/raid1/www/Hosts/bankrupt/TCR_Public/200712.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

              Sunday, July 12, 2020, Vol. 24, No. 193

                            Headlines

AASET TRUST 2019-2: Fitch Affirms BBsf Rating on Class C Debt
AMERICAN CREDIT 2019-2: S&P Affirms B (sf) Rating on Class F Notes
AMERICREDIT AUTOMOBILE 2020-2: Fitch to Rate Class E Debt 'BB(EXP)'
BALLYROCK CLO 2020-1: S&P Rates Class D Notes 'BB- (sf)'
BANK 2017-BNK7: Fitch Affirms B-sf Rating on 2 Tranches

BLADE ENGINE 2006-1: Fitch Lowers Rating on Class B Debt to Dsf
BUNKER HILL 2020-1: S&P Rates Class B-2 Notes 'B+ (sf)'
CARLYLE GLOBAL 2016-2: Moody's Cuts Rating on Cl. D-2R Notes to B1
CD 2018-CD7: Fitch Affirms Class G-RR Certs at 'B-sf'
CITIGROUP 2020-WSS: S&P Assigns Prelim B(sf) Rating to Cl. F Certs

COMM 2013-CCRE7: Moody's Confirms Caa3 Rating on Class G Debt
COMM 2014-CCRE14: Moody's Lowers Class E Debt to Caa1
COMM 2015-LC23: Fitch Affirms Class G Debt at 'B-sf'
DBUBS 2011-LC3: Moody's Lowers Class F Debt to Caa2
FINANCE OF AMERICA 2019-AB1: Moody's Cuts Class M3 Debt to B1

FREDDIE MAC 2020-DNA3: Fitch Assigns Bsf Rating on 17 Tranches
FREDDIE MAC 2020-DNA3: S&P Rates Class B-1B Notes 'B (sf)'
FREDDIE MAC SCRT 2020-2: Fitch to Rate Class M Debt 'B-(EXP)'
GS MORTGAGE 2013-GCJ14: Moody's Lowers Class F Certs to B2
GS MORTGAGE 2015-GC34: Fitch Cuts Class F Certs to 'CCCsf'

HOMEWARD 2020-2: S&P Assigns Prelim B (sf) Rating to Cl. B-2 Certs
JP MORGAN 2012-LC9: Moody's Lowers Rating on Class G Debt to Caa2
JPMBB COMMERCIAL 2013-C14: Moody's Cuts Class G Debt Rating to Caa3
MADISON PARK XLV: S&P Rates Class E Notes 'BB- (sf)'
MARATHON CLO XIII: Moody's Cuts Rating on $30MM Class D Notes to B1

MVW LLC 2020-1: Fitch to Rate Class D Notes 'BB(EXP)'
PALISADES CENTER 2016-PLSD: Moody's Lowers Class D Certs to Caa1
SDART 2020-2: Moody's Gives '(P)B2' Rating to Class E Notes
TOWD POINT 2020-3: Fitch Assigns B(EXP) Rating on Class B2 Notes
UBS COMMERCIAL 2012-C1: Moody's Lowers Class F Certs to C

UBS-CITIGROUP COMMERCIAL 2011-C1: Moody's Cuts Class G Certs to C
WELLS FARGO 2020-3: Fitch to Rate Class B-5 Debt 'B+(EXP)sf'
WELLS FARGO 2020-3: Moody's Gives (P)Ba3 Rating on Class B-5 Debt
WFRBS COMMERCIAL 2013-C13: Moody's Confirms B2 Rating on F Certs
[*] S&P Takes Various Actions on 71 Classes From 11 US RMBS Deals

[*] S&P Takes Various Actions on 72 Classes From 13 U.S. RMBS Deals

                            *********

AASET TRUST 2019-2: Fitch Affirms BBsf Rating on Class C Debt
-------------------------------------------------------------
Fitch Ratings affirms the ratings on all outstanding notes of the
AASET 2019-2 Trust (AASET 2019-2) and AASET 2020-1 Trust (2020-1)
aircraft ABS transactions. The Rating Outlooks for all classes of
AASET 2019-2 and AASET 2020-1 remain Negative.

RATING ACTIONS

AASET 2019-2 Trust

Class A 00038RAA4; LT Asf Affirmed;   previously at Asf

Class B 00038RAB2; LT BBBsf Affirmed; previously at BBBsf

Class C 00038RAC0; LT BBsf Affirmed;  previously at BBsf

AASET 2020-1 Trust

Class A 00255UAA3; LT Asf Affirmed;   previously at Asf

Class B 00255UAB1; LT BBBsf Affirmed; previously at BBBsf

Class C 00255UAC9; LT BBsf Affirmed;  previously at BBsf

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.

The Negative Outlooks for each note of both transactions reflect
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 revised the Outlook for all series of
notes of each transaction to Negative as a part of its aviation ABS
portfolio review, due to the ongoing impact of the coronavirus
pandemic 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. This was a key driver of these
rating actions, along with modeled cash flows. Furthermore,
recessionary timing was brought forward to start immediately. 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.

Carlyle Aviation Partners Ltd. (CAP) (parent: The Carlyle Group
rated BBB+/Stable) and its affiliates manage certain funds (the
SASOF Funds). AASET 2019-2 purchased the initial aircraft in its
pool from the SASOF Funds. AASET 2020-1 already owned a majority of
the initial aircraft, while the remainder of the pool was acquired
by aircraft-owning entities (AOE). Carlyle Aviation Management
Limited (CAML; not rated by Fitch), an indirect subsidiary of CAP,
is the servicer for both transactions. Fitch believes the servicer
can adequately service these transactions based on its experience
as a lessor and overall servicing capabilities.

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 assumed to have an Issuer Default Rating (IDR) of 'CCC' or
lower increased to 58.7% from 14.5% at closing for AASET 2019-2 and
rose to 76.7% from 60.4% at closing for AASET 2020-1.

Newly-assumed 'CCC' credit airlines in AASET 2019-2 include GOL
Linhas Aereas S.A. (GOL), VietJet Aviation Joint Stock Company, Go
Airlines Limited, Aegean Airlines, Azur Air and Nordwind. In AASET
2020-1 newly-assumed 'CCC' lessees include Boliviana de Aviacion,
ASL Airlines Ireland and GOL. One credit was assumed to immediately
default (consistent with 'D' IDR assumption) in the analysis of
AASET 2019-2, and two credits for 2020-1 which included Alitalia -
Societa Aerea Italiana (Alitalia) and Aerolineas Argentinas. This
is due to the Fitch' view of the lessee's elevated defaulted risk,
the current administration/bankruptcy for Alitalia, and the recent
downgrade of Argentina's sovereign IDR to 'RD' and 100% government
ownership of the Argentinian airline.

All 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. For airlines in
administration/bankruptcy or assumed to immediately default in
Fitch's modeling, narrowbody (NB) aircraft were assumed to remain
on ground for three additional months and widebody (WB) aircraft
for six additional months to account for potential remarketing
challenges in placing these aircraft with new lessees in the
current distressed environment.

Asset Quality and Appraised Pool Value:

Each pool consists of older mid-to-end-of-life aircraft
(weighted-average [WA] age of 12.5 years for 2019-2 and 15.7 years
for 2020-1) and leases with short remaining terms (WA 2.7 years
remaining term for 2019-2 and 3.5 years for 2020-1).

Both pools include WB aircraft concentrations totaling 15.0% in
2019-2 with four aircraft, and 13.8% in 2020-1 with three WB. 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 (MVs) as opposed to base
values (BVs) for cash flow modeling, after taking into account
depreciation applied by Fitch since the last appraisals received in
April 2020 for 2019-2 and September 2019 for 2020-1.

To account for the value softness of the WBs in 2020-1 since the
last appraisal, further adjustments were applied using recent April
2020 values of comparable WB aircraft of the same vintage. Fitch
believes these recent MVs for WBs in both transactions capture some
of the more recent downward market pressure. Therefore, Fitch did
not adjust values further downward. The remaining aircraft in both
pools consist of NB aircraft, which Fitch utilized BVs given
ongoing market dynamics, consistent with prior reviews.

For this review, Fitch utilized the average of the two lowest and
most current appraisal values (BV for NB and MV for WB) for each
pool. Appraisers for both transactions are Avitas, Inc., Collateral
Valuations, Inc. (CV) and Morten Beyer & Agnew, Inc. (mba). This
approach results in Fitch modeled pool values of $548.9 million for
AASET 2019-2, and $424.2 million for AASET 2020-1, both value
assumptions are notably lower compared to $611.9 million and $489.8
million appraisals stated in the June 2020 servicer reports,
respectively.

Transaction Performance to Date:

Lease collections and transaction cash flows for both transactions
have trended down due to impact from the pandemic. AASET 2019-2
received $3.8 million in rent collections in the May collection
period, down 46% from the January collection period but up 3% from
the April collection period. AASET 2020-1 received $2.8 million in
rent collections in the May collection period, down 13% versus the
April collection period. Still, May collections are relatively in
line since March. In the May collection period, AASET 2019-2
payments reached the series A scheduled principal payment amount
step, while AASET 2020-1's available cashflow was insufficient to
pay any note principal amount reaching only the senior maintenance
reserve amount step.

To date, no aircraft have been sold from either pool. The
debt-service-coverage-ratio triggers (DSCR) for AASET 2019-2
continues to remain above the 1.20x cash trap trigger and the 1.15x
rapid amortization event trigger, currently at 1.41x although it
continues to fall. AASET 2020-1 DSCR has not yet been reported as
the transaction is only four months outstanding to date.

As a result of the coronavirus pandemic, AASET 2019-2 and 2020-1
had eight and 13 lessees that are delinquent and behind on lease
payments by at least one month, in each case accounting for 59% and
71% of their respective pools. The servicer is expecting the number
of lessees in arrears to increase due to the coronavirus pandemic.
Fitch took these risks into consideration during this review when
assessing airline credit and applicable ratings applied.

Nearly all lessees across each transaction has requested some form
of payment relief/deferrals, consistent across peer aircraft ABS
pools due to disruptions related to the coronavirus pandemic. 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 CAML 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.

Four aircraft on lease are expected to mature within the next 12
months for AASET 2019-2 and two in 2020-1. 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.

As of the May collection period, two aircraft are reported as off
lease while two aircraft with expired leases are in the redelivery
process for AASET 2019-2. In cash flow modeling, Fitch assumed zero
collections for three months in addition to modeled downtime to
account for potential difficulty to re-lease this aircraft in this
current environment. For AASET 2020-1, one aircraft was reported
off lease, with a potential follow-on lease. Fitch assumed zero
collections until Q4 2020.

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 haircut 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 July 2021. Maintenance costs over the
immediate six months were assumed to be incurred as reported. Costs
in the next 12 months were haircut to 50% of their original
schedules. Over the following 12 months, the 50% of deferred costs
in prior periods were assumed to be repaid every month in addition
to the scheduled maintenance costs.

RATING SENSITIVITIES

The Negative Rating Outlooks on the notes for AASET 2019-2 and
2020-1 reflect the potential for further negative rating actions
due to concerns surrounding the ultimate impact of the coronavirus
pandemic, and resulting performance concerns associated with
airlines, 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 sensitivities 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 transaction to
exhibit sensitivity to the timing or severity of assumed
recessions. Fitch also found that greater default probability of
the leases has 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 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 remain below the initial ratings. However, if the
assets in this pool experience stronger residual value (RV)
realization than what 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 the rating cap in the sector, the industry
cyclicality, and weaker lessee mix present in ABS pools and
uncertainty around future lessee mix, all combined with the
negative impact on the coronavirus on the global travel/airline
sectors and ultimately ABS transactions.

Under this scenario, residual value recoveries at time of sale are
assumed at 70% of their depreciated market values up from 50% in
the base case for certain aircraft that are less marketable. Net
cash flow increases by approximately $50.0 million and $35.0
million at 'Asf' rating category for AASET 2019-2 and 2020-1,
respectively. Under the scenario, all series of notes for both
transactions are able to pass under the 'Asf' rating category.

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

Down: Base Assumptions with 10% Weaker Widebody Values

The pools contain a WB concentration of approximately 14% and 15%
for AASET 2019-2 and 2020-1, respectively, and any further
softening in WB values could lead to further downward rating
action. Due to downward market value pressure on WB, and worsening
supply and demand value dynamics, Fitch explores the potential cash
flow decline if WB values are reduced further by 10% of Fitch's
modeled value for cash flow modeling.

Net cash flow declines by approximately $2.9 million and $1.3
million at the 'Asf' rating category, for AASET 2019-2 and 2020-1,
respectively. For AASET 2019-2, all series of notes are able to
pass under the 'Asf' rating category. For AASET 2020-1, series A
and B pass under the 'Asf' scenario while the series C pass under
the 'BBsf' scenario.

Down: Base Assumptions with Jurisdictional Downtime Six Months

During this coronavirus pandemic, parked aircraft, sharply reduced
air travel demand and increased bankruptcies would lead to lessors
facing significant challenges to place aircraft to new lessees or
extending existing leases. As a result, downtimes can be longer
during this recession. Fitch ran a sensitivity to extend downtime
by six months for leases maturing within the next four years.

Under this scenario, leases that mature during the first recession
(i.e. within the next 48 months) were assumed to have six months of
additional downtime. Net cash flow declines by approximately $5.3
million and $4.2 million at the 'Asf' rating category for AASET
2019-2 and 2020-1, respectively. For AASET 2019-2, all series of
notes are able to pass under the 'Asf' rating category. For AASET
2020-1, series A and B pass under the 'Asf' scenario while the
series C pass under the 'BBsf' scenario.

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).


AMERICAN CREDIT 2019-2: S&P Affirms B (sf) Rating on Class F Notes
------------------------------------------------------------------
S&P Global Ratings raised its ratings on 17 classes and affirmed
its ratings on seven classes of notes from American Credit
Acceptance Receivables Trust 2016-4, 2017-3, 2017-4, 2018-4,
2019-1, and 2019-2.

The rating actions reflect each transaction's collateral
performance to date and S&P's expectations regarding future
performance, including an upward adjustment in remaining cumulative
net losses (CNLs) to account for the COVID-19-induced recession.

"The actions also took into account our view of each transaction's
structure and the respective credit enhancement levels.
Additionally, our analysis incorporated secondary credit factors,
including credit stability, payment priorities under various
scenarios, and sector- and issuer-specific analyses. Considering
all these factors, we believe the creditworthiness of the notes
remains consistent with the raised and affirmed ratings," S&P
said.

  Table 1

  Collateral Performance (%)
  As of the June 2020 distribution date

                     Pool    Current  Extensions   60+ day
  Series     Mo.   factor        CNL               delinq.
  2016-4      43    17.36      26.17        4.83      6.32
  2017-3      33    22.89      19.99        4.77      6.60
  2017-4      30    30.51      19.97        4.95      6.34
  2018-4      18    54.60      14.48        5.31      6.85
  2019-1      15    63.80      12.31        5.05      6.43
  2019-2      13    67.98      10.54        5.04      6.64

  Mo.--Month.
  Delinq.—Delinquencies.
  CNL--Cumulative net loss.

For all the transactions, S&P factored in an upward adjustment to
remaining losses that could result from elevated unemployment
levels associated with the current COVID-19-induced recession. The
2016-4 transaction is seasoned with 43 months of performance and a
pool factor of 17.36%. It is performing in line with S&P's prior
expectations. Series 2017-3 and 2017-4 have the highest percentage
of called collateral in its pools, and as a result the pools had
higher seasoning. At the time of issuance, these transactions had a
seasoning of 10.4 and 5.3 months, respectively. These transactions
are performing better than S&P's initial expectations; as a result,
the rating agency has lowered its loss expectations. The 2018-4,
2019-1, and 2019-2 transactions have 18, 15, and 13 months of
performance, thereby nearing their peak loss periods. In general,
these transactions are performing in line with S&P's initial
expectations; however, based on its future expectations of the
deals' performance in the recession, it has raised its expected
CNLs. Based on these factors, S&P's lifetime loss levels have been
revised.

  Table 2

  CNL Expectations (%)

               Original         Former         Revised
               lifetime       lifetime        lifetime
  Series       CNL exp.       CNL exp.(i)     CNL exp.(ii)
  2016-4    26.50-27.50    27.00-28.00     Up to 27.50
  2017-3    26.75-27.75    26.00-27.00     24.50-25.50
  2017-4    28.25-29.25    28.00-29.00     26.50-27.50
  2018-4    27.00-28.00            N/A     27.50-28.50
  2019-1    28.00-29.00            N/A     30.50-31.50
  2019-2    27.00-28.00            N/A     29.50-30.50

(i)Former lifetime CNL expectations were revised in March 2019.
(ii)Current lifetime CNL expectations are as of June 2020
distribution date.
CNL exp.--Cumulative net loss expectations.
N/A–-Not applicable.

All transactions have a sequential principal payment structure with
credit enhancement consisting of overcollateralization (O/C), a
non-amortizing reserve account, subordination for the more senior
classes, and excess spread. As of the June 2020 distribution date,
each transaction was at its target O/C level, calculated as a
percentage of the current pool balance. In addition to O/C targets,
each transaction has an O/C floor of 2.5% of the initial pool
balance.

For each transaction, overall hard credit enhancement has continued
to grow as a percentage of its current pool balance. The raised and
affirmed ratings reflect S&P's view that the total credit support
as a percentage of the amortizing pool balance, compared with its
expected remaining losses, is commensurate with each raised or
affirmed rating.

  Table 3

  Hard Credit Support
  As of the June 2020 distribution date

                                Total hard    Current total hard
                            credit support        credit support
  Series       Class       at issuance (%)(i)    (% of current)(i)
  2016-4       D                     19.75                 46.73
  2016-4       E                     17.00                 30.89
  2017-3       D                     24.51                 64.63
  2017-3       E                     16.25                 28.55
  2017-4       C                     39.65                104.23
  2017-4       D                     24.50                 54.58
  2017-4       E                     16.75                 29.17
  2018-4       B                     53.80                 95.64
  2018-4       C                     36.80                 64.50
  2018-4       D                     22.60                 38.49
  2018-4       E                     15.60                 25.67
  2018-4       F                     10.10                 15.60
  2019-1       A                     65.25                101.10
  2019-1       B                     54.35                 84.02
  2019-1       C                     36.60                 56.20
  2019-1       D                     24.95                 37.94
  2019-1       E                     15.70                 23.44
  2019-1       F                     10.60                 15.45
  2019-2       A                     64.10                 94.58
  2019-2       B                     52.60                 77.67
  2019-2       C                     34.90                 51.63
  2019-2       D                     21.90                 32.51
  2019-2       E                     15.60                 23.24
  2019-2       F                      9.90                 14.86

(i)Calculated as a percentage of the total gross receivable pool
balance, consisting of a reserve account, overcollateralization,
and, if applicable, subordination.

"We incorporated an analysis of the current hard credit enhancement
compared to the remaining expected CNL for those classes in which
hard credit enhancement alone--without credit to the stressed
excess spread--was sufficient, in our opinion, to raise or affirm
the ratings at 'AAA (sf)'," S&P said.

For the other classes, S&P incorporated a cash flow analysis to
assess the loss coverage level, giving credit to stressed excess
spread. S&P's various cash flow scenarios included forward-looking
assumptions on recoveries, the timing of losses, and voluntary
absolute prepayment speeds that the rating agency believes are
appropriate given each transaction's performance to date and the
assigned ratings.

"The results demonstrated, in our view, that all of the classes
have adequate credit enhancement at their respective raised and
affirmed rating levels" S&P said.

S&P also conducted sensitivity analyses to determine the impact
that a moderate ('BBB') stress scenario would have on its ratings
if losses began trending higher than its revised base-case loss
expectations. S&P's results showed that the raised and affirmed
ratings are consistent with its ratings stability criteria, which
outline the outer bounds of credit deterioration for any given
security under specific, hypothetical stress scenarios."

S&P acknowledges a high degree of uncertainty about the evolution
of the coronavirus pandemic. The consensus among health experts is
that the pandemic may now be at, or near, its peak in some regions
but will remain a threat until a vaccine or effective treatment is
widely available, which may not occur until the second half of
2021. S&P is using this assumption in assessing the economic and
credit implications associated with the pandemic. As the situation
evolves, S&P will update its assumptions and estimates
accordingly.

"We will continue to monitor the performance of all of the
outstanding transactions to evaluate if the credit enhancement
remains sufficient, in our view, to cover our CNL expectations
under our stress scenarios for each of the rated classes," S&P
said.

  RATINGS RAISED
  American Credit Acceptance Receivables Trust

                              Rating
  Series      Class     To              From
  2016-4      D         AAA (sf)        A+ (sf)
  2016-4      E         AAA (sf)        A- (sf)
  2017-3      D         AAA (sf)        A+ (sf)
  2017-4      D         AA (sf)         A (sf)
  2018-4      B         AAA (sf)        AA (sf)
  2018-4      C         AAA (sf)        A (sf)
  2018-4      D         A+ (sf)         BBB (sf)
  2018-4      E         BBB (sf)        BB- (sf)
  2018-4      F         BB- (sf)        B (sf)
  2019-1      B         AAA (sf)        AA (sf)
  2019-1      C         AA- (sf)        A (sf)
  2019-1      D         A- (sf)         BBB (sf)
  2019-1      E         BBB- (sf)       BB- (sf)
  2019-2      B         AAA (sf)        AA (sf)
  2019-2      C         AA- (sf)        A (sf)
  2019-2      D         A- (sf)         BBB (sf)
  2019-2      E         BBB- (sf)       BB- (sf)

  RATINGS AFFIRMED
  American Credit Acceptance Receivables Trust

  Series      Class     Rating
  2017-3      E         BBB (sf)
  2017-4      C         AAA (sf)
  2017-4      E         BBB (sf)
  2019-1      A         AAA (sf)
  2019-1      F         B (sf)
  2019-2      A         AAA (sf)
  2019-2      F         B (sf)


AMERICREDIT AUTOMOBILE 2020-2: Fitch to Rate Class E Debt 'BB(EXP)'
-------------------------------------------------------------------
Fitch Ratings expects to assign ratings and Rating Outlooks to
AmeriCredit Automobile Receivables Trust 2020-2.

The social and market disruptions caused by the coronavirus
pandemic and related containment measures have negatively affected
the U.S. economy. To account for the potential impact on AMCAR
2020-2, Fitch's base case cumulative net loss proxy was derived by
taking into account GMF's 2006-2008 recessionary static-managed
portfolio performance resulting from an elevated unemployment
environment, along with more recent GMF-managed vintage
performance. The sensitivity of the rating(s) to scenarios more
severe than currently expected is provided in the Rating
Sensitivities section of this report.

AmeriCredit Automobile Receivables Trust 2020-2

  - Class A-1;   ST  F1+(EXP)sf Expected Rating

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

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

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

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

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

  - Class D;     LT  BBB(EXP)sf Expected Rating

  - Class E;     LT  BB(EXP)sf  Expected Rating

KEY RATING DRIVERS

Collateral and Concentration Risks — Consistent Credit Quality:
The pool has consistent credit quality versus recent pools based on
internal credit scores and its weighted average Fair Isaac Corp.
score of 581. Obligors with FICO scores of 600 and greater total
39.3%, up from 38.4% in 2020-1 and higher versus the 2019
transactions. Extended-term (61-plus month) contracts total 94.3%,
which is nominally higher than 93.1% in 2020-1. The 73-to-75-month
contracts total 13.0%, which is lower than the share of the prior
four transactions. However, 2020-2 also includes 76-to-84-month
contracts (totaling 3.8%) for the first time on the AMCAR
platform.

Forward-Looking Approach to Derive Base Case Loss Proxy: Fitch
considers economic conditions and future expectations by assessing
key macroeconomic and wholesale market conditions in deriving the
series loss proxy. Losses on GMF's managed portfolio and
securitizations have been normalizing in recent years, with
2015-2017 vintages tracking higher than the strong 2010-2014
vintages. However, overall performance continues to be within
Fitch's expectations. Fitch accounted for the weaker performance by
focusing on the 2006-2008 and 2015-2016 vintages to arrive at a
forward-looking CNL proxy of 11.25%.

Payment Structure — Sufficient Credit Enhancement: The initial
hard credit enhancement is slightly lower than that of 2019 and
2018 transactions for classes A, B and C, and higher for classes D
and E. The CE totals 34.35%, 27.10%, 18.10%, 11.25% and 8.40% for
classes A, B, C, D and E, respectively. Excess spread is expected
to be 8.02% per annum. Loss coverage for each class of notes is
sufficient to cover the respective multiples of Fitch's base case
CNL proxy.

Seller/Servicer Operational Review — Consistent
Origination/Underwriting/Servicing: Fitch downgraded GM and GMF to
'BBB-/F3' from 'BBB/F2' in May 2020 with a Stable Rating Outlook.
GMF demonstrates adequate abilities as an originator, underwriter
and servicer, as evidenced by historical portfolio and
securitization performance. Fitch deems GMF capable of adequately
servicing this transaction.

Coronavirus Causing Economic Shock: 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 coupled with a rapid spike in
unemployment, followed by a recovery that begins in 3Q20 as the
health crisis subsides. Under this scenario, Fitch's initial base
case CNL proxy was derived using a 2006-2008 recessionary
static-managed portfolio and 2015-2016 vintages that have
experienced slightly weaker performance, and it also took into
consideration ABS performance.

As a downside (sensitivity) scenario provided in the Rating
Sensitivities section describes, Fitch considers a more severe and
prolonged period of stress with an inability to begin meaningful
recovery until beyond 2021. Under the downside case, Fitch
completed a rating sensitivity by doubling the initial base case
loss proxy (please refer to Rating Sensitivities section). Under
this scenario, the notes could be downgraded by upwards of three
categories.

RATING SENSITIVITIES

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

  -- Unanticipated increases in the frequency of defaults could
produce CNL levels that are higher than the base case and would
likely result in declines of CE and remaining net loss coverage
levels available to the notes. Additionally, unanticipated declines
in recoveries could also result in a decline in net loss coverage.
Decreased net loss coverage may make certain note ratings
susceptible to potential negative rating actions depending on the
extent of the decline in coverage.

  -- Hence, Fitch conducts sensitivity analyses by stressing both a
transaction's initial base case CNL and recovery rate assumptions
and examining the rating implications on all classes of issued
notes. The CNL sensitivity stresses the CNL proxy to the level
necessary to reduce each rating by one full category, to
non-investment grade (BBsf) and to 'CCCsf' based on the break-even
loss coverage provided by the CE structure.

  -- Additionally, Fitch conducts increases of 1.5x and 2.0x to the
CNL proxy, representing moderate and severe stresses, respectively.
Fitch also evaluates the impact of stressed recovery rates on an
automobile loan ABS structure and the rating impact with a 50%
haircut. These analyses are intended to provide an indication of
the rating sensitivity of the notes to unexpected deterioration of
a trust's performance. A more prolonged disruption from the
pandemic is accounted for in the severe downside stress of 2.0x and
could result in downgrades of up to two rating categories.

  -- Due to the coronavirus pandemic, the U.S. and the broader
global economy remain under stress, with surging unemployment and
pressure on businesses stemming from government-led social
distancing guidelines. Unemployment pressure on the consumer base
may result in increases in delinquencies. In addition, an inability
to repossess and recover on vehicles from charged off contracts
might delay recovery cashflows available to the notes. For
sensitivity purposes, Fitch assumes a 2.0x increase in delinquency
stress. The results indicate no adverse rating impact to the notes.
Fitch acknowledges that lower prepayments and longer recovery lag
times due to a delayed ability to repossess and recover on vehicles
may result from the pandemic. However, changes in these
assumptions, with all else equal, would not have an adverse impact
on modeled loss coverage, and Fitch has maintained its stressed
assumptions.

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 the
projected proxy, the expected ratings would be maintained for the
class A notes at stronger rating multiples.

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.

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).


BALLYROCK CLO 2020-1: S&P Rates Class D Notes 'BB- (sf)'
--------------------------------------------------------
S&P Global Ratings assigned its ratings to Ballyrock CLO 2020-1
Ltd.'s floating-rate notes.

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

The ratings reflect:

-- The diversification of the collateral pool;

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

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

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

S&P Global Ratings acknowledges a high degree of uncertainty about
the evolution of the coronavirus pandemic. The consensus among
health experts is that the pandemic may now be at, or near, its
peak in some regions but will remain a threat until a vaccine or
effective treatment is widely available, which may not occur until
the second half of 2021.

"We are using this assumption in assessing the economic and credit
implications associated with the pandemic. As the situation
evolves, we will update our assumptions and estimates accordingly,"
S&P said.

  RATINGS ASSIGNED

  Ballyrock CLO 2020-1 Ltd.

  Class                Rating       Amount (mil. $)
  X                    AAA (sf)                2.30
  A-1                  AAA (sf)              248.00
  A-2                  AA (sf)                56.00
  B (deferrable)       A (sf)                 24.00
  C (deferrable)       BBB- (sf)              20.00
  D (deferrable)       BB- (sf)               12.00
  Subordinated notes   NR                     31.45

  NR--Not rated.


BANK 2017-BNK7: Fitch Affirms B-sf Rating on 2 Tranches
-------------------------------------------------------
Fitch Ratings has affirmed 17 classes of BANK 2017-BNK7 Commercial
Mortgage Pass-Through Certificates Series 2017-BNK7.

