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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, May 24, 2020, Vol. 24, No. 144

                            Headlines

AMUR EQUIPMENT: DBRS Places 10 Tranches Under Review Negative
ANGEL OAK 2020-2: Fitch Rates Class B-2 Certs 'B(EXP)sf'
BEAR STEARNS 2007-PWR17: Fitch Affirms Csf Rating on Class D Certs
BX COMMERCIAL 2020-VIVA: Moody's Gives Ba2 Rating on Class E Certs
CD MORTGAGE 2016-CD1: Fitch Affirms Class X-E Certs at 'B-sf'

CITIGROUP COMMERCIAL 2006-C4: Moody's Cuts Class C Debt to B2
CITIGROUP COMMERCIAL 2015-GC33: Fitch Affirms B-sf on F Certs
COMM 2014-CCRE19: Fitch Affirms Class E Debt at 'BBsf'
CSMC TRUST 2018-RPL1: Fitch Assigns CCCsf Rating on 2 Tranches
CSMC TRUST 2018-RPL6: Fitch Gives B-sf Rating on 2 Tranches

CSMC TRUST 2019-RPL11: Fitch Gives CCC Rating on 4 Tranches
CSMC TRUST 2019-RPL7: Fitch Gives B-sf Rating on 2 Tranches
DEUTSCHE BANK 2011-LC3: Fitch Cuts Class F Certs to 'CCCsf'
ECAF I LTD: Fitch Cuts Class B-1 Notes to 'BBsf'
FIRST REPUBLIC 2020-1: Fitch Rates Class B5 Debt 'B+(EXP)sf'

FLAGSHIP CREDIT 2020-2: DBRS Gives Prov. BB Rating on Cl. E Notes
GS MORTGAGE 2020-GC47: Fitch Rates 2 Tranches 'B-sf'
GS MORTGAGE-BACKED 2020-PJ3: Fitch Rates Class B-5 Certs 'B(EXP)'
HOMEWARD OPPORTUNITIES 2020-1: DBRS Finalizes B Rating on B2 Notes
IMSCI 2013-4: Fitch Cuts Rating on 2 Tranches to CCsf

JP MORGAN 2010-C1: Fitch Affirms D Ratings on 4 Tranches
JPMCC COMMERCIAL 2017-JP7: Fitch Affirms Cl. G-RR Certs at Bsf
LB-UBS COMMERCIAL 2005-C3: Moody's Cuts Class H Debt Rating to C
MORGAN STANLEY 2014-C16: Fitch Affirms CCC Rating on Class D Debt
MSBAM 2013-C11: Fitch Affirms Bsf Rating on Class F Debt

NATIONAL COLLEGIATE 2005-1: Fitch Cuts Class C Notes Rating to Dsf
ORANGE LAKE 2019-A: Fitch Puts BB on Class D Notes on Watch Neg.
PACKERS HOLDINGS: Fitch Affirms B- LongTerm IDR, Outlook Stable
PFP LTD 2019-5: DBRS Confirms B(low) Rating on Class G Notes
READY CAPITAL 2019-FL3: DBRS Confirms B(low) Rating on Cl. F Notes

SAPPHIRE AVIATION 1: Fitch Cuts Rating on Class C Notes to 'Bsf'
SAXON ASSET 2007-4: Moody's Cuts Class A-2 Debt to Caa1
SDART 2018-5: Fitch Affirms BB Rating on Class E1 Notes
VERUS SECURITIZATION 2020-2: Fitch Rates Class B-2 Certs 'B(EXP)'
WELLS FARGO 2012-LC5: Fitch Affirms Bsf Rating on Class F Certs

WELLS FARGO 2016-C35: Fitch Affirms Class F Certs at 'Bsf'
WELLS FARGO 2017-C38: Fitch Affirms Class F Certs at 'B-sf'
WELLS FARGO 2018-C45: Fitch Affirms B-sf Rating on Cl. H-RR Certs
WFCM 2020-C56: Fitch to Rate $7.3MM Class J-RR Certs 'B-sf'
[*] Fitch Alters Outlook on 53 Tranches From 24 CMBS Deals to Neg.

[*] Fitch Takes Action on 48 Tranches From 6 Trust Preferred CDOs

                            *********

AMUR EQUIPMENT: DBRS Places 10 Tranches Under Review Negative
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DBRS, Inc. placed the following 10 classes of securities issued by
Amur Equipment Finance Receivables V LLC, Amur Equipment Finance
Receivables VI LLC, and Amur Equipment Finance Receivables VII LLC
Under Review with Negative Implications:

-- Amur Equipment Finance Receivables V LLC, Series 2018-1,
     Class F Notes
-- Amur Equipment Finance Receivables VI LLC, Series 2018-2,
     Class C Notes
-- Amur Equipment Finance Receivables VI LLC, Series 2018-2,
     Class D Notes
-- Amur Equipment Finance Receivables VI LLC, Series 2018-2,
     Class E Notes
-- Amur Equipment Finance Receivables VI LLC, Series 2018-2,
     Class F Notes
-- Amur Equipment Finance Receivables VII LLC, Series 2019-1,
     Class B Notes
-- Amur Equipment Finance Receivables VII LLC, Series 2019-1,
     Class C Notes
-- Amur Equipment Finance Receivables VII LLC, Series 2019-1,
     Class D Notes
-- Amur Equipment Finance Receivables VII LLC, Series 2019-1,
     Class E Notes
-- Amur Equipment Finance Receivables VII LLC, Series 2019-1,
     Class F Notes

The Ratings are:

Amur Equipment Finance Receivables V LLC, Series 2018-1

  Class F Notes      UR-Neg.         Bsf

Amur Equipment Finance Receivables VI LLC, Series 2018-2

  Class C Notes      UR-Neg.         Asf
  Class D Notes      UR-Neg.         BBBsf
  Class E Notes      UR-Neg.         BBsf
  Class F Notes      UR-Neg.         Bsf

Amur Equipment Finance Receivables VII LLC, Series 2019-1

  Class B Notes      UR-Neg.         AAsf
  Class C Notes      UR-Neg.         Asf
  Class D Notes      UR-Neg.         BBBsf
  Class E Notes      UR-Neg.         BBsf
  Class F Notes      UR-Neg.         Bsf

Due to the widespread shutdown of economic activity throughout the
U.S. because of the Coronavirus Disease (COVID-19) pandemic,
significant stress on domestic businesses is expected to continue
during the next several months. Consequently, DBRS Morningstar
expects the performance of collateral securing the notes listed
above to be adversely affected. In addition to the expected stress
from the coronavirus pandemic, DBRS Morningstar's rating actions
take into account the respective transactions' performance to date
(based on April 15, 2020 remittance reports), which has been
negatively affected by the downturn in the trucking industry
throughout 2019 that began in the fourth quarter of 2018.

The rating actions by DBRS Morningstar are based on the following
analytical considerations:

-- The updated loss expectation for each transaction by DBRS
Morningstar considers how the transactions' performance has been
affected to date by the last year's downturn in trucking industry
as well as the impact of the coronavirus pandemic.

-- DBRS Morningstar's assessment as to how collateral performance
could deteriorate due to macroeconomic stresses brought about by
the coronavirus pandemic. As the pandemic spreads and its
consequences unfold, it is difficult to anticipate the ultimate
impact on the variables that drive credit quality. In the context
of this highly uncertain environment and in the interest of
transparency, we released a set of forward-looking macroeconomic
scenarios for select economies related to the coronavirus in a
commentary titled "Global Macroeconomic Scenarios: Implications for
Credit Ratings" on April 16, 2020. The moderate and the adverse
scenarios are being used in the context of DBRS Morningstar's
rating analysis, with the moderate scenario serving as the primary
anchor for current ratings and the adverse scenario serving as a
benchmark for sensitivity analysis.

-- DBRS Morningstar's moderate scenario assumes some success in
containment within Q2 2020 and a gradual relaxation of
restrictions, enabling most economies to begin a gradual economic
recovery in Q3 2020. This moderate scenario primarily considers two
economic measures: declining gross domestic product (GDP) growth
and increased unemployment levels for the year. For commercial
asset classes, the GDP growth rate is intended to provide the basis
for measurement of performance expectations.

-- There have been material changes in Amur Equipment Finance,
Inc.'s (AEF) origination strategies, underwriting framework,
financed asset mix, and access to liquidity since the Great
Recession of 2008–09, which DBRS Morningstar considered in
assessing the additional economic stress related to the coronavirus
pandemic. DBRS Morningstar also views these factors as potentially
mitigating some of the impact of recessionary conditions stemming
from the coronavirus pandemic.

-- The potential impact of the U.S. government stimulus programs
provided to businesses that are expected to benefit businesses by
softening the impact of the coronavirus pandemic. The programs are
intended to enable companies to retain employees to promote an
efficient restart of operations and to use other available
liquidity to support nonpayroll business needs.

-- The relative benefit from obligor and geographic
diversification of collateral pools.

-- Current level of available credit enhancement in each
transaction.

-- The information provided to DBRS Morningstar by AEF with
respect to the current market conditions and the impact of
coronavirus outbreak on origination, underwriting, operations, and
portfolio performance to date.

When a rating is placed Under Review with Negative Implications,
DBRS Morningstar seeks to complete its assessment and remove the
rating from this status as soon as appropriate. Upon the resolution
of the Under Review status, DBRS Morningstar may confirm or
downgrade the ratings on the affected classes.


ANGEL OAK 2020-2: Fitch Rates Class B-2 Certs 'B(EXP)sf'
--------------------------------------------------------
Fitch Ratings has assigned expected ratings to the residential
mortgage-backed certificates issued by Angel Oak Mortgage Trust
2020-2.

AOMT 2020-2

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

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

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

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

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

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

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

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

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

TRANSACTION SUMMARY

Fitch has assigned expected ratings to the residential
mortgage-backed certificates to be issued by Angel Oak Mortgage
Trust 2020-2. The certificates are supported by 827 loans with a
balance of $345.95 million as of the cutoff date. This will be the
eighth Fitch-rated transaction consisting of loans majority
originated by several Angel Oak-affiliated entities (collectively,
Angel Oak).

The certificates are secured mainly by nonqualified mortgages as
defined by the Ability to Repay rule. 85.3% of the loans were
originated by several Angel Oak entities, which include Angel Oak
Mortgage Solutions LLC (AOMS; 76.4%), Angel Oak Home Loans LLC
(AOHL; 7.6%) and Angel Oak Prime Bridge LLC (AOPB; 0.2%). The
remaining 15.9% of the loans were originated third-party
originators. 81.1% of the pool is designated as Non-QM, 0.1% as a
higher priced QM, and the remaining 18.8% is not subject to ATR.

KEY RATING DRIVERS

Revised GDP Due to Coronavirus: Coronavirus and the resulting
containment efforts have resulted in revisions to Fitch's GDP
estimates for 2020. Its baseline global economic outlook for U.S.
GDP growth is currently a 5.6% decline for 2020, down from 1.7% for
2019. Fitch's downside scenario would see an even larger decline in
output in 2020 and a weaker recovery in 2021. To account for
declining macroeconomic conditions resulting from the coronavirus,
an Economic Risk Factor floor of 2.0 (the ERF is a default variable
in the U.S. RMBS loan loss model) was applied to 'BBBsf' and
below.

Expected Payment Deferrals Related to Coronavirus (Negative): The
outbreak of the coronavirus and widespread containment efforts in
the U.S. will result in increased unemployment and cash flow
disruptions. To account for the cash flow disruptions, Fitch
assumed deferred payments on a minimum of 30% of the pool for the
first six months of the transaction at all rating categories with a
reversion to its standard delinquency and liquidation timing curve
by month 10. This assumption is based on observations of legacy
Alt-A delinquencies and past due payments following Hurricane Maria
in Puerto Rico. The cash flows on the certificates will not be
disrupted for the first six months due to principal and interest
advancing on delinquent loans by the servicer; however, after month
six the lowest ranked classes may be vulnerable to temporary
interest shortfalls to the extent there is not enough funds
available once the more senior bonds are paid.

Stop Advance Structure (Mixed): The transaction has a stop advance
feature where the servicer will advance delinquent P&I up to 180
days. While the limited advancing of delinquent P&I benefits the
pool's projected loss severity, it reduces liquidity. To account
for the reduced liquidity of a limited advancing structure,
principal collections are available to pay timely interest to the
'AAAsf', 'AAsf' and 'Asf' rated bonds. Fitch expects 'AAAsf' and
'AAsf' rated bonds to receive timely payments of interest and all
other bonds to receive ultimate interest.

The servicer, Select Portfolio Servicing, will provide P&I
advancing on delinquent loans. If SPS is not able to advance, the
master servicer will advance P&I on the certificates.

Payment Forbearance (Mixed): Roughly 26% (197 loans) of the
borrowers are on a coronavirus forbearance plan. Angel Oak is
offering borrowers a three-month payment forbearance plan.
Beginning in month four, the borrower can opt to reinstate (i.e.
repay the three missed mortgage payments in a lump sum) or repay
the missed amounts with a repayment plan. If reinstatement or a
repayment plan is not affordable, the missed payments will be added
to the end of the loan term due at payoff or maturity as a deferred
principal. If the borrower does not become current under a
repayment plan or is not able to make payments under a deferral
plan, other loss mitigation options will be pursued.

The servicer will continue to advance during the forbearance
period. Recoveries of advances will be repaid either from
reinstated or repaid amounts from loans where borrowers are on a
repayment plan. For loans with deferrals of missed payments, the
servicer can recover advances from the principal portion of
collections, which may result in a mismatch between the loan
balance and certificate balance. While this may increase realized
losses, the 190bps of excess spread should be available to absorb
these amounts and reduce the potential for writedowns.

Expanded Prime Credit Quality (Mixed): The collateral consists of
30-year and 40-year mainly fixed-rate loans (6.1% of the loans are
adjustable rate); 10.9% of the loans are interest-only loans and
the remaining 89.2% are fully amortizing loans. The pool is
seasoned approximately eight months in aggregate (as determined by
Fitch). The borrowers in this pool have strong credit profiles with
a 725 weighted-average FICO and moderate leverage (77.9% sLTV). In
addition, the pool contains 54 loans over $1.0 million and the
largest is $2.69 million.

5.6% of the pool consists of borrowers with prior credit events in
the past seven years, and 0.5% of the pool was underwritten to
foreign nationals. The pool characteristics resemble recent
non-prime collateral, and, therefore, the pool was analyzed using
Fitch's non-prime model.

Bank Statement Loans Included (Negative): Approximately 61.0% (448
loans) were made to self-employed borrowers underwritten to a bank
statement program (20.8% to a 24-month bank statement program and
40.2% to a 12-month bank statement program) for verifying income in
accordance with either AOHL's or AOMS's guidelines, which is not
consistent with Appendix Q standards or Fitch's view of a full
documentation program. To reflect the additional risk, Fitch
increases the probability of default by 1.5x on the bank statement
loans.

High Investor Property Concentration (Negative): Approximately 19%
of the pool comprises investment properties. 7.9% were underwritten
using the borrower's credit profile, while 11.1% of which were
originated through the originators' investor cash flow program that
targets real estate investors qualified on a debt service coverage
ratio basis. The borrowers of the Non-DSCR investor properties in
the pool have strong credit profiles, with a WA FICO of 723 (as
calculated by Fitch) and an original CLTV of 76.3% and DSCR loans
have a WA FICO of 735 (as calculated by Fitch) and an original CLTV
of 65.2%. Fitch increased the PD by approximately 2.0x for the cash
flow ratio loans (relative to a traditional income documentation
investor loan) to account for the increased risk.

Geographic Concentration (Negative): Approximately 38% of the pool
is concentrated in California with relatively low MSA
concentration. The largest MSA concentration is in the Los Angeles
MSA (19.1%) followed by the Miami MSA (10.9%) and the San Diego MSA
(5.0%). The top three MSAs account for 34.9% of the pool. As a
result, there was a 9-basis point increase to the 'AAA' expected
loss to account for geographic concentration.

Modified Sequential Payment Structure (Neutral): The structure
distributes collected principal pro rata among the class A
certificates while shutting out the subordinate bonds from
principal until all four classes have been reduced to zero. To the
extent that either the cumulative loss trigger event or the
delinquency trigger event occurs in a given period, principal will
be distributed sequentially to the class A-1A, A-1B, A-2 and A-3
bonds until they are reduced to zero.

Low Operational Risk (Positive): Operational risk is well
controlled for in this transaction. Angel Oak employs robust
sourcing and underwriting processes and is assessed by Fitch as an
'Average' originator. Primary and master servicing functions will
be performed by Select Portfolio Servicing and Wells Fargo Bank, NA
(Wells Fargo), rated 'RPS1-'/Outlook Negative and 'RMS1-'/Outlook
Negative, respectively. Fitch's Long-Term Issuer Default Rating for
SPS's parent, Credit Suisse (USA) Inc., is 'A'/Outlook Positive, as
of June 12, 2019. The sponsor's retention of at least 5% of the
bonds helps ensure an alignment of interest between the issuer and
investors.

R&W Framework (Negative): Angel Oak Home Loans LLC, will be
providing loan-level representations and warranties to the loans in
the trust. If the entity is no longer an ongoing business concern,
it will assign to the trust its rights under the mortgage loan
purchase agreements with the originators, which include repurchase
remedies for R&W breaches. While the loan-level reps for this
transaction are substantially consistent with a Tier I framework,
the lack of an automatic review for loans other than those with ATR
realized loss and the nature of the prescriptive breach tests,
which limit the breach reviewers' ability to identify or respond to
issues not fully anticipated at closing, resulted in a Tier 2
framework. Fitch increased its loss expectations (159 bps at the
AAAsf rating category) to mitigate the limitations of the framework
and the non-investment-grade counterparty risk of the providers.

The number of unnecessary R&W breach reviews due to a loan going
delinquent due to coronavirus forbearance should be limited since
the R&W review trigger is based on the loan having a realized loss
and an ATR violation.

Due Diligence Review Results (Positive): Third-party due diligence
was performed on 100% of loans in the transaction by SitusAMC an
'Acceptable - Tier 1' third-party review firm. The results of the
review confirm strong origination practices with only a few
material exceptions. Exceptions on loans with 'B' grades either had
strong mitigating factors or were mostly accounted for in Fitch's
loan loss model. Fitch applied a credit for the high percentage of
loan level due diligence, which reduced the 'AAAsf' loss
expectation by 50bps.

RATING SENSITIVITIES

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper 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 that may be considered in
the surveillance of the transaction. Sensitivity analyses was
conducted at the state and national levels to assess the effect of
higher MVDs for the subject pool as well as lower MVDs, illustrated
by a gain in home prices.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

This defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level.

The analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to
the model-projected 4.6% at 'AAA'.

The analysis indicates that there is some potential rating
migration with higher MVDs for all rated classes, compared with the
model projection.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

This defined positive rating sensitivity analysis demonstrates how
the ratings would react to negative MVDs at the national level, or
in other words positive home price growth with no assumed
overvaluation.

The analysis assumes positive home price growth of 10.0%. Excluding
the senior classes which are already 'AAAsf', the analysis
indicates there is potential positive rating migration for all of
the rated classes.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in up and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Fitch has also added a Coronavirus Sensitivity Analysis that
contemplates a more severe and prolonged economic stress caused by
a re-emergence of infections in the major economies, before a slow
recovery begins in 2Q21. Under this severe scenario, Fitch expects
the ratings to be impacted by changes in its sustainable home price
model due to updates to the model's underlying economic data
inputs. Any long-term impact arising from coronavirus disruptions
on these economic inputs will likely affect both investment and
speculative grade ratings.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Third-party loan-level results were reviewed by Fitch for this
transaction. Where applicable, the due diligence firm, SitusAMC
examined 100% of the loan files in three areas: compliance review,
credit review and valuation review. AMC is assessed by Fitch as a
Tier 1 TPR firm.

The results of the reviews indicated an overall loan quality that
is in line with other prior transactions from the issuer and other
Fitch-rated nonprime transactions.

Approximately 33% or 276 loans were assigned a final credit grade
of 'B'. The credit exceptions graded 'B' were approved by the
originator or waived by Angel Oak due to the presence of
compensating factors.

Roughly 28% of the loans were graded 'B' for compliance exceptions.
The majority of these exceptions are either TRID related issues
that were corrected with subsequent documentation, no adjustments
were applied for the 'B' graded loans.

Form "ABS Due Diligence 15E" was reviewed and used as a part of the
rating for this transaction.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the pool. The third-party due diligence was
generally consistent with Fitch's "U.S. RMBS Rating Criteria." AMC
was engaged to perform the review. Loans reviewed under this
engagement were given compliance, credit and valuation grades, and
assigned initial grades for each subcategory. Minimal exceptions
and waivers were noted in the due diligence reports.

Fitch also utilized data files that were made available by the
issuer on its SEC Rule 17g-5 designated website. Fitch received
loan-level information based on the American Securitization Forum's
data layout format, and the data are considered to be
comprehensive. The ASF data tape layout was established with input
from various industry participants, including rating agencies,
issuers, originators, investors and others to produce an industry
standard for the pool-level data in support of the U.S. RMBS
securitization market. The data contained in the ASF layout data
tape were reviewed by the due diligence companies, and no material
discrepancies were noted.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


BEAR STEARNS 2007-PWR17: Fitch Affirms Csf Rating on Class D Certs
------------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of Bear Stearns Commercial
Mortgage Securities Trust, series 2007-PWR17 (BSCMSI 2007-PWR17)
commercial mortgage pass-through certificates.

RATING ACTIONS

Bear Stearns Commercial Mortgage Securities Trust 2007-PWR17

Class C 07388QAN9; LT CCCsf Affirmed; previously at CCCsf

Class D 07388QAQ2; LT Csf Affirmed;   previously at Csf

Class E 07388QAS8; LT Dsf Affirmed;   previously at Dsf

Class F 07388QAU3; LT Dsf Affirmed;   previously at Dsf

Class G 07388QAW9; LT Dsf Affirmed;   previously at Dsf

Class H 07388QAY5; LT Dsf Affirmed;   previously at Dsf

Class J 07388QBA6; LT Dsf Affirmed;   previously at Dsf

Class K 07388QBC2; LT Dsf Affirmed;   previously at Dsf

Class L 07388QBE8; LT Dsf Affirmed;   previously at Dsf

Class M 07388QBG3; LT Dsf Affirmed;   previously at Dsf

Class N 07388QBJ7; LT Dsf Affirmed;   previously at Dsf

Class O 07388QBL2; LT Dsf Affirmed;   previously at Dsf

Class P 07388QBN8; LT Dsf Affirmed;   previously at Dsf

Class Q 07388QBQ1; LT Dsf Affirmed;   previously at Dsf

KEY RATING DRIVERS

High Loss Expectations; Concentration of Specially Serviced
Loans/Assets: Fitch's overall loss expectations on the specially
serviced loans/REO assets remain high. Four loans totaling $51
million (75.2% of pool) are currently in special servicing and REO.
Fitch expects losses for these assets to be significant based on
the servicer's most recent values.

The largest specially serviced loan, City Center Englewood (48.6%),
is secured by a 218,076 sf retail center located in Englewood, CO,
six miles south of the Denver CBD. The loan transferred to special
servicing in June 2017 and is REO as of August 2018. Larger tenants
include Ross Dress for Less, 24 Hour Fitness, Office Depot and
Harbor Freight Tools. The center is part of the larger development,
including a 425-unit apartment complex and a Walmart and has been
identified in an Opportunity Zone. The trust's interest is
leasehold as the property is on a ground lease with the City of
Englewood. The ground lease, which began in 2000, is for 75 years
with no renewal options. The entire $4.2 million ground lease
payment for the 75-year term was pre-paid. The City of Englewood
would like to see this asset mostly demolished and replaced with a
mixed use project that focuses on density to include a significant
multifamily component, a large parking structure, ground floor
commercial and a hotel. Such a project would combine the subject
acreage with an adjacent city parcel of roughly the same size. The
property is not currently being marketed for sale.

Changes to Credit Enhancement: Since Fitch's last rating action,
the pool balance has been reduced by 24% from limited amortization
and the disposition of three loans with a $20.4 million balance at
disposition and a $10.3 million loss to the trust. As of the May
2020 distribution date, the pool's aggregate principal balance has
been reduced by 97.9% to $67.9 million from $3.26 billion at
issuance. There have been $277.4 million (8.5% of original pool
balance) in realized losses to date. Cumulative interest shortfalls
of $7.8 million are currently affecting classes C through S.

Pool Concentration: Only nine of the original 265 loans remain.
Retail and office properties located in secondary and tertiary
markets comprise 85% and 15% of the pool, respectively. Due to the
concentrated nature of the pool, Fitch performed a sensitivity
analysis that grouped the remaining loans based on the likelihood
of repayment and expected losses from the liquidation of specially
serviced loans and/or underperforming or overleveraged loans. Five
performing loans (24.9% of pool) are fully amortizing and secured
by single-tenant Rite Aid properties in tertiary markets in
Michigan with leases that expire in 2026 and 2027. The loans had an
ARD in June 2017 and have final maturity in June 2037.

Exposure to Coronavirus Pandemic: Retail properties, which account
for 85% of the pool, have exposure to the coronavirus pandemic and
will be challenged by a decline in shopping and property closures.
Retail properties include five single-tenant Rite Aid properties in
tertiary markets in Michigan and two REO properties. Fitch's
distressed ratings consider the potential for negative impact on
potential sales, refinance and workout strategies.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

A downgrade of class C to 'CCsf' or 'Csf' is considered possible if
expected losses on the specially serviced loans increase. A
downgrade of class D to 'Dsf' will incur when losses, which are
considered inevitable, are realized as REO assets are disposed.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Upgrades are currently not expected given the high concentration of
specially serviced REO assets, but are possible if valuations
improve significantly and losses are lower than currently
expected.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


BX COMMERCIAL 2020-VIVA: Moody's Gives Ba2 Rating on Class E Certs
------------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to two
classes of CMBS securities, issued by BX Commercial Mortgage Trust
2020-VIVA, Commercial Mortgage Pass-Through Certificates, Series
2020-VIVA:

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba2 (sf)

RATINGS RATIONALE

The certificates are collateralized by a single loan that is
collateralized (together with multiple related companion loans) by
a first lien commercial mortgage on the borrower's fee simple
interests in two properties, the MGM Grand Hotel and Casino and
Mandalay Bay Resort and Casino in Las Vegas, NV. Its ratings are
based on the credit quality of the loans and the strength of the
securitization structure.

The MGM Grand is a AAA Four-Diamond, full-service luxury resort and
casino property. It is the third largest hotel in the world,
situated on over 101.9 acres of land and consisting of 4,998
guestrooms. The guestroom mix includes 4,270 standard guestrooms,
554 suites, 88 luxury suites, 51 Skyloft Suites (excluding one
additional office unit), 30 Mansion Villas (lodging targeted for
high-end gamblers), and four entourage rooms associated with the
Mansion Villas. The hotel features approximately 177,268 SF of
casino space that houses 1,553 slot machines and 128 gaming tables,
numerous restaurants, approximately 748,325 SF of meeting space, an
approximately 23,000 SF spa, four swimming pools and approximately
41,800 SF of retail space featuring 31 retailers. The MGM Grand is
also home to multiple shows including Cirque du Soleil's "Ka", an
acrobatic theater production that has been in residence at the MGM
Grand since October 2004. The MGM Grand also has the David
Copperfield Theatre, Hakkasan Nightclub and the MGM Grand Garden
Arena, which has seating capacity of over 16,000 and hosts premier
concerts, award shows, sporting events including championship
boxing, and other special events.

The Mandalay Bay is a AAA Four-Diamond, full-service luxury resort
and casino property. It is the premier conference hotel in Las
Vegas with over 2.1 million SF of convention, ballroom, and meeting
space, making it the 5th largest event space in the United States.
Mandalay Bay is situated on over 124.1 acres of land and consists
of 4,750 guestrooms. Included in the Mandalay Bay are (i) a Four
Seasons Hotel with its own lobby, restaurants, pool, and spa, and
(ii) The Delano, which is an all-suite hotel tower within the
complex including its own spa, fitness center, lounge and
restaurants. Mandalay Bay features 152,159 SF of casino space that
houses over 1,232 slot machines and 71 gaming tables, numerous
restaurants, an approximately 30,000 SF spa, 10 swimming pools, and
approximately 54,000 SF of retail space featuring 41 retailers.
Mandalay Bay is home to Cirque du Solieil's Michael Jackson "One",
which has been in residence in a 1,805-seat showroom since 2013, a
12,000-seat special events arena, the House of Blues, and the Shark
Reef Aquarium. Additionally, Mandalay Bay's expansive pool and
beach area plays host to an array of evening open air concerts
during the pool season, a large wave pool, and Moorea, a
European-style "ultra" beach and Daylight Beach Club.

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

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

The whole loan first mortgage balance of $3,000,000,000 represents
a Moody's LTV of 79.6%. The Moody's First Mortgage Actual DSCR is
4.37X and Moody's First Mortgage Actual Stressed DSCR is 1.56X.

Moody's also grades properties on a scale of 0 to 5 (best to worst)
and considers those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. Each property received
a property quality grade of 1.75, however, the Four Season's within
the Mandalay Bay received a property quality grade of 1.50.

Positive features of the transaction include the asset quality,
recent refurbishments, location, strong sponsorship, and MGM
Resorts International's (Ba3, senior unsecured) guaranty.
Offsetting these strengths are property closures due to
coronavirus, property type volatility, lack of diversification, new
supply, dependence on tourism, and credit negative legal features.

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

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

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.

Its analysis has considered the effect of the coronavirus outbreak
on the US economy as well as the effects that the announced
government measures, put in place to contain the virus, will have
on the performance of commercial real estate.

The contraction in economic activity in the second quarter will be
severe and the overall recovery in the second half of the year will
be gradual. However, there are significant downside risks to its
forecasts in the event that the pandemic is not contained and
lockdowns have to be reinstated. As a result, the degree of
uncertainty around its forecasts is unusually high. Moody's regards
the coronavirus outbreak as a social risk under its ESG framework,
given the substantial implications for public health and safety.

Moody's also regards gaming as a social risk under its ESG
framework. High exposure to the gambling industry can subject some
CMBS to unfavorable ESG societal and governance trends, and this is
a material negative ratings consideration in combination with other
mitigating credit factors.

Younger generations spend less time playing casino-style games than
older generations, and gambling activities are increasingly
performed online. Additionally, while gambling remains a popular
expenditure, it is a highly discretionary segment of consumer
demand. A further risk relates to responsible marketing and
distribution, which can be a source of social responsibility
failings where companies continue to promote their products to
individuals already identified as problem gamblers.

While more prevalent outside the US, regulators have placed
restrictions on betting amounts and gambling locations in response
to pressure from lobby groups and local government desires to
promote social responsibility, which limits profitability and
increases compliance costs for gaming enterprises. Some US local
governments are increasing "sin" taxes related to the gaming
industry to compensate for reduced tax income.


CD MORTGAGE 2016-CD1: Fitch Affirms Class X-E Certs at 'B-sf'
-------------------------------------------------------------
Fitch has affirmed all classes of German America Capital Corp.'s CD
Mortgage Securities Trust 2016-CD1 commercial mortgage pass-through
certificates. Fitch has also revised the Rating Outlook for two
classes to Negative from Stable.

CD 2016-CD1

  - Class A-1 12514MAY1; LT AAAsf; Affirmed

  - Class A-2 12514MAZ8; LT AAAsf; Affirmed

  - Class A-3 12514MBB0; LT AAAsf; Affirmed

  - Class A-4 12514MBC8; LT AAAsf; Affirmed

  - Class A-M 12514MBE4; LT AAAsf; Affirmed

  - Class A-SB 12514MBA2; LT AAAsf; Affirmed

  - Class B 12514MBF1; LT AA-sf; Affirmed

  - Class C 12514MBG9; LT A-sf; Affirmed

  - Class D 12514MAL9; LT BBB-sf; Affirmed

  - Class E 12514MAN5; LT BB-sf; Affirmed

  - Class F 12514MAQ8; LT B-sf; Affirmed

  - Class X-A 12514MBD6; LT AAAsf; Affirmed

  - Class X-B 12514MAA3; LT A-sf; Affirmed

  - Class X-C 12514MAC9; LT BBB-sf; Affirmed

  - Class X-D 12514MAE5; LT BB-sf; Affirmed

  - Class X-E 12514MAG0; LT B-sf; Affirmed

KEY RATING DRIVERS

Increased Loss Expectations: Fitch's projected losses for these
certificates have increased since the last rating action and have
contributed to the Negative Outlooks. Expected losses are driven by
two loans in particular.

401 South State Street (2.2% of the pool) is the largest
contributor to projected losses and the fifteenth largest loan in
the pool. The collateral consists of 487,000 sf of office space
between two buildings located at 418 South Wabash and 401 South
State Streets in Chicago's South Loop submarket. The property was
previously 75% occupied by a single tenant, Robert Morris College.
The borrower recently informed the servicer that the tenant
defaulted on its lease and vacated ahead of the June 2024 lease
expiration. The tenant is no longer paying rent, and the borrower
is seeking legal action while simultaneously marketing the asset
for sale. Robert Morris College was recently purchased by
Chicago-based Roosevelt University, and its move-out appears to
coincide with the acquisition. The loan has missed the March and
April 2020 debt service payments, but has not yet transferred to
special servicing. A dark value analysis of the asset indicates
losses for this loan could be significant.

Kahana Retail (1.7% of the pool) is the second largest contributor
to projected losses and the eighteenth largest loan in the pool.
The asset is a neighborhood shopping center located in Lahaina, HI.
Performance has fluctuated since issuance, and in 2018, occupancy
dropped to 56%. While occupancy seems to have improved to 82% as of
December 2019, the loan's NOI debt service coverage remains low at
1.01x, compared to 1.17x at YE2018 and 1.32x at YE2017. The
borrower recently requested debt service relief and the loan is
currently in forbearance.

Coronavirus Exposure: The social and market disruption caused by
the effects of the coronavirus pandemic and related containment
measures have also contributed to the Negative Outlooks. Twelve
loans representing 27.9% of the pool have been flagged as Fitch
Loans of Concern, two of which were FLOCs at the time of the last
rating action. Two loans in the Top 15 representing 9.4% of the
pool are secured by regional outlet malls which are temporarily
closed. An additional seven loans (14.7% of the pool balance) have
requested forbearance terms and are not currently amortizing,
including two hotels and one mixed-use property in the Top 15. One
loan (0.8% of the pool) secured by a hotel transferred to special
servicing in May 2020 for imminent monetary default. Overall, the
retail and hotel concentration in the pool is 18.1% and 7.8%,
respectively.

Additional stresses were applied to three hotels and four retail
properties across the pool, in light of the recent coronavirus
outbreak.

Minimal Change to Credit Enhancement: As of the May 2020
distribution date, the pool's aggregate balance has been reduced by
2.9% to $683.1 million from $703.2 million at issuance. All 32 of
the original loans remain outstanding. Based on the loans'
scheduled maturity balances, the pool is expected to amortize 11.1%
during the term. Five loans (34.8% of the pool balance) are full
term, IO.

RATING SENSITIVITIES

The Outlooks on classes A-1 through D and the IO classes X-A
through X-C remain Stable. The Outlook on classes F and X-E were
already Negative following Fitch's bulk vintage review in May 2020.
The Outlook on classes E and X-D have been revised to Negative from
Stable.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Factors that lead to upgrades would include improved performance
coupled with pay down and/or defeasance.

An upgrade to class B would occur with continued pay down, but
would be limited as concentrations increase.

Upgrades of classes C and D would only occur with significant
improvement in credit enhancement and stabilization of the FLOCs.

Classes would not be upgraded above 'Asf' if there is likelihood
for interest shortfalls.

An upgrade to classes E and F is not likely unless performance of
the FLOCs improves and if performance of the remaining pool is
stable, and would not likely occur until later years in the
transaction assuming losses were minimal.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that lead to downgrades include an increase in pool level
losses from underperforming or specially serviced loans.

Downgrades to the classes rated 'AAAsf' are not considered likely
due to the position in the capital structure, but may occur at
'AAAsf' or 'AA-sf' should interest shortfalls occur.

Downgrades to classes C and D are possible should additional
defaults occur.

Downgrades to classes E and F are possible should the performance
of FLOCs decline further.

In addition to its baseline scenario, Fitch also envisions a
downside scenario where the health crisis is prolonged beyond 2021;
should this scenario play out, Fitch expects that a greater
percentage of classes may be assigned a Negative Rating Outlook or
those with Negative Outlooks will be downgraded one or more
categories.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


CITIGROUP COMMERCIAL 2006-C4: Moody's Cuts Class C Debt to B2
-------------------------------------------------------------
Moody's Investors Service has downgraded the rating on one class
and affirmed the ratings on two classes in Citigroup Commercial
Mortgage Trust 2006-C4 as follows:

  Cl. C, Downgraded to B2 (sf); previously on Oct 31, 2019
  Affirmed Ba1 (sf)

  Cl. D, Affirmed C (sf); previously on Oct 31, 2019 Downgraded
  to C (sf)

  Cl. E, Affirmed C (sf); previously on Oct 31, 2019 Affirmed
  C (sf)

RATINGS RATIONALE

The rating on the principal and interest Class C was downgraded due
to higher anticipated losses and ongoing interest shortfalls
concerns due to the high exposure to loans in specially servicing.
The three specially serviced loans make up 64% of the pool, are all
REO and secured by retail properties.

The ratings on two P&I classes, Class D and Class E, were affirmed
because the ratings are consistent with Moody's expected loss plus
realized losses. Class E has already experienced a 34% realized
loss as a result of previously liquidated loans.

Its analysis has considered the effect of the coronavirus outbreak
on the US economy as well as the effects that the announced
government measures, put in place to contain the virus, will have
on the performance of commercial real estate. Stress on commercial
real estate properties will be most directly stemming from declines
in hotel occupancies (particularly related to conference or other
group attendance) and declines in foot traffic and sales for
non-essential items at retail properties.

The contraction in economic activity in the second quarter will be
severe and the overall recovery in the second half of the year will
be gradual. However, there are significant downside risks to its
forecasts in the event that the pandemic is not contained and
lockdowns have to be reinstated. As a result, the degree of
uncertainty around its forecasts is unusually high. Moody's regards
the coronavirus outbreak as a social risk under its ESG framework,
given the substantial implications for public health and safety.

Moody's rating action reflects a base expected loss of 64.5% of the
current pooled balance, compared to 54.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 9.3% of the
original pooled balance, compared to 9.0% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 64% of the pool is in
special servicing. In this approach, Moody's determines a
probability of default for each specially serviced and troubled
loan that it expects will generate a loss and estimates a loss
given default based on a review of broker's opinions of value (if
available), other information from the special servicer, available
market data and Moody's internal data. The loss given default for
each loan also takes into consideration repayment of servicer
advances to date, estimated future advances and closing costs.
Translating the probability of default and loss given default into
an expected loss estimate, Moody's then applies the aggregate loss
from specially serviced to the most junior class(es) and the
recovery as a pay down of principal to the most senior class(es).

DEAL PERFORMANCE

As of the April 17, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 97% to $68.8 million
from $2.3 billion at securitization. The certificates are
collateralized by 10 mortgage loans. Two loans, constituting 14.7%
of the pool, have defeased and are secured by US government
securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 3, the same as at Moody's last review.

Three cross-collateralized loans, constituting 6.8% of the pool,
are on the master servicer's watchlist. The watchlist includes
loans that meet certain portfolio review guidelines established as
part of the CRE Finance Council monthly reporting package. As part
of Moody's ongoing monitoring of a transaction, the agency reviews
the watchlist to assess which loans have material issues that could
affect performance.

