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

              Sunday, January 5, 2020, Vol. 24, No. 4

                            Headlines

A10 TERM 2017-1: DBRS Confirms BB(low) Rating on Class F Notes
ACAM LTD 2019-FL1: DBRS Finalizes B(low) Rating on Class G Notes
ANGEL OAK 2019-4: DBRS Assigns B Rating on Class B-2 Certs
BANK 2019-BNK24: DBRS Finalizes BB Rating on Class X-G Certs
BENCHMARK 2019-B15: DBRS Finalizes BB(low) Rating on Class F Certs

BRAVO RESIDENTIAL 2019-1: DBRS Assigns B Rating on Class B-2 Notes
BRAVO RESIDENTIAL 2019-NQM1: DBRS Assigns BB Rating on B-2 Notes
BUNKER HILL 2019-1: DBRS Assigns B Rating on Class B-2 Notes
CARVANA AUTO 2019-4: Moody's Rates $44.2MM Class E Notes B2(sf)
CITIGROUP COMM'L 2019-C7: DBRS Finalizes B Rating on J-RR Certs

COLT 2018-2: DBRS Assigns BB(high) Rating on Class B-2 Certs
COMM 2015-CCRE22: Fitch Affirms BB-sf Rating on Class E Certs
DEEPHAVEN RESIDENTIAL 2018-3: DBRS Assigns B Rating on B-2 Notes
EAST WEST 2019-1: S&P Assigns BB- (sf) Rating to Class E Notes
ELLINGTON FINANCIAL 2018-1: DBRS Assigns B Rating on B-2 Certs

GCAT 2019-NQM1: DBRS Assigns B(high) Rating on Class B-2 Certs
GE COMMERCIAL 2007-C1: Moody's Cuts Rating on 3 Tranches to Caa1
GERMAN AMERICAN 2012-LC4: Fitch Lowers Class E Certs to Bsf
GREAT WOLF 2019-WOLF: Moody's Assigns B3 Rating on Class F Certs
IMSCI 2012-2: DBRS Puts B(low) on Class G Certs Under Review

IMSCI 2013-3: DBRS Puts B(low) on Class G Certs Under Review
JP MORGAN 2005-LDP2: Moody's Hikes Class G Debt Rating to B1
JP MORGAN 2019-INV3: Moody's Assigns B3 Rating on 2 Tranches
JPMBB COMMERCIAL 2014-C23: Moody's Affirms Class UH5 Debt at Ba1
MADISON PARK XXXVI: S&P Assigns BB- (sf) Rating to Class E Notes

MCAP CMBS 2014-1: DBRS Places B Rating on Class G Certs
METROPOLITAN ASSET 2000-A: Moody's Cuts Cl. A-IO Debt Rating to Ca
MIDWEST FAMILY 2006A: S&P Affirms 'BB+' Rating on Class IV Bonds
NOMURA HOME 2006-WF1: Moody's Raises Class M-3 Debt Rating to Ba3
NRMLT 2019-NQM2: DBRS Assigns B Rating on Class B-2 Notes

RCO 2017-INV1: DBRS Assigns B Rating on Class B-2 Notes
RESIDENTIAL MORTGAGE 2019-1: DBRS Assigns B Rating on B-2 Notes
SEQUOIA MORTGAGE 2020-1: Fitch to Rate Cl. B-4 Debt BB-(EXP)sf
SPRUCE HILL 2019-SH1: DBRS Assigns B Rating on Class B-2 Notes
STAR 2019-1: DBRS Assigns B Rating on Class B-2 Certs

VERUS TRANSACTIONS 2017-2: DBRS Assigns BB(low) Rating on B3 Certs
WFRBS COMMERCIAL 2014-LC14: Fitch Affirms Class E Certs at BBsf

                            *********

A10 TERM 2017-1: DBRS Confirms BB(low) Rating on Class F Notes
--------------------------------------------------------------
DBRS Limited confirmed the ratings on the following fixed-rate
notes issued by A10 Term Asset Financing 2017-1, LLC:

-- Class A-2 at AAA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (sf)
-- Class D at BBB (high) (sf)
-- Class E at BB (high) (sf)
-- Class F at BB (low) (sf)

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the underlying loans within the pool. Based on the reported Q2 2019
figures and the current loan balances, the remaining loans reported
a weighted-average debt yield of 9.4%, which is considered healthy
for a pool or stabilizing assets. Some of the remaining assets have
taken longer than initially anticipated to stabilize, but the
respective sponsors remain committed to the loans and properties
and, in general, DBRS Morningstar believes the overall risk for the
remaining loans in the pool remains relatively stable from
issuance.

The transaction originally consisted of 30 loans secured by 52
transitional commercial real estate assets, including office,
retail, industrial, and mixed-use properties. According to the
November 2019 remittance, there has been a collateral reduction of
74.2% since issuance, as 19 loans have been repaid in full,
contributing to a principal paydown of $204.8 million. There are
three portfolio loans in the pool, representing 41.1% of the
transaction balance. Across the three portfolio loans, there are a
total of 20 properties, and each individual loan's collateral set
is cross-collateralized and cross-defaulted.

Most of the remaining loans are structured with two- to four-year
terms and include built-in extensions and available future funding
facilities as the properties work toward stabilization. Both the
extensions and future funding amounts are at the lender's sole
discretion. Of the remaining loans in the pool, 89.9% of the pool
has loan terms that extend past 2020. Two loans, 75th Street Center
and 535 Broadway, were granted extensions past the respective
initial loan maturity dates.

The reserve account established for future funding obligations has
a current balance of $4.2 million, with remaining future funding
obligations totaling $6.6 million. According to the most recent
reporting, the collateral assets generally have stable debt yields;
however, the majority of the properties continue to be in the
process of stabilization and have generally missed initial target
dates set forth in the respective business plans. Details on the
stabilization status for pivotal loans within the pool are provided
in the Loan Commentary on the DBRS Viewpoint platform, as discussed
below.

The ratings assigned by DBRS Morningstar contemplate timely
payments of distributable interest and, in the case of the offered
notes other than Class A, ultimate recovery of deferred
collateralized note interest amounts (inclusive of interest payable
thereon at the applicable rate, to the extent permitted by law).
The transaction has a standard sequential-pay waterfall.

DBRS Morningstar materially deviated from its principal methodology
when determining the ratings assigned to Classes B, C, D, E, and F.
DBRS Morningstar considers a material deviation from a methodology
to exist when there may be a substantial likelihood that a
reasonable investor or other users of the credit rating(s) would
consider the material deviation to be a significant factor in
evaluating the rating(s). The material deviation(s) is warranted
given the structure features (loan or transaction) and/or
provisions in other relevant methodologies outweigh the
quantitative model output.

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


ACAM LTD 2019-FL1: DBRS Finalizes B(low) Rating on Class G Notes
----------------------------------------------------------------
DBRS, Inc. finalized provisional ratings on the following classes
of Commercial Mortgage-Backed Notes issued by ACAM 2019-FL1, Ltd.
(the Issuer):

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

All trends are Stable. Classes F and G have been privately placed.

The initial collateral consists of 21 floating-rate mortgages
secured by 35 mostly transitional properties with a cut-off balance
totaling $400.3 million, excluding approximately $87.4 million of
future funding commitments. Most loans are in a period of
transition with plans to stabilize and improve asset value. During
the Reinvestment Period, the Issuer may acquire future funding
commitments and additional eligible loans subject to the
Eligibility Criteria. The transaction stipulates a $1.0 million
threshold on pari passu participation acquisitions before a rating
agency condition is required if a portion of the underlying loan is
already included in the pool.

For the floating-rate loans, the index DBRS Morningstar used
(one-month LIBOR) was the lower of a DBRS Morningstar stressed rate
that corresponded with the remaining fully extended term of the
loans or the strike price of the interest-rate cap, with the
respective contractual loan spread added to determine a stressed
interest rate over the loan term. When the cut-off balances were
measured against the DBRS Morningstar As-Is Net Cash Flow, 18
loans, comprising 86.9% of the initial pool, had a DBRS Morningstar
As-Is Debt Service Coverage Ratio (DSCR) below 1.00 times (x), a
threshold indicative of elevated term default risk. Additionally,
the DBRS Morningstar Stabilized DSCR for six loans, comprising
29.8% of the initial pool balance, is below 1.00x, which is
indicative of elevated refinance risk. The majority of the
properties are transitioning with potential upside in cash flow;
however, DBRS Morningstar does not give full credit to the
stabilization if there are no holdbacks or if other loan structural
features in place are insufficient to support such treatment.
Furthermore, even with the structure provided, DBRS Morningstar
generally does not assume the assets to stabilize the above market
levels.

The transaction has a sequential-pay structure.

The properties are primarily located in core markets with the
overall pool's weighted-average (WA) DBRS Morningstar Market Rank
at a very high 5.1. Eight loans, totaling 41.0% of the pool, are in
markets with a DBRS Morningstar Market Rank of 8, 7 and 6. These
higher DBRS Morningstar Market Ranks correspond with zip codes that
are more urbanized in nature.

Three loans in the pool, totaling 33.8% of the DBRS Morningstar
sample by cut-off date pool balance, are backed by a property whose
quality DBRS Morningstar deemed to be Average (+) or Above
Average.

The borrowers of all 21 floating-rate loans have purchased LIBOR
rate caps that range between 2.5% and 3.75% to protect against
rising interest rates over the term of the loan.

Thirteen loans, representing 51.8% of the initial pool balance,
represent acquisition financing. Acquisition financing generally
requires the respective sponsor(s) to contribute material cash
equity as a source of funding in conjunction with the mortgage
loan, resulting in a higher sponsor cost basis in the underlying
collateral.

The Class F Notes, Class G Notes and Preferred Shares, which
represent 15.6% of the transaction balance, have been retained by
ACAM 2019-FL1 Retention Holder, LLC, an affiliate of the trust
asset seller.

The pool consists of mostly transitional assets. Given the nature
of the assets, DBRS Morningstar determined a sample size,
representing 77.7% of the pool cut-off date balance. This is higher
than the typical sample size for traditional conduit commercial
mortgage-backed security (CMBS) transactions. DBRS Morningstar also
performed physical site inspections, including management meetings.
When DBRS Morningstar visits these markets, it may actually visit
properties more than once to follow the progress (or lack thereof)
toward stabilization. The service is also in constant contact with
the borrowers to track progress.

Five loans, representing 27.7% of the pool, are secured by hotels,
including three of the largest ten loans. Hotels have the highest
cash flow volatility of all major property types as their income,
which is derived from daily contracts rather than multi-year
leases, and expenses, which are often mostly fixed, are quite high
as a percentage of revenue. These two factors cause revenue to fall
swiftly during a downturn and cash flow to fall even faster as a
result of high operating leverage. The loans in the pool secured by
hotel properties have a WA As-Is Loan-to-Value (LTV) ratio of 57.4%
based on their fully funded loan amount and as-is appraised value,
which compares favorably with the WA LTV of 89.7% for non-hotel
properties in the pool. Additionally, the WA market index for the
hotel properties in the pool is 6.3, with 61.5% of the hotel
properties located in markets ranked 7 and 8, indicating
concentration in urban locations.

Based on the weighted initial pool balances, the overall WA DBRS
Morningstar As-Is DSCR of 0.77x reflects high-leverage financing.
The assets are generally well-positioned to stabilize, and any
realized cash flow growth would help to offset rising interest
rates and also improve the overall debt yield of the loans. DBRS
Morningstar associates its loss given default (LGD) with the
assets' As-Is LTV and does not assume that the stabilization plan
and cash flow growth will ever materialize. Additionally, including
all future funding in the calculation, the WA DBRS Morningstar
As-Stabilized LTV is low at 53.8%. The WA DBRS Morningstar
As-Stabilized LTV reflects downward stabilized value adjustments
that DBRS Morningstar made to two loans.

All loans in the pool have floating interest rates. Eighteen loans,
comprising 78.0% of the pool balance, are interest-only during the
original term and have original terms ranging from 24 months to 60
months, creating interest-rate risk. All loans are short-term loans
and, even with extension options, they have a fully extended
maximum loan term of five years. Additionally, for the
floating-rate loans, DBRS Morningstar used the one-month LIBOR
index, which is based on the lower of a DBRS Morningstar stressed
rate that corresponded with the remaining fully extended term of
the loans or the strike price of the interest-rate cap with the
respective contractual loan spread added to determine a stressed
interest rate over the loan term. Additionally, all loans have
extension options and, to qualify for these options, the loans must
meet minimum DSCR and LTV requirements.

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

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


ANGEL OAK 2019-4: DBRS Assigns B Rating on Class B-2 Certs
----------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage Pass-Through
Certificates from Angel Oak Mortgage Trust (AOMT) 2019-4:

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

The AOMT transaction is generally classified as a non-qualified
mortgage (non-QM) transaction.

DBRS Morningstar performed the following rating analysis on the
transaction:

-- Loan-level default probability, loss severity, and expected
     loss review;

-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;

-- Third-party due diligence sample size review;

-- Representations and warranties framework review; and

-- Historical performance analysis as reflected in delinquencies,
    cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for the transaction. DBRS Morningstar recalculated or
remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transaction were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for the transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


BANK 2019-BNK24: DBRS Finalizes BB Rating on Class X-G Certs
------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2019-BNK24 issued by BANK 2019-BNK24 as follows:

-- Class A-1 at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class X-A at AAA (sf)
-- Class A-S at AAA (sf)
-- Class B at AAA (sf)
-- Class X-B at AA (sf)
-- Class C at AA (low) (sf)
-- Class D at A (low) (sf)
-- Class X-D at A (low) (sf)
-- Class E at BBB (high) (sf)
-- Class X-F at BBB (low) (sf)
-- Class F at BB (high) (sf)
-- Class X-G at BB (sf)
-- Class G at BB (low) (sf)

All trends are Stable. Classes X-D, X-F, X-G, X-H, D, E, F, G, H,
and RR have been privately placed.

The collateral consists of 71 fixed-rate loans secured by 104
commercial and multifamily properties. The transaction is a
sequential-pay pass-through structure. DBRS Morningstar analyzed
the conduit pool to determine the provisional ratings, reflecting
the long-term probability of loan default within the term and its
liquidity at maturity. Four loans, representing 22.4% of the pool,
are shadow-rated investment grade by DBRS Morningstar. When DBRS
Morningstar measured the cut-off loan balances against the DBRS
Morningstar Stabilized Net Cash Flow (NCF) and their respective
actual constants, the initial DBRS Morningstar weighted-average
(WA) debt service coverage ratio (DSCR) for the pool was 2.94 times
(x). The WA DSCR is elevated because 22.4% of the pool is
shadow-rated investment grade and low-leverage residential
co-operative loans represent 8.9% of the pool. Residential
co-operative loans have very low loan-level credit enhancement at
the AAA level and near-zero loan-level credit enhancement at the
BBB (low) level. Only one loan, Totowa Shoppes, had a DBRS
Morningstar Term DSCR below 1.30x, a threshold indicative of a
higher likelihood of mid-term default. The WA loan-to-value (LTV)
ratio of the pool at issuance was 53.1%, and the pool is scheduled
to amortize down to a WA LTV of 51.2% at maturity. The pool
includes 17 loans, representing 24.6% of the pool by allocated loan
balance, with issuance LTVs equal to or higher than 65.0%, a
threshold historically indicative of above-average default
frequency.

