/raid1/www/Hosts/bankrupt/TCR_Public/191201.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, December 1, 2019, Vol. 23, No. 334

                            Headlines

ACC TRUST 2019-2: Moody's Assigns B2 Rating on $23MM Cl. C Notes
AMERICA MERRILL 2013-C7: Moody's Cuts Class G Certs Rating to Caa1
BALLYROCK CLO 2019-2: Moody's Rates $18MM Class D Notes Ba3
BARCLAYS COMMERCIAL 2013-C6: Fitch Affirms Class F Certs at Bsf
BBCMS 2019-BWAY: Fitch Affirms BB-sf Rating $45.1MM Cl. E Certs

BBCMS MORTGAGE 2019-C5: Fitch Rates $9.6MM Cl. G-RR Certs B-sf
BEAR STEARNS 2007-PWR16: Moody's Affirms C Rating on 2 Tranches
BENCHMARK 2019-B14: Fitch Assigns B-sf Rating on Class G-RR Certs
BRAVO RESIDENTIAL 2019-NQM2: Fitch to Rate Cl. B-2 Debt 'B(EXP)'
CIM TRUST 2019-R5: Moody's Assigns (P)B3 Rating on Cl. B2 Notes

COBALT CMBS 2007-C3: Fitch Lowers Class B Certs Rating to CCsf
COMM 2013-CCRE8: Moody's Affirms B2 Rating on Class F Debt
COMM 2015-LC19: Fitch Affirms B-sf Rating on Class F Certs
CONN'S RECEIVABLES 2017-B: Fitch Hikes Class C Notes Rating to BBsf
CONN'S RECEIVABLES 2019-B: Fitch Assigns Bsf Rating on Cl. C Debt

CSFB MORTGAGE 2005-C3: Moody's Affirms Caa3 Rating on Cl. D Certs
FLAGSTAR MORTGAGE 2019-2: Fitch Assigns B Rating on Cl. B-5 Certs
GS MORTGAGE 2012-GC6: Fitch Affirms Bsf Rating on Class F Debt
GS MORTGAGE 2014-GC18: Fitch Cuts Rating on Class F Debt to CCsf
GSAA HOME 2005-8: Moody's Hikes Rating on Class M-1 Debt to B3(sf)

HERTZ VEHICLE 2019-3: Fitch Assigns BBsf Rating on Cl. D Notes
HORIZON AIRCRAFT I: Fitch Affirms BBsf Rating on Class C Debt
JAMESTOWN CLO XIV: Moody's Assigns Ba2 Rating on $14MM Cl. D Notes
JP MORGAN 2003-CIBC7: Moody's Affirms C Rating on Class J Certs
JP MORGAN 2007-CIBC20: Fitch Lowers Class E Certs Rating to CCsf

JP MORGAN 2012-C6: Fitch Affirms Bsf Rating on Class H Certs
JP MORGAN 2019-9: Moody's Assigns B3 Rating on 2 Debt Classes
JPMBB COMMERCIAL 2016-C1: Fitch Affirms B-sf Rating on Cl. F Certs
MORGAN STANELY 2007-IQ13: Fitch Affirms Dsf Rating on 12 Tranches
MORGAN STANLEY 2005-IQ10: Moody's Affirms C Rating on Cl. F Certs

MORGAN STANLEY 2015-C21: Fitch Affirms B- Rating on Class F Certs
MORGAN STANLEY 2018-MP: Moody's Affirms Ba3 Rating on Cl. E Certs
MORGAN STANLEY 2019-L3: Fitch Assigns B-sf Rating on 2 Tranches
MORGAN STANLEY 2019-MEAD: Moody's Assigns Ba2 Rating on Cl. E Certs
NATIONSTAR HECM 2019-2: Moody's Assigns B3 Rating on Cl. M4 Certs

NEW RESIDENTIAL 2019-6: Moody's Gives (P)Ba3 Rating on 4 Tranches
PALISADES CENTER 2016-PLSD: Moody's Cuts Cl. D Certs Rating to Ba3
SECURITIZED TERM 2019-CRT: Moody's Rates $27.7MM Class D Notes Ba1
SEQUOIA MORTGAGE 2019-5: Fitch Assigns BB- Rating on Cl. B-4 Certs
TERWIN MORTGAGE 2005-5SL: Moody's Hikes Cl. M-3 Debt Rating to Ba1

TESLA AUTO 2019-A: Moody's Assigns Ba3 Rating on $38MM Cl. E Notes
TOWD POINT 2019-SJ3: Fitch to Rate 3 Tranches 'B(EXP)'
UBS COMMERCIAL 2017-C7: Fitch Affirms Class G-RR Certs at B-sf
UBS COMMERCIAL 2018-C15: Fitch Affirms B- Rating on Cl. G-RR Certs
UBS-BARCLAYS 2013-C5: Fitch Lowers Class F Debt Rating to CCC

WAMU COMMERCIAL 2006-SL1: Fitch Affirms CCsf Rating on Cl. F Certs
WELLS FARGO 2015-C26: Fitch Affirms BBsf Rating on 2 Tranches
WELLS FARGO 2016-C37: Fitch Affirms B-sf Rating on 2 Tranches
WELLS FARGO 2019-4: Fitch Rates Class B-4 Certs 'BB-sf'
[*] Moody's Takes Action on $929.8MM RMBS Issued 2003-2007


                            *********

ACC TRUST 2019-2: Moody's Assigns B2 Rating on $23MM Cl. C Notes
----------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to the notes
issued by ACC Trust 2019-2. This is the second auto lease
transaction of the year and the third overall for RAC King, LLC
(not rated). The notes are backed by a pool of closed-end retail
automobile leases originated by RAC King, LLC. RAC Servicer, LLC is
the servicer and administrator for this transaction.

The complete rating actions are as follows:

Issuer: ACC Trust 2019-2

US$167,646,000, 2.82%, Class A Notes, Definitive Rating Assigned
Baa2 (sf)

US$37,066,000, 3.63%, Class B Notes, Definitive Rating Assigned
Baa3 (sf)

US$23,485,000, 5.24%, Class C Notes, Definitive Rating Assigned B2
(sf)

RATINGS RATIONALE

The ratings are based on the quality of the underlying collateral
and its expected performance, the strength of the capital
structure, the experience and expertise of RAC Servicer, LLC as the
servicer and administrator, and the presence of Wells Fargo N.A.
(long-term deposits Aa1 and long-term senior unsecured Aa2 stable)
as the named backup servicer.

The definitive rating for the Class B notes, Baa3 (sf), is one
notch higher than its provisional rating, (P)Ba1 (sf). This
difference is the result of the transaction closing at a lower cost
of funds than Moody's modeled when the provisional ratings were
assigned. The weighted average coupon and other structural features
were provided by the issuer.

Moody's median cumulative net credit loss expectation is 31%.
Moody's based its cumulative net credit loss expectation on an
analysis of the quality of the underlying collateral; managed
portfolio performance; the historical credit loss of similar
collateral; the ability of RAC Servicer, LLC to perform the
servicing functions; and current expectations for the macroeconomic
environment during the life of the transaction.

Moody's also analyzed the residual risk of the pool based on the
exposure to residual value risk; the historical turn-in rate; and
the historical residual value performance.

At closing, the Class A notes, the Class B notes and the Class C
notes are expected to benefit from 42.75%, 29.65%, 21.35% of hard
credit enhancement, respectively. Hard credit enhancement for the
notes consists of a combination of overcollateralization, a
non-declining reserve account and subordination, except for the
Class C notes, which do not benefit from subordination. The notes
may also benefit from excess spread.

PRINCIPAL METHODOLOGY

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

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

Up

Moody's could upgrade the subordinate notes if levels of credit
enhancement are higher than necessary to protect investors against
current expectations of portfolio losses. 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 vehicles
securing an obligor's promise of payment. Portfolio losses also
depend greatly on the US job market and the market for used
vehicles. Other reasons for better-than-expected performance
include changes to servicing practices that enhance collections or
refinancing opportunities that result in prepayments.

Down

Moody's could downgrade the notes if levels of credit enhancement
are insufficient to protect investors against current expectations
of portfolio losses. 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 vehicles securing an obligor's
promise of payment. Portfolio losses also depend greatly on the US
job market and the market for used vehicles. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.


AMERICA MERRILL 2013-C7: Moody's Cuts Class G Certs Rating to Caa1
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings on eleven classes
and downgraded the ratings on two classes in Morgan Stanley Bank of
America Merrill Lynch Trust 2013-C7, Commercial Mortgage
Pass-Through Certificates as follows:

Cl. A-AB, Affirmed Aaa (sf); previously on Jul 12, 2018 Affirmed
Aaa (sf)

Cl. A-3, Affirmed Aaa (sf); previously on Jul 12, 2018 Affirmed Aaa
(sf)

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

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

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

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

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

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

Cl. F, Downgraded to B1 (sf); previously on Jul 12, 2018 Affirmed
Ba3 (sf)

Cl. G, Downgraded to Caa1 (sf); previously on Jul 12, 2018 Affirmed
B2 (sf)

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

Cl. X-B*, Affirmed A2 (sf); previously on Jul 12, 2018 Affirmed A2
(sf)

Cl. PST**, Affirmed Aa3 (sf); previously on Mar 18, 2019 Upgraded
to Aa3 (sf)

* Reflects Interest Only Classes

** Reflects Exchangeable Classes

RATINGS RATIONALE

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

The ratings on two P&I classes, Cl. F and Cl. G, were downgraded
due to the decline in performance of the two specially serviced
loans, Valley West Mall and 494 Broadway, representing a total of
6% of the pool as well as the performance decline of the third
largest loan in the pool, Solomon Pond Mall.

The ratings on the IO classes, Cl. X-A and Cl. X-B, were affirmed
based on the credit quality of their referenced classes.

The rating on the exchangeable class, Cl. PST, was affirmed due to
the credit quality of the referenced exchangeable classes.

Moody's rating action reflects a base expected loss of 4.9% of the
current pooled balance, compared to 2.2% at Moody's last review.
Moody's base expected loss plus realized losses is now 3.9% of the
original pooled balance, compared to 2.0% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the November 18, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 25% to $1.04 billion
from $1.39 billion at securitization. The certificates are
collateralized by 57 mortgage loans ranging in size from less than
1% to 15.8% of the pool, with the top ten loans (excluding
defeasance) constituting 60% of the pool. One loan, constituting 2%
of the pool, has an investment-grade structured credit assessments.
Eight loans, constituting 6.3% of the pool, have defeased and are
secured by US government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 16, compared to 18 at Moody's last review.

Seven loans, constituting 12% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

One loan has been liquidated from the pool, resulting in a realized
loss of $2.7 million (for a loss severity of 17%). Two loans,
constituting 6.1% of the pool, are currently in special servicing.
The largest specially serviced loan is the Valley West Mall ($43.4
million -- 4.2% of the pool), which is secured by an 856,000 square
foot (SF) enclosed regional mall located in West Des Moines, Iowa.
At securitization the mall was anchored by Von Maur, JC Penney, and
Younkers (all collateral tenants). However, Yonkers (205,250 SF;
24% of the NRA) vacated in August 2018 and the space remains
vacant. The mall faces competition from the Jordan Creek Town
Center, the dominant mall in the West Des Moines submarket, located
approximately four miles southwest of the property. A Von Maur is
expected to open at Jordan Creek Town Center in 2022. Performance
at the Valley West Mall has continually declined since
securitization primarily due to the decline in rental revenue. The
year-end 2018 NOI was 45% lower than in 2013. As of June 2019, the
property was 61% occupied, with an in-line occupancy of 60%. The
loan was transferred to special servicing in August 2019 due to
imminent default.

The second largest specially serviced loan is the 494 Broadway Loan
($20.1 million -- 1.9% of the pool), which is secured by 13,000 SF
mixed-use, property located in the SoHo neighborhood of New York
City, New York. As of May 2019, the property was 100% leased to
four office and retail tenants. The largest tenant, Pandora
Ventures, renewed their lease in February 2018 at a significantly
lower rate than at securitization. As a result, the actual DSCR has
fallen to below 1.00X. The loan was transferred to special
servicing in July 2019. The borrower is planning to a request a
loan modification and the special servicer is working to file
foreclosure and appoint a receiver.

Moody's received full year 2018 operating results for 100% of the
pool, and partial year 2019 operating results for 55% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 97%, compared to 98% at Moody's last review.
Moody's conduit component excludes loans with structured credit
assessments, defeased and CTL loans, and specially serviced and
troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 14% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.3%.

Moody's actual and stressed conduit DSCRs are 1.71X and 1.08X,
respectively, compared to 1.72X and 1.09X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The loan with a structured credit assessment is the Sunvalley
Shopping Center Fee Loan ($20.7 million -- 2.0% of the pool), which
is secured by the leased fee interest associated with six parcels
of land totaling 68.4 acres located in Concord, California. The
parcels generate revenue through a ground lease to a 1.4 million SF
regional mall which is operated by an affiliate of Taubman Centers
Inc. The mall anchors are JC Penney, Macy's and Sears. Moody's
structured credit assessment is aaa (sca.pd), the same as at
Moody's last review.

The top three conduit loans represent 34% of the pool balance. The
largest loan is the Chrysler East Building Loan ($165 million --
15.8% of the pool), which is secured by a 32-story, 745,000 SF
multi-tenant office building within the Grand Central office market
of New York, New York. The loan sponsor is Tishman Speyer
Properties. The property is part of the Chrysler Center, a two
building interconnected complex that also includes the Chrysler
Building skyscraper. The collateral was 98% leased as of June 2019,
compared to 84% leased in December 2018. The largest tenants at the
property include Mintz, Levin, Cohn & Ferris, Viner Finance Inc,
and APG Asset Management. The loan is interest only for its entire
term and Moody's LTV and stressed DSCR are 123% and 0.75X,
respectively, the same as at Moody's last review.

The second largest loan is the Millennium Boston Retail Loan ($96.3
million -- 9.2% of the pool), which is secured by nine commercial
condominium units contained within three buildings, totaling
282,000 SF of mixed use space in the Midtown/Theater District area
of downtown Boston, Massachusetts. The properties were 100% leased
as of May 2018. The loan is benefitting from amortization, having
amortized nearly 11% since securitization. Moody's LTV and stressed
DSCR are 81% and 1.07X, respectively, the same as at last review.

The third largest loan is the Solomon Pond Mall Loan ($95.2 million
-- 9.1% of the pool), which is secured by a 399,000 SF component of
a 885,000 SF regional mall located in Marlborough, Massachusetts
(approximately 27 miles west of Boston). The property is anchored
by Macy's, JC Penney, and Sears, none of which are part of the loan
collateral. The largest collateral tenants are Regal Cinema (17% of
the NRA) and Tilt Arcade (7% of the NRA). As of June 2019, the
property was 94% leased, with an in-line occupancy of 84%. The
property's financial performance generally improved from
securitization through 2017, however, the 2018 NOI declined
approximately 14% from the prior year due to lower rental revenue.
The loan is benefitting from amortization, having amortized 13.2%
since securitization and the 2018 actual NOI DSCR was 1.94X.
Moody's LTV and stressed DSCR are 106% and 1.05X, respectively,
compared to 90% and 1.17X at the last review.


BALLYROCK CLO 2019-2: Moody's Rates $18MM Class D Notes Ba3
-----------------------------------------------------------
Moody's Investors Service assigned ratings to five classes of notes
issued by Ballyrock CLO 2019-2 Ltd.

Moody's rating action is as follows:

US$240,000,000 Class A-1a Senior Secured Floating Rate Notes due
2030 (the "Class A-1a Notes"), Assigned Aaa (sf)

US$44,000,000 Class A-2 Senior Secured Floating Rate Notes due 2030
(the "Class A-2 Notes"), Assigned Aa2 (sf)

US$24,000,000 Class B Senior Secured Deferrable Floating Rate Notes
due 2030 (the "Class B Notes"), Assigned A2 (sf)

US$22,000,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2030 (the "Class C Notes"), Assigned Baa3 (sf)

US$18,000,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2030 (the "Class D Notes"), Assigned Ba3 (sf)

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

RATINGS RATIONALE

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.

Ballyrock 2019-2 is a managed cash flow CLO. The issued notes will
be collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90% of the portfolio must consist of
first lien senior secured loans and eligible investments, and up to
10% of the portfolio may consist of not senior secured loans. The
portfolio is approximately 70% ramped as of the closing date.

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

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

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

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

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

Par amount: $400,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2711

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.5%

Weighted Average Life (WAL): 7 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.


BARCLAYS COMMERCIAL 2013-C6: Fitch Affirms Class F Certs at Bsf
---------------------------------------------------------------
Fitch Ratings affirmed 12 classes of Barclays Commercial Mortgage
Securities LLC's UBS-Barclays Commercial Mortgage Trust 2013-C6,
commercial mortgage pass-through certificates.

RATING ACTIONS

UBS-BB 2013-C6

Class A-3 90349GBE4;   LT AAAsf Affirmed;  previously at AAAsf

Class A-3FL 90349GAC9; LT AAAsf Affirmed;  previously at AAAsf

Class A-3FX 90349GAA3; LT AAAsf Affirmed;  previously at AAAsf

Class A-4 90349GBF1;   LT AAAsf Affirmed;  previously at AAAsf

Class A-S 90349GBH7;   LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 90349GBG9;  LT AAAsf Affirmed;  previously at AAAsf

Class B 90349GAN5;     LT AA-sf Affirmed;  previously at AA-sf

Class C 90349GAQ8;     LT A-sf Affirmed;   previously at A-sf

Class D 90349GAS4;     LT BBB-sf Affirmed; previously at BBB-sf

Class E 90349GAU9;     LT BBsf Affirmed;   previously at BBsf

Class F 90349GAW5;     LT Bsf Affirmed;    previously at Bsf

Class X-A 90349GAG0;   LT AAAsf Affirmed;  previously at AAAsf

Class X-B 90349GAJ4;   LT A-sf Affirmed;   previously at A-sf

KEY RATING DRIVERS

Overall Stable Performance and Loss Expectations: Overall pool
performance and loss expectations remain stable since issuance.
However, one loan (1%) is in special servicing. The loan is secured
by a 138-key limited service hotel located in Santa Rosa, CA and
transferred to special servicing in April 2018. Although the loan
remains current, the franchise agreement is in forbearance due to
low quality assurance scores. The servicer reports that recent
quality assurance scores have been satisfactory; a final inspection
is expected at year end and the loan may transfer back to the
master service upon full compliance. As of September 2019, the TTM
occupancy was reported to be 81.3%.

One loan has been designated as a Fitch Loan of Concern (FLOC). The
4141 Northeast 2nd Avenue loan (1.8%) is secured by a 112,929 sf
mixed-use property located in Miami, FL. Occupancy has improved to
89% as of June 2019 after dropping to 59% in June 2018. Despite the
increased in occupancy, the loan remains a FLOC due to significant
lease rollover in 2020.

Defeasance/Improved Credit Enhancement Since Issuance: Credit
enhancement has improved since issuance from paydown and
defeasance. Twelve loans (12.2%) are fully defeased, including the
fourth largest loan (6.2%). As of the November 2019 distribution
date, the pool's aggregate balance has been reduced by 10.6% to
$1.2 billion from $1.3 billion at issuance. Interest shortfalls in
the amount of $66,466 are currently affecting non-rated class G.
Ten loans (46.7% of the pool) are full-term interest-only, one loan
(1%) is fully amortizing and the remaining 48 loans are
amortizing.

Alternative Loss Considerations: Fitch has concerns with the
ability to refinance the Broward Mall loan (8.1%) due to the loan's
size, lack of amortization and the overall outlook for retail. As
such, Fitch performed a sensitivity analysis to account for
outsized losses should the loan have difficulty refinancing at
maturity. However, Fitch does not foresee any immediate risk and
there is no impact to the current ratings as property performance
has remained relatively stable and the loan does not mature until
March 2023.

Retail Concentration: Retail properties represent 49.2% of the
pool, with five retail loans in the top 10. Additionally, mixed-use
properties make up 16.4% of the pool, with three mixed-use loans in
the top 15. For 2012 vintage transactions, the average retail and
mixed-use exposures were 35.9% and 4.2%, respectively.

RATING SENSITIVITIES

The Rating Outlook for all classes remains Stable due to generally
stable collateral performance. Fitch does not foresee positive or
negative ratings migration until a material economic or asset-level
event changes the transaction's portfolio-level metrics.


BBCMS 2019-BWAY: Fitch Affirms BB-sf Rating $45.1MM Cl. E Certs
---------------------------------------------------------------
Fitch Ratings assigned the following ratings and Rating Outlooks to
BBCMS 2019-BWAY Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2019-BWAY:

  -- $187,400,000 class A 'AAAsf'; Outlook Stable;

  -- $187,400,000a class X-NCP 'AAAsf'; Outlook Stable;

  -- $36,600,000 class B 'AA-sf'; Outlook Stable;

  -- $24,500,000 class C 'A-sf'; Outlook Stable;

  -- $38,800,000 class D 'BBB-sf'; Outlook Stable;

  -- $45,100,000 class E 'BB-sf'; Outlook Stable;

  -- $17,600,000b class HRR 'B+sf'; Outlook Stable.

(a)Notional amount and interest only.

(b)Horizontal credit risk retention interest.

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

Since Fitch published its expected ratings on Nov. 12, 2019, the
expected ratings of one class of interest-only certificates, class
X-CP (notional balance $187,400,000) has been withdrawn because the
class was removed from the final deal structure by the issuer.

BBCMS 2019-BWAY Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2019-BWAY, represent the beneficial ownership
interest in a two-year (with three, one-year extension options),
floating-rate, interest only first-lien mortgage loan with an
original principal balance of $350.0 million. The mortgage loan is
secured by the leasehold interest in 1407 Broadway, a 43-story,
office tower totaling 1.1 million square feet in New York City.

The loan proceeds were used to pay off the existing $286.0 million
debt, return $52.0 million of equity to the sponsor, and fund
upfront reserves and closing costs. The expected closing date for
the transaction is Nov. 26, 2019.

KEY RATING DRIVERS

Strong Infill Manhattan Location: The property is located between
38th Street and 39th Street in Manhattan in close proximity to
Manhattan's public transportation hubs, including Times Square,
Grand Central Terminal, New York Penn Station and the Port
Authority Bus Terminal. In addition, the property is located one
block from Bryant Park, a 10-acre outdoor space with six million
annual visitors, and the property benefits from the recent
development of the Hudson Yards district, a $25 billion mixed-use
development that opened in March 2019, located six blocks to the
west. According to Reis, the subject is located within the Penn
Station submarket (within the New York Metro office market), which
reports an average vacancy of 3.60% and average asking rent of
$57.19 per square foot (psf) as of third-quarter 2019 (3Q19). Class
A average asking rents are $75.57 psf as of 3Q19.

Fitch Leverage: The $350.0 million mortgage loan has a Fitch debt
service coverage ratio (DSCR) and loan to value ratio (LTV) of
1.03x and 85.9%, respectively, and debt of $313 psf. The sponsor
acquired the property in 2015 for $330.0 million.

Short-term Leasehold Interest: The Estate of Sol Goldman owns the
land, and 1407 Broadway is subject to a 76-year ground lease
through December 2030, with one remaining fixed-rent, 18-year
renewal option, which would extend the ground lease through
December 2048. The fully extended loan term is five years, which
would result in 24 years remaining on the ground lease at loan
maturity. Fitch conducted break-even analysis to determine the
maximum coupon required to maintain a 1.00x DSCR at loan maturity,
assuming a fully amortizing loan concurrent with the expiration of
the ground lease. Assuming Fitch's current in-place stressed cash
flow, the break-even refinance coupon is 7.9% for the scheduled
balloon balance of the entire loan.

Recent Leasing and Capex: The property is currently 93.8% leased
with a weighted average lease term of 5.4 years to 152 tenants,
including Comcast (9.3% NRA), S. Rothschild (4.2% NRA) and Vince
Camuto (3.8% NRA). The sponsor has increased occupancy from 75.3%
to 93.8% by executing approximately 700,000 square feet (sf) of new
and renewal leases. In addition, the property underwent a $61.1
million renovation from 2015 to 2018. Major projects included the
common areas ($9.2 million), lobby ($8.3 million), retail
storefronts ($6.5 million) and HVAC ($5.5 million).

Experienced Ownership: The sponsor for the loan is an affiliate of
Shorenstein Company, LLC. Starting in 1992, Shorenstein has
sponsored 12 closed-end investment funds with total equity
commitments of $8.7 billion, of which Shorenstein committed $723.5
million. Those funds have invested in properties totaling 65.4
million sf. The company currently owns over 25 million sf in 20
markets.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 10.6% below
the Underwritten Issuer NCF. Unanticipated further declines in
property-level NCF could result in higher defaults and loss
severities on defaulted loans, and could result in potential rating
actions on the certificates.

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3 - ESG issues are credit
neutral or have only a minimal credit impact on the transaction,
either due to their nature or the way in which they are being
managed by the transaction.


BBCMS MORTGAGE 2019-C5: Fitch Rates $9.6MM Cl. G-RR Certs B-sf
--------------------------------------------------------------
Fitch Ratings assigned the following ratings and Rating Outlooks to
BBCMS Mortgage Trust 2019-C5 Commercial Mortgage Pass-Through
Certificates, Series 2019-C5:

  -- $21,460,000 class A-1 'AAAsf'; Outlook Stable;

  -- $86,300,000 class A-2 'AAAsf'; Outlook Stable;

  -- $187,000,000d class A-3 'AAAsf'; Outlook Stable;

  -- $349,400,000d class A-4 'AAAsf'; Outlook Stable;

  -- $30,830,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $94,017,000 class A-S 'AAAsf'; Outlook Stable;

  -- $674,990,000a class X-A 'AAAsf'; Outlook Stable;

  -- $40,981,000 class B 'AA-sf'; Outlook Stable;

  -- $39,776,000 class C 'A-sf'; Outlook Stable;

  -- $174,774,000a class X-B 'A-sf'; Outlook Stable;

  -- $25,313,000b class D 'BBBsf'; Outlook Stable;

  -- $19,285,000b class E 'BBB-sf'; Outlook Stable;

  -- $44,598,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $22,902,000b class F 'BB-sf'; Outlook Stable;

  -- $22,902,000ab class X-F 'BB-sf'; Outlook Stable;

  -- $9,642,000b class G-RR 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $37,366,303b class H-RR.

  -- $37,048,885bc class V-RR.

(a) Notional amount and interest only.

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

(c) Vertical credit-risk retention interest.

Since Fitch published its expected ratings on Oct. 30, 2019, the
following changes occurred: the balances for class A-3 and class
A-4 were finalized. At the time that the expected ratings were
assigned, the exact initial certificate balances of class A-3 and
class A-4 were unknown and expected to be within the range of
$100,000,000-$260,000,000 and $276,400,000-$436,400,000,
respectively. The final class balances for class A-3 and class A-4
are $187,000,000 and $349,400,000, respectively. The classes
reflect the final ratings and deal structure.

TRANSACTION SUMMARY

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 55 loans secured by 115
commercial properties having an aggregate principal balance of
$1,001,321,188 as of the cut-off date. The loans were contributed
to the trust by Barclays Capital Real Estate Inc., KeyBank National
Association, Natixis Real Estate Capital LLC, Societe Generale
Financial Corporation, Rialto Mortgage Finance, LLC, and BSPRT CMBS
Finance, LLC.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch debt service coverage ratio of
1.31x is better than the 2018 and 2019 YTD averages of 1.22x and
1.24x, respectively, for other Fitch-rated multiborrower
transactions. The pool's Fitch loan-to-value of 104.9% is higher
than the 2018 and 2019 YTD averages of 102.0%.

Lower Pool Concentration Relative to Recent Transactions: The top
10 loans represent 40.6% of the pool by balance, which is lower
than the 2018 and 2019 YTD multiborrower transaction averages of
50.6% and 51.3%, respectively. The pool's loan concentration index
(LCI) score of 280 and sponsor concentration index (SCI) score of
314 are also below the YTD 2019 averages of 383 and 404,
respectively.

Property Type Concentration: Multifamily properties represent 20.6%
of the pool. This is above the 2019 YTD and 2018 values of 13.4%
and 11.6%, respectively. This includes Presidential City (4.5% of
the pool), which received a stand-alone credit opinion of 'A-sf*'.
Additionally the pool contains only 21.6% of office loans, which is
below the 2019 YTD and 2018 averages of 34.3% and 31.9%,
respectively. All else being equal, multifamily properties
demonstrate less performance volatility and, therefore have lower
default probabilities.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 10.4% below
the most recent year's NOI for properties for which a full-year NOI
was provided, excluding properties that were stabilizing during
this period. Unanticipated further declines in property-level NCF
could result in higher defaults and loss severities on defaulted
loans and in potential rating actions on the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the
BBCMS 2019-C5 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.