Twenty-nine loans have been liquidated from the pool, resulting in
an aggregate realized loss of $166.1 million (for an average loss
severity of 41.1%). Three loans, constituting 64% of the pool, are
currently in special servicing. The largest specially serviced loan
is the DuBois Mall Loan ($28.2 million -- 41.0% of the pool), which
is secured by an enclosed mall and outparcels totaling roughly
439,000 square feet. The property is located in DuBois,
Pennsylvania, approximately 100 miles northeast of Pittsburgh. The
mall is currently anchored by JC Penney, Big Lots, and Ross Dress
for Less. As of January 2020, the property was 70%, unchanged from
August 2019, and compared to 87% in December 2017. The decrease in
occupancy was a result of a prior anchor, Sears (approximately 14%
of net rentable area), vacating the property in 2019. The
property's performance has declined significantly since
securitization as a result of lower revenues and the property's
reported 2019 inline sales were less than $200 per square foot. The
loan was transferred to special servicing in May 2016 due to
maturity default and became real estate owned in May 2019.

The second largest specially serviced loan is the State &
Perryville Shopping Center Loan ($11.2 million -- 16.3% of the
pool), which is secured by a 110,725 SF retail shopping center
located in Rockford, Illinois, approximately 80 miles northwest of
Chicago. The largest tenant, Ashley Furniture, accounts for
approximately 45% of NRA and has a lease expiration in July 2021.
As of January 2020, the property was 48% occupied, unchanged from
2019 and January 2018. The high vacancy is due to a prior tenant,
Gordman's (approximately 55% of NRA), vacating the property
subsequent to filing bankruptcy. The servicer indicated there were
two tenants' prospects in negotiations to fill this vacancy,
however, discussions were suspended due to the coronavirus outbreak
uncertainty. The loan transferred to special servicing in April
2017 due to imminent default and became REO in February 2019.

The third largest specially serviced loan is the Highland Plaza
Loan ($4.5 million -- 6.5% of the pool), which is secured by an
anchored retail shopping center located in Highland, Indiana,
approximately 28 miles southeast of Chicago. As of January 2020,
the property was 44% occupied, compared to 48% in September 2019
and 62% in December 2017. The former largest tenant, World Gym, has
since vacated, which would reduce the occupancy to 16%. The special
servicer indicated that the property is expected to be put into
auction in 2020. The loan was previously modified in 2017 for a
maturity date extension and became REO in April 2019.

Moody's has estimated an aggregate loss of $43.5 million (a 99%
expected loss on average) from these specially serviced loans. As
of the April 2020 remittance statement cumulative interest
shortfalls were $11.7 million. Moody's anticipates interest
shortfalls will continue because of the exposure to specially
serviced loans and/or modified loans. Interest shortfalls are
caused by special servicing fees, including workout and liquidation
fees, appraisal entitlement reductions, loan modifications and
extraordinary trust expenses.

Moody's received full year 2018 operating results for 100% of the
pool, and full or partial year 2019 operating results for 100% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 115%, compared to 113% 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
reflects a weighted average haircut of 26% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 9.0%.

The top three conduit loans represent 21.5% of the pool balance.
The largest loan is the Walgreen's- Henderson, NV Loan ($6.4
million -- 9.4% of the pool), which is secured by a 14,490 SF
single-tenant retail building located in Henderson, Nevada. The
property is 100% leased by Walgreens through April 2079. The loan
has amortized 18% since securitization and has an anticipated
repayment date (ARD) in January 2021. Moody's LTV and stressed DSCR
are 105% and 0.87X, respectively.

The second largest exposure is the G4 Portfolio Loan ($4.7 million
-- 6.8% of the pool), which is cross-collateralized by three loans.
Each loan is secured by a single-tenant retail building totaling
66,460 SF located in Texas, Ohio and Michigan. One property is
leased by a United Supermarket and the two remaining properties are
leased by Advanced Auto Parts. The portfolio was placed on the
watchlist in November 2019 due to low average rents for the
Advanced Auto Parts loan resulting in a low DSCR. As of December
2019, the portfolio is 100% occupied, however, all three tenants
have upcoming lease expirations in July 2020 and August 2020. The
special servicer reported that United Supermarket has indicated
they intend to allow their lease to auto-renew an additional six
months. The loan has amortized 19% since securitization and has an
anticipated repayment date in February 2021. Moody's analysis
incorporated the near-term rollover concerns for the three
properties. Moody's LTV and stressed DSCR are 135% and 0.79X.

The third largest loan is the Walgreen's - Orange, CT loan ($3.7
million -- 5.3% of the pool), which is secured by a 14,820 SF
single-tenant retail building located in Orange, Connecticut. The
property is 100% leased by Walgreens through October 2080. The loan
has amortized 18% since securitization and has an ARD in January
2021. Moody's LTV and stressed DSCR are 108% and 0.88X,
respectively.


CITIGROUP COMMERCIAL 2015-GC33: Fitch Affirms B-sf on F Certs
-------------------------------------------------------------
Fitch Ratings has affirmed 13 classes of Citigroup Commercial
Mortgage Trust 2015-GC33 commercial mortgage pass-through
certificates and revised Class F's Outlook to Negative.

CGCMT 2015-GC33    

  - Class A-2 29425AAB9; LT AAAsf; Affirmed

  - Class A-3 29425AAC7; LT AAAsf; Affirmed

  - Class A-4 29425AAD5; LT AAAsf; Affirmed

  - Class A-AB 29425AAE3; LT AAAsf; Affirmed

  - Class A-S 29425AAF0; LT AAAsf; Affirmed

  - Class B 29425AAG8; LT AA-sf; Affirmed

  - Class C 29425AAH6; LT A-sf; Affirmed

  - Class D 29425AAJ2; LT BBB-sf; Affirmed

  - Class E 29425AAP8; LT BB-sf; Affirmed

  - Class F 29425AAR4; LT B-sf; Affirmed

  - Class PEZ 29425AAN3; LT A-sf; Affirmed

  - Class X-A 29425AAK9; LT AAAsf; Affirmed

  - Class X-D 29425AAM5; LT BBB-sf; Affirmed

Classes X-A and X-D are interest only.

KEY RATING DRIVERS

Stable Loss Expectations: The affirmations reflect the continued
stable performance of the majority of the pool. There are five
loans designated Fitch Loans of Concern (FLOCs, 3.3% of the pool).

Fitch Loans of Concern: The largest FLOC is secured by the Houston
Hotel Portfolio, a portfolio of two Texas limited service hotels
(1.4% of the pool). The overall portfolio servicer reported the net
operating income debt service coverage ratio declined to 1.14x for
YE 2019 from 2.20x for YE 2018. The Holiday Inn Express West Road
in Houston, TX has seen a sharp performance decline since 2017. Per
STR, the TTM December 2019 RevPAR was $57 compared with $72 as of
TTM December 2017; further, the servicer reported YE 2019 NOI DSCR
for this hotel was only 0.54x. The Hampton Inn Port Arthur is
reporting healthy cash flow again after suffering damage from
Hurricane Harvey that is now repaired. The YE 2019 servicer
reported NOI DSCR for this property was 2.06x. However, Port Arthur
is home to the largest oil refinery in the United States, and could
be negatively affected by the recent oil price decline.

No other FLOC comprises more than 0.7% of the pool.

Minimal Credit Enhancement Improvement: As of the May 2020
distribution date, the pool's aggregate principal balance was paid
down by only 4.1% to $918.7 million from $958.5 million at
issuance. One loan was pre-paid early in the amount of $10.5
million. Four loans (10%) are full-term interest only, while an
additional 11 loans (31.6%) remain in their partial interest only
periods. Three loans have defeased (5% of the pool). Only two loans
(1.6% of the pool in 2020) are scheduled to mature prior to 2025.

Coronavirus Effects: A significant economic impact on certain
hotels, retail and multifamily properties is expected from the
coronavirus pandemic due to the recent and sudden reductions in
travel and tourism; temporary property closures; and lack of
clarity at this time on the potential duration of the impact. The
pandemic has already prompted the closure of several hotel
properties in gateway cities along with malls, entertainment venues
and individual stores.

Loans secured by hotels constitute a significant portion of the
transaction collateral at 22.4% of the pool, while loans secured by
retail properties represent 22.8% of the pool. Loans secured by
multifamily properties compose only 7.6% of the pool with no
student or senior housing properties. Fitch applied additional
stresses to hotel, retail and multifamily loans to account for
potential cash flow disruptions due to the coronavirus pandemic.
The Negative Outlook on Class F reflects this analysis.

Additional Considerations

Above-Average Pool Concentration: The largest 10 loans account for
55.7% of the pool by balance.

Diverse Property Types: The pool has a diverse mix of property
types, with office as the largest at 27.6%, including three of the
top four loans in the pool. Overall, the office properties have a
diverse mix of geographic locations, including both CBD and
suburban markets.

RATING SENSITIVITIES

The Stable Outlooks on Classes A-2 through E, and interest only
Classes X-A and X-D, reflect the overall stable performance of the
majority of the pool.

The Negative Outlook on Class F reflects performance concerns with
hotel and retail properties due to the slowdown in economic
activity related to the coronavirus pandemic.

Factors That Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade:

Factors that lead to upgrades would include improved performance
coupled with pay down and/or defeasance. Classes would not be
upgraded above 'Asf' if there is likelihood for interest
shortfalls. An upgrade to Classes E and F is not likely until the
later years in a transaction and only if the performance of the
remaining pool is stable and/or properties vulnerable to the
coronavirus return to pre-pandemic levels, and there is sufficient
credit enhancement to the class.

Factors That Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade:

Factors that lead to downgrades include an increase in pool level
losses from underperforming or specially serviced loans. Downgrades
to the 'Asf', 'AAsf' and 'AAAsf' categories are not likely due to
the position in the capital structure but may occur at the 'AAsf'
and 'AAAsf' categories should interest shortfalls occur. Downgrades
to the 'BBB-' classes would occur should overall pool losses
increase and/or one or more large loans have an outsized loss,
which would erode credit enhancement. Downgrades to the 'BB-' or
'B-' classes would occur should loss expectations increase due to
an increase in specially serviced loans and/or the loans vulnerable
to the coronavirus pandemic do not stabilize.

In addition to its baseline scenario related to the coronavirus,
Fitch also envisions a downside scenario where the health crisis is
prolonged beyond 2021. Should this scenario play out, Fitch expects
that a greater percentage of classes may be assigned a Negative
Rating Outlook or those with Negative Rating Outlooks will be
downgraded one or more categories.

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

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


COMM 2014-CCRE19: Fitch Affirms Class E Debt at 'BBsf'
------------------------------------------------------
Fitch Ratings has affirmed eleven classes of COMM 2014-CCRE19
Mortgage Trust as follows:

COMM 2014-CCRE19      

  - Class A-4 12592GBC6; LT AAAsf; Affirmed

  - Class A-5 12592GBD4; LT AAAsf; Affirmed

  - Class A-M 12592GBF9; LT AAAsf; Affirmed

  - Class A-SB 12592GBB8; LT AAAsf; Affirmed

  - Class B 12592GBG7; LT AA-sf; Affirmed

  - Class C 12592GBJ1; LT A-sf; Affirmed

  - Class D 12592GAG8; LT BBB-sf; Affirmed

  - Class E 12592GAJ2; LT BBsf; Affirmed

  - Class PEZ 12592GBH5; LT A-sf; Affirmed

  - Class X-A 12592GBE2; LT AAAsf; Affirmed

  - Class X-B 12592GAA1; LT AA-sf; Affirmed

KEY RATING DRIVERS

Relatively Stable Performance: The majority of the pool has
exhibited relatively stable performance since issuance. Loss
expectations have increased due to performance deterioration of the
Fitch Loans of Concern and the slowdown in economic activity
related to the coronavirus pandemic. Fitch designated nine loans
(19.2% of pool) as FLOCs, including the largest loan (7.9%), the
third largest loan (6.2%) and two specially serviced loans (1.1%).

Fitch Loans of Concern: The largest loan, Bridgepoint Tower (7.9%),
which is secured by a 273,764 sf office property located in San
Diego, CA, was flagged as a FLOC due to the single tenant
indicating its intent to vacate the property. In April 2019,
Bridgepoint Education announced plans to relocate its headquarters
from the subject property to Chandler, AZ and change its name to
Zovio. The relocation began in Summer 2019, with plans to complete
the transition over the next 18-24 months. In May 2020, the
servicer confirmed Bridgepoint Education extended the lease for a
portion of space at the property (50,023 sf; 18.3% of NRA) through
Dec. 31, 2020, with an option to terminate on June 1st. The
original lease for the entire property expired in February 2020.
Although there has been interest for space at the property, the
borrower has halted all new leasing discussions due to the
coronavirus and related California state restrictions.

The third largest loan, Cipriani Manhattan Portfolio (6.2%), which
is secured by two commercial condominium interests located at 55
Wall Street (81,145 sf) and 110 East 42nd Street (71,308 sf) in
Manhattan, NY, was flagged as a FLOC due to a significant loss of
revenue from event cancellations due to the coronavirus pandemic.
Both properties are owner occupied and derive the majority of their
income from hosting banquets and events. Fitch is concerned with
the sponsor's ability to restart business operations after the
pandemic.

The specially-serviced Rozelle Crossing loan (0.7%), which is
secured by a 63,650 sf grocery anchored retail property located in
Charlotte, NC, will lose its grocery anchor, Bi-Lo (73.7% of NRA),
upon lease expiration in February 2022. Following Bi-Lo's
confirmation of plans to not renew its lease at the subject
property, as well as significant lease rollover in 2020 (9.7% of
NRA, including three of the top five tenants), the loan was unable
to be refinanced or sold at maturity and transferred to the special
servicer in August 2019. A receiver was appointed in December 2019.
Bi-Lo continues to make rental payments through its lease
expiration. Due to statewide closures related to the coronavirus,
several in-line tenants have requested rent reduction or deferral
beginning with the April payment. As of September 2019, occupancy
has remained flat at 97%, compared to 97% in 2018 and 96% in 2016.
The servicer-reported NOI DSCR was 1.67x as of September 2019,
compared to 1.59x in 2018 and 1.63x in 2017.

The specially-serviced Autumn Chase Apartments loan (0.4%), which
is secured by a 76-unit multifamily property located in Columbus,
OH, transferred to the special servicer in July 2019 for maturity
default. The borrower attributed the declining performance to
increased crime in the area and a new commuting policy at a nearby
hospital, both of which have contributed to tenants vacating. A
forbearance agreement was executed in November 2019 through March
6, 2020. A proposed sale of the property did not close; therefore,
the forbearance period was subsequently extended for an additional
four months to July 2020. Occupancy was 84% as of July 2019, up
from 76% in 2017 and 64% in 2016. The servicer-reported NOI DSCR
declined to 1.0x in 2019 from 1.34x in 2018, 1.79x in 2017 and
1.74x in 2016.

Five loans outside of the top 15 (combined, 4.1%) were flagged as
FLOCs for recent occupancy and/or cash flow declines.

Increased Credit Enhancement: Credit enhancement has increased
since issuance due to loan payoffs, scheduled amortization and
defeasance. As of the April 2020 distribution date, the pool's
aggregate principal balance has been reduced by 24.2% to $890.3
million from $1.17 billion at issuance. Realized losses to date
total 0.3% of the original pool balance and are fully attributed to
the Pheasant Ridge Apartments II loan, which was disposed in April
2018 with a $3 million loss. Eight loans (10.6% of pool) are fully
defeased. Three loans (9.5%) are full-term interest-only, and the
remaining 49 loans (90.5%) are amortizing. Scheduled loan
maturities include two loans (1.1%) in 2020, one loan (1.8%) in
2021 and 49 loans (97.1%) in 2024. Interest shortfalls are
currently impacting the non-rated class.

Coronavirus Exposure: Eleven loans (17.8% of pool), which have a
weighted average NOI DSCR of 2.04x, are secured by hotel
properties. Eleven loans (20%), which have a weighted average NOI
DSCR of 1.56x, are secured by retail properties. Fitch's analysis
applied additional stresses to eight hotel loans (13.8%) and five
retail loans (11.8%), as well as a potential outsize loss of 25% on
the Cipriani Manhattan Portfolio loan; these additional stresses
contributed to the Negative Outlook on class E.

RATING SENSITIVITIES

The Stable Outlooks on classes A-SB through D reflect the stable
pool performance, increased credit enhancement and expected
continued paydowns. The Negative Rating Outlook on class E reflects
performance concerns stemming from the coronavirus pandemic on cash
flow to the hotel and retail loans, as well as the Cipriani
Manhattan Portfolio loan, given the significant derivation of its
revenues related to hosting banquets and events.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Sensitivity factors that lead to upgrades include stable to
improved asset performance coupled with pay down and/or defeasance.
Upgrades of one category to the 'Asf' and 'AAsf' categories would
likely occur with significant improvement in credit enhancement
and/or defeasance; however, adverse selection and increased
concentrations and further underperformance of the FLOC or loans
expected to be negatively impacted by the coronavirus pandemic
could cause this trend to reverse. An upgrade of the 'BBBsf'
category is considered unlikely and would be limited based on
sensitivity to concentrations or the potential for future
concentration. If interest shortfalls become likely, the classes
would not be upgraded above 'Asf'. Upgrades of one category to the
'BBsf' category is not likely until the later years of the
transaction and only if the performance of the remaining pool is
stable and/or properties vulnerable to the coronavirus return to
pre-pandemic levels, and there is sufficient credit enhancement to
the class.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Sensitivity factors that lead to downgrades include an increase in
pool level losses from underperforming or specially serviced loans.
Downgrades to the 'Asf', 'AAsf' and 'AAAsf' categories are not
likely due to the position in the capital structure, but may occur
at the 'AAsf' and 'AAAsf' categories should interest shortfalls
occur. A downgrade of one category or more to the 'BBBsf' category
would occur if a high proportion of the pool defaults and expected
losses increase significantly. Downgrades of one category or more
to the 'BBsf' category would occur should loss expectations
increase and/or properties vulnerable to the coronavirus fail to
return to pre-pandemic levels. In addition to its baseline scenario
related to the coronavirus, Fitch also envisions a downside
scenario where the health crisis is prolonged beyond 2021; should
this scenario play out, Fitch expects negative rating actions are
likely, including Negative Outlook revisions or rating downgrades.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


CSMC TRUST 2018-RPL1: Fitch Assigns CCCsf Rating on 2 Tranches
--------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to CSMC 2018-RPL1 Trust:

RATING ACTIONS

CSMC 2018-RPL1

Class A-1; LT AAAsf; New Rating

Class A-2; LT Asf;   New Rating

Class A-3; LT CCCsf; New Rating

Class B-1; LT Asf;   New Rating

Class B-2; LT CCCsf; New Rating

Class B-3; LT NRsf;  New Rating

Class B-4; LT NRsf;  New Rating

Class B-5; LT NRsf;  New Rating

Class PT;  LT NRsf;  New Rating

TRANSACTION SUMMARY

CSMC 2018-RPL1 is supported by a pool of re-performing mortgage
loans (RPL). The transaction was originally issued in the first
half of 2018 and was not rated at deal close. In tandem with this
rating assignment, the transaction is being modified to 1) allow
principal collection to be redirected to cover any potential
interest shortfalls on the class A-1, 2) using interest payment
otherwise allocable to the class B-3 to fund an account that may be
used for potential repurchases and 3) adding certain constraints on
which institutions can act as an 'Eligible Account'.

KEY RATING DRIVERS

Revised GDP due to Coronavirus (Negative): The coronavirus pandemic
and the resulting containment efforts have resulted in revisions to
Fitch's GDP estimates for 2020. Fitch's baseline global economic
outlook for U.S. GDP growth is currently a 5.6% decline for 2020,
down from 1.7% for 2019. Fitch's downside scenario would see an
even larger decline in output in 2020 and a weaker recovery in
2021. Using the recession in 2008 and 2009 as a reference point,
the baseline GDP estimate growth is close to 4Q09 where GDP growth
turned positive ~ .50%. To account for declining macroeconomic
conditions resulting from the coronavirus, Fitch applied a 2.0x
floor to the Economic Risk Factor (ERF) default variable in its
loan loss model.

Expected Payment Deferrals Related to the Coronavirus Pandemic
(Negative): The outbreak of the coronavirus and widespread
containment efforts in the U.S. will result in increased
unemployment and cash flow disruptions. To account for the cash
flow disruptions, Fitch assumed deferred payments on a minimum of
40% of the pool for the first six months of the transaction at all
rating categories with a reversion to its standard delinquency and
liquidation timing curve by month 10. This assumption is based on
observations of legacy 'Alt-A' delinquencies and past due payments
following Hurricane Maria in Puerto Rico. The lowest rate classes
will likely experience interest shortfalls to the extent excess
cash flow is insufficient as the cash flow waterfall provides for
principal otherwise distributable to the lower rated bonds to pay
timely interest to the 'AAAsf' and 'AAsf' bonds.

RPL Credit Quality (Mixed): The collateral consists of 30-year FRM
and 5-year and 10-year ARM fully amortizing loans, seasoned
approximately 162 months in aggregate. The borrowers in this pool
have weaker credit profiles (675 FICO) and relatively high leverage
(99.3% sLTV). In addition, the pool contains no loans of
particularly large size. There are two loans over $1 million and
the largest is $1.1 million. 14.8% of the pool had a delinquency in
the past 24 months.

Geographic Concentration (Neutral): Approximately 25% of the pool
is concentrated in California with relatively low MSA
concentration. The largest MSA concentration is in New York MSA
(13.4%) followed by the Chicago MSA (8.4%) and the Miami MS (8.2%).
The top three MSAs account for 30% of the pool. As a result, there
was no adjustment for geographic concentration.

Transaction Structure (Positive): The transaction's cash flow is
based on a sequential-pay structure whereby the subordinate classes
do not receive principal until the senior classes are repaid in
full. Losses are allocated in reverse-sequential order.

No Servicer Advancing (Mixed): The servicers will not be advancing
delinquent monthly payments of principal and interest. Because P&I
advances made on behalf of loans that become delinquent and
eventually liquidate reduce liquidation proceeds to the trust, the
loan-level loss severities (LS) are less for this transaction than
for those where the servicer is obligated to advance P&I.

Low Operational Risk (Positive): Operational risk is well
controlled for in this transaction. Credit Suisse has an
established operating history acquiring single-family residential
loans. Select Portfolio Servicing (SPS) is the servicer for the
transaction and is rated 'RPS1'/Outlook Negative. The 'AAAsf'
rating category expected loss was reduced by 2.57% based on the
transaction parties. Issuer retention of at least 5% of the bonds
also helps ensure an alignment of interest between both the issuer
and investor.

R&W's Have Knowledge Qualifiers and Sunset Period (Negative): The
loan-level representations and warranties (R&Ws) are consistent
with a Tier 2 framework. The tier assessment is based primarily on
the inclusion of knowledge qualifiers in the underlying reps as
well as a breach reserve account that replaces the Sponsor's
responsibility to cure any R&W breaches following the established
sunset period. Fitch increased its loss expectations by 194 bps at
the 'AAAsf' rating category to reflect both the limitations of the
R&W framework as well as the non-investment-grade counterparty risk
of the provider.

Due Diligence Review Results (Negative): A third-party due
diligence review was performed on 100% of the loans in the
transaction pool. The review was performed by SitusAMC, which is
assessed by Fitch as an 'Acceptable - Tier 1' TPR firm. The due
diligence results indicate moderate operational risk with 7.8% of
loans receiving a final grade of 'C' or 'D'. This concentration of
material exceptions is similar to other Fitch-rated RPL RMBS,and
adjustments were applied to loans missing estimated final HUD-1.
These regulations are not subject to statute of limitations like
most compliance findings, which ultimately exposes the trust to
added assignee liability risk. Fitch adjusted its loss expectation
at the 'AAAsf' rating category by 28 bps to account for this added
risk.

RATING SENSITIVITIES

Fitch 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
that may be considered in the surveillance of the transaction.
Sensitivity analyses was conducted at the state and national levels
to assess the effect of higher MVDs for the subject pool as well as
lower MVDs, illustrated by a gain in home prices.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in up and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Factors That Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade:

This defined positive rating sensitivity analysis demonstrates how
the ratings would react to negative MVDs at the national level, or
in other words positive home price growth with no assumed
overvaluation. The analysis assumes positive home price growth of
10.0%. Excluding the senior class, which is already 'AAAsf', the
analysis indicates there is potential positive rating migration for
all of the rated classes. Specifically a 10% gain in home prices
would result in a full category upgrade for the rated class
excluding those assigned 'AAAsf' ratings.

Factors That Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade:

This defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model-projected 37.8% at 'AAA' for Group 1 and 38% at 'AAA' for
Group 2. The analysis indicates that there is some potential rating
migration with higher MVDs for all rated classes, compared with the
model projection. Specifically, a 10% additional decline in home
prices would lower all rated classes by one full category.

Fitch has added a Coronavirus Sensitivity Analysis that includes a
prolonged health crisis resulting in depressed consumer demand and
a protracted period of below-trend economic activity that delays
any meaningful recovery to beyond 2021. Under this severe scenario,
Fitch expects the ratings to be affected by changes in its
sustainable home price model due to updates to the model's
underlying economic data inputs. Any long-term impact arising from
coronavirus disruptions on these economic inputs will likely affect
both investment and speculative-grade ratings.


CSMC TRUST 2018-RPL6: Fitch Gives B-sf Rating on 2 Tranches
-----------------------------------------------------------
Fitch Ratings has assigned ratings to CSMC 2018-RPL6 Trust.

CSMC 2018-RPL6 Trust    

  - Class A-1; LT AAAsf New Rating  

  - Class A-2; LT Asf New Rating  

  - Class A-3; LT B-sf New Rating  

  - Class B-1; LT Asf New Rating  

  - Class B-2; LT B-sf New Rating  

  - Class B-3; LT NRsf New Rating  

  - Class B-4; LT NRsf New Rating  

  - Class B-5; LT NRsf New Rating  

  - Class PT; LT NRsf New Rating  

TRANSACTION SUMMARY

CSMC 2018-RPL6 is supported by a pool of re-performing mortgage
loans. The transaction was originally issued in the third quarter
of 2018 and was not rated at deal close. In tandem with this rating
assignment, the transaction is being modified to 1) allow principal
collection to be redirected to cover any potential interest
shortfalls on the class A-1, 2) using interest payment otherwise
allocable to the class B-3 to fund an account that may be used for
potential repurchases and 3) adding certain constraints on which
institutions can act as an 'Eligible Account'.

KEY RATING DRIVERS

Coronavirus Impact Addressed (Negative): Coronavirus and the
resulting containment efforts have resulted in revisions to Fitch's
GDP estimates for 2020. Fitch's current baseline outlook for U.S.
GDP growth is -5.6% for 2020, down from 1.7% for 2019. To account
for declining macroeconomic conditions the Economic Risk Factor
default variable for the 'Bsf' and 'BBsf' rating categories was
increased from a floor of 1.0 and 1.5, respectively to 2.0. The ERF
floor of 2.0 best approximates Fitch's baseline GDP for 2020 and a
recovery of 4.3% in 2021. If conditions deteriorate further and
recovery is longer or less than current projections, the ERF floors
may be further revised higher. See Rating Sensitivities section for
additional information.

Expected Payment Deferrals Related to Coronavirus (Negative): The
outbreak of coronavirus and widespread containment efforts in the
U.S. will result in increased unemployment and cash flow
disruptions. To account for the cash flow disruptions, Fitch
assumed deferred payments on a minimum of 40% of the pool for the
first six months of the transaction at all rating categories with a
reversion to its standard delinquency and liquidation timing curve
by month 10. This assumption is based on observations of legacy
Alt-A delinquencies and past due payments following Hurricane Maria
in Puerto Rico. Because the cash flow waterfall provides for
principal otherwise distributable to the lower rated bonds to pay
timely interest to the 'AAAsf' and 'AAsf' bonds, the lowest rate
classes will likely experience interest shortfalls to the extent
excess cash flow is insufficient. The excess cash flow in the
structure helped mitigate some of the impact of this assumption.

RPL Credit Quality (Mixed): The collateral consists of 30-year FRM
and 5 year ARM fully amortizing loans, seasoned approximately 161
months in aggregate. The borrowers in this pool have weaker credit
profiles (689 FICO) and relatively high leverage (91.6% sLTV). In
addition, the pool contains no loans of particularly large size.
There are no loans over $1 million and the largest is $0.83
million. 18% of the pool had a delinquency in the past 24 months.

Geographic Concentration (Neutral): Approximately 28% of the pool
is concentrated in California with relatively low MSA
concentration. The largest MSA concentration is in New York MSA
(14.1%) followed by the Los Angeles MSA (10.5%) and the Miami MSA
(6.8%). The top three MSAs account for 31.5% of the pool. As a
result, there was no adjustment for geographic concentration.

Transaction Structure (Positive): The transaction's cash flow is
based on a sequential-pay structure whereby the subordinate classes
do not receive principal until the senior classes are repaid in
full. Losses are allocated in reverse-sequential order.

No Servicer Advancing (Mixed): The servicers will not be advancing
delinquent monthly payments of principal and interest. Because P&I
advances made on behalf of loans that become delinquent and
eventually liquidate reduce liquidation proceeds to the trust, the
loan-level loss severities are less for this transaction than for
those where the servicer is obligated to advance P&I.

Low Operational Risk (Neutral): Operational risk is well controlled
for in this transaction. Credit Suisse has an established operating
history acquiring single family residential loans. Shellpoint
Mortgage Servicing is the named servicer for the transaction and is
rated by Fitch as 'RPS2-' with a Stable Outlook. Fitch did not
apply adjustments to the 'AAAsf' rating category based on the
transaction parties. Issuer retention of at least 5% of the bonds
also helps ensure an alignment of interest between both the issuer
and investor.

R&W's Have Knowledge Qualifiers and Sunset Period (Negative): The
loan-level representations and warranties are consistent with a
Tier 2 framework. The tier assessment is based primarily on the
inclusion of knowledge qualifiers in the underlying reps as well as
a breach reserve account that replaces the Sponsor's responsibility
to cure any R&W breaches following the established sunset period.
Fitch increased its loss expectations by 201 bps at the 'AAAsf'
rating category to reflect both the limitations of the R&W
framework as well as the non-investment-grade counterparty risk of
the provider.

Due Diligence Review Results (Negative): A third-party due
diligence review was performed on 100% of the loans in the
transaction pool. The review was performed by SitusAMC which is
assessed by Fitch as an 'Acceptable - Tier 1' TPR firm. The due
diligence results indicate moderate operational risk with 6.5% of
loans receiving a final grade of 'C' or 'D'. While this
concentration of material exceptions is similar to other
Fitch-rated RPL RMBS, adjustments were applied only to loans
missing of estimated final HUD-1 documents that are subject to
testing for compliance with predatory lending regulations. These
regulations are not subject to statute of limitations like most
compliance findings which ultimately exposes the trust to added
assignee liability risk. Fitch adjusted its loss expectation at the
'AAAsf' rating category by 19 bps to account for this added risk.

RATING SENSITIVITIES

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper 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 that may be considered in
the surveillance of the transaction. Sensitivity analyses was
conducted at the state and national levels to assess the effect of
higher MVDs for the subject pool as well as lower MVDs, illustrated
by a gain in home prices.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

This defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model-projected 37.7% at 'AAA'. The analysis indicates that there
is some potential rating migration with higher MVDs for all rated
classes, compared with the model projection. Specifically, a 10%
additional decline in home prices would lower all rated classes by
one full category.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

This defined positive rating sensitivity analysis demonstrates how
the ratings would react to negative MVDs at the national level, or
in other words positive home price growth with no assumed
overvaluation. The analysis assumes positive home price growth of
10.0%. Excluding the senior class which is already 'AAAsf', the
analysis indicates there is potential positive rating migration for
all of the rated classes. Specifically, a 10% gain in home prices
would result in a full category upgrade for the rated class
excluding those being assigned ratings of 'AAAsf'.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in up- and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Fitch has added a Coronavirus Sensitivity Analysis that that
includes a prolonged health crisis resulting in depressed consumer
demand and a protracted period of below-trend economic activity
that delays any meaningful recovery to beyond 2021. Under this
severe scenario, Fitch expects the ratings to be impacted by
changes in its sustainable home price model due to updates to the
model's underlying economic data inputs. Any long-term impact
arising from coronavirus disruptions on these economic inputs will
likely affect both investment and speculative grade ratings.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

CRITERIA VARIATION

There are two variations to the U.S. RMBS Rating Criteria. The tax
and title search were performed at the time of the initial
transaction closing, which is outside of the six-month timeframe
that Fitch looks to in criteria. This is mitigated by the
relatively small number of outstanding amounts at the time the
search was completed; the close proximity to the threshold Fitch
has in place as well as the servicers responsibility in line with
the transaction documents to advance these payments to maintain the
trust's interest in the loans. As a result, there was no rating
impact. The second variation relates to the outdated FICO scores
for the transaction. The FICOs were updated at the time of the
transaction close, which is more than the six-month window in which
Fitch looks for updated values. The stale values have no impact on
the levels as the performance has been fairly stable since they
were pulled. Additionally, while outdated, the values better
capture the borrowers' credit after the modification and their
initial default. To the extent the borrower has underperformed it
will be reflected in the pay string which would have a much more
meaningful impact on the levels.

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

A third-party due diligence review was completed on 100% of the
loans in the transaction pool. The due diligence scope included a
regulatory compliance review that covered applicable federal, state
and local high-cost loan and/or anti-predatory laws, as well as the
Truth in Lending Act and Real Estate Settlement Procedures Act. The
scope was consistent with published Fitch criteria for due
diligence on RPL RMBS.

The regulatory compliance review indicated that 1,308 reviewed
loans, or approximately 6.5% of the total pool, were found to have
a material defect and therefore assigned a final grade of 'C' or
'D'.

973 of reviewed loans, or approximately 4.8% of the total pool,
received a final grade of 'D' as the loan file did not contain a
final HUD-1. The absence of a final HUD-1 file does not allow the
TPR firm to properly test for compliance surrounding predatory
lending in which statute of limitations does not apply. These
regulations may expose the trust to potential assignee liability in
the future and create added risk for bond investors. Fitch
increased the LS on these loans to account for missing final
HUD-1.

The remaining 335 loans with a final grade of 'C' or 'D' reflect
missing final HUD-1 files that are not subject to predatory
lending, missing state disclosures, and other missing documents
related to compliance testing. Fitch notes that these exceptions
are unlikely to add material risk to bondholders since the statute
of limitations on these issues have expired. No adjustment to loss
expectations were made for these 335 loans for compliance issues.

Fitch also applied model adjustments on 214 loans with a broken
chain of title and 312 loans that had missing modification
agreements. These loans received a three-month foreclosure timeline
extension, respectively, to represent a delay in the event of
liquidation as a result of these files not being present.

Fitch adjusted its loss expectation at the 'AAAsf' by approximately
25 basis points to reflect both missing final HUD-1 files and
modification agreements and broken chain of title.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


CSMC TRUST 2019-RPL11: Fitch Gives CCC Rating on 4 Tranches
-----------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to CSMC
2019-RPL11 Trust.

CSMC 2019-RPL11

  - Class 1-A-1; LT AAsf New Rating   

  - Class 1-A-2; LT BBBsf New Rating   

  - Class 1-A-3; LT CCCsf New Rating   

  - Class 1-B-1; LT BBBsf New Rating   

  - Class 1-B-2; LT CCCsf New Rating   

  - Class 1-B-3; LT NRsf New Rating   

  - Class 1-B-4; LT NRsf New Rating   

  - Class 1-B-5; LT NRsf New Rating   

  - Class 1-PT; LT NRsf New Rating   

  - Class 2-A-1; LT AA+sf New Rating   

  - Class 2-A-1A; LT AA+sf New Rating   

  - Class 2-A-1B; LT AA+sf New Rating   

  - Class 2-A-1C; LT AA+sf New Rating   

  - Class 2-A-1D; LT AA+sf New Rating   

  - Class 2-A-1E; LT AA+sf New Rating   

  - Class 2-A-1F; LT AA+sf New Rating   

  - Class 2-A-2; LT A-sf New Rating   

  - Class 2-A-3; LT CCCsf New Rating   

  - Class 2-B-1; LT A-sf New Rating   

  - Class 2-B-2; LT CCCsf New Rating   

  - Class 2-B-3; LT NRsf New Rating   

  - Class 2-B-4; LT NRsf New Rating   

  - Class 2-B-5; LT NRsf New Rating   

  - Class 2-PT; LT NRsf New Rating   

TRANSACTION SUMMARY

CSMC 2019-RPL11 is supported by two pools of re-performing mortgage
loans. The notes from each group are not cross-collateralized with
the notes of the other group. The transaction was originally issued
in fourth-quarter 2019 and was not rated at the deal close.

In tandem with this rating assignment the transaction is being
modified to allow principal collection to be redirected to cover
any potential interest shortfalls on the most senior class
outstanding; use interest payment otherwise allocable to the class
B-3 to fund an account that may be used for potential repurchases;
and add certain constraints on which institutions can act as an
'Eligible Account.'

KEY RATING DRIVERS

Economic Impact from the Coronavirus Pandemic Addressed (Negative):
The coronavirus and the resulting containment efforts have resulted
in revisions to its GDP estimates for 2020. Its current baseline
outlook for U.S. GDP growth is a decline of 5.6% for 2020, down
from 1.7% for 2019. To account for declining macroeconomic
conditions the Economic Risk Factor default variable for the 'Bsf'
and 'BBsf' rating categories was increased from a floor of 1.0 and
1.5, respectively to 2.0. The ERF floor of 2.0 best approximates
its baseline GDP for 2020 and a recovery of 4.3% in 2021. If
conditions deteriorate further and recovery is longer or less than
current projections, the ERF floors may be further revised higher.
See the Rating Sensitivities section for additional information.

Expected Payment Deferrals Related to the Coronavirus Pandemic
(Negative): The outbreak of the coronavirus and widespread
containment efforts in the U.S. will result in increased
unemployment and cash flow disruptions. To account for the cash
flow disruptions, Fitch assumed deferred payments on a minimum of
40% of the pool for the first six months of the transaction at all
rating categories with a reversion to its standard delinquency and
liquidation timing curve by month 10. This assumption is based on
observations of legacy 'Alt-A' delinquencies and past due payments
following Hurricane Maria in Puerto Rico. The lowest rate classes
will likely experience interest shortfalls to the extent excess
cash flow is insufficient as the cash flow waterfall provides for
principal otherwise distributable to the lower rated bonds to pay
timely interest to the 'AAAsf' and 'AAsf' bonds.

RPL Credit Quality (Mixed): The transaction consists of two
collateral groups. Both groups consist of fixed and adjustable rate
RPLs. Group 1 is seasoned approximately 143 months in aggregate.
The borrowers in this pool have weaker credit profiles with a 670
weighted average FICO score and relatively high leverage with a
75.5% sustainable loan to value. Approximately 47% of loans
experienced a delinquency in the past 24 months and 14.5% is
currently delinquent. Group 2 is seasoned approximately 160 months
in aggregate. The borrowers in this pool have weaker credit
profiles with a 656 weighted average FICO score but relatively low
leverage with a 57.2% sLTV. Approximately 54% of the loans
experienced a delinquency in the past 24 months and 23% is
currently delinquent.

Transaction Structure (Positive): The transaction's cash flow is
based on a sequential-pay structure whereby the subordinate classes
do not receive principal until the senior classes are repaid in
full. Losses are allocated in reverse-sequential order.

No Servicer Advancing (Mixed): The servicers will not be advancing
delinquent monthly payments of principal and interest. As principal
and interest advances made on behalf of loans that become
delinquent and eventually liquidate reduce liquidation proceeds to
the trust, the loan-level loss severities are less for this
transaction than for those where the servicer is obligated to
advance P&I.

Low Operational Risk (Neutral): Operational risk is well controlled
for in this transaction. Credit Suisse has an established operating
history acquiring single-family residential loans. Rushmore Loan
Management Services LLC is the named servicer for the transaction
and is rated by Fitch as 'RPS2' with a Negative Outlook. Fitch did
not apply adjustments to the 'AAAsf' rating category based on the
transaction parties. Issuer retention of at least 5% of the bonds
also helps ensure an alignment of interest between both the issuer
and investor.

