/raid1/www/Hosts/bankrupt/TCR_Public/210718.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 18, 2021, Vol. 25, No. 198

                            Headlines

A10 BRIDGE 2019-B: DBRS Confirms B(sf) Rating on Class F Certs
A10 SACM 2021-LRMR: DBRS Gives B(sf) Rating on Class F Certs
AJAX MORTGAGE 2021-E: DBRS Gives Prov. B Rating on Class B-2 Notes
AMERICAN CREDIT 2021-3: S&P Assigns Prelim 'B+' Rating on F Notes
AMSR 2021-SFR2: DBRS Finalizes BB(low) Rating on Class F-2 Certs

ANGEL OAK 2021-3: Fitch Assigns Final B Rating on Class B-2 Debt
ARROYO MORTGAGE 2021-1R: DBRS Finalizes B Rating on Class B-2 Notes
BAIN CAPITAL 2020-2: S&P Assigns BB- (sf) Rating on E-R Notes
BANK 2019-BNK22: DBRS Confirms BB Rating on Class G Certs
BB-UBS 2012-TFT: DBRS Confirms B(high) Rating on Class TE Certs

BBCMS 2021-AGW: DBRS Finalizes B(low) Rating on Class G Trust
BBCMS MORTGAGE 2020-C8: DBRS Confirms B Rating on Class J-RR Certs
BBCMS MORTGAGE 2021-C10: Fitch Affirms Final B- Rating on 2 Certs
BRSP 2021-FL1: DBRS Gives Prov. B(low) Rating on Class G Notes
CG-CCRE COMMERCIAL 2014-FL2: S&P Cuts STC1 Certs Rating to 'CCC-'

CITIGROUP COMMERCIAL 2013-GC17: Fitch Rates Class F Certs 'CCC'
CITIGROUP COMMERCIAL 2014-GC19: Fitch Rates Class F Certs 'B'
CITIGROUP COMMERCIAL 2015-GC35: Fitch Lowers Class E Certs to 'CCC'
CITIGROUP COMMERCIAL 2019-GC41: DBRS Confirms B(high) on GRR Certs
CITIGROUP MORTGAGE 2021-RP4: DBRS Gives Prov. B Rating on B2 Notes

COMM 2012-LTRT: S&P Lowers Class X-B Certs Rating to CCC (sf)
COMM TRUST 2016-COR1: Fitch Affirms B- Rating on 2 Tranches
CSAIL 2016-C5: DBRS Confirms B(sf) Rating on Class X-F Certs
CSAIL 2016-C6: DBRS Confirms B(sf) Rating on Class X-F Certs
CSAIL TRUST 2015-C1: Fitch Lowers 4 Cert. Tranches to 'Csf'

CSAIL TRUST 2015-C3: Fitch Lowers 2 Cert. Tranches to 'CCsf'
CSMC TRUST 2021-RPL5: Fitch Assigns B Rating on B-2 Notes
CSMC TRUST 2021-RPL5: Fitch Gives 'B(EXP)' Rating to B-2 Certs
DRYDEN 86 CLO: S&P Assigned Prelim BB- (sf) Rating on E-R Notes
ELMWOOD CLO IX: S&P Assigns BB-(sf) Rating on $18MM Class E Notes

GS MORTGAGE-BACKED 2021-PJ7: Fitch Gives 'B(EXP)' to B-5 Certs
HERTZ VEHICLE III: DBRS Finalizes BB Rating on Class D Notes
HOME PARTNERS 2021-1: DBRS Gives Prov. BB Rating on Class F Certs
IVY HILL IX: Fitch Affirms B+ Rating on Class E-R Notes
JP MORGAN 2003-CIBC7: Moody's Cuts Cl. X-1 Certs Rating to 'C'

JP MORGAN 2011-C3: DBRS Lowers Rating on 2 Classes to C
JP MORGAN 2011-C4: DBRS Confirms B Rating on Class H Certs
JP MORGAN 2013-C17: Fitch Lowers Class F Certs to 'B-sf'
LCCM 2021-FL2: DBRS Gives Prov. B(low) Rating on Class G Notes
LCM 29: S&P Assigns Prelim BB- (sf) Rating on Class E-R Notes

MELLO MORTGAGE 2021-MTG3: DBRS Finalizes B Rating on Cl. B5 Certs
MORGAN STANLEY 2021-L6: Fitch Gives Final B- Rating on G-RR Certs
NEWSTAR FAIRFIELD: Fitch Affirms BB- Rating on Class D-N Notes
OAKTREE CLO 2021-1: S&P Assigns B- (sf) Rating on Class F Notes
OCEANVIEW MORTGAGE 2021-3: Moody's Gives (P)B3 Rating to B-5 Certs

OHA CREDIT 6: S&P Assigns Prelim BB- (sf) Rating on E-R Notes
REGIONAL 2021-2: S&P Assigns Prelim BB (sf) Rating on Class D Notes
SREIT 2021-FLWR: DBRS Gives Prov. B(low) Rating on Class F Certs
STARWOOD MORTGAGE 2021-3: DBRS Finalizes B Rating on Cl. B-2 Certs
TCW CLO 2021-2: S&P Assigns Prelim BB- (sf) Rating on Class E Notes

TRK 2021-INV1: S&P Assigns Prelim B (sf) Rating on Class B-2 Certs
US AUTO FUNDING 2019-1: Moody's Hikes Class C Notes From Ba1
WELLS FARGO 2014-C22: Fitch Affirms CCC Rating on 4 Tranches
WELLS FARGO 2015-C31: DBRS Confirms B(low) Rating on F Certs
WELLS FARGO 2021-C60: Fitch Affirms B- Rating on J-RR Certs

WFRBS COMMERCIAL 2013-C18: Fitch Lowers Class F Certs to 'Csf'
[*] DBRS Confirms Ratings on All Classes in 4 Student Loan Deals
[*] DBRS Reviews 105 Classes from 33 U.S. RMBS Transactions
[*] DBRS Reviews 114 Classes from 14 U.S. RMBS Transactions
[*] S&P Takes Various Actions on 13 Exeter Automobiles Trusts

[*] S&P Takes Various Actions on 17 Collegiate Student Loan Trusts
[*] S&P Takes Various Actions on 46 Classes from Nine US CLO Deals
[*] S&P Takes Various Actions on 87 Classes from 29 US RMBS Deals
[*] S&P Takes Various Actions on Four Classes from Two US RMBS Deal

                            *********

A10 BRIDGE 2019-B: DBRS Confirms B(sf) Rating on Class F Certs
--------------------------------------------------------------
DBRS Limited confirmed the ratings on the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-B issued
by A10 Bridge Asset Financing 2019-B, LLC:

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

The trends on Classes D and E have been changed to Stable from
Negative while the trend on Class F remains Negative. The trends on
all other classes in the transaction are Stable.

DBRS Morningstar had previously changed the trends on Classes D, E,
and F to Negative from Stable as multiple loans in the transaction
were either delinquent or individual borrowers had received a
forbearance as a result of the Coronavirus Disease (COVID-19)
pandemic. While there are currently two specially serviced loans in
the pool (11.2% of the current trust balance) and three loans on
the servicer's watchlist (15.8% of the current trust balance), the
overall credit profile of the transaction has recently shown signs
of improvement. Most notably, the transaction has experienced a
collateral reduction of 15.6% in recent months, contributing to
increased credit enhancement across the capital stack.
Additionally, one loan of concern identified during DBRS
Morningstar's previous review, 500 Dekalb Ave (4.9% of the issuance
trust balance), was repaid in full in April 2021.

The initial collateral consisted of 36 fixed-rate and eight
floating-rate mortgages secured by mostly transitional properties
with a cut-off balance of $281.1 million, excluding approximately
$83.3 million of future funding commitments. At issuance, the pool
had a maximum balance of $320.0 million, inclusive of $38.9 million
of future funding companion participations. While the Reinvestment
Period does not end until September 2021, $50.0 million of
principal paydown has been contributed to the trust over the past
year, reducing the maximum balance to $270.0 million. According to
the June 2021 remittance report, there are 29 loans in the pool
with a current principal balance of $221.3 million and an
outstanding balance of unfunded future funding obligations of $33.5
million for capital expenditures as well as tenant improvement and
leasing commission costs. The trust currently has a reinvestment
account of $48.7 million available. By property type, 13 loans,
representing 40.3% of the principal balance, are secured by
multifamily, industrial, or self-storage assets, while 16 loans,
representing 51.3% of the principal balance, are secured by retail
and office assets; the remainder of the pool is secured by
mixed-use assets.

The larger of the two loans in special servicing, Gowanus
Assemblage (6.1% of the current trust balance), is secured by four
adjacent mixed-use buildings, totalling 57,418 square feet (sf), in
Brooklyn, New York. At origination, the borrower's business plan
consisted of completing $1.5 million of capital improvements across
three of the four buildings to improve occupancy. As a result of
the mandated construction moratoriums in New York, however,
construction was delayed at the property, which significantly
affected leasing momentum. The loan was transferred to special
servicing in August 2020 and is more than 121 days delinquent as of
the June 2021 reporting. Given the sponsor's illiquid position with
financial pressure from other near-term maturities, alternative
financing was sought to delay the resolution process; however, such
funding did not materialize and as a result the property was listed
for sale in January 2021. According to the servicer, The Yard
(44.7% of the net rentable area (NRA), lease expiring April 2028)
remains operational, but there have been issues with rent
collections. Collective Arts (23.7% of the NRA, lease expiring June
2029) has not yet taken occupancy, however, the tenant reportedly
remains committed to its space. Based on the September 2020
appraisal, the property was valued at $19.5 million, below the
issuance value of $31.0 million, reflecting a 37.0% decline in
value. DBRS Morningstar liquidated this loan from the trust in its
analysis for this review, resulting in a hypothetical loss severity
in excess of 30.0%.

The largest loan both on the servicer's watchlist and in the
transaction, Janss Marketplace (7.6% of the current trust balance),
is secured by a 449,829-sf anchored retail property in Thousand
Oaks, California. The borrower was previously granted forbearance
in May 2020, which was extended in January 2021. The borrower has
cooperated with the terms of the agreement and the loan is now
current. While the servicer reports that a few tenants are still
operating through rental deferral arrangements, the majority of
tenants appear to be operational with an occupancy rate of 83.4% as
of March 2021. The delivery of Aldi's space (5.0% of the NRA, lease
expiring May 2030) was significantly delayed, but the tenant opened
for business in January 2021. In addition, the borrower has
reportedly signed four new leases and an extension with Gold's Gym
(currently 7.0% of the NRA, lease expiring August 2023), which will
also expand its footprint at the property. While the property has
experienced cash flow disruption with the Q2 2020 annualized figure
falling to $476,052, below the DBRS Morningstar Stabilized figure
of $5.0 million, rental collections appear to be normalizing with a
large pool of prospective tenants interested in available space at
the property.

The two smaller loans on the servicer's watchlist have both faced
challenges with increased vacancy rates and the timeliness of debt
service payments. While the 2929 N Central Expressway (2.1% of the
current trust balance) is more than 60 days delinquent as of the
June 2021 reporting, the servicer indicates that the borrower is in
the final stages of lease negotiations with a major tenant that is
expected to execute a lease in July 2021. The borrower's investor
group has noted that the default will be cured and the expected
buildout and leasing package will be funded if the lease is
executed. DBRS Morningstar will continue to monitor both loans.

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



A10 SACM 2021-LRMR: DBRS Gives B(sf) Rating on Class F Certs
------------------------------------------------------------
DBRS, Inc. assigned new ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2021-LRMR
issued by A10 Single Asset Commercial Mortgage-LRMR (A10 SACM
2021-LRMR).

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

All trends are Stable.

RATING RATIONALE

The ratings reflect DBRS Morningstar's analysis of the sustainable
cash flow and value for the property securing the loan held by the
trust; the presence of loan structural features, such as the lack
of amortization; a $25 million limited guaranty from the sponsor;
and qualitative factors, such as DBRS Morningstar's opinion on the
quality of the underlying collateral property, the sponsor's
business plan to renovate and stabilize the collateral property,
the current and expected performance of the real estate markets in
which the property is located, and the current and future state of
the macroeconomic environment and its potential impact on the
performance of commercial properties.

A10 SACM 2021-LRMR is supported by the payment stream from the
borrower's fee-simple and leasehold interests in Larimer Square, a
246,000-square-foot (sf) retail/office mixed-use development in
Denver, Colorado. The collateral represents the Larimer Square
protected historic district and comprises 26 buildings, including a
parking garage on 12 separate real estate tax parcels. Two of the
buildings are subject to ground leases. DBRS Morningstar determined
the provisional ratings for each class of certificates by analyzing
the stabilized cash flow generated by the property, giving
consideration to the quality and location of the property, the
sponsor's business plan, fundamentals of the property's real estate
market, and legal and structural features of the mortgage loan.
DBRS Morningstar's analysis of the property's operations, based on
information provided on the arranger's website as of June 29, 2021,
yielded a stabilized net cash flow (NCF) of $7.2 million. DBRS
Morningstar's concluded NCF is 21.1% less than the sponsor's
projected Year 4 NCF of $9.2 million. The DBRS Morningstar NCF
resulted in an interest-only debt-service coverage ratio (DSCR) of
1.70 times (x) (1.22x amortizing DSCR) on the fully funded mortgage
loan of $88.7 million, based on the interest rate of 4.742%. DBRS
Morningstar valued the collateral at a stabilized value of $96.4
million based on the concluded NCF and a capitalization rate of
7.50%. DBRS Morningstar's valuation resulted in a loan-to-value
ratio (LTV) of 92.03% on the fully funded first-mortgage loan.

The sponsor will provide a $25.0 million limited guaranty, which
may be terminated upon meeting certain performance metrics
including average occupancy of 90.0% or more in the prior six
months, a debt yield of 9.0% or more based on trailing three
months' office and retail revenues, and an LTV of 60.0% or less
based on a fresh appraisal. Borrower's counsel provided a
nonconsolidation opinion as to the limited guaranty. Given that the
guaranty, at 28.2% of the fully funded loan balance, is
significantly higher than typical market standards, it was reviewed
by DBRS Morningstar counsel for substance and analysis and is
considered acceptable by DBRS Morningstar.

DBRS Morningstar determined the ratings on each class of
certificates by performing quantitative and qualitative collateral,
structural, and legal analysis. This analysis incorporates DBRS
Morningstar's "North American Single-Asset/Single-Borrower Ratings
Methodology" and the DBRS Morningstar LTV Benchmark Sizing tool.

DBRS Morningstar determined its concluded sustainable NCF and
sustainable value of the underlying property by applying its "DBRS
Morningstar North American Commercial Real Estate Property Analysis
Criteria." DBRS Morningstar's maximum LTV thresholds at each rating
category were based on the transaction's sequential-pay waterfall,
underlying property type, lack of amortization, borrower, trust
LTV, pari passu debt outside the trust, limited property type and
geographic diversity, and other factors relevant to the credit
analysis.

DBRS Morningstar will perform surveillance subject to North
American CMBS Surveillance Methodology.

DBRS Morningstar adjusted its maximum LTV thresholds (the
Quality/Volatility Adjustment) to account for the following
factors:

Cash Flow Volatility: The sponsor's business plan involves a
substantial renovation of the collateral property, especially the
office space to attract more institutional quality office tenants.
In addition, the sponsor also intends to rebalance the retail
tenant mix from its current 70% restaurant tenants to 55% to 60%
restaurants and 40% to 45% daily use and soft goods retailers. As
such, the DBRS Morningstar stabilized analysis assumes rolling to
market all tenants with lease expirations through June 2022. Given
the significant retenanting of the property, DBRS Morningstar did
not make any adjustments based on cash flow volatility.

Property Quality: Twenty-three of the 26 buildings comprising the
collateral were built between 1876 and 1890; the remaining three
were built between 1992 and 2003. Although the buildings have
undergone periodic renovations, they have certain deferred
maintenance issues. In addition, the sponsor's business plan
involves a substantial renovation of the office spaces. The sponsor
has a $30.9 million capital expenditure (capex) plan to cure the
deferred maintenance, implement base building repairs, and renovate
the office spaces. The lender will fund $21.1 or 68.4% of the capex
budget. Based on the capex plan, DBRS Morningstar elected to
increase its LTV thresholds by 0.5% to account for the improved
property quality.

Market/Location: The property is located in the southern edge of
the Lower Downtown district in Denver. It benefits from proximity
to the Denver central business district with approximately 19
million sf of office space, Auraria Campus (located next to Larimer
Square and houses facilities for University of Colorado Denver,
Metropolitan State University of Denver, and Community College of
Denver), the Denver Convention Center, and Ball Arena. The property
has excellent public transport access via the Union Station
transportation hub with commuter train, The property can also be
accessed from Interstate 25 to the west and Colfax Avenue, one of
the main east-west arterials, to the south. Based on the location
and market fundamentals of the property, DBRS Morningstar increased
its LTV thresholds by 1.5%.

Other Qualitative Adjustments – Business Plan Execution Risk: The
collateral property is significantly transitional and the sponsor's
business plan includes a substantial renovation of the buildings as
well as an almost total retenanting and lease-up. Fifty-six percent
of the current rent roll will expire in the first three years of
the loan term, including 28.4% in the first year alone. The sponsor
has a $30.9 million capex plan for deferred maintenance and base
building renovations, and a $10.1 million plan for releasing
expenses. However, the lender will fund only $21.1 million (68.4%)
of the capital expense plan and $6.6 million (65.0% ) of the
leasing costs. In addition, while the sponsor provides a completion
guaranty for the capital improvement program. Based on transitional
nature of the property and the heavy lift required to stabilize it,
DBRS Morningstar decreased its LTV thresholds by 7.5%.

Other Qualitative Adjustments – Ground Lease Provisions: Two of
the parcels comprising the property are subject to a ground lease,
which commenced in 1995 and had a twenty-year initial term with
four 10-year extensions. The fully extended ground lease will
expire in 2056. The ground lease does not allow for the leasehold
mortgagee to hold any insurance proceeds during the renovation of
the overlying buildings, does not prohibit amendments without the
consent of the leasehold mortgagee, and the loan agreement does not
define a violation or termination of the ground lease as a recourse
event. Based on the above considerations, DBRS Morningstar
decreased its LTV thresholds by 0.5%.

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



AJAX MORTGAGE 2021-E: DBRS Gives Prov. B Rating on Class B-2 Notes
------------------------------------------------------------------
DBRS, Inc. assigned the following provisional ratings to the
Mortgage-Backed Notes, Series 2021-E to be issued by Ajax Mortgage
Loan Trust 2021-E:

-- $396.6 million Class A-1 at AAA (sf)
-- $34.2 million Class A-2 at A (sf)
-- $19.4 million Class M-1 at BBB (sf)
-- $17.9 million Class B-1 at BB (sf)
-- $20.5 million Class B-2 at B (sf)

The AAA (sf) rating on the Notes reflects 23.40% of credit
enhancement provided by subordinated certificates. The A (sf), BBB
(sf), BB (sf), and B (sf) ratings reflect 16.80%, 13.05%, 9.60%,
and 5.65% of credit enhancement, respectively.

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

The Trust is a securitization of a portfolio of seasoned performing
and reperforming first-lien residential mortgages funded by the
issuance of the Notes. The Notes are backed by 3,142 loans with a
total principal balance of $517,741,210 as of the Cut-Off Date (May
31, 2021).

The mortgage loans are approximately 167 months seasoned. For 15.7%
of the pool, DBRS Morningstar received more recent payment status
as of June 7 and used these in its analysis. As of the Cut-Off Date
or June 7 where applicable, approximately 90.9% of the loans are
current under the Mortgage Bankers Association delinquency method,
including 59 bankruptcy-performing loans. Below is the current
delinquency status distribution for this pool.

Although the number of months clean (consecutively zero times 30 (0
x 30) days delinquent) at issuance is weaker relative to other DBRS
Morningstar-rated seasoned transactions, the borrowers in this pool
demonstrate reasonable cash flow velocity (as by number of payments
over time) in the past six, 12, and 24 months.

The portfolio contains 87.6% modified loans. The modifications
happened more than two years ago for 93.5% of the modified loans.
Within the pool, 1,032 mortgages (42.6% of the pool) have
non-interest-bearing deferred amounts of $49,272,810, which equate
to approximately 9.5% of the total principal balance.

The mortgage loans were previously included in prior
securitizations issued by the Sellers, Ajax Mortgage Loan Trust
2020-C and Ajax Mortgage Loan Trust 2020-D. The issuers of the
prior securitizations will exercise certain loan sale rights, and,
on the Closing Date, the mortgage loans will be conveyed by each
Seller to the Depositor.

To satisfy the credit risk retention requirements, Great Ajax
Operating Partnership L.P. (Ajax or the Sponsor) or a
majority-owned affiliate of the Sponsor will retain at least a 5%
eligible vertical interest in the securities (except for the Class
R Notes).

Gregory Funding LLC is the Servicer for the entire pool and will
not advance any delinquent principal and interest on the mortgages;
however, the Servicer is obligated to make advances in respect of
prior liens, insurance, real estate taxes and assessments, as well
as reasonable costs and expenses incurred in the course of
servicing and disposing of properties.

Since 2013, Ajax and its affiliates have issued 42 securitizations
under the Ajax Mortgage Loan Trust shelf prior to AJAX 2021-E.
These issuances were backed by seasoned loans, reperforming loans
(RPL), or nonperforming loans and are mostly unrated by DBRS
Morningstar. DBRS Morningstar reviewed the historical performance
of the Ajax shelf; however, the nonrated deals generally exhibit
worse collateral attributes than the rated deals with regard to
delinquencies at issuance. The prior nonrated Ajax transactions
generally exhibit relatively high levels of delinquencies and
losses as compared with the rated Ajax securitizations, which are
expected given the nature of these severely distressed assets.

The Issuer has the option to redeem the Notes in full at a price
equal to the remaining note amount of the rated Notes plus accrued
and unpaid interest, including any Step-Up Interest Payment
Amounts, and any unpaid expenses and reimbursement amounts. Such
Note Redemption Rights may be exercised on any date

-- Beginning three years after the Closing Date at the direction
of the Depositor or

-- Beginning on the payment date in July 2026 at the direction of
either the Depositor or holders of more than 50.0% of Class B-3
Notes.

The transaction employs a sequential-pay cash flow structure.
Principal proceeds can be used to pay interest and Cap Carryover
Amounts on the Notes, but such interest and Cap Carryover Amounts
on Class A-2 and more subordinate bonds will not be paid from the
principal remittance amount until the more senior classes are
retired. In addition, unique to this shelf, the senior and
mezzanine classes are entitled to Step-Up Interest Payments,
beginning eight years from the Closing Date.

In contrast to prior DBRS Morningstar-rated Ajax-seasoned RPL
securitizations, the representations and warranties (R&W) framework
for this transaction incorporates the following new features:

-- A pool level review trigger that delays potential breach
reviews, similar to many other rated RPL securitizations;

-- The absence of a repurchase remedy by the Sponsor (except for
the real estate mortgage investment conduit representation),
dissimilar to other rated RPL securitizations; and

-- A Breach Reserve Account, which will be available to satisfy
losses related to R&W breaches. Such account is unfunded upfront
and then funds from monthly excess cash flow at the bottom of the
interest remittance waterfall, dissimilar to other rated RPL
securitizations.

Although these updates weaken the R&W framework, the historical
experience of having minimal putbacks and comprehensive third-party
due diligence for the shelf mitigates these features. In addition,
the cash flow structure allows sufficient excess spread to fully
fund the Breach Reserve Account within four months under DBRS
Morningstar cash flow scenarios, which is much faster than other
rated RPL securitizations.

CORONAVIRUS IMPACT

The Coronavirus Disease (COVID-19) pandemic and the resulting
isolation measures have caused an immediate economic contraction,
leading to sharp increases in unemployment rates and income
reductions for many consumers. Shortly after the onset of the
pandemic, DBRS Morningstar saw an increase in the delinquencies for
many residential mortgage-backed securities (RMBS) asset classes.

Such mortgage delinquencies were mostly in the form of
forbearances, which are generally short-term periods of payment
relief that may perform very differently from traditional
delinquencies. At the onset of the pandemic, the option to forbear
mortgage payments was widely available, driving forbearances to an
elevated level. When the dust settled, loans with
coronavirus-induced forbearance in 2020 performed better than
expected, thanks to government aid, low loan-to-value ratios, and
acceptable underwriting in the mortgage market in general. Across
nearly all RMBS asset classes in recent months delinquencies have
been gradually trending downward, as forbearance periods come to an
end for many borrowers.

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



AMERICAN CREDIT 2021-3: S&P Assigns Prelim 'B+' Rating on F Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to American
Credit Acceptance Receivables Trust 2021-3's asset-backed notes.

The note issuance is an ABS securitization backed by subprime auto
loan receivables.

The preliminary ratings are based on information as of July 14,
2021. 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 availability of approximately 63.96%, 57.63%, 49.13%,
41.70%, 38.10%, and 33.79% credit support, including excess spread,
for the class A, B, C, D, E, and F notes, respectively, based on
stressed cash flow scenarios. These credit support levels provide
more than 2.35x, 2.10x, 1.70x, 1.37x, 1.29x, and 1.15x coverage of
S&P's expected net loss range of 26.50%-27.50% for the class A, B,
C, D, E, and F notes, respectively.

-- The hard credit enhancement in the form of subordination,
overcollateralization, and a reserve account in addition to excess
spread.

-- The expectation that under a moderate ('BBB') stress scenario
(1.37x S&P's expected loss level), all else being equal, S&P's
preliminary 'AAA (sf)', 'AA (sf)', 'A (sf)', 'BBB (sf)', 'BB+
(sf)', and 'B+ (sf)' ratings on the class A, B, C, D, E, and F
notes, respectively, will be within the credit stability limits
specified by section A.4 of the Appendix of "S&P Global Ratings
Definitions," published Jan. 5, 2021.

-- The timely payment of interest and principal by the designated
legal final maturity dates under our stressed cash flow modeling
scenarios that we believe are appropriate for the assigned
preliminary ratings.

-- The collateral characteristics of the subprime automobile loans
securitized in this transaction.

-- The backup servicing arrangement with Wells Fargo Bank N.A.

-- The transaction's payment and legal structure.

  Preliminary Ratings Assigned

  American Credit Acceptance Receivables Trust 2021-3(i)

  Class A, $208.35 million: AAA (sf)  
  Class B, $50.92 million: AA (sf)
  Class C, $82.65 million: A (sf)
  Class D, $64.70 million: BBB (sf)
  Class E, $28.78 million: BB+ (sf)
  Class F, $24.60 million: B+ (sf)

(i)The actual size of these tranches will be determined on the
pricing date.



AMSR 2021-SFR2: DBRS Finalizes BB(low) Rating on Class F-2 Certs
----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the Single-Family
Rental Pass-Through Certificates issued by AMSR 2021-SFR2 Trust
(AMSR 2021-SFR2):

-- $168.8 million Class A at AAA (sf)
-- $53.6 million Class B at AA (low) (sf)
-- $23.3 million Class C at A (low) (sf)
-- $24.5 million Class D at BBB (high) (sf)
-- $22.1 million Class E-1 at BBB (sf)
-- $30.0 million Class E-2 at BBB (low) (sf)
-- $36.1 million Class F-1 at BB (high) (sf)
-- $27.9 million Class F-2 at BB (low) (sf)

The AAA (sf) rating on the Class A Certificates reflects 58.2% of
credit enhancement provided by subordinated notes in the pool. The
AA (low) (sf), A (low) (sf), BBB (high) (sf), BBB (sf), BBB (low)
(sf), BB (high) (sf), and BB (low) (sf) ratings reflect 45.0%,
39.2%, 33.1%, 27.7%, 22.5% 13.5%, and 6.6% credit enhancement,
respectively.

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

The AMSR 2021-SFR2 certificates are supported by the income streams
and values from 1,779 rental properties. The properties are
distributed across 14 states and 37 metropolitan statistical areas
(MSAs) in the United States. DBRS Morningstar maps an MSA based on
the ZIP code provided in the data tape, which may result in
different MSA stratifications than those provided in offering
documents. As measured by broker price opinion value, 64.9% of the
portfolio is concentrated in three states: Florida (36.8%), Georgia
(15.9%), and North Carolina (12.2%). The average value is $261,804.
The average age of the properties is roughly 23 years. The majority
of the properties have three or more bedrooms. The certificates
represent a beneficial ownership in an approximately five-year,
fixed-rate, interest-only loan with an initial aggregate principal
balance of approximately $465.7 million.

DBRS Morningstar finalized the provisional ratings for each class
of certificates by performing a quantitative and qualitative
collateral, structural, and legal analysis. This analysis uses DBRS
Morningstar's single-family rental subordination model and is based
on DBRS Morningstar's published criteria. DBRS Morningstar
developed property-level stresses for the analysis of single-family
rental assets. DBRS Morningstar assigned the provisional ratings to
each class based on the level of stresses each class can withstand
and whether such stresses are commensurate with the applicable
rating level. DBRS Morningstar's analysis includes estimated
base-case net cash flows (NCFs) by evaluating the gross rent,
concession, vacancy, operating expenses, and capital expenditure
(capex) data. The DBRS Morningstar NCF analysis resulted in a
minimum debt service coverage ratio of higher than 1.0 times (x).

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


ANGEL OAK 2021-3: Fitch Assigns Final B Rating on Class B-2 Debt
----------------------------------------------------------------
Fitch Ratings has assigned final ratings to Angel Oak Mortgage
Trust 2021-3 (AOMT 2021-3).

DEBT           RATING               PRIOR
----           ------               -----
AOMT 2021-3

A-1      LT  AAAsf   New Rating   AAA(EXP)sf
A-2      LT  AAsf    New Rating   AA(EXP)sf
A-3      LT  Asf     New Rating   A(EXP)sf
M-1      LT  BBB-sf  New Rating   BBB-(EXP)sf
B-1      LT  BBsf    New Rating   BB(EXP)sf
B-2      LT  Bsf     New Rating   B(EXP)sf
B-3      LT  NRsf    New Rating   NR(EXP)sf
A-IO-S   LT  NRsf    New Rating   NR(EXP)sf
XS       LT  NRsf    New Rating   NR(EXP)sf

TRANSACTION SUMMARY

Fitch Ratings rates the residential mortgage-backed certificates
issued by Angel Oak Mortgage Trust 2021-3, Mortgage-Backed
Certificates, Series 2021-3 (AOMT 2021-3), as indicated above. The
certificates are supported by 602 loans with a balance of $302.58
million as of the cutoff date. This will be the 15th Fitch-rated
AOMT transaction.