BEAR STEARNS 2007-PWR16: Moody's Affirms C Rating on 2 Tranches
---------------------------------------------------------------
Moody's Investors Service affirmed the ratings on four classes in
Bear Stearns Commercial Mortgage Securities Trust 2007-PWR16, as
follows:

Cl. C, Affirmed Caa1 (sf); previously on Jun 21, 2018 Affirmed Caa1
(sf)

Cl. D, Affirmed Caa3 (sf); previously on Jun 21, 2018 Affirmed Caa3
(sf)

Cl. E, Affirmed C (sf); previously on Jun 21, 2018 Affirmed C (sf)

Cl. F, Affirmed C (sf); previously on Jun 21, 2018 Affirmed C (sf)

RATINGS RATIONALE

The ratings on the P&I classes were affirmed because the ratings
are consistent with Moody's expected recovery of principal from the
remaining loans as well as Moody's expected plus realized losses.

Moody's rating action reflects a base expected loss of 59.3% of the
current pooled balance, compared to 38.5% at Moody's last review.
Moody's base expected loss plus realized losses is now 9.2% of the
original pooled balance, compared to 8.8% 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, an increase in
the pool's share of defeasance or an improvement in pool
performance.

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 93.3% of the pool is in
special servicing and Moody's has identified an additional troubled
loan representing 6.7% of the pool. In this approach, Moody's
determines a probability of default for each specially serviced and
troubled loan that it expects will generate a loss and estimates a
loss given default based on a review of broker's opinions of value
(if available), other information from the special servicer,
available market data and Moody's internal data. The loss given
default for each loan also takes into consideration repayment of
servicer advances to date, estimated future advances and closing
costs. Translating the probability of default and loss given
default into an expected loss estimate, Moody's then applies the
aggregate loss from specially serviced and troubled loans to the
most junior classes and the recovery as a pay down of principal to
the most senior classes.

DEAL PERFORMANCE

As of the November 14, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $74 million
from $3.3 billion at securitization. The certificates are
collateralized by seven mortgage loans ranging in size from less
than 1% to 41.7% of the pool.

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

One loan, constituting 6.7% of the pool, is on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package. As part of Moody's
ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Forty-six loans have been liquidated from the pool, resulting in an
aggregate realized loss of $261.6 million (for an average loss
severity of 50.7%). Six loans, constituting 93.3% of the pool, are
currently in special servicing. The largest specially serviced loan
is The Shops at Northern Boulevard Loan ($30.9 million -- 41.7% of
the pool), which is secured by the leasehold interest in a 218,000
square foot retail property located in Long Island City, New York.
The transferred to the special servicer in June 2017 for maturity
default after it was unable to payoff at its maturity date and the
loan became REO in June 2019. Retailers at the property include
grocer Stop & Shop, Marshall's, Old Navy, Party City, Guitar
Center, and Chuck E Cheese. The property is well leased and was 97%
occupied as of October 2019. However, the ground rent expense made
up over 30% of the property's 2018 total revenue and is subject to
a rent reset in 2022. The special servicer indicated they working
on capital expenditure and environmental remediation and plan to
market the asset for sale in 2020.

The second largest specially serviced loan is the Kingwood Office
Loan ($14.0 million -- 19.0% of the pool), which is secured by a
198,983 square foot Class B suburban office property in Kingwood,
Texas, a suburb of Houston. The loan passed its scheduled maturity
date in June 2017 and subsequently transferred to special servicing
and became REO in January 2018. As of September 2019, the property
was 81% leased and capital repair items are being completed. The
special servicer indicated they plan to market the property for
sale in 2020.

The third largest specially serviced loan is the Canal Farms
Shopping Center Loan ($9.8 million -- 13.2% of the pool), which is
secured by a 110,535 square foot shopping center in Los Banos,
California. The property was transferred to special servicing April
2017 for imminent default and the property became REO in August
2018. As of September 2019, the property was 48% leased. The
special servicer indicated the property is currently being marketed
for sale.

The remaining three specially serviced loans are secured by a mix
of retail properties. Moody's estimates an aggregate $42.0 million
loss for the specially serviced loans (61% expected loss on
average).

The sole remaining non-specially serviced loan is the MSC
Industrial Building ($4.9 million -- 6.7% of the pool) which is
secured by a 50,000 SF class B office building located in
Southfield, MI. The loan passed its anticipated repayment date
(ARD) in January 2017 and has a final maturity date of January
2037. As of January 2019, the property was 100% leased to a single
tenant, with a lease expiration of February 2022. The lender has
provided approval for the tenant to extend its lease term through
December 2029, although the lease extension has yet to be executed.
Due the tenant concentration, Moody's value utilized a lit/dark
analysis. The loan is on the master servicer's watchlist due to
lower DSCR and Moody's has identified this as a troubled loan.

As of the November 14, 2019 remittance statement cumulative
interest shortfalls were $9.7 million. Moody's anticipates interest
shortfalls will continue because of the exposure to specially
serviced loans. Interest shortfalls are caused by special servicing
fees, including workout and liquidation fees, appraisal entitlement
reductions (ASERs), loan modifications and extraordinary trust
expenses.


BENCHMARK 2019-B14: Fitch Assigns B-sf Rating on Class G-RR Certs
-----------------------------------------------------------------
Fitch Ratings assigned ratings and Rating Outlooks to BENCHMARK
2019-B14 Mortgage Trust, commercial mortgage pass-through
certificates series 2019-B14.

Fitch has rated the transaction and assigned Rating Outlooks as
follows:

  -- $22,760,000 class A-1 'AAAsf'; Outlook Stable;

  -- $249,620,000 class A-2 'AAAsf'; Outlook Stable;

  -- $55,480,000 class A-3 'AAAsf'; Outlook Stable;

  -- $187,000,000 class A-4 'AAAsf'; Outlook Stable;

  -- $350,570,000 class A-5 'AAAsf'; Outlook Stable;

  -- $37,040,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $127,315,000 class A-S 'AAAsf'; Outlook Stable;

  -- $1,029,785,000a class X-A 'AAAsf'; Outlook Stable;

  -- $61,240,000 class B 'AA-sf'; Outlook Stable;

  -- $53,180,000 class C 'A-sf'; Outlook Stable;

  -- $114,420,000a class X-B 'AA-sf'; Outlook Stable;

  -- $33,845,000b class D 'BBBsf'; Outlook Stable;

  -- $25,785,000b class E 'BBB-sf'; Outlook Stable;

  -- $59,630,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $24,175,000bd class F-RR 'BB-sf'; Outlook Stable;

  -- $12,890,000bd class G-RR 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $33,000,000bc class VRR;

  -- $48,349,368bd class NR-RR Interest;

  -- The transaction includes six classes of non-offered,
loan-specific certificates (non-pooled rake classes) related to the
subordinate companion loan of 225 Bush. Classes 225B-A, 225B-B,
222B-C, 225B-D, 225B-E, and 225B-VRR Interest are all not rated by
Fitch.

(a) Notional amount and interest only.

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

(c) Vertical credit-risk retention interest, which represents
approximately 2.5% of the certificate balance, notional amount or
percentage interest of each class of certificates.

(d) Horizontal Risk Retention.

TRANSACTION SUMMARY

Since Fitch published its expected ratings on Oct. 30, 2019, the
balances for class A-4 and A-5 were finalized. At the time the
classes were assigned, the class A-4 balance range was $100,000,000
to $187,000,000 and the class A-5 balance range was $350,570,000 to
$437,570,000. The final class sizes for class A-4 and A-5 are
$187,000,000 and $350,570,000, respectively. Additionally, the
final rating on class X-B has been updated to 'AA-sf' from 'A-sf'
to reflect the rating of the lowest referenced tranche whose
payable interest has an impact on the IO payments, consistent with
Fitch's Global Structured Finance Rating Criteria dated May 2,
2019. The classes reflect the final ratings and deal structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 53 loans secured by 112
commercial properties having an aggregate principal balance of
$1,322,249,369 as of the cut-off date. The loans were contributed
to the trust by JPMorgan Chase Bank, National Association, Citi
Real Estate Funding Inc., and German American Capital Corporation.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 78.0% of the properties
by balance, cash flow analysis of 81.4% of the pool, and asset
summary reviews on 100% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch LTV of 105.5% is higher than the
2019 YTD and 2018 averages of 102.3% and 102.0%, respectively, for
other Fitch-rated multiborrower transactions. Additionally, the
pool's Fitch trust debt service coverage ratio (DSCR) of 1.21x is
line with the 2019 YTD and 2018 averages of 1.21x and 1.22x,
respectively.

Investment-Grade Credit Opinions: Five loans, representing 17.9% of
the pool, have investment-grade credit opinions. This is above the
YTD 2019 and 2018 averages of 14.4% and 13.6%, respectively. Net of
these loans, the Fitch LTV and DSCR are 112.7% and 1.20x,
respectively, for this transaction. Loans with investment-grade
credit opinions include 225 Bush (4.5% of the pool), The Essex
(4.3% of the pool), Osborn Triangle (3.0% of the pool), 180 Water
(3.7% of the pool), and Grand Canal Shoppes (2.3% of the pool).
Each of these loans received an investment-grade credit opinion of
'BBB-sf*' on a stand-alone basis.

Limited Amortization: Based on the scheduled balance at maturity,
the pool will pay down by 5.0%, which reflects an amortization
below 2019 and 2018 averages of 6.1% and 7.2%, respectively. The
pool has 28 interest only loans (62.8% of the pool by balance) and
16 partial interest only loans (21.8% of the pool by balance).

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 8.0% 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
BMARK 2019-B14 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.


BRAVO RESIDENTIAL 2019-NQM2: Fitch to Rate Cl. B-2 Debt 'B(EXP)'
----------------------------------------------------------------
Fitch Ratings expects to rate BRAVO Residential Funding Trust
2019-NQM2 (BRAVO 2019-NQM2).

RATING ACTIONS

BRAVO Residential Funding Trust 2019-NQM2;

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

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

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

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

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

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

Class M-1; LT BBB(EXP)sf; Expected Rating

TRANSACTION SUMMARY

Fitch expects to rate the residential mortgage-backed transaction
BRAVO Residential Funding Trust 2019-NQM2, issued by a private fund
managed by Pacific Investment Management Company LLC. The notes are
supported by 742 loans with a total balance of approximately
$341.10 million as of the cutoff date.

Over 41% of the pool consists of loans previously securitized in
the 2016 and 2017 COLT transactions that have since been called.
The remaining loans were originated by various sellers.
Approximately 64% of the pool is designated as non-qualified
mortgages (non-QM), 11% consists of higher priced QM (HPQM) and
close to 2% comprises safe harbor QM (SHQM). The ability to repay
(ATR) does not apply to the remaining loans since they are business
purpose loans that are not subject to ATR (22%) or are exempt from
QM (1.3%) or were originated prior to the QM rule (0.01%).

The servicing agreements provide that a substitute index will be
selected to replace LIBOR when the LIBOR index is not available for
the adjustable rate loans based off one-year LIBOR. The notes in
the transaction are not affected by LIBOR replacement since the
coupons are based on a fixed rate or the net WAC.

KEY RATING DRIVERS

Non-Prime Credit Quality (Mixed): The pool has a weighted average
(WA) Fitch model credit score of 719 and a Fitch derived WA
mark-to-market combined loan-to-value ratio (CLTV) of 72.2%. This
pool is seasoned 18 months, has an original term of 363 months and
is comprised mainly of adjustable rate mortgages (ARMs) (64%). The
pool contains 56 loans that are over $1 million and the largest
loan is $2.83 million. The majority of the loans were originated
through a non-retail channel.

Alternative Income Documentation (Negative): Less than half of the
pool is comprised of fully documented loans (46%) and 54% consists
of alternative income documentation such as bank statements, CPA
letters, profit and loss (P&L) statements, property cash flows, and
asset depletion. Approximately 19% of the pool was underwritten to
a bank statement program and over 10% was underwritten using a
letter from a CPA or P&L statements, or both, to verify income.
Fitch increased its base case probability of default (PD) by
roughly 1.5x to account for higher risk associated with the bank
statements, which assumes slightly less relative risk than a
pre-crisis "stated income" loan. The CPA and P&L income
documentation were treated as "stated income" loans and received a
slightly higher penalty than the bank statements.

Investor Loans (Negative): Approximately 22% of the pool is
comprised of investment property loans, with 13% underwritten to a
debt service cash flow ratio (DSCR) rather than the borrower's
debt-to-income ratio (DTI). The investor property borrowers have a
WA FICO of 730 and an original LTV of 64% (loans underwritten to
the cash flow ratio have a WA FICO of 733 and an original LTV of
63%). Fitch increased the PD by more than 2.0x for the cash flow
ratio loans and assumed them to have 'no income' documentation.

Non-Permanent Residents (Negative): Almost 5% of the pool is
comprised of loans made to non-permanent residents. The collateral
attributes of these borrowers are strong with a weighted average
714 and original LTV of 66%. The majority of these loans are
purchase loans on primary residences (77%), and are mostly
single-family homes (70%). To account for the potentially higher
default risk associated with non-permanent residents, Fitch assumed
these loans to be non-owner occupied with no documented income or
assets and zero liquid reserves.

Geographic Concentration (Negative): Approximately 44% of the pool
is concentrated in California with relatively low MSA
concentration. The largest MSA concentration is in the Los Angeles
MSA (20.4%) followed by the Miami MSA (11.7%) and the New York MSA
(7.2%). The top three MSAs account for 39.3% of the pool. As a
result, there was a 1.03x PD adjustment for geographic
concentration.

Modified Sequential Structure (Positive): A modified sequential
structure is being used, which is in line with previously issued
non-prime transactions. Under this structure principal is
distributed pro-rata to the senior classes subject to the passing
of certain performance triggers while the subordinate classes are
locked out from any principal until the senior classes are paid in
full. To the extent the triggers fail, the payment priority reverts
to fully sequential. Principal collections can be used to provide
interest to the bonds.

Excess Cash Flow (Positive): The transaction benefits from a
material amount of excess cash flow that provides benefit to the
rated notes before being paid out to the class XS. In Fitch's
analysis, the excess is used to protect against realized losses
(resulting in required subordination below Fitch's collateral loss
expectations) as well as timely payment of interest for all classes
in their respective rating stress. To the extent that the
collateral weighted average coupon (WAC) and corresponding excess
are reduced through a rate modification, Fitch would view the
impact as credit neutral as the modification would reduce the
borrower's PD, resulting in a lower loss expectation.

Performance Triggers (Positive): Delinquency and loan loss triggers
convert principal distribution to a straight sequential payment
priority in the event of poor asset performance. The delinquency
trigger is based on a rolling six-month average. The triggers for
this transaction should help to protect the A-1 and A-2 classes
from a high stress scenario by cutting off principal payments to
more junior classes and ensuring a higher amount of protection
compared to when the triggers are passing.

Due Diligence Review Results (Positive): Third-party due diligence
was performed on 99.6% of loans in the transaction. AMC Diligence,
LLC (AMC) and Clayton Services, LLC (Clayton), both an 'Acceptable
- Tier 1' TPR, performed the vast majority of the due diligence
reviews. A small percentage of due diligence review was performed
by Digital Risk, LLC (Digital Risk) an 'Acceptable - Tier 2' TPR.
The results of the review confirm high overall loan quality with
the majority of exceptions deemed as non-material. Fitch applied a
credit for the high percentage of loan level due diligence which
reduced the 'AAA' loss expectation by 42 bps. Negative adjustments
were made on only a handful of loans to account for due diligence
findings relating to missing final HUDs and unrecorded original
modification agreements which had an immaterial impact on Fitch's
loss expectation.

Low Operational Risk (Neutral): Certain investment vehicles managed
by PIMCO have a long operating history of aggregating residential
mortgage loans. PIMCO is assessed as 'Above Average' by Fitch as an
aggregator. The servicers for this transaction are Rushmore Loan
Management Servicer LLC (rated RPS2 by Fitch), Specialized Loan
Servicing, LLC (rated RPS2+ by Fitch), Sterling Bank and Trust, FSB
(not assessed by Fitch) and AmWest Funding Corp. (not assessed by
Fitch). Nationstar Mortgage LLC will be master servicer and is
rated 'RMS2+' by Fitch.

Representation Framework (Negative): The seller will be providing
loan-level representations and warranties (R&W) to the loans in the
trust. The rep and warranty (R&W) framework is consistent with Tier
2 quality. The framework lacks an automatic review trigger which is
the primary driver of the Tier 2 consideration. The controlling
holder has the option to pursue a breach review for loans with a
realized loss; however, 25% of the aggregate bond holders may also
initiate a review. An improvement from BRAVO 2019-NQM1, is the
inclusion of a knowledge qualifier clawback provision. The reps are
being provided by an unrated counterparty. Fitch increased its loss
expectation by 163bps at the 'AAAsf' rating category due to the rep
framework and unrated counterparty.

No P&I Advancing (Mixed): This deal is structured without P&I
advancing. This is atypical for a modified sequential non-prime
transaction structure, which typically features limited advancing
of four to six months. The lack of advancing led to lower loss
severities, but resulted in a higher spread between expected
collateral loss and credit enhancement (CE).

RATING SENSITIVITIES

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

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

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

CRITERIA VARIATION

The transaction was analyzed with one variation to the "U.S. RMBS
Rating Criteria" report regarding the scope of the diligence that
was performed. Per Fitch's criteria, Fitch expects loans seasoned
less than 24 months to have received a property valuation review
and a credit review. In this transaction, two of the recently
originated loans (seasoned less than 24 months) did not receive a
property valuation review and two of the loans (seasoned less than
24 months) did not receive a credit review. For these four loans,
Fitch did not apply due diligence credit. As a result, there was no
rating impact due to this variation.

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), Clayton Services, LLC
(Clayton), Digital Risk, LLC (Digital Risk). The third-party due
diligence focused on three areas: a compliance review; a credit
review; and a valuation review; and was conducted on 99.6% of the
loans in the pool. Solidifi Title & Closing, LLC provided a 15E for
the title review that they completed. 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.


CIM TRUST 2019-R5: Moody's Assigns (P)B3 Rating on Cl. B2 Notes
---------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to eight
classes of notes issued by CIM Trust 2019-R5, which are backed by
one pool of primarily fixed-rate re-performing residential mortgage
loans. As of the cut-off date of October 31, 2019, the collateral
pool is comprised of 1,872 first lien mortgage loans with a
non-zero weighted average updated borrower FICO score of 661, a WA
current loan-to-value Ratio of 73.4% and a total unpaid balance of
$315,039,230. Approximately 78.5% of the collateral pool consists
of previously modified mortgage loans and about 11.7% consists of
adjustable-rate mortgage loans. Approximately 2.1% of the pool
balance is non-interest bearing, which consists of both principal
reduction alternative and non-PRA deferred principal balance.

Fay Servicing, LLC and Specialized Loan Servicing LLC will be the
primary servicers for 81.1% and 18.9% of the pool balance,
respectively. The servicers will not advance any principal or
interest on the delinquent loans, but they will be required to
advance costs and expenses incurred in connection with a default,
delinquency or other event in the performance of its servicing
obligations.

The complete rating actions are as follows:

Issuer: CIM Trust 2019-R5

Class A1, Assigned (P)Aaa (sf)

Class A1-A, Assigned (P)Aaa (sf)

Class A1-B, Assigned (P)Aaa (sf)

Class M1, Assigned (P)Aa2 (sf)

Class M2, Assigned (P)A3 (sf)

Class M3, Assigned (P)Baa3 (sf)

Class B1, Assigned (P)Ba2 (sf)

Class B2, Assigned (P)B3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected loss on CIM 2019-R5's collateral pool is 12.00% in
its base case scenario and 36.00% at a stress level consistent with
the Aaa rating. Its loss estimates take into account the historical
performance of loans that have similar collateral characteristics
as the loans in the pool. Its credit opinion is the result of its
analysis of a wide array of quantitative and qualitative factors, a
review of the third-party review of the pool, servicing framework
and the representations and warranties framework.

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

Collateral Description

CIM 2019-R5's collateral pool is primarily comprised of fixed-rate
re-performing mortgage loans. About 78.5% of mortgage loans in the
pool have been previously modified and about 11.7% of the mortgage
loans are adjustable-rate mortgage loans.

Moody's based its expected losses on its estimates of 1) the
default rate on the remaining balance of the loans and 2) the
principal recovery rate on the defaulted balances. The two factors
that most strongly influence a re-performing mortgage loan's
likelihood of re-default are the length of time that the loan has
performed since a loan modification, and the amount of the
reduction in the monthly mortgage payment as a result of the
modification. The longer a borrower has been current on a
re-performing loan, the less likely the borrower is to re-default.
Approximately 40.5% of the borrowers have been current on their
payments for at least the past 24 months under the MBA method of
calculating delinquencies.

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

In the pool-level approach, Moody's estimates losses on the pool
using an approach similar to its surveillance approach whereby
Moody's applies assumptions of future delinquencies, default rates,
loss severities and prepayments based on observed performance of
similar collateral. Moody's projects future annual delinquencies
for eight years by applying an initial annual default rate and
delinquency burnout factors. Based on the loan characteristics of
the pool and the demonstrated pay histories, Moody's expects an
annual delinquency rate of 14.8% on the collateral pool for year
one. Moody's then calculated future delinquencies on the pool using
its default burnout and voluntary conditional prepayment rate (CPR)
assumptions. The delinquency burnout factors reflect its future
expectations of the economy and the U.S. housing market. Moody's
then aggregated the delinquencies and converted them to losses by
applying pool-specific lifetime default frequency and loss severity
assumptions. Its loss severity assumptions are based off observed
severities on liquidated seasoned loans and reflect the lack of
principal and interest advancing on the loans.

Moody's also conducted a loan level analysis on CIM 2019-R5's
collateral pool. Moody's applied loan-level baseline lifetime
propensity to default assumptions and considered the historical
performance of seasoned loans with similar collateral
characteristics and payment histories. Moody's then adjusted this
base default propensity up for (1) loans that have the risk of
coupon step-ups and (2) loans with high updated loan to value
ratios (LTVs). Moody's applied a higher baseline lifetime default
propensity for interest-only loans, using the same adjustments. To
calculate the expected loss for the pool, Moody's applied a
loan-level loss severity assumption based on the loans' updated
estimated LTVs. Moody's further adjusted the loss severity
assumption upwards for loans in states that give super-priority
status to homeowner association (HOA) liens, to account for
potential risk of HOA liens trumping a mortgage.

As of the statistical cut-off date, approximately 2.1% of the pool
balance is non-interest bearing, which consists of both PRA and
non-PRA deferred principal balance. However, the PRA deferred
amount of $152,112 will be carved out as a separate Class PRA
note.

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

Transaction Structure

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

Moody's ran 96 different loss and prepayment scenarios through its
cash flow analysis. The scenarios encompass six loss levels, four
loss timing curves, and four prepayment curves.

Third Party Review

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

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

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

The diligence provider conducted a review of the title policies,
mortgages and lien searches (within twelve months of the cut-off
date) on all of the mortgage in the collateral pool to confirm the
first lien position of the mortgages and to identify other amounts
owed on the mortgage. Moody's did not increase losses for any
outstanding lien because the remedy provider will extinguish the
liens within 150 days of closing date. If the liens are not
extinguished, then remedy provider will be obligated to repurchase
the loans.

The review also consisted of validating 39 data fields for each
loan in the pool which resulted in 1,662 loans having one or more
data variances. It was determined that such data variances were
attributable to missing or defective source documentation,
non-material variances within acceptable tolerances, allocation
between documented and undocumented deferred principal balances,
timing and data formatting differences. Moody's did not make any
adjustments for these findings.

Representations & Warranties (R&W)

The R&W provider is Chimera Funding TRS LLC, wholly-owned
subsidiary of Chimera Investment Corporation (NYSE: CIM) and is not
an investment grade-rated entity. The creditworthiness of the R&W
provider determines the probability that the R&W provider will be
available and have the financial wherewithal to repurchase
defective loans upon identifying a breach. An investment
grade-rated R&W provider lends substantial strength to its R&Ws.
For financially weaker entities, Moody's look for other offsetting
factors, such as a strong alignment of interest and enforcement
mechanisms, to derive the same level of protection. Moody's
analyzes the impact of less creditworthy R&W providers case by
case, in conjunction with other aspects of the transaction.

Mortgage loans will be reviewed for a breach of R&Ws only if one of
the following occurs (1) a loan becomes 120 days delinquent (MBA
method) or (2) a loan has been liquidated and upon such liquidation
has incurred a realized loss.

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

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

Trustee Indemnification

Moody's believes there is a very low likelihood that the rated
notes in CIM 2019-R5 will incur any loss from extraordinary
expenses or indemnification payments owing to potential future
lawsuits against key deal parties. First, majority of the loans are
seasoned with demonstrated payment history, reducing the likelihood
of a lawsuit on the basis that the loans have underwriting defects.
Second, the transaction has reasonably well-defined processes in
place to identify loans with defects on an ongoing basis. In this
transaction a well-defined breach discovery and enforcement
mechanism reduces the likelihood that parties will be sued for
inaction.

Servicing arrangement

Fay and SLS will be the primary servicers for 81.1% and 18.9% of
the collateral pool, respectively. In the event of a termination of
a servicer under the related Servicing Agreement, a successor
servicer that is reasonably acceptable to the Class C holder will
be appointed by the Depositor on behalf of the Issuer. In addition,
the servicers do not advance principal and interest on delinquent
loans in this transaction which would make servicing transfer
easier as the replacement servicer will not be obligated to make
P&I advances. Moody's considers the overall servicing arrangement
to be credit neutral.

Other Considerations

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

Other Transaction Parties

Wells Fargo Bank, N.A. will act as the custodian, trust
administrator and paying agent. Wilmington Savings Fund Society,
FSB will be the owner trustee and U.S. Bank National Association
will be the indenture trustee.

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

Factors that would lead to an upgrade of the ratings

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

Factors that would lead to a downgrade of the ratings

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


COBALT CMBS 2007-C3: Fitch Lowers Class B Certs Rating to CCsf
--------------------------------------------------------------
Fitch Ratings downgraded one class and affirmed 12 classes of
Cobalt CMBS Commercial Mortgage Trust commercial mortgage
pass-through certificates series 2007-C3.

RATING ACTIONS

Cobalt CMBS Commercial Mortgage Trust 2007-C3

Class B 19075DAK7; LT CCsf Downgrade; previously at CCCsf

Class C 19075DAL5; LT Dsf Affirmed;   previously at Dsf

Class D 19075DAM3; LT Dsf Affirmed;   previously at Dsf

Class E 19075DAN1; LT Dsf Affirmed;   previously at Dsf

Class F 19075DAP6; LT Dsf Affirmed;   previously at Dsf

Class G 19075DAT8; LT Dsf Affirmed;   previously at Dsf

Class H 19075DAU5; LT Dsf Affirmed;   previously at Dsf

Class J 19075DAV3; LT Dsf Affirmed;   previously at Dsf

Class K 19075DAW1; LT Dsf Affirmed;   previously at Dsf

Class L 19075DAX9; LT Dsf Affirmed;   previously at Dsf

Class M 19075DAY7; LT Dsf Affirmed;   previously at Dsf

Class N 19075DAZ4; LT Dsf Affirmed;   previously at Dsf

Class O 19075DBA8; LT Dsf Affirmed;   previously at Dsf

KEY RATING DRIVERS

Increased Loss Expectations: The downgrade to class G reflects
increased loss expectations associated with the largest loan in the
pool. The pool remains highly concentrated with only two of the
original 126 loans remaining. Both loans have been identified as
Fitch Loans of Concern. Due to the concentrated nature of the pool,
Fitch performed a sensitivity analysis that grouped the remaining
loans based on collateral quality, performance and perceived
likelihood of repayment.

Alameda Media Center (80% of the remaining pool) is secured by a
122,000 sf office building located in Burbank, CA. The loan
previously transferred to the special servicer in 2015 due to
imminent default, and returned to the master servicer in 2017
following a loan modification. Occupancy declined to 66% at YE 2017
from 96% at YE 2016 due to the loss of the largest tenant, Ascent
Media Group, at their lease expiration date in December 2016.
Occupancy subsequently rebounded to the mid-70s at YE 2018, and
remains low at 76% as of June 2019. The loan is scheduled to mature
in June 2020. The loan's ability to refinance remains a concern.
The other loan in the pool, Cherry Hill Theatres (20%), is secured
by a single tenant movie theater located in Chery Hill, NJ. The
property is 100% leased to AMC/Loews Cinema. The loan is currently
hyper amortizing, with excess cash flow being applied to principal
pay down, as it did not repay in full at its June 2017 anticipated
repayment date (ARD). The loan matures June 2037.

Decreasing Credit Enhancement: Credit enhancement for class B has
decreased since the last rating action, as six loans disposed;
losses were in line with Fitch expectations. The losses reduced
classes D, E and F to zero and reduced class C by $15 million. As
of the October 2019 remittance report, the pool's aggregate
principal balance has been reduced by 98% to $45.1 million from $2
billion at issuance. Realized losses total $203.5 million (10% of
original pool balance).

RATING SENSITIVITIES

Class B is reliant on proceeds from the largest loan. Given the
property's declining performance and maturity risk, default is
considered probable. Upgrades, while unlikely, are possible should
the largest loan refinance in the near future. A downgrade to 'Dsf'
would occur should the class experience losses.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. ESG issues are credit neutral
or have only a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by the
transaction.