The transaction includes four loans, representing 22.4% of the
total pool balance, that are shadow-rated investment grade by DBRS
Morningstar, including 55 Hudson Yards, Jackson Park, Park Tower at
Transbay, and ILPT Industrial Portfolio. Park Tower at Transbay
exhibits credit characteristics consistent with a AAA shadow
rating, Jackson Park exhibits credit characteristics consistent
with a AA (high) shadow rating, ILPT Industrial Portfolio exhibits
credit characteristics consistent with a AA (low) shadow rating,
and 55 Hudson Yards exhibits credit characteristics consistent with
a BBB shadow rating.

Thirty-two loans in the pool, representing 8.9% of the transaction,
are backed by residential co-operative loans. Residential
co-operatives tend to have minimal risk, given their low leverage
and low risk to residents if the co-operative associations default
on their mortgages. The WA LTV for these loans is 12.5%.

Fifty loans, representing 69.7% of the pool, have collateral
located in Metropolitan Statistical Area (MSA) Group 3, which
represents the best-performing group in terms of historical
commercial mortgage-backed security (CMBS) default rates among the
top 25 MSAs. The MSA Group 3 has a historical default rate of
17.25%, which is 50.00% lower than the overall CMBS historical
default rate of approximately 28.00%.

Forty-seven loans, representing 67.8% of the pool by allocated loan
balance, exhibit issuance LTVs of equal to or less than 60.0%, a
threshold historically indicative of relatively low-leverage
financing and generally associated with below-average default
frequency.

Only one loan had property quality deemed to be Average (-) while
none had property quality deemed Below Average or Poor.
Additionally, nine loans, representing 46.6% of the pool balance,
exhibited Average (+), Above Average or Excellent property quality.
One of the top ten loans, Park Tower at Transbay, is secured by
collateral with Excellent property quality.

The pool has a relatively high concentration of loans secured by
office properties as ten loans, representing 33.7% of the pool by
allocated loan balance, are secured by this property type. DBRS
Morningstar considers office properties to be a riskier property
type with a generally above-average historical default frequency.
Two of the ten office loans (55 Hudson Yards and Park Tower at
Transbay), comprising 12.2% of the pool balance, are shadow-rated
investment grade by DBRS Morningstar. Five office properties,
totaling 18.9% of the pool balance, have DBRS Morningstar DSCRs
higher than 2.00x while the remaining five office loans, totaling
14.8% of the pool balance, have DBRS Morningstar DSCRs higher than
1.45x. Four office loans, representing 73.1% of the office
concentration, are secured by office properties in areas
characterized as extremely dense and desirable urban markets, which
have a DBRS Morningstar Market Rank of 8.

Thirty loans, representing 75.2% of the pool by allocated loan
balance, are structured with full-term interest-only (IO) periods.
Of these 30 loans, 12 loans, representing 42.5% of the pool by
allocated loan balance, are in areas with a DBRS Morningstar Market
Rank of 6, 7, or 8. These markets benefit from increased liquidity
even during times of economic stress. Four of the 30 identified
loans, representing 22.4% of the total pool balance, are
shadow-rated investment grade by DBRS Morningstar: Park Tower at
Transbay, Jackson Park, ILPT Industrial Portfolio, and 55 Hudson
Yards.

DBRS Morningstar completed a cash flow review and a cash flow
stability and structural review on 26 of the 71 loans, representing
83.5% of the pool by loan balance. For loans not subject to an NCF
review, DBRS Morningstar applied the average NCF variance of its
respective loan seller. DBRS Morningstar uses recent leasing to
determine leasing cost assumptions in loan-level NCF analysis,
which was the main driver for the sampled commercial properties in
the transaction. The sampled variance in the transaction reflects
an increasing leasing cost environment, particularly for suburban
office properties. The DBRS Morningstar sample had an average NCF
variance of -10.2% and ranged from -21.5% (Galleria 57) to +0.2%
(Park Tower at Transbay).

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

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


BENCHMARK 2019-B15: DBRS Finalizes BB(low) Rating on Class F Certs
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2019-B15 issued by Benchmark 2019-B15 Mortgage Trust:

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

All trends are Stable. Classes X-B, X-D, X-F, F, E, F, and G-RR
have been privately placed. The Class X-B notes previously
referenced the Class B and Class C notes as of the transaction
announcement date. The DBRS Morningstar rating of AA (sf) for the
Class X-B certificates is reflective of Class B notes referencing
the Class B notes as of the closing date.

The collateral consists of 32 fixed-rate loans secured by 87
commercial and multifamily properties. The transaction is a
sequential-pay pass-through structure. The conduit pool was
analyzed to determine the provisional ratings, reflecting the
long-term probability of loan default within the term and its
liquidity at maturity. When the cut-off loan balances were measured
against the DBRS Morningstar Stabilized Net Cash Flow (NCF) and
their respective actual constants, the initial DBRS Morningstar
weighted-average (WA) DSCR of the pool was 2.05 times (x). None of
the loans had a DBRS Morningstar Term Debt Service Coverage Ratio
(DSCR) below 1.32x, a threshold indicative of a higher likelihood
of mid-term default. Additionally, excluding hospitality
properties, 17 loans, comprising 66.8% of the pool by allocated
loan balance, exhibited a favorable DSCR in excess of 1.69x, a
threshold generally associated with below-average default
frequency. The pool additionally includes five loans comprising a
combined 37.5% of the pool balance with an DBRS Morningstar
loan-to-value (LTV) ratio in excess of 67.1%, a threshold generally
indicative of above-average default frequency. The WA DBRS
Morningstar LTV of the pool at issuance was 61.6%, and the pool is
scheduled to amortize down to a DBRS Morningstar WA LTV of 58.0% at
maturity.

The transaction includes three loans, representing a combined 12.7%
of the total pool balance, that are shadow-rated investment grade
by DBRS Morningstar, including Century Plaza Towers, The Essex and
Osborn Triangle. Century Plaza Towers exhibits credit
characteristics consistent with an "A" shadow rating; The Essex
exhibits credit characteristics consistent with a BBB (high) shadow
rating; and Osborn Triangle exhibits credit characteristics
consistent with a BBB (low) shadow rating.

There were 13 loans, representing 62.8% of the pool by allocated
loan amount, assigned with either Average (+), Above Average or
Excellent quality. Only two loans, representing a combined 5.3% of
the pool by allocated loan balance, were assigned Average (-)
property quality scores and there were no loans assigned Below
Average or Poor property scores. Properties with favorable property
quality tend to attract and retain tenancy and are more liquid in
the capital markets.

The pool has a high concentration of loans secured by office
properties, as evidenced by ten loans loans, representing a
combined 44.0% of the pool by allocated loan balance, being secured
by such properties. DBRS Morningstar considers office properties to
be a riskier property type with above-average default frequency.
Two of the identified loans (comprising 22.1% of the pool's total
office composition), Century Plaza Towers and Osborn Triangle, are
secured by office properties that are shadow-rated investment grade
by DBRS Morningstar. Eight of the identified office loans
(comprising 88.7% of the pool's total office composition) are
secured by properties with either Average (+), Above Average or
Excellent quality.

The pool features a relatively high concentration of loans secured
by properties located in less favorable suburban market areas, as
evidenced by 15 loans, representing 43.7% of the pool by allocated
loan balance, being secured by properties located in areas with a
DBRS Morningstar Market Rank of either 3 or 4. Twenty-two of the
identified loans, representing 56% of the pool balance that is
secured by properties located in areas with a DBRS Morningstar
Market Rank of either 3 or 4, will amortize over the loan term,
which can reduce risk over time. The WA expected amortization of
these loans is 7.3%, which is higher than the pool's total WA
expected amortization of 5.3%.

Thirteen loans, representing a combined 58.6% of the pool by
allocated loan balance, are structured with full-term interest-only
(IO) periods and an additional seven loans, accounting for 19.6% of
the pool by allocated loan balance, are structured with partial IO
terms ranging from 24 to 60 months. Expected amortization across
the pool is 5.3%. The loans structured with full-term IO periods
are, for the most part, pre-amortized, as is evidenced by a DBRS
Morningstar WA Issuance LTV of 56.3% for these loans.

The average DBRS Morningstar sampled NCF variance of -15.6% for
this transaction is higher than the straight-line average sampled
NCF variance of -11.1% for the last six conduits DBRS
Morningstar-rated transactions, ranging from -14.2% for GSMS
2019-GC42 to -8.0% for WFCM 2019-C53. If DBRS Morningstar were to
exclude the -30.6% variance for 8 West Centre, the average sampled
NCF variance for the transaction would fall to -14.1%, which is
within the range of the past six DBRS Morningstar-rated conduit
transactions. DBRS Morningstar uses recent leasing to determine
leasing cost assumptions in loan-level NCF analysis, which was the
predominant driver for the sampled commercial properties in the
transaction. The increasing leasing cost environment, particularly
for suburban office properties, is a macro-economic trend reflected
in the sampled variance for this transaction.

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

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


BRAVO RESIDENTIAL 2019-1: DBRS Assigns B Rating on Class B-2 Notes
------------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage-Backed Notes
from BRAVO Residential Funding Trust 2019-1:

-- Class A-1 at AAA (sf)
-- Class A-1-A at AAA (sf)
-- Class A-1-B at AAA (sf)
-- Class A-1-C at AAA (sf)
-- Class A-1-D at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (sf)
-- Class M-1 at BBB (sf)
-- Class B-1 at BB (sf)
-- Class B-2 at B (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

This transaction is generally classified as a seasoned RMBS
transaction.

DBRS Morningstar performed the following rating analysis on the
transaction:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for the transaction. DBRS Morningstar recalculated or
remapped certain collateral attributes in its analysis. Such
recalculations and remapping for the transaction were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for the transaction is stepped up from the raw
model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For the transaction, the
servicer will not advance any principal and interest payments on
delinquent mortgages to the securitization trust. When performing
cash flow analysis, DBRS approximated delinquency curves by
front-loading its standard seasoned loss timing vectors by 24
months and assumed that the servicer will not advance for
delinquent mortgages. This would result in P&I collections being
shut off as soon as loans become delinquent until they are
liquidated. Additionally, WAC deterioration stresses were
incorporated in the runs.


BRAVO RESIDENTIAL 2019-NQM1: DBRS Assigns BB Rating on B-2 Notes
----------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage-Backed Notes
from BRAVO Residential Funding Trust 2019-NQM1:

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class M-1 at A (sf)
-- Class B-1 at BBB (sf)
-- Class B-2 at BB (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

The BRAVO transaction is generally classified as a non-qualified
mortgage (non-QM) transaction.

DBRS Morningstar performed the following rating analysis on the
transaction:

-- Loan-level default probability, loss severity, and expected
     loss review;

-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;

-- Third-party due diligence sample size review;

-- Representations and warranties framework review; and

-- Historical performance analysis as reflected in delinquencies,

    cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for the transaction. DBRS Morningstar recalculated or
remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transaction were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for the transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.

OPERATIONAL RISK REVIEW

DBRS Morningstar performed operational risk reviews on many non-QM
originators and the servicers. For the purpose of assigning ratings
to the transaction, DBRS Morningstar did not perform additional
operational risk reviews. DBRS Morningstar notes the following
reasons and mitigating factors:

-- If an originator consisted of less than 15% of a securitized
pool, an operational risk review is generally not warranted in
accordance with DBRS Morningstar's RMBS rating methodology.

-- MCR, when assigning ratings to a non-QM transaction on or prior
to the closing date, generally conducted operational risk reviews,
at the aggregator or originator level, for such securitization.

-- If a DBRS Morningstar originator review was not performed for a
transaction, DBRS Morningstar evaluated the actual historical
performance of the securitization and deemed the performance
satisfactory.

-- Notwithstanding the above, DBRS Morningstar adjusted the
originator scores to zero. Lower originator scores resulted in
increased loss assumptions.

THIRD-PARTY DUE DILIGENCE

DBRS Morningstar reviewed the sample size for each of the due
diligence review categories, including credit, regulatory
compliance, valuation, data integrity, pay histories, servicing
comments, and tax and title, when applicable. The sample sizes in
the transaction meet DBRS Morningstar's due diligence criteria.
DBRS Morningstar did not review the loan-level due diligence
findings for the transaction, rather it relied on the analysis done
by MCR at the time of assigning ratings to the transaction on or
prior to the closing dates, as well as the satisfactory performance
of the transaction to date.

REPRESENTATIONS AND WARRANTIES FRAMEWORK

DBRS Morningstar conducted a review of the representations and
warranties (R&W) framework for the transaction. The review covers
key considerations, such as R&W provider, controlling holder,
enforcement mechanism, breach reviewer, remedy, and dispute
resolution. For non-QM securitizations, DBRS Morningstar generally
adjusted the originator scores downward for the mortgage pools
because of certain perceived weaknesses in the R&W framework in
such transactions. Such adjustments resulted in increased default
and expected loss assumptions. DBRS Morningstar reviewed the
various aspects of the R&W framework in conjunction with a detailed
analysis of (1) the quality of the underlying mortgage loans and
(2) third-party due diligence sample size and deemed the R&W
standard for the transaction acceptable.


BUNKER HILL 2019-1: DBRS Assigns B Rating on Class B-2 Notes
------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage-Backed Notes
from two Bunker Hill Loan Depositary Trust (BHLD) transactions:

BHLD 2019-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (low) (sf)
-- Class A-3 at A (low) (sf)
-- Class M-1 at BBB (low) (sf)
-- Class B-1 at BB (sf)
-- Class B-2 at B (sf)

BHLD 2019-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (low) (sf)
-- Class A-3 at A (low) (sf)
-- Class M-1 at BBB (low) (sf)
-- Class B-1 at BB (low) (sf)
-- Class B-2 at B (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

These two BHLD transactions are generally classified as
non-qualified mortgage (non-QM) transactions.

DBRS Morningstar performed the following rating analysis on the
transactions:

-- Loan-level default probability, loss severity, and expected
     loss review;

-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;

-- Third-party due diligence sample size review;

-- Representations and warranties framework review; and

-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for each of the transactions. DBRS Morningstar recalculated
or remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transactions were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for each transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


CARVANA AUTO 2019-4: Moody's Rates $44.2MM Class E Notes B2(sf)
---------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to the notes
issued by Carvana Auto Receivables Trust 2019-4. This is the fourth
144A auto loan transaction for Carvana, LLC, an indirect wholly
owned subsidiary of Carvana Co. (B3 stable). The notes will be
backed by a pool of retail automobile loan contracts originated by
Carvana, who is also the administrator of the transaction.
Bridgecrest Credit Company, LLC, an indirect wholly owned
subsidiary of DriveTime Auto Group (B3 stable), will be the
servicer of the transaction.