R&W's Have Knowledge Qualifiers and Sunset Period (Negative): The
loan-level representations and warranties are consistent with a
Tier 2 framework. The tier assessment is based primarily on the
inclusion of knowledge qualifiers in the underlying reps and a
breach reserve account that replaces the sponsor's responsibility
to cure any R&W breaches following the established sunset period.
Fitch increased its loss expectations by 223bps for Group 1 and
208bps for Group 2 bps at the 'AAAsf' rating category to reflect
both the limitations of the R&W framework and the
non-investment-grade counterparty risk of the provider.

Due Diligence Review Results (Negative): A third-party due
diligence review was performed on 100% of the loans in the
transaction pool. The review was performed by SitusAMC, which is
assessed by Fitch as an 'Acceptable - Tier 1' TPR firm. The due
diligence results indicate moderate operational risk with 5% of
loans receiving a final grade of 'C' or 'D'. While this
concentration of material exceptions is similar to other
Fitch-rated RPL RMBS, adjustments were applied only to loans
missing estimated final HUD-1 documents that are subject to testing
for compliance with predatory lending regulations. These
regulations are not subject to statute of limitations like most
compliance findings, which ultimately exposes the trust to added
assignee liability risk. For each group, Fitch adjusted its loss
expectation at the 'AAAsf' rating category by approximately 30bps
to account for this added risk.

RATING SENSITIVITIES

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper market value declines 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
that may be considered in the surveillance of the transaction.
Sensitivity analyses was conducted at the state and national levels
to assess the effect of higher MVDs for the subject pool as well as
lower MVDs, illustrated by a gain in home prices.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in up and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Factors That Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade:

This defined positive rating sensitivity analysis demonstrates how
the ratings would react to negative MVDs at the national level, or
in other words positive home price growth with no assumed
overvaluation. The analysis assumes positive home price growth of
10.0%. Excluding the senior class which is already 'AAAsf', the
analysis indicates there is potential positive rating migration for
all of the rated classes. Specifically, a 10% gain in home prices
would result in a full category upgrade for the rated class
excluding those being assigned ratings of 'AAAsf'.

Factors That Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade:

This defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model-projected 37.8% at 'AAA' for Group 1 and 38% at 'AAA' for
Group 2. The analysis indicates that there is some potential rating
migration with higher MVDs for all rated classes, compared with the
model projection. Specifically, a 10% additional decline in home
prices would lower all rated classes by one full category.

Fitch has added a Coronavirus Sensitivity Analysis that includes a
prolonged health crisis resulting in depressed consumer demand and
a protracted period of below-trend economic activity that delays
any meaningful recovery to beyond 2021. Under this severe scenario,
Fitch expects the ratings to be affected by changes in its
sustainable home price model due to updates to the model's
underlying economic data inputs. Any long-term impact arising from
coronavirus disruptions on these economic inputs will likely affect
both investment and speculative-grade ratings.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

CRITERIA VARIATION

The first variation is that the tax and title search was performed
at the time of the initial transaction closing, which is outside of
the six-month timeframe that Fitch looks for in criteria. This is
mitigated by the relatively small number of outstanding amounts at
the time the search was completed, the close proximity to the
threshold Fitch has in place as well as the servicers
responsibility in line with the transaction documents to advance
these payments to maintain the trust's interest in the loans. As a
result, there was no rating impact.

The second variation relates to the outdated FICO scores for the
transaction. The FICOs were updated at the time of the transaction
closing, which is more than the six-month window in which Fitch
looks for updated scores. The stale values have no impact on the
levels as the performance has been fairly stable since they were
pulled. Additionally, while outdated, the values better capture the
borrower's credit after modification and their initial default. To
the extent the borrower has underperformed, it will be reflected in
the pay string which would have a much more meaningful impact on
the levels. This variation did not result in a rating impact.

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

A third-party due diligence review was completed on 100% of the
loans in the transaction pool. The due diligence scope included a
regulatory compliance review that covered applicable federal, state
and local high-cost loan and/or anti-predatory laws, as well as the
Truth in Lending Act and Real Estate Settlement Procedures Act. The
scope was consistent with published Fitch criteria for due
diligence on RPL RMBS.

Of the reviewed loans 240, or approximately 53% of the aggregate
pool (Group 1 and Group 2 combined), received a final grade of 'D'
as the loan file did not contain a final HUD-1. The absence of a
final HUD-1 file does not allow the TPR firm to properly test for
compliance surrounding predatory lending in which statute of
limitations does not apply. These regulations may expose the trust
to potential assignee liability in the future and create added risk
for bond investors. Fitch increased the LS on these loans to
account for missing final HUD-1.

The remaining 218 loans with a final grade of 'D' reflect missing
final HUD-1 files that are not subject to predatory lending,
missing state disclosures and other missing documents related to
compliance testing. Fitch notes that these exceptions are unlikely
to add material risk to bondholders since the statute of
limitations on these issues have expired. No adjustment to loss
expectations were made for these 218 loans for compliance issues.

Fitch also applied model adjustments on 89 loans with a broken
chain of title and 84 loans that had missing modification
agreements. These loans received a three-month foreclosure timeline
extension to represent a delay in the event of liquidation as a
result of these files not being present.

A tax, title and lien search were performed on the loans in the
transaction pool at the time of the initial transaction closing. A
tax and title review are considered part of the due diligence scope
for RPL transactions because the searches may identify loans with
outstanding liens and delinquent taxes that can supersede the
subject mortgage in payment priority. Fitch factored the
outstanding amounts reported from the searches, into the expected
loss levels, an approximately 12bps adjustment to the 'AAAsf' LS
for each group.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


CSMC TRUST 2019-RPL7: Fitch Gives B-sf Rating on 2 Tranches
-----------------------------------------------------------
Fitch Ratings has assigned Ratings to CSMC 2019-RPL7 Trust as
follows:

CSMC 2019 - RPL7    

  - Class A-1; LT AAAsf New Rating  

  - Class A-2; LT Asf New Rating  

  - Class A-3; LT B-sf New Rating  

  - Class B-1; LT Asf New Rating  

  - Class B-2; LT B-sf New Rating  

  - Class B-3; LT NRsf New Rating  

  - Class B-4; LT NRsf New Rating  

  - Class B-5; LT NRsf New Rating  

  - Class PT; LT NRsf New Rating  

TRANSACTION SUMMARY

CSMC 2019-RPL7 is supported by a pool of reperforming mortgage
loans. The transaction was originally issued in 2019 and was not
rated at deal close. In tandem with this rating assignment, the
transaction is being modified to 1) allow principal collection to
be redirected to cover any potential interest shortfalls on the
most senior class then outstanding, 2) use interest payment
otherwise allocable to the class B-3 to fund an account that may be
used for potential repurchases and 3) add certain constraints on
which institutions can act as an 'Eligible Account'.

KEY RATING DRIVERS

Economic Impact from the Coronavirus Pandemic Addressed (Negative):
Coronavirus and the resulting containment efforts have resulted in
revisions to its GDP estimates for 2020. Its current baseline
outlook for U.S. GDP growth is -5.6% for 2020, down from 1.7% for
2019. To account for declining macroeconomic conditions the
Economic Risk Factor default variable for the 'Bsf' and 'BBsf'
rating categories was increased from a floor of 1.0 and 1.5,
respectively to 2.0. The ERF floor of 2.0 best approximates its
baseline GDP for 2020 and a recovery of 4.3% in 2021. If conditions
deteriorate further and recovery is longer or less than current
projections, the ERF floors may be further revised higher. See
Rating Sensitivities section for additional information.

Expected Payment Deferrals Related to the coronavirus pandemic
(Negative): The outbreak of the coronavirus and widespread
containment efforts in the U.S. will result in increased
unemployment and cash flow disruptions. To account for the cash
flow disruptions, Fitch assumed deferred payments on a minimum of
40% of the pool for the first six months of the transaction at all
rating categories with a reversion to its standard delinquency and
liquidation timing curve by month 10. This assumption is based on
observations of legacy Alt-A delinquencies and past due payments
following Hurricane Maria in Puerto Rico. Because the cash flow
waterfall provides for principal otherwise distributable to the
lower rated bonds to pay timely interest to the 'AAAsf' and 'AAsf'
bonds, the lowest rate classes will likely experience interest
shortfalls to the extent excess cash flow is insufficient. The
excess cash flow in the structure helped mitigate some of the
impact of this assumption.

RPL Credit Quality (Mixed): The collateral consists of 30-year FRM
and 40-yesr FRM fully amortizing loans, seasoned approximately 148
months in aggregate. The borrowers in this pool have weaker credit
profiles (664 FICO) and relatively high leverage (75.2% sLTV). In
addition, the pool contains no loans of particularly large size. No
loans are over $1 million and the largest is $0.8 million. A total
of 46% of the pool had a delinquency in the past 24 months.

Transaction Structure (Positive): The transaction's cash flow is
based on a sequential-pay structure whereby the subordinate classes
do not receive principal until the senior classes are repaid in
full. Losses are allocated in reverse-sequential order.

No Servicer Advancing (Mixed): The servicers will not be advancing
delinquent monthly payments of principal and interest. Because P&I
advances made on behalf of loans that become delinquent and
eventually liquidate reduce liquidation proceeds to the trust, the
loan-level loss severities are less for this transaction than for
those where the servicer is obligated to advance P&I.

Low Operational Risk (Neutral): Operational risk is well controlled
for in this transaction. Credit Suisse has an established operating
history acquiring single family residential loans. Select Portfolio
Servicing is the named servicer for the transaction and is rated by
Fitch as RPS1- with an Outlook Negative. Fitch applied a credit to
the 'AAAsf' rating category based on the transaction parties.
Issuer retention of at least 5% of the bonds also helps ensure an
alignment of interest between both the issuer and investor.

R&W's Have Knowledge Qualifiers and Sunset Period (Negative): The
loan-level representations and warranties are consistent with a
Tier 2 framework. The tier assessment is based primarily on the
inclusion of knowledge qualifiers in the underlying reps as well as
a breach reserve account that replaces the Sponsor's responsibility
to cure any R&W breaches following the established sunset period.
Fitch increased its loss expectations by 191 bps at the 'AAAsf'
rating category to reflect both the limitations of the R&W
framework as well as the non-investment-grade counterparty risk of
the provider.

Due Diligence Review Results (Negative): A third-party due
diligence review was performed on 100% of the loans in the
transaction pool. The review was performed by SitusAMC which is
assessed by Fitch as an 'Acceptable - Tier 1' TPR firm. The due
diligence results indicate moderate operational risk with 9.3% of
loans receiving a final grade of 'C' or 'D'. While this
concentration of material exceptions is similar to other
Fitch-rated RPL RMBS, adjustments were applied only to loans
missing of estimated final HUD-1 documents that are subject to
testing for compliance with predatory lending regulations. These
regulations are not subject to statute of limitations like most
compliance findings which ultimately exposes the trust to added
assignee liability risk. Fitch adjusted its loss expectation at the
'AAAsf' rating category by less than 25 bps to account for this
added risk.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

This defined positive rating sensitivity analysis demonstrates how
the ratings would react to negative MVDs at the national level, or
in other words positive home price growth with no assumed
overvaluation. The analysis assumes positive home price growth of
10.0%. Excluding the senior class which is already 'AAAsf', the
analysis indicates there is potential positive rating migration for
all of the rated classes. Specifically, a 10% gain in home prices
would result in a full category upgrade for the rated class
excluding those being assigned ratings of 'AAAsf'.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

This defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model-projected 37.5% at 'AAA'. The analysis indicates that there
is some potential rating migration with higher MVDs for all rated
classes, compared with the model projection. Specifically, a 10%
additional decline in home prices would lower all rated classes by
one full category.

Fitch has added a Coronavirus Sensitivity Analysis that
contemplates a more severe and prolonged economic stress caused by
a reemergence of infections in the major economies, before a slow
recovery begins in 2Q21. Under this severe scenario, Fitch expects
the ratings to be impacted by changes in its sustainable home price
model due to updates to the model's underlying economic data
inputs. Any long-term impact arising from coronavirus disruptions
on these economic inputs will likely affect both investment and
speculative grade ratings.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modeling process uses the modification of
these variables to reflect asset performance in up- and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

CRITERIA VARIATION

There are two variations to the U.S. RMBS Rating Criteria. The tax
and title search were performed at the time of the initial
transaction closing which is outside of the 6-month timeframe that
Fitch looks to in criteria. This is mitigated by the relatively
small number of outstanding amounts at the time the search was
completed, the close proximity to the threshold it has in place as
well as the servicers responsibility in line with the transaction
documents to advance these payments to maintain the trust's
interest in the loans. As a result, there was no rating impact. The
second variation relates to the outdated FICO scores for the
transaction. The FICOs were updated at the time of the transaction
close which is more than the 6-month window in which Fitch looks
for updated values. The stale values have no impact on the levels
as the performance has been fairly stable since they were pulled.
Additionally, while outdated, the values better capture the
borrowers' credit after the modification and their initial default.
To the extent the borrower has underperformed it will be reflected
in the pay string which would have a much more meaningful impact on
the levels.

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

The regulatory compliance review indicated that 686 reviewed loans,
or approximately 9.3% of the total pool, were found to have a
material defect and therefore assigned a final grade of 'C' or
'D'.

A total of 415 of reviewed loans, or approximately 5.7% of the
total pool, received a final grade of 'D' as the loan file did not
have a final HUD-1. The absence of a final HUD-1 file does not
allow the TPR firm to properly test for compliance surrounding
predatory lending in which statute of limitations does not apply.
These regulations may expose the trust to potential assignee
liability in the future and create added risk for bond investors.

The remaining 271 loans with a final grade of 'C' or 'D' reflect
missing final HUD-1 files that are not subject to predatory
lending, missing state disclosures, and other missing documents
related to compliance testing. Fitch notes that these exceptions
are unlikely to add material risk to bondholders since the statute
of limitations on these issues have expired. No adjustment to loss
expectations were made for these 271 loans.

Fitch also applied model adjustments on 30 loans with a broken
chain of title and 86 loans that had missing modification
agreements. These loans received a three-month foreclosure timeline
extension to represent a delay in the event of liquidation as a
result of these files not being present.

Fitch adjusted its loss expectation at the 'AAAsf' by less than 25
bps to reflect missing both final HUD-1 files and modification
agreements as well as having broken chain of title.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


DEUTSCHE BANK 2011-LC3: Fitch Cuts Class F Certs to 'CCCsf'
-----------------------------------------------------------
Fitch Ratings has downgraded classes E and F and has affirmed the
remaining classes of Deutsche Bank Securities commercial mortgage
pass-through certificates series 2011-LC3.

DBUBS 2011-LC3      

  - Class A-4 23305YAD1; LT AAAsf; Affirmed

  - Class A-M 23305YAJ8; LT AAAsf; Affirmed

  - Class B 23305YAK5; LT AAAsf; Affirmed

  - Class C 23305YAL3; LT Asf; Affirmed

  - Class D 23305YAM1; LT BBB-sf; Affirmed

  - Class E 23305YAN9; LT Bsf; Downgrade

  - Class F 23305YAP4; LT CCCsf; Downgrade

  - Class PM-1 23305YAU3; LT AAAsf; Affirmed

  - Class PM-2 23305YAW9; LT AAsf; Affirmed

  - Class PM-3 23305YAX7; LT Asf; Affirmed

  - Class PM-4 23305YAY5; LT BBBsf; Affirmed

  - Class PM-5 23305YAZ2; LT BBB-sf; Affirmed

  - Class PM-X 23305YAV1; LT AAAsf; Affirmed

  - Class X-A 23305YAG4; LT AAAsf; Affirmed

Classes PM-1 through PM-5 are secured by Providence Place Mall on a
stand-alone basis. Overall performance of the mall remains stable
since issuance. The mall has historically strong sales with the
most recent reported comparable in-line mall sales as of YE 2019
for tenants less than 10,000 sf at $647 psf (excluding Apple $476
psf) and a debt yield of 13.8%.

The class A-1, A-2, and A-3 certificates have paid in full. Fitch
does not rate the class G certificates.

KEY RATING DRIVERS

Higher Loss Expectations; Fitch Loans of Concern: Loss expectations
have increased primarily due to the larger retail FLOCs and the
specially serviced loans. In total, eight loans (43.9%) are
considered FLOCs, of which five (38%) are currently on the master
servicer's watchlist.

The largest specially serviced loan, Western Lights Shopping Center
(3%), transferred to special servicing in December 2018 due to
imminent monetary default, due to several issues with various
tenants at the property that caused significant impairment to
property cash flows, including one rent reduction request (Price
Chopper) and two minor tenants with co-tenancy triggers. The loan's
collateral is a 243,311 sf retail property built in 1969 and
located in Syracuse, NY. It is anchored by a Price Chopper food
store and shadow anchored by Wegman's. A 37,000 sf tenant vacated
three years ago, followed by Fallas (10%) vacating in 4Q18. Per the
special servicer, the Department of Motor Vehicle lease renewal has
progressed and is expected to be signed in June 2020, and anchor
Price Chopper indicated they will exercise their renewal option for
five years at their current rent. One tenant, Shoe Show has
indicated they will be leaving the center.

The other specially serviced loan, Ba Mar Basin (1.1%) was
transferred to special servicing effective April 2019 due to
imminent monetary default. The loan's collateral consists of a
151-pad manufactured housing community built in 1975 located in
Stony Point, NY, significantly damaged by Hurricane Sandy in 2012.
Approximately 45% of the homeowners have accepted buyouts from the
State recovery fund, which mandates that bought-out homes not be
occupied. Per the special servicer they are currently evaluating
the viability of the collateral property, which is approximately
12% occupied as of March 2020.

The largest FLOC is the Dover Mall and Commons (16.6%) located in
Dover, DE with exposure to collateral anchors Macy's, a dark Sears
and non-collateral anchor JCPenney. Sears closed this location and
vacated in August 2018, and the space remains vacant. Fitch's base
case loss includes an additional 40% stress to the net operating
income, on top of using a higher minimum NOI haircut of 10% pool
wide due to the increased pool concentration, to reflect the lack
of updated sales, declining anchor sales, dark Sears space, dated
mall, near-term lease rollover concerns and upcoming maturity in
2021. The most recent in-line occupancy as of YE 2019 is 76.4%.
Fitch requested an update on leasing activity, but has not received
a response. Fitch also requested recent tenant sales, but per the
master servicer, the borrower is not required to report sales.

The second largest FLOC is Albany Mall (5.1%) located in Albany, GA
with exposure to collateral anchor Dillard's and non-collateral
anchors JCPenney, Belk and a dark Sears, which closed its location
and vacated in March 2017. Additionally, Toys R Us also closed and
vacated in August 2018. Both spaces remain vacant. The property's
occupancy has fluctuated since issuance due to tenants vacating. As
of February 2020, the property's occupancy declined to 69% from 74%
in 2018 and 90% in March 2017. The most recent servicer reported
NOI DSCR as of September 2019 is 1.18x compared to 1.29x in 2018
and 1.39x YE 2017 and below 1.72x at issuance. Fitch requested
recent tenant sales from the master servicer, but per the master
servicer, the borrower is not required to report sales.

The third largest FLOC is Montgomery Plaza (5.1%) located in
Albuquerque, NM. The most recent occupancy is 70.9%; however, if
several signed letters of intent were included, occupancy would be
92%, compared to 73.6% (2016) and 87% (2015). The decline in
occupancy in 2016 was due to tenant IT'Z Pizza (53,670 and 13.6%
NRA) vacating after their lease expired in May 2016 as they closed
the location. Fitch has requested an update on leasing activity as
the December 2019 rent rolls shows several signed LOIs with the
following tenants: Vasa (for the vacant IT'Z Pizza space), Dollar
tree, Five Below, Marshalls and Rack Room, but a response has not
been received.

The fourth largest FLOC is Inland-SuperValu/Walgreens Portfolio
(4.3%) The portfolio's occupancy remains at 49.8% as of YE 2019 in
line with YE 2018, but below 85.2% YE 2017 and 100% in December
2015. This is largely attributed to the Stop N Save - Twin Oaks
property as the tenant, Stop N Save, which occupied 53,411 sf
vacated in 2018 and has subsequently ceased making its required
rental payments in July 2019. Additionally, there are two dark
Walgreen properties located in West Virginia and Kentucky. A
leasing update has been requested of the master servicer, but not
received.

The fifth largest FLOC is Feasterville Shopping Center (2.7%), a
110,632 sf retail center anchored by Giant Foods at issuance and
located in Feasterville, PA. The anchor tenant Giant Food, which
occupied 52,694 sf (47% of GLA) vacated their space in September
2018 and the space was fully leased to Bell's Market, which began
paying rent in July 2019. Per the master servicer, two more leases
were signed in 3Q19, KinderCuts (1,466 sf) which began paying rent
in November 2019 and Max Challenge (4,000 sf 3.6%). Max Challenge
was expected to take occupancy in April 2020. The most recent
occupancy as of December 2019 is 93.5% up from 89.8% in 2018 and
100% at issuance. Fitch requested an update from the master
servicer regarding Max Challenge's expected occupancy in April
2020, but has not received a response; however, the Max Challenge
website has the location listed as coming soon and currently
offering virtual classes.

Increased Credit Enhancement; Additional Defeasance: The rating
affirmations of senior classes reflect increased credit enhancement
to the classes due to defeasance and paydown, which help offset
Fitch's increased loss expectations. As of the May 2020
distribution date, the pool's aggregate principal balance
(excluding the non-pooled rakes associated with the Providence
Place Mall) has paid down by 65.0% to $488.8 million from $1.4
billion at issuance. Twelve loans (50.7% of the pool) are defeased,
of which five loans (25%), including the largest loan in the pool
(20%), were defeased since Fitch's last rating action. There have
been no realized losses since issuance.

Coronavirus Exposure: Significant economic impact to certain
hotels, retail and multifamily properties is expected from the
coronavirus pandemic, due to the recent and sudden reductions in
travel and tourism, temporary property closures and lack of clarity
at this time on the potential length of the impact. The pandemic
has already prompted the closure of several hotel properties in
gateway cities as well as malls, entertainment venues and
individual stores. Of the non-defeased and non-specially serviced
loans, six loans (42.6%) are secured by retail properties, which
have a weighted-average debt service coverage ratio (WADSCR) of
1.81x and could sustain a 44.8% decline in NOI before the actual
NOI DSCR would fall below 1.00x. Although four of the six retail
loans would fail the coronavirus NOI DSCR tolerance threshold for
retail, the coronavirus stress was not a factor. A higher base case
NOI stress was applied pool wide due to the concentration and
upcoming maturities in 2021. In addition, Fitch applied a
recognition of 100% maturity defaults.

High Retail Concentration: Approximately eight (47.6%) of the
remaining 22 loans in the pool are secured by retail properties,
including three (30.5%) of the top five loans, which are secured by
regional malls located in secondary and tertiary markets, with
exposure to and/or closure of at least one anchor tenant, Sears,
JCPenney, Macy's, and Nordstrom.

Pool Concentrations: The transaction is highly concentrated with
only 22 loans remaining; the top five and 10 largest loans
accounting for 59.7% and 81.6% of the poo, respectively. Fitch
applied a higher NOI and cap rate scenario pool wide (assuming a
10% NOI decline and 100 bps increase to the default cap rates) in
its base case due to the increased pool concentration. All of the
remaining loans in the transaction mature in 2021. One loan (4.4%)
is full-term interest only, with the remaining 21 loans (95.6%)
currently amortizing.

RATING SENSITIVITIES

Near-term rating changes will be limited, as indicated by the
senior classes' sufficient CE, continued amortization and
defeasance, relatively stable performance of the pool as evidenced
by the Stable Outlooks on classes A-4 through D. The downgrades of
classes E and F and Negative Outlooks on classes E reflect
performance concerns with the FLOCs as well as the retail
properties due to the decline in travel and commerce as a result of
the coronavirus pandemic.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Factors that could lead to upgrades would include stable to
improved asset performance, coupled with additional pay down and/or
defeasance. Upgrades to the 'Asf' rated class would likely occur
with significant improvement in CE and/or defeasance; however,
adverse selection and increased concentrations, or the
underperformance of the FLOC could cause this trend to reverse.

Upgrades of the 'BBB-sf' and below-rated classes are considered
unlikely and would be limited based on the sensitivity to
concentrations or the potential for future concentrations. Classes
would not be upgraded above 'Asf' if there were likelihood for
interest shortfalls. An upgrade to the 'Bsf' and 'CCCsf' rated
classes is not likely until the later years in the transaction and
only if the performance of the remaining pool is stable and/or if
there is sufficient credit enhancement, which would likely occur
when the non-rated class is not eroded and the senior classes pay
off. Upgrades would only occur only if the performance of the
remaining pool is stable and/or properties vulnerable to the
coronavirus return to pre-pandemic levels, and there is sufficient
credit enhancement to the class.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that could lead to downgrades include an increase in pool
level losses due to underperforming loans or should loans transfer
to specially servicing. Downgrades to the senior classes, rated
'Asf' through 'AAAsf', are not likely due to the position in the
capital structure and the high credit enhancement; however,
downgrades of these classes may occur should interest shortfalls
occur. Downgrades to the classes rated 'Bsf' and below would occur
if the performance of the FLOCs continues to decline or fails to
stabilize. The Rating Outlook on class E may be revised back to
Stable if performance of the FLOCs improves and/or properties
vulnerable to the coronavirus stabilize once the pandemic is over.

In addition to its baseline scenario, Fitch also envisions a
downside scenario where the health crisis is prolonged beyond 2021;
should this scenario play out, Fitch expects that a greater
percentage of classes may be assigned a Negative Outlook or those
with Negative Rating Outlooks will be downgraded one or more
categories.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

ESG Considerations: The DBUBS 2011-LC3 transaction has an ESG
Relevance Score of 4 for Exposure to Social Impacts due to the
three regional malls and other retail FLOCs that are
underperforming as a result of changing consumer preference to
shopping, which has a negative impact on the credit profile, and is
highly relevant to the rating, resulting in the downgrades of
classes E and F.


ECAF I LTD: Fitch Cuts Class B-1 Notes to 'BBsf'
------------------------------------------------
Fitch Ratings has downgraded the class A-1, A-2 and B-1 asset
backed notes issued by ECAF I Ltd. The ratings have been removed
from Rating Watch Negative and assigned Negative Outlooks.

ECAF I Ltd.      

  - Class A-1 26827EAA3; LT BBBsf; Downgrade

  - Class A-2 26827EAC9; LT BBBsf; Downgrade

  - Class B-1 26827EAE5; LT BBsf; Downgrade

TRANSACTION SUMMARY

The downgrades reflect ongoing deterioration of all airline lessee
credits backing the leases in the pool, downward pressure on
certain aircraft values, Fitch's updated assumptions and stresses,
and resulting impairments to modeled cash flows and coverage
levels. Fitch removed the notes from Negative Watch and assigned
Negative Outlooks, reflecting base case expectations for the
structure to withstand immediate and near-term stresses at the
updated assumptions and stressed scenarios and current ratings.

On March 31, 2020, Fitch placed all classes of notes on Negative
Watch as part of its aviation ABS portfolio review due to the
ongoing impact of the coronavirus on the global macro and
travel/airline sectors. The unprecedented worldwide pandemic
continues to evolve rapidly and negatively affect airlines across
the globe. To accurately reflect its ongoing global recessionary
environment and the impact to airlines backing these pools, Fitch
updated rating assumptions for both rated and non-rated airlines
with a vast majority of ratings moving lower, which was a key
driver of these rating actions along with modeled cash flows.

Furthermore, recessionary timing was brought forward to start
immediately at this point in time. This scenario further stresses
airline credits, asset values and lease rates immediately while
incurring remarketing and repossession cost and downtime, at each
relevant rating stress level. Previously, Fitch assumed that the
first recession commenced six months from either the transaction
closing date or date of subsequent reviews.

Entities managed by affiliates of BBAM Limited Partnership acted as
initial sellers to ECAF I. BBAM Aviation Services Limited (BBAM,
not rated by Fitch) is the servicer, and Stellwagen Capital is the
administrator for ECAF I following the acquisition of Element
Financial Corporation in 2017.

KEY RATING DRIVERS

Deteriorating Airline Lessee Credit:

The credit profiles of the airline lessees in the pool have further
deteriorated further due to the coronavirus-related impact on
global airlines in 2020, resulting in lower lessee rating
assumptions utilized for this review. The proportion of the pool
with a 'CCC' Issuer Default Rating increased to 44.6% versus 10.0%
in the prior review in 2019.

Fitch applied 'CCC' rating assumptions to Air Serbia, Bangkok
Aiways, Condor Flugdienst GmbH, ASL Airlines France (formerly
Europe Airpost), IndiGo, Jet2.com Limited, Korean Air Co., Ltd.,
MAB Leasing Ltd., PAL Holdings, Inc., SunExpress and T'Way Air Co.,
Ltd. The 'CCC' assumptions reflect these airlines' ongoing credit
profiles and fleets in the current operating environment due to the
coronavirus-related impact on the sector. Airlines currently rated
by Fitch or other publicly rated airlines in the pool were utilized
for this review.

Asset Quality and Appraised Pool Value:

The current pool includes three A330-300s, one B777-200ER and one
B777-300ER, totaling 43.4% widebody aircraft concentration in the
pool. The majority of the remaining narrow-body aircraft are tier 1
aircraft, with 7.9% tier two spread across four A319-100s and one
B737-700. There is ongoing uncertainty around aircraft market
values and how the current environment will impact them and also
near-term lease maturities and demand for those aircraft coming
off-lease. WB aircraft are particularly susceptible to MV declines
in the current environment having been pressured coming into the
pandemic.

Fitch recognizes that there is downward pressure on MVs in the
short to medium term. Aviation Specialists Group, Inc., AVITAS,
Inc., and Ascend Flightglobal Consultancy are the three transaction
appraisers. Applying the average of these three
maintenance-adjusted base values produces a pool value of $783.0
million as of June 30, 2019. IBA Group Limited and morten beyer &
agnew Inc. (mba) were solicited to provide additional appraisals in
2016 given the conservative approach taken by the existing
transaction appraisers and have been updated annually on the same
schedule as the transaction appraisers. The average MABV of IBA and
mba appraisals resulted in a pool value of $838.1 million (as of
June 30, 2019).

Fitch utilized the average excluding highest method applied to the
three transaction appraisers' MABVs for modeling consistent with
recent reviews, resulting in modeled pool value of $760.6 million
for this review. Fitch's cash flow model considers the appraisal
date, and values are depreciated to May 2020.

Transaction Performance to Date:

Airline deferral requests are in the process of being evaluated by
the servicer. Based on observations of peer transactions where all
or nearly all lessees have made some request for deferral, Fitch
expects ECAF I to reflect similar trends as other lessors have
experienced so far. As a result, three-month deferral terms were
applied to 22 leases in the pool with repayment terms assumed
assessed over a six-month period beginning in January 2021. Four
aircraft with leases ending in 2020 were not assumed to have any
deferred payments given their near-term lease expirations this
year.

Lease collections vary from month to month but have trended down in
recent months. The declines in lease collections are less
pronounced compared to certain peer transactions, with in the April
2020 servicing report flowing all the way through the waterfall to
E Note holders.

Fitch Assumptions, Stresses and Cash Flow Modeling:

Nearly all BBAM servicer-driven assumptions applied to this
analysis are consistent with the prior review conducted in 2019.
These include costs and certain downtime assumptions relating to
aircraft repossessions and remarketing terms of new leases and
extension terms. Leases ending in the next year were assumed to
remain on ground for three additional months, on top of
lessor-specific remarketing downtime assumptions to account for
potential remarketing challenges to place these aircraft with a new
lessee in the current distressed environment. Please refer to the
published presale and prior reviews of ECAF I for further
information on these assumptions and stresses.

With the grounding of global fleets and significant reduction in
air travel, maintenance revenues and costs will be impacted and are
expected to decline due to airline lessee credit issues and
grounded aircraft. Maintenance revenues were reduced by 50% over
the next immediate 12 months, and missed payments were then assumed
to be recouped in the following 12 months thereafter, starting in
May 2021. Maintenance costs over the immediate five months were
assumed to be incurred as reported. Costs in the following month
were reduced by 50% and assumed to increase on a straight-line
basis to 100% over a 12-month period. Any deferred costs were
repaid in the following 12 months.

RATING SENSITIVITIES

The Negative Outlooks on the notes reflect potential for further
negative rating actions due to concerns surrounding the ongoing
impact of the coronavirus pandemic and resulting performance
concerns associated with airlines, aircraft values and other
assumptions across the aviation industry with the severe decline in
travel and grounding of airlines.

At close of the transaction, Fitch conducted multiple rating
sensitivities to evaluate the impact of changes to a number of the
variables in the analysis. The performance of aircraft operating
lease securitizations is affected by various factors, which in turn
could have an impact on the assigned ratings. Due to the
correlation between global economic conditions and the airline
industry, the ratings can be affected by the strength of the
macroeconomic environment over the remaining term of the
transaction.

In the initial analysis, Fitch found the transaction exhibited
sensitivity to the timing or severity of assumed recessions. There
is also greater default probability of the leases that will have a
material impact on the ratings. The timing or degree of
technological advancement in the commercial aviation space and the
impacts these changes would have on values, lease rates, and
utilization would have a moderate impact on the ratings.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Up: Base Assumptions with Stronger Values than Appraised

The aircraft ABS sector has a rating cap of 'Asf'. All subordinate
tranches carry one category of ratings lower than the senior
tranche. If the transaction experiences stronger asset values than
currently appraised or if it experiences stronger lease collection
inflow than Fitch's stressed scenarios, the transaction could
perform better than expected and result in upgrades but remains
limited by the 'Asf' rating. Future upgrades beyond 'Asf' would not
be considered due to the rating cap in the sector, the industry
cyclicality, weaker current lessee mix in ABS pools and uncertainty
around future lessee mix.

Since the transaction offers additional appraisals, Fitch ran a
scenario utilizing the average MABV of IBA and mba values,
utilizing appraisals from these two additional sources provided by
the servicer. A 10% downward MV adjustment was applied to the
A330-300s and the B777-200ER in the pool, and a 5% downward MV
adjustment was applied to the B777-300ER in the pool, resulting in
a modeled value of $807.4 million compared to $783.0 million the
April 2020 servicer report. Under this scenario, classes A-1, A-2
and B-1 notes are able to pass at 'A-sf', 'A-sf' and 'BBBsf' rating
categories due to stronger modeled lease cash flows and residual
sales proceeds.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Down: Base Assumptions with Weaker Widebody Values

With 43.4% WB concentration in the current pool, any further
softening in WB values could lead to further negative rating
actions. Using Fitch's primary modeled pool value of $760.6 million
as a starting point and applying the same downward MV adjustment as
described in the Up scenario, Fitch ran a downside sensitivity
using $733.1 million for the pool. Classes A-1 and A-2 fall further
short of their 'A-sf' rating stress level but remain able to pay in
full under the 'BBBsf' scenario.

Greater sensitivity is observed for the class B-1 notes, which
experiences a $4 million principal shortfall under the 'BBsf'
scenario but is able to pay in full under the 'Bsf' scenario. As a
result, class B-1 could be considered for further downgrade to the
'Bsf' rating category.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


FIRST REPUBLIC 2020-1: Fitch Rates Class B5 Debt 'B+(EXP)sf'
------------------------------------------------------------
Fitch has assigned expected ratings to the first residential
mortgage-backed certificates issued by First Republic Mortgage
Trust 2020-1.

FRMT 2020-1    

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

  - Class A-6 LT NR(EXP)sf Expected Rating  

  - Class B1; LT AA(EXP)sf Expected Rating  

  - Class B2; LT A(EXP)sf Expected Rating  

  - Class B3; LT BBB+(EXP)sf Expected Rating  

  - Class B4; LT BB+(EXP)sf Expected Rating  

  - Class B5; LT B+(EXP)sf Expected Rating  

  - Class B6; LT NR(EXP)sf Expected Rating  

TRANSACTION SUMMARY

The certificates are supported by 303 prime adjustable-rate
mortgage loans with a total balance of approximately $300 million
as of the cutoff date. All of the loans were originated by First
Republic Bank (FRB, RMBS Primary Servicer rating: RPS2-). This is
the first post-2007-2008 global financial crisis issuance from
FRB.

The transaction is similar to other prime Fitch-rated transactions
with a standard senior-subordinate, shifting-interest deal
structure.

KEY RATING DRIVERS

Revised GDP Due to Pandemic: The coronavirus pandemic and resulting
containment efforts have resulted in revisions to Fitch's GDP
estimates for 2020. Its baseline global economic outlook for U.S.
GDP growth is a 5.6% decline for 2020, down from 1.7% growth in
2019. Fitch's downside scenario would see an even larger decline in
output in 2020 and a weaker recovery in 2021. To account for
declining macroeconomic conditions resulting from the pandemic, an
economic risk factor floor of 2.0 (the ERF is a default variable in
the US RMBS loan-loss model) was applied to 'BBBsf' and below.

Pandemic-Related Payment Deferrals (Negative): The outbreak of
COVID-19 and widespread containment efforts in the U.S. will
increase unemployment and disrupt cash flow. To account for the
cash flow disruption, Fitch assumed deferred payments on a minimum
of 25% of the pool for the first six months of the transaction at
all rating categories, with a reversion to its standard delinquency
and liquidation timing curve by month 10. This assumption is based
on observations of legacy Alt-A delinquencies and past-due payments
following Hurricane Maria in Puerto Rico.

High-Quality Mortgage Pool (Positive): The collateral attributes
are among the strongest of post-crisis RMBS rated by Fitch. The
pool consists of 10-year hybrid adjustable rate loans with a
30-year original term to maturity, which are predominately interest
only and made to high net worth borrowers with strong credit
profiles, low leverage and large liquid reserves. The loans are
seasoned an average of seven months.

The pool has a Fitch-calculated weighted-average original FICO
score of 771, which is indicative of high credit-quality borrowers.
Approximately 53.8% of the loans have an original FICO score at or
above 780. In addition, the original WA combined loan/value ratio
of 57.1% represents substantial borrower equity in the property.
The pool's attributes, together with FRB's sound origination
practices, support Fitch's low default risk expectations.

Low Operational Risk (Positive): Operational risk is controlled for
in this transaction. Fitch accesses FRB as an 'Above-Average'
originator. FRB has experienced senior management and staff that
cater to high net-worth individuals. It maintains strong risk
management and corporate governance controls and a robust due
diligence process. FRB is the primary servicer rated 'RPS2-' and
master servicing functions will be performed by Wells Fargo Bank,
N.A., rated 'RMS1-'. Fitch has affirmed all of its U.S. RMBS
servicer ratings and has revised the Outlooks to Negative where a
Negative Outlook was not already in place due to the evolving
economic stress and operating conditions caused by the pandemic.

Top Tier Representation and Warranty Framework (Positive): The
loan-level representation, warranty and enforcement framework is
consistent with Fitch's Tier 1, the highest possible. Fitch reduced
losses by 8bp 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 representations and
warranties provider backstop.

Acceptable Due Diligence Results (Positive): Third-party due
diligence was performed on all the loans in the transaction by
Clayton Services LLC, assessed as 'Acceptable - Tier 1' by Fitch.
The review did not identify material exceptions. There were no
credit or valuation exceptions to the guidelines for this
transaction and compliance exceptions were either cured or
considered non-material. Fitch applied a credit for the high
percentage of loan-level due diligence, which reduced the 'AAAsf'
loss expectation by 5bp.

Geographic Diversification (Negative): The pool is 48% concentrated
in California; approximately 69% is located in the top-three
metropolitan statistical areas - San Francisco, New York and Boston
- with 30% of the pool located in the San Francisco metropolitan
statistical area. The pool's regional concentration added 0.25% to
Fitch's 'AAAsf' loss expectations.

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

Subordination Floor (Positive): A CE or senior subordination floor
of 1.25% has been considered to mitigate potential tail-end risk
and loss exposure for senior tranches as pool size declines and
performance volatility increases due to adverse loan selection and
small-loan count concentration. A junior subordination floor of
1.00% has been considered to mitigate potential tail-end risk and
loss exposure for subordinate tranches as pool size declines and
performance volatility increases due to adverse loan selection and
small-loan count concentration.