BANK 2017-BNK7

  - Class A-1 06541XAA8; LT AAAsf; Affirmed

  - Class A-2 06541XAB6; LT AAAsf; Affirmed

  - Class A-3 06541XAC4; LT AAAsf; Affirmed

  - Class A-4 06541XAE0; LT AAAsf; Affirmed

  - Class A-5 06541XAF7; LT AAAsf; Affirmed

  - Class A-S 06541XAJ9; LT AAAsf; Affirmed

  - Class A-SB 06541XAD2; LT AAAsf; Affirmed

  - Class B 06541XAK6; LT AA-sf; Affirmed

  - Class C 06541XAL4; LT A-sf; Affirmed

  - Class D 06541XAV2; LT BBB-sf; Affirmed

  - Class E 06541XAX8; LT BB-sf; Affirmed

  - Class F 06541XAZ3; LT B-sf; Affirmed

  - Class X-A 06541XAG5; LT AAAsf; Affirmed

  - Class X-B 06541XAH3; LT AA-sf; Affirmed

  - Class X-D 06541XAM2; LT BBB-sf; Affirmed

  - Class X-E 06541XAP5; LT BB-sf; Affirmed

  - Class X-F 06541XAR1; LT B-sf; Affirmed

KEY RATING DRIVERS

Increasing Loss Expectations: While overall pool performance has
been relatively stable since issuance, loss expectations have
increased since issuance mainly due to an increase in Fitch Loans
of Concern and additional stress applied due to coronavirus
resulting in the Negative Outlooks on classes D, X-D, E, X-E, F,
and X-F. Two loans (4.2% of the current pool balance) are 30 days
delinquent and seven loans (21%) have requested relief as a result
of coronavirus. Ten loans (20.6%) are FLOCs including three (11.1%)
in the top 15, one of which (1.1%) is 30 days delinquent and in
special servicing.

Fitch Loans of Concern: The largest FLOC is the Mall of Louisiana
(5.5%), a 1.5 million sf regional mall located in Baton Rouge, LA.
Per the March 2020 rent roll, collateral occupancy is 93% and total
mall occupancy is 96%. While cash flow at the property has remained
stable overall, inline sales have declined since issuance. Per the
March 2020 sales report, comp inline sales for tenants less than
10,000 sf were $414 psf (excluding Apple) compared to $461 psf at
YE 2018, $461 psf at issuance (March 2018), $438 psf in March 2017,
and $428 psf in 2014. AMC Theatres (9.6% NRA) is the largest
collateral tenant and has experienced a decline in sales per screen
to $342,933 as of March 2020 compared to $390,617 per screen at YE
2018 and $560,583 per screen at issuance. Non-collateral anchors at
the property include Dillard's, Dillard's Men & Home, JC Penney,
Macy's, and Sear's, all of which have reported nationwide store
closures and declining revenue in recent years. While the subject
is the dominant mall in its trade area, it is also located in a
secondary market with fewer demand drivers. Fitch applied an
additional haircut to the YE 2019 NOI due to upcoming tenant
rollover.

Redondo Beach Hotel Portfolio (5.2%) is a two-property, 319-key
hotel portfolio located in Redondo Beach, CA where the borrower has
requested relief as a result of coronavirus. As of YE 2019, the
properties were performing at a 90% occupancy rate and 1.34x NOI
debt service coverage ratio compared to an 89% occupancy rate and
1.41x NOI DSCR at YE 2018. YOY cash flow has deteriorated due to a
decline in revenue while expenses remain stable. Portfolio-level
RevPAR, per the servicer-provided OSAR, was $139 at YE 2019 and
$142 at YE 2018 compared to Fitch's expectations of $141 at
issuance. Fitch applied an additional haircut to the YE 2019 NOI in
order to stress test for coronavirus.

Raleigh Marriott City Center (3.1%) is a 400-key full-service hotel
located immediately adjacent to the convention center in Raleigh,
NC. While cash flow at the property has improved significantly in
2019 due to the completion of a PIP in 2018, Fitch has concerns
about the hotel's ability to continue to perform at the same level.
The property's primary demand driver is large events at the
adjacent convention center and without these events, property
performance is expected to decline. Fitch applied an additional
haircut to the YE 2019 NOI in order to stress test for
coronavirus.

Smaller loans of concern include a hotel in Jacksonville, FL (2.2%)
where the borrower has requested relief as a result of coronavirus;
a hotel in Cordova, TN (1.1%) that has transferred to special
servicing as a result of coronavirus; and five smaller retail
properties with lower DSCRs that have an additional NOI stress due
to coronavirus.

Alternative Loss Consideration: Fitch's analysis included a 20%
loss to the maturity balance of the Mall of Louisiana due to the
regional mall asset class, secondary market, declining sales, and
economic volatility due to coronavirus. Due to this stressed
scenario, Fitch revised Outlooks on classes D and X-D.

Coronavirus Exposure: The pool contains four loans (12.2%) secured
by hotels with a weighted-average NOI DSCR of 1.84x. Retail
properties account for 22% of the pool balance and have weighted
average NOI DSCR of 2.15x. Cash flow disruptions continue as a
result of property and consumer restrictions due to the spread of
the coronavirus. Fitch's base case analysis applied an additional
NOI stress to four hotel and six retail loans due to their
vulnerability to the coronavirus pandemic. These additional
stresses contributed to the Negative Outlooks on classes D, X-D, E,
X-E, F, and X-F.

Minimal Change to Credit Enhancement: As of the June 2020
distribution date, the pool's aggregate principal balance has been
reduced by 1.8% to $1.19 billion from $1.21 billion at issuance.
Twenty-two loans (50.2%) are full-term interest-only loans and 13
loans (23.5%) are partial-term interest-only, four of which (5.9%)
have begun amortizing. There are no defeased loans and interest
shortfalls are currently impacting class G.

Investment Grade Credit Opinion Loans: Four loans (21.8%) were
given investment-grade credit opinions at issuance. The General
Motors Building (9.4%), Westin Building Exchange (5.7%), The
Churchill (4.1%), and Moffett Place B4 (2.7%) were rated 'AAAsf',
'AAAsf', 'AAAsf', and 'BBB-sf', respectively, at issuance.

RATING SENSITIVITIES

The Negative Outlooks on classes D, X-D, E, X-E, F, and X-F reflect
the potential for a near-term rating change should the performance
of the FLOCs deteriorate. It also reflects concerns with hotel and
retail properties due to decline in travel and commerce as a result
of the coronavirus pandemic. The Stable Outlooks on all other
classes 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, X-B, and C may occur with significant improvement in
credit enhancement and/or defeasance but would be limited should
the deal be susceptible to a concentration whereby the
underperformance of particular loan(s) could cause this trend to
reverse. An upgrade to classes D and X-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 is a likelihood for
interest shortfalls. An upgrade to classes E, X-E, F, and X-F is
not likely until the later years in a transaction and only if the
performance of the remaining pool is stable and/or if there is
sufficient CE, which would likely occur when class G is not eroded
and the senior classes payoff. While coronavirus-related stresses
and concerns with the Mall of Louisiana continue to impact the
pool, upgrades are 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 or specially serviced loans. Downgrades
to the senior classes, A-1, A-2, A-3, A-SB, A-4, A-5, X-A, B, X-B,
and C are not likely due to the position in the capital structure
and the high CE, but may occur at 'AAAsf' or 'AAsf' should interest
shortfalls occur or if a high proportion of the pool defaults and
expected losses increase significantly. Downgrades to classes D and
X-D would occur should overall pool losses increase and/or one or
more large loans, such as the Mall of Louisiana, Redondo Beach
Hotel Portfolio, or Raleigh Marriott City Center have an outsized
loss which would erode CE and/or properties vulnerable to the
coronavirus fail to stabilize to pre-pandemic levels. Downgrades to
classes E, X-E, F, and X-F would occur should loss expectations
increase due to an increase in specially serviced loans, the
disposition of a specially serviced loan at a high loss, or a
decline in the FLOCs' performance. The Negative Rating Outlooks on
classes D, X-D, E, X-E, F, and X-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 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 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).


BLADE ENGINE 2006-1: Fitch Lowers Rating on Class B Debt to Dsf
---------------------------------------------------------------
Fitch Ratings has downgraded the ratings of the series 2006-1A-1
floating rate notes and the series 2006-1A-2 fixed rate notes, and
affirmed the ratings of the series 2006-1B floating rate notes, all
issued by Blade Engine Securitization Ltd. Fitch has removed the
series A notes from Rating Watch Negative.

Blade Engine Securitization LTD 2006-1

  - Class A-1 092650AA8; LT CCsf; Downgrade

  - Class A-2 092650AC4; LT CCsf; Downgrade

  - Class B 092650AB6; LT Dsf; Affirmed

TRANSACTION SUMMARY

The rating actions reflect ongoing deterioration of all airline
lessee credits backing the aircraft engine leases in the pool,
downward pressure on values and lease rates for certain aging
engine types, Fitch's updated assumptions and stresses, and
resulting impairments to modeled cash flows and coverage levels.

On March 31, 2020, Fitch placed the series A notes issued by Blade
on RWN as part of its aviation ABS portfolio review, due to the
ongoing impact of the coronavirus pandemic 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 today's global recessionary environment and
the impact on airlines leasing the engines in this pool, Fitch
updated rating assumptions for both rated and non-rated airlines
with a vast majority of ratings moving lower. Furthermore,
recessionary timing was brought forward to start immediately. This
scenario further stresses airline credits, asset values and lease
rates immediately, while incurring remarketing and repossession
cost and downtime. Previously, Fitch assumed that the first
recession commenced six months from either the transaction closing
date or date of subsequent reviews.

General Electric Capital Corporation (GECC, parent: General
Electric Company, rated BBB/Stable) and certain of its affiliates
were the sellers of beneficial interests to Blade. GE Commercial
Aviation Services Limited, a wholly owned subsidiary of GECC, acts
as servicer to the aircraft engine ABS transaction. Fitch believes
the servicer can adequately service this transaction based on its
experience as a lessor and overall servicing capabilities of its
owned and managed portfolio, including prior ABS transactions.

KEY RATING DRIVERS

Deteriorating Airline Lessee Credit:

The credit profiles of the airline lessees in the pool 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 transaction is supported largely by
rated airlines or flag carriers with highly rated sovereign Issuer
Default Ratings, with lower credit migration in the recent quarter.
As a result, the proportion of airline lessees assumed to have an
IDR of 'CCC' remained low at just 1.7% with one carrier Asiana
Airlines with such rating.

Asset Quality and Appraised Pool Value:

The pool consists of 25 remaining aircraft engines supporting
mostly widebody aircraft airframes totaling 66.4% of the pool. The
remaining portion is split between narrowbody airframes at 18.9%
and regional jet airframes at 14.7%. As the engines have aged and
migrated through their life cycle phases, the transaction has
encountered continued headwinds in releasing and disposal of
engines. For this review, Fitch utilized the average of the two
lowest appraisal half-life base values updated as of December 2019,
resulting in a modeled value of $155.5 million.

Transaction Performance to Date:

Lease collections and transaction cash flows have trended down in
recent months below the historical average partly due to impact
from the pandemic. Two engine sales have finalized since the prior
review at values well below actual appraisals, driven by the
maintenance conditions at sale. The transaction remains reliant on
a limited number of in-demand engines supporting WB, NB and RJ
airframes.

Under the indenture, Blade is required to enter into interest rate
hedging agreements, and is expected to renew such agreements in
2H20 upon the expiration of the current interest rate hedging
product. Monthly expenses are expected to peak around
September/October due to clustered hedge fees and other trust
expenses, placing added pressure on the structure.

Blade does not feature certain triggers and protective mechanisms
found in most aircraft ABS structures rated in recent years. A
notice of default was previously issued in July 2019 on the series
B notes, and the senior cash account was depleted, while all
available cash since then has been used to pay down the series A
notes. Without a liquidity facility in place, this leaves the
series A notes particularly vulnerable to liquidity risk during a
period of compressed lease cash flow and potentially uneven
expenses.

Following the default of the series B notes, a forbearance
agreement was reached between Blade and the controlling holder of
the series A notes to forbear from directing the trustee to
exercise rights and remedies available in connection with the
continuing event of default. The agreement will terminate at latest
in November 2020. In cash flow modeling, Fitch assumed that the
agreement is renewed and the trust continues to operate, albeit
facing elevated risks.

Fitch Assumptions, Stresses and Cash Flow Modeling:

Nearly all GECAS servicer-driven Fitch assumptions are unchanged
from the prior rating review, and include consistent repossession
and remarketing costs, new lease and lease extension terms assumed.
Fitch updated phase transition date expectations for each engine
type in the pool to align with more recently rated aircraft engine
ABS transactions. Please refer to the published presales for Blade
and recently rated transactions for further information on these
assumptions and stresses.

For any leases expected to end in the next 12 months or any engines
that are currently off lease, Fitch assumed an additional three
months of downtime in addition to lessor-specific remarketing
downtime assumptions in order to account for potential remarketing
challenges in placing engines with a new lessee in the current
distressed environment.

With the grounding of global fleets and significant reduction to
air travel, maintenance revenue and costs will be affected and are
expected to decline due to airline lessee credit issues and
grounded aircraft. However, no additional maintenance costs are
expected through YE 2020 based on Blade's annual budget. At the
initial rating of Blade, maintenance revenues were also assumed to
net out against maintenance costs over time. Therefore, no
additional adjustments have been made for this review.

RATING SENSITIVITIES

The ratings on the series A notes of Blade 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 engine 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 engine 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 engine 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:

The Aircraft ABS sector has a rating cap of 'Asf'. All subordinate
tranches carry one category of ratings lower than the senior
tranche, and remain below the initial ratings. Stronger residual
values alone would not be sufficient to improve the rating
recommendation in Blade. However, if the transaction experiences
stronger residual value realization than what was modeled by Fitch
coupled with stronger lease cash flow collections than the stressed
scenarios, the transactions could perform better than expected.

Under this scenario, residual value recoveries at time of sale are
assumed at 100% of their depreciated market values up from 50% in
the base case. In addition, lease rate factors are assumed at 1.50%
up from 0.85%/1.40% for operating leases/short-term leases in the
base case. Gross cash flows increase approximately 75%, and the A-1
and A-2 notes are able to pay in full under the 'Bsf' stress level
implying potential upgrade beyond current ratings.

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

Due to the current ratings on the notes, further downside
sensitivities would be of limited informational value.

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).


BUNKER HILL 2020-1: S&P Rates Class B-2 Notes 'B+ (sf)'
-------------------------------------------------------
S&P Global Ratings assigned its ratings to Bunker Hill Loan
Depositary Trust 2020-1's mortgage-backed notes.

The note issuance is an RMBS transaction backed by first-lien,
fixed-, and adjustable-rate and interest-only residential mortgage
loans secured by single-family residences, planned-unit
developments, two- to four-family residences, condominiums, and
other property types to both prime and nonprime borrowers.

The ratings reflect:

-- The pool's collateral composition;
-- The credit enhancement provided for this transaction;
-- The transaction's associated structural mechanics;
-- The transaction's representation and warranty framework;
-- The mortgage aggregator and originators; and
-- The impact that the economic stress brought on by COVID-19 is
likely to have on the performance of the mortgage borrowers in the
pool and liquidity available in the transaction.

S&P Global Ratings acknowledges a high degree of uncertainty about
the evolution of the coronavirus pandemic. The consensus among
health experts is that the pandemic may now be at, or near, its
peak in some regions, but will remain a threat until a vaccine or
effective treatment is widely available, which may not occur until
the second half of 2021.

"We are using this assumption in assessing the economic and credit
implications associated with the pandemic. As the situation
evolves, we will update our assumptions and estimates accordingly,"
S&P said.

   RATINGS ASSIGNED

  Bunker Hill Loan Depositary Trust 2020-1

  Class       Rating(i)            Amount ($)
  A-1         AAA (sf)            135,244,000
  A-2         AA (sf)               9,331,000
  A-3         A (sf)               12,535,000
  M-1         BBB (sf)             10,461,000
  B-1         BB+ (sf)              7,163,000
  B-2         B+ (sf)               6,032,000
  B-3         NR                    7,728,662
  A-IO-S      NR                     Notional(ii)
  XS          NR                     Notional(ii)
  R           NR                          N/A

(i)The ratings address the ultimate payment of interest and
principal. They do not address payment of the cap carryover
amounts.
(ii)The notional amount equals the loans' aggregate stated
principal balance.
NR--Not rated.
N/A--Not applicable.


CARLYLE GLOBAL 2016-2: Moody's Cuts Rating on Cl. D-2R Notes to B1
------------------------------------------------------------------
Moody's Investors Service has downgraded the ratings on the
following notes issued by Carlyle Global Market Strategies CLO
2016-2, Ltd.:

US$28,000,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes due 2027, Downgraded to Ba1 (sf); previously on April 17,
2020 Baa3 (sf) Placed Under Review for Possible Downgrade

US$5,000,000 Class D-1 Mezzanine Secured Deferrable Floating Rate
Notes due 2027, Downgraded to B1 (sf); previously on April 17, 2020
Ba3 (sf) Placed Under Review for Possible Downgrade

US$16,000,000 Class D-2R Mezzanine Secured Deferrable Floating Rate
Notes due 2027, Downgraded to B1 (sf); previously on April 17, 2020
Ba3 (sf) Placed Under Review for Possible Downgrade

These actions conclude the review for downgrade initiated on April
17, 2020 on the Class C, Class D-1 and Class D-2R notes issued by
the CLO. Carlyle Global Market Strategies CLO 2016-2, Ltd., issued
in June 2016 and partially refinanced in August 2018, is a managed
cashflow CLO. The notes are collateralized primarily by a portfolio
of broadly syndicated senior secured corporate loans. The
transaction's reinvestment period will end in January 2021.

RATINGS RATIONALE

The downgrades on the Class C, Class D-1 and Class D-2R notes
reflect the risks posed by credit deterioration and loss of
collateral coverage observed in the underlying CLO portfolio, which
have been primarily prompted by economic shocks stemming from the
coronavirus pandemic. Since the outbreak widened in March, the
decline in corporate credit has resulted in a significant number of
downgrades, other negative rating actions, or defaults on the
assets collateralizing the CLO. Consequently, the default risk of
the CLO portfolio has increased, the credit enhancement available
to the CLO notes has eroded, exposure to Caa-rated assets has
increased significantly, and expected losses (ELs) on certain notes
have increased materially.

Based on Moody's calculation, the weighted average rating factor
(WARF) was 3411 as of June 2020, or 18% worse compared to a WARF of
2892 reported in the March 2020 trustee report [1]. Moody's
calculation also showed the WARF was failing the test level of 2879
reported in the June 2020 trustee report [2] by 532 points. Moody's
noted that approximately 33% of the CLO's par was from obligors
assigned a negative outlook and 4% from obligors whose ratings are
on review for possible downgrade. Additionally, based on Moody's
calculation, the proportion of obligors in the portfolio with
Moody's corporate family or other equivalent ratings of Caa1 or
lower (adjusted for negative outlook and watchlist for downgrade)
was approximately 21% of the CLO par as of June 2020. Furthermore,
Moody's calculated the total collateral par balance, including
recoveries from defaulted securities, at $488.1 million, or $11.9
million less than the deal's ramp-up target par balance, and
Moody's calculated the over-collateralization (OC) ratios
(excluding haircuts) for the Class C and Class D notes as of June
2020 at 111.19% and 106.12%, respectively. Moody's noted that the
OC test for the Class D notes and the interest diversion test were
recently reported [2] as failing. If these failures were to occur
on the next payment date, they would result in a portion of excess
interest collections being diverted towards note repayment or
reinvestment in collateral.

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

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base case,
Moody's analyzed the collateral pool as having a performing par and
principal proceeds balance of $481.1 million, defaulted par of
$13.5 million, a weighted average default probability of 25.83%
(implying a WARF of 3411), a weighted average recovery rate upon
default of 47.77%, a diversity score of 80 and a weighted average
spread of 3.57%. Moody's also analyzed the CLO by incorporating an
approximately $12.4 million par haircut in calculating the OC and
interest diversion test ratios. Finally, Moody's also considered in
its analysis impending restrictions on trading resulting from the
end of the reinvestment period, the positive impact on the rated
notes of the imminent reduction of leverage as notes begin to
amortize, and the CLO manager's recent investment decisions and
trading strategies.

In consideration of the current high uncertainties around the
global economy and the ultimate performance of the CLO portfolio,
Moody's conducted a number of additional sensitivity analyses
representing a range of outcomes that could diverge, both to the
downside and the upside, from its base case. Some of the additional
scenarios that Moody's considered in its analysis of the
transaction include, among others: additional near-term defaults of
companies facing liquidity pressure; additional OC par haircuts to
account for potential future downgrades and defaults resulting in
an increased likelihood of cash flow diversion to senior notes; and
some improvement in WARF as the US economy gradually recovers in
the second half of the year and corporate credit conditions
generally stabilize.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of corporate assets from the collapse
in the US economic activity in the second quarter and a gradual
recovery in the second half of the year. However, that outcome
depends on whether governments can reopen their economies while
also safeguarding public health and avoiding a further surge in
infections. 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.

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

The performance of the rated notes is subject to uncertainty in the
performance of the related CLO's underlying portfolio, which in
turn depends on economic and credit conditions that may change. In
particular, the length and severity of the economic and credit
shock precipitated by the global coronavirus pandemic will have a
significant impact on the performance of the securities. The CLO
manager's investment decisions and management of the transaction
will also affect the performance of the rated securities.

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


CD 2018-CD7: Fitch Affirms Class G-RR Certs at 'B-sf'
-----------------------------------------------------
Fitch Ratings has affirmed fifteen classes of the CD 2018-CD7
Mortgage Trust Commercial Mortgage Pass-Through Certificates,
Series 2018-CD7and revised the Outlooks on two classes to Negative
from Stable.

CD 2018-CD7

  - Class A-1 12512JAR5; LT AAAsf; Affirmed  

  - Class A-2 12512JAS3; LT AAAsf; Affirmed  

  - Class A-3 12512JAV6; LT AAAsf; Affirmed  

  - Class A-4 12512JAW4; LT AAAsf; Affirmed  

  - Class A-M 12512JAY0; LT AAAsf; Affirmed  

  - Class A-SB 12512JAT1; LT AAAsf; Affirmed  

  - Class B 12512JAZ7; LT AA-sf; Affirmed  

  - Class C 12512JBA1; LT A-sf; Affirmed  

  - Class D 12512JAE4; LT BBB-sf; Affirmed  

  - Class E-RR 12512JAG9; LT BBB-sf; Affirmed  

  - Class F-RR 12512JAJ3; LT BB-sf; Affirmed  

  - Class G-RR 12512JAL8; LT B-sf; Affirmed  

  - Class X-A 12512JAX2; LT AAAsf; Affirmed  

  - Class X-B 12512JAA2; LT AA-sf; Affirmed  

  - Class X-D 12512JAC8; LT BBB-sf; Affirmed  

KEY RATING DRIVERS

Increasing Loss Expectations/Specially Serviced Loans: Loss
expectations have increased primarily due to an increased number of
Fitch Loans of Concern, including seven loans (8.9% of the pool)
that have recently transferred to special servicing. Six of the
seven specially serviced loans transferred between May and June of
2020 due to hardships related to the coronavirus pandemic. Within
the specially serviced loans, two (2.9% of the pool) are secured by
retail properties located in secondary and tertiary locations; one
loan (1.2% of the pool), is secured by a multifamily property
located in San Antonio, TX and at issuance was noted that
approximately 49% of the tenants received some form of rental
subsidies. The remaining four specially serviced loans (4.9% of the
pool) are secured by limited service and extended stay hotel
properties located primarily in the southern United States.

The largest specially serviced loan, Homestead TownePlace Suites
(2.0% of the pool), is secured by a 115-key extended stay hotel
located in Homestead, FL (approximately 41 miles from Miami, FL).
The loan transferred in May 2020 due to imminent monetary default
due to the borrower's concerns with occupancy and cash flow due to
the ongoing coronavirus pandemic. Per the special servicer, the
loan remains current and they are currently evaluating next steps.

The Kinston Portfolio (1.3% of the pool) is the sole
non-coronavirus related special servicing transfer. The loan is
secured by two limited service hotels located in Kinston, NC. The
loan transferred to special servicing in October 2018 due to
imminent default after one of the properties sustained significant
damage during Hurricane Florence. The property subsequently
underwent a property improvement plan, which resulted in the
closure of the property due to renovations. The hotel received
approval from the franchisor to re-open in April 2020; however,
given the ongoing pandemic the borrower and special servicer have
agreed to a seven-month forbearance agreement that includes
deferred payment of principal, interest and FF&E for four months,
commencing in May 2020 through August 2020. All deferrals must be
re-paid by the end of the forbearance period, which expires in
December 2020. The borrower has also requested approval for use of
a PPP loan for payment of expenses of the property and the loan.
The loan remained current while with the special servicer; however,
it is 30 days delinquent as of June 2020.

Outside of the specially serviced loans, two loans (6.6% of the
pool) were considered Fitch Loans of Concern due to either failing
to meet the coronavirus NOI debt service coverage ratio tolerance
thresholds and/or significant upcoming lease rollover. The largest
non-specially serviced FLOC, Alabama Hotel Portfolio (3.8% of the
pool), is secured by two hotels totaling 304 keys located in
Alabama. The loan transferred to special servicing in March 2020
for imminent default. Per the special servicer commentary, the
borrower was seeking forbearance, but upon further discussion
withdrew the request. The loan subsequently returned to the master
servicer in April 2020 and remains current. As of YE 2019, the
portfolio had a weighted average RevPar penetration rate of 134.8%
compared with 130.5% at issuance and NOI DSCR of 2.04x as of YE
2019 from 2.13x at YE 2018. However, the loan fails to meet the
property specific coronavirus NOI DSCR tolerance threshold and
therefore, received additional stresses to address expected
declines in performance.

The last FLOC, Riverwalk (2.8% of the pool), is secured by a
630,379-sf office property located in Lawrence, MA, built in 1901
and renovated in 2007. Approximately 41% of the NRA has lease
expirations between 2020 and 2021, including three of the top five
tenants. The property's occupancy as of YE 2019 remained stable at
91.1% from 91.5% at YE 2018 and NOI DSCR improved to 1.64x from
1.42x at YE 2018.

Minimal Changes to Credit Enhancement: As of the June 2020
remittance, the pool's aggregate principal balance has been reduced
by 0.5% to $714 million from $717 million at issuance. All
forty-two loans remain in the pool. Twenty loans (39.6% of the
pool) have partial interest only payments, including six loans (21%
of the pool) in the top 15. Six of the loans with partial interest
only payments are now amortizing. Thirteen loans (49.6% of the
pool) are interest only for the full loan term, including eight
loans (43.5% of the pool) in the top 15. As of the June 2020
remittance, three loans (4.0% of the pool) are between 30 and 60
days delinquent, all of which are specially serviced.

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 prompted
the closure of several hotel properties in gateway cities as well
as malls, entertainment venues and individual stores.

Eight loans (14.3% of the pool) are secured by hotel loans and ten
loans (22.4% of the pool) are secured by retail properties. The
hotel loans have a weighted average DSCR of 2.37x; however,
excluding the specially serviced hotel loans, the WADSCR is 2.26x
On average, excluding the specially serviced loans, the hotel loans
can sustain an average decline of 54.8% before the NOI DSCR would
fall below 1.0x.

On average, the retail loans have a WADSCR of 2.07x and would
sustain a 50.6% decline in NOI before the DSCR would fall below
1.0x. Excluding the specially serviced retail loans, the WADSCR
remains the same. One multifamily loan, the Westside NYC
Multifamily Portfolio (5.9% of the pool), failed the coronavirus
NOI DSCR tolerance threshold. As of YE 2019, the NOI DSCR was 1.11x
from 1.22x at issuance. Fitch has requested updates on the reason
for the declines in performance.

In addition to the loans that have already transferred to special
servicing due to the coronavirus pandemic, four loans (11.5% of the
pool) are currently on the master servicer's watchlist due to the
borrower's indication of potential cash flow issues related to the
coronavirus pandemic, including two loans (9.4% of the pool) in the
top 15. All the loans on the master servicer's watchlist remain
current. 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 revisions on classes F-RR and
G-RR.

RATING SENSITIVITIES

The Negative Outlook revisions on classes F-RR and G-RR, reflect
performance concerns with the specially serviced and FLOCs, which
are primarily secured by hotel and retail properties, given 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 paydown and/or
defeasance. Upgrades to the 'A-sf' and 'AA-sf' rated classes are
not expected, but would likely occur with significant improvement
in credit enhancement and/or defeasance and/or the stabilization to
the properties impacted from the coronavirus pandemic.

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 of
interest shortfalls. An upgrade to the 'BB-sf' and 'B-sf' rated
classes is not likely unless the performance of the remaining pool
stabilizes and the senior classes pay off.

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

Downgrades to the senior classes, rated 'A-sf' through 'AAAsf', are
not likely due to the position in the capital structure and the
high CE. Downgrades to the classes rated 'BBB-sf' and below would
occur if the performance of the FLOCs and/or specially serviced
loans continues to decline or fails to stabilize. The Rating
Outlooks on classes 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, classes 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 to or reviewed by Fitch
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).


CITIGROUP 2020-WSS: S&P Assigns Prelim B(sf) Rating to Cl. F Certs
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Citigroup
Commercial Mortgage Trust 2020-WSS' commercial mortgage
pass-through certificates.

The certificate issuance is a CMBS transaction backed by a
commercial mortgage loan secured by the borrowers' fee simple
interests and the operating lessee's leasehold interest in 74
extended-stay WoodSpring Suites hotels across 26 U.S. states.

The preliminary ratings are based on information as of July 7,
2020. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect S&P's view of the collateral's
historical and projected performance, the sponsor's and manager's
experience, the trustee-provided liquidity, the loan's terms, and
the transaction's structure.

  PRELIMINARY RATINGS ASSIGNED

  Citigroup Commercial Mortgage Trust 2020-WSS

  Class          Rating          Amount ($)
  A              AAA (sf)       148,646,000
  B              AA- (sf)        46,526,000
  C              A- (sf)         42,313,000
  D              BBB- (sf)       51,221,000
  E              BB- (sf)        80,852,000
  F              B (sf)          43,692,000
  VRR interest   NR              21,750,000

  NR--Not rated.