Issuer: Carvana Auto Receivables Trust 2019-4

$105,000,000, 2.20%, Class A-2 Notes, Definitive Rating Assigned
Aaa (sf)

$100,480,000, 2.30%, Class A-3 Notes, Definitive Rating Assigned
Aaa (sf)

$85,020,000, 2.53%, Class B Notes, Definitive Rating Assigned Aa2
(sf)

$47,580,000, 2.72%, Class C Notes, Definitive Rating Assigned A2
(sf)

$57,980,000, 3.07%, Class D Notes, Definitive Rating Assigned Baa3
(sf)

$44,200,000, 4.70%, Class E Notes, Definitive Rating Assigned B2
(sf)

RATINGS RATIONALE

The ratings are based on the quality of the underlying collateral
originated by Carvana and its expected performance, the strength of
the capital structure, the experience and expertise of Bridgecrest
Credit as the servicer and the presence of Vervent Inc. (unrated)
as the backup servicer.

Moody's median cumulative net loss expectation for the 2019-4 pool
is 11% and the loss at a Aaa stress is 50%. The loss levels for
2019-4 are unchanged relative to 2019-3 and 2019-2, the last two
transactions Moody's rated. Moody's based its cumulative net loss
expectation on an analysis of the credit quality of the underlying
collateral; the historical performance of similar collateral
including Carvana's managed portfolio performance; the ability of
Bridgecrest Credit to perform the servicing functions; and current
expectations for the macroeconomic environment during the life of
the transaction.

At closing, the Class A notes, Class B notes, Class C notes, Class
D notes and Class E notes are expected to benefit from 48.85%,
32.50%, 23.35%, 12.20% and 3.70% of hard credit enhancement,
respectively. Hard credit enhancement for the notes consists of a
combination of overcollateralization, a non-declining reserve
account and subordination except for the Class E notes which do not
benefit from subordination. The notes may also benefit from excess
spread.

PRINCIPAL METHODOLOGY

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

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

Up

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

Down

Moody's could downgrade the notes if, given current expectations of
portfolio losses, levels of credit enhancement are consistent with
lower ratings. Credit enhancement could decline if excess spread is
not sufficient to cover losses in a given month. Moody's
expectation of pool losses could rise as a result of a higher
number of obligor defaults or deterioration in the value of the
vehicles securing an obligor's promise of payment. Portfolio losses
also depend greatly on the US job market, the market for used
vehicles, and poor servicing. Other reasons for worse-than-expected
performance include error on the part of transaction parties,
inadequate transaction governance, and fraud.


CITIGROUP COMM'L 2019-C7: DBRS Finalizes B Rating on J-RR Certs
---------------------------------------------------------------
DBRS, Inc. finalized provisional ratings on the following classes
of Commercial Mortgage Pass-Through Certificates, Series 2019-C7
issued by the Citigroup Commercial Mortgage Trust 2019-C7:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-AB at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X-A AAA (sf)
-- Class B at AAA (sf)
-- Class C at A (high) (sf)
-- Class X-B at AAA (sf)
-- Class D at BBB (high) (sf)
-- Class E at BBB (low) (sf)
-- Class X-D at BBB (sf)
-- Class F at BB (high) (sf)
-- Class X-F at BBB (low) (sf)
-- Class G at BB (high) (sf)
-- Class X-G at BBB (low) (sf)
-- Class H at B (high) (sf)
-- Class X-H at BB (low) (sf)
-- Class J-RR at B (low) (sf)

All trends are Stable. Classes X-B, X-D, D, E, F, G, H, and J-RR
have been privately placed.

The collateral consists of 55 fixed-rate loans secured by 113
commercial and multifamily properties. The transaction has a
sequential-pay pass-through structure. DBRS Morningstar analyzed
the conduit pool to determine the ratings, reflecting the long-term
probability of loan default within the term and its liquidity at
maturity. Two loans, representing approximately a combined 8.8% of
the pool, have investment-grade shadow ratings from DBRS
Morningstar. Based on the cutoff loan balances against the DBRS
Morningstar Stabilized Net Cash Flow and their respective actual
constants, five loans, representing a combined 5.1% of the pool,
had a DBRS Morningstar Term Debt Service Coverage Ratio (DSCR)
below 1.32 times (x), a threshold indicative of a higher likelihood
of midterm default. The pool additionally includes 16 loans
(representing a combined 27.9% of the pool by allocated loan
balance) with issuance loan-to-value ratios (LTVs) exceeding 67.1%,
a threshold historically indicative of above-average default
frequency. The weighted-average (WA) LTV of the pool at issuance is
61.8%, and the pool will amortize down to a WA LTV of 57.6% at
maturity.

The collateral features two loans, representing a combined 8.8% of
the pool, that have investment-grade shadow ratings from DBRS
Morningstar: 650 Madison and 805 3rd Avenue. The 650 Madison loan
exhibits credit characteristics consistent with a BBB (low) shadow
rating, and 805 3rd Avenue exhibits credit characteristics
consistent with a BBB shadow rating.

Of the 55 loans in the pool, the DBRS Morningstar sample included
27 loans, representing a combined 73.6% of the pool by allocated
loan balance. Of the loans sampled, 12, representing 55.2% of the
sample, have either Average (+) or Above Average property quality.
Additionally, only four loans, representing 13.5% of the sampled
loans, have Average (-) or Below Average property quality. The
properties securing the three largest loans in the pool, all with
identical balances representing 4.4% of the pool balance each, are
Average (+).

The pool exhibits some leverage barbelling. While the pool has six
loans, representing 13.1% of the pool balance, which have an
issuance LTV below 59.3%, a threshold historically indicative of
relatively low-leverage financing and generally associated with
below-average default frequency, there are also 16 loans,
representing 27.9% of the pool balance, which have an issuance LTV
above 67.1%, a threshold historically indicative of relatively
high-leverage financing and generally associated with above-average
default frequency. Only two of the identified high-leverage loans
exhibit a DBRS Morningstar DSCR of less than 1.32x. These loans
exhibited a WA expected loss of 6.8%, which is considerably higher
than the WA expected loss of the overall pool. As a result, DBRS
Morningstar reflects the risk of these loans in the credit
enhancement levels of the pool.

The pool features a relatively high concentration of loans secured
by properties in less favorable suburban market areas. Thirty
loans, representing 46.9% of the pooled cutoff balance, are secured
by properties predominately in areas with a DBRS Morningstar Market
Rank of either 3 or 4. The DBRS Morningstar WA DSCR of these loans
is still relatively high at 1.87x and the pool also has 13 loans,
representing 31.2% of the cutoff pool balance, that are in urban
areas with a DBRS Morningstar Market Rank of 7 or 8.

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

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


COLT 2018-2: DBRS Assigns BB(high) Rating on Class B-2 Certs
------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage Pass-Through
Certificates from the COLT 2018-2, 2019-1, 2019-2, and 2019-3
Mortgage Loan Trust transactions:

COLT 2018-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AA (high) (sf)
-- Class M-1 at AA (low) (sf)
-- Class B-1 at BBB (high) (sf)
-- Class B-2 at BB (high) (sf)

COLT 2019-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (high) (sf)

COLT 2019-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class M-1 at A (low) (sf)
-- Class B-1 at BBB (sf)
-- Class B-2 at B (high) (sf)

COLT 2019-3

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at BB (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

These four COLT transactions are generally classified as
non-qualified mortgage (non-QM) transactions.

DBRS Morningstar performed the following rating analysis on the
transactions:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and

     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for each of the transactions. DBRS Morningstar recalculated
or remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transactions were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for each transaction are generally stepped up
from the raw model results.


COMM 2015-CCRE22: Fitch Affirms BB-sf Rating on Class E Certs
-------------------------------------------------------------
Fitch Ratings affirmed 13 classes of COMM 2015-CCRE22 Mortgage
Trust commercial mortgage pass-through certificates, series
2015-CCRE22.

RATING ACTIONS

COMM 2015-CCRE22

Class A-2 12592XAZ9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 12592XBA3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 12592XBC9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-5 12592XBD7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-M 12592XBF2;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 12592XBB1; LT AAAsf Affirmed;  previously at AAAsf

Class B 12592XBG0;    LT AA-sf Affirmed;  previously at AA-sf

Class C 12592XBJ4;    LT A-sf Affirmed;   previously at A-sf

Class D 12592XAG1;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 12592XAJ5;    LT BB-sf Affirmed;  previously at BB-sf

Class PEZ 12592XBH8;  LT A-sf Affirmed;   previously at A-sf

Class X-A 12592XBE5;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 12592XAA4;  LT AA-sf Affirmed;  previously at AA-sf

Classes X-A and X-B are interest only. Class PEZ is an exchangeable
class corresponding to classes A-M, B, and C.

KEY RATING DRIVERS

Overall Stable Loss Expectations: The affirmations are based on the
overall stable performance of the underlying collateral. There are
no loans in special servicing and three loans (4.9%) have been
designated as Fitch Loans of Concern (FLOC). The pool has realized
$54,052 in losses which are impacting the non-rated class H.

Improving Credit Enhancement: As of the November 2019 distribution
date, the pool's aggregate principal balance has been paid down by
6.7% to $1.21 billion from $1.30 billion at issuance. Since Fitch's
prior rating action, one loan has liquidated with a small loss and
total defeasance has increased to 8.2% of the current pool balance
compared to 1.5% at the prior rating action. As property-level
performance is generally in line with issuance expectations, the
original rating analysis was considered in affirming the
transaction.

Fitch Loans of Concern: Three performing loans (4.9%) have been
designated as FLOCs. The largest FLOC is TPI Hospitality Pool A
(2.3%), a two-property hotel portfolio located in the Minneapolis
metro area. While occupancy has remained stable, cash flow for the
portfolio has declined due to increasing expenses. As of the 3Q
2019 TTM financials, the portfolio is performing at a 1.53x NCF
DSCR. Other FLOCs include 1424 K Street Northwest and 3300-3340 New
York Ave (1.8%), two cross-collateralized office and industrial
properties in Washington D.C. with declining occupancy and cash
flow; and Mayfair Plaza (0.8%), a retail property on the north side
of Chicago where a major tenant (Mattress Firm - 18.5% NRA) has
vacated and two additional tenants (11.3% NRA) have leases rolling
in 2020.

Limited Amortization: Seven loans, representing 25.1% of the pool,
are full term interest-only, and 25 loans, representing 46.6% of
the pool, are partial interest-only. The remainder of the pool
consists of 29 balloon loans representing 28.2% by balance, with
two loans (1.2%) maturing in 2020, one loan (0.8%) maturing in
2022, two loans (1.2%) maturing in 2022, and 24 loans (24%)
maturing in 2025.

New York City and Leased Fee Concentration: Seven loans (29.7%) are
secured by properties located in New York City, including the
largest loan in the pool. In addition, three loans in the pool
(10.7%) are secured by leased fee properties located in New York
City and Portland, OR.

RATING SENSITIVITIES

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



DEEPHAVEN RESIDENTIAL 2018-3: DBRS Assigns B Rating on B-2 Notes
----------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage-Backed Notes
from eight Deephaven Residential Mortgage Trust (DRMT)
transactions:

DRMT 2017-3

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AA (high) (sf)
-- Class M-1 at AA (low) (sf)

DRMT 2018-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AA (high) (sf)
-- Class M-1 at AA (low) (sf)

DRMT 2018-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AA (high) (sf)
-- Class M-1 at A (sf)

DRMT 2018-3

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (sf)
-- Class B-2 at B

DRMT 2018-4

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (sf)
-- Class B-2 at B (sf)

DRMT 2019-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (sf)
-- Class B-2 at B (sf)

DRMT 2019-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (sf)

DRMT 2019-3

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

These eight DRMT transactions are generally classified as
non-qualified mortgage (non-QM) transactions.

DBRS Morningstar performed the following rating analysis on the
transactions:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for each of the transactions. DBRS Morningstar recalculated
or remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transactions were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for each transaction are generally stepped up
from the raw model results.


EAST WEST 2019-1: S&P Assigns BB- (sf) Rating to Class E Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to East West Investment
Management CLO 2019-1 Ltd./East West Investment Management CLO
2019-1 LLC's floating-rate notes.

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

The ratings reflect S&P's view of:

-- The diversification of the collateral pool;

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

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

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

  RATINGS ASSIGNED

  East West Investment Management CLO 2019-1 Ltd./East West  
  Investment Management CLO 2019-1 LLC

  Class            Rating           Amount (mil. $)

  A                AAA (sf)                 225.000
  B                AA (sf)                   44.500
  C (deferrable)   A (sf)                    24.500
  D (deferrable)   BBB- (sf)                 17.500
  E (deferrable)   BB- (sf)                  10.500
  Sub notes        NR                        34.925

  NR--Not rated.


ELLINGTON FINANCIAL 2018-1: DBRS Assigns B Rating on B-2 Certs
--------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage Pass-Through
Certificates from two Ellington Financial Mortgage Trust (EFMT)
transactions:

EFMT 2018-1

-- Class A-1FX at AAA (sf)
-- Class A-1FLA at AAA (sf)
-- Class A-1FLB at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (sf)

EFMT 2019-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (sf)
-- Class M-1 at BBB (sf)
-- Class B-1 at BB (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

These two EFMT transactions are generally classified as
non-qualified mortgage (non-QM) transactions.

DBRS Morningstar performed the following rating analysis on the
transactions:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and

     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for each of the transactions. DBRS Morningstar recalculated
or remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transactions were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for each transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


GCAT 2019-NQM1: DBRS Assigns B(high) Rating on Class B-2 Certs
--------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage Pass-Through
Certificates from GCAT 2019-NQM1:

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (high) (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

The GCAT transaction is generally classified as a non-qualified
mortgage (non-QM) transaction.

DBRS Morningstar performed the following rating analysis on the
transaction:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for the transaction. DBRS Morningstar recalculated or
remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transaction were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for the transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


GE COMMERCIAL 2007-C1: Moody's Cuts Rating on 3 Tranches to Caa1
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on three classes and
downgraded the ratings on three classes in GE Commercial Mortgage
Corporation, Series 2007-C1 Trust, Commercial Mortgage Pass-Through
Certificates as follows:

Cl. A-M, Downgraded to Caa1 (sf); previously on Aug 23, 2018
Affirmed B3 (sf)

Cl. A-MFL, Downgraded to Caa1 (sf); previously on Aug 23, 2018
Affirmed B3 (sf)

Cl. A-MFX, Downgraded to Caa1 (sf); previously on Aug 23, 2018
Affirmed B3 (sf)

Cl. A-J, Affirmed C (sf); previously on Aug 23, 2018 Affirmed C
(sf)

Cl. A-JFL, Affirmed C (sf); previously on Aug 23, 2018 Affirmed C
(sf)

Cl. X-C*, Affirmed C (sf); previously on Aug 23, 2018 Affirmed C
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on three P&I classes were downgraded due to increased
realized losses and higher anticipated losses from the deal's
exposure to specially serviced loans. The remaining two loans in
the pool are both in special servicing.

