/raid1/www/Hosts/bankrupt/TCR_Public/191229.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 29, 2019, Vol. 23, No. 362

                            Headlines

CFMT LLC 2019-HB1: Moody's Assigns Ba3 Rating on Class M4 Debt
CITIGROUP COMMERCIAL 2019-C7: Moody's Rates Class 805C Certs B3
COMM 2013-CCRE10: Moody's Affirms B3 Rating on Class F Debt
COMM 2019-GC44: Moody's Assigns B3 Rating on Class 180W-C Certs
CWALT INC 2005-16: Moody's Cuts Rating on Class A-4 Debt to B2

DBUBS 2011-LC3: Moody's Upgrades Class F Debt to B3(sf)
GS MORTGAGE 2012-GCJ9: Moody's Affirms B2 Rating on Cl. F Certs
GS MORTGAGE 2013-GCJ16: Moody's Affirms B3 Rating on Cl. G Certs
JP MORGAN 2006-LDP7: Moody's Affirms Caa2 Rating on Cl. A-J Debt
JP MORGAN 2018-PHH: Moody's Affirms B3 Rating on Cl. HRR Certs

MAD COMMERCIAL 2019-650M: Fitch Rates $97.755MM Cl. B Certs B-sf
MORGAN STANLEY 2006-HQ10: Moody's Affirms C Rating on 4 Tranches
MORGAN STANLEY 2019-NUGS: Moody's Gives Ba3 Rating on Cl. E Certs
UBS COMMERCIAL 2019-C18: Fitch Rates $7.435MM Class G Certs B-sf
US CAPITAL V: Moody's Hikes $42MM Cl. A-3 Notes to Ba1

WACHOVIA BANK 2004-C12: Fitch Hikes Class K Certs Rating to BBsf
[*] Fitch Takes Actions on 12 SLM & 2 Navient Private Trusts

                            *********

CFMT LLC 2019-HB1: Moody's Assigns Ba3 Rating on Class M4 Debt
--------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to five
classes of residential mortgage-backed securities issued by CFMT
2019-HB1, LLC. The ratings range from Aaa (sf) to Ba3 (sf).

The Notes are backed by a pool that includes 1,100 inactive home
equity conversion mortgages. There is no Real Estate-Owned
properties backing the Notes. This transaction is sponsored by SHAP
2018-1, LLC, a Delaware limited liability company owned by four
funds: Waterfall Victoria Master Fund, Ltd., Waterfall Eden Master
Fund, Ltd., Waterfall Sandstone Fund, L.P., and Waterfall Rock
Island, LLC (collectively, the Responsible Parties). The
Responsible Parties are in turn managed by Waterfall Asset
Management, LLC, in its capacity as an SEC-registered investment
adviser. The servicer for this transaction is Mortgage Asset
Management, LLC (MAM). The sub-servicer is Compu-Link Corporation
d/b/a. Celink. The complete rating actions are as follows:

Issuer: CFMT 2019-HB1, LLC

Class A, Definitive Rating Assigned Aaa (sf)

Class M1, Definitive Rating Assigned Aa3 (sf)

Class M2, Definitive Rating Assigned A3 (sf)

Class M3, Definitive Rating Assigned Baa3 (sf)

Class M4, Definitive Rating Assigned Ba3 (sf)

RATINGS RATIONALE

The collateral backing CFMT 2019-HB1 consists of first-lien
inactive HECMs covered by Federal Housing Administration (FHA)
insurance secured by properties in the US. 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. SHAP 2018-1, LLC, acquired the mortgages through various
third party sponsors. All of the mortgage assets are covered by FHA
insurance for the repayment of principal up to certain amounts.
There are 1,100 mortgage assets with a balance of $263,493,439. The
assets are in either default, due and payable, referred, bankruptcy
or foreclosure 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 after this transaction closes.
10.06% of the assets are in default of which 0.64% (of the total
assets) are in default due to non-occupancy, 9.42% (of the total
assets) are in default due to taxes and insurance. 16.13% of the
assets are due and payable, 57.02% of the assets are in foreclosure
and 16.80% were in bankruptcy status.

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

Servicing

MAM will be the named servicer under the sale and servicing
agreement. MAM has the necessary processes, staff, technology and
overall infrastructure in place to effectively oversee the
servicing of this transaction. MAM will use Compu-Link Corporation,
d/b/a Celink (Celink) as sub-servicer to service the mortgage
assets. Based on an operational review of MAM, it has strong
sub-servicing monitoring processes, a seasoned servicing oversight
team and direct system access to the sub-servicers core systems. In
addition, a third party will review MAM's monthly servicing reports
on a quarterly basis to ensure data accuracy throughout the life of
the transaction.

Similar to other inactive HECM transactions (RBIT) Moody's has
rated, in CFMT 2019-HB1 an independent accountant firm or a
due-diligence review firm (the verification agent) will perform
quarterly procedures with respect to the monthly servicing reports
delivered by the servicer to the trustee. These procedures will
include comparison of the underlying records relating to the
subservicer's servicing of the loans and determination of the
mathematical accuracy of calculations of loan balances stated in
the monthly servicing reports delivered to the trustee. Any
material exceptions identified as a result of the procedures will
be described in the verification agent's report. To the extent the
verification agent identifies errors in the monthly servicing
reports, the servicer will be obligated to correct them.

Transaction Structure

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

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 February 2022. For the Class
M1 notes, the expected final payment date is in August 2022. For
the Class M2 notes, the expected final payment date is in November
2022. For the Class M3 notes, the expected final payment date is in
March 2023. For the Class M4 notes, the expected final payment date
is in June 2023. For the Class M5 notes, the expected final payment
date is in August 2023. For each of the subordinate notes, there
are various target amortization periods that conclude on the
respective expected final payment dates. The legal stated maturity
of the transaction is 10 years.

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

Certain aspects of the waterfall are dependent upon MAM remaining
as servicer. Servicing fees and servicer related reimbursements are
subordinated to interest and principal payments while MAM is
servicer. However, servicing advances (i.e. taxes, insurance and
property preservation) will instead have priority over interest and
principal payments in the event that MAM defaults and a new
servicer is appointed. The transaction provides a strong mechanism
to ensure continuous advancing for the assets in the pool. Of note,
in contrast to HECM securitizations issued by other sponsors
Moody's has rated to date, the transaction structure here is
somewhat different, where MAM, the servicer, is wholly owned by the
sponsor, and in turn, the sponsor's membership interests are
wholly-owned in various proportions by the Responsible Parties
(Victoria, Eden, Sandstone and Rock Island). The sponsor is managed
by Waterfall, in its capacity as an SEC-registered investment
adviser.

In this transaction, to the extent that the Servicer or sponsor
lack sufficient funds to reimburse the trust for any of the
obligations contemplated by the transaction documents (including to
the extent the Servicer lacks sufficient funds to make any
servicing advances or principal advances), the Responsible Parties
will capitalize the sponsor in amounts sufficient to cover such
obligations. The obligations of the Responsible Parties to honor
any commitments of the sponsor are several and not joint, based on
respective defined percentages of ownership of the sponsor.
Overall, Moody's believes that this arrangement provides a
relatively high alignment of interests between the parties to the
transaction to meet their respective financial commitments as
contemplated under the transaction documents.

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

Third-Party Review

A third party firm conducted a review of certain characteristics of
the mortgage assets on behalf of SHAP 2018-1 LLC. The review
focused on data integrity, SHAP 2018-1 LLC insurance coverage
verification, accuracy of appraisal recording, accuracy of
occupancy status recording, borrower age documentation,
identification of excessive corporate advances, documentation of
servicer advances, and identification of tax liens. Also, broker
price opinions (BPOs) were ordered for 198 properties in the pool.

The TPR firm conducted an extensive data integrity review. Certain
data tape fields, such as the MIP rate, the current UPB, current
interest rate, and marketable title date were reviewed against
MAM'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.

Certain of the TPR results were in line with recent inactive HECM
transactions that Moody's has rated including the results related
to the accuracy of reported valuations, the presence of FHA
insurance and the accuracy of reported disbursements. However,
other TPR results were the weakest compared to other inactive HECM
transactions such as the high rate of exceptions in data integrity
for called due date, UPB at called due date, and foreclosure and
bankruptcy fees advances above the allowable limit. CFMT 2019-HB1's
TPR results showed a 36.7% initial-tape exception rate related to
the called due date, 25.1% initial-tape exception rate related to
the UPB at called due date and a 39.6% initial-tape exception rate
related to foreclosure and bankruptcy fees advances above the
allowable limit. In its analysis, Moody's applied adjustments to
account for the TPR results in certain areas.

Reps & Warranties (R&W)

The sponsor, SHAP 2018-1 LLC, (and ultimately the Responsible
Parties who own the sponsor) is the loan-level R&W provider and is
unrated. This risk is mitigated by the fact that a third-party due
diligence firm conducted a review on the loans for evidence of FHA
insurance.

The sponsor represents that the mortgage loans are covered by FHA
insurance that is in full force and effect. Among other
considerations, the R&Ws address title, first lien position,
enforceability of the lien, regulatory compliance, and the
condition of the property. There is also a no fraud R&W (which also
covers misrepresentation, material error or omission or gross
negligence) covering the origination of the mortgage loans,
determination of value of the mortgaged properties, and the sale
and servicing of the mortgage loans. Although numerous R&Ws include
knowledge qualifiers, there is a mitigating R&W claw-back
provision, that is, even if the sponsor did not have actual
knowledge of the breach, the sponsor is still required to remedy
the breach in the same manner as if no knowledge qualifier had been
made.

Upon the identification of an R&W breach, the sponsor has to cure
the breach. If the sponsor is unable to cure the breach, the
sponsor 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, the sponsor,
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.

The Responsible Parties will fund a repurchase of the related
mortgage assets to the extent the sponsor is not able to satisfy
such obligations. The obligations of the Responsible Parties to
honor any commitments of the sponsor are several, not joint. In
other words, the liability of each Responsible Party is in
accordance with its respective ownership percentage in SHAP 2018-1
LLC. Moody's believes that the wherewithal of the Responsible
Parties is sufficient to support such obligations, if need be.