COMM 2013-CCRE7: Moody's Confirms Caa3 Rating on Class G Debt
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings on nine classes and
confirmed the ratings on three classes in COMM 2013-CCRE7 Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series
2013-CCRE7 as follows:

Cl. A-SB, Affirmed Aaa (sf); previously on Jun 21, 2019 Affirmed
Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on Jun 21, 2019 Affirmed Aaa
(sf)

Cl. A-M, Affirmed Aaa (sf); previously on Jun 21, 2019 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa3 (sf); previously on Jun 21, 2019 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on Jun 21, 2019 Affirmed A3
(sf)

Cl. D, Affirmed Ba2 (sf); previously on Jun 21, 2019 Affirmed Ba2
(sf)

Cl. E, Confirmed at B1 (sf); previously on Apr 17, 2020 B1 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Confirmed at B3 (sf); previously on Apr 17, 2020 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. G, Confirmed at Caa3 (sf); previously on Apr 17, 2020 Caa3 (sf)
Placed Under Review for Possible Downgrade

Cl. X-A*, Affirmed Aaa (sf); previously on Jun 21, 2019 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed A2 (sf); previously on Jun 21, 2019 Affirmed A2
(sf)

Cl. PEZ**, Affirmed Aa3 (sf); previously on Jun 21, 2019 Affirmed
Aa3 (sf)

*Reflects Interest-Only Classes

**Reflects Exchangeable Class

RATINGS RATIONALE

The ratings on six principal and interest (P&I) classes were
affirmed and the ratings on three P&I classes were confirmed due to
the pool's share of defeasance and the transaction's key metrics,
including Moody's loan-to-value (LTV) ratio, Moody's stressed debt
service coverage ratio (DSCR) and the transaction's Herfindahl
Index (Herf), being within acceptable ranges.

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

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

The actions conclude the review for downgrade initiated on April
17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 6.0% of the
current pooled balance, compared to 8.9% at Moody's last review.
The one specially serviced loan at last review, One West Fourth
Street, liquidated with a $9.5 million loss (for a 27% loss
severity). Moody's base expected loss plus realized losses is now
4.1% of the original pooled balance, compared to 5.7% at the last
review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except the
exchangeable class and interest-only classes were "Approach to
Rating US and Canadian Conduit/Fusion CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 12th, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 49% to $481 million
from $936 million at securitization. The certificates are
collateralized by 46 mortgage loans ranging in size from less than
1% to 13% of the pool, with the top ten loans (excluding
defeasance) constituting 47% of the pool. Nine loans, constituting
20% 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 18, compared to 23 at Moody's last review.

As of the June 2020 remittance report, loans representing 80% were
current or within their grace period on their debt service
payments, 17% were beyond their grace period but less than 30 days
delinquent, 2% were between 30 -- 59 days delinquent, and 2% were
delinquent at 60 days or more.

Seven loans, constituting 30% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

One loan has been liquidated from the pool, the One West Fourth
Street loan, resulting in a realized loss of $9.5 million (for an
average loss severity of 27%). Five loans, constituting 8% of the
pool, are currently in special servicing. All the five specially
serviced loans have transferred to special servicing since March
2020 and are each either current or less than 60 days delinquent on
debt service payments.

The largest specially serviced loan is the Hampton Inn Jekyll
Island, GA loan ($12.8 million -- 2.7% of the pool), which is
secured by a 138-key limited service hotel located in Jekyll
Island, Georgia. Property performance has generally increased from
securitization; however, the loan was transferred to special
servicing in late March 2020 as a result of the coronavirus
outbreak and the borrower has requested relief. Jekyll Island is an
oceanfront tourist destination with three premiere golf courses and
65.0% of the land on Jekyll Island is prohibited from being
developed due to its classification as a state park. The special
servicer indicated that the loan payments have been made current
through July and forbearance discussion are in progress.

The remaining four specially serviced loans are secured by retail
and hotel properties. They each transferred to specially servicing
between April and May and as of the June 2020 remittance statement
were either current or less than 60 days delinquent on their debt
service payments. The special servicer has indicated that short
term forbearance agreements are being discussed for each of the
loans.

Moody's has also assumed a high default probability for one poorly
performing loan, Villagio Apartments constituting 1.7% of the pool.
The loan is secured by a multifamily property in Fayetteville,
North Carolina that has sufferance from declining revenue and
occupancy since securitization. The property's reported DSCR has
been below 1.00X since 2018, however, the loan remains current as
of the June 2020 remittance statement.

Moody's received full or partial year 2019 operating results for
89% of the pool (excluding specially serviced and defeased loans).
Moody's weighted average conduit LTV is 101%. Moody's conduit
component excludes loans with structured credit assessments,
defeased and CTL loans, and specially serviced and troubled loans.
Moody's net cash flow (NCF) reflects a weighted average haircut of
20% to the most recently available net operating income (NOI).
Moody's value reflects a weighted average capitalization rate of
10.2%.

Moody's actual and stressed conduit DSCRs are 1.55X and 1.19X,
respectively, compared to 1.72X and 1.30X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 24% of the pool balance. The
largest loan is the Lakeland Square Mall Loan ($60.6 million --
12.6% of the pool), which is secured by a 535,937 square feet (SF)
component of a 883,290 SF regional mall located in Lakeland,
Florida approximately 35 miles east of Tampa. At securitization,
the property was anchored by Dillard's, J.C. Penney, Macy's, and
Sears, with only J.C. Penney contributed as collateral for the
loan. However, Macy's and Sears closed their stores at this
location in 2017 and 2018, respectively. The J.C. Penney location
has not been included in the list of closures as a result of the
recent Chapter 11 Bankruptcy. Other major collateral tenants at
securitization include Burlington Coat Factory, Cinemark Movie
Theaters, and Sports Authority. Sports Authority vacated its space
in late 2016, but was subsequently backfilled by a 42,000 SF Urban
Air Adventure Park. As of March 2020, the property was 94% leased,
compared to 90% leased as of December 2019 and 85% leased as of
December 2017. The mall also faces direct competition from a
lifestyle center built in 2006, located in the affluent, southern
section of the trade area, approximately 10 miles from the subject
property. Performance of the property has trended downward since
securitization, with the 2019 NOI being 10% lower than in 2014 as a
result of lower revenue. Comparable tenant in-line sales (less than
10,000 SF) were $372 PSF for the trailing 12-month period ending in
March 2020, compared to $393 PSF for the prior 12-month period. The
loan sponsor is Brookfield Properties and the loan is current
through its June 2020 payment date. Moody's LTV and stressed DSCR
are 141% and 0.82X, respectively, compared to 133% and 0.87X at
last review.

The second largest loan is the PNC Center Loan ($28.2 million --
5.9% of the pool), which is secured by a 22-story, Class A-/B+
office building now known as 20 Stanwix, located in the "Golden
Triangle" submarket within the CBD of Pittsburgh, Pennsylvania. At
securitization PNC Bank was the largest tenant, occupying 109,710
SF, 32.5% of the net rentable area (NRA), on five of the top six
floors of the property, however, they vacated at their lease
expiration date in December 2017. As of March 2020, the property
was 61% leased, compared to 62% leased in April 2019 and 88% leased
in December 2017. The low occupancy has caused the DSCR to drop
below 1.00X in both 2018 and 2019. However, the loan remains
current as of its June 2020 payment date and the borrower indicates
they are negotiating with tenants for portions of the vacant space.
The loan has amortized 12% since securitization and Moody's LTV and
stressed DSCR are 135% and 0.80X, respectively, compared to 131%
and 0.78X at the last review.

The third largest loan is the 20 Church Street Loan ($26.8 million
-- 5.6% of the pool), which is secured by 404,015 SF Class A-/B+
office tower located in the CBD of Hartford, Connecticut. As of
October 2019, the property was 94% leased, compared to 98% leased
in September 2018 and 97% in December 2017. Property performance
has improved since securitization due to increased rental revenue.
The loan benefits from amortization and has amortized 13% since
securitization. Moody's LTV and stressed DSCR are 89% and 1.22X,
respectively, compared to 84% and 1.29X at the last review.


COMM 2014-CCRE14: Moody's Lowers Class E Debt to Caa1
-----------------------------------------------------
Moody's Investors Service has affirmed the ratings on nine classes,
confirmed the rating on one class and downgraded the ratings on two
classes in COMM 2014-CCRE14 Mortgage Trust, Commercial Pass-Through
Certificates, Series 2014-CCRE14 as follows:

Cl. A-2, Affirmed Aaa (sf); previously on Feb 25, 2019 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Feb 25, 2019 Affirmed
Aaa (sf)

Cl. A-3, Affirmed Aaa (sf); previously on Feb 25, 2019 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Feb 25, 2019 Affirmed Aaa
(sf)

Cl. A-M, Affirmed Aaa (sf); previously on Feb 25, 2019 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa3 (sf); previously on Feb 25, 2019 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on Feb 25, 2019 Affirmed A3
(sf)

Cl. D, Downgraded to Ba2 (sf); previously on Apr 17, 2020 Ba1 (sf)
Placed Under Review for Possible Downgrade

Cl. E, Downgraded to Caa1 (sf); previously on Apr 17, 2020 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Confirmed at Caa3 (sf); previously on Apr 17, 2020 Caa3 (sf)
Placed Under Review for Possible Downgrade

Cl. X-A*, Affirmed Aaa (sf); previously on Feb 25, 2019 Affirmed
Aaa (sf)

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

* Reflects interest-only classes

** Reflects exchangeable classes

RATINGS RATIONALE

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

The ratings on two P&I classes, were downgraded due to the decline
in pool performance and higher anticipated losses from the
specially serviced and troubled loans.

The rating on P&I class, Cl. F was confirmed because the ratings
are consistent with Moody's expected loss plus realized losses.

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

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

The actions conclude the review for downgrade initiated on April
17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 4.8% of the
current pooled balance, compared to 5.4% at the last review.
Moody's base expected loss plus realized losses is now 4.5% of the
original pooled balance, compared to 4.2% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except exchangeable
classes and interest-only classes were "Approach to Rating US and
Canadian Conduit/Fusion CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 12, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 25% to $1.03 billion
from $1.38 billion at securitization. The certificates are
collateralized by 45 mortgage loans ranging in size from less than
1% to 15% of the pool, with the top ten loans (excluding
defeasance) constituting 62% of the pool. Two loans, constituting
25.6% of the pool, have investment-grade structured credit
assessments. Eight loans, constituting 10.7% 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 12, compared to 15 at Moody's last review.

As of the June 2020 remittance report, loans representing 91% were
current, 3% were beyond their grace period but less than 30 days
late, 3% were 30 days delinquent, 1% was delinquent at 60 days and
2% were foreclosed.

Six loans, constituting 8.8% 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.

Four loans have been liquidated from the pool, resulting in an
aggregate realized loss of $11.4 million (for an average loss
severity of 60%). Three loans, constituting 4.0% of the pool, are
currently in special servicing. The largest specially serviced loan
is the McKinley Mall Loan ($24.4 million -- 2.4% of the pool),
which represents a 73.7% pari-passu portion of a $34.8 million
first mortgage loan. The loan is secured by a 728,133 square foot
portion of an 847,000 SF regional mall located in Buffalo, New
York. The loan transferred to special servicing in April 2018. The
property lost anchor tenant Macy's in 2017 and anchor tenant
Bon-Ton in 2018. Current anchors include: Sears and JC Penney.
Property performance has declined steadily since securitization and
year end 2019 net operating income is substantially lower than at
securitization. The loan is delinquent and has taken significant
appraisal reductions.

The remaining two specially serviced loans are secured by hotel
properties with the Residence Inn flag. Moody's has also assumed a
high default probability for two poorly performing loans,
constituting approximately 2% of the pool. Moody's estimates an
aggregate $28 million loss for the specially serviced and troubled
loans (a 47% expected loss on average).

As of the June 12, 2020 remittance statement cumulative interest
shortfalls were $3.07 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 2019 operating results for 90% of the
pool, and partial year 2020 operating results for 51% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 108%, compared to 105% at Moody's last
review. Moody's conduit component excludes loans with structured
credit assessments, defeased and CTL loans, and specially serviced
and troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 19% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.7%.

Moody's actual and stressed conduit DSCRs are 1.29X and 0.99X,
respectively, compared to 1.35X and 1.01X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The largest loan with a structured credit assessment is the 60
Hudson Street Loan ($155.0 million -- 15.0% of the pool), which
represents a 55.4% pari-passu portion of a $280.0 million mortgage
loan. The loan is secured by a 24-story, mission critical
telecommunications and data center building located in the Tribeca
neighborhood of New York City. The property is widely regarded as
one of the world's most connected telecommunications and data
center buildings. The property was 74% leased as of March 2020,
compared to 75% in September 2018, and 76% in February 2017.
Moody's structured credit assessment and stressed DSCR are aaa
(sca.pd) and 1.81X, respectively.

The other loan with a structured credit assessment is the 625
Madison Avenue loan ($110.0 million, 10.6% of the pool), which
represents a 56.4% pari-passu portion of a $195 million first
mortgage loan. The loan is secured by the fee interest in a
0.81-acre parcel of land located at 625 Madison Avenue between East
58th and East 59th Street in New York City. The property is also
encumbered with $195 million of mezzanine debt. The fee interest is
subject to a ground lease pursuant to which the ground tenant
constructed, developed and owns the improvements that sit on top of
the ground. The improvements consist of a 17-story, mixed-use
building, and the ground tenant's interest in the improvements is
not collateral for the 625 Madison Avenue loan. Moody's structured
credit assessment is aa2 (sca.pd).

The top three conduit loans represent 22.9% of the pool balance.
The largest loan is the Google and Amazon Office Portfolio Loan
($150.0 million --14.5% of the pool), which represents a 34.3%
pari-passu portion of a $445.9 million mortgage. The property is
also encumbered by $67.8 million of mezzanine debt. The loan is
secured by an office portfolio located in Sunnyvale, California.
The Moffett Towers Building D (Amazon Building) is a newly
constructed eight-story, Class A office building containing 357,481
SF. It is part of a seven-building campus. A2Z Development, a
wholly owned subsidiary of Amazon, will use the space for design
and product development for the Kindle e-reader. The Google Campus
is comprised of four, four-story, Class A office buildings totaling
700,328 SF, which is part of a six-building office campus known as
Technology Corners. Moody's LTV and stressed DSCR are 108% and
0.94X, respectively, compared to 110% and 0.92X at the last
review.

The second largest loan is the Highland Hills Apartments Loan
($49.4 million -- 4.8% of the pool), which is secured by an
826-unit student housing property located in Mankato, Minnesota.
The property was constructed in three separate phases between 1963
and 2011. The property is located directly across from Minnesota
State University. The property was 86% leased as of December 2019
compared to 90% in September 2018, 83% in September 2017 and 98% at
securitization. Property performance has deteriorated since
securitization, with a decline in NOI and occupancy. Moody's LTV
and stressed DSCR are 125% and 0.87X, respectively, compared to
106% and 0.91X at the last review.

The third largest loan is the 175 West Jackson Loan ($37.9 million
-- 3.7% of the pool), which is secured by a Class A, 22-story
office building totaling 1.45 million SF and located within the CBD
of Chicago, Illinois. The loan had transferred to special servicing
March 2018 for imminent monetary default. The loan was assumed by
Brookfield Property Group as the new sponsor, in connection with
the purchase of the property. The loan returned to the master
servicer in August 2018. Moody's LTV and stressed DSCR are 122% and
0.80X, respectively, compared to 113% and 0.86X at the last review.


COMM 2015-LC23: Fitch Affirms Class G Debt at 'B-sf'
----------------------------------------------------
Fitch Ratings has affirmed 17 classes of COMM 2015-LC23 Mortgage
Trust.

COMM 2015-LC23

  - Class A-1 12636FBE2; LT AAAsf; Affirmed  

  - Class A-2 12636FBF9; LT AAAsf; Affirmed  

  - Class A-3 12636FBH5; LT AAAsf; Affirmed  

  - Class A-4 12636FBJ1; LT AAAsf; Affirmed  

  - Class A-M 12636FBM4; LT AAAsf; Affirmed  

  - Class A-SB 12636FBG7; LT AAAsf; Affirmed  

  - Class B 12636FBN2; LT AA-sf; Affirmed  

  - Class C 12636FBP7; LT A-sf; Affirmed  

  - Class D 12636FAL7; LT BBBsf; Affirmed  

  - Class E 12636FAN3; LT BBB-sf; Affirmed  

  - Class F 12636FAQ6; LT BB-sf; Affirmed  

  - Class G 12636FAS2; LT B-sf; Affirmed  

  - Class X-B 12636FAA1; LT AA-sf; Affirmed  

  - Class X-C 12636FAC7; LT BBB-sf; Affirmed  

  - Class X-D 12636FAE3; LT BB-sf; Affirmed  

  - Class XP-A 12636FBK8; LT AAAsf; Affirmed  

  - Class XS-A 12636FBL6; LT AAAsf; Affirmed  

KEY RATING DRIVERS

Increased Loss Expectations: While the majority of the pool
maintains stable performance, loss expectations on the pool have
increased due to the seven Fitch Loans of Concern (FLOCs, 18% of
the pool), including three loans (10.6%) in special servicing, as
well as overall concerns over the impact of the coronavirus
pandemic on the pool.

Fitch Loans of Concern: The largest FLOC is the Equity Inns
Portfolio loan (8.7%), which is secured by fee simple and leasehold
interests in 21 hotel properties located across 13 states totaling
2,690 rooms. No one state accounts for more than 18.6% of the
portfolio's total rooms, with Florida representing the largest
exposure by room count to a single state. As of YE 2019, the
servicer reported NOI DSCR was 2.30x for this interest only loan.
Occupancy, ADR and RevPAR are all in line with issuance. The loan
has an upcoming scheduled maturity in October 2020. Per the
servicer, the lender is finalizing a forbearance agreement with the
borrower related to the coronavirus pandemic. No further details
have been provided.

The second largest FLOC is the Whitehall Hotel loan (3.5%), which
is secured by a 222-key full-service hotel located in Chicago, IL.
The loan is 60 days delinquent. Performance at the property
declined prior to the coronavirus pandemic. As of YE 2019, the
servicer reported NOI DSCR was 1.04x compared to with 1.30x at YE
2018 for this amortizing loan. The loan is currently cash managed.

The third largest FLOC is the Springfield Mall loan (3.2%), which
is secured by a 611,079-sf (223,180 sf collateral) retail mall
located in Springfield Township, PA. The mall is anchored by
non-collateral tenants Macy's and Target. The loan is 30 days
delinquent. According to servicer updates, the loan has not
transferred to special servicing; however, the special servicer is
reviewing a modification request. Per its website, the mall has
reportedly re-opened with reduced hours. As of YE 2019, the
servicer reported NOI DSCR for this amortizing loan was 1.75x with
collateral occupancy of 92%. Per the December 2019 rent roll, 22%
of the NRA rolls in 2020, 22% of NRA in 2021, 21% of NRA in 2022
and 1.4% of NRA in 2023. Comparative inline sales for the TTM March
2020 period were reported at $396 psf compared with $401 psf at YE
2018 and $412 psf at YE 2017.

The next largest FLOC is the REO Colerain Center (1.2%), which is a
74,000-sf community retail center located in Colerain Township, OH.
The loan transferred to special servicing in December 2017 for
imminent default and became REO in June 2019. The largest tenant LA
Fitness (39% of NRA) went dark in January 2017. As of YE 2019,
occupancy was reported at 57%. According to servicer updates, the
property remains in value-add with no current disposition plans.

The remaining three FLOCs combine for 1.3% of the pool balance and
are secured by two hotels, one of which transferred to special
servicing in December 2019 due to cash flow issues. The last FLOC
is secured by a retail property that has seen a significant decline
in occupancy since issuance. Fitch will continue to monitor the
FLOCs.

Minimal Increase to Credit Enhancement: As of the June 2020
distribution date, the pool's aggregate principal balance was
reduced by 4% to $922.3 million from $961 million at issuance. Two
loans (6.6%) are fully defeased. There have been no realized losses
to date and interest shortfalls are currently affecting the
non-rated class J. Thirteen loans (22%) are full-term IO, and six
loans (7.9%) remain in partial IO periods, all of which will expire
in the fourth quarter of 2020.

Exposure to Coronavirus Pandemic: Fitch expects significant
economic impacts to certain hotels, retail and multifamily
properties 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 impacts. The pandemic prompted the closure of several hotel
properties in gateway cities, as well as malls, entertainment
venues and individual stores. Retail and Hotel properties comprise
31.8% and 19.9% of the pool balance, respectively. Fitch's base
case analysis applied additional stresses to 15 retail loans and
seven hotel loans due to their vulnerability to the coronavirus
pandemic.

Additional Considerations

High Hotel Exposure: There is a significant concentration of retail
hotel properties at 19.9%.

Geographic Concentrations: Loans secured by properties located in
California have the highest concentration at 26.4% followed by New
York at 21.3%.

RATING SENSITIVITIES

The Negative Outlooks on classes E, F, G, and interest only X-C and
X-D reflect the potential for a downgrade should performance of the
FLOCs continue to deteriorate. The Stable Outlooks on classes A-1
through D reflect the sufficient credit enhancement relative to
expected losses.

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

  -- 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
credit enhancement and/or defeasance; however, adverse selection
and increased concentrations, or the underperformance of the FLOCs,
could cause this trend to reverse.

  -- Upgrades to the 'BBBsf' and below-rated classes are considered
unlikely and would be limited based on sensitivity to
concentrations or the potential for future concentrations. Classes
would not be upgraded above 'Asf' if there is a likelihood of
interest shortfalls. An upgrade to the 'BB-sf' and 'B-sf' rated
classes is not likely until later years of 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:

  -- An increase in pool level losses due to underperforming or
specially serviced loans. Downgrades to the senior classes, rated
'A-sf' through 'AAAsf', are not likely due to their position in the
capital structure and the high credit enhancement; however,
downgrades to these classes may occur should interest shortfalls
occur. Downgrades to the classes rated 'BBBsf' would occur if the
performance of the FLOC continues to decline or fails to
stabilize.

  -- Downgrades to the classes with Negative Outlooks are possible
should performance of the FLOCs continue to decline and additional
loans transfer to special servicing and/or losses be realized.

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 classes assigned
a Negative Rating Outlook will be downgraded in 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).


DBUBS 2011-LC3: Moody's Lowers Class F Debt to Caa2
---------------------------------------------------
Moody's Investors Service has affirmed the ratings on six classes
and downgraded the ratings on three classes in DBUBS 2011-LC3
Mortgage Trust as follows:

  Cl. A-4, Affirmed Aaa (sf); previously on Dec 23, 2019 Affirmed
  Aaa (sf)

  Cl. A-M, Affirmed Aaa (sf); previously on Dec 23, 2019 Affirmed
  Aaa (sf)

  Cl. B, Affirmed Aaa (sf); previously on Dec 23, 2019 Affirmed
  Aaa (sf)

  Cl. C, Affirmed Aa1 (sf); previously on Dec 23, 2019 Upgraded
  to Aa1 (sf)

  Cl. D, Affirmed Baa1 (sf); previously on Dec 23, 2019 Affirmed
  Baa1 (sf)

  Cl. E, Downgraded to B1 (sf); previously on Apr 17, 2020
  Ba2 (sf) Placed Under Review for Possible Downgrade

  Cl. F, Downgraded to Caa2 (sf); previously on Apr 17, 2020
  B3 (sf) Placed Under Review for Possible Downgrade

  Cl. X-A*, Affirmed Aaa (sf); previously on Dec 23, 2019
  Affirmed Aaa (sf)

  Cl. X-B*, Downgraded to B3 (sf); previously on Apr 17, 2020
  B1 (sf) Placed Under Review for Possible Downgrade

* Reflects interest-only classes

RATINGS RATIONALE

The ratings on five P&I classes were affirmed due to the pool's
share of defeasance and the transaction's key metrics, including
Moody's loan-to-value ratio, Moody's stressed debt service coverage
ratio and the transaction's Herfindahl Index, being within
acceptable ranges.

The rating on two P&I classes, Cl. E and Cl. F, were downgraded due
to a decline in pool performance and higher anticipated losses
driven primarily by the declining performance of the Dover Mall and
Commons (16.6% of the pooled balance) and the Albany Mall (5.1% of
the pool). As of the June remittance statement, The Dover Mall and
Commons loan was more than 60 days delinquent and the Albany mall
loan were between 30 -- 59 days delinquent. Both loans mature by
July 2021 and may face significant refinance risk due to the
current retail environment.

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

The rating on the interest only (IO) class, Cl. X-B, was downgraded
due to the decline in credit quality of its referenced classes.

The actions conclude the review for downgrade initiated on April
17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 12.7% of the
current pooled balance, compared to 6.5% at the last review.
Moody's base expected loss plus realized losses is now 4.4% of the
original pooled balance, compared to 2.3% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except interest-only
classes were "Approach to Rating US and Canadian Conduit/Fusion
CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 12, 2020 distribution date, the transaction's
aggregate pooled certificate balance has decreased by 65% to $488
million from $1.40 billion at securitization. The certificates are
collateralized by 22 mortgage loans ranging in size from less than
1% to 9% of the pool. Twelve loans, constituting 51% 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 5, compared to 6 at Moody's last review.

As of the June 2020 remittance report, loans representing 71% were
current, 4% were beyond their grace period but less than 30 days
late, 8% were 30 days delinquent and 17% was delinquent at 60
days.

Five loans, constituting 26.0% 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.

No loans have been liquidated from the pool since securitization,
there are three loans, constituting 21% of the pool, are currently
in special servicing.

The largest specially serviced loan is the Dover Mall and Commons
Loan ($81.0 million -- 16.6% of the pooled balance), which is
secured by an approximately 554,000 SF component of an 886,000 SF
single-level enclosed super-regional mall located in Dover,
Delaware. Mall anchors include Macy's, Boscov's (non-collateral),
and JC Penney (non-collateral). The mall has one vacant anchor box,
a former Sears (111,000 SF) which vacated this location in August
2018. The total mall and inline space (


FINANCE OF AMERICA 2019-AB1: Moody's Cuts Class M3 Debt to B1
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches from Finance of America HECM Buyout 2019-AB1.

The certificates are backed by a pool of active home equity
conversion mortgages. The servicer for the deal is Finance of
America Reverse LLC.

The complete rating actions are as follows:

Issuer: Finance of America HECM Buyout 2019-AB1

Cl. AM2, Downgraded to Baa3 (sf); previously on Dec 19, 2019
Definitive Rating Assigned Baa2 (sf)

Cl. M2, Downgraded to Baa3 (sf); previously on Dec 19, 2019
Definitive Rating Assigned Baa2 (sf)

Cl. M3, Downgraded to B1 (sf); previously on Dec 19, 2019
Definitive Rating Assigned Ba2 (sf)

RATINGS RATIONALE

The rating actions are primarily driven by the large amounts of HUD
assignments since issuance. Since December 2019, the servicer
assigned approximately $115 million of mortgage loans to HUD. When
a loan is assigned to HUD, the trust receives the lower of the
maximum claim amount and the unpaid principal balance of the loan
as of the assignment date. Assignments to HUD have the same effect
as if the related borrowers made prepayments in full of such
mortgage loans. Although the assignment is beneficial to the senior
note, the most junior tranches are at a disadvantage because
increased assignments reduce the excess spread available to cover
principal payments.

As of closing, there were 1,174 loans with an aggregate balance of
$254,425,213. Approximately, 59% of the loans were flagged as
assignable to HUD as of closing. As of June 2020, the pool contains
623 loans with an aggregate balance of $145,052,137. About 31% of
the remaining loans are assignable to HUD which Moody's expects to
be assigned by the servicer by the end of the year.

The collateral in this pool accrues interest on an average mortgage
rate of 4.99% and the bonds accrue interest on a weighted average
coupon rate of 3.17%. The large number of HUD assignments observed
in the past few months have decreased the number of outstanding
mortgage loans and the credit enhancement available, from the
spread, for Class M-2 and Class M-3.

This transaction follows a sequential payment structure with
accrual features. The unpaid interest is added to the outstanding
principal balance of the subordinate notes and the interest is
calculated on the outstanding balance. This accrual feature leads
to an increase in the balance of the notes overtime.

The loans are predominately fixed rate, fully drawn with a weighted
average current mortgage rate of 4.99%. Current LTV is 111.0% which
is slightly up from the pool at closing which was 106.7%. The
weighted average age of the borrowers in the pool is 79 years and
the borrowers ages range from 68 to 99. About 39.4% of the pool is
comprised of borrowers who are more than 79 years of age (based on
the minimum age of living borrower and co-borrowers)

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of US RMBS from the collapse in the
US economic activity in the second quarter and a gradual recovery
in the second half of the year. However, that outcome depends on
whether governments can reopen their economies while also
safeguarding public health and avoiding a further surge in
infections. 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.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Reverse
Mortgage Securitizations Methodology" published in April 2020.7.

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

Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of stress could
drive the ratings up. Transaction performance depends greatly on
the US macro economy and housing market. Property markets could
improve from its original expectations resulting in appreciation in
the value of the mortgaged property and faster property sales.

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of stresses could drive the
ratings down. High level of prepayment or assignment which will
lead to lower excess spread to cover principal payments on the
junior subordinate notes. Transaction performance depends greatly
on the US macro economy and housing market. Property markets could
deteriorate from its original expectations resulting in
depreciation in the value of the mortgaged property and slower
property sales.


FREDDIE MAC 2020-DNA3: Fitch Assigns Bsf Rating on 17 Tranches
--------------------------------------------------------------
Fitch Ratings has assigned ratings to Freddie Mac's Structured
Agency Credit Risk REMIC Trust 2020-DNA3.

