B-1;   LT AA(EXP)sf;  Expected Rating  

Class B-2;   LT A(EXP)sf;   Expected Rating  

Class B-3;   LT BBB(EXP)sf; Expected Rating  

Class B-4;   LT BB(EXP)sf;  Expected Rating  

Class B-5;   LT B(EXP)sf;   Expected Rating  

Class B-6;   LT NR(EXP)sf;  Expected Rating  

TRANSACTION SUMMARY

The notes are supported by one collateral group that consists of
414 prime fixed-rate mortgages (FRMs) acquired by subsidiaries of
AIG from various mortgage originators with a total balance of
approximately $298.61 million as of the cut-off date.

The 'AAAsf' rating on the class A notes reflects the 4.45%
subordination provided by the 1.70% class B-1, 1.15% class B-2,
0.85% class B-3, 0.35% class B-4, 0.15% class B-5 and 0.25% class
B-6 notes.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The pool consists of very
high-quality 30-year fixed-rate fully amortizing Safe Harbor
Qualified Mortgage (SHQM) loans to borrowers with strong credit
profiles, relatively low leverage, and large liquid reserves. The
loans are seasoned an average of three months. The pool has a
weighted average (WA) original FICO score of 777, which is
indicative of very high credit-quality borrowers. Approximately 88%
of the loans have a borrower with an original FICO score above 750.
In addition, the original WA CLTV ratio of 69.0% represents
substantial borrower equity in the property and reduced default
risk.

Low Operational Risk (Neutral): Operational risk is well controlled
for in this transaction. AIG has strong operational practices and
is an 'Above Average' aggregator. The aggregator has experienced
senior management and staff, strong risk management and corporate
governance controls, and a robust due diligence process. Primary
and master servicing functions will be performed by Cenlar FSB and
Wells Fargo Bank, N.A., rated 'RPS2'/Stable and 'RMS1-'/Stable,
respectively.

Third-Party Due Diligence Results (Positive): Third-party due
diligence was performed on 100% of loans in the transaction by AMC
Diligence, LLC (AMC) and Opus Capital Markets Consultants LLC
(Opus), respectively assessed as Acceptable - Tier 1 and Acceptable
- Tier 2 by Fitch. The results of the review identified no material
exceptions. Credit exceptions were supported by strong mitigating
factors and compliance exceptions were primarily TRID related and
cured with subsequent documentation. Fitch applied a credit for the
high percentage of loan level due diligence, which reduced the
'AAAsf' loss expectation by 18 bps.

Top Tier Representation and Warranty Framework (Positive): The
loan-level representation, warranty and enforcement (RW&E)
framework is consistent with Tier I quality. Fitch reduced its loss
expectations by 16 bps at the 'AAAsf' rating category as a result
of the Tier 1 framework and the 'A' Fitch-rated counterparty
supporting the repurchase obligations of the RW&E providers.

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

CE Floor (Positive): To mitigate tail risk, which arises as the
pool seasons and fewer loans are outstanding, a subordination floor
of 1.25% of the original balance will be maintained for the
certificates. The floor is sufficient to protect against the seven
largest loans defaulting at Fitch's 'AAAsf' average loss severity
of 40.83%. Additionally, the stepdown tests do not allow principal
prepayments to subordinate bondholders in the first five years
following deal closing.

Geographic Concentration (Neutral): The pool is geographically
diverse and as a result, no geographic concentration penalty was
applied. Approximately 42% of the pool is located in California,
which is in line with other recent Fitch-rated transactions. The
top three Metropolitan Statistical Areas (MSAs) account for 32.7%
of the pool. The largest MSA concentration is in the San Francisco
MSA (15.0%), followed by the Los Angeles MSA (11.5%) and the
Seattle MSA (6.2%).

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 certificates.
Furthermore, the expenses to be paid from the trust are capped at
$300,000 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 metropolitan statistical area (MSA) and
national levels. The implied rating sensitivities are only an
indication of some of the potential outcomes and do not consider
other risk factors that the transaction may become exposed to or be
considered in the surveillance of the transaction.

Fitch conducted sensitivity analysis determining how the ratings
would react to steeper MVDs at the national level. The analysis
assumes MVDs of 10%, 20% and 30%, in addition to the
model-projected 5.0%. The analysis indicates there is some
potential rating migration with higher MVDs, compared with the
model projection.

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC Diligence, LLC (AMC) and Opus Capital Markets
Consultants, LLC (Opus). The third-party due diligence described in
Form 15E focused on credit, compliance and valuation. Fitch
considered this information in its analysis and it did not have an
effect on Fitch's analysis or conclusions. Fitch believes the
overall results of the review generally reflected strong
underwriting controls.



REPUBLIC FINANCE 2019-A: DBRS Finalizes BB Rating on Class C Notes
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
asset-backed notes issued by Republic Finance Issuance Trust
2019-A:

-- $238,430,000 Class A Notes at A (sf)
-- $21,940,000 Class B Notes at BBB (sf)
-- $14,630,000 Class C Notes at BB (sf)

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

-- Transaction capital structure, current 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.