COMM 2013-CCRE8: Moody's Affirms B2 Rating on Class F Debt
----------------------------------------------------------
Moody's Investors Service affirmed the ratings on ten classes and
upgraded the ratings of two classes in COMM 2013-CCRE8 Mortgage
Trust as follows:

Cl. A-SBFL, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed
Aaa (sf)

Cl. A-SBFX, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed
Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed Aaa
(sf)

Cl. A-5, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed Aaa
(sf)

Cl. A-M, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed Aaa
(sf)

Cl. B, Upgraded to Aa2 (sf); previously on Jun 15, 2018 Affirmed
Aa3 (sf)

Cl. C, Upgraded to A2 (sf); previously on Jun 15, 2018 Affirmed A3
(sf)

Cl. D, Affirmed Baa3 (sf); previously on Jun 15, 2018 Affirmed Baa3
(sf)

Cl. E, Affirmed Ba2 (sf); previously on Jun 15, 2018 Affirmed Ba2
(sf)

Cl. F, Affirmed B2 (sf); previously on Jun 15, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed
Aaa (sf)

Cl. X-C*, Affirmed B3 (sf); previously on Jun 15, 2018 Affirmed B3
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

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

The ratings on two P&I classes were upgraded based primarily on an
increase in credit support resulting from loan paydowns and
amortization, as well as an increase in defeasance. The deal has
paid down 26% since securitization and defeasance now represents
13% of the pool.

The ratings on the IO classes were affirmed based on the credit
quality of their referenced classes.

Moody's rating action reflects a base expected loss of 2.4% of the
current pooled balance, compared to 3.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.1% of the
original pooled balance, compared to 2.6% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the November 13, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 26% to $1.03 billion
from $1.38 billion at securitization. The certificates are
collateralized by 51 mortgage loans ranging in size from less than
1% to 20% of the pool, with the top ten loans (excluding
defeasance) constituting 58% of the pool. Two loans, constituting
26% of the pool, have investment-grade structured credit
assessments. Nine loans, constituting 13% of the pool, have
defeased and are secured by US government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 12, compared to 15 at Moody's last review.

One loan, constituting 1% of the pool, are on the master servicer's
watchlist. The watchlist includes loans that meet certain portfolio
review guidelines established as part of the CRE Finance Council
(CREFC) monthly reporting package. As part of Moody's ongoing
monitoring of a transaction, the agency reviews the watchlist to
assess which loans have material issues that could affect
performance.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $4.9 million (for an average loss
severity of 38%). One loan, the Georgetown MHC Portfolio loan ($8.9
million -- 0.9% of the pool), is currently in special servicing.
The loan is secured by a manufactured housing community located in
Georgetown, KY. The loan transferred to special servicing in March
2014 due to payment default and became REO in March 2016. The
property was 69% occupied as of September 2018 compared to 97% at
securitization. Performance has declined significantly since
securitization due to lower rental revenue and higher expenses. The
special servicer indicated they are working to address deferred
maintenance, stabilize the asset, and then prepare the property for
sale.

Moody's has also assumed a high default probability for one poorly
performing loan, constituting 1% of the pool. The troubled loan is
secured by an office building located in Houston, TX which lost two
major tenants and is experiencing both low occupancy and DSCR. The
special servicer indicated a lease was finalized with a replacement
tenant for over 90% of the NRA but with a free-rent period until
September 2020.

Moody's received full year 2018 operating results for 99% of the
pool, and partial year 2019 operating results for 78% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 99%, compared to 101% at Moody's last
review. Moody's conduit component excludes loans with structured
credit assessments, defeased and CTL loans, and specially serviced
and troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 20% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.5%.

Moody's actual and stressed conduit DSCRs are 1.57X and 1.07X,
respectively, compared to 1.58X and 1.04X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The largest loan with a structured credit assessment is the 375
Park Avenue Loan ($209.0 million -- 20.3% of the pool), which
represents a pari-passu participation interest in a $418 million
senior mortgage loan. The loan is secured by the Seagram Building,
a class A trophy, landmark office tower located in Midtown
Manhattan. The building has 38 stories with a net rentable area
(NRA) of approximately 830,928 square feet. The property was 97%
leased as of February 2019, unchanged from March 2018 and compared
to 95% in December 2017. The property's largest tenant, Wells Faro
(30% of NRA), announced plans to vacate its space at the property
and relocate to Hudson Yards in late 2019. Wells Fargo had an
original lease expiration date in February 2021, however, the
Borrower and Wells Fargo reached an agreement that allows the
Borrower the option to accelerate the expiration of the lease upon
60-day notice. As part of the early termination, Wells Fargo would
be required to pay a sum of $1.2 million to satisfy certain
restoration obligations under their lease. The borrower indicated
this would allow them to attract potential tenant ahead of the
original lease expiration date. Wells Fargo's current in-place base
rent is below market based on demonstrated recent leasing at the
property and at other trophy assets located in the submarket. The
property is one of the premier office buildings in Manhattan with
superior amenities, location and architecture. The loan is also
encumbered by a $364.8 million B note and $217.3 million of
mezzanine debt. Moody's structured credit assessment and stressed
DSCR on the senior mortgage loan are aaa (sca.pd) and 1.64X,
respectively.

The other loan with a structured credit assessment is The Paramount
Building loan ($55.0 million -- 5.3% of the pool), which represents
a pari-passu portion in a $130 million senior mortgage loan. The
loan is secured by a 31-story, Class A office property located in
the Times Square section of Midtown Manhattan. The property incudes
ground floor retail space leased to national retail and restaurant
tenants. Occupancy has fluctuated and property performance has
declined slightly since securitization due to an increase in
operating expenses. The property was 71% leased as of March 2019,
compared to 70% at securitization. Moody's structured credit
assessment and stressed DSCR are aa2 (sca.pd) and 1.43X,
respectively.

The top three conduit loans represent 16% of the pool balance. The
largest loan is Westin San Diego loan ($61.9 million -- 6.0% of the
pool). The loan is secured by a 27-story, 436-room, full service
hotel property in downtown San Diego, CA. The hotel property is
part of a larger, mixed use development which contains
non-collateral components, including condominium residences and
offices. As of the September 2019 STR report, the property trailing
twelve month occupancy, ADR, and RevPAR were 80.1%, $194.41, and
$155.70, respectively, compared to 83%, $187.94 and $155.99,
respectively, for the prior year period. The loan has amortized by
over 12% and Moody's LTV and stressed DSCR are 87% and 1.27X,
respectively, compared to 90% and, 1.23X at the last review.

The second largest loan is the RHP Portfolio I Loan ($50.5 million
-- 4.9% of the pool). The loan is secured by six manufactured
housing communities located in Florida, Kansas, New York and Utah.
The portfolio consists of 1,636 pads and all developments were
constructed between 1956 and 1979. The entire portfolio was
approximately 93% occupied as of June 2019, compared to 85% in
December 2017. Occupancy levels have generally averaged above 82%
since securitization. The loan has amortized by over 6% and Moody's
LTV and stressed DSCR are 108% and 0.89X, respectively, compared to
111% and 0.86X at the last review.

The third largest loan is the RHP Portfolio II Loan ($49.4 million
-- 4.8% of the pool). The loan is secured by six manufactured
housing communities located in Florida, Kansas, New York and Utah.
The portfolio consists of 1,199 pads and all developments were
constructed between 1968 and 1994. The entire portfolio was
approximately 97% occupied as of December 2018, compared to 93% in
December 2017. The loan has amortized by over 6% and Moody's LTV
and stressed DSCR are 100% and 0.96X, respectively, compared to
101% and 0.95X at the last review.


COMM 2015-LC19: Fitch Affirms B-sf Rating on Class F Certs
----------------------------------------------------------
Fitch Ratings affirmed all classes of COMM 2015-LC19 Mortgage Trust
commercial mortgage pass-through certificates.

RATING ACTIONS

COMM 2015-LC19

Class A-2 200474AY0;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 200474BB9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 200474BC7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-M 200474BE3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 200474AZ7; LT AAAsf Affirmed;  previously at AAAsf

Class B 200474BF0;    LT AA-sf Affirmed;  previously at AA-sf

Class C 200474BH6;    LT A-sf Affirmed;   previously at A-sf

Class D 200474AE4;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 200474AG9;    LT BB-sf Affirmed;  previously at BB-sf

Class F 200474AJ3;    LT B-sf Affirmed;   previously at B-sf

Class PEZ 200474BG8;  LT A-sf Affirmed;   previously at A-sf

Class X-A 200474BD5;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 200474AA2;  LT AA-sf Affirmed;  previously at AA-sf

Class X-C 200474AC8;  LT BBB-sf Affirmed; previously at BBB-sf

KEY RATING DRIVERS

Stable Loss Expectations: Since issuance, base case loss
expectations have remained relatively stable. While there are four
Fitch Loans of Concern (FLOCs) totaling 4.1% of the pool, overall
performance of the pool has been stable. The FLOCs include three
specially serviced loans (2.5%) and one additional loan on the
watch list. Two of these loans are in the top 25. While the overall
percentage of FLOCs has remained flat, the former FLOC with the
highest expected loss, Marlow Portfolio (1.5%), has since been
defeased. The remaining FLOCs have experienced stable to improving
performance since last review, and the new FLOC, Enclave West
(1.5%), reflects collateral performance sufficient to operate and
make its debt service payments.

Modestly Improved Credit Enhancement: The pool has paid down
approximately 4.2% since issuance, which has resulted in a modest
increase in credit enhancement. Five loans totaling 4.2% of the
pool are currently defeased. At issuance, the loans in the pool
were scheduled to amortize by only 9.7%. Approximately 13 loans
totaling 42.5% of the pool are full-term interest-only. An
additional 20 loans totaling 29.4% of the pool are partial-term
interest-only.

High Leverage: At issuance, this pool had an average Fitch LTV of
112.9%, which is above the 2015 average Fitch LTV of 111.9%, the
highest average of any vintage since 2010. Given high leverage and
low coupon levels relative to historical averages, several of these
loans may face challenges in securing refinancing opportunities.

RATING SENSITIVITIES

The Rating Outlook on Class F has been revised to Stable from
Negative given lower deal loss expectations as a former FLOC with
high assumed losses has defeased. Downgrades are possible in the
event of performance declines related to the FLOCs, particularly
the specially serviced loans and the AHIP Oklahoma City Portfolio
(1.9% of the pool). Upgrades, while unlikely in the near term, are
possible with continued paydown, defeasance, or in the event of a
material improvement from several FLOCs.


CONN'S RECEIVABLES 2017-B: Fitch Hikes Class C Notes Rating to BBsf
-------------------------------------------------------------------
Fitch Ratings upgraded Conn's Receivables Funding 2017-B, LLC's
class C notes, which consists of notes backed by retail loans
originated and serviced by Conn Appliances, Inc.

RATING ACTIONS

Conn's Receivables Funding 2017-B

Class C 20825AAC2; LT BBsf Upgrade; previously at B-sf

The upgrade of the notes is due to performance in line with
expectations and growth in credit enhancement since closing. CE for
the class C notes has been steady at the target total
overcollateralization level of 35% since that level was reached as
of the January 2019 payment date.

The class C notes will continue to maintain steady OC as long as
the 35% OC release level is met, and have just begun to amortize as
of the November 2019 payment date. Due to this, the class C notes
remain more sensitive to tail-end risks.

KEY RATING DRIVERS

Collateral Quality: The 2017-B trust pool consists of 100%
fixed-rate consumer loans originated and serviced by Conn
Appliances, Inc. The pool exhibited a weighted average FICO score
of 607 at closing and has a weighted average borrower rate of
27.42%.

The lifetime base case default rate for the 2017-B pool is assumed
to be approximately 25.25%, equal to the original lifetime base
case default rate at closing. After taking into account defaults
that have already been recognized, remaining defaults of
approximately 25.81% were assumed. Defaults are mitigated by the CE
that has been steady at the 35% CE release level.

Fitch applied a 1.5x stress at the 'BBsf' level, reflecting the
high absolute value of the historical defaults, along with the
variability of default performance in recent years and the high
geographic concentration. The recovery rate on defaulted loans for
each note is assumed to be 5%.

Dependence on Trust Triggers: The trust depends on three trust
triggers (Cumulative Net Loss Trigger, Annualized Net Loss Trigger,
and Recovery Trigger) in order to ensure the payments due on the
notes during times of degrading collateral performance. While the
class C notes have begun to receive principal payments as of the
Nov. 15, 2019 payment date, their upward rating movement is
constrained due to the trust's ability to release excess spread
while the triggers are not active. Rating sensitivity is especially
prominent in stress scenarios with back loaded defaults.

A shortened version of the 18-month WAL default timing curve as
show in the Global Consumer ABS Criteria was utilized in order to
recognize all defaults within the life of the transaction.

Rating Cap at the 'BBBsf' Category: Due to the subprime credit-risk
profile of the customer base, higher loan defaults in recent years,
the high concentration of receivables from Texas, management
changes at Conn's, and servicing continuity risk due to in-store
payments, Fitch placed a rating cap on this transaction at
'BBBsf'.

Liquidity Support: Liquidity support is provided by a reserve
account, which was fully funded at closing at 1.50% of the initial
pool balance. The reserve account stepped down to 1.25% of the
original collateral balance when OC reached 30% of the current
collateral balance and will step down to 1.00% of the original
collateral balance once OC reaches 35% of the current collateral
balance. The reserve account is currently sized at $6,692,568.

Servicing Capabilities: Conn Appliances, Inc. demonstrates adequate
abilities as originator, underwriter, and servicer. The credit risk
profile of the entity is mitigated by the backup servicing provided
by Systems & Services Technologies, Inc. (SST), who has committed
to servicing transition period of 30 days.

RATING SENSITIVITIES

Unanticipated increases in the frequency of defaults or charge-offs
on borrower accounts could produce loss levels higher than the base
case and would likely result in declines of CE and remaining loss
coverage levels available to the notes. Decreased CE may make
certain ratings on the notes 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 charge-off assumption by an additional 10%, 25%,
and 50%, and examining the rating implications. The increases of
the base case charge-offs are intended to provide an indication of
the rating sensitivity of the notes to unexpected deterioration of
a transaction's performance.

During the sensitivity analysis, Fitch examines the magnitude of
the multiplier compression by projecting the expected cash flows
and loss coverage levels over the life of investments under higher
than the initial base case charge-off assumptions. Fitch models
cash flows with the revised charge-off estimates while holding
constant all other modelling assumptions.

Rating sensitivity to increased charge-off rate:

  -- Class C current ratings (Remaining Defaults as a percent of
current: 25.81%): 'BBsf';

  -- Increase base case by 10%: 'BBsf';

  -- Increase base case by 25%: 'B+sf',

  -- Increase base case by 50%: less than 'CCCsf'.

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

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is typically a score of 3 - ESG issues are
credit neutral or have only a minimal credit impact on transaction,
either due to their nature or the way in which they are being
managed.


CONN'S RECEIVABLES 2019-B: Fitch Assigns Bsf Rating on Cl. C Debt
-----------------------------------------------------------------
Fitch Ratings assigned the following ratings to Conn's Receivables
Funding 2019-B, LLC, which consists of notes backed by retail loans
originated by Conn Appliances, Inc. or Conn Credit Corporation,
Inc. and serviced by Conn Appliances, Inc.

RATING ACTIONS

Conn's Receivables Funding 2019-B

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

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

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

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

KEY RATING DRIVERS

Subprime Collateral Quality: The Conn's 2019-B receivables pool has
a weighted average (WA) FICO of 606, and 10.6% of the loans have
scores below 550 or no score. Fitch assigned a base case default
rate of 25% and applied a 2.2x stress at the 'BBBsf' level. The
default multiple reflects the high absolute value of the historical
defaults, the variability of default performance in recent years
and the high geographical concentration.

Rating Cap at 'BBBsf': Due to the subprime credit-risk profile of
the customer base, higher loan defaults in recent years, the high
concentration of receivables from Texas, management changes at
Conn's, and servicing continuity risk due to in-store payments,
Fitch placed a rating cap on this transaction at 'BBBsf'.

Stabilizing Asset Performance: Cumulative defaults increased with
each successive vintage from fiscal 2012 through fiscal 2017 as the
company aggressively expanded its originations. Early performance
indicators on the fiscal 2018 vintage do suggest some
stabilization. Fitch focused on the fiscal 2017 and fiscal 2018
periods for default assumption derivation to project future
portfolio performance.

Adequate Servicing Capabilities: Conn Appliances, Inc. has a long
track record as an originator, underwriter and servicer. The credit
risk profile of the entity is mitigated by the backup servicing
provided by Systems & Services Technologies, Inc. (SST), which has
committed to a servicing transition period of 30 days. Fitch
considers all parties to be adequate servicers for this pool at the
expected rating levels, based on prior experience and
capabilities.

RATING SENSITIVITIES

Unanticipated increases in the frequency of defaults or write-offs
on customer accounts could produce loss levels higher than the base
case and would likely result in declines of credit enhancement (CE)
and remaining loss coverage levels available to the investments.
Decreased CE may make certain ratings on the investments
susceptible to potential negative rating actions, depending on the
extent of the decline in coverage.

Rating sensitivities provide greater insight into the model-implied
sensitivities the transaction faces when one or two risk factors
are stressed while holding others equal. The modeling process first
uses the estimation and stress of a base case loss assumption to
reflect asset performance in a stressed environment. Second,
structural protection was analyzed with Fitch's proprietary cash
flow model. The results should only be considered as one potential
outcome as the transaction is exposed to multiple risk factors that
are all dynamic variables.

  -- Default increase 10%: class A 'BBB-sf'; class B 'BBsf'; class
C below 'CCCsf';

  -- Default increase 25%: class A 'BB+sf'; class B 'B+sf'; class C
below 'CCCsf';

  -- Default increase 50%: class A 'BBsf'; class B below 'CCCsf';
class C below 'CCCsf';

  -- Recoveries decrease to 0%: class A 'BBBsf'; class B 'BBsf';
class C 'Bsf'.


CSFB MORTGAGE 2005-C3: Moody's Affirms Caa3 Rating on Cl. D Certs
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on three classes in
CSFB Mortgage Securities Corp., Commercial Mortgage Pass-Through
Certificates, Series 2005-C3:

Cl. D, Affirmed Caa3 (sf); previously on Mar 11, 2019 Affirmed Caa3
(sf)

Cl. A-X*, Affirmed C (sf); previously on Mar 11, 2019 Affirmed C
(sf)

Cl. A-Y*, Affirmed Aaa (sf); previously on Mar 11, 2019 Affirmed
Aaa (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The rating on Cl. D was affirmed because the ratings are consistent
with Moody's expected loss plus realized losses. Class D has
already experienced a realized loss of 17% as a result of
previously liquidated loans.

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

The rating on the IO class A-Y was affirmed based on the credit
quality of its referenced residential cooperative loans.

Moody's rating action reflects a base expected loss of 4.8% of the
current pooled balance, compared to 21.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 7.9% of the
original pooled balance, essentially the same as at the last
review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the November 18, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by over 99% to $11.8
million from $1.64 billion at securitization. The certificates are
collateralized by 8 mortgage loans ranging in size from less than
1% to 27% of the pool. The pool contains four low leverage
cooperative loans, constituting 46% of the pool balance, that were
too small to credit assess; however, have Moody's leverage that is
consistent with other loans previously assigned an investment grade
Structured Credit Assessments.

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

Six loans, constituting 74% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package. As part of Moody's
ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Thirty loans have been liquidated from the pool, resulting in an
aggregate realized loss of $129 million (for an average loss
severity of 44%). There are no loans currently in special
servicing.

Moody's has assumed a high default probability for one poorly
performing loan, constituting 27% of the pool.

Moody's received full year 2018 operating results and partial year
2019 operating results for 100% of the pool (excluding specially
serviced and defeased loans). Moody's weighted average conduit LTV
is 77%, compared to 78% at Moody's last review. Moody's conduit
component excludes loans with structured credit assessments,
defeased and CTL loans, and specially serviced and troubled loans.
Moody's net cash flow (NCF) reflects a weighted average haircut of
29% to the most recently available net operating income (NOI).
Moody's value reflects a weighted average capitalization rate of
9.7%.

Moody's actual and stressed conduit DSCRs are 1.18X and 1.69X,
respectively, the same as at Moody's last review. Moody's actual
DSCR is based on Moody's NCF and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stress
rate the agency applied to the loan balance.

The top three non-cooperative loan exposures represent 53% of the
pool balance. The largest loan is the Foxcroft Mobile Home
Community loan ($3.2 million -- 27% of the pool), which is secured
by a mobile home community located in Loch Sheldrake, NY. The loan
is experiencing deferred maintenance issues which have contributed
to lower occupancy at the property and higher expenses. As a result
of depressed occupancy and elevated expenses the property's net
operating income has been well below 1.00X for several years. The
property was 70% occupied as of June 2019, compared to 73% in
September 2018, 78% in June 2017 and 93% at securitization. The
loan is fully amortizing, has amortized over 60% and has a maturity
date in February 2025. As a result of the low occupancy and DSCR,
Moody's considers this a troubled loan.

The second largest loan is the Fishers Gateway Shops loan ($2.7
million -- 23% of the pool), which is secured by an unanchored
retail center in Fishers, IN, approximately 20 miles north of
Indianapolis. As of June 2019, the property was 100% occupied. The
loan has amortized by over 28% and Moody's LTV and stressed DSCR
are 82% and 1.29X, respectively, compared to 84% and 1.25X at the
last review.

The third largest loan is the 750 New York Ave loan ($495,836 --
4.2% of the pool), which is secured by a single tenant retail
property located in Brooklyn, NY. The property is 100% leased to
Duane Reade with a lease expiring in October 2022. The loan has
amortized by over 58% and is fully amortizing with a maturity date
in April 2025. Moody's LTV and stressed DSCR are 64% and 1.65X,
respectively, compared to 70% and 1.49X at the last review.


FLAGSTAR MORTGAGE 2019-2: Fitch Assigns B Rating on Cl. B-5 Certs
-----------------------------------------------------------------
Fitch Ratings assigns ratings to the residential mortgage-backed
certificates issued by Flagstar Mortgage Trust 2019-2.

RATING ACTIONS

FSMT 2019-2

Class A-1;   LT AA+sf New Rating; previously at AA+(EXP)sf

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

Class A-11;  LT AA+sf New Rating; previously at AA+(EXP)sf

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

Class A-3;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-4;   LT AAAsf New Rating; previously at AAA(EXP)sf

Class A-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-X-1; LT AA+sf New Rating; previously at AA+(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 BBsf New Rating;  previously at BB(EXP)sf

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

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

TRANSACTION SUMMARY

The certificates are supported by 509 jumbo prime (78.5%) and
high-balance conforming (21.5%) loans with a total balance of
approximately $359.84 million. This is the 10th post-crisis
issuance from Flagstar Bank, FSB (Flagstar). The pool comprises
loans that Flagstar originated through its retail, broker and
correspondent channels. The transaction is similar to previous
Fitch-rated prime transactions, with a standard senior-subordinate,
shifting-interest deal structure.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The collateral pool consists
primarily of 30-year, fully amortizing, high balance conforming and
jumbo fixed-rate loans to borrowers with strong credit profiles and
low leverage. A large majority of the loans are designated as Safe
Harbor Qualified Mortgages (SHQMs) or Temporary Qualified
Mortgages. Less than 1% of the loans are Higher Priced Qualified
Mortgages (HPQM). The pool has a weighted average (WA) original
FICO score of 761 and an original combined loan to value (CLTV)
ratio of 68.4%. The collateral attributes of the pool are generally
consistent with those of recent prime transactions.

Low Operational Risk (Positive): Operational risk is well
controlled for in this transaction. Flagstar is experienced in
originating and securitizing prime quality loans and is considered
an 'Average' originator. The approximately 42% of due diligence
confirmed the quality of the loans, which were all underwritten to
full documentation and are more than 99% SHQM. The strong
representation and warranty (R&W) framework (classified by Fitch as
Tier 1) also contributes to the low operational risk for this
transaction.

Geographic Diversification (Neutral): The pool's primary
concentration is in California, representing 45.7% of the pool.
Approximately 32% of the pool is located in the top three MSAs (Los
Angeles, San Francisco and New York), with 14% of the pool located
in the Los Angeles MSA. The pool's regional concentration did not
add to Fitch's 'AAAsf' loss expectations.

Tier 1 R&W Framework (Positive): Flagstar's R&W framework is viewed
by Fitch as a full framework. While the framework still contains
materiality factors (which the reviewer must consider when
determining if a loan has a material failure), there are thresholds
that define materiality, which Fitch views as a key mitigant. In
addition, the reviewer can consider information not included in the
test. Fitch believes the R&W features support the investors'
ability to put back loans due to misrepresentation or manufacturing
defects. As a result of the Tier 1 representation, warranty and
enforcement (RW&E) framework and financial condition of the R&W
provider, the pool received neutral treatment at the 'AAAsf'
level.

Strong Due Diligence Results (Positive): A loan-level due diligence
review was conducted on 42% of the pool, in accordance with Fitch's
criteria, and focused on credit, compliance and property valuation.
All the loans that received a due diligence review in the final
pool received a grade of 'A' or 'B', indicating strong underwriting
practices and sound quality-control procedures. The majority of the
'B' graded loans were due to non-material compliance issues related
to TILA-RESPA Integrated Disclosure (TRID) findings, which were all
corrected or cleared/canceled.

Shifting Interest Structure (Negative): 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. This structure
is weaker than a pure sequential structure as it allows for leakage
of principal to subordinate bonds subject to the performance
triggers. As a result, the senior classes are more vulnerable to a
back loaded default timing curve later on in the life of the
transaction.

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 senior certificates and
a floor of 0.80% will be maintained for subordinate certificates.

Leakage from Reviewer Expenses (Negative): The trustee is obligated
to reimburse the breach reviewer, PentAlpha Surveillance, LLC
(PentAlpha), each month for any reasonable, out-of-pocket expenses
incurred if the company is requested to participate in any
arbitration, legal or regulatory actions, proceedings or hearings.
These expenses include PentAlpha's legal fees and other expenses
incurred outside its reviewer fee and are not subject to
certificateholder approval.

While Fitch accounted for the potential additional costs, Fitch
views this construct as adding potentially more ratings volatility
than those that do not have this type of provision. To account for
the risk of these expenses reducing subordination, Fitch adjusted
its required credit enhancement upward by 20bps at each rating
category.

Extraordinary Trust Expenses (Neutral): Extraordinary trust
expenses (with the exception of expenses incurred by the reviewer,
PentAlpha), including indemnification amounts and costs of
arbitration, reduce the net WA coupon (WAC) of the loans, which
does not affect the contractual interest due on the certificates.
Fitch did not make any adjustment for expenses that reduce the net
WAC.

RATING SENSITIVITIES

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

Fitch conducted sensitivity analysis determining how the ratings
would react to steeper MVDs at the national level. The analysis
assumes MVDs of 10%, 20%, and 30%, in addition to the
model-projected 5.3% at the base case. The analysis indicates there
is some potential rating migration with higher MVDs, compared with
the model projection. Fitch also conducted sensitivities to
determine the stresses to MVDs that would reduce a rating by one
full category, to non-investment grade, and to 'CCCsf'.


GS MORTGAGE 2012-GC6: Fitch Affirms Bsf Rating on Class F Debt
--------------------------------------------------------------
Fitch Ratings affirmed the ratings on all of the classes of GS
Mortgage Securities Trust 2012-GC6.

RATING ACTIONS

GSMS 2012-GC6

Class A-3 36192BAY3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-AB 36192BAZ0; LT AAAsf Affirmed;  previously at AAAsf

Class A-S 36192BAE7;  LT AAAsf Affirmed;  previously at AAAsf

Class B 36192BAG2;    LT AA-sf Affirmed;  previously at AA-sf

Class C 36192BAJ6;    LT A-sf Affirmed;   previously at A-sf

Class D 36192BAL1;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 36192BAN7;    LT BBsf Affirmed;   previously at BBsf

Class F 36192BAQ0;    LT Bsf Affirmed;    previously at Bsf

Class X-A 36192BAA5;  LT AAAsf Affirmed;  previously at AAAsf

KEY RATING DRIVERS

Stable Loss Expectations: The majority of the loans in the pool
continue to exhibit stable performance and loss expectations remain
fairly low. The ratings affirmations reflect the pool's continued
stable performance. Fitch has identified five (5.2%) Loans of
Concern including three loans (2.4%) in special servicing, all of
the loans remain current.

The non-specially serviced FLOCs were flagged due to declining
occupancy. The largest, Great Northern Corporate Center (1.8%), is
secured by a 270,000 sf office complex, located in North Olmsted,
OH. Several tenants left at their respective lease expiration
dates, as a result, occupancy declined to 79% by YE 2018 from 94%
at YE 2017 and DSCR declined to 1.45x from 1.71x during the same
period. Occupancy remains unchanged at a reported 79% as of
September 2019.