STACR 2020-DNA3

  - Class A-H; LT NRsf New Rating

  - Class M-1; LT BBB-sf New Rating

  - Class M-1H; LT NRsf New Rating

  - Class M-2; LT Bsf New Rating

  - Class M-2A; LT BBsf New Rating

  - Class M-2AH; LT NRsf New Rating

  - Class M-2AI; LT BBsf New Rating

  - Class M-2AR; LT BBsf New Rating

  - Class M-2AS; LT BBsf New Rating

  - Class M-2AT; LT BBsf New Rating

  - Class M-2AU; LT BBsf New Rating

  - Class M-2B; LT Bsf New Rating

  - Class M-2BH; LT NRsf New Rating

  - Class M-2BI; LT Bsf New Rating

  - Class M-2BR; LT Bsf New Rating

  - Class M-2BS; LT Bsf New Rating

  - Class M-2BT; LT Bsf New Rating

  - Class M-2BU; LT Bsf New Rating

  - Class M-2I; LT Bsf New Rating

  - Class M-2R; LT Bsf New Rating

  - Class M-2RB; LT Bsf New Rating

  - Class M-2S; LT Bsf New Rating

  - Class M-2SB; LT Bsf New Rating

  - Class M-2T; LT Bsf New Rating

  - Class M-2TB; LT Bsf New Rating

  - Class M-2U; LT Bsf New Rating

  - Class M-2UB; LT Bsf New Rating

  - Class B-1; LT NRsf New Rating

  - Class B-1A; LT NRsf New Rating

  - Class B-1AH; LT NRsf New Rating

  - Class B-1AI; LT NRsf New Rating

  - Class B-1AR; LT NRsf New Rating

  - Class B-1B; LT NRsf New Rating

  - Class B-1BH; LT NRsf New Rating

  - Class B-2; LT NRsf New Rating

  - Class B-2A; LT NRsf New Rating

  - Class B-2AH; LT NRsf New Rating

  - Class B-2AI; LT NRsf New Rating

  - Class B-2AR; LT NRsf New Rating

  - Class B-2B; LT NRsf New Rating

  - Class B-2BH; LT NRsf New Rating

  - Class B-2H; LT NRsf New Rating

  - Class B-3H; LT NRsf New Rating

TRANSACTION SUMMARY

This is Freddie Mac's seventh risk transfer transaction in which
the notes are not general, senior unsecured obligations of Freddie
Mac but instead are issued as a REMIC from a bankruptcy-remote
trust.

However, similar to prior transactions, the notes are still subject
to the credit and principal payment risk of a pool of certain
residential mortgage loans (the reference pool) held in various
Freddie Mac-guaranteed mortgage-backed securities (MBS). The switch
in transaction structure is to expand the investor base, align tax
treatment and better align the program with other mortgage-related
securities, as well as to reduce counterparty exposure to Freddie
Mac.

KEY RATING DRIVERS

Coronavirus Impact Addressed (Negative): The coronavirus outbreak
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 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 pandemic, an Economic Risk Factor (ERF, a default variable
in the U.S. RMBS loan-loss model) floor of 2.0 was applied to
'BBBsf' and below ratings.

COVID Forbearance Loans Removed (Neutral): Freddie Mac removed any
loan from the reference pool that was reported with a forbearance
indicator as of the May 31, 2020 cutoff date. Any loans that were
missed but otherwise reported as delinquent and in forbearance as
of May 31, 2020 to Freddie Mac in June 2020, which is expected to
be a small amount, will be removed from the pool in the first
distribution period as full prepayment without loss to investors.
The servicers are required to report to Freddie Mac any loans that
are in forbearance and delinquent.

COVID Relief Options (Neutral): COVID relief options offered to
mortgagors who have been affected by the COVID pandemic include
forbearance plans (in accordance with the Coronavirus Aid, Relief
and Economic Security [CARES] Act), payment deferrals and
modifications. Mortgagors who enter a forbearance plan will not be
required to make their monthly payment for up to 12 months. At the
end of the forbearance period, mortgagors who have the ability to
make their monthly payments will have the option to defer forborne
payments until the end of the mortgage loan. Payment deferrals will
not be considered a modification in this transaction and will not
result in write-downs to the reference tranches or the
corresponding class of notes. Mortgagors who are unable to make
their monthly payments at the end of the forbearance period will
likely be offered modification options that lower payments or keep
payments the same after the forbearance period. Ultimately, these
modification options may result in write-downs to the reference
tranches and the corresponding class of notes. Fitch believes the
credit enhancement provided in this transaction is sufficient to
cover any potential write-downs to the rated notes.

High-Quality Mortgage Pool (Positive): The reference pool consists
of 179,314 fixed-rate fully amortizing loans with terms of 360
months totaling $48.3 billion. The loans were acquired by Freddie
Mac between Jan. 1, 2015 and Dec. 31, 2019 and have original
loan-to-value (LTV) ratios between 60% and 80%. The borrowers in
this pool have strong credit profiles (755 FICO) and relatively low
leverage (80.5% sLTV).

Geographic Concentration (Neutral): Approximately 20% of the pool
is concentrated in California with relatively low MSA
concentration. The largest MSA concentration is in the Los Angeles
MSA (6.3%), followed by the New York MSA (4.8%) and the Chicago MSA
(3.0%). The top three MSAs account for 14.1% of the pool. As a
result, there was no adjustment for geographic concentration.

Very Low Operational Risk (Positive): Fitch considers this
transaction to have very low operational risk. Freddie Mac is an
industry leader in residential mortgage activities and is assessed
by Fitch as an 'Above Average' aggregator. The government-sponsored
enterprise maintains strong seller oversight and implements a
comprehensive risk management framework on its acquisition
processes. While multiple counterparties are performing primary
servicing functions for the loans in the reference pool, Freddie
Mac has robust servicer oversight to mitigate servicer disruption
risk.

Production Sample and Limited Size of Third-Party Due Diligence
(Neutral): Third-party due diligence was conducted on a sample of
the reference pool by Adfitech, Inc., which is assessed by Fitch as
an 'Acceptable — Tier 2' third-party review firm. The review was
performed on a sample of loans selected from a population of loans
that were subject to Freddie Mac's post-purchase quality control
review. Freddie Mac recently transitioned to a due diligence
process to review ongoing loan production, compared to previously
selecting loans to review per credit risk transfer issuance.

While the review does not cover 100% of loans in the pool, the
sampling methodology and review scope for the due diligence is
consistent with Fitch criteria and prior Freddie Mac-issued CRT
transactions. The due diligence results support Fitch's opinion of
Freddie Mac as an 'Above Average' aggregator. Fitch did not apply
loss adjustments based on the results.

Solid Alignment of Interests (Positive): While the transaction is
designed to transfer credit risk to private investors, Fitch
believes the transaction benefits from a solid alignment of
interests. Freddie Mac will retain credit risk in the transaction
by holding the senior reference tranche A-H, which has 4.00% of
loss protection, as well as a minimum of 5% of the M-1, M-2A, M-2B,
B-1A, B-1B, B-2A and B-2B reference tranches and 100% of the
first-loss B-3H reference tranche. Initially, Freddie Mac will
retain an approximate 39% vertical slice/interest through the M-1H,
M-2AH, M-2BH, B-1AH, B-1BH, B-2AH and B-2BH reference tranches.

REMIC Structure (Neutral): This is Freddie Mac's eighth credit risk
transfer transaction (and the fourth Fitch-rated) being issued as a
REMIC from a bankruptcy-remote trust. This limits the transaction's
dependency on Freddie Mac for payments of principal to the notes.
Under the current structure, Freddie Mac still acts as a final
backstop with regard to payments of interest on the notes and
potential investment losses of principal. As a result, ratings may
still be linked to Freddie Mac's corporate rating, but to a lesser
extent than in previous transactions where payment of both
principal and interest were direct obligations of Freddie Mac.

Receivership Risk Considered (Neutral): Under the Federal Housing
Finance Regulatory Reform Act, the Federal Housing Finance Agency
must place Freddie Mac into receivership if it determines that the
GSE's assets are less than its obligations for longer than 60 days
following the deadline of its SEC filing. As receiver, the FHFA
could repudiate any contract entered into by Freddie Mac if it is
determined that such action would promote an orderly administration
of the GSE's affairs. Fitch believes the U.S. government will
continue to support Freddie Mac, as reflected in its current rating
of the GSE. However, if at some point Fitch views the support as
being reduced and receivership as likely, the rating of Freddie Mac
could be downgraded, and the ratings on the M-1, M-2A and M-2B
notes, along with their corresponding MACR notes, could be
affected.

RATING SENSITIVITIES

Fitch's analysis 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
which may be considered in the surveillance of the transaction. Two
sets of sensitivity analyses were 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 positive
rating action/upgrade:

  -- The defined negative stress 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 MVD. The analysis indicates there is some
potential rating migration with higher MVDs, compared with the
model projection.

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

  -- The 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% and indicates potential positive rating migration for all 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 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-related disruptions on these economic inputs will
likely affect both investment-grade 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

Fitch was provided with due diligence information from Adfitech,
Inc. The due diligence focused on credit and compliance reviews,
desktop valuation reviews and data integrity. Adfitech examined
selected loan files with respect to the presence or absence of
relevant documents. Fitch received certification indicating that
the loan-level due diligence was conducted in accordance with
Fitch's published standards. The certification also stated that the
company performed its work in accordance with the independence
standards, per Fitch's criteria, and that the due diligence
analysts performing the review met Fitch's criteria of minimum
years of experience. Fitch considered this information in its
analysis, and the findings did not have an impact on the analysis.

While Fitch was provided with due diligence from a third party,
Form 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

STACR 2020-DNA3: Customer Welfare - Fair Messaging, Privacy & Data
Security: 4, Human Rights, Community Relations, Access &
Affordability: 4

STACR 2020-DNA3 has an ESG Relevance Score of '4' for customer
welfare — fair messaging and privacy and data security, as STACR
is a GSE program focused on customer welfare and fair messaging
while driving strong performance, contributing to reduced expected
losses in the rating analysis. This transaction also has an ESG
Relevance Score of '4' for human rights, community relations, and
access and affordability, as STACR is a GSE program that addresses
access and affordability while driving strong performance,
contributing to reduced expected losses in the rating analysis.

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(ies),
either due to their nature or the way in which they are being
managed by the entity(ies).


FREDDIE MAC 2020-DNA3: S&P Rates Class B-1B Notes 'B (sf)'
----------------------------------------------------------
S&P Global Ratings assigned its ratings to Freddie Mac STACR REMIC
Trust 2020-DNA3's notes.

The note issuance is an RMBS securitization backed by fully
amortizing first-lien fixed-rate residential mortgage loans secured
by one- to four-family residences, planned-unit developments,
condominiums, cooperatives, and manufactured housing to prime
borrowers.

The ratings reflect:

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

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

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

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

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

-- The impact that COVID-19 is likely to have on the U.S. economy
and the U.S. housing market, and the additional structural
provisions included to address corresponding forbearance and
subsequent defaults.  S&P Global Ratings acknowledges a high degree
of uncertainty about the evolution of the coronavirus pandemic. The
consensus among health experts is that the pandemic may now be at,
or near, its peak in some regions but will remain a threat until a
vaccine or effective treatment is widely available, which may not
occur until the second half of 2021. S&P is using this assumption
in assessing the economic and credit implications associated with
the pandemic. As the situation evolves, the rating agency will
update its assumptions and estimates accordingly.

Please note that while the offered bond sizes have increased since
assigning preliminary ratings, the available credit enhancement for
each class has remained unchanged and, therefore, S&P's ratings
remain the same.

  RATINGS ASSIGNED
  Freddie Mac STACR REMIC Trust 2020-DNA3

  Class       Rating                Amount ($)
  A-H(i)      NR             46,395,132,712.00
  M-1         A- (sf)           336,000,000.00
  M-1H(i)     NR                147,282,632.00
  M-2         BBB- (sf)         420,000,000.00
  M-2R        BBB- (sf)         420,000,000.00
  M-2S        BBB- (sf)         420,000,000.00
  M-2T        BBB- (sf)         420,000,000.00
  M-2U        BBB- (sf)         420,000,000.00
  M-2I        BBB- (sf)         420,000,000.00
  M-2A        BBB+ (sf)         210,000,000.00
  M-2AR       BBB+ (sf)         210,000,000.00
  M-2AS       BBB+ (sf)         210,000,000.00
  M-2AT       BBB+ (sf)         210,000,000.00
  M-2AU       BBB+ (sf)         210,000,000.00
  M-2AI       BBB+ (sf)         210,000,000.00
  M-2AH(i)    NR                 92,051,645.00
  M-2B        BBB- (sf)         210,000,000.00
  M-2BR       BBB- (sf)         210,000,000.00
  M-2BS       BBB- (sf)         210,000,000.00
  M-2BT       BBB- (sf)         210,000,000.00
  M-2BU       BBB- (sf)         210,000,000.00
  M-2BI       BBB- (sf)         210,000,000.00
  M-2RB       BBB- (sf)         210,000,000.00
  M-2SB       BBB- (sf)         210,000,000.00
  M-2TB       BBB- (sf)         210,000,000.00
  M-2UB       BBB- (sf)         210,000,000.00
  M-2BH(i)    NR                 92,051,645.00
  B-1         B (sf)            250,000,000.00
  B-1A        BB (sf)           125,000,000.00
  B-1AR       BB (sf)           125,000,000.00
  B-1AI       BB (sf)           125,000,000.00
  B-1AH(i)    NR                116,641,317.00
  B-1B        B (sf)            125,000,000.00
  B-1BH(i)    NR                116,641,317.00
  B-2         NR                100,000,000.00
  B-2A        NR                 50,000,000.00
  B-2AR       NR                 50,000,000.00
  B-2AI       NR                 50,000,000.00
  B-2AH(i)    NR                 70,820,658.00
  B-2B        NR                 50,000,000.00
  B-2BH(i)    NR                 70,820,658.00
  B-3H(i)     NR                120,820,657.00

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


FREDDIE MAC SCRT 2020-2: Fitch to Rate Class M Debt 'B-(EXP)'
-------------------------------------------------------------
Fitch Ratings expects to rate Freddie Mac's risk-transfer
transaction, Seasoned Credit Risk Transfer Trust Series 2020-2.

Seasoned Credit Risk Transfer Trust 2020-2

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

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

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

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

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

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

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

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

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

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

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

  - Class M55D; LT NR(EXP)sf Expected Rating

  - Class M55E; LT NR(EXP)sf Expected Rating

  - Class M55G; LT NR(EXP)sf Expected Rating

  - Class M55H; LT NR(EXP)sf Expected Rating

  - Class M55I; LT NR(EXP)sf Expected Rating

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

TRANSACTION SUMMARY

The certificates are supported by three collateral groups that
comprise 9,702 seasoned performing and re-performing mortgages,
with a total balance of approximately $1.57 billion, of which
$168.0 million, or 10.7% are in non-interest-bearing deferred
principal amounts as of the cutoff date.

The three collateral groups are distinguished between loans that
either have additional interest rate changes outstanding due to the
terms of the modification or have not yet made a payment at the
final step-rate (Group H loans) and those expected to remain fixed
for the remainder of the term.

Among the fixed-rate loans, the groups are further distinguished by
loans that have no principal forbearance amounts and an interest
rate above 5.50% (Group M55 loans) and loans with either principal
forbearance amounts or no forbearance amounts and an interest rate
below 5.50% (Group M loans). Distributions of principal and
interest (P&I) and loss allocations to the rated classes are based
on a senior-subordinate, sequential structure.

KEY RATING DRIVERS

Revised GDP Due to Coronavirus (Negative): Coronavirus and the
resulting containment efforts have resulted in revisions to Fitch's
GDP estimates for 2020. The agency'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 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.

Distressed Performance History (Negative): The collateral pool
comprises primarily peak-vintage re-performing loans, the majority
of which have been modified. Roughly 33.8% of the pool has been
paying on time for the past 24 months, per the Mortgage Bankers
Association methodology, and 15.3% of the loans experienced a
delinquency within the past 12 months. The pool has a weighted
average sustainable loan-to-value ratio of 79.1%, and the WA model
FICO score is 664.

Expected Payment Forbearance and 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. Mortgage payment forbearance or deferrals will
provide immediate relief to affected borrowers, and Fitch expects
servicers to broadly adopt this practice. The missed payments will
result in interest shortfalls that will likely be recovered, the
timing of which will depend on repayment terms; if interest is
added to the underlying balance as a non-interest bearing amount,
repayment will occur at refinancing, property liquidation or loan
maturity.

To account for the potential for cash flow disruptions, Fitch
assumed delinquent 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. The 40% assumption is based on observed peak
delinquencies for legacy Alt-A collateral.

Low Operational Risk (Positive): Operational risk is well
controlled for this transaction. Freddie Mac has an established
track record in residential mortgage activities and is assessed as
an 'Above Average' aggregator by Fitch. Select Portfolio Servicing
Inc. is the named servicer for this transaction and is rated
'RPS1-' and 'RSS1-' by Fitch for primary and special servicing
functions. The benefit of the highly rated servicer decreased
Fitch's loss expectations by 99 bps at the 'Bsf' rating category.

Interest Payment Risk (Negative): In Fitch's timing scenarios, the
M class incurs temporary shortfalls in the 'B-sf' rating category
but is ultimately repaid prior to maturity of the transaction. The
difference between Fitch's expected loss and the credit enhancement
on the rated classes is due to the repayment of interest deferrals.
Interest to the rated class is subordinated to the senior bonds and
repayments made to Freddie Mac for prior payments on the senior
classes. Timely payments of interest are also at potential risk as
principal collections on the underlying loans can only be used to
repay interest shortfalls on the rated classes after the balance of
the senior classes is paid off. This results in an extended period
until potential shortfalls are ultimately repaid in Fitch's stress
scenarios.

Representation and Warranty Framework (Negative): Fitch considers
the representation, warranty and enforcement mechanism construct
for this transaction as weaker than that of other Fitch-rated RPL
deals. The weakness is due to the exclusion of a number of reps
Fitch views as consistent with a full framework and the limited
diligence that may have otherwise acted as a mitigant.
Additionally, Freddie Mac as rep provider will only be obligated to
repurchase a loan, pay an indemnity loss amount or cure the
material breach prior to July 13, 2023. However, Fitch believes
that the defect risk is lower relative to other RPL transactions
because the loans were subject to Freddie Mac's loan-level review
process in place at the time the loan became delinquent. Therefore,
Fitch treated the construct as Tier 3 and increased its 'B-sf'
expected loss expectations by 26bps to account for the weaknesses
in the reps.

Sequential-Pay Structure (Positive): Once the initial CE of the
senior bonds has reached the target amount and if all performance
triggers are passing, principal is allocated pro rata among the
senior and subordinate classes with the most senior-subordinate
bond receiving the full subordinate share.

This structure is a positive to the rated class as it results in a
faster paydown and allows them to receive principal earlier than
under a fully sequential structure. However, to the extent any of
the performance triggers are failing, principal is distributed
sequentially to the senior classes until triggers pass or the
senior classes are paid in full.

No Servicer P&I Advances (Mixed): The servicer will not advance
delinquent monthly payments of P&I, which reduces liquidity to the
trust. However, as reimbursement of 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 transactions where the
servicer is obligated to advance P&I. Structural provisions and
cash flow priorities, together with increased subordination,
provide for ultimate payment of interest to the rated class.

Third-Party Due Diligence Review (Negative): Third-party due
diligence was performed on a statistically random sample of
approximately 12% of the initial loan population for this
transaction. The review was performed by Clayton Services LLC,
which is assessed by Fitch as 'Acceptable - Tier 1'. Approximately
33% of the loan sample were found to have material regulatory
compliance exceptions and received a final due diligence grade of
'C' or 'D'. The exceptions were primarily due to missing final
HUD-1 files that inhibited the TPR from properly testing for
predatory lending and missing mortgage insurance certificate. Fitch
adjusted its 'B-sf' loss expectations by less than 10 bps to
account for loans in the transaction with missing final HUD-1;
however, it is expected that most of these loans would not be in
violation if testing can be completed.

ESG Factors (Neutral): This transaction has an ESG Relevance Score
of 4 for human rights, community relations and access and
affordability, as SCRT is a GSE program that addresses access and
affordability while driving strong performance, contributing to
reduced expected losses in the rating analysis. This transaction
also has an ESG Relevance Score of 4 for customer welfare — fair
messaging and privacy and data security, as SCRT is a GSE program
focused on customer welfare and fair messaging while driving strong
performance, contributing to reduced expected losses in the rating
analysis.

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 13.6% at 'B-'. 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 rated '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.

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.

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

A third-party compliance due diligence review was completed on
approximately 12% of the initial loan population for this
transaction. Freddie Mac removed loans from the initial population
following the results of the review due to various reasons. The due
diligence scope is similar to prior RPL transactions issued by
Freddie Mac and included a review of regulatory compliance, pay
history, data integrity, tax and title search, and updated property
values.

The regulatory compliance review covered applicable federal, state
and local high cost and/or anti-predatory laws. Approximately 33%
of loans that were selected for review received a compliance grade
of 'C' or 'D', which is above the prior SCRT 2020-1 transaction but
in line with SCRT 2019-4 rated by Fitch. Although the review was
performed through a random sampling methodology, Fitch did not
extrapolate the due diligence results to the remainder of the pool
since the proposed rating for this transaction is non-investment
grade at 'B-sf'.

151 loans were identified as missing a final HUD-1 or using an
estimated HUD-1 as part of the loan file that prevented the TPR
firm from properly testing for predatory lending. Of the 151 loans,
only 39 loans remained in the collateral pool. The inability to
test for predatory lending may expose the trust to potential
assignee liability, which can increase risk for bond investors.
Fitch applied adjustments on these loans where missing or
alternative documentation inhibited the TPR from testing for high
cost loans. The total adjustment to Fitch's loss expectation at the
'B-sf' is less than 10 bps to reflect increased risk.

Seventeen loans were identified as being high-cost and 1 loan with
a TRID error that was not corrected within the cure period. All
these loans were not in the final pool.

Form 15E was provided to or reviewed by Fitch in relation to this
rating action, from the due diligence firm AMC.

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

Seasoned Credit Risk Transfer Trust 2020-2: Customer Welfare - Fair
Messaging, Privacy & Data Security: 4, Human Rights, Community
Relations, Access & Affordability: 4

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.


GS MORTGAGE 2013-GCJ14: Moody's Lowers Class F Certs to B2
----------------------------------------------------------
Moody's Investors Service affirmed the ratings on seven classes,
confirmed the ratings on two classes and downgraded the ratings on
four classes in GS Mortgage Securities Trust 2013-GCJ14, Commercial
Mortgage Pass-Through Certificates, Series 2013-GCJ14 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Jul 29, 2019 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Jul 29, 2019 Affirmed Aaa
(sf)

Cl. A-5, Affirmed Aaa (sf); previously on Jul 29, 2019 Affirmed Aaa
(sf)

Cl. A-AB, Affirmed Aaa (sf); previously on Jul 29, 2019 Affirmed
Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on Jul 29, 2019 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa2 (sf); previously on Jul 29, 2019 Upgraded to
Aa2 (sf)

Cl. C, Confirmed at A2 (sf); previously on Apr 17, 2020 A2 (sf)
Placed Under Review for Possible Downgrade

Cl. D, Downgraded to Ba1 (sf); previously on Apr 17, 2020 Baa3 (sf)
Placed Under Review for Possible Downgrade

Cl. E, Downgraded to B1 (sf); previously on Apr 17, 2020 Ba2 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Downgraded to B2 (sf); previously on Apr 17, 2020 Ba3 (sf)
Placed Under Review for Possible Downgrade

Cl. G, Downgraded to Caa2 (sf); previously on Apr 17, 2020 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. PEZ**, Confirmed at Aa3 (sf); previously on Apr 17, 2020 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. X-A*, Affirmed Aaa (sf); previously on Jul 29, 2019 Affirmed
Aaa (sf)

*Reflects Interest-Only Class

**Reflects Exchangeable Class

RATINGS RATIONALE

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

The ratings on four P&I classes were downgraded due to a decline in
pool performance and higher anticipated losses from specially
serviced and troubled loans. The specially serviced and troubled
loans, (6.8 % of the pool) are all secured by retail properties
that were already experiencing declines in performance prior to the
coronavirus impact. Furthermore, the third largest loan in the
pool, W Chicago -- City Center (7.6% of the pool), has seen a
consistent decline in performance over the last five years.

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

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

The actions conclude the review for downgrade initiated on April
17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 6.3% of the
current pooled balance, compared to 3.3% at Moody's last review.
Moody's base expected loss plus realized losses is now 5.1% of the
original pooled balance, compared to 2.8% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except exchangeable
classes and interest-only classes were "Approach to Rating US and
Canadian Conduit/Fusion CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 12, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 18.8% to $1.0
billion from $1.2 billion at securitization. The certificates are
collateralized by 73 mortgage loans ranging in size from less than
1% to 14.9% of the pool, with the top ten loans (excluding
defeasance) constituting 52.1% of the pool. Twelve loans,
constituting 12.0% of the pool, have defeased and are secured by US
government securities.

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

As of the June 2020 remittance report, loans representing 87% were
current or within their grace period on their debt service
payments, 1% were beyond their grace period but less than 30 days
delinquent, 5% were between 30 -- 59 days delinquent, and 1% were
delinquent for 60 days or more.

Eighteen loans, constituting 28.4% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

One loan resulting in a minimal realized loss, has been liquidated
from the pool. One loan, constituting 1.3% of the pool, is
currently in special servicing. The largest specially serviced loan
is the Indiana Mall loan ($13.3 million -- 1.3% of the pool), which
is secured by an approximately 457,000 square feet (SF) regional
mall located in Indiana, Pennsylvania. Prior anchors included
Sears, Kmart, and Bon-Ton. The property is currently anchored by
J.C. Penney (14% of net rentable area (NRA) with an upcoming lease
expiration in November 2020. The second largest tenant, Kohl's,
backfilled a portion of the prior Sears space with lease start date
in October 2019 and accounts for 9% of NRA. The next largest
tenants, Harbor Freight Tools and Sobex Fitness LLC, signed leases
at the property in 2018 and 2019, respectively, and account for a
combined 7% of NRA. The mall reopened on June 5, 2020 with some
retailers expected to open later in the month, after temporary
closures due to the coronavirus outbreak. As of September 2019, the
property was 43% occupied compared to 35% in December 2018.

Moody's has also assumed a high default probability for five poorly
performing loans, constituting 5.4% of the pool, and has estimated
an aggregate loss of $24.0 million (a 35% expected loss on average)
from these specially serviced and troubled loans. The largest
troubled loan, Willow Knolls Court ($21.9 million -- 2.2% of the
pool), is secured by an approximately 273,000 SF retail property
located in Peoria, Illinois. The loan has been on the watchlist in
June 2019 due to Burlington Coat Factory (26% of gross leasable
area (GLA)) vacating at lease expiration in March 2019. As of
January 2020, the property was 73% occupied and the net cash flow
(NCF) DSCR has decreased to 0.85X in 2019 from 1.31X in 2018. The
second largest troubled loan, Cobblestone Court ($19.1 million --
1.9% of the pool), is secured by an approximately 265,000 SF retail
property located in Victor, New York. The loan has been on the
watchlist since November 2017 due to the largest tenant, Kmart (45%
of GLA), vacating prior to its 2019 lease expiration. A 10-year
lease commencing in May 2021 with a major craft store has been
approved by the servicer that would backfill nearly half of the
Kmart vacancy. The borrower has confirmed the current largest
tenant at the property, Dick's Sporting Goods (19% of GLA), with a
lease expiration in January 2022, is expected to vacate to another
location but intends to honor their existing lease. The remaining
troubled loans each account for less than 1.0% of the pool and are
secured retail properties located in Illinois, Wisconsin, and
Florida.

Moody's received full year 2019 operating results for 100% of the
pool, and partial year 2020 operating results for 37% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 102%, compared to 97% at Moody's last
review. Moody's conduit component excludes loans with structured
credit assessments, defeased and CTL loans, and specially serviced
and troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 19% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 10.0%.

Moody's actual and stressed conduit DSCRs are 1.52X and 1.08X,
respectively, compared to 1.58X and 1.13X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 32% of the pool balance. The
largest loan is the 11 West 42nd Street Loan ($150.0 million --
14.9% of the pool), which represents a pari-passu portion of a
$300.0 million mortgage loan. The loan is secured by a 33-story
office building located in the Grand Central submarket of
Manhattan, New York. The largest tenant, Michael Kors, has more
than doubled its presence at the property since securitization and
accounts for 28% of NRA with a lease expiration in March 2025. The
second largest tenant, CIT Group (22% of NRA), renewed the majority
of its space through May 2034. The non-renewed portion accounts for
6% of NRA with a lease expiration in October 2021. As of March
2020, the property was 93% occupied compared to 90% in March 2019
and 91% in December 2017. The loan is interest-only through its
entire term and the loan is current through its June 2020 payment.
Moody's LTV and stressed DSCR are 97% and 0.95X, respectively, the
same as the last review.

The second largest loan is the ELS Portfolio Loan ($97.3 million --
9.6% of the pool), which is secured by twelve manufactured housing
and RV sites totaling 5,849 pads. The properties are located across
four states (Florida, Texas, Maine, and Arizona) with the highest
concentration in Florida (57% of pads). Subsequent to an April 2018
modification, one property with 424 pads was released and two
properties with combined pads of 619 were added to the portfolio.
As of December 2019, the portfolio was 91% occupied compared to 85%
in March 2019. The loan has amortized 11.5% since securitization n
and the loan is current through its June 2020 payment. Moody's LTV
and stressed DSCR are 87% and 1.25X, respectively, compared to 89%
and 1.22X at the last review.