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 sponsor. Moody's believes that CFMT
2019-HB1 is adequately protected against such risk in part because
a third-party data integrity review was conducted on a significant
random sample of the loans.

Trustees

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

Methodology

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

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

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

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

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. To make
this assumption, Moody's considered industry data and the
historical experience of MAM. Moody's stressed this percentage at
higher credit rating levels. In a Aaa scenario, Moody's assumed
that these ABC appraisal haircuts could reach up to 30.0%.

In its asset analysis, Moody's also assumed there would be some
losses for SBCs, albeit lower amounts than for ABCs. Based on
historical performance, in the base case scenario 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. In a Aaa scenario, 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 ABC and SBC sales disposition payments and
associated insurance payments (four payments in total). All
payments are then probability weighted and run through a modeled
liability structure. Moody's considered industry data and the
historical experience of MAM in its analysis. 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 asset is categorized into one of four
categories: default, due and payable, foreclosure and REO. In its
analysis, Moody's assumes loans that are in referred status to be
either in the foreclosure or REO category. The loans are assumed to
move through each of these stages until being sold out of REO.
Moody's assumed that loans would be in default status for six to
nine months depending on the default reason. Due and payable status
is expected to last six to 12 months depending on the default
reason. REO disposition is assumed to take place in six months for
SBCs and 12 months for ABCs.

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

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

Debenture interest: The receipt of debenture interest is dependent
upon performance of certain actions within certain timelines by the
servicer. If these timeline and performance benchmarks are not met
by the servicer, debenture interest is subject to curtailment. Its
base case assumption is that 90.0% of debenture interest will be
received by the trust. Moody's stressed the amount of debenture
interest that will be received at higher rating levels. Moody's
made an additional adjustment to the debenture interest that will
be received by the trust because of the TPR findings. Its debenture
interest assumptions reflect the requirement that MAM reimburse the
trust for debenture interest curtailments due to servicing errors
or failures to comply with HUD guidelines. However, the transaction
documents do not specify a required time frame within which the
servicer must reimburse the trust for debenture interest
curtailments. As such, there may be a delay between when insurance
payments are received and when debenture interest curtailments are
reimbursed. Its debenture interest assumptions take this into
consideration. Its assumption for recovered debenture interest is
low compared to prior FASST and RMIT transactions due to the
relatively high percentage of missed servicing milestone mortgage
assets in the pool. Of note, the debenture rate is actually higher
than the note rate in CFMT 2019-HB1 as majority of the pool
comprises of ARM loans and it is currently at a lower rate compared
to debenture rate that is set at origination.

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 loan's appraisal value (post haircut) to its UPB.

  -- Moody's assumed that foreclosure costs will average $4,500 per
loan, two thirds of which will be reimbursed by the FHA. 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.

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.


CITIGROUP COMMERCIAL 2019-C7: Moody's Rates Class 805C Certs B3
---------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to 3 classes
of loan-specific CMBS securities, issued by Citigroup Commercial
Mortgage Trust 2019-C7, Commercial Mortgage Pass-Through
Certificates, Series 2019-C7.

Cl. 805A, Definitive Rating Assigned Baa3 (sf)

Cl. 805B, Definitive Rating Assigned Ba3 (sf)

Cl. 805C, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

The loan-specific certificates are collateralized by a $125.0
million B-note, which is a junior component of a $275.0 million,
fixed-rate mortgage loan secured by the borrower's fee simple
interest in 596,100 SF office property at 805 Third Avenue, New
York, NY. Its ratings are based on the credit quality of the loan
and the strength of the securitization structure. In addition to
the rake certificates, the transaction will also issue the
following certificates that are not being rated by Moody's: Class
A-1, Class A-2, Class A-3, Class A-4, Class A-AB, Class X-A, Class
A-S, Class B, Class C, Class X-B, Class X-D, Class X-F, Class X-G,
Class X-H, Class D, Class E, Class F, Class G, Class H, Class J-RR,
Class R, Class K-RR, and Class S Certificates. The loan-specific
certificates will be entitled to receive distributions only from
the B-note, which will not be part of the pool of mortgage loans
backing the pooled certificates. Similarly, the rake certificates
will only incur losses that are allocated to the B-note.

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

The credit risk of commercial real estate loans is determined
primarily by two factors: 1) the probability of default, which is
largely driven by the DSCR, and 2) the severity of loss in the
event of default, which is largely driven by the LTV of the
underlying loan.

The mortgage loan balance of $275.0 million represents a Moody's
LTV of 135.8%. The Moody's Trust Loan Actual DSCR is 1.46X and
Moody's Trust Loan Stressed DSCR is 0.64X. The whole loan of $275.0
million is split into multiple promissory notes that include: a
$50.0 million senior trust note that is being contributed to this
transaction as a pooled asset; a $125.0 million subordinate B note
as a non-pooled asset of the trust supporting the rake
certificates; and $100.0 million of non-trust pari passu notes that
are expected to be contributed to future CMBS conduit
transactions.

The collateral under the mortgage loan is a 29-story office
building located at 805 Third Avenue. The property is situated on a
0.57-acre site on the east side of Third Avenue between 49th and
50th Streets. The Cohen Brothers developed 805 Third Avenue in 1982
and have owned the property since. The property contains
approximately 596,100 SF of net rentable area ("NRA") that was
91.9% occupied as of October 2019. The largest tenant, Meredith
Corp (35.7% of NRA) has subleased the majority of its space to
multiple tenants including KBRA (16.0% of NRA) and Gen II Fund
(11.8% of NRA). No other tenant or subtenant occupies more than
6.9% of NRA.

Notable strengths of the transaction include: the Midtown Manhattan
location, stable occupancy history, below-market rents, and the
strong sponsorship.

Notable credit challenges of the transaction include: lack of
diversity for this single asset transaction, high leverage,
age/condition of the asset, and increasing competition from newly
constructed as well as recently renovated properties.

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 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 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.

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

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


COMM 2013-CCRE10: Moody's Affirms B3 Rating on Class F Debt
-----------------------------------------------------------
Moody's Investors Service upgraded the ratings of two classes and
affirmed the ratings of 11 classes in COMM 2013-CCRE10 Mortgage
Trust as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed Aaa
(sf)

Cl. A-3FL, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed
Aaa (sf)

Cl. A-3FX, 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-M, Affirmed Aaa (sf); previously on Jun 15, 2018 Affirmed Aaa
(sf)

Cl. A-SB, 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 Ba3 (sf); previously on Jun 15, 2018 Affirmed Ba3
(sf)

Cl. F, Affirmed B3 (sf); previously on Jun 15, 2018 Affirmed B3
(sf)

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

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

* Reflects Interest Only Classes

** Reflects Exchangeable Classes

RATINGS RATIONALE

The ratings on P&I classes Cl.B and Cl.C were upgraded based
primarily on an increase in credit support resulting from loan
paydowns and amortization. The deal has paid down 10% since Moody's
last review. In addition, loans constituting 19%% of the pool have
defeased.

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

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

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

Moody's rating action reflects a base expected loss of 1.1% of the
current pooled balance, compared to 3.6% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.6% of the
original pooled balance, compared to 3.6% 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 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 the 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 (IO) Securities" published in
February 2019.

DEAL PERFORMANCE

As of the December 12, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 20% to $805 million
from $1.01 billion at securitization. The certificates are
collateralized by 48 mortgage loans ranging in size from less than
1% to 12.4% of the pool, with the top ten loans (excluding
defeasance) constituting 54.2% of the pool. One loan, constituting
12.4% of the pool, has an investment-grade structured credit
assessment. One loan, constituting 12.4% of the pool, has an
investment-grade structured credit assessment. Eleven loans,
constituting 18.7% 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 17, compared to 23 at Moody's last review.

One loan has been liquidated from the pool, resulting in a realized
loss of $17.2 million (for an average loss severity of 99.8%).
There are currently no loans in special servicing.

Seven loans, constituting 12.3% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Moody's received full year 2018 operating results for 93% of the
pool, and full or partial year 2019 operating results for 81% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 89%, compared to 96% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 15% 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 1.58X and 1.22X,
respectively, compared to 1.52X and 1.13X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The loan with a structured credit assessment is the One Wilshire
Loan ($100.0 million -- 12.4% of the pool), which represents a pari
passu portion of a $180.0 million first mortgage loan. The loan is
secured by a 663,000 square-foot (SF) Class A office building and
colocation center in Los Angeles, California. The building operated
as a traditional office building until 1992, when the building was
converted to a telecommunications building through installation of
infrastructure necessary to attract telecommunication companies.
The building is recognized as the primary communications hub
connecting North America and Asia, the most significant point of
interconnection in the western United States, and of one the top
three network interconnections points in the world. The property
was 90% leased as of September 2019, compared to 86% leased as of
December 2017 and 92% at securitization. Moody's structured credit
assessment and stressed DSCR are a1 (sca.pd) and 1.59X,
respectively.

The top three conduit loans represent 17.6% of the pool balance.
The largest loan is the RHP Portfolio IV Loan ($51.1 million --
6.3% of the pool), which is secured by a portfolio of five
manufactured housing communities located across four states:
Florida (2), Kansas (1), New York (1), and Utah (1). The property
was acquired by the sponsor in 2013 as part of a 35 property
portfolio. The sponsor, RHP Properties, is one of the largest
operators of manufactured housing communities in the United States.
The portfolio was 92% leased as of June 2019, compared to 88%
leased as of December 2017 and 83% at securitization. Moody's LTV
and stressed DSCR are 107% and 0.92X, respectively, compared to
110% and 0.90X at the last review.

The second largest loan is the RHP Portfolio V Loan ($49.6 million
-- 6.2% of the pool), which is secured by a portfolio of seven
manufactured housing communities located across four states:
Florida (2), Kansas (1), New York (1), and Utah (3). The property
was acquired by the sponsor in 2013 as part of a 35 property
portfolio. The sponsor is also RHP Properties. The portfolio was
78% leased as of September 2019, the same as in December 2017 and
79% at securitization. Moody's LTV and stressed DSCR are 105% and
0.93X, respectively, compared to 108% and 0.90X at the last
review.