Specially Serviced Loans: The largest specially serviced loan,
Coconut Grove Courtyard (1.2%), is secured by a 196-key,
full-service hotel located in Miami, FL. The hotel suffered
significant hurricane damage in September 2017 and has remained
closed in order to undergo major renovations. The second largest
specially serviced loan, Towers of Coral Springs (0.8%), is secured
by a suburban office property located in Coral Springs, FL. The
loan transferred in August 2017 due to imminent monetary default.
Occupancy has remained in the mid-60s from YE 2015 through YE 2018,
compared with 73% at YE 2012. As of June 2019, the property was 71%
occupied. The smallest specially serviced loan, Holiday Inn Express
- Baltimore, MD (0.4%), is secured by a 68-key, limited-service
hotel located in Baltimore, MD. The loan transferred due to the
expiration of the franchise agreement in mid-2018. The borrower has
since entered into a re-licensing agreement with an expiration date
of September 2029, contingent on the completion of the franchise
mandated property improvement plan (PIP). The PIP is expected to be
completed by February 2020.

Limited Improvement in Credit Enhancement: There have been minimal
improvements in credit enhancement since Fitch's last rating
action. Twenty-six loans (27.7%) are defeased including 10 loans
(6.5% of pool) since the last rating action, one of which was
previously specially serviced. A majority of the pool (77%) is
amortizing balloon. Only two loans (3.2%) are full term interest
only. Four loans (19.8%) are structured with partial interest only
periods, all of which have begun amortizing. Loan maturities are
concentrated in 2021 (89.7%), and the remaining 10.3% of the pool
matures in January of 2022. There have been minimal realized losses
to date (less than 0.1% of the original balance), which have been
fully absorbed by the non-rated class.

Alternative Loss Considerations: Fitch ran an additional
sensitivity analysis on the maturity balance of three loans to
reflect the potential for outsized losses. A 15% loss was applied
to Meadowood Mall due to exposure to troubled retailers and
increased competition and Coconut Grove Courtyard by Marriott due
to delays in the renovation and re-opening process. Fitch also
applied a 50% loss to Great Northern Corporate Center due to
continued low occupancy and market weakness. The Negative Outlooks
on classes E and F reflect these sensitivity scenarios.

ADDITIONAL CONSIDERATIONS

Pool and Property Concentrations: The top 15 loans represent 64.7%
of the pool balance. The largest property types in the pool are:
Retail (41.2%), Office (16.8%) and Hotel (14.8%). Additionally, the
largest loan in the pool, Meadowood Mall (11.6%) is secured by a
regional mall located in Reno, NV. The mall is anchored by
collateral tenants Macy's - Men and Home, and Dick's Sporting
Goods. The mall lost non-collateral tenant Sears in July 2018.
Round1, a bowling alley and entertainment center, has reportedly
leased a portion of the Sears space and opened in August 2019. As
of September 2019, collateral occupancy was 91% with a servicer
reported NOI DSCR of 1.76x at year-end 2018.

RATING SENSITIVITIES

The Negative Outlooks on classes E and F represent a potential
ratings downgrade should performance, specifically with the FLOCs
and the regional mall, decline further. Outlooks on classes A-3
through D remain Stable due to overall stable performance and
continued amortization. Upgrades may occur with improved pool
performance and additional paydown or defeasance.

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.


GS MORTGAGE 2014-GC18: Fitch Cuts Rating on Class F Debt to CCsf
----------------------------------------------------------------
Fitch Ratings downgraded eight and affirmed five classes of GS
Mortgage Securities Trust 2014-GC18 pass-through certificates.

Fitch has issued a focus report on this transaction. The report
provides a detailed and up-to-date perspective on key credit
characteristics of the GSMS 2014-GC18 transaction and
property-level performance of the related trust loans.

RATING ACTIONS

GSMS 2014-GC18

Class A-3 36252RAJ8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 36252RAM1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-AB 36252RAQ2; LT AAAsf Affirmed;  previously at AAAsf

Class A-S 36252RAZ2;  LT AAAsf Affirmed;  previously at AAAsf

Class B 36252RBC2;    LT Asf Downgrade;   previously at AA-sf

Class C 36252RBJ7;    LT BBBsf Downgrade; previously at A-sf

Class D 36252RAG4;    LT Bsf Downgrade;   previously at BBsf

Class E 36252RAK5;    LT CCCsf Downgrade; previously at Bsf

Class F 36252RAN9;    LT CCsf Downgrade;  previously at CCCsf

Class PEZ 36252RBF5;  LT BBBsf Downgrade; previously at A-sf

Class X-A 36252RAT6;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 36252RAW9;  LT Asf Downgrade;   previously at AA-sf

Class X-C 36252RAA7;  LT CCCsf Downgrade; previously at Bsf

KEY RATING DRIVERS

Increased Loss Expectations: The downgrades to classes B through F,
as well as the interest only classes X-B and X-C, reflect an
increase to Fitch's loss expectations, primarily driven by the REO
Wyoming Valley Mall (8% of pool). Fitch modeled a base case loss of
80% on the asset.

Wyoming Valley Mall: The largest Fitch Loan of Concern (FLOC) is
the REO Wyoming Valley Mall (8%), a 910,000 sf super regional mall
located in Wilkes-Barre, PA. The loan transferred to special
servicing in June 2018 for imminent default and became REO in
September 2019. The property lost anchors Sears and Bon-Ton in
2018. The loss of the two anchors triggered co-tenancy clauses,
which further increased vacancy at the property. Fitch has
requested additional information from the servicer and is awaiting
response.

Additional Fitch Loans of Concern: Five other loans (14.8%) are
designated as FLOCs, including two special serviced loans (2.1%).

The largest FLOC is the Crossroads Mall loan (9.9%), which is
secured by a 348,810 sf portion of a 769,770 sf regional mall
located in Portage, MI. Sears (non-collateral) went dark at the end
of October 2019. The remaining anchors are Macy's (non-collateral),
J.C. Penney (non-collateral) and Burlington Coat Factory.
Comparable inline sales are low at $327 for TTM July 2019 compared
to $360 psf at issuance (as of TTM Nov. 2013).

The next largest FLOC is the Crowne Plaza Anchorage (1.9%), which
is secured by 165 room full service hotel located in Anchorage, AK.
While performance has improved this year, volatility in the local
oil and gas industry severely impacted performance between 2016 and
2018, and Fitch is continuing to monitor performance.

The specially serviced Hilton Garden Inn Pittsburgh - Cranberry
loan (1.7%) is secured by a 136 room limited service hotel located
in Cranberry Township, PA. The loan transferred to special
servicing in December 2018 for maturity default. Performance at the
property suffered after Westinghouse Electric Company, which was
headquartered in Cranford and located adjacent to the subject
hotel, filed for Chapter 11 bankruptcy protection in 2017. The
special servicer is currently pursuing foreclosure.

The two other FLOCs include the Residence Inn College Station loan
(0.9%), which is secured by an 84- room hotel located near Texas
A&M University that has had seasonal performance issues; and the
REO Sullivan Apartments (0.3%), a 36 unit multifamily property
located in Williston, ND. The loan transferred in March 2016 due to
imminent payment default and became REO in April 2018. The property
is reportedly being marketed for sale.

Minimal Credit Enhancement Improvement: As of the October 2019
distribution date, the pool's aggregate principal balance has been
reduced by 18.4% to $909.2 million from $1.1 billion at issuance.
Since issuance, eight loans have paid off with a de minimis loss of
$7,323 on one loan. Only 4.4% of the pool is interest only. All
other loans are amortizing. No performing loans mature until 2023
(40.7%) and 2024 (42.5%). Eight loans (6.4% of the pool balance)
are fully defeased.

Alternative Loss Considerations: Fitch performed an additional
sensitivity scenario that assumed potential outsized losses of 25%
and 100%, respectively, on the maturity balance of the Crossroads
Mall loan and the current exposure on the REO Wyoming Valley Mall.
The Negative Rating Outlook on class B reflects this scenario.

RATING SENSITIVITIES

The Negative Outlook assigned to class D primarily reflects
concerns over the possibility of outsized losses on the REO Wyoming
Valley Mall and The Crossroads loan. Fitch ran additional
sensitivity scenarios on these regional malls, and based on the
results, class D could be subject to further downgrades. Outlooks
on the remaining classes are Stable due to overall stable
performance of the majority of the pool and expected continued
amortization. Upgrades, while unlikely, could occur with improved
pool performance and additional paydown or defeasance.

Deutsche Bank is the trustee for the transaction, and also serves
as the backup advancing agent. Fitch's Issuer Default Rating for
Deutsche Bank is currently 'BBB'/'F2'/Evolving. Fitch relies on the
master servicer, Wells Fargo & Company (A+/F1/Stable), which is
currently the primary advancing agent, as a direct counterparty.
Fitch provided ratings confirmation on Dec. 12, 2018.

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.


GSAA HOME 2005-8: Moody's Hikes Rating on Class M-1 Debt to B3(sf)
------------------------------------------------------------------
Moody's Investors Service upgraded the ratings of eighteen tranches
from six transactions, and downgraded the ratings of three tranches
from one transaction, backed by Subprime and Alt-A loans issued by
multiple issuers.

Complete rating actions are as follows:

Issuer: Credit Suisse First Boston Mortgage Securities Corp. Series
2004-1

Cl. M-1, Upgraded to A3 (sf); previously on Jan 9, 2017 Upgraded to
Baa1 (sf)

Cl. M-2, Upgraded to Baa3 (sf); previously on Aug 6, 2018 Upgraded
to Ba2 (sf)

Cl. M-3, Upgraded to Ba2 (sf); previously on Aug 6, 2018 Upgraded
to B1 (sf)

Cl. B-1, Upgraded to Caa1 (sf); previously on Aug 6, 2018 Upgraded
to Caa3 (sf)

Issuer: GSAA Home Equity Trust 2005-8

Cl. M-1, Upgraded to B3 (sf); previously on Jun 28, 2017 Upgraded
to Caa2 (sf)

Issuer: GSAA Trust 2004-3

Cl. AF-4, Upgraded to A3 (sf); previously on Jun 18, 2012
Downgraded to Baa1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2004-HE7

Cl. B-1, Upgraded to Caa2 (sf); previously on Apr 1, 2013 Affirmed
Ca (sf)

Cl. B-2, Upgraded to Ca (sf); previously on Apr 1, 2013 Affirmed C
(sf)

Cl. M-4, Upgraded to B1 (sf); previously on May 24, 2017 Upgraded
to B3 (sf)

Cl. M-5, Upgraded to B3 (sf); previously on Dec 20, 2018 Upgraded
to Caa1 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2004-NC3

Cl. B-1, Upgraded to Caa1 (sf); previously on Dec 20, 2018 Upgraded
to Caa3 (sf)

Cl. B-2, Upgraded to Ca (sf); previously on May 4, 2015 Downgraded
to C (sf)

Cl. M-2, Upgraded to Ba1 (sf); previously on Dec 20, 2018 Upgraded
to Ba3 (sf)

Cl. M-3, Upgraded to B1 (sf); previously on Dec 20, 2018 Upgraded
to B3 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2004-NC7

Cl. B-1, Upgraded to Ca (sf); previously on Feb 28, 2013 Affirmed C
(sf)

Cl. M-3, Upgraded to Ba1 (sf); previously on Dec 20, 2018 Upgraded
to Ba2 (sf)

Cl. M-4, Upgraded to B1 (sf); previously on Dec 20, 2018 Upgraded
to B3 (sf)

Cl. M-5, Upgraded to Caa2 (sf); previously on Dec 20, 2018 Upgraded
to Ca (sf)

Issuer: C-Bass Mortgage Loan Asset Backed Notes, Series 2001-CB4

Cl. IB-1, Downgraded to B2 (sf); previously on Dec 20, 2018
Upgraded to Ba2 (sf)

Cl. IM-1, Downgraded to B1 (sf); previously on Jun 8, 2018 Upgraded
to Baa3 (sf)

Cl. IM-2, Downgraded to B1 (sf); previously on Dec 20, 2018
Upgraded to Ba1 (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to improvement in pool
performances and credit enhancement available to the bonds. The
rating downgrades on C-Bass Mortgage Loan Asset Backed Notes,
Series 2001-CB4 Class IM-1, Class IM-2, and Class IB-1 reflect the
correction of an error. In the December 20, 2018 rating action, the
interest shortfalls for these three tranches were incorrectly not
taken into consideration. The rating action properly reflects the
current outstanding interest shortfalls of $64,192, $48,989 and
$2,618 for Classes IM-1, IM-2 and IB-1, respectively, as well as
the weak performance of the underlying collateral and the erosion
of credit enhancement available to the bonds. The rating actions
also reflect Moody's updated loss expectations on the underlying
pools.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in October 2019 from 3.8% in
October 2018. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2019 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2019. Lower increases than
Moody's expects or decreases could lead to negative rating actions.
Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions.


HERTZ VEHICLE 2019-3: Fitch Assigns BBsf Rating on Cl. D Notes
--------------------------------------------------------------
Fitch Ratings assigned ratings and Rating Outlooks to the four
classes of series 2019-3 ABS notes issued by Hertz Vehicle
Financing II LP.

RATING ACTIONS

Hertz Vehicle Financing II LP, Series 2019-3

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

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

KEY RATING DRIVERS

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

Collateral Analysis - Diverse Vehicle Fleet: HVF II's fleet is
deemed diverse under Fitch's criteria due to the high degree of
manufacturer, model, segment and geographic diversification in the
Hertz, Dollar and Thrifty rental fleets. Concentration limits,
based on a number of characteristics, are present to help mitigate
risks related to overconcentrations. Original Equipment
Manufacturers (OEMs) with PV concentrations in HVF II have all
improved their financial position in recent years and are well
positioned to meet repurchase agreement obligations. As of the
cutoff date, 96.3% of the fleet is from OEMs with an
investment-grade Issuer Default Rating (IDR).

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

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

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

RATING SENSITIVITIES

Fitch's rating sensitivity analysis focuses on two scenarios
involving potentially extreme market disruptions that would force
the agency to redefine its stress assumptions. The first examines
the effect of moving Fitch's bankruptcy/liquidation timing scenario
to eight months at 'AAAsf' with subsequent increases to each rating
level. The second considers the effect of moving the disposition
stresses to the higher end of the range at each rating level for a
diverse fleet. For example, the 'AAAsf' stress level would move to
28% from 24%. Finally, the last example shows the impact of both
stresses on the structure. The purpose of these stresses is to
demonstrate the potential rating impact on a transaction if one or
a combination of these scenarios occurs.

A sufficient increase in either the timing of the liquidation of
the fleet or increases to disposition fees could cause a downgrade
of the class A notes to 'AAsf'. To approach non-investment-grade
rating levels or move down to 'CCCsf', in addition to the combined
scenario described, depreciation costs would need to increase to
previously unseen levels for the platform, increasing at least to
two times the highest monthly depreciation levels seen for both the
program and non-program vehicles at the height of the recession.

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

Fitch was provided with third-party due diligence information from
PricewaterhouseCoopers LLP (PwC). The third-party due diligence
focused on a review of the procedures and related data for 59
vehicles in the pool, including the following areas:

  -- Title, Lien and OEM;

  -- Capital Costs;

  -- Mark-to-Market and Disposition Proceeds.

Fitch considered this information in its analysis, but the findings
had no impact on the ratings.


HORIZON AIRCRAFT I: Fitch Affirms BBsf Rating on Class C Debt
-------------------------------------------------------------
Fitch Ratings affirmed the outstanding notes issued by of Horizon
Aircraft Finance I Limited.

RATING ACTIONS

Horizon Aircraft Finance I Limited

Class A 440405AE8; LT Asf Affirmed;   previously at Asf

Class B 440405AF5; LT BBBsf Affirmed; previously at BBBsf

Class C 440405AG3; LT BBsf Affirmed;  previously at BBsf

KEY RATING DRIVERS

The affirmation of the series A, B and C notes reflects performance
within expectations. Lease cash flows have been in line with
Fitch's base scenarios since close, and the notes are paying as
scheduled. Loan-to-value levels have risen following the recent set
of appraisals conducted in June 2019, but remain below its based
stressed scenarios. Utilization has been 100% and the debt service
coverage ratio is currently at 1.53x as of the November 2019
distribution, well above trigger levels.

Fitch has been monitoring the portfolio activity over the past
eleven months. The majority of aircraft remain on initial leases
and all aircraft were novated into the trust by second-quarter
2019. There have been four new lease transitions to date: three to
Laudamotion, and one to Sundair. Two leases come due in December of
2019, and three more leases come due in 2020.

Cash flow modeling was not completed for this review, as
performance has been within expectations, trigger levels have not
been breached, and the transaction was previously modeled within
the past 18 months, all in line with criteria.

RATING SENSITIVITIES

Due to the correlation between global economic conditions and the
airline industry, the ratings may be affected by the strength of
the macro-environment over the remaining term of this transaction.
Global economic conditions that are inconsistent with Fitch's
expectations and stress parameters could lead to negative rating
actions. In the initial rating analysis, Fitch found the
transaction to have minimal sensitivity to the timing or severity
of assumed recessions.

Fitch also found that greater default probability of the leases
would have a material impact on the ratings. In addition, Fitch
found the timing or degree of technological advancement in the
commercial aviation space and the impacts these changes would have
on values, lease rates, and utilization, would have a moderate
impact on the ratings.

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

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is typically a score of 3 - ESG issues are
credit neutral or have only a minimal credit impact on the
transaction, either due to their nature or the way in which they
are being managed.


JAMESTOWN CLO XIV: Moody's Assigns Ba2 Rating on $14MM Cl. D Notes
------------------------------------------------------------------
Moody's Investors Service assigned ratings to seven classes of
notes issued by Jamestown CLO XIV Ltd..

Moody's rating action is as follows:

US$256,000,000 Class A-1 Senior Secured Floating Rate Notes due
2032 (the "Class A-1 Notes"), Definitive Rating Assigned Aaa (sf)

US$45,500,000 Class A-2 Senior Secured Floating Rate Notes due 2032
(the "Class A-2 Notes"), Definitive Rating Assigned Aa2 (sf)

US$18,000,000 Class B Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class B Notes"), Definitive Rating Assigned A2 (sf)

US$8,000,000 Class C-1 Senior Secured Deferrable Floating Rate
Notes due 2032 (the "Class C-1 Notes"), Definitive Rating Assigned
Baa1 (sf)

US$11,000,000 Class C-2a Senior Secured Deferrable Floating Rate
Notes due 2032 (the "Class C-2a Notes"), Definitive Rating Assigned
Baa3 (sf)

US$5,000,000 Class C-2b Senior Secured Deferrable Fixed Rate Notes
due 2032 (the "Class C-2b Notes"), Definitive Rating Assigned Baa3
(sf)

US$14,500,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class D Notes"), Definitive Rating Assigned Ba2
(sf)

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

RATINGS RATIONALE

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

Jamestown CLO XIV is a managed cash flow CLO. The issued notes will
be collateralized primarily by broadly syndicated senior secured
corporate loans. At least 92.5% of the portfolio must consist of
senior secured loans, cash, and eligible investments, and up to
7.5% of the portfolio may consist of second lien loans and
unsecured loans. The portfolio is approximately 80% ramped as of
the closing date.

Investcorp Credit Management US LLC will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's five year reinvestment period.
Thereafter, subject to certain restrictions, the Manager may
reinvest unscheduled principal payments and proceeds from sales of
credit risk assets.

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

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

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

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

Par amount: $400,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2638

Weighted Average Spread (WAS): 3.10%

Weighted Average Coupon (WAC): 6.50%

Weighted Average Recovery Rate (WARR): 47.0%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

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

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

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


JP MORGAN 2003-CIBC7: Moody's Affirms C Rating on Class J Certs
---------------------------------------------------------------
Moody's Investors Service upgraded the ratings on two classes and
affirmed the ratings on three classes in J.P. Morgan Chase
Commercial Mortgage Securities Corp. Series 2003-CIBC7, Commercial
Pass-Through Certificates, Series 2003-CIBC7 as follows:

Cl. F, Affirmed Aaa (sf); previously on May 17, 2018 Upgraded to
Aaa (sf)

Cl. G, Upgraded to Aaa (sf); previously on May 17, 2018 Upgraded to
Aa3 (sf)

Cl. H, Upgraded to Ba1 (sf); previously on May 17, 2018 Upgraded to
B1 (sf)

Cl. J, Affirmed C (sf); previously on May 17, 2018 Affirmed C (sf)

Cl. X-1*, Affirmed Ca (sf); previously on May 17, 2018 Affirmed Ca
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The rating on the principal and interest class, Cl. F, was affirmed
because the transaction's key metrics, including Moody's
loan-to-value ratio, Moody's stressed debt service coverage ratio
and the transaction's Herfindahl Index (Herf), are within
acceptable ranges.

The ratings on two P&I classes, Cl. G and Cl. H, were upgraded
based primarily on an increase in credit support resulting from
loan paydowns and amortization. The deal has paid down 46% since
Moody's last review.

The rating on the P&I class, Cl. J, was affirmed because the
ratings are consistent with Moody's expected loss plus realized
losses. Class J has already experienced a 47% realized loss as
result of previously liquidated loans.

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

Moody's rating action reflects a base expected loss of 0.2% of the
current pooled balance, compared to 0.3% at Moody's last review.
Moody's base expected loss plus realized losses is now 3.8% of the
original pooled balance, the same as the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the November 12, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $32 million
from $1.39 billion at securitization. The certificates are
collateralized by 26 mortgage loans ranging in size from less than
1% to 13% of the pool, with the top ten loans (excluding
defeasance) constituting 56% of the pool. One loan, constituting
13% of the pool, has an investment-grade structured credit
assessment. Eight loans, constituting 40% of the pool, have
defeased and are secured by US government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 8, the same as at Moody's last review.

Four loans, constituting 9% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Twenty-three loans have been liquidated from the pool, resulting in
an aggregate realized loss of $52 million (for an average loss
severity of 46%). No loans are currently in special servicing.

Moody's received full year 2018 operating results for 95% of the
pool, and partial year 2019 operating results for 38% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 24%, compared to 31% at Moody's last review.
Moody's conduit component excludes loans with structured credit
assessments, defeased and CTL loans, and specially serviced and
troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 26% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.9%.

Moody's actual and stressed conduit DSCRs are 1.53X and 5.01X,
respectively, compared to 1.48X and 5.81X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The loan with a structured credit assessment is the Brown
Noltemeyer Apartments Portfolio Loan ($4.1 million -- 12.7% of the
pool), which is secured by a portfolio of five cross-collateralized
loans secured by eight multifamily properties located in
Louisville, Kentucky. The loans are fully amortizing and have
amortized 90% since securitization. The loan matures in November
2020 and Moody's structured credit assessment and stressed DSCR are
aaa and greater than 4.00X, respectively.

The top three conduit loans represent 27.0% of the pool balance.
The largest loan is the Crestpointe Corporate Center II Loan ($4.1
million -- 12.7% of the pool), which is secured by an approximately
122,000 square foot (SF) office property located in Columbia,
Maryland. As per the March 2019 rent roll, the property was 95%
leased, unchanged from December 2018 and December 2017. The loan is
fully amortizing and has amortized 68% since securitization. The
loan matures in October 2023 and Moody's LTV and stressed DSCR are
32% and 3.25X, respectively.

The second largest loan is the Grande Communications Portfolio Loan
($2.5 million -- 7.7% of the pool), which is secured by a portfolio
of four office properties located throughout Texas. The four
properties are fully leased to Grande Communications. Due to the
single tenant exposure, Moody's value incorporated a lit/dark
analysis. The loan is fully amortizing, has amortized 67% since
securitization and matures in September 2023. Moody's LTV and
stressed DSCR are 18% and greater than 4.00X, respectively.

The third largest loan is the Hopkins Emporia Loan ($2.1 million --
6.6% of the pool), which is secured by a 321,000 SF industrial
property located in Emporia, Kansas. The property serves as the
headquarters for Hopkins Manufacturing Corporation and includes
warehouse and production space on 16.6 acres. Hopkins
Manufacturing's lease expires in December 2020, and the loan
matures in September 2023. Due to the single tenant exposure,
Moody's value incorporated a lit/dark analysis. The loan is fully
amortizing and has amortized 69% since securitization. Moody's LTV
and stressed DSCR are 18% greater than 4.00X, respectively.


JP MORGAN 2007-CIBC20: Fitch Lowers Class E Certs Rating to CCsf
----------------------------------------------------------------
Fitch Ratings downgraded one class and affirmed nine classes of
J.P. Morgan Chase Commercial Mortgage Securities Corp. commercial
mortgage pass-through certificates, series 2007-CIBC20.

RATING ACTIONS

J.P. Morgan Chase Mortgage Securities Trust 2007-CIBC20

Class D 46631QAR3; LT CCsf Affirmed; previously at  CCsf

Class E 46631QAT9; LT Csf Downgrade; previously at  CCsf

Class F 46631QAV4; LT Csf Affirmed;  previously at  Csf

Class G 46631QAX0; LT Csf Affirmed;  previously at  Csf

Class H 46631QAZ5; LT Dsf Affirmed;  previously at  Dsf

Class J 46631QBB7; LT Dsf Affirmed;  previously at  Dsf

Class K 46631QBD3; LT Dsf Affirmed;  previously at  Dsf

Class L 46631QBF8; LT Dsf Affirmed;  previously at  Dsf

Class M 46631QBH4; LT Dsf Affirmed;  previously at  Dsf

Class N 46631QBK7; LT Dsf Affirmed;  previously at  Dsf

KEY RATING DRIVERS

Increasing Loss Expectations/Specially Serviced Loans/Assets:
Fitch's overall loss expectations on the specially serviced
loans/REO assets remain high. Of the remaining pool, six
loans/assets remain, four of which (96% of the pool) are in special
servicing. The largest loan in the pool, Clark Tower (48.3% of the
pool), transferred to special servicing in July 2018 for imminent
default after the loan did not payoff at its previously extended
maturity date in September 2018. The loan had previously been
modified in July 2015 for imminent maturity default. The
modification included an A/B note split, extension of the loan's
maturity and retroactive application of interest only payments. The
trust has currently begun pursuing foreclosure; however, an
injunction by the Borrower has delayed the foreclosure proceedings.
Additionally, the borrower has made affirmative claims against the
trust and litigation is ongoing with an expected trial in 2020.

The remaining specially serviced assets are REO. The largest REO
asset, Holiday Inn - Harrisburg West, is secured by a hotel
consisting of 238 rooms located in Mechanicsburg, PA. The loan was
transferred to special servicing in July 2016 when the borrower
indicated it could no longer support cash flow shortfalls. Per the
special servicer, a foreclosure sale was held on Aug. 8, 2018 and
the deed was recorded Oct. 20, 2018. A receiver was put into place
and a new franchise agreement was signed. The Lodge property (part
of the subject collateral) of 20 rooms was shut down and mothballed
as costs to rehab the rooms is not feasible at this time. Per the
special servicer commentary, the asset was put on the market for
sale and an acceptable offer was accepted by the trust. Fitch
expects the asset to be disposed before year end.

The remaining REO assets, Gannttown (12.6% of the pool) and
Fayetteville Inn - Fayetteville, NC (7.3% of the pool), are both
located in tertiary markets and have suffered declines in occupancy
and performance. Gannttown was transferred to special servicing in
2013 due to imminent payment default and became REO in 2016. As of
Sept. 30, 2019, the property 63% occupied. Property occupancy has
remained low after multiple tenants vacated, including former top
tenant Forman Mills (formerly 41% of the NRA) vacated upon lease
expiration and Blockbuster Video (previously 9% of the NRA) vacated
upon filing for bankruptcy. Per the special servicer, as of June
2019, CBRE became the new leasing agent and is pursuing additional
leasing prospects. Similarly, Fairfield Inn - Fayetteville, NC was
transferred to special servicing and became REO in 2017. Upon
becoming REO, the asset changed flags to a Red Lion after the
Marriott franchise agreement expired. As of the trailing twelve
months (TTM) ended Sept. 30, 2019, the property's occupancy, ADR
and RevPAR were 46.8%, $60 and $28, respectively, compared with its
competitive set of 63.3%, $79 and $50. The special servicer has
indicated that efforts are being made to improve operations,
including possibly changing hotel brands.

Increased Credit Enhancement: Since Fitch's last rating action, two
loans were disposed. The Columbus Corporate Office (previously 14%
of the pool) prepaid in full ahead of its September 2019 maturity
date. Ultra Plaza (previously 8% of the pool) was in foreclosure
and was sold in March 2019 at a 79% loss severity. Losses were
isolated by the class H certificates and interest shortfalls are
currently affecting classes E through NR. Despite the disposition
of the two loans/assets, further improvement is not expected as the
majority of the pool is currently in special servicing and REO.
Only two loans (4% of the pool) are performing, both of which are
fully amortizing, and are only expected to recover 17% of the class
D certificates.

Increased Pool Concentration: The transaction has become highly
concentrated with only six loans/assets remaining, of which four
(96% of the pool) are specially serviced. There are currently
interest shortfalls totaling $19.4 million affecting distressed
classes E thru NR.

RATING SENSITIVITIES

The remaining classes are all distressed and may be subject to
further downgrades given the concentration of specially serviced
assets and additional losses are realized.

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

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. ESG issues are credit neutral
or have only a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by
transaction.