Full Servicer Advancing (Mixed): First Republic Bank
(A-/Stable/F1/RPS2-/Negative) will provide full advancing for the
life of the transaction. The master servicer (Wells Fargo Bank,
N.A., (AA-/Negative/F1+/RMS1-/Negative) will advance if needed.
Although full principal and interest advancing will provide
liquidity to the certificates, it will also increase loan-level
loss severity, since the servicer looks to recoup principal and
interest advances from liquidation proceeds, which results in less
recoveries.

Extraordinary Expense Treatment (Neutral): The trust provides for
expenses, including indemnification amounts, reviewer fees and
costs of arbitration, to be paid by the net WA coupon of the loans,
which does not affect the contractual interest due on the
certificates. Furthermore, the expenses to be paid from the trust
are capped at $550,000 a year, with the exception of the cost to
engage an independent reviewer (if needed) and to negotiate a
breach review agreement with an independent reviewer, which can be
carried over each year, subject to the cap until paid in full.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analysis to demonstrate
how the ratings would react to steeper market value declines than
assumed at the metropolitan statistical area 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 be considered in the
surveillance of the transaction. Two sets of sensitivity analyses
were conducted at the state and national level to assess the effect
of higher MVDs for the subject pool.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

This defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model-projected 0.6% at 'AAA'. The analysis indicates that there is
some potential rating migration with higher MVDs for all rated
classes, compared with the model projection.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

This defined positive rating sensitivity analysis demonstrates how
the ratings would react to negative MVDs at the national level, or
in other words, positive home price growth with no assumed
overvaluation. The analysis assumes positive home price growth of
10.0%. Excluding the senior classes, which are already 'AAAsf', the
analysis indicates there is potential positive rating migration for
all of the rated classes.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in up and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Fitch has also added a coronavirus sensitivity analysis that
contemplates a more severe and prolonged economic stress caused by
a re-emergence of infections in major economies, before a slow
recovery begins in 2Q21. Under this severe scenario, Fitch expects
the ratings to be impacted by changes in its sustainable home price
model due to updates to the model's underlying economic data
inputs. Any long-term impact arising from coronavirus disruption on
these economic inputs will likely affect both investment and
speculative grade ratings.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Form "ABS Due Diligence 15E" was reviewed and used as a part of the
rating for this transaction, as prepared by Clayton.

Third-party due diligence was performed on all the loans in the
transaction by Clayton and is assessed as 'Acceptable - Tier 1'
TPR. The review scope includes review of credit, compliance, and
property valuation for each loan and is consistent with Fitch
criteria. The results indicate high-quality loan origination
practices that are consistent with non-agency prime RMBS. Fitch did
not apply any loss adjustments.

Approximately 7.7% of the loan pool (by loan count) was assigned a
final grade 'B', which is lower than prior prime jumbo RMBS, mainly
due to the updated SFA TRID 3.0 review by the TPR in-line with
Fitch. There were no credit or valuation exceptions to guidelines
for this transaction and the compliance exceptions were either
cured or considered non-material.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the pool. The third-party due diligence was
consistent with Fitch's "U.S. RMBS Rating Criteria". Clayton was
engaged to perform the review. Loans reviewed under this engagement
were given compliance, credit and valuation grades and assigned
initial grades for each subcategory. Minimal exceptions and waivers
were noted in the due diligence reports.

Fitch also utilized data files that were made available by the
issuer on its SEC Rule 17g-5 designated website. Fitch received
loan-level information based on the American Securitization Forum's
data layout format, and the data are considered to be
comprehensive. The ASF data tape layout was established with input
from various industry participants, including rating agencies,
issuers, originators, investors and others to produce an industry
standard for the pool-level data in support of the U.S. RMBS
securitization market. The data contained in the ASF layout data
tape were reviewed by the due diligence companies, and no material
discrepancies were noted.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

FRMT 2020-1 has an ESG Relevance Score of +4 for Transaction
Parties & Operational Risk. Operational risk is well controlled at
FRMT 2020-1 and includes strong RW&E and transaction due diligence
as well as a strong originator and service. This reduces expected
losses.

Except for the matters discussed, the highest level of ESG credit
relevance, if present, is a score of 3. This means ESG issues are
credit-neutral or have only a minimal credit impact on the
entity(ies), either due to their nature or to the way in which they
are being managed by the entity(ies).


FLAGSHIP CREDIT 2020-2: DBRS Gives Prov. BB Rating on Cl. E Notes
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
notes to be issued by Flagship Credit Auto Trust 2020-2 (the
Issuer):

-- $128,590,000 Class A Notes at AAA (sf)
-- $13,920,000 Class B Notes at AA (sf)
-- $24,410,000 Class C Notes at A (sf)
-- $18,840,000 Class D Notes at BBB (sf)
-- $14,240,000 Class E Notes at BB (sf)

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

(1) Transaction capital structure, proposed ratings, and form and
sufficiency of available credit enhancement.

-- Credit enhancement is in the form of over-collateralization
(OC), subordination, amounts held in the reserve fund, and excess
spread. Credit enhancement levels are sufficient to support the
DBRS Morningstar-projected cumulative net loss (CNL) assumption
under various stress scenarios.

-- DBRS Morningstar's projected CNL assumption includes an
assessment of how collateral performance could deteriorate because
of macroeconomic stresses related to the Coronavirus Disease
(COVID-19) pandemic. This assessment was guided by DBRS
Morningstar's set of macroeconomic scenarios for select economies
related to the coronavirus, available in its "Global Macroeconomic
Scenarios: Implications for Credit Ratings" commentary published on
April 16, 2020.

-- The transaction assumptions include an increase to the expected
loss. DBRS Morningstar applied transaction stresses in
consideration of its moderate and adverse scenarios in addition to
observed performance during the 2008–09 financial crisis and the
possible impact of stimulus from the Coronavirus Aid, Relief, and
Economic Security Act. In the moderate scenario for the United
States, DBRS Morningstar anticipates that containment of the
coronavirus will begin during Q2 2020, resulting in a gradual
relaxation of stay-at-home measures and nonessential business
closures and allowing a gradual economic recovery to begin starting
in Q3 2020.

(2) The ability of the transaction to withstand stressed cash flow
assumptions and repay investors according to the terms under which
they have invested. For this transaction, the ratings address the
timely payment of interest on a monthly basis and the payment of
principal by the legal final maturity date.

(3) The consistent operational history of Flagship Credit
Acceptance, LLC (Flagship or the Company), and the strength of the
overall Company and its management team.

-- The Flagship senior management team has considerable experience
and a successful track record within the auto finance industry.

(4) The capabilities of Flagship with regard to origination,
underwriting, and servicing.

-- DBRS Morningstar performed an operational review of Flagship
and considers the entity to be an acceptable originator and
servicer of subprime automobile loan contracts with an acceptable
backup servicer.

(5) DBRS Morningstar exclusively used the static pool approach
because Flagship has enough data to generate a sufficient amount of
static pool projected losses.

-- DBRS Morningstar was conservative in the loss forecast analysis
performed on the static pool data.

(6) The Company indicated that it may be subject to various
consumer claims and litigation seeking damages and statutory
penalties. Some litigation against Flagship could take the form of
class-action complaints by consumers; however, the Company
indicated that there is no material pending or threatened
litigation.

(7) The legal structure and presence of legal opinions that will
address the true sale of the assets to the Issuer, the
nonconsolidation of the special-purpose vehicle with Flagship, that
the trust has a valid first-priority security interest in the
assets, and the consistency with the DBRS Morningstar "Legal
Criteria for U.S. Structured Finance."

Flagship is an independent full-service automotive financing and
servicing company that provides (1) financing to borrowers who do
not typically have access to prime credit-lending terms for the
purchase of late-model vehicles and (2) refinancing of existing
automotive financing.

The rating on the Class A Notes reflects 41.95% of initial hard
credit enhancement provided by subordinated notes in the pool
(33.35%), the reserve account (2.00%), and OC (6.60%). The ratings
on Class B, Class C, Class D, and Class E Notes reflect 35.45%,
24.05%, 15.25%, and 8.60% of initial hard credit enhancement,
respectively. Additional credit support may be provided from excess
spread available in the structure.

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


GS MORTGAGE 2020-GC47: Fitch Rates 2 Tranches 'B-sf'
----------------------------------------------------
Fitch Ratings has assigned the following final ratings and Rating
Outlooks to GS Mortgage Securities Trust 2020-GC47 Commercial
Mortgage Pass-Through Certificates Series 2020-GC47:

RATING ACTIONS

  -- $3,688,000 class A-1 'AAAsf'; Outlook Stable;

  -- $190,000,000 class A-4 'AAAsf'; Outlook Stable;

  -- $310,694,000 class A-5 'AAAsf'; Outlook Stable;

  -- $8,900,000 class A-AB 'AAAsf'; Outlook Stable;

  -- $573,776,000a class X-A 'AAAsf'; Outlook Stable;

  -- $60,494,000 class A-S 'AAAsf'; Outlook Stable;

  -- $35,746,000 class B 'AA-sf'; Outlook Stable;

  -- $32,997,000 class C 'A-sf'; Outlook Stable;

  -- $22,914,000b class D 'BBBsf'; Outlook Stable;

  -- $17,415,000b class E 'BBB-sf'; Outlook Stable;

  -- $17,415,000ab class X-E 'BBB-sf'; Outlook Stable;

  -- $13,749,000b class F 'BB-sf'; Outlook Stable;

  -- $13,749,000ab class X-F 'BB-sf'; Outlook Stable;

  -- $7,332,000b class G 'B-sf'; Outlook Stable;

  -- $7,332,000ab class X-G 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $29,331,281b class H;

  -- $25,565,001bc class RR Interest;

  -- $13,027,646bc class RR.

(a) Notional amount and interest only.

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

(c) Vertical credit-risk retention interest.

Since Fitch published its expected ratings on May 4, 2020, the
expected ratings on the $68,743,000a class X-B and the
$22,914,000ab class X-D have been withdrawn because the classes
were removed from the final deal structure. Additionally, the
balances for class A-4 and class A-5 were finalized. At the time
that the expected ratings were assigned, the exact initial
certificate balances of class A-4 and class A-5 were unknown and
expected to be approximately $500,694,000 in aggregate. The final
class balances for class A-4 and class A-5 are $190,000,000 and
$310,694,000, respectively. The classes in the table reflect the
final ratings and deal structure.

Additionally, since Fitch published its expected ratings, Fitch
reviewed new information regarding three of the pool's loans, 711
Fifth Avenue, City National Plaza and Midland Atlantic Portfolio.
No changes were made to Fitch's ratings or the treatment of the
loans as a result of the new information.

711 Fifth Avenue (8.1% of pool; third largest loan): The property's
third largest tenant, Ralph Lauren (11.4% of NRA), has requested
rent relief with respect to the tenant's Polo Bar space (1.4% of
the tenant's total base rent). Fitch maintained its initial
analysis of the 711 Fifth Avenue loan given the Polo Bar space rent
accounts for only 0.1% of the property's total in-place rent and
Fitch's analysis includes a 29.1% economic vacancy factor.

City National Plaza (6.5% of pool; seventh largest loan): The
property's third largest tenant, Paul Hastings, LLP (5.6% of NRA
and 7.1% of in-place base rent), has requested rent relief and nine
other tenants(9.3% of NRA and 13.6% of in-place base rent) recently
began discussions with the sponsor regarding rent relief. Fitch
maintained its initial analysis of the City National Plaza loan
given the loan's robust structure that includes an upfront debt
service reserve equal to one years' worth of debt service
payments.

Midland Atlantic Portfolio (1.9% of pool; 18th largest loan): The
portfolio's sixth largest tenant, J.C. Penney (4.1% of NRA) filed
for Chapter 11 bankruptcy on May 15, 2020. In Fitch's cash flow
analysis, a vacancy stress of 7.7% was applied to in-place rents to
adjust occupancy down to the lower of in-place occupancy or 90%
occupancy for each property. Fitch maintained its initial analysis
of the Midland Atlantic Portfolio loan given Fitch's vacancy stress
exceeds J.C. Penney's total rent and recoveries.

TRANSACTION SUMMARY

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 29 loans secured by 60
commercial properties having an aggregate principal balance of
$771,852,928 as of the cut-off date. The loans were contributed to
the trust by Goldman Sachs Mortgage Securities and Citi Real Estate
Funding Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections and/or sponsor and
management conference calls on 69.4% of the properties by balance,
cash flow analysis of 97.4% of the pool, and asset summary reviews
on 100% of the pool.

Coronavirus Impact: The ongoing containment effort related to the
coronavirus pandemic may have an adverse impact on near-term
revenue (i.e. bad debt expense, rent relief) and operating expenses
(i.e. sanitation costs) for some properties in the pool.
Delinquencies may occur in the coming months as forbearance
programs are put in place, although the ultimate impact on credit
losses will depend heavily on the severity and duration of the
negative economic impact of the coronavirus pandemic, and to what
degree fiscal interventions by the U.S. federal government can
mitigate the impact on consumers. Per the offering documents, all
of the loans are current and not subject to any forbearance or
modification requests.

KEY RATING DRIVERS

Fitch Leverage Exceeds that of Recent Transactions: The pool has
slightly higher leverage than in other, recent, Fitch-rated
multiborrower transactions. The pool's Fitch LTV of 100.3% is
higher than the YTD 2020 average of 97.9%, but lower than the 2019
average of 103.0%. The pool's Fitch DSCR of 1.20x is lower than the
YTD 2020 average of 1.33x and the 2019 average of 1.26x.

Favorable Property Type Concentrations: The pool includes only
three loans (4.2% of pool) secured by retail properties and no
loans secured by hotel properties. Multifamily properties represent
the second largest concentration at 25.1%, which is higher than the
YTD 2020 and 2019 average multifamily concentrations of 20.4% and
16.9%, respectively. In Fitch's multiborrower model, multifamily
properties have a below-average likelihood of default, all else
equal. Office properties, which represent the largest concentration
at 54.1% of the pool, have an average likelihood of default in
Fitch's multiborrower model, all else equal.

Credit Opinion Loans: Six loans, representing 37.8% of the pool,
received investment-grade credit opinions. This is significantly
above the YTD 2020 and 2019 averages of 28.4% and 14.2%,
respectively. 1633 Broadway (8.4% of pool), Moffett Towers
Buildings A, B & C (8.4% of pool), 650 Madison Avenue (6.7% of
pool), 555 10th Avenue (6.5% of pool) and City National Plaza (6.5%
of pool) received stand-alone credit opinions of 'BBB-sf*'. 525
Market (1.3% of pool) received a stand-alone credit opinion of
'A-sf*'.

Very Limited Amortization: Nineteen loans (86.0% of pool) are
full-term interest-only (IO) loans, and eight loans (11.2% of pool)
are partial IO. Based on the scheduled balance at maturity, the
pool will pay down by only 1.8%, which is well below the YTD 2020
average of 4.3% and the 2019 average of 5.9%.

Concentrated Pool: The top 10 loans constitute 68.2% of the pool,
which is greater than the YTD 2020 average of 51.3% and the 2019
average of 51.0%. Additionally, the loan concentration index (LCI)
of 555 is greater than the YTD 2020 and 2019 average, both of which
are 379.

RATING SENSITIVITIES

This section provides insight into the sensitivity of ratings when
one assumption is modified, while holding others equal. For U.S.
CMBS, the sensitivity reflects the impact of changes to property
net cash flow (NCF) in up- and down-environments. The results
should only be considered as one potential outcome, as the
transaction is exposed to multiple dynamic risk factors. It should
not be used as an indicator of possible future performance.

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade:

Declining cash flow decreases property value and capacity to meet
its debt service obligations. The table indicates the model implied
rating sensitivity to changes in one variable, Fitch NCF:

Original Rating 'AAAsf' / 'AA-sf' / 'A-sf' / 'BBBsf' / 'BBB-sf' /
'BB-sf' / 'B-sf'

10% NCF Decline 'AA-sf' / 'A-sf' / 'BBBsf' / 'BB+sf' / 'BB-sf' /
'CCCsf' / 'CCCsf'

20% NCF Decline 'Asf' / 'BBBsf' / 'BB+sf' / 'B+sf' / 'CCCsf' /
'CCCsf' / 'CCCsf'

30% NCF Decline 'BBB+sf' / 'BBB-sf' / 'BB-sf' / 'CCCsf' / 'CCCsf' /
'CCCsf' / 'CCCsf'

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade:

Similarly, improvement in cash flow increases property value and
capacity to meet its debt service obligations. The table indicates
the model implied rating sensitivity to changes to the same one
variable, Fitch NCF:

Original Rating 'AAAsf' / 'AA-sf' / 'A-sf' / 'BBBsf' / 'BBB-sf' /
'BB-sf' / 'B-sf'

20% NCF Increase 'AAAsf' / 'AAAsf' / 'AA+sf' / 'A+sf' / 'BBB+sf' /
'BBBsf' / 'BBB-sf'


GS MORTGAGE-BACKED 2020-PJ3: Fitch Rates Class B-5 Certs 'B(EXP)'
-----------------------------------------------------------------
Fitch Ratings has assigned expected ratings to the residential
mortgage-backed certificates issued by GS Mortgage-Backed
Securities Trust 2020-PJ3.

GSMBS 2020-PJ3      

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

TRANSACTION SUMMARY

Fitch Ratings expects to rate the residential mortgage-backed
certificates issued by GS Mortgage-Backed Securities Trust
2020-PJ3. The transaction is expected to close on May 29, 2020. The
certificates are supported by 433 conforming and nonconforming
loans with a total balance of approximately $355.04 million as of
the cut-off date.

KEY RATING DRIVERS

Revised GDP due to COVID-19 (Negative): The coronavirus pandemic
and the resulting containment efforts have resulted in revisions to
Fitch's GDP estimates for 2020. Fitch's baseline global economic
outlook for U.S. GDP growth is currently a 5.6% decline for 2020,
down from 1.7% for 2019. Fitch's downside scenario would see an
even larger decline in output in 2020 and a weaker recovery in
2021. To account for declining macroeconomic conditions resulting
from the coronavirus, an Economic Risk Factor floor of 2.0 (the ERF
is a default variable in the U.S. RMBS loan loss model) was applied
to 'BBBsf' and below.

Compared to prior GSMBS-PJ transactions the new model had a 20
bps-25 bps impact at the non-investment-grade stresses.

Payment Holidays Related to Coronavirus (Negative): The outbreak of
the coronavirus and widespread containment efforts in the U.S. will
result in increased unemployment and cash flow disruptions. To
account for the cash flow disruptions, Fitch assumed delinquent
payments on a minimum of 25% of the pool for the first six months
of the transaction at all rating categories with a reversion to its
standard delinquency and liquidation timing curve by month 10. This
assumption is based on observations of past-due payments following
Hurricane Maria in Puerto Rico.

Due to the servicer advancing P&I payments, this stress does not
significantly impact the structure. Alternatively, the 'AAA' and
'AA' classes can withstand 7.75% of the borrowers offered a payment
deferral where their payment due date is moved to a future date and
not considered delinquent by the servicer for advancing.

As of the cut-off date, the issuer confirmed that no loans were
delinquent; no loans had entered a forbearance program, and the
servicer is not expected to defer scheduled payment dates.

P&I Advancement Recoupment (Mixed): To the extent that borrowers
enter into a coronavirus related payment forbearance plan, the
servicer will be required to make advances of principal and
interest to the bonds. While the advances will allow for timely
interest payments to the bonds, reimbursement of advances to the
servicer from funds other than those recovered by the borrower may
result in write-downs later in the life of the transaction, when
the loan is deemed modified due to a deferral of the missed
payments or advances are deemed to be nonrecoverable. To the extent
the missed interest payments during the forbearance period are not
capitalized, there could be a mismatch between what is paid on the
loans compared to what is due on the bonds. While the servicer will
continue to advance as long as such payment is not deemed to be a
nonrecoverable advance, the servicer will be able to fully repay
itself from collections on the date prior to the loan's final
maturity date resulting in potential write-downs to the most
subordinate bonds.

High-Quality Mortgage Pool (Positive): The collateral consists
primarily of 30-year FRM fully amortizing loans, seasoned
approximately two months in aggregate. Generally, the loans were
originated through the sellers' retail channels. The borrowers in
this pool have strong credit profiles (764 model FICO) and
relatively low leverage (71.7% sLTV). The collateral is a mix of
conforming agency eligible loans (21%) and nonconforming
prime-jumbo loans (79%). The 111 conforming loans have an average
balance of $627,475 compared with a balance of $824,960 for the
nonconforming loans. The conforming loans have a lower FICO (755
versus 767) and a higher LTV (69.8% versus 68.2%).

Shifting-Interest Deal Structure (Negative): The mortgage cash flow
and loss allocation are based on a senior-subordinate,
shifting-interest structure, whereby the subordinate classes
receive only scheduled principal and are locked out from receiving
unscheduled principal or prepayments for five years. While there is
only minimal leakage to the subordinate bonds early in the life of
the transaction, the structure is more vulnerable to defaults
occurring at a later stage compared to a sequential or modified
sequential structure. To help mitigate tail risk, which arises as
the pool seasons and fewer loans are outstanding, a subordination
floor of 1.50% of the original balance will be maintained for the
senior certificates and a subordination floor of 1.05% of the
original balance will be maintained for the subordinate
certificates.

Representation Framework (Negative): The loan-level representation,
warranty and enforcement framework are consistent with Tier 2
quality. Fitch increased its loss expectations by 39 bps at the
'AAAsf' rating category as a result of the Tier 2 framework and the
underlying sellers supporting the repurchase obligations of the
RW&E providers. The Tier 2 framework was driven by the inclusion of
knowledge qualifiers without a claw back provision and the narrow
testing construct, which limits the breach reviewers' ability to
identify or respond to issues not fully anticipated at closing.

Low Operational Risk (Neutral): Operational risk is well controlled
for in this transaction. Goldman Sachs is assessed as an 'Above
Average' aggregator by Fitch due to its robust sourcing strategy
and seller oversight, experienced senior management and staff,
strong risk management and corporate governance controls. Primary
and master servicing responsibilities are performed by Shellpoint
Mortgage Servicing (Shellpoint) and Wells Fargo, which are rated by
Fitch as 'RPS2-' and 'RMS1-', respectively.

Due Diligence Review Results (Positive): Third-party due diligence
was performed on 100% of loans in the transaction. Due diligence
was performed by AMC, Consolidated Analytics, Digital Risk and Opus
which are assessed by Fitch as 'Acceptable - Tier 1', 'Acceptable -
Tier 3', 'Acceptable - Tier 2' and 'Acceptable - Tier 2',
respectively. The review scope is consistent with Fitch criteria,
and the results are generally similar to prior prime RMBS
transactions. Credit exceptions were supported by strong mitigating
factors and compliance exceptions were primarily cured with
subsequent documentation. Fitch applied a credit for the high
percentage of loan level due diligence, which reduced the 'AAAsf'
loss expectation by 25 bps.

RATING SENSITIVITIES

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper 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 that may be considered in
the surveillance of the transaction. Sensitivity analyses was
conducted at the state and national levels to assess the effect of
higher MVDs for the subject pool as well as lower MVDs, illustrated
by a gain in home prices.

Factors that could, individually or collectively, lead to negative
rating action/downgrade: This defined negative rating sensitivity
analysis demonstrates how the ratings would react to steeper MVDs
at the national level. The analysis assumes MVDs of 10.0%, 20.0%
and 30.0% in addition to the model-projected 4.6% at 'AAA'. The
analysis indicates that there is some potential rating migration
with higher MVDs for all rated classes, compared with the model
projection.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

This defined positive rating sensitivity analysis demonstrates how
the ratings would react to negative MVDs at the national level or,
in other words, positive home price growth with no assumed
overvaluation. The analysis assumes positive home price growth of
10.0%. Excluding the senior classes which are already 'AAAsf', the
analysis indicates there is potential positive rating migration for
all of the rated classes.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in up and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Fitch has also added a Coronavirus Sensitivity Analysis that
contemplates a more severe and prolonged economic stress caused by
a re-emergence of infections in the major economies, before a slow
recovery begins in 2Q21. Under this severe scenario, Fitch expects
the ratings to be impacted by changes in its sustainable home price
model due to updates to the model's underlying economic data
inputs. Any long-term impact arising from coronavirus disruptions
on these economic inputs will likely affect both investment and
speculative grade ratings.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

A due diligence review was completed on 100% of the loans in this
transaction. Each loan received a full due diligence scope of
credit, compliance and property valuation, which is consistent with
Fitch's criteria.

Form "ABS Due Diligence 15E" was reviewed and used as a part of the
rating for this transaction.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the pool. The third-party due diligence was
generally consistent with Fitch's "U.S. RMBS Rating Criteria."
Opus, SitusAMC Consolidated Analytics, and Digital Risk were
engaged to perform the review. Loans reviewed under this engagement
were given compliance, credit and valuation grades, and assigned
initial grades for each subcategory. Minimal exceptions and waivers
were noted in the due diligence reports.

Fitch also utilized data files that were made available by the
issuer on its SEC Rule 17g-5 designated website. Fitch received
loan-level information based on the American Securitization Forum's
(ASF) data layout format, and the data are considered to be
comprehensive. The ASF data tape layout was established with input
from various industry participants, including rating agencies,
issuers, originators, investors and others to produce an industry
standard for the pool-level data in support of the U.S. RMBS
securitization market. The data contained in the ASF layout data
tape were reviewed by the due diligence companies, and no material
discrepancies were noted.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


HOMEWARD OPPORTUNITIES 2020-1: DBRS Finalizes B Rating on B2 Notes
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage Pass-Through Certificates, Series 2020-1 (the
Certificates) issued by Homeward Opportunities Fund I Trust 2020-1
(HOF I 2020-1 or the Trust):

-- $144.7 million Class A-1 at AAA (sf)
-- $15.7 million Class A-2 at AA (sf)
-- $14.1 million Class A-3 at A (sf)
-- $14.1 million Class M-1 at BBB (sf)
-- $13.2 million Class B-1 at BB (sf)
-- $13.2 million Class B-1A at BB (sf)
-- $13.2 million Class B-1AX at BB (sf)
-- $13.2 million Class B-1B at BB (sf)
-- $13.2 million Class B-1BX at BB (sf)
-- $13.2 million Class B-1C at BB (sf)
-- $13.2 million Class B-1CX at BB (sf)
-- $13.2 million Class B-1D at BB (sf)
-- $13.2 million Class B-1DX at BB (sf)
-- $13.2 million Class B-1E at BB (sf)
-- $13.2 million Class B-1EX at BB (sf)
-- $13.2 million Class B-1F at BB (sf)
-- $13.2 million Class B-1FX at BB (sf)
-- $13.2 million Class B-1G at BB (sf)
-- $13.2 million Class B-1GX at BB (sf)
-- $13.3 million Class B-2 at B (sf)

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

The AAA (sf) rating on the Class A-1 Certificates reflects 36.80%
of credit enhancement provided by subordinate Certificates. The AA
(sf), A (sf), BBB (sf), BB (sf), and B (sf) ratings reflect 29.95%,
23.80%, 17.65%, 11.90%, and 6.10% of credit enhancement,
respectively.

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate prime, expanded prime, and nonprime first-lien
residential mortgages funded by the issuance of the Certificates.
The Certificates are backed by 492 mortgage loans with a total
principal balance of $228,890,726 as of the Cut-Off Date (April 1,
2020).

The originators for the mortgage pool are 5th Street Capital, Inc.
(42.8%), Sprout Mortgage Corporation (41.0%), and other
originators, each comprising less than 6.0% of the mortgage loans.
Specialized Loan Servicing LLC (62.4%), Fay Servicing, LLC (31.4%),
and Lima One Capital, LLC (6.2%) will service all loans within the
pool.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's (CFPB) Qualified Mortgage (QM) and
Ability-to-Repay (ATR) rules, they were made to borrowers who
generally do not qualify for an agency, government, or
private-label nonagency prime jumbo products for various reasons.
In accordance with the QM/ATR rules, 58.3% of the loans are
designated as non-QM. Approximately 41.7% of the loans are made to
investors for business purposes and, hence, are not subject to the
QM/ATR rules.

Homeward Opportunities Fund I LP (HOF I) is the Sponsor and the
Servicing Administrator of the transaction. HOF I Asset Selector
LLC serves as the Asset Selector for securitizations sponsored by
HOF I and, for this transaction, determined which mortgage loans
would be included in the pool. The Sponsor, Depositor,
Administrator, Asset Selector, and Servicing Administrator are
affiliates of the same entity.

Wells Fargo Bank, N.A. (rated AA with a Stable trend by DBRS
Morningstar) will act as the Master Servicer. U.S. Bank National
Association (rated AA (high) with a Stable trend by DBRS
Morningstar) will serve as the Trustee, Securities Administrator,
Certificate Registrar, and Custodian.

The Sponsor, directly or indirectly through a majority-owned
affiliate, will retain an eligible horizontal residual interest in
at least 5% of the Certificates (the Class B-3 and X Certificates)
issued by the Trust, to satisfy the credit risk-retention
requirements under Section 15G of the Securities Exchange Act of
1934 and the regulations promulgated thereunder.

On or after the earlier of (1) the three-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, the Depositor has the option to purchase all outstanding
Certificates at a price equal to the outstanding class balance plus
accrued and unpaid interest, including any cap carryover amounts.
After such a purchase, the Depositor then has the option to
complete a qualified liquidation, which requires (1) a complete
liquidation of assets within the Trust and (2) proceeds to be
distributed to the appropriate holders of regular or residual
interests.

The Sponsor will have the option, but not the obligation, to
repurchase any mortgage loan (other than loans under the
forbearance plan as of the Closing Date) that becomes 90 or more
days delinquent or are real estate owned at the repurchase price
(par plus interest), provided that such repurchases in aggregate do
not exceed 10% of the total principal balance as of the Cut-Off
Date.

Unlike prior HOF non-QM securitizations where the servicers fund
advances of delinquent principal and interest (P&I) on loans that
become 180 days delinquent, for this transaction, the Servicers
will only fund advances for 30 days of delinquent P&I. The
Servicers, however, are obligated to make advances in respect of
taxes, insurance premiums, and reasonable costs incurred in the
course of servicing and disposing of properties. The one-month
advancing mechanism may significantly increase the probability of
periodic interest shortfalls in the current economic environment
affected by the Coronavirus Disease (COVID-19). As a large number
of borrowers seek forbearance on their mortgages in the coming
months, P&I collections may be reduced meaningfully.

Also unlike prior HOF non-QM (or traditional non-QM)
securitizations that incorporate a pro-rata feature among the
senior tranches, this transaction employs a sequential-pay cash
flow structure across the entire capital stack. Principal proceeds
can be used to cover interest shortfalls on the Certificates as the
outstanding senior Certificates are paid in full. Furthermore, the
excess spread can be used to cover realized losses and prior period
bond writedown amounts first before being allocated to unpaid cap
carryover amounts to Class A-1 up to Class B-1.

The coronavirus pandemic and resulting isolation measures have
caused an economic contraction, leading to sharp increases in
unemployment rates and income reductions for many consumers. DBRS
Morningstar anticipates that delinquencies may arise in the coming
months for much residential mortgage-backed security (RMBS) asset
classes—some meaningfully.

The non-QM sector is a traditional RMBS asset class that consists
of securitizations backed by pools of residential home loans that
may fall outside of the CFPB's ATR rules, which became effective on
January 10, 2014. Non-QM loans encompass the entire credit
spectrum. They range from high-FICO, high-income borrowers who opt
for interest-only or higher debt-to-income ratio mortgages, to
near-prime debtors who have had certain derogatory pay histories
but were cured more than two years ago, to nonprime borrowers whose
credit events were only recently cleared. In addition, some
originators offer alternative documentation or bank statement
underwriting to self-employed borrowers in lieu of verifying income
with W-2s or tax returns. Finally, foreign nationals and real
estate investor programs, while not necessarily non-QM in nature,
are often included in non-QM pools.

As a result of the coronavirus, DBRS Morningstar expects increased
delinquencies and loans on forbearance plans, slower voluntary
prepayment rates, and a potential near-term decline in the values
of the mortgaged properties. Such deteriorations may adversely
affect borrowers' ability to make monthly payments, refinance their
loans, or sell properties in an amount sufficient to repay the
outstanding balance of their loans.

In connection with the economic stress assumed under its moderate
scenario (see the DBRS Morningstar commentary titled "Global
Macroeconomic Scenarios: Implications for Credit Ratings,"
published on April 16, 2020), for the non-QM asset class, DBRS
Morningstar assumes a combination of higher unemployment rates,
lower voluntary prepayment rates and more conservative home price
assumptions than what DBRS Morningstar previously used. In
addition, for pools with loans on forbearance plans, DBRS
Morningstar may assume higher loss expectations above and beyond
the coronavirus assumptions. Such assumptions translate to higher
expected losses on the collateral pool and correspondingly higher
credit enhancement.

In the non-QM asset class, while the full effect of the coronavirus
may not occur until a few performance cycles later, DBRS
Morningstar generally believes loans originated to (1) borrowers
with recent credit events, (2) self-employed borrowers, or (3)
higher loan-to-value ratio (LTV) borrowers may be more sensitive to
economic hardships resulting from higher unemployment rates and
lower incomes. Borrowers with prior credit events have exhibited
difficulties in fulfilling payment obligations in the past and may
revert to spotty payment patterns in the near term. Self-employed
borrowers are potentially exposed to more volatile income sources,
which could lead to reduced cash flows generated from their
businesses. Higher LTV borrowers, with lower equity in their
properties, generally have fewer refinance opportunities and
therefore slower prepayments. In addition, certain pools with
elevated geographic concentrations in densely populated urban
metropolitan statistical areas may experience additional stress
from extended lockdown periods and the slowdown of the economy.

In addition, for this transaction, as permitted by the Coronavirus
Aid, Relief, and Economic Security Act, which was signed into law
on March 27, 2020, 19.1% of the borrowers are on forbearance plans
because of financial hardship related to the coronavirus. These
forbearance plans allow temporary payment holidays for three months
followed by repayment once the forbearance period ends. For these
loans, DBRS Morningstar applied additional assumptions to evaluate
the impact of potential cash flow disruptions on the rated
tranches, stemming from (1) lower P&I collections and (2) limited
servicing advances on delinquent P&I. These assumptions include the
following:

(1) Increasing delinquencies to generally two times (x) the
forbearance percentage as of the Closing Date for the AAA (sf) and
AA (sf) rating levels for the first 12 months,
(2) Increasing delinquencies to generally 1.5x the forbearance
percentage as of the Closing Date for the first nine months for the
A (sf) and below rating levels, and
(3) Assuming no voluntary prepayments for the first 12 months for
the AAA (sf) and AA (sf) rating levels.

For more information regarding rating methodologies and the
coronavirus, please see the following DBRS Morningstar press
releases and commentaries: "DBRS Morningstar Provides Update on
Rating Methodologies in Light of Measures to Contain Coronavirus
Disease (COVID-19)," dated March 12, 2020; "DBRS Morningstar Global
Structured Finance Rating Methodologies and Coronavirus Disease
(COVID-19)," dated March 20, 2020; and "Global Macroeconomic
Scenarios: Implications for Credit Ratings."

The ratings reflect transactional strengths that include the
following:

-- Robust loan attributes and pool composition,
-- Satisfactory third-party due diligence review,
-- Improved underwriting standards,
-- Compliance with the ATR rules, and
-- Current loans and faster prepayments.

The transaction also includes the following challenges:

-- Borrowers on forbearance plans,
-- One-month servicer advances of delinquent P&I,
-- Representations and warranties framework,
-- Certain nonprime, non-QM, and investor loans,
-- Servicers' financial capability, and
-- High loan amounts.

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


IMSCI 2013-4: Fitch Cuts Rating on 2 Tranches to CCsf
-----------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed five
classes of Institutional Mortgage Securities Canada Inc.'s (IMSCI)
Commercial Mortgage Pass-Through Certificates series 2013-4.

IMSCI 2013-4

  - Class A-1 45779BBT5; LT AAAsf; Affirmed

  - Class A-2 45779BBU2; LT AAAsf; Affirmed

  - Class B 45779BBW8; LT AAsf; Affirmed

  - Class C 45779BBX6; LT Asf; Affirmed

  - Class D 45779BBY4; LT BBBsf; Affirmed

  - Class E 45779BBZ1; LT BBsf; Downgrade

  - Class F 45779BBH1; LT CCCsf; Downgrade

  - Class G 45779BBJ7; LT CCsf; Downgrade

KEY RATING DRIVERS

Increasing Loss Expectations: The downgrades to classes E, F, and G
are due to the increase in loss expectations since Fitch's last
rating action. Loss expectations have increased as a result of
collateral underperformance of several loans in the pool including
five Fitch Loans of Concern that account for 30.7% of the current
pool balance. The majority of the increase in expected loss is due
to the Nelson Ridge loan (10.3%). The increase in loss expectations
is offset by the improvement in credit enhancement on the senior
classes and low historical delinquency and loss rates associated
with Canadian CMBS loans. Additionally, most of the FLOCs are
structured with recourse, and the sponsors have continued to fund
debt service shortfalls.

Improved Credit Enhancement: Credit enhancement has improved since
issuance due to loan amortization and payoffs. As of the April 2020
distribution date, the pool's aggregate principal balance has been
reduced by 49.6% to $166.6 million from $330.4 million at issuance.
There are no specially serviced or delinquent loans, and one loan
(10.0%) is defeased.

Canadian Loan Attributes and Historical Performance: The
affirmations reflect strong historical Canadian commercial real
estate loan performance, as well as positive loan attributes, such
as short amortization schedules, recourse to the borrower and
additional guarantors. Approximately 60.5% of the loans in the pool
reflect full or partial recourse.

Fitch Loans of Concern: The largest FLOC is Festival Marketplace
(11.8%), a shopping center in Stratford, ON where major tenants
include Winners, Hart, and Sport Chek. Sears closed in January
2018, resulting in a decline in occupancy and cash flow. The Sears
space was partially re-leased to Hart, and the borrower is in
negotiations with an additional tenant. As of March 2020, the
property was 81% occupied, and, per the most recent financials from
YE 2018, the borrower reported a 1.13x NOI DSCR.

The second largest FLOC is Nelson Ridge (10.3%), a 225-unit
multifamily property in Fort McMurray, AB, which transferred to
special servicing in early 2016 due to a decline in operating
performance. The property was affected by the decline in oil prices
and occupancy declined to a low of only 45% in 2015. Subsequently,
the property was affected by the area wildfires in May 2016;
however, the loan returned to master servicing in January 2017. The
loan was scheduled to mature in December 2018 and is currently in
forbearance through November 2020. According to the servicer, the
property was 69% occupied in November 2019, and as of December
2018, NOI DSCR was 0.50x. Fitch's loss expectations were based on
an assumed reduction in cash flow given the exposure to the oil
industry and continued poor performance. No credit was given to the
recourse.

Energy Market Concentration: Two loans, Nelson Ridge (10.3%) and
Franklin Suites (5.2%), totaling 15.5% of the pool, have
experienced substantial performance declines as a result of a
sustained decline in oil and gas prices. These loans are located in
Fort McMurray, and both have exhibited DSCRs at or below 1.00x
since YE 2016.

Coronavirus: The pool contains one loan (5.9%) secured by a hotel
with a debt service coverage ratio (DSCR) of 0.86x. Retail
properties account for 49.6% of the pool balance and have weighted
average DSCR of 1.40x. Cash flow disruptions are expected as a
result of property and consumer restrictions due to the spread of
coronavirus; however, the rating actions are primarily the result
of the continued underperformance of the two properties with
exposure to the energy market.

Pool Concentration: The pool has become concentrated, with only 13
of the original 30 loans remaining when accounting for
cross-collateralized and cross-defaulted loans.