-- Republic Finance, LLC's (Republic or the Company) capabilities
with regard to originations, underwriting and servicing.

-- DBRS Morningstar performed an operational review of Republic
and considers the entity to be an acceptable originator and
servicer of personal loans with an acceptable backup servicer.

-- Republic's senior management team has considerable experience
and a successful track record within the consumer loan industry.

-- Acquisition of a majority stake in the Company by CVC Capital
Partners (CVC) in December 2017. CVC has since implemented a growth
strategy that includes increasing the number of branches,
centralizing the underwriting and servicing functions and building
an online presence.

-- In April 2019, Republic completed the implementation of
centralized underwriting policies and processes for all branches,
which led to the ability to create a hybrid servicing model. The
Company is in the process of building up staffing levels at a new
fully centralized collections center in Charlotte, North Carolina.

-- Wells Fargo Bank, N.A. (rated AA with a Stable trend by DBRS
Morningstar) will serve as backup servicer. This transaction
includes an additional Early Amortization Event that addresses a
data mapping failure. This early amortization will occur if the
backup servicer has not completed the data mapping within 60 days
of closing.

-- The credit quality of the collateral and performance of
Republic's consumer loan portfolio. DBRS Morningstar used a hybrid
approach in analyzing the Republic portfolio that incorporates
elements of static pool analysis, employed for assets such as
consumer loans, and revolving asset analysis, employed for assets
such as credit card master trusts.

-- The legal structure and presence of legal opinions that will
address the true sale of the assets from the Seller to the
Depositor, the non-consolidation of the special-purpose vehicle
with the Seller, that the Indenture Trustee has a valid
first-priority security interest in the assets and that it is
consistent with DBRS Morningstar's "Legal Criteria for U.S.
Structured Finance."

Credit enhancement in the transaction consists of over
collateralization, subordination, excess spread and a reserve
account. The rating on the Class A Notes reflects the 19.50% of
initial hard credit enhancement provided by the subordinated notes
in the pool, the reserve account (1.00%) and overcollateralization
(6.00%). The ratings on the Class B Notes and the Class C Notes
reflect 12.00% and 7.00% 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.


RITE AID 1999-1: Moody's Lowers Class A-2 Certs Rating to Caa1
--------------------------------------------------------------
Moody's Investors Service downgraded the rating of Rite Aid
Pass-Through Trust Certificates, Series 1999-1 as follows:

Class A-2, Downgraded to Caa1; previously on Oct 16, 2018
Downgraded to B3

RATINGS RATIONALE

The rating for this CTL lease transaction Class A-2 was downgraded
primarily due to the downgrade of Rite Aid Corporation senior
unsecured notes to Caa3 from Caa2. Additional consideration is
given to the support provided by a residual value insurance policy
issued by a rated entity and the value of the real estate
collateral relative to the outstanding loan balance. The
transaction balance has decreased approximately 61% since
securitization.

On October 18, 2019 Rite Aid Corporation guaranteed senior
unsecured notes were downgraded to Caa2 from Caa1 and senior
unsecured notes were downgraded to Caa3 from Caa2.

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

The ratings of Credit Tenant Lease deals are primarily based on the
senior unsecured debt rating (or the corporate family rating) of
the tenants leasing the real estate collateral supporting the
bonds. Other factors that are also considered are Moody's dark
value of the collateral (value based on the property being vacant
or dark), which is used to determine a recovery rate upon a loan's
default and the rating of the residual insurance provider, if
applicable. Factors that may cause an upgrade of the ratings
include an upgrade in the rating of the corporate tenant or
significant loan paydowns or amortization which results in a lower
loan to dark value ratio. Factors that may cause a downgrade of the
ratings include a downgrade in the rating of the corporate tenant
or the residual insurance provider.

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in this rating was "Moody's Approach
to Rating Credit Tenant Lease and Comparable Lease Financings,"
published in November 2018.

DEAL PERFORMANCE

As of the October 2, 2019 distribution date, the transaction's
aggregate Certificate balance has decreased by approximately 61% to
$65.7 million from $167.6 million at securitization.

The Class A-1 certificate with the original balance of $75 million
has paid off in full. The remaining Class A-2 balance has decreased
by 29% to $65.7 million from $92.6 million at securitization and
will have a balloon payment of $54 million that is protected by
residual insurance.

This credit-tenant lease transaction is supported by a mortgage on
a portfolio of 53 drug stores with a total of 841,411 square feet
located in 14 states and the District of Columbia. Each property is
subject to a fully bondable, triple net lease guaranteed by Rite
Aid Corporation.

Residual insurance covers 51 of the 53 properties and is provided
by Hartford Fire Insurance Company (Moody's insurance financial
strength rating of A1; stable outlook) of The Hartford Financial
Services Group (Moody's senior unsecured debt rating of Baa1;
stable outlook). The two properties not covered by the residual
insurance secure loans that fully amortize by the lease expiration.


SEQUOIA MORTGAGE 2019-4: Fitch Gives BB-sf Rating on Cl. B-4 Certs
------------------------------------------------------------------
Fitch Ratings assigned ratings to the residential mortgage-backed
certificates issued by Sequoia Mortgage Trust 2019-4.