The third largest loan is the W Chicago -- City Center Loan ($76.9
million -- 7.6% of the pool), which is secured by a 403-room,
full-service, luxury hotel located in the Loop of Chicago,
Illinois. The property underwent renovation from December 2017 to
April 2018 which impacted the 2018 financials. As of December 2019,
the hotel was 72% occupied with a revenue per available room
(RevPar) of $182, compared to an occupancy of 72% and RevPar of
$183 in 2018. Property performance has steadily deteriorated since
2015 with the 2019 NOI declining approximately 40% since
securitization as a result of decreased revenue. The loan has been
on the watchlist since February 2019 for the decrease in DSCR. The
loan has amortized 17.4% since securitization and the loan is
current through its June 2020 payment. Moody's LTV and stressed
DSCR are 127% and 0.94X, respectively, compared to 103% and 1.11X
at the last review.


GS MORTGAGE 2015-GC34: Fitch Cuts Class F Certs to 'CCCsf'
----------------------------------------------------------
Fitch Ratings has downgraded two and affirmed 12 classes of GS
Mortgage Securities Trust, commercial mortgage pass-through
certificates, series 2015-GC34.

GSMS 2015-GC34

  - Class A-2 36250VAB8; LT AAAsf; Affirmed  

  - Class A-3 36250VAC6; LT AAAsf; Affirmed  

  - Class A-4 36250VAD4; LT AAAsf; Affirmed  

  - Class A-AB 36250VAE2; LT AAAsf; Affirmed  

  - Class A-S 36250VAH5; LT AAAsf; Affirmed  

  - Class B 36250VAJ1; LT AA-sf; Affirmed  

  - Class C 36250VAL6; LT A-sf; Affirmed  

  - Class D 36250VAM4; LT BBB-sf; Affirmed  

  - Class E 36250VAP7; LT Bsf; Downgrade  

  - Class F 36250VAR3; LT CCCsf; Downgrade  

  - Class PEZ 36250VAK8; LT A-sf; Affirmed  

  - Class X-A 36250VAF9; LT AAAsf; Affirmed  

  - Class X-B 36250VAG7; LT AA-sf; Affirmed  

  - Class X-D 36250VAN2; LT BBB-sf; Affirmed  

KEY RATING DRIVERS

Increased Loss Expectations; High Concentration of Fitch Loans of
Concern: The downgrades and Negative Outlook revisions reflect an
increase in Fitch's loss expectations, primarily due to continued
performance deterioration on a greater number of Fitch Loans of
Concern and the slowdown in economic activity related to the
coronavirus. Fitch has designated 13 loans (40.3% of pool) as
FLOCs, which includes three loans (6%) that have transferred to
special servicing over the past year. The largest contributors to
the overall loss expectations are the Parkside at So7 (6.8% of
pool), 750 Lexington Avenue (10.6%) and Bluejay Grocery Portfolio
(3.3%) loans; the average NOI for these loans declined 4.3% between
2018 and 2019.

Fitch Loans of Concern: The largest FLOC, 750 Lexington Avenue
(10.6% of pool), is secured by a 382,256 sf Class A office and
retail property located in Manhattan's Plaza District that has
experienced significant cash flow declines since issuance and has
exposure to WeWork as the largest tenant. The loan has been on the
master servicer's watchlist since October 2016 due to declining
occupancy and debt service coverage ratio following the departure
of the largest tenant, Locke Lord (33.3% of NRA), at its June 2016
lease expiration. Cash flow has also been negatively affected by
the substantial increases to the real estate tax and ground rent
expenses. The ground rent expense increased to $5.8 million in 2018
from $4.2 million in 2017, as part of a scheduled rent reset, and
will further increase in 2024 at a fixed 10% rate. TTM September
2019 NOI was 76% below the issuer's underwritten NOI. The
servicer-reported TTM September 2019 NOI DSCR was 0.51x, compared
with 0.43x at YE 2018 and 1.07x at YE 2017. This partial
interest-only loan will start amortizing in November 2020.

Although a significant portion of the former Locke Lord space was
re-leased to WeWork (23% of NRA) starting in March 2018, property
occupancy continued to fluctuate. Occupancy declined to 82% as of
July 2019 from 89% in June 2018 after several tenants vacated at
their scheduled lease expirations between August 2018 and April
2019, which was partially offset by new leasing activity with
smaller tenants and the expansion of an existing tenant.

The WeWork lease includes two portions, both at below-market rents
and expiring in March 2035, with the tenant receiving a total of 32
months of free rent spread over its lease term. The first portion
of the lease (82,500 sf; 23% of NRA) commenced in March 2018, which
helped to drive occupancy up to 89.2% in June 2018 from 66% in June
2017. The second portion of the lease, which includes an additional
30,775 sf (8.6% of NRA) on the 10th and 11th floors, was expected
to commence in February 2020. According to servicer updates as of
mid-June 2020, the borrower is in the process of delivering the
space after demolition was halted as a result of coronavirus
restrictions. Upon commencement of the second portion of the lease,
WeWork will occupy a total of 113,275 sf (31.6% of NRA) at the
property and property occupancy would improve to 87%. Fitch remains
concerned with future property performance given the high coworking
tenant exposure due to the impact of the coronavirus pandemic.

The second largest FLOC, the Hammons Hotel Portfolio (8.4%), became
60 days delinquent in June 2020. The loan is secured by the fee and
leasehold interests in seven hotels totaling 1,869 keys under the
Marriott or Hilton flags located across seven states. The borrower
notified the master servicer of coronavirus-related hardships. The
servicer-reported NOI DSCR was 2.03x for the TTM March 2020 period,
compared with 2.09x at YE 2019 and 2.13x at YE 2018. The loan
previously spent nearly two years in special servicing due to
borrower bankruptcy before being returned to the master servicer in
July 2019.

The next largest FLOC, Parkside at So7 (6.8%), is secured by a
Class A apartment complex with 65,411 sf of office and retail space
located approximately 1.5 miles from the Fort Worth, TX CBD. The
loan was flagged due to significant recent cash flow declines from
lower occupancy and rental income, as well as higher operating
expenses. YE 2019 NOI was down 21% from YE 2018 and nearly 33% from
the issuer's underwritten NOI. Overall property occupancy fell to
91.8% as of March 2020 from 94.6% in December 2018. The vacancy of
the commercial component of the property remains high at 28.4% as
of March 2020, up from 24.9% at issuance. Average in-place rents
for the multifamily component of the property have also declined by
approximately 5% to $1,602 per unit as of the March 2020 rent roll
from $1,680 per unit at issuance. Overall property operating
expenses increased by 12% between 2018 and 2019, largely due to
repairs and maintenance, real estate tax, utilities and payroll and
benefits. The servicer-reported YE 2019 NOI DSCR was 1.19x, down
from 1.50x at YE 2018. The partial interest-only loan begins
amortizing in November 2020.

The next largest FLOC, Bluejay Grocery Portfolio (3.3%), is secured
by a portfolio of four single-tenant grocery stores located in
secondary and tertiary markets across WI, IN and NY. Two of the
grocery stores (Copps Madison in Madison, WI and Marsh Kokomo in
Kokomo, IN) closed in 2017, which reduced the physical portfolio
occupancy to 56.1% as of December 2019 from 100% at issuance. The
Copps Madison store remains dark. New leases have been signed with
Family Dollar and Fieldhouse Gym (combined, 17,200 sf; started in
February and October 2019, respectively) for portions of the former
Marsh Kokomo store; the remainder of the Marsh Kokomo space is
vacant. The Tops Lockport store received a rent reduction due to
the grocer's parent company Chapter 11 bankruptcy filing in early
2018. Portfolio-level YE 2019 NOI was flat from YE 2018, although
NOI had already declined significantly in 2018 due to the closure
of the Marsh Kokomo store and the rent reduction for Tops.

The six non-specially serviced FLOCs outside of the top 15 (5.2%)
include a portfolio of three Hyatt-flagged hotel properties in
Austin, San Antonio and Dallas, TX (Hyatt Place Texas Portfolio;
1.6%), which suffered performance declines following the completion
of property renovations in early 2017; a multifamily property in
Southfield, MI (Carnegie Park; 1.5%) where performance was
negatively affected after fire damage to 40 of the 176 units in
February 2017; and four other loans (2.2%) that have reported
declines in occupancy and/or cash flow.

Specially Serviced Loans: The specially serviced loans (6% of pool)
include two of the top 15 loans (4.6%). The ninth largest loan in
the pool, Woodlands Corporate Center and 7049 Williams Road
Portfolio (2.8%), was transferred to special servicing in December
2019 for imminent default. The loan is secured by a portfolio of
eight office/flex properties located in Suburban Buffalo, NY, which
has experienced continued cash flow declines since issuance. The
portfolio's largest tenant, Silipos (16.6% of total portfolio NRA,
leased through April 2028), received a nearly 47% rent reduction as
part of its recent 10-year lease renewal. Portfolio occupancy was
86.3% as of April 2020, up from 80.7% in April 2019 and 76.6% in
March 2018. According to the special servicer, the borrower
expressed they are no longer able to come out of pocket to cover
both debt service and operating expense payments, and previously
submitted a loan modification proposal which was rejected by the
lender. The lender has engaged counsel and will continue
discussions with the borrower regarding a potential resolution.
Prior to its transfer, the loan had been on the servicer's
watchlist since April 2016 for low DSCR and the occurrence of a
servicing trigger event.

The Church Lane Shopping Center loan (1.8%) is secured by a 95,742
sf anchored retail center located in Cockeysville, MD. The loan was
transferred to special servicing in May 2020 for imminent default
due to the coronavirus, but remains current as of the June 2020
distribution date. The property is anchored by Tuesday Morning,
Jo-Ann Fabrics and Party City; the Tuesday Morning location is not
on any of the retailer's recent store closing lists. The
servicer-reported YE 2019 NOI DSCR was 1.45x, compared with 1.82x
at YE 2018; the partial interest-only loan began amortizing in
October 2018.

The LA Fitness Powell loan (1.4%) is secured by a 53,206-sf single
tenant retail property fully leased to LA Fitness through December
2027 and located in Powell, OH. The loan was transferred to special
servicing in May 2020 for imminent default due to the sole tenant's
failure to pay rent, and the loan became 60 days delinquent in June
2020. The LA Fitness location was closed for approximately two and
a half months due to coronavirus restrictions and reopened on June
1. The servicer-reported YE 2019 NOI DSCR was 1.63x, compared with
1.65x at YE 2018.

Slight Improvement in Credit Enhancement: As of the June 2020
distribution date, the pool's aggregate principal balance has paid
down by 5.8% to $799.3 million from $848.4 million at issuance. The
transaction is expected to pay down by 11.9% based on scheduled
loan maturity balances. Two loans (1.3% of pool) have been
defeased. Since the last rating action, two loans ($21.3 million)
were repaid prior to their scheduled 2020 and 2025 maturity dates,
including one former FLOC (Regalia Mansfield/Dolce; $16.8 million).
Three loans (9%) are full-term interest-only and six loans (35.1%)
still have a partial interest-only component during their remaining
loan term, compared with 62.5% of the original pool at issuance.

Coronavirus Exposure: Loans secured by retail, hotel and
multifamily properties represent 23.5% (17 loans), 13.3% (four
loans) and 10.6% (10 loans) of the pool, respectively. The
multifamily exposure includes one loan (The Heights at State
College Phase III; 3%) secured by a student housing property and
one loan (Villas at Waters Edge; 1.3%) secured by a senior housing
property. The retail loans have a weighted average NOI DSCR of
1.67x and can withstand an average 39.9% decline to NOI before DSCR
falls below 1.00x. The hotel loans have a WA NOI DSCR of 2.13x and
can withstand an average 53.1% decline to NOI before DSCR falls
below 1.00x. The multifamily loans have a WA NOI DSCR of 1.71x and
can withstand an average 41.5% decline to NOI before DSCR falls
below 1.00x.

Fitch applied additional coronavirus-related stresses on seven
retail loans (6.1%), three hotel loans (11.2%) and three
multifamily loans (5%). These additional stresses contributed to
the downgrades of classes E and F and the Negative Rating Outlooks
on classes A-S through E, PEZ, X-A, X-B and X-D.

Upcoming Loan Maturities: Two loans (Hyatt Place Texas Portfolio
and LA Fitness Powell; combined 3% of pool) are scheduled to mature
in October 2020; however, both of these loans are FLOCs, with the
LA Fitness Powell loan being in special servicing, therefore a
payoff at maturity is not expected. The remainder of the pool (53
loans; 97%) is scheduled to mature in 2025.

RATING SENSITIVITIES

The Stable Rating Outlooks on classes A-2 through A-AB reflect the
overall stable performance of the majority of the pool and expected
continued amortization, as well as the substantial credit
enhancement to the classes and senior position in the capital
stack. The Negative Rating Outlooks on classes A-S through E, PEZ,
X-A, X-B and X-D reflect the potential for downgrade due to
concerns surrounding the ultimate impact of the coronavirus
pandemic and the performance concerns associated with the FLOCs,
which include three specially serviced loans.

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

Sensitivity factors that could lead to upgrades would include
stable to improved asset performance, particularly on the FLOCs,
coupled with additional paydown and/or defeasance. Upgrades to the
'A-sf' and 'AA-sf' rated classes are not expected but would likely
occur with significant improvement in CE and/or defeasance and/or
the stabilization to the properties impacted from the coronavirus
pandemic. Upgrades of the 'BBB-sf' and 'BB-sf' 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
of interest shortfalls. The 'Bsf' and distressed classes are
unlikely to be upgraded absent significant performance improvement
on the FLOCs and substantially higher recoveries than expected on
the specially serviced loans/assets.

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/assets. Downgrades to the senior 'AAAsf' rated classes are
not likely due to the position in the capital structure, but may
occur should interest shortfalls impact these classes. A downgrade
of one category to the junior 'AAAsf' rated class (class A-S) is
possible should expected losses for the pool increase significantly
and/or should all of the loans susceptible to the coronavirus
pandemic suffer losses. Downgrades to the 'AA-sf', 'A-sf' and
'BBB-sf' rated classes are possible should performance of the FLOCs
continue to decline, should additionally loans transfer to special
servicing and/or should loans susceptible to the coronavirus
pandemic not stabilize. Downgrades to the 'Bsf' rated class would
occur should loss expectations increase due to a continued decline
in the performance of the FLOCs, an increase in specially serviced
loan or the disposition of a specially serviced loan at a high
loss. The Negative Rating Outlooks on classes A-S through E, PEZ,
X-A, X-B and X-D may be revised back to Stable if performance of
the FLOCs improves and/or properties vulnerable to the coronavirus
pandemic eventually stabilize. The 'CCCsf' rated class could be
further downgraded should losses become more certain or be
realized.

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.

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 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).


HOMEWARD 2020-2: S&P Assigns Prelim B (sf) Rating to Cl. B-2 Certs
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Homeward
Opportunities Fund Trust 2020-2's mortgage pass-through
certificates.

The certificate issuance is an RMBS securitization backed by
first-lien, fixed- and adjustable-rate, fully amortizing
residential mortgage loans (some with interest-only periods) to
prime and non-prime borrowers, generally secured by single-family
residential properties, planned-unit developments, condominiums,
two- to four- family residential properties, five- to eight-unit
multifamily residential properties and mixed-use properties. The
loans are mainly nonqualified or exempt mortgage loans.

The preliminary ratings are based on information as of the term
sheet dated July 1, 2020. Subsequent information may result in the
assignment of final ratings that differ from the preliminary
ratings.

The preliminary ratings reflect S&P's view of:

-- The pool's collateral composition;

-- The transaction's credit enhancement;

-- The transaction's associated structural mechanics;

-- The transaction's representation and warranty (R&W) framework;

-- The transaction's geographic concentration;

-- The mortgage aggregator, Neuberger Berman Investment Advisors
LLC (Neuberger Berman); and

-- The impact that the economic stress brought on by the COVID-19
pandemic is likely to have on the performance of the mortgage
borrowers in the pool and liquidity available in the transaction.

S&P Global Ratings acknowledges a high degree of uncertainty about
the evolution of the coronavirus pandemic. The consensus among
health experts is that the pandemic may now be at, or near, its
peak in some regions but will remain a threat until a vaccine or
effective treatment is widely available, which may not occur until
the second half of 2021. S&P is using this assumption in assessing
the economic and credit implications associated with the pandemic.
As the situation evolves, S&P will update its assumptions and
estimates accordingly.

  PRELIMINARY RATINGS ASSIGNED
  Homeward Opportunities Fund Trust 2020-2

  Class       Rating(i)               Amount ($)
  A-1         AAA (sf)               372,559,000
  A-2         AA (sf)                 48,947,000
  A-3         A (sf)                  61,418,000
  M-1         BBB (sf)                34,917,000
  B-1         BB (sf)                 36,789,000
  B-2         B (sf)                  28,994,000
  B-3         NR                      39,906,281
  A-IO-S      NR                        Notional(ii)
  X           NR                        Notional(ii)
  R           NR                             N/A

(i)The preliminary ratings address the ultimate payment of interest
and principal. They do not address payment of the cap carryover
amounts.
(ii)The notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period.
NR--Not rated.
N/A--Not applicable.


JP MORGAN 2012-LC9: Moody's Lowers Rating on Class G Debt to Caa2
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on nine classes and
downgraded the ratings on three classes in J.P. Morgan Chase
Commercial Mortgage Securities Trust 2012-LC9 as follows:

Cl. A-5, Affirmed Aaa (sf); previously on Feb 19, 2020 Affirmed Aaa
(sf)

Cl. A-S, Affirmed Aaa (sf); previously on Feb 19, 2020 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Feb 19, 2020 Affirmed
Aaa (sf)

Cl. B, Affirmed Aa2 (sf); previously on Feb 19, 2020 Affirmed Aa2
(sf)

Cl. C, Affirmed A2 (sf); previously on Feb 19, 2020 Affirmed A2
(sf)

Cl. D, Affirmed Baa1 (sf); previously on Feb 19, 2020 Affirmed Baa1
(sf)

Cl. E, Downgraded to Ba2 (sf); previously on Apr 17, 2020 Baa3 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Downgraded to B2 (sf); previously on Apr 17, 2020 Ba2 (sf)
Placed Under Review for Possible Downgrade

Cl. G, Downgraded to Caa2 (sf); previously on Apr 17, 2020 B2 (sf)
Placed Under Review for Possible Downgrade

Cl. X-A*, Affirmed Aaa (sf); previously on Feb 19, 2020 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed A1 (sf); previously on Feb 19, 2020 Affirmed A1
(sf)

Cl. EC**, Affirmed Aa3 (sf); previously on Feb 19, 2020 Affirmed
Aa3 (sf)

*Reflects Interest-Only Classes

**Reflects Exchangeable Class

RATINGS RATIONALE

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

The ratings on three P&I classes, Cl. E, Cl. F and Cl. G, were
downgraded due to the decline in pool performance and higher
anticipated losses, primarily driven by the specially serviced
loans (37% of the pool) and troubled loans.

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

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

The actions conclude the review for downgrade initiated on April
17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 9.4% of the
current pooled balance, compared to 3.8% at Moody's last review.
Moody's base expected loss plus realized losses is now 5.3% of the
original pooled balance, compared to 2.2% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except the
exchangeable class and interest-only classes were "Approach to
Rating US and Canadian Conduit/Fusion CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 15th 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 43% to $610 million
from $1.07 billion at securitization. The certificates are
collateralized by 31 mortgage loans ranging in size from less than
1% to 19% of the pool, with the top ten loans (excluding
defeasance) constituting 77% of the pool. Four loans, constituting
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 10, the same as at Moody's last review.

As of the June 2020 remittance report, loans representing 82% were
current or within their grace period on their debt service
payments, 13% were beyond their grace period but less than 30 days
delinquent.

Six loans, constituting 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 (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

No loans have been liquidated from the pool. Three loans,
constituting 36.9% of the pool, are currently in special servicing.
Two of the specially serviced loans, representing 32% of the pool,
have transferred to special servicing since March 2020.

The largest specially serviced loan is the West County Center Loan
($118.2 million -- 19.4% of the pool), which represents a
pari-passu portion of a $172.7 million mortgage loan. The loan is
secured by the 744,000 square feet (SF) collateral portion of a 1.2
million SF super-regional mall in Des Peres, Missouri, a suburb of
St. Louis. As of the March 2020 rent roll, the mall was 97% leased,
unchanged from the September 2019 rent roll. Anchor tenants include
Macy's (non-collateral), JC Penney (non-collateral), Dick's
Sporting Goods, and Nordstrom. Other notable tenants are Barnes &
Noble Booksellers, Forever 21, H&M, and Apple. The loan was
recently transferred to special servicing on April 2020 for
imminent monetary default at the borrower's request as a result of
the Covid-19 pandemic. However, the loan remains current as of its
June 2020 payment date. The mall is owned by a joint venture
comprised of entities affiliated with CBL, TIAA-CREF, and the Dutch
pension fund APG. CBL classified the mall as a tier 1 mall in its
2019 annual report and indicated 2019 mall store sales of $584 per
square foot (PSF), compared to the 2018 reported sales of $536 PSF.
Property performance has declined since securitization due to lower
revenues and the 2019 NOI was approximately 17% below underwritten
levels. The mall also faces competition from six regional and super
regional malls within the St. Louis MSA. However, the loan has
amortized 9% since securitization and the 2019 reported NOI DSCR
remained high at 1.87X. Due to the performing nature of the loan,
this has been included in the conduit statistics. Moody's LTV and
stressed DSCR are 128% and 0.91X, respectively.

The second largest specially serviced loan is the Waterfront Loan
($77.8 million --12.7% of the pool), which is secured by the retail
components of a larger master planned development in Homestead,
Pennsylvania, a suburb of Pittsburgh roughly five miles from the
CBD. The collateral includes a power center component, a big box
component, as well as strip center and restaurant pad space. At
securitization, the property was shadow anchored by Lowe's Home
Improvement Center, Target, Giant Eagle, Macy's and Costco.
However, Macy's closed their store at the location in 2018 and the
space was converted into Class-A office space. Major collateral
tenants include Loews Theater, Dave & Buster's, Old Navy and
Michaels. One of the major collateral tenants, Best Buy (30,055 SF,
3.9% of the net rentable area (NRA)) closed their store at this
location in November 2019. As of March 2020, the collateral was 94%
leased, compared to 98% leased as of September 2019. Property
performance has declined moderately since 2017 due to decline in
revenues and increased expenses. The reported 2019 actual NOI DSCR
was 1.60X. The loan is last paid through its May 2020 payment date
and was recently transferred to special servicing at the borrower's
request as a result of the Covid-19 pandemic. Due to the historical
performance, this has been included in the conduit statistics.
Moody's LTV and stressed DSCR are 120% and 0.86X, respectively.

The third largest specially serviced loan is the Salem Center Loan
($29.5 million -- 4.8% of the pool), which is secured by the
212,007 SF collateral portion of a 649,624 SF regional mall,
located in Salem, Oregon. At securitization, the mall's
non-collateral anchors included Kohl's, Nordstrom, JCPenney, and
Macy's. However, Nordstrom closed its location in April 2018, and
JCPenney recently announced it would close its location as part of
its Chapter 11 Bankruptcy proceedings. Property performance
declined from securitization as a result of declining occupancy and
revenue. The loan transferred to special servicing in August 2017
due to imminent default and was foreclosed in August 2018. The mall
was temporarily closed as a result of the coronavirus outbreak but
re-opened in late May with limited stores. The special servicer
indicating they are working to stabilize asset.

Moody's has also assumed a high default probability for a poorly
performing portfolio loan, constituting 2.2% of the pool,
securitized by two limited service hotels located in Texas. The
loan remains current as of the June 2020 payment date, but the
properties had already experienced a decline in performance in 2019
and the loan is on the watchlist due to the borrower's coronavirus
relief request.

Moody's received full or partial year 2019 operating results for
87% of the pool, and partial year 2020 operating results for 16% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 110%, compared to 95% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, one
specially serviced (Salem Center) and troubled loans. Moody's net
cash flow (NCF) reflects a weighted average haircut of 22% to the
most recently available net operating income (NOI). Moody's value
reflects a weighted average capitalization rate of 9.8%.

Moody's actual and stressed conduit DSCRs are 1.54X and 1.00X,
respectively, compared to 1.70X and 1.11X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three non-specially serviced conduit loans represent 23% of
the pool balance. The largest loan is the Summit Woods Shopping
Center Loan ($53.8 million -- 8.8% of the pool), which is secured
by a 545,051 SF retail power center located in Lee's Summit,
Missouri. The property is also encumbered with $9.0 million of
mezzanine financing held outside the trust. As of March 2020, the
property was 99% leased, unchanged from September 2019. The largest
tenants include Lowe's Home Center (25% of NRA; lease expiration
March 2022) and Kohl's (16% of the NRA; lease expiration January
2022). The loan has amortized 9% since securitization and remains
current through its June 2020 payment date. Moody's LTV and
stressed DSCR are 91% and 1.06X, respectively, compared to 92% and
1.06X at the last review.

The second largest loan is the BJ's Wholesale Club Portfolio Loan
($48.1 million -- 7.9% of the pool), which is secured by first
mortgage liens on four stand-alone retail properties occupied by
BJ's Wholesale Club. BJ's Wholesale Club operates at the
improvements subject to a single triple-net, 20-year master lease
that is scheduled to expire in September 2032. The lease does not
provide for early termination rights outside of the standard
condemnation and casualty clauses. The loan is current as of its
June 2020 payment date and is interest only for its entire term.
Moody's LTV and stressed DSCR are 89% and 1.16X, respectively,
unchanged from Moody's last review.

The third largest loan is the One South Broad Street Loan ($40.8
million -- 6.7% of the pool), which is secured by a 25-story, Class
B office building with a Walgreens in its street-level retail space
located in the Philadelphia CBD, directly south of City Hall. The
property was built in 1932 with the most recent significant
renovation occurring in 2001 and property benefits from its CBD
location just south of Philadelphia City Hall. As of March 2020,
the property was 86% leased, however, the largest tenant, Well
Fargo (25% of the NRA) is anticipated to vacate their space at
lease expiration in December 2020. A cash trap is now active as a
result the failure of Wells Fargo to renew their lease 18 months
prior to expiration. Moody's analysis took into account the lease
up risk of upcoming vacant spaces. Moody's LTV and stressed DSCR
are 111% and 0.87X, respectively, compared to 86% and 1.13X at the
last review.


JPMBB COMMERCIAL 2013-C14: Moody's Cuts Class G Debt Rating to Caa3
-------------------------------------------------------------------
Moody's Investors Service affirmed the ratings on seven classes and
downgraded the ratings on four classes in JPMBB Commercial Mortgage
Securities Trust 2013-C14, Commercial Mortgage Pass-Through
Certificates, Series 2013-C14 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on May 10, 2019 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on May 10, 2019 Affirmed Aaa
(sf)

Cl. A-S, Affirmed Aaa (sf); previously on May 10, 2019 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on May 10, 2019 Affirmed
Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on May 10, 2019 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on May 10, 2019 Affirmed A3
(sf)

Cl. D, Downgraded to Ba2 (sf); previously on Apr 17, 2020 Baa3 (sf)
Placed Under Review for Possible Downgrade

Cl. E, Downgraded to B1 (sf); previously on Apr 17, 2020 Ba2 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Downgraded to B3 (sf); previously on Apr 17, 2020 Ba3 (sf)
Placed Under Review for Possible Downgrade

Cl. G, Downgraded to Caa3 (sf); previously on Apr 17, 2020 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. X-A*, Affirmed Aaa (sf); previously on May 10, 2019 Affirmed
Aaa (sf)

*Reflects Interest-Only Class

RATINGS RATIONALE

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

The ratings on four P&I classes were downgraded due to a decline in
pool performance and higher anticipated losses from specially
serviced and troubled loans. The pool has significant exposure to
three regional malls, the Meadows Mall (12.5% of the pool), the
Southridge Mall (9.4% of the pool), and the Country Club Mall (3.1%
of the pool), all three of which have experienced recent declines
in net operating income (NOI).

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

The actions conclude the review for downgrade initiated on April
17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 9.7% of the
current pooled balance, compared to 5.1% at Moody's last review.
Moody's base expected loss plus realized losses is now 6.1% of the
original pooled balance, compared to 3.7% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except interest-only
classes were "Approach to Rating US and Canadian Conduit/Fusion
CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 17, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 37.2% to $720.7
million from $1.15 billion at securitization. The certificates are
collateralized by 32 mortgage loans ranging in size from less than
1% to 12.7% of the pool, with the top ten loans (excluding
defeasance) constituting 63.3% of the pool. Five loans,
constituting 19.3% of the pool, have defeased and are secured by US
government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 11, compared to 14 at Moody's last review.

As of the June 2020 remittance report, loans representing 84% were
current or within their grace period on their debt service
payments, 2% were beyond their grace period but less than 30 days
delinquent,12% were between 30 -- 59 days delinquent, and 2% were
delinquent for 60 days or more.

Eleven loans, constituting 59.8% of the pool, are on the master
servicer's watchlist, of which eight loans, representing 42% of the
pool, indicate the borrower has requested relief in relation to
coronavirus impact on the property. The watchlist includes loans
that meet certain portfolio review guidelines established as part
of the CRE Finance Council (CREFC) monthly reporting package. As
part of Moody's ongoing monitoring of a transaction, the agency
reviews the watchlist to assess which loans have material issues
that could affect performance.

No loans have been liquidated from the pool. Three loans,
constituting 2.5% of the pool, are currently in special servicing.
One of the specially serviced loans, representing 0.6% of the pool,
have transferred to special servicing since March 2020.