The certificates are secured by mortgage loans that were originated
by Angel Oak Home Loans LLC and Angel Oak Mortgage Solutions LLC
(referred to as Angel Oak originators). Of the loans in the pool,
89.1% are designated as nonqualified mortgage (Non-QM), and 10.9%
are investment properties not subject to the Ability to Repay (ATR)
Rule. No loans are designated as QM in the pool.

There is LIBOR exposure in this transaction since 1.0% of the pool
comprises adjustable-rate mortgage (ARM) loans that reference
one-year LIBOR. The offered certificates are fixed rate and capped
at the net weighted average coupon (WAC).

KEY RATING DRIVERS

Non-QM Credit Quality (Mixed): The collateral consists of 602 loans
totaling $303 million and seasoned at approximately seven months in
aggregate. The borrowers have a strong credit profile (736 FICO and
34.4% debt-to-income as determined by Fitch) and relatively high
leverage, with an original combined loan-to-value ratio (CLTV) of
75.4% that translates to a Fitch-calculated sustainable LTV (sLTV)
of 84%. Of the pool, 84.0% consists of loans where the borrower
maintains a primary residence, while 16.0% comprises an investor
property or second home, and 12.7% of the loans were originated
through a retail channel. Additionally, 89.1% are designated as
non-QM, while the remaining 10.9% are exempt from QM since they are
investor loans.

The pool contains 65 loans over $1 million, with the largest at
$2.6 million.

A 10.9% portion of the pool comprises loans on investor properties
(4.8% underwritten to the borrower's credit profile and 6.1%
comprising investor cash flow loans). None of the borrowers have
subordinate financing, there are no second lien loans, and 1.3% of
the borrowers were viewed by Fitch as having a prior credit event
within the past seven years.

Twenty-one loans in the pool had a deferred balance, which is
treated by Fitch as a second lien, and the CLTV for such loans was
increased to account for amounts still owed on the respective
loans.

The majority of the loans in the pool are located in Florida (27%)
and California (23%). The top three MSAs account for approximately
35% of the pool. The largest MSA is Miami at 15.5%, followed by
Atlanta at 11.2%.

Although the credit quality of the borrowers is higher than in
prior AOMT transactions, the pool characteristics resemble nonprime
collateral and, therefore, the pool was analyzed using Fitch's
nonprime model.

Loan Documentation (Negative): Approximately 93.3% of the pool was
underwritten to borrowers with less than full documentation. Of
this amount, 87.0% was underwritten to a 12- or 24-month bank
statement program for verifying income, which is not consistent
with Appendix Q standards and Fitch's view of a full documentation
program. To reflect the additional risk, Fitch increases the
probability of default (PD) by 1.5x on the bank statement loans.
Besides loans underwritten to a bank statement program, 0.2%
comprises an asset depletion product and 6.1% is a debt service
coverage ratio product. The pool does not have any loans
underwritten to a CPA or profit and loss (PnL) product, which Fitch
viewed as a positive.

Limited Advancing (Mixed): The deal is structured to six months of
servicer advances for delinquent P&I. The limited advancing reduces
loss severities, as there is a lower amount repaid to the servicer
when a loan liquidates, and liquidation proceeds are prioritized to
cover principal repayment over accrued but unpaid interest. The
downside to this is the additional stress on the structure side, as
there is limited liquidity in the event of large and extended
delinquencies

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

Macro or Sector Risks (Positive): Consistent with the Additional
Scenario Analysis section of Fitch's "U.S. RMBS Coronavirus-Related
Analytical Assumptions" criteria, Fitch will consider applying
additional scenario analysis based on stressed assumptions as
described in the section to remain consistent with significant
revisions to Fitch's macroeconomic baseline scenario or if actual
performance data indicate the current assumptions require
reconsideration.

In response to revisions made to Fitch's macroeconomic baseline
scenario, observed actual performance data and the unexpected
development in the health crisis arising from the advancement and
availability of coronavirus vaccines, Fitch reconsidered the
application of the coronavirus-related Economic Risk Factor (ERF)
floors of 2.0 and used ERF floors of 1.5 and 1.0 for the 'BBsf' and
'Bsf' rating stresses, respectively.

Fitch's "Global Economic Outlook - June 2021" and related baseline
economic scenario forecasts have been revised to 6.8% U.S. GDP
growth for 2021 and 3.9% for 2022 following a 3.5% GDP contraction
in 2020. Additionally, Fitch's U.S. unemployment forecasts for 2021
and 2022 are 5.6% and 4.5%, respectively, which is down from 8.1%
in 2020. These revised forecasts support Fitch reverting to the 1.5
and 1.0 ERF floors described in Fitch's "U.S. RMBS Loan Loss Model
Criteria."

RATING SENSITIVITIES

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper market value declines (MVDs) than
assumed at the MSA level. 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.

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

-- This defined positive rating sensitivity analysis demonstrates
    how the ratings would react to positive home price growth of
    10% with no assumed overvaluation. 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 being assigned ratings of 'AAAsf'.

Factor 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 41.9%, at 'AAA'. The analysis
    indicates 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.

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. They should not be used as indicators of
possible future performance.

BEST/WORST CASE RATING SCENARIO

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC, Infinity and Consolidated Analytics. The
third-party due diligence described in Form 15E focused on three
areas: compliance review, credit review and valuation review. Fitch
considered this information in its analysis and, as a result, Fitch
did not make any adjustment(s) to its analysis due to the due
diligence findings. Based on the results of the 100% due diligence
performed on the pool, the overall expected loss was reduced by
0.52%.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the loans. The third-party due diligence was
consistent with Fitch's "U.S. RMBS Rating Criteria." The sponsor,
Angel Oak Real Estate Investment Trust II, engaged American
Mortgage Consultants, Inc., Consolidated Analytics, Inc. and
Infinity IPS to perform the review. Loans reviewed under these
engagements were given compliance, credit and valuation grades and
assigned initial grades for each subcategory.

An exception and waiver report was provided to Fitch, indicating
the pool of reviewed loans has a number of exceptions and waivers.
Fitch determined that the exceptions and waivers do not materially
affect the overall credit risk of the loans due to the presence of
compensating factors, such as having liquid reserves or FICOs above
guideline requirements or LTV or debt-to-income ratios below
guideline requirements. Therefore, no adjustments were needed to
compensate for these occurrences.

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

ESG CONSIDERATIONS

AOMT 2021-3 has an ESG Relevance Score of '4+' for Transaction
Parties and Operational Risk due to strong transaction due
diligence and a 'RPS1-' Fitch-rated servicer, which resulted in a
reduction in expected losses and is relevant to the ratings in
conjunction with other factors.

The issuer indicated that all loans in the pool fit into an ESG
category mainly due to the fact that they improve access to capital
market liquidity to underserved borrowers. Specifically, 88% of the
loans in the pool are made to borrowers with nonstandard income and
are to first-time homebuyers or buyers in economic opportunity
zones, or they are categorized as affordable housing; 11% are in
opportunity zones; and the remainder are to first-time homebuyers.
Fitch did not take these ESG programs into consideration when
assigning Fitch's ESG score of '4+' and did not take them into
consideration in the analysis of the transaction.

For this transaction, Angel Oak Capital Advisors (AOCAS) received a
secondary party opinion of its social bonds linked to its
sustainability strategy. Fitch reviewed the secondary party opinion
and concluded that the report's assessment has no additional impact
to the relevance or materiality factors considered in assigning
Fitch's ESG Relevance Scores. In addition, it had no impact on
Fitch's rating analysis.

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


ARROYO MORTGAGE 2021-1R: DBRS Finalizes B Rating on Class B-2 Notes
-------------------------------------------------------------------
DBRS, Inc. finalized provisional ratings on the following
Mortgage-Backed Notes, Series 2021-1R issued by Arroyo Mortgage
Trust 2021-1R:

-- $342.6 million Class A-1 at AAA (sf)
-- $27.6 million Class A-2 at AA (sf)
-- $20.9 million Class A-3 at A (sf)
-- $11.4 million Class M-1 at BBB (sf)
-- $1.8 million Class B-1 at BB (sf)
-- $812.0 thousand Class B-2 at B (sf)

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

The AAA (sf) rating on the Class A-1 Notes reflects 15.60% of
credit enhancement provided by subordinate notes. The AA (sf), A
(sf), BBB (low) (sf), BB (sf), and B (sf) ratings reflect 8.80%,
3.65%, 0.85%, 0.40%, and 0.20% of credit enhancement,
respectively.

This is a securitization of a portfolio of seasoned fixed- and
adjustable-rate, expanded prime and nonprime, first-lien
residential mortgages funded by the issuance of the Mortgage-Backed
Notes, Series 2021-1R (the Notes). The Notes are backed by 1,233
mortgage loans with a total principal balance of $405,897,128 as of
the Cut-Off Date (June 1, 2021).

Subsequent to the issuance of the related Presale Report, one loan
was dropped from the securitization. The Notes are backed by 1,234
mortgage loans with a total principal balance of $406,285,237 in
the Presale Report. Unless specified otherwise, all the statistics
regarding the mortgage loans in the related Rating Report are based
on the Presale Report balance.

The mortgage pool consists primarily of loans (95.0% of the total
aggregated balance) from a previously issued and collapsed Non-QM
Arroyo transaction. The remaining 5.0% of the pool are from two
other New York common law trusts.

The loans are on average, more seasoned than a typical new
origination non-Qualified Mortgage (non-QM) securitization. The
DBRS Morningstar calculated weighted-average (WA) loan age is 61
months, and all of the loans are seasoned 24 months or more. Within
the pool, 98.3% of the loans are current, 1.5% are 30 days
delinquent, and 0.1% are 60 days or more delinquent. (All loans 60
days or more delinquent are part of an active forbearance plan.)
The Coronavirus Disease (COVID-19)-affected loans account for 21.4%
of the pool and are described in further detail below.

The originators for the mortgage pool are AmWest Funding Corp.
(Amwest; 40.8%), Metro City Bank (MCB; 25.9%), East West Bank
(25.8%), and other originators that each comprise less than 10.0%
of the mortgage loans. The Servicers of the loans are AmWest
(40.8%), MCB (25.9%), East West Bank (25.8%), and other servicers
that each comprise less than 10.0% of the mortgage loans.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's Ability-to-Repay (ATR) rules, they
were made to borrowers who generally do not qualify for agency,
government, or private-label nonagency prime jumbo products for
various reasons. In accordance with the Qualified Mortgage (QM)/ATR
rules, 79.8% of the loans are designated as non-QM. Approximately
20.2% of the loans are made to investors for business purposes and,
hence, are not subject to the QM/ATR rules.

The sponsor, directly or indirectly through a majority-owned
affiliate, will retain an eligible horizontal residual interest
consisting of the Class B-3, Class XS, and Class A-IO-S Notes, to
satisfy the credit risk-retention requirements under Section 15G of
the Securities Exchange Act of 1934 and the regulations promulgated
thereunder.

The Seller will have the option, but not the obligation, to
repurchase any mortgage loan that becomes 90 or more days
delinquent under the Mortgage Bankers Association method at the
price equal to the stated principal balance of the loan plus
accrued interested and any advanced amounts, provided that the
total repurchases may not exceed 10% of the aggregate stated
principal balance as of the Cut-Off Date.

On or after the earlier of (1) the three year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, the Administrator, at the Issuer's option, may redeem all
of the outstanding Notes at a price equal to the greater of (a) the
class balances of the related Notes plus accrued and unpaid
interest, including any cap carryover amounts, unreimbursed fee and
expenses, and preclosing deferred and forbearance amounts, and (b)
the aggregate stated principal balance of the mortgage loans plus
accrued and unpaid interest, the fair value of any
real-estate-owned property, unreimbursed advances and fees, and
preclosing deferred and forbearance amounts. After such purchase,
the Issuer must complete a qualified liquidation, which requires
(1) a complete liquidation of assets within the Trust and (2)
proceeds to be distributed to the appropriate holders of regular or
residual interests.

The Servicers will fund advances of delinquent principal and
interest (P&I) on any mortgage until such loan becomes 180 days
delinquent. The Servicers are obligated to make advances in respect
of taxes, insurance premiums, and reasonable costs incurred in the
course of servicing and disposing properties. The six-month
advancing mechanism may increase the probability of periodic
interest shortfalls in the current economic environment affected by
the Coronavirus Disease (COVID-19) pandemic.

This transaction incorporates a sequential-pay cash flow structure
with a pro rata feature among the senior tranches. Principal
proceeds can be used to cover interest shortfalls on the Class A-1
and A-2 Notes sequentially (IPIP) after a Trigger Event. For more
subordinated Notes, principal proceeds can be used to cover
interest shortfalls as the more senior Notes are paid in full.
Furthermore, excess spread can be used to cover realized losses and
prior period bond writedown amounts first before being allocated to
unpaid cap carryover amounts to Class A-1 down to the Class B-1
Notes.

CORONAVIRUS IMPACT

The coronavirus pandemic and the resulting isolation measures have
caused an immediate economic contraction, leading to sharp
increases in unemployment rates and income reductions for many
consumers. Shortly after the onset of the pandemic, DBRS
Morningstar saw an increase in the delinquencies for many
residential mortgage-backed securities (RMBS) asset classes.

Such mortgage delinquencies were mostly in the form of
forbearances, which are generally short-term periods of payment
relief, that may perform differently from traditional
delinquencies. At the onset of the pandemic, the option to forebear
mortgage payments was widely available, driving forbearances to an
elevated level. When the dust settled, loans with
coronavirus-induced forbearance in 2020 performed better than
expected, thanks to government aid, low loan-to-value ratios, and
acceptable underwriting in the mortgage market in general. Across
nearly all RMBS asset classes in recent months delinquencies have
been gradually trending downwards, as forbearance periods come to
an end for many borrowers.

In connection with the economic stress assumed under its moderate
scenario (see "Global Macroeconomic Scenarios: June 2021 Update,"
published on June 18, 2021), DBRS Morningstar may assume higher
loss expectations for pools with loans on forbearance plans.

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



BAIN CAPITAL 2020-2: S&P Assigns BB- (sf) Rating on E-R Notes
-------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-R, B-R, C-R, D-R, and E-R replacement notes and proposed new
class X-R notes from Bain Capital Credit CLO 2020-2 Ltd., a CLO
originally issued in June 2020 that is managed by Bain Capital
Credit U.S. CLO Manager LLC.

The preliminary ratings are based on information as of July 12,
2021. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the July 19, 2021, refinancing date, the proceeds from the
replacement notes will be used to redeem the original notes. At
that time, S&P expects to withdraw our ratings on the original
notes and assign ratings to the replacement notes. However, if the
refinancing doesn't occur, S&P may affirm its ratings on the
original notes and withdraw its preliminary ratings on the
replacement notes.

The replacement notes will be issued via a proposed supplemental
indenture, which outlines the terms of the replacement notes.
According to the proposed supplemental indenture:

-- The replacement class A-R, B-R, C-R, D-R, and E-R notes are
expected to be issued at a lower spread over three-month LIBOR than
the original notes.

-- The stated maturity will be extended three years.

-- The reinvestment period will be extended three years.

-- There will be a two-year non-call period.

-- The class X-R notes are being issued in connection with this
refinancing. These notes are expected to be paid down using
interest proceeds during the first eight payment dates beginning
with the payment date in October 2021.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis (and other qualitative factors, as applicable)
demonstrated, in our view, that the outstanding rated classes all
have adequate credit enhancement available at the rating levels
associated with the rating actions.

"We will continue to review whether, in our view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Preliminary Ratings Assigned

  Bain Capital Credit CLO 2020-2 Ltd.

  Class X-R, $4.00 million: AAA (sf)
  Class A-R, $248.00 million: AAA (sf)
  Class B-R, $56.00 million: AA (sf)
  Class C-R (deferrable), $24.00 million: A (sf)
  Class D-R (deferrable), $24.00 million: BBB- (sf)
  Class E-R (deferrable), $15.25 million: BB- (sf)
  Subordinated notes, $33.30 million: Not rated



BANK 2019-BNK22: DBRS Confirms BB Rating on Class G Certs
---------------------------------------------------------
DBRS Limited confirmed its ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2019-BNK22 issued by BANK
2019-BNK22 as follows:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction. At issuance, the transaction consisted of 58
fixed-rates loans secured by 131 commercial and multifamily
properties with an aggregate trust balance of $1.2 billion.
According to the June 2021 remittance, all loans remain in the pool
and there has been negligible amortization to date. The transaction
is concentrated by property type as 10 loans, representing 38.4% of
the current trust balance, are secured by office collateral, while
the second-largest concentration comprises eight loans,
representing 19.1% of the current trust balance, secured by
multifamily collateral. There are two loans, representing 2.2% of
the current trust balance, in special servicing; however, both
loans are performing and will return to the master servicer. There
are also 20 loans, representing 29.3% of the current trust balance,
on the servicer's watchlist for cash flow disruption, occupancy
fluctuation, failure to submit financials, and/or deferred
maintenance.

The largest of the watchlist loans, 230 Park Avenue South
(Prospectus ID#2, 9.2% of the current trust balance), was added as
a result of an artificially low debt service coverage ratio (DSCR)
of 0.63x as of YE2020. The loan is secured by a 374,379-square-foot
(sf) office in New York, close to Union Square, and is fully
occupied, with the largest tenant being Discovery Communications
LLC (96.7% of the net rentable area (NRA)), an investment-grade
mass media corporation, which signed a long-term lease expiring
January 2037. As part of the leasing agreement, the tenant received
a 14- month rent abatement period, which ended in June 2021. With
the end of the abatement period, cash flow will likely rise to
expected levels over the next year.

The third-largest loan on the servicer's watchlist, National
Anchored Retail Portfolio (Prospectus ID#14, 2.5% of the current
trust balance) was initially added to the servicer's watchlist in
August 2020 following missed May and June 2020 loan payments, which
the servicer reported were because of Coronavirus Disease
(COVID-19)-related hardships. As of October 2020, the special
servicer approved the borrower's relief request and the loan was
brought current with reserve tenant improvement/leasing commission
reserve funds, which appear to now be empty.

While the loan remains current as of the June 2021 reporting, DBRS
Morningstar continues to monitor the loan given the sponsorship
provided by Washington Prime Group Inc. (WPG), which announced its
Chapter 11 bankruptcy filing June 13, 2021, citing challenges faced
during the coronavirus pandemic as contributing to the filing. WPG
secured $100 million in debtor-in-possession financing to support
daily operations during the bankruptcy proceedings. The filing was
likely, as WPG missed an interest payment on its corporate debt in
February 2021 and was widely reported to be in discussion with
creditors regarding a potential bankruptcy filing since missing the
payment. The bankruptcy filing does not include the subject loan's
sponsor entities, so DBRS Morningstar does not expect the
property-level debt to be directly affected by this latest
development for WPG.

The loan is secured by a five-property anchored retail portfolio
spread across three states, including Illinois (48.5% of the
allocated loan balance (ALB)), Texas (42.5% of ALB), and Indiana
(9.0% of ALB). As of Q1 2020, the portfolio reported an occupancy
rate of 91.2%, while the loan was performing at an annualized DSCR
of 2.93x, in line with the DBRS Morningstar term figure of 2.95x.

At issuance, DBRS Morningstar shadow rated three loans investment
grade, Park Tower at Transbay (Prospectus ID#1, 9.6% of the current
trust balance), 230 Park Avenue South, and Midtown Center
(Prospectus ID#3, 7.4% of the current pool balance). DBRS
Morningstar maintained the shadow ratings on all three loans with
this review.

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



BB-UBS 2012-TFT: DBRS Confirms B(high) Rating on Class TE Certs
---------------------------------------------------------------
DBRS Limited downgraded the ratings on two classes of the
Commercial Mortgage-Pass Through Certificates, Series 2012-TFT
issued by BB-UBS Trust 2012-TFT as follows:

-- Class B to A (high) from AA (low) (sf)
-- Class C to BB (high) from BBB (high) (sf)

DBRS Morningstar also confirmed the ratings on the remaining
classes as follows:

-- Class A at AAA (sf)
-- Class X-A at AAA (sf)
-- Class D at B (low) (sf)
-- Class E at CCC (sf)
-- Class TE at B (high) (sf)

With this review, DBRS Morningstar removed Classes A, X-A, B, C, D,
and TE from Under Review with Negative Implications where they were
placed on October 8, 2020. The trends on Classes C, D, and TE are
Negative. The trends on the remaining classes are Stable, with the
exception of Class E which does not carry a trend.

The downgrades and Negative trends are reflective of the increased
risks to the trust with the updated appraisal figures obtained for
both collateral mall properties, which represent variances ranging
between -11.6% and -50.0% from the respective values at issuance,
as further described below. In addition, both loans are specially
serviced after failing to repay at loan maturity in June 2021;
however, the servicer has confirmed monthly payments will continue
to be paid in the interim as loan modifications and extensions are
being negotiated.

The transaction was originally backed by three separate 7.5-year,
fixed-rate, interest-only (IO) first-mortgage loans with a combined
principal balance of $567.8 million. The three loans were secured
by the Tucson Mall located in Tucson, Arizona; the Fashion Place
mall located in Murray, Utah; and the Town East Mall in Mesquite,
Texas. The loans were sponsored by GGP Limited Partnership, which
Brookfield Property Partners, L.P. acquired in July 2018. The
first-mortgage loans, along with a combined $65.2 million in
mezzanine debt ($40.5 million of which was allocated to Tucson Mall
and the remaining $24.7 million was allocated to Fashion Place)
were used to refinance $341.0 million of existing debt and return
$292.0 million of equity back to the sponsor.

The loans were originally set to mature on June 1, 2020; however,
the sponsor was unable to refinance the outstanding debt, primarily
because of complications surrounding the Coronavirus Disease
(COVID-19) pandemic. The sponsor requested relief and all of the
underlying loans were transferred to special servicing in May 2020
for imminent default. In June 2020, a modification agreement was
executed, which includes the following for all three loans: (1) a
maturity date extension to June 1, 2021, including mezzanine debts;
and (2) the borrower's ability to grant rent deferral without the
servicer's consent, but to a limited degree. Other terms and
conditions have been instituted to permit the basic forbearance
strategy and the loans were returned to the master servicer in
October 2020. The extended maturity date was missed for two of the
three loans, with the Tucson Mall and Town East Mall loans
transferred to special servicing for the second time; however, with
the Fashion Place loan repaid with the June 2021 remittance.

The Tucson Mall loan (Prospectus ID#1, 56.2% of the pool) is
secured by a 667,581-square foot (sf) portion of a 1.3 million-sf
super regional mall in Tucson, Arizona. The property is anchored by
Dillard's, Macy's, JCPenney, Dick's Sporting Goods, and Forever 21,
all of which own their own improvements. Dillard's, Macy's, and
JCPenney sublease the land from the sponsor. In addition to the
current anchor set, a Sears was in place at issuance but vacated
the property in April 2020. No replacement tenant has been signed
to date, but the borrower has previously reported discussions with
Harkins Theatre to take over the space, but nothing has
materialized to date. JCPenney, which filed for Chapter 11
bankruptcy in 2020 and was ultimately acquired by a joint venture
that includes affiliates of the loan sponsor, remains open and no
reports of a planned closure of the subject location have been
published to date. The occupancy rate of 92.2% as of May 2021 is in
line with historical figures. The most recent sales figures for the
trailing 12-month (T-12) period ending March 2021, reported in-line
tenant sales less than 10,000 sf of $345 per square foot (psf),
which represents an 8.5% increase from the T-12 December 2020 sales
of $318 psf.

Over the past few years, the property has shown precipitous revenue
declines as cash flow dropped from $19.5 million as of YE2018 to
$16.8 million as of YE2019. Cash flow declined an additional 17.2%
to $13.9 million at YE2020, a figure that is 42.4% below the
Issuer's underwritten cash flow. Based on the whole loan debt
service, the loan reported a debt service coverage ratio (DSCR) of
1.86 times (x) as of YE2020. An updated appraisal as of April 2020
valued the property at $200.0 million on an as-is basis and $250.0
million as-stabilized, representing a 50.0% decline from $400.0
million at issuance. The appraiser considered the redevelopment of
the former Sears space and the inclusion of the Harkins Theatre
tenant for its as-stabilized estimate. Given the performance
declines that preceded the coronavirus pandemic that could be
exacerbated amid the disruption to brick and mortar retail,
particularly mall properties located in secondary markets, DBRS
Morningstar applied a conservative haircut to the April 2020
appraisal value for this review, resulting in a DBRS Morningstar
Value of $160.0 million, which implies an A-note loan-to-value
(LTV) of 128.4% and a whole loan LTV of 153.8%.

The Town East Mall loan (Prospectus ID#2, 43.8% of the pool) is
secured by a 421,206-sf portion of a 1.2 million-sf regional mall
in Mesquite, Texas, 10 miles east of Dallas. The property is
anchored by Dillard's, JCPenney, and Macy's, all of which have
lease expires in December 2021 and own their own stores, portions
of the land, and parking areas. A noncollateral Sears previously
anchored the mall but closed in April 2021. No replacement tenant
has been identified. Other major retailers at the mall include
Dick's Sporting Goods, Forever 21, and H&M. In a bit of a contrast
to the Tucson Mall's performance in the last few years, the Town
East Mall's performance has been strong since issuance, with
occupancy, including noncollateral anchors, remaining above 95%
since 2009. At YE2020, the loan reported a year-over-year cash flow
decline of 12.3% from YE2019; however, the YE2020 whole loan DSCR
of 3.11x remains 7.7% above the Issuer's underwritten DSCR of
2.89x. The most recent sales figures for the T-12 period ending
December 2020, reported in-line tenant sales less than 10,000 sf of
$431 psf, which represents a 20.0% decline from the T-12 December
2019 sales of $539 psf.

The mall experienced a minor valuation decline with the July 2020
appraisal reporting an as-is value of $224.4 million and an
as-stabilized value of $249.9 million, compared to the issuance
value of $254.0 million. DBRS Morningstar applied a moderate
haircut to the July 2020 value resulting in a DBRS Morningstar
Value of $202.0 million, implying a whole loan LTV of 79.4%.

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



BBCMS 2021-AGW: DBRS Finalizes B(low) Rating on Class G Trust
-------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of BBCMS 2021-AGW Mortgage Trust, Series 2021-AGW, as
follows:

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

All trends are Stable. Class HRR is not rated by DBRS Morningstar.

Class X-CP and X-NCP are interest-only (IO) classes whose balance
is notional.

The BBCMS 2021-AGW Mortgage Trust single-asset/single-borrower
transaction is collateralized by the leasehold interest in 16
cross-collateralized, suburban office assets totaling approximately
two million sf located on the North Shore of Long Island, NY.
Angelo Gordon purchased a 95.5% leasehold interest in the portfolio
in November 2019 from the WE'RE Group (WE'RE), which retained the
remaining 4.5% leasehold interest and 100% of the leased fee
interest. The acquisition coincided with a bifurcation of the fee
and leasehold interests and the creation of new 99-year Section 467
leases for each asset. The Section 467 leases were used for tax
planning purposes on behalf of WE'RE, who developed each of the
assets in the portfolio from 1970 to 2007.

As of June 2021, the portfolio is 86.8% occupied by a diverse
roster of tenants in the medical, finance, and law industries with
no single tenant comprising more than 24.1% of base rent or 18.3%
of NRA. Approximately 50.6% of base rent is derived from
investment-grade tenants and/or tenants with investment-grade
parent entities and the top three tenants include ProHealth Corp.
(24.1% of base rent), Northwell Health (10.5% of base rent), and
Newsday (5.8% of base rent). Outside of the top three tenants, no
single tenant represents more than 3.3% of base rent or 3.7% of
NRA. The weighted average (WA) remaining lease term and WA tenure
of the portfolio are 6.1 years and 14.8 years, respectively.
Medical tenants comprise 53.8% of base rent and have a WA tenure of
16.3 years. Since acquisition, the sponsor has executed more than
440,000 sf of new and renewal leasing (approximately 21.7% of NRA),
improving net operating income by approximately $12 million.

Only 50.9% of base rent and 40.3% of leased sf expire during the
fully extended loan term. Tenants representing no more than 12.0%
of NRA or 16.2% of base rent roll in any single year during fully
extended loan term. The WA remaining lease term of the 10 largest
tenants, which comprise 59.5% of base rent, is 6.6 years, and the
WA remaining lease term for the portfolio is 6.1 years.

The sponsorship is a joint venture between Angelo Gordon and WE'RE.
Angelo Gordon has been investing in commercial real estate since
1993 and has acquired more than $35 billion of properties globally.
Angelo Gordon's investment strategies span a broad spectrum of
value creation, ranging from light value add to heavy value add,
with the goal of increasing cash flow and stabilizing
underperforming properties. The WE'RE Group, owned by the Rechler
and Wexler families, has designed, built, owned, and managed more
than 10 million sf of commercial real estate in Long Island, NY,
over the past 50 years. WE'RE exhibits tenant retention rates of
90% across its entire portfolio and has decades of experience in
owning and operating Long Island office properties.

The portfolio is well located along the North Shore of Long Island,
which contains some of Long Island's strongest submarkets and all
assets are located within close proximity of major arterials
including the Northern Parkway and the Long Island Expressway. The
western Nassau County assets, which represent 61.8% of portfolio
NOI, are proximate to Long Island Jewish Hospital and North Shore
University Hospital, which merged in 2016 to form Northwell Health.
These renowned hospitals are major demand drivers for medical
office space on the North Shore.

The proximity of the properties to the major hospitals on Long
Island's North Shore makes the portfolio a highly desirable
location for medical tenants, which comprise approximately 53.8% of
base rent with a WA tenure of 16.3 years vs 14.8 years at the
property overall. Medical tenants tend to receive above market
allocations for tenant improvements, but will often spend
additional capital on the build out of their space. This larger
upfront investment substantially increases potential relocation
costs upon lease expiration and increases probability of renewal.

New supply has been limited because of the infill nature of the
portfolio's submarkets and the high surrounding population density.
Per the appraisals, two of the submarkets, Western and Eastern
Nassau (collectively 63.9% of NRA) have had no new supply within
the past 12 months and no new construction is under way. Western
Suffolk (36.1% of NRA) has only had 15,000 sf of new supply within
the past 12 months and only 65,700 sf of new supply (0.3% of total
submarket inventory) is currently under construction.

The DBRS Morningstar LTV is high at 99.7% based on the $350 million
in total mortgage debt. In order to account for the high leverage,
DBRS Morningstar programmatically reduced its LTV benchmark targets
for the transaction by 1.5% across the capital structure.