SEMT 2019-4

                Current Rating        Prior Rating

Class A-1;    LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-10;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-11;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-12;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-13;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-14;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-15;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-16;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-17;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-18;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-19;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-2;    LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-20;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-21;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-22;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-23;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-24;   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-5;    LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-6;    LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-7;    LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-8;    LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-9;    LT AAAsf New Rating; previously at AAA(EXP)sf

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

Class A-IO1;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO10; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO11; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO12; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO13; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO14; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO15; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO16; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO17; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO18; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO19; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO2;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO20; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO21; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO22; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO23; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO24; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO25; LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO3;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO4;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO5;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO6;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO7;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO8;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-IO9;  LT AAAsf New Rating; previously at AAA(EXP)sf

Class B-1;    LT AAsf New Rating;  previously at AA(EXP)sf

Class B-2;    LT Asf New Rating;   previously at A(EXP)sf

Class B-3;    LT BBBsf New Rating; previously at BBB(EXP)sf

Class B-4;    LT BB-sf New Rating; previously at BB-(EXP)sf

Class B-5;    LT NRsf New Rating;  previously at NR(EXP)sf

TRANSACTION SUMMARY

The certificates are supported by 506 loans with a total balance of
approximately $359.63 million as of the closing date. The pool
consists of prime fixed-rate mortgages (FRMs) acquired by Redwood
Residential Acquisition Corp (Redwood) from various mortgage
originators. Distributions of principal and interest and loss
allocations are based on a senior-subordinate, shifting-interest
structure.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The pool consists of very
high-quality 30, 25 and 20-year fixed-rate fully amortizing loans
to borrowers with strong credit profiles, relatively low leverage,
and large liquid reserves. The pool has a weighted average (WA)
original model FICO score of 769, and an original WA CLTV ratio of
72%. Over 99% of the pool consists of Safe Harbor Qualifed Mortgage
(SHQM) and less than 1% was originated prior to the
Ability-to-Repay rule, but underwritten consistent with the QM
definition.

Interest Reduction Risk (Negative): The transaction incorporates a
structural feature unique to Redwood's program for loans more than
120 days delinquent (a Stop Advance Loan). Unpaid interest on Stop
Advance Loans reduces the amount of interest that is contractually
due to bondholders in reverse sequential order. While this feature
helps limit cash flow leakage to subordinate bonds, it can result
in interest reductions to rated bonds in high stress scenarios.

Prioritization of Principal Payments (Positive): The limited
advancing leads to lower loss severities than a full advancing
structure. The unique Stop Advance structural feature reduces
interest payments to subordinate bonds but allows for greater
principal recovery than a traditional structure. Further, while
traditional structures determine senior principal distributions by
comparing the senior bond size with the collateral balance, this
transaction structure compares the senior balance with the
collateral balance less any Stop Advance loans. In a period of
increased delinquencies, this will result in a larger amount of
principal paid to the senior bonds relative to a traditional
structure.

Above-Average Aggregator (Neutral): Fitch has completed numerous
operational assessments of Redwood and considers the company to be
an 'above-average' aggregator. Redwood's well-established
acquisition strategy is reflected in the very strong performance of
the post-crisis Sequoia pools.

Third-Party Due Diligence Results (Positive): Third-party due
diligence was performed on 94% of loans in the transaction by
Clayton Services (assessed as Acceptable - Tier 1 by Fitch). The
remaining 6% of loans received a limited review. The results of the
review indicated sound operational controls and strong
manufacturing quality. Credit exceptions were supported by strong
mitigating factors and compliance exceptions were primarily cured
with subsequent documentation. Fitch applied a credit for the high
percentage of loan level due diligence, which reduced the 'AAAsf'
loss expectation by 18 bps.

Top Tier Representation and Warranty Framework (Neutral): The
loan-level representation, warranty and enforcement (RW&E)
framework is consistent with Fitch's Tier 1, the highest possible.
Fitch applied a neutral treatment at the 'AAAsf' rating category as
a result of the Tier 1 framework and the internal credit opinion
supporting the repurchase obligations of the ultimate R&W
backstop.

Credit Enhancement Floor (Positive): To mitigate tail risk, which
arises as the pool seasons and fewer loans are outstanding, a
subordination floor of 1.30% of the original balance will be
maintained for the certificates. The floor is more than sufficient
to protect against the five largest loans defaulting at Fitch's
'AAAsf' average loss severity of 41.03%.

RATING SENSITIVITIES

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

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10%, 20% and 30%, in addition to the
model-projected 6.5%. As shown in the table included in the presale
report, the analysis indicates that some potential rating migration
exists with higher MVDs compared with the model projection.

Additionally, 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'. The percentage points in
the related presale report reflect the additional MVDs that would
have to occur to affect ratings for each defined sensitivity for
this transaction.


SIERRA TIMESHARE 2019-3: Fitch Assigns BBsf Rating on Cl. D Notes
-----------------------------------------------------------------
Fitch Ratings assigned ratings and Rating Outlooks to notes issued
by Sierra Timeshare 2019-3 Receivables Funding LLC.