The largest specially serviced loan is the Four Points Sheraton --
San Diego Loan ($8.4 million -- 1.2% of the pool), which is secured
by a 225-room full-service hotel built in 1987 and located in
Kearny Mesa, approximately 10 miles north of the San Diego central
business district (CBD). The loan transferred to special servicing
in February 2016 due to imminent default followed by a monetary
default. The borrower filed for Chapter 11 bankruptcy in May 2016
and the debtor was required to reinstate the loan provided a
property improvement plan (PIP) completion and improvement to guest
scores by December 2017. The borrower is complying with cash
management, changed property managers, and reports to be working on
a PIP extension. The loan is current through its June 2020 payment
and is being monitored until the borrower is in compliance with the
franchise agreement.

The second largest specially serviced loan is the Parkway Place
($5.7 million -- 0.8% of the pool), which is secured by a fee and
leasehold interest in a 78,469 SF mixed-use center located in
Flowood, Mississippi. The collateral comprises of a 31,300 SF movie
theatre, a 6,919 SF restaurant outparcel, and a 40,250 SF shopping
center. The shopping center is the only portion encumbered by a
ground lease which expires in July 2063. As May 2020, the property
was 75% occupied (the theatre and restaurant are still in-place).
The loan was transferred to special servicing in September 2019 for
payment default. Foreclosure was initiated and a receivership was
appointed in January 2020.

The third largest specially serviced loan is the Best Western --
Portage, IN Loan ($4.0 million -- 0.6% of the pool), which is
secured by a 100-room limited service hotel located in Portage,
Indiana, approximately 2 miles south of the Port of Indiana. The
property's 2019 NOI has decreased by 21% from the 2018 but is 33%
above securitization. The borrower requested borrower relief due to
the coronavirus outbreak in April 2020 and the loan transferred to
special servicing in May 2020 for payment default. The loan was
last paid through February 2020 and the special servicer indicated
a forbearance agreement is currently under review.

Moody's has also assumed a high default probability for three
poorly performing loans, constituting 13.4% of the pool. The
largest troubled loan is the Southridge Mall Loan ($67.9 million --
9.4% of the pool) and is further discussed.

The second largest troubled loan is the Country Club Mall Loan
($22.0 million -- 3.1% of the pool), which is secured by an
approximately 394,000 SF component of a 597,000 SF regional mall
located in LaValle, Maryland. The non-collateral portion is
occupied by a Walmart Supercenter. Two collateral anchor tenants,
Bon-Ton (23% of NRA) and Sears (19% of NRA), vacated the property
in 2018 and 2020, respectively. The property's remaining anchor,
J.C. Penney (18% of NRA) has recently been listed as one of the
expected store closures as a result of the company's Chapter 11
Bankruptcy proceedings. Excluding these anchors, the next largest
tenants are T.J. Maxx (6% of NRA) and Country Club Cinema (6% of
NRA) with lease expirations in March 2023 and July 2031,
respectively. As of March 2020, the total property was 77% occupied
including Sears and J.C. Penney. The mall has reopened on June 20,
2020 after a temporary closure due to the coronavirus outbreak. The
loan had been on the watchlist since September 2019 due to
Bon-Ton's bankruptcy and is last paid through its April 2020
payment date.

The third largest troubled loan is the Hyatt Place North Charleston
Loan ($7.0 million -- 1.0% of the pool), which is secured by a
113-room limited service hotel located in North Charleston, South
Carolina. The loan has been on the watchlist since January 2020 due
to a decrease in DSCR. The 2019 NOI has decreased by 32% as
compared to 2018 and borrower relief was requested in April 2020
due to the coronavirus outbreak. The loan was last paid through its
March 2020 payment.

Moody's received full year 2019 operating results for 96% of the
pool, and partial year 2020 operating results for 28% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 109%, compared to 99% at Moody's last
review. Moody's conduit component excludes loans with structured
credit assessments, defeased and CTL loans, and specially serviced
and troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 18.6% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 10.2%.

Moody's actual and stressed conduit DSCRs are 1.32X and 1.05X,
respectively, compared to 1.59X and 1.10X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 34.6% of the pool balance.
The largest loan is the Spirit Portfolio Loan ($91.7 million --
12.7% of the pool), which is secured by a portfolio of 26
properties including retail, industrial, office, and mixed-use. The
properties are located in 13 different states and the top five
states by allocated loan balance are Illinois (19%), New Hampshire
(13%), Texas (12%), North Carolina (11%), and Indiana (11%).
Twenty-five of the 26 properties are leased to single tenants with
several tenants have leases at more than one property: LA Fitness
(leases 2 properties); CVS (2 properties); Walgreens (2
properties); Ferguson Enterprises (3 properties) and Tractor Supply
(2 properties). The loan has been on the watchlist since November
2019 due to the servicer advancing funds for forced placed
insurance and the advanced balance has been over the threshold for
more than 30 days. The loan has amortized 10% since securitization
and is current through its June 2020 debt service payment date.
Moody's LTV and stressed DSCR are 79% and 1.33X, respectively,
compared to 79% and 1.34X at last review.

The second largest loan is the Meadows Mall Loan ($90.0 million --
12.5% of the pool), which represents a pari-passu portion of a
$134.6 million mortgage loan. The loan is secured by an
approximately 308,000 SF portion of a 945,000 SF regional mall
located five miles west of the Strip in Las Vegas, Nevada. The mall
is anchored by Curacao, Dillard's Clearance Center, JC Penney, and
Macy's. All anchor tenants own their respective stores which are
not included as collateral for the loan. A prior non-collateral
anchor, Sears, vacated in February 2020. The first floor of Sears
was partially backfilled by Round1 Bowling and Amusement which
opened in November 2019. As of March 2020, the collateral was 91%
occupied (84% when excluding specialty leasing) compared to 96% and
90%, respectively, in September 2018. For the trailing twelve-month
(TTM) period ending March 2020, in-line sales for tenants less than
10,000 SF was $389 per square foot (PSF) compared to $383 PSF for
the TTM period ending June 2018. Property performance has declined
since securitization as a result of decreased revenue. The 2019 NOI
declined approximately 18% from 2018 and was 20% lower than in
2013. The mall has reopened since May 29, 2020 after a temporary
closure due to the coronavirus outbreak and the loan has been on
the watchlist since June 2020 for borrower relief request. The loan
has amortized 18% since securitization and is current on through
its June 2020 payment date. Moody's LTV and stressed DSCR are 136%
and 0.85X, respectively, compared to 119% and 0.89X at the last
review.

The third largest loan is the Southridge Mall Loan ($67.9 million
-- 9.4% of the pool), which represents a pari-passu portion of a
$113.2 million mortgage loan. The loan is secured by a 554,000 SF
portion of a 1.2 million SF regional mall in Greendale, Wisconsin,
a suburb of Milwaukee. At securitization, the mall was anchored by
non-collateral anchors Boston Store, Sears, J.C. Penney, and
collateral anchors, Macy's and Kohl's. Sears and Boston Store
vacated the property in 2017 and 2018, respectively. Subsequently
Kohl's moved their store to a new retail development in late 2018.
The former Sears space was partially backfilled by a Dick's
Sporting Goods/Golf Galaxy, Round1 Bowling and Amusement, and T.J.
Maxx, all of which opened for business between 2018 and 2019. As of
March 2020, the collateral was 71% occupied and in-line occupancy
was 76%. The mall has reopened since May 20, 2020 after a temporary
closure due to the coronavirus outbreak and the loan has been on
the watchlist since May 2020 due to the borrower s relief request.
The loan is last paid through its April 2020 payment and due to the
decline in performance anchor store closures Moody's has identified
this as a troubled loan. The loan has amortized 10% since
securitization.


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

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

The ratings reflect S&P's view of:

-- The diversification of the collateral pool;

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

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

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

S&P Global Ratings acknowledges a high degree of uncertainty about
the evolution of the coronavirus pandemic. The consensus among
health experts is that the pandemic may now be at, or near, its
peak in some regions but will remain a threat until a vaccine or
effective treatment is widely available, which may not occur until
the second half of 2021. S&P is using this assumption in assessing
the economic and credit implications associated with the pandemic.
As the situation evolves, S&P will update its assumptions and
estimates accordingly.

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

  Class                Rating     Amount (mil. $)
  A                    AAA (sf)            244.00
  B                    AA (sf)              56.00
  C (deferrable)       A (sf)               26.00
  D (deferrable)       BBB- (sf)            22.00
  E (deferrable)       BB- (sf)             14.00
  Subordinated notes   NR                   36.90

  NR--Not rated.


MARATHON CLO XIII: Moody's Cuts Rating on $30MM Class D Notes to B1
-------------------------------------------------------------------
Moody's Investors Service downgraded the ratings on the following
notes issued by Marathon CLO XIII Ltd.:

US$17,125,000 Class B-L Senior Secured Deferrable Floating Rate
Notes Due April 2032, Downgraded to A3 (sf); June 3, 2020 A2 (sf)
Placed Under Review for Possible Downgrade

US$7,125,000 Class B-F Senior Secured Deferrable Fixed Rate Notes
Due April 2032, Downgraded to A3 (sf); June 3, 2020 A2 (sf) Placed
Under Review for Possible Downgrade

US$30,000,000 Class C Senior Secured Deferrable Floating Rate Notes
Due April 2032, Downgraded to Ba1 (sf); April 17, 2020 Baa3 (sf)
Placed Under Review for Possible Downgrade

US$30,000,000 Class D Secured Deferrable Floating Rate Notes Due
April 2032, Downgraded to B1 (sf); April 17, 2020 Ba3 (sf) Placed
Under Review for Possible Downgrade

These actions conclude the review for downgrade initiated on June
3, 2020 on the Class B-L and Class B-F notes and on April 17, 2020
on the Class C and Class D notes issued by the CLO. Marathon CLO
XIII Ltd., issued in June 2019 is a managed cashflow CLO. The notes
are collateralized primarily by a portfolio of broadly syndicated
senior secured corporate loans. The transaction's reinvestment
period will end on July 2024.

RATINGS RATIONALE

The downgrade rating action on the Class B-L, Class B-F, Class C
and Class D notes reflect the risks posed by credit deterioration
and loss of collateral coverage observed in the underlying CLO
portfolio, which have been primarily prompted by economic shocks
stemming from the coronavirus pandemic. Since the outbreak widened
in March, the decline in corporate credit has resulted in a
significant number of downgrades, other negative rating actions, or
defaults on the assets collateralizing the CLO. Consequently, the
default risk of the CLO portfolio has increased substantially and
exposure to Caa-rated assets has increased significantly.

Based on Moody's calculation, the weighted average rating factor
(WARF) is 3734 as of June 2020, or 27.3% worse compared to 2978
reported in the March 2020 trustee report [1]. Moody's calculation
also showed the WARF was failing the test level of 3099 reported in
the June 2020 trustee report [2] by 635 points. Moody's noted that
approximately 40.6% of the CLO's par was from obligors assigned a
negative outlook and 5.3% from obligors whose ratings are on review
for possible downgrade. Additionally, based on Moody's calculation,
the proportion of obligors in the portfolio with Moody's corporate
family or other equivalent ratings of Caa1 or lower (adjusted for
negative outlook or watchlist for downgrade) was approximately 28%
as of June 2020. Furthermore, Moody's calculated the total
collateral par balance, including recoveries from defaulted
securities, is $493.7 million, or $6.3 million less than the deal's
original ramp-up target par balance, and Moody's calculated the
over-collateralization (OC) ratios (excluding haircuts) for the
Class D notes as well as the interest diversion test as of June
2020 at 107.7%. Moody's noted that the OC test for the Class D
notes, as well as the interest diversion test were recently
reported in June 2020 trustee report [3] as failing. If these
failures were to occur on the next payment date they would result
in the repayment of senior notes or a portion of excess interest
collections being diverted towards reinvestment in collateral.

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

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base case,
Moody's analyzed the collateral pool as having a performing par and
principal proceeds balance of $491.8 million, defaulted par of $7.2
million, a weighted average default probability of 30.93% (implying
a WARF of 3734), a weighted average recovery rate upon default of
47.72%, a diversity score of 75 and a weighted average spread of
3.80%. Moody's also analyzed the CLO by incorporating an
approximately $18 million par haircut in calculating the OC and
interest diversion test ratios. Finally, Moody's also considered in
its analysis the CLO manager's recent investment decisions and
trading strategies.

In consideration of the current high uncertainties around the
global economy and the ultimate performance of the CLO portfolio,
Moody's conducted a number of additional sensitivity analyses
representing a range of outcomes that could diverge, both to the
downside and the upside, from its base case. Some of the additional
scenarios that Moody's considered in its analysis of the
transaction include, among others: additional near-term defaults of
companies facing liquidity pressure; additional OC par haircuts to
account for potential future downgrades and defaults resulting in
an increased likelihood of cash flow diversion to senior notes; and
some improvement in WARF as the US economy gradually recovers in
the second half of the year and corporate credit conditions
generally stabilize.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of corporate assets from the collapse
in the US economic activity in the second quarter and a gradual
recovery in the second half of the year. However, that outcome
depends on whether governments can reopen their economies while
also safeguarding public health and avoiding a further surge in
infections. 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.

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

The performance of the rated notes is subject to uncertainty in the
performance of the related CLO's underlying portfolio, which in
turn depends on economic and credit conditions that may change. In
particular, the length and severity of the economic and credit
shock precipitated by the global coronavirus pandemic will have a
significant impact on the performance of the securities. The CLO
manager's investment decisions and management of the transaction
will also affect the performance of the rated securities.

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


MVW LLC 2020-1: Fitch to Rate Class D Notes 'BB(EXP)'
-----------------------------------------------------
Fitch Ratings has assigned expected ratings and Outlooks to notes
issued by MVW 2020-1 LLC. The social and market disruption caused
by the coronavirus pandemic and related containment measures has
negatively affected the U.S. economy. To account for the potential
impact, Fitch incorporated conservative assumptions in deriving the
base case cumulative gross default proxy. The analysis focused on
peak extrapolations of 2006-2009 and 2015-2017 vintages, as a
starting point and made adjustments based on the prefunding account
that will only consist of well-seasoned receivables from the MVW
2013-1 transaction, which is expected to be redeemed during the
prefunding period, as well as a small portion of new contracts.

MVW 2020-1

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

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

  - Class C; LT BBB(EXP)sf Expected Rating

  - Class D; LT BB(EXP)sf Expected Rating

KEY RATING DRIVERS

Borrower Risk — Weaker Collateral Pool: This is the third
transaction to include originations from both the MVWC and VSE
platforms. Overall, the pool is consistent with 2019-2, as the
weighted average FICO is stable at 735 compared with 734. The
concentration of foreign obligors declined to 6.0% from 6.6% in
2019-2, while 15-year loans are stable at 27.3% compared with 26.4%
in 2019-2.

However, the 2020-1 pool includes 19.2% of Sheraton collateral, up
from 15.0% in 2019-2, which performs worse than Marriott Vacation
Club across all FICO bands. Conversely, there is a greater
concentration of Westin loans at 19.2%, consistent with 20.1% in
2019-2.

This is the first transaction to include Hyatt-branded loans, which
are 6.6% of the initial pool and historically have higher forecast
losses compared with other brands. Seasoning declined to eight
months from 12 months in 2019-2.

Forward-Looking Approach on CGD Proxy — Varied Performance: With
the exception of certain foreign segments, MVC 2010-2016 vintages
continue to display improved performance relative to the weaker
2007-2009 periods, although more recent vintages remain under
stress. The VSE portfolio experienced stress during the recession.
Since then, Westin loan performance improved and is stable.

Sheraton loan performance deteriorated in recent years driven by
Sheraton Flex and 15-year loans, with the newly included
Hyatt-branded loans showing overall high projected losses on par
and in some cases exceeding other VSE brands, including Sheraton.
Fitch's current base case cumulative gross default proxy is also
13.25% for 2019-2.

Coronavirus Causing Economic Shock: 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 first-half 2020 driven by sharp
economic contractions in major economies with a rapid spike in
unemployment, followed by a recovery that begins in third-quarter
2020 as the health crisis subsides. Under this scenario, Fitch's
initial base case CGD proxy was derived using weaker performing
2006-2009 and 2015-2017 vintages.

The CGD proxy accounts for the weaker performance and potential
negative impacts from the severe downturn in the tourism and travel
industries during the pandemic that are highly correlated with the
timeshare sector.

Structural Analysis — Higher CE Structure: To compensate for
higher expected losses and the current economic environment,
initial hard credit enhancement is 38.3%, 19.6%, 8.1% and 2.5% for
the class A, B, C and D notes, respectively. CE is notably higher
relative to 2019-2, given both the weaker collateral pool and
higher forecast losses with the advent of the pandemic. Available
CE is sufficient to support stressed 'AAAsf', 'Asf', 'BBBsf' and
'BBsf' multiples of Fitch's base case CGD proxy of 13.25%.

As with prior MVW/MVW Owner Trust transactions, 2020-1 has a
pre-funding account that will hold up to 3.92%, of the initial
collateral balance after the closing date to buy eligible timeshare
loans, down from 25% in 2019-2. This account is required to be used
to buy both called collateral from the MVW 2013-1 transaction and
new originations limited to 1.1% of the total pool.

Originator/Seller/Servicer Operational Review — Quality of
Origination/Servicing: MVW/MORI and VSE demonstrated sufficient
abilities as an originator and servicer of timeshare loans, as
evidenced by the historical delinquency and default performance of
securitized trusts and of the managed portfolio.

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 CGD is 20% less than the projected
proxy, the expected ratings would be maintained for class A notes
at stronger rating multiples. For the class B, C and D notes, the
multiples would increase resulting for potential upgrade of one
rating category and one notch, respectively.

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

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

Hence, Fitch conducts sensitivity analysis by stressing both a
transaction's initial base case CGD and prepayment assumptions and
examining the rating implications on all classes of issued notes.
The CGD sensitivity stresses the CGD proxy to the level necessary
to reduce each rating by one full category, to non-investment grade
(BBsf) and to 'CCCsf' based on the break-even loss coverage
provided by the CE structure. The prepayment sensitivity includes
1.5x and 2.0x increases to the prepayment assumptions representing
moderate and severe stresses, respectively. These analyses are
intended to provide an indication of the rating sensitivity of
notes to unexpected deterioration of a trust's performance.

Additionally, Fitch conducts increases of 1.5x and 2.0x to the CGD
proxy, which represents moderate and severe stresses, respectively.
These analyses are intended to provide an indication of the rating
sensitivity of notes to unexpected deterioration of a trust's
performance. A more prolonged disruption from the pandemic is
accounted for in the severe downside stress of 2.0x and could
result in downgrades of up to two rating categories.

Due to the coronavirus pandemic, the U.S. and the broader global
economy remain under stress, with surging unemployment and pressure
on businesses stemming from government social distancing
guidelines. Unemployment pressure on the consumer base may result
in increases in delinquencies.

For sensitivity purposes, Fitch also assumed a 2.0x increase in
delinquency stress. The results indicated no adverse rating impact
to the 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

Fitch was provided with due diligence information from Ernst &
Young LLP. The due diligence information was provided on Form ABS
Due Diligence-15E and focused on a comparison and recalculation of
certain characteristics with respect to 148 sample loans by Ernst &
Young LLP. Fitch considered this information in its analysis, and
the findings did not have an impact on the analysis.

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).


PALISADES CENTER 2016-PLSD: Moody's Lowers Class D Certs to Caa1
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of four classes in
Palisades Center Trust 2016-PLSD, Commercial Mortgage Pass-Through
Certificates, Series 2016-PLSD as follows:

Cl. A, Downgraded to A1 (sf); previously on Apr 17, 2020 Aaa (sf)
Placed Under Review for Possible Downgrade

Cl. B, Downgraded to Ba1 (sf); previously on Apr 17, 2020 A2 (sf)
Placed Under Review for Possible Downgrade

Cl. C, Downgraded to B1 (sf); previously on Apr 17, 2020 Baa3 (sf)
Placed Under Review for Possible Downgrade

Cl. D, Downgraded to Caa1 (sf); previously on Apr 17, 2020 Ba3 (sf)
Placed Under Review for Possible Downgrade

RATINGS RATIONALE

The ratings on Cl. A, Cl. B, Cl. C and Cl. D were downgraded due to
an increase in Moody's LTV as a result of continued decline in
performance since securitization, additional store closures, and
further stress on the property ahead of the loan's April 2021
maturity date as a result of the temporary interior closure and
re-opening uncertainty due to the coronavirus outbreak. The actions
conclude the review for downgrade initiated on April 17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING

The principal methodology used in these ratings was "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 15, 2020 payment date, the transaction's aggregate
certificate balance remains unchanged since securitization at
approximately $389 million. The whole loan of $419 million has a
split loan structure represented by the trust loan component of
$389 million and a companion loan component of $30 million (not
included in the trust) that is securitized in JPMDB 2016-C2. The
trust includes notes A, B, C and D. The $229 million senior trust A
note and the $30 million companion loan component in JPMDB 2016-C2
are pari passu. The trust notes B, C and D are junior to the trust
note A and the companion loan. Additionally, there is $142 million
of mezzanine debt held outside the trust. The five-year fixed-rate
mortgage loan matures in April 2021.

The Palisades Center is located approximately 3.5 miles northwest
of the Tappan Zee Bridge and 18 miles northwest of New York City.
The property is managed by the loan's sponsor, Pyramid Management
Group, LLC, a privately held real estate management and development
company headquartered in Syracuse, New York.

The subject's primary trade area includes sections from three
densely populated and affluent counties of the New York MSA:
Rockland County, Westchester County, and Bergen County. Moody's
identifies Garden State Plaza and Shops at Nanuet as significant
competitors. The property draws substantial Sunday traffic from the
nearby residence of New Jersey's Bergen County due to the county's
highly restrictive "Blue Laws". These Blue Laws restrict retail
operations on Sunday in Bergen County. Furthermore, the property
may face additional competition from the American Dream
development, a 2.9 million SF retail and entertainment complex,
located approximately 25 miles south of the property in East
Rutherford, New Jersey. The American Dream had a soft opening in
October 2019 prior to closing due to the coronavirus outbreak.

The Palisades Center contains several occupied anchors comprised of
Macy's (201,000 SF), Home Depot (132,800 SF), Target (130,140 SF),
BJ's Wholesale Club (118,076 SF), Dick's Sporting Goods (94,745 SF)
and Burlington Coat Factory (54,609 SF). Anchor collateral for the
loan does not include the Macy's space. Other larger collateral
tenants include a 21-screen AMC Palisades Center Cinema, Barnes and
Noble, Best Buy, Dave and Busters, DSW, Autobahn Indoor Speedway,
and New York Sports Club.

The property's performance has continued to decline since
securitization. In July 2017, JC Penney closed and vacated their
three-level 157,000 SF anchor space, which is part of the loan
collateral. The JC Penney space remains vacant. In addition, Lord &
Taylor (120,000 SF) closed in January 2020 and Bed Bath and Beyond
(45,000 SF with lease expiring in January 2022) closed in June
2020. As a result of New York State mandate the interior of the
mall has remained closed since March 19, 2020, with certain tenants
offering curbside pick-up in the exterior of the mall. As a result
of the closure, many tenants have not remitted rent payments in
recent months and the decline in tenant sales from temporarily
closures at Palisades and other non-essential retail properties may
lead to increased likelihood of additional store closures. Moody's
expects the store closures, weakened tenant credit profiles and
re-opening uncertainty will pressure the mall's performance for the
rest of the year and the first half of 2021.

The loan was transferred in April 2020 to special servicing as a
result of the closure of the center related to the coronavirus
outbreak. As of the June distribution date the special servicer was
in discussions with borrower and mezzanine lender regarding
potential payment relief terms. The property's NCF has continually
declined since securitization and was $36.9 million in 2019, down
from $40.5 MM in 2018 and $44.9 MM in 2016. Moody's loan to value
for the first mortgage ratio is 122%, compared to 97% at last
review and reflects a decrease in Moody's stabilized NCF. Moody's
trust stressed debt service coverage ratio is 0.77X compared to
0.98X at the last review. The loan status is 60 days delinquent as
of the June payment date and there is outstanding P&I advances
totaling approximately $1.43 million. Furthermore, the loan matures
in April 2021 and may face significant refinance risk as a result
of the declining performance and the current retail environment.


SDART 2020-2: Moody's Gives '(P)B2' Rating to Class E Notes
------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to the notes
to be issued by Santander Drive Auto Receivables Trust 2020-2
(SDART 2020-2). This is the second SDART auto loan transaction of
the year for Santander Consumer USA Inc. (SC; unrated). The notes
will be backed by a pool of retail automobile loan contracts
originated by SC, who is also the servicer and administrator for
the transaction

The complete rating actions are as follows:

Issuer: Santander Drive Auto Receivables Trust 2020-2

Class A-1 Notes, Assigned (P)P-1 (sf)

Class A-2-A Notes, Assigned (P)Aaa (sf)

Class A-2-B Notes, Assigned (P)Aaa (sf)

Class A-3 Notes, Assigned (P)Aaa (sf)

Class B Notes, Assigned (P)Aa1 (sf)

Class C Notes, Assigned (P)Aa2 (sf)

Class D Notes, Assigned (P)Baa2 (sf)

Class E Notes, Assigned (P)B2 (sf)

RATINGS RATIONALE

The ratings are based on the quality of the underlying collateral
and its expected performance, the strength of the capital
structure, and the experience and expertise of SC as the servicer.

Moody's median cumulative net loss expectation for SDART 2020-2 is
18.0% and loss at a Aaa stress is 47.0%, unchanged from SDART
2020-1, the last transaction Moody's rated. Moody's based its
cumulative net loss expectation and loss at a Aaa stress on an
analysis of the credit quality of the underlying collateral; the
historical performance of similar collateral, including
securitization performance and managed portfolio performance; the
ability of SC to perform the servicing functions; and current
expectations for the macroeconomic environment during the life of
the transaction.

At closing the Class A notes, Class B notes, Class C notes, Class D
notes and Class E notes are expected to benefit from 53.50%,
44.00%, 30.25%, 18.25% and 11.25% of hard credit enhancement,
respectively. Hard credit enhancement for the notes consists of a
combination of overcollateralization, a non-declining reserve
account and subordination. The notes may also benefit from excess
spread.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of auto loan asset backed securities
(ABS) sector from the collapse in US economic activity in the
second quarter and a gradual recovery in the second half of the
year. However, that outcome depends on whether governments can
reopen their economies while also safeguarding public health and
avoiding a further surge in infections. Specifically, for auto loan
ABS, loan performance will weaken due to the unprecedented spike in
the unemployment rate that may limit the borrower's income and
their ability to service debt. The softening of used vehicle prices
due to lower demand will reduce recoveries on defaulted auto loans,
also a credit negative. Furthermore, borrower assistance programs
to affected borrowers, such as extensions, may adversely impact
scheduled cash flows to bondholders.

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.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Auto Loan- and Lease-Backed ABS" published in
May 2020.

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

Up

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

Down

Moody's could downgrade the notes if, given current expectations of
portfolio losses, levels of credit enhancement are consistent with
lower ratings. Credit enhancement could decline if excess spread is
not sufficient to cover losses in a given month. Moody's
expectation of pool losses could rise as a result of a higher
number of obligor defaults or deterioration in the value of the
vehicles securing an obligor's promise of payment. Portfolio losses
also depend greatly on the US job market, the market for used
vehicles, and poor servicing. Other reasons for worse-than-expected
performance include error on the part of transaction parties,
inadequate transaction governance, and fraud. Additionally, Moody's
could downgrade the Class A-1 short-term rating following a
significant slowdown in principal collections that could result
from, among other things, high delinquencies, high usage of
borrower relief programs or a servicer disruption that impacts
obligor's payments.


TOWD POINT 2020-3: Fitch Assigns B(EXP) Rating on Class B2 Notes
----------------------------------------------------------------
Fitch Ratings has assigned expected ratings to the residential
mortgage-backed notes issued by Towd Point Mortgage Trust 2020-3.

TPMT 2020-3

  - Class A1A; LT AAA(EXP)sf Expected Rating

  - Class A1B; LT AAA(EXP)sf Expected Rating

  - Class A2; LT AA(EXP)sf Expected Rating

  - Class M1; LT A(EXP)sf Expected Rating

  - Class M2; LT BBB(EXP)sf Expected Rating

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

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

  - Class B3; LT NR(EXP)sf Expected Rating

  - Class B4; LT NR(EXP)sf Expected Rating

  - Class B5; LT NR(EXP)sf Expected Rating

  - Class A1; LT AAA(EXP)sf Expected Rating

  - Class A2A; LT AA(EXP)sf Expected Rating

  - Class A2AX; LT AA(EXP)sf Expected Rating

  - Class A2B; LT AA(EXP)sf Expected Rating

  - Class A2BX; LT AA(EXP)sf Expected Rating

  - Class M1A; LT A(EXP)sf Expected Rating

  - Class M1AX; LT A(EXP)sf Expected Rating

  - Class M1B; LT A(EXP)sf Expected Rating

  - Class M1BX; LT A(EXP)sf Expected Rating

  - Class M2A; LT BBB(EXP)sf Expected Rating

  - Class M2AX; LT BBB(EXP)sf Expected Rating

  - Class M2B; LT BBB(EXP)sf Expected Rating

  - Class M2BX; LT BBB(EXP)sf Expected Rating

  - Class A3; LT AA(EXP)sf Expected Rating

  - Class A4; LT A(EXP)sf Expected Rating

  - Class A5; LT BBB(EXP)sf Expected Rating

TRANSACTION SUMMARY

The notes are supported by one collateral group that consists of
12,585 seasoned performing loans and re-performing loans with a
total balance of approximately $1.64 billion, which includes $61
million, or 4%, of the aggregate pool balance in
non-interest-bearing deferred principal amounts, as of the
statistical calculation date.

Distributions of principal and interest 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 servicers will not be advancing delinquent monthly
payments of P&I.