The sponsor is partially using proceeds from the mortgage loan to
repatriate approximately $98.1 million of equity. DBRS Morningstar
views cash-out refinancing transactions as less favorable than
acquisition financings because sponsors typically have less
incentive to support a property through times of economic stress if
less of their own cash equity is at risk. Based on the appraiser's
as-is valuation of $458.7 million, the sponsor will have
approximately $108.7 million of unencumbered market equity
remaining in the transaction.

The nonrecourse carveout guarantors are five Angelo Gordon fund
entities on a several (and not joint basis) that are required to
maintain an aggregate minimum net worth of at least $200 million,
exclusive of the properties with no liquidity requirement. This
effectively limits the recourse to the sponsor for bad act
carveouts. "Bad boy" guarantees and consequent access to the
guarantor help mitigate the risk and increased loss severity of
bankruptcy, additional encumbrances, unapproved transfers, fraud,
misappropriation of rents, and other potential bad acts of the
borrower or its sponsor.

The loan allows for pro rata paydowns associated with property
releases for the first 20% of the unpaid principal balance. The
loan has been structured with a partial pro rata/sequential-pay
structure. DBRS Morningstar considers this structure credit
negative, particularly at the top of the capital stack. Under a
partial pro rata structure, deleveraging of the senior notes
through the release of individual properties occurs at a slower
pace compared with a sequential-pay structure. DBRS Morningstar
applied a penalty to the transaction's capital structure to account
for the pro rata nature of certain voluntary prepayments.

Individual properties are permitted to be released with customary
requirements. However, the prepayment premium for the release of
individual assets is 105% of the allocated loan amount for the
applicable property up to 10% of the original principal balance,
110% of the ALA for the applicable property up to 20% and 115%
thereafter. With regard to the individual assets located within the
Lake Success Quadrangle, the release price shall equal 115% at any
given time for: 1 Dakota Drive; 3000 Marcus Avenue; 2800 Marcus
Avenue; 3 Delaware Drive; 3003 New Hyde Park; 5 Delaware Drive; and
6 Ohio Drive and 120% at any given time for: 3 Dakota Drive; 5
Dakota Drive; 2 Ohio Drive; and 4 Ohio Drive. DBRS Morningstar
elected not to apply a penalty to the transactions capital
structure as 63.5% of the portfolio by ALA is subject to a release
price of 115% or greater, which DBRS Morningstar considers to be
credit neutral.

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



BBCMS MORTGAGE 2020-C8: DBRS Confirms B Rating on Class J-RR Certs
------------------------------------------------------------------
DBRS Limited confirmed its ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2020-C8 issued by BBCMS Mortgage
Trust 2020-C8 Trust as follows:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction. At issuance, the transaction consisted of 48
fixed-rates loans secured by 127 commercial and multifamily
properties with a trust balance of $700.2 million. As of the June
2021 remittance, all loans remain in the pool and there has been
negligible amortization to date. The transaction is concentrated by
property type as 10 loans, representing 36.4% of the current trust
balance, are secured by office collateral, while the second-largest
concentration comprises 12 loans, representing 15.8% of the current
trust balance, secured by self-storage collateral. There are four
loans, representing 16.3% of the current trust balance, on the
servicer's watchlist for cash flow disruption, outstanding
advances, and deferred maintenance. No loans are specially serviced
as of June 2020.

The largest loan on the watchlist, the MGM Grand & Mandalay Bay
loan, is secured by the fee-simple interests in the MGM Grand and
Mandalay Bay, two full-service luxury resorts and casinos
consisting of 9,748 rooms on the Las Vegas Strip. The loan was
added to the servicer's watchlist in April 2021 as a result of a
suppressed debt service coverage ratio as both properties'
operations have struggled as a result of the ongoing effects of the
Coronavirus Disease (COVID-19) pandemic. Both properties are now
reopened and operational, although certain amenities appear to be
somewhat limited. Sponsorship is provided by a joint venture
between Blackstone Real Estate Income Trust (49.9%) and MGM Growth
Properties (50.1%), which together acquired the property for $4.6
billion as part of a sale-lease back transaction including $1.6
billion of equity. The sponsors subsequently executed a 30-year
triple net master lease with two 10-year renewal options. Under the
terms of the master lease, MGM Tenant is required to make an
initial master lease payment of $292 million per annum, with $159
million allocated to MGM Grand and $133 million allocated to
Mandalay Bay. The loan remains current as of the June 2021
reporting.

At issuance, DBRS Morningstar shadow rated two loans investment
grade, including One Manhattan West (Prospectus ID#1, 10.0% of the
pool) and MGM Grand & Mandalay Bay (Prospectus ID#3, 10.0% of the
pool). DBRS Morningstar maintained the shadow ratings on both loans
with this review given their strong credit characteristics
associated with the senior A note debt.

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


BBCMS MORTGAGE 2021-C10: Fitch Affirms Final B- Rating on 2 Certs
-----------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to
BBCMS Mortgage Trust 2021-C10, commercial mortgage pass-through
certificates, Series 2021-C10.

Fitch's ratings and Rating Outlooks are as follows:

-- $23,478,000 class A-1 'AAAsf'; Outlook Stable;

-- $24,100,000 class A-2 'AAAsf'; Outlook Stable;

-- $480,300,000 class A-5 'AAAsf'; Outlook Stable;

-- $40,774,000 class A-SB 'AAAsf'; Outlook Stable;

-- $568,652,000b class X-A 'AAAsf'; Outlook Stable;

-- $146,225,000b class X-B 'A-sf'; Outlook Stable;

-- $75,144,000 class A-S 'AAAsf'; Outlook Stable;

-- $35,540,000 class B 'AA-sf'; Outlook Stable;

-- $35,541,000 class C 'A-sf'; Outlook Stable;

-- $38,587,000bc class X-D 'BBB-sf'; Outlook Stable;

-- $11,170,000bc class X-F 'BB+sf'; Outlook Stable;

-- $8,124,000bc class X-G 'BB-sf'; Outlook Stable;

-- $8,123,000bc class X-H 'B-sf'; Outlook Stable;

-- $21,325,000c class D 'BBBsf'; Outlook Stable;

-- $17,262,000c class E 'BBB-sf'; Outlook Stable;

-- $11,170,000c class F 'BB+sf'; Outlook Stable;

-- $8,124,000c class G 'BB-sf'; Outlook Stable;

-- $8,123,000c class H-RR 'B-sf'; Outlook Stable;

The following classes are not rated by Fitch:

-- $31,479,939 Class J-RR

-- $31,479,939 Class X-J

-- $22,208,016 Class RR

-- $12,213,699 RR Interest

(a) Notional amount and interest only.

(b) Privately-placed and pursuant to Rule 144a.

(c) The Class H-RR and J-RR certificates collectively are the
"eligible horizontal residual interest."

TRANSACTION SUMMARY

The ratings are based on information provided by the issuer as of
July 13, 2021.

Since Fitch published its expected ratings on June 21, 2021, the
following changes occurred: The balances for class A-4 and A-5 were
finalized. At the time that the expected ratings were assigned, the
exact initial certificate balances of class A-4 and class A-5 were
unknown and expected to be approximately $480,300,000 in aggregate.
The final class balances for class A-4 and class A-5 are $0 and
$480,300,000, respectively. As class A-4 no longer has a balance it
has been withdrawn from the transaction and is no longer a part of
the deal structure.

The certificates and the RR Interest represent the beneficial
ownership interest in the trust, primary assets of which are 64
loans secured by 127 commercial properties having an aggregate
principal balance of $846,782,655 as of the cutoff date. The loans
were contributed to the trust by Societe Generale Financial
Corporation, Barclays Capital Real Estate Inc., Starwood Mortgage
Capital LLC, UBS AG and KeyBank National Association. The Master
Servicer is expected to be KeyBank National Association and the
Special Servicer is expected to be Rialto Capital Advisors, LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 45.9% of the properties
by balance, cash flow analyses of 79.5% of the pool, and asset
summary reviews on 100% of the pool.

Coronavirus Impact: The ongoing containment effort related to the
coronavirus (which causes COVID-19) pandemic may have an adverse
impact on near-term revenue (i.e. bad debt expense, rent relief)
and operating expenses (i.e. sanitation costs) for some properties
in the pool. Delinquencies may occur in the coming months as
forbearance programs are put in place, although the ultimate impact
on credit losses will depend heavily on the severity and duration
of the negative economic impact of the coronavirus pandemic, and to
what degree fiscal interventions by the U.S. federal government can
mitigate the impact on consumers. Per the offering documents, all
of the loans are current and are not subject to any forbearance
requests.

Fitch has withdrawn the class A-4 expected rating as it is no
longer expected to convert to a final rating.

KEY RATING DRIVERS

Leverage Exceeds that of Recent Transactions: The pool has a higher
leverage than those of other recent multiborrower transactions
rated by Fitch. The pool's Fitch loan-to-value ratio (LTV) of
105.2% is higher than the YTD 2021 and 2020 averages of 101.6% and
99.6%, respectively. Additionally, the pool's Fitch debt service
coverage ratio (DSCR) of 1.29x is lower than the YTD 2021 and 2020
averages of 1.39x and 1.32x, respectively.

Investment-Grade Credit Opinion Loans: Only two loans representing
8.2% of the pool received an investment-grade credit opinion. MGM
Grand & Mandalay Bay, representing 5.8% of the pool, received a
standalone credit opinion of 'BBB+sf', and Kings Plaza,
representing 2.4% of the pool received a standalone credit opinion
of 'BBB-sf'. This is below the YTD 2021 average of 15.0% and
considerably below the 2020 average of 24.5%.

High Multifamily Exposure and Low Retail and Hotel Exposure: Loans
secured by traditional multifamily properties represent 21.1% of
the pool by balance, including four of the top 20 loans. The total
multifamily concentration is higher than the YTD 2021 and 2020
averages of 14.2% and 16.3%, respectively. Loans secured by
multifamily properties have a lower probability of default in
Fitch's multiborrower model, all else equal.

Loans secured by retail properties represent 9.3% of the pool by
balance, lower than the YTD 2021 and 2020 averages of 16.5% and
16.3%, respectively. There is only one hotel loan in the pool
(Wyndham national Hotel Portfolio), which accounts for 1.2% of the
cutoff. Fitch considers hotel and retail asset types to have the
greatest downside risk among all commercial asset types as a result
of the coronavirus pandemic.

Diverse Pool: The pool's 10 largest loans represent 42.6% of the
pool's cutoff balance, which is considerably lower than the YTD
2021 and 2020 averages of 53.5% and 56.8%, respectively. The pool's
LCI of 281 is also considerably lower than the YTD 2021 and 2020
averages of 405 and 440, respectively. 2020 and 2019 averages of
56.8% and 51.0%, respectively. The SCI of 302 indicates that there
is little sponsor concentration.

RATING SENSITIVITIES

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

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

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

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

-- 10% NCF Decline: 'AA+sf' / 'A+sf' / 'BBB+sf' / 'BBB-sf' /
    'BB+sf' / 'BBsf' / 'B+sf' / CCCsf'

-- 20% NCF Decline: 'A-sf' / 'BBBsf' / 'BB+sf' / 'BB-sf' /
    'CCCsf' / 'CCCsf' / 'CCCsf' / 'CCCsf'

-- 30% NCF Decline: 'BBBsf' / 'BB+sf' / 'Bsf' / 'CCCsf' / 'CCCsf'
    / 'CCCsf' / 'CCCsf' / 'CCCsf'

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

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

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

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

BEST/WORST CASE RATING SCENARIO

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Ernst & Young, LLP. The third-party due diligence
described in Form 15E focused on a comparison and re-computation of
certain characteristics with respect to each of the mortgage loans.
Fitch considered this information in its analysis and it did not
have an effect on Fitch's analysis or conclusions.

DATA ADEQUACY

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


BRSP 2021-FL1: DBRS Gives Prov. B(low) Rating on Class G Notes
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
notes to be issued by BRSP 2021-FL1, Ltd.:

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

All trends are Stable.

Coronavirus Overview

With regard to the Coronavirus Disease (COVID-19) pandemic, the
magnitude and extent of performance stress posed to global
structured finance transactions remains highly uncertain. This
considers the fiscal and monetary policy measures and statutory law
changes that have already been implemented or will be implemented
to soften the impact of the crisis on global economies. Some
regions, jurisdictions, and asset classes are, however, feeling
more immediate effects. Accordingly, DBRS Morningstar may apply
additional short-term stresses to its rating analysis. For example,
DBRS Morningstar may front-load default expectations and/or assess
the liquidity position of a structured finance transaction with
more stressful operational risk and/or cash flow timing
considerations.

The initial collateral consists of 31 floating-rate mortgages
secured by 41 mostly transitional properties, with a cut-off
balance totaling $800.0 million, excluding approximately $58.1
million of future funding commitments. The trust comprises one
combined loan and 30 participations in mortgage loans. The combined
loan, 360 Wythe (Prospectus #13), includes a mortgage loan and
related mezzanine loan that DBRS Morningstar treated as a single
loan. There is one delayed close loan, BELA Apartments (Prospectus
#4), that is expected to close on or prior to the closing date or
within six months after the closing date. If the loan does not
close during this period, the funds may be used to acquire
additional collateral subject to the eligibility criteria as
detailed in the offering memorandum. Most loans are in a period of
transition with plans to stabilize operations and improve the asset
value. The transaction stipulates a $1.0 million threshold on
companion participation acquisitions before a rating agency
confirmation (RAC) is required if there is already a participation
of the underlying loan in the trust.

For the floating-rate loans, DBRS Morningstar used the one-month
Libor index, which is based on the lower of a DBRS Morningstar
stressed rate that corresponded to the remaining fully extended
term of the loans or the strike price of the interest rate cap with
the respective contractual loan spread added to determine a
stressed interest rate over the loan term. When the cut-off
balances were measured against the DBRS Morningstar As-Is Net Cash
Flow (NCF), 21 loans, totaling 76.2% of the initial pool, had a
DBRS Morningstar As-Is Debt Service Coverage Ratio (DSCR) below
1.00 times (x), a threshold indicative of default risk. However,
the DBRS Morningstar Stabilized DSCR for only six loans,
representing 23.5% of the initial pool balance, are below 1.00x.
The properties are often transitioning with potential upside in
cash flow; however, DBRS Morningstar does not give full credit to
the sponsor's stabilization plan if there are no holdbacks or if
other loan structural features in place are insufficient to support
such treatment. Furthermore, even with the structure provided, DBRS
Morningstar generally does not assume the assets to stabilize above
market levels.

Five loans were originated prior to the onset of the Coronavirus
Disease (COVID-19) pandemic. Those loans are backed by collateral
in markets where shutdowns were more pronounced and may have some
uncertainty in their near-term recovery. In addition, because they
were originated prior to 2020, there may be less time for the
respective borrowers to realize their business plan. DBRS
Morningstar believes that the transaction may be exposed to losses
beyond the base case pool loss captured within the CMBS Insight
Model described in the "North American CMBS Multi-Borrower
Methodology." DBRS Morningstar materially deviated from its "CMBS
Insight Model" when determining the ratings assigned to Class B,
which deviated from the higher ratings implied by the quantitative
results. The material deviation is also driven in part by the
Issuer's proposed capital structure representing a more
conservative pool composition than the current assets contributed
to the trust. Such capital structure would allow for negative drift
in concentration as allowed by the Eligibility Criteria. The
Eligibility Criteria also require receipt of a No Downgrade
Confirmation to be provided by DBRS Morningstar in connection with
the trust's acquisition of a Ramp-Up Collateral Interest or
Reinvestment Collateral Interest, which would also provide a
barrier to negative concentration drift, if needed. DBRS
Morningstar considers a material deviation from a model to exist
when there may be a substantial likelihood that a reasonable
investor or other user of the credit ratings would consider the
material deviation to be a significant factor in evaluating the
ratings.

The transaction will have a sequential-pay structure.

The loans are generally secured by traditional property types
(e.g., multifamily, office, and industrial), with no hotel loans in
the pool. There is a 72.1% multifamily concentration in the pool,
which is considerably higher than recent commercial real estate
collateralized loan obligation (CRE CLO) transactions rated by DBRS
Morningstar that are not exclusively limited to one property type.
The largest loan in the pool, Clutter NYC Portfolio, is secured by
four self-storage properties, the highest performing property type
DBRS Morningstar observed.

The initial pool exhibits a Herfindahl score of 24.4, given the 31
collateral interests, which is favorable for a CRE CLO and higher
than most recent CRE CLO transactions rated by DBRS Morningstar.

The weighted-average (WA) DBRS Morningstar Stabilized Loan-to-Value
is 67.0%. This credit metric compares favorably with recent CRE CLO
transactions rated by DBRS Morningstar, resulting in lower loan
level probability of defaults (PODs) and loss severity given
defaults (LGDs).

The pool exhibits a WA DBRS Morningstar Business Plan Score of
1.99, which is considerably lower than recent CRE CLO transactions
rated by DBRS Morningstar. The low Business Plan Score indicates
that borrowers have the necessary funds to achieve their business
plans, proper loan structures, and adequate upside cash flow
potential. The score also reflects that many loans in the pool have
achieved the proposed stabilized operations.

The sponsor for this transaction, BrightSpire, is an experienced
CRE CLO issuer and collateral manager. BrightSpire was previously
managed externally by Colony Capital Inc., before completing an
internalization of management in April 2021. The sponsor had a $1.3
billion market capitalization and $4.1 billion in total assets as
of March 31, 2021. BrightSpire, under Colony Capital Inc.'s
management, has completed one CRE CLO securitization, CLNC
2019-FL1, Ltd., which is rated by DBRS Morningstar. Additionally,
BRSP 2021-FL1 DRE, LLC (BRSP), a wholly-owned subsidiary of
BrightSpire, will purchase and retain 100.0% of the Class F Notes,
Class G Notes, and Preferred Shares, which represent 16.25% of the
transaction total.

Five loans in the pool were originated before April 2020 at the
onset of the coronavirus pandemic in the U.S., including the
largest loan in the pool. The ongoing coronavirus pandemic
continues to pose challenges and risks to the CRE sector, and the
long-term effects on the general economy and consumer sentiment are
still unclear. All properties were appraised or reappraised in late
2020 or early 2021, and the recent appraisals incorporated the
current property performance and changes to market conditions as a
result of the coronavirus pandemic. All loans in the pool are
current on debt service payments as of the cut-off date and no
loans in the pool requested any form of forbearance throughout the
coronavirus pandemic.

The transaction is managed and includes a ramp-up component and
reinvestment period, which could result in negative credit
migration and/or an increased concentration profile over the life
of the transaction. The ramp-up period only goes into effect if the
BELA Apartments loan does not close within six months of the
transaction's closing date. DBRS Morningstar believes this is
unlikely, and if the loan does not close, there will be relatively
minimal funding for the ramp-up period. Additionally, these funds
will be subject to the eligibility criteria as stipulated in the
offering memorandum. DBRS Morningstar has RAC for ramp loans,
companion participations above $1.0 million, and new reinvestment
loans. DBRS Morningstar will analyze these loans for potential
ratings impacts.

DBRS Morningstar has analyzed the loans to a stabilized cash flow
that is, in some instances, above the in-place cash flow. It is
possible that the sponsors will not successfully execute their
business plans and that the higher stabilized cash flow will not
materialize during the loan term, particularly with the ongoing
coronavirus pandemic and its impact on the overall economy. A
sponsor's failure to execute the business plan could result in a
term default or the inability to refinance the fully funded loan
balance. DBRS Morningstar determined a sample size that represents
74.8% of the pool cut-off date balance. While site inspections did
not occur, DBRS Morningstar did a thorough analysis of all
third-party documents and loan documents from the Issuer. DBRS
Morningstar made relatively conservative stabilization assumptions
and, in each instance, considered the business plan to be rational
and the loan structure to be sufficient to execute such plans. In
addition, DBRS Morningstar analyzes LGDs based on the as-is credit
metrics, assuming the loan is fully funded with no NCF or value
upside. Affiliates of BRSP will hold future funding companion
participations and has the obligation to make future advances. BRSP
agrees to indemnify the Issuer against losses arising out of the
failure to make future advances when required under the related
participated loan. Furthermore, BRSP will be required to meet
certain liquidity conditions on a quarterly basis.

All 31 loans have floating interest rates, and all loans are
interest only during the original term, except for one loan with
minimal amortization. Additionally, all loans have original terms
ranging from 12 months to 36 months, creating interest rate risk.
All loans are short-term loans, and even with extension options,
they have a fully extended maximum loan term of five years to six
years. For the floating-rate loans, DBRS Morningstar used the
one-month Libor index, which is based on the lower of a DBRS
Morningstar stressed rate that corresponded to the remaining fully
extended term of the loans or the strike price of the interest rate
cap with the respective contractual loan spread added to determine
a stressed interest rate over the loan term.

The pool reflects a WA DBRS Morningstar Market Rank of 4.42,
indicative of a higher concentration of suburban markets, which
generally experience higher PODs and LGDs. There are 15 loans,
representing 43.2% of the pool that fall in a DBRS Morningstar
Market Rank of 3 or 4, which represents a higher POD. Conversely,
only five loans, representing 13.0% of the pool, are secured by
properties in DBRS Morningstar Market Ranks of 6, 7, and 8, which
tend to be more urban in nature. The pool has a Herfindahl index of
24.4, which indicates a highly diversified pool. There are 41
properties in the pool, which is more than many of the recent CRE
CLO transactions rated by DBRS Morningstar. There were several
loans in the pool that received beneficial treatment because of
their property quality. Three loans, representing 16.3% of the
pool, received Above Average property quality scores, and seven
loans, representing 28.2% of the pool, received Average + property
quality scores. No loans in the pool received a property quality
score that was below Average.

Five loans were originated prior to the onset of the coronavirus
pandemic. Those loans are backed by collateral in markets where
shutdowns were more pronounced and may have some uncertainty in
their near-term recovery. In addition, because they were originated
prior to 2020, there may be less time for the respective borrowers
to realize their business plan. DBRS Morningstar believes that the
transaction may be exposed to losses beyond the base-case pool loss
captured within the CMBS Insight Model described in the "North
American CMBS Multi-Borrower Rating Methodology." DBRS Morningstar
materially deviated from its CMBS Insight Model when determining
the ratings assigned to Class B, which deviated from the higher
ratings implied by the quantitative results. The material deviation
is also driven in part by the Issuer's proposed capital structure
representing a more conservative pool composition than the current
assets contributed to the trust. Such capital structure would allow
for negative drift in concentration as allowed by the Eligibility
Criteria. The Eligibility Criteria also require receipt of a No
Downgrade Confirmation to be provided by DBRS Morningstar in
connection with the trust's acquisition of a Ramp-Up Collateral
Interest or Reinvestment Collateral Interest, which would also
provide a barrier to negative concentration drift, if needed. DBRS
Morningstar considers a material deviation from a model to exist
when there may be a substantial likelihood that a reasonable
investor or other users of the credit ratings would consider the
material deviation to be a significant factor in evaluating the
ratings.

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


CG-CCRE COMMERCIAL 2014-FL2: S&P Cuts STC1 Certs Rating to 'CCC-'
-----------------------------------------------------------------
S&P Global Ratings lowered its ratings on eight classes of
commercial mortgage pass-through certificates from CG-CCRE
Commercial Mortgage Trust 2014-FL2, a U.S. CMBS transaction. At the
same time, S&P affirmed its rating on class COL2 from the same
transaction.

This is a U.S. large-loan CMBS transaction currently backed by two
uncrossed floating-rate mortgage loans, each secured by a regional
mall property.

Rating Actions

The downgrades on the class A, B, C, D, and E pooled certificates
primarily reflect our re-evaluation of the two regional mall
properties that secure the two remaining mortgage loans: South
Towne Center ($107.7 million; 59.6% of pooled trust balance) and
Colonie Center ($73.2 million; 40.4%) in the trust, based on our
review of the updated lower-than-expected March 2021 appraisal
value for the South Towne Center loan (57.4% lower than the
appraisal value at issuance) and the two malls' most recent
available performance data provided by the servicers.

S&P said, "Our expected-case value, in aggregate, has declined
19.6% since our last review in December 2019. The decline in our
overall valuation is driven primarily by the lower S&P Global
Ratings' sustainable net cash flow (NCF) (down 14.1%, in aggregate,
since our last review) to account for the decline in reported
performance due primarily to the negative impact of the COVID-19
pandemic and the application of a higher S&P Global Ratings'
capitalization rate for the two remaining loans.

"Our downgrade and affirmation on the class COL1 and COL2 nonpooled
certificates, respectively, reflect our reevaluation of the Colonie
Center loan, while the downgrade on class STC1 non-pooled
certificates reflectd our reevaluation of the South Town Center
loan. Specifically, compared to our last review, our expected-case
value is 8.4% lower for the Colonie Center loan and 29.0% lower for
the South Towne Center loan.

"In addition, the downgrades on classes E, COL1, and STC1 and the
affirmation on class COL2 reflect our view that, based on an S&P
Global Ratings' loan-to-value (LTV) ratio of over 100% on the two
remaining loans, these classes are more susceptible to reduced
liquidity support and the risk of default and loss have increased
due to the uncertain market conditions. In addition, according to
the June 15, 2021 trustee remittance report, class E reported
accumulated interest shortfalls of $12,152, due primarily to
reimbursement for interest on advances. If the accumulated interest
shortfalls remain outstanding for a prolonged period of time, we
may take further rating action on class E.

"While the model-indicated rating on class A was higher than the
class' revised rating level, we downgraded the class to 'AA (sf)'
because we qualitatively considered the class' exposure to retail
mall properties and the potential for their performance and
valuation to decline further due to the changing retail mall
landscape. Furthermore, we qualitatively considered that the two
remaining loans, while recently modified and extended, were
transferred to special servicing in 2019 because the sponsors were
unable to pay them off upon their final maturity dates in 2019
(details below).

"We lowered our rating on the class X-EXT interest-only (IO)
certificates based on our criteria for rating IO securities, in
which the rating on the IO security would not be higher than that
of the lowest-rated reference class. The notional balance of class
X-EXT references the aggregate balances of the pooled certificate
classes."

Transaction Summary

This is a U.S. large-loan CMBS transaction backed by two uncrossed
floating-rate mortgage loans indexed to one-month LIBOR, down from
six loans at issuance. As of the June 15, 2021, trustee remittance
report, the trust had a pooled trust balance of $180.9 million and
an aggregate trust balance of $248.7 million (including the
non-pooled loan components), down from $410.2 million and $512.0
million, respectively, at issuance. The pooled trust has not
incurred any principal losses to date.

S&P's property-level analysis included a reevaluation of the two
regional malls backing the two remaining loans in the pool using
servicer-provided operating statements from 2017 through available
year-to-date period ended March 31, 2021, the available 2021 rent
rolls, and the 2021 borrower's budget.

Details on the two remaining loans are as follows:

-- The South Towne Center loan, the larger of the two remaining
loans in the pool, has a whole loan balance of $139.4 million that
is divided into a $107.7 million senior pooled trust component
(59.6% of the pooled trust balance) and a $31.7 million subordinate
nonpooled trust component that supports the class STC1, STC2, and
STC3 certificates. Classes STC2 and STC3 are not rated by S&P
Global Ratings. At loan origination, the equity interest in the
borrower of the whole loan secured $20.0 million in mezzanine debt.
However, it is S&P's understanding that as part of the recent loan
modification, the mezzanine debt was extinguished. The IO whole
loan pays a floating interest rate of LIBOR plus gross margin
(2.49718% [pooled] and 4.6168% [nonpooled]) per year, and
originally matured on Nov. 9, 2019. The loan, which has a reported
current payment status, was transferred to special servicing on
Oct. 30, 2019, due to imminent maturity default. According to the
special servicer, KeyBank Real Estate Capital, the loan has
subsequently been assumed and modified on May 13, 2021, and is
expected to return to the master servicer in the near term. As part
of the loan modification, a new sponsor assumed the loan and
provided a new guarantor. In addition, the loan's maturity date was
extended to November 2023 with two one-year extension options, and
a 166,000-sq.-ft. anchor space formerly occupied by Dillard's (now
partially occupied by Round One and Home Goods) was contributed as
additional collateral for the loan.

-- The South Towne Center loan is secured by 1.07 million sq. ft.
of a 1.28 million-sq.-ft. super-regional mall and adjacent power
center in Sandy, Utah. Our property-level analysis considered the
generally declining servicer-reported net operating income (NOI):
-10.2% in 2018, +2.4% in 2019, and -11.2% in 2020, due primarily to
decreasing occupancy, base rent, expense reimbursement income, and
other income. According to the March 31, 2021, rent roll, the
occupancy rate for the collateral was 95.8% and the five largest
collateral tenants comprising 57.2% of collateral's net rentable
area (NRA) included: Macy's (18.7% of NRA; July 2021 expiration),
Target (17.1%; May 2026 expiration), JCPenney (9.4%; August 2022
expiration), Automotive Addiction (7.9%; December 2021 expiration)
and Obstacle Warrior Kids (4.1%; April 2028 expiration). The mall
faces significant tenant rollover in 2021 (30.4% of NRA) and 2022
(19.2%), mainly attributable to the four largest collateral
tenants.

S&P said, "Our current analysis on the South Towne Center loan
excluded tenants that had closed, announced impending closures,
and/or had parent companies facing financial uncertainty, including
Macy's (store closing in July 2021) and JCPenney, bringing the
collateral occupancy rate down to 67.1%. We derived our sustainable
NCF of $7.5 million (down 21.1% from our last review). We then
divided our NCF by a 10.00% S&P Global Ratings' capitalization rate
(up from 9.00% in the last review), resulting in our expected-case
value of $74.9 million, down from $105.4 million in the last
review. This yielded an S&P Global Ratings' LTV ratio that was
significantly above 100.0% on the whole loan balance. Our analysis
also considered the March 2021 appraisal value of $88.6 million, a
37.2% and 57.4% decline from the March 2020 and issuance appraisal
values, respectively."