Sierra Timeshare 2019-3 Receivables Funding LLC

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

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

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

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

KEY RATING DRIVERS

Borrower Risk - Stable Collateral Quality: Approximately 72.8% of
Sierra 2019-3 consists of Wyndham Vacation Resorts, Inc (WVRI)
originated loans; the remainder are Wyndham Resort Development
Corporation (WRDC) loans. Fitch has determined that, on a
like-for-like FICO basis, WRDC's receivables perform better than
WVRI's. The weighted average original FICO score of the pool is
724. Overall, the 2019-3 pool shows a marginal decrease in WRDC
loans and moderate shift downward in the FICO band concentrations
for the WVRI platform relative to the 2019-2 transaction.

Forward-Looking Approach on CGD Proxy - Stabilizing CGD
Performance: Similar to other timeshare originators, Wyndham
Destinations' delinquency and default performance exhibited notable
increases in the 2007-2008 vintages, stabilizing in 2009 and
thereafter. However, more recent vintages, from 2014-2016, have
begun to show increasing gross defaults versus vintages back to
2009, partially driven by increased paid product exits. Fitch's
cumulative gross default (CGD) proxy for this pool is 19.45%
(slightly higher than 19.40% from 2019-2). Furthermore, given the
expected stable economic conditions, no adjustments were made to
Fitch's CGD proxy.

Structural Analysis - Lower CE Structure: Initial hard credit
enhancement (CE) is expected to be 61.30%, 34.75%, 13.25% and 4.50%
for class A, B, C and D notes, respectively, decreased for class A,
B and C, and unchanged for class D from 2019-2. Hard CE comprises
overcollateralization, a reserve account and subordination. Soft CE
is also provided by excess spread and is expected to be 10.66% per
annum. Loss coverage for all notes are able to support default
multiples of 3.50x, 2.50x, 1.75x and 1.25x for 'AAAsf', 'Asf',
'BBBsf' and 'BBsf', respectively.

Originator/Seller/Servicer Operational Review - Quality of
Origination/Servicing: Wyndham Destinations has demonstrated
sufficient abilities as an originator and servicer of timeshare
loans. This is evidenced by the historical delinquency and loss
performance of securitized trusts and of the managed portfolio.

Legal Structure Integrity: The legal structure of the transaction
should provide that a bankruptcy of Wyndham Destinations and
Wyndham Consumer Finance, Inc. (WCF) would not impair the
timeliness of payments on the securities.

RATING SENSITIVITIES

Unanticipated increases in the frequency of defaults could produce
CGD levels higher than the base case and would likely result in
declines of CE and remaining default coverage levels available to
the notes. Additionally, unanticipated increases in prepayment
activity could also result in a decline in coverage. Decreased
default coverage may make certain notes' ratings susceptible to
potential negative rating actions, depending on the extent of the
decline in coverage.

Fitch conducts sensitivity analysis by stressing a transaction's
initial base case CGD to the level required to reduce each rating
by one full category, to non-investment grade (BBsf) and to
'CCCsf'. Fitch also stresses base prepayment assumptions by 1.5x
and 2.0x and examines the rating implications on all classes of
issued notes. The 1.5x and 2.0x increases of the prepayment
assumptions represent moderate and severe stresses, respectively,
and are intended to provide an indication of the rating sensitivity
of notes to unexpected deterioration of a trust's performance.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Deloitte & Touche LLP. The third-party due diligence
described in Form 15E focused on a comparison and recalculation of
certain attributes with respect to 150 loans. Fitch considered this
information in its analysis, and it did not have an effect on
Fitch's analysis or conclusions.


SIERRA TIMESHARE 2019-3: S&P Rates $26.78MM Class D Notes 'BB (sf)'
-------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Sierra Timeshare 2019-3
Receivables Funding LLC's asset-backed notes.

The note issuance is asset-backed securities (ABS) transaction
backed by vacation ownership interval (timeshare) loans.

"The ratings reflect our opinion of the credit enhancement
available in the form of subordination, overcollateralization, a
reserve account, and available excess spread. Our ratings also
reflect our view of Wyndham Consumer Finance Inc.'s servicing
ability and experience in the timeshare market," S&P said.

  RATINGS ASSIGNED

  Sierra Timeshare 2019-3 Receivables Funding LLC

  Class      Rating     Amount (mil. $)
  A          AAA (sf)            126.13
  B          A (sf)               81.28
  C          BBB (sf)             65.82
  D          BB (sf)              26.78


THL CREDIT 2017-1: Moody's Affirms $27MM Cl. E Notes at Ba3(sf)
---------------------------------------------------------------
Moody's Investors Service assigned a rating to one class of CLO
refinancing notes issued by THL Credit Wind River 2017-1 CLO Ltd.