The third largest loan is the Brighton Town Square Loan ($40.8
million -- 5.1% of the pool), which is secured by a 328,000 SF
mixed-use power center located in Brighton, Michigan, approximately
20 miles north of Ann Arbor and 45 miles northwest of Detroit. The
property is comprised of a 236,000 SF retail component and 91,500
SF office component. Major tenants at the property include Home
Depot, MJR Theatre, and the University of Michigan, which operates
a medical office at the property. Other major tenants include
Staples, Party City, and KeyBank. The collateral is also
shadow-anchored by a Target. The property was 98% leased as of
September 2019, the same in December 2017 and 93% at
securitization. Moody's LTV and stressed DSCR are 101% and 1.05X,
respectively, compared to 103% and 1.02X at the last review.


COMM 2019-GC44: Moody's Assigns B3 Rating on Class 180W-C Certs
---------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to 10 classes
of CMBS securities, issued by COMM 2019-GC44 Mortgage Trust
Commercial Mortgage Pass-Through Certificates, Series 2019-GC44:

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-SB, Definitive Rating Assigned Aaa (sf)

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

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

Cl. A-M, Definitive Rating Assigned Aa3 (sf)

Cl. 180W-A***, Definitive Rating Assigned Baa3 (sf)

Cl. 180W-B***, Definitive Rating Assigned Ba3 (sf)

Cl. 180W-C***, Definitive Rating Assigned B3 (sf)

*** Reflects rake bond classes

RATINGS RATIONALE

The Certificates are collateralized by 43 fixed rate loans secured
by 55 properties. The ratings are based on the collateral and the
structure of the transaction.

Moody's approach to rating CMBS deals combines both commercial real
estate and structured finance analysis. Based on commercial real
estate analysis, Moody's determines the credit quality of each
mortgage loan and calculates an expected loss on a loan specific
basis. Under structured finance, the credit enhancement for each
certificate typically depends on the expected frequency, severity,
and timing of future losses. 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 Moody's Actual DSCR of 2.36x (2.03x excluding credit assessed
loans) is better than the 2018 conduit/fusion transaction average
of 1.69x, and better than the trailing four quarters ending Q3 2019
conduit/fusion transactions average of 1.67x. The Moody's Stressed
DSCR of 0.97x (0.92x excluding credit assessed loans) is largely
in-line with the trailing four quarters ending Q3 2019
conduit/fusion transaction average of 1.00x.

The pooled trust loan balance of $1,024,298,346 represents a
Moody's LTV ratio of 104.3% (112.9% excluding credit assessed
loans), which is lower than the 2018 conduit/fusion transaction
average of 113.2% and higher than the trailing four quarters ending
Q3 2019 transaction average of 111.9%. There are five loans in the
pool structured with additional debt in the form of subordinate
debt, mezzanine debt, or debt-like preferred equity. With the
additional debt, the Moody's total debt LTV ratio rises to 109.3%
(114.4% excluding credit assessed loans).

Moody's also considers both loan level diversity and property level
diversity when selecting a ratings approach. With respect to loan
level diversity, the pool's loan level Herfindahl score is 27.9.
The transaction loan level diversity profile is lower than the
Moody's-rated transactions during the prior four quarters, which
averaged 30.5. With respect to property level diversity, the pool's
property level Herfindahl score is 34.4.

The following notable strengths of the transaction include:

(i) CRE quality is very strong: The pool's weighted average
Property Quality Grade is 1.88 (2.21 excluding SCAs), which is much
stronger than the Moody's 2018 conduit/fusion average quality grade
of 2.42. Moreover, the pool's top 10 loans have a very strong
weighted average Property Quality Grade of 1.48. Of these, eight
were assigned quality grades of 2.00 or less.

(ii) Market composition: Loans representing approximately 47.0% of
the pool balance are secured by real estate located in the top tier
major MSAs of New York (12.4%), Los Angeles (11.9%), San
Francisco/Oakland/San Jose (8.5%), Boston (8.4%) and Chicago
(5.8%). Moreover, properties located in small markets collateralize
loans represent only 10.5% of the pool balance.

(iii) Share of multiple-property loans: Five loans (15.3% of the
pool balance) are secured by multiple properties and/or cross
collateralized assets.

The following notable concerns of the transaction include:

(i) High Moody's LTV: The pool has a weighted average Moody's LTV
("MLTV") ratio of 104.3% (112.9% excluding SCAs).

(ii) High full-term IO loan share: The amortization profile for the
underlying assets contains a high concentration of loans with
interest-only debt service components. Twenty-eight loans (66.3% of
the pool balance) are structured with interest-only payment
schedules for the entire term of the loan, seven loans (16.7% of
the pool balance) are structured with an initial interest-only
period followed by fixed amortization payments, and eight loans
(17.0% of the pool balance) are structured with amortization during
the entire loan term prior to a balloon payment obligation.

(iii) Single tenant share: The pool contains four loans comprised
of 12 properties (13.0% of the pool balance) that are leased to
single tenants.

(iv) Low share of acquisition financing: Only eight loans (19.9% of
the pool balance) represent acquisition financing.

Moody's also grades properties on a scale of 0 to 5 (best to worst)
and considers those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The pool's weighted
average property quality grade is 1.88 (2.21 excluding credit
assessed loans), which is better than the average score of 2.42
calculated across Moody's-rated multi-borrower transactions during
the prior four quarters.

The principal methodology used in rating all tranches except rake
bond classes was "Approach to Rating US and Canadian Conduit/
Fusion CMBS" published in July 2017. The principal methodology used
in rating rake bond classes was "Moody's Approach to Rating Large
Loan and Single Asset/Single Borrower CMBS" published in July
2017.

Moody's analysis of credit enhancement levels for conduit deals is
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate Moody's uses to estimate Moody's value). Moody's fuses the
conduit results with the results of its analysis of
investment-grade structured credit assessed loans and any conduit
loan that represents 10% or greater of the current pool balance.

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.


CWALT INC 2005-16: Moody's Cuts Rating on Class A-4 Debt to B2
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five tranches
from two RMBS transactions, backed by Option-Arm mortgage loans
issued by CWALT.

Issuer: CWALT, Inc. Mortgage Pass-Through Certificates, Series
2005-16

Cl. A-3, Downgraded to B2 (sf); previously on Oct 7, 2016 Upgraded
to Ba2 (sf)

Cl. A-4, Downgraded to B2 (sf); previously on Oct 7, 2016 Upgraded
to Ba2 (sf)

Issuer: CWALT, Inc. Mortgage Pass-Through Certificates, Series
2005-24

Cl. 2-A-1A, Downgraded to Caa2 (sf); previously on Sep 19, 2016
Upgraded to Caa1 (sf)

Cl. 2-A-1B, Downgraded to Caa1 (sf); previously on Sep 19, 2016
Upgraded to B3 (sf)

Cl. 4-A-1, Downgraded to B1 (sf); previously on Aug 31, 2017
Upgraded to Ba1 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance and Moody's
updated loss expectations on the underlying pools. The rating
downgrades are due to the weaker performance of the underlying
collateral and/or the erosion of enhancement available to the
bonds.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.5% in November 2019 from 3.7% in
November 2018. Moody's forecasts an unemployment central range of
3.8% to 4.2% for the 2020 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 2020. 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.


DBUBS 2011-LC3: Moody's Upgrades Class F Debt to B3(sf)
-------------------------------------------------------
Moody's Investors Service upgraded the rating on one class,
affirmed the ratings on five classes and downgraded the ratings on
three classes in DBUBS 2011-LC3 Mortgage Trust as follows:

Cl. A-4, Affirmed Aaa (sf); previously on Oct 14, 2018 Affirmed Aaa
(sf)

Cl. A-M, Affirmed Aaa (sf); previously on Oct 14, 2018 Affirmed Aaa
(sf)

Cl. B, Affirmed Aaa (sf); previously on Oct 14, 2018 Affirmed Aaa
(sf)

Cl. C, Upgraded to Aa1 (sf); previously on Oct 14, 2018 Affirmed
Aa3 (sf)

Cl. D, Affirmed Baa1 (sf); previously on Oct 14, 2018 Affirmed Baa1
(sf)

Cl. E, Downgraded to Ba2 (sf); previously on Oct 14, 2018 Affirmed
Ba1 (sf)

Cl. F, Downgraded to B3 (sf); previously on Oct 14, 2018 Affirmed
B2 (sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Oct 14, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Downgraded to B1 (sf); previously on Oct 14, 2018
Affirmed Ba3 (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The rating on class Cl. C was upgraded due to a significant
increase in defeasance, to 47% of the current pool balance from 21%
at the last review.

The ratings on four 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 rating on two P&I classes, Cl. E and Cl. F, were downgraded due
to a decline in pool performance driven primarily by higher
anticipated losses from specially serviced loans and a decline in
performance of Albany Mall and Dover Mall and Commons.

The rating on the interest only (IO) class, Cl. X-A, was affirmed
based on the credit quality of the referenced classes.

The rating on the interest only (IO) class, Cl. X-B, was downgraded
based on the credit quality of the referenced classes.

Moody's rating action reflects a base expected loss of 6.5% of the
current pooled balance, compared to 2.1% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.3% of the
original pooled balance, compared to 1.6% 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 (IO)
Securities" published in February 2019.

DEAL PERFORMANCE

As of the December 12, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 65% to $493 million
from $1.40 billion at securitization. The certificates are
collateralized by 22 mortgage loans ranging in size from less than
1% to 17% of the pool, with the top ten loans (excluding
defeasance) constituting 51% of the pool. Nine loans, constituting
47% 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 six, compared to a Herf of seven at Moody's last
review.

Eight loans, constituting 46% 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.

Two loans, constituting 4.1% of the pool, are currently in special
servicing. The largest specially serviced loan is the Western
Lights Shopping Center Loan ($14.7 million -- 3.0% of the pool),
which is secured by a retail property located in Syracuse, New
York. The property is anchored by a Price Chopper food store and is
shadow anchored by a Wegman's. A 37,000 square foot (SF) tenant
vacated three years ago and a 25,000 SF tenant vacated in Q4 2018.
The loan transferred to special servicing in December 2018 for
imminent monetary default.