The Colonie Center loan, the smaller of the two loans remaining in
the pool, has a whole loan balance of $109.3 million that is split
into a $73.2 million senior pooled trust component (40.4%) and a
$36.1 million subordinate nonpooled trust component that supports
the class COL1, COL2, COL3, and COL4 certificates. Classes COL3 and
COL4 are not rated by S&P Global Ratings. The whole loan pays a
floating interest rate of LIBOR plus gross margin (1.74720%
[pooled] and 4.93610% [nonpooled]) per year, and originally matured
on Aug. 9, 2019. The whole loan was transferred to special
servicing on July 26, 2019, for imminent default because the
borrower was unable to pay off the loan at maturity. Moreover, the
borrower had unsuccessfully tried to sell the property in early
2020. According to the special servicer, LNR Partners LLC, the
whole loan, which has a reported current payment status, was
modified effective Feb. 9, 2021, and was recently returned to the
master servicer in June 2021 as a corrected mortgage loan. The
modification terms included among other items, extending the loan's
maturity date to Dec. 9, 2023, and converting to principal and
interest payments from monthly IO.

The Colonie Center whole loan is secured by 759,750 sq. ft. of a
1.33 million-sq.-ft. super-regional mall in Albany, N.Y. The
servicer-reported NOI for 2015 through 2019 has been relatively
stable; however, it dropped materially partly because of the
COVID-19 pandemic, to $6.0 million, a 45.7% decline from 2019.
Based on the Jan. 1, 2021, rent roll, the collateral's occupancy
was 98.5%, and the five-largest collateral tenants, which made up
53.8% of collateral NRA, included: Boscov's (29.8% of collateral
NRA; October 2028 expiration), Christmas Tree Shop (7.5%; December
2023 expiration), Regal Cinemas (7.3%; May 2023 expiration),
Nordstrom Rack (4.6%; September 2025 expiration), and Barnes &
Nobles Booksellers (4.6%; January 2023 expiration). S&P noted that
the noncollateral former Sears' anchor space (275,811 sq. ft.) is
partially leased to Whole Foods. In addition, the property faces
concentrated tenant rollover in 2023 (22.4% of NRA) and 2028
(34.6%), mainly attributable to some of the largest tenants noted
above.

S&P said, "Our current analysis on the Colonie Center loan excluded
tenants that are no longer listed on the mall directory website or
had expired lease terms, bringing the collateral occupancy rate
down to 94.9%. We derived our sustainable NCF of $7.6 million (down
5.8% from our last review). Using an S&P Global Ratings'
capitalization rate of 9.25%, up from 9.00% in our last review, we
arrived at our expected-case value of $81.7 million, down from
$89.2 million in the last review. Our expected-case value yielded
an S&P Global Ratings' LTV ratio above 100% on the whole loan
balance."

Environmental, social, and governance (ESG) factors relevant to the
rating action:

-- Health and safety.

  Ratings Lowered

  CG-CCRE Commercial Mortgage Trust 2014-FL2

  Class A: to 'AA (sf)' from 'AAA (sf)'
  Class B: to 'BBB (sf)' from 'A+ (sf)'
  Class C: to 'B (sf)' from 'BB+ (sf)'
  Class D: to 'B- (sf)' from 'BB- (sf)'
  Class E: to 'CCC (sf)' from 'B- (sf)'
  Class X-EXT: to 'CCC (sf)' from 'B- (sf)'
  Class COL1: to 'CCC- (sf)' from 'B (sf)'
  Class STC1: to 'CCC- (sf)' from 'CCC (sf)'

  Rating Affirmed

  CG-CCRE Commercial Mortgage Trust 2014-FL2

  Class COL2: CCC- (sf)



CITIGROUP COMMERCIAL 2013-GC17: Fitch Rates Class F Certs 'CCC'
---------------------------------------------------------------
Fitch Ratings has downgraded two and affirmed 11 classes of
Citigroup Commercial Mortgage Trust, commercial mortgage
pass-through certificates series 2013-GC17 (CGCMT 2013-GC17). In
addition, the Rating Outlook for one class was revised to Negative
from Stable.

   DEBT               RATING           PRIOR
   ----               ------           -----
CGCMT 2013-GC17

A-3 17321RAC0    LT  AAAsf  Affirmed   AAAsf
A-4 17321RAD8    LT  AAAsf  Affirmed   AAAsf
A-AB 17321RAE6   LT  AAAsf  Affirmed   AAAsf
A-S 17321RAH9    LT  AAAsf  Affirmed   AAAsf
B 17321RAJ5      LT  AAsf   Affirmed   AAsf
C 17321RAL0      LT  Asf    Affirmed   Asf
D 17321RAM8      LT  BBBsf  Affirmed   BBBsf
E 17321RAP1      LT  Bsf    Downgrade  BBsf
F 17321RAR7      LT  CCCsf  Affirmed   CCCsf
PEZ 17321RAK2    LT  Asf    Affirmed   Asf
X-A 17321RAF3    LT  AAAsf  Affirmed   AAAsf
X-B 17321RAG1    LT  AAsf   Affirmed   AAsf
X-C 17321RAV8    LT  Bsf    Downgrade  BBsf

KEY RATING DRIVERS

Increased Loss Expectations: The downgrades reflect increased loss
expectations for the pool since Fitch's prior rating action,
primarily driven by The Outlet Shoppes at Atlanta loan (11.5% of
pool), as well as continued performance deterioration on a greater
number of Fitch Loans of Concern (FLOCs) that have been affected by
the coronavirus pandemic. There are 15 FLOCs (40.2%), three of
which are REO assets (6.2%). Fitch's current ratings incorporate a
base case loss of 7.60%. The Negative Outlooks reflect losses that
could reach 9.50% when factoring a potential outsized loss on The
Outlet Shoppes at Atlanta loan.

The largest increase in loss since the prior rating action is The
Outlet Shoppes at Atlanta loan (11.5%), which is secured by a
retail outlet center located in Woodstock, GA, approximately 30
miles north of Atlanta. This is a FLOC due to performance
deterioration and refinance concerns exacerbated by the coronavirus
pandemic, coupled with weak sponsorship that has filed bankruptcy,
market competition and significant upcoming lease rollover prior to
loan maturity.

Fitch's base case loss expectation increased to 12% from 7% at the
prior rating action, and reflects a 12% cap rate and 15% haircut to
the YE 2020 NOI. Fitch also performed an additional sensitivity
that applied a potential outsized loss of 30% to the loan's
maturity balance, which implies a cap rate of approximately 15% on
the YE 2020 NOI; this scenario contributed to the Negative
Outlooks.

The loan, which is scheduled to mature in November 2023, is
sponsored by a joint venture between Horizon Group Properties and
CBL & Associates Properties, Inc. (CBL). In November 2020, CBL
declared bankruptcy and announced plans to restructure. The largest
tenants include Saks Fifth Avenue OFF 5th (6.7% of NRA leased
through July 2023), Nike Factory Store (3.7%; January 2024) and
Adidas (2.4%; January 2031). Property occupancy was 89.2% as of
April 2021, up slightly from 86.9% in June 2020, but below 94.9%
reported in April 2019.

The recent occupancy improvement is primarily due to a new lease
signed with Adidas for approximately 10 years starting in July
2020. Previously, 10 tenants totaling approximately 9% of the NRA
vacated at or prior to their scheduled lease expirations in 2019
and 2020. Upcoming lease rollover includes 5.1% of the NRA in 2021,
5.8% in 2022 and 38.8% in 2023. YE 2020 NOI declined 18.7% from YE
2019 and the servicer-reported YE 2020 NOI DSCR was 1.47x, compared
with 1.81x at YE 2019.

Inline comparable tenant sales were $381 psf as of TTM March 2021,
down from $448 psf as of TTM March 2020, $450 psf in 2019 and $436
psf in 2018, but remains above sales reported around the time of
issuance of $355 psf. Saks Fifth Avenue OFF 5th reported lower
sales of $96 psf as of TTM March 2021, down from $127 psf as of TTM
March 2019, $144 psf in 2019, $169 psf in 2018 and $210 psf at
issuance.

The next largest increase in loss since the prior rating action is
the REO Park Place Shopping Center asset (2.7%), which is a retail
center in Vallejo, CA that was previously anchored by a Raley's
Supermarket before the location closed in June 2017. The property
was 32.8% occupied as of April 2021, down from 51.8% in June 2020.
Tenant 24 Hour Fitness (previously 14.6% of NRA and 27% of total
base rents), vacated in mid-2020, which was ahead of its July 2023
scheduled lease expiration, after filing for bankruptcy and having
its lease at the property rejected in June 2020. Current tenants
include Satelite Healthcare (8%; November 2023), Aaron's (7.4%;
January 2023) and Bank of the West (2.6%; January 2025).

The loan was transferred to special servicing for imminent monetary
default in June 2020 and the asset became REO in February 2021. Per
the servicer, the property is currently being rezoned, as the City
of Vallejo may redevelop the asset to meet the city's apartment
needs. The servicer plans on marketing the asset after the rezoning
is completed, which is estimated by October 2021. Fitch's expected
loss of approximately 73% factors in a discount to a recent
appraisal valuation, which equates to a stressed value of $33 psf.

Increasing Credit Enhancement (CE): As of the June 2021
distribution date, the pool's aggregate principal balance has paid
down by 30.8% to $600 million from $867 million at issuance. Eight
loans (8.7%) have been defeased, up from six loans (6.5%) at the
prior rating action. The majority of the pool (49 loans; 84.1% of
pool) is currently amortizing and six loans (15.9%) are full-term,
interest-only. All remaining loans in the pool are scheduled to
mature between September and November 2023.

Coronavirus Exposure; High Retail Concentration: Loans secured by
retail, hotel and multifamily properties represent 58.4%, 8.4% and
2.5% of the pool, respectively. The retail exposure includes two
loans (23.7%) secured by a regional mall and an outlet center. The
multifamily exposure includes one student housing loan (Sooner
Crossing; 0.4%).

Fitch's analysis applied additional coronavirus-related stresses on
five retail loans (14.8%) and four hotel loans (4.9%) to account
for potential cash flow disruptions. While these additional
stresses did not directly contribute to the Negative Outlooks,
property performance has yet to stabilize for some of the larger
retail and hotel FLOCs that have been negatively affected by the
coronavirus pandemic.

The largest loan, Miracle Mile Shops (12.1%), is secured by a
regional mall located at the base of the Planet Hollywood Resort &
Casino on the Las Vegas Strip. The mall tenancy is made up of a
variety of retail shops, restaurants and entertainment venues. The
largest tenant is V Theater (8.5% of NRA; December 2023) and the
third largest tenant is Race and Sports Book (4.3%; July 2045).

The mall was temporarily closed due to the pandemic in March 2020
and re-opened in July 2020. The former second largest tenant, Saxe
Theater (5%), vacated in 2020 during the pandemic. With the loss of
several other tenants (12 tenants; 4.2% of NRA), occupancy fell to
88.8% as of April 2021 from 96.7% in April 2020 and 98% in December
2019. The mall had strong historical sales performance prior to the
pandemic. However, inline sales fell to $348 psf as of TTM January
2021 due largely to closures related to the pandemic, from $835 psf
as of TTM February 2020, $817 as of TTM March 2019 and $868 psf at
issuance in 2013.

The loan, which transferred to special servicing in August 2020 due
to the borrower requesting coronavirus relief, was modified. Terms
include a seven-month deferral of principal payments and leasing
reserve deposits from August 2020 through February 2021, with
repayment beginning in March 2021. The loan was subsequently
returned to the master servicer later in August 2020. Fitch's
analysis includes a 20% haircut to the YE 2019 NOI to account for
the occupancy decline and other performance concerns.

RATING SENSITIVITIES

The Negative Rating Outlooks on classes D, E, and X-C reflect
potential downgrades based on the additional sensitivity analysis
performed on The Outlet Shoppes at Atlanta loan, as well as
continued performance concerns on a growing number of FLOCs and the
ultimate impact of the coronavirus pandemic on performance
stabilization. The Stable Rating Outlooks on classes A-3, A-4,
A-AB, A-S, X-A, B, C, X-B and PEZ reflect the stable performance
for the majority of the pool, increasing CE and expected continued
amortization.

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

-- Stable to improved asset performance, particularly on The
    Outlet Shoppes at Atlanta loan and the REO assets, coupled
    with additional paydown and/or defeasance.

-- Upgrades to classes B, X-B, C and PEZ may occur with
    significant improvement in CE and/or defeasance, and with the
    stabilization of performance on the FLOCs and/or the
    properties affected by the coronavirus pandemic; however,
    adverse selection and increased concentrations, or the
    underperformance of the FLOCs could cause this trend to
    reverse.

-- Upgrades to classes D, X-C, E and F are not currently expected
    given continued performance concerns with The Outlet Shoppes
    at Atlanta loan, but could occur if performance stabilizes for
    this outlet center and/or the REO Park Place Shopping Center
    and SpringHill Suites - Willow Grove, PA assets are resolved
    with better recoveries than expected. Classes would not be
    upgraded above 'Asf' if there is a likelihood of interest
    shortfalls.

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

-- An increase in pool-level losses from underperforming or
    specially serviced loans/assets.

-- Downgrades to classes A-3 through A-AB, A-S and X-A and are
    not likely due to the position in the capital structure but
    may occur should interest shortfalls affect these classes.

-- Downgrades to classes B, X-B, C and PEZ may occur should all
    of the FLOCs and/or properties affected by the coronavirus
    pandemic suffer losses, particularly The Outlet Shoppes at
    Atlanta and the REO Park Place Shopping Center and SpringHill
    Suites - Willow Grove, PA assets, or if interest shortfalls
    occur.

-- Downgrades to classes D, E and X-C would occur should loss
    expectations for the pool increase significantly from
    continued performance decline of the FLOCs, loans susceptible
    to the pandemic not stabilize, additional loans default and/or
    transfer to special servicing, higher losses than expected are
    incurred on the REO assets and/or The Outlet Shoppes at
    Atlanta loan experiences an outsized loss.

-- A downgrade to class F would occur as losses are realized
    and/or become more certain.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


CITIGROUP COMMERCIAL 2014-GC19: Fitch Rates Class F Certs 'B'
-------------------------------------------------------------
Fitch Ratings has upgraded two and affirmed 11 classes of Citigroup
Commercial Mortgage Trust 2014-GC19, commercial pass-through
certificates, series 2014-GC19.

   DEBT                RATING           PRIOR
   ----                ------           -----
CGCMT 2014-GC19

A-3 17322AAC6    LT  AAAsf  Affirmed   AAAsf
A-4 17322AAD4    LT  AAAsf  Affirmed   AAAsf
A-AB 17322AAE2   LT  AAAsf  Affirmed   AAAsf
A-S 17322AAF9    LT  AAAsf  Affirmed   AAAsf
B 17322AAG7      LT  AAAsf  Affirmed   AAAsf
C 17322AAH5      LT  AAsf   Upgrade    Asf
D 17322AAM4      LT  BBBsf  Affirmed   BBBsf
E 17322AAP7      LT  BBsf   Affirmed   BBsf
F 17322AAR3      LT  Bsf    Affirmed   Bsf
PEZ 17322AAL6    LT  AAsf   Upgrade    Asf
X-A 17322AAJ1    LT  AAAsf  Affirmed   AAAsf
X-B 17322AAK8    LT  AAAsf  Affirmed   AAAsf
X-C 17322AAV4    LT  BBsf   Affirmed   BBsf

KEY RATING DRIVERS

Overall Stable Performance; Increased Defeasance: The upgrades of
classes C and PEZ are due to continued amortization and the
increase in defeasance compared with the prior rating action while
the affirmation of all other classes were driven by overall stable
loss expectations. Twenty-two loans (28.5%) have been defeased,
compared with 16 loans (19.5%) at the prior rating action. Five
loans (11.6%) have been designated as Fitch Loans of Concern
(FLOCs), including three loans (4.1%) in special servicing. The
affirmations and upgrades reflect a base case loss expectation of
4.50%.

Largest Drivers to Losses: The largest driver to losses is 136-138
West 34th Street (4.2%), a retail property in New York City where
occupancy dropped to 50% in 2020. Sprint (previously 50% NRA)
vacated in 2021 prior to the November 2023 lease expiration. The
other remaining tenant is Kay Jewelers (50% NRA) with a lease
running until December 2024. As of YE 2020, the loan was performing
at a 2.38x NOI debt service coverage ratio (DSCR) compared with
2.41x at YE 2019. Fitch applied a 50% haircut to the YE 2020 NOI,
resulting in a modeled loss of approximately 30%.

The second largest driver to losses is CityScape - East
Office/Retail (11.2%), a mixed-use property in Phoenix, AZ with
upcoming tenant rollover. As of YE 2020, occupancy and NOI DSCR
were 89% and 1.22x, respectively, compared with 91% and 1.32x at YE
2019. Fitch applied a 10% haircut to the YE 2020 NOI, resulting in
a modeled loss of approximately 8%.

Smaller drivers to loss include Festival Plaza (1.7%), a shopping
center in Montgomery, AL that transferred to special servicing in
May 2020 when the borrower requested coronavirus relief and 334-336
West 46th Street (1.1%), a mixed-use property in New York City that
transferred to special servicing in August 2020 for payment
default.

Alternative Loss Considerations: Prior to considering an upgrade
for classes C and PEZ, Fitch's analysis applied additional stresses
to the cap rates and (NOIs on the performing loans in the pool,
while also factoring in paydown of the defeased collateral. The
additional stresses supported the upgrades.

Stable Credit Enhancement (CE): As of the June 2021 distribution,
the pool's aggregate balance has been paid down by 30.2% to $709.2
million from $1.0 billion at issuance. There entire pool is
scheduled to mature between November 2023 and March 2024.

Coronavirus Exposure: The pool contains one loan (1.1%) secured by
a hotel with an NOI DSCR of 2.10x at YE 2019. Non-defeased loans
backed by retail properties account for 27.0% of the pool balance
and have weighted average NOI DSCR of 1.71x Fitch's base case
analysis applied an additional NOI stress to one retail and one
hotel loan due to their vulnerability to the coronavirus pandemic.

RATING SENSITIVITIES

The Outlook on all classes remains Stable due to overall stable
performance and increasing CE.

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

-- Improved performance coupled with paydown and/or defeasance.
    An additional upgrade to classes C and PEZ would occur with
    increased paydown and/or defeasance, but could be limited as
    concentrations increase. An upgrade of class D could occur
    with stabilization of the FLOCs and additional
    paydown/defeasance. Classes would not be upgraded above 'Asf'
    if there is likelihood for interest shortfalls.

-- An upgrade to E, X-C, and F is not likely until the later
    years in a transaction and only if the performance of the
    remaining pool is stable and there is sufficient CE to the
    classes. If collateral performance and pool credit metrics
    continue to improve, upgrades and/or revisions to Outlook
    Positive are possible within the next one to two years.

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

-- An increase in pool level losses from underperforming or
    specially serviced loans. Downgrades to the classes rated
    'AAAsf' are not considered likely due to the high credit
    enhancement and significant paydown/defeasance, but may occur
    should interest shortfalls occur.

-- Downgrades to classes C and PEZ are possible should Fitch's
    projected losses increase due to a substantial decline in pool
    performance or increased loan defaults. A downgrade to class D
    is possible should the performance of FLOCs and specially
    serviced loans decline further. Downgrades to classes E and F
    are possible should loans remain in special servicing, go
    unresolved and losses exceed expectations.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


CITIGROUP COMMERCIAL 2015-GC35: Fitch Lowers Class E Certs to 'CCC'
-------------------------------------------------------------------
Fitch Ratings has downgraded three and affirmed 11 classes for
Citigroup Commercial Mortgage Trust (CGCMT) 2015-GC35 Mortgage
Pass-Through Certificates Series 2015-GC35.

   DEBT                RATING           PRIOR
   ----                ------           -----
CGCMT 2015-GC35

A-2 17324KAM0    LT  AAAsf  Affirmed    AAAsf
A-3 17324KAN8    LT  AAAsf  Affirmed    AAAsf
A-4 17324KAP3    LT  AAAsf  Affirmed    AAAsf
A-AB 17324KAQ1   LT  AAAsf  Affirmed    AAAsf
A-S 17324KAR9    LT  AAAsf  Affirmed    AAAsf
B 17324KAS7      LT  AA-sf  Affirmed    AA-sf
C 17324KAT5      LT  A-sf   Affirmed    A-sf
D 17324KAU2      LT  BBsf   Downgrade   BBB-sf
E 17324KAA6      LT  CCCsf  Downgrade   Bsf
F 17324KAC2      LT  CCCsf  Affirmed    CCCsf
PEZ 17324KAY4    LT  A-sf   Affirmed    A-sf
X-A 17324KAV0    LT  AAAsf  Affirmed    AAAsf
X-B 17324KAW8    LT  AA-sf  Affirmed    AA-sf
X-D 17324KAX6    LT  BBsf   Downgrade   BBB-sf

KEY RATING DRIVERS

Increased Loss Expectations: The downgrades reflect increased loss
expectations for the pool, due primarily to higher loss
expectations on the South Plains Mall and specially serviced loans.
Fitch's current ratings incorporate a base case loss of 9.0%. The
Negative Rating Outlooks reflect losses that could reach 10.6% when
factoring additional pandemic-related stresses and a potential
outsized loss on the South Plains Mall loan. There are 14 Fitch
Loans of Concern (FLOCs; 54.3% of pool), including three in special
servicing (10.7%).

The largest increase in loss since the last rating action is the
South Plains Mall loan (10.3% of pool), which is secured by a
992,140-sf portion of a 1,135,840-sf super regional mall located in
Lubbock, TX. Collateral anchors include JCPenney (20.4% of
collateral NRA; July 2027 lease expiry), Dillard's Women (16.4%;
January 2022) and Dillard's Men & Children (9.5%; January 2022).
Upon lease expiry, both of the Dillard's leases will convert to
month-to-month. A former non-collateral Sears box closed in late
2018.

Collateral occupancy declined to 73.7% as of March 2021 from 78.7%
at YE 2020, 92.7% in September 2020 and 95.9% in March 2019. A
junior collateral anchor tenant, Beall's (4% of collateral NRA),
vacated in August 2020. YE 2020 NOI declined 18% from YE 2019. As
of the March 2021 rent roll, near-term lease rollover includes 4.4%
in 2021 (across 22 tenants), 30.8% in 2022 (24 tenants) and 7.8% in
2023 (14 tenants). Comparable in-line sales for tenants less than
10,000 sf were $418 psf as of YE 2020, compared with $502 psf as of
TTM June 2019, $461 psf as of TTM August 2018 and $456 psf at the
time of issuance.

Fitch's base case loss expectation of 20% incorporates a 12% cap
rate applied to the YE 2020 NOI. Fitch applied an additional
sensitivity that considered a 20% cap rate applied to the YE 2020
NOI, resulting in a potential outsized loss of 32%.

Specially Serviced Loans: The Doubletree Jersey City loan (6.2%),
which is secured by a 198-key hotel in Jersey City, NJ, transferred
to special servicing in October 2020. The borrower informed the
special servicer of their intention to give back title to the
property in November 2020. As of TTM March 2021, occupancy, ADR and
RevPAR declined to 33%, $138 and $46, respectively, from 83%, $220
and $183 (TTM June 2019). Fitch's expected loss of 27% incorporates
an 11% cap rate applied to the YE 2019 NOI, reflecting a Fitch
stressed value of $230,764 per room, and factors in the property's
strong location.

The Hammons Hotel Portfolio loan (3.1%) is secured by fee and
leasehold interests in seven full service, limited service, and
extended stay hotels located in seven distinct markets in seven
states. The properties, which total 1,869 rooms, were developed
between 2006 and 2010 and all carry either a Hilton or Marriott
flag. Four out of the seven hotels have a convention center
included in the collateral. The loan transferred to special
servicing for a second time in June 2020 due to the borrower's
request for coronavirus relief and was over 90 days delinquent as
of the June 2021 remittance reporting.

The servicer and borrower have agreed upon relief terms, which
included cash infusion from a new equity partner to cover operating
shortfalls. The loan was modified in May 2021, with terms including
the addition of two one-year maturity extension options,
contribution of $30 million of equity by the borrower to cover
outstanding costs and replenish reserves, conversion of payments to
interest-only and repayment of previously deferred amounts from
2020 beginning in October 2021. The loan was previously in special
servicing due to a borrower related bankruptcy that was resolved in
2019.

Aggregate portfolio NOI for YE 2020 was down 86.4% from YE 2019.
The servicer-reported YE 2020 NOI DSCR was 0.72x, down from 2.09x
at YE 2019. Per the TTM March 2021 STR report, the weighted average
portfolio RevPAR was down 59.2% from TTM December 2019. Fitch's
expected loss of approximately 17% reflects a discount to a recent
appraisal valuation, which equates to a stressed value of $111,717
per key.

The 750 Lexington Avenue loan (10.8%), which transferred to the
special servicer in June 2021, 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 (23% of NRA; 20%
of total base rents; March 2035). The loan began amortizing in
November 2020. The effects of the coronavirus pandemic continue to
hamper the market for new office leasing as well as the operation
of the property's retail tenants.

The borrower stated that they are collecting nearly 100% of office
rents, but the property faces near-term lease rollover and vacancy
which includes two full floors of space in dispute with WeWork
(30,775 sf; 8.6% of NRA) representing approximately $2 million per
year in rent. In addition, retail tenant AmorePacific (1.3% of NRA;
4% of total base rents) has not paid rent since November 2020 and
now maintains arrears of over $365,000. WeWork is obligated to pay
its monthly base rent and additional rent until the expiration date
in 2035 for the second tranche of space. This will be remedied with
the security deposit, which is held in a $6 million letter of
credit. Fitch will continue to monitor the loan for performance and
tenancy updates.

Increased Credit Enhancement: As of the June 2021 remittance
reporting, the pool's aggregate balance has paid down by 12.2% to
$970.9 million from $1.1 billion at issuance. Credit enhancement
has increased since the prior rating action due to six loans (9.1%
of original pool balance) repaying in full with better than
expected recoveries and continued amortization. Nine loans (45.8%
of pool) are full-term, interest-only, one loan (6.2%) remains in
its partial interest-only period and 47 loans (48%) are amortizing.
Scheduled loan maturities include one loan (1.4%) in 2021 and 56
loans (98.6%) in 2025.

Additional Stresses Applied due to Coronavirus Exposure: Six loans
(21.4% of pool) are secured by hotel properties and 19 loans
(31.3%) are secured by retail properties. Fitch applied additional
coronavirus-related stresses to four hotel loans (17.5%) and five
retail loans (12.6%); these additional stresses contributed to the
Negative Outlooks.

Credit Opinion Loan: One loan, 590 Madison Avenue (10.3% of the
pool), received an investment-grade credit opinion on a stand-alone
basis at issuance of 'AA+'.

RATING SENSITIVITIES

The Negative Rating Outlooks on classes A-S, B, C, D, PEZ, X-A, X-B
and X-D reflect potential for downgrades due to performance
concerns on a growing number of FLOCs and the ultimate impact of
the pandemic on performance stabilization. The Stable Rating
Outlooks on classes A-2, A-3, A-4 and A-AB reflect the increasing
CE from paydowns and continued amortization.

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

-- Stable to improved asset performance, coupled with paydown
    and/or defeasance.

-- Upgrades to classes B, C and X-B may occur with significant
    improvement in CE and/or defeasance, and with the
    stabilization of performance on the FLOCs, including South
    Plains Mall, and/or the properties affected by the coronavirus
    pandemic; however, adverse selection and increased
    concentrations, or the underperformance of the FLOCs could
    cause this trend to reverse;

-- Upgrades to classes D and X-D are considered unlikely and
    would be limited based on sensitivity to concentrations or the
    potential for future concentration. Classes would not be
    upgraded above 'Asf' if interest shortfalls were likely;

-- Upgrades to the distressed classes E and F are not likely
    unless resolution of the specially serviced loans is better
    than expected and performance of the remaining pool is stable,
    and/or properties vulnerable to the coronavirus pandemic
    return to pre-pandemic levels and there is sufficient CE to
    the classes.

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

-- An increase in pool-level losses from underperforming or
    specially serviced loans.

-- Downgrades to classes A-2, A-3, A-4, A-AB and X-A are not
    considered likely due to their position in the capital
    structure, but may occur should interest shortfalls affect
    these classes;

-- Downgrade to classes A-S, B and X-B may occur should all of
    the loans susceptible to the coronavirus pandemic suffer
    losses, an outsized loss is incurred on the South Plains Mall
    and/or interest shortfalls affect these classes;

-- Downgrades to classes C, D and X-D may occur should loss
    expectations increase from continued performance decline of
    the FLOCs, loans susceptible to the pandemic not stabilize,
    additional loans default and/or transfer to special servicing,
    higher losses than expected are incurred on the specially
    serviced loans and/or the larger FLOCs experience outsized
    losses;

-- Downgrades to the distressed classes E and F would occur as
    losses are realized and/or become more certain.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


CITIGROUP COMMERCIAL 2019-GC41: DBRS Confirms B(high) on GRR Certs
------------------------------------------------------------------
DBRS Limited confirmed the ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2019-GC41 issued by Citigroup
Commercial Mortgage Trust 2019-GC41 as follows:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction, which has remained in line with DBRS Morningstar's
expectations since issuance. This transaction closed in August 2019
with an original trust balance of $1.28 billion. At issuance, the
collateral consisted of 43 loans secured by 100 commercial and
multifamily properties. As of the June 2021 remittance, all loans
remain in the pool with an aggregate principal balance of $1.27
billion, representing a collateral reduction of 0.3% since
issuance.

Loans secured by office properties represent the greatest property
type concentration, accounting for 33.4% of the current pool
balance. Meanwhile, the pool has a smaller concentration of loans
secured by retail and lodging properties, which represent 14.3% and
10.1% of the current pool, respectively. Additionally, the pool
features four loans, representing a combined 18.1% of the pool,
that DBRS Morningstar shadow-rates as investment grade: 30 Hudson
Yards, Grand Canal Shoppes, Moffett Towers II Buildings 3 & 4, and
The Centre. With this review, DBRS Morningstar confirmed the loans
continue to perform in line with the investment-grade shadow
ratings.

DBRS Morningstar continues to monitor the Grand Canal Shoppes loan
as the Coronavirus Disease (COVID-19) pandemic has been
particularly hard on the Las Vegas economy, and sales at the
property and its financial performance have declined since
issuance. The loan was previously on the servicer's watchlist for a
relief request submitted by the borrower because of the pandemic,
but the request was ultimately retracted and the loan was removed
from the watchlist. The loan was returned to the servicer's
watchlist in June 2021 for failing a debt-yield trigger that
required the debt yield to be above 6.5%, with the servicer
calculating a debt yield of 5.9% at December 2020. The cash flow
declines appear to be related to occupancy drops in the last year,
but the in-place debt service coverage ratio (DSCR) remained
generally healthy at 1.74 times (x) at YE2020.