Moody's rating action is as follows:

US$390,000,000 Class A-R Senior Secured Floating Rate Notes Due
2029 (the "Class A-R Notes"), Assigned Aaa (sf)

Additionally, Moody's has affirmed the ratings on the following
outstanding notes issued on March 16, 2017 (the "Original Closing
Date"):

US$66,000,000 Class B Senior Secured Floating Rate Notes Due 2029
(the "Class B Notes"), Affirmed Aa2 (sf); previously on March 16,
2017 Definitive Rating Assigned Aa2 (sf)

US$36,000,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes Due 2029 (the "Class C Notes"), Affirmed A2 (sf); previously
on March 16, 2017 Definitive Rating Assigned A2 (sf)

US$33,000,000 Class D Mezzanine Secured Deferrable Floating Rate
Notes Due 2029 (the "Class D Notes"), Affirmed Baa3 (sf);
previously on March 16, 2017 Definitive Rating Assigned Baa3 (sf)

US$27,000,000 Class E Junior Secured Deferrable Floating Rate Notes
Due 2029 (the "Class E Notes"), Affirmed Ba3 (sf); previously on
March 16, 2017 Definitive Rating Assigned Ba3 (sf)

RATINGS RATIONALE

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

The Issuer is a managed cash flow collateralized loan obligation
(CLO). The issued notes are collateralized primarily by a portfolio
of broadly syndicated senior secured corporate loans. At least 90%
of the portfolio must consist of senior secured loans and eligible
investments, and up to 10% of the portfolio may consist of second
liens loans and unsecured loans.

THL Credit Advisors 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 remaining one year and a half reinvestment period.
Thereafter, subject to certain restrictions, the Manager may
reinvest unscheduled principal payments and proceeds from sales of
credit risk assets.

The Issuer has issued the Refinancing Notes on October 18, 2019 in
connection with the refinancing of one class of secured notes
originally issued on the Original Closing Date. On the Refinancing
Date, the Issuer used the proceeds from the issuance of the
Refinancing Notes to redeem in full the Refinanced Original Notes.
On the Original Closing Date, the issuer also issued four classes
of other secured notes and one class of subordinated notes that
remain outstanding.

In addition to the issuance of the Refinancing Notes, a variety of
other changes to transaction features will occur in connection with
the refinancing. These include: extensions of the non-call period
and changes to certain collateral quality tests.

The rating affirmation actions on the Class B, Class C, Class D,
and Class E Notes take into consideration the issuance of the
Refinancing Notes, which increases excess spread available as
credit enhancement, as well as the changes to the transaction
features occurring in connection with the refinancing.

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

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

Performing par and principal proceeds balance: $600,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2870 (corresponding to a
weighted average default probability of 24.65%)

Weighted Average Spread (WAS): 3.30%

Weighted Average Recovery Rate (WARR): 47.50%

Weighted Average Life (WAL): 6.5 Years

Methodology Underlying the Rating Action:

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

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

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


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.

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.



TRIMARAN CAVU 2019-2: S&P Assigns Prelim BB- Rating to Cl. D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Trimaran
CAVU 2019-2 Ltd.'s floating-rate debt.

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 Trimaran
Advisors LLC, a subsidiary of LibreMax Intermediate Holdings L.P.
This is Trimaran Advisors LLC's second CLO in 2019, which will
bring its total CLO assets under management (AUM) to $3.9 billion.

The preliminary ratings are based on information as of Oct. 23,
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 debt through collateral selection, ongoing
portfolio management, and trading.

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

  PRELIMINARY RATINGS ASSIGNED
  Trimaran CAVU 2019-2 Ltd./Trimaran CAVU 2019-2 LLC

  Class                 Rating       Amount (mil. $)
  A-NA(i)               AAA (sf)               63.00
  A-L(i)                AA (sf)               300.00
  A-NB(i)               AA (sf)                12.00
  B                     A (sf)                 35.00
  C                     BBB- (sf)              30.00
  D                     BB- (sf)               17.50
  Subordinated notes    NR                     52.70

(i)The class A-N notes and class A-L loan are pari passu. However,
the class A-NA notes will be paid before the class A-NB notes.
NR--Not rated.


VERUS SECURITIZATION 2019-4: DBRS Gives Prov. B Rating on B2 Certs
------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following Mortgage
Pass-Through Certificates, Series 2019-4 (the Certificates) to be
issued by Verus Securitization Trust 2019-4 (Trust):

-- $454.2 million Class A-1 at AAA (sf)
-- $454.2 million Class A-1X at AAA (sf)
-- $454.2 million Class A-1B at AAA (sf)
-- $40.5 million Class A-2 at AA (sf)
-- $80.4 million Class A-3 at A (sf)
-- $50.1 million Class M-1 at BBB (sf)
-- $21.8 million Class B-1 at BB (sf)
-- $21.1 million Class B-2 at B (sf)

Class A-1X is an interest-only certificate. The class balance
represents a notional amount.

Class A-1B is an exchangeable certificate. This class can be
exchanged for combinations of exchange notes as specified in the
offering documents.

The AAA (sf) rating on the Class A-1 Certificates reflects 33.30%
of credit enhancement provided by subordinated Certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 27.35%, 15.55%, 8.00%, 5.00% and 1.65% 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, first-lien
residential mortgages funded by the issuance of the Certificates.
The Certificates are backed by 1,452 mortgage loans with a total
principal balance of $680,978,906 as of the Cut-Off Date (October
1, 2019).