The other specially serviced loan is the Ba Mar Basin MHC Loan
($5.6 million -- 1.1% of the pool), which is secured by a mobile
home community located in Stony Point, New York, that suffered
substantial damage in 2012's hurricane Sandy and has been unable to
rebuild the park due to changes in land use rules. The loan
transferred to special servicing in April 2019 for imminent
monetary default.

Moody's has also assumed a high default probability for one poorly
performing loan, Albany Mall, constituting 5% of the pool, and has
estimated an aggregate loss of $22.8 million (a 50% expected loss
based on an 89% probability default) from the specially serviced
and troubled loans.

Moody's received full year 2017 and 2018 operating results for 100%
of the pool, and partial year 2019 operating results for 85% of the
pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 106%, 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 20% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 10%.

Moody's actual and stressed conduit DSCRs are 1.32X and 1.07X,
respectively, compared to 1.35X and 1.07X 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 loans not in special servicing represent 31% of the
pool balance. The largest loan is the Dover Mall and Commons Loan
($81.9 million -- 16.6% of the pool), which is secured by an
approximately 554,000 SF component of an 886,000 SF single-level
enclosed super-regional mall located in Dover, Delaware. Mall
anchors include Macy's, Boscov's (non-collateral), and JC Penney
(non-collateral). Sears, a former anchor representing 20% of the
NRA, closed its store at this location in August 2018. As of
December 2018, the collateral was 92% leased, however, Sears
represented 20% of the NRA. Moody's LTV and stressed DSCR are 123%
and 0.92X, respectively, compared to 121% and 0.90X at the last
review.

The second largest loan is the Providence Place Mall Loan ($43.8
million -- 8.9% of the pool), which is secured by a 980,000 SF
portion of a 1.2 million SF regional mall in downtown Providence,
Rhode Island. The property anchors include Macy's (non-collateral),
Boscov's and Providence Place Cinemas. This loan has non-pooled
debt, some of which is held as rake bonds in this deal (not rated
by Moody's). Of the rake bonds, one -- the A-2 note -- is
pari-passu with the A note for Providence Place Mall. As of
September 2019, the collateral was 92% leased, compared to 88% at
the prior review. Moody's LTV and stressed DSCR are 40% and 2.45X,
respectively, compared to 42% and 2.34X at the last review.

The third largest loan is the Albany Mall Loan ($25.3 million --
5.1% of the pool), which is secured by a 447,900 SF component of a
756,300 SF regional mall in Albany, Georgia. Non-collateral anchor
tenants at the property include Dillard's, J.C. Penney and Belk.
One former anchor, Sears, closed its store at this location in
March 2017. As of December 2018, the total mall was 71% occupied
compared to 74% as of December 2017. Performance has deteriorated
since securitization as revenue has declined by more than 16% from
underwritten levels. Additionally, renewing tenants have generally
signed leases at the similar or lower rents due to a lack of sales
growth at the property. Due to the declines in financial
performance, Moody's has identified this as a troubled loan.


GS MORTGAGE 2012-GCJ9: Moody's Affirms B2 Rating on Cl. F Certs
---------------------------------------------------------------
Moody's Investors Service upgraded the rating on one class and
affirmed the ratings on nine classes in GS Mortgage Securities
Trust 2012-GCJ9, Commercial Mortgage Pass-Through Certificates,
Series 2012-GCJ9 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Jun 19, 2018 Affirmed Aaa
(sf)

Cl. A-AB, Affirmed Aaa (sf); previously on Jun 19, 2018 Affirmed
Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on Jun 19, 2018 Affirmed Aaa
(sf)

Cl. B, Upgraded to Aa2 (sf); previously on Jun 19, 2018 Affirmed
Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on Jun 19, 2018 Affirmed A3
(sf)

Cl. D, Affirmed Baa3 (sf); previously on Jun 19, 2018 Affirmed Baa3
(sf)

Cl. E, Affirmed Ba2 (sf); previously on Jun 19, 2018 Affirmed Ba2
(sf)

Cl. F, Affirmed B2 (sf); previously on Jun 19, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Jun 19, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed B1 (sf); previously on Jun 19, 2018 Affirmed B1
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

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

The rating on the P&I class, Cl. B, was upgraded based primarily on
an increase in credit support resulting from loan paydowns and
amortization as well as the significant increase in defeasance. The
deal has paid down 24% since securitization and defeasance now
represents 22% of the current pool balance.

The ratings on the interest only (IO) classes were affirmed based
on the credit quality of their referenced classes.

Moody's rating action reflects a base expected loss of 2.5% of the
current pooled balance, compared to 4.3% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.8% of the
original pooled balance, compared to 3.6% 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 (IO)
Securities" published in February 2019.

DEAL PERFORMANCE

As of the December 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 24% to $1.05 billion
from $1.39 billion at securitization. The certificates are
collateralized by 64 mortgage loans ranging in size from less than
1% to 13% of the pool, with the top ten loans (excluding
defeasance) constituting 55% 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 13, compared to 18 at Moody's last review.

Twelve loans, constituting 34% 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.

Four loans have been liquidated from the pool, resulting in an
aggregate realized loss of $12.8 million (for an average loss
severity of 61%). One loan, Residence Inn -- Buffalo ($5.6 million
-- 0.5% of the pool), is currently in special servicing. The loan
is secured by a 112-unit extended stay lodging property located in
Buffalo, NY. Loan transferred to special servicing in June 2019 for
a borrower declared imminent default. Moody's estimates a moderate
loss for the specially serviced loan.

Moody's received full year 2018 operating results for 98% of the
pool, and partial year 2019 operating results for 100% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 97%, compared to 96% at Moody's last review.
Moody's conduit component excludes loans with structured credit
assessments, defeased and CTL loans, and specially serviced and
troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 11% 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 1.53X and 1.09X,
respectively, compared to 1.65X and 1.11X 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 Bristol Portfolio loan ($140 million -- 13.3%
of the pool), which is secured by two multifamily properties
located at 200 East 65th Street and 336 East 71st Street in New
York City. The property on 200 East 65th Street, also known as
Bristol Plaza, contains 297 residential condominiums, medical
office and retail space, of which 173 condominium units and the
commercial space serve as collateral for the loan. The property at
336 East 71st Street is a 30-unit apartment building built in 1910.
As of September 2019, the portfolio was 88% occupied, compared to
97% as of December 2018. The loan is interest only for the full
term. Moody's current LTV and stressed DSCR are 82% and 1.04X,
respectively, the same as at the last review.

The second largest loan is the Pinnacle I loan ($124.3 million --
11.8% of the pool), which is secured by a Class A, six-story,
393,000 square foot (SF) office building that includes a four-level
sub-grade parking garage located in Burbank, California. In
February 2019, the largest tenant Warner Music Group (195,166 SF,
50% of the net rentable area (NRA); lease expiration December 2019)
announced that it is moving to a building located in Downtown Los
Angeles. The borrower has entered into three lease agreements
commencing 2020 for a combined 218,479 SF. The leases will
back-fill the space currently occupied by Warner Music Group in its
entirety. As per the June 2019 rent roll, the property was 96%
leased, compared to 97% leased as of December 2018 and December
2017. Moody's current LTV and stressed DSCR are 109% and 0.94X,
respectively, compared to 112% and 0.92X at the last review.

The third largest loan is the Jamaica Center loan ($70.4 million --
6.7% of the pool), which is secured by a leasehold interest in a
3-story mixed-use complex containing 215,806 SF located in Jamaica
Queens, New York. The improvements were constructed in 2002 and
contain 95,295 SF of retail space, 83,000 SF of theater space, and
37,511 SF of office space. In addition, there is a two-level, below
grade parking garage providing 375 parking spaces. As per the June
2019 rent roll the property was 80% leased, compared to 77% leased
as of December 2018 and 88% leased as of December 2017. The loan
benefits from amortization and has amortized 13% since
securitization. Moody's LTV and stressed DSCR are 97% and 0.99X,
respectively, compared to 96% and 1.00X at the last review.


GS MORTGAGE 2013-GCJ16: Moody's Affirms B3 Rating on Cl. G Certs
----------------------------------------------------------------
Moody's Investors Service upgraded the ratings on five classes and
affirmed the ratings on eight classes in GS Mortgage Securities
Trust 2013-GCJ16, Commercial Mortgage Pass-Through Certificates,
Series 2013-GCJ16 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Jun 29, 2018 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Jun 29, 2018 Affirmed Aaa
(sf)

Cl. A-AB, Affirmed Aaa (sf); previously on Jun 29, 2018 Affirmed
Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on Jun 29, 2018 Affirmed Aaa
(sf)

Cl. B, Upgraded to Aa1 (sf); previously on Jun 29, 2018 Upgraded to
Aa2 (sf)

Cl. C, Upgraded to A1 (sf); previously on Jun 29, 2018 Upgraded to
A2 (sf)

Cl. D, Upgraded to Baa2 (sf); previously on Jun 29, 2018 Affirmed
Baa3 (sf)

Cl. E, Affirmed Ba1 (sf); previously on Jun 29, 2018 Affirmed Ba1
(sf)

Cl. F, Affirmed Ba3 (sf); previously on Jun 29, 2018 Affirmed Ba3
(sf)

Cl. G, Affirmed B3 (sf); previously on Jun 29, 2018 Affirmed B3
(sf)

Cl. PEZ**, Upgraded to Aa2 (sf); previously on Jun 29, 2018
Upgraded to Aa3 (sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Jun 29, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Upgraded to Aa1 (sf); previously on Jun 29, 2018 Upgraded
to Aa2 (sf)

* Reflects Interest Only Classes

** Reflects Exchangeable Classes

RATINGS RATIONALE

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

The ratings on the P&I classes, Cl. B, Cl. C, and Cl. D, were
upgraded based primarily on an increase in credit support resulting
from loan paydowns and amortization as well as the significant
increase in defeasance. The deal has paid down 28% since
securitization and defeasance now represents 19% of the current
pool balance.

The rating on the interest only(IO) class, Cl. X-A, was affirmed
based on the credit quality of its referenced classes.