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

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

Moody's rating action reflects a base expected loss of 75.2% of the
current pooled balance, compared to 68.1% at Moody's last review.
Moody's base expected loss plus realized losses is now 21.0% of the
original pooled balance, compared to 19.7% 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 would 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 would 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
interest-only classes was "Moody's Approach to Rating Large Loan
and Single Asset/Single Borrower CMBS" published in July 2017. The
methodologies used in rating interest-only classes were "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 100% of the pool is in
special servicing. In this approach, Moody's determines a
probability of default for each specially serviced 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 10, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 93.8% to $246.7
million from $3.9 billion at securitization. The certificates are
collateralized by two mortgage loans that are both in special
servicing. Sixty loans have been liquidated from the pool,
resulting in an aggregate realized loss of $643.3 million (for an
average loss severity of 55%).

The largest remaining specially serviced loan is the JPMorgan
Portfolio Loan ($134.6 million -- 54.5% of the pool), which was
originally secured by the fee and leasehold interests in two office
properties. The properties included a 724,000 square foot (SF)
office building and 1,905 stall parking garage located in Phoenix,
Arizona and a 429,000 SF office building located in Houston, Texas.
The loan was transferred to the special servicer in March 2017 due
to the borrower being unable to repay the loan at maturity in April
2017. A note sale of the Phoenix Office Complex concluded in March
2018, and paid down the loan balance by approximately $62.2
million. The remaining Houston property was foreclosed in February
2018 and is now REO. The property is currently 100% leased to
JPMorgan Chase through September 2021, however, the special
servicer indicated that the tenant has signaled it would wait for
new ownership prior negotiating any lease extensions. Due to the
single tenant exposure, Moody's valuation reflects a lit/dark
analysis.

The second largest specially serviced loan is the Wellpoint Office
Tower ($112.1 million -- 45.5% of the pool), which is secured by
the fee interest in a 13-story Class A office building and three,
single-story annex buildings. The properties are located on a 6.3
acre site in Woodland Hills, California, approximately 25 miles
from the Los Angeles CBD. The tower building comprises 365,000 SF
of office space, with a helicopter pad located on the roof. The
three, single-story buildings consist of the Visitor Center which
includes security offices, the Walker Theatre Building which houses
an auditorium and series of classrooms and computers for training
of personnel, and the Cafeteria Building which holds a full service
cafeteria. The property was 100% leased as of September 2019 to
Anthem Blue Cross, however, Anthem Blue Cross is relocating its
corporate operations to a new space at the nearby Warner Center
office campus following its lease expiration in December 2019. The
loan transferred to special servicing after the loan was unable to
refinance at its December 2019 maturity date.



GERMAN AMERICAN 2012-LC4: Fitch Lowers Class E Certs to Bsf
-----------------------------------------------------------
Fitch Ratings downgraded one class and affirmed seven classes of
German American Capital Corp.'s COMM 2012-LC4 commercial mortgage
pass-through certificates. Fitch has also revised the Rating
Outlooks on classes A-M, B, and X-A to Negative from Stable.

RATING ACTIONS

COMM 2012-LC4

Class A-4 126192AD5; LT AAAsf Affirmed;  previously at AAAsf

Class A-M 126192AE3; LT AAAsf Affirmed;  previously at AAAsf

Class B 126192AF0;   LT AAsf Affirmed;   previously at AAsf

Class C 126192AG8;   LT Asf Affirmed;    previously at Asf

Class D 126192AK9;   LT BBB-sf Affirmed; previously at BBB-sf

Class E 126192AL7;   LT Bsf Downgrade;   previously at BBsf

Class F 126192AM5;   LT CCCsf Affirmed;  previously at CCCsf

Class X-A 126192AH6; LT AAAsf Affirmed;  previously at AAAsf

KEY RATING DRIVERS

Increased Loss Expectations/Specially Serviced Loans: Fitch's base
case expected loss reflects higher loss expectations associated
with the specially serviced asset/loans. Two loans (5.7%) are
currently in special servicing; one (3.7%) is currently REO and the
other (2%) was transferred since Fitch's last rating action.
Susquehanna Valley Mall, was transferred to special servicing in
March 2018 for imminent monetary default and is a 628,063 square
foot (sf) regional mall located in Selinsgrove, PA. The property
suffered declines in performance due to the loss of anchors JC
Penney (collateral) in November 2015, Sears (non-collateral) in
March 2017, BonTon (collateral) in April 2018 and Weis Markets
(collateral) in October 2018, in addition to weak in-line sales.
The trailing twelve month (TTM) 9/2019 comparable in-line sales are
$266 psf with total mall sales of $153 psf. The mall is anchored by
Boscovs and in-line occupancy is currently 55.6% with total mall
occupancy at 84.2%. Per the special servicer, the property was
foreclosed on Aug. 8, 2019 and is currently REO. At this time, the
property is not being marketed for sale and the leasing broker is
aggressively attempting to lease up the vacant space. Significant
losses are expected.

Johnstown Galleria, was transferred to special servicing in
September 2019 due to imminent default. The loan is secured by a
fee simple interest in a 45.77 acre site of loan, which is improved
by a 711,665 sf, two-story regional mall, Johnstown Galleria (not
part of collateral) that is subject to a ground lease (collateral).
Per the special servicer, the Lessee under the ground lease is in
default and the Trust's Borrower (Lessor) has issued a notice of
default. The special servicer is evaluating the matter.

Fitch Loans of Concern: In addition to the specially serviced
loans, Fitch has designated eight loans (30.2%) as Fitch Loans of
Concern (FLOCs) including four loans (25.2%) in the top 15, of
which one (3.7%) is specially serviced.

The largest non-specially serviced FLOC, Square One Mall is secured
by a 541,128 sf portion of a 928,667 sf two-story enclosed regional
mall located in Saugus, MA. The mall is shadow-anchored by Sears
and Macy's (both non-collateral), and features other major tenants
including Dick's Sporting Goods, Best Buy, BD's Furniture, TJ Maxx,
Old Navy and H&M. The mall was flagged as a FLOC due to exposure to
troubled retailers, declining NOI and near-term lease roll. The
Sears box is owned by Seritage Growth Properties, and while the
store is not on recent store closing lists, it consolidated and
continues to operate on the first floor and the second floor
remains vacant. The third largest tenant, BD Furniture (11%),
renewed their lease through April 2022. The property's in-line
occupancy is 74.7% as of September 2019 with collateral occupancy
at 84.2%. Fitch requested updates on leasing activity and tenant
sales. Per the master servicer, the borrower is not required to
report tenant sales.

The second largest FLOC, Alamance Crossing East is a 649,989 sf
open-air lifestyle center anchored by Dillard's, JC Penney, and
Belk, along with a 16-screen Carousel Cinemas theater. Hobby Lobby
and Barnes and Noble are junior anchors. The lifestyle component of
the center contains 198,740 sf of in-line retail space and four
freestanding restaurant pads (23,000 sf). Dillard's (124,683 sf)
and JC Penney (102,826 sf) own their own stores and underlying
land. Alamance Crossing Central is a strip retail shopping center
located across an access road and west of Alamance Crossing East.
It contains 32,639 SF of NRA, all of which are part of the
collateral. The property is 91.3% occupied as of September 2019.
There is approximately 12% rollover in 2019 and 8% in 2020. The
most recent reported tenant sales for Dillard's (noncollateral)
were $62 (2017); $59 (2016); $61 (2015);JC Penney (noncollateral):
$77 (2018); $74 (2017); $79 (2016); Belk: $131 (2018); $136 (2017);
$133 (2016); $133 (2015); Carousel Cinemas (16 screens): $288,960
(2017); 276,770 (2016).

The third largest non-specially serviced FLOC, Montebello Town
Square, is secured by a 251,489 sf retail center located in
Montebello, CA, built in 1992. At issuance, the property was
anchored by Sears, Toys 'R' Us, AMC Theatres and Petco. Toys R Us
46,270 sf (18% GLA; lease exp. Jan 2023) and Sears (42% GLA; lease
exp. Feb 2022) both filed bankruptcy and vacated. Big Lots leased
the vacant Toys R Us as of June 2018 and the store opened in Dec
2018. There were no co-tenancy issues related to the Toys R Us.
Sears filed BK in October 2018 and the store closed by Jan. 6,
2019; they accounted for 36% of base rent at the property. One
tenant, Petco, has a co-tenancy clause requiring Sears or another
tenant to be open and operating in the space. An update on leasing
activity and vacant Sears space was requested. The property is
57.7% occupied as of June 2019. There is approximately 3% rollover
in 2020, 3% in 2021, 11% in 2022; 19% in 2023; 2% in 2024; 3% in
2025; 16% in 2028. The most recently reported tenant sales for AMC
Montebello 10 Theatre Sales: were $1,276,854 (2018); $1,249,444
(2017); 1,360,173 (2016).

High Retail Concentration: Retail properties account for 60.3% of
the pool, an increase from 41% at issuance; and comprise 72% of the
current non-defeased collateral. Retail properties include three
(23%) regional malls and exposure to retailers Macy's, JC Penney,
Best Buy and Barnes and Noble. The majority of Fitch's increased
loss expectations in the base case and in the sensitivity scenario
are due to the larger retail properties within the top 15.

Improved Credit Enhancement: Credit enhancement has improved since
issuance due to ongoing amortization and defeasance. As of December
2019, the pool has paid down 27.8%. The majority of the pool, (28
loans, 80.8%) have been amortizing since issuance and the eighth
largest loan, Piatt Place (4.5%), is the only partial interest-only
loan in the pool and has been amortizing since 2014. The remaining
three loans (14.6%) are full-term interest only. Additionally, six
loans (19%) have been fully defeased; four (11%) since Fitch's last
rating action.

Alternative Loss Considerations: Fitch applied an additional
sensitivity scenario of 25% on the Square One Mall, 25% on Alamance
Crossing, 40% on Montebello Town Square all to reflect the
potential for outsized losses given declining/or lack of updated
sales, exposure to weaker anchors/troubled retailers, upcoming
rollover, loss of anchor tenants. The sensitivity scenario also
factored in the expected paydown of the transaction from defeased
loans. The Negative Rating Outlooks on Classes A-M through E and
X-A reflect this scenario.

RATING SENSITIVITIES

The Rating Outlook Negative for classes AM through E indicates that
future downgrades to the classes are possible if the performance of
the larger Fitch Loans of Concern further deteriorates and/or
additional loans default and/or if loans with increased loss
assumptions in Fitch's sensitivity test approach maturity without
performance improvement. The Rating Outlook for class A-4 remains
Stable due to sufficient credit enhancement and continued
amortization and defeasance. Upgrades are possible with improved
pool performance and additional paydown or defeasance. However,
upgrades may be limited given the concentration of regional malls,
as these may have difficulty refinancing given declines in
performance and a potentially higher interest rate environment.


GREAT WOLF 2019-WOLF: Moody's Assigns B3 Rating on Class F Certs
----------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to six
classes of CMBS securities, issued by Great Wolf Trust 2019-WOLF
Commercial Mortgage Pass-Through Certificates, Series 2019-WOLF:

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)

Cl. F, Definitive Rating Assigned B3 (sf)

*Note: Moody's previously assigned a provisional rating to Class
X-CP described in the provisional press release, dated December 5,
2019. Per the "Moody's Approach to Rating Structured Finance
Interest-Only (IO) Securities" published in February 2019, Moody's
has withdrawn the Class X-CP provisional rating and will not assign
this certificate a definitive rating given that the deal may be
paid off prior to Class X-CP receiving scheduled payments.

RATINGS RATIONALE

The certificates are collateralized by a single loan collateralized
by the borrower's varying ownership interests in a portfolio of 17
waterpark resorts. The single borrower underlying the mortgage is
comprised of thirty-three special-purpose bankruptcy-remote
entities, that are subsidiaries of Great Wolf Resorts, Inc. which
is majority owned and controlled by a joint venture indirectly
majority owned and controlled by Blackstone Real Estate Partners IX
L.P.

Moody's approach to rating this transaction involved an application
of Moody's Approach to Rating Large Loan and Single Asset/Single
Borrower. 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, we also consider 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 first mortgage balance of $1,700,000,000 represents a Moody's
LTV of 118.7%. The Moody's first mortgage actual DSCR is 2.49X and
Moody's first mortgage actual stressed DSCR is 1.07X.

Loan collateral is secured by the cross-collateralized first
mortgage liens on the applicable fee and or leasehold interests in
14 resort properties (collectively, the "Wholly Owned Properties"),
(ii) the applicable borrowers' interests in the operating leases
relating to the Wholly Owned Properties (other than the
Williamsburg Wholly Owned property), (iii) a pledge of the
Borrowers' indirect equity interests in the joint venture entities
that own two resort properties (the "JV Properties"), (iv) a pledge
of the license and franchise management agreements with respect to
the Wholly Owned Properties and one resort owned and managed by a
third party (the "Non-Owned Licensed Property" and, together with
the Wholly Owned Properties and the JV Properties, the
"Licensed/Managed Properties") and the applicable Borrowers' right
to receive certain fees under the license, franchise and management
agreements with respect to the JV Properties, (v) the Borrowers'
interests in certain intellectual property and (vi) a pledge of
equity interests in the Borrower that owns such intellectual
property and the Borrower that acts as a manager under the license
and franchise management agreements.

Notable strengths of the transaction include: revenue diversity,
strong performance trends, portfolio diversity, property age and
capital investment, and experienced sponsorship.

Notable credit challenges of the transaction include: competition
and new supply, property type performance volatility, the loan's
floating-rate and interest-only mortgage loan profile, and credit
negative legal features.

Moody's rating approach considers sequential pay in connection with
a collateral release as a credit neutral benchmark. Although the
loans' release premium mitigates the risk of a ratings downgrade
due to adverse selection, the pro rata payment structure limits
ratings upgrade potential as mezzanine classes are prevented from
building enhancement. The benefit received from pooling through
cross-collateralization is also reduced.

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 our
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.


IMSCI 2012-2: DBRS Puts B(low) on Class G Certs Under Review
------------------------------------------------------------
DBRS Limited placed four classes of the Commercial Mortgage
Pass-Through Certificates issued by Institutional Mortgage
Securities Canada Inc. (IMSCI) Series 2012-2 Under Review with
Negative Implications as follows:

-- Class D at BBB (high) (sf), Under Review with Negative
     Implications

-- Class E at BBB (low) (sf), Under Review with Negative
     Implications

-- Class F at BB (low) (sf), Under Review with Negative
     Implications

-- Class G at B (low) (sf), Under Review with Negative
     Implications

There are no trends for these rating actions. After the last
surveillance review in March 2019, DBRS Morningstar maintained
Negative trends for Classes F and G, with Classes E and D assigned
Stable trends. The Negative trends previously assigned to Classes F
and G reflected DBRS Morningstar's concerns surrounding the
performance decline of the Lakewood Apartments loan (10.0% of the
pool), secured by a property located in Fort McMurray.