The originators for the mortgage pool are Excelerate Capital
(14.5%), Sprout Mortgage (12.8%) and other originators, each
comprising less than 10.0% of the mortgage loans. The Servicers of
the loans are Specialized Loan Servicing LLC (5.7%) and Shellpoint
Mortgage Servicing (Shellpoint; 94.3%).

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's 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 Qualified Mortgage (QM)/ATR
rules, 80.5% of the loans are designated as non-QM, 0.6% as QM
Rebuttable Presumption and 0.5% as QM Safe Harbor. Approximately
18.4% 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-2, 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, the Administrator, at the Issuer's option, may redeem all
of the outstanding Certificates at a price equal to the class
balances of the related Certificates 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 Servicers (or Advancing Party for loans serviced by Shellpoint)
will fund advances of delinquent principal and interest on any
mortgage until such loan becomes 180 days delinquent. The Servicers
are 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 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-2.

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


VOYA CLO 2012-4: S&P Assigns Prelim B- (sf) Rating to E-R-R Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
X-R-R, A-1-a-R-R, A-1-b-R-R, A-2-A-R-R, A-2-B-R-R, B-R-R, C-1-R-R,
C-2-R-R, D-R-R, and E-R-R replacement notes from Voya CLO 2012-4
Ltd., a collateralized loan obligation (CLO) originally issued in
November 2012 that is managed by Voya Alternative Asset Management
LLC (see list). This is a proposed refinancing of its November 2012
transaction, which had been previously refinanced in September. The
replacement notes will be issued via a proposed supplemental
indenture.

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

The preliminary ratings are based on information as of Oct. 23,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Nov. 5, 2019, refinancing date, the proceeds from the
issuance of the replacement notes are expected to redeem the
original notes. At that time, S&P anticipates withdrawing the
ratings on the original notes and assigning ratings to the
replacement notes. However, if the refinancing doesn't occur, S&P
may affirm the ratings on the original notes and withdraw its
preliminary ratings on the replacement notes.

  PRELIMINARY RATINGS ASSIGNED
  Voya CLO 2012-4 Ltd./Voya CLO 2012-4 LLC

  Replacement class        Rating      Amount (mil. $)
  X-R-R                    AAA (sf)               4.00
  A-1-a-R-R                AAA (sf)             245.00
  A-1-b-R-R                AAA (sf)              15.00
  A-2-A-R-R                AA (sf)               27.90
  A-2-B-R-R                AA (sf)               16.50
  B-R-R (deferrable)       A (sf)                23.60
  C-1-R-R (deferrable)     BBB- (sf)             14.00
  C-2-R-R (deferrable)     BBB- (sf)             10.00
  D-R-R (deferrable)       BB- (sf)              15.00
  E-R-R (deferrable)       B- (sf)                3.32
  Income notes             NR                    42.75

  NR--Not rated.


WELLS FARGO 2019-C53: DBRS Gives Prov. B(low) Rating on KRR Certs
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-C53 (the
Certificates) to be issued by Wells Fargo Commercial Mortgage Trust
2019-C53:

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

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

The collateral consists of 58 fixed-rate loans secured by 85
commercial and multifamily properties. The transaction is a
sequential-pay pass-through structure. The conduit pool was
analyzed to determine the provisional ratings, reflecting the
long-term probability of a loan default within the term and its
liquidity at maturity. When the cut-off loan balances were measured
against the DBRS Morningstar Stabilized Net Cash Flow and their
respective actual constants, one loan — Smoke Tree Village and
Smoke Tree Commons, representing 1.5% of the pool — had a DBRS
Morningstar Issuance DSCR below 1.15 times (x), a threshold
indicative of a higher likelihood of mid-term default. The pool
additionally includes 25 loans comprising a combined 47.2% of the
pool balance with an issuance loan-to-value (LTV) ratio in excess
of 67 .1%, a threshold generally indicative of above-average
default frequency. The weighted-average (WA) DBRS Morningstar LTV
of the pool at issuance was 64.6%, and the pool is scheduled to
amortize down to a DBRS Morningstar WA LTV of 58.6% at maturity.

Only three loans, representing a combined 2.4% of the pool by
allocated loan balance, were assigned Average (-) property quality
scores, and only one property comprising 0.6% of the pool by
allocated loan balance was deemed to exhibit Below Average property
quality. Additionally, four loans comprising 18.7% of the pool by
allocated loan balance exhibited Average (+) property quality. Term
default risk is relatively low, as is evidenced by a relatively
strong WA DBRS Morningstar Issuance DSCR of 1.82x. Across the pool,
DBRS Morningstar Issuance DSCRs generally ranged from 1.14x to
4.35x and only nine loans comprising a combined 16.6% of the pool
by allocated loan balance exhibited a DBRS Morningstar Issuance
DSCR of less than 1.32x, a threshold generally associated with
above-average default frequency. Additionally, excluding
hospitality properties, 13 loans comprising 32.0% of the pool by
allocated loan balance exhibited a favorable DSCR in excess of
1.69x, a threshold generally associated with below-average default
frequency.