A May 27, 2021, article in the Las Vegas Review-Journal reported
that tourist traffic to Las Vegas in April 2021 was the highest
since February 2020 but still down just over 27.0% from April 2019.
The article also noted hotel room rates and occupancy rates had
rebounded significantly in recent months, with the lag in traffic
to the city attributed to the reduction in trade shows and
conventions compared with pre-pandemic levels. DBRS Morningstar
believes the Grand Canal Shoppes' prime location, historically
strong performance, relatively low leverage, and tenant mix are
significant mitigating factors for the near- to medium-term risks
introduced by the pandemic and suggest the property will be well
positioned to capture visitor traffic as tourism levels continue to
rise over the lows of 2020.

As of the July 2020 remittance, one loan was in special servicing
and nine loans were on the servicer's watchlist, representing 0.6%
and 21.2% of the pool, respectively. The loans on the servicer's
watchlist are being monitored for a variety of reasons, including
coronavirus relief requests, trigger events, and low DSCRs. The
Burbank Collection loan (Prospectus ID#21; 1.6% of the pool) is
secured by 39,035 square feet (sf) of weakly anchored retail space
that makes up the ground floor retail space beneath a multifamily
property in Burbank, California. This loan is on the servicer's
watchlist following the loan's return from special servicing, where
it was transferred in July 2020. The property's tenant base
includes several restaurants that catered to patrons of an AMC
Theatres location across the street. When the movie theatre was
closed because of the pandemic, the tenants at the subject property
suffered as a result and the loan went delinquent with the sponsor
requesting relief from the servicer, which prompted the loan's
transfer to special servicing. The loan was ultimately brought
current and transferred back to the master servicer in June 2021.

The Floridian Hotel & Suites loan (Prospectus ID#39; 0.6% of the
pool) transferred to special servicing in June 2020 and remains
delinquent for the October 2020 debt service payment. The loan is
secured by a 130-key, independently branded, limited-service hotel
in Orlando. The servicer obtained an appraisal in January 2021 that
valued the property on an as-is basis at $7.9 million compared with
the issuance appraised value of $13.5 million. The January 2021
appraisal also estimated an as-stabilized value of $11.5 million.
Given the small loan size, the rated Certificates are generally
well insulated against any loss with this loan at resolution.

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




CITIGROUP MORTGAGE 2021-RP4: DBRS Gives Prov. B Rating on B2 Notes
------------------------------------------------------------------
DBRS, Inc. assigned the following provisional ratings to the
Mortgage-Backed Notes, Series 2021-RP4 to be issued by Citigroup
Mortgage Loan Trust 2021-RP4:

-- $2.2 billion Class A-1 at AAA (sf)
-- $142.3 million Class A-2 at AA (sf)
-- $2.3 billion Class A-3 at AA (sf)
-- $2.4 billion Class A-4 at A (sf)
-- $2.5 billion Class A-5 at BBB (sf)
-- $106.7 million Class M-1 at A (sf)
-- $84.3 million Class M-2 at BBB (sf)
-- $61.9 million Class B-1 at BB (sf)
-- $47.4 million Class B-2 at B (sf)

Classes A-3, A-4, and A-5 are exchangeable notes. These classes can
be exchanged for combinations of exchange notes.

The AAA (sf) rating on the Notes reflects 17.90% of credit
enhancement provided by subordinated certificates. The AA (sf), A
(sf), BBB (sf), BB (sf), and B (sf) ratings reflect 12.50%, 8.45%,
5.25%, 2.90%, and 1.10% of credit enhancement, respectively.

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

The Trust is a securitization a securitization of a portfolio of
seasoned performing and reperforming first-lien residential
mortgages funded by the issuance of mortgage-backed notes (the
Notes). The Notes are backed by 14,648 loans with a total principal
balance of $2,634,798,746 as of the Cut-Off Date (May 31, 2021).

The mortgage loans, which were purchased from Fannie Mae, are
approximately 173 months seasoned. As of the Cut-Off Date, 98.2% of
the loans are current, including 113 bankruptcy-performing loans.
Approximately 71.0% and 91.8% of the mortgage loans have been zero
times 30 days delinquent for the past 24 months and 12 months,
respectively, under the Mortgage Bankers Association delinquency
method.

The portfolio contains 98.3% modified loans. The modifications
happened more than two years ago for 96.5% of the modified loans.
Within the pool, 11,115 mortgages have aggregate
noninterest-bearing deferred amounts of $558,734,544, which
comprise approximately 21.2% of the total principal balance.

Approximately 1.2% of the loans in the pool are subject to the
Consumer Financial Protection Bureau Ability-to-Repay and Qualified
Mortgage (QM) rules. Approximately 1.2% of these loans are
designated as either Safe Harbor or Temporary Safe Harbor and less
than 0.1% as non-QM. The remainder of the pool is exempt due to
seasoning or loan purpose.

The Seller, Citigroup Global Markets Realty Corp. (CGMRC), acquired
the mortgage loans from Fannie Mae following the award of a bid in
connection with a competitive auction for the initial pool. The
Seller will then contribute the loans to the Trust through an
affiliate, Citigroup Mortgage Loan Trust Inc. (the Depositor). As
the Sponsor, CGMRC or one of its majority-owned affiliates will
acquire and retain a 5% eligible vertical interest in each class of
Notes (other than the Class R Notes) to satisfy the credit risk
retention requirements. The loans were originated and previously
serviced by various entities.

As of the Cut-Off Date, the loans are serviced by an interim
servicer. Such servicing will be transferred to Rushmore Loan
Management Services, LLC, on September 1, 2021. There will not be
any advancing of delinquent principal or interest on any mortgages
by the Servicer or any other party to the transaction; however, the
Servicer is obligated to make advances in respect of homeowner
association fees in super lien states and, in certain cases, taxes
and insurance as well as reasonable costs and expenses incurred in
the course of servicing and disposing of properties.

When the aggregate pool balance is reduced to less than 25% of the
balance as of the Cut-off Date, the directing noteholder may
purchase all of the mortgage loans and real-estate-owned properties
from the Issuer, as long as the aggregate proceeds meet a minimum
price.

The transaction employs a sequential-pay cash flow structure.
Principal proceeds can be used to cover interest shortfalls on the
Notes, but such shortfalls on Class M-1 and more subordinate
principal and interest bonds will not be paid from principal
proceeds until the more senior classes are retired.

CORONAVIRUS IMPACT

The Coronavirus Disease (COVID-19) pandemic and the resulting
isolation measures have caused an immediate economic contraction,
leading to sharp increases in unemployment rates and income
reductions for many consumers. Shortly after the onset of the
pandemic, DBRS Morningstar saw an increase in the delinquencies for
many residential mortgage-backed securities (RMBS) asset classes.

Such mortgage delinquencies were mostly in the form of
forbearances, which are generally short-term periods of payment
relief that may perform very differently from traditional
delinquencies. At the onset of the pandemic, the option to forebear
mortgage payments was widely available, driving forbearances to an
elevated level. When the dust settled, loans with
coronavirus-induced forbearance in 2020 performed better than
expected, thanks to government aid, low loan-to-value ratios, and
acceptable underwriting in the mortgage market in general. Across
nearly all RMBS asset classes in recent months delinquencies have
been gradually trending downwards, as forbearance periods come to
an end for many borrowers.

In connection with the economic stress assumed under its moderate
scenario (see "Global Macroeconomic Scenarios: June 2021 Update,"
published on June 18, 2021), DBRS Morningstar may assume higher
loss expectations for pools with loans on forbearance plans.

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



COMM 2012-LTRT: S&P Lowers Class X-B Certs Rating to CCC (sf)
-------------------------------------------------------------
S&P Global Ratings lowered its ratings on eight classes of
commercial mortgage pass-through certificates from COMM 2012-LTRT,
a U.S. CMBS transaction.

This is a U.S. large-loan CMBS transaction backed by two uncrossed
fixed-rate amortizing mortgage loans, each secured by a regional
mall property.

Rating Actions

The downgrades on classes A-1, A-2, B, C, D, and E primarily
reflect our re-evaluation of the two regional malls that secure the
two uncrossed amortizing mortgage loans in the transaction:
Westroads Mall ($118.0 million, 54.3% of trust balance) and The
Oaks Mall ($99.2 million, 45.7%). S&P's analysis includes a review
of the two malls' most recent available performance data provided
by the servicer.

S&P said, "Our expected-case valuation, in aggregate, has declined
27.5% since our last review in July 2020. The decline in our
overall valuation is driven largely by the lower S&P Global
Ratings' sustainable net cash flow (NCF) (down 27.4%, in aggregate,
since our last review) to account for the further decline in
reported performance due primarily to the negative impact of the
COVID-19 pandemic.

"The downgrade on class E reflects our view that, based on an S&P
Global Ratings' loan-to-value (LTV) ratio of over 100% on The Oaks
Mall loan, the class is more susceptible to reduced liquidity
support and the risk of default and loss have increased due to the
uncertain market conditions.

"While the model-indicated ratings on classes A-1, A-2, B, C, and D
were lower than the classes' revised rating levels, we tempered our
downgrades because we weighted qualitative considerations such as
the classes' positions in the waterfall, additional de-leveraging
of the mortgage loans through their maturity date, the significant
market value decline that would be needed before these classes
experience losses, and the liquidity support provided in the form
of servicer advancing. We also considered that the borrowers of the
loans remained current on their debt service payments through the
pandemic.

"We lowered our ratings on the class X-A and X-B interest-only (IO)
certificates based on our criteria for rating IO securities, in
which the ratings on the IO securities would not be higher than
that of the lowest-rated reference class. Class X-A's notional
balance references classes A-1 and A-2, and class X-B references
classes B, C, D, and E."

Transaction Summary

This is a U.S. large loan CMBS transaction backed by two uncrossed
fixed-rate amortizing balloon mortgage loans, same as at issuance.
As of the July 8, 2021, trustee remittance report, the trust had an
aggregated trust balance of $217.2 million, down from $259.0
million at issuance. The trust has not incurred any principal
losses to date.

S&P's property-level analysis included a reevaluation of the two
regional malls backing the two loans in the pool using
servicer-provided operating statements from 2015 through 2020 and
the available year-end 2020 or March 2021 rent rolls.

Details on the two loans are as follows:

-- The Westroads Mall loan, the larger of the two loans, has a
$118.0 million trust balance, down from $140.7 million at issuance.
The loan pays an annual fixed interest rate of 4.30%, amortizes on
a 360-month schedule, and matures on Oct. 1, 2022. In addition,
there is $15.6 million (down from $16.3 million at issuance) in
mezzanine debt.

-- The Westroads Mall loan is secured by the borrower's fee
interest in 540,304 sq. ft. of a 1.07 million-sq.-ft. multi-level
enclosed regional mall in Omaha, Neb. S&P's property-level analysis
considered the fluctuating servicer-reported net operating income
(NOI): -1.7% in 2016; +2.6% in 2017; +0.5% in 2018; -5.1% in 2019;
and -19.3% in 2020. The sharp decline in 2020 is due predominantly
to decreasing base rent and other income and increasing operating
expenses. According to the March 31, 2021, rent roll, the occupancy
rate for the collateral was 91.0% and the five largest tenants
comprising 43.0% of collateral's net rentable area (NRA) included:
Dick's Sporting Goods (15.6% of NRA; January 2024 lease
expiration), AMC Westroads (13.6%; November 2023 expiration);
Forever 21 (5.7%; January 2023 expiration), The Container Store
(4.7%; February 2027 expiration), and H&M (3.4%; January 2025
expiration). The mall also includes three noncollateral anchor
spaces, two of which are currently occupied by JC Penney (177,223
sq. ft.) and Von Maur (179,114 sq. ft.). The remaining
173,065-sq.-ft. anchor space was formerly occupied by Younkers, who
vacated in August 2018. The mall faces elevated tenant rollover in
2023 (29.4% of NRA) and 2024 (19.7%), mainly attributable to three
of the largest aforementioned collateral tenants. The master
servicer, KeyBank Real Estate Capital (KeyBank), reported a 1.51x
debt service coverage (DSC) and 91.0% occupancy rate for the year
ended Dec. 31, 2020.

S&P said, "Our current analysis on the Westroads Mall loan excluded
tenants that had closed, announced impending closures, had parent
companies facing financial uncertainty, had expired lease terms,
and/or were no longer on the mall's directory website, which
resulted in our assumed collateral occupancy rate of 84.5%.
Furthermore, we assumed lower rents on certain tenants that have
near-term rollover. We derived our sustainable NCF of $11.6
million, which is 23.1% and 7.3% lower than our last review and the
2020 servicer-reported NCF, respectively. We then divided our NCF
by an S&P Global Ratings' capitalization rate of 9.00% (the same as
our last review), resulting in our expected-case value of $128.4
million, down from $167.1 million in the last review. This yielded
an S&P Global Ratings' LTV ratio of 91.9% and an S&P Global
Ratings' DSC of 1.39x on the trust balance."

The Oaks Mall loan has a $99.2 million trust balance, down from
$118.3 million at issuance. The loan pays an annual fixed interest
rate of 4.12%, amortizes on a 360-month schedule, and matures on
Oct. 1, 2022. In addition, there is $20.7 million (same as at
issuance) in mezzanine debt.

The Oaks Mall loan is secured by the borrower's fee interest in
581,849 sq. ft. of a 906,349-sq.-ft. single-level enclosed regional
mall in Gainesville, Fla. Our property-level analysis considered
the year-over-year decline in servicer-reported NOI in the past
three years: -6.7% in 2018; -17.5% in 2019; and -25.6% in 2020, due
primarily to decreasing gross rent and other income revenue. Based
on the Dec. 31, 2020, rent roll, the collateral's occupancy rate
was 94.0%, and the five-largest tenants, which comprised 50.6% of
the collateral NRA, included: JC Penney (23.0% of NRA; January 2023
lease expiration), Belk (17.2%; February 2023 expiration), Forever
21 (4.8%; January 2024 expiration), H&M (3.9%; January 2026
expiration), and Shoe Carnival (1.7%; January 2027 expiration). The
mall also includes a ground lease anchor, Dillard's (188,000 sq.
ft.), as well as a 136,000-sq.-ft. noncollateral former Sears
anchor space, currently occupied by the University of Florida
Health. The mall faces concentrated tenant rollover in 2023 (44.8%
of NRA) and 2024 (12.0%), mainly attributable to some of the
largest tenants noted above. KeyBank reported a 0.86x DSC and 94.0%
occupancy rate for the year ended Dec. 31, 2020.

S&P said, "Our current analysis on The Oaks Mall loan excluded
tenants that had closed, announced impending closures, had parent
companies facing financial uncertainty, had expired lease terms,
and/or were no longer on the mall's directory website, which
resulted in our assumed collateral occupancy rate of 60.7%.
Furthermore, we assumed lower rents on certain tenants that have
near-term rollover. We derived our sustainable NCF of $6.9 million,
down 33.8% and 6.0% from our last review and the 2020
servicer-reported NCF, respectively. Using an S&P Global Ratings'
capitalization rate of 9.00% (the same as our last review), we
arrived at our expected-case value of $76.7 million, down from
$115.7 million in the last review. This yielded an S&P Global
Ratings LTV ratio of 129.4% and an S&P Global Ratings' DSC below
1.00x on the trust balance."

Environmental, social, and governance factors relevant to the
rating action:

-- Health and safety.

  RATINGS LOWERED

  COMM 2012-LTRT

  Class A-1 to AA (sf), from AAA (sf)

  Class A-2 to AA (sf), from AAA (sf)

  Class B to BBB (sf), from A- (sf)

  Class C to BB (sf), from BBB- (sf)

  Class D to B (sf), from BB (sf)

  Class E to CCC (sf), from B+ (sf)

  Class X-A to AA (sf), from AAA (sf)

  Class X-B to CCC (sf), from B+ (sf)



COMM TRUST 2016-COR1: Fitch Affirms B- Rating on 2 Tranches
-----------------------------------------------------------
Fitch Ratings has affirmed 15 classes of COMM 2016-COR1 Mortgage
Trust. Fitch has also maintained the Negative Rating Outlooks on
classes D, E, F, X-C, X-E and X-F.

    DEBT               RATING           PRIOR
    ----               ------           -----
COMM 2016-COR1

A-2 12594MAZ1    LT  AAAsf   Affirmed   AAAsf
A-3 12594MBB3    LT  AAAsf   Affirmed   AAAsf
A-4 12594MBC1    LT  AAAsf   Affirmed   AAAsf
A-M 12594MBG2    LT  AAAsf   Affirmed   AAAsf
A-SB 12594MBA5   LT  AAAsf   Affirmed   AAAsf
B 12594MBE7      LT  AA-sf   Affirmed   AA-sf
C 12594MBF4      LT  A-sf    Affirmed   A-sf
D 12594MAL2      LT  BBB-sf  Affirmed   BBB-sf
E 12594MAN8      LT  BB-sf   Affirmed   BB-sf
F 12594MAQ1      LT  B-sf    Affirmed   B-sf
X-A 12594MBD9    LT  AAAsf   Affirmed   AAAsf
X-B 12594MAA6    LT  AA-sf   Affirmed   AA-sf
X-C 12594MAC2    LT  BBB-sf  Affirmed   BBB-sf
X-E 12594MAE8    LT  BB-sf   Affirmed   BB-sf
X-F 12594MAG3    LT  B-sf    Affirmed   B-sf

KEY RATING DRIVERS

Stable Loss Expectations: Fitch's base case loss is in-line with
prior rating action due to the overall stable performance of the
underlying collateral. Fitch's ratings assume a base case loss of
5.3%. The Negative Outlooks on Classes D, E and F reflect
additional sensitives, which reflect losses that could reach 7.7%;
these additional sensitivities include additional stresses applied
to loans expected to be affected by the coronavirus pandemic as
well as a 15% sensitivity loss on Birch Run Premium Outlets
(1.8%).

There are 15 loans (40.6% of pool) that were designated Fitch Loans
of Concern (FLOCs). As of the June 2021 distribution period there
were 15 loans (35.5%) on the servicer's watchlist for low DSCR,
increased vacancy, executed coronavirus relief, upcoming lease
expirations and coronavirus pandemic-related underperformance.
Greenwich Portfolio (1.6%), is a retail/office/multifamily mixed
used portfolio located in Greenwich, CT. This loan transferred to
special servicing in May 2020 for imminent monetary default as a
result of pandemic-related underperformance.

Minimal Change to Credit Enhancement: As of the June 2021
distribution date, the pool's aggregate principal balance has paid
down by 5.1% to $845.5 million from $890.7 million at issuance. At
issuance, based on the scheduled balance at maturity, the pool was
expected to pay down by 9.4%, which is below the 2015 average of
11.7%. There are three loans (6.3%) that are scheduled to mature
between September and October 2021, and the remaining pool is
scheduled to mature in 2025 and 2026. Overall, four loans (10.1%)
have been defeased since issuance and one loan ($7.4 million)
prepaid in full in January 2021. Of the remaining pool balance, 15
loans comprising 54.6% of the pool are full interest-only through
the term of the loan.

Fitch Loans of Concern:

Prudential Plaza (4.6%) is an office property located in the East
Loop of Chicago. The largest tenant, Tribune Publishing Company
(NRA 5%), recently announced its plans to vacate the entirety of
its space at the property at the end of January 2021. The publisher
has moved its operations from the subject to another location in an
effort to reduce its physical footprint while continuing to
navigate the challenges of the coronavirus pandemic. The property
was 88% occupied as of YE 2020. Upcoming lease rollover includes
6.1% of the NRA (16 tenants) in 2021, 4.6% (eight tenants) in 2022
and 10.1% (10 tenants) in 2023.

Comcast Plaza (3.9%) is a single tenant office property located in
Livermore, CA (approximately 32 miles from Fremont, CA). YE 2020
NOI DSCR has fallen to 1.12x from 2.45x at YE 2019 and underwritten
NOI DSCR of 1.87x. The decline in performance is due to the
subject's sole tenant, Comcast (NRA 66%), giving back 33% of
subject NRA at the end of its prior lease at year-end 2019. Comcast
renewed its remaining space and its new lease expiration is
scheduled for December 2030. According to the servicer, the
borrower has hired a new brokerage firm to market the space. The
borrower has stated there is little interest in the space at this
time due to the coronavirus pandemic.

The Renaissance Retail Condo (3.7%) is a retail condo property
located on 116 Street and Lenox Avenue in Harlem in NYC. Imperial
Parking (NRA 49.4%) lease is scheduled to expire in October 2021.
According to the servicer, the Imperial Parking will vacate at
lease expiration, and negotiations are ongoing with a replacement
tenant to take over the space in November 2021. Should Imperial
Parking vacate without a replacement tenant, Fitch estimates
occupancy to fall to 49%. At issuance, Imperial Parking paid $6.05
psf in annual base rent and accounted for 19% of underwritten gross
rent collections. The loan is structured with a lease sweep
provision where any tenant that comprises more than 10% of NRA fail
to give renewal notice 12 months before lease expiration, the
loan's hard lockbox and springing cash management would be
triggered.

Westfield San Francisco Centre (2.8%) is a retail/office property
located in San Francisco, CA. It is a Fitch Loan of Concern due to
the decline in occupancy over the past year to 75% as of YE2020
from 95% at YE2019. The occupancy decline is mainly attributable to
the departure of two office tenants at lease expiration:
Crunchyroll (9% NRA) and TrustArc (3.5% NRA). Retail tenants that
vacated in 2020 include Sur La Table, Shein and SoulCycle. There is
concentrated roll in 2021 including the three largest tenants, San
Francisco State University (15.8% NRA), Century Theatres (6.6% NRA)
and Bespoke (5.1% NRA). The YE 2020 NOI declined 23.5% from YE 2019
as result of lost rental income. The YE 2020 DSCR was 1.77x on an
IO basis compared to 2.32x at YE2019. Leases representing 31.5% of
the NRA are scheduled to roll in 2021, and an additional 14.8% in
2022.

Brea Portfolio (2.6%) is an urban retail center located in Brea,
CA. Subject YE 2020 NOI DSCR has fallen to 0.84x from 1.07x at YE
2019, 1.77x at YE 2018 and underwritten NOI DSCR of 1.82x.
According to the borrower, the initial decline in NOI in 2019 is
due to Olive Pit (NRA 10%) and Izakaya (NRA 7%) were closed for
portions of the year due to surrounding construction, and did not
pay rent. The further decline in NOI in 2020 was due to rent
deferment in order to provide relief from the coronavirus pandemic.
The subject has maintained 100% occupancy since issuance. The Armed
Services Career Center's (NRA 12%) lease is scheduled to expire in
September 2021.

Mt Diablo Terrace (2.5%) is a suburban office property located in
Lafayette, CA. Lafayette Physical Therapy's (NRA 9.12%) lease and
Insight Resource Group's (NRA 6.33%) lease are scheduled to expire
in February and January 2022, respectively. Subject March 2021
occupancy has fallen to 75% from 88% at YE 2019, 100% at YE 2018
and underwritten occupancy of 98%. The decline in occupancy is
primarily due to NFP CA Insurance Company (NRA 15.1%) vacating at
lease expiration in February 2020 as well as a number of smaller
tenants vacating at lease expiration between YE 2018 and YE 2020.
Due to the decrease in occupancy and rent collections, NOI has
fallen 20.5% between YE 2020 and underwritten NOI. In order to
provide relief from economic relief from the coronavirus pandemic,
a consent agreement was executed in June 2020 whereby the borrower
could use reserve funds to fund debt service between June and
August 2020.

There are two hotel loans in the Top 15 that have been flagged as
FLOC for coronavirus pandemic-related underperformance. Hilton San
Diego Mission Valley (6.3%) is a limited service hotel located in
San Diego, CA and subject YE 2020 NOI DSCR has fallen to -0.04x
from 1.88x at YE 2019 and 1.81x at underwriting. Hampton Inn &
Suites Boston Crosstown (2.9%) is a limited service hotel located
in Boston, MA and subject YE 2020 NOI DSCR has fallen to -0.24x
from 1.46x at YE 2019 and 2.01x at underwriting.

Exposure to Coronavirus: Four loans (13.4% of pool), which have a
weighted average NOI DSCR of -0.23x, are secured by hotel
properties. Fifteen loans (28.7%), which have a weighted average
NOI DSCR of 1.73x, are secured by retail properties. Eight loans
(8.7%), which have a weighted average NOI DSCR of 1.59x, are
secured by multifamily properties. Fitch's analysis applied
additional stresses to four hotel loans given the significant
declines in property-level cash flow expected in the short term as
a result of the decrease in consumer spending and property closures
from the coronavirus pandemic.

ADDITIONAL CONSIDERATIONS

Investment-Grade Credit Opinion Loans: At issuance, Westfield San
Francisco Centre (2.8%) and Grant and Geary Center (1.2%) were
given has an investment-grade credit opinions of 'Asf' and 'A+sf',
respectively, on a stand-alone basis. Both loans have seen
performance declines; Fitch no longer considers them to be
investment grade credit opinions.

RATING SENSITIVITIES

The Negative Rating Outlook on classes D, E and F reflects the
potential for downgrade due to concerns surrounding the ultimate
impact of the coronavirus pandemic and the performance concerns
associated with the FLOCs. The Stable Rating Outlooks on classes
A-1 through C and interest-only classes X-A and X-B reflect the
increasing credit enhancement, continued amortization and
relatively stable performance of the majority of the pool.

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

-- Stable to improved asset performance coupled with pay down
    and/or defeasance. Upgrades to the 'A-sf' and 'AA-sf'
    categories would likely occur with significant improvement in
    credit enhancement and/or defeasance. However, adverse
    selection, increased concentrations and further
    underperformance of the FLOCs or loans expected to be
    negatively affected by the coronavirus pandemic could cause
    this trend to reverse.

-- Upgrades to the 'BBB-sf' category would also take in to
    account these factors, but would be limited based on
    sensitivity to concentrations or the potential for future
    concentration. Classes would not be upgraded above 'Asf' if
    there were likelihood for interest shortfalls. Upgrades to the
    'B-sf' and 'BB-sf' categories are not likely until the later
    years in a transaction and only if the performance of the
    remaining pool is stable and/or properties vulnerable to the
    coronavirus return to pre-pandemic levels, and there is
    sufficient credit enhancement to the classes.

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

-- An increase in pool-level losses from underperforming or
    specially serviced loans. Downgrades to the 'A-sf', 'AA-sf'
    and 'AAAsf' categories are not likely due to the position in
    the capital structure, but may occur at the 'AA-sf' and
    'AAAsf' categories should interest shortfalls occur.

-- Downgrades to the 'A-sf' and 'BBB-sf' category would occur
    should overall pool losses increase and/or one or more large
    loans have an outsized loss, which would erode credit
    enhancement. Downgrades to the 'B-sf' and 'BB-sf' categories
    would occur should loss expectations increase due to an
    increase in specially serviced loans and/or the loans
    vulnerable to the coronavirus pandemic not stabilize.

-- In addition to its baseline scenario related to the
    coronavirus, Fitch also envisions a downside scenario where
    the health crisis is prolonged beyond 2021; should this
    scenario play out, Fitch expects negative rating actions,
    including downgrades or Negative Rating Outlook revisions.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


CSAIL 2016-C5: DBRS Confirms B(sf) Rating on Class X-F Certs
------------------------------------------------------------
DBRS, Inc. confirmed its ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2016-C5 issued by CSAIL 2016-C5
Commercial Mortgage Trust as follows:

-- Class A-4 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-S at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class X-A at AAA (sf)
-- Class X-B at AA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class X-D at BBB (sf)
-- Class D at BBB (low) (sf)
-- Class X-E at BB (sf)
-- Class E at BB (low) (sf)
-- Class X-F at B (sf)
-- Class F at B (low) (sf)

The trends on Classes D, E, F, X-D, X-E, and X-F are Negative,
reflecting the continuing performance challenges to the underlying
collateral, many of which have been driven by the impact of the
Coronavirus Disease (COVID-19) pandemic. The trends on all other
classes are Stable.

The rating confirmations reflect the relatively stable performance
of the transaction, which has remained in line with DBRS
Morningstar's expectations from last review. At issuance, the
transaction consisted of 59 loans with an original trust balance of
$936.4 million. As of the June 2021 remittance report, 53 loans
remain in the transaction with a current trust balance of $699.5
million, representing a collateral reduction of approximately 25.3%
since issuance resulting from amortization, the payoff of five
loans, and the liquidation of one loan. In addition, four loans,
representing 4.5% of the pool, have defeased. The transaction
benefits from a favorable pool composition as 13 loans,
representing 28.5% of the current trust balance, are secured by
multifamily properties, followed by hospitality properties, (which
account for 16.4% of the pool) and industrial properties (which
account for 13.6% of the pool).

As of the June 2021 remittance there are six loans in special
servicing representing 13.6% of the pool. The largest loan in
special servicing is the Embassy Suites and Claypool Court
(Prospectus ID#7, 4.1% of the pool), which is secured by a 360-room
hotel that includes 77,121 square feet of office and retail space
and is located within the Indianapolis CBD. The office and retail
components make up the first three floors while the hotel operates
in floors four through 15. The loan transferred to special
servicing in October 2020 due to payment default after the borrower
requested coronavirus relief. A recent proposal submitted by the
borrower is under review. The loan had maintained stable
performance prior to the pandemic. While year-end 2019 net cash
flow (NCF) was down 5%, revenue was up 13% compared with issuance.
Further, the loan maintained a strong debt service coverage ratio
of 2.28 times during that timeframe. The property was reappraised
in December 2020 for $53.2 million, reflecting a relatively low
loan-to-value ratio of 53.8%. Given the loan's current delinquency
and request for relief, the loan was analyzed with a significant
probability of default penalty to increase the expected loss in the
analysis for this review

The second-largest loan in special servicing, Sheraton Lincoln
Harbor Hotel (Prospectus ID#12, 2.9% of the pool), is secured by a
358-key full-service hotel in Weehawken, New Jersey. The loan
transferred to special servicing in January 2021 for imminent
default. The servicer has confirmed the borrower will no longer be
funding shortfalls and has expressed a desire to transfer the title
to the property to the trust. The hotel's performance was
deteriorating prior to the pandemic, with the year-end (YE) 2019
NCF down 24.7% compared with issuance. The March 2021 appraisal
obtained by the special servicer estimated an as-is value of $87.4
million, which reflects a 31.7% decrease from the issuance
appraisal of $128.0 million. Given the hotel's challenges prior to
the onset of the pandemic and the likelihood that the property will
continue to struggle even as travel begins to increase, DBRS
Morningstar believes the as-is value could further deteriorate and
assumed a conservative haircut to the March 2021 value in the
liquidation analysis, which resulted in a loss severity in excess
of 23.0%.