The rating on the IO class, Cl. X-B, was upgraded based on an
improvement in the credit quality of its referenced class.

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

Moody's rating action reflects a base expected loss of 1.8% of the
current pooled balance, the same as at Moody's last review. Moody's
base expected loss plus realized losses is now 1.3% of the original
pooled balance, compared to 1.6% 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 principal methodology used in rating all classes except
exchangeable classes and interest-only classes was "Approach to
Rating US and Canadian Conduit/Fusion 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 and "Moody's Approach to Rating Structured
Finance Interest-Only (IO) Securities" published in February 2019.

DEAL PERFORMANCE

As of the December 10, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 28% to $783 million
from $1.09 billion at securitization. The certificates are
collateralized by 64 mortgage loans ranging in size from less than
1% to 9% of the pool, with the top ten loans (excluding defeasance)
constituting 49% of the pool. One loan, constituting 7% of the
pool, has an investment-grade structured credit assessment. Sixteen
loans, constituting 19% 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 20, compared to 27 at Moody's last review.

Seven loans, constituting 14% 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.

No loans have been liquidated from the pool. No loans are currently
in special servicing.

Moody's received full or partial year 2018 operating results for
100% of the pool, and partial year 2019 operating results for 90%
of the pool (excluding specially serviced and defeased loans).
Moody's weighted average conduit LTV is 89%, compared to 92% 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 9.5%.

Moody's actual and stressed conduit DSCRs are 1.57X and 1.20X,
respectively, compared to 1.57X and 1.18X 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 Gates at
Manhasset loan ($53.5 million -- 6.8% of the pool), which is
secured by a 106,000 square foot (SF) open air retail property
located on Northern Boulevard in Manhasset, New York. The property
was 97% leased as of June 2019, compared to 99% leased as of
December 2018 and 100% leased as of September 2017. The property's
major tenants include Crate & Barrel, Gap, and Urban Outfitters.
Moody's structured credit assessment and stressed DSCR are a1
(sca.pd) and 1.34X, respectively.

The top three conduit loans represent 23% of the pool balance. The
largest loan is the Miracle Mile Shops loan ($68.8 million -- 8.8%
of the pool), which represents a pari passu portion of a $570
million mortgage loan. The loan is secured by a 450,000 SF regional
mall located in the heart of the Las Vegas strip. The subject draws
from non-traditional anchors, three performing arts theaters and
the Las Vegas Strip itself. As of September 2019, the property was
97% leased, unchanged from December 2018 and December 2017. Moody's
LTV and stressed DSCR are 88% and 0.89X, respectively, compared to
89% and 0.88X at Moody's last review.

The second largest loan is the Windsor Court New Orleans Loan
($66.2 million -- 8.5% of the pool), which is secured by 316-key
hotel located in the central business district (CBD) of New
Orleans, Louisiana (less than one mile from the French Quarter).
For the trailing twelve-month period ending June 2019, the hotel
was 68% occupied and had a revenue per available room (RevPAR) of
$240, compared to an occupancy and RevPAR of 64% and $215,
respectively, for the prior trailing twelve-month period ending
June 2018. Moody's LTV and stressed DSCR are 94% and 1.27X,
respectively, compared to 96% and 1.24X at last review.

The third largest loan is the Walpole Shopping Mall Loan ($45.2
million -- 5.8% of the pool), which represents a pari-passu portion
of a $62.1 million mortgage loan. The loan is secured by a 397,791
SF retail center located in Walpole, Massachusetts. The property is
also encumbered by a $10 million mezzanine loan. The property was
96% leased as of September 2019, unchanged from December 2018. The
third largest tenant (7% of the NRA), OfficeMax, has an upcoming
lease expiration in January 2020. Moody's A-note LTV and stressed
DSCR are 117% and 0.85X, respectively, compared to 120% and 0.84X
at the last review.


JP MORGAN 2006-LDP7: Moody's Affirms Caa2 Rating on Cl. A-J Debt
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on six classes in
J.P. Morgan Chase Commercial Mortgage Securities Corp. Series
2006-LDP7 as follows:

Cl. A-J, Affirmed Caa2 (sf); previously on Jun 1, 2018 Affirmed
Caa2 (sf)

Cl. B, Affirmed C (sf); previously on Jun 1, 2018 Affirmed C (sf)

Cl. C, Affirmed C (sf); previously on Jun 1, 2018 Affirmed C (sf)

Cl. D, Affirmed C (sf); previously on Jun 1, 2018 Affirmed C (sf)

Cl. E, Affirmed C (sf); previously on Jun 1, 2018 Affirmed C (sf)

Cl. F, Affirmed C (sf); previously on Jun 1, 2018 Affirmed C (sf)

RATINGS RATIONALE

The ratings on the P&I classes were affirmed because the ratings
are consistent with Moody's expected loss plus realized losses.

Moody's rating action reflects a base expected loss of 88.3% of the
current pooled balance, compared to 60.4% at Moody's last review.
Moody's base expected loss plus realized losses is now 14.4% of the
original pooled balance, compared to 14.5% 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 98% of the pool is in
special servicing. 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 to the most junior classes and the recovery
as a pay down of principal to the most senior classes.

DEAL PERFORMANCE

As of the December 15, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 92% to $316 million
from $3.94 billion at securitization. The certificates are
collateralized by 13 mortgage loans ranging in size from less than
1% to 76% of the pool. One loan, constituting less than 0.5% of the
pool, has defeased and is secured by US government securities.

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

Sixty-three loans have been liquidated from the pool, resulting in
an aggregate realized loss of $287 million (for an average loss
severity of 44%). Eight loans, constituting 98% of the pool, are
currently in special servicing. The largest specially serviced loan
is the former Westfield Centro Portfolio ($240.0 million -- 75.9%
of the pool), which is currently secured by two mall properties.
The portfolio was originally secured by four mall properties and
one large retail center. Two of the properties were sold in 2017
and one was sold in 2019 and the proceeds were used to paydown
outstanding advances. The remaining two properties serving as
collateral for the loan are the West Park and Eagle Rock
properties. The Eagle Rock property is secured by a 460,000 square
foot (SF) regional mall located in Los Angeles, California, and the
West Park Property is secured by a 426,000 SF portion of a 510,000
SF regional mall located in Cape Girardeau, Missouri. The special
servicer indicated they plan to market the assets for sale in
January 2020.

The second largest specially serviced loan is the Doubletree --
Lisle / Naperville Loan (formerly the Hilton -- Lisle / Naperville)
($33.9 million -- 10.7% of the pool), which is secured by a 309-key
hotel located in Lisle, Illinois, approximately 30 miles west of
Chicago. The loan transferred to special servicing in February 2016
due to imminent maturity default and the property is now REO. The
property operated under the Hilton brand and is now being converted
to operate under the DoubleTree brand.

The third largest specially serviced loan is the Nilfisk Advance --
MN Loan ($15.2 million -- 4.8% of the pool), which is secured by an
industrial (warehouse / distribution) property located in Plymouth,
Minnesota. The property became REO in November 2016. The special
servicer indicated they are working to lease up the property.

The remaining five specially serviced loans are secured by a mix of
property types. Moody's estimates an aggregate $278 million loss
for the specially serviced loans (90% expected loss on average).

The four non-defeased performing loans represent 2.1% of the pool
balance. All four conduit loans are fully amortizing loans and have
amortized by between 50% and 85% since securitization. The
performing loans are secured by a mix of property types and each
has a Moody's LTV of less than 50%.


JP MORGAN 2018-PHH: Moody's Affirms B3 Rating on Cl. HRR Certs
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings on eight classes of
JP Morgan Chase Commercial Mortgage Securities Trust 2018-PHH,
Commercial Mortgage Pass-Through Certificates, Series 2018-PHH.
Moody's rating action is as follows:

Cl. A, Affirmed Aaa (sf); previously on Aug 7, 2018 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Aug 7, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on Aug 7, 2018 Definitive
Rating Assigned A3 (sf)

Cl. D, Affirmed Baa3 (sf); previously on Aug 7, 2018 Definitive
Rating Assigned Baa3 (sf)

Cl. E, Affirmed Ba3 (sf); previously on Aug 7, 2018 Definitive
Rating Assigned Ba3 (sf)

Cl. F, Affirmed B2 (sf); previously on Aug 7, 2018 Definitive
Rating Assigned B2 (sf)

Cl. HRR, Affirmed B3 (sf); previously on Aug 7, 2018 Definitive
Rating Assigned B3 (sf)

Cl. X-CP*, Affirmed A2 (sf); previously on Aug 7, 2018 Definitive
Rating Assigned A2 (sf)

* Reflects interest-only classes

RATINGS RATIONALE

Moody's has affirmed the ratings on seven 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. The rating on the IO class, Class
X-CP, is affirmed based on the credit quality of its reference
classes.

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

DEAL PERFORMANCE

As of the December 16, 2019 distribution date, the transaction's
aggregate certificate balance has decreased to approximately $329
million from approximately $333 million at securitization due to
annual principal paydown from 25% of excess cash flow. The
securitization is backed by a single floating-rate loan
collateralized by the borrower's fee simple interest in the Palmer
House Hilton. The 24-story, 1,642 guestroom property is located in
the central business district of Chicago, IL, one block west of
Millennium Park and Michigan Avenue. The interest only loan's final
maturity date (including three one-year extension options) is in
June 2023. There is an approximately $94 million of mezzanine debt
held outside of the trust.

The property was completed in 1925 and is part of a larger
mixed-use complex that includes non-collateral space consisting of
57,000 square feet of ground-floor retail space, a 13-story office
building and the attached valet parking garage. The hotel amenities
include food and beverage outlets, fitness facility, full-service
spa and 130,000 SF of meeting space.

The property's net cash flow for the trailing twelve month period
ending June 2019 was $27.6 million compared to $36.6 million at
securitization. The decline in NCF is noteworthy; however, the
Chicago market has experienced a large increase in new supply and
softening market conditions. Moody's will continue to monitor for
any further changes and trends for the property. Moody's stabilized
NCF is $28.4 million, the same as securitization. Moody's stressed
LTV and stressed DSCR for the first mortgage are 122% and 0.93X,
respectively. The trust has not incurred any losses or interest
shortfalls as of the current distribution date.