The pool has a relatively high concentration of loans secured by
office properties, as evidenced by eight loans, representing a
combined 25.2% of the pool by allocated loan balance) being secured
by such properties. DBRS Morningstar considers office properties to
be a riskier property type with above-average default frequency.
Two of the identified loans (comprising 22.4% of the pool's total
office composition) are secured by office properties located in
areas with a DBRS Morningstar market rank of 6, which are generally
characterized as urban locations. These markets generally benefit
from increased liquidity that is driven by consistently strong
investor demand and therefore tend to benefit from lower default
frequencies than less dense suburban, tertiary or rural markets.
The WA expected loss of the seven loans secured by office
properties is more than two times the WA expected loss of the
overall pool. As a result, the risk of these loans is reflected in
the credit enhancement levels of the pool.

The pool exhibits some leverage barbelling, as is evidenced by 26
loans comprising 48.5% of the pool by allocated loan balance having
DBRS Morningstar Issuance LTV ratios in excess of 67.1%, a
threshold historically indicative of relatively high-leverage
financing and generally associated with above-average default
frequency. Only four of the identified properties exhibited a DBRS
Morningstar Issuance DSCR of less than 1.32x, a threshold generally
associated with above-average default frequency. The three
identified loans with a DBRS Morningstar Issuance DSCR of less than
1.32x exhibited a WA expected loss of 9.2%, more than three times
the WA expected loss of the overall pool. As a result, the risk of
these loans is reflected in the credit enhancement levels of the
pool. The WA DBRS Morningstar Issuance DSCR exhibited by the 26
loans identified to represent relatively high-leverage financing
was 1.54x.

The pool has a relatively high concentration of loans secured by
non-traditional property types such as self-storage, hospitality,
data center and manufactured housing community (MHC) assets, which,
on a combined basis, represent 40.8% of the pool by allocated loan
balance across 30 loans. While not historically considered core
property types, CBMS loans secured by MHC and self-storage
properties have performed better than other property types over the
past two decades and are generally associated with below-average
default frequency.

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

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


WESTLAKE AUTOMOBILE 2019-3: S&P Rates Class F Notes 'B+(sf)'
------------------------------------------------------------
S&P Global Ratings assigned its ratings to Westlake Automobile
Receivables Trust 2019-3's automobile receivables-backed notes
series 2019-3.

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

The ratings reflect:

-- The availability of approximately 49.0%, 42.5%, 33.8%, 26.2%,
22.6%, and 18.9% credit support for the class A, B, C, D, E, and F
notes, respectively, based on stressed cash flow scenarios
(including excess spread). These provide approximately 3.50x,
3.00x, 2.30x, 1.75x, 1.58x, and 1.23x S&P's 13.00%-13.50% expected
cumulative net loss range, respectively.

-- The transaction's ability to make timely interest and principal
payments under stressed cash flow modeling scenarios appropriate
for the assigned ratings.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal and for the transaction's life, its
rating on the class A and B notes would not likely be lowered from
the assigned rating; the rating on the class C notes would likely
remain within one rating category of the assigned ratings; and the
rating on the class D notes would likely remain within two rating
categories of the assigned rating. S&P's ratings on the class E and
F notes would likely remain within two rating categories of the
assigned ratings during the first year but would ultimately default
under the rating agency's 'BBB' moderate stress scenario, which is
within the bounds of its credit stability criteria.

-- The collateral characteristics of the securitized pool of
subprime automobile loans.

-- The originator/servicer's long history in the
subprime/specialty auto finance business.

-- S&P's analysis of approximately 13 years (2006-2018) of static
pool data on the company's lending programs.

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

  RATINGS ASSIGNED
  Westlake Automobile Receivables Trust 2019-3

  Class         Rating       Amount (mil. $)
  A-1           A-1+ (sf)             277.50
  A-2           AAA (sf)              492.60
  B             AA (sf)               115.49
  C             A (sf)                150.46
  D             BBB (sf)              134.62
  E             BB+ (sf)               58.73
  F             B+ (sf)                70.60


WFRBS COMMERCIAL 2012-C6: Fitch Affirms Bsf Rating on Cl. F Certs
-----------------------------------------------------------------
Fitch Ratings affirmed nine classes of WFRBS Commercial Mortgage
Trust 2012-C6 commercial mortgage pass-through certificates series
2012-C6.

WFRBS 2012-C6

                      Current Rating      Prior Rating

Class A3 92936QAE8;  LT AAAsf Affirmed;  previously at AAAsf

Class A4 92936QAG3;  LT AAAsf Affirmed;  previously at AAAsf

Class AS 92936QBC1;  LT AAAsf Affirmed;  previously at AAAsf

Class B 92936QAJ7;   LT AAsf Affirmed;   previously at AAsf

Class C 92936QAQ1;   LT Asf Affirmed;    previously at Asf

Class D 92936QAS7;   LT BBB-sf Affirmed; previously at BBB-sf

Class E 92936QAU2;   LT BBsf Affirmed;   previously at BBsf

Class F 92936QAW8;   LT Bsf Affirmed;    previously at Bsf

Class X-A 92936QAL2; LT AAAsf Affirmed;  previously at AAAsf

KEY RATING DRIVERS

Stable Loss Expectations: Loss expectations have remained largely
stable since issuance. There are five Fitch Loans of Concern
totaling 6.6% of the pool, including two specially-serviced hotel
loans (4.0% of the pool), and two loans in the top 20, Commerce
Park IV &V (2.0%) and Montclair on the Park - Missouri (1.8%), both
of which have experienced declines in occupancy. However, the loss
expectations on these loans have largely stabilized or decreased
given occupancy and cash flow improvements resulting from property
improvements.