As of the June 2021 remittance, 10 loans, representing 11.7% of the
pool, are on the servicer's watchlist. The majority of the
watchlisted loans are being monitored for cash flow concerns that
have generally been driven by disruptions related to the pandemic.

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



CSAIL 2016-C6: DBRS Confirms B(sf) Rating on Class X-F Certs
------------------------------------------------------------
DBRS Limited confirmed the ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2016-C6 issued by CSAIL 2016-C6
Commercial Mortgage Trust as follows:

-- Class A-4 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-S at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class X-A at AAA (sf)
-- Class X-B at AA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class X-D at BBB (sf)
-- Class D at BBB (low) (sf)
-- Class X-E at BB (sf)
-- Class E at BB (low) (sf)
-- Class X-F at B (sf)
-- Class F at B (low) (sf)

All trends are Stable, with the exception of classes X-E, E, X-F
and F, which carry a Negative trend. The Negative trends reflect
the continued performance challenges for the underlying collateral,
particularly with the Quaker Bridge Mall loan (Prospectus ID#3,
11.7% of the pool), which has been specially serviced since
November 2020. The mall received an updated as-is appraised value
of $168.0 million as of February 2021, well below the appraised
value at issuance of $333.0 million. Based on this most recent
valuation, any potential future losses related to this loan would
be limited to the unrated class, but concerns regarding further
value deterioration persist.

As of the June 2021 remittance, 44 of the original 50 loans remain
in the pool, representing a collateral reduction of 28.3% since
issuance. Since November 2020, two specially serviced loans
comprising 6.3% of the pool were completely repaid. Three loans,
representing 14.2% of the pool, are currently specially serviced,
the largest of which is the previously mentioned Quaker Bridge
Mall. Additionally, there are 12 loans, representing 22.3% of the
pool, on the servicer’s watchlist. These loans are being
monitored for various reasons, including low debt service coverage
ratio (DSCR) or occupancy, tenant rollover risk, and/or
pandemic-related forbearance requests.

Quaker Bridge Mall transferred to special servicing in November
2020 after the loan fell behind on its debt service payments. The
borrower had initially requested a payment deferral at the outset
of the pandemic, but was denied as the servicer determined the
borrower was not able to demonstrate the need for deferral. The
loan ultimately missed its October 2020 payment and has been
delinquent ever since. While the post-transfer workout plan seemed
headed toward a payment deferral, the servicer is now negotiating
potential reinstatement terms.

The loan is secured by the interior portion of a 1.1 million square
foot (sf) Simon-operated regional mall in Lawrence Township, New
Jersey, that has seen two of its four noncollateral anchor tenants
vacate in the last three years. Sears vacated its space in
September 2018 and Lord & Taylor vacated in February 2021 after
giving notice during the summer of 2020. The YE2020 net cash flow
(NCF) was reported at $14.2 million, representing a 3.4% decline
from the YE2019 NCF of $14.7 million, and a 2.8% decline from the
issuer’s underwritten NCF of $14.6 million. Despite the negative
effects from the pandemic, collateral occupancy remains healthy at
92.6% as of December 2020. The largest collateral tenants are
Forever 21, Old Navy, and H&M, which collectively occupy 17.6% of
the net rentable area. DBRS Morningstar analyzed this loan using a
hypothetical liquidation scenario, with an implied loss severity in
excess of 20.0%.

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




CSAIL TRUST 2015-C1: Fitch Lowers 4 Cert. Tranches to 'Csf'
-----------------------------------------------------------
Fitch Ratings has downgraded nine classes of Credit Suisse USA
CSAIL 2015-C1 commercial mortgage pass-through certificates and
affirmed five others. The Rating Outlooks for seven classes remain
Negative.

    DEBT               RATING           PRIOR
    ----               ------           -----
CSAIL 2015-C1

A-3 126281AY0    LT  AAAsf  Affirmed    AAAsf
A-4 126281AZ7    LT  AAAsf  Affirmed    AAAsf
A-S 126281BD5    LT  AAAsf  Affirmed    AAAsf
A-SB 126281BA1   LT  AAAsf  Affirmed    AAAsf
B 126281BE3      LT  Asf    Downgrade   AA-sf
C 126281BF0      LT  BBBsf  Downgrade   A-sf
D 126281AL8      LT  B-sf   Downgrade   BBsf
E 126281AN4      LT  Csf    Downgrade   Bsf
F 126281AQ7      LT  Csf    Downgrade   CCCsf
X-A 126281BB9    LT  AAAsf  Affirmed    AAAsf
X-B 126281BC7    LT  Asf    Downgrade   AA-sf
X-D 126281AC8    LT  B-sf   Downgrade   BBsf
X-E 126281AE4    LT  Csf    Downgrade   Bsf
X-F 126281AG9    LT  Csf    Downgrade   CCCsf

KEY RATING DRIVERS

Loss Expectations Remain High: While Fitch's loss expectations
remain in line with the last rating action, there is increased
certainty of losses following the transfer of two of the largest
FLOCs to special servicing in the last year, including a regional
mall which is now in foreclosure proceedings. Twenty-four loans
representing 51.2% of the pool have been flagged as Fitch Loans of
Concern (FLOCs) including three regional malls and one outlet mall
in the Top 15. Fitch's current ratings incorporate a base case loss
of 9.8%. The Negative Outlooks reflect losses that could reach
16.3% when factoring in additional pandemic-related stresses and
potential for outsized losses on the Westfield Wheaton and
Westfield Trumbull loans.

The largest contributors to Fitch's projected losses are three
regional malls in the Top 15. Westfield Trumbull (7.2% of the pool)
is a 1.1 million sf regional mall in Trumbull, CT. It is sponsored
by Unibail-Rodamco-Westfield, rated 'BBB+'/'F2'/Negative by Fitch.
Anchor tenants are Target, JCPenney, Macy's and LA Fitness. Lord
and Taylor closed in early 2021 following the retailer's
bankruptcy. JCPenney recently extended its lease through 2027, and
Macy's lease expires in 2023. Both Macy's and JCPenney are anchors
at a competing mall owned by the same sponsor located 9.5 miles
away.

The subject was closed for a period of time during 2020 as a result
of containment measures stemming from the pandemic. Prior to the
pandemic, inline sales were $329 psf (exclusive of Apple) at
YE2019, down from $346 psf at YE2017 and $335 psf at issuance.
Media sources indicate the borrower had intended to break ground in
July 2021 on a 260-unit apartment complex located along the
periphery of the mall. However, in a message to journalists earlier
this year, the CEO of Unibail-Rodamco-Westfield announced that the
company intends to shed its U.S. portfolio of real estate in the
near term. Fitch's base case loss of 30% based on a 15% cap rate
and a stress to the YE2020 NOI to reflect upcoming lease rollover,
the loss of a major anchor and declining valuations for regional
malls.

Westfield Wheaton (4.0% of the pool) is a 1.6 million sf regional
mall in Wheaton, MD. Anchor tenants are JCPenney, Target, Macy's
and Costco. There is also a nine-screen AMC Theater and two
ground-leased outparcels leased to Giant Food and American Freight.
This loan is also sponsored by Unibail-Rodamco-Westfield. There are
five large retail centers located within a 10-mile radius, with the
closest mall being the Westfield Montgomery, also owned by
Unibail-Rodamco-Westfield, located seven miles away with a similar
inline tenant profile.

The subject was closed for a period of time during 2020 as a result
of containment measures stemming from the pandemic. Prior to the
pandemic, total mall sales were $353 psf at YE2019, in line with
$354 psf at YE2017 and issuance. Fitch's base case loss of 23% is
based on a 15% cap rate and a stress to the YE2020 NOI to reflect
upcoming lease rollover, significant market competition and
declining valuations for regional malls.

Bayshore Mall (2.0% of the pool) is a one-story enclosed regional
mall in Eureka, CA. Total mall occupancy has declined 69% as of
November 2020, down from 73% at YE2019 and 88% at YE2018. Two major
tenants vacated in 2019, and there is significant upcoming rollover
in the near term including the largest tenant Walmart in 2022. The
loan transferred to special servicing in October 2020 for payment
default and the sponsor, Brookfield, has agreed to a foreclosure.
Fitch's expected loss of 50% is based on a stressed value, which
assumes a 25% haircut to the YE2019 NOI given the lack of updated
financial reporting and upcoming lease rollover, and a 20% cap rate
to reflect the property's tertiary location and declining valuation
for regional malls.

The base case treatment for these loans was a primary driver for
the downgrades.

Changes in Credit Enhancement: Since the last rating action, one
loan has repaid from the pool and one loan was liquidated and
incurred $4.1 million in realized loss to the trust. Credit support
to the junior bonds has deteriorated although the senior-most bonds
have amortized. As of the June 2021 remittance, the pool's
aggregate principal balance has been reduced by 11.1% to $1.1
billion from $1.2 billion at issuance. Five loans representing
31.1% of the pool balance are interest-only for the full term.
Sixteen loans representing 17.0% of the pool balance are fully
defeased. The increased defeasance from the time of the last rating
action helps offset Fitch's loss projections relative to the senior
bonds. There are no scheduled maturities until 2024.

Sensitivity to Regional Malls: There continues to be concern with
the retail market overall, and liquidity available for regional
malls in particular. Fitch ran additional sensitivity stresses on
Westfield Trumbull and Westfield Wheaton, assuming a potential
outsized loss of 50% for both assets to reflect declining sales,
occupancy, upcoming roll and the sponsor's reduced commitment to
the properties based on its announcement of intentions to exit the
U.S. market. There is increased risk for term default should the
properties fail to attract new ownership. This scenario is the main
driver for the Negative Outlooks.

RATING SENSITIVITIES

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

-- Upgrades are not likely unless the regional malls are repaid
    or disposed with higher than expected recoveries. Classes B
    and C could be upgraded with significant improvement in credit
    enhancement and stabilization of the Fitch Loans of Concern.
    Class D may be upgraded if loans in special servicing
    liquidate with higher than expected recoveries or if the
    Westfield Trumbull and Westfield Wheaton loans repay in full.

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

-- Downgrades are possible for classes rated 'AAAsf' or 'AAsf'
    should interest shortfalls occur. Classes B, C and D be
    downgraded further should the Westfield Trumbull or Westfield
    Wheaton loans default. Downgrades to the distressed classes
    are expected as losses are realized.

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.

ESG CONSIDERATIONS

CSAIL 2015-C1 has an ESG Relevance Score of '4' for Exposure to
Social Impacts due to malls that are underperforming as a result of
changing consumer preference to shopping, which has a negative
impact on the credit profile and is highly relevant to the
ratings.

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


CSAIL TRUST 2015-C3: Fitch Lowers 2 Cert. Tranches to 'CCsf'
------------------------------------------------------------
Fitch Ratings has downgraded seven and affirmed seven classes of
CSAIL 2015-C3 Commercial Mortgage Trust commercial mortgage
pass-through certificates, series 2015-C3.

    DEBT               RATING           PRIOR
    ----               ------           -----
CSAIL 2015-C3

A-3 12635FAS3    LT  AAAsf  Affirmed    AAAsf
A-4 12635FAT1    LT  AAAsf  Affirmed    AAAsf
A-S 12635FAX2    LT  AAAsf  Affirmed    AAAsf
A-SB 12635FAU8   LT  AAAsf  Affirmed    AAAsf
B 12635FAY0      LT  Asf    Downgrade   AA-sf
C 12635FAZ7      LT  BBBsf  Downgrade   A-sf
D 12635FBA1      LT  CCCsf  Downgrade   Bsf
E 12635FAG9      LT  CCsf   Downgrade   CCCsf
F 12635FAJ3      LT  CCsf   Affirmed    CCsf
X-A 12635FAV6    LT  AAAsf  Affirmed    AAAsf
X-B 12635FAW4    LT  Asf    Downgrade   AA-sf
X-D 12635FBB9    LT  CCCsf  Downgrade   Bsf
X-E 12635FAA2    LT  CCsf   Downgrade   CCCsf
X-F 12635FAC8    LT  CCsf   Affirmed    CCsf

KEY RATING DRIVERS

High Loss Expectations; Increased Certainty of Loss: The downgrades
of classes B, X-B, C, D, X-D, E, and X-E are based on the high loss
expectations, increased certainty of loss on the specially serviced
loans, large number of Fitch Loans of Concern (FLOCs), and concerns
surrounding the three regional malls. Twenty-two loans/assets
(37.1%) have been designated as FLOCs including eight (7.9%) in
special servicing. Three loans (20.1%) are secured by regional
malls, all of which are FLOCs. Fitch's current ratings incorporate
a base case loss of 11.80%. The Negative Outlooks reflects losses
that could reach 17.00% when factoring additional mall and
coronavirus-related stresses.

Largest Drivers to Loss: The largest driver to loss is the second
largest loan in the pool, The Mall of New Hampshire (8.4%), a
regional mall sponsored by Simon and located in Manchester, NH.
Sears, a non-collateral anchor that owns their own box, closed in
November 2018 and has re-leased a portion of the space to Dick's
Sporting Goods and Dave & Buster's. The loan transferred to special
servicing in May 2020 due to the coronavirus pandemic and the
special servicer agreed to a forbearance agreement that deferred
payments between May 2020 and December 2020. Beginning in January
2021, the borrower began repaying the deferred amounts in 13
installments. As of April 2021, the loan was returned to the master
servicer. As of YE 2020, the property was 86% occupied and
performing at a 1.78x NOI debt service coverage ratio (DSCR)
compared to YE 2019 occupancy of 87% and 2.11x NOI DSCR. Fitch
applied a 15.0% cap rate and a 15% haircut to the YE 2020 NOI,
which resulted in a modeled loss of approximately 30%.

Westfield Wheaton (8.2%) is a 1.6 million sf regional mall in
Wheaton, MD in the Washington DC metro with declining anchor sales
and strong nearby competitors. The mall is anchored by Target, JC
Penney, and Macy's. Occupancy has remained stable near 95% since
issuance and as of YE 2020, the loan is performing at a 2.53x
interest-only (IO) NOI DSCR compared to 3.05x at YE 2019. Excluding
the major anchors and grocer, tenant sales are approximately $189
psf compared to $255 psf at YE 2019. Fitch applied a 15.0% cap rate
and a 15% haircut to the YE 2020 NOI, which resulted in a modeled
loss of approximately 24%.

The WPC Department Store Portfolio (1.4%) consists of five
single-tenant retail properties that were 100% leased by Bon-Ton
stores at issuance. The loan transferred to the special servicer
when Bon-Ton filed for bankruptcy in February 2018. As part of the
bankruptcy, the company surrendered its leases and vacated the
properties. The properties are within regional malls located in the
Milwaukee metro, Green Bay, WI, Joliet, IL and Fargo, ND. One of
the properties was liquidated at auction in October 2020 for
approximately $3 million resulting in $2.7 million in proceeds
being passed through to the trust, most of which was used to repay
servicer advances. Fitch modeled a 100% loss on the portfolio.

Westfield Trumbull (3.5%) is a 1.1 million sf regional mall in
Trumbull, CT in the Bridgeport metro area with flat sales, a dark
anchor box, and significant competition. The mall is anchored by
Macy's, Target, and JC Penney; Lord and Taylor (10.4% NRA) closed
in early 2021 as part of their bankruptcy, reducing occupancy to
87%. As of YE 2020, the loan was performing at a 1.86x NOI DSCR
compared to 1.93x at YE 2019. Additionally, the borrower will break
ground in July 2021 on a 260 unit apartment complex located along
the periphery of the mall. Fitch applied a 15.0% cap rate and a 15%
NOI haircut to the YE 2020 NOI, which resulted in a modeled loss of
approximately 30%.

Smaller drivers to loss include an underperforming hotel in San
Diego, CA that is in the process of going REO; an REO hotel in
McCallen, TX; a Florida multifamily portfolio with fluctuating
occupancy and low DSCR; and several smaller properties with
occupancy declines or upcoming tenant rollover, low DSCRs due to
pandemic-related stress, and specially serviced loans with
declining asset valuations.

Alternative Loss Considerations: Fitch ran a sensitivity scenario
to evaluate the impact an outsized loss on the regional malls would
have on the pool's credit enhancement as Fitch has concerns about
the likelihood that the borrowers will be able to refinance these
loans at maturity. A 50% loss was applied to the maturity balances
of the Mall of New Hampshire, Westfield Trumbull, and Westfield
Wheaton. This sensitivity scenario contributed to the downgrades
and Negative Outlooks. In addition, an ESG relevance score of '4'
for Social Impacts was applied as a result of exposure to a
sustained structural shift in secular preferences affecting
consumer trends, occupancy trends, and more, which, in combination
with other factors, affects the ratings.

Coronavirus Exposure: The pool contains 10 loans (16.5%) secured by
hotels with a weighted-average (WA) NOI DSCR of 2.21x. Retail
properties account for 37.6% of the pool balance and have WA NOI
DSCR of 1.73x. Fitch's base case analysis applied an additional NOI
stress to five hotel loans due to their vulnerability to the
coronavirus pandemic.

Minimal Change to Credit Enhancement (CE): As of the June 2021
distribution date, the pool's aggregate principal balance has paid
down by 16.6% to $1.18 billion from $1.42 billion at issuance. Two
loans (9.2% of the prior pool balance) have been liquidated since
the prior rating action, one of which realized a loss of
approximately $4.1 million. Interest shortfalls are currently
affecting class NR. Eleven loans (7.7%) have been defeased compared
to eight loans (4.8%) at the prior rating action. Of the current
pool, 28.6% of the loans are full-term IO and 37.2% are partial IO,
all of which have begun amortizing.

RATING SENSITIVITIES

The Negative Outlooks on classes A-S, X-A, B, X-B, and C reflect
the potential for a near-term rating change should the performance
of the FLOCs, specifically specially serviced loans and/or the
regional malls, deteriorate. The Stable Outlooks on the super
senior classes reflect the stable performance of the remainder of
the pool along with expected continued amortization.

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

-- Stable to improved asset performance coupled with significant
    paydown and/or defeasance.

-- Upgrades of classes B, X-B, and C would only occur with
    significant improvement in CE 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. While a significant portion of the pool
    continues to be designated as FLOCs, upgrades are unlikely.

-- An upgrade to classes D and X-D 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 the 'CCCsf' or below classes are
    not eroded and the senior classes payoff.

-- An upgrade to classes E, X-E, F, and X-F is extremely unlikely
    without significant paydown/defeasance and the resolution of
    the three regional mall loans without substantial losses.

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

-- A further increase in pool level losses from underperforming
    or specially serviced loans or the default and transfer of the
    regional malls to special servicing. Downgrades to the 'AAAsf'
    super senior classes, A-3, A-4, and A-SB, may occur should
    loan level losses increase further, if additional loans
    transfer to special servicing, or should interest shortfalls
    occur.

-- Downgrades to classes A-S and X-A are possible should
    performance of the FLOCs continue to decline, if additional
    loans transfer to special servicing, should loans susceptible
    to the coronavirus pandemic not stabilize, or interest
    shortfalls occur. Downgrades to classes B, X-B, and C could
    occur if loss expectations increase due to an increase in the
    certainty of losses on the specially serviced loans or FLOCs.

-- The Negative Rating Outlooks 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.
    Downgrades to classes D, X-D, E, X-E, F and X-F would occur as
    losses are realized.

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.

ESG CONSIDERATIONS

CSAIL 2015-C3 has an ESG Relevance Score of '4' for Exposure to
Social Impacts due to the exposure to the sustained structural
shift in secular preferences affecting consumer trends, occupancy
trends, etc., which has a negative impact on the credit profile,
and is highly relevant to the ratings. This impact contributed to
the downgrades of classes B, X-B, C, D, X-D, E, and X-E.

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


CSMC TRUST 2021-RPL5: Fitch Assigns B Rating on B-2 Notes
---------------------------------------------------------
Fitch Ratings has assigned ratings to the residential
mortgage-backed notes issued by CSMC 2021-RPL5 Trust (CSMC
2021-RPL5).

DEBT           RATING             PRIOR
----           ------             -----
CSMC 2021-RPL5

A-1     LT  AAAsf  New Rating   AAA(EXP)sf
A-1A    LT  AAAsf  New Rating   AAA(EXP)sf
A-1X    LT  AAAsf  New Rating   AAA(EXP)sf
M-1     LT  AAsf   New Rating   AA(EXP)sf
M-2     LT  Asf    New Rating   A(EXP)sf
M-3     LT  BBBsf  New Rating   BBB(EXP)sf
B-1     LT  BBsf   New Rating   BB(EXP)sf
B-2     LT  Bsf    New Rating   B(EXP)sf
B-3     LT  NRsf   New Rating   NR(EXP)sf
B-4     LT  NRsf   New Rating   NR(EXP)sf
B-5     LT  NRsf   New Rating   NR(EXP)sf
PT      LT  NRsf   New Rating   NR(EXP)sf
A-IO-S  LT  NRsf   New Rating   NR(EXP)sf
SA      LT  NRsf   New Rating   NR(EXP)sf
XS      LT  NRsf   New Rating   NR(EXP)sf

TRANSACTION SUMMARY

The notes are supported by one collateral group that consists of
1,982 seasoned performing loans (SPLs) and re-performing loans
(RPLs) with a total balance of approximately $402.42 million,
including $43.64 million in deferred balances.

Distributions of principal and interest (P&I) and loss allocations
are based on a traditional senior-subordinate, sequential
structure. The sequential-pay structure locks out principal to the
subordinated notes until the most senior notes outstanding are paid
in full. The servicers will not be advancing delinquent monthly
payments of P&I.

KEY RATING DRIVERS

Distressed Performance History (Negative): The collateral pool
consists primarily of peak-vintage SPLs and RPLs. Based on Fitch's
treatment of coronavirus-related forbearance and deferral loans,
approximately 21% of the loans were treated as having clean payment
histories for the past two years; 67% of the loans are current but
have had recent delinquencies or incomplete 24-month pay strings
and 12% are delinquent. Roughly 90% have been modified.

Geographic Concentration (Neutral): Approximately 20.1% of the pool
is concentrated in California. The New York MSA has the largest
concentration at 18.8% followed by the Los Angeles MSA (8.2%) and
the Washington MSA (5.0). The top three MSAs account for 32.0% of
the pool. As a result, there was no PD penalty due to the
geographic concentration.

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.

No Servicer P&I Advances (Mixed): The servicer will not be
advancing delinquent monthly payments of P&I, which reduce
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.

Updated Economic Risk Factor (Positive): Consistent with the
Additional Scenario Analysis section of Fitch's "U.S. RMBS
Coronavirus-Related Analytical Assumptions" criteria, Fitch will
consider applying an additional scenario analysis based on stressed
assumptions as described in the section to remain consistent with
significant revisions to its macroeconomic baseline scenario or if
actual performance data indicate the current assumptions require
reconsideration.

In response to revisions to Fitch's macroeconomic baseline
scenario, observed actual performance data, and the unexpected
development in the health crisis arising from the advancement and
availability of coronavirus vaccines, Fitch reconsidered the
application of the coronavirus-related Economic Risk Factor (ERF)
floors of 2.0 and used ERF floors of 1.5 and 1.0 for the 'BBsf' and
'Bsf' rating stresses, respectively.

Fitch's "Global Economic Outlook - March 2021" and related baseline
economic scenario forecasts have been revised to 6.2% U.S. GDP
growth for 2021 and 3.3% for 2022 following the negative 3.5% GDP
rate in 2020. Additionally, Fitch's U.S. unemployment forecasts for
2021 and 2022 are 5.8% and 4.7%, respectively, down from 8.1% in
2020. These revised forecasts support Fitch reverting to the 1.5
and 1.0 ERF floors described in its "U.S. RMBS Loan Loss Model
Criteria."

RATING SENSITIVITIES

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper market value declines (MVDs) than
assumed at the MSA level. Sensitivity analysis was conducted at the
state and national level to assess the effect of higher MVDs for
the subject pool as well as lower MVDs, illustrated by a gain in
home prices.

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

-- The 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 41% 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.

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

-- The defined positive rating sensitivity analysis demonstrates
    how the ratings would react to positive home price growth of
    10% with no assumed overvaluation. 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
    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

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 SitusAMC, Clayton Services, Opus CMC, Recovco and
Residential Real Estate Review Management. The third-party due
diligence described in Form 15E focused on regulatory compliance
which covered applicable federal, state and local high-cost loan
and/or anti-predatory laws, as well as the Truth-in-Lending Act and
Real Estate Settlement Procedures Act.

81 of reviewed loans, or approximately 4.2% of the review sample,
received a final grade of 'C-D' as the loan file did not have a
final HUD-1. The absence of a final HUD-1 file does not allow the
TPR firm to properly test for compliance surrounding predatory
lending in which statute of limitations does not apply. These
regulations may expose the trust to potential assignee liability in
the future and create added risk for bond investors.

The remaining 152 loans with a final grade of 'C' or 'D' reflect
missing final HUD-1 files that are not subject to predatory
lending, missing state disclosures and other missing documents
related to compliance testing. Fitch notes that these exceptions
are unlikely to add material risk to bondholders since the statute
of limitations on these issues have expired. No adjustment to loss
expectations were made for these 152 loans.

Fitch also applied an adjustment on 54 loans that had missing
modification agreements. Each loan received a three-month
foreclosure timeline extension to represent a delay in the event of
liquidation as a result of these files not being present.

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


CSMC TRUST 2021-RPL5: Fitch Gives 'B(EXP)' Rating to B-2 Certs
---------------------------------------------------------------
Fitch Ratings expects to rate the residential mortgage-backed notes
to be issued by CSMC 2021-RPL5 Trust (CSMC 2021-RPL5)

DEBT                RATING
----                ------
CSMC 2021-RPL5

A-1     LT  AAA(EXP)sf  Expected Rating
A-1A    LT  AAA(EXP)sf  Expected Rating
A-1X    LT  AAA(EXP)sf  Expected Rating
M-1     LT  AA(EXP)sf   Expected Rating
M-2     LT  A(EXP)sf    Expected Rating
M-3     LT  BBB(EXP)sf  Expected Rating
B-1     LT  BB(EXP)sf   Expected Rating
B-2     LT  B(EXP)sf    Expected Rating
B-3     LT  NR(EXP)sf   Expected Rating
B-4     LT  NR(EXP)sf   Expected Rating
B-5     LT  NR(EXP)sf   Expected Rating
A-IO-S  LT  NR(EXP)sf   Expected Rating
PT      LT  NR(EXP)sf   Expected Rating
SA      LT  NR(EXP)sf   Expected Rating
XS      LT  NR(EXP)sf   Expected Rating

TRANSACTION SUMMARY

The notes are supported by one collateral group that consists of
1,982 seasoned performing loans (SPLs) and re-performing loans
(RPLs) with a total balance of approximately $402.42 million,
including $43.64 million in deferred balances.

Distributions of principal and interest (P&I) and loss allocations
are based on a traditional senior-subordinate, sequential
structure. The sequential-pay structure locks out principal to the
subordinated notes until the most senior notes outstanding are paid
in full. The servicers will not be advancing delinquent monthly
payments of P&I.

KEY RATING DRIVERS

Distressed Performance History (Negative): The collateral pool
consists primarily of peak-vintage SPLs and RPLs. Based on Fitch's
treatment of coronavirus-related forbearance and deferral loans,
approximately 21% of the loans were treated as having clean payment
histories for the past two years; 67% of the loans are current but
have had recent delinquencies or incomplete 24-month pay strings
and 12% are delinquent. Roughly 90% have been modified.

Geographic Concentration (Neutral): Approximately 20.1% of the pool
is concentrated in California. The New York MSA has the largest
concentration at 18.8% followed by the Los Angeles MSA (8.2%) and
the Washington MSA (5.0). The top three MSAs account for 32.0% of
the pool. As a result, there was no PD penalty due to the
geographic concentration.

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.

No Servicer P&I Advances (Mixed): The servicer will not be
advancing delinquent monthly payments of P&I, which reduce
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.

Updated Economic Risk Factor (Positive): Consistent with the
Additional Scenario Analysis section of Fitch's "U.S. RMBS
Coronavirus-Related Analytical Assumptions" criteria, Fitch will
consider applying an additional scenario analysis based on stressed
assumptions as described in the section to remain consistent with
significant revisions to its macroeconomic baseline scenario or if
actual performance data indicate the current assumptions require
reconsideration.

In response to revisions to Fitch's macroeconomic baseline
scenario, observed actual performance data, and the unexpected
development in the health crisis arising from the advancement and
availability of coronavirus vaccines, Fitch reconsidered the
application of the coronavirus-related Economic Risk Factor (ERF)
floors of 2.0 and used ERF floors of 1.5 and 1.0 for the 'BBsf' and
'Bsf' rating stresses, respectively.

Fitch's "Global Economic Outlook - March 2021" and related baseline
economic scenario forecasts have been revised to 6.2% U.S. GDP
growth for 2021 and 3.3% for 2022 following the negative 3.5% GDP
rate in 2020. Additionally, Fitch's U.S. unemployment forecasts for
2021 and 2022 are 5.8% and 4.7%, respectively, down from 8.1% in
2020. These revised forecasts support Fitch reverting to the 1.5
and 1.0 ERF floors described in its "U.S. RMBS Loan Loss Model
Criteria."

RATING SENSITIVITIES

Fitch's incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper market value declines (MVDs) than
assumed at the MSA level. Sensitivity analysis was conducted at the
state and national level to assess the effect of higher MVDs for
the subject pool as well as lower MVDs, illustrated by a gain in
home prices.

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

-- The 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 41% 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.

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

-- The defined positive rating sensitivity analysis demonstrates
    how the ratings would react to positive home price growth of
    10% with no assumed overvaluation. 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
    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

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 SitusAMC, Clayton Services, Opus CMC, Recovco and
Residential Real Estate Review Management. The third-party due
diligence described in Form 15E focused on regulatory compliance
which covered applicable federal, state and local high-cost loan
and/or anti-predatory laws, as well as the Truth-in-Lending Act and
Real Estate Settlement Procedures Act.

81 of reviewed loans, or approximately 4.2% of the review sample,
received a final grade of 'C-D' as the loan file did not have a
final HUD-1. The absence of a final HUD-1 file does not allow the
TPR firm to properly test for compliance surrounding predatory
lending in which statute of limitations does not apply. These
regulations may expose the trust to potential assignee liability in
the future and create added risk for bond investors.