JP MORGAN 2012-C6: Fitch Affirms Bsf Rating on Class H Certs
------------------------------------------------------------
Fitch Ratings affirmed 11 classes of J.P. Morgan Chase Commercial
Mortgage Securities Trust, commercial mortgage pass-through
certificates, series 2012-C6 (JPMCC 2012-C6).

RATING ACTIONS

J.P. Morgan Chase Commercial Mortgage Securities Trust 2012-C6

Class A-3 46634SAC9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 46634SAF2;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 46634SAD7; LT AAAsf Affirmed;  previously at AAAsf

Class B 46634SAG0;    LT AAsf Affirmed;   previously at AAsf

Class C 46634SAH8;    LT A+sf Affirmed;   previously at A+sf

Class D 46634SAJ4;    LT A-sf Affirmed;   previously at A-sf

Class E 46634SAM7;    LT BBB-sf Affirmed; previously at BBB-sf

Class F 46634SAP0;    LT BBB-sf Affirmed; previously at BBB-sf

Class G 46634SAR6;    LT BBsf Affirmed;   previously at BBsf

Class H 46634SAT2;    LT Bsf Affirmed;    previously at Bsf

Class X-A 46634SAE5;  LT AAAsf Affirmed;  previously at AAAsf

The class A-1 and A-2 certificates have paid in full. Fitch does
not rate the interest-only class X-B or class NR certificates.

KEY RATING DRIVERS

Increased Credit Enhancement: The affirmations and the Rating
Outlook revision for class G to Stable from Negative reflect
increased credit enhancement (CE) since the last rating action due
to loan payoffs, increased defeasance and continued amortization.
Since Fitch's last rating action, two loans ($54.6 million) were
repaid prior to their scheduled 2022 maturity date, one of which
was previously considered a Fitch Loan of Concern (FLOC). Three
loans (18.6% of pool) have been defeased, including the largest
loan, 200 Public Square (15.4%). The majority of the pool (28
loans; 89.1% of pool) is currently amortizing. Six loans (10.9%)
are full-term interest-only.

As of the October 2019 distribution date, the pool's aggregate
principal balance has been reduced by 33.9% to $749.5 million from
$1.1 billion at issuance. The pool has experienced $2.9 million
(0.3% of original pool balance) in realized losses since issuance
from the disposition of the 317 6th Avenue loan by discounted
payoff in February 2017.

Stable Performance and Loss Expectations: Fitch's loss expectations
have increased slightly since the last rating action due to higher
expected losses for the FLOCs; however, the increase is partially
offset by the increased CE. The majority of the remaining pool has
continued to exhibit stable performance since issuance, with loss
expectations in line with the prior rating action. Cumulative
interest shortfalls of approximately $49,000 are currently
affecting class NR. There are currently no specially serviced
loans.

High Concentration of Fitch Loans of Concern: Fitch has designated
eight loans (32.3% of pool) as FLOCs, including five top 15 loans
(23.4%). This is an increase from the six loans comprising
approximately 12% of the pool at the last rating action. The
largest FLOC is the second largest loan, Arbor Place Mall (14.3%),
which is secured by a regional mall in Douglasville, GA where the
non-collateral Sears store will be closing in February 2020. The
second FLOC, The Summit Las Colinas (4.2%), is secured by an office
property in Irving, TX with recent occupancy declines from tenants
vacating at lease expiration. The third FLOC, Oak Ridge Office
Portfolio (3.3%), is secured by a seven-building office portfolio
in Oak Ridge, TN that faces significant upcoming lease rollover in
2020, including its largest tenant, and whose occupancy recently
declined after two tenants downsized their spaces. Although
property occupancy for the fourth FLOC, Continental Executive Parke
(3.3%), recently improved from new leasing activity, Fitch
continues to monitor performance and cash flow, and the property is
located in a high vacancy office submarket. The fifth FLOC, 785
Market Street (2.5%), is secured by an office property in downtown
San Francisco where the largest tenant will be vacating at its
January 2020 lease expiration. The other FLOCs outside of the top
15 (combined 4.8%) were flagged for declines in occupancy and cash
flow, upcoming lease rollover and/or the occurrence of a servicing
trigger event.

Alternative Loss Considerations: Fitch's analysis included an
additional sensitivity scenario that factored in the paydown from
the defeased loans and applied increased loss severities on both
the Arbor Place Mall and Northwoods Mall loans to reflect the
potential for outsized losses should the loans have difficulty
refinancing at maturity in 2022. Although overall performance
remains generally stable, Fitch has concerns with the
refinancibility of the two malls. Both malls are sponsored by CBL &
Associates Properties, Inc. (B-/Negative) and have exposure to weak
anchor tenants and overall low inline and/or anchor sales. In
addition to modeling a base case loss, Fitch applied a 25% loss
severity on the maturity balance of the Arbor Place Mall loan given
the upcoming closure of the non-collateral Sears anchor in February
2020, the collateral JCPenney anchor having a lease expiring two
years after loan maturity and overall low anchor sales. Fitch
applied a 15% loss severity on the maturity balance of the
Northwoods Mall loan due to exposure to weaker anchor tenants,
JCPenney rolling two years after loan maturity and low overall
inline sales. The rating affirmations, Rating Outlook revision to
Stable for class G and Negative Rating Outlook maintained on class
H reflect this scenario.

Pool Concentrations: Loans secured by retail properties comprise
42.3% of the current pool by balance and include four of the top 15
loans (28.3%), two of which are secured by regional mall loans
(22.9%) that have the same sponsor, CBL & Associates Properties,
Inc. Loans secured by office properties comprise 18.2% of the
current pool balance, including four of the top 15 loans (12.5%).

Upcoming Maturities: Two loans (5.6% of pool) mature in 2021 and
the remaining 32 loans (94.4%) mature in 2022.

RATING SENSITIVITIES

The Negative Rating Outlook on class H reflects additional
sensitivity analysis and potential downgrade concerns should
performance of the FLOCs continue to deteriorate, or should the
Arbor Place Mall and/or Northwoods Mall loans face difficulty in
refinancing at maturity. The Stable Rating Outlooks for classes A-3
through G reflect increasing CE and expected continued paydown.
Future upgrades will be limited due to the high retail
concentration and limited upcoming loan maturities, but may occur
with improved pool performance and additional paydown or
defeasance.

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.


JP MORGAN 2019-9: Moody's Assigns B3 Rating on 2 Debt Classes
-------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to 34 classes
of residential mortgage-backed securities issued by J.P. Morgan
Mortgage Trust 2019-9. The ratings range from Aaa (sf) to B3 (sf).

The certificates are backed by 998 30-year, fully-amortizing
fixed-rate mortgage loans with a total balance of $680,976,702 as
of the November 1, 2019 cut-off date. Similar to prior JPMMT
transactions, JPMMT 2019-9 includes agency-eligible mortgage loans
(10.13% 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 87% 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, National Association (JPMCB) and United Shore. United Shore
will ultimately be the servicer for majority of the pool (83.44% by
balance) and JPMCB will account for 8.5% by balance. NewRez LLC
f/k/a New Penn Financial, LLC d/b/a Shellpoint Mortgage Servicing
(Shellpoint) will act as interim servicer for the JPMorgan Chase
Bank, National Association (JPMCB) mortgage loans until the
servicing transfer date, which is expected to occur on or about
February 1, 2020, 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, JPMCB, Shellpoint, and
loanDepot.com, LLC 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).
The other servicer, USAA Federal Savings Bank , 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 will be the
master servicer and Citibank, N.A. will be the securities
administrator and Delaware trustee. Pentalpha Surveillance LLC will
be the representations and warranties breach reviewer.
Distributions of principal and interest and loss allocations are
based on a typical shifting interest structure that benefits from
senior and subordination floors.

The complete rating actions are as follows:

Issuer: J.P. Morgan Mortgage Trust 2019-9

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Cl. B-4, Definitive Rating Assigned Ba3 (sf)

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

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

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected loss for this pool in a baseline scenario is 0.70%
and reaches 6.18% at a stress level consistent with its Aaa
ratings.

Moody's calculated losses on the pool using its US Moody's
Individual Loan Analysis model based on the loan-level collateral
information as of the cut-off date. Loan-level adjustments to the
model results included, but were not limited to, adjustments for
origination quality, third-party review scope and results, and the
financial strength of the representation & warranty (R&W)
providers.

Collateral Description

JPMMT 2019-9 is a securitization of a pool of 998 30-year,
fully-amortizing fixed-rate mortgage loans with a total balance of
$680,976,702 as of the cut-off date, with a weighted average
remaining term to maturity of 358 months, and a WA seasoning of
2.08 months. The WA current FICO score is 771 and the WA original
combined loan-to-value ratio is 72.2%. 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 has 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 originator(s)
contributing a significant percentage of the collateral pool (above
10%). As such, for United Shore, Moody's reviewed United Shore's
underwriting guidelines and its policies and documentation (where
available). Additionally, Moody's increased its base case and Aaa
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 87% 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, JPMCB,
Shellpoint and LoanDepot 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
servicer, USAA, will be paid a monthly flat servicing fee equal to
one-twelfth of 0.25% of the remaining principal balance of the
mortgage loans. Shellpoint will act as interim servicer for the
JPMCB mortgage loans until the servicing transfer date, February 1,
2020 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

Three third party review firms, AMC Diligence, LLC (AMC), Clayton
Services LLC (Clayton), 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 loss levels for such loans.

R&W Framework

JPMMT 2019-9'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

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
balance declines, senior bonds are exposed to eroding credit
enhancement over time, and increased performance volatility as a
result. To mitigate this risk, the transaction provides for a
senior subordination floor of 0.75% of the closing pool balance,
and a subordination lock-out amount of 0.60% of the closing pool
balance.

The floors are consistent with the credit neutral floors for the
assigned ratings according to its methodology.

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 RMBS Using the MILAN Framework " published in
October 2019.


JPMBB COMMERCIAL 2016-C1: Fitch Affirms B-sf Rating on Cl. F Certs
------------------------------------------------------------------
Fitch Ratings affirmed 15 classes of JPMBB Commercial Mortgage
Securities Trust 2016-C1 commercial mortgage pass-through
certificates.

RATING ACTIONS

JPMBB 2016-C1

Class A-2 46645LAV9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 46645LAW7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 46645LAX5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-5 46645LAY3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 46645LBD8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 46645LAZ0; LT AAAsf Affirmed;  previously at AAAsf

Class B 46645LBE6;    LT AA-sf Affirmed;  previously at AA-sf

Class C 46645LBF3;    LT A-sf Affirmed;   previously at A-sf

Class D 46645LAG2;    LT BBB-sf Affirmed; previously at BBB-sf

Class D-1 46645LAC1;  LT BBBsf Affirmed;  previously at BBBsf

Class D-2 46645LAE7;  LT BBB-sf Affirmed; previously at BBB-sf

Class E 46645LAJ6;    LT BB-sf Affirmed;  previously at BB-sf

Class F 46645LAL1;    LT B-sf Affirmed;   previously at B-sf

Class X-A 46645LBA4;  LT AAAsf Affirmed;  previously at AAAsf

Class X-D 46645LAA5;  LT BBB-sf Affirmed; previously at BBB-sf

KEY RATING DRIVERS

Stable Performance: The affirmations follow the generally stable
performance of the pool. There have been no material changes to the
pool since issuance; therefore, the original rating analysis was
considered in affirming the transaction.

One loan is in special servicing. The University Parke loan (1.8%)
transferred in July 2018 due to payment default. The loan is
secured by a 468-bed student housing property located in Big
Rapids, MI (approximately one mile from the Ferris State University
campus). Occupancy has dropped to 52% as of November 2019 compared
to 98% at issuance. The borrower and servicer could not reach an
agreement for a loan restructure and a receiver has been appointed
to operate the property. The servicer reports that a sale is
expected in the first quarter of 2020.

Minimal Changes in Credit Enhancement: As of the October 2019
distribution date, the pool's aggregate principal balance has been
reduced by 3.04% to $1.01 billion resulting in minimal increases in
credit enhancement to the senior classes. Eight loans (38.5%),
including five of the largest 15 loans, are full-term interest-only
loans. Additionally, there are nine loans representing 14.4% of the
pool that remain in their partial interest-only period.

Other Considerations:

Property Concentration: The largest property type is office
(36.7%), followed by hotel (22.6%), and multifamily (15%). The
pool's office concentration is above the 2014 vintage average of
22.8% and the 2015 vintage average of 23.5%. And the pool's hotel
concentration is higher than the 2014 vintage concentration of
14.2% and the 2015 vintage average of 17.0%.

Watchlist Loans: There are two loans (5.5%) on the servicer's
watchlist for deferred maintenance and life safety issues. The
U-Haul Portfolio - AREC 11 (5.1%) is secured by 27 self-storage
facilities and the EDC Portfolio (0.5%) is secured by 10
multifamily properties in Chicago, IL. Both loans remain current
and performance has been stable.

RATING SENSITIVITIES

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


MORGAN STANELY 2007-IQ13: Fitch Affirms Dsf Rating on 12 Tranches
-----------------------------------------------------------------
Fitch Ratings affirmed 13 classes of Morgan Stanley Capital I Trust
commercial mortgage pass-through certificates, series 2007-IQ13.

RATING ACTIONS

Morgan Stanley Capital I Trust 2007-IQ13

Class A-J 61753JAG4; LT BBBsf Affirmed; previously at BBBsf

Class B 61753JAK5;   LT Dsf Affirmed;   previously at Dsf

Class C 61753JAL3;   LT Dsf Affirmed;   previously at Dsf

Class D 61753JAM1;   LT Dsf Affirmed;   previously at Dsf

Class E 61753JAN9;   LT Dsf Affirmed;   previously at Dsf

Class F 61753JAP4;   LT Dsf Affirmed;   previously at Dsf

Class G 61753JAQ2;   LT Dsf Affirmed;   previously at Dsf

Class H 61753JAR0;   LT Dsf Affirmed;   previously at Dsf

Class J 61753JAS8;   LT Dsf Affirmed;   previously at Dsf

Class K 61753JAT6;   LT Dsf Affirmed;   previously at Dsf

Class L 61753JAU3;   LT Dsf Affirmed;   previously at Dsf

Class M 61753JAV1;   LT Dsf Affirmed;   previously at Dsf

Class N 61753JAW9;   LT Dsf Affirmed;   previously at Dsf

KEY RATING DRIVERS

Stable Loss Expectations: The pool remains concentrated, with only
seven of the original 176 loans remaining. The majority of the
remaining collateral continues to perform as expected. The largest
driver of losses is from Real Estate Owned (REO) asset. The Neiss
Portfolio initially consisted of three grocery anchored retail
centers two of which have liquidated; the remaining asset is
secured by a 68,000 sf neighborhood retail center anchored by Winn
Dixie (53% NRA; expires May 2021) located in Montgomery, AL. The
property is currently 84.5% occupied. The special servicer intends
to continue leasing up vacant space before disposition.

The remaining assets in the pool are one defeased loan (5.7%),
three loans secured by co-op apartment buildings (37.6%), and two
loans secured by single tenant retail properties (26.3%). Due to
the concentrated nature of the pool, Fitch performed a sensitivity
analysis that grouped the remaining loans based on collateral
quality, performance and perceived likelihood of repayment.

Improving Credit Enhancement: Credit enhancement for class A-J has
improved since Fitch's last rating action due to continued
amortization of the remaining loans, the disposal of one loan that
prepaid with a premium, and proceeds from the sale of one asset
from the Neiss Portfolio. The transaction has paid down nearly 99%,
to $18 million from $1.6 billion at issuance. There have been
$163.6 million (10% of the original pool balance) in realized
losses to date.

RATING SENSITIVITIES

Ratings for class A-J are expected to be stable. Further rating
actions are not expected.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. ESG issues are credit neutral
or only have a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by the
transaction.


MORGAN STANLEY 2005-IQ10: Moody's Affirms C Rating on Cl. F Certs
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on two classes and
upgraded the rating on one class in Morgan Stanley Capital I Trust
2005-IQ10, Commercial Pass-Through Certificates, Series 2005-IQ10
as follows:

Cl. E, Upgraded to A1 (sf); previously on Jul 26, 2018 Upgraded to
A3 (sf)

Cl. F, Affirmed C (sf); previously on Jul 26, 2018 Affirmed C (sf)

Cl. X-Y*, Affirmed Aaa (sf); previously on Jul 26, 2018 Affirmed
Aaa (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The rating Cl. E was upgraded based primarily on an increase in
credit support resulting from loan paydowns and amortization as
well as an increase in defeasance. The deal has paid down 18% since
Moody's last review and nearly 99% since securitization.
Additionally, defeasance increased to 35% of the pool from 24% at
last review.

The rating on Cl. F was affirmed because the rating is consistent
with Moody's expected loss. Class F has already experienced a 52%
realized loss as a result of previously liquidated loans.

The rating on the interest only (IO) class was affirmed based on
the credit quality of its referenced multifamily cooperative
loans.

Moody's rating action reflects a base expected loss of 0.9% of the
current pooled balance, compared to 1.1% at Moody's last review.
Moody's base expected loss plus realized losses is now 5.8% of the
original pooled balance, the same as at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the November 11, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by nearly 99% to $20.1
million from $1.55 billion at securitization. The certificates are
collateralized by nineteen mortgage loans ranging in size from less
than 1% to 13.4% of the pool, with the top ten loans (excluding
defeasance) constituting 59% of the pool. Three loans, constituting
35% of the pool, have defeased and are secured by US government
securities. The pool contains two non-defeased residential
cooperative loans, constituting 5% of the pool, that were too small
to credit assess; however, have Moody's leverage that is consistent
with other loans previously assigned an investment grade Structured
Credit Assessments.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of nine, compared to 12 at Moody's last review.

Ten loans, constituting 35% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Thirteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $89 million (for an average loss
severity of 49%). The are no loans currently in special servicing.

Moody's received full year 2018 operating results for 93% of the
pool (excluding defeased loans). Moody's weighted average conduit
LTV is 56%, compared to 55% at Moody's last review. Moody's conduit
component excludes loans with structured credit assessments,
defeased and CTL loans, and specially serviced and troubled loans.
Moody's net cash flow (NCF) reflects a weighted average haircut of
15% to the most recently available net operating income (NOI).
Moody's value reflects a weighted average capitalization rate of
9.2%.

Moody's actual and stressed conduit DSCRs are 1.28X and 3.41X,
respectively, compared to 1.18X and 2.79X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 32% of the pool balance. The
largest loan is the Walgreens Athens Loan ($2.7 million -- 13.4% of
the pool), which is secured by a single tenant Walgreens store
located in Athens, Georgia. The property is 100% leased to
Walgreens through August 2029. The loan is fully amortizing, having
already amortized 40% since securitization. Moody's LTV and
stressed DSCR are 79% and 1.20X, respectively, compared to 83% and
1.13X at the last review.

The second largest loan is the Heritage Walton Reserve Apartments
Loan ($2.3 million -- 11.6% of the pool), which is secured by a
105-unit multifamily apartment complex located approximately 15
miles west of Atlanta in Austell, Georgia. As of September 2019,
the property was 100% leased, compared to 98% leased as of March
2018. The loan benefits from amortization, having already amortized
24% since securitization, and matures in January 2020. Moody's LTV
and stressed DSCR are 69% and 1.34X, respectively, compared to 76%
and 1.23X at the last review.

The third largest loan is the Hatch Law Firm Loan ($1.3 million --
6.7% of the pool), which is secured by an approximately 41,000
square foot (SF) office property located in Albuquerque, New
Mexico. As of December 2018, the property was 98% occupied by six
tenants. The loan is fully amortizing and has amortized 61% since
securitization. Moody's LTV and stressed DSCR are 41% and 2.59X,
respectively, compared to 40% and 2.61X at the last review.


MORGAN STANLEY 2015-C21: Fitch Affirms B- Rating on Class F Certs
-----------------------------------------------------------------
Fitch Ratings affirms 15 classes of Morgan Stanley Bank of America
Merrill Lynch Trust, commercial mortgage pass-through certificates,
series 2015-C21 (MSBAM 2015-C21).

RATING ACTIONS

MSBAM 2015-C21

Class 555A 61764XBA2; LT BBB-sf Affirmed; previously at BBB-sf

Class A-2 61764XBF1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 61764XBH7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 61764XBJ3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 61764XBL8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 61764XBG9; LT AAAsf Affirmed;  previously at AAAsf

Class B 61764XBM6;    LT AAsf Affirmed;   previously at AAsf

Class C 61764XBP9;    LT A-sf Affirmed;   previously at A-sf

Class D 61764XAN5;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 61764XAQ8;    LT BB-sf Affirmed;  previously at BB-sf

Class F 61764XAS4;    LT B-sf Affirmed;   previously at B-sf

Class PST 61764XBN4;  LT A-sf Affirmed;   previously at A-sf

Class X-A 61764XBK0;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 61764XAA3;  LT AAsf Affirmed;   previously at AAsf

Class X-E 61764XAG0;  LT BB-sf Affirmed;  previously at BB-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The rating affirmations
reflect the majority of the loans in the pool continuing to perform
in line with Fitch's expectations at issuance.

Non-pooled Asset; Stable to Improved Performance: The transaction
contains a $30 million non-pooled senior B note related to 555 11th
NW Street, the second largest loan in the pool. The loan is secured
by an office building in Washington DC. Occupancy has improved to
97% as of second quarter 2019.

Minimal Change to Credit Enhancement: As of the November 2019
distribution date, the pool's aggregate principal balance has been
paid down by 4.7% to $830.6 million from $871.2 million at
issuance. Interest shortfalls are currently impacting class H. At
issuance, the pool was scheduled to amortize by 13.5% of the
original pool balance through maturity. Of the current pool, eight
loans (32.2%) are full-term interest-only, and 31 loans (41.6%) are
partial-term interest-only.

Specially Serviced Loan: The fifth largest loan, Fontainebleau Park
Plaza (5.9%), transferred to special servicing in January 2017 when
the master servicer determined the tenants were not making full
rent and CAM reimbursements into the lockbox. The loan is
collateralized by a 233,334 sf retail center located in Miami, FL
and anchored by Wal-Mart. Though full-year financials have not been
reported since YE 2016, a rent roll from January 2019 indicates
that occupancy has remained stable at 100% and leases accounting
for only 9.4% of the net rentable area (NRA) expire during the loan
term. The special servicer filed suit in November 2017, and
litigation is ongoing.

Fitch Loans of Concern: Eight loans (16.7%) have been designated as
Fitch Loans of Concern (FLOCs), including the specially serviced
loan. Briarwood Office (3.0%) is an office building in the Denver
metro where two tenants (25.2% of NRA) will vacate prior to YE 2019
and the loan has a maturity date in January 2020. Stone Ridge Plaza
(2.3%) is a shopping center in the Rochester metro where Toys R Us
(26.4% of NRA) vacated and the borrower is in the process of
re-tenanting the space. Talbots Flagship Store (1.5%) is a retail
property in Walnut Creek, CA where Talbots (100% of NRA) has a
lease expiration in January 2020 and has not indicated if they plan
to vacate or renew. Smaller FLOCs include a hotel with weaker
performance due to energy sector exposure, several loans with
occupancy declines due to major tenant departures, and a hotel
where the franchise agreement expired in October 2019.

Regional Mall: The largest loan in the pool is the only loan
collateralized by a regional mall. Westfield Palm Desert Mall
(7.3%) is a 977,888 sf regional mall built in 1983, renovated in
2014, and located in Palm Desert, CA. Non-collateral anchors
include Macy's, JC Penney, and Sears. The Sears box, owned by
Seritage Properties is expected to close in early 2020. Overall
performance at the property has remained stable and in line with
Fitch's expectations at issuance. 2Q 2019 occupancy was 86.3% and
the 2Q 2019 DSCR was 2.26x. Per the June 2019 sales report, in-line
sales averaged $418 psf compared to $384 psf in 2018, $380 psf in
2017 and $377 psf in 2015. In addition, the nearest enclosed
regional mall is approximately 60 miles away. The property's main
competitors are a high-end lifestyle center and an outlet mall.

RATING SENSITIVITIES

The Outlook on class F has been revised to Negative from Stable due
to exposure to the FLOCs, including the specially serviced loan. If
performance improves for the Loans of Concern including if the
Briarwood Office is paid in full at maturity and/or if Talbots
chooses to renew at Talbots Flagship Store, then the Outlook could
be revised to Stable. However, continued performance declines in
the Fitch Loans of Concern or the regional mall could result in
downgrades in the future. Upgrades are possible in the future with
improved collateral performance, additional paydown, or
defeasance.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. ESG issues are credit neutral
or have only a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by
transaction.


MORGAN STANLEY 2018-MP: Moody's Affirms Ba3 Rating on Cl. E Certs
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on five classes of
Morgan Stanley Capital I Trust 2018-MP, Commercial Mortgage
Pass-Through Certificates, Series 2018-MP. Moody's rating action is
as follows:

Cl. A, Affirmed Aaa (sf); previously on Aug 9, 2018 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Aug 9, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on Aug 9, 2018 Definitive
Rating Assigned A3 (sf)

Cl. D, Affirmed Baa3 (sf); previously on Aug 9, 2018 Definitive
Rating Assigned Baa3 (sf)

Cl. E, Affirmed Ba3 (sf); previously on Aug 9, 2018 Definitive
Rating Assigned Ba3 (sf)

RATINGS RATIONALE

Moody's has affirmed the ratings on five P&I classes due to the
transaction's key metrics, including Moody's loan-to-value (LTV)
ratio and Moody's stressed debt service coverage ratio (DSCR),
being within acceptable ranges.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the November 14, 2019 distribution date, the transaction's
aggregate certificate balance remains unchanged at approximately
$464 million. The 10-year, fixed rate, interest only whole loan of
$710 million has a split loan structure represented by the trust
loan component of $464 million and companion loan components (BANK
2018-BN14, BANK 2018-BN15, BANK 2019-BN16, and MSC 2018-L1) with an
aggregate balance of $246 million (not included in the trust). The
trust includes A-1, B-1, and C notes. The A-1 and B-1 notes and the
companion loan components are pari passu. The C note is junior to
the trust notes A-1 and B-1 as well as non-trust companion loan
components. In addition, the property is encumbered with an
approximately $280 million of subordinated and non-pooled mezzanine
debt.

The portfolio is comprised of condominium interests in eight Class
A properties all centrally located within top tier gateway markets
(New York, Boston, San Francisco, Washington D.C. and Miami). In
aggregate, the collateral improvements contain 1,549,699 SF of
retail, office and/or parking area. The three New York City
properties represent retail components of luxury apartment
condominiums on Manhattan's Upper West Side. The Boston property
represents the retail and office component of a recently
constructed luxury residential tower in Boston's Downtown Crossing
neighborhood. The remaining four properties represent commercial
condominium components of a related 5-star luxury hotel (two
Ritz-Carlton hotels and two Four Seasons hotels). Except for a
small office/retail building located at 735 Market Street in San
Francisco, all of the properties were developed by the sponsor,
Millennium Partners LLC, within the last 25 years.

As of June 2019, the portfolio's NCF for the first six months of
2019 was $36.7 million compared to 2018 NCF of $72.7 million.
Moody's stabilized NCF remains at $61.9 million, unchanged from
securitization. Moody's LTV and stressed DSCR for the first
mortgage debt amount (including non-trust companion loan
components) are 92% and 0.94X, respectively. The trust has not
experienced any losses of interest shortfalls since securitization.


MORGAN STANLEY 2019-L3: Fitch Assigns B-sf Rating on 2 Tranches
---------------------------------------------------------------
Fitch Ratings assigned the following ratings and Rating Outlooks to
MSC 2019-L3 commercial mortgage pass-through certificates, series
2019-L3:

  -- $11,300,000 class A-1 'AAAsf'; Outlook Stable;

  -- $9,200,000 class A-2 'AAAsf'; Outlook Stable;

  -- $24,600,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $243,051,000 class A-3 'AAAsf'; Outlook Stable;

  -- $426,667,000 class A-4 'AAAsf'; Outlook Stable;

  -- $714,818,000a class X-A 'AAAsf'; Outlook Stable;

  -- $192,746,000a class X-B 'AAAsf'; Outlook Stable;

  -- $94,458,000 class A-S 'AAAsf'; Outlook Stable;

  -- $53,612,000 class B 'AA-sf'; Outlook Stable;

  -- $44,676,000 class C 'A-sf'; Outlook Stable;

  -- $47,229,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $11,488,000ab class X-F 'BB+sf'; Outlook Stable;

  -- $10,212,000ab class X-G 'BB-sf'; Outlook Stable;

  -- $10,211,000ab class X-H 'B-sf'; Outlook Stable;

  -- $26,805,000b class D 'BBBsf'; Outlook Stable;

  -- $20,424,000b class E 'BBB-sf'; Outlook Stable;

  -- $11,488,000b class F 'BB+sf'; Outlook Stable;

  -- $10,212,000b class G 'BB-sf'; Outlook Stable;

  -- $10,211,000b class H 'B-sf'; Outlook Stable.

The following class is not rated by Fitch:

  -- $34,465,361bc class J-RR.

(a) Notional amount and interest-only.

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

(c) Horizontal credit risk retention interest.

The ratings are based on information provided by the issuer as of
Nov. 20, 2019.