RATING SENSITIVITIES

The Negative Outlooks on classes C, D, and E reflect the potential
for a near term rating changes should the performance of FLOCs
deteriorate, specifically Nelson Ridge and Franklin Suites. The
Stable Outlooks on classes A- 1, A-2, and B reflect the overall
stable performance of the pool and expected continued
amortization.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Factors that lead to upgrades would include stable to improved
asset performance coupled with paydown and/or defeasance. Upgrades
of classes B and C may occur with significant improvement in credit
enhancement or defeasance but would be limited should the deal be
susceptible to a concentration whereby the underperformance of
FLOCs could cause this trend to reverse. An upgrade to class D
would also consider these factors but would be limited based on
sensitivity to concentrations or the potential for future
concentration. Classes would not be upgraded above 'Asf' if there
is a likelihood of interest shortfalls. An upgrade to classes E, F,
and G is not likely until the later years in a transaction and only
if there are better than expected recoveries on Fitch Loans of
Concern and the performance of the remaining pool is stable, and if
there is sufficient credit enhancement, which would likely occur
when the non-rated class is not eroded and the senior classes
payoff. While high expected losses on loans of concern continue to
impact the pool, upgrades are extremely unlikely.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that lead to downgrades include an increase in pool level
losses from underperforming loans. Downgrades to the super-senior
classes, A-1 and A-2, are not likely due to the position in the
capital structure and the high credit enhancement but could occur
if interest shortfalls occur or if a high proportion of the pool
defaults and expected losses increase significantly. Downgrades to
classes B, C, and D may occur and be one category or more should
overall pool losses increase or if several large loans have an
outsized loss, properties vulnerable to the coronavirus fail to
stabilize to pre-pandemic levels and/or Fitch Loans of Concern
transfer to special servicing. Downgrades to class E would occur
should loss expectations increase due to an increase in specially
serviced loans, the disposition of a specially serviced loan/asset
at a high loss, or a decline in the performance of FLOCs. Further
downgrades to the distressed classes F and G will occur if losses
are considered probable or inevitable or if losses are realized.
The Negative Rating Outlooks on classes B, C, D, and E may be
revised back to Stable if performance of the FLOCs improves and/or
properties vulnerable to the coronavirus stabilize once the
pandemic is over.

In addition to its baseline scenario, Fitch also envisions a
downside scenario where the health crisis is prolonged beyond 2021;
should this scenario play out, Fitch expects that a greater
percentage of classes may be assigned a Negative Rating Outlook or
those with Negative Rating Outlooks will be downgraded one or more
categories.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


JP MORGAN 2010-C1: Fitch Affirms D Ratings on 4 Tranches
--------------------------------------------------------
Fitch Ratings has affirmed six classes of JP Morgan Chase
Commercial Mortgage Securities Trust, commercial mortgage pass
through certificates, series 2010-C1.

J.P. Morgan Chase Commercial Mortgage Securities Trust 2010-C1

  - Class C 46634NAU0; LT BBsf; Affirmed

  - Class D 46634NAX4; LT Csf; Affirmed

  - Class E 46634NBA3; LT Dsf; Affirmed

  - Class F 46634NBD7; LT Dsf; Affirmed

  - Class G 46634NBG0; LT Dsf; Affirmed

  - Class H 46634NBK1; LT Dsf; Affirmed

KEY RATING DRIVERS

Increased Credit Enhancement; Stable Loss Expectations: The
affirmations reflect increased credit enhancement since Fitch's
last rating action from continued amortization and the payoff of
six loans (approximately $115 million balance at disposition).
Although an additional asset transferred to the special servicer
since the last rating action, loss expectations have remained
relatively stable. As of the April 2020 distribution date, the
pool's aggregate principal balance had paid down by 96% to $28.8
million from $716.3 million at issuance. One loan (35.6%) is a low
leveraged self-storage portfolio with a YE 2019 NOI DSCR of 2.77x.
The other two remaining assets are REO with uncertain disposition
dates. Realized losses since issuance total $46.2 million (6.5% of
original pool balance). Cumulative interest shortfalls totaling
$5.2 million are currently impacting classes D, E, and NR.

Pool Concentration/Adverse Selection: The transaction is highly
concentrated with only three of the original 39 loans/assets
remaining. Due to the concentrated nature of the pool, Fitch
performed a sensitivity analysis that grouped the remaining loans
based on the likelihood of repayment and expected losses from the
liquidation of specially serviced loans. The ratings reflect this
sensitivity analysis.

REO Assets: The Aquia Office Building is 99,492 SF suburban office
building located in Stafford, VA. The asset transferred to the
special servicer for a second time in June 2016 after the borrower
was unable to refinance at the modified maturity date. The asset
became REO through a deed-in-lieu of foreclosure in August 2016.
Property occupancy has improved significantly to 60% from the
historical low of 31% in 2014 when TASC, the former largest tenant
that occupied 61% of NRA, exercised its lease termination option
and vacated. The borrower and master developer are in ongoing
settlement discussions after failed litigation pertaining to the
area around the office building due to unreasonable parking/CAM
expenses.

The Del Alba Plaza is 72,014 SF grocery-anchored retail center
located in Pittsfield, MA. The asset transferred to the special
servicer in June 2019 for imminent monetary default after the
grocery anchor, Stop & Shop (92% of NRA),did not renew their lease
that expired 10/31/2019. Following the loan transfer, the special
servicer was able to negotiate a new lease with Stop & Shop which
has since been executed. A deed in-lieu of foreclosure took place
in December 2019.

Coronavirus Exposure: The third largest asset is an REO retail
property and comprises 23.7% of the pool. Retail properties will be
challenged by a decline in shopping and property closures. Fitch's
loss assumption was based on a discount to the updated appraisal
value. Additional stresses were not applied as the grocer anchor
renewed their lease (however, at a lower rental rate) and is an
essential business and remains open.

RATING SENSITIVITIES

The Stable Rating Outlook on class C reflects the high CE and
overall stable performance of the pool since the prior rating
action.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Upgrades are currently not expected due to adverse selection and
the high concentration specially serviced assets. Factors that
would lead to an upgrade on Class C would include an improvement in
valuations on the REO assets or better recoveries than currently
anticipated. Class D would only be upgraded if recoveries on the
specially serviced assets are significantly better than expected.
Classes E and below will not be upgraded as they have already
realized losses. Classes would not be upgraded above 'Asf' if there
is likelihood for interest shortfalls, which could occur with a
significant reduction in servicing advancing if appraisal values
decline.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that lead to downgrades include an increase in expected
losses from specially serviced loans and/or if the one performing
loan defaults at maturity. Downgrade to class C could occur if
losses on the REO assets significantly exceed Fitch's expectations.
Downgrades to the distressed class D will occur if losses are
realized. Classes E and below are defaulted.

Fitch also envisions a downside scenario where the health crisis is
prolonged beyond 2021; should this scenario play out, Fitch expects
negative rating actions, including downgrades or Negative Rating
Outlook revisions if the performing loan defaults at maturity and
the resolution of the REO assets becomes protracted and expected
losses increase.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


JPMCC COMMERCIAL 2017-JP7: Fitch Affirms Cl. G-RR Certs at Bsf
--------------------------------------------------------------
Fitch Ratings has affirmed 15 classes and revised the Rating
Outlook on one class of JPMCC Commercial Mortgage Securities Trust
(JPMCC) 2017-JP7 commercial mortgage pass-through certificates.

RATING ACTIONS

JPMCC 2017-JP7

Class A-1 465968AA3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 465968AB1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 465968AC9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 465968AD7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-5 465968AE5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 465968AJ4;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 465968AF2; LT AAAsf Affirmed;  previously at AAAsf

Class B 465968AK1;    LT AA-sf Affirmed;  previously at AA-sf

Class C 465968AL9;    LT A-sf Affirmed;   previously at A-sf

Class D 465968AM7;    LT BBBsf Affirmed;  previously at BBBsf

Class E-RR 465968AP0; LT BBB-sf Affirmed; previously at BBB-sf

Class F-RR 465968AR6; LT BBsf Affirmed;   previously at BBsf

Class G-RR 465968AT2; LT Bsf Affirmed;    previously at Bsf

Class X-A 465968AG0;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 465968AH8;  LT A-sf Affirmed;   previously at A-sf

KEY RATING DRIVERS

Increased Loss Expectations: While the majority of the loans in the
pool continue to exhibit stable performance, loss expectations have
increased primarily due to the increasing number of Fitch Loans of
Concern. Since Fitch's last rating action, the Carolina Hotel
Portfolio (2.0% of the pool) transferred to special servicing and
is secured by five limited service hotels totaling 511-keys located
in North Carolina and South Carolina. The loan transferred to
special servicing in April 2020 due to imminent default at the
borrower's request due to the coronavirus pandemic, and the special
servicer is evaluating next steps. The portfolio has exhibited
overall stable performance with a net operating income (NOI) debt
service coverage ratio (DSCR) as of the year end (YE) 2019 of 1.64x
from 2.01x at YE 2018. Per the most recent Smith Travel Research
(STR) report for the TTM ended Sept. 30, 2019, the overall weighted
average portfolio RevPAR penetration rate was 96.7%. Only one
property, the Holiday Inn Express & Suites Goldsboro Base Area,
reported a RevPAR penetration rate above 100%. The loan is
currently 30 days delinquent.

Outside of the specially serviced loan, five loans (14.0% of the
pool) are considered Fitch Loans of Concern (FLOCs) due to upcoming
rollover concerns. The largest FLOC, 211 Main Street (5.6% of the
pool), is secured by a 417,266 square foot (sf) office property
located in San Francisco, CA. The property currently serves as the
corporate headquarters of Charles Schwab (A/F1). However, per
recent news articles, as part of the firm's merger with TD
Ameritrade, Charles Schwab indicated its intention to move its
corporate headquarters to the Dallas, TX area. Fitch has requested
further updates from the master servicer.

The second largest FLOC, the Crystal Corporate Center (2.8% of the
pool), is secured by a 128,411 sf office property located in Boca
Raton, FL. The property's occupancy improved to 94.1% as of
year-end (YE) 2019, from 87.0% at YE 2018. The most recent NOI DSCR
as of Sept. 30, 2019 was 1.48x up from 1.23x at YE 2018. Despite
the improved performance, approximately 35% of the leases expire
between 2020 and 2021, including the top tenant, BFW Advertising
(7.1% of the NRA). Fitch requested a leasing update from the master
servicer but has not received a response.

The third largest FLOC, the Marriott Park City (2.6% of the pool),
is secured by a 199-key hotel located in Park City, UT. As of YE
2019, the property occupancy, average daily rate (ADR) and revenue
per available room (RevPAR) were reported at 60.9%, $188 and $114
from 54.5%, $185, and $101 at YE 2018. Per the most recent STR
report as of TTM December 2019, the RevPAR penetration rate was
reported at 96.9%. The property's NOI DSCR as of YE 2019 was 2.41x
up from 2.04x at YE 2018. Despite the improved performance, the
loan is currently 30 days delinquent. The loan also failed to meet
the property specific coronavirus NOI DSCR tolerance thresholds and
additional stresses were applied to the loan to address the
expected declines in performance related to coronavirus pandemic.

The fourth largest FLOC, Springhill Suites Newark Airport (2.3% of
the pool), is secured by a 200-key hotel located in Newark, NJ
within close proximity to Newark Airport. As of YE 2019, property
occupancy was 86.9% from 89.6% at YE 2018. Per the most recent STR
report as of YE 2019, the RevPAR penetration rate was 115.3%. The
most recent NOI DSCR as of YE 2019 declined to 1.23x from 1.54x at
YE 2018. Per the master servicer, the property has been undergoing
a property improvement plan (PIP) which impacted occupancy. Fitch
requested an update from the master servicer. The loan also failed
to meet the property specific coronavirus NOI DSCR tolerance
thresholds and additional stresses were applied to the loan to
address the expected declines in performance related to coronavirus
pandemic.

The remaining FLOC is less than 1% of the pool and is secured by a
96-key hotel located in San Antonio, TX.

Minimal Change to Credit Enhancement: As of the May 2020
remittance, the pool's aggregate principal balance has been reduced
by 1.4% to $800 million from $811 million at issuance. There are no
defeased loans. Eight loans (50.8% of the pool) are interest only,
including seven loans (50% of the pool) that are within the top 15.
Nineteen loans (31% of the pool) have partial interest only
payments, 16 of which (25% of the pool) are now amortizing. The
remaining loans in the pool (19% of the pool) are amortizing.

Coronavirus Exposure: Significant economic impact to certain
hotels, retail and multifamily properties is expected from the
coronavirus pandemic, due to the recent and sudden reductions in
travel and tourism, temporary property closures and lack of clarity
at this time on the potential length of the impact. The pandemic
has already prompted the closure of several hotel properties in
gateway cities as well as malls, entertainment venues and
individual stores. Six loans (16% of the pool) are secured by hotel
properties. The weighted average (WA) debt service coverage ratio
(DSCR) for all hotel loans in the pool is approximately 2.43x. On
average, the hotel loans could sustain a 57.6% decline in NOI
before the actual DSCR would fall below 0.95x coverage.

Ten loans (20.4% of the pool) are secured by retail properties. The
WADSCR for the retail loans is 2.04x and on average, the retail
loans could sustain a 49.6% decline in NOI before the actual NOI
DSCR would fall below 0.95x. As part of its base case scenario,
Fitch applied additional stresses to three hotel loans and three
retail loans to address the expected declines related to the
coronavirus pandemic; these stresses contributed to the Negative
Outlook revision for class F-RR.

Investment-Grade Credit Opinion Loans: Two loans in the top 15
(13.1%) received standalone investment-grade credit opinions at
issuance. 245 Park Avenue (9.4%) received a credit opinion of
'BBB-sf' and West Town Mall (3.7%) received a credit opinion of
'BBBsf' at issuance.

RATING SENSITIVITIES

Near-term rating changes are limited, as indicated by the
sufficient CE, continued amortization, relatively stable
performance of the pool as evidenced by the Stable Outlooks on
classes A-1 through E-RR. The Negative Outlooks on classes F-RR and
G-RR reflect performance concerns with hotel and retail properties
due to the decline in travel and commerce as a result of the
coronavirus pandemic.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Factors that could lead to upgrades would include stable to
improved asset performance, coupled with additional pay down and/or
defeasance. Upgrades to the 'A-sf' and 'AA-sf' rated classes would
likely occur with significant improvement in CE and/or defeasance;
however, adverse selection and increased concentrations, or the
underperformance of the FLOCs could cause this trend to reverse.

Upgrades of the 'BBB-sf' and below-rated classes are considered
unlikely and would be limited based on the sensitivity to
concentrations or the potential for future concentrations. Classes
would not be upgraded above 'Asf' if there is a likelihood for
interest shortfalls. An upgrade to the 'BB-sf' and 'B-sf' rated
classes is not likely until the later years in the transaction and
only if the performance of the remaining pool is stable and/or if
there is sufficient credit enhancement, which would likely occur
when the non-rated class is not eroded and the senior classes pay
off.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that could lead to downgrades include an increase in pool
level losses due to underperforming or specially serviced loans.
Downgrades to the senior classes, rated 'AA-sf' through 'AAAsf',
are not likely due to the position in the capital structure and the
high credit enhancement; however, downgrades of these classes may
occur should interest shortfalls occur. Downgrades to the classes
rated 'BBB-sf' and below would occur if the performance of the
Fitch Loans of Concern continue to decline or fail to stabilize.
The Rating Outlook on class F-RR and G-RR may be revised back to
Stable if performance of the FLOCs improves and/or properties
vulnerable to the coronavirus stabilize once the pandemic is over.

In addition to its baseline scenario, Fitch also envisions a
downside scenario where the health crisis is prolonged beyond 2021;
should this scenario play out, Fitch expects that a greater
percentage of classes may be assigned a Negative Outlook or those
with Negative Rating Outlooks will be downgraded one or more
categories.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


LB-UBS COMMERCIAL 2005-C3: Moody's Cuts Class H Debt Rating to C
----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings on three classes
and downgraded the rating on one class in LB-UBS Commercial
Mortgage Trust 2005-C3:

Cl. F, Affirmed B1 (sf); previously on Feb 8, 2019 Affirmed B1
(sf)

Cl. G, Affirmed Caa2 (sf); previously on Feb 8, 2019 Affirmed Caa2
(sf)

Cl. H, Downgraded to C (sf); previously on Feb 8, 2019 Affirmed Ca
(sf)

Cl. X-CL*, Affirmed C (sf); previously on Feb 8, 2019 Affirmed C
(sf)

* Reflects interest-only classes

RATINGS RATIONALE

The ratings on two P&I classes were affirmed because the ratings
are consistent with Moody's expected principal recovery and losses
from the remaining specially serviced loans.

The rating on Cl. H was downgraded due to realized losses plus
anticipated losses from the remaining specially serviced loans.
Class H has already realized a 27% loss from previously liquidated
loans.

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

Its analysis has considered the effect of the coronavirus outbreak
on the US economy as well as the effects that the announced
government measures, put in place to contain the virus, will have
on the performance of commercial real estate. Stress on commercial
real estate properties will be most directly stemming from declines
in hotel occupancies (particularly related to conference or other
group attendance) and declines in foot traffic and sales for
non-essential items at retail properties.

The contraction in economic activity in the second quarter will be
severe and the overall recovery in the second half of the year will
be gradual. However, there are significant downside risks to its
forecasts in the event that the pandemic is not contained and
lockdowns have to be reinstated. As a result, the degree of
uncertainty around its forecasts is unusually high. Moody's regards
the coronavirus outbreak as a social risk under its ESG framework,
given the substantial implications for public health and safety.

Moody's rating action reflects a base expected loss of 13.2% of the
current pooled balance, compared to 8.9% at Moody's last review.
Moody's base expected loss plus realized losses is now 4.5% of the
original pooled balance, compared to 4.6% at the last review.

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

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

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

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

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 loans to the most junior classes and the recovery as a pay
down of principal to the most senior classes.

DEAL PERFORMANCE

As of the May 15, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $32.2 million
from $1.97 billion at securitization. The certificates are
collateralized by two remaining mortgage loans secured by retail
properties that have transferred to special servicing since April
2020.

Twenty loans have been liquidated from the pool, resulting in an
aggregate realized loss of $84.6 million (for an average loss
severity of 43%).

The largest specially serviced loan is the Medlock Crossing Loan
($27.4 million -- 85.1% of the pool), which is secured by a 159,000
square feet (SF) retail center located in Duluth, Georgia,
approximately 30 miles northeast of the Atlanta CBD. The property
is anchored by a 70,700 SF, 18-screen, Regal Cinema (44% of the
NRA), whose lease extends through February 2024. The property was
96% leased as of September 2019, compared to 100% in September
2018. The loan transferred to special servicing in April 2020 due
to its inability to pay off at its May 2020 maturity date. The loan
has amortized 15% since securitization.

The other specially serviced loan is the Chambersburg Loan ($4.8
million -- 14.9% of the pool), which is secured by a 139,000 SF
retail center located in Chambersburg, Pennsylvania. The property
recently lost its K-Mart (60% of the NRA) anchor, which vacated at
its lease expiration in December 2019. Excluding K-Mart the
occupancy would be approximately 32%, compared to 92% leased as of
December 2019. The loan transferred to special servicing in April
2020 due its inability to refinance at its April 2020 maturity
date. The loan has amortized by 15% since securitization.


MORGAN STANLEY 2014-C16: Fitch Affirms CCC Rating on Class D Debt
-----------------------------------------------------------------
Fitch Ratings has revised the Rating Outlooks on 18 classes from
nine U.S. CMBS conduit transactions from the 2014 vintage to
Negative from Stable. In addition, 13 classes from two transactions
were removed from Rating Watch Negative and affirmed; 12 of these
classes were assigned Negative Outlooks and one class has a
distressed 'CCCsf' rating. Fitch has also revised the Rating
Outlooks to Stable from Positive on three classes from two
transactions.

Fitch reviewed the following three 2014 transactions, JPMBB
2014-C21, JPMBB 2014-C22 and COMM 2014-CCRE19, in the past four
weeks, and assigned Negative Rating Outlooks at that time. No
further actions were taken on these three deals for this review.

As part of the review, Fitch analyzed its entire portfolio of 2014
U.S. CMBS conduit transactions, which consists of 32 deals. The
review focused solely on the impact of the coronavirus pandemic on
the transactions. Including the transactions listed, 27
transactions from the 2014 vintage now have at least one class with
a Negative Outlook. Five transactions have Stable Rating Outlooks
on all outstanding classes.

RATING ACTIONS

Morgan Stanley Bank of America Merrill Lynch Trust 2014-C16

Class B 61763MAJ9;   LT AA-sf Affirmed; previously AA-sf

Class C 61763MAL4;   LT A-sf Affirmed;  previously A-sf

Class D 61763MAR1;   LT BBsf Affirmed;  previously BBsf

Class E 61763MAT7;   LT CCCsf Affirmed; previously CCCsf

Class PST 61763MAK6; LT A-sf Affirmed;  previously A-sf

Class X-B 61763MAM2; LT AA-sf Affirmed; previously AA-sf

JPMBB 2014-C19

Class E 46641WAJ6; LT BBsf Revision Outlook; previously BBsf

COMM 2014-CCRE20

Class E 12592LAQ5; LT BB-sf Revision Outlook; previously BB-sf

Class F 12592LAS1; LT B-sf Revision Outlook;  previously B-sf

JPMBB 2014-C18

Class D 46641JAE6; LT BBB-sf Revision Outlook; previously BBB-sf

COMM 2014-UBS6

Class D 12592PAJ2;   LT BBB-sf Revision Outlook; previously BBB-sf


Class X-C 12592PAC7; LT BBB-sf Revision Outlook; previously BBB-sf


CGCMT 2014-GC19

Class C 17322AAH5;   LT Asf Revision Outlook; previously Asf

Class PEZ 17322AAL6; LT Asf Revision Outlook; previously Asf

COMM 2014-CCRE21

Class D 12592RAL3;   LT BBB-sf Revision Outlook; previously BBB-sf


Class E 12592RAN9;   LT BB+sf Revision Outlook;  previously BB+sf

Class X-C 12592RAC3; LT BBB-sf Revision Outlook; previously BBB-sf


JPMBB 2014-C25

Class D 46643PAN0;   LT BBB-sf Revision Outlook; previously BBB-sf


Class X-D 46643PAE0; LT BBB-sf Revision Outlook; previously BBB-sf


COMM 2014-CCRE17

Class E 12631DAJ2; LT BBsf Revision Outlook; previously BBsf

Morgan Stanley Bank of America Merrill Lynch Trust 2014-C15

Class B 61763KBD5;   LT AAsf Affirmed;   previously AAsf

Class C 61763KBF0;   LT Asf Affirmed;    previously Asf

Class D 61763KAE4;   LT BBB-sf Affirmed; previously BBB-sf

Class E 61763KAG9;   LT BB+sf Affirmed;  previously BB+sf

Class F 61763KAJ3;   LT BB-sf Affirmed;  previously BB-sf

Class PST 61763KBE3; LT Asf Affirmed;    previously Asf

Class X-B 61763KAA2; LT AAsf Affirmed;   previously AAsf

JPMBB 2014-C23

Class B 46643ABK8;   LT AAsf Revision Outlook; previously AAsf

Class F 46643AAL7;   LT Bsf Revision Outlook;  previously Bsf

Class X-D 46643AAC7; LT Bsf Revision Outlook;  previously Bsf

GSMS 2014-GC18

Class B 36252RBC2;   LT Asf Revision Outlook;   previously Asf

Class C 36252RBJ7;   LT BBBsf Revision Outlook; previously BBBsf

Class PEZ 36252RBF5; LT BBBsf Revision Outlook; previously BBBsf

Class X-B 36252RAW9; LT Asf Revision Outlook;   previously Asf

KEY RATING DRIVERS

The Negative Rating Outlooks reflect the potential for future
downgrades stemming from an increase in expected losses due to
Fitch's anticipation of a significant negative economic impact and
property performance deterioration due to the coronavirus pandemic.
Near-term cash flow performance is expected to decline on certain
properties. However, it is difficult to discern at this time which
loans will ultimately default and whether the default will result
in losses to the trust given the lack of clarity about the length
of the pandemic and permanence of the performance declines.

As described in Fitch's "Update on Response on Coronavirus Related
Reviews for North American CMBS", published on April 13, 2020,
Fitch continues to incorporate its baseline scenario from its
Global Economic Outlook into its analysis.

For property sectors highly vulnerable to the coronavirus pandemic,
Fitch has assumed significant declines in cash flow occurring over
the next two to four months: for hotel, a 65% decline; for retail,
a 45% decline; and for multifamily, a 20% decline. After applying
the declines to cash flow, Fitch assumed any loan with a resulting
debt service coverage ratio (DSCR) of less than 0.95x would have a
75% probability of default. For the hotel sector, the cash flow
stress is roughly equivalent to a loan with the most recent
servicer-reported DSCR of 2.75x moving to 0.95x; for retail, the
most recent servicer-reported DSCR of 1.75x moving to 0.95x; and
for multifamily, the most recent servicer-reported DSCR of 1.20x
moving to 0.95x. Although Fitch expects significant defaults for
properties that suffer the harshest short-term cash flow declines,
some well-capitalized sponsors will be willing and able to support
their properties through this period, particularly those in high
demand locations. Fitch does not expect loans to be liquidated in
any great number prior to the end of 2Q21, when the agency's
"Global Economic Outlook" envisages a slow recovery will be under
way. The expected losses for the loans assumed to default were
calculated by applying Fitch's stressed cap rate to the most recent
servicer-reported NOI less a haircut of 26% for hotel, 20% for
retail and 15% for multifamily. Fitch's stressed cap rates
generally range between 10.25%-13.50% for hotel, 8.00%-11.25% for
retail and 8.00%-10.00% for multifamily.

Fitch did not apply distinct coronavirus stresses for office and
industrial properties; however, individual factors such as tenancy,
lease term, demand drivers and location were considered. For
example, single-tenant office properties with unrated tenants and
office properties with significant exposure to co-working tenants
were assumed likely to default.

The rating actions at this time were limited to Negative Rating
Outlooks. Over the next few months, Fitch will monitor the
performance of the loans in the transactions to evaluate if actual
defaults are occurring in line with Fitch's expectations. A
significant divergence to the downside may accelerate ratings
downgrades. Otherwise, ratings changes, if any, will likely occur
in 2021 with a clearer view of how an economic recovery is
affecting property performance and values.

Additionally, all of the transactions will be subject to their
annual review over the next 12 months, and Fitch's analysis will
incorporate adjustments, both less and more stressful, if
warranted, based on idiosyncratic features of the loans and
properties.

The transactions that were not assigned Negative Rating Outlooks
had several common factors, including increased credit enhancement
(CE) from paydowns and/or defeasance, lower concentrations of loans
to sectors vulnerable to the pandemic and/or higher DSCRs relative
to Fitch's assumptions on default risk.

By rating category, a summary of the current ratings and
transaction characteristics of the 30 classes from the 11
transactions with Negative Outlook revisions or assignments is
included:

Four classes from two transactions in the 'AAsf' category. These
two transactions include: MSBAM 2014-C15 and MSBAM 2014-C16;
Average hotel concentration of 26% (ranging between 25%-26%);
Average retail concentration of 33% (ranging between 30%-36%).

Six classes from three transactions in the 'Asf' category. These
three transactions include: GSMS 2014-GC18, MSBAM 2014-C15 and
MSBAM 2014-C16; Average hotel concentration of 20% (ranging between
7%-26%); Average retail concentration of 37% (ranging between
30%-45%).

Ten classes from five transactions in the 'BBBsf' category. These
five transactions include: COMM 2014-UBS6, GSMS 2014-GC18, JPMBB
2014-C18, JPMBB 2014-C25 and MSBAM 2014-C15; Average hotel
concentration of 15% (ranging between 7%-25%); Average retail
concentration of 36% (ranging between 25%-57%).

Seven classes from six transactions in the 'BBsf' category; this
represents 26% of the total number of classes rated in the 'BBsf'
category from the 2014 vintage. These six transactions include:
COMM 2014-CR17, COMM 2014-CR20, COMM 2014-CR21, JPMBB 2014-C19,
MSBAM 2014-C15 and MSBAM 2014-C16; Average hotel concentration of
20% (ranging between 14%-26%); Average retail concentration of 35%
(ranging between 25%-57%).

Three classes from two transactions in the 'Bsf' category; this
represents 12% of the total number of classes rated in the 'Bsf'
category from the 2014 vintage. These two transactions include:
COMM 2014-CR20 and JPMBB 2014-C23; Average hotel concentration of
20% (ranging between 17%-23%); Average retail concentration of 25%
(ranging between 23%-29%).

The Rating Outlooks on two classes from the CGCMT 2014-GC19
transaction and one class from the JPMBB 2014-C23 transaction were
revised to Stable from Positive.

Fitch will be reviewing its entire portfolio and expects to release
updated rating actions for each vintage, with the 2011 through 2013
vintages transactions to follow.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Upgrades, although not likely in the near term, would occur with
stable to improved asset performance coupled with paydown and/or
defeasance. The Negative Rating Outlooks may be revised back to
Stable if overall pool performance and/or properties vulnerable to
the coronavirus stabilize to pre-pandemic levels. Classes with
Negative Outlooks in the 'AAAsf', 'AAsf' and 'Asf' categories may
be more likely to be revised back to Stable should CE or defeasance
increase significantly. Prior to any classes being upgraded,
adverse selection, sensitivity to concentrations and/or the
potential for future concentration would be taken into
consideration. Classes would not be upgraded above 'Asf' if there
is a likelihood of interest shortfalls.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that could lead to downgrade include an increase in
expected pool level losses from underperforming or specially
serviced loans. Downgrades of one category or more to the classes
assigned Negative Rating Outlooks would occur if expected losses
increase, or a high proportion of the pool defaults and/or
properties vulnerable to the coronavirus fail to return to
pre-pandemic levels. The severity of the downgrades would be based
on the level of CE relative to losses. Below-investment grade
classes with Negative Outlooks would likely be downgraded first, as
losses would impact these classes sooner.

In addition to its baseline scenario related to the coronavirus,
Fitch also envisions a downside scenario where the health crisis is
prolonged beyond 2021; should this scenario play out, Fitch expects
that a greater percentage of classes may be assigned a Negative
Rating Outlook and/or those with Negative Rating Outlooks may be
downgraded by a greater magnitude.


MSBAM 2013-C11: Fitch Affirms Bsf Rating on Class F Debt
--------------------------------------------------------
Fitch Ratings has revised the Rating Outlooks on 11 classes from 10
U.S. CMBS conduit transactions from the 2013 vintage to Negative
from Stable. In addition, seven classes from one transaction were
removed from Rating Watch Negative and affirmed; five of these
classes were assigned Negative Outlooks, one class was assigned a
Stable Outlook and one class has a distressed 'CCCsf' rating. Fitch
has also revised the Rating Outlooks to Stable from Positive on six
classes from four transactions.

Fitch reviewed two 2013 transactions, COMM 2013-CCRE9 and GSMS
2013-GCJ13, in the past four weeks, and assigned Negative Rating
Outlooks at that time. No further actions were taken on these two
deals for this review. Fitch is also currently in the process of
reviewing the WFRBS 2013-C16 transaction, where five classes remain
on Rating Watch Negative.

Fitch analyzed its portfolio of 2013 U.S. CMBS conduit
transactions, which consists of 31 deals. The review focused solely
on the impact of the coronavirus pandemic on the transactions.
Including the transactions listed above, 22 transactions from the
2013 vintage now have at least one class with a Negative Outlook.
Eight transactions have Stable Rating Outlooks on all outstanding
classes.

RATING ACTIONS

MSBAM 2013-C10

Class E 61762MBE0; LT BBB-sf Revision Outlook; previously BBB-sf

Class F 61762MBG5; LT BB+sf Revision Outlook;  previously BB+sf

WFRBS 2013-C11

Class B 92937EAG9; LT AAsf Revision Outlook; previously AAsf

Class F 92937EAN4; LT Bsf Revision Outlook;  previously Bsf

GS Mortgage Securities Trust 2013-GC10

Class D 36192CAQ8; LT BBB-sf Revision Outlook; previously BBB-sf

JPMCC 2013-C16

Class E 46641BAR4; LT BBsf Revision Outlook; previously BBsf

CGCMT 2013-GCJ11

Class B 17320DAQ1; LT AAsf Revision Outlook; previously AAsf

Class F 17320DAY4; LT Bsf Revision Outlook;  previously Bsf

JPMBB 2013-C15

Class B 46640NAK4;   LT AAsf Revision Outlook; previously AAsf

Class C 46640NAL2;   LT Asf Revision Outlook;  previously Asf

Class X-B 46640NAH1; LT AAsf Revision Outlook; previously AAsf

COMM 2013-CCRE13

Class B 12630BBD9; LT AAsf Revision Outlook; previously AAsf

UBS-BB 2013-C6

Class F 90349GAW5; LT Bsf Revision Outlook; previously Bsf

WFRBS 2013-C18

Class D 96221QAM5; LT BBB-sf Revision Outlook; previously BBB-sf

MSBAM 2013-C12

Class F 61762XAG2; LT BB-sf Revision Outlook; previously BB-sf

MSBAM 2013-C11

Class A-S 61762TAG1; LT AAAsf Affirmed; previously AAAsf

Class B 61762TAH9;   LT AA-sf Affirmed; previously AA-sf

Class C 61762TAK2;   LT A-sf Affirmed;  previously A-sf

Class D 61762TAN6;   LT BBsf Affirmed;  previously BBsf

Class E 61762TAQ9;   LT Bsf Affirmed;   previously Bsf

Class F 61762TAS5;   LT CCCsf Affirmed; previously CCCsf

Class PST 61762TAJ5; LT A-sf Affirmed;  previously A-sf

JPMBB 2013-C17; previously  ; previously  

Class E 46640UAP7; LT BBsf Revision Outlook; previously BBsf

CGCMT 2013-GC17

Class F 17321RAR7; LT Bsf Revision Outlook; previously Bsf

KEY RATING DRIVERS

The Negative Rating Outlooks reflect the potential for future
downgrades stemming from an increase in expected losses due to
Fitch's anticipation of a significant negative economic impact and
property performance deterioration due to the coronavirus pandemic.
Near-term cash flow performance is expected to decline on certain
properties. However, it is difficult to discern at this time which
loans will ultimately default and whether the default will result
in losses to the trust given the lack of clarity about the length
of the pandemic and permanence of the performance declines.

As described in Fitch's "Update on Response on Coronavirus Related
Reviews for North American CMBS" published on April 13, 2020, Fitch
continues to incorporate its baseline scenario from its Global
Economic Outlook into its analysis.

For property sectors highly vulnerable to the coronavirus pandemic,
Fitch has assumed significant declines in cash flow occurring over
the next two to four months: for hotel, a 65% decline; for retail,
a 45% decline; and for multifamily, a 20% decline. After applying
the declines to cash flow, Fitch assumed any loan with a resulting
debt service coverage ratio (DSCR) of less than 0.95x would have a
75% probability of default. For the hotel sector, the cash flow
stress is roughly equivalent to a loan with the most recent
servicer-reported DSCR of 2.75x moving to 0.95x; for retail, the
most recent servicer-reported DSCR of 1.75x moving to 0.95x; and
for multifamily, the most recent servicer-reported DSCR of 1.20x
moving to 0.95x. Although Fitch expects significant defaults among
for properties that suffer the harshest short-term cash flow
declines, some well-capitalized sponsors will be willing and able
to support their properties through this period, particularly those
in high demand locations. Fitch does not expect loans to be
liquidated in any great number prior to the end of 2Q21, when the
agency's "Global Economic Outlook" envisages a slow recovery will
be under way. The expected losses for the loans assumed to default
were calculated by applying Fitch's stressed cap rate to the most
recent servicer-reported NOI less a haircut of 26% for hotel, 20%
for retail and 15% for multifamily. Fitch's stressed cap rates
generally range between 10.25%-13.50% for hotel, 8.00%-11.25% for
retail and 8.00%-10.00% for multifamily.

Fitch did not apply distinct coronavirus stresses for office and
industrial properties; however, individual factors such as tenancy,
lease term, demand drivers and location were considered. For
example, single-tenant office properties with unrated tenants and
office properties with significant exposure to co-working tenants
were assumed likely to default.

The rating actions at this time were limited to Negative Rating
Outlooks. Over the next few months, Fitch will monitor the
performance of the loans in the transactions to evaluate if actual
defaults are occurring in line with Fitch's expectations. A
significant divergence to the downside may accelerate ratings
downgrades. Otherwise, ratings changes, if any, will likely occur
in 2021 with a clearer view of how an economic recovery is
affecting property performance and values.

Additionally, all of the transactions will be subject to their
annual review over the next 12 months, and Fitch's analysis will
incorporate adjustments, both less and more stressful, if
warranted, based on idiosyncratic features of the loans and
properties.

The transactions that were not assigned Negative Rating Outlooks
had several common factors, including increased credit enhancement
(CE) from paydowns and/or defeasance, lower concentrations of loans
to sectors vulnerable to the pandemic and/or higher DSCRs relative
to Fitch's assumptions on default risk.

By rating category, a summary of the current ratings and
transaction characteristics of the 16 classes from the 11
transactions with Negative Outlook revisions or assignments is
included:

One class in the 'AAsf' category and two classes in the 'Asf'
category from the MSBAM 2013-C11 transaction, which has a hotel
concentration of 21% and a retail concentration of 43%.

Three classes from three transactions in the 'BBBsf' category.

  -- These three transactions include: GSMS 2013-GC10, MSBAM
2013-C10 and WFRBS 2013-C18;

  -- Average hotel concentration of 11% (ranging between 4%-19%);

  -- Average retail concentration of 39% (ranging between
30%-45%).

Five classes from five transactions in the 'BBsf' category; this
represents 16% of the total number of classes rated in the 'BBsf'
category from the 2013 vintage.

  -- These five transactions include: JPMBB 2013-C17, JPMCC
2013-C16, MSBAM 2013-C10, MSBAM 2013-C11 and MSBAM 2013-C12;

  -- Average hotel concentration of 13% (ranging between 9%-21%);

  -- Average retail concentration of 32% (ranging between
15%-43%).

Five classes from five transactions in the 'Bsf' category; this
represents 19% of the total number of classes rated in the 'Bsf'
category from the 2013 vintage.

  -- These five transactions include: CGCMT 2013-GCJ11, CGCMT
2013-GC17, MSBAM 2013-C11, UBSBB 2013-C6 and WFRBS 2013-C11;

  -- Average hotel concentration of 13% (ranging between 9%-21%);

  -- Average retail concentration of 38% (ranging between
13%-60%).

The Rating Outlooks on one class from the CGCMT 2013-GCJ11
transaction, one class from the COMM 2013-CCRE13 transaction, three
classes from the JPMBB 2013-C15 transaction and one class from the
WFRBS 2013-C11 transaction were revised to Stable from Positive. A
Stable Outlook was assigned to one class in the MSBAM 2013-C11
transaction, which had previously been on Rating Watch Negative.

Fitch will be reviewing its entire portfolio and expects to release
updated rating actions for each vintage, with the 2011 and 2012
vintage transactions to follow.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Upgrades, although not likely in the near term, would occur with
stable to improved asset performance coupled with paydown and/or
defeasance. The Negative Rating Outlooks may be revised back to
Stable if overall pool performance and/or properties vulnerable to
the coronavirus stabilize to pre-pandemic levels. Classes with
Negative Outlooks in the 'AAAsf', 'AAsf' and 'Asf' categories may
be more likely to be revised back to Stable should CE or defeasance
increase significantly. Prior to any classes being upgraded,
adverse selection, sensitivity to concentrations and/or the
potential for future concentration would be taken into
consideration. Classes would not be upgraded above 'Asf' if there
is a likelihood of interest shortfalls.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that could lead to downgrade include an increase in
expected pool level losses from underperforming or specially
serviced loans. Downgrades of one category or more to the classes
assigned Negative Rating Outlooks would occur if expected losses
increase, or a high proportion of the pool defaults and/or
properties vulnerable to the coronavirus fail to return to
pre-pandemic levels. The severity of the downgrades would be based
on the level of CE relative to losses. Below-investment grade
classes with Negative Outlooks would likely be downgraded first, as
losses would impact these classes sooner.