Increasing Credit Enhancement: The pool has paid down approximately
27.3% since issuance, which has resulted in an increase in credit
enhancement (CE). In addition, 11 loans totaling 15.0% of the pool
are currently defeased. This includes one additional loan, Boca
Industrial Park (3.6%), which has been defeased since the last
rating action.

Alternative Loss Scenarios: Fitch ran two additional sensitivity
tests in which it stressed its pool-level losses by increasing the
cap rates and NOI haircuts applied to all of remaining the loans in
the pool and a separate test wherein it modeled outsized losses of
75% and 30% on the Commerce Park IV & V and Montclair on the Park -
Missouri loans. These sensitivity tests were a factor in the upward
revision of Rating Outlooks.

Pool Concentration Factors: Approximately 31 loans in the pool,
totaling 39.8% of total balance are collateralized by retail
properties, reflecting only a modest increase from 34.7% at
issuance. However, none of the loans in the pool are secured by
regional malls. Additionally, concentrations in several property
types, such as lodging, self-storage and manufactured housing have
decreased given loan payoffs and defeasance.

RATING SENSITIVITIES

The Rating Outlook on class F has been revised to Stable from
Negative and the Rating Outlook on class B has been revised to
Positive from Stable. All other Rating Outlooks are maintained at
Stable. The revised outlooks are related to increased CE as a
result of additional paydown and defeasance since the last rating
action, as well as stable to improved performance from the
collateral securing the Fitch Loans of Concern (FLOCs). Notably,
the second largest FLOC, Montclair on the Park - Missouri (1.8%),
which has exhibited substantial improvements in occupancy and cash
flow as a result of property renovations. The largest FLOC,
Commerce Park IV & V loan (2.0%), has been transferred to special
servicing and exhibited continued underperformance, as was expected
at the last rating action. Upgrades are possible with continued
paydown, loan payoffs, defeasance, and performance improvements
from the FLOCs. Downgrades are possible with continued performance
declines from the FLOCs, most notably, Commerce Park IV & V or in
the event additional defaults occur.

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

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


WORLD OMNI 2018-1: Fitch Affirms BB Rating on Class E Debt
----------------------------------------------------------
As part of its ongoing surveillance, Fitch Ratings has taken
various rating actions on World Omni Select Auto Trust 2018-1.

World Omni Select Auto Trust 2018-1

Class A-2 98162DAC3; LT AAAsf Affirmed; previously at AAAsf

Class A-3 98162DAE9; LT AAAsf Affirmed; previously at AAAsf

Class B 98162DAG4;   LT AAAsf Upgrade;  previously at AAsf

Class C 98162DAJ8;   LT AAsf Upgrade;   previously at Asf

Class D 98162DAL3;   LT BBBsf Affirmed; previously at BBBsf

Class E 98162DAN9;   LT BBsf Affirmed;  previously at BBsf

KEY RATING DRIVERS

The rating actions are based on available credit enhancement (CE)
and cumulative net loss (CNL) performance to date. The collateral
pool continues to perform within Fitch's expectations and hard CE
is building for the notes. The securities are able to withstand
stress scenarios consistent with the recommended ratings and make
full payments to investors in accordance with the terms of the
documents. The Positive Outlooks on the applicable classes reflect
the possibility for an upgrade in the next one to two years.

As of the October 2019 distribution, 61+ day delinquencies were
1.82% of the remaining collateral balance, and CNL were at 1.87%,
tracking below Fitch's initial base case of 8.50%. Further, hard CE
has grown to 49.54% for class A notes, 41.42% for class B notes,
29.61% for class C notes, 20.75% for class D notes and 15.65% for
class E notes.

Based on transaction specific performance to date, Fitch revised
the lifetime CNL proxy to 7.50% from 8.50% at close. Under Fitch's
stressed cash flow assumptions, all notes are able to support loss
coverage multiples commensurate with their respective ratings.

RATING SENSITIVITIES

Unanticipated increases in the frequency of defaults and loss
severity could produce loss levels higher than the current
projected base case loss proxy and impact available loss coverage
and multiples levels for the transaction. Lower loss coverage could
impact ratings and Rating Outlooks, depending on the extent of the
decline in coverage.

To date, the transactions have exhibited consistent performance
with losses within Fitch's initial expectations, with rising loss
coverage and multiple levels consistent with the current ratings. A
material deterioration in performance would have to occur within
the asset pool to have potential negative impact on the outstanding
ratings.


                            *********

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 ***