KEY RATING DRIVERS

Revised GDP Due to Coronavirus: The coronavirus pandemic 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% growth 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.

Distressed Performance History (Negative): The collateral pool
consists primarily of peak-vintage, SPLs and RPLs. Of the pool,
3.8% was 30 days delinquent as of the statistical calculation date,
and 23% of loans are current but have had recent delinquencies or
incomplete 24 month pay strings. 73% of the loans have been paying
on time for the past 24 months. Roughly, 55% have been modified.

Expected Payment Forbearance and 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. Mortgage payment deferrals
will provide immediate relief to affected borrowers, and Fitch
expect servicers to broadly adopt this practice. The missed
payments will result in interest shortfalls that will likely be
recovered, the timing of which will depend on repayment terms; if
interest is added to the underlying balance as a
non-interest-bearing amount, repayment will occur at refinancing,
property liquidation, or loan maturity.

To account for the cash flow disruptions, Fitch assumed forbearance
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.
Under these assumptions, the 'AAAsf' and 'AAsf' classes did not
incur any shortfalls and are expected to receive timely payments of
interest. The cash flow waterfall providing for principal otherwise
distributable to the lower rated bonds to pay timely interest to
the 'AAAsf' and 'AAsf' bonds and availability of excess spread also
mitigate the risk of interest shortfalls. The 'Asf' through 'Bsf'
rated classes incurred temporary interest shortfalls that were
ultimately recovered.

Low Operational Risk (Positive): Operational risk is well
controlled for in this transaction. FirstKey Mortgage, LLC has a
well-established track record in RPL activities and has an
"above-average" aggregator assessment from Fitch. Select Portfolio
Servicing, Inc. and Specialized Loan Servicing LLC will perform
primary and special servicing functions for this transaction and
are rated 'RPS1-'/Negative and 'RPS2+'/Negative, respectively, for
this product type. The benefit of highly rated servicers decreased
Fitch's loss expectations by 134 bps at the 'AAAsf' rating
category. The issuer's retention of at least 5% of the bonds helps
ensure an alignment of interest between issuer and investor.

Low Aggregate Servicing Fee (Mixed): Fitch determined that the
stated aggregate servicing fee of approximately 17 bps (SPS
servicing fee of 17 bps and SLS servicing fee of 32 bps) may be
insufficient to attract subsequent servicers under a period of poor
performance and high delinquencies. To account for the potentially
higher fee needed to obtain a subsequent servicer, Fitch's cash
flow analysis assumed a 50-bp servicing fee.

Third-Party Due Diligence (Negative): A third-party due diligence
review was conducted on 64% of the loan by loan count / 74% by UPB
and focused on regulatory compliance, pay history and a tax and
title lien search. The third-party due diligence was performed by
Clayton and AMC, both which are assessed as 'Acceptable-Tier 1' TPR
firms by Fitch. The results of the review indicate moderate
operational risk with approximately 9.1% of the entire pool (14% of
the reviewed loans) were assigned a 'C' or 'D' grade, meaning the
loans had material violations or lacked documentation to confirm
regulatory compliance. Fitch adjusted its loss expectation at the
'AAAsf' rating category by approximately 10 bps to account for this
added risk. See the Third-Party Due Diligence section for
additional details.

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement mechanism construct for
this transaction to generally be consistent with what it views as a
Tier 2 framework. The tier assessment is based primarily on the
inclusion of knowledge qualifiers in the framework and the
exclusion of several representations such as loans identified as
having unpaid taxes. The issuer is not providing R&Ws for second
liens, and newly originated loans are receiving R&Ws applicable for
seasoned collateral; Fitch treated these loans as Tier 5. Fitch
increased its 'AAAsf' loss expectations by 174 bps to account for a
potential increase in defaults and losses arising from weaknesses
in the reps a well as the non-investment grade counterparty. See
Mortgage Loan Representations and Warranties section for more
detail.

Limited Life of Rep Provider (Negative): FirstKey, as rep provider,
will only be obligated to repurchase a loan due to breaches prior
to the payment date in August 2021. Thereafter, a reserve fund will
be available to cover amounts due to noteholders for loans
identified as having rep breaches. Amounts on deposit in the
reserve fund as well as the increased level of subordination will
be available to cover additional defaults and losses resulting from
rep weaknesses or breaches occurring on or after the payment date
in August 2021.

No Servicer P&I Advances (Mixed): The servicers will not be
advancing delinquent monthly payments of P&I, which reduces
liquidity to the trust. P&I advances made on behalf of loans that
become delinquent and eventually liquidate reduce liquidation
proceeds to the trust. Due to the lack of P&I advancing, the
loan-level loss severity is less for this transaction than for
those where the servicer is obligated to advance P&I. Structural
provisions and cash flow priorities, together with increased
subordination, provide for timely payments of interest to the
'AAAsf' and 'AAsf' rated classes.

Sequential-Pay 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 notes prior to other principal
distributions is highly supportive of timely interest payments to
that class in the absence of servicer advancing.

Deferred Amounts (Negative): Non-interest-bearing principal
forbearance amounts totaling $61 million (4%) of the UPB are
outstanding on 2,656 loans. Fitch included the deferred amounts
when calculating the borrower's loan-to-value ratio and sustainable
LTV, despite the lower payment and amounts not being owed during
the term of the loan. The inclusion resulted in a higher
probability of default and LS than if there were no deferrals.
Fitch believes that borrower default behavior for these loans will
resemble that of the higher LTVs, as exit strategies (i.e. sale or
refinancing) will be limited relative to those borrowers with more
equity in the property.

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 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 39.5% 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 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.

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

Fitch's analysis incorporated three criteria variations from its
"U.S. RMBS Rating Criteria."

The first variation relates to the tax/title review. The tax/title
review was outdated (over six months ago) on 10% of the reviewed
loans by loan count. Approximately 94% of the sample loans were
reviewed within 12 months and the remaining loans were reviewed
more than 12 month ago. Additionally, the servicers are monitoring
the tax and title status as part of standard practice and will
advance where deemed necessary to keep the first lien position of
each loan. This variation had no rating impact.

The second variation is that a due diligence compliance and data
integrity review was not completed on approximately 36% of the pool
by loan count. The sample meets Fitch's criteria for second liens
and SPL loans as 31% of the second liens and 48% of the SPL loans
were reviewed (the criteria allows for a 20% sample). Fitch defines
SPL as loans that are seasoned over 24 months, have not been
modified and have had no more one 30-day delinquency in the prior
24 months but are current as of the cutoff date. A criteria
variation was applied for the RPL loans. 44% of the pool is
categorized as RPL, and Fitch's criteria expects 100% review for
RPL loans (90% was reviewed). The loans in the pool are
predominately from two sources with nearly 80% of the loans in the
pool from a single source. Of the loans reviewed, only about 1.5%
had findings which Fitch made an adjustment for in its analysis
and, therefore, Fitch believes the sample does not introduce
additional operational risk to the transaction.

Additionally, 2% of the pool consists of new origination (loans
seasoned less than 24 month) and a credit and valuation review was
not completed for these loans. While a full credit review was not
completed, the ATR status was checked and updated values were
provided in lieu of a valuations review. This variation had no
rating impact.

The third variation relates to the pay history review. For RPL
transactions, Fitch expects a pay history review to be completed on
100% of the loans and expects the review to reflect the past 24
months. The pay history sample completed on the newly originated
loans, the SPL and second liens meet's Fitch's criteria. A pay
history review was either not completed, was outdate or a pay
string was not received from the servicer for approximately 10% of
the RPL loans. As nearly 80% of the loans are from a single source,
Fitch believes the sample does not introduce additional operational
risk to the transaction.

In addition, the loans are approximately 12.5 years seasoned and
73% of the pool has been paying on time for the past 24 months. For
the loans where a pay history review was conducted, the results
verified what was provided on the loan tape. Additionally, the pay
strings that were provided on the loan tape were provided by the
current servicer where applicable. This variation had no rating
impact.

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

A third-party regulatory compliance review was completed on
approximately 64% of the loans (by loan count) in the transaction
pool. The sample meets Fitch's criteria for second liens and SPL
loans. 31% of the second liens and 48% of the SPL loans were
reviewed, which meets Fitch's criteria as the criteria allows for a
20% sample. Fitch defines SPL as loans that are seasoned over 24
months, have not been modified and have had no more one 30-day
delinquency in the prior 24 months but are current as of the cutoff
date.

A criteria variation was applied for the RPL and newly originated
loans. 44% of the pool is categorized as RPL by Fitch, and criteria
expects 100% review for RPL loans (90% was reviewed). The loans in
the pool are predominately from two sources with close to 80% of
the loans in the pool from a single source. Of the loans reviewed,
only about 1.5% had findings, which Fitch made an adjustment for in
its analysis and therefore Fitch believes the sample does not
introduce additional operational risk to the transaction.

Additionally, 2% of the pool consists of new origination (loans
seasoned less than 24 month) and a credit and valuation review was
not completed for these loans. While a full credit review was not
completed, the ATR status was checked and updated values were
provided in lieu of a valuations review.

1,147, or about 9% of the pool (14% of the reviewed loans) were
assigned a grade of 'C' or 'D'. The diligence results indicated
similar operational risk to prior TPMT transactions as well as
other Fitch-reviewed RPL transactions.

For 163 of the 'C' or 'D' grades, Fitch adjusted its loss
expectation to reflect the missing documents that prevented the
testing for predatory lending compliance and the missing
modification agreements. The inability to test for predatory
lending may expose the trust to potential assignee liability, which
creates added risk for bond investors. Fitch make and adjustment
for loan modification agreements identified as pending receipt in
the custodial report. For this pool, 2,126 were identified as such,
however all but 452 of the loans had imaged LMAs in their
respective servicing file and were used by the TPRs to facilitate
the modification review and capture the modified loan repayment
terms. Fitch believes that the imaged files are sufficient to
demonstrate the borrower's contractual obligations under the terms
of the LMA and unlikely to materially delay or prevent
enforceability.

Fitch adjusted its loss expectation at the 'AAAsf' rating stress by
approximately 10 bps to reflect the additional risks.

The remaining 984 loans graded 'C' or 'D' were due to missing Final
HUD1's that are not subject to predatory lending, missing state
disclosures, and other compliance related missing documents. Fitch
believes these issues do not add material risk to bondholders since
the statute of limitations has expired. No adjustment to loss
expectations were made for these 984 loans.

Fitch received certifications indicating that due diligence was
conducted in accordance with its published standards for
legal/regulatory compliance. The certifications also stated that
the companies performed their work in accordance with the
independence standards, per Fitch's "U.S. RMBS Rating Criteria."
The due diligence analysts performing the reviews met Fitch's
criteria of minimum years of experience.

Form 'ABS Due Diligence 15E' was received from each of the TPR
firms. The 15E forms were reviewed and used as a part of the rating
for this transaction.

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).


UBS COMMERCIAL 2012-C1: Moody's Lowers Class F Certs to C
---------------------------------------------------------
Moody's Investors Service affirmed the ratings on six classes and
downgraded the ratings on four classes in UBS Commercial Mortgage
Trust 2012-C1, Commercial Mortgage Pass-Through Certificates,
Series 2012-C1 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Feb 25, 2020 Affirmed Aaa
(sf)

Cl. A-AB, Affirmed Aaa (sf); previously on Feb 25, 2020 Affirmed
Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on Feb 25, 2020 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa1 (sf); previously on Feb 25, 2020 Affirmed Aa1
(sf)

Cl. C, Affirmed A1 (sf); previously on Feb 25, 2020 Affirmed A1
(sf)

Cl. D, Downgraded to Ba2 (sf); previously on Apr 17, 2020 Baa2 (sf)
Placed Under Review for Possible Downgrade

Cl. E, Downgraded to Caa2 (sf); previously on Apr 17, 2020 B2 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Downgraded to C (sf); previously on Apr 17, 2020 Caa3 (sf)
Placed Under Review for Possible Downgrade

Cl. X-A*, Affirmed Aaa (sf); previously on Feb 25, 2020 Affirmed
Aaa (sf)

Cl. X-B*, Downgraded to Caa1 (sf); previously on Apr 17, 2020 B3
(sf) Placed Under Review for Possible Downgrade

*Reflects Interest-Only Classes

RATINGS RATIONALE

The ratings on five of the P&I classes were affirmed due to the
pool's share of defeasance and the transaction's key metrics,
including Moody's loan-to-value (LTV) ratio, Moody's stressed debt
service coverage ratio (DSCR) and the transaction's Herfindahl
Index (Herf), being within acceptable ranges.

The ratings on three P&I classes were downgraded due to higher
anticipated losses from a decline in pool performance, primarily
driven by the increase in specially serviced loans. The largest
specially serviced loan, the Poughkeepsie Galleria Mall (7.5% of
the pool), transferred to special servicing in April 2020 and was
experiencing deteriorating performance prior to the coronavirus
pandemic. Furthermore, the deal faces upcoming refinance risk with
all loans maturing prior to year-end 2022 and non-defeased hotel
and retail properties representing 15% and 38% of the pool,
respectively.

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

The rating on one IO Class, Class X-B, was downgraded due to a
decline in the credit quality of its referenced classes.

The actions conclude the review for downgrade initiated on April
17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 8.1% of the
current pooled balance, compared to 5.1% at Moody's last review.
Moody's base expected loss plus realized losses is now 6.6% of the
original pooled balance, compared to 4.3% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except interest-only
classes were "Approach to Rating US and Canadian Conduit/Fusion
CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 12th, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 24% to $1.02 billion
from $1.33 billion at securitization. The certificates are
collateralized by 65 mortgage loans ranging in size from less than
1% to 7.5% of the pool, with the top ten loans (excluding
defeasance) constituting 34% of the pool. Twenty-four loans,
constituting 48% 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 15, the same as at Moody's last review.

As of the June 2020 remittance report, loans representing 86% of
the pool were current or within their grace period on their debt
service payments, 4% were beyond their grace period but less than
30 days delinquent and 9% were 60+ days delinquent.

Six loans, constituting 9% of the pool, are on the master
servicer's watchlist, of which one loan, representing 1% of the
pool, indicate the borrower has requested relief in relation to
coronavirus impact on the property. The watchlist includes loans
that meet certain portfolio review guidelines established as part
of the CRE Finance Council (CREFC) monthly reporting package. As
part of Moody's ongoing monitoring of a transaction, the agency
reviews the watchlist to assess which loans have material issues
that could affect performance.

One loan has been liquidated from the pool, resulting in an
aggregate realized loss of $5.0 million (for a loss severity of
33.5%). Five loans, constituting 11% of the pool, are currently in
special servicing.

The largest specially serviced loan is the Poughkeepsie Galleria
($76.7 million -- 7.5% of the pool), which represents a pari-passu
portion of $139.4 million senior mortgage. The loan is also
encumbered by $21 million of mezzanine debt. The loan is secured by
a 691,000 square foot (SF) portion of a 1.2 million SF regional
mall located about 70 miles north of New York City in Poughkeepsie,
New York. The mall's anchors included J.C. Penney, Regal Cinemas,
and Dick's Sporting Goods, each part of the collateral, and Macy's,
Best Buy, Target and Sears (non-collateral anchors). However, Sears
(145,000 SF) announced plans to vacate in February 2020 and J.C.
Penney (180,000 SF) recently announced plans to close this location
as part their Chapter 11 bankruptcy filing. As of the December 2019
rent roll the total mall was 92% leased, however, this would drop
to 59% upon the Sears and J.C. Penney departures. The mall has also
suffered from declining in-line space occupancy and tenant sales.
As of December 2019, the inline occupancy (10,000 SF) was only 69%
occupied and potential co-tenancy provisions from multiple anchor
closures may further impact inline performance. The property's net
operating income (NOI) has also continued to decline from
securitization with the 2019 NOI nearly 28% lower than in 2011. The
property is managed by the loan's sponsor, Pyramid Management
Group, LLC and the loan transferred to special servicing in April
2020 at the borrower's request as a result of the Covid-19 pandemic
and is last paid through its March 2020 payment date. The loan has
amortized 10% since securitization and matures in November 2021,
however, as a result of the declining performance, multiple anchor
closures and the current retail environment the loan may face
increased term and refinance risk.

The second largest specially serviced loan is the Westminster
Square Loan ($16.2 million -- 1.6% of the pool), which is secured
by a 194,703 SF office building located in Providence, RI. The loan
was transferred to the special servicer in October 2019 due to
declines in occupancy. As of December 2019, the property was 72%
occupied compared to 82% in December 2018. The special servicer
indicated a pre-negotiation letter was executed and negotiations
are currently underway. The loan is last paid through its March
2020 payment date and is currently 60+ days delinquent.

The third largest specially serviced loan is the Action Hotel
Portfolio Loan ($13.9 million -- 1.4% of the pool), which is
secured by three cross-collateralized and cross-defaulted
limited-service hotels located in Syracuse, NY. The hotels total
247-rooms and operate under a Holiday Inn Express franchise. The
portfolio's NOI has been declining year-over-year since 2015. The
loan transferred to the special servicer in March 2020 at
borrowers' request as a result of the Covid-19 pandemic. The loan
is current through its June 2020 payment date and the special
servicer has noted that they will to monitor the loan as the
borrower continues to make payments.

Moody's has also assumed a high default probability for one poorly
performing loan secured by a poorly performing unanchored retail
center, constituting 0.2% of the pool.

Moody's received full year 2018 operating results for 100% of the
pool, and full or partial year 2019 operating results for 92% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 92%, compared to 89% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 19% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 9.8%.

Moody's actual and stressed conduit DSCRs are 1.39X and 1.26X,
respectively, compared to 1.42X and 1.28X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 15% of the pool balance. The
largest loan is the Hartford 21 Loan ($68.1 million -- 6.7% of the
pool), which is secured by Class A mixed-use
multi-family/office/retail development located in center city
Hartford, Connecticut. The property includes a 36-story residential
component with 262-units and a 3-story commercial component with
both buildings containing ground floor retail. As of December 2019,
the residential, office, and retail portions were 96%, 46%, and 47%
leased, respectively, compared to 91%, 46%, and 49% leased in
December 2017. The residential portion has historically contributed
over 70% of the property's rental revenue. The loan has amortized
9.1% since securitization. Moody's LTV and stressed DSCR are 126%
and 0.78X, respectively the same as at the last review.

The second largest loan is the Bridgewater Falls Loan ($52.8
million -- 5.2% of the pool), which is secured by a retail power
center constructed in phases from 2005-2011. The property consists
of ten, one-story buildings with a total collateral net rentable
area (NRA) of 389,062 SF, as well as five ground-leased outparcels
with improvements totaling an additional 119,094 SF. The property
is anchored by JCPenney (98,250 SF, non- collateral), Dick's
Sporting Goods (50,000 SF), TJ Maxx (32,000 SF), Best Buy (30,000
SF), Bed Bath & Beyond (29,494 SF), and Michaels (22,433 SF).
Additionally, the property is shadow anchored by a 123,700 SF
Target. As of the December 30, 2019 rent roll the property was 94%
leased compared to 90% in December 2018. However, the property
faces significant near-term rollover risk with Dick's Sporting
Goods, TJ Maxx, Best Buy and Bed Bath and Beyond all having lease
expiration dates on January 31, 2021. The loan is current through
its June 2020 payment date and Moody's LTV and stressed DSCR are
114% and 0.93X, respectively, compared to 93% and 1.08X at the last
review.

The third largest loan is the Tharaldson Hotel Portfolio Loan
($33.5 million -- 3.3% of the pool), which is secured by five
cross-collateralized and cross-defaulted limited-service hotels,
consisting of 533-rooms. Four of the properties operate under a
Marriott franchise while the remaining property operates under a
Hilton franchise. The portfolio is concentrated in California with
one of the hotels is in Dayton, OH. The portfolios 2019 NOI
declined to $9.2 million in December 2019 from $10.4 million in
December 2018 but remains significantly above securitization
levels. The loan has also amortized 17% since securitization and is
current through its June 2020 payment date. Moody's LTV and
stressed DSCR are 73% and 1.66X, respectively.


UBS-CITIGROUP COMMERCIAL 2011-C1: Moody's Cuts Class G Certs to C
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on six classes and
downgraded the ratings on five classes in UBS-Citigroup Commercial
Mortgage Trust 2011-C1, Commercial Mortgage Pass-Through
Certificates, Series 2011-C1 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Feb 24, 2020 Affirmed Aaa
(sf)

Cl. A-AB, Affirmed Aaa (sf); previously on Feb 24, 2020 Affirmed
Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on Feb 24, 2020 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa1 (sf); previously on Feb 24, 2020 Affirmed Aa1
(sf)

Cl. C, Affirmed A1 (sf); previously on Feb 24, 2020 Affirmed A1
(sf)

Cl. D, Downgraded to Ba1 (sf); previously on Apr 17, 2020 A3 (sf)
Placed Under Review for Possible Downgrade

Cl. E, Downgraded to B3 (sf); previously on Apr 17, 2020 Ba3 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Downgraded to Caa3 (sf); previously on Apr 17, 2020 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. G, Downgraded to C (sf); previously on Apr 17, 2020 Caa3 (sf)
Placed Under Review for Possible Downgrade

Cl. X-A*, Affirmed Aaa (sf); previously on Feb 24, 2020 Affirmed
Aaa (sf)

Cl. X-B*, Downgraded to Caa1 (sf); previously on Apr 17, 2020 B3
(sf) Placed Under Review for Possible Downgrade

*Reflects Interest-Only Classes

RATINGS RATIONALE

The ratings on five of the P&I classes were affirmed due to the
pool's share of defeasance and the transaction's key metrics,
including Moody's loan-to-value (LTV) ratio, Moody's stressed debt
service coverage ratio (DSCR) and the transaction's Herfindahl
Index (Herf), being within acceptable ranges.

The ratings on four P&I classes were downgraded due to higher
anticipated losses and a decline in pool performance primarily
driven by the increase in specially serviced loans secured by hotel
and regional mall properties. The Poughkeepsie Galleria Mall (15%
of the pool) and Marriott Buffalo Niagara (5%) transferred to
special servicing in April 2020 and were both experiencing
deteriorating performance prior to the coronavirus pandemic.
Furthermore, the deal faces upcoming refinance risk with all loans
maturing prior to year-end 2021 with non-defeased hotel and retail
loans representing 20% and 29% of the pool, respectively.

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

The rating on one IO Class, Class X-B, was downgraded due to a
decline in the credit quality of its referenced classes.

The actions conclude the review for downgrade initiated on April
17, 2020.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 15.6% of the
current pooled balance, compared to 8.2% at Moody's last review.
Moody's base expected loss plus realized losses is now 9.4% of the
original pooled balance, compared to 5.0% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except interest-only
classes were "Approach to Rating US and Canadian Conduit/Fusion
CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 12, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 40% to $406.7
million from $673.9 million at securitization. The certificates are
collateralized by 25 mortgage loans ranging in size from less than
1% to 15% of the pool, with the top ten loans (excluding
defeasance) constituting 50% of the pool. Ten loans, constituting
43% of the pool, have defeased and are secured by US government
securities.

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

As of the June 2020 remittance report, loans representing 72% were
current or within their grace period on their debt service
payments, 4% were beyond their grace period but less than 30 days
delinquent and 5% were between 30 -- 59 days delinquent and 19%
were 60 days delinquent.

Six loans, constituting 18% of the pool, are on the master
servicer's watchlist, of which one loan, representing 4% of the
pool, indicate the borrower has requested relief in relation to
coronavirus impact on the property. The watchlist includes loans
that meet certain portfolio review guidelines established as part
of the CRE Finance Council (CREFC) monthly reporting package. As
part of Moody's ongoing monitoring of a transaction, the agency
reviews the watchlist to assess which loans have material issues
that could affect performance.

One loan has been liquidated from the pool, resulting in a minimal
loss of $81,661 (for a loss severity of 1.2%). Two loans,
constituting 21% of the pool, are currently in special servicing
and each loan has transferred after March 2020 as a result of the
coronavirus impact.

The largest specially serviced loan is the Poughkeepsie Galleria
($62.7 million -- 15.4% of the pool), which represents a pari-passu
portion of $139.4 million senior mortgage. The loan is also
encumbered by $21 million of mezzanine debt. The loan is secured by
a 691,000 square foot (SF) portion of a 1.2 million SF regional
mall located about 70 miles north of New York City in Poughkeepsie,
New York. The mall's anchors included J.C. Penney, Regal Cinemas,
and Dick's Sporting Goods, each part of the collateral, and Macy's,
Best Buy, Target and Sears (non-collateral anchors). However, Sears
(145,000 SF) announced plans to vacate in February 2020 and J.C.
Penney (180,000 SF) recently announced plans to close this location
as part of their Chapter 11 bankruptcy filing. As of the December
2019 rent roll the total mall was 92% leased, however, this would
drop to 59% upon the Sears and J.C. Penney departures. The mall has
also suffered from declining in-line space occupancy and tenant
sales. As of December 2019, the inline occupancy (10,000 SF) was
only 69% occupied and potential co-tenancy provisions from multiple
anchor closures may further impact inline performance. The
property's net operating income (NOI) has also continued to decline
from securitization with the 2019 NOI nearly 28% lower than in
2011. The property is managed by the loan's sponsor, Pyramid
Management Group, LLC and the loan transferred to special servicing
in April 2020 at the borrower's request as a result of the Covid-19
pandemic. The loan has is last paid through its March 2020 payment
dat.The loan amortized 10% since securitization and matures in
November 2021, however, as a result of the declining performance,
multiple anchor closures and the current retail environment the
loan may face increased term and refinance risk.

The other specially serviced loan is the Marriott Buffalo Niagara
($22.0 million -- 5.4% of the pool), which is secured by the
borrower's fee simple interest in a 356-room full-service hotel
located in Amherst, NY. Hotel amenities include 11,476 SF of
flexible meeting space, one restaurant, fitness center, outdoor
swimming pool, business center and gift shop. The property's
revenue per available room (RevPAR) has annually declined over the
past four years. As a result, the NOI for the trailing-twelve-month
period ending September 2019 was $3.1 million, down 9% from
year-end 2018 and 44% from 2011. In April 2020 the loan transferred
to the special servicer after the borrower requested debt relief
due to the COVID-19 pandemic. The loan has amortized 12% since
securitization and is last paid through its April 2020 payment
date. The special servicer is currently assessing the loan
performance and potential resolutions.

Moody's has also assumed a high default probability for two poorly
performing loans, constituting 6.9% of the pool. The largest
troubled loan is the Hospitality Specialists Portfolio -- Pool 2
($18.1 million -- 4.5% of the pool) and is discussed further in
detail. The other troubled loan is the Plaza Mall of Georgia --
Phase II Portfolio (2.5% of the pool) which is secured by a 106,437
SF anchored shopping center located in Buford, GA. Since 2018, the
property's performance has struggled due to occupancy issues after
the largest tenant, Toy's R' Us (70,000 SF; 66% NRA) vacated. The
borrower has been working to lease up the vacant space and as of
year-end 2019 the property was 66% leased.

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 97%, compared to 89% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 23% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 10.3%.

Moody's actual and stressed conduit DSCRs are 1.25X and 1.19X,
respectively, compared to 1.43X and 1.36X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's
s actual debt service. Moody's stressed DSCR is based on Moody's
NCF and a 9.25% stress rate the agency applied to the loan
balance.

The top three performing loans represent 13% of the pool balance.
The largest loan is the Doubletree Chattanooga Loan ($18.3 million
-- 4.5% of the pool), which is secured by a 13-story, 186 room
full-service hotel in Chattanooga, TN. The property is located in
the Chattanooga central business district and is less than one mile
to both the Chattanooga Convention Center and the University at
Chattanooga. The property performance has declined in recent years
due to higher operating expenses and lower revenue. The loan has
amortized 20% since securitization and despite the decline in
performance in 2019, the actual NOI DSCR was 1.57X. The loan is
current through its June 2020 payment date and matures in June
2021. Moody'Moody'ss LTV and stressed DSCR are 99% and 1.20X,
respectively, compared to 82% and 1.41X at the last review.

The second largest loan is the Hospitality Specialists Portfolio --
Pool 2 ($18.1 million -- 4.5% of the pool) which is secured by a
portfolio of three select-service hotels totaling 257 rooms. Two of
the properties are in Moline, IL (one Hilton and one Marriott flag)
and one property is in Stevensville, MI (Hilton). The portfolio has
realized a significant decline in NOI over the past year, with the
2019 NOI dropping nearly 20% as compared to 2018. The portfolio's
occupancy and revenue per available room (RevPAR) was 63% and $73,
respectively, for the year-ending 2019. The decline in performance
was largely driven by the Stevensville, MI property due to
seasonality issues and an additional two competing properties added
to the market in 2019. The loan is last paid through its May 2020
payment date and due to the recent decline in performance, Moody's
has identified this as a troubled loan.

The third largest loan is the 560 Lincoln Road Loan ($17.5 million
-- 4.3% of the pool), which is secured by a mixed-use retail/office
building built in 1929 and renovated in 2000. The property is
located at the southeast corner of Lincoln Road Mall and
Pennsylvania Avenue in Miami Beach, FL. In late 2018, an office
tenant (Wall Street Languages - 26% of the total NRA and 48% of
office space), vacated the property leading to a decline in
occupancy. As of December 2019, the property was 57% leased,
compared to 66% in 2018 and 93% in 2017. However, servicer
commentary indicated the property had benefitted from recent
leasing in late 2019 that should increase the occupancy to 71%.
Moody's LTV and stressed DSCR are 85% and 1.12X, respectively,
compared to 62% and 1.48X at the last review.


WELLS FARGO 2020-3: Fitch to Rate Class B-5 Debt 'B+(EXP)sf'
------------------------------------------------------------
Fitch Ratings expects to rate Wells Fargo Mortgage-Backed
Securities 2020-3 Trust.