In addition to its baseline scenario related to the coronavirus,
Fitch also envisions a downside scenario where the health crisis is
prolonged beyond 2021; should this scenario play out, Fitch expects
that a greater percentage of classes may be assigned a Negative
Rating Outlook and/or those with Negative Rating Outlooks may be
downgraded by a greater magnitude. No third-party due diligence was
provided or reviewed in relation to this rating action.


NATIONAL COLLEGIATE 2005-1: Fitch Cuts Class C Notes Rating to Dsf
------------------------------------------------------------------
Fitch Ratings has downgraded National Collegiate Student Loan Trust
2005-1/NCF Grantor Trust 2005-1's class C notes to 'Dsf' from
'Csf'. The Rating Watch Negative was maintained on NCSLT 2005-1's
class A-5 notes, while the class B notes were affirmed at 'CCsf'.

The downgrade of the class C notes to 'Dsf' reflects the occurrence
of an event of default for the class C notes on the March 2020
payment date.

The affirmations of class B notes and the maintained RWN on class
A-5 notes reflect available credit enhancement and the outstanding
CFPB proposed judgment, for which there have been no substantive
updates since last review. As such, Fitch maintains 'BBsf' or
'BBBsf' rating caps across all NCSLT transactions and the RWN on
all notes with ratings of 'Bsf' or above.

RATING ACTIONS

National Collegiate Student Loan Trust 2005-1/NCF Grantor Trust
2005-1

  - Class A-5 1 63543PBM7; LT BBsf; Rating Watch Maintained

  - Class A-5 2 63543PBN5; LT BBsf; Rating Watch Maintained

  - Class B 63543PBK1; LT CCsf; Affirmed

  - Class C 63543PBL9; LT Dsf; Downgrade

KEY RATING DRIVERS

Class C Event of Default:

On the March 2020 payment date, the class C note interest trigger
was cured (pool of assets plus the reserve greater than outstanding
A-5 and B notes) making the outstanding accrued but unpaid class C
interest due and payable on the March payment date. Due to
insufficient funds to pay the total amount due as class C interest,
an event of default notice was serviced by the administrator. The
event of default cured on the April 2020 payment date.

Collateral Performance:

NCSLT 2005-1 is collateralized by private student loans originated
by First Marblehead Corporation. At deal inception, all loans were
guaranteed by The Education Resources Institute (TERI); however, no
credit is given to the TERI guaranty since TERI filed for
bankruptcy on April 7, 2008. Fitch has increased its assumption of
constant default rate to 4.00% from 3.50%. The recovery rate was
assumed to be 0% in light of recent lawsuit uncertainty between the
trusts and defaulted borrowers.

Payment Structure:

On the March 2020 payment date, the senior and total parity was
173.27% and 73.06%. The class C note interest rate trigger was
cured causing the funds in the reserve account to be used as
available funds as there was an interest shortfall on the class C
notes. There was still an interest shortfall on the class C notes
of $477,586 causing an event of default.

On the April 2020 payment date, the senior and total parity
decreased to 163.20% and 68.81%, respectively. The class C note
interest rate trigger re-triggered causing the available funds to
reinstate up to the required reserve amount balance. The event of
default cured upon the re-triggering of the class C note interest
trigger.

Operational Capabilities:

Pennsylvania Higher Education Assistance Agency services roughly
98% of the trusts, with Nelnet servicing the rest. US Bank N.A.
acts as special servicer for the trusts. Fitch believes all
servicers are acceptable servicers of private student loans.

Nevertheless, Fitch understands that a lawsuit to call a servicer
default under the transaction documents against PHEAA was initiated
by some of the holders of the beneficial interest in the NCSLT
trusts. Despite the uncertainty on the outcome of pending
litigations between transaction parties, including PHEAA, Fitch
believes such risk is addressed by the rating cap at 'BBsf' for
this trust and Fitch's conservative assumptions on defaults and
recoveries.

Coronavirus Impact:

Fitch has made assumptions about the spread of the coronavirus and
the economic impact of the related containment measures. Under the
coronavirus baseline scenario, Fitch assumes a global recession in
1H20 driven by sharp economic contractions in major economies with
a rapid spike in unemployment, followed by a recovery that begins
in 3Q20 as the health crisis subsides. Fitch increased its base
case CDR assumption to 4.00% from 3.50% to take into account the
effects of the pandemic on the portfolio, assuming a short-term
peak of CDR followed by a plateau in line with previous 3.50%
assumption.

RATING SENSITIVITIES

Rating sensitivities provide greater insight into the model-implied
sensitivities the transaction faces when one or two risk factors
are stressed while holding others equal. The results should only be
considered as one potential outcome, as the transaction is exposed
to multiple risk factors that are all dynamic variables.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Positive rating actions are not likely until there is resolution of
the outstanding CFPB judgement. As Fitch's base case default and
recovery assumptions are derived primarily from historical
collateral performance. Actual performance that is materially
better than these assumptions will increase CE and the remaining
loss coverage levels available to the notes, which may result in
positive rating action.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Fitch expects to resolve the RWN on the class A-5 notes as soon as
additional information is available on the effects (if any) of the
proposed CFPB judgement on the affected NCSLT trusts. Allocation of
the settlement payment (if confirmed and applicable) to one or a
few NCSLTs trusts in a short period of time may result in
multi-category downgrades on the affected trusts. Allocation of the
payment across all trusts over a longer horizon may result in
smaller downgrades or no rating actions.

Under Fitch's Baseline Coronavirus scenario, when increasing
assumed the base case default rate by 10%, 25% and 50% in
accordance with Fitch's U.S. Private Student Loan ABS Rating
Criteria, there would be no expected rating change due to the
rating cap on the trust following the CFPB proposed judgment.

Under Fitch's Coronavirus Downside Scenario, Fitch considers a more
severe and prolonged period of stress with a halting recovery
beginning in 2Q21. To reflect this greater stress, Fitch ran
sensitivities in line with 'BBsf' and 'BBBsf' default rates where
base case default assumptions were increased by about 35% and 85%,
respectively. Under this scenario, due to the rating cap on the
trust following the CFPB proposed judgment, there would be no
expected rating change for the bonds.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

National Collegiate Student Loan Trust 2005-1/NCF Grantor Trust
2005-1: Customer Welfare - Fair Messaging, Privacy & Data Security:
5

NCSLT 2005-1 has an ESG Relevance Score of 5 for customer welfare
due to compliance with consumer protection related regulatory
requirements, such as fair/transparent lending, data security, and
safety standards, which has a negative impact on the credit
profile, and is highly relevant to the rating, resulting in capping
the ratings at 'BBBsf' as well as placing the non-distressed notes
on Rating Watch Negative.


ORANGE LAKE 2019-A: Fitch Puts BB on Class D Notes on Watch Neg.
----------------------------------------------------------------
Fitch Ratings has placed all outstanding ratings for Orange Lake
Timeshare Trust series 2018-A and 2019-A on Rating Watch Negative,
and has revised the Rating Outlook for all outstanding ratings for
series 2016-A to Negative from Stable. In addition, the outstanding
ratings for series 2014-A and 2015-A have been affirmed.

The Rating Watch Negative was driven by increasing delinquencies
and defaults, which are materially higher than predecessor OLLT
transactions and Fitch's initial expectation. The social and market
disruption caused by the coronavirus pandemic and related
containment measures has negatively impacted the U.S. economy. To
account for the potential impact on the outstanding OLTT ABS
trusts, Fitch incorporated conservative assumptions in deriving
revised base case CGD proxies for each trust. The analysis focused
on peak extrapolations from prior recessionary highs on the
2006-2009 vintages as a starting point and making adjustments based
on amortization levels and transaction performance to date.

Orange Lake Timeshare Trust 2016-A

  - Class A 68504LAA9; LT Asf; Revision Outlook

  - Class B 68504LAB7; LT BBBsf; Revision Outlook

Orange Lake Timeshare Trust 2019-A

  - Class A 68504UAA9; LT AAAsf; Rating Watch On

  - Class B 68504UAB7; LT Asf; Rating Watch On

  - Class C 68504UAC5; LT BBBsf; Rating Watch On

  - Class D 68504UAD3; LT BBsf; Rating Watch On

Orange Lake Timeshare Trust 2015-A

  - Class A 68504TAA2; LT Asf; Affirmed

  - Class B 68504TAB0; LT BBBsf; Affirmed

Orange Lake Timeshare Trust 2014-A

  - Class A 68504RAA6; LT Asf; Affirmed

  - Class B 68504RAB4; LT BBBsf; Affirmed

Orange Lake Timeshare Trust 2018-A

  - Class A 68504WAA5; LT AAAsf; Rating Watch On

  - Class B 68504WAB3; LT Asf; Rating Watch On

  - Class C 68504WAC1; LT BBBsf; Rating Watch On

KEY RATING DRIVERS

The Rating Watch Negative for the class A, B, C, and D (where
applicable) notes for 2018-A and 2019-A, reflect asset performance
well outside of initial expectations as well as the potential for
more severe asset deterioration over the next six months due to the
pandemic and overall weak economic environment given the limited
amortization in these trusts. In particular, these transactions
have experienced materially higher default rates relative to the
2014-2016 transactions. Given the limited amortization, further
asset deterioration would result in lower loss coverage levels and
pose greater risk of potential negative rating actions.

As of the March 2020 collection period, the 61+ day delinquency
rates for 2018-A and 2019-A, were 2.96% and 4.57%, respectively.
Cumulative gross defaults adjusted for substitutions are currently
at 14.33% and 10.16%, respectively. Both transactions are tracking
above their initial base cases of 17.60% and 21.50%, respectively.
The higher defaults in 2019-A is largely attributed to defaults
related to paid product exits, which has negatively impacted
certain timeshare developers since mid-2015. However, the seller
has exercised the option to repurchase and substitute all defaults.
There have been zero net losses to date on the entire OLTT
portfolio.

The revision of the Outlook to Negative from Stable for all classes
of series 2016-A is based on potential weaker asset performance
over the next 1-2 years for the timeshare ABS sector, due to the
pandemic, which has had a negative impact on the U.S economy and
consumer health. While performance of this transaction has been
stronger than 2018-A and 2019-A, CGD's remain elevated and well
outside of Fitch's initial expectations. The 2016-A notes have a
much shorter risk horizon than 2018-A and 2019-A given the more
seasoned collateral pool, making these notes less susceptible to
negative rating actions relative to the aforementioned newer less
seasoned transactions. As of the March 2020 collection period, the
61+ day delinquency rates were 2.66% and CGD's adjusted for
substitutions are currently at 19.02%.

The affirmations and Stable Outlook for all outstanding notes for
2014-A and 2015-A reflect loss coverage levels consistent with
their current ratings. CGD's for these transactions are materially
lower than the aforementioned newer transactions, but are slightly
higher than Fitch's initial expectation. Given the significant
amortization, these transactions have limited risk of negative
rating actions with loss coverage levels consistent their current
ratings. As of the March 2020 collection period, the 61+ day
delinquency rates for 2014-A and 2015-A were 2.65% and 1.92%,
respectively. CGD's adjusted for substitutions (where applicable)
are currently at 15.17% and 17.61%, respectively.

Due to the uncertainty surrounding the coronavirus pandemic, Fitch
has established a base case coronavirus ratings scenario, which
assumes a global recession in 1H20 driven by sharp economic
contractions in major economies with a rapid spike in unemployment,
followed by a recovery that begins in 3Q20 as the health crisis
subsides. Timeshare ABS in particular is expected to experience
weaker asset performance in the near term as the sector is highly
correlated to tourism and travel, which has been impacted
significantly due to the pandemic, as evidenced by resorts closures
across the entire timeshare industry and the significant decline in
occupancy rates at timeshare resorts. This combined with high
unemployment and resultant loss of income, is expected to result in
increases in delinquencies and defaults as owners are unable to
vacation at timeshare resorts.

Fitch believes timeshare ABS performance depends on consumer
confidence returning, which will be based on the resolution of the
pandemic and overall health of the U.S. economy and consumer. In
particular, it will depend on the willingness of timeshare owners
to travel, timing of resort openings, and social distancing
implications at resorts. While Fitch does not expect consumer
confidence levels to return to pre-pandemic levels in the near
term. The agency will be closely monitoring resort openings, new
booking, occupancy levels, and utilization rates over the next
several months. Positive metrics could suggest lower default rates
as timeshare owners will be able to use their points for vacations.
These metrics along with delinquency and defaults trends over the
next six months will be monitored closely and will be considered
when resolving the Rating Watch Negative for the 2018-A and 2019-A
transactions.

Importantly, there are near-term mitigants that may shield
timeshare ABS asset performance, which include: a number of
drive-to destinations; the timeshare product viewed as a long-term
commitment and an owned product; owners with the ability to bank
their points and book vacations at a later date; overall monthly
payments that are smaller relative to other borrower obligations;
and maintenance fees, which are typically the largest monthly
payment, paid prior to the pandemic.

To account for potential increases in delinquencies and defaults,
Fitch revised the lifetime CGD proxies to 17.00%, 22.00%, 24.50%,
25.00%, and 28.00% for 2014-A, 2015-A, 2016-A, 2018-A, and 2019-A,
respectively. The revised base case proxies represent an increase
from the initial base proxies of 15.75%, 19.70%, 18.00%, 17.60%,
and 21.50% for 2014-A, 2015-A, 2016-A, 2018-A, and 2019-A,
respectively. The updated base case default proxies were derived
utilizing extrapolations for each transaction to account for the
expected increase in defaults due to negative impacts from the
pandemic and reflective of Fitch's updated baseline scenarios and
also influenced by downside scenario sensitivities (2x the updated
CGD proxies). These include pool factor and timing curve
extrapolations, as well as comparing more recent performance with
2006-2009 recessionary vintages. Additionally, qualitative
considerations were made in determining the revised proxies to
account for the fact there have been zero losses as all defaults
have been repurchased or substituted to date.

Under Fitch's stressed cash flow assumptions, loss coverage for the
2014-A and 2015-A class A and B notes falls slightly short of the
2.50x and 1.75x multiples for 'Asf' and 'BBBsf'. The shortfalls are
considered marginal and are within the range of the multiples for
the current ratings given the significant level of amortization
experienced on these transactions.

For the 2016-A, 2018-A, and 2019-A transactions, due to the higher
revised default proxies, Fitch has revised its rating multiples to
3.00x, 2.25x, 1.50x, and 1.25x from 3.50x, 2.50x, 1.75x, and 1.25x
for 'AAAsf', 'Asf', 'BBBsf', and 'BBsf', respectively. Under
Fitch's stressed cash flow assumptions, loss coverage for the
outstanding classes for 2016-A, 2018-A, and 2019-A are consistent
with the recommended multiples. However, in certain cases multiple
compression has occurred as the result of Fitch's higher revised
base case CDG proxies.

The ratings also reflect the quality of Holiday Inn Club Vacations,
Inc. timeshare receivable originations, the sound financial and
legal structure of the transactions, and the strength of the
servicing provided by Holiday Inn Club Vacations, Inc. Fitch will
continue to monitor economic conditions and their impact as they
relate to timeshare asset backed securities and the trust level
performance variables and update the ratings accordingly.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

  -- Stable to improved asset performance driven by stable
delinquencies and defaults would lead to increasing CE levels and
consideration for potential upgrades. Fitch applied an up
sensitivity, by reducing the base case proxy by 20%. The impact of
reducing the proxies by 20% from the current proxies could result
in one category upgrades or affirmations of ratings with stronger
multiples.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

  -- Conversely, unanticipated increases in the frequency of
defaults could produce default levels higher than the current
projected base case default proxy, and impact available loss
coverage and multiples levels for the transaction;

  -- Weakening asset performance is strongly correlated to
increasing levels of delinquencies and defaults that could
negatively affect CE levels. Lower loss coverage could impact
ratings and Rating Outlooks, depending on the extent of the decline
in coverage. The timeshare sector is currently more exposed to
weaker asset performance due to the strong correlation with tourism
and travel that has been severely affected by the pandemic

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


PACKERS HOLDINGS: Fitch Affirms B- LongTerm IDR, Outlook Stable
---------------------------------------------------------------
Fitch Ratings has affirmed Packers Holdings, LLC's Long-Term Issuer
Default Rating at 'B-'. Fitch has also affirmed the long-term
ratings on the company's senior first lien secured term loans and
revolver at 'B+'/'RR2'. The Rating Outlook is Stable.

PKR's Long-Term IDR is supported by its strong cash flow
generation, leading market position as the largest contract
sanitation company serving the food processing industry in North
America, and the high degree of regulation within the markets in
which it operates. The rating is further supported by the company's
consistent and expanding profit margins and long-held, blue-chip
customer relationships. These positive factors are offset by PKR's
customer concentration and by the company's elevated leverage and
aggressive financial policy.

The Stable Outlook reflects Fitch's expectations that the company's
leverage will likely remain elevated over the long term as a result
of relatively aggressive shareholder activities, such as the
debt-funded dividend distribution in May 2019. In the absence of
distributions, Fitch believes the company provides capacity to
delever either organically or through bolt-on acquisitions. Fitch
views the company's cash flow generation, market position, and
operating profile as favorable and strong for the 'B-' rating.
Customer concentration will likely remain a concern over the next
few years, although this risk is mitigated somewhat as individual
contracts are typically negotiated on a facility by facility basis.
Expansion into new end-markets could also broaden the company's
exposure over time.

KEY RATING DRIVERS

Elevated Leverage: PKR's leverage (gross debt/EBITDAR) remains a
significant factor when considering the company's rating. Fitch
expects leverage will remain stable over the rating horizon as the
sponsor monetizes its investment through distributions. The company
would outperform Fitch's expectations if there were any material
voluntary debt repayments, or if the company shifts to a more
conservative capital deployment strategy and avoids further
material shareholder friendly, leveraging transactions, such as
sponsor dividend recapitalizations. Fitch currently doesn't expect
a meaningful change in capital deployment strategy. Fitch cites
that the company's consistent profitability, long-standing customer
relationships and mission-critical nature as mitigants to elevated
leverage.

Strong Market Position: As the largest contract sanitation company
for the food-processing industry in North America, PKR has a
limited set of competitors that can fully service large plants or
quickly relocate resources to address customer needs. The
industrial food preparation segment is highly fragmented across the
U.S. and Canada with a large concentration of closely held regional
players; however, PKR is nearly three times the size (by location)
of its closest competitor, The Vincent Group-QSI.

Bolt-on Acquisitions Likely: Despite being the largest firm in the
industry, there are opportunities for expansion through further
penetration into additional plants of existing customers or through
acquisition, as the firm has completed several acquisitions in the
past five years, typically with a size of roughly $10 million to
$30 million and financed primarily through internally generated
cash. Fitch expects this will remain part of PKR's overall strategy
over the next several years, particularly as the company aims to
expand in geographies and end-markets where it is currently less
exposed.

Strong Profitability, FCF: Fitch considers PKR's stable margins,
growing revenue base, and strong FCF to be more commensurate with a
higher rating than 'B-'. The company has generated positive FCF
over the last several years, and Fitch expects this to continue
through 2023. The company has implemented and executed on several
cost cutting initiatives over the past two to three years,
particularly in regards to training and employee retention. Fitch
expects these initiatives will result in EBITDA margins remaining
steady over the rating horizon.

Coronavirus Impact: Fitch expects the impact of the coronavirus
pandemic on PKR's top and bottom line to be minimal. Although many
of PKR's customers' plants have experienced closures, individual
incidents have been briefed. PKR is also heavily involved in the
additional sanitation required to reopen. Raw materials sales in
the company's Chemicals segment have also benefitted from the
pandemic.

The coronavirus pandemic has also highlighted the importance of
sanitation regulations and Fitch believes such standards are
increasing, further strengthening PKR's position and expanding the
available opportunities for the company. Fitch assesses PKR's
function as mission-critical for its customers such as JBS or
Cargill as opposed to other plant production costs that may be
delayed such as maintenance or capex for machinery. Sanitation
usually represents less than 5% of a customer's plant's cost
structure.

Necessity of Service: Fitch believes the company's rating is
supported by its clear position within the market. All U.S. protein
plants are USDA-inspected daily prior to opening. Protein plants
must pass these daily inspections or be subject to fines, citations
and production delays with costs running in the tens of thousands
of dollars per hour. In addition, non-protein plants are regularly
reviewed by the FDA with end-customers such as Walmart, McDonalds
and Subway driving higher sanitation standards.

Positive Industry Trends: PKR's credit risk is somewhat reduced by
several current broad markets trends that are likely to continue
over the medium term, even absent the coronavirus pandemic, which
will likely strengthen these trends. As the grocery segment
continues to see pricing pressure from online retailers, both
protein and non-protein producers will seek to further streamline
production by outsourcing additional functions such as human
resources and sanitation. Fitch believes that human resources is a
core competency of PKR as the company has over 17,000 full-time
employees, no union representation and employee turnover that is
below industry average.

An additional source of demand is the increased regulatory
complexity across various food categories coupled with increasingly
unannounced FDA audits. Finally, PKR's management notes that the
growing presence of automation in the food processing arena has in
many cases led to increased demand for sanitation services as a
growing number of mechanical components need to be disassembled,
sanitized and reassembled by its trained staff.

Customer Concentration: Fitch considers PKR's customer
concentration to be one of its more material concerns. Fitch
estimates the company's top five customers comprise approximately
half of the company's revenue. The loss of any of these top
customers would significantly impact the company's financial
performance and subsequently its credit profile. PKR's strong
market position offsets some of Fitch's concerns, while the
concentration is also somewhat mitigated by the fact that these
relationships are spread out across dozens of unique plants that
have discrete plant managers, each responsible for plant
performance and regulatory compliance, who decide to employ PKR's
services.

Additionally, contracts are typically negotiated on a
plant-by-plant basis, rather than on a corporate level, though
corporate relationships can impact broader wins, renewals, and
losses. They typically have very high renewal rates, which Fitch
expects to be between 90% and 95% on average.

DERIVATION SUMMARY

PKR compares favorably to its (industry) peers in terms of cash
flow generation, strategy and profitability. In particular, Fitch
considers the company's FCF margins and stable margins to be
exceptional compared to similar-rated companies. Fitch also
considers PKR to be differentiated from its other 'B-' rated peers
due to its strong market position within its segment. Many other
companies in the 'B' category operate in highly fragmented markets
with minimal competitive advantage. The company's rating is
somewhat limited due to its leverage, which is high, but relatively
in line with similarly rated companies. The propensity for
shareholder focused leveraging transactions was also a rating
consideration. There are no parent/subsidiary, country ceiling, or
operating environment influences or constraints on this rating.

KEY ASSUMPTIONS

Fitch's Key Assumptions Within its Rating Case for the Issuer

  -- Minimal top-line impact from coronavirus; Low-to-mid single
digit annual organic growth over the rating horizon, coupled with
modest bolt-on acquisitions;

  -- Acquisitions of between $20 million and $30 million per year
from 2020 to 2023, predominantly funded with internally generated
cash;

  -- Additional cash deployment is allocated between reinvestment
in the company and modest debt reduction, with intermittent
leveraging transactions such as a dividend recapitalization keeping
leverage around its positive sensitivity of 6.5x over the long
term;

  -- EBITDA margins stable throughout forecast with increased
marketing and corporate expenses offset by effects of improved
employee training, employee retention and cost savings
initiatives;

  -- Modest capex investment of less than 1% of total revenue.

KEY RECOVERY RATING ASSUMPTIONS

The recovery analysis assumes Packers Holdings would be reorganized
rather than liquidated, and would be considered on a going concern.
Fitch has assumed a 10% administrative claim in the recovery
analysis.

In Fitch's recovery analysis, potential default is assumed to come
from a combination of one or more of the following: a prolonged
economic downturn leads to one or more major customers to close a
significant number of facilities; customers shifting to insource a
high percentage of currently outsourced contracts; or loss of more
than one of the company's major customers.

Fitch's GC EBITDA assumptions reflect the equivalent of PKR losing
one of its top two customers along with at least one of its
remaining top five customers, resulting in each a revenue and
EBITDA decline of approximately 20% compared to Fitch's rating
case, as margins also decline modestly.

Fitch expects the EV multiple used in Packers' recovery analysis
will be approximately 6.5x. Fitch believes the company's business
profile and market position are strong, despite the highly
leveraged capital structure. PKR has consistently generated
positive FCF and stable margins, while growing organically. Fitch's
EV multiple also considers the approximately 13x transaction
multiple when Leonard Green (sponsor) purchased Packers in 2014.

The $50 million senior first lien secured revolving credit facility
is assumed to be fully drawn upon default. The revolver and senior
first lien secured term loan are senior to the senior unsecured
notes in the waterfall.

The waterfall incorporates the negative impact of the incremental
term loan although the recovery remains between 71% and 90% for the
senior first lien revolver and term loans. This corresponds to a
Recovery Rating of 'RR2'.

RATING SENSITIVITIES

Factors That May, Individually or Collectively, Lead to Positive
Rating Action:

  -- Leverage (gross debt/EBITDA) below 6.5x for a sustained
period;

  -- FFO leverage below 6.5x for a sustained period;

  -- FFO Fixed Charge Coverage above 2.5x for a sustained period;

  -- Shift to a consistently conservative financial policy.

Factors That May, Individually or Collectively, Lead to Negative
Rating Action:

  -- Leverage consistently above 7.5x;

  -- Multiple consecutive periods of negative FCF;

  -- FFO Fixed Charge Coverage sustained below 1.5x;

  -- Loss of a major customer.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Non-Financial Corporate
issuers have a best-case rating upgrade scenario (defined as the
99th percentile of rating transitions, measured in a positive
direction) of three notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of four notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAA' to 'D'. Best- and worst-case scenario credit ratings are
based on historical performance.

LIQUIDITY AND DEBT STRUCTURE

Adequate Liquidity: Fitch considers PKR's liquidity to be adequate
at approximately $76 million as of YE 2019, comprised of $26
million of cash and equivalents and $50 million of revolver
availability. The company has a relatively nimble operating
structure and minimal annual maintenance capital expenditures. Its
liquidity is also supported by the company's positive FCF
generation, which Fitch expects to continue over the rating
horizon. Fitch does not consider any of the company's cash to be
restricted, and Fitch does not believe the company requires a
material cash balance to sustain operations given its lean
operating structure and minimal fixed costs. Fitch considers the
company's capital structure and maturity schedule to be relatively
favorable, with its nearest term maturity being the TLB in 2024.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

Packers Holdings, LLC: Governance Structure: 4

Packers Holdings has exposure to board independence risk due to
sponsor ownership and potential for aggressive shareholder
distributions which, in combination with other factors, impacts the
rating.


PFP LTD 2019-5: DBRS Confirms B(low) Rating on Class G Notes
------------------------------------------------------------
DBRS, Inc. confirmed the ratings on the following classes of
secured floating-rate notes issued by PFP 2019-5, Ltd. (the
Issuer):

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. In its analysis of the transaction,
DBRS Morningstar applied the probability of default (POD)
adjustments to loans with confirmed issues partially related to the
stressed real estate environment caused by the Coronavirus Disease
(COVID-19) pandemic. Given the transitional nature of the
underlying collateral, proposed business plans necessary to bring
the assets to stabilization may be delayed, and, in some cases,
borrowers may request relief from the Issuer. DBRS Morningstar has
built additional POD stress into its analysis of this transaction
and, based on currently available information, DBRS Morningstar
expects the rated classes to be insulated from adverse credit
implications at this time, warranting the rating confirmations.

At issuance, the collateral consisted of 35 floating-rate mortgages
secured by 39 transitional properties totaling $764.2 million,
excluding $109.9 million of remaining future funding commitments.
Per the May 2020 remittance, three loans have been paid in full
with 31 loans secured by 35 properties remaining in the trust. To
date, approximately $36.4 million of future funding commitments
have been released to individual borrowers since issuance and $71.0
million of future funding commitments remain. The pool is
concentrated in multifamily properties (43.6% of the pool balance)
and office properties (38.1% of the pool balance). Additionally,
the collateral is concentrated in secondary and tertiary markets
with approximately 49.5% of the pool balance located in DBRS
Morningstar Market Ranks of 2 or 3, which typically have weaker
investor demand during times of economic stress. As of May 2020
reporting, 14 loans, representing 39.5% of the pool balance, were
on the servicer's watchlist primarily because of low debt service
coverage ratios and occupancy rates, which is expected given the
transitional nature of the assets in the pool. Twelve loans,
representing 30.8% of the pool balance, have initial maturity dates
by YE2020, and all loans are structured with three one-year
extension options available to the borrower provided that certain
conditions are met.

Through May 2020, 30 of the 32 loans in the pool were current;
however, DBRS Morningstar expects that additional borrower may
request debt service relief in the form of loan modifications or
forbearances as the pandemic-induced economic slowdown deepens.
Property types that are most at risk of cash flow disruption
include hotel and retail assets, which account for three loans,
representing 6.4% of the pool balance, and one loan, representing
2.8% of the pool balance, respectively. The two loans that became
delinquent with May 2020 reporting are secured by hotel properties
and include Ivy Hotel (Prospectus ID#24; 1.9% of the pool balance)
and Hampton Inn Vilano Beach (Prospectus ID#27; 1.7% of the pool).
DBRS Morningstar has reached out to the servicer regarding the
reason for the delinquency; however, it is likely a direct result
of property cash flow disruption, stemming from a significant
slowdown in the travel and lodging sector.

The lone retail asset in the transaction, Loyal Plaza (Prospectus
ID#14; 2.8% of the pool balance), is secured by a grocery-anchored
community retail shopping center in Williamsport, Pennsylvania. As
of March 2020 reporting, the property was approximately 60.0%
occupied and its collateral K-Mart big-box storefront recently
closed, which was expected at issuance. DBRS Morningstar also
acknowledges the risks to The Icon (Prospectus ID#8; 3.8% of the
pool balance), Aspen Heights (Prospectus ID#19; 2.1% of the pool
balance), 2340 Telegraph (Prospectus ID#21; 2.1% of the pool
balance), and The Quad Apartments (Prospectus ID#35; 1.2% of the
pool balance) loans, which are secured by student housing
properties and may be affected by campus closures or lower student
enrollment for the fall 2020 semester because of the coronavirus
pandemic.

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


READY CAPITAL 2019-FL3: DBRS Confirms B(low) Rating on Cl. F Notes
------------------------------------------------------------------
DBRS Limited confirmed its ratings on the following classes of
Commercial Mortgage-Backed Notes, Series 2019-FL3 issued by Ready
Capital Mortgage Financing 2019-FL3 (the Issuer) as follows:

-- 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 (low) (sf)
-- Class E at BB (low) (sf)
-- Class F at B (low) (sf)

All trends are Stable. The ratings have been removed from Under
Review with Developing Implications, where they were placed on
April 9, 2020.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. In its analysis of the transaction,
DBRS Morningstar applied the probability of default (POD)
adjustments to loans with confirmed issues partially related to the
stressed real estate environment caused by the Coronavirus Disease
(COVID-19) pandemic. Because of the transitional nature of the
underlying collateral, proposed business plans that are necessary
to bring the assets to stabilization may be delayed, and, in some
cases, borrowers may request relief from the Issuer. DBRS
Morningstar has built additional POD stress into its analysis of
this transaction and, based on currently available information,
DBRS Morningstar expects the rated classes to be insulated from
adverse credit implications at this time, warranting the rating
confirmations.

At issuance, the collateral consisted of 43 floating-rate mortgages
secured by 44 transitional properties totaling approximately $320.8
million, excluding approximately $101.3 million of future funding
commitments held outside the trust. As of the April 2020
remittance, 37 loans remain in the pool with approximately $50.7
million of future funding commitments purchased by the trust as of
March 2020.

As of the April 2020 remittance, 10 loans, representing 20.9% of
the pool, are on the servicer's watchlist and two loans,
representing 3.7% of the pool, are in special servicing. The
Bungalows at Queen Anne (Prospectus ID#13; 2.4% of the pool)
transferred to special servicing in April 2020 after the borrower
made a hardship request because of the coronavirus. The loan's
business plan contemplates adding two floors to an existing
two-storey multifamily and retail property. Previous residential
units have been demolished to make way for the new construction,
leaving just the ground-floor retail tenants in occupancy. Because
of the coronavirus, renovation work stopped on March 25, 2020.

Arbor Grove (Prospectus ID#25; 1.3% of the pool), secured by a
multifamily property in Canton, Ohio, transferred to special
servicing in February 2020 after the loan failed to secure
refinancing at its November 2019 maturity. The borrower's business
plan called for increases to occupancy, at which time it would
target permanent refinancing via a Freddie Mac exit; however,
according to servicer commentary, the property was mismanaged,
which resulted in a decline from its occupancy of 75% at issuance.
The borrower remained current on its debt service obligations from
the originally stated maturity date until April 2020 when the loan
was classified as a nonperforming matured balloon. DBRS Morningstar
analyzed both specially serviced loans with elevated PODs to
reflect their increased risk profile.

DBRS Morningstar remains concerned with loans secured by hotel
properties, given the coronavirus pandemic and its impact on
tourism and travel. The Tapestry by Hilton Daytona Beach
(Prospectus ID#22; 2.8% of the pool) is the only loan in the pool
secured by a lodging property. The loan's business plan
contemplates a $4.3 million ($39,000 per key) property improvement
plan to reflag the hotel as a Tapestry by Hilton. Because of the
ongoing coronavirus pandemic, the hotel has temporarily closed to
reduce expenses and to speed up renovations. As of April 2020, the
renovations are over 40% completed. The hotel, which is located in
Daytona Beach, Florida, relies heavily on tourism and the pandemic
will continue to negatively affect the hotel as the broader
hospitality industry experiences occupancy rates of nearly 0%. DBRS
Morningstar analyzed this loan with an elevated POD to reflect
concerns with the hospitality industry and the subject's delayed
stabilization.

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


SAPPHIRE AVIATION 1: Fitch Cuts Rating on Class C Notes to 'Bsf'
----------------------------------------------------------------
Fitch Ratings has downgraded the series A, B and C fixed-rate
secured notes issued by Sapphire Aviation Finance I Limited, and
affirmed the ratings on the Sapphire Aviation Finance II Limited
Series A, B and C fixed-rate secured notes. The existing Rating
Watch Negatives on SAPA I were removed and assigned Rating Outlook
Negative on all the notes rated by Fitch, while the existing RONs
on SAPA II notes were maintained.

Sapphire Aviation Finance I

  - Class A 80306AAA8; LT BBBsf; Downgrade

  - Class B 80306AAB6; LT BBsf; Downgrade

  - Class C 80306AAC4; LT Bsf; Downgrade

Sapphire Aviation Finance II Limited

  - Class A 80307AAA7; LT Asf; Affirmed

  - Class B 80307AAB5; LT BBBsf; Affirmed

  - Class C 80307AAC3; LT BBsf; Affirmed

TRANSACTION SUMMARY

The rating actions reflect ongoing deterioration of all airline
lessee credits backing the leases in each transaction pool,
downward pressure on certain aircraft values, Fitch's updated
assumptions and stresses, and resulting impairments to modeled cash
flows and coverage levels.

Fitch revised or maintained each tranche of each transaction on
RON, reflecting Fitch's base case expectation for the structure to
withstand immediate and near-term stresses at the updated
assumptions and stressed scenarios commensurate with their
respective ratings.

On March 31, 2020, Fitch placed the series B and C notes of SAPA I
on RWN, while all other series of notes in SAPA I and SAPA II were
placed on RON as a part of its aviation ABS portfolio review due to
the ongoing impact of the coronavirus on the global macro and
travel/airline sectors. This unprecedented worldwide pandemic
continues to evolve rapidly and negatively affect airlines across
the globe.

To accurately reflect the global recessionary environment and the
impact on airlines backing these pools, Fitch updated rating
assumptions for both rated and non-rated airlines with a vast
majority of ratings moving lower, which was a key driver of these
rating actions, along with modeled cash flows.

Furthermore, recessionary timing was brought forward to start
immediately at this point in time. This scenario further stresses
airline credits, asset values and lease rates immediately while
incurring remarketing and repossession cost and downtime, at each
relevant rating stress level. Previously, Fitch assumed that the
first recession commenced six months from either the transaction
closing date or date of subsequent reviews.

Avolon Aerospace Leasing Limited and certain affiliates are the
sellers for the assets and is an indirect subsidiary of Avolon
Holdings Limited (IDR currently at BBB-/Negative). Avolon and
certain of their subsidiaries are the initial sellers, and Avolon
acts as servicer to both transactions.

KEY RATING DRIVERS

Deteriorating Airline Lessee Credit

The credit profiles of the airline lessees in the pools have
further deteriorated due to the coronavirus-related impact on all
global airlines in 2020, resulting in lower lessee rating
assumptions utilized for this review. The proportion of airline
lessees in the SAPA I pool assumed to be at 'CCC' IDR increased to
61.0% from 35.7% at the time of the last review in February 2020,
and increased to 82.9%, compared with 44.9% at closing for SAPA
II.

Newly assumed 'CCC' credit airlines in SAPA I include IndiGo, Jet2,
Air Transat, Ural Airlines, Eastar Jet, Yamal Airlines, Bangkok
Airways, Jeju Air and Enter Air. For SAPA II, these now 'CCC' rated
airlines were Philippine Airlines, Air Transat, T'Way Airlines,
IndiGo, Sunwing and VietJet Air. These assumptions reflect these
airlines' ongoing deteriorating credit profiles and fleet in the
current operating environment due to the coronavirus-related impact
on the sector.

Since the last review for SAPA I, Miami Air International filed
bankruptcy in April 2020. The single aircraft leased to the airline
represents 1.0% of the pool as of May 2020 and is currently in
Avolon's possession on ground. Fitch assumed zero collections for
three months prior to modeling remarketing activity to account for
additional time to place this aircraft, on top of typically assumed
remarketing time, and stress this asset further.

Asset Quality and Appraised Pool Value

Both pools include widebody aircraft concentrations totaling 41.1%
in SAPA I and 31.7% in SAPA II. WBs typically incur higher
repossession, transition, reconfiguration and maintenance costs.
Due to ongoing market value pressures for WBs and worsening supply
and demand value dynamics for these aircraft, Fitch utilized market
values as opposed to base values for cash flow modeling, and then
further applied an additional immediate and permanent 5% value
haircut, after taking into account depreciation applied by Fitch
since the last appraisals on the aircraft. The remaining aircraft
in both pools consist of narrowbody aircraft. For these aircraft,
Fitch utilized BVs given ongoing market dynamics, consistent with
prior review.

For this review, Fitch utilized the average of the two lowest and
most current appraisal values (BV for NB and MV for WB) as of
December 2019 for SAPA I, and September 2019 for SAPA II. The
appraisals were provided for each pool, but as stated, Fitch
utilized the average of the lowest two appraisals.

IBA Group Limited, morten beyer & agnew Inc. and BK Associates Inc.
are appraisers for SAPA I. Appraisers for SAPA II are IBA, MBA and
Collateral Valuations, Inc. This approach resulted in Fitch-modeled
pool values of $604.9 million for SAPA I and $672.6 million for
SAPA II. This is notably lower compared to $702.8 million and
$746.8 million as stated in the May 2020 servicer reports.

Transaction Performance to Date

SAPA I lease collections and transaction cash flows have trended
down since the beginning of 2020, receiving $2.9 million in the May
collection period, versus the peak monthly $9.7 million received in
the February period. With only two months of seasoning, SAPA II
received $4.2 million in lease collections in the May collection
period. As of the May period, SAPA I available cash flow was
insufficient to pay any note principal amounts, reaching the senior
maintenance reserve amount step, while SAPA II payments reached the
series A scheduled principal payment amount step.

Since the February 2020 last review by Fitch, SAPA I sold two
additional aircraft and now total five aircraft disposed of since
close (includes four aircraft sales and one total loss), which
contributed to a faster than expected scheduled principal paydown
of each series of notes to date. The DSCR continues to remain above
the 1.20x cash trap trigger, although it has fallen in recent
months, but remained above the trigger level, and no rapid
amortization event has occurred.

As a result of the COVID-19 pandemic, Avolon has agreed to a number
of short-term deferrals averaging three months, and expects that
some form of short-term deferrals will be granted to a majority of
its customers. For modeling purposes, Fitch assumed three months of
lease deferrals for all airlines, with contractual lease payments
resuming thereafter plus additional repayment of deferred amounts
over a six-month period.