DBRS Morningstar has taken these actions because of the concerns
and uncertainty surrounding the Centre 1000 loan (Prospectus ID#7,
8.3% of the pool) amid recent developments with the loan sponsor,
Strategic Group, LLC (Strategic Group).

On December 11, 2019, Strategic Group, a Calgary-based real estate
investment firm, submitted an initial application filing under
Canada's Companies' Creditors Arrangement Act (CCAA). The filing
affects entities affiliated with 50 commercial properties within
the company's 171-property portfolio, including the collateral
property for the Centre 1000 loan in this pool. The subject
property has been underperforming following the loss of a major
tenant in early 2018, driving the debt service coverage ratio
(DSCR) down to 0.16 times (x) at year-end 2018, when occupancy for
the property was reported at 62.0%. Updated occupancy and leasing
information has been requested from the servicer and the response
is pending.

Notes: All figures are in Canadian dollars unless otherwise noted.


IMSCI 2013-3: DBRS Puts B(low) on Class G Certs Under Review
------------------------------------------------------------
DBRS Limited placed four classes of the Commercial Mortgage
Pass-Through Certificates issued by Institutional Mortgage
Securities Canada Inc. (IMSCI) Series 2013-3 Under Review with
Negative Implications as follows:

-- Class D at BBB (sf), Under Review with Negative Implications

-- Class E at BBB (low) (sf), Under Review with Negative
     Implications

-- Class F at B (sf), Under Review with Negative Implications

-- Class G at B (low) (sf), Under Review with Negative
    Implications

There are no trends for these rating actions. After the last
surveillance review in March 2019, DBRS Morningstar maintained
Negative trends for Classes F and G, with Classes D and E each
assigned a Stable trend. The Negative trends previously assigned to
Classes F and G reflected DBRS Morningstar's concerns surrounding
performance declines for six properties in Fort McMurray, securing
three loans (Lunar & Whimbrel Apartments, Snowbird & Skyview
Apartments, and Parkland & Gannet Apartments) that represent a
cumulative 12.5% of the outstanding pool balance.

DBRS Morningstar has taken these latest rating actions because of
the concerns and uncertainty surrounding the Deerfoot Court
(Prospectus ID#5, 7.5% of the pool) and Airways Business Plaza
(Prospectus ID#12, 5.1% of the pool) loans amid recent developments
with the loans' sponsor, Strategic Group LLC (Strategic Group).

On December 11, 2019, Strategic Group, a Calgary-based real estate
investment firm, submitted an initial application filing under
Canada's Companies' Creditors Arrangement Act (CCAA). The filing
affects entities affiliated with 50 commercial properties within
the company's 171-property portfolio, including the collateral
properties for the Deerfoot Court and Airways Business Plaza loans
in this pool. Both properties have performed well relative to their
respective submarkets. As of YE2018 reporting, Deerfoot Court
reported an occupancy rate of 96.0% and debt service coverage ratio
(DSCR) of 1.46 times (x) while Airways Business Plaza reported an
occupancy rate of 89.0% and DSCR of 1.29x. Updated occupancy and
leasing information has been requested from the servicer and the
response is pending.

Notes: All figures are in Canadian dollars unless otherwise noted.


JP MORGAN 2005-LDP2: Moody's Hikes Class G Debt Rating to B1
------------------------------------------------------------
Moody's Investors Service upgraded the rating on one class and
affirmed the ratings on two classes in J.P. Morgan Chase Commercial
Mortgage Securities Corp. Series 2005-LDP2 as follows:

Class G, Upgraded to B1 (sf); previously on February 20, 2019
Upgraded to Caa2 (sf)

Class H, Affirmed C (sf); previously on February 20, 2019 Affirmed
C (sf)

Class X-1*, Affirmed C (sf); previously on February 20, 2019
Affirmed C (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The rating on Principal & Interest (P&I) Cl. G was upgraded
primarily due to an increase in credit support resulting from loan
paydowns and amortizations as well as an increase in the pool's
share of defeasance. The deal has paid down 73% since Moody's last
review and defeasance increased to 12.9% of the pool from 1.1% at
last review.

The rating of P&I Class H was affirmed because the rating is
consistent with Moody's expected loss plus realized losses. Class H
has already experienced a 74% realized loss as a result of
previously liquidated loans.

The rating of Interest Only (IO) Class X-1 was affirmed based on
the credit quality of its referenced classes.

Moody's rating action reflects a base expected loss of 12.3% of the
current pooled balance, compared to 3.2% at Moody's last review.
Moody's base expected loss plus realized losses is now 6.8% of the
original pooled balance, unchanged since 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
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 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 99.5% to $15.3
million from $2.98 billion at securitization. The certificates are
collateralized by 13 mortgage loans ranging in size from less than
1% to 15.5% of the pool. Two loans, constituting 12.9% of the pool,
have defeased and are secured by US government securities.

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

Two loans, constituting 28.6% 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.

Sixty-one loans have been liquidated from the pool with a loss,
contributing to an aggregate realized loss of $200.6 million (for
an average loss severity of 35%). One loan, the Landmark Retail
Portfolio ($1.9 million -- 12.1% of the pool), is currently in
special servicing. The specially serviced loan was originally
secured by three retail centers totaling 78,131 SF. The loan
transferred to special servicing in June 2014 due to imminent
default. Two of the properties were sold between 2017 and 2018. The
loan is now secured by one retail center, Prestige Plaza, totaling
22,661 SF located and located in Miamisburg, Ohio. The remaining
property was 76% leased as of August 2018. The asset is currently
REO and the special servicer is working to lease up the property.

Moody's received full year 2018 operating results for 100% of the
pool, and full or partial year 2019 operating results for 59% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 50%, compared to 70% 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 9.4%.

Moody's actual and stressed conduit DSCRs are 1.19X and 3.78X,
respectively, compared to 1.21X and 1.81X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three non-defeased performing loans represent 43.7% of the
pool balance. The largest loan is the Cedar Breaks Retail Loan
($2.4 million -- 15.5% of the pool), which is secured by 26,813 SF
retail center located in Georgetown, TX, approximately 34 miles
north of Austin, TX. The retail center was constructed in 2004 and
its largest tenant is CVS (52% of NRA, lease expiration in March
2024). As of March 2019 rent roll, the property was 100% occupied.
This loan has amortized approximately 59% since securitization.
Moody's LTV and stressed DSCR are 44% and 2.34X, respectively.

The second largest loan is the Townparc at Tyler Loan ($2.3 million
-- 15.0% of the pool), which is secured by a 96-unit garden style
multifamily community located in Tyler, TX, approximately 95 miles
southeast of Dallas, TX and 98 miles west of Shreveport, LA. The
property was constructed in 2003 and was 95% leased as of October
2019 rent roll. The loan has amortized approximately 26% since
securitization. Moody's LTV and stressed DSCR are 72% and 1.35X,
respectively.

The third largest loan is The Boulders Center Loan ($2.0 million --
13.1% of the pool), which is secured by a 32,000 square foot (SF)
retail center, located in Richmond, VA. The property was
constructed in 1972 and includes Aaron's Rental, WaWa and an auto
body shop. As of September 2019 rent roll, the property was 100%
leased. The loan has amortized approximately 41% since
securitization. Moody's LTV and stressed DSCR are 52% and 1.97X,
respectively.


JP MORGAN 2019-INV3: Moody's Assigns B3 Rating on 2 Tranches
------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to 34 classes
of residential mortgage-backed securities issued by J.P. Morgan
Mortgage Trust 2019-INV3. The ratings range from Aaa (sf) to B3
(sf). JPMMT 2019-INV3 is the twentieth prime jumbo transaction of
2019 issued by J.P. Morgan Mortgage Acquisition Corporation and the
third JPMMT transaction in 2019 backed by 100% investment property
loans.

The certificates are backed by 1,049 fully-amortizing (20, 25 and
30-year term) fixed-rate investment property mortgage loans with a
total balance of $388,315,530 as of the December 1, 2019, cut-off
date. Similar to prior JPMMT transactions backed by 100% investment
property loans, JPMMT 2019-INV3 includes GSE-eligible mortgage
loans (97.9% by loan balance) mostly originated by JPMorgan Chase
Bank, National Association, United Shore Financial Services d/b/a
United Wholesale Mortgage and Shore Mortgage and Quicken Loans Inc.
underwritten to the government sponsored enterprises guidelines.
The remaining 2.1% is comprised of prime jumbo non-conforming
investor mortgages purchased by JPMMAC, sponsor and mortgage loan
seller, from various originators and aggregators. JPMCB, United
Shore and Quicken originated 36.6%, 31.7% and 10.6% of the mortgage
pool, respectively.

NewRez LLC f/k/a New Penn Financial, LLC d/b/a Shellpoint Mortgage
Servicing, JPMCB, Quicken and United Shore are the servicers. JPMCB
and Quicken will service approximately 36.6% and 10.6% of the
mortgage loans, respectively, on behalf of the issuing entity.
Shellpoint will interim service approximately 21.2% of the mortgage
loans on behalf of the issuing entity from the closing date until
the servicing transfer date, after which date the mortgage loans
will be serviced by JPMCB. The servicing transfer date is expected
to occur on or about February 1, 2020, but may occur on a later
date as determined by the issuing entity and JPMCB. United Shore
will own the mortgage servicing rights for approximately 31.7% of
the mortgage loans which will be serviced by Cenlar FSB, as
subservicer.

The complete rating actions are as follows:

Issuer: J.P. Morgan Mortgage Trust 2019-INV3

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Cl. A-14, Definitive Rating Assigned Aa1 (sf)

Cl. A-15, Definitive Rating Assigned Aa1 (sf)

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

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

Cl. B-1, Definitive Rating Assigned Aa3 (sf)

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

Cl. B-2, Definitive Rating Assigned A2 (sf)

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

Cl. B-3, Definitive Rating Assigned Baa2 (sf)

Cl. B-3-A, Definitive Rating Assigned Baa2 (sf)

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

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

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

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected loss for this pool in a baseline scenario is 1.28%
and reaches 10.00% at a stress level consistent with our Aaa
ratings.

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

Collateral Description

The JPMMT 2019-INV3 transaction is a securitization of 1,049
investment property mortgage loans secured by fixed rate, first
liens on one-to-four family residential investment properties,
planned unit developments, condominiums and townhouses with an
unpaid principal balance of $388,315,530. The GSE-eligible loans,
which make up about 98% of the JPMMT 2019-INV3 pool by loan
balance, were underwritten using Fannie Mae's Desktop Underwriter
Program or Freddie Mac's Loan Prospector Program, subject to any
permitted variances for the related originator.

All the loans have a 20-year (22 loans or 1.25% of UPB), 25-year (2
loans or 0.17% of UPB) or a 30-year original term (1,025 loans or
98.6% of UPB). The weighted average seasoning of the mortgage pool
is 3.4 months. The loans have strong borrower characteristics with
a WA original primary borrower FICO score of 766 and a WA original
combined loan-to-value ratio of 66.6%. In addition, 28.3% of the
borrowers are self-employed and refinance loans comprise about
46.5% of the aggregate pool. The pool has a high geographic
concentration with 48.1% of the aggregate pool located in
California, with 19.2% located in the Los Angeles-Long
Beach-Anaheim, CA MSA and 9.6% located in San
Francisco-Oakland-Hayward, CA MSA. The characteristics of the loans
underlying the pool are generally comparable to other recent prime
RMBS transactions backed primarily by 100% investment property
30-year mortgage loans that we have rated.

With the exception of personal-use loans, all other mortgage loans
in the pool are not subject to TILA because each such mortgage loan
is an extension of credit primarily for a business purpose and is
not a "covered transaction" as defined in Section 1026.43(b)(1) of
Regulation Z. All the personal-use loans are "qualified mortgages"
under Regulation Z as result of the temporary provision allowing
qualified mortgage status for loans eligible for purchase,
guaranty, or insurance by Fannie Mae and Freddie Mac (and certain
other federal agencies). The sponsor, directly or through a
majority-owned affiliate, intends to retain an eligible vertical
residual interest with a fair value of at least 5% of the aggregate
fair value of the notes issued by the trust.

Aggregation/Origination Quality

We consider JPMMAC's aggregation platform to be adequate and we did
not apply a separate loss-level adjustment for aggregation quality.
In addition to reviewing JPMMAC as an aggregator, we have also
reviewed the originator(s) contributing a significant percentage of
the collateral pool (above 10%). With one exception noted below, we
did not make an adjustment for GSE-eligible loans, regardless of
the originator, since those loans were underwritten in accordance
with GSE guidelines. However, we applied an adjustment to the loss
levels for loans originated by Quicken due to the relatively worse
performance of their agency-eligible investment property mortgage
loans compared to similar loans from other originators in the
Freddie Mac and Fannie Mae database.

Servicing Arrangement

We consider the overall servicing arrangement for this pool to be
adequate given the strong servicing arrangement of the servicers,
as well as the presence of a strong master servicer to oversee the
servicers. The servicers are contractually obligated to the issuing
entity to service the related mortgage loans. In this transaction,
Nationstar Mortgage LLC (rated B2) will act as the master servicer.
The servicers are required to advance principal and interest on the
mortgage loans. To the extent that the servicers are unable to do
so, the master servicer will be obligated to make such advances. In
the event that the master servicer, Nationstar, is unable to make
such advances, the securities administrator, Citibank N.A. (rated
Aa3) will be obligated to do so to the extent such advance is
determined by the securities administrator to be recoverable.

Servicing Fee Framework

The servicing fee for loans serviced by JPMCB, Shellpoint and
United Shore will be based on a step-up incentive fee structure
with a monthly base fee of $40 per loan and additional fees for
servicing delinquent and defaulted loans. The incentive structure
includes an initial monthly base servicing fee of $40 for all
performing loans and increases according to a pre-determined
delinquent and incentive servicing fee schedule. The delinquent and
incentive servicing fees will be deducted from the available
distribution amount and Class B-6 net WAC. The other servicer,
Quicken, will be paid a monthly flat servicing fee equal to
one-twelfth of 0.25% of the remaining principal balance of the
mortgage loans.

The servicing fee framework is comparable to other recent JPMMT
transactions backed by prime mortgage loans that we have rated. By
establishing a base servicing fee for performing loans that
increases with the delinquency of loans, the fee-for-service
structure aligns monetary incentives to the servicer with the costs
of the servicer. The servicer receives higher fees for
labor-intensive activities that are associated with servicing
delinquent loans, including loss mitigation, than they receive for
servicing a performing loan, which is less labor-intensive. The
fee-for-service compensation is reasonable and adequate for this
transaction because it better aligns the servicer's costs with the
deal's performance. Furthermore, higher fees for the more
labor-intensive tasks make the transfer of these loans to another
servicer easier, should that become necessary. By contrast, in
typical RMBS transactions a servicer can take actions, such as
modifications and prolonged workouts, that increase the value of
its mortgage servicing rights. The transaction does not have a
servicing fee cap, so, in the event of a servicer replacement, any
increase in the base servicing fee beyond the current fee will be
paid out of the available distribution amount.