The remaining 152 loans with a final grade of 'C' or 'D' reflect
missing final HUD-1 files that are not subject to predatory
lending, missing state disclosures, and other missing documents
related to compliance testing. Fitch notes that these exceptions
are unlikely to add material risk to bondholders since the statute
of limitations on these issues have expired. No adjustment to loss
expectations were made for these 152 loans.

Fitch also applied an adjustment on 54 loans that had missing
modification agreements. Each loan received a three-month
foreclosure timeline extension to represent a delay in the event of
liquidation as a result of these files not being present.

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


DRYDEN 86 CLO: S&P Assigned Prelim BB- (sf) Rating on E-R Notes
---------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
X-R, A-1-R, A-2-R, B-R, C-R, D-R, and E-R replacement notes and
proposed new class X notes from Dryden 86 CLO Ltd./Dryden 86 CLO
LLC, a CLO originally issued in August 2020 that is managed by PGIM
Inc.

The preliminary ratings are based on information as of July 12,
2021. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the July 19, 2021, refinancing date, the proceeds from the
replacement notes will be used to redeem the original notes. S&P
said, "At that time, we expect to withdraw our ratings on the
original notes and assign ratings to the replacement notes.
However, if the refinancing doesn't occur, we may affirm our
ratings on the original notes and withdraw our preliminary ratings
on the replacement notes."

The replacement notes will be issued via a proposed supplemental
indenture, which outlines the terms of the replacement notes.
According to the proposed supplemental indenture:

-- The replacement class A-1-R, A-2-R, B-R, C-R, D-R, and E-R
notes are expected to be issued at a lower spread over three-month
LIBOR than the original notes.

-- The replacement class X-R, A-1-R, A-2-R, B-R, C-R, D-R, and E-R
notes are expected to be issued at a floating spread.

-- The stated maturity will be extended by approximately four
years.

-- The reinvestment period will be extended by approximately three
years

-- The non-call period will be extended by approximately two
years.

-- The transaction documents updated the terms of workout-related
concepts and introduced new workout-related concepts.

-- The proposed class X-R notes were issued in connection with
this refinancing. These notes are expected to be paid down using
interest proceeds over 12 payment dates, beginning with the payment
date in April 2023.

-- 100% of the identified underlying collateral obligations have
credit ratings assigned by S&P Global Ratings.

-- 92.58% of the identified underlying collateral obligations have
recovery ratings assigned by S&P Global Ratings.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis (and other qualitative factors, as applicable)
demonstrated, in our view, that the outstanding rated classes all
have adequate credit enhancement available at the rating levels
associated with the rating actions.

"We will continue to review whether, in our view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Preliminary Ratings Assigned

  Dryden 86 CLO Ltd./Dryden 86 CLO LLC

  Class X-R, $3.60 million: AAA (sf)
  Class A-1-R, $381.30 million: AAA (sf)
  Class A-2-R, $25.00 million: AAA (sf)
  Class B-R, $68.80 million: AA (sf)
  Class C-R (deferrable), $37.50 million: A (sf)
  Class D-R (deferrable), $37.50 million: BBB- (sf)
  Class E-R (deferrable), $25.00 million: BB- (sf)
  Subordinated notes, $62.50 million: Not rated



ELMWOOD CLO IX: S&P Assigns BB-(sf) Rating on $18MM Class E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Elmwood CLO IX
Ltd./Elmwood CLO IX LLC's floating-rate debt.

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

The ratings reflect:

-- The diversification of the collateral pool;

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

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

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

  Ratings Assigned

  Elmwood CLO IX Ltd./Elmwood CLO IX LLC

  Class A-L(i), $142.0 million: AAA (sf)
  Class A, $141.5 million: AAA (sf)
  Class B, $58.5 million: AA (sf)
  Class C (deferrable), $27.0 million: A (sf)
  Class D (deferrable), $27.0 million: BBB- (sf)
  Class E (deferrable), $18.0 million: BB- (sf)
  Subordinated notes, $45.6 million: Not rated

(i)The class A-L debt will be issued in loan form and have the
ability to be converted into class A notes.



GS MORTGAGE-BACKED 2021-PJ7: Fitch Gives 'B(EXP)' to B-5 Certs
---------------------------------------------------------------
Fitch expects to rate the residential mortgage-backed certificates
issued by GS Mortgage-Backed Securities Trust 2021-PJ7 (GSMBS
2021-PJ7) as indicated. The transaction is expected to close on
July 30, 2021. The certificates are supported by 953 prime-jumbo
mortgage loans with a total balance of approximately $929 million
as of the cut-off date.

DEBT                 RATING
----                 ------
GSMBS 2021-PJ7

A-1      LT  AAA(EXP)sf  Expected Rating
A-10     LT  AAA(EXP)sf  Expected Rating
A-11     LT  AAA(EXP)sf  Expected Rating
A-11-X   LT  AAA(EXP)sf  Expected Rating
A-12     LT  AAA(EXP)sf  Expected Rating
A-13     LT  AAA(EXP)sf  Expected Rating
A-14     LT  AAA(EXP)sf  Expected Rating
A-15     LT  AAA(EXP)sf  Expected Rating
A-15-X   LT  AAA(EXP)sf  Expected Rating
A-16     LT  AAA(EXP)sf  Expected Rating
A-17     LT  AAA(EXP)sf  Expected Rating
A-17-X   LT  AAA(EXP)sf  Expected Rating
A-18     LT  AAA(EXP)sf  Expected Rating
A-18-X   LT  AAA(EXP)sf  Expected Rating
A-19     LT  AAA(EXP)sf  Expected Rating
A-2      LT  AAA(EXP)sf  Expected Rating
A-20     LT  AAA(EXP)sf  Expected Rating
A-21     LT  AA+(EXP)sf  Expected Rating
A-3      LT  AA+(EXP)sf  Expected Rating
A-4      LT  AA+(EXP)sf  Expected Rating
A-5      LT  AAA(EXP)sf  Expected Rating
A-6      LT  AAA(EXP)sf  Expected Rating
A-7      LT  AAA(EXP)sf  Expected Rating
A-7-X    LT  AAA(EXP)sf  Expected Rating
A-8      LT  AAA(EXP)sf  Expected Rating
A-9      LT  AAA(EXP)sf  Expected Rating
A-IO-S   LT  NR(EXP)sf   Expected Rating
A-R      LT  NR(EXP)sf   Expected Rating
A-X-1    LT  AA+(EXP)sf  Expected Rating
A-X-13   LT  AAA(EXP)sf  Expected Rating
A-X-2    LT  AAA(EXP)sf  Expected Rating
A-X-3    LT  AA+(EXP)sf  Expected Rating
A-X-4    LT  AA+(EXP)sf  Expected Rating
A-X-5    LT  AAA(EXP)sf  Expected Rating
A-X-9    LT  AAA(EXP)sf  Expected Rating
B-1      LT  AA(EXP)sf   Expected Rating
B-2      LT  A(EXP)sf    Expected Rating
B-3      LT  BBB(EXP)sf  Expected Rating
B-4      LT  BB(EXP)sf   Expected Rating
B-5      LT  B(EXP)sf    Expected Rating
B-6      LT  NR(EXP)sf   Expected Rating

KEY RATING DRIVERS

High-Quality Mortgage Pool (Positive): The collateral consists of
mostly 30-year fixed-rate mortgage fully amortizing loans seasoned
approximately five months in aggregate. The collateral is a mix of
prime-jumbo (92.2%) and agency conforming loans (7.8%). The
borrowers in this pool have strong credit profiles (767 model FICO)
and relatively low leverage (a 74.6% sustainable loan to value
ratio). Fitch treated 98.5% as full documentation collateral, while
100% of the loans are safe-harbor qualified mortgages. Of the pool,
97.6% are loans for which the borrower maintains a primary
residence, while 2.4% are for second homes. Additionally, 88% of
the loans were originated through a retail channel.

Shifting-Interest Deal Structure (Mixed): The mortgage cash flow
and loss allocation are based on a senior-subordinate,
shifting-interest structure, whereby the subordinate classes
receive only scheduled principal and are locked out from receiving
unscheduled principal or prepayments for five years. While there is
only minimal leakage to the subordinate bonds early in the life of
the transaction, the structure is more vulnerable to defaults
occurring at a later stage compared to a sequential or
modified-sequential structure.

To help mitigate tail risk, which arises as the pool seasons and
fewer loans are outstanding, a subordination floor of 0.70% of the
original balance will be maintained for the senior certificates,
and a subordination floor of 0.50% of the original balance will be
maintained for the subordinate certificates.

Shellpoint Mortgage Servicing (SMS) will provide full advancing for
the life of the transaction. While this helps the liquidity of the
structure, it also increases the expected loss due to unpaid
servicer advances.

Low Operational Risk (Neutral): Operational risk is well controlled
for in this transaction. Goldman Sachs is assessed as an 'Above
Average' aggregator by Fitch due to its robust sourcing strategy
and seller oversight, experienced senior management and staff, and
strong risk management and corporate governance controls.

Additionally, Fitch has conducted reviews on almost 80% of the
originators in this transaction, all of which are considered at
least an 'Average' originator by industry standards. Primary
servicing responsibilities are performed by SMS, rated 'RPS2' by
Fitch. Fitch did not adjust its expected losses based on these
operational assessments.

Updated Economic Risk Factor (Positive): Consistent with the
Additional Scenario Analysis section of Fitch's "U.S. RMBS
Coronavirus-Related Analytical Assumptions" criteria, Fitch will
consider applying additional scenario analysis based on stressed
assumptions as described in the section to remain consistent with
significant revisions to its macroeconomic baseline scenario or if
actual performance data indicate the current assumptions require
reconsideration.

In response to revisions made to Fitch's macroeconomic baseline
scenario, observed actual performance data, and the unexpected
development in the health crisis arising from the advancement and
availability of coronavirus vaccines, Fitch reconsidered the
application of the coronavirus-related Economic Risk Factors (ERF)
floors of 2.0 and used ERF floors of 1.5 and 1.0 for the 'BBsf' and
'Bsf' rating stresses, respectively.

Fitch's "Global Economic Outlook -- March 2021" and related
baseline economic scenario forecasts have been revised to 6.2% U.S.
GDP growth for 2021 and 3.3% for 2022, following -3.5% GDP growth
in 2020. Additionally, Fitch's U.S. unemployment forecasts for 2021
and 2022 are 5.8% and 4.7%, respectively, down from 8.1% in 2020.
These revised forecasts support Fitch reverting to the 1.5 and 1.0
ERF floors described in its "U.S. RMBS Loan Loss Model Criteria."
The lower expected losses in the non-investment-grade rating
stresses led to higher ratings for class B5 compared to prior
transactions.

RATING SENSITIVITIES

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper market value declines (MVDs) than
assumed at the MSA level.

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.

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

-- This 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 decline at the base case. This
    analysis indicates there is some potential rating migration
    with higher MVDs compared with the model projection.

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

-- This defined positive rating sensitivity analysis demonstrates
    how the ratings would react to positive home price growth with
    no assumed overvaluation. The analysis assumes positive home
    price growth of 10.0%. Excluding the senior classes already
    rated 'AAAsf' and classes constrained due to qualitative
    rating caps, the analysis indicates there is potential
    positive rating migration for all of the other rated classes.

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. For enhanced disclosure of Fitch's
stresses and sensitivities, please refer to "Fitch U.S. RMBS Loss
Metrics".

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. Third-party due diligence was
performed on 100% of the loans in the transaction. Due diligence
was performed by SitusAMC, Opus, Recovco, Digital Risk, and Evolve
which Fitch assesses as 'Acceptable -- Tier 1', 'Acceptable -- Tier
2', 'Acceptable -- Tier 3', 'Acceptable -- Tier 2', and 'Acceptable
-- Tier 3' respectively. The review scope is consistent with Fitch
criteria, and the results are generally similar to prior prime RMBS
transactions. Credit exceptions were supported by strong mitigating
factors, and compliance exceptions were primarily cured with
subsequent documentation.

DATA ADEQUACY

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

Fitch also utilized data files made available by the issuer on its
SEC Rule 17g-5-designated website. Fitch received loan-level
information based on the American Securitization Forum's (ASF) data
layout format, and the data are considered comprehensive.

The ASF data tape layout was established with input from various
industry participants, including rating agencies, issuers,
originators, investors and others, to produce an industry standard
for the pool-level data in support of the U.S. RMBS securitization
market. The data contained in the ASF layout data tape were
reviewed by the due diligence companies, and no material
discrepancies were noted.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


HERTZ VEHICLE III: DBRS Finalizes BB Rating on Class D Notes
------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following notes
issued by Hertz Vehicle Financing III LLC:

-- Series 2021-1, Class A Notes at AAA (sf)
-- Series 2021-1, Class B Notes at A (sf)
-- Series 2021-1, Class C Notes at BBB (sf)
-- Series 2021-1, Class D Notes at BB (sf)
-- Series 2021-2, Class A Notes at AAA (sf)
-- Series 2021-2, Class B Notes at A (sf)
-- Series 2021-2, Class C Notes at BBB (sf)
-- Series 2021-2, Class D Notes at BB (sf)

The ratings are based on a review by DBRS Morningstar of the
following analytical considerations:

-- The transaction's capital structure as well as the form and
sufficiency of available credit enhancement.

-- Credit enhancement in the transaction is dynamic, depending on
the composition of the vehicles in the fleet and certain market
value tests.

-- Amortization Events include, but are not limited to, default in
the payment of amounts due after five consecutive business days,
default in the payment of amounts due by the expected final payment
date, deficiency of amounts available in the liquidity reserve
account, payment default under the master lease, the required asset
amount exceeding the aggregate asset amount, servicer default, and
administrator default.

-- The ability of the transaction to withstand stressed cash flow
assumptions and repay investors according to the terms of the
documents. The ratings address the timely payment of interest to
the Class A, Class B, Class C, and Class D noteholders at their
respective note rates as well as ultimate payment of principal on
the notes, in each case by the legal final payment date.

-- The intention of each party to the master lease to treat the
lease as a single indivisible lease.

-- The transaction allows vehicles, for which the Collateral Agent
has not yet been noted on the Certificates of Title as lienholder,
to remain as eligible assets for up to 28 days for new vehicles
(which may be extended to up to 45 days in some states) and 45 days
for used vehicles (Lien Holidays). All vehicles benefit from a
negative pledge.

-- Inclusion of box trucks that are subject to a limit of 5% and a
required credit enhancement of 35%.

-- The analysis considers DBRS Morningstar's set of macroeconomic
scenarios for select economies related to the Coronavirus Disease
(COVID-19), available in its commentary "Global Macroeconomic
Scenarios - June 2021 Update," published on June 18, 2021. DBRS
Morningstar initially published macroeconomic scenarios on April
16, 2020, which have been regularly updated. The scenarios were
last updated on June 18, 2021, and are reflected in DBRS
Morningstar's rating analysis. The assumptions consider the
moderate macroeconomic scenario outlined in the commentary, with
the moderate scenario serving as the primary anchor for the current
ratings. The moderate scenario factors in continued success in
containment during the second half of 2021, enabling the continued
relaxation of restrictions.

-- Mandatory shutdowns of nonessential businesses in spring 2020,
which led to the closure of used-vehicle auctions and dealerships
and resulted in a rapid decline in the value of used vehicles.
However, by Q3 2020 values recovered and continued to increase
because the global chip shortage has significantly reduced the
availability of new vehicles, resulting in the recovery of used
vehicle prices in spring 2021.

-- The transaction parties' capabilities to effectively manage
rental car operations and dispose of the fleet to the extent
necessary, including the Back-up Disposition Agent, Defi AUTO, LLC,
and the Back-up Administrator, Lord Securities Corporation.

-- The legal structure and its consistency with DBRS Morningstar's
Legal Criteria for U.S. Structured Finance methodology, the
provision of legal opinions that address the treatment of the
operating lease as a true lease, the nonconsolidation of the
special-purpose vehicles with Hertz and its affiliates, and that
the trust has a valid first-priority security interest in the
assets.

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



HOME PARTNERS 2021-1: DBRS Gives Prov. BB Rating on Class F Certs
-----------------------------------------------------------------
DBRS, Inc. assigned the following provisional ratings to the
Single-Family Rental Pass-Through Certificates to be issued by Home
Partners of America 2021-1 Trust:

-- $196.5 million Class A at AAA (sf)
-- $58.1 million Class B at AA (low) (sf)
-- $29.7 million Class C at A (low) (sf)
-- $32.1 million Class D at BBB (sf)
-- $28.4 million Class E at BBB (low) (sf)
-- $35.8 million Class F at BB (sf)

The AAA (sf) rating on the Certificates reflects 52.61% of credit
enhancement provided by subordinated notes in the pool. The AA
(low) (sf), A (low) (sf), BBB (sf), BBB (low) (sf), and BB (sf)
ratings reflect 38.60%, 31.45%, 23.70%, 16.84%, and 8.20% of credit
enhancement, respectively.

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

The Certificates are supported by the income streams and values
from 1399 rental properties. The properties are distributed across
16 states and 42 metropolitan statistical areas (MSAs) in the
United States. DBRS Morningstar maps an MSA based on the ZIP code
provided in the data tape, which may result in different MSA
stratifications than those provided in offering documents. As
measured by value, 43.3% of the portfolio is concentrated in three
states: Colorado (17.5%), Florida (13.3%), and Georgia (12.5%). The
average purchase price per property is $337,542, and the average
value is $353,316. The average age of the properties is roughly 26
years. The majority of the properties have three or more bedrooms.
The certificates represent a beneficial ownership in an eight-year,
fixed-rate, interest-only loan with an initial aggregate principal
balance of approximately $414.6 million.

As in typical single-borrower, single-family rental transactions,
the waterfall has straight sequential payments with reverse
sequential losses.

DBRS Morningstar estimated the base-case net cash flow (NCF) by
evaluating the gross rent, concession, vacancy, operating expenses,
and capital expenditure data. DBRS Morningstar's base-case
underwriting yielded an aggregate annualized NCF of approximately
$14.9 million. Based on DBRS Morningstar's NCF assumptions outlined
in the presale report, the DBRS Morningstar NCF analysis resulted
in a minimum DSCR of greater than 1.0 times (x).

Vacancy data in the single-family rental space is relatively
limited. In general, based on performance data in existing
securitizations as well as information gathered in annual
property-manager reviews, vacancy is considered low in the
single-family rental market. DBRS Morningstar applied a base
vacancy rate of 9.0%, an additional base vacancy adjustment related
to the rental payment delinquency impact of the Coronavirus Disease
(COVID-19) pandemic, plus a qualitative adjustment to account for
structural and documentation weakness in the transaction. The loan
agreement lacks credit measures, such as the income-to-rent ratio,
in the eligible tenant provision. DBRS Morningstar accounted for
this potential impact by reducing the DBRS Morningstar gross rent
by 1.0%. DBRS Morningstar also accounted for the current
delinquency and vacancy levels as well as the highly concentrated
lease expiration profile by further stressing the vacancy
assumption, bringing the DBRS Morningstar vacancy rate to 14.9%,
which is more conservative than the underwritten economic vacancy
rate of 4.1% (includes underwritten annual credit loss) of the
Issuer's gross income.

Additionally, DBRS Morningstar applied a stress to the broker price
opinions (BPOs) because, in general, a valuation based on a BPO may
be less comprehensive than a valuation based on a full appraisal.
DBRS Morningstar had initially increased the BPO stress in response
to the pandemic and the resulting isolation measures, which caused
an immediate economic contraction, leading to sharp increases in
unemployment rates and income reductions for many consumers. Due to
the continued strong performance of the housing market, DBRS
Morningstar will no longer apply the additional pandemic-related
BPO stress.

The transaction allows for discretionary substitutions of up to
5.0% of the number of properties as of the closing date, as long as
certain restrictions are met.

The Sponsor intends to satisfy its risk retention obligations under
the U.S. Risk Retention Rules by holding the Class G Certificates,
either directly or through a majority-owned affiliate.

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


IVY HILL IX: Fitch Affirms B+ Rating on Class E-R Notes
-------------------------------------------------------
Fitch Ratings has affirmed six classes of notes issued by two
middle market (MM) collateralized loan obligations (CLOs) managed
by Ivy Hill Asset Management, L.P. (Ivy Hill). All tranches remain
on Rating Outlook Stable.

    DEBT               RATING          PRIOR
    ----               ------          -----
Ivy Hill Middle Market Credit Fund IX, Ltd.

A-R 46603BAN9   LT  AAAsf   Affirmed   AAAsf
B-R 46603BAQ2   LT  AAsf    Affirmed   AAsf
C-R 46603BAS8   LT  BBB+sf  Affirmed   BBB+sf
D-R 46603BAU3   LT  BB+sf   Affirmed   BB+sf
E-R 46603GAE8   LT  B+sf    Affirmed   B+sf

Ivy Hill Middle Market Credit Fund XIV, Ltd

A-1 46603VAA3   LT  AAAsf   Affirmed   AAAsf

TRANSACTION SUMMARY

Ivy Hill Middle Market Credit Fund IX, Ltd. (Ivy Hill IX) and Ivy
Hill Middle Market Credit Fund XIV, Ltd. (Ivy Hill XIV) are MM CLOs
backed by portfolios of primarily senior secured loans and actively
managed by Ivy Hill. Ivy Hill IX is a 2017 vintage transaction that
exits its reinvestment period in January 2022, while Ivy Hill XIV
is a 2018 vintage transaction that exits its reinvestment period in
April 2022.

KEY RATING DRIVERS

Stable Asset Credit Quality

The rating actions for Ivy Hill IX reflect the stable asset credit
quality and overall performance of the portfolio since the last
review in August 2020. The Fitch-calculated weighted average rating
factor (WARF) of the performing portfolio was relatively unchanged
at 44.3 (B-/CCC+). The CLO gained approximately 0.8% of the
original portfolio target par amount since the last review through
recoveries on assets that defaulted in 2020 and from active
portfolio management. Portfolio exposure to assets with
Fitch-derived ratings 'CCC+' and lower (excluding non-rated assets)
decreased to 17.1% from 26.3% for Ivy Hill IX, and assets with a
Fitch-derived rating with a Negative Outlook comprised 9.5% of the
portfolio, down from 22.5% at last review.

The affirmation for Ivy Hill XIV also reflects overall stable
collateral performance of the portfolio. The Fitch-calculated WARF
is 47.3 (B-/CCC+) and the CLO gained approximately 0.1% of the
original portfolio target par amount since last review.
Fitch-derived 'CCC+' and lower rating exposure (excluding non-rated
assets) decreased to 13.1% from 17.7% for Ivy Hill XIV, and assets
with a Fitch-derived rating with a Negative Outlook decreased to
6.7% from 16.0% of the portfolio.

Asset Security, Portfolio Composition and Portfolio Management

The portfolios have strong recovery prospects, as they consist of
98.9% first lien senior secured loans. The Fitch WARR of the
current portfolios is 71.5% for Ivy Hill IX and 66.8% for Ivy Hill
XIV, compared with 73.9% and 66.4%, respectively, at last review.
Portfolios remain fairly diversified, with obligor count averaging
130 obligors. Exposure to the top 10 obligors ranged from 19.5% for
Ivy Hill IX to 18.0% for Ivy Hill XIV and no obligor represents
more than 3.0% of the portfolio balance.

The CLOs remain in their reinvestment periods, and weighted average
life (WAL) for Ivy Hill IX has increased to approximately 4.2 years
from 4.0 years. The portfolio WAL for Ivy Hill XIV decreased to 3.9
years from 4.0 years.

Asset credit quality, asset security and portfolio composition from
portfolio management are captured in rating default rate (RDR),
rating recovery rate (RRR) and rating loss rate (RLR) produced by
Fitch's Portfolio Credit Model (PCM). PCM RLRs from their current
portfolios were compared with the RLRs corresponding to the
original Fitch Stressed Portfolio (FSP) at the initial rating
assignment. For Ivy Hill XIV, the 'AAAsf' RLR cushion remains
positive and Fitch affirmed the class A-1 notes with a Stable
Rating Outlook. However, the loss rates projected for the class D-R
and E-R notes in Ivy Hill IX continue to exceed the loss rates
projected from its Fitch Stressed Portfolio analysis.

Cash Flow Analysis

Fitch conducted an updated cash flow analysis of Ivy Hill IX,
applied across all scenarios outlined in Fitch's CLOs and Corporate
CDOs Rating Criteria.

The results of the cash flow analysis for the current portfolio
improved from the last review, with model-implied ratings (MIR) in
line with the current ratings for the class A-R, C-R, D-R, and E-R
notes, and one notch higher for the class B-R notes. Fitch did not
upgrade the class B-R notes to their MIR because the CLO remains in
its reinvestment period until January 2022, which allows the
manager to change portfolio composition. As a result, Fitch
affirmed all classes of notes in Ivy Hill IX with Stable Rating
Outlooks.

The Stable Rating Outlooks on all notes in this review reflect
Fitch's expectation that the classes have sufficient levels of
credit protection to withstand potential deterioration in the
credit quality of the portfolios in stress scenarios commensurate
with such classes' rating.

RATING SENSITIVITIES

Fitch conducted rating sensitivity analysis on the closing date of
each CLO, incorporating increased levels of defaults and reduced
levels of recovery rates, among other sensitivities, as defined in
its CLOs and Corporate CDOs Rating Criteria. For more information
on Fitch's Stressed Portfolio and initial model-implied rating
sensitivities, please refer to the presale/new issuance report of
each transaction.

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

-- For Ivy Hill IX, a 25% reduction of the mean default rate
    across all ratings and a 25% increase of the recovery rate at
    all rating levels would lead to an upgrade of up to two
    notches for the class B-R notes, up to three notches for the
    class C-R notes, and up to six notches for the class D-R and
    E-R notes, based on the model-implied ratings;

-- An upgrade scenario would not be applicable to the class A-R
    notes in Ivy Hill IX or the A-1 notes in Ivy Hill XIV since
    they are already rated at the highest rating level (AAAsf).

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

-- Downgrades may occur if realized and projected losses in the
    respective portfolios are higher than those assumed at closing
    in the Fitch Stressed Portfolio and that are not offset by the
    increase in the CLO notes' CE levels;

-- For Ivy Hill IX, a 25% increase of the mean default rate
    across all ratings and a 25% decrease of the recovery rate at
    all rating levels would lead to a downgrade of two notches for
    the class A-R notes, five notches for the class B-R notes,
    three notches for the class C-R notes, four notches for the
    class D-R notes, and more than three notches for the class E-R
    notes based on the model-implied ratings.

BEST/WORST CASE RATING SCENARIO

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

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

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

DATA ADEQUACY

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other nationally
recognized statistical rating organizations and/or European
securities and markets authority-registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk-presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


JP MORGAN 2003-CIBC7: Moody's Cuts Cl. X-1 Certs Rating to 'C'
--------------------------------------------------------------
Moody's Investors Service has affirmed the rating on one class,
upgraded the rating on one class and downgraded the rating on one
class in J.P. Morgan Chase Commercial Mortgage Securities Corp.
Series 2003-CIBC7, Commercial Pass-Through Certificates, Series
2003-CIBC7 as follows:

Cl. H, Upgraded to Baa3 (sf); previously on Nov 22, 2019 Upgraded
to Ba1 (sf)

Cl. J, Affirmed C (sf); previously on Nov 22, 2019 Affirmed C (sf)

Cl. X-1*, Downgraded to C (sf); previously on Nov 22, 2019 Affirmed
Ca (sf)

* Reflects interest-only classes

RATINGS RATIONALE

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

The rating on the P&I class, Cl. H, was upgraded primarily due to
an increase in credit support resulting from loan paydowns and
amortization as well as an increase in defeasance. The deal has
paid down 45% since Moody's last review and defeasance has
increased to 46% of the current pool balance from 40% at last
review.

The rating on the IO class Cl. X-1 was downgraded due to the
decline in the credit quality of its reference classes resulting
from principal paydowns of higher quality reference classes.

Moody's rating action reflects a base expected loss of 0.2% of the
current pooled balance, unchanged from Moody's last review. Moody's
base expected loss plus realized losses is now 3.8% of the original
pooled balance, unchanged from 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 September 2020.

DEAL PERFORMANCE

As of the June 14, 2021 distribution date, the transaction's
aggregate certificate balance has decreased by 99% to $18 million
from $1.39 billion at securitization. The certificates are
collateralized by 19 mortgage loans ranging in size from 1.5% to
15% of the pool, with the top ten loans (excluding defeasance)
constituting 52.5% of the pool. Eight loans, constituting 46% 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 7, compared to 8 at Moody's last review.

As of the June 2021 remittance report, all loans were current or
within their grace period on their debt service payments.

Three loans, constituting 22.6% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

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

The credit risk of loans is determined primarily by two factors: 1)
Moody's assessment of the probability of default, which is largely
driven by each loan's DSCR, and 2) Moody's assessment of the
severity of loss upon a default, which is largely driven by each
loan's loan-to-value ratio, referred to as the Moody's LTV or MLTV.
As described in the CMBS methodology used to rate this transaction,
Moody's make various adjustments to the MLTV. Moody's adjust the
MLTV for each loan using a value that reflects capitalization (cap)
rates that are between Moody's sustainable cap rates and market cap
rates. Moody's also use an adjusted loan balance that reflects each
loan's amortization profile. The MLTV reported in this publication
reflects the MLTV before the adjustments described in the
methodology.

Moody's received full year 2019 operating results for 88% of the
pool, and full or partial year 2020 operating results for 88% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 19%, compared to 24% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 20% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 9.9%.

Moody's actual and stressed conduit DSCRs are 1.29X and 6.71X,
respectively, compared to 1.53X and 5.01X 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 top three conduit loans represent 31.6% of the pool balance.
The largest loan is the Crestpointe Corporate Center II Loan ($2.7
million -- 15.0% of the pool), which is secured by an approximately
122,000 square foot (SF) office property located in Columbia,
Maryland. Occupancy dropped to 73% as of year-end 2020 compared to
95% in March 2019. The largest tenant vacated prior to lease
expiration. The loan is fully amortizing and has amortized 79%
since securitization. The loan matures in October 2023 and Moody's
LTV and stressed DSCR are 25% and greater than 4.00X,
respectively.

The second largest loan is the Grande Communications Portfolio Loan
($1.6 million -- 9.0% of the pool), which is secured by a portfolio
of four office properties located throughout Texas. The four
properties are fully leased to Grande Communications. Due to the
single tenant exposure, Moody's value incorporated a lit/dark
analysis. The loan is fully amortizing, has amortized 78% since
securitization and matures in September 2023. Moody's LTV and
stressed DSCR are 12% and greater than 4.00X, respectively.