Fitch Assumptions, Stresses and Cash Flow Modeling

Nearly all Avolon servicer-driven Fitch assumptions are unchanged
from the prior rating reviews for each transaction, and include
consistent repossession and remarketing costs, new lease and
extended lease terms assumed.

Eleven aircraft on lease are expected to mature within the next 12
months for SAPA I, and one for SAPA II. For these near-term
maturities, Fitch assumed an additional three-month downtime stress
at lease-end in addition to lessor-specific remarketing downtime
assumptions, in order to account for potential remarketing
challenges in placing this aircraft with a new lessee in the
current distressed environment.

With the grounding of global fleets and significant reduction in
air travel, maintenance revenue and costs will be affected and are
expected to decline due to airline lessee credit issues and
grounded aircraft. Maintenance revenues were reduced by 50% over
the next immediate 12 months for these reviews, and such missed
payments were assumed to be recouped in the following 12 months
thereafter starting in May 2021. Maintenance costs over the
immediate six months were assumed to be incurred as reported. Costs
in the next 12 months were reduced to 75% of their original
schedules. Over the following 12 months, the 25% of deferred costs
in prior periods were assumed to be repaid every month in addition
to the scheduled maintenance costs.

RATING SENSITIVITIES

The Rating Outlook Negative on all classes of SAPA I and SAPA II
reflect the potential for further negative rating actions due to
concerns over the ultimate impact of the coronavirus pandemic, the
resulting concerns associated with airline performance and aircraft
values, and other assumptions across the aviation industry due to
the severe decline in travel and grounding of airlines.

At close, Fitch conducted multiple rating sensitivity analyses to
evaluate the impact of changes to a number of the variables in the
analysis. The performance of aircraft operating lease
securitizations is affected by various factors, which, in turn,
could have an impact on the assigned ratings. Due to the
correlation between global economic conditions and the airline
industry, the ratings can be affected by the strength of the
macro-environment over the remaining term of this transaction.

In the initial rating analysis, Fitch found the transactions to
exhibit sensitivity to the timing and severity of assumed
recessions. Fitch also found that greater default probability of
the leases has a material impact on the ratings. Furthermore, the
timing and degree of technological advancement in the commercial
aviation space, and the resulting impact on aircraft values, lease
rates and utilization would have a moderate impact on the ratings.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade

Up: Base Assumptions with Stronger Residual Value Realization:

The aircraft ABS sector has a rating cap of 'Asf'. All subordinate
tranches carry one category of ratings lower than the senior
tranche and below the ratings at close. However, if the assets in
this pool experience stronger residual value realization than Fitch
modeled, or if it experiences a stronger lease collection in flow
than Fitch's stressed scenarios, the transaction could perform
better than expected. At this point, future upgrades beyond current
ratings would not be considered due to a combination of the sector
rating cap, industry cyclicality, weaker lessee mix present in ABS
pools and uncertainty around future lessee mix, along with the
negative impact due to the coronavirus on the global travel/airline
sectors and, ultimately, ABS transactions.

In an "Up" scenario, RV recoveries at time of sale are assumed to
be 70% of their depreciated market values, higher than the base
case scenario at 50% for certain aircraft. For SAPA I, net cash
flow increases by approximately $51 million at the 'Asf' rating
category, and class A is able to pass under the 'Asf' stress
scenario, while class B and C both pass under the 'BBBsf' stress
scenario. For SAPA II, net cash flow increases by $37.9 million at
the 'Asf' rating category, and all classes are able to pass under
the 'Asf' stress scenario.

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade

Down: Base Assumptions with 10% Weaker Widebody Values

The pools contain large concentration of WB aircraft at
approximately 41% and 32% for SAPA I and II, respectively, and any
further softening in these aircraft values could lead to further
downward rating action. Due to downward ongoing MV pressure on WB
and worsening supply and demand value dynamics, Fitch explored the
potential cash flow decline if WB values were reduced further by
10% of Fitch's modeled value for cash flow modeling (versus the 5%
base scenario haircuts applied in this review mentioned prior).

For SAPA I, net cash flow declines by approximately $1.3 million at
the 'Asf' rating category; class A, B and C notes are able to pass
at the recommended ratings of 'BBBsf', 'BBsf' and 'Bsf',
respectively. For SAPA II, net cash flow decline by $16 million at
the 'Asf' rating category, and class A and B are each able to pass
at 'Asf', while class C is able to pass at 'BBBsf'.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


SAXON ASSET 2007-4: Moody's Cuts Class A-2 Debt to Caa1
-------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches from two RMBS transactions backed by subprime loans.

The complete rating action is as follows:

Issuer: Saxon Asset Securities Trust 2007-4

Cl. A-2, Downgraded to Caa1 (sf); previously on Dec 7, 2017
Upgraded to B2 (sf)

Issuer: New Century Home Equity Loan Trust, Series 2004-A

Cl. B-II, Downgraded to Caa3 (sf); previously on Mar 1, 2016
Upgraded to Caa1 (sf)

Cl. M-II, Downgraded to Caa1 (sf); previously on May 15, 2019
Downgraded to B2 (sf)

RATINGS RATIONALE

The rating downgrades are primarily due to deterioration in
collateral performances and credit enhancement available to the
bonds. The rating actions reflect the recent performance and
Moody's updated loss expectations on the underlying pools.

Its analysis has considered the effect of the coronavirus outbreak
on the US economy as well as the effects that the announced
government measures, put in place to contain the virus, will have
on the performance of consumer assets. Specifically, for US RMBS,
loan performance will weaken due to the unprecedented spike in the
unemployment rate, which may limit borrowers' income and their
ability to service debt. The softening of the housing market will
reduce recoveries on defaulted loans, also a credit negative.
Furthermore, borrower assistance programs such as forbearance, may
adversely impact scheduled cash flows to bondholders.

The contraction in economic activity in the second quarter will be
severe and the overall recovery in the second half of the year will
be gradual. However, there are significant downside risks to its
forecasts in the event that the pandemic is not contained and
lockdowns have to be reinstated. As a result, the degree of
uncertainty around its forecasts is unusually high. Moody's regards
the coronavirus outbreak as a social risk under its ESG framework,
given the substantial implications for public health and safety.

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:

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.

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.

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.


SDART 2018-5: Fitch Affirms BB Rating on Class E1 Notes
-------------------------------------------------------
Fitch Ratings has taken various rating actions on Santander Drive
Auto Receivables Trusts (SDART) 2018-5 and 2019-2. The market
disruption caused by the coronavirus and related containment
measures did not negatively affect the ratings, because there is
sufficient credit enhancement to cover higher cumulative net losses
projected after more severe assumptions were applied.

Santander Drive Auto Receivables Trust 2018-5

  - Class B1 80286AAE4; LT AAAsf; Affirmed

  - Class C1 80286AAF1; LT AAsf; Upgrade

  - Class D1 80286AAG9; LT BBBsf; Affirmed

  - Class E1 80286AAH7; LT BBsf; Affirmed

Santander Drive Auto Receivables Trust 2019-2

  - Class A2 80286GAB7; LT AAAsf; Affirmed

  - Class A3 80286GAD3 LT AAAsf; Affirmed

  - Class B 80286GAE1; LT AAAsf; Upgrade

  - Class C 80286GAF8; LT Asf; Affirmed

  - Class D 80286GAG6; LT BBBsf; Affirmed

  - Class E 80286GAH4; LT BBsf; Affirmed

KEY RATING DRIVERS

The rating actions are based on available credit enhancement and
cumulative net loss performance to date. The collateral pools
continue to perform within Fitch's expectations, and hard CE is
building for the notes. The securities are able to withstand stress
scenarios consistent with or higher than their current ratings, and
make full payments to investors in accordance with the terms of the
documents. The Stable Outlooks reflect Fitch's expectation that the
classes have sufficient levels of credit protection to withstand
potential deterioration in credit quality of the portfolios in
stress scenarios and loss coverage will continue to increase as the
transaction amortizes. The Positive Outlooks on the class C notes
reflect the possibility of an upgrade in the next one to two years
as a result of building CE.

As of the May 2020 payment report, 61+ day delinquencies were 3.92%
and 2.95% of the remaining collateral balance for 2018-5 and
2019-2, respectively, and CNLs were 6.22% and 3.36%. CNLs for both
transactions are tracking inside Fitch's initial base case of
17.00% for each pool. Further, hard CE has grown for both
transactions from close, respectively.

Fitch has made assumptions about the spread of coronavirus and the
economic impact of the related containment measures. As a base-case
scenario, Fitch assumes a global recession in 1H20 driven by sharp
economic contractions in major economies with a rapid spike in
unemployment, followed by a recovery that begins in 3Q20 as the
health crisis subsides. As a downside (sensitivity) scenario
provided in the Rating Sensitivities section, Fitch considers a
more severe and prolonged period of stress preventing recovery
until beyond 2021.

To account for potential increases in delinquencies and losses,
utilizing the base case coronavirus ratings scenario, Fitch applied
conservative assumptions in deriving the updated base case proxy.
For both transactions, the base case proxies were increased by
utilizing recessionary static managed portfolio performance along
with projections based on current performance. Given the current
economic environment, Fitch deemed it appropriately conservative to
utilize these approaches for both transactions.

For 2018-5, the base case lifetime CNL proxy was increased to
16.50% from 16.00% at the prior review. Under Fitch's stressed cash
flow assumptions, loss coverage for classes A and B support
multiples in excess of 3.00x for 'AAAsf'. Classes C and D loss
coverage supports multiples in excess of 2.50x and 1.50x for 'AAsf'
and 'BBBsf', respectively. Class E loss coverage falls marginally
short of 1.25x multiple for 'BBsf'. Fitch considers the miss to be
immaterial.

For 2019-2, the base case lifetime CNL proxy was increased to
18.00% from the initial proxy of 17.00%. Under Fitch's stressed
cash flow assumptions, loss coverage for classes A and B support
multiples in excess of 3.00x for 'AAAsf'. Further, classes C and D
loss coverage supports multiples in excess of 2.00x and 1.50x for
'Asf' and 'BBBsf', respectively. Class E loss coverage falls
marginally short of 1.25x multiple for 'BBsf'. Fitch considers the
miss to be immaterial.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Stable to improved asset performance driven by stable delinquencies
and defaults would lead to increasing CE levels and consideration
for potential upgrades. If CNL is 20% less than projected CNL
proxy, the ratings could be maintained/upgraded.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Conversely, unanticipated increases in the frequency of defaults
could produce default levels higher than the current projected base
case default proxy, and impact available loss coverage and
multiples levels for the transaction. Weakening asset performance
is strongly correlated to increasing levels of delinquencies and
defaults that could negatively impact CE levels. Lower loss
coverage could impact ratings and Rating Outlooks, depending on the
extent of the decline in coverage.

In Fitch's initial review, the notes were found to have some
sensitivity to a 1.5x and 2.0x increase of Fitch's base case loss
expectation for each transaction. The 2.0x scenario was updated and
is considered Fitch's coronavirus downside rating sensitivity. For
2018-5, this scenario suggests consistent ratings for the class A,
B and C notes, and a possible downgrade of 1-2 categories for
classes D and E notes. For 2019-2, this scenario suggests
consistent ratings for the class A and B, and a possible downgrade
of 1-2 categories for classes C, D and E notes. To date, the
transactions have strong performance with losses within Fitch's
initial expectations with adequate loss coverage and multiple
levels. Therefore, a material deterioration in performance would
have to occur within the asset collateral to have potential
negative impact on the outstanding ratings.

Due to the uncertainty surrounding the coronavirus outbreak, Fitch
ran additional sensitivities to account for potential increases in
delinquencies. The transactions are able to withstand the added
stresses with loss coverage consistent with or in excess of the
ratings in their respective notes.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


VERUS SECURITIZATION 2020-2: Fitch Rates Class B-2 Certs 'B(EXP)'
-----------------------------------------------------------------
Fitch Ratings has assigned expected ratings to the residential
mortgage-backed certificates issued by Verus Securitization Trust
2020-2.

RATING ACTIONS

Verus 2020-2

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

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

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

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

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

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

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

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

TRANSACTION SUMMARY

The certificates are supported by 870 loans with a balance of
$389.21 million as of the cutoff date. This will be the first
transaction issued by Verus that Fitch is expected to rate.

The certificates are secured mainly by nonqualified mortgages
(Non-QM) as defined by the ability to repay (ATR) rule. Of the
pool, 80.8% is designated as Non-QM, 0.9% as safe-harbor QM, 0.4%
as a higher priced QM and the remaining 18.0% is not subject to
ATR. Distributions of principal and interest (P&I) and loss
allocations are based on a traditional senior-subordinate,
sequential structure. The sequential-pay structure locks out
principal to the subordinated notes until the most senior notes
outstanding are paid in full. The transaction has a stop advance
feature where the P&I advancing party will advance delinquent P&I
up to 90 days.

KEY RATING DRIVERS

Revised GDP Due to the Coronavirus: The coronavirus and the
resulting containment efforts have resulted in revisions to Fitch's
GDP estimates for 2020. Fitch's baseline global economic outlook
for U.S. GDP growth is currently at a 5.6% decline for 2020, down
from 1.7% for 2019. Fitch's downside scenario would see an even
larger decline in output in 2020 and a weaker recovery in 2021. To
account for declining macroeconomic conditions resulting from the
coronavirus, an Economic Risk Factor (ERF) floor of 2.0 was applied
to 'BBBsf' and below. The ERF is a default variable in the U.S.
RMBS loan loss model.

Expected Payment Deferrals Related to the Coronavirus (Negative):
The outbreak of the coronavirus and widespread containment efforts
in the U.S. will result in increased unemployment and cash flow
disruptions. To account for the cash flow disruptions, Fitch
assumed deferred payments on a minimum of 30% of the pool for the
first six months of the transaction at all rating categories, with
a reversion to its standard delinquency and liquidation timing
curve by month 10. This assumption is based on observations of
legacy Alt-A delinquencies and past-due payments following
Hurricane Maria in Puerto Rico.

Stop Advance Structure (Mixed): The transaction has a stop advance
feature where the P&I advancing party, IRP Advancing Company II,
LLC, will advance delinquent P&I up to 90 days. While the limited
advancing of delinquent P&I benefits the pool's projected loss
severity, it reduces liquidity. To account for the reduced
liquidity of a limited advancing structure, principal collections
are available to pay timely interest to the 'AAAsf' and 'AAsf'
rated bonds.

If the P&I advancing party fails to make a required advance, the
master servicer, Nationstar Mortgage LLC, will be obligated to make
such advance. If the master servicer fails to make advances, the
securities administrator, Citibank, N.A., will fund advances.

Payment Forbearance (Mixed): Roughly 7% of the borrowers - 46 loans
- in the pool are on a coronavirus forbearance plan, all of which
are current. These borrowers were generally granted up to a
three-month forbearance period by the servicer. While a borrower
who does not make a payment while on a forbearance plan, related to
the coronavirus or not, will be considered delinquent, the P&I
advancing party will not be obligated to advance until the end of
the related forbearance period for the missed payments.

The servicer is expected to offer up to three months forbearance
for borrowers affected by the coronavirus. At the end of the
forbearance period, the servicer, in conjunction with or at the
direction of the servicing administrator - Verus Residential
Loanco, LLC, may evaluate repayment and/or loss mitigation options.
Repayment options are likely to include reinstatement, such as a
lump sum repayment of the missed payments, repayment plans
deferrals of the missed payments to the end of the loan term, or
capitalization of the missed payments. Loss mitigation options for
borrowers with permanent hardships could be offered rate and/or
term modifications, principal reduction modifications, short sales
or deed-in-lieu resolution strategies.

P&I Advancing During Forbearance Period (Mixed): The P&I advancing
party will not be advancing delinquent P&I for borrowers on any
forbearance plan, even those relating to the coronavirus, during
the forbearance period. A borrower who does not make a payment
while on a forbearance plan will be considered delinquent; however,
the P&I advancing party will not be obligated to advance during
that time.

If a borrower fails to make P&I payments during the related
forbearance period and has not received any additional forbearance,
payment restructuring or modification relief, the P&I advancing
party will advance an amount equal to the missed payments in a lump
sum to the trust irrespective of whether the borrower becomes
current. This occurs at the end of the related forbearance period,
such as in month four. As P&I advances are intended to provide
liquidity to the rated certificates if borrowers fail to make their
monthly payments, the lack of advancing during a forbearance period
could result in temporary interest shortfalls to the lowest ranked
classes, as principal can be used to pay interest to the A-1 and
A-2 classes.

Fitch assumed a no-advancing scenario in its cash flow analysis,
and there were no interest shortfalls to the most senior classes
under this scenario. The 'BBsf' and 'Bsf' certificates experienced
roughly 25bps of write-downs in period 150, when delinquencies are
unlikely to result in a no-advancing scenario.

Expanded Prime Credit Quality (Mixed): The collateral consists of
15-year, 30-year and 40-year fixed-rate and adjustable-rate loans,
with 47.9% of the loans being adjustable rate; 17.9% of the loans
are interest-only loans and the remaining 82.1% are fully
amortizing loans. The pool is seasoned approximately five months in
aggregate. The borrowers in this pool have moderate credit profiles
with a 709 weighted average Fitch-calculated model FICO and
relatively low leverage, with a sustainable loan to value of 71.9%
.

Approximately 1.8% of the pool has experienced a non-servicing
transfer related delinquency in the past, but all loans are
current. Approximately 6.9% of the loans in the pool were
underwritten to foreign national or nonpermanent resident
borrowers. The pool characteristics resemble recent nonprime
collateral, and, therefore, the pool was analyzed using Fitch's
nonprime model.

Nonfull Documentation Loans (Negative): Approximately 68% of the
loans used alternative documentation to underwrite the loan. Of
this, 43.1% was underwritten to a bank statement program - 23.2% to
a 24-month bank statement program and 19.9% to a 12-month bank
statement program - for verifying income, which is not consistent
with Appendix Q standards or Fitch's view of a full documentation
program. To reflect the additional risk, Fitch increases the
probability of default by 1.5x on the bank statement loans.

A key distinction between this pool and legacy Alt-A loans is that
these loans adhere to underwriting and documentation standards
required under the Consumer Finance Protection Bureau's ATR rule,
which reduces the risk of borrower default arising from lack of
affordability, misrepresentation or other operational quality risks
due to the rigor of the rule's mandates for underwriting and
documenting a borrower's ability to repay.

Geographic Concentration (Negative): Approximately 54% of the pool
is concentrated in California with a moderate MSA concentration.
The largest MSA concentration is in the Los Angeles MSA (28.0%)
followed by the Miami MSA (9.6%) and the San Francisco MSA (6.0%).
The top three MSAs account for 43.6% of the pool. As a result,
there was an 83bp increase to the 'AAA' expected loss to account
for geographic concentration.

Sequential Payment Structure (Positive): The transaction's cash
flow is based on a sequential-pay structure whereby the subordinate
classes do not receive principal until the senior classes are
repaid in full. Losses are allocated in reverse-sequential order.
Furthermore, the provision to re-allocate principal to pay interest
on the 'AAAsf' and 'AAsf' rated certificates prior to other
principal distributions is highly supportive of timely interest
payments to those classes.

Low Operational Risk (Neutral): Verus Mortgage Capital, a wholly
owned subsidiary of Invictus Capital Partners, exceeds industry
standards needed to properly aggregate residential mortgage loans.
Verus' assessment as an 'Above Average' aggregator incorporates its
well-established underwriting team of 30 plus individuals, which is
atypical for most aggregators, controlled acquisition strategy, and
highly experienced management. Primary and master servicing
functions will be performed by Shellpoint Mortgage Servicing
(RPS2-/Negative)and Nationstar Mortgage LLC (RMS2+/Negative).

Alignment of Interests (Positive): The transaction benefits from an
alignment of interest between the issuer and investors. VMC Asset
Pooler, LLC, as sponsor, will retain a horizontal residual interest
of at least 5% of the aggregate certificate balance of all
certificates in the transaction, subject to both U.S. and European
risk retention rules.

R&W Framework (Negative): The R&W framework for this transaction is
classified as a Tier 2 due to the lack of an automatic review for
loans other than those with ATR realized losses. The R&Ws are being
provided by Invictus Alternative Credit Pooler, LLC and Invictus
Residential Pooler II, L.P., which do not have a financial credit
opinion or public rating from Fitch. The rep providers are the
parent of the sponsor. Fitch increased its loss expectations 166bps
at the 'AAAsf' rating category to account for the limitations of
the Tier 2 framework and the counterparty risk.

The number of unnecessary R&W breach reviews due to a loan going
delinquent due to coronavirus-related forbearance should be limited
as the R&W review trigger is based on the loan having a realized
loss and an ATR violation.

Due Diligence Review Results (Positive): Third-party due diligence
was performed on 100% of loans in the transaction by SitusAMC
(AMC), Clayton Services, Covius Real Estate Services and Edge
Mortgage Advisory Company, LLC (EdgeMac). The due diligence results
are in line with industry averages and 99% received an overall
grade of 'A' or 'B'. Loan exceptions with an overall grade 'B'
either had strong mitigating factors or were accounted for in
Fitch's loan loss model resulting in no additional adjustments.
Fitch applied adjustments for the three loans with overall grades
of 'C', which had an immaterial impact to the losses. The model
credit for the high percentage of loan level due diligence combined
with the adjustments for loan exceptions reduced the 'AAAsf' loss
expectation by 47bps.

RATING SENSITIVITIES

Fitch 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
that may be considered in the surveillance of the transaction.
Sensitivity analysis was conducted at the state and national levels
to assess the effect of higher MVDs for the subject pool, as well
as lower MVDs illustrated by a gain in home prices.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in up and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade:

This defined positive rating sensitivity analysis demonstrates how
the ratings would react to negative MVDs at the national level, or
positive home price growth with no assumed overvaluation. The
analysis assumes positive home price growth of 10%. Excluding the
senior class which is already 'AAAsf', the analysis indicates there
is potential positive rating migration for all of the rated
classes. Specifically a 10% gain in home prices would result in a
full category upgrade for the rated class excluding those being
assigned ratings of 'AAAsf'.

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade:

This defined negative rating 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 3.5%. The analysis indicates that there is some
potential rating migration with higher MVDs for all rated classes,
compared with the model projection. Specifically, a 10% additional
decline in home prices would lower all rated classes by one full
category.

Fitch has added a coronavirus sensitivity analysis that includes a
prolonged health crisis resulting in depressed consumer demand and
a protracted period of below-trend economic activity that delays
any meaningful recovery to beyond 2021. Under this severe scenario,
Fitch expects the ratings to be affected by changes in its
sustainable home price model due to updates to the model's
underlying economic data inputs. Any long-term effects arising from
coronavirus-related disruptions on these economic inputs will
likely affect both investment and speculative-grade ratings.



WELLS FARGO 2012-LC5: Fitch Affirms Bsf Rating on Class F Certs
---------------------------------------------------------------
Fitch Ratings has affirmed 10 classes of Wells Fargo Commercial
Mortgage Trust (WFCM) commercial mortgage pass-through
certificates, series 2012-LC5.

RATING ACTIONS

WFCM 2012-LC5

Class A-3 94988HAC5;  LT AAAsf Affirmed;  previously AAAsf

Class A-S 94988HAE1;  LT AAAsf Affirmed;  previously AAAsf

Class A-SB 94988HAD3; LT AAAsf Affirmed;  previously AAAsf

Class B 94988HAF8;    LT AA-sf Affirmed;  previously AA-sf

Class C 94988HAG6;    LT A-sf Affirmed;   previously A-sf

Class D 94988HAP6;    LT BBB-sf Affirmed; previously BBB-sf

Class E 94988HAR2;    LT BBsf Affirmed;   previously BBsf

Class F 94988HAT8;    LT Bsf Affirmed;    previously Bsf

Class X-A 94988HAK7;  LT AAAsf Affirmed;  previously AAAsf

Class X-B 94988HAM3;  LT A-sf Affirmed;   previously A-sf

KEY RATING DRIVERS

Improved Credit Enhancement, High Defeasance Percentage: Credit
enhancement has improved since issuance due to loan amortization,
defeasance and payoffs. As of the May 2020 reporting period, the
pool has paid down by 28.8% since issuance to $910.0 million from
$1.277 billion. The remaining pool matures between April and
October 2022. Pool defeasance has increased to 29.6% compared to
19.8% during Fitch's prior rating action in 2019 and includes two
former Fitch Loans of Concern (FLOCs) in the Top 15, Columbia SC
Hotel Portfolio (2.8%) and The Walker Building (2.1%). There are
six loans (14.7% of pool) that are full term interest-only, and the
remaining 55 loans (85.3%) in the pool are amortizing. Between July
and December 2020, three loans comprising approximately $59 million
prepaid including the top 15 loan Cole Retail 12 Portfolio.

Overall Stable Loss Expectations: Fitch's base case loss is inline
with loss expectations at issuance due to most of the loans in the
pool exhibiting stable property-level performance through year-end
2019. There are nine loans (15%) on the servicer's watchlist for
low DSCR, fluctuating performance, concentrated tenant rollover,
and high vacancy; three (6.4%) of which have been flagged as FLOCs.
Overall the pool contains six FLOCs (12.9%) including four (10.7%)
in the Top 15. The pool's sole specially serviced loan is Courtyard
by Marriott Wilmington, DE (.9%).

Exposure to Coronavirus: Of the non-defeased loans, there are six
(9.1% of pool) secured by hotels and have a weighted average NOI
DSCR of 2.41x. Twenty-one loans (25.9%) loans are secured by retail
properties and have a weighted average NOI DSCR of 1.81x. Fitch's
base case analysis applied additional stresses to six hotel loans
and 10 retail loans given the significant declines in
property-level cash flow expected in the short term as a result of
the decrease in travel, tourism and commerce, and property closures
from the coronavirus pandemic.

Included in this analysis are two crossed-collateralized,
cross-defaulted loans, Academy Sports + Outdoors - Columbia and
Academy Sports + Outdoors - Snellville (1.1%). Both loans are
collateralized by free standing Academy Sports Stores.

Additional Loss Consideration: Fitch applied an additional stress
scenario that assumed an outsized loss of 40% on the FLOC,
Rockville Corporate Center (3.7%), a two building office property
totaling 220,539 sf. One of the buildings is 98% lease to AARP with
a lease that expires in November 2021. Approximately 83% of the
AARP space is being marketed for sublease. The loan matures in May
2022. This stress scenario did not affect the Positive Outlook on
class B.

Specially Serviced Loan: Courtyard by Marriott Wilmington, DE
(.86%) is a 126 key, limited service hotel located in Wilmington,
DE. This loan transferred to special servicing in May 2020 for
imminent monetary default. Subject year-end 2018 NOI DSCR was
2.86x, and occupancy was 55% compared to underwritten NOI DSCR and
occupancy at issuance of 2.72x and 64%, respectively. The borrower
has requested payment relief due to the coronavirus pandemic.
Although no further details have been provided, Fitch assumed
losses on the loan.

RATING SENSITIVITIES

The Stable Outlooks on classes A-1 through A-S and classes C
through F reflect the overall stable performance of the pool and
expected continued amortization. The Positive Outlook on class B
reflects the potential for upgrade to 'AAsf' or 'AAAsf' if the
performance of the remaining pool is stable and/or properties
vulnerable to the coronavirus return to pre-pandemic levels. In the
event that the coronavirus pandemic is prolonged beyond 2020 and
property-level performance declines, the Outlook on class B will be
revised to Stable.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Factors that lead to upgrades would include stable to improved
asset performance coupled with pay down and/or defeasance. Upgrades
to classes B and C would likely occur with improvement in credit
enhancement and/or defeasance; however, adverse selection and
increased concentrations and further underperformance of the FLOC
or loans expected to be negatively impacted by the coronavirus
pandemic could cause this trend to reverse. Upgrades to class D
would also take into account these factors but would be limited
based on sensitivity to concentrations or the potential for future
concentration. Classes would not be upgraded above 'Asf' if there
were likelihood for interest shortfalls. An upgrade to classes E
and F are not likely until the later years in a transaction and
only if the performance of the remaining pool is stable and/or
properties vulnerable to the coronavirus return to pre-pandemic
levels, and there is sufficient CE to the class.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that lead to downgrades include an increase in pool level
losses from underperforming or specially serviced loans. Downgrades
to the 'Asf', 'AAsf' and 'AAAsf' categories are not likely due to
the position in the capital structure but may occur at the 'AAsf'
and 'AAAsf' categories should interest shortfalls occur. Downgrades
to classes D would occur should overall pool losses increase and/or
one or more large loans have an outsized loss, which would erode
credit enhancement. Downgrades to classes, E and would occur should
loss expectations increase due to an increase in specially serviced
loans and/or the loans vulnerable to the coronavirus pandemic not
stabilize.

In addition to its baseline scenario related to the coronavirus,
Fitch also envisions a downside scenario where the health crisis is
prolonged beyond 2021; should this scenario play out, Fitch expects
that a greater percentage of classes may be assigned a Negative
Rating Outlook or those with Negative Rating Outlooks will be
downgraded one or more categories.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


WELLS FARGO 2016-C35: Fitch Affirms Class F Certs at 'Bsf'
----------------------------------------------------------
Fitch Ratings has affirmed 15 classes of Wells Fargo Bank, National
Association commercial mortgage pass-through certificates, series
2016-C35.

WFCM 2016-C35      

  - Class A-1 95000FAQ9; LT AAAsf; Affirmed

  - Class A-2 95000FAR7; LT AAAsf; Affirmed

  - Class A-3 95000FAS5; LT AAAsf; Affirmed

  - Class A-4 95000FAT3; LT AAAsf; Affirmed

  - Class A-4FL 95000FBA3; LT AAAsf; Affirmed

  - Class A-4FX 95000FBC9; LT AAAsf; Affirmed

  - Class A-S 95000FAV8; LT AAAsf; Affirmed

  - Class A-SB 95000FAU0; LT AAAsf; Affirmed

  - Class B 95000FAY2; LT AA-sf; Affirmed

  - Class C 95000FAZ9; LT A-sf; Affirmed

  - Class D 95000FAC0; LT BBB-sf; Affirmed

  - Class E 95000FAE6; LT BBsf; Affirmed

  - Class F 95000FAG1; LT Bsf; Affirmed

  - Class X-A 95000FAW6; LT AAAsf; Affirmed

  - Class X-D 95000FAA4; LT BBB-sf; Affirmed

KEY RATING DRIVERS

Increased Loss Expectations: While the majority of the pool has
exhibited stable pool performance, loss expectations have increased
due to the increasing number of Fitch Loans of Concern and
additional stresses applied to loans expected to be impacted in the
near term from the coronavirus pandemic. Fitch identified 12 loans
as Fitch Loans of Concern (FLOCs; 24/9% of the pool) including the
three of the top five largest loans in the pool.

The largest FLOC is The Mall at Rockingham Park (6.1% of pool),
which is secured by 540,867 sf of a 1.024 million sf regional mall
located in Salem, NH. Lord & Taylor is a collateral anchor.
JCPenney and Macy's are non-collateral anchors. Recent reports
indicate that Lord & Taylor is considering bankruptcy and will be
liquidating inventory in all of its 38 stores once coronavirus
restrictions are lifted. Additionally, JC Penney is reportedly
preparing to file for bankruptcy and may close a quarter of its
stores. Sears, a former non-collateral anchor closed this location
in November 2018. The vacant Sears box, owned by Seritage, has been
partially subleased to Dick's Sporting Goods. A 12-screen Cinemark
Theater was built on another Seritage-owned parcel and opened in
December 2019. Comparable in-line tenant sales at the property
(excluding Apple) have increased to $542 psf at YE 2019 from $501
psf at issuance. Collateral occupancy was 93% and the
servicer-reported NOI debt service coverage ratio was 2.12x as of
YE 2019. Despite the high sales and DSCR, the loan has been
designed as a FLOC due to exposure to two anchor tenants that are
expected to file for bankruptcy and the potential for performance
declines. The Simon-owned mall is open upon the governor of New
Hampshire's plan to reopen retail businesses in the state. Although
all stores are able to open, Simon indicates that only half are
expected to be.

Another FLOC and the largest contributor to expected losses is the
fifth largest loan in the pool, the Mall at Turtle Creek (4%). The
loan, sponsored by Brookfield Properties, is secured by 329,398sf
of inline space within an enclosed mall located in Jonesboro, AR
(approximately 60 miles northwest of Memphis). Non-collateral
anchor tenants include JCPenney, Dillard's and Target. The largest
collateral tenants include Barnes and Noble, Bed Bath & Beyond,
Best Buy and H&M. Although the mall benefits from limited direct
competition, occupancy and tenant sales have both declined since
issuance. Collateral occupancy declined to 84% as of September2019
from 90.9% in December 2017 and 90.8% at issuance. The occupancy
decline was primarily due to tenants vacating at lease expiration.
In-line tenant sales have dropped to $329 psf as of March 2019 from
$349 psf around the time of issuance (as of TTM March 2016). In
March 2020, a tornado went through the Jonesboro area and caused
significant damage to the mall, including collapsing the walls of
the Best Buy store. Local reports indicate that damage estimates
are at least $100 million. There have been no updates regarding
insurance proceeds or plans for redevelopment.

High Retail and Hotel Concentration: Loans backed by retail
properties represent 34.6% of the pool, including six (24.1%) in
the top 15. Hotel loans represent 19.2% of the pool, including two
(7.4%) in the top 15 that have both been designated as FLOCs due to
expected revenue declines from the coronavirus pandemic.

The largest hotel loan in the pool is the Marriott Indianapolis
North (5.1%). It is secured by a 315-key, full-service hotel
located 20 miles north of the Indianapolis CBD. An $8 million
property improvement plan was completed in 2018 that included a
complete renovation of all guest rooms and updates to common areas.
As of the TTM ending January 2020, occupancy, ADR and RevPar were
reported to be 63.5%, $163.59 and $103.85, respectively, compared
to 66%, $153 and $99.50 at issuance. Columbia Sussex Corporation is
the loan sponsor. The loan remains current, but significant revenue
declines are expected from the coronavirus pandemic.

Minimal Credit Enhancement Improvement: As of the April 2020
distribution date, the pool's aggregate balance has been reduced by
3.6% to $985.6 million from $1.023 billion at issuance. Interest
shortfalls are currently affecting class G.

Coronavirus Exposure: The weighted average DSCR for all of the 19
hotel loans in the pool is approximately 1.90x and the WADSCR for
all of the 23 retail loans is approximately 1.87x. There are
currently two hotel loans (1%) in special servicing. A modification
for one loan (0.56%) was completed in March 2020 and a return to
the master servicer is expected. The other specially serviced loan
(0.47%) transferred in August 2019 for imminent default. The
servicer is pursuing foreclosure and the appointment of receiver
while dual tracking discussions with the borrower.

As part of its analysis, Fitch applied an additional stress on
loans that do not meet certain DSCR tolerance thresholds to address
the expected significant performance declines due to the
coronavirus pandemic. These additional stresses contributed to the
Negative Outlooks on classes E and F.

ESG: The transaction has an ESG Relevance Score of 4 for Exposure
to Social Impacts due to a mall that is underperforming as a result
of changing consumer preference to shopping, which has a negative
impact on the credit profile and is highly relevant to the
ratings.

RATING SENSITIVITIES

The Rating Outlook for classes E and F remain Negative due to
concerns with the FLOCs and the overall hotel and retail
concentration within the pool.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Sensitivity factors that lead to upgrades would include stable to
improved asset performance coupled with pay down and/or defeasance.
Upgrades of the 'AA-sf' and 'A-sf' rated classes would likely occur
with significant improvement in credit enhancement and/or
defeasance; however, adverse selection and increased
concentrations, further underperformance of the FLOCs could cause
this trend to reverse. An upgrade of the 'BBB-sf' class is
considered unlikely and would be limited based on sensitivity to
concentrations or the potential for future concentration. Classes
would not be upgraded above 'Asf' if there is likelihood for
interest shortfalls. An upgrade of the 'BBsf' and 'Bsf' categories
are not likely until the later years of the transaction and only if
the performance of the remaining pool is stable and/or properties
vulnerable to the coronavirus return to pre-pandemic levels, and
there is sufficient CE to the class. The Rating Outlook on classes
E and F may be revised back to Stable if pool performance and/or
properties vulnerable to the coronavirus stabilize once the
pandemic is over.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Sensitivity factors that lead to downgrades include an increase in
pool level losses from underperforming loans or specially serviced
loans. Downgrades to the 'AAAsf' categories are not likely in the
near term due to the position in the capital structure and high CE,
but may occur with interest shortfalls. Downgrades of a category or
more are likely to classes B through F should overall pool loss
expectations increase and/or properties vulnerable to the
coronavirus fail to return to pre-pandemic levels or should
insurance proceeds for the Mall at Turtle Creek be insufficient to
repay the loan.

In addition to its baseline scenario, Fitch also envisions a
downside scenario where the health crisis is prolonged beyond 2021;
should this scenario play out, classes with Negative Rating
Outlooks will be downgraded one or more categories. For more
information on Fitch's original rating sensitivity on the
transaction, please refer to the new issuance report.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The transaction has an ESG Relevance Score of 4 for Exposure to
Social Impacts due to a mall that is underperforming as a result of
changing consumer preference to shopping, which has a negative
impact on the credit profile and is highly relevant to the
ratings.

Except for the matters discussed, the highest level of ESG credit
relevance, if present, is a score of 3. ESG issues are credit
neutral or have only a minimal credit impact on the entity, either
due to their nature or the way in which they are being managed by
the entity.


WELLS FARGO 2017-C38: Fitch Affirms Class F Certs at 'B-sf'
-----------------------------------------------------------
Fitch Ratings has affirmed 15 classes of Wells Fargo Commercial
Mortgage Trust 2017-C38 commercial mortgage pass-through
certificates.

WELLS FARGO COMMERCIAL MORTGAGE TRUST 2017-C38    

  - Class A-1 95001MAA8; LT AAAsf; Affirmed

  - Class A-2 95001MAB6; LT AAAsf; Affirmed

  - Class A-3 95001MAC4; LT AAAsf; Affirmed

  - Class A-4 95001MAE0; LT AAAsf; Affirmed

  - Class A-5 95001MAF7; LT AAAsf; Affirmed

  - Class A-S 95001MAG5; LT AAAsf; Affirmed

  - Class A-SB 95001MAD2; LT AAAsf; Affirmed

  - Class B 95001MAK6; LT AA-sf; Affirmed

  - Class C 95001MAL4; LT A-sf; Affirmed

  - Class D 95001MAP5; LT BBB-sf; Affirmed

  - Class E 95001MAR1; LT BB-sf; Affirmed

  - Class F 95001MAT7; LT B-sf; Affirmed

  - Class X-A 95001MAH3; LT AAAsf; Affirmed

  - Class X-B 95001MAJ9; LT A-sf; Affirmed

  - Class X-D 95001MAM2 LT BBB-sf; Affirmed

KEY RATING DRIVERS

Increased Loss Expectations: While the majority of the pool has
exhibited stable performance since issuance, loss expectations have
increased primarily due to the Fitch Loans of Concern. Twenty-two
loans (17.1% of the pool) are considered FLOCs primarily due to
higher stresses, which were applied to hotel, retail and
multifamily loans that failed to meet certain net operating income
debt-service coverage ratio thresholds, given the expected declines
in performance related to the coronavirus pandemic. There are
currently no specially serviced or delinquent loans.

The largest FLOC, Raleigh Marriott City Center (2.6% of the pool),
is secured by a 400-key full-service hotel located in downtown
Raleigh. The hotel is one of two hotels that connect to the Raleigh
Convention Center through an underground walkway. The property also
has a block rate agreement with the city for events, in which the
ADR is agreed to in advance. As of YE 2019, the property's
occupancy, average daily rate and revenue per available room was
79.8%, $167 and $133, respectively, compared to 69.1%, $162 and
$112 as of YE 2018. Fitch expects declines in performance related
to the coronavirus pandemic, coupled with the property's connection
to the nearby convention center.