Since Fitch published its expected ratings on Nov. 4, 2019, the
balances for class A-3 and class A-4 were finalized. At the time
that the expected ratings were assigned, the exact initial
certificate balances of class A-3 and class A-4 were unknown and
expected to be within the range of $200,000,000 to $315,000,000 and
$354,718,000 to $469,718,000, respectively. The final class
balances for class A-3 and class A-4 are $243,051,000 and
$426,667,000, respectively. Fitch's rating on class X-B has been
updated to 'AAAsf' to reflect the rating of the lowest referenced
tranche whose payable interest has an impact on the interest-only
payments. The classes reflect the final ratings and deal
structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 51 loans secured by 100
commercial properties having an aggregate principal balance of
$1,021,169,362 as of the cut-off date. The loans were contributed
to the trust by Morgan Stanley Mortgage Capital Holdings LLC,
Argentic Real Estate Finance LLC, Starwood Mortgage Capital LLC,
Cantor Commercial Real Estate Lending, L.P. and Key Bank National
Association.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 68.8% of the properties
by balance, cash flow analysis of 79.3% and asset summary reviews
on 100.0% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch loan-to-value of 105.3% is higher
than the 2018 and 2019 YTD average of 102.0% for other Fitch-rated
multiborrower transactions. However, the pool's Fitch debt service
coverage ratio of 1.27x is better than the 2018 and 2019 YTD
averages of 1.22x and 1.24x, respectively.

Above-Average Multifamily Concentration: Loans secured by
multifamily properties represent 36.7% of the pool, which is above
the 2018 and 2019 YTD averages of 11.6% and 13.4%, respectively,
for other Fitch-rated multiborrower transactions. Three of the top
10 loans (East Village Multifamily Portfolio, The Hendry, and
Bushwick Avenue Portfolio) are backed by multifamily properties.
Loans secured by multifamily properties have a lower probability of
default in Fitch's multiborrower model, all else being equal.

Minimal Amortization: The pool has 28 interest-only loans (73.0% of
the pool by balance) and 18 partial interest-only loans (20.1% of
the pool by balance). From securitization to maturity, the pool is
projected to pay down by only 3.7%, which is well-below the 2018
and 2019 YTD averages of 7.2% and 6.1%, respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 8.7% below
the most recent year's NOI for properties for which a full-year NOI
was provided, excluding properties that were stabilizing during
this period. Unanticipated further declines in property-level NCF
could result in higher defaults and loss severities on defaulted
loans and in potential rating actions on the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the MSC
2019-L3 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.


MORGAN STANLEY 2019-MEAD: Moody's Assigns Ba2 Rating on Cl. E Certs
-------------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to six
classes of CMBS securities, issued by Morgan Stanley Capital I
Trust 2019-MEAD, Commercial Mortgage Pass-Through Certificates,
Series 2019-MEAD

Cl. A, Definitive Rating Assigned Aaa (sf)

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

Cl. B, Definitive Rating Assigned Aa2 (sf)

Cl. C, Definitive Rating Assigned A3 (sf)

Cl. D, Definitive Rating Assigned Baa2 (sf)

Cl. E, Definitive Rating Assigned Ba2 (sf)

* Reflects interest-only classes

RATINGS RATIONALE

The Certificates are collateralized by a single loan secured by the
borrower's fee simple interest in the Park Meadows mall, a
1,585,948 SF, two-story enclosed mall located approximately 15.2
miles southeast of the Denver central business district. The
property is anchored by Nordstrom, Dillard's, Macy's, JC Penney and
Dick's Sporting Goods. The Dick's Sporting Goods store is owned by
mall ownership and leased to the retailer. Nordstrom, Dillard's,
Macy's, and JCPenney own their stores and underlying land. Owned
GLA of the subject is calculated to be 762,948 SF and the owned
land area is calculated to be 69.63 acres. Mall shop space consists
of approximately 630,040 SF, inclusive of the food court and
permanent kiosks.

As of September 30, 2019, the Park Meadows Mall was occupied by a
diverse tenant mix of over 130 inline retailers and had a total
mall occupancy of 98.2%, a collateral occupancy of 96.3% (in each
case, including Forever 21) and an in-line occupancy of 95.8%. The
property contains a roster of high profile tenants, including
several first-to-market retailers such as Nordstrom, Tesla, Peloton
and Amazon 4-star. In addition, due to the outdoor culture of the
Denver market, the property presents a strong offering of targeted
outdoor and athleisure tenants such as Lululemon, Athleta and
Orvis.

The loan is a five-year, fixed-rate interest-only, first-lien
mortgage loan with an original and outstanding principal balance of
$615,000,000. Its ratings are based on the credit quality of the
loans and the strength of the securitization structure.

Moody's approach to rating this transaction involved an application
of Moody's Approach to Rating Large Loan and Single Asset/Single
Borrower CMBS and Moody's Approach to Rating Structured Finance
Interest-Only (IO) Securities. The rating approach for securities
backed by a single loan compares the credit risk inherent in the
underlying collateral with the credit protection offered by the
structure. The structure's credit enhancement is quantified by the
maximum deterioration in property value that the securities are
able to withstand under various stress scenarios without causing an
increase in the expected loss for various rating levels. In
assigning single borrower ratings, Moody's also considers a range
of qualitative issues as well as the transaction's structural and
legal aspects.

The credit risk of loans is determined primarily by two factors: 1)
Moody's assessment of the probability of default, which is largely
driven by each loan's DSCR, and 2) Moody's assessment of the
severity of loss upon a default, which is largely driven by each
loan's LTV ratio.

The trust loan balance of $615,000,000 represents a Moody's LTV of
90.6%. The Moody's loan trust actual DSCR is 2.60x and Moody's loan
trust stressed DSCR at a 9.25% stressed constant is 0.89x. The
Moody's LTV including the non-trust mezzanine loan of $85,000,000
is 103.1%.

Notable strengths of the transaction include the asset's operating
performance, inline sales productivity, anchor sales, rollover
profile, and strong sponsorship. Offsetting these strengths are a
lack of asset diversification, the interest-only mortgage loan
profile, retail competition in the market, interest-only mortgage
loan profile, and credit negative legal features.

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 approach for single borrower and large loan multi-borrower
transactions evaluates credit enhancement levels based on an
aggregation of adjusted loan level proceeds derived from its
Moody's loan level LTV ratios. Major adjustments to determining
proceeds include leverage, loan structure, and property type. These
aggregated proceeds are then further adjusted for any pooling
benefits associated with loan level diversity, other concentrations
and correlations.

These ratings: (a) are based solely on information in the public
domain and/or information communicated to Moody's by the issuer at
the date it was prepared and such information has not been
independently verified by Moody's; (b) must be construed solely as
a statement of opinion and not a statement of fact or an offer,
invitation, inducement or recommendation to purchase, sell or hold
any securities or otherwise act in relation to the issuer or any
other entity or in connection with any other matter. Moody's does
not guarantee or make any representation or warranty as to the
correctness of any information, rating or communication relating to
the issuer. Moody's shall not be liable in contract, tort,
statutory duty or otherwise to the issuer or any other third party
for any loss, injury or cost caused to the issuer or any other
third party, in whole or in part, including by any negligence (but
excluding fraud, dishonesty and/or willful misconduct or any other
type of liability that by law cannot be excluded) on the part of,
or any contingency beyond the control of Moody's, or any of its
employees or agents, including any losses arising from or in
connection with the procurement, compilation, analysis,
interpretation, communication, dissemination, or delivery of any
information or rating relating to the issuer.

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

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range may
indicate that the collateral's credit quality is stronger or weaker
than Moody's had previously anticipated. Factors that may cause an
upgrade of the ratings include significant loan paydowns or
amortization, an increase in the pool's share of defeasance or
overall improved pool performance. Factors that may cause a
downgrade of the ratings include a decline in the overall
performance of the pool, loan concentration, increased expected
losses from specially serviced and troubled loans or interest
shortfalls.

Moody's ratings address only the credit risks associated with the
transaction. Other non-credit risks have not been addressed and may
have a significant effect on yield to investors.


NATIONSTAR HECM 2019-2: Moody's Assigns B3 Rating on Cl. M4 Certs
-----------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to five
classes of residential mortgage-backed securities issued by
Nationstar HECM Loan Trust 2019-2 (NHLT 2019-2). The ratings range
from Aaa (sf) to B3 (sf).

The certificates are backed by a pool that includes 1,128 inactive
home equity conversion mortgages and 167 real estate owned
properties. The servicer for the deal is Nationstar Mortgage LLC.
The complete rating actions are as follows:

Issuer: Nationstar HECM Loan Trust 2019-2

Cl. A, Assigned Aaa (sf)

Cl. M1, Assigned Aa3 (sf)

Cl. M2, Assigned A3 (sf)

Cl. M3, Assigned Baa3 (sf)

Cl. M4, Assigned B3 (sf)

RATINGS RATIONALE

The collateral backing NHLT 2019-2 consists of first-lien inactive
HECMs covered by Federal Housing Administration (FHA) insurance
secured by properties in the US along with Real-Estate Owned (REO)
properties acquired through conversion of ownership of reverse
mortgage loans that are covered by FHA insurance. If a borrower or
their estate fails to pay the amount due upon maturity or otherwise
defaults, the sale of the property is used to recover the amount
owed. Nationstar acquired the mortgage assets from Ginnie Mae
sponsored HECM mortgage backed (HMBS) securitizations. All of the
mortgage assets are covered by FHA insurance for the repayment of
principal up to certain amounts.

There are 1,295 mortgage assets with a balance of $353,148,906. The
assets are in either default, due and payable, referred,
foreclosures or REO status. Loans that are in default may move to
due and payable; due and payable loans may move to foreclosure; and
foreclosure loans may move to REO. 18.7% of the assets are in
default of which 0.1% (of the total assets) are in default due to
non-occupancy and the remaining are in default due to delinquent
taxes and insurance and HOA. 16.5% of the assets are due and
payable, 49.0% of the assets are in foreclosure and 2.4% of the
assets are in pre-foreclosure liquidated status. Finally, 13.3% of
the assets are REO properties and were acquired through foreclosure
or deed-in-lieu of foreclosure on the associated loan. If the value
of the related mortgaged property is greater than the loan amount,
some of these loans may be settled by the borrower or their
estate.

The collateral composition of NHLT 2019-2 is different from that of
NHLT 2019-1 in several key respects. First, NHLT 2019-2 has a lower
percentage of loans in default status and a higher percentage of
loans in foreclosure status. In addition, a relatively large
percentage of the collateral in NHLT 2019-2 is inactive due to
death or non-occupancy (21.6% which is comparable to 23.0% in
2019-1 but higher than 17.1% in NHLT 2018-3). Furthermore, the
weighted average loan-to-value ratio based on most recent appraisal
value, at 132.8%, is higher than most NHLT transactions Moody's has
rated. This implies that borrowers in this pool tend to have less
equity in their homes compared to in prior transactions which may
lead to lower cure and repayment rates.

As with most NHLT transactions Moody's has rated, the pool has a
significant concentration of mortgage assets backed by properties
in New York, Florida and New Jersey. Such states are judicial
foreclosure states with long foreclosure timelines. Also, there are
13 assets (0.5% of the asset balance) in NHLT 2019-2 that are
backed by properties in Puerto Rico, which is still recovering from
Hurricane Maria and suffering from poor economic conditions due to
a public debt crisis and continued out-migration. Its credit
ratings reflect state-specific foreclosure timeline stresses.

Nationstar has noted that there are no damaged properties in the
pool. In addition, there are property level representations &
warranties that no mortgaged property has suffered damages due to
fire, flood, windstorm, earthquake, tornado, hurricane, or any
other damages.

Transaction Structure

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

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

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

Certain aspects of the waterfall are dependent upon Nationstar
remaining as servicer. Servicing fees and servicer related
reimbursements are subordinated to interest and principal payments
while Nationstar is servicer. However, servicing advances will
instead have priority over interest and principal payments in the
event that Nationstar defaults and a new servicer is appointed.

Third-Party Review

A third party firm conducted a review of certain characteristics of
the mortgage assets on behalf of Nationstar. The review focused on
data integrity, FHA insurance coverage verification, accuracy of
appraisal recording, accuracy of occupancy status recording,
borrower age documentation, identification of excessive corporate
advances, documentation of servicer advances, and identification of
tax liens with first priority in Texas. Also, broker price opinions
(BPOs) were ordered for 154 properties in the pool.

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

The results of the third-party review (TPR) are comparable to
previous NHLT transactions in many respects. However, the number of
exceptions related to the accuracy of reported valuations, and
foreclosure and bankruptcy attorney fees is similar to what was
observed in NHLT 2019-1 transaction. NHLT 2019-2's TPR results
showed an 20.7% initial-tape exception rate related to the accuracy
of reported valuations and a 39.07% initial-tape exception rate
related to foreclosure and bankruptcy attorney fees. In its
analysis of the pool, Moody's applied adjustments to account for
the TPR results in certain areas.

Reps & Warranties (R&W)

Nationstar is the loan-level R&W provider and is rated B2
(Negative). This relatively weak financial profile is mitigated by
the fact that Nationstar will subordinate its servicing advances,
servicing fees, and MIP payments in the transaction and thus has
significant alignment of interests. Another factor mitigating the
risks associated with a financially weak R&W provider is that a
third-party due diligence firm conducted a review on the loans for
evidence of FHA insurance.

Nationstar represents that the mortgage loans are covered by FHA
insurance that is in full force and effect. Nationstar provides
further R&Ws including those for title, first lien position,
enforceability of the lien, and the condition of the property.
Although Nationstar provides a no fraud R&W covering the
origination of the mortgage loans, determination of value of the
mortgaged properties, and the sale and servicing of the mortgage
loans, the no fraud R&W is made only as to the initial mortgage
loans. Aside from the no fraud R&W, Nationstar does not provide any
other R&W in connection with the origination of the mortgage loans,
including whether the mortgage loans were originated in compliance
with applicable federal, state and local laws. Although certain
representations are knowledge qualified, the transaction documents
contain language specifying that if a representation would have
been breached if not for the knowledge qualifier then Nationstar
will repurchase the relevant asset as if the representation had
been breached.

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

When analyzing the transaction, Moody's reviewed the transaction's
exposure to large potential indemnification payments owed to
transaction parties due to potential lawsuits. In particular,
Moody's assessed the risk that the acquisition trustee would be
subject to lawsuits from investors for a failure to adequately
enforce the R&Ws against the seller. Moody's believes that NHLT
2019-2 is adequately protected against such risk in part because a
third-party data integrity review was conducted on a significant
random sample of the loans. In addition, the third-party due
diligence firm verified that all of the loans in the pool are
covered by FHA insurance.

Trustee

The acquisition and owner trustee for the NHLT 2019-2 transaction
is Wilmington Savings Fund Society, FSB. The paying agent and cash
management functions will be performed by U.S. Bank National
Association. U.S. Bank National Association will also serve as the
claims payment agent and as such will be the HUD mortgagee of
record for the mortgage assets in the pool.

Methodology

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

Its quantitative asset analysis is based on a loan-by-loan modeling
of expected payout amounts given the structure of FHA insurance and
with various stresses applied to model parameters depending on the
target rating level.

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

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

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

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

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

Liquidation process: each mortgage asset is categorized into one of
four categories: default, due and payable, foreclosure and REO. In
its analysis, Moody's assumes loans that are in referred status to
be either in foreclosure or REO category. The loans are assumed to
move through each of these stages until being sold out of REO.
Moody's assumed that loans would be in default status for six
months. Due and payable status is expected to last six to 12 months
depending on the default reason. Foreclosure status is based on the
state in which that the related property is located and is further
stressed at higher rating levels. The base case foreclosure
timeline is based on FHA timeline guidance. REO disposition is
assumed to take place in six months with respect to SBCs and 12
months with respect to ABCs.

Debenture interest: the receipt of debenture interest is dependent
upon performance of certain actions within certain timelines by the
servicer. If these timeline and performance benchmarks are not met
by the servicer, debenture interest is subject to curtailment. Its
base case assumption is that 95.0% of debenture interest will be
received by the trust. Moody's stressed the amount of debenture
interest that will be received at higher rating levels. Its
debenture interest assumptions reflect the requirement that
Nationstar (B2, Negative) reimburse the trust for debenture
interest curtailments due to servicing errors or failures to comply
with HUD guidelines.

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

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

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

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

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

Moody's ran additional stress scenarios that were designed to mimic
expected cash flows in the case where Nationstar is no longer the
servicer. Moody's assumes the following in the situation where
Nationstar is no longer the servicer:

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

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

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

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

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

Up

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

Down

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


NEW RESIDENTIAL 2019-6: Moody's Gives (P)Ba3 Rating on 4 Tranches
-----------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to 32
classes of notes issued by New Residential Mortgage Loan Trust
2019-6. The NRMLT 2019-6 transaction is a $506 million
securitization of 4,681 first lien, seasoned performing and
re-performing fixed-rate mortgage loans with weighted average
seasoning of 188 months, a weighted average updated LTV ratio of
50.8% and a non-zero weighted average updated FICO score of 667.
Based on the OTS methodology, 74.2% of the loans by scheduled
balance have been continuously current for the past 24 months.
Approximately 61.9% of the loans in the pool (by scheduled balance)
have been previously modified. PHH Mortgage Corporation (PHH
Mortgage), Mr. Cooper Group Inc and Select Portfolio Servicing,
Inc. and Shellpoint Mortgage Servicing are the four servicers who
will service approximately 62.9%, 29.3%, 5.7% and 2.0% of the loans
(by scheduled balance), respectively. Nationstar Mortgage LLC
(Nationstar) will act as master servicer and successor servicer and
Shellpoint will act as the special servicer.

The complete rating action is as follows:

Issuer: New Residential Mortgage Loan Trust 2019-6

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

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

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

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

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

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

Cl. A-2, Provisional Rating Assigned (P)Aa1 (sf)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Cl. B-7, Provisional Rating Assigned (P)B2 (sf)

RATINGS RATIONALE

Its losses on the collateral pool equal 9.00% in an expected
scenario and reach 33.75% at a stress level consistent with the Aaa
ratings on the senior classes. Moody's based its expected losses
for 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 final expected losses for the pool
reflect the third-party review (TPR) findings and its assessment of
the representations and warranties (R&Ws) framework for this
transaction. Also, the transaction contains a mortgage loan sale
provision, the exercise of which is subject to potential conflicts
of interest. As a result of this provision, Moody's increased its
expected losses for the pool.

To estimate the losses on the pool, Moody's used an approach
similar to its surveillance approach. Under this approach, Moody's
applies expected annual delinquency rates, conditional prepayment
rates (CPRs), loss severity rates and other variables to estimate
future losses on the pool. Its assumptions on these variables are
based on the observed performance of seasoned modified and
non-modified loans, the collateral attributes of the pool including
the percentage of loans that were delinquent in the past 36 months.
For this pool, Moody's used default burnout assumptions similar to
those detailed in its "US RMBS Surveillance Methodology" for Alt-A
loans originated pre-2005. Moody's then aggregated the
delinquencies and converted them to losses by applying
pool-specific lifetime default frequency and loss severity
assumptions.

Collateral Description

NRMLT 2019-6 is a securitization of 4,681 seasoned performing and
re-performing fixed-rate residential mortgage loans which the
seller, NRZ Sponsor IX LLC, has purchased in connection with the
termination of various securitization trusts. Similar to prior
NRMLT transactions Moody's has rated, nearly all of the collateral
was sourced from terminated securitizations. Approximately 61.9% of
the loans had previously been modified.

The updated value of properties in this pool were provided by a
third-party firm using a home data index (HDI) and/or an updated
broker price opinion (BPO). BPOs were provided for a sample of
1,301 out of the 4,681 properties contained within the
securitization. HDI values were provided for all but two properies
contained within the securitization. The weighted average updated
LTV ratio on the collateral is 50.8%, implying an average of 49.2%
borrower equity in the properties.

Third-Party Review and Representations & Warranties

Two third-party due diligence providers, AMC and Recovco, conducted
a regulatory compliance review on a sample of 545 and 1,394
seasoned mortgage loans respectively for the initial due diligence
pool. The regulatory compliance review consisted of a review of
compliance with the federal Truth in Lending Act (TILA) as
implemented by Regulation Z, the federal Real Estate Settlement
Procedures Act (RESPA) as implemented by Regulation X, the
disclosure requirements and prohibitions of Section 50(a)(6),
Article XVI of the Texas Constitution, federal, state and local
anti-predatory regulations, federal and state specific late charge
and prepayment penalty regulations, and document review.

AMC found that 116 out of 545 loans had compliance exceptions with
rating agency grade C or D. Recovco reviewed 1,394 loans and 179
loans have ratings of C or D. Based on its analysis of the TPR
reports, Moody's determined that a portion of the loans with some
cited violations are at enhanced risk of having violated TILA
through an under-disclosure of the finance charges or other
disclosure deficiencies. Although the TPR report indicated that the
statute of limitations for borrowers to rescind their loans has
already passed, borrowers can still raise these legal claims in
defense against foreclosure as a set off or recoupment and win
damages that can reduce the amount of the foreclosure proceeds.
Such damages include up to $4,000 in statutory damages, borrowers'
legal fees and other actual damages. Moody's increased its losses
for these loans to account for such damages.

AMC and Recovco reviewed the findings of various title search
reports covering 269 and 987 mortgage loans respectively in the
preliminary sample population in order to confirm the first lien
position of the related mortgages. Overall, AMC's review confirmed
that 157 mortgages were in first lien position. For the 112
remaining loans reviewed by AMC, for 16 mortgage loans the final
title policy at loan origination was accepted to be proof of a
first lien position and two loans had pending searches. Loans with
pending searches were dropped from the pool. Recovco reported that
the 967 out of 987 mortgage loans it reviewed were in first-lien
position. For 6 mortgage loans, the final title policy was used to
verify the first lien and for 20 other mortgage loans the results
were pending. All loans with pending searches were dropped from the
pool. The seller, NRZ Sponsor IX LLC, is providing a representation
and warranty for missing mortgage files. To the extent that the
master servicer, related servicer or depositor has actual
knowledge, or a responsible officer of the Indenture Trustee has
received written notice, of a defective or missing mortgage loan
document or a breach of a representation or warranty regarding the
completeness of the mortgage file or the accuracy of the mortgage
loan documents, and such missing document, defect or breach is
preventing or materially delaying the (a) realization against the
related mortgaged property through foreclosure or similar loss
mitigation activity or (b) processing of any title claim under the
related title insurance policy, the party with such actual
knowledge will give written notice of such breach, defect or
missing document, as applicable, to the seller, indenture trustee,
depositor, master servicer and related servicer. Upon notification
of a missing or defective mortgage loan file, the seller will have
120 days from the date it receives such notification to deliver the
missing document or otherwise cure the defect or breach. If it is
unable to do so, the seller will be obligated to replace or
repurchase the mortgage loan.

Trustee, Custodians, Paying Agent, Servicers, Master Servicer,
Successor Servicer and Special Servicer

The transaction indenture trustee is Wilmington Trust, National
Association. The custodian functions will be performed by Wells
Fargo Bank, N.A and U.S. Bank National Association. The paying
agent and cash management functions will be performed by Citibank,
N.A. In addition, Nationstar, as master servicer, is responsible
for servicer oversight, termination of servicers, and the
appointment of successor servicers. Having Nationstar as a master
servicer mitigates servicing-related risk due to the performance
oversight that it will provide. Shellpoint will serve as the
special servicer and, as such, will be responsible for servicing
mortgage loans that become 60 or more days delinquent. Nationstar
will serve as the designated successor servicer.

PHH Mortgage Corporation (PHH Mortgage), Mr Cooper, Select
Portfolio Servicing, Inc. (SPS) and Shellpoint Mortgage Servicing
(Shellpoint) are the four servicers who will service approximately
62.9%, 29.3%, 5.7% and 2.0% of the loans (by scheduled balance),
respectively. Moody's considers the overall servicing arrangement
to be adequate.

Transaction Structure

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to increasingly receive principal
prepayments after an initial lock-out period of five years,
provided two performance tests are met. To pass the first test, the
delinquent and recently modified loan balance cannot exceed 50% of
the subordinate bonds outstanding. To pass the second test,
cumulative losses cannot exceed certain thresholds that gradually
increase over time.

Because a shifting interest structure allows subordinated bonds to
pay down over time as the loan pool shrinks, senior bonds are
exposed to tail risk, i.e., risk of back-ended losses when fewer
loans remain in the pool. The transaction provides for a senior and
subordination floor that helps to reduce this tail risk.
Specifically, the subordination floor prevents subordinate bonds
from receiving any principal if the amount of subordinate bonds
outstanding falls below 9.00% of the cut-off date principal
balance. There is also a provision that prevents subordinate bonds
from receiving principal if the credit enhancement for the Class
A-1 note falls below its percentage at closing, 35.60%. In
addition, there are provisions that "lock out" certain subordinate
bonds and allocate principal to more senior subordinate bonds if,
for a given class, credit enhancement levels decline below their
initial percentages or below 9.00% of the cut-off date principal
balance. These provisions have been incorporated into its cash flow
model and are reflected in its ratings

Other Considerations

The transaction contains a mortgage loan sale provision, the
exercise of which is subject to potential conflicts of interest.
The servicers in the transaction may sell mortgage loans that
become 60 or more days delinquent according to the MBA methodology
to any party in the secondary market in an arms-length transaction
and at a fair market value. For such sale to take place, the
related servicer must determine, in its reasonable commercial
judgment, that such sale would maximize proceeds on a present value
basis. If the sponsor or any of its subsidiaries is the purchaser,
the related servicer must obtain at least two additional
independent bids. The transaction documents provide little detail
on the method of receipt of bids and there is no set minimum sale
price. Such lack of detail creates a risk that the independent bids
could be weak bids from purchasers that do not actively participate
in the market. Furthermore, the transaction documents provide
little detail regarding how servicers should conduct present value
calculations when determining if a note sale should be pursued. The
special servicer, Shellpoint, is an affiliate of the sponsor. The
servicers in the transaction may have a commercial relationship
with the sponsor outside of the transaction. These business
arrangements could lead to conflicts of interest. Moody's took this
into account and adjusted its losses accordingly.

When analyzing the transaction, Moody's reviewed the transaction's
exposure to large potential indemnification payments owed to
transaction parties due to potential lawsuits. In particular,
Moody's assessed the risk that the indenture trustee would be
subject to lawsuits from investors for a failure to adequately
enforce the R&Ws against the seller. Moody's believes that NRMLT
2019-6 is adequately protected against such risk primarily because
the loans in this transaction are highly seasoned with a weighted
average seasoning of approximately 190 months. Although some loans
in the pool were previously delinquent and modified, the loans all
have a substantial history of payment performance. This includes
payment performance during the last recession. As such, if loans in
the pool were materially defective, such issues would likely have
been discovered prior to the securitization. Furthermore, third
party due diligence was conducted on a significant random sample of
the loans for issues such as data integrity, compliance, and title.
As such, Moody's did not apply adjustments in this transaction to
account for indemnification payment risk.

In addition, prior to closing, the collateral pool has
approximately $1,857,986 of unreimbursed servicing advances such as
taxes and insurance. The mortgage borrower is responsible for
reimbursing the related servicer for the pre-existing servicing
advances. The related servicer may choose to set the pre-existing
advances as escrow to be repaid by the borrower as part of monthly
mortgage payments. However, in the event the borrower defaults on
the mortgage prior to fully repaying the pre-existing servicing
advances, the related servicer will recoup the outstanding amount
of pre-existing advances from the loan liquidation proceeds. The
amount of pre-existing servicing advances only represents
approximately 20 basis points of total pool balance. As borrowers
make monthly mortgage payments, this amount would likely decrease.
Moreover, its loan loss severity assumption incorporates
reimbursement of servicing advances from liquidation proceeds.

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

Up

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

Down

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

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.


PALISADES CENTER 2016-PLSD: Moody's Cuts Cl. D Certs Rating to Ba3
------------------------------------------------------------------
Moody's Investors Service affirmed the rating of the most senior
class and downgraded the ratings of three classes in Palisades
Center Trust 2016-PLSD, Commercial Mortgage Pass-Through
Certificates, Series 2016-PLSD as follows:

Cl. A, Affirmed Aaa (sf); previously on Jul 20, 2018 Affirmed Aaa
(sf)

Cl. B, Downgraded to A2 (sf); previously on Jul 20, 2018 Affirmed
Aa3 (sf)

Cl. C, Downgraded to Baa3 (sf); previously on Jul 20, 2018
Downgraded to Baa1 (sf)

Cl. D, Downgraded to Ba3 (sf); previously on Jul 20, 2018
Downgraded to Ba1 (sf)

RATINGS RATIONALE

The rating on Cl. A was affirmed because the transaction's key
metrics, including Moody's loan-to-value (LTV) ratio and Moody's
stressed debt service coverage ratio (DSCR), are within acceptable
ranges.

The ratings on three classes, Cl. B, Cl. C and Cl. D, were
downgraded due to an increase in Moody's LTV as a result of a
decline in performance, recent additional store closures
announcements and increased competition.