Third-Party Review

Two third party review firms, AMC Diligence, LLC (AMC) and Opus
Capital Markets Consultants, LLC (Opus) (collectively, TPR firms),
verified the accuracy of the loan-level information that we
received from the sponsor. These firms conducted detailed credit,
valuation, regulatory compliance and data integrity reviews on 100%
of the mortgage pool. The TPR results indicated compliance with the
originators' underwriting guidelines for majority of loans, no
material compliance issues, and no appraisal defects. The TPR firms
also reviewed the loan files for indications that the loans were
approved by the DU/LP Programs. Overall, the loans that had
exceptions to guidelines had strong documented compensating factors
such as low DTIs, low LTVs, high reserves, high FICOs, or clean
payment histories. Overall, we did not make any adjustments to our
credit enhancement for credit and regulatory compliance quality
issues.

Furthermore, the property valuation review consisted of reviewing
the valuation materials utilized at origination to ensure the
appraisal report was complete and in conformity with the
underwriting guidelines. The TPR firms also reviewed each loan to
determine whether a third-party valuation product was required and
if required, that the third-party product value was compared to the
original appraised value to identify a value variance. The property
valuation portion of the TPR was conducted using, among other
methods, a third-party collateral desk appraisal (CDA), a field
review, automated valuation model (AVM), Fannie Mae's Collateral
Underwriter (CU) or Freddie Mac Loan Collateral Advisor (LCA) risk
scores. There were loans for which the original appraisal was
evaluated using only AVMs for which appraisal risk was inconsistent
with the respective GSE's day one representation warranty and
enforcement mechanism relief. We believe that utilizing only AVMs
in such situations as a comparison to verify the original
appraisals is much weaker and less accurate than utilizing CDAs.
Hence, we took this framework into consideration and applied an
adjustment to our credit enhancement levels for such loans.

R&W Framework

JPMMT 2019-INV3's R&W framework is in line with that of other JPMMT
transactions where an independent reviewer is named at closing, and
costs and manner of review are clearly outlined at issuance. Our
review of the R&W framework considers the financial strength of the
R&W providers, scope of R&Ws (including qualifiers and sunsets) and
enforcement mechanisms. The R&W providers vary in financial
strength. The creditworthiness of the R&W provider determines the
probability that the R&W provider will be available and have the
financial strength to repurchase defective loans upon identifying a
breach. An investment grade rated R&W provider lends substantial
strength to its R&Ws. We analyze the impact of less creditworthy
R&W providers case by case, in conjunction with other aspects of
the transaction.

We made no adjustments to the loans for which JPMCB (Aa2), its
affiliate, JPMMAC provided R&Ws since they are highly rated and/or
financially stable entities. Furthermore, the R&W provider,
Quicken, is rated Ba1, has a strong credit profile and is a
financially stable entity. However, we applied an adjustment to our
expected losses to account for the risk that Quicken may be unable
to repurchase defective loans in a stressed economic environment in
which a substantial portion of the loans breach the R&Ws, given
that it is a non-bank entity with a monoline business (mortgage
origination and servicing) that is highly correlated with the
economy. We tempered this adjustment by taking into account
Quicken's relative financial strength and the strong TPR results
which suggest a lower probability that poorly performing mortgage
loans will be found defective following review by the independent
reviewer.

In contrast, the rest of the R&W providers are unrated and/or
financially weaker entities. We applied an adjustment to the loans
for which these entities provided R&Ws. JPMMAC will make the
mortgage loan representations and warranties with respect to
mortgage loans originated by certain originators (approx. 1.5% by
loan balance). For loans that JPMMAC acquired via the MAXEX
Clearing LLC (MaxEx) platform, MaxEx under the assignment,
assumption and recognition agreement with JPMMAC, will make the
R&Ws. The R&Ws provided by MaxEx to JPMMAC and assigned to the
trust are in line with the R&Ws found in other JPMMT transactions.

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

Additional Counterparties

The transaction Delaware trustee is Citibank N.A. Wells Fargo Bank,
N.A. and JPMCB will each maintain custody, on behalf of the issuing
entity, of the documents relating to approximately 63.43% and
approximately 36.57% of the mortgage loans, respectively, under the
related custody agreement. The paying agent and cash management
functions will be performed by Citibank N.A. Nationstar, as master
servicer, is responsible for servicer oversight, servicer
termination and for the appointment of any successor servicer. In
addition, Nationstar is committed to act as successor if no other
successor servicer can be found. The master servicer is required to
advance principal and interest if the servicer fails to do so. If
the master servicer fails to make the required advance, the
securities administrator is obligated to make such advance.

Tail Risk & Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
balance declines, senior bonds are exposed to eroding credit
enhancement over time, and increased performance volatility as a
result. To mitigate this risk, the transaction provides for a
senior subordination floor of 1.00% of the closing pool balance,
and a subordination lock-out amount of 0.85% of the closing pool
balance. The floors are consistent with the credit neutral floors
for the assigned ratings according to our methodology.

Transaction Structure

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

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

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

The Class A-11 Certificates will have a pass-through rate that will
vary directly with the rate of one-month LIBOR and the Class A-11-X
Certificates will have a pass-through rate that will vary inversely
with the rate of one-month LIBOR. If the securities administrator
notifies the depositor that it cannot determine one-month LIBOR in
accordance with the methods prescribed in the sale and servicing
agreement and a benchmark transition event has not yet occurred,
one-month LIBOR for such accrual period will be one-month LIBOR as
calculated for the immediately preceding accrual period. Following
the occurrence of a benchmark transition event, a benchmark other
than one-month LIBOR will be selected for purposes of calculating
the pass-through rate on the class A-11 certificates.

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

Down

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

Up

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

Methodology

The principal methodology used in these ratings was "Moody's
Approach to Rating US RMBS Using the MILAN Framework " published in
October 2019.


JPMBB COMMERCIAL 2014-C23: Moody's Affirms Class UH5 Debt at Ba1
----------------------------------------------------------------
Moody's Investors Service upgraded the ratings on three classes and
affirmed the ratings on seven classes in JPMBB Commercial Mortgage
Securities Trust 2014-C23:

Cl. A-3, Affirmed Aaa (sf); previously on Sep 21, 2018 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Sep 21, 2018 Affirmed Aaa
(sf)

Cl. A-5, Affirmed Aaa (sf); previously on Sep 21, 2018 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Sep 21, 2018 Affirmed
Aaa (sf)

Cl. A-S, Upgraded to Aaa (sf); previously on Sep 21, 2018 Affirmed
Aa1 (sf)

Cl. B, Upgraded to Aa2 (sf); previously on Sep 21, 2018 Affirmed
Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on Sep 21, 2018 Affirmed A3
(sf)

Cl. X-A*, Upgraded to Aaa (sf); previously on Sep 21, 2018 Affirmed
Aa1 (sf)

Cl. EC**, Affirmed A1 (sf); previously on Sep 21, 2018 Affirmed A1
(sf)

Cl. UH5***, Affirmed Ba1 (sf); previously on Sep 21, 2018 Upgraded
to Ba1 (sf)

* Reflects interest-only classes

** Reflects exchangeable classes

*** Reflects rake bond classes

RATINGS RATIONALE

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

The ratings on two P&I classes, Cl. A-S and Cl. B, were upgraded
due to increased credit support from paydowns and amortization as
well as an increase in the pool's share of defeasance. The deal has
paid down 22.5% since securitization and defeasance now represents
11.3% of the pool.

The rating on the IO class, Cl. X-A, was upgraded due to increase
in the credit quality of its referenced classes.

The rating on the exchangeable class, Cl. EC, was affirmed due the
credit quality of its exchangeable classes.

The rating on the non-pooled rake class, Class UH5, was affirmed
based on the U-Haul Self Storage Pool 5 loan's key metrics,
including LTV and DSCR. Class UH5 is a pari passu non-pooled rake
class of the U-Haul Self Storage Pool 5 loan.

Moody's rating action reflects a base expected loss of 5.0% of the
current pooled balance, compared to 3.9% at Moody's last review.
Moody's base expected loss plus realized losses is now 3.8% of the
original pooled balance, the same as 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, exchangeable classes, and rake bond classes were "Approach
to Rating US and Canadian Conduit/Fusion CMBS" published in July
2017 and "Moody's Approach to Rating Large Loan and Single
Asset/Single Borrower CMBS" published in July 2017. The principal
methodology used in rating exchangeable classes was "Moody's
Approach to Rating Repackaged Securities" published in March 2019.
The 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. 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.

Press releases announcing prior ratings actions on the rake bond
class, Class UH5, mistakenly did not include a citation to the
principal methodology used in rating that class, "Moody's Approach
to Rating Large Loan and Single Asset/Single Borrower CMBS."

DEAL PERFORMANCE

As of the November 15, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 22.5% to $1.05
billion from $1.36 billion at securitization. The certificates are
collateralized by 54 mortgage loans ranging in size from less than
1% to 10% of the pool, with the top ten loans (excluding
defeasance) constituting 57.6% of the pool. Eight loans,
constituting 11.3% of the pool, have defeased and are secured by US
government securities. The transaction also includes a pari passu
non-pooled rake class of the U-Haul Self Storage Pool 5 loan in the
amount of $12.257 million.

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 18, compared to 25 at Moody's last review.

Nine loans, constituting 12.6% 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 since securitization.
There are currently two loans in special servicing, constituting
2.1% of the pool. The largest specially serviced loan is the 1000
Floral Vale Boulevard Loan ($13.3 million -- 1.3% of the pool),
which is secured by an 87,155 square feet (SF) office property
located in Yardley, PA. The loan transferred to the special
servicing in November 2019 due to the borrower not being able to
payoff the loan at its September 2019 maturity date. The servicer
reports that the borrower is in the process of refinancing the
loan. As of March 2019, the property's occupancy was 98% with the
actual DSCR at 3.65X. The other loan in special servicing is the
Duncan Center Loan ($9.1 million -- 0.9% of the pool), which is
secured by a 57,468 SF office property located in Dover, DE. The
loan was transferred to special servicing in October 2019 for
imminent default and it is currently in the foreclosure process.

Moody's has also assumed a high default probability for two poorly
performing loans, constituting 1.7% of the pool, and has estimated
an aggregate loss of $8.3 million (a 31% expected loss) from these
troubled loans and specially serviced loans.

Moody's received full year 2018 operating results for 100% of the
pool, and partial year 2019 operating results for 98% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 111%, compared to 109% 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 9.3%.

Moody's actual and stressed conduit DSCRs are 1.60X and 0.95X,
respectively, compared to 1.60X and 0.97X 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 27.3% of the pool balance.
The largest loan is the 17 State Street Loan ($105.0 million --
10.0% of the pool), which represents a pari passu portion of a $180
million senior mortgage loan. The property is also encumbered with
$40 million of mezzanine financing held outside the trust. The loan
is secured by a 42-story, Class-A office tower located in downtown
New York City. The tower contains 560,210 SF of net rentable area
and floor-to-ceiling windows overlooking both Battery Park and the
New York Harbor. As of September 2019, the property was 92% leased,
compared to 85% as of June 2018, and 79% at year-end 2017. Overall,
performance has declined slightly due to higher expenses. The loan
is interest only for the entire 10-year term. Moody's LTV and
stressed DSCR are 119% and 0.79X, the same as at the last review.

The second largest loan is the Columbus Square Portfolio Loan
($101.7 million -- 9.7% of the pool), which represents a pari passu
portion of a $392.0 million mortgage loan. The loan is secured by
five mixed-use buildings containing approximately 500,000 SF and
located on the Upper West Side in New York City. The property
contains 31 condominium units at 775, 795, 805, 808 Columbus Avenue
and 801 Amsterdam Avenue. The retail component, which contains
approximately 276,000 SF is anchored by a Whole Foods, TJ Maxx,
HomeGoods and Michaels. As of September 2019, the property was 99%
leased, compared to 98% in December 2018, and 96% in December 2017.
Performance has been stable since securitization. Moody's LTV and
stressed DSCR are 128% and 0.68X, respectively, compared to 130%
and 0.67X at the last review.

The third largest loan is the Grapevine Mills Loan ($80.0 million
-- 7.6% of the pool), which is secured by a 1.34 million SF
component of a 1.63 million SF super-regional mall located in
Grapevine, Texas. The loan represents a pari-passu portion of a
$268.0 million mortgage loan. The property is located approximately
10 miles north of Dallas/Fort Worth International Airport and
contains a mix of outlets, traditional retailers and entertainment
related venues. The largest tenants include Fieldhouse USA,
Burlington Coat Factory, and Round 1 Bowling. The property also
includes a 30-screen AMC Theatres. As of December 2018, the
property was 96% leased, compared to 95% as of December 2017, and
85% at securitization. For the year ending December 2018, in-line
sales per square foot for comparable stores less than 10,000 SF
were $411PSF, compared to $407PSF for the prior year. Property
performance has continued to improve since securitization due to
higher rental revenues. The loan is interest only for the entire
10-year term. Moody's LTV and stressed DSCR are 71% and 1.38X,
respectively.


MADISON PARK XXXVI: S&P Assigns BB- (sf) Rating to Class E Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Madison Park Funding
XXXVI Ltd./Madison Park Funding XXXVI LLC's fixed- and
floating-rate notes.

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

The ratings reflect S&P's view of:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  Madison Park Funding XXXVI Ltd./Madison Park Funding XXXVI LLC

  Class                 Rating          Amount
                                      (mil. $)
  A                     AAA (sf)        496.00
  B-1                   AA (sf)          66.95
  B-2                   AA (sf)          45.05
  C (deferrable)        A (sf)           48.00
  D (deferrable)        BBB- (sf)        48.00
  E (deferrable)        BB- (sf)         32.00
  Subordinated notes    NR               61.20

  NR--Not rated.


MCAP CMBS 2014-1: DBRS Places B Rating on Class G Certs
-------------------------------------------------------
DBRS Limited placed three classes of the Commercial Mortgage
Pass-Through Certificates, Series 2014-1 (the Certificates) issued
by MCAP CMBS Issuer Corporation, Series 2014-1 Under Review with
Negative Implications as follows:

-- Class E at BBB (low), Under Review with Negative Implications

-- Class F at BB (sf), Under Review with Negative Implications

-- Class G at B (sf), Under Review with Negative Implications

There is no trend for these rating actions. With the last
surveillance review, in March 2019, DBRS Morningstar maintained a
Negative trend for Class G, reflecting our concerns surrounding the
performance declines for two loans secured by office properties in
Calgary, Alberta.

DBRS Morningstar has taken these most recent rating actions because
of the concerns and uncertainty surrounding the 1121 Centre Street
NW loan (Prospectus ID#7, 23.2% of the pool) amid recent
developments with the loan sponsor, Strategic Group.