The second and third largest FLOCs are TownePlace Boynton Beach
(1.4% of the pool) and TownePlace VA (1.3% of the pool). The
TownePlace Boyton Beach loan is secured by a 116-key hotel located
in Boyton Beach, FL; the TownePlace VA loan is secured by two
cross-collateralized hotels totaling 186-keys located in Stafford
Beach, VA and Fredericksburg, VA. Although both loans have
exhibited relatively stable performance since issuance, Fitch
expects declines in performance related to declines in travel due
to the coronavirus pandemic. As of YE 2019, TownePlace Boyton
Beach's occupancy, ADR and RevPAR were 83.2%, $134 and $111,
respectively from 88.7%, $138 and $123 as of YE 2018. TownePlace VA
reported occupancy, ADR and RevPAR of 81.7%, $149 and $122,
respectively, as of YE 2018 from 79%, $146 and $115 as of YE 2017.

The third largest FLOC, the Holiday Inn Ames (1.2% of the pool), is
secured by a 112-key hotel loan located in Ames, IA. The loan is
currently on the master servicer's watchlist and the property has
reported declining performance since issuance. Per the master
servicer, the declines in performance are primarily related to
declining enrollment at Iowa State University, which is down by 10%
since issuance, and the underperformance of the school's sports
programs, causing a lack of demand for rooms during the football
and basketball seasons. The property is located near the main
campus for Iowa State University. As of the TTM ended February
2020, the property reported occupancy, ADR and RevPAR of 68.9%,
$129 and $89, respectively, from 65.9%, $136 and $90 as of YE 2018.
The property's RevPAR penetration rate is 133.3% as of TTM February
2020. The property's NOI DSCR as of June 2019 was 1.44x from 1.41x
at YE 2018 and 1.90x at issuance. The declines in NOI are primarily
related to the declining occupancy since issuance. Fitch expects
performance to continue to decline given the declines in travel
related to the coronavirus pandemic.

The remaining FLOCs failed to meet various NOI DSCR tolerance
thresholds and additional stresses were also applied to these loans
to address the declines in performance related to the coronavirus
pandemic. Fitch will continue to monitor the loans for further
updates.

Increasing Credit Enhancement/Defeasance: As of the April 2020
remittance, the pool balance has been reduced by 1.4% to $1.14
billion from $1.15 billion at issuance. No loans are defeased.
Eighteen loans (57.4% of the pool) have interest only payments,
including 12 loans (51.1% of the pool) in the top 15. Twelve loans
(13.5% of the pool) have partial interest only payments, including
two loans (5.6% of the pool) in the top 15. Of the loans with
partial interest only payments, six loans (5.2% of the pool) are
now amortizing. The remaining loans are amortizing.

Coronavirus Exposure: Significant economic impact to certain
hotels, retail and multifamily properties is expected from the
coronavirus pandemic, due to the recent and sudden reductions in
travel and tourism, temporary property closures and lack of clarity
on the potential length of the impact. The pandemic has already
prompted the closure of several hotel properties in gateway cities
as well as malls, entertainment venues and individual stores.

Fourteen loans (16.8% of the pool) are secured by hotel loans and
24 loans (25.5% of the pool) are secured by retail properties. The
hotel loans have a weighted average debt service coverage ratio of
2.32x. On average, the hotel loans can sustain an average decline
of 54% before the NOI DSCR would fall below 1.0x. However,
excluding the largest hotel loan, the Starwood Hotel Portfolio
(4.4% of the pool), which has a DSCR of 2.98x, the hotel loans have
an WADSCR of 2.10x and would sustain a 49.6% decline in NOI before
the DSCR falls below 1.0x.

On average, the retail loans have a WADSCR of 2.24x and would
sustain a 52.5% decline in NOI before the DSCR would fall below
1.0x. Excluding the top retail loan, Del Amo Fashion Center (5.3%
of the pool), the retail loans have a WADSCR of 2.10x and would
sustain an average 49.8% decline in NOI before the DSCR falls below
1.0x. Fitch applied additional stresses to hotel, retail and
multifamily loans to account for potential cash flow disruptions
due to the coronavirus pandemic. These additional stresses
contributed to the Negative Outlook on class F.

Maturity Concentrations: Three loans (4.0% of the pool) have
maturity dates in 2022, one loan (0.8% of the pool) in 2024 and one
loan (2.9% of the pool) in 2026. The remaining loans mature in
2027.

RATING SENSITIVITIES

Near-term rating changes are limited, as indicated by the
sufficient CE, continued amortization, relatively stable
performance of the pool as evidenced by the Stable Outlooks on
classes A-1 through E. The Negative Outlook on class F reflects
performance concerns with hotel and retail properties due to the
decline in travel and commerce as a result of the coronavirus
pandemic.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Factors that could lead to upgrades would include stable to
improved asset performance, coupled with additional pay down and/or
defeasance. Upgrades to the 'A-sf' and 'AA-sf' rated classes would
likely occur with significant improvement in CE and/or defeasance;
however, adverse selection and increased concentrations, or the
underperformance of the FLOC could cause this trend to reverse.

Upgrades of the 'BBB-sf' and below-rated classes are considered
unlikely and would be limited based on the sensitivity to
concentrations or the potential for future concentrations. Classes
would not be upgraded above 'Asf' if there is a likelihood for
interest shortfalls. An upgrade to the 'BB-sf' and 'B-sf' rated
classes is not likely until the later years in the transaction and
only if the performance of the remaining pool is stable and/or if
there is sufficient credit enhancement, which would likely occur
when the non-rated class is not eroded and the senior classes pay
off.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that could lead to downgrades include an increase in pool
level losses due to underperforming or specially serviced loans.
Downgrades to the senior classes, rated 'AA-sf' through 'AAAsf',
are not likely due to the position in the capital structure and the
high credit enhancement; however, downgrades of these classes may
occur should interest shortfalls occur. Downgrades to the classes
rated 'BBB-sf' and below would occur if the performance of the
FLOCs continue to decline or fails to stabilize. The Rating Outlook
on class F may be revised back to Stable if performance of the
FLOCs improves and/or properties vulnerable to the coronavirus
stabilize once the pandemic is over.

In addition to its baseline scenario, Fitch also envisions a
downside scenario where the health crisis is prolonged beyond 2021;
should this scenario play out, Fitch expects that a greater
percentage of classes may be assigned a Negative Outlook or those
with Negative Rating Outlooks will be downgraded one or more
categories.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


WELLS FARGO 2018-C45: Fitch Affirms B-sf Rating on Cl. H-RR Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed 16 classes of Wells Fargo Commercial
Mortgage (WFCM) Trust 2018-C45 Commercial Mortgage Pass-Through
Certificates.

RATING ACTIONS

Wells Fargo Commercial Mortgage Trust 2018-C45

Class A-1 95001NAU2;  LT AAAsf Affirmed;  previously AAAsf

Class A-2 95001NAV0;  LT AAAsf Affirmed;  previously AAAsf

Class A-3 95001NAX6;  LT AAAsf Affirmed;  previously AAAsf

Class A-4 95001NAY4;  LT AAAsf Affirmed;  previously AAAsf

Class A-S 95001NBB3;  LT AAAsf Affirmed;  previously AAAsf

Class A-SB 95001NAW8; LT AAAsf Affirmed;  previously AAAsf

Class B 95001NBC1;    LT AA-sf Affirmed;  previously AA-sf

Class C 95001NBD9;    LT A-sf Affirmed;   previously A-sf

Class D 95001NAC2;    LT BBB-sf Affirmed; previously BBB-sf

Class E-RR 95001NAE8; LT BBB-sf Affirmed; previously BBB-sf

Class F-RR 95001NAG3; LT BB+sf Affirmed;  previously BB+sf

Class G-RR 95001NAJ7; LT BB-sf Affirmed;  previously BB-sf

Class H-RR 95001NAL2; LT B-sf Affirmed;   previously B-sf

Class X-A 95001NAZ1;  LT AAAsf Affirmed;  previously AAAsf

Class X-B 95001NBA5;  LT A-sf Affirmed;   previously A-sf

Class X-D 95001NAA6;  LT BBB-sf Affirmed; previously BBB-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: Overall pool performance
and loss expectations have remained stable since issuance. There
have been no specially serviced loans since issuance. Four loans
(5.9% of the pool) have been designated as Fitch Loans of Concern
(FLOCs), as they are 30 days delinquent as of the May 2020
distribution.

The largest FLOC, Montclair East (2.2%), is secured by a 135,603-sf
anchored retail center located in Montclair, CA. Property occupancy
fell to 83.2% from 100% at issuance after Fallas Discount Stores
(16.8% of NRA) vacated in 4Q18. The former Fallas space was leased
on a short-term basis to seasonal tenant Spirit Halloween between
July 2019 and November 2019. Fitch has an outstanding inquiry to
the servicer to confirm whether a Best Buy Outlet store has leased
and taken occupancy of the former Fallas space at the property. The
servicer-reported NOI DSCR was 2.12x as of YTD September 2019.

The three other FLOCs outside of the top 15 are secured by a
mixed-use property consisting of 241 multifamily units and 53,942
sf of retail space located in Cleveland, OH (2.0%); a 110-key
limited service hotel located in Omaha, NE (1.0%); and a 63-unit
multifamily property located in Dundalk, MD (0.6%).

Minimal Change in Credit Enhancement: As of the May 2020
distribution date, the pool's aggregate balance has paid down by
0.5% to $655.6 million from $658.8 million at issuance. No loans
have been paid off or defeased. At issuance, based on the scheduled
balance at maturity, the pool was expected to pay down by 8.7%. Ten
loans (25.6% of the current pool), including five of the top 15
loans, are full-term interest-only and 16 loans (45.5%) remain in
partial interest-only periods. Loan maturities are concentrated in
2028 (98.9%), with 0.8% in 2023 and 0.3% in 2027.

Alternative Loss Considerations: Fitch performed an additional
sensitivity scenario that assumed a potential outsized loss of 15%
on the maturity balance of the CoolSprings Galleria to reflect the
loan's weak sponsorship, the property's overlapping anchors with
nearby competing malls and declining sales. This additional
sensitivity scenario did not affect the ratings or Outlooks.

Coronavirus Exposure: Five loans (6.6%) are secured by hotel
properties. The weighted average (WA) NOI DSCR for the hotel loans
is 2.30x; these hotel loans could sustain a decline in NOI of 56%
before DSCR falls below 1.0x. Sixteen loans (35.1%) are secured by
retail properties, including the largest loan in the pool. The WA
NOI DSCR for the retail loans is 2.04x; these retail loans could
sustain a decline in NOI of 50% before DSCR falls below 1.0x. Three
loans (10.2%) are secured by multifamily properties, including two
loans in the top 10. The WA NOI DSCR for the multifamily loans is
1.57x; these multifamily loans could sustain a WA decline in NOI of
36% before DSCR falls below 1.0x. Additional coronavirus specific
stresses were applied to five hotel loans and one retail loan;
these additional stresses did not affect the ratings or Outlooks.

Credit Opinion Loan: One loan, 181 Fremont Street (3.1% of the
pool), had an investment-grade credit opinion of BBB-sf* on a
stand-alone basis at issuance.

Additional Debt: Two loans totaling 9.5% of the pool have
additional mezzanine financing and two loans totaling 7.8% of the
pool have subordinate secured financing.

RATING SENSITIVITIES

Near-term rating changes are expected to be limited as indicated by
the sufficient credit enhancement, continued amortization and
stable performance of the pool as evidenced by the Stable Rating
Outlooks assigned to classes A-1 through H-RR.

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade:

Sensitivity factors that lead to upgrades would include stable to
improved asset performance coupled with pay down and/or defeasance.
Upgrades to the 'Asf' and 'AAsf' categories would likely occur with
significant improvement in credit enhancement and/or defeasance;
however, adverse selection, increased concentrations and further
underperformance of the FLOCs or loans expected to be negatively
affected by the coronavirus pandemic could cause this trend to
reverse. Upgrades to the 'BBBsf' category would also take into
account these factors, but would be limited based on sensitivity to
concentrations or the potential for future concentration. Classes
would not be upgraded above 'Asf' if there were likelihood for
interest shortfalls. Upgrades to the 'Bsf' and 'BBsf' categories
are not likely until the later years in a transaction and only if
the performance of the remaining pool is stable and/or properties
vulnerable to the coronavirus return to pre-pandemic levels, and
there is sufficient credit enhancement to the classes.

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade:

Sensitivity factors that lead to downgrades include an increase in
pool level losses from underperforming or specially serviced loans.
Downgrades to the 'Asf', 'AAsf' and 'AAAsf' categories are not
likely due to the position in the capital structure, but may occur
at the 'AAsf' and 'AAAsf' categories should interest shortfalls
occur. Downgrades to the 'BBsf' and 'BBBsf' categories would occur
should overall pool losses increase and/or one or more large loans
have an outsized loss, which would erode credit enhancement.
Downgrades to the 'Bsf' category would occur should loss
expectations increase due to an increase in specially serviced
loans and/or the loans vulnerable to the coronavirus pandemic not
stabilize.

In addition to its baseline scenario related to the coronavirus,
Fitch also envisions a downside scenario where the health crisis is
prolonged beyond 2021; should this scenario play out, Fitch expects
negative rating actions, including downgrades or Negative Rating
Outlook revisions.

ESG CONSIDERATIONS

The highest level of ESG credit relevance, if present, is a score
of 3. This means ESG issues are credit-neutral or have only a
minimal credit impact on the entity(ies), either due to their
nature or to the way in which they are being managed by the
entity(ies).


WFCM 2020-C56: Fitch to Rate $7.3MM Class J-RR Certs 'B-sf'
-----------------------------------------------------------
Fitch Ratings has issued a presale report on WFCM 2020-C56
commercial mortgage pass-through certificates, series 2020-C56.

RATING ACTIONS

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

  -- $18,464,000 class A-1 'AAAsf'; Outlook Stable;

  -- $54,939,000 class A-2 'AAAsf'; Outlook Stable;

  -- $2,605,000 class A-3 'AAAsf'; Outlook Stable;

  -- $29,226,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $200,000,000ae class A-4 'AAAsf'; Outlook Stable;

  -- $206,562,000ae class A-5 'AAAsf'; Outlook Stable;

  -- $511,796,000b class X-A 'AAAsf'; Outlook Stable;

  -- $127,035,000bf class X-B 'A-sf'; Outlook Stable;

  -- $62,147,000e class A-S 'AAAsf'; Outlook Stable;

  -- $35,643,000 class B 'AA-sf'; Outlook Stable;

  -- $29,245,000f class C 'A-sf'; Outlook Stable;

  -- $10,967,000cdf class D-RR 'BBB+sf'; Outlook Stable;

  -- $10,968,000,00cd class E-RR 'BBBsf'; Outlook Stable;

  -- $16,450,000cdf class F-RR 'BBB-sf'; Outlook Stable;

  -- $7,312,000,000cd class G-RR 'BB+sf'; Outlook Stable.

  -- $7,311,000cd class H-RR 'BB-sf'; Outlook Stable;

  -- $7,311,000cd class J-RR 'B-sf'; Outlook Stable;

The following class is not expected to be rated by Fitch:

  -- $31,988,094cd class K-RR;

(a) The initial certificate balances of classes A-4 and A-5 are
unknown and expected to be $406,562,000 in aggregate. The
certificate balances will be determined based on the final pricing
of those classes of certificates. The expected class A-4 balance
range is $50,000,000 to $406,562,000, and the expected class A-5
balance range is $206,562,000 to $356,562,000. The balances of
classes A-4 and A-5 shown above are the hypothetical balance for
A-4 if A-5 were sized at the minimum of its range. In the event
that the class A-4 certificates are issued with an initial
certificate balance of $406,562,000, the class A-5 certificates
will not be issued.

(b) Notional amount and interest-only.

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

(d) Non-offered horizontal credit-risk retention interest.

(e) Exchangeable Certificates. The class A-4, class A-5, class A-S
certificates are exchangeable certificates. Each class of
exchangeable certificates may be exchanged for the corresponding
classes of exchangeable certificates, and vice versa. The dollar
denomination of each of the received classes of certificates must
be equal to the dollar denomination of each of the surrendered
classes of certificates. The class A-4 may be surrendered (or
received) for the received (or surrendered) classes A-4-1, A-4-2,
A-4-1X, and A-4-2X. The class A-5 may be surrendered (or received)
for the received (or surrendered) class A-5-1, A-5-2, A-5-1X, and
A-5-2X. The class A-S may be surrendered (or received) for the
received (or surrendered) class A-S-1, A-S-2, A-S-1X, and A-S-2X.
The ratings of the exchangeable classes would reference the ratings
on the associated referenced or original classes.

(f) The initial certificate balance of class C, class X-B, class
D-RR, and class F-RR certificates are subject to change based on
final pricing of all certificates and the final determination of
the Class D-RR, E-RR, F-RR, G-RR, H-RR, J-RR and K-RR certificates
(collectively, the horizontal risk retention certificates) that
will be retained by the retaining sponsor through a third-party
purchaser as part of the U.S. risk retention requirements.

The expected ratings are based on information provided by the
issuer as of May 21, 2020.

TRANSACTION SUMMARY

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 46 loans secured by 66
commercial properties having an aggregate principal balance of
$731,138,094 as of the cut-off date. The loans were contributed to
the trust by Wells Fargo Bank, National Association, Column
Financial, Inc., LMF Commercial, LLC (f/k/a Rialto Mortgage
Finance, LLC), UBS AG, Barclays Capital Real Estate Inc., Ladder
Capital Finance LLC, and Argentic Capital Finance LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 65.7% of the properties
by balance, cash flow analysis of 94.3% and asset summary reviews
on 100.0% of the pool.

Coronavirus Impact: The ongoing containment effort related to the
coronavirus (which causes the COVID-19 disease) pandemic may have
an adverse impact on near-term revenue (i.e. bad debt expense, rent
relief) and operating expenses (i.e. sanitation costs) for some
properties in the pool. Delinquencies may occur in the coming
months as forbearance programs are put in place, although the
ultimate impact on credit losses will depend heavily on the
severity and duration of the negative economic impact of the
coronavirus pandemic, and to what degree fiscal interventions by
the U.S. federal government can mitigate the impact on consumers.
Per the offering documents, all of the loans are current and not
subject to any forbearance or modification requests.

KEY RATING DRIVERS

Fitch Leverage Exceeds that of Recent Transactions: The pool has
higher leverage than other, recent, Fitch-rated multiborrower
transactions. The pool's Fitch LTV of 108.0% is higher than the YTD
2020 average of 97.9% and the 2019 average of 103.0%. The pool's
Fitch DSCR of 1.20x is lower than the YTD 2020 average of 1.33x and
the 2019 average of 1.26x.

Favorable Property Type Concentrations: The pool includes eight
loans (9.7% of pool) secured by retail properties and no loans
secured by hotel properties. Multifamily properties represent the
largest concentration at 45.2%, which is higher than the YTD 2020
and 2019 average multifamily concentrations of 20.4% and 16.9%,
respectively. In Fitch's multiborrower model, multifamily
properties have a below-average likelihood of default, all else
equal. Office properties, which represent the second largest
concentration at 26.5% of the pool, have an average likelihood of
default in Fitch's multiborrower model, all else equal.

Above-Average Volatility: The pool's weighted average (WA)
volatility score is 3.60, which is above the YTD 2020 and 2019
averages of 3.11 and 3.20, respectively. Twenty-three loans (39.5%
of pool) in the pool have been assigned a '3' volatility score, and
23 loans (60.5%) have been assigned a '4'. Asset volatility scores
and probability of default are directly related; a lower asset
volatility score results in a lower probability of default. Asset
volatility scores range from 1-5, with 1 the least volatile and 5
the most volatile.

Pool Concentration: The top 10 loans represent 51.4% of the pool,
which is consistent with the YTD 2020 average of 51.3% and the 2019
average of 51.0%. However, the losses estimated by Fitch's
deterministic test at 'AAAsf' for this transaction exceeded the
base model loss estimate. The results of the deterministic test
increased Fitch's concluded loss estimate at 'AAAsf' by
approximately 50 bps.

RATING SENSITIVITIES

This section provides insight into the sensitivity of ratings when
one assumption is modified, while holding others equal. For U.S.
CMBS, the sensitivity reflects the impact of changes to property
net cash flow (NCF) in up- and down-environments. The results
should only be considered as one potential outcome, as the
transaction is exposed to multiple dynamic risk factors. It should
not be used as an indicator of possible future performance.

Factors that Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade :

  -- Declining cash flow decreases property value and capacity to
meet its debt service obligations. The table indicates the model
implied rating sensitivity to changes in one variable, Fitch NCF:

Original Rating: AAAsf / AA-sf / A-sf / BBB+sf / BBBsf / BBB-sf /
BB+sf

10% NCF Decline: A+sf / BBB+sf / BBB-sf / BB+sf / BB+sf / B+sf /
CCCsf

20% NCF Decline: BBBsf / BBB-sf / BB-sf / Bsf / CCCsf / CCCsf /
CCCsf

30% NCF Decline: BBB-sf / BB-sf / CCCsf / CCCsf / CCCsf / CCCsf /
CCCsf

Factors that Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade:

  -- Similarly, improvement in cash flow increases property value
and capacity to meet its debt service obligations. The table
indicates the model implied rating sensitivity to changes to the
same one variable, Fitch NCF:

Original Rating: AAAsf / AA-sf / A-sf / BBB+sf / BBBsf / BBB-sf /
BB+sf

20% NCF Increase: AAAsf / AAAsf / AA+sf / AA+sf / AA-sf / A-sf /
BBB+sf


[*] Fitch Alters Outlook on 53 Tranches From 24 CMBS Deals to Neg.
------------------------------------------------------------------
Fitch Ratings has revised the Rating Outlooks on 53 classes from 24
U.S. CMBS conduit transactions from the 2015 vintage to Negative
from Stable.

Fitch reviewed the following six 2015 transactions, COMM
2015-CCRE26, COMM 2015-CCRE25, WFCM 2015-SG1, COMM 2015-CCRE24, MSC
2015-UBS8 and CGCMT 2015-GC33, in the past five weeks, and assigned
Negative Rating Outlooks at that time. No further actions were
taken on these six deals for this review.

As part of the review, Fitch analyzed its entire portfolio of 2015
U.S. CMBS conduit transactions, which consists of 39 deals. The
review focused solely on the impact of the coronavirus pandemic on
the transactions. Including the transactions listed, 30
transactions from the 2015 vintage now have at least one class with
a Negative Outlook. Nine transactions have Stable Rating Outlooks
on all outstanding classes.

CSAIL 2015-C1      

  - Class B 126281BE3; LT AA-sf Revision Outlook

  - Class C 126281BF0; LT A-sf Revision Outlook

  - Class D 126281AL8; LT BBB-sf Revision Outlook

  - Class X-D 126281AC8; LT BBB-sf Revision Outlook

MSBAM 2015-C26      

  - Class E 61690VAG3; LT BB-sf Revision Outlook

  - Class F 61690VAJ7; LT B-sf Revision Outlook

WFCM 2015-C26      

  - Class D 94989CAG6; LT BBB-sf Revision Outlook

MSBAM 2015-C23      

  - Class F 61690QAW9; LT B-sf Revision Outlook

GSMS 2015-GC34      

  - Class D 36250VAM4; LT BBB-sf Revision Outlook

  - Class X-D 36250VAN2; LT BBB-sf Revision Outlook

CSAIL 2015-C3      

  - Class B 12635FAY0; LT AA-sf Revision Outlook

  - Class C 12635FAZ7; LT A-sf Revision Outlook

  - Class X-B 12635FAW4; LT AA-sf Revision Outlook

CSAIL 2015-C4      

  - Class G 12635RAN8; LT B-sf Revision Outlook

CGCMT 2015-GC29      

  - Class E 17323VAC9; LT BBsf Revision Outlook

  - Class F 17323VAE5; LT Bsf Revision Outlook

GSMS 2015-GS1      

  - Class D 36252AAL0; LT BBB-sf Revision Outlook

  - Class E 36252AAN6; LT BB-sf Revision Outlook

  - Class X-D 36252AAM8; LT BBB-sf Revision Outlook

WFCM 2015-C29      

  - Class E 94989KAE3; LT BBsf Revision Outlook

CGCMT 2015-GC35      

  - Class C 17324KAT5; LT A-sf Revision Outlook

  - Class D 17324KAU2; LT BBB-sf Revision Outlook

  - Class PEZ 17324KAY4; LT A-sf Revision Outlook

  - Class X-D 17324KAX6; LT BBB-sf Revision Outlook

WFCM 2015-NXS4      

  - Class F 94989XAN5; LT BB-sf Revision Outlook

  - Class X-F 94989XAA3; LT BB-sf Revision Outlook

COMM 2015-LC19      

  - Class E 200474AG9 LT BB-sf Revision Outlook

  - Class F 200474AJ3; LT B-sf Revision Outlook

COMM 2015-LC23      

  - Class E 12636FAN3; LT BBB-sf Revision Outlook

  - Class F 12636FAQ6; LT BB-sf Revision Outlook

  - Class G 12636FAS2; LT B-sf Revision Outlook

  - Class X-C 12636FAC7; LT BBB-sf Revision Outlook

  - Class X-D 12636FAE3; LT BB-sf Revision Outlook

COMM 2015-CCRE27      

  - Class E 12635QAN0; LT BB-sf Revision Outlook

  - Class F 12635QAQ3; LT B-sf Revision Outlook

MSBAM 2015-C25      

  - Class F 61765TAR4; LT B-sf Revision Outlook

GSMS 2015-GC32      

  - Class D 36250PAM7; LT BBB-sf Revision Outlook

  - Class E 36250PAP0; LT BBsf Revision Outlook

  - Class F 36250PAR6; LT Bsf Revision Outlook

  - Class X-D 36250PAN5; LT BBB-sf Revision Outlook

JPMCC 2015-JP1      

  - Class F 46590KAS3; LT BBsf Revision Outlook

  - Class G 46590KAU8; LT B-sf Revision Outlook

WFCM 2015-C31      

  - Class E 94989WAD9; LT BB-sf Revision Outlook

CGCMT 2015-P1      

  - Class F 17324DAG9; LT Bsf Revision Outlook

MSBAM 2015-C21      

  - Class D 61764XAN5; LT BBB-sf Revision Outlook

  - Class E 61764XAQ8; LT BB-sf Revision Outlook

  - Class X-E 61764XAG0; LT BB-sf Revision Outlook

WFCM 2015-NXS1      

  - Class F 94989HBU3; LT B-sf Revision Outlook

WFCM 2015-C30      

  - Class F 94989NAQ0; LT B-sf Revision Outlook

MSBAM 2015-C22      

  - Class B 61690FAQ6; LT AA-sf Revision Outlook

  - Class C 61690FAS2; LT A-sf Revision Outlook

  - Class PST 61690FAR4; LT A-sf Revision Outlook

  - Class X-B 61690FAA1; LT AA-sf Revision Outlook

KEY RATING DRIVERS

The Negative Rating Outlooks reflect the potential for future
downgrades stemming from an increase in expected losses due to
Fitch's anticipation of a significant negative economic impact and
property performance deterioration due to the coronavirus pandemic.
Near-term cash flow performance is expected to decline on certain
properties. However, it is difficult to discern at this time which
loans will ultimately default and whether the default will result
in losses to the trust given the lack of clarity about the length
of the pandemic and permanence of the performance declines.

For property sectors highly vulnerable to the coronavirus pandemic,
Fitch has assumed significant declines in cash flow occurring over
the next two to four months: for hotel, a 65% decline; for retail,
a 45% decline; and for multifamily, a 20% decline. After applying
the declines to cash flow, Fitch assumed any loan with a resulting
debt service coverage ratio of less than 0.95x would have a 75%
probability of default. For the hotel sector, the cash flow stress
is roughly equivalent to a loan with the most recent
servicer-reported DSCR of 2.75x moving to 0.95x; for retail, the
most recent servicer-reported DSCR of 1.75x moving to 0.95x; and
for multifamily, the most recent servicer-reported DSCR of 1.20x
moving to 0.95x. Although Fitch expects significant defaults among
for properties that suffer the harshest short-term cash flow
declines, some well-capitalized sponsors will be willing and able
to support their properties through this period, particularly those
in high demand locations. Fitch does not expect loans to be
liquidated in any great number prior to the end of 2Q21, when the
agency's "Global Economic Outlook" envisages a slow recovery will
be under way. The expected losses for the loans assumed to default
were calculated by applying Fitch's stressed cap rate to the most
recent servicer-reported net operating income less a haircut of 26%
for hotel, 20% for retail and 15% for multifamily. Fitch's stressed
cap rates generally range between 10.25%-13.50% for hotel,
8.00%-11.25% for retail and 8.00%-10.00% for multifamily.

Fitch did not apply distinct coronavirus stresses for office and
industrial properties; however, individual factors such as tenancy,
lease term, demand drivers and location were considered. For
example, single-tenant office properties with unrated tenants and
office properties with significant exposure to co-working tenants
were assumed likely to default.

The rating actions at this time were limited to Negative Rating
Outlooks. Over the next few months, Fitch will monitor the
performance of the loans in the transactions to evaluate if actual
defaults are occurring in line with Fitch's expectations. A
significant divergence to the downside may accelerate ratings
downgrades. Otherwise, ratings changes, if any, will likely occur
in 2021 with a clearer view of how an economic recovery is
affecting property performance and values.

Additionally, all of the transactions will be subject to their
annual review over the next 12 months, and Fitch's analysis will
incorporate adjustments, both less and more stressful, if
warranted, based on idiosyncratic features of the loans and
properties.

The transactions that were not assigned Negative Rating Outlooks
had several common factors, including increased credit enhancement
from paydowns and/or defeasance, lower concentrations of loans to
sectors vulnerable to the pandemic and/or higher DSCRs relative to
Fitch's assumptions on default risk.

By rating category, a summary of the current ratings and
transaction characteristics of the 53 classes from the 24
transactions with Negative Outlook revisions is included:

Five classes from three transactions in the 'AAsf' category.

  -- These three transactions include: CSAIL 2015-C1, CSAIL 2015-C3
and MSBAM 2015-C22;

  -- Average hotel concentration of 23% (ranging between 23%-24%);

  -- Average retail concentration of 30% (ranging between
26%-33%).

Six classes from four transactions in the 'Asf' category.

  -- These four transactions include: CGCMT 2015-GC35, CSAIL
2015-C1, CSAIL 2015-C3 and MSBAM 2015-C22;

  -- Average hotel concentration of 23% (ranging between 23%-24%);

  -- Average retail concentration of 30% (ranging between
26%-33%).

Fourteen classes from eight transactions in the 'BBBsf' category.

-- These eight transactions include: COMM 2015-LC23, GSMS
2015-GC32, GSMS 2015-GC34, GSMS 2015-GS1, MSBAM 2015-C21, WFCM
2015-C26, CGCMT 2015-GC35 and CSAIL 2015-C1;

  -- Average hotel concentration of 18% (ranging between 10%-24%);

  -- Average retail concentration of 30% (ranging between
23%-41%).

Fifteen classes from 12 transactions in the 'BBsf' category; this
represents 43% of the total number of classes rated in the 'BBsf'
category from the 2015 vintage.

  -- These 12 transactions include: CGCMT 2015-GC29, COMM
2015-CR27, COMM 2015-LC19, JPMCC 2015-JP1, MSBAM 2015-C26, WFCM
2015-C29, WFCM 2015-C31, WFCM 2015-NXS4, COMM 2015-LC23, GSMS
2015-GC32, GSMS 2015-GS1 and MSBAM 2015-C21;

  -- Average hotel concentration of 14% (ranging between 5%-20%);

  -- Average retail concentration of 26% (ranging between
10%-41%).

Thirteen classes from 13 transactions in the 'Bsf' category; this
represents 33% of the total number of classes rated in the 'Bsf'
category from the 2015 vintage.

  -- These 13 transactions include: CGCMT 2015-P1, CSAIL 2015-C4,
MSBAM 2015-C23, MSBAM 2015-C25, WFCM 2015-C30, WFCM 2015-NXS1,
CGCMT 2015-GC29, COMM 2015-CR27, COMM 2015-LC19, JPMCC 2015-JP1,
MSBAM 2015-C26, COMM 2015-LC23 and GSMS 2015-GC32;

  -- Average hotel concentration of 14% (ranging between 6%-21%);

  -- Average retail concentration of 24% (ranging between
10%-41%).

Fitch will be reviewing its entire portfolio and expects to release
updated rating actions for each vintage, with the 2011 through 2014
vintages transactions to follow.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Upgrades, although not likely in the near term, would occur with
stable to improved asset performance coupled with paydown and/or
defeasance. The Negative Rating Outlooks may be revised back to
Stable if overall pool performance and/or properties vulnerable to
the coronavirus stabilize to pre-pandemic levels. Classes with
Negative Outlooks in the 'AAAsf', 'AAsf' and 'Asf' categories may
be more likely to be revised back to Stable should CE or defeasance
increase significantly. Prior to any classes being upgraded,
adverse selection, sensitivity to concentrations and/or the
potential for future concentration would be taken into
consideration. Classes would not be upgraded above 'Asf' if there
is a likelihood of interest shortfalls.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Factors that could lead to downgrade include an increase in
expected pool level losses from underperforming or specially
serviced loans. Downgrades of one category or more to the classes
assigned Negative Rating Outlooks would occur if expected losses
increase, or a high proportion of the pool defaults and/or
properties vulnerable to the coronavirus fail to return to
pre-pandemic levels. The severity of the downgrades would be based
on the level of CE relative to losses. Below-investment grade
classes with Negative Outlooks would likely be downgraded first, as
losses would impact these classes sooner.

In addition to its baseline scenario related to the coronavirus,
Fitch also envisions a downside scenario where the health crisis is
prolonged beyond 2021; should this scenario play out, Fitch expects
that a greater percentage of classes may be assigned a Negative
Rating Outlook and/or those with Negative Rating Outlooks may be
downgraded by a greater magnitude.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.


[*] Fitch Takes Action on 48 Tranches From 6 Trust Preferred CDOs
-----------------------------------------------------------------
Fitch Ratings, on May 13, 2020, affirmed 39, upgraded four, and
revised or assigned Rating Outlooks to five tranches from six
collateralized debt obligations backed primarily by trust preferred
securities issued by banks and insurance companies. Performance
metrics for each CDO are reported in the accompanying report.

Fitch expects underlying portfolio quality to deteriorate, driven
by the likely future rise in non-current loans and low interest
rates. In addition to the standard analytical framework, described
in the "U.S. Trust Preferred CDOs Surveillance Rating Criteria"
(TruPS CDO Criteria), this review applied a coronavirus stress
scenario. Under this scenario, all issuers in the pool were
downgraded either by 0.5 for private bank scores or one notch for
publicly rated banks and insurance issuers with a mapped rating.
Due to the application of performing credit enhancement caps under
the TruPS CDO Criteria, no class of notes from CDOs in this review
was affected by this scenario.

Preferred Term Securities XXIV, Ltd./Inc.      

  - Class A-1 74043CAA5; LT Asf; Affirmed

  - Class A-2 74043CAB3; LT BBsf; Affirmed

  - Class B-1 74043CAC1; LT CCCsf; Affirmed

  - Class B-2 74043CAE7; LT CCCsf; Affirmed

  - Class C-1 74043CAG2; LT Csf; Affirmed

  - Class C-2 74043CAJ6; LT Csf; Affirmed

  - Class D 74043CAL1; LT Csf; Affirmed

Preferred Term Securities XXVI, Ltd./Inc.      

  - Class A-1 74042QAA5; LT AAsf; Upgrade

  - Class A-2 74042QAB3; LT BBBsf; Affirmed

  - Class B-1 74042QAC1; LT Bsf; Affirmed

  - Class B-2 74042QAE7; LT Bsf; Affirmed

  - Class C-1 74042QAG2; LT CCCsf; Affirmed

  - Class C-2 74042QAJ6; LT CCCsf; Affirmed

  - Class D 74042QAL1; LT Csf; Affirmed

Preferred Term Securities XXVIII, Ltd./Inc.      

  - Class A-1 74042CAA6; LT Asf; Affirmed

  - Class A-2 74042CAC2; LT BBBsf; Affirmed

  - Class B 74042CAE8; LT BBsf; Affirmed

  - Class C-1 74042CAG3; LT CCCsf; Affirmed

  - Class C-2 74042CAJ7; LT CCCsf; Affirmed

  - Class D 74042CAL2; LT CCsf; Affirmed

Preferred Term Securities XX, Ltd./Inc.      

  - Floating Rate Class A-1 Senior 74042DAA4; LT Asf; Affirmed

  - Floating Rate Class A-2 Senior 74042DAC0; LT BBBsf; Upgrade

  - Floating Rate Class B Mezzanin 74042DAE6; LT Bsf; Affirmed

  - Floating Rate Class C Mezzanin 74042DAG1; LT CCCsf; Affirmed

  - Floating Rate Class D Mezzanin 74042DAJ5; LT Csf; Affirmed

Preferred Term Securities XXIII, Ltd./Inc.      

  - Class A-1 74043AAD3; LT Asf; Affirmed

  - Class A-2 74043AAE1; LT BBBsf; Affirmed

  - Class A-FP 74043AAC5; LT BBBsf; Affirmed

  - Class B-1 74043AAJ0; LT BBsf; Affirmed

  - Class B-2 74043AAL5; LT BBsf; Affirmed

  - Class B-FP 74043AAG6; LT BBsf; Affirmed

  - Class C-1 74043AAQ4; LT CCCsf; Affirmed

  - Class C-2 74043AAS0; LT CCCsf; Affirmed

  - Class C-FP 74043AAN1; LT CCCsf; Affirmed

  - Class D-1 74043AAW1; LT Csf; Affirmed

  - Class D-FP 74043AAU5; LT Csf; Affirmed

Preferred Term Securities XXV, Ltd./Inc.      

  - Class A-1 74042FAA9; LT Asf; Affirmed

  - Class A-2 74042FAB7; LT BBsf; Affirmed

  - Class B-1 74042FAC5; LT Bsf; Upgrade

  - Class B-2 74042FAE1; LT Bsf; Upgrade

  - Class C-1 74042FAG6; LT Csf; Affirmed

  - Class C-2 74042FAJ0; LT Csf; Affirmed

  - Class D 74042FAL5 LT Csf; Affirmed

KEY RATING DRIVERS

The main driver behind the upgrades was deleveraging from
collateral redemptions and excess spread, which resulted in
paydowns to the senior most notes, ranging between 2% and 20% of
their balances at last review, as reported in the accompanying
report. In four transactions, excess spread is currently paying
down cumulative deferred interest of mezzanine classes and in the
remaining two transactions it is paying principal on the senior and
mezzanine notes to cure failing coverage tests.

For three transactions, the credit quality of the collateral
portfolios, as measured by a combination of Fitch's bank scores and
public ratings, exhibited negative credit migration, with the other
three remaining stable or improving. There were two new cures
across four CDOs. No new deferrals or defaults have been reported.

The ratings on 31 classes of notes in the six transactions have
been capped based on the application of the performing CE cap as
described in Fitch's TruPS CDO Criteria.

RATING SENSITIVITIES

Ratings of the notes issued by these CDOs remain sensitive to
significant levels of defaults, deferrals, cures and collateral
redemptions. To address potential risks of adverse selection and
increased portfolio concentration, Fitch applied a sensitivity
scenario, as described in the criteria, to applicable
transactions.

Factors That Could, Individually or Collectively, Lead to Positive
Rating Action/Upgrade:

Future upgrades to the rated notes may occur if a transaction
experiences improvement in credit enhancement through deleveraging
from collateral redemptions and/or interest proceeds being used for
principal repayment.

Factors That Could, Individually or Collectively, Lead to Negative
Rating Action/Downgrade:

Downgrades to the rated notes may occur if a significant share of
the portfolio issuers defers or defaults on their TruPS
instruments, which would cause a decline in performing CE levels.
If the coronavirus pandemic inflicted disruptions become more
prolonged, Fitch will formulate a sensitivity scenario that
represents a more severe impact on the banking and insurance
sectors than the scenario specified.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

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

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.


                            *********

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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
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