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 would lead to an upgrade of the ratings include a
significant amount of loan paydowns or amortization, an increase in
defeasance or an improvement in loan performance.

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the November 15, 2019 payment date, the transaction's
aggregate certificate balance remains unchanged since
securitization at approximately $389 million. The whole loan of
$419 million has a split loan structure represented by the trust
loan component of $389 million and a companion loan component of
$30 million (not included in the trust) that is securitized in
JPMDB 2016-C2 . The trust includes notes A, B, C and D. The $229
million senior trust A note and the $30 million companion loan
component securitized in JPMDB 2016-C2 are pari passu. The trust
notes B, C and D are junior to the trust note A and the companion
loan component. Additionally, there is $142 million of mezzanine
debt held outside the trust. The five-year, fixed-rate mortgage
loan matures in April 2021.

The Palisades Center is located approximately 3.5 miles northwest
of the Tappan Zee Bridge and 18 miles northwest of New York City.
The property is managed by the loan's sponsor, Pyramid Management
Group, LLC, a privately held real estate management and development
company headquartered in Syracuse, New York.

The Palisades Center contains seven occupied anchors comprised of
Macy's (201,000 SF), Home Depot (132,800 SF), Target (130,140 SF),
Lord & Taylor (120,000 SF), BJ's Wholesale Club (118,076 SF),
Dick's Sporting Goods (94,745 SF) and Burlington Coat Factory
(54,609 SF). Anchor collateral for the loan does not include the
Lord & Taylor and Macy's spaces. Other larger collateral tenants
include a 21-screen AMC Palisades Center Cinema, Barnes and Noble,
Best Buy, Dave and Busters, Bed Bath & Beyond, DSW, Autobahn Indoor
Speedway and New York Sports Club.

The property's revenue and net cash flow (NCF) have continued to
decline since securitization. In July 2017, JC Penney, a collateral
anchor, closed and vacated their three-level, 157,000 SF anchor
space, and the space remains vacant. JC Penney continued to pay
rent through their lease expiration in March 2018. In addition,
Lord & Taylor (not part of the collateral) and Bed Bath and Beyond
(45,000 SF with lease expiring in January 2022) announced plans to
close their respective stores at the center in 2020. Management
indicated that they are in discussions to re-tenant the former JC
Penney space.

The subject's primary trade area includes sections from three
densely populated and affluent counties of the New York MSA:
Rockland County, Westchester County, and Bergen County. Moody's
identifies Garden State Plaza and Shops at Nanuet as significant
competitors. The property draws substantial Sunday traffic from the
nearby residence of New Jersey's Bergen County due to the county's
highly restrictive "Blue Laws". These Blue Laws restrict retail
operations on Sunday in Bergen County. Furthermore, the property
may face additional competition from the American Dream
development, a 2.9 million SF retail and entertainment complex,
located approximately 25 miles south of the property in East
Rutherford, New Jersey. The American Dream had a soft opening in
October 2019.

The property's NCF for 2018 was $40.5 million, and just shy of
$18.0 million during the first half of 2019. Moody's NCF is $37.9
million. Moody's loan to value (LTV) ratio for the first mortgage
loan is 97%, compared to 85% at last review and reflects a decrease
in Moody's stabilized NCF and an increase in Moody's capitalization
rate. Moody's stressed debt service coverage ratio (DSCR) for the
first mortgage loan is 0.98X compared to 1.08X at the last review.
The trust has not experienced any losses or interest shortfalls
since securitization.


SECURITIZED TERM 2019-CRT: Moody's Rates $27.7MM Class D Notes Ba1
------------------------------------------------------------------
Moody's Investors Service assigned definitive ratings of Aa1(sf) to
the Class B notes, A2(sf) to Class C notes, and Ba1(sf) to Class D
notes issued by Securitized Term Auto Receivables Trust 2019-CRT.
This is the seventh term auto loan-backed transaction sponsored by
The Bank of Nova Scotia. The notes are collateralized by a pool of
retail automobile loan contracts originated by BNS.

The complete rating actions are as follows:

Issuer: Securitized Term Auto Receivables Trust 2019-CRT

$37,865,000, 2.453%, Class B Notes, Definitive Rating Assigned Aa1
(sf)

$37,865,000, 2.849%, Class C Notes, Definitive Rating Assigned A2
(sf)

$27,770,000, 4.572%, Class D Notes, Definitive Rating Assigned Ba1
(sf)

RATINGS RATIONALE

The ratings are primarily based on an analysis of the credit
quality of the collateral pool, the servicing ability of BNS, and
the level of credit enhancement available under the proposed
capital structure.

Moody's expected median cumulative net credit loss for START
2019-CRT is 2.00% and total credit enhancement (including excess
spread credit) required to achieve the Aaa (sf) rating is 10.0%.
The cumulative net loss expectation and loss at a Aaa stress are
higher than previously rated 2019-1 transaction due to relatively
weaker collateral pool characteristics given the higher percentage
of longer term loans, the higher proportion of used vehicles and
inclusion of only non-subvened loans. Moody's based its cumulative
net loss expectation and loss at a Aaa stress on an analysis of the
credit quality of the underlying collateral; the historical
performance of similar collateral, including securitization
performance and BNS's owned and managed non-subvened book
performance; the ability of BNS to perform the servicing functions;
and current expectations for the macroeconomic environment during
the life of the transaction.

At closing, the Class B notes, Class C notes, and Class D notes
notes will benefit from 6.75%, 3.00% and 0.25% of hard credit
enhancement, respectively. Hard credit enhancement for the notes
consists of subordination and a non-declining reserve account
except for Class D which does not benefit from subordination. The
notes will also benefit from excess spread.

PRINCIPAL METHODOLOGY

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

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

Up

Moody's could upgrade the Class B, Class C, and/or Class D notes if
levels of credit protection are higher than necessary to protect
investors against current expectations of portfolio losses. 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 vehicles securing an obligor's promise of payment. Transaction
performance also depends greatly on the Canadian job market and the
market for used vehicles. Other reasons for better-than-expected
performance include changes to servicing practices that enhance
collections or refinancing opportunities that result in
prepayments.

Down

Moody's could downgrade the Class B, Class C, and/or Class D notes
if levels of credit protection are insufficient to protect
investors against current expectations of portfolio losses. 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 vehicles securing an obligor's promise of payment. Transaction
performance also depends greatly on the Canadian job market and the
market for used vehicles. Other reasons for worse-than-expected
performance include poor servicing, error on the part of
transaction parties, inadequate transaction governance and fraud.


SEQUOIA MORTGAGE 2019-5: Fitch Assigns BB- Rating on Cl. B-4 Certs
------------------------------------------------------------------
Fitch Ratings assigned ratings to the residential mortgage-backed
certificates issued by Sequoia Mortgage Trust 2019-5.

RATING ACTIONS

Sequoia Mortgage Trust 2019-5

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 AA-sf New Rating; previously at AA-(EXP)sf

Class B-2;    LT A-sf 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 537 loans with a total balance of
approximately $397.18 million as of the cutoff 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-year, 25-year 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 772 and an
original WA CLTV ratio of 70%. All of the loans in the pool consist
of Safe Harbor Qualified Mortgages (SHQM).

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. Furthermore, 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 95% of loans in the transaction. Due
diligence was performed by Clayton, AMC and Opus, which are
assessed by Fitch as 'Acceptable - Tier 1', 'Acceptable - Tier 1'
and 'Acceptable - Tier 2', respectively. The review scope is
consistent with Fitch criteria and the results are generally
similar to prior RMBS issued by Redwood. 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 16 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.

CE Floor (Positive): To mitigate tail risk, which arises as the
pool seasons and fewer loans are outstanding, a subordination floor
of 1.00% 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 39.94%.

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'.

CRITERIA VARIATION

The analysis included one criteria variation from the "U.S. RMBS
Rating Criteria." Fitch typically looks for assessments of
originators that make up more than 15% of the total collateral.
Quicken is the largest originator in the pool at more than 16%.
Fitch was comfortable with the lack of an assessment despite the
concentration due to the minor amount over the threshold, Redwood's
established aggregation platform and the very high credit quality.
There was no impact to the ratings.


TERWIN MORTGAGE 2005-5SL: Moody's Hikes Cl. M-3 Debt Rating to Ba1
------------------------------------------------------------------
Moody's Investors Service upgraded the rating of one tranche from
Terwin Mortgage Trust 2005-5SL. The securitization is backed by a
pool of fixed-rate, second lien mortgage loans.

Complete rating action is as follows:

Issuer: Terwin Mortgage Trust 2005-5SL

Cl. M-3, Upgraded to Ba1 (sf); previously on May 3, 2018 Upgraded
to Ba3 (sf)

RATINGS RATIONALE

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

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in October 2019 from 3.8% in
October 2018. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2019 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2019. Lower increases than
Moody's expects or decreases could lead to negative rating actions.
Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions.


TESLA AUTO 2019-A: Moody's Assigns Ba3 Rating on $38MM Cl. E Notes
------------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to the notes
issued by Tesla Auto Lease Trust 2019-A. This is the first auto
lease transaction in 2019 for Tesla Finance LLC (not rated). The
notes are backed by a pool of closed-end retail automobile leases
originated by TFL, who is also the servicer and administrator for
this transaction.

The complete rating actions are as follows:

Issuer: Tesla Auto Lease Trust 2019-A

$105,000,000, 2.00502%, Class A-1 Notes, Definitive Rating Assigned
P-1 (sf)

$260,000,000, 2.13%, Class A-2 Notes, Definitive Rating Assigned
Aaa (sf)

$240,000,000, 2.16%, Class A-3 Notes, Definitive Rating Assigned
Aaa (sf)

$81,890,000, 2.20%, Class A-4 Notes, Definitive Rating Assigned Aaa
(sf)

$61,160,000, 2.41%, Class B Notes, Definitive Rating Assigned Aa2
(sf)

$37,630,000, 2.68%, Class C Notes, Definitive Rating Assigned A2
(sf)

$36,700,000, 3.37%, Class D Notes, Definitive Rating Assigned Baa2
(sf)

$38,580,000, 5.48%, Class E Notes, Definitive Rating Assigned Ba3
(sf)

RATINGS RATIONALE

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

Moody's expected median cumulative net credit loss expectation for
TALT 2019-A is 0.50% and the total loss at a Aaa stress on the
collateral is 32.50% (including 4.50% credit loss and 28.00%
residual value loss at a Aaa stress). The residual value loss at a
Aaa stress of 28.00% is higher than the 24.50% assigned to the
2018-B transaction, due to (1) the sponsor's very limited
securitization history and short operating history; (2) thin RV
performance data, especially for Model 3, which is included in ABS
transactions for the first time; (3) a lack of model
diversification; (4) higher RV setting as percentage of MSRP; (5)
high RV maturity and geographic concentration: (6) unique or
significantly greater RV risk for BEVs, especially for Tesla
vehicles, which have significant technology risks including those
that relate to self-driving and battery technology; and (7) the
impact of a potential manufacturer bankruptcy on RV, especially in
the context of Tesla's vertically integrated production model.
Moody's based its cumulative net credit loss expectation and loss
at a Aaa stress of the collateral on an analysis of the quality of
the underlying collateral; the historical credit loss and residual
value performance of similar collateral, including securitization
performance and managed portfolio performance; the ability of TFL
and its sub-servicer LeaseDimensions, Inc. to perform the servicing
functions; and current expectations for the macroeconomic
environment during the life of the transaction.

At closing, the Class A notes, the Class B notes, the Class C
notes, the Class D notes, and the Class E notes are expected to
benefit from 27.75%, 21.25%, 17.25%, 13.35%, and 9.25% of hard
credit enhancement, respectively. Initial hard credit enhancement
for the notes consists of a combination of a non-declining reserve
account and subordination. The notes may also benefit from excess
spread.

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

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

Up

Moody's could upgrade the subordinate notes if levels of credit
enhancement are higher than necessary to protect investors against
current expectations of portfolio losses. 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 vehicles
securing an obligor's promise of payment. Portfolio losses also
depend greatly on the US job market and the market for used
vehicles. Other reasons for better-than-expected performance
include changes to servicing practices that enhance collections or
refinancing opportunities that result in prepayments.

Down

Moody's could downgrade the notes if levels of credit enhancement
are insufficient to protect investors against current expectations
of portfolio losses. 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 vehicles securing an obligor's
promise of payment. Portfolio losses also depend greatly on the US
job market and the market for used vehicles. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud. Additionally, Moody's could downgrade the Class A-1
short-term rating following a significant slowdown in principal
collections that could result from, among other things, high
delinquencies or a servicer disruption that impacts obligor's
payments.


TOWD POINT 2019-SJ3: Fitch to Rate 3 Tranches 'B(EXP)'
------------------------------------------------------
Fitch Ratings expects to assign ratings and Rating Outlooks to Towd
Point Mortgage Trust 2019-SJ3.

RATING ACTIONS

Towd Point Mortgage Trust 2019-SJ3

Class A1;   LT AAA(EXP)sf; Expected Rating

Class A1A;  LT AAA(EXP)sf; Expected Rating

Class A1AX; LT AAA(EXP)sf; Expected Rating

Class A2;   LT AA(EXP)sf;  Expected Rating

Class A2A;  LT AA(EXP)sf;  Expected Rating

Class A2AX; LT AA(EXP)sf;  Expected Rating

Class A3;   LT AA(EXP)sf;  Expected Rating

Class A4;   LT A(EXP)sf;   Expected Rating

Class A5;   LT BBB(EXP)sf; Expected Rating

Class A6;   LT NR(EXP)sf;  Expected Rating

Class B1;   LT BB(EXP)sf;  Expected Rating

Class B1A;  LT BB(EXP)sf;  Expected Rating

Class B1AX; LT BB(EXP)sf;  Expected Rating

Class B2;   LT B(EXP)sf;   Expected Rating

Class B2A;  LT B(EXP)sf;   Expected Rating

Class B2AX; LT B(EXP)sf;   Expected Rating

Class B3;   LT NR(EXP)sf;  Expected Rating

Class B3A;  LT NR(EXP)sf;  Expected Rating

Class B3AX; LT NR(EXP)sf;  Expected Rating

Class B4;   LT NR(EXP)sf;  Expected Rating

Class B4A;  LT NR(EXP)sf;  Expected Rating

Class B4AX; LT NR(EXP)sf;  Expected Rating

Class B5;   LT NR(EXP)sf;  Expected Rating

Class M1;   LT A(EXP)sf;   Expected Rating

Class M1A;  LT A(EXP)sf;   Expected Rating

Class M1AX; LT A(EXP)sf;   Expected Rating

Class M2;   LT BBB(EXP)sf; Expected Rating

Class M2A;  LT BBB(EXP)sf; Expected Rating

Class M2AX; LT BBB(EXP)sf; Expected Rating

TRANSACTION SUMMARY

The notes are supported by one collateral group that consists of
13,889 seasoned performing and re-performing second-lien mortgages
with a total balance of approximately $725 million, which includes
$28 million, or 3.9%, of the aggregate pool balance in
non-interest-bearing deferred principal amounts, as of the cut-off
date.

KEY RATING DRIVERS

Closed-End Second Liens (Negative): The collateral pool consists of
100% closed-end, second lien, seasoned performing loans and RPLs
with a weighted average (WA) model credit score of 702, sustainable
loan to value ratio (sLTV) of 73.1%, 50.3% 36 months of clean pay
history (under the MBA method) and seasoning of approximately 158
months. Fitch assumes 100% loss severity (LS) on all defaulted
second lien loans. Fitch assumes second lien loans default at a
rate comparable to first lien loans, after controlling for credit
attributes, no additional default penalty was applied.

Re-Performing Loans (Negative): No loans were delinquent as of the
cut-off date, and 64.3% of the pool has been "current" for over two
years. 35.7% of loans are current but have recent delinquencies or
incomplete pay strings. Of the total pool, 64.9% have received
modifications. The average time since loan modification is
approximately 65 months.

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

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

Low Operational Risk (Positive): Operational risk is well
controlled for in this RPL transaction. FirstKey Mortgage, LLC
(FirstKey) has a well-established track record in RPL activities
and has an 'average' aggregator assessment from Fitch. Select
Portfolio Servicing, Inc. (SPS) and Specialized Loan Servicing LLC
(SLS) will perform primary and special servicing functions for this
transaction and is rated as an 'RPS1-'/'RPS2+' servicer for this
product type. The issuer's retention of at least 5% of the bonds
helps to ensure an alignment of interest between the issuer and
investors.

Low Aggregate Servicing Fee (Negative): Fitch determined that the
initial servicing fee of 31 basis points (bps) may be insufficient
to attract subsequent servicers under a period of poor performance
and high delinquencies. In the event that a successor servicer is
appointed, the servicing fee can be increased to an amount greater
than the cap. To reflect the risk of an increased servicing fee,
Fitch assumed a 60-bp servicing fee in its cash flow analysis to
test the adequacy of CE and excess spread.

Third-Party Due Diligence (Neutral): Third-party due diligence was
performed by 'Acceptable - Tier 1' firms on approximately 26%/32%
(loan count/UPB) of the loans and confirmed high overall loan
quality. The results of the reviews indicated low operational risk
with approximately 10.5% of the reviewed loans assigned a 'C' or
'D' grade for compliance, which is consistent with overall industry
averages. Expected loss adjustments were not applied for the due
diligence findings since 100% LS is already assumed for these
loans.

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement (RW&E) mechanism construct
for this transaction to generally be consistent with what it views
as a Tier 2 framework, due to the inclusion of knowledge qualifiers
and the exclusion of certain reps that Fitch typically expects for
RPL transactions. After a threshold event (which occurs when
realized loss exceeds the class principal balance of the B3, B4 and
B5 notes), loan reviews for identifying breaches will be conducted
on loans that experience a realized loss of $10,000 or more. To
account for the Tier 2 framework, Fitch increased its 'AAAsf' loss
expectations by roughly 362 bps to account for a potential increase
in defaults and losses arising from weaknesses in the reps.

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

Deferred Amounts (Negative): Non-interest-bearing principal
forbearance amounts totaling $28 million (3.9%) of the UPB are
outstanding on 2,147 loans. Fitch included the deferred amounts
when calculating the borrower's loan to value ratio (LTV) and
sustainable LTV (sLTV), despite the lower payment and amounts not
being owed during the term of the loan. The inclusion resulted in a
higher probability of default (PD) than if there were no deferrals.
Because deferred amounts are due and payable by the borrower at
maturity, Fitch believes that borrower default behavior for these
loans will resemble that of the higher LTVs, as exit strategies
(that is, sale or refinancing) will be limited relative to those
borrowers with more equity in the property.

RATING SENSITIVITIES

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

Fitch conducted sensitivity analysis determining how the ratings
would react to steeper MVDs at the national level. The analysis
assumes MVDs of 10%, 20% and 30%, in addition to the
model-projected 37.3% at 'AAAsf'. The analysis indicates there is
some potential rating migration with higher MVDs, compared with the
model projection.

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


UBS COMMERCIAL 2017-C7: Fitch Affirms Class G-RR Certs at B-sf
--------------------------------------------------------------
Fitch Ratings affirmed 14 classes of UBS Commercial Mortgage Trust
2017-C7 commercial mortgage pass-through certificates series
2017-C7.

RATING ACTIONS

UBS 2017-C7

Class A-1 90276WAN7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 90276WAP2;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 90276WAR8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 90276WAS6;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 90276WAV9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 90276WAQ0; LT AAAsf Affirmed;  previously at AAAsf

Class B 90276WAW7;    LT AA-sf Affirmed;  previously at AA-sf

Class C 90276WAX5;    LT A-sf Affirmed;   previously at A-sf

Class D-RR 90276WAA5; LT BBBsf Affirmed;  previously at BBBsf

Class E-RR 90276WAC1; LT BBB-sf Affirmed; previously at BBB-sf

Class F-RR 90276WAE7; LT BB-sf Affirmed;  previously at BB-sf

Class G-RR 90276WAG2; LT B-sf Affirmed;   previously at B-sf

Class X-A 90276WAT4;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 90276WAU1;  LT AA-sf Affirmed;  previously at AA-sf

KEY RATING DRIVERS

Stable Performance: The overall pool performance remains stable
from issuance. There are no delinquent or specially serviced loans.
There are three loans on the servicer's watchlist, none of which
are considered a Fitch Loan of Concern.

Minimal Changes to Credit Enhancement: There has been little change
to credit support given the recent issuance of the deal. As of the
November 2019 distribution date, the pool's aggregate balance has
been reduced by approximately 1.15% to $881 million, from $891
million at issuance. Amortization in the near term will be limited
as 11 loans representing 34.3% of the pool are full-term
interest-only and 14 loans representing 28.2% of the pool are
partial interest-only, of which 12 loans representing 25.41% of the
pool have not yet begun amortizing. The pool is scheduled to
amortize by 10.3% prior to maturity.

Investment Grade Credit Opinion: Two loans, representing 11.31% of
the pool, have investment grade credit opinions. At issuance, One
State Street (7.06% of the pool), the largest loan in the pool,
received an investment grade credit opinion of 'BBB+sf' on a
stand-alone basis and General Motors Building (4.25% of the pool)
received an investment grade credit opinion of 'AAAsf' on a
stand-alone basis.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable due to the overall
stable performance of the pool. Future upgrades may occur with
improved pool performance and additional paydown or defeasance.
Downgrades may be possible should a material asset-level or
economic event adversely affect pool performance.

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

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


UBS COMMERCIAL 2018-C15: Fitch Affirms B- Rating on Cl. G-RR Certs
------------------------------------------------------------------
Fitch Ratings affirms UBS Commercial Mortgage Trust 2018-C15
commercial mortgage pass-through certificates, series 2018-C15.

RATING ACTIONS

UBS 2018-C15

Class A-1 90278LAU3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 90278LAV1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 90278LAX7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 90278LAY5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 90278LBB4;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 90278LAW9; LT AAAsf Affirmed;  previously at AAAsf

Class B 90278LBC2;    LT AA-sf Affirmed;  previously at AA-sf

Class C 90278LBD0;    LT A-sf Affirmed;   previously at A-sf

Class D 90278LAC3;    LT BBB+sf Affirmed; previously at BBB+sf

Class D-RR 90278LAE9; LT BBB-sf Affirmed; previously at BBB-sf

Class E-RR 90278LAG4; LT BB+sf Affirmed;  previously at BB+sf

Class F-RR 90278LAJ8; LT BB-sf Affirmed;  previously at BB-sf

Class G-RR 90278LAL3; LT B-sf Affirmed;   previously at B-sf

Class X-A 90278LAZ2;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 90278LBA6;  LT AA-sf Affirmed;  previously at AA-sf

KEY RATING DRIVERS

Minimal Change in Credit Enhancement: As of the November 2019
distribution date, the pool's aggregate balance has been reduced by
0.48% to $643.4 million from $646.5 million at issuance. No loans
have paid off or defeased. At issuance, based on the scheduled
balance at maturity, the pool was expected to pay down by 9.0%
prior to maturity, which is higher than the average for
transactions of a similar vintage.

Stable Performance and Loss Expectations: While the overall pool
performance remains stable from issuance, three loans (8.5% of the
current pool balance) have been designated as Fitch Loans of
Concern (FLOCs) including one specially serviced loan (1.5%).
Interest shortfalls are currently impacting NR-RR.

Fitch Loans of Concern: Three loans (8.5%) have been designated as
FLOCs. The largest FLOC is Pier 1 Imports Headquarters (4.2%), a
409,977 sf office building located in Fort Worth, TX. Pier 1
Imports occupies 100% of the building through June 2027. At
issuance, Fitch noted that Pier 1 had sublet approximately 13% of
net rentable area (NRA) and gone dark in an additional 10% of NRA.
At the time, the sponsor indicated that they wanted to negotiate
with Pier 1 about downsizing so that the building could be
converted to a multi-tenant property. Since issuance, a number of
media reports have indicated that Pier 1 may be considering filing
bankruptcy due to declining revenue and shifting consumer trends
that have put pressure on their business.

16300 Roscoe Blvd (2.8%) is a 154,033 sf office property located in
Van Nuys, CA and built in 1956. The largest tenant, MGA
Entertainment (61.3% of NRA) has gone dark, reducing physical
occupancy at the property to 38.7%. MGA Entertainment is a
sponsor-affiliated tenant with a lease expiration in December 2033.
Per the servicer, the space is being marketed but there are no
prospects. The loan is currently not cash managed as MGA
Entertainment guarantees their lease. If MGA Entertainment were to
terminate the lease, cash management would be triggered. MGA
Entertainment has also indicated that they have plans to renovate
the building's exterior and build a parking garage on the property.
They believe that these updates will make the property more
appealing to potential tenants.

Feather River Crossing (1.5%) is a 90,580 sf retail center located
in Oroville, CA. The loan transferred to special servicing after
first-quarter 2019 debt service coverage ratio was reported at
0.89x and the borrower did not comply with the master servicer's
attempts to set up cash management.

Investment-Grade Credit Opinion Loans: At issuance, two loans had
investment-grade credit opinions. The Great Value Storage Portfolio
(8.6%) received a 'BBB-sf' credit opinion and Christiana Mall
(1.6%) received a 'AA-sf' credit opinion.

RATING SENSITIVITIES

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

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.

REPRESENTATIONS, WARRANTIES AND ENFORCEMENT MECHANISMS

A description of the transaction's representations, warranties and
enforcement mechanisms (RW&Es) that are disclosed in the offering
document and which relate to the underlying asset pool is available
by clicking the link to the Appendix. The appendix also contains a
comparison of these RW&Es to those Fitch considers typical for the
asset class as detailed in the Special Report titled
'Representations, Warranties and Enforcement Mechanisms in Global
Structured Finance Transactions'.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. ESG issues are credit neutral
or have only a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by
transaction.


UBS-BARCLAYS 2013-C5: Fitch Lowers Class F Debt Rating to CCC
-------------------------------------------------------------
Fitch Ratings downgraded one class and affirmed 11 classes of
UBS-Barclays Commercial Mortgage Trust commercial mortgage
pass-through certificates series 2013-C5.

RATING ACTIONS

UBS-BB 2013-C5

Class A-3 90270YBE8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 90270YBF5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-AB 90270YBG3; LT AAAsf Affirmed;  previously at AAAsf

Class A-S 90270YAA7;  LT AAAsf Affirmed;  previously at AAAsf

Class B 90270YAG4;    LT AA-sf Affirmed;  previously at AA-sf

Class C 90270YAL3;    LT A-sf Affirmed;   previously at A-sf

Class D 90270YAN9;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 90270YAQ2;    LT BBsf Affirmed;   previously at BBsf

Class EC 90270YAJ8;   LT A-sf Affirmed;   previously at A-sf

Class F 90270YAS8;    LT CCCsf Downgrade; previously at Bsf

Class XA 90270YAC3;   LT AAAsf Affirmed;  previously at AAAsf

Class XB 90270YAE9;   LT AA-sf Affirmed;  previously at AA-sf

KEY RATING DRIVERS

Increased Loss Expectations: While the majority of pool has
exhibited overall stable performance since the last rating action,
loss expectations have increased on two loans (6.8%) that
transferred to special servicing in 1Q19. Both loans share the same
sponsor and were considered Fitch Loans of Concern (FLOCs) at the
last rating action; however, performance has continued to decline.
Harborplace (5.2%) is secured by a 148,928-sf retail center located
in the heart of Baltimore's Inner Harbor at the intersection of
Pratt and Light streets and situated steps away from the harbor.
Anchor tenants include H&M, Ripley's Believe it or Not, and major
restaurant tenants include Bubba Gump Shrimp Company, Pizzeria Uno,
and The Cheesecake Factory. Occupancy has been trending downward
over the past several years due to continued loss of smaller
tenants: 95% (issuance), 87% (YE 2014), 77% (YE 2015), 72.4% (YE
2016 and YE 2017), 68% (YE 2018 and Aug. 2019). NOI DSCR similarly
trended downward: 1.50x (YE 2015), 1.15x (YE 2016), 0.96x (YE 2017)
and 0.66x (YE 2018). A receiver was appointed in May 2019.

The Village of Cross Keys (1.6%) is a mixed-use property located
just east of Interstate 83 in central Baltimore approximately seven
miles north of Baltimore's Inner Harbor. The loan is secured by
147,140-sf retail space, 119,334-sf office space, and a 30,292-sf
tennis club. Occupancy has remained below 79% since issuance and
has been trending downward over the past several years: 78% (YE
2015 and YE 2016), 64% (YE 2017), 65% (YE 2018) and 53% (September
2019). NOI DSCR similarly has trended downward: 1.69x (YE 2015),
1.46x (YE 2016), 1.20x (YE 2017) and 0.92x (YE 2018). While the
servicer indicated the loan is expected to transfer back to the
master servicer, Fitch Ratings requested a leasing status update.
Four loans (3.7%) were on the servicer's watchlist due to
performance triggers or concerns with larger tenants; one (0.8%)
was flagged as a FLOC.