On December 11, 2019, Strategic Group, a Calgary, Alberta-based
real estate investment firm, submitted an initial application
filing under Canada's Companies' Creditors Arrangement Act (CCAA).
The filing impacts entities affiliated with 50 commercial
properties within the company's 171-property portfolio, including
the collateral property for the 1121 Centre Street NW loan in this
pool.

Although historic performance for the subject property has been
stable, recent developments suggest cash flows will decline in the
coming year, as the former second-largest tenant, BGC Engineering
Inc. (19.9% of the NRA), vacated the property in June 2018,
decreasing occupancy to 68.0%. The office market in Calgary
continues to exhibit prolonged vacancy rate spikes, reductions in
rental rates, and an overall lack of liquidity. Updated occupancy
and leasing information for the subject property has been requested
from the servicer.

Notes: All figures are in Canadian unless otherwise noted.


METROPOLITAN ASSET 2000-A: Moody's Cuts Cl. A-IO Debt Rating to Ca
------------------------------------------------------------------
Moody's Investors Service downgraded the rating of one tranche from
Metropolitan Asset Funding, Inc. Series 2000-A.

Complete rating actions are as follows:

Issuer: Metropolitan Asset Funding, Inc. Series 2000-A

Cl. A-IO*, Downgraded to Ca (sf); previously on Nov 29, 2017
Confirmed at Caa1 (sf)

*Reflects Interest Only Classes

RATINGS RATIONALE

The downgrade of the rating of Class A-IO reflects the rating
constraint on the IO bond to the highest current tranche rating on
bonds backed by the reference pool. The Class A-IO is a pool-linked
IO bond whose rating is subject to lowest of (i) the highest
current tranche rating on bonds that are outstanding backed by the
reference pool; or (ii) the rating corresponding to the pool's
expected loss; or (iii) the rating corresponding to the pool's
realized losses. The recent paydown of Class M1 in the November
2019 distribution report has subjected the Class A-IO to a highest
current tranche rating of Ca (sf).

The methodologies used in this rating were "US RMBS Surveillance
Methodology" published in February 2019 and "Moody's Approach to
Rating Structured Finance Interest-Only (IO) Securities" published
in February 2019.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate
The unemployment rate fell to 3.5% 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.


MIDWEST FAMILY 2006A: S&P Affirms 'BB+' Rating on Class IV Bonds
----------------------------------------------------------------
S&P Global Ratings revised its outlook on Hunt Companies Inc.,
Texas' (Navy Midwest Housing privatization project) 2006A military
housing revenue bonds, issued for Midwest Family Housing LLC, Ill,
to positive from stable, and affirmed all of its ratings on the
bonds as follows:

-- 'A+'(sf) long-term rating and underlying rating (SPUR) on the
project's class I bonds;

-- 'A'(sf) long-term rating and SPUR on the project's class II
bonds;

-- 'BBB'(sf) long-term rating and SPUR on the project's class III
bonds; and

-- 'BB+'(sf) on the project's class IV bonds.

"We base the outlook revision on improved financial performance and
strong basic allowance for housing growth rates," said S&P Global
Ratings credit analyst Raymond Kim.

The ratings reflect S&P's opinion of the following strengths:

-- Very strong quality of the assets supporting the bonds,
including a revenue stream derived from the federally appropriated
basic allowance for housing (BAH), demonstrated demand for military
housing at the base, and the high quality of the real estate
collateral supporting the bonds;

-- Improvement in all-in debt service coverage (DSC) for all four
classes of debt to 1.32x total DSC as of fiscal 2018, the third
consecutive year of increased DSC at the project;

-- Strong BAH increases in 2018 and 2019; and

-- High military essentiality of the military installations in the
project.

The ratings reflect S&P's view of:

-- Vulnerable loss coverage for the class III and IV bonds, with a
loan-to-value (LTV) ratio of 81%; and

-- Reduction in scope of the project to 1,719 stabilized units.

The positive outlook on the class I, II, III, and IV bond ratings
reflects S&P's view of the project's improving financial
performance. The project's DSC has increased over the past three
years, and S&P projects further increases in DSC at the close of
2019. Continued improvement in the project's financial performance
could lead to positive rating action.

Should the project experience a significant decrease in occupancy
or rental income, or higher-than-expected increase in expenses,
weakening the project's net operating income (NOI), S&P could take
negative rating action.


NOMURA HOME 2006-WF1: Moody's Raises Class M-3 Debt Rating to Ba3
-----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of ten tranches and
downgraded the rating of three tranches from eight transactions,
backed Subprime and Alt-A loans, issued from 2003 to 2006.

Complete rating actions are as follows:

Issuer: Nomura Asset Acceptance Corporation, Alternative Loan
Trust, Series 2004-AP3

Cl. A-5A, Upgraded to Aaa (sf); previously on Jan 22, 2018 Upgraded
to Aa3 (sf)

Cl. A-5B, Upgraded to Aaa (sf); previously on Jan 22, 2018 Upgraded
to Aa3 (sf)

Cl. A-6, Upgraded to Aaa (sf); previously on Jan 22, 2018 Upgraded
to Aa2 (sf)

Underlying Rating: Upgraded to Aaa (sf); previously on Jan 22, 2018
Upgraded to Aa2 (sf)

Financial Guarantor: Ambac Assurance Corporation (Segregated
Account - Unrated)

Issuer: Nomura Home Equity Loan Trust 2006-WF1

Cl. M-2, Upgraded to A2 (sf); previously on Apr 9, 2018 Upgraded to
Baa1 (sf)

Cl. M-3, Upgraded to Ba3 (sf); previously on Apr 9, 2018 Upgraded
to B2 (sf)

Issuer: Aegis Asset Backed Securities Trust 2003-3

Cl. M1, Downgraded to A3 (sf); previously on Mar 5, 2013 Downgraded
to A1 (sf)

Issuer: Ameriquest Mortgage Securities Inc., Series 2004-R2

Cl. M-4, Downgraded to B1 (sf); previously on Jan 13, 2017 Upgraded
to Ba3 (sf)

Issuer: Argent Securities Trust 2006-W1

Cl. A-1, Upgraded to A1 (sf); previously on Nov 20, 2018 Upgraded
to A3 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2006-HE8

Cl. II-1A-2, Upgraded to Aa1 (sf); previously on Sep 21, 2018
Upgraded to A1 (sf)

Cl. II-1A-3, Upgraded to Aa3 (sf); previously on Sep 21, 2018
Upgraded to A2 (sf)

Cl. II-2A, Upgraded to Aaa (sf); previously on Sep 21, 2018
Upgraded to Aa1 (sf)

Issuer: Chase Funding Trust, Series 2003-4

Cl. IIM-1, Upgraded to Ba1 (sf); previously on Oct 21, 2013
Upgraded to Ba3 (sf)

Issuer: Chase Funding Trust, Series 2003-5

Cl. IIM-1, Downgraded to Caa1 (sf); previously on Dec 28, 2017
Upgraded to B2 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance and Moody's
updated loss expectations on the underlying pools. The rating
upgrades are a result of improving performance of the related pools
and/or an increase in credit enhancement available to the bonds.
The rating downgrades are due to weaker performance of the
underlying collateral and/or the erosion of credit enhancement
available to the bonds. Class M-4 from Ameriquest Mortgage
Securities Inc., Series 2004-R2 is downgraded due to outstanding
interest shortfalls on the bond that are not expected to be
recouped as the bond has weak reimbursement mechanism for interest
shortfalls.

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.


NRMLT 2019-NQM2: DBRS Assigns B Rating on Class B-2 Notes
---------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage Backed-Notes
from NRMLT 2019-NQM2:

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (sf)
-- Class M-1 at BBB (sf)
-- Class B-1 at BB (sf)
-- Class B-2 at B (sf)

The above referenced securities are currently also rated by our
affiliated rating agency, Morningstar Credit Ratings, LLC (MCR). In
connection with the ongoing consolidation of DBRS Morningstar and
MCR, MCR previously announced that it had placed its outstanding
ratings of these securities Under Review–Analytical Integration
Review and that MCR intended to withdraw its outstanding ratings;
such withdrawal will occur on or about [January 2, 2020]. In
accordance with MCR's engagement letter covering these securities,
upon withdrawal of MCR's outstanding ratings, the DBRS Morningstar
ratings will become the successor ratings to the withdrawn MCR
ratings.

The NRMLT transaction is generally classified as a non-qualified
mortgage (non-QM) transaction.

DBRS Morningstar performed the following rating analysis on the
transaction:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for the transaction. DBRS Morningstar recalculated or
remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transaction were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for the transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


RCO 2017-INV1: DBRS Assigns B Rating on Class B-2 Notes
-------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage-Backed Notes
from RCO 2017-INV1:

-- Class A at AAA (sf)
-- Class M-1 at AA (low) (sf)
-- Class M-2 at A (low) (sf)
-- Class B-1 at BBB (low) (sf)
-- Class B-2 at B (sf)

The above referenced securities are currently also rated by our
affiliated rating agency, Morningstar Credit Ratings, LLC (MCR). In
connection with the ongoing consolidation of DBRS Morningstar and
MCR, MCR previously announced that it had placed its outstanding
ratings of these securities Under Review–Analytical Integration
Review and that MCR intended to withdraw its outstanding ratings;
such withdrawal will occur on or about [January 2, 2020]. In
accordance with MCR's engagement letter covering these securities,
upon withdrawal of MCR's outstanding ratings, the DBRS Morningstar
ratings will become the successor ratings to the withdrawn MCR
ratings.

The RCO transaction is generally classified as a non-qualified
mortgage (non-QM) transaction.

DBRS Morningstar performed the following rating analysis on the
transaction:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for the transaction. DBRS Morningstar recalculated or
remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transaction were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for the transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


RESIDENTIAL MORTGAGE 2019-1: DBRS Assigns B Rating on B-2 Notes
---------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage-Backed Notes
from two Residential Mortgage Loan Trust (RMLT) transactions:

RMLT 2019-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (sf)

RMLT 2019-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (sf)

The above referenced securities are currently also rated by our
affiliated rating agency, Morningstar Credit Ratings, LLC (MCR). In
connection with the ongoing consolidation of DBRS Morningstar and
MCR, MCR previously announced that it had placed its outstanding
ratings of these securities Under Review–Analytical Integration
Review and that MCR intended to withdraw its outstanding ratings;
such withdrawal will occur on or about [January 2, 2020]. In
accordance with MCR's engagement letter covering these securities,
upon withdrawal of MCR's outstanding ratings, the DBRS Morningstar
ratings will become the successor ratings to the withdrawn MCR
ratings.

These two RMLT transactions are generally classified as
non-qualified mortgage (non-QM) transactions.

DBRS Morningstar performed the following rating analysis on the
transactions:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,
cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for each of the transactions. DBRS Morningstar recalculated
or remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transactions were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for each transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


SEQUOIA MORTGAGE 2020-1: Fitch to Rate Cl. B-4 Debt BB-(EXP)sf
--------------------------------------------------------------
Fitch Ratings expects to rate the residential mortgage-backed
certificates issued by Sequoia Mortgage Trust 2020-1 as follows:

RATING ACTIONS

SEMT 2020-1

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Class A-IO-S; LT NR(EXP)sf;   Expected Rating

Class A-IO1;  LT AAA(EXP)sf;  Expected Rating

Class A-IO10; LT AAA(EXP)sf;  Expected Rating

Class A-IO11; LT AAA(EXP)sf;  Expected Rating

Class A-IO12; LT AAA(EXP)sf;  Expected Rating

Class A-IO13; LT AAA(EXP)sf;  Expected Rating

Class A-IO14; LT AAA(EXP)sf;  Expected Rating

Class A-IO15; LT AAA(EXP)sf;  Expected Rating

Class A-IO16; LT AAA(EXP)sf;  Expected Rating

Class A-IO17; LT AAA(EXP)sf;  Expected Rating

Class A-IO18; LT AAA(EXP)sf;  Expected Rating

Class A-IO19; LT AAA(EXP)sf;  Expected Rating

Class A-IO2;  LT AAA(EXP)sf;  Expected Rating

Class A-IO20; LT AAA(EXP)sf;  Expected Rating

Class A-IO21; LT AAA(EXP)sf;  Expected Rating

Class A-IO22; LT AAA(EXP)sf;  Expected Rating

Class A-IO23; LT AAA(EXP)sf;  Expected Rating

Class A-IO24; LT AAA(EXP)sf;  Expected Rating

Class A-IO25; LT AAA(EXP)sf;  Expected Rating

Class A-IO3;  LT AAA(EXP)sf;  Expected Rating

Class A-IO4;  LT AAA(EXP)sf;  Expected Rating

Class A-IO5;  LT AAA(EXP)sf;  Expected Rating

Class A-IO6;  LT AAA(EXP)sf;  Expected Rating

Class A-IO7;  LT AAA(EXP)sf;  Expected Rating

Class A-IO8;  LT AAA(EXP)sf;  Expected Rating

Class A-IO9;  LT AAA(EXP)sf;  Expected Rating

Class AIO26;  LT AAA(EXP)sf;  Expected Rating

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

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

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

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

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

TRANSACTION SUMMARY

Fitch Ratings expects to rate the residential mortgage-backed
certificates issued by Sequoia Mortgage Trust 2020-1 as indicated.
The certificates are supported by 742 loans with a total balance of
approximately $459.28 million as of the cutoff date. The pool
consists of prime fixed-rate mortgages acquired by Redwood
Residential Acquisition Corp from various mortgage originators.
Distributions of principal and interest and loss allocations are
based on a senior-subordinate, shifting-interest structure.

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The pool consists of very
high-quality 30-year, 25-year and 20-year fixed-rate fully
amortizing loans to borrowers with strong credit profiles,
relatively low leverage, and large liquid reserves. The pool has a
weighted average (WA) original model FICO score of 773 and an
original WA CLTV ratio of 71%. All of the loans in the pool consist
of Safe Harbor Qualified Mortgages (SHQM) or were originated prior
to the implementation of the rule.

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

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

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

Third-Party Due Diligence Results (Positive): Third-party due
diligence was performed on more than 98% of loans in the
transaction. Due diligence was performed by Clayton and Opus, which
are assessed by Fitch as 'Acceptable - Tier 1' and 'Acceptable -
Tier 2', respectively. The review scope is consistent with Fitch
criteria, and the results are generally better than prior RMBS
issued by Redwood, as the majority of the loans were originated
prior to the implementation of TRID.

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

CE Floor (Positive): To mitigate tail risk, which arises as the
pool seasons and fewer loans are outstanding, a subordination floor
of .75% of the original balance will be maintained for the
certificates. The floor is more than sufficient to protect against
the five largest loans defaulting at Fitch's 'AAAsf' average loss
severity of 37.10%.

RATING SENSITIVITIES

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

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10%, 20% and 30%, in addition to the
model-projected 5.2%. As shown in the table included in the presale
report, the analysis indicates that some potential rating migration
exists with higher MVDs compared with the model projection.