WFMBS 2020-3

  - Class A-1; 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-10; LT AAA(EXP)sf Expected Rating

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

TRANSACTION SUMMARY

The certificates are supported by 671 prime fixed-rate mortgage
loans with a total balance of approximately $522.9 million as of
the cutoff date. All of the loans were originated by Wells Fargo
Bank, N.A or were acquired from its correspondents. This is the
eighth post-crisis issuance from Wells Fargo.

KEY RATING DRIVERS

Revised GDP Due to COVID-19 (Negative): COVID-19 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 COVID-19, 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 COVID-19 (Negative): The
outbreak of COVID-19 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 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 delinquencies and
past-due payments following Hurricane Maria in Puerto Rico.

Payment Forbearance (Mixed): As of the cutoff date, none of the
borrowers in the pool are on a COVID-19 forbearance plan.
Additionally, any loan that enters a COVID-19 forbearance plan
between the cutoff date and prior to or on the closing date will be
removed from the pool (at par) within 30 days of closing. For
borrowers who enter a COVID-19 forbearance plan post-closing, the
P&I advancing party will advance delinquent P&I during the
forbearance period. If at the end of the forbearance period the
borrower begins making payments, the advancing party will be
reimbursed from any catch-up payment amount.

If the borrower doesn't resume making payments, the loan will
likely become modified and the advancing party will be reimbursed
from available funds. Fitch increased its loss expectations by 10
bps for the 'BB+sf' ratings categories and below to address the
potential for write-downs due to reimbursements of servicer
advances. This increase is based on a servicer reimbursement
scenario analysis which incorporated collateral similar to WFMBS
2020-3. Fitch did not adjust its loss expectations above 'BB+sf"
because the agency's model output levels were sufficiently lower
than its loss floors for 30-year collateral.

Full Servicer Advancing (Neutral): The pool benefits from advances
of delinquent P&I until the servicer, Wells Fargo, the primary
servicer of the pool, deems them non-recoverable. Fitch's loss
severities reflect reimbursement of amounts advanced by the
servicer from liquidation proceeds based on its liquidation
timelines assumed at each rating stress. In addition, the credit
enhancement for the rated classes has some cushion for recovery of
servicer advances for loans that are modified following a payment
forbearance.

Very High-Quality Mortgage Pool (Positive): The collateral
attributes are among the strongest of post-crisis RMBS rated by
Fitch. The pool consists primarily of 30-year fixed-rate fully
amortizing loans to borrowers with strong credit profiles, low
leverage and large liquid reserves. All loans are Safe Harbor
Qualified Mortgages. The loans are seasoned an average of 7.1
months.

The pool has a weighted average original FICO score of 774, which
is indicative of very high credit-quality borrowers. Approximately
82% has original FICO scores at or above 750. In addition, the
original WA CLTV ratio of 70.6% represents substantial borrower
equity in the property. The pool's attributes, together with Wells
Fargo's sound origination practices, support Fitch's very low
default risk expectations.

High Geographic Concentration (Negative): Approximately 49% of the
pool is concentrated in California with a relatively low MSA
concentration. The largest MSA concentration is in New York MSA
(19.3%) followed by the San Francisco MSA (18.9%) and the Los
Angeles MSA (10.5%). The top three MSAs account for 48.9% of the
pool. As a result, an additional penalty of approximately 7% was
applied to the pool's lifetime default expectations.

Low Operational Risk (Positive): Operational risk is very well
controlled for in this transaction. Wells Fargo has an extensive
operating history in residential mortgage originations and is
assessed as an 'Above Average' originator by Fitch. The entity has
a diversified sourcing strategy and utilizes an effective
proprietary underwriting system for its retail originations. Wells
Fargo will perform primary and master servicing for this
transaction; these functions are rated 'RPS1-' and 'RMS1-',
respectively, which are among Fitch's highest servicer ratings.
Each of these servicers were moved to Outlook Negative from Outlook
Stable due to the changing economic landscape. The expected losses
at the 'AAAsf' rating stress were reduced by approximately 58 bps
to reflect these strong operational assessments.

Tier 2 R&W (Representations and Warranties) Framework (Neutral):
While the loan-level R&Ws for this transaction are substantially in
conformity with Fitch criteria, the framework has been assessed as
a Tier 2 due to the narrow testing construct which limits the
breach reviewers ability to identify or respond to issues not fully
anticipated at closing. The Tier 2 assessment and the strong
financial condition of Wells Fargo as the R&W provider resulted in
a neutral impact to the CE. In response to the coronavirus, and in
an effort to focus breach reviews on loans that are more likely to
contain origination defects that let to or contributed to the
delinquency of the loan, Wells Fargo added additional carve-out
language relating to the delinquency review trigger for certain
Disaster Mortgage Loans that are modified or delinquent due to
disaster related loss mitigation (including the coronavirus
pandemic). This is discussed further in the Asset Analysis
section.

Due Diligence Review Results (Positive): Third-party due diligence
was performed on 100% of loans in the transaction pool. The review
was performed by Clayton, which is assessed by Fitch as an
'Acceptable - Tier 1' TPR firm. 99.7% of the loans received a final
grade of 'A' or 'B' which reflects strong origination practices.
Loans with a final grade of 'B' were supported with sufficient
compensating factors or were already accounted for in Fitch's loan
loss model. The two remaining loans received a final due diligence
grade of 'C' that reflected a material property valuation exception
where the secondary review value yielded a negative variance larger
than 10% of the original appraisal value. Fitch applied the lower
of the values to calculate the LTV. The adjustment did not have a
material impact on the expected loss levels. Loans with due
diligence receive a credit in the loss model; the aggregate
adjustment reduced the 'AAAsf' expected losses by 14 bps.

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

To mitigate tail risk, which arises as the pool seasons and fewer
loans are outstanding, a subordination floor of 0.90% of the
original balance will be maintained for the senior certificates.

Extraordinary Expense Treatment (Neutral): The trust provides for
expenses, including indemnification amounts, reviewer fees and
costs of arbitration, to be paid by the net WA coupon of the loans,
which does not affect the contractual interest due on the
certificates. Furthermore, the expenses to be paid from the trust
are capped at $350,000 per annum, with the exception of independent
reviewer breach review fee, which can be carried over each year,
subject to the cap until paid in full.

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 a
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 38.5% 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.

Factors that could, individually or collectively, lead to a
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%. 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 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.

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.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Clayton Services LLC. The third-party due diligence
described in Form 15E focused on a compliance review, credit review
and valuation review. The due diligence company performed a review
on 100% of the loans. Fitch believes the overall results of the
review generally reflected strong underwriting control.

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

WFMBS 2020-3: Transaction Parties & Operational Risk: 4

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 2020-3: Moody's Gives (P)Ba3 Rating on Class B-5 Debt
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to 25
classes of residential mortgage-backed securities issued by Wells
Fargo Mortgage Backed Securities 2020-3 Trust. The ratings range
from (P)Aaa (sf) to (P)Ba3 (sf).

WFMBS 2020-3 is the third prime issuance by Wells Fargo Bank, N.A.
(Wells Fargo Bank, the sponsor and mortgage loan seller) in 2020,
consisting of 671 primarily 30-year, fixed rate, prime residential
mortgage loans with an unpaid principal balance of $522,906,953.
The pool has strong credit quality and consists of borrowers with
high FICO scores, significant equity in their properties and liquid
cash reserves. The pool has clean pay history and weighted average
seasoning of approximately 5.06 months. The mortgage loans for this
transaction are originated by Wells Fargo Bank, through its retail
and correspondent channels, in accordance with its underwriting
guidelines. In this transaction, all 671 loans are designated as
qualified mortgages under the QM safe harbor rules. Wells Fargo
Bank will service all the loans and will also be the master
servicer for this transaction.

The securitization has a shifting interest structure with a
five-year lockout period that benefits from a senior floor and a
subordinate floor. Moody's coded the cash flow to each of the
certificate classes using Moody's proprietary cash flow tool.

The complete rating actions are as follows:

Issuer: Wells Fargo Mortgage Backed Securities 2020-3 Trust

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

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

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

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

Cl. A-5, Assigned (P)Aaa (sf)

Cl. A-6, Assigned (P)Aaa (sf)

Cl. A-7, Assigned (P)Aaa (sf)

Cl. A-8, Assigned (P)Aaa (sf)

Cl. A-9, Assigned (P)Aaa (sf)

Cl. A-10, Assigned (P)Aaa (sf)

Cl. A-11, Assigned (P)Aaa (sf)

Cl. A-12, Assigned (P)Aaa (sf)

Cl. A-13, Assigned (P)Aaa (sf)

Cl. A-14, Assigned (P)Aaa (sf)

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

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

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

Cl. A-18, Assigned (P)Aa1 (sf)

Cl. A-19, Assigned (P)Aaa (sf)

Cl. A-20, Assigned (P)Aaa (sf)

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

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

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

Cl. B-4, Assigned (P)Ba1 (sf)

Cl. B-5, Assigned (P)Ba3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected loss for this pool in a baseline scenario-mean is
0.22% and reaches 3.12% at a stress level consistent with its Aaa
ratings.

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of US RMBS from the collapse in the
US economic activity in the second quarter and a gradual recovery
in the second half of the year. However, that outcome depends on
whether governments can reopen their economies while also
safeguarding public health and avoiding a further surge in
infections.

The contraction in economic activity in the second quarter was
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
increased its model-derived median expected losses by 15% (9.06%
for the mean) and its Aaa losses by 5% to reflect the likely
performance deterioration resulting from of a slowdown in US
economic activity in 2020 due to the COVID-19 outbreak.

Moody's regards the COVID-19 outbreak as a social risk under its
ESG framework, given the substantial implications for public health
and safety.

Moody's bases its ratings on the certificates on the credit quality
of the mortgage loans, the structural features of the transaction,
its assessments of the origination quality and servicing
arrangement, the strength of the third-party due diligence and the
R&W framework of the transaction.

Collateral Description

The WFMBS 2020-3 transaction is a securitization of 671 first lien
residential mortgage loans with an unpaid principal balance of
$522,906,953. The loans in this transaction have strong borrower
characteristics with a weighted average original FICO score of 782
and a weighted-average original loan-to-value ratio of 70.4%. In
addition, 3.6% of the borrowers are self-employed, rate-and-term
refinance and cash-out loans comprise approximately 53.0% of the
aggregate pool (inclusive of construction to permanent loans). Of
note, 7.4% (by loan balance) of the pool comprised of construction
to permanent loans. The construction to permanent is a two-part
loan where the first part is for the construction and then it
becomes a permanent mortgage once the property is complete. For
such loans in the pool, the construction was complete and because
the borrower cannot receive cash from the permanent loan proceeds
or anything above the construction cost, Moody's treated these
loans as a rate term refinance rather than a cash out refinance
loan. The pool has a high geographic concentration with 49.2% of
the aggregate pool located in California and 19.4% located in the
New York-Newark-Jersey City MSA. The characteristics of the loans
underlying the pool are slightly stronger than recent prime RMBS
transactions backed by 30-year mortgage loans that Moody's has
rated.

Origination Quality

Wells Fargo Bank (long term debt Aa2) is an indirect, wholly-owned
subsidiary of Wells Fargo & Company (long term debt A2). Wells
Fargo & Company is a U.S. bank holding company with approximately
$1.98 trillion in assets and approximately 263,000 employees as of
March 31, 2020, which provides banking, insurance, trust, mortgage
and consumer finance services throughout the United States and
internationally.

Wells Fargo Bank has sponsored or has been engaged in the
securitization of residential mortgage loans since 1988. Wells
Fargo Home Lending is a key part of Wells Fargo & Company's
diversified business model. The mortgage loans for this transaction
are originated by WFHL, through its retail and correspondent
channels, generally in accordance with its underwriting guidelines.
The company uses a solid loan origination system which include
embedded features such as a proprietary risk scoring model,
role-based business rules and data edits that ensure the quality of
loan production. After considering the company's origination
practices, Moody's made no additional adjustments to its base case
and Aaa loss expectations for origination.

Third Party Review

One independent third-party review firm, Clayton Services LLC, was
engaged to conduct due diligence for the credit, regulatory
compliance, property valuation, and data accuracy for all 671 loans
in the initial population of this transaction (100% of the mortgage
pool). For an initial population of 693 loans, Clayton Services LLC
identified 545 loans level A, 146 loans level B and two (2) loans
of level C grade with its review. Most of the level B loans were
underwritten using underwriter discretion. Areas of discretion
included insufficient cash reserves, length of mortgage/rental
history, cash out amount exceeds guidelines, missing verbal
verification of employment and explanation for other multiple
credit exceptions. The due diligence firm noted that these
exceptions are minor and/or provided an explanation of compensating
factors. For these two (2) level C loans there are findings related
to property valuation review, because Clayton determined that the
appraisal value used in the origination of such mortgage loans was
not supported by field review within a negative 10% variance. These
two findings are disclosed in the transaction's PPM. Moody's ran an
additional sensitivity to take these valuation variances into
account which it ultimately concluded to be of a non-material
impact. In addition, with respect to these two-level C loans, the
property value per field review resulted in a LTV ratio which was
still within the parameters of Wells Fargo's underwriting
guidelines.

Representation & Warranties

Wells Fargo Bank, as the originator, makes the loan-level
representation and warranties for the mortgage loans. The
loan-level R&Ws are strong and, in general, either meet or exceed
the baseline set of credit-neutral R&Ws Moody's has identified for
US RMBS. Further, R&W breaches are evaluated by an independent
third party using a set of objective criteria to determine whether
any R&Ws were breached when loans become 120 days delinquent, the
property is liquidated at a loss above a certain threshold, or the
loan is modified by the servicer. Similar to J.P. Morgan Mortgage
Trust (JPMMT) transactions, the transaction contains a
"prescriptive" R&W framework. These reviews are prescriptive in
that the transaction documents set forth detailed tests for each
R&W that the independent reviewer will perform.

It should be noted that exceptions exist for certain excluded
disaster mortgage loans that trip the delinquency trigger. These
excluded disaster loans include COVID-19 forbearance loans or any
other loan with respect to which (a) the related mortgaged property
is located in an area that is subject to a major disaster
declaration by either the federal or state government and (b) has
either been modified or is being reported delinquent by the
servicer as a result of a forbearance, deferral or other loss
mitigation activity relating to the subject disaster. As excluded
disaster mortgage loans may be subject to a review in future
periods if certain conditions are satisfied.

Overall, Moody's believes that Wells Fargo Bank's robust processes
for verifying and reviewing the reasonableness of the information
used in loan origination along with effectively no knowledge
qualifiers mitigates any risks involved. Wells Fargo Bank has an
anti-fraud software tools that are integrated with the loan
origination system and utilized pre-closing for each loan. In
addition, Wells Fargo Bank has a dedicated credit risk, compliance
and legal teams oversee fraud risk in addition to compliance and
operational risks. Moody's did not make any additional adjustment
to its base case and Aaa loss expectations for R&Ws.

Tail Risk and Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
shrinks, senior bonds are exposed to increased performance
volatility, known as tail risk. The transaction provides for a
senior subordination floor of 0.90% of the closing pool balance,
which mitigates tail risk by protecting the senior bonds from
eroding credit enhancement over time. Additionally, there is a
subordination lock-out amount which is 0.90% of the closing pool
balance.

Moody's calculates the credit neutral floors for a given target
rating as shown in its principal methodology. The senior
subordination floor of 0.90% and subordinate floor of 0.90% are
consistent with the credit neutral floors for the assigned
ratings.

Transaction Structure

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

All certificates in this transaction are subject to a net WAC cap.
Realized losses are allocated reverse sequentially among the
subordinate and senior support certificates and on a pro-rata basis
among the super senior certificates.

Servicing Arrangement

In WFMBS 2020-3, unlike other prime jumbo transactions, Wells Fargo
Bank as servicer, master servicer, securities administrator and
custodian of all of the mortgage loans for the deal. The servicer
will be primarily responsible for funding certain servicing
advances and delinquent scheduled interest and principal payments
for the mortgage loans, unless the servicer determines that such
amounts would not be recoverable. The master servicer and servicer
will be entitled to be reimbursed for any such monthly advances
from future payments and collections (including insurance and
liquidation proceeds) with respect to those mortgage loans (see
also COVID-19 impacted borrowers' section for additional
information).

In the case of the termination of the servicer, the master servicer
must consent to the trustee's selection of a successor servicer,
and the successor servicer must have a net worth of at least $15
million and be Fannie or Freddie approved. The master servicer
shall fund any advances that would otherwise be required to be made
by the terminated servicer (to the extent the terminated servicer
has failed to fund such advances) until such time as a successor
servicer is appointed. Additionally, in the case of the termination
of the master servicer, the trustee will be required to select a
successor master servicer in consultation with the depositor. The
termination of the master servicer will not become effective until
either the trustee or successor master servicer has assumed the
responsibilities and obligations of the master servicer which also
includes the advancing obligation.

After considering Wells Fargo Bank's servicing practices, Moody's
did not make any additional adjustment to its losses.

COVID-19 Impacted Borrowers

As of the cut-off date, no borrower under any mortgage loan has
entered into a COVID-19 related forbearance plan with the servicer.
The mortgage loan seller will covenant in the mortgage loan
purchase agreement to repurchase at the repurchase price within 30
days of the closing date any mortgage loan with respect to which
the related borrower requests or enters into a COVID-19 related
forbearance plan after the cut-off date but on or prior to the
closing date. In the event that after the closing date a borrower
enters into or requests a COVID-19 related forbearance plan, such
mortgage loan (and the risks associated with it) will remain in the
mortgage pool.

In the event the servicer enters into a forbearance plan with a
COVID-19 impacted borrower of a mortgage loan, the servicer will
report such mortgage loan as delinquent (to the extent payments are
not actually received from the borrower) and the servicer will be
required to make advances in respect of delinquent interest and
principal (as well as servicing advances) on such loan during the
forbearance period (unless the servicer determines any such
advances would be a nonrecoverable advance). At the end of the
forbearance period, if the borrower is able to make the current
payment on such mortgage loan but is unable to make the previously
forborne payments as a lump sum payment or as part of a repayment
plan, the servicer anticipates it will modify such mortgage loan
and any forborne amounts will be deferred as a non-interest bearing
balloon payment that is due upon the maturity of such mortgage
loan.

At the end of the forbearance period, if the borrower repays the
forborne payments via a lump sum or repayment plan, advances will
be recovered via the borrower payment(s). In an event of
modification, Wells Fargo Bank will recover advances made during
the period of Covid-19 related forbearance from pool level
collections.

Any principal forbearance amount created in connection with any
modification (whether as a result of a COVID-19 forbearance or
otherwise) will result in the allocation of a realized loss and to
the extent any such amount is later recovered, will result in the
allocation of a subsequent recovery.

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

Down

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

Up

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

Methodology

The principal methodology used in these ratings was "Moody's
Approach to Rating US RMBS Using the MILAN Framework" published in
April 2020.


WFRBS COMMERCIAL 2013-C13: Moody's Confirms B2 Rating on F Certs
----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings on nine classes
and confirmed the ratings on two classes in WFRBS Commercial
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2013-C13 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Jul 22, 2019 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Jul 22, 2019 Affirmed Aaa
(sf)

Cl. A-S, Affirmed Aaa (sf); previously on Jul 22, 2019 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Jul 22, 2019 Affirmed
Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Jul 22, 2019 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on Jul 22, 2019 Affirmed A3
(sf)

Cl. D, Affirmed Baa3 (sf); previously on Jul 22, 2019 Affirmed Baa3
(sf)

Cl. E, Confirmed at Ba2 (sf); previously on Apr 17, 2020 Ba2 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Confirmed at B2 (sf); previously on Apr 17, 2020 B2 (sf)
Placed Under Review for Possible Downgrade

Cl. X-A*, Affirmed Aaa (sf); previously on Jul 22, 2019 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed A2 (sf); previously on Jul 22, 2019 Affirmed A2
(sf)

* Reflects interest-only classes

RATINGS RATIONALE

The ratings on seven P&I classes were affirmed and the ratings on
two P&I classes were confirmed due to the pool's share of
defeasance and the transaction's key metrics, including Moody's
loan-to-value ratio, Moody's stressed debt service coverage ratio
and the transaction's Herfindahl Index, being within acceptable
ranges.

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

The rapid spread of the coronavirus outbreak, the government
measures put in place to contain it and the deteriorating global
economic outlook, have created a severe and extensive credit shock
across sectors, regions and markets. Its analysis has considered
the effect on the performance of commercial real estate from the
collapse in US economic activity in the second quarter and a
gradual recovery in the second half of the year. However, that
outcome depends on whether governments can reopen their economies
while also safeguarding public health and avoiding a further surge
in infections. 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. 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.

Moody's rating action reflects a base expected loss of 2.2% of the
current pooled balance, compared to 1.5% at Moody's last review.
Moody's base expected loss plus realized losses is now 1.7% of the
original pooled balance, compared to 1.2% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in rating all classes except
interest-only classes was "Approach to Rating US and Canadian
Conduit/Fusion CMBS" published in May 2020.

DEAL PERFORMANCE

As of the June 17, 2020 distribution date, the transaction's
aggregate certificate balance has decreased by 22% to $682 million
from $877 million at securitization. The certificates are
collateralized by 83 mortgage loans ranging in size from less than
1% to 12% of the pool, with the top ten loans (excluding
defeasance) constituting 39% of the pool. Eighteen loans,
constituting 6.8% of the pool, have investment-grade structured
credit assessments. Ten loans, constituting 22.1% 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 21, compared to 25 at Moody's last review.

As of the June 2020 remittance report, loans representing 93% were
current or within their grace period on their debt service
payments, 3% were beyond their grace period but less than 30 days
delinquent and 2% were between 30 -- 59 days delinquent.

Nineteen loans, constituting 12.6% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council 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.

There have been no loans liquidated from the pool. One loan,
constituting less than 1% of the pool, is currently in special
servicing. The specially serviced loan is the Staybridge Suites
Stafford loan ($5.9 million), which is secured by a 90-room
extended stay hotel in Stafford, Texas. The loan had been on the
watchlist since May 2019 for low DSCR as a result of the property's
declining average daily rate. The loan transferred to special
servicing in May 2020 for imminent default due to the fallout of
the coronavirus pandemic and is last paid through its May 2020
payment date.

Moody's has also assumed a high default probability for two poorly
performing loans, constituting 1.6% of the pool, both of which are
backed by underperforming hotel properties. Moody's has estimated
an aggregate loss of $3.8 million (an 23% expected loss based on a
82% probability default) from the specially serviced and troubled
loans.

Moody's received full year 2019 operating results for 95% of the
pool, and full or partial year 2020 operating results for 91% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 87%, essentially the same as at
Moody's last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 17.7% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 9.6%.

Moody's actual and stressed conduit DSCRs are 1.96X and 1.26X,
respectively, compared to 1.92X and 1.25X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

There are 18 loans with structured credit assessments ($46.3
million -- 6.8% of the pool) that are secured by multifamily
cooperative properties located in New Jersey and New York.

The top three conduit loans represent 23.7% of the pool balance.
The largest loan is the 301 South College Street Loan ($81.9
million -- 12.0% of the pool), which represents a pari passu
interest in a $168.6 million mortgage loan. The loan is secured by
a 988,646 square foot Class A office tower located in the central
business district of Charlotte, North Carolina. The property was
99% leased as of March 2020, down from 100% at the prior review.
The largest tenant, Wells Fargo, represents 69% of the net rentable
are and has a lease expiration date in December 2021. Wells Fargo
announced plans to lease space at a nearby building and to reduce
its space at this property. The next largest tenants include Womble
Carlyle (6% of NRA; lease expiration June 2028) and YMCA (4% of
NRA; lease expiration January 2022). Moody's has accounted for the
tenant concentration risk of the largest tenant by utilizing a
lit-dark analysis. After an initial 5-year interest only period the
loan has now amortized 3.7% since securitization. Moody's LTV and
stressed DSCR are 108% and 1.02X, respectively, compared to 102%
and 1.00X at the last review.

The second largest loan is the General Services Administration
Portfolio Loan ($50 million -- 7.3% of the pool). The loan is
secured by 14 cross-collateralized and cross-defaulted office and
flex warehouse buildings totaling approximately 341,000 SF and
located throughout 11 states. The loan sponsor is GSA Realty
Holdings, Inc. The properties are collectively 100% leased to GSA
tenants under 14 long-term leases, with only 19% of the NRA
expiring prior to January 2023. The loan is interest only for its
entire term and Moody's LTV and stressed DSCR are 89% and 1.13X,
respectively, the same as at last review.

The third largest loan is the 825-845 Lincoln Road Loan ($30
million -- 4.4% of the pool). The loan is secured by a 38,843 SF
retail property located in Lincoln Road Mall, an eight-block retail
corridor within walking distance from the Atlantic Ocean and some
of South Beach's high-end hotels, including the Ritz-Carlton, The
Delano, and The Shore Club. As of March 2020, the property was 100%
leased to six tenants, including CB2 (15,200 SF, 39% of the NRA),
Urban Outfitters (13,126 SF, 34% of the NRA), and American Eagle
(4,500 SF, 12% of the NRA). The Urban Outfitters space serves as a
flagship store for the retailer and the earliest expiration date
amongst the three largest tenants is in August 2023. Property
performance has improved since securitization due to higher rental
revenues and the loan was current as its June 2020 remittance date.
The loan is interest only for its entire term and Moody's LTV and
stressed DSCR are 71% and 1.26X.


[*] S&P Takes Various Actions on 71 Classes From 11 US RMBS Deals
-----------------------------------------------------------------
S&P Global Ratings completed its review of 71 classes from 11 U.S.
RMBS transactions issued between 2000 and 2005. The review yielded
22 downgrades, 40 affirmations, six discontinuances, and three
withdrawals.

Analytical Considerations

S&P acknowledges a high degree of uncertainty about the evolution
of the coronavirus pandemic. The consensus among health experts is
that the pandemic may now be at, or near, its peak in some regions,
but will remain a threat until a vaccine or effective treatment is
widely available, which may not occur until the second half of
2021. S&P is using this assumption in assessing the economic and
credit implications associated with the pandemic.

"As the situation evolves, we will update our assumptions and
estimates accordingly. Our views also consider that the loans
supporting the RMBS in the rating actions are significantly
seasoned and are to borrowers that have weathered the Great
Recession, a period of significant economic stress. As the
situation evolves, we will update our assumptions and estimates
accordingly," S&P said.

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes. Some of these considerations may include:

-- Factors related to COVID-19
-- Collateral performance/delinquency trends;
-- Historical interest shortfalls/missed interest payments;
-- Erosion of or increases in credit support; and
-- Small loan count.

Rating Actions

"The rating changes reflect our opinion regarding the associated
transaction-specific collateral performance and/or structural
characteristics, and/or reflect the application of specific
criteria applicable to these classes. Please see the ratings list
below for the specific rationales associated with each of the
classes with rating transitions," S&P said.

"The ratings affirmations reflect our opinion that our projected
credit support and collateral performance on these classes has
remained relatively consistent with our prior projections," the
rating agency said.

S&P lowered its ratings on classes A-1, A-2, and A-3 from Merrill
Lynch Mortgage Investors Trust's series MLMI 2004-A4 to 'BB+ (sf)'
from 'A+ (sf)' due to erosion of hard dollar credit support.
Principal payments to subordinate classes is eroding the credit
support available to cover S&P's projected losses at higher rating
levels. The subordinate classes received approximately $1.08
million in principal during the past 12 months, reducing the credit
support available for these classes to $3.03 million from $4.13
million a year ago.

S&P withdrew its ratings on three classes from one transaction due
to the small number of loans remaining in the related group or
structure. Once a pool has declined to a de minimis amount, S&P
believes there is a high degree of credit instability that is
incompatible with any rating level.

The list of Affected Ratings can be viewed at:

           https://bit.ly/3fdboE3


[*] S&P Takes Various Actions on 72 Classes From 13 U.S. RMBS Deals
-------------------------------------------------------------------
S&P Global Ratings completed its review of 72 classes from 13 U.S.
RMBS transactions issued between 2004 and 2007. All of these
transactions are backed by negative amortization collateral. The
review yielded 28 downgrades, 42 affirmations, and two
discontinuances.

ANALYTICAL CONSIDERATIONS

S&P Global Ratings acknowledges a high degree of uncertainty about
the evolution of the coronavirus pandemic. The consensus among
health experts is that the pandemic may now be at, or near, its
peak in some regions, but will remain a threat until a vaccine or
effective treatment is widely available, which may not occur until
the second half of 2021. S&P is using this assumption in assessing
the economic and credit implications associated with the pandemic.
As the situation evolves, S&P will update its assumptions and
estimates accordingly.

S&P's views also consider that the loans supporting the RMBS in the
rating actions are significantly seasoned and are to borrowers that
have weathered the Great Recession, a period of significant
economic stress.

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes. Some of these considerations may include:

-- Factors related to COVID-19;
-- Collateral performance/delinquency trends;
-- Available subordination and/or overcollateralization; and
-- Erosion of credit support.

RATING ACTIONS

"The rating changes reflect our opinion regarding the associated
transaction-specific collateral performance or structural
characteristics, or reflect the application of specific criteria
applicable to these classes," S&P said.

"The ratings affirmations reflect our opinion that our projected
credit support and collateral performance on these classes has
remained relatively consistent with our prior projections," the
rating agency said.

The majority of the downgrades reflect S&P's view that the payment
allocation triggers are passing, which allow principal payments to
be made to more subordinate classes and erode projected credit
support for the affected classes. Additionally, S&P has seen higher
reported delinquencies when compared to those reported during the
previous review dates. As a result, the increased delinquencies
have had an adverse impact on the performance of the mortgage loans
and increased S&P's projected losses.

A list of Affected Ratings can be reached through:

            https://bit.ly/3fi2HIO


                            *********

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