Defeasance/Improved Credit Enhancement Since Issuance: Eighteen
loans (17.2%) are fully defeased, including the fourth and sixth
largest loans. Four loans (6.2%) have defeased since the last
rating action, including a partial defeasance of the 14th largest
loan. As of the November 2019 distribution date, the pool's
aggregate balance had been reduced by 27.4% to $1.3 billion from
$1.9 billion at issuance. Realized losses totaled $2.5 million, and
interest shortfalls in the amount of $577,799 are currently
affecting non-rated class G. Four loans (34.7% of the pool) are
full-term interest only, one loan (0.1%) is fully amortizing and
the remaining 73 loans are amortizing.

Alternative Loss Considerations: Fitch applied an additional
sensitivity scenario that assumed a 50% loss on the Village at
Crosskeys to reflect the potential for outsized losses due to
continued occupancy declines and upcoming rollover risk. The
Negative Rating Outlook on classes D and E reflect this scenario.

Pool and Property Concentrations: The largest loan, Santa Anita
Mall, represents 16.8% of the current pool balance. Additionally
the top 10 loans represent 59.9% of the current pool balance. The
pool's largest property type is retail at 48.5%, including the
first and second largest loans (32.1%), which are secured by
regional malls.

RATING SENSITIVITIES

The downgrade to class F reflects the increased loss expectations,
primarily due to the two loans in special servicing. The Negative
Rating Outlook on classes D and E reflect the potential for
outsized losses on these loans should their performances continue
to decline. Rating Outlooks on classes A-3 through C remain Stable
due to overall stable performance of the pool and continued
amortization and defeasance. Upgrades may occur with improved pool
performance and additional paydown or defeasance.


WAMU COMMERCIAL 2006-SL1: Fitch Affirms CCsf Rating on Cl. F Certs
------------------------------------------------------------------
Fitch Ratings affirmed ten classes of WaMu Commercial Mortgage
Securities Trust 2006-SL1, small balance commercial mortgage
pass-through certificates.

RATING ACTIONS

WaMu Commercial Mortgage Securities Trust 2006-SL1

Class C 933633AE9; LT AAAsf Affirmed; previously at AAAsf

Class D 933633AF6; LT BBBsf Affirmed; previously at BBBsf

Class E 933633AG4; LT CCCsf Affirmed; previously at CCCsf

Class F 933633AH2; LT CCsf Affirmed;  previously at CCsf

Class G 933633AJ8; LT Dsf Affirmed;   previously at Dsf

Class H 933633AK5; LT Dsf Affirmed;   previously at Dsf

Class J 933633AL3; LT Dsf Affirmed;   previously at Dsf

Class K 933633AM1; LT Dsf Affirmed;   previously at Dsf

Class L 933633AN9; LT Dsf Affirmed;   previously at Dsf

Class M 933633AP4; LT Dsf Affirmed;   previously at Dsf

KEY RATING DRIVERS

Stable Loss Projections: As a percent of the original and
outstanding pool balances, Fitch's modeled losses on the remaining
loans are largely unchanged since the last rating action. The pool
is comprised mainly of small balance loans backed by small
multifamily properties. Many loan level reports are dated. Fitch's
analysis includes conservative assumptions for these loans.

Increased Credit Enhancement: According to the October 2019
remittance report, the trust has received $4.3 million in
unscheduled principal from loans prepaying during their open period
since the last rating action. With scheduled monthly amortization,
class D is not anticipated to begin paying down until 2026.
However, this may occur sooner with continued unscheduled principal
from prepaying loans. There is only one specially serviced loan
remaining. The November 2018 appraised value for the asset exceeds
the loan exposure. A full loss on the loan would be contained to
class G, which is already rated 'Dsf'.

Pool Concentration and Extended Maturity Profile: The pool is
comprised almost entirely of small balance, fully amortizing loans
backed by multifamily properties, with geographic concentration in
California. Given this concentration, and because many of the
asset-level financial statements are missing or dated, Fitch used
conservative NOI haircuts and higher cap rate and refinance
constant assumptions for the pool. The resulting loan level loss
projections may be considered high relative to the leverage points.
However, the pool's maturity profile is extended. Only one loan
representing 1.0% of the pool is scheduled to mature prior to
2036.

RATING SENSITIVITIES

The Rating Outlook for class D has been revised to Positive, while
class C remains on Rating Outlook Stable. The pool continues to
experience collateral reduction, largely because of prepayments. As
a result, credit enhancement has improved since the last rating
action. Prepayments are difficult to time, and scheduled monthly
principal is minimal given the pool's extended maturity profile.
However, with continued principal paydown, it is possible that
class D could be upgraded in the future. Downgrades are not
considered likely unless a significant number of loans default or
have performance declines.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. ESG issues are credit neutral
or have only a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by the
transaction.


WELLS FARGO 2015-C26: Fitch Affirms BBsf Rating on 2 Tranches
-------------------------------------------------------------
Fitch Ratings affirms 13 classes of Wells Fargo Commercial Mortgage
Trust 2015-C26, commercial mortgage pass-through certificates.

RATING ACTIONS

WFCM 2015-C26

Class A-2 94989CAV3;  LT PIFsf Paid In Full; previously at AAAsf

Class A-3 94989CAW1;  LT AAAsf Affirmed;     previously at AAAsf

Class A-4 94989CAX9;  LT AAAsf Affirmed;     previously at AAAsf

Class A-S 94989CAZ4;  LT AAAsf Affirmed;     previously at AAAsf

Class A-SB 94989CAY7; LT AAAsf Affirmed;     previously at AAAsf

Class B 94989CBC4;    LT AA-sf Affirmed;     previously at AA-sf

Class C 94989CBD2;    LT A-sf Affirmed;      previously at A-sf

Class D 94989CAG6;    LT BBB-sf Affirmed;    previously at BBB-sf

Class E 94989CAJ0;    LT BBsf Affirmed;      previously at BBsf

Class F 94989CAL5;    LT Bsf Affirmed;       previously at Bsf

Class PEX 94989CBE0;  LT A-sf Affirmed;      previously at A-sf

Class X-A 94989CBA8;  LT AAAsf Affirmed;     previously at AAAsf

Class X-C 94989CAA9;  LT BBsf Affirmed;      previously at BBsf

Class X-D 94989CAC5;  LT Bsf Affirmed;       previously at Bsf

KEY RATING DRIVERS

Increased Loss Expectations Since Issuance: While the majority of
the pool continues to exhibit stable performance, Fitch's loss
expectations have increased since issuance and remained relatively
stable since the last rating action. There are nine Fitch Loans of
Concern (FLOCs, 17.3% of the pool), including three specially
serviced loans (6.2%). The Negative Rating Outlooks on classes E
and F, and the interest-only classes X-C and X-D, primarily reflect
concerns over these loans.

Three loans are in special servicing, including the largest loan in
the pool, Chateau on the Lake (4.9%). The loan, which is secured by
fee and leasehold interests in a 301-room hotel complex located in
Branson, MO, transferred to special servicing in July 2016 due to
the borrower and parent company filing for Chapter 11 Bankruptcy.
The filing was made in connection with litigation related to a
complex deal made in 2005 to reprivatize the sponsor's company,
Hammons Hotels. Under the bankruptcy action, there has been a
transfer of interest to a new borrower; the servicer is still
working to settle remaining issues related to default interest and
other expenses. The loan has remained current. The
servicer-reported YE 2018 debt service coverage ratio (DSCR)
improved to 2.12x from 1.72x at YE 2017. Per STR, RevPAR has
declined slightly since 2018. Per the TTM September 2019 report,
RevPAR has declined 4.9% yoy. Per the report, occupancy, ADR, and
RevPAR were 56.1%, $162, and $91, respectively, with RevPAR
penetration of 87.9%.

The other specially serviced loans include Piedmont Center (1.1%),
which transferred to special servicing in November 2018. The office
property, which is located in Greenville, SC, has seen declining
performance since losing tenants near the end of 2016. The property
is located in a weak market. Per Reis (3Q 2019), the East submarket
of Greenville has a vacancy rate of 18.9%. The borrower was working
on leasing up the property, however, interim financing taken out by
the borrower for tenant improvement work was not paid back as
agreed and a receiver has now been appointed. The property is
expected to be marketed for sale next year.

The final specially serviced loan, Hearth House Owners Corp (0.2%)
is secured by a 17-unit coop property located in the East Village
neighborhood of Manhattan. The current debt per unit is
approximately $97,000. Per the servicer, the loan is currently
involved in a bankruptcy action and the servicer is working towards
resolution. No further details have been provided.

The other FLOCs include the fourth largest loan in the pool, the
Broadcom Building loan (4.1%). The loan is secured by a fully
vacant 200,000-sf class B office/R&D property located in San Jose,
CA. At issuance, the property was 100% leased to the Broadcom
Corporation, which had been in occupancy since 2000. However,
Broadcom exercised its option to terminate the lease early and
vacated by May 2018. In connection with the early termination,
Broadcom was required to pay a termination fee of $2.5 million;
further, cash was trapped for several months after notice of
termination. As of October 2019, the total combined reserve balance
was reported at $4.5 million (from $6.0 million in June 2018). The
property is currently being marketed for lease with some possible
interest. No further details have been provided by the servicer.

The fifth largest loan, Aloft Houston by the Galleria (3.6%), has
suffered a 32% decline in RevPAR since issuance. The loan, which
remains current, is secured by a 152-room limited service hotel
located adjacent to the Houston Galleria, a 2.4 million sf
mixed-use facility featuring a super-regional mall and three office
towers. Per the servicer, the TTM June 2019 NOI DSCR was 0.90x, a
slight increase from YE 2018 at 0.82x. Per the TTM August 2019 STR
report, occupancy, ADR, and RevPAR were 86.2%, $116, and $100,
respectively, with RevPAR penetration of 111.3%. RevPAR at issuance
was $132 (TTM September 2014). The declining performance has been
attributed to increased competition in the area and the borrower
has reportedly instituted an expense reduction program until demand
stabilizes and rates rise.

The Bellwether Gate A Office loan (1.9%) of the pool has seen
performance decline since losing its largest tenant (69.5% of NRA)
in 2017/2018. The servicer reported YE 2018 NOI DSCR fell to 0.96x
from 1.41x at YE 2017. Occupancy recently climbed to 87.8% with a
new large tenant (59.7% of NRA); however, the tenant's current in
place rent is notably lower than the prior tenant. A rent step in
September 2020 should improve cash flow. No tenants are scheduled
to roll before 2021.

No other FLOC comprises more than 1.0% of the pool collateral.
Fitch will continue to monitor all FLOCs going forward.

Minimal Change to Credit Enhancement Since Issuance: As of the
October 2019 distribution date, the pool's aggregate balance had
been reduced by 9.7% to $868.3 million from $962.1 million at
issuance. Five loans have paid off since issuance. The majority of
the pool matures in 2024 (20.7%) and 2025 (79.2%), with only one
loan (0.1%) maturing in 2022. Currently, three loans (1.1%) are
full-term interest only, while 12 loans (22.5%) remain in their
partial interest-only periods. Five loans (5.5%) are currently
defeased.

Additional Considerations

Diverse Pool: The 10 largest loans represent 36% of the total pool
balance, which is a lower concentration than other Fitch-rated CMBS
transactions of similar vintage.

Property Type Concentration: The highest property type
concentration is retail at 25.2%, while the next highest is
multifamily/manufactured housing at 23.7% and then hotels with an
above average concentration of 20.9%. Hotels have the highest
probability of default in Fitch's multiborrower model.

RATING SENSITIVITIES

The Negative Outlooks on classes E and F, and the interest only
classes X-C and X-D, reflect concern over the larger FLOCs;
downgrades to these classes may occur if a replacement lease is not
executed for the Broadcom Building or if performance continues to
decline at other properties. Rating Outlooks for the senior classes
remain Stable due to the stable performance of the majority of the
remaining pool and continued expected amortization. Upgrades may
occur with improved pool performance and additional paydown or
defeasance.

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.


WELLS FARGO 2016-C37: Fitch Affirms B-sf Rating on 2 Tranches
-------------------------------------------------------------
Fitch Ratings affirmed 18 classes of Wells Fargo Commercial
Mortgage Trust 2016-C37 commercial mortgage pass-through
certificates.

RATING ACTIONS

WFCM 2016-C37

Class A-1 95000PAA2;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 95000PAB0;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 95000PAC8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 95000PAD6;  LT AAAsf Affirmed;  previously at AAAsf

Class A-5 95000PAE4;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 95000PAG9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 95000PAF1; LT AAAsf Affirmed;  previously at AAAsf

Class B 95000PAK0;    LT AA-sf Affirmed;  previously at AA-sf

Class C 95000PAL8;    LT A-sf Affirmed;   previously at A-sf

Class D 95000PAX2;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 95000PAZ7;    LT BB+sf Affirmed;  previously at BB+sf

Class F 95000PBB9;    LT BB-sf Affirmed;  previously at BB-sf

Class G 95000PBD5;    LT B-sf Affirmed;   previously at B-sf

Class X-A 95000PAH7;  LT AAAsf Affirmed;  reviously at AAAsf

Class X-B 95000PAJ3;  LT AA-sf Affirmed;  previously at AA-sf

Class X-D 95000PAM6;  LT BBB-sf Affirmed; previously at BBB-sf

Class X-EF 95000PAP9; LT BB-sf Affirmed;  previously at BB-sf

Class X-G 95000PAR5;  LT B-sf Affirmed;   previously at B-sf

KEY RATING DRIVERS

Stable Loss Expectations: Overall pool performance remains stable;
therefore, expected losses are in-line with issuance expectations.
As of the November 2019 distribution date, the pool has four loans
(7.4%) that have been designated as Fitch Loans of Concern (FLOC),
including two Top 15 loans (5.2%). The servicer's watchlist
includes 11 loans (13.3%) for deferred maintenance, upcoming lease
expirations, large tenant departures, underperformance and
delinquency. No loans have transferred to special servicing.

Minimal Change to Credit Enhancement: There has been limited
amortization, no defeasance and no disposed loans since issuance.
As of the November 2019 distribution date, the pool's aggregate
principal balance has been reduced by 1.4% to $732.0 million from
$750.5 million at issuance. At issuance, the pool was scheduled to
amortize by 12.2% of the initial pool balance by maturity. Six
loans representing 26.2% of the pool balance are interest only for
the full term and an additional eighteen loans representing 30.6%
of the pool were structured with partial interest-only periods.

Fitch Loans of Concern

The eleventh largest loan, The Lodge & Waterfall Park Apartments
Portfolio (3.1%), is collateralized by a two multifamily properties
in Houston TX. The loan was placed on the servicer's watchlist in
December 2017 due to a major fire at one of the buildings.
According to the servicer there was one casualty, which resulted in
a $25 million lawsuit. According to the servicer the lawsuit is
still ongoing. The building has been restored and tenants began
moving back in mid-September 2018. The building that burned down
represented 6% of GLA. The property continues to exhibit stable
performance.

The UConn Portfolio (2.1%) consists of five student-housing
communities totalling 231 units, located in Storrs (Mansfield), CT,
located near the University of Connecticut (UConn) campus. The
portfolio's occupancy fell to 67% by year-end 2018 compared with
100% occupancy at issuance. Year-end 2018 NOI debt service coverage
ratio (DSCR) was .69x. The borrower attributes the underperformance
to new supply in the subject's submarket. In order to make the
subject more competitive, the borrower plans to renovate all the
properties in the portfolio. The borrower has stated they expect
occupancy to fluctuate due to units going offline for renovations.
Fitch has requested information regarding the renovation schedule
and how renovations might affect portfolio performance; however,
the agency has not received a response.

Holiday Inn Express Cheektowaga North East (1.0%) is securitized by
a 85-key Holiday Inn express located in Cheektowaga, NY. The loan
is on the servicer's watchlist for underperformance and
delinquency. YE 2018 NOI DSCR has fallen to 1.01x from 1.59x at YE
2017. Occupancy has fallen to 63.5% from 70.0% over the same
period. The borrower attributes this drop in performance to a
number of issues related to the loss of corporate clients, losing a
general manager and a general slowdown in the market. As of the
October 2019 the loan was 30 days delinquent. According to
watchlist commentary the asset manager has been working with the
borrower to manage delinquent payments and monitor the loan.

Macgregor Place (1.2%) is a 87,914-sf suburban office property
located in Cary, NC. The loan considered a FLOC due to the
departure of Staples (25% NRA) and Small HD,LLC (22% NRA). As of
June 2019, subject occupancy and YTD NOI DSCR were 48% and 1.16x,
respectively. Additionally, 100% of the subject's remaining leases
roll in the next two years. According to watchlist commentary, the
borrower has no prospective tenants to fill the vacated space.

RATING SENSITIVITIES

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

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.


WELLS FARGO 2019-4: Fitch Rates Class B-4 Certs 'BB-sf'
-------------------------------------------------------
Fitch Ratings assigned the following ratings to Wells Fargo
Mortgage Backed Securities 2019-4 Trust:

  -- $515,760,000 class A-1 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $515,760,000 class A-2 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $386,820,000 class A-3 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $386,820,000 class A-4 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $128,940,000 class A-5 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $128,940,000 class A-6 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $309,456,000 class A-7 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $309,456,000 class A-8 certificates 'AAAsf'; Outlook Stable;

  -- $206,304,000 class A-9 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $206,304,000 class A-10 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $77,364,000 class A-11 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $77,364,000 class A-12 certificates 'AAAsf'; Outlook Stable;

  -- $83,811,000 class A-13 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $83,811,000 class A-14 certificates 'AAAsf'; Outlook Stable;

  -- $45,129,000 class A-15 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $45,129,000 class A-16 certificates 'AAAsf'; Outlook Stable;

  -- $60,721,000 class A-17 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $60,721,000 class A-18 certificates 'AAAsf'; Outlook Stable;

  -- $576,481,000 class A-19 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $576,481,000 class A-20 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $576,481,000 class A-IO1 notional certificates 'AAAsf';
Outlook Stable;

  -- $515,760,000 class A-IO2 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $386,820,000 class A-IO3 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $128,940,000 class A-IO4 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $309,456,000 class A-IO5 notional certificates 'AAAsf';
Outlook Stable;

  -- $206,304,000 class A-IO6 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $77,364,000 class A-IO7 notional certificates 'AAAsf'; Outlook
Stable;

  -- $83,811,000 class A-IO8 notional certificates 'AAAsf'; Outlook
Stable;

  -- $45,129,000 class A-IO9 notional certificates 'AAAsf'; Outlook
Stable;

  -- $60,721,000 class A-IO10 notional certificates 'AAAsf';
Outlook Stable;

  -- $576,481,000 class A-IO11 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $12,743,000 class B-1 certificates 'AAsf'; Outlook Stable;

  -- $9,406,000 class B-2 certificates 'Asf'; Outlook Stable;

  -- $3,640,000 class B-3 certificates 'BBBsf'; Outlook Stable;

  -- $2,124,000 class B-4 certificates 'BBsf'; Outlook Stable.

Fitch will not be rating the following class:

  -- $2,428,156 class B-5 certificates.

The certificates are supported by 790 prime fixed-rate mortgage
loans with a total balance of approximately $606.8 million as of
the cutoff date. All of the loans were originated by Wells Fargo
Bank, N.A. or were acquired from its correspondents. This is the
fifth post-crisis issuance from Wells Fargo.

KEY RATING DRIVERS

Very High-Quality Mortgage Pool (Positive): The collateral
attributes are among the strongest of post-crisis RMBS rated by
Fitch. The pool consists of 30-year fixed-rate fully amortizing
loans to borrowers with strong credit profiles, low leverage and
large liquid reserves. All loans are Safe Harbor Qualified
Mortgages (SHQM). The loans are seasoned an average of four
months.

The pool has a weighted average (WA) original FICO score of 773,
which is indicative of very high credit-quality borrowers.
Approximately 50.5% has original FICO scores at or above 780. In
addition, the original WA CLTV ratio of 73.4% represents
substantial borrower equity in the property. The pool's attributes,
together with Wells Fargo's sound origination practices, support
Fitch's very low default risk expectations.

Low Operational Risk (Positive): Operational risk is very well
controlled for in this transaction. Wells Fargo has an extensive
operating history in residential mortgage originations and is
assessed as an 'Above Average' originator by Fitch. The entity has
a diversified sourcing strategy and utilizes an effective
proprietary underwriting system for its retail originations. Wells
Fargo will perform primary and master servicing for this
transaction; these functions are rated RPS1- and RMS1-,
respectively, by Fitch.

Tier 2 R&W Framework (Neutral): While the loan-level
representations and warranties (R&Ws) for this transaction are
substantially in conformity with Fitch criteria, the framework has
been assessed as a Tier 2 due to the narrow testing construct which
limits the breach reviewers ability to identify or respond to
issues not fully anticipated at closing. The Tier 2 assessment and
the strong financial condition of Wells Fargo as R&W provider
resulted in a neutral impact to the credit enhancement.

Due Diligence Review Results (Positive): Third-party due diligence
was performed on 100% of loans in the transaction pool. The due
diligence was performed by Clayton, which is assessed by Fitch as
an 'Acceptable - Tier 1' third-party review (TPR) firm. The due
diligence results indicated strong origination processes and 99.7%
of the population was graded 'A' or 'B'. Loan exceptions either had
strong mitigating factors or were mostly accounted for in Fitch's
loan loss model; one loan was adjusted due to the secondary value
not supporting the original appraised value. The model credit for
the high percentage of loan level due diligence combined with the
adjustment reduced the 'AAAsf' loss expectation by 16 bps.

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

To mitigate tail risk, which arises as the pool seasons and fewer
loans are outstanding, a subordination floor of 1.20% of the
original balance will be maintained for the senior certificates.

Full Servicer Advancing (Neutral): The pool benefits from advances
of delinquent principal and interest until the servicer, Wells
Fargo, the primary servicer of the pool, deems them
non-recoverable. Fitch's loss severities reflect reimbursement of
amounts advanced by the servicer from liquidation proceeds based on
its liquidation timelines assumed at each rating stress.

Extraordinary Expense Treatment (Neutral): The trust provides for
expenses, including indemnification amounts, reviewer fees 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 $350,000 per annum (with the exception of independent
reviewer breach review fee), which can be carried over each year,
subject to the cap until paid in full.

CRITERIA APPLICATION

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

RATING SENSITIVITIES

Fitch's analysis incorporates 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 2.9%. The analysis indicates that there is some
potential rating migration with higher MVDs, compared with the
model projection.

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


[*] Moody's Takes Action on $929.8MM RMBS Issued 2003-2007
----------------------------------------------------------
Moody's Investors Service upgraded the ratings of 27 tranches and
downgraded the ratings of 17 tranches from 14 transactions backed
Prime Jumbo, Alt-A and Subprime loans.

Complete rating actions are as follows:

Issuer: BCAP LLC Trust 2007-AA2

Cl. II-1-A-1, Downgraded to Ca (sf); previously on Nov 11, 2010
Downgraded to Caa3 (sf)

Cl. II-1-A-2, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. II-1-A-3, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. II-1-A-11, Downgraded to Ca (sf); previously on Nov 11, 2010
Downgraded to Caa3 (sf)

Cl. II-1-A-12, Downgraded to Ca (sf); previously on Nov 11, 2010
Downgraded to Caa3 (sf)

Cl. II-1-A-8, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. II-1-A-4, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. II-1-A-5, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. II-1-A-6, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. II-1-A-7, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. II-1-A-15, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. I-1-A, Upgraded to Caa2 (sf); previously on Nov 11, 2010
Downgraded to Ca (sf)

Cl. II-1-PO, Downgraded to Ca (sf); previously on Nov 11, 2010
Confirmed at Caa3 (sf)

Cl. II-2-A-1, Downgraded to Ca (sf); previously on Nov 11, 2010
Downgraded to Caa3 (sf)

Cl. I-2-A-1, Upgraded to Caa2 (sf); previously on Nov 11, 2010
Downgraded to Ca (sf)

Cl. II-2-PO, Downgraded to Ca (sf); previously on Nov 11, 2010
Downgraded to Caa3 (sf)

Issuer: Equifirst Mortgage Loan Trust 2004-3

Cl. M-8, Upgraded to Caa2 (sf); previously on Apr 26, 2016 Upgraded
to Ca (sf)

Issuer: Fremont Home Loan Trust 2004-4

Cl. M-1, Downgraded to Ba2 (sf); previously on Mar 18, 2013
Downgraded to Baa3 (sf)

Issuer: Fremont Home Loan Trust 2005-A

Cl. M3, Upgraded to Aa1 (sf); previously on Mar 27, 2018 Upgraded
to A1 (sf)

Cl. M4, Upgraded to Caa1 (sf); previously on Mar 27, 2018 Upgraded
to Caa3 (sf)

Issuer: IndyMac Home Equity Mortgage Loan Asset-Backed Trust, INABS
2006-A

Cl. A-3, Upgraded to Ba3 (sf); previously on Feb 27, 2018 Upgraded
to B2 (sf)

Cl. A-4, Upgraded to B1 (sf); previously on Feb 27, 2018 Upgraded
to B3 (sf)

Issuer: J.P. Morgan Mortgage Acquisition Corp. 2005-OPT1

Cl. M-5, Upgraded to B2 (sf); previously on Apr 20, 2018 Upgraded
to Caa1 (sf)

Issuer: J.P. Morgan Mortgage Acquisition Corp. 2006-FRE1

Cl. M-2, Upgraded to B2 (sf); previously on Mar 26, 2018 Upgraded
to Caa1 (sf)

Issuer: J.P. Morgan Mortgage Acquisition Trust 2007-CH1,
Asset-Backed Pass-Through Certificates, Series 2007-CH1

Cl. AF-4, Upgraded to Ba1 (sf); previously on Apr 20, 2018 Upgraded
to B1 (sf)

Cl. AF-5, Upgraded to Ba3 (sf); previously on Apr 20, 2018 Upgraded
to B2 (sf)

Cl. AF-6, Upgraded to Ba2 (sf); previously on Apr 20, 2018 Upgraded
to B1 (sf)

Cl. MV-9, Upgraded to B1 (sf); previously on Apr 20, 2018 Upgraded
to B2 (sf)

Cl. MV-10, Upgraded to B2 (sf); previously on Apr 20, 2018 Upgraded
to Caa2 (sf)

Issuer: J.P. Morgan Mortgage Acquisition Trust 2007-CH3,
Asset-Backed Pass-Through Certificates, Series 2007-CH3

Cl. A-1B, Upgraded to Aa2 (sf); previously on Feb 1, 2019 Upgraded
to A1 (sf)

Cl. A-4, Upgraded to Aaa (sf); previously on Feb 1, 2019 Upgraded
to Aa2 (sf)

Cl. A-5, Upgraded to A1 (sf); previously on Feb 1, 2019 Upgraded to
A2 (sf)

Issuer: J.P. Morgan Mortgage Acquisition Trust 2007-CH5

Cl. A-1, Upgraded to Aa1 (sf); previously on Apr 20, 2018 Upgraded
to A1 (sf)

Cl. A-4, Upgraded to Aaa (sf); previously on Apr 20, 2018 Upgraded
to Aa2 (sf)

Cl. A-5, Upgraded to Aaa (sf); previously on Apr 20, 2018 Upgraded
to Aa3 (sf)

Issuer: Thornburg Mortgage Securities Trust 2003-4

Cl. A-1, Upgraded to Baa1 (sf); previously on Oct 17, 2012
Downgraded to Baa3 (sf)

Cl. A-2, Upgraded to Ba2 (sf); previously on Oct 17, 2012
Downgraded to B2 (sf)

Issuer: Thornburg Mortgage Securities Trust 2004-2

Cl. A-1, Downgraded to Baa3 (sf); previously on Aug 29, 2013
Downgraded to Baa1 (sf)

Cl. A-4, Downgraded to Baa3 (sf); previously on Aug 29, 2013
Downgraded to Baa1 (sf)

Issuer: Thornburg Mortgage Securities Trust 2004-3

Cl. A, Upgraded to Ba1 (sf); previously on Mar 16, 2016 Downgraded
to Ba3 (sf)

Cl. A-X*, Upgraded to Ba1 (sf); previously on Mar 16, 2016
Downgraded to Ba3 (sf)

Cl. B1, Upgraded to Caa3 (sf); previously on Mar 16, 2016
Downgraded to Ca (sf)

Issuer: WaMu Mortgage Pass-Through Certificates, WMABS Series
2006-HE1 Trust

Cl. I-A, Upgraded to Aaa (sf); previously on Apr 9, 2018 Upgraded
to Aa3 (sf)

Cl. II-A-4, Upgraded to Aa1 (sf); previously on Apr 9, 2018
Upgraded to A1 (sf)

*Reflects Interest Only Classes

RATINGS RATIONALE

The rating upgrades are primarily due to an improvement in credit
enhancement available to the bonds relative to projected losses on
the underlying pools. The rating downgrades are primarily due to
deteriorating credit enhancement and pool performance. The rating
actions reflect the recent performance and Moody's updated loss
expectations on the underlying pools.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in Oct 2019 from 3.8% in Oct
2018. Moody's forecasts an unemployment central range of 3.5% to
4.5% for the 2019 year. Deviations from this central scenario could
lead to rating actions in the sector. House prices are another key
driver of US RMBS performance. Moody's expects house prices to
continue to rise in 2019. Lower increases than Moody's expectations
or decreases could lead to negative rating actions. Finally,
performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


                            *********

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