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

CRITERIA VARIATION

The analysis included one criteria variation from the "U.S. RMBS
Rating Criteria." The updated tax and lien search did not include a
search for potential delinquent HOA or municipal liens. At the time
of securitization (for every deal), Redwood instructs the servicer
to send notices to each HOA organization with a request that the
HOA notify the servicer in the event of any default, filing, or
legal proceeding and should be notified of any issues that arise.
As for municipal liens, if there are any legal proceedings as a
result of a municipal lien, the servicer will be notified.
Additionally, given the very high credit quality, the strong
performance history and the increase of the proposed losses above
the model output losses the incremental risk to the transaction is
immaterial and there was no impact to the transaction.

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

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


SPRUCE HILL 2019-SH1: DBRS Assigns B Rating on Class B-2 Notes
--------------------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage-Backed Notes
from Spruce Hill Mortgage Loan Trust 2019-SH1:

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

The Spruce Hill transaction is generally classified as a
non-qualified mortgage (non-QM) transaction.

DBRS Morningstar performed the following rating analysis on the
transaction:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for the transaction. DBRS Morningstar recalculated or
remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transaction were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for the transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


STAR 2019-1: DBRS Assigns B Rating on Class B-2 Certs
-----------------------------------------------------
DBRS, Inc. assigned ratings to the following Mortgage Pass-Through
Certificates from STAR 2019-1:

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (sf)
-- Class B-1 at BB (sf)
-- Class B-2 at B (sf)

The above referenced securities are currently also rated by our
affiliated rating agency, Morningstar Credit Ratings, LLC (MCR). In
connection with the ongoing consolidation of DBRS Morningstar and
MCR, MCR previously announced that it had placed its outstanding
ratings of these securities Under Review–Analytical Integration
Review and that MCR intended to withdraw its outstanding ratings;
such withdrawal will occur on or about [January 2, 2020]. In
accordance with MCR's engagement letter covering these securities,
upon withdrawal of MCR's outstanding ratings, the DBRS Morningstar
ratings will become the successor ratings to the withdrawn MCR
ratings.

The Starwood transaction is generally classified as a non-qualified
mortgage (non-QM) transaction.

DBRS Morningstar performed the following rating analysis on the
transaction:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for the transaction. DBRS Morningstar recalculated or
remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transaction were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for the transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios


VERUS TRANSACTIONS 2017-2: DBRS Assigns BB(low) Rating on B3 Certs
------------------------------------------------------------------
DBRS, Inc. assigned ratings to the following mortgage pass-through
certificates from 12 Verus Securitization Trust (VERUS)
transactions:

VERUS 2017-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AA (high) (sf)
-- Class B-1 at AA (low) (sf)
-- Class B-2 at A (low) (sf)
-- Class B-3 at BBB (low) (sf)

VERUS 2017-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (sf)
-- Class B-1 at A (low) (sf)
-- Class B-2 at BBB (low) (sf)
-- Class B-3 at BB (low) (sf)

VERUS 2017-SG1

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AA (high) (sf)
-- Class B-1 at A (sf)
-- Class B-2 at BBB (high) (sf)
-- Class B-3 at BB (high) (sf)

VERUS 2018-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AA (high) (sf)
-- Class B-1 at BBB (high) (sf)
-- Class B-2 at BB (high) (sf)
-- Class B-3 at B (high) (sf)

VERUS 2018-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at AA (low) (sf)
-- Class B-1 at BBB (high) (sf)
-- Class B-2 at BB (low) (sf)
-- Class B-3 at B (high) (sf)

VERUS 2018-3

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (low) (sf)
-- Class B-1 at BB (low) (sf)
-- Class B-2 at B (sf)

VERUS 2018-INV2

-- Class A-1FX at AAA (sf)
-- Class A-1FL at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (high) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (high) (sf)

VERUS 2019-1

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (sf)
-- Class B-1 at BB (low) (sf)
-- Class B-2 at B (high) (sf)

VERUS 2019-2

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (sf)
-- Class M-1 at BBB (sf)
-- Class B-1 at BB (sf)
-- Class B-2 at B (sf)

VERUS 2019-3

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (high) (sf)
-- Class M-1 at BBB (low) (sf)
-- Class B-1 at BB (high) (sf)
-- Class B-2 at B (sf)

VERUS 2019-INV1

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (sf)
-- Class A-3 at A (sf)
-- Class M-1 at BBB (low) (sf)
-- Class B-1 at BB (low) (sf)
-- Class B-2 at B (sf)

VERUS 2019-INV2

-- Class A-1 at AAA (sf)
-- Class A-2 at AA (high) (sf)
-- Class A-3 at A (sf)
-- Class M-1 at BBB (low) (sf)
-- Class B-1 at BB (low) (sf)
-- Class B-2 at B (sf)

The above-referenced securities are currently also rated by DBRS
Morningstar's affiliated rating agency, Morningstar Credit Ratings,
LLC (MCR). In connection with the ongoing consolidation of DBRS
Morningstar and MCR, MCR previously announced that it had placed
its outstanding ratings of these securities Under
Review–Analytical Integration Review and that MCR intended to
withdraw its outstanding ratings; such withdrawal will occur on or
about January 2, 2020. In accordance with MCR's engagement letter
covering these securities, upon withdrawal of MCR's outstanding
ratings, the DBRS Morningstar ratings will become the successor
ratings to the withdrawn MCR ratings.

These 12 VERUS transactions are generally classified as
non-qualified mortgage (non-QM) transactions.

DBRS Morningstar performed the following rating analysis on the
transactions:

-- Loan-level default probability, loss severity, and expected
     loss review;
-- Cash flow analysis incorporating prepayment, loss timing, and
     interest rate assumptions, to evaluate the form and
     sufficiency of available credit enhancement;
-- Third-party due diligence sample size review;
-- Representations and warranties framework review; and
-- Historical performance analysis as reflected in delinquencies,

     cumulative losses, and constant prepayment rates.

POOL EXPECTED LOSSES

DBRS Morningstar used its proprietary RMBS Insight 1.3 model to
derive probability of defaults, loss severities, and expected
losses for each of the transactions. DBRS Morningstar recalculated
or remapped certain collateral attributes in its analysis. Such
recalculations and remapping in the transactions were applied in a
consistent manner to how DBRS Morningstar would analyze similar
RMBS transactions. The probability of defaults, loss severities,
and expected losses for each transaction are generally stepped up
from the raw model results.

CASH FLOW ANALYSIS

A structural analysis that encompassed 12 cash flow stress
scenarios was performed, which focused on prepayment speeds, timing
of losses, and interest rate stresses. For transactions where the
servicer funds advances of delinquent principal and interest on any
mortgage for a limited period, DBRS Morningstar approximated
delinquency curves by front-loading its standard seasoned loss
timing vectors and assumes that the servicer will only advance for
delinquent mortgages up to that period. This results in principal
and interest collections being shut off as soon as loans reach
certain months of delinquency until they are liquidated.
Additionally, weighted-average coupon deterioration stresses were
incorporated in the cash flow scenarios.


WFRBS COMMERCIAL 2014-LC14: Fitch Affirms Class E Certs at BBsf
---------------------------------------------------------------
Fitch Ratings affirmed 15 classes of WFRBS Commercial Mortgage
Trust 2014-LC14 commercial mortgage pass-through certificates.

RATING ACTIONS

WFRBS 2014-LC14

Class A-2 96221TAB3;   LT AAAsf Affirmed;  previously at AAAsf

Class A-3FL 96221TBC0; LT AAAsf Affirmed;  previously at AAAsf

Class A-3FX 96221TBE6; LT AAAsf Affirmed;  previously at AAAsf

Class A-4 96221TAD9;   LT AAAsf Affirmed;  previously at AAAsf

Class A-5 96221TAE7;   LT AAAsf Affirmed;  previously at AAAsf

Class A-S 96221TAG2;   LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 96221TAF4;  LT AAAsf Affirmed;  previously at AAAsf

Class B 96221TAK3;     LT AA-sf Affirmed;  previously at AA-sf

Class C 96221TAL1;     LT A-sf Affirmed;   previously at A-sf

Class D 96221TAQ0;     LT BBB-sf Affirmed; previously at BBB-sf

Class E 96221TAS6;     LT BBsf Affirmed;   previously at BBsf

Class F 96221TAU1;     LT CCCsf Affirmed;  previously at CCCsf

Class PEX 96221TAM9;   LT A-sf Affirmed;   previously at A-sf

Class X-A 96221TAH0;   LT AAAsf Affirmed;  previously at AAAsf

Class X-B 96221TAJ6;   LT BBB-sf Affirmed; previously at BBB-sf

KEY RATING DRIVERS

Stable Loss Expectations: The affirmations reflect the relatively
stable performance of the majority of the pool since the prior
rating action in January 2019. There are 11 Fitch Loans of Concern
(17.4% of the pool), including four specially serviced assets (6.5%
of the pool), which is consistent with the January 2019 rating
action.

Specially Serviced Assets: Four loans are specially serviced
(6.5%). The largest is the Williams Center Tower loan (4.4%), which
was transferred to special servicing in May 2018 for imminent
monetary default. The loan is secured by two office towers totaling
765,809 sf located within the Central Business District of Tulsa,
OK. The property was 78% physically occupied as of August 2019 with
a 1.45x NOI debt service coverage ratio (DSCR) at March 2019
compared to 1.05x NOI DSCR and 78% occupancy at YE 2018 and a 1.65x
NOI DSCR and occupancy of 92% at issuance. The loan has remained
current despite the drop in occupancy and declining cashflow. Bank
of Oklahoma gave notice of their intent to terminate the lease on
Dec. 31, 2019 and has paid a termination fee of $215,000.

The Westridge Apartments asset (0.9%) was transferred to special
servicing in June 2016 for imminent monetary default. The property
is a 96 unit multifamily property located in Williston, ND, which
sits on the Bakken shale formation and has been negatively affected
by the drop in oil production in the region. The asset is REO after
a deed in lieu of foreclosure closed in November 2017. The
property's occupancy declined to 65% at year-end (YE) 2015 and 63%
at YE 2016 from 100% at issuance and its NOI DSCR declined to 0.39x
at YE 2016 and 0.29x at YE 2017 from 1.91x at issuance. The
property manager has been replaced and occupancy has improved to
100% as of December 2019 and rental rates have increased from their
earlier lows while concessions were eliminated. NOI DSCR remains
low and was most recently reported at 0.36x as of March 2019 and
0.35x at YE 2018. The property is currently being marketed for
sale.

The Holiday Inn Express Houston West loan (0.8%) was transferred to
special servicing in August 2017 for imminent monetary default, but
remains current on loan payments as of December 2019. The property
is a 119 key hotel located in the West Energy Corridor of Houston,
TX. The hotel has been affected by declining demand in the Houston
market from the volatility in crude oil prices. As of June 2018,
the property had a TTM occupancy of 39% with an NOI DSCR of 0.13x
compared with 50% occupancy and 0.98x NOI DSCR at YE 2017. The loan
remains in default after the borrower executed of a new franchise
agreement without the lender's consent. The resolution strategy and
time frame are unknown at this time.

Fitch Loans of Concern: The largest non-specially serviced Fitch
Loan of Concern (FLOC) is Caruth Plaza (3.2%), secured by a 206,192
sf retail center located in Dallas, TX. The property had a
significant decline in occupancy to 67% as of YE 2017 from 98% at
issuance due to Sports Authority (28.2% NRA) filing for bankruptcy
and vacating in June 2016. The borrower has since divided the space
previously occupied by Sports Authority and has signed three new
tenants totaling 24% of the NRA. The property has minimal lease
rollover with 5.8% in 2019 and 2020. As of the September 2019 rent
roll, the property was 86% physically occupied with an NOI DSCR of
1.25x. If the property continues to stabilize it will no longer be
considered a FLOC.

West Side Mall (2.5%) is secured by a 420,434-sf retail power
center anchored by Lowe's and Price Chopper located in
Edwardsville, PA. The property was originally constructed in 1960
as an enclosed mall and has undergone significant renovation in the
decades since, converting to an open-air shopping center. Occupancy
as of June 2019 declined to 71% from 85% at issuance and NOI DSCR
declined to 0.92x from 1.43x at issuance.

Two additional FLOCs account for approximately 3.6% of the pool.
Arci Terra Portfolio is secured by 12 retail properties located in
eight different states with a combined 209,779 sf. The overall
occupancy declined to 75% as of September 2019 from 97% at
issuance, while NOI DSCR dropped to 1.33x from 1.78x at issuance.
Coral Walk is secured by a 102,612 sf retail center located in Cape
Coral, FL. Occupancy declined to 41% at YE 2017 from 94% at
issuance due to Sports Authority and Staples vacating in July 2016
and December 2017, respectively. Occupancy has increased to 80%
(not including temporary tenant Spirit Halloween in the old Staples
space) as of September 2019 as Burlington took over the Sports
Authority space and began paying rent in March 2018. NOI DSCR was
1.33x as of September 2019 and 1.25x as of YE 2018 compared with
1.64x at issuance.

Improved Credit Enhancement: As of the December 2019 distribution
date, the pool's aggregate principal balance had paid down by 21.2%
to $989.6 million from $1.26 billion at issuance and 64 of the
original 71 loans remain. At issuance, the pool was expected to
amortize by approximately 13.3% from cutoff balance to maturity
balance. The pool has only one remaining IO loan which is a full
term IO loan: The Outlet Collection Jersey Gardens (8.1%). The
current pool's loan maturity schedule is as follows: 8.1% (2020),
32% (2023) and 58.6% (2024). Twelve loans (12.9% of the current
pool balance) are defeased, compared with three loans (3.9%) at
Fitch's prior rating action.

RATING SENSITIVITIES

The Negative Rating Outlook remains on class E due to continued
concerns over the specially serviced assets, primarily the Williams
Center Towers and the larger FLOCs. Rating downgrades to this class
may occur if performance of these loans continues to decline.
Rating Outlooks for classes A-1 through D remain Stable due to the
stable performance of the majority of the remaining pool and
continued expected amortization and increased credit enhancement
since issuance due to paydown and defeasance. Rating upgrades may
occur with improved pool performance and additional paydown or
defeasance.

Deutsche Bank is the trustee for the transaction, and also serves
as the backup advancing agent. Fitch's Issuer Default Rating for
Deutsche Bank is currently 'BBB'/'F2'/Outlook Stable. Fitch relies
on the master servicer, Wells Fargo Bank, N.A., a division of Wells
Fargo & Company (A+/F1/Stable), which is currently the primary
advancing agent, as counterparty. Fitch provided ratings
confirmation on Jan. 24, 2018.


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

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

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

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

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

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

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

                            *********

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

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

Copyright 2020.  All rights reserved.  ISSN: 1520-9474.

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

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e-mail.  Additional e-mail subscriptions for members of the same
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are $25 each.  For subscription information, contact Peter A.
Chapman at 215-945-7000.

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