MAD COMMERCIAL 2019-650M: Fitch Rates $97.755MM Cl. B Certs B-sf
----------------------------------------------------------------
Fitch Ratings assigned ratings to MAD Commercial Mortgage Trust
2019-650M, Commercial Mortgage Pass-Through Certificates, Series
2019-650M as follows:

  -- $105,735,000 class A 'BB-sf'; Outlook Stable;

  -- $97,755,000 class B 'B-sf'; Outlook Stable.

The following classes are not expected to be rated:

  -- $10,710,000a class VRR.

(a) Vertical credit risk retention interest, which represents
approximately 5.00% of the certificate balance, of each class
certificates.

All classes are privately placed and pursuant to Rule 144A.

There were no changes since Fitch published its expected ratings on
Dec. 3, 2019. The classes reflect the final ratings and deal
structure based on information provided by the issuer as of Dec.
17, 2019.

The MAD Commercial Mortgage Trust 2019-650M, Commercial Mortgage
Pass-Through Certificates, Series 2019-650M, represent the
beneficial ownership interest in the trust loan portion of an
$800.0 million, 10-year, fixed-rate, interest-only mortgage loan
secured by the fee simple interest in a 600,415-sf, 27-story office
tower located at 650 Madison Avenue, between 59th and 60th Streets,
in New York City.

The total mortgage loan consists of $1.0 million of senior trust
notes (trust loan), $585.8 million of pari passu senior companion
loan notes (non-trust) and $213.2 million of junior trust notes
(trust loan). The class A certificates include $1.0 million of
senior trust notes and a portion of the junior trust notes. The
class B certificates consist solely of junior trust notes. The pari
passu senior companion loan notes will not be part of the assets of
this trust, and they are expected to be contributed to one or more
future securitizations.

Total mortgage loan proceeds, along with $20.0 million held in
existing debt reserve accounts and $9.5 million in sponsor equity,
were used to refinance $800.0 million of existing debt, fund
approximately $9.6 million in upfront reserves and pay closing
costs.

KEY RATING DRIVERS

High-Quality Office Collateral in Prime Location: The 650 Madison
Avenue property is a 27-story, class A office building occupying
the western block of Madison Avenue between 59th and 60th Streets
in the Plaza office submarket of Midtown Manhattan. Fitch assigned
a property quality grade of A.

Stable Historical Occupancy and High-Quality Tenancy: The property
was 97.4% occupied as of Oct. 31, 2019 and has exhibited average
occupancy of 94.5% since 1996. The property serves as global
corporate headquarters of Ralph Lauren and Sotheby's. Tenants with
investment-grade credit ratings account for 58.9% of the property's
gross rental revenue.

Institutional Sponsorship: Oxford Properties Group is the global
real estate investment, development and management arm of Ontario
Municipal Employees Retirement System (OMERS) Administration
Corporation (AAA/Stable). Oxford Properties Group owns and operates
a diversified real estate portfolio consisting of over 100 million
sf of office, retail and industrial space, in addition to
multifamily units. Vornado (BBB/Stable) is one of the largest
owners and managers of commercial real estate in the U.S. with a
portfolio of 37.1 million sf of office, retail and other commercial
space, primarily located in New York City.

Rollover Risk: Approximately 90.5% of the property's Net Rentable
Area (NRA) is subject to rollover during the loan term. The highest
rollover concentration during the loan term occurs in 2023 and
2024, when 19.7% and 53.7% of the property's NRA expires,
respectively. This includes the property's largest tenant, Ralph
Lauren (RL; 46.1% of NRA; 36.0% of gross rent) whose lease expires
in December 2024. The loan is structured with a "specific tenant
trigger" tied to the RL lease, which if tripped, will lead to
springing cash management.

Fitch Leverage: The $800.0 million mortgage loan has a Fitch DSCR
and LTV of 0.82x and 106.3%, respectively, and debt of $1,332psf.
The sponsor acquired the property in 2013 for $1.3 billion
(2,165.16 psf).

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 7.3% 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 MAD
Commercial Mortgage Trust, Series 2019-650M certificates and found
that the transaction displays average sensitivities to further
declines in NCF. In a scenario in which NCF declined a 10% from
Fitch's NCF, a downgrade of the 'BB-sf' certificates to 'B-sf'
could result. In a more severe scenario, in which NCF declined a
further 20% from Fitch's NCF, a downgrade of the 'BB-sf'
certificates to 'CCCsf' 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.


MORGAN STANLEY 2006-HQ10: Moody's Affirms C Rating on 4 Tranches
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on five classes in
Morgan Stanley Capital I Trust 2006-HQ10 as follows:

Cl. B, Affirmed Caa2 (sf); previously on Jul 20, 2018 Affirmed Caa2
(sf)

Cl. C, Affirmed C (sf); previously on Jul 20, 2018 Affirmed C (sf)

Cl. D, Affirmed C (sf); previously on Jul 20, 2018 Affirmed C (sf)

Cl. E, Affirmed C (sf); previously on Jul 20, 2018 Affirmed C (sf)

Cl. X-1*, Affirmed C (sf); previously on Jul 20, 2018 Affirmed C
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on four P&I classes were affirmed due to ratings being
in line with realized plus Moody's expected losses.

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

Moody's rating action reflects a base expected loss of 65.8% of the
current pooled balance, compared to 48.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 9.7% of the
original pooled balance, compared to 10.5% 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 rating all classes except
interest-only classes were "Moody's Approach to Rating Large Loan
and Single Asset/Single Borrower CMBS" published in July 2017. The
methodologies used in rating interest-only classes were "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 82% of the pool is in
special servicing. 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 to the most junior classes and the recovery
as a pay down of principal to the most senior class.

DEAL PERFORMANCE

As of the December 13, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 95.2% to $71.0
million from $1.5 billion at securitization. The certificates are
collateralized by four exposures, which includes one portfolio with
five remaining cross-collateralized loans.

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 3, the same as at Moody's last review.

Thirty loans have been liquidated from the pool, resulting in an
aggregate realized loss of $98.2 million (for an average loss
severity of 38%). Six loans (two exposures), constituting 82% of
the pool, are currently in special servicing. The largest specially
serviced loan is the PPG Portfolio Loan ($34.1 million -- 48.0% of
the pool), which was originally secured by seven medical office
properties located in Arizona, Colorado and Indiana, totaling
approximately 435,000 square feet (SF). The loan transferred to
special servicing in May 2016 due to imminent maturity default as
the loan was scheduled to mature in October 2016. Three properties
were released in 2018 while another three properties were sold
between 2018 and April 2019. The proceeds were used to paydown the
loan balance and outstanding interest shortfalls. The sole
remaining property in the portfolio is the Gateway Medical Center,
a 76,731 square feet (SF), located in Phoenix, Arizona. The
property has been REO since March 2018. Moody's anticipates a
significant loss on the loan's remaining balance.

The second largest specially serviced exposure is the Fort Roc
Portfolio Loan ($23.8 million -- 33.5% of the pool), which is
secured by five remaining cross-collateralized loans. The portfolio
was originally secured by six free-standing retailers and one
community shopping center located across four states: Pennsylvania,
New York, Tennessee and Delaware. The loan transferred to special
servicing in September 2016 for imminent maturity default. Two
single tenant properties in the portfolio were sold between October
2018 and April 2019 and the proceeds were used to paydown the loan
balance and outstanding advances and shortfalls. The remaining five
properties consists of two single tenant Rite Aids, one Kmart, one
vacant free-standing property formerly leased to Staples and a
community shopping center, Penn Plaza. Penn Plaza was only 34%
leased as of November 2019 following the closure of its anchor
tenant, Kmart. All remaining loans in the portfolio became REO
between March 2019 and October 2019.

As of the December 13, 2019 remittance statement cumulative
interest shortfalls were $8.5 million. Moody's anticipates interest
shortfalls will continue because of the exposure to specially
serviced loans and/or modified loans. Interest shortfalls are
caused by special servicing fees, including workout and liquidation
fees, appraisal entitlement reductions (ASERs), loan modifications
and extraordinary trust expenses.

The two performing loans represent 18.5% of the pool balance. The
largest loan is the Copperwood Apartments Loan ($9.6 million --
13.6% of the pool), which is secured by a 300-unit apartment
complex, built in 1982, renovated in 2000 and located in The
Woodlands, Texas. The property has enjoyed a sustained occupancy of
99% since securitization. The loan has amortized 16% since
securitization and Moody's LTV and stressed DSCR are 41% and 2.29X,
respectively, compared to 42% and 2.27X at the last review.

The other remaining performing loan is the Dick's Sporting Goods --
Akron Loan ($3.5 million -- 4.9% of the pool), which is secured by
a freestanding store within an open-air shopping center in Akron,
Ohio. The loan has passed its anticipated repayment date in October
2016 and has a final maturity date in October 2036. Given the
single tenant exposure for this loan, a lit/dark approach was
incorporated into Moody's analysis. The loan has amortized 19%
since securitization and Moody's LTV and stressed DSCR are 116% and
0.88X, respectively, compared to 122% and 0.84X at the last review.


MORGAN STANLEY 2019-NUGS: Moody's Gives Ba3 Rating on Cl. E Certs
-----------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to five
classes of CMBS securities, issued by Morgan Stanley Capital I
Trust 2019-NUGS, Commercial Mortgage Pass-Through Certificates,
Series 2019-NUGS.

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa3 (sf)

Cl. C, Definitive Rating Assigned A3 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba3 (sf)

Note: Moody's previously assigned a provisional rating to Class
X-CP, assigned (P) Aaa (sf), described in the prior press release,
dated December 10, 2019. Subsequent to the release of the
provisional ratings for this transaction, the Class X is no longer
being offered. Since the Class X-CP is no longer offered, Moody's
has withdrawn its provisional rating and will not rate this
certificate.

RATINGS RATIONALE

The certificates are collateralized by a single loan backed by a
first lien commercial mortgage related to Wells Fargo Center
located in CBD Denver, CO. The property is a 1,195,149 SF, Class A,
office property comprised of 52-story tower and an adjoining
12-story garage containing 996 enclosed parking spaces. It was
developed in 1983 and is amongst the tallest building in the city.
The loan is a five-year (fully extended), floating rate
interest-only, first-lien mortgage loan with an original and
outstanding principal balance of $277,100,000. Its ratings are
based on the credit quality of the loan and the strength of the
securitization structure.

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

The credit risk of commercial real estate loans is determined
primarily by two factors: 1) the probability of default, which is
largely driven by the DSCR, and 2) and the severity of loss in the
event of default, which is largely driven by the LTV of the
underlying loan.

The trust loan balance of $217,100,000 represents a Moody's LTV of
106.0%. The Moody's loan trust actual DSCR is 2.08x and Moody's
loan trust stressed DSCR at a 9.25% stressed constant is 0.89x. The
Moody's LTV including the non-trust b-note of $50,600,000 and
mezzanine loan of $45,300,000 is 142.7%.

Notable strengths of the transaction include: Property's location,
quality, recent capital improvements, investment grade tenancy, and
strong sponsorship.

Notable concerns of the transaction include: Moody's LTV ratio,
floating-rate interest-only mortgage loan profile, lack of asset
diversification, and certain credit negative legal features

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 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 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.

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

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


UBS COMMERCIAL 2019-C18: Fitch Rates $7.435MM Class G Certs B-sf
----------------------------------------------------------------
Fitch Ratings assigned the following ratings and Rating Outlooks to
UBS Commercial Mortgage Trust 2019-C18 Commercial Mortgage
Pass-Through Certificates, Series 2019-C18:

  -- $29,089,000 class A-1 'AAAsf'; Outlook Stable;

  -- $69,160,000 class A-2 'AAAsf'; Outlook Stable;

  -- $35,630,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $156,589,000 class A-3 'AAAsf'; Outlook Stable;

  -- $230,029,000 class A-4 'AAAsf'; Outlook Stable;

  -- $520,497,000a class X-A 'AAAsf'; Outlook Stable;

  -- $136,630,000a class X-B 'AA-sf'; Outlook Stable;

  -- $72,498,000 class A-S 'AAAsf'; Outlook Stable;

  -- $33,460,000 class B 'AA-sf'; Outlook Stable;

  -- $30,672,000 class C 'A-sf'; Outlook Stable;

  -- $36,249,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $14,872,000ab class X-F 'BB-sf'; Outlook Stable;

  -- $7,435,000ab class X-G 'B-sf'; Outlook Stable.

  -- $20,448,000b class D 'BBBsf'; Outlook Stable;

  -- $15,801,000b class E 'BBB-sf'; Outlook Stable;

  -- $14,872,000b class F 'BB-sf'; Outlook Stable;

  -- $7,435,000b class G 'B-sf'; Outlook Stable.

The following class is not rated by Fitch:

  -- $27,884,548bc class NR-RR;

(a) Notional amount and interest only.

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

(c) Represents the eligible horizontal credit-risk retention
interest.

TRANSACTION SUMMARY

Since Fitch published its expected ratings on Dec. 4, 2019, the
balances for class A-3 and class A-4 were finalized. At the time
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 $25,000,000 to $386,618,000 and $211,618,000 to
$361,618,000, 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 55 loans secured by 127
commercial properties having an aggregate principal balance of
$743,567,549 as of the cut-off date. The loans were contributed to
the trust by UBS Real Estate Securities Inc, Societe Generale,
Natixis Real Estate Capital LLC, Cantor Commercial Real Estate
Lending, L.P., Wells Fargo Bank, National Association, and Rialto
Real Estate Fund IV - Debt, LP

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 65.1% of the properties
by balance, cash flow analysis of 85.9% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Average Fitch Leverage: The pool's Fitch LTV is 102.1%, which is in
line with the YTD 2019 and 2018 averages of 102.8% and 102.0%,
respectively, for other Fitch-rated multiborrower transactions. The
pool's Fitch DSCR of 1.22x falls below the YTD 2019 average of
1.25x and is equal to the 2018 average of 1.22x; however, the
pool's weighted-average (WA) coupon was just 3.97%, which is below
2019 YTD and 2018 averages of 4.38% and 4.77%, respectively.

Lower Than Average Pool Concentration: The top 10 loans comprise
41.0% of the pool. This is a lower concentration than the YTD 2019
average of 51.4% and the 2018 average of 50.6%. The loan
concentration index (LCI) of 270 is also lower than the YTD 2019
average of 383 and 2018 average of 373.

Investment-Grade Credit Opinion Loans: Five loans totalling 19.2%
of the pool have investment-grade credit opinions on a stand-alone
basis. These loans include the largest loan, 225 Bush Street (4.7%
of the pool), 3 Columbus Circle and ILPT Industrial Portfolio (both
4.0% of the pool), DoubleTree New York Times Square West Leased Fee
(3.8% of the pool) and Century Plaza Towers (2.7% of the pool). The
YTD 2019 average pool composition of such loans is 13.9% and the
2018 average composition is 13.6%. Excluding credit opinion loans,
the Fitch DSCR and LTV are 1.22 and 109.6%.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 5.2% below
the most recent year's NOI for properties for which a full-year NOI
was provided, excluding properties that were stabilizing during
this period. Unanticipated further declines in property-level NCF
could result in higher defaults and loss severities on defaulted
loans and in potential rating actions on the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the UBS
2019-C18 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 'BBB+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.


US CAPITAL V: Moody's Hikes $42MM Cl. A-3 Notes to Ba1
------------------------------------------------------
Moody's Investors Service upgraded the ratings on the following
notes issued by U.S. Capital Funding V, Ltd.:

US$193,000,000 Class A-1 Floating Rate Senior Notes Due 2040
(current balance of $68,449,561.27), Upgraded to A1 (sf);
previously on October 30, 2017 Upgraded to A3 (sf);

US$30,000,000 Class A-2 Floating Rate Senior Notes Due 2040
(current balance of $30,000,000.00), Upgraded to Baa1 (sf);
previously on October 30, 2017 Upgraded to Baa2 (sf);

US$42,000,000 Class A-3 Floating Rate Senior Notes Due 2040
(current balance of $42,000,000.00), Upgraded to Ba1 (sf);
previously on October 30, 2017 Upgraded to Ba2 (sf);

U.S. Capital Funding V, Ltd., issued in October 2006, is a
collateralized debt obligation backed mainly by a portfolio of bank
trust preferred securities.

RATINGS RATIONALE

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

The Class A-1 notes have paid down by approximately 13.87% or $11.0
million since December 2018, using principal proceeds from the
redemption of the underlying assets and the diversion of excess
interest proceeds. Based on Moody's calculations, the OC ratios for
the Class A-1, Class A-2 and Class A-3 notes have improved to
229.59%, 159.62% and 111.89%, respectively, from December 2018
levels of 208.02%, 151.22% and 109.40%, respectively. The Class A-1
notes will continue to benefit from redemptions of any assets in
the collateral pool and the diversion of excess interest so long as
the Class A OC ratio (reported at 111.18% on the October 2019
trustee report compared to a trigger level of 114.22%) continues to
fail.

The deal has also benefited from improvement in the credit quality
of the underlying portfolio. According to Moody's calculations, the
weighted average rating factor (WARF) improved to 583 from 776 in
December 2018.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, and weighted average recovery rate,
are based on its methodology and could differ from the trustee's
reported numbers. In its base case, Moody's analyzed the underlying
collateral pool as having a performing par of $157.2 million,
defaulted/deferring par of $55.5 million, a weighted average
default probability of 6.58% (implying a WARF of 583), and a
weighted average recovery rate upon default of 10%.

Methodology Used for the Rating Action

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

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

The performance of the rated notes is subject to uncertainty. The
performance of the rated notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The portfolio consists primarily
of unrated assets whose default probability Moody's assesses
through credit scores derived using RiskCalcā„¢ or credit
assessments. Because these are not public ratings, they are subject
to additional estimation uncertainty.


WACHOVIA BANK 2004-C12: Fitch Hikes Class K Certs Rating to BBsf
----------------------------------------------------------------
Fitch Ratings upgraded two classes and downgraded four classes of
Wachovia Bank Commercial Mortgage Trust, commercial mortgage
pass-through certificates, series 2004-C12.

RATING ACTIONS

Wachovia Bank Commercial Mortgage Trust 2004-C12

Class J 929766SP9; LT Asf Upgrade;   previously at CCCsf

Class K 929766SQ7; LT BBsf Upgrade;  previously at CCCsf

Class L 929766SR5; LT Dsf Downgrade; previously at CCsf

Class M 929766SS3; LT Dsf Downgrade; previously at Csf

Class N 929766ST1; LT Dsf Downgrade; previously at Csf

Class O 929766SU8; LT Dsf Downgrade; previously at Csf

KEY RATING DRIVERS

Lower Loss Expectations: The upgrades to classes J and K reflect
the significant decline in loss expectations due to better than
expected recoveries on the REO Eastdale Mall asset (56% of pool at
Fitch's last rating action), which was disposed on Nov. 18, 2019,
and six loans (20.6%) paying in full since Fitch's last rating
action in January 2019. The downgrades to classes L through O
reflect realized losses incurred as a result of the Eastdale Mall
liquidation.

Fitch Loan of Concern: Fitch designated the The Crossroads Shopping
Center loan (13% of pool) as a Fitch Loan of Concern (FLOC). The
loan, which is secured by an unanchored retail center located in
Charlotte, NC, has continued to underperform with NOI debt service
coverage ratio (DSCR) falling to 0.39x as of YE 2018, from 1.82x at
YE 2017 and 1.98x at YE 2016. Occupancy remains low at 39% as of
March 2019, compared with 49% at YE 2018, 88% at YE 2017, 90% at YE
2016 and 100% at YE 2015. Bi-Lo (previously 35.6% of NRA) closed in
April 2018 prior to their December 2028 lease expiration.
Additionally, The Savannah Children's Theater (21.6% NRA) is
currently on month-to-month lease terms.

Increased Credit Enhancement: Following the disposition of the REO
Eastdale Mall asset in November 2019, class J is currently the
first-pay class, with credit enhancement increasing to 83.7% as of
December 2019 from 45.7% at Fitch's last rating action. The
remaining balance of class J is fully-reliant on fully amortizing,
low-leveraged loans that mature in 2024 and are located in
secondary markets, none of which are considered Fitch Loans of
Concern. As of the December 2019 remittance, the pool has been
reduced by 99.2% to $8.4 million from $1.06 billion at issuance.
Realized losses total $26.2 million (2.5% of original pool) and
cumulative interest shortfalls currently affect the non-rated class
P.

Highly Concentrated Pool: Only five loans remain of the 97 at
issuance. Due to the concentrated nature of the pool, Fitch
performed a sensitivity analysis that grouped the remaining loans
based on the likelihood/timing of repayment. The ratings reflect
this analysis.

RATING SENSITIVITIES

The Stable Rating Outlooks on classes J and K are due to high
credit enhancement and the expectation that the class will pay down
in the near to longer term (2024), respectively, from amortization
and loan repayments. Further upgrades are unlikely given the
concentrated nature of the pool and the adverse selection of the
remaining collateral.

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.


[*] Fitch Takes Actions on 12 SLM & 2 Navient Private Trusts
------------------------------------------------------------
Fitch Ratings affirmed 35 tranches and upgraded 4 tranches from 11
SLM Private Credit Student Loan Trust transactions (SLM), and
affirmed one tranche from SLM Private Education Loan Trust
transactions and seven tranches from two Navient Private Education
Loan Trust. The affirmations include SLM 2006-B's class A-5W notes,
which are a portion of the A-5 notes receiving interest and
principal payments pro rata with the A-5 notes.


RATING ACTIONS

SLM Private Credit Student Loan Trust 2004-A

  Class A-3 78443CBH6; LT AAsf Affirmed; previously at AAsf

  Class B 78443CBJ2;   LT A+sf Upgrade;  previously at Asf

SLM Private Credit Student Loan Trust 2003-B

  Class A-3 78443CAN4; LT A-sf Affirmed; previously at A-sf

  Class A-4 78443CAP9; LT A-sf Affirmed; previously at A-sf

  Class B 78443CAQ7;   LT BBBsf Upgrade; previously at BBsf

  Class C 78443CAR5;   LT CCsf Affirmed; previously at CCsf

SLM Private Credit Student Loan Trust 2003-A

  Class A-3 78443CAJ3; LT A-sf Affirmed;  previously at A-sf

  Class A-4 78443CAK0; LT A-sf Affirmed;  previously at A-sf

  Class B 78443CAG9;   LT BBB+sf Upgrade; previously at BB+sf

  Class C 78443CAH7;   LT CCsf Affirmed;  previously at CCsf

SLM Private Credit Student Loan Trust 2003-C

  Class A-3 78443CBA1; LT A-sf Affirmed; previously at A-sf

  Class A-4 78443CBB9; LT A-sf Affirmed; previously at A-sf

  Class A-5 78443CBC7; LT A-sf Affirmed; previously at A-sf

  Class B 78443CBD5;   LT BBBsf Upgrade; previously at BBsf

  Class C 78443CBE3;   LT CCsf Affirmed; previously at CCsf

SLM Private Credit Student Loan Trust 2006-B

  Class A-5 78443CCU6;  LT Asf Affirmed;    previously at Asf

  Class A-5W 78443CCY8; LT Asf Affirmed;    previously at Asf

  Class B 78443CCV4;    LT BBB+sf Affirmed; previously at BBB+sf

  Class C 78443CCW2;    LT BBB-sf Affirmed; previously at BBB-sf

Navient Private Education Loan Trust 2015-A

  Class A-2A 63939EAB9; LTAAAsf Affirmed; previously at AAAsf

  Class A-2B 63939EAC7; LTAAAsf Affirmed; previously at AAAsf

  Class A3 63939EAD5;   LTAAAsf Affirmed; previously at AAAsf

  Class B 63939EAE3;    LTAAsf Affirmed;  previously at AAsf

Navient Private Education Loan Trust 2016-A

  Class A-2A 63939NAB9; LT AAAsf Affirmed; previously at AAAsf

  Class A-2B 63939NAC7; LT AAAsf Affirmed; previously at AAAsf

  Class B 63939NAD5;    LT AAsf Affirmed;  previously at AAsf

SLM Private Credit Student Loan Trust 2004-B

  Class A-3 78443CBN3; LT AAAsf Affirmed; previously at AAAsf

  Class A-4 78443CBP8; LT AAsf Affirmed;  previously at AAsf

  Class B 78443CBQ6;   LT Asf Affirmed;   previously at Asf

SLM Private Credit Student Loan Trust 2007-A

  Class A-4 78443DAD4; LT A-sf Affirmed;  previously at A-sf

  Class B 78443DAF9;   LT BBBsf Affirmed; previously at BBBsf

  Class C-1 78443DAH5; LT BB+sf Affirmed; previously at BB+sf

  Class C-2 78443DAJ1; LT BB+sf Affirmed; previously at BB+sf

SLM Private Education Loan Trust 2013-B

  Class B 78447VAD0; LT AAAsf Affirmed; previously at AAAsf

SLM Private Credit Student Loan Trust 2006-C

  Class A-5 78443JAE9; LT AA-sf Affirmed;  previously at AA-sf

  Class B 78443JAF6;   LT Asf Affirmed;    previously at Asf

  Class C 78443JAG4;   LT BBB-sf Affirmed; previously at BBB-sf

SLM Private Credit Student Loan Trust 2005-A

  Class A-3 78443CBU7; LT AAAsf Affirmed; previously at AAAsf

  Class A-4 78443CBV5; LT A+sf Affirmed;  previously at A+sf

  Class B 78443CBW3;   LT A-sf Affirmed;  previously at A-sf

  Class C 78443CBX1;   LT BBBsf Affirmed; previously at BBBsf

SLM Private Credit Student Loan Trust 2006-A

  Class A-5 78443CCL6; LT A+sf Affirmed;  previously at A+sf

  Class B 78443CCM4;   LT Asf Affirmed;   previously at Asf

  Class C 78443CCN2;   LT BBBsf Affirmed; previously at BBBsf

SLM Private Credit Student Loan Trust 2005-B

  Class A-4 78443CCB8; LT A+sf Affirmed;  previously at A+sf

  Class B 78443CCC6;   LT A-sf Affirmed;  previously at A-sf

  Class C 78443CCD4;   LT BBBsf Affirmed; previously at BBBsf

TRANSACTION SUMMARY

The rating actions reflect the current transactions' portfolio
performance that remains within Fitch's expectations, and
sufficient credit enhancement (CE) at each bond's corresponding
rating level.

In line with Fitch's "U.S. Private Student Loan ABS Rating
Criteria," PE 2013-B was not modeled for this review, as all bonds
are at the highest level of 'AAAsf'. None of the variables
affecting the transaction performance has changed beyond what was
expected as of last review. In addition, CE levels have increased
since the last review.

KEY RATING DRIVERS

Collateral Performance: All trusts are collateralized by private
student loans, originated by SLM Corp. (BB+/B/Stable) and Navient
Corp. (BB/B/Stable). Loans in the SLM trusts were originated under
the Signature Education Loan Program, LAWLOANS program, MBA Loans
program and MEDLOANS program. SLM 2007-A, SLM PE trusts and Navient
PE trusts also included loans originated under the Direct to
Consumer and Private Credit Consolidation programs. SLM PE and
Navient PE also comprise Navient's Smart Option program, launched
in 2009.

For transactions modelled for this surveillance review, Fitch's
remaining default projections are as follows:

SLM 2003-A: 7.3%

SLM 2003-B: 7.4%

SLM 2003-C: 7.4%

SLM 2004-A: 7.3%

SLM 2004-B: 7.5%

SLM 2005-A: 9.4%

SLM 2005-B: 9.4%

SLM 2006-A: 9.9%

SLM 2006-B: 11.2%

SLM 2006-C: 11.1%

SLM 2007-A: 12.3%

Navient 2015-A: 13.7%

Navient 2016-A: 13.4%

The recovery assumption is 18.0% for all transactions, unchanged
from previous surveillance reviews.

For SLM 2003-A, SLM 2003-B, SLM 2003-C, SLM 2004-A, SLM 2004-B, SLM
2005-A and SLM 2005-B, Fitch applied a low default stress multiple
in the multiple range envisaged by Fitch's PSL Criteria, resulting
in a 3.5x multiple at 'AAAsf'. For SLM 2006-A, SLM 2006-B, SLM
2006-C, 2007-A, Navient 2015-A and Navient 2016-A, Fitch applied a
medium/low default stress multiple of 3.75x multiple at 'AAAsf'.
The assumed multiples are unchanged from previous surveillance
review.

Payment Structure: For all transactions, available CE is sufficient
to provide loss coverage in line with the assigned rating category.
CE is provided by a combination of overcollateralization (OC; the
excess of the trust's asset balance over the bond balance), excess
spread and subordination of more junior notes. As reflected in the
assigned ratings, the class C notes for SLM 2003-A, 2003-B and
2003-C are currently under collateralized. All other deals are at
or above their OC floor level.

Operational Capabilities: Navient Solutions LLC is the servicer for
all the loans in the trusts. Fitch has reviewed the servicing
operations of Navient and considers it to be an effective private
student loan servicer.

RATING SENSITIVITIES

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 base-case default and recovery
assumptions to reflect asset performance in a stressed environment.
Second, structural protection was analyzed with Fitch's GALA 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.


                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
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public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
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Don't be fooled.  Assets, for example, reported at historical cost
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than a balance sheet solvency test.

On Thursdays, the TCR delivers a list of recently filed
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liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
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Each Friday's edition of the TCR includes a review about a book of
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available at your local bookstore or through Amazon.com.  Go to
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Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

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

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

                            *********

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

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.
Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
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Sheryl Joy P. Olano, Psyche A. Castillon, Ivy B. Magdadaro, Carlo
Fernandez, Christopher G. Patalinghug, and Peter A. Chapman,
Editors.

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

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