The third largest loan is the Hopkins Emporia Loan ($1.4 million --
7.7% of the pool), which is secured by a 321,000 SF industrial
property located in Emporia, Kansas. The property serves as the
headquarters for Hopkins Manufacturing Corporation and includes
warehouse and production space on 16.6 acres. Hopkins
Manufacturing's lease has been recently renewed through December
2036 and the loan matures in September 2023. Due to the single
tenant exposure, Moody's value incorporated a lit/dark analysis.
The loan is fully amortizing and has amortized 80% since
securitization. Moody's LTV and stressed DSCR are 18% and greater
than 4.00X, respectively.


JP MORGAN 2011-C3: DBRS Lowers Rating on 2 Classes to C
-------------------------------------------------------
DBRS, Inc. downgraded six classes of Commercial Mortgage
Pass-Through Certificates, Series 2011-C3 issued by JP Morgan Chase
Commercial Mortgage Securities Trust 2011-C3 as follows:

-- Class D to BBB (high) (sf) from A (sf)
-- Class E to B (sf) from BBB (sf)
-- Class F to CCC (sf) from BB (high) (sf)
-- Class G to CCC (sf) from B (sf)
-- Class H to C (sf) from CCC (sf)
-- Class J to C (sf) from CCC (sf)

In addition, DBRS Morningstar confirmed the remaining classes as
follows:

-- Class B at AAA (sf)
-- Class C at AA (low) (sf)

DBRS Morningstar changed the trend on Class D to Negative from
Stable because of weakened performance across both remaining loans.
Classes B and C carry Stable trends, while Class E carries a
Negative trend. Classes F, G, H, and J have ratings that do not
carry a trend.

The downgrades and Negative trends reflect the acute risk related
to the only two remaining loans in the pool. As of the June 2021
remittance, the remaining collateral consists of two loans backed
by regional malls including Holyoke Mall (77.35% of the pool) and
Sangertown Square (22.65%). Both properties are owned and operated
by affiliates of the Pyramid Companies (Pyramid), which has seen
many of its loans in its mall portfolio move to the special
servicer amid the Coronavirus Disease (COVID-19) pandemic.

Both loans in this pool transferred to the special servicer for
payment relief in May 2020. After the borrowers and lenders agreed
upon modifications (the terms of which included three-year maturity
extensions) and the loans prepared to move back to the master
servicer, the borrowers notified the servicer that they would not
be able to perform under the terms of the original modifications
and they were seeking additional relief.

Sangertown Square, which is secured by a 894,127-square-foot (sf)
regional mall in New Hartford, New York, a tertiary market between
Utica and Syracuse, currently remains in special servicing. The
property is anchored by Dick's Sporting Goods, Target, and
Boscov's, with the other two anchor spaces currently vacant after
losing JCPenney and Macy's in October 2020 and April 2021,
respectively. The loss of the two anchors has allowed other tenants
to exercise cotenancy provisions in their leases. The loan has
remained in special servicing as negotiations on a second
modification continue. Occupancy has been declining in recent
months to its current level of 58% following Macy's departure in
April from 76% as of YE2020 after JCPenney vacated. The YE2020 net
cash flow (NCF) was 45% below the YE2019 NCF and 59% below
issuance. According to the servicer, an updated appraisal is in
draft and is not available for release; however, the value of the
property has likely plummeted from the issuance figure of $107
million given current market conditions and the steep drop in
performance before the pandemic.

Holyoke Mall is secured by a 1.56 million-sf regional mall in
Holyoke, Massachusetts. The mall is anchored by JCPenney, Macy's,
Target, and Apple. Macy's owns its space and is not part of the
loan collateral. One anchor space remains empty as Sears vacated in
2018. Junior anchors include Old Navy, Burlington Coat Factory,
DSW, Hobby Lobby, and Planet Fitness, which opened in 2019. Pyramid
had begun the process of converting the vacant Sears space into a
Cinemark theater before the pandemic, securing permits in late
2019; the status of this development remains unknown. The loan
returned to the master servicer in May 2021 after the servicer
rejected the request for a second modification. The YE2020 NCF was
36% below the 2019 NCF and 54% below issuance levels. The property
was 69% occupied as of March 2021. An updated appraisal completed
in August 2020 valued the property at $200 million, down from $400
million at issuance. The updated value reflects a trust debt
loan-to-value ratio (LTV) of 100% and a whole loan LTV of 117.5%
when factoring in the $35 million mezzanine loan.

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


JP MORGAN 2011-C4: DBRS Confirms B Rating on Class H Certs
----------------------------------------------------------
DBRS Limited upgraded the ratings on three classes of Commercial
Mortgage Pass-Through Certificates, Series 2011-C4 issued by JP
Morgan Chase Commercial Mortgage Securities Trust 2011-C4 as
follows:

-- Class C to AAA (sf) from AA (low) (sf)
-- Class D to AAA (sf) from A (sf)
-- Class E to AA (low) (sf) from BBB (high) (sf)

DBRS Morningstar also confirmed the ratings on the remaining
classes as follows:

-- Class F at BBB (low) (sf)
-- Class G at BB (low) (sf)
-- Class H at B (sf)

DBRS Morningstar changed the trend on Class H to Stable from
Negative. All other trends are Stable.

The rating upgrades reflect the collateral reduction to date, while
the rating confirmations reflect the overall stable performance of
the remaining collateral in the transaction. Since December 2020,
10 loans, with a combined balance of $141.2 million, have been
repaid. As a result, there has been total collateral reduction of
86.7% since issuance. As of the June 2021 remittance, the remaining
collateral consists of three loans, the largest of which is the
Newport Centre loan (Prospectus ID#1, 87.3% of the pool).

The Newport Centre loan is secured by a 782,000-square-foot (sf)
portion of a 1.15-million-sf regional mall located in Jersey City,
New Jersey, owned by a joint venture between Melvin Simon &
Associates and the LeFrak family, who also developed the Newport
Master Planned Community where the property is located. The
management company for Simon Property Group manages the mall. The
loan was transferred to special servicing in July 2020 when a
Coronavirus Disease (COVID-19) relief request was made by the
borrower. A loan modification was granted in September 2020 that
allowed for the deferral of principal, replacement, and leasing
reserve payments from May 2020 through to July 2020. The loan was
brought current in November 2020 and was returned to the master
servicer in January 2021.

The loan was transferred to special servicing for a second time,
however, after the loan failed to repay at its May 2021 maturity
date. The servicer reports that the borrower has requested approval
for a loan modification that would extend the maturity date for a
period of two years through to May 2023, with an additional
12-month extension option available that would extend the maturity
through May 2024. The servicer has not provided confirmation of a
modification or terms to date, but the loan was returned to the
master servicer with the June 2021 remittance, suggesting a
modification has closed. DBRS Morningstar has requested details and
the servicer's response is pending as of the date of this press
release.

Prior to the pandemic, performance had been quite stable, with the
YE2019 and YE2018 debt service coverage ratios (DSCRs) reported at
2.08 times (x) and 2.05x, respectively. Cash flow dipped slightly
in 2020 due to lower percentage rents and other income, with
occupancy holding steady at 93.2% as of February 2021. The YE2020
DSCR was reported at 1.85x, representing a 10.8% decline from
YE2019 and a 9.7% increase from the issuer's underwritten DSCR.

Although the healthy DSCR figures are encouraging, DBRS Morningstar
does note risks in the anchor mix, which includes Macy's (23.6% of
total net rentable area (NRA), expiring January 2028), Sears (19.8%
of total NRA, subject to a ground lease that expires in October
2027), JCPenney (18.5% of total NRA, expiring January 2050), Kohl's
(14.9% of total NRA, expiring January 2028), and an 11-screen AMC
Theatres (4.9% of total NRA, expiring January 2026). All of these
tenants have reported difficulties both before and during the
pandemic, with noteworthy developments including JCPenney's Chapter
11 bankruptcy filing in May 2020 and Macy's prepandemic
announcement that 125 stores would be closed in the next few years.
Although there is tenant risk at the subject, the mall has held its
value even throughout the pandemic, with the most recent appraised
value as of April 2021 being reported at $315.0 million. This
represents a 6.5% decline from the issuance value of $337.0 million
but is still well in excess of the current loan amount of $167.6
million.

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


JP MORGAN 2013-C17: Fitch Lowers Class F Certs to 'B-sf'
--------------------------------------------------------
Fitch Ratings has downgraded one class and affirmed 10 classes of
JP Morgan Chase Commercial Mortgage Securities Trust (JPMBB
2013-C17) commercial mortgage pass-through certificates series
2013-C17.

    DEBT               RATING           PRIOR
     ----              ------           -----
JPMBB 2013-C17

A-3 46640UAC6    LT  AAAsf   Affirmed   AAAsf
A-4 46640UAD4    LT  AAAsf   Affirmed   AAAsf
A-S 46640UAH5    LT  AAAsf   Affirmed   AAAsf
A-SB 46640UAE2   LT  AAAsf   Affirmed   AAAsf
B 46640UAJ1      LT  AA-sf   Affirmed   AA-sf
C 46640UAK8      LT  A-sf    Affirmed   A-sf
D 46640UAN2      LT  BBB-sf  Affirmed   BBB-sf
E 46640UAP7      LT  BBsf    Affirmed   BBsf
EC 46640UAL6     LT  A-sf    Affirmed   A-sf
F 46640UAQ5      LT  B-sf    Downgrade  Bsf
X-A 46640UAF9    LT  AAAsf   Affirmed   AAAsf

KEY RATING DRIVERS

Generally Stable Loss Expectations: The downgrade of class F
reflects the lack of stabilization of several larger Fitch Loans of
Concern which were struggling pre-pandemic. Overall there are seven
Fitch Loans of Concern (FLOCs, 22.6%), which includes one loan in
special servicing (3.7%). Performance and loss expectations for the
majority of the pool, however, remain stable.

Fitch's current ratings incorporate a base case loss of 5.6%.
Losses could reach 6.4% when factoring in additional stresses
related to the coronavirus pandemic.

The largest contributor to loss is The Aire loan (10.6%), which is
secured by a 310-unit multifamily property located on the Upper
West Side of Manhattan, near Lincoln Center. The loan has been
designated as a Fitch Loan of Concern due to a declining cash flow.
The servicer-reported NOI DSCR was 0.58 at YE 2020, compared with
0.78x at YE 2019 and 0.90x at YE 2018. A cash flow sweep was
triggered in 2017 due to the DSCR falling below the required
threshold. Per the December 2020 rent roll, occupancy had fallen to
70% a significant decline from 95% in March 2020 as the residential
rental market in New York was severely impacted by COVID-19. The
sponsor has continued to pay the loan as agreed, although the
property generates cash flow that is inadequate to service its
debt. According to servicer updates, the borrower continues to
foresee no issues in continuing to fund debt service and operating
shortfalls going forward. Fitch modeled a loss of approximately
13%.

The second largest contributor to loss is the 801 Travis loan
(3.4%), which is secured by a 220,000-sf office property located in
Houston, TX. The property has been negatively affected by the
volatile oil and gas industry. Per the March 2021 rent roll,
occupancy was 63% which remains unchanged since 2017. The servicer
reported NOI DSCR was 0.91x at YE 2020 compared with 1.08x at YE
2019. Fitch modeled a loss of approximately 37%.

The third largest contributor to loss is the Jordan Creek Town
Center loan (13.7%), which is secured by a 503,034 sf portion of a
1.1 million-sf regional mall located in West Des Moines, IA.
COVID-19 relief was requested and granted in June 2020. The mall is
anchored by Dillard's (non-collateral) and Scheels Logo
(leasehold). The largest collateral tenants are Century Theatres
(NRA 14% through 08/2024) and Barnes & Noble (NRA 6% through
01/31/2025). No other tenant occupies more than 2.6% of the NRA.
Upcoming rollover at the property includes 5.5% of the NRA in 2021,
followed by 4% in 2022, 3.2% in 2023 and 44% in 2024.

Sales have declined due to the pandemic. For the TTM March 2021
total mall sales reported at $397 psf ($366 psf excluding apple)
compared with $592 psf ($474 excluding Apple) for the TTM March
2020 period. Fitch modeled a loss of approximately 7% which
reflects a cap rate of 12% utilizing the YE 2020 cash flow.

Increased Credit Enhancement: Credit enhancement has increased
since issuance due to loan payoffs, amortization and defeasance. As
of the June 2021 distribution date, the pool's aggregate principal
balance had been reduced by 30% to $756.8 million from $1.1 billion
at issuance. There has been $8.4 million in realized losses to date
and interest shortfalls are currently affecting the non-rated class
J. One loan (2.4%) is full-term IO, and all loans in partial IO
periods expired.

Since issuance, 14 loans with a combined outstanding balance of
$210 million have paid off. Fifty loans in the pool remain.

Coronavirus Impact: Significant continued economic impact to
certain hotels and retail and multifamily properties has occurred
due to the pandemic. Uncertainty remains about the timeline for
full recovery of these assets. Loans collateralized by retail
properties and mixed use properties with a retail component account
for 12 loans (32.1% of pool). Loans secured by hotel properties
account for three loans (7.8%), while 13 loans (24.3%) are secured
by multifamily properties. Fitch's analysis applied additional
stresses to three retail loans and one hotel loan to account for
the impact of the coronavirus pandemic. These additional stresses
contributed to the Negative Outlooks on classes E and F.

RATING SENSITIVITIES

The Stable Outlooks on classes A-3 through D reflect the stable
performance of the majority of the pool and expected continued
amortization. The Negative Outlooks on classes E and F reflect
concerns over the FLOCS as well as the lingering impact of the
pandemic on the overall pool.

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

-- 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.

-- Fitch considers upgrades to the 'BBB-sf' and below-rated
    classes are unlikely, and they 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 'BBsf' 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:

-- 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 'BBB-sf' would occur if the
    performance of the FLOC continues to decline.

-- Downgrades to the classes with a Negative Outlook are possible
    should performance of the FLOCs fail to stabilize, if
    additional loans transfer to special servicing and/or losses
    be realized.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


LCCM 2021-FL2: DBRS Gives Prov. B(low) Rating on Class G Notes
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Notes to be issued by LCCM 2021-FL2 Trust (LCCM 2021-FL2):

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

All trends are Stable.

With regard to the Coronavirus Disease (COVID-19) pandemic, the
magnitude and extent of performance stress posed to global
structured finance transactions remains highly uncertain. This
considers the fiscal and monetary policy measures and statutory law
changes that have already been implemented or will be implemented
to soften the impact of the crisis on global economies. Some
regions, jurisdictions, and asset classes are, however, feeling
more immediate effects. DBRS Morningstar continues to monitor the
ongoing coronavirus pandemic and its impact on both the commercial
real estate sector and the global fixed income markets.
Accordingly, DBRS Morningstar may apply additional short-term
stresses to its rating analysis, for example by front-loading
default expectations and/or assessing the liquidity position of a
structured finance transaction with more stressful operational risk
and/or cash flow timing considerations.

The initial collateral consists of 23 floating-rate mortgage loans
or pari passu participation interests in mortgage loans secured by
27 mostly transitional assets with a cut-off balance of $607.5
million excluding approximately $125.8 million of future funding
commitments. The pool consists of nine multifamily properties
representing 31.4% of the pool balance, three office properties
with 23.3% of the pool balance, four mixed-use properties totaling
23.2% of the pool balance, three manufactured housing communities
totaling 9.2% of the pool balance, three retail properties totaling
6.0% of the pool balance, and one hotel totaling 4.9% of the pool
balance.

For the floating-rate loans, DBRS Morningstar used the one-month
Libor index, which is based on the lower of a DBRS Morningstar
stressed rate that corresponded to the remaining fully extended
term of the loans or the strike price of the interest rate cap with
the respective contractual loan spread added to determine a
stressed interest rate over the loan term. When the cut-off
balances were measured against the DBRS Morningstar As-Is Net Cash
Flow (NCF), 20 loans, totaling 94.4% of the initial pool, had a
DBRS Morningstar As-Is Debt Service Coverage Ratio (DSCR) below
1.00 times (x), a threshold indicative of default risk.
Furthermore, the DBRS Morningstar Stabilized DSCRs for 10 loans,
representing 43.9% of the initial pool balance, are below 1.00x.

All of the rated classes of the LCCM 2021-FL2 transaction have been
conveyed into a trust by Ladder Capital Corp. (Ladder Capital) to
issue corresponding classes of Secured Floating Rate Notes. All
DBRS Morningstar-rated classes will be subject to ongoing
surveillance, confirmations, upgrades, or downgrades by DBRS
Morningstar after the date of issuance. An affiliate of Ladder
Capital, an indirect wholly owned subsidiary of the Sponsor (as
retention holder), will acquire the Class F, G, and H notes,
representing the most subordinate 18% of the transaction by
principal balance.

DBRS Morningstar completed a cash flow review and cash flow
stability and structural review on 15 of the 23 loans, representing
83.0% of the pool by loan balance. Overall, the Issuer's cash flows
were generally recent, from early 2021, and reflective of recent
conditions. For the loans not subject to NCF review, DBRS
Morningstar applied NCF variances of -32.7% and -26.0% to the
Issuer's as-is and stabilized NCFs, respectively, which are based
on average sampled NCF variances.

Seven of the 23 loans, representing 33.2% of the pool are in areas
with DBRS Morningstar Market Ranks of 7 or 8, which are generally
characterized as highly dense urbanized areas that benefit from
increased liquidity driven by consistently strong investor demand,
even during times of economic stress. DBRS Morningstar Market Ranks
of 7 and 8 benefit from lower default frequencies than less dense
suburban, tertiary, and rural markets. Urban markets represented in
the deal include Los Angeles, Seattle, New York, and Miami. Six
loans, representing 23.0% of the pool balance, have collateral in
Metropolitan Statistical (MSA) Group 3, which is the best
performing group in terms of historical commercial mortgage-backed
securities (CMBS) default rates among the top 25 MSAs. MSA Group 3
has a historical default rate of 17.2%, which is 10.8 percentage
points lower than the overall CMBS historical default rate of
28.0%.

Based on the initial pool balances, the overall weighted-average
(WA) DBRS Morningstar As-Is DSCR of 0.57x and WA DBRS Morningstar
As-Is Loan-to-Value Ratio (LTV) of 81.1% generally reflect
high-leverage financing. When measured against the DBRS Morningstar
Stabilized NCF, the WA DBRS Morningstar DSCR is estimated to
improve to 1.02x, suggesting that the properties are likely to have
improved NCFs once the sponsors' business plans have been
implemented. DBRS Morningstar has analyzed the loans to a
stabilized cash flow that is, in some instances, above the in-place
cash flow. It is possible that the sponsors will not successfully
execute their business plans and that the higher stabilized cash
flow will not materialize during the loan term, particularly with
the ongoing coronavirus pandemic and its impact on the overall
economy. A sponsor's failure to execute the business plan could
result in a term default or the inability to refinance the fully
funded loan balance. DBRS Morningstar made relatively conservative
stabilization assumptions and, in each instance, considered the
business plan to be rational and the future funding amounts to be
sufficient to execute such plans. In addition, DBRS Morningstar
analyzes loss severity given default LGD based on the as-is LTV,
assuming the loan is fully funded.

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


LCM 29: S&P Assigns Prelim BB- (sf) Rating on Class E-R Notes
-------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-R, B-R, C-R, D-R, E-R, and X-R replacement notes from LCM 29
Ltd./LCM 29 LLC, a CLO originally issued in 2019 that is managed by
LCM Asset Management LLC.

The preliminary ratings are based on information as of July 12,
2021. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the July 15, 2021, refinancing date, the proceeds from the
replacement notes will be used to redeem the original notes. S&P
said, "At that time, we expect to withdraw our ratings on the
original notes and assign ratings to the replacement notes.
However, if the refinancing doesn't occur, we may affirm our
ratings on the original notes and withdraw our preliminary ratings
on the replacement notes."

Environmental, social, and governance (ESG) credit factors

S&P said, "Our rating analysis considers a transaction's potential
exposure to ESG credit factors. We regard this transaction's
exposure as being broadly in line with our benchmark for the sector
(see "ESG Industry Report Card: Collateralized Loan Obligations,"
published March 31, 2021). For CLOs, we view the exposure to
environmental credit factors as below average, to social credit
factors as below average, and to governance credit factors as
average, primarily due to the diversity of the assets within the
sector. For this transaction, the documents prohibit assets from
being related to the controversial weapons industry. Accordingly,
since there are no material differences compared to our ESG
benchmark for the sector, we made no specific adjustments in our
rating analysis to account for any ESG-related risks or
opportunities."

The replacement notes will be issued via a proposed supplemental
indenture, which outlines the terms of the replacement notes.
According to the proposed supplemental indenture:

-- The non-call period will be extended to July 2022; and

-- An ESG restriction will be added to exclude manufacturers of
controversial weapons.

  Replacement And Original Note Issuances

  Replacement notes

  Class X-R, $2.0 million: Three-month LIBOR + 0.80%
  Class A-R, $260.0 million: Three-month LIBOR + 1.07%
  Class B-R, $44.0 million: Three-month LIBOR + 1.60%
  Class C-R, $24.0 million: Three-month LIBOR + 2.20%
  Class D-R, $24.0 million: Three-month LIBOR + 3.40%
  Class E-R, $13.6 million: Three-month LIBOR + 6.83%

  Original notes

  Class X, $1.3 million: Three-month LIBOR + 0.75 %
  Class A-1, $240.0 million: Three-month LIBOR + 1.33%
  Class A-2, $20.0 million: Three-month LIBOR + 1.65%
  Class B, $44.0 million: Three-month LIBOR + 1.90%
  Class C, $24.0 million: Three-month LIBOR + 2.60%
  Class D, $24.0 million: Three-month LIBOR + 3.85%
  Class E, $13.6 million: Three-month LIBOR + 6.90%
  Subordinated notes, $36.6 million: Not applicable

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis (and other qualitative factors, as applicable)
demonstrated, in our view, that the outstanding rated classes all
have adequate credit enhancement available at the rating levels
associated with the rating actions.

"We will continue to review whether, in our view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Preliminary Ratings Assigned

  LCM 29 Ltd./LCM 29 LLC

  Class X-R, $2.0 million: AAA (sf)
  Class A-R, $260.0 million: AAA (sf)
  Class B-R, $44.0 million: AA (sf)
  Class C-R (deferrable), $24.0 million: A (sf)
  Class D-R (deferrable), $24.0 million: BBB- (sf)
  Class E-R (deferrable), $13.6 million: BB- (sf)
  Subordinated notes, $36.6 million: Not rated


MELLO MORTGAGE 2021-MTG3: DBRS Finalizes B Rating on Cl. B5 Certs
-----------------------------------------------------------------
DBRS, Inc. finalized the following provisional ratings on the
Mortgage Pass-Through Certificates, Series 2021-MTG3 issued by
Mello Mortgage Capital Acceptance 2021-MTG3 (MELLO 2021-MTG3):

-- $276.3 million Class A1 at AAA (sf)
-- $276.3 million Class A2 at AAA (sf)
-- $240.9 million Class A3 at AAA (sf)
-- $240.9 million Class A4 at AAA (sf)
-- $35.4 million Class A5 at AAA (sf)
-- $35.4 million Class A6 at AAA (sf)
-- $144.5 million Class A7 at AAA (sf)
-- $144.5 million Class A8 at AAA (sf)
-- $180.7 million Class A9 at AAA (sf)
-- $180.7 million Class A10 at AAA (sf)
-- $35.4 million Class A11 at AAA (sf)
-- $35.4 million Class A11X at AAA (sf)
-- $192.7 million Class A12 at AAA (sf)
-- $192.7 million Class A13 at AAA (sf)
-- $36.1 million Class A14 at AAA (sf)
-- $36.1 million Class A15 at AAA (sf)
-- $12.0 million Class A16 at AAA (sf)
-- $12.0 million Class A17 at AAA (sf)
-- $48.2 million Class A18 at AAA (sf)
-- $48.2 million Class A19 at AAA (sf)
-- $48.2 million Class A20 at AAA (sf)
-- $48.2 million Class A21 at AAA (sf)
-- $60.2 million Class A22 at AAA (sf)
-- $60.2 million Class A23 at AAA (sf)
-- $96.4 million Class A24 at AAA (sf)
-- $96.4 million Class A25 at AAA (sf)
-- $29.3 million Class A26 at AAA (sf)
-- $29.3 million Class A27 at AAA (sf)
-- $29.3 million Class A28 at AAA (sf)
-- $305.5 million Class A29 at AAA (sf)
-- $264.3 million Class A30 at AAA (sf)
-- $305.5 million Class A31 at AAA (sf)
-- $305.5 million Class AX1 at AAA (sf)
-- $240.9 million Class AX4 at AAA (sf)
-- $35.4 million Class AX5 at AAA (sf)
-- $35.4 million Class AX6 at AAA (sf)
-- $144.5 million Class AX8 at AAA (sf)
-- $180.7 million Class AX10 at AAA (sf)
-- $192.7 million Class AX13 at AAA (sf)
-- $36.1 million Class AX15 at AAA (sf)
-- $12.0 million Class AX17 at AAA (sf)
-- $48.2 million Class AX19 at AAA (sf)
-- $48.2 million Class AX21 at AAA (sf)
-- $96.4 million Class AX25 at AAA (sf)
-- $29.3 million Class AX26 at AAA (sf)
-- $29.3 million Class AX27 at AAA (sf)
-- $29.3 million Class AX28 at AAA (sf)
-- $264.3 million Class AX30 at AAA (sf)
-- $7.2 million Class B1 at AA (high) (sf)
-- $7.2 million Class B1A at AA (high) (sf)
-- $7.2 million Class BX1 at AA (high) (sf)
-- $4.2 million Class B2 at A (high) (sf)
-- $4.2 million Class B2A at A (high) (sf)
-- $4.2 million Class BX2 at A (high) (sf)
-- $3.9 million Class B3 at BBB (high) (sf)
-- $2.6 million Class B4 at BB (sf)
-- $488.0 thousand Class B5 at B (sf)

Classes AX1, AX4, AX5, AX6, AX8, AX10, A11X, AX13, AX15, AX17,
AX19, AX21, AX25, AX26, AX27, AX28, AX30, BX1, and BX2 are
interest-only certificates. The class balances represent notional
amounts.

Classes A1, A2, A3, A4, A5, A6, A7, A9, A10, A12, A13, A14, A16,
A18, A19, A20, A22, A23, A24, A25, A26, A27, A29, A30, A31, AX4,
AX5, AX6, AX10, AX13, AX19, AX25, AX26, AX30, B1, and B2 are
exchangeable certificates. These classes can be exchanged for
combinations of exchange certificates.

Classes A1, A2, A3, A4, A5, A6, A7, A8, A9, A10, A11, A12, A13,
A14, A15, A16, A17, A18, A19, A20, A21, A22, A23, A24, and A25 are
super-senior certificates. These classes benefit from additional
protection from the senior support certificates (Classes A26, A27,
and A28) with respect to loss allocation.

The AAA (sf) ratings on the Certificates reflect 6.00% of credit
enhancement provided by subordinated certificates. The AA (high)
(sf), A (high) (sf), BBB (high) (sf), BB (sf), and B (sf) ratings
reflect 3.80%, 2.50%, 1.30%, 0.50%, and 0.35% of credit
enhancement, respectively.

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

This securitization is a portfolio of first-lien fixed-rate prime
conventional residential mortgages funded by the issuance of the
Certificates. The Certificates are backed by 508 loans with a total
principal balance of $325,006,710 as of the Cut-Off Date (June 1,
2021).

MELLO 2021-MTG3 is the fifth prime securitization issued from the
MELLO shelf MTG series and comprises fully amortizing fixed-rate
mortgages with original terms to maturity of primarily 30 years.
The first two MELLO deals were issued in 2018 and consisted of a
combination of nonagency and agency-eligible prime collateral.
Unlike the first securitizations from 2018, all loans in the MELLO
2021-MTG3 pool are conforming, high-balance mortgage loans that
were underwritten by loanDepot.com, LLC (loanDepot) using an
automated underwriting system designated by Fannie Mae or Freddie
Mac and were eligible for purchase by such agencies. In addition,
the pool contains a large concentration of loans (35.5%) that were
granted appraisal waivers by the agencies. In its analysis, DBRS
Morningstar applied property value haircuts to such loans, which
increased the expected losses on the collateral.

loanDepot is the Originator, Seller, and Servicing Administrator of
the mortgage loans and Artemis Management LLC is the Sponsor of the
transaction. LD Holdings Group LLC, the parent company of the
Sponsor and Seller, will serve as Guarantor with respect to the
remedy obligations of the Seller. LDPMF LLC, a subsidiary of the
Sponsor and an affiliate of the Seller, will act as Depositor of
the transaction.

Cenlar FSB will act as the Servicer. Wells Fargo Bank, N.A. (rated
AA with a Negative trend by DBRS Morningstar) will act as the
Master Servicer and Securities Administrator. Wilmington Savings
Fund Society, FSB will serve as Trustee, and Deutsche Bank National
Trust Company will serve as Custodian.

The transaction employs a senior-subordinate, shifting-interest
cash flow structure that is enhanced from a pre-crisis structure.

As of the Cut-Off Date, no borrower within the pool has entered
into a Coronavirus Disease (COVID-19)-related forbearance plan with
a servicer. In the event a borrower requests or enters into a
forbearance plan after the Closing Date, such loan will remain in
the pool.

Coronavirus Pandemic Impact

The coronavirus pandemic and the resulting isolation measures have
caused an immediate economic contraction, leading to sharp
increases in unemployment rates and income reductions for many
consumers. Shortly after the onset of the pandemic, DBRS
Morningstar saw an increase in delinquencies for many residential
mortgage-backed securities (RMBS) asset classes.

Such mortgage delinquencies were mostly in the form of
forbearances, which are generally short-term periods of payment
relief that may perform very differently from traditional
delinquencies. At the onset of the pandemic, the option to forebear
mortgage payments was widely available, driving forbearances to an
elevated level. When the dust settled, loans with
coronavirus-induced forbearance in 2020 performed better than
expected, thanks to government aid, low loan-to-value ratios, and
acceptable underwriting in the mortgage market in general. Across
nearly all RMBS asset classes in recent months, delinquencies have
been gradually trending downwards as forbearance periods come to an
end for many borrowers.

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


MORGAN STANLEY 2021-L6: Fitch Gives Final B- Rating on G-RR Certs
-----------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to
Morgan Stanley Capital I Trust 2021-L6, commercial mortgage
pass-through certificates, series 2021-L6 as follows:

-- $20,900,000 class A-1 'AAAsf'; Outlook Stable;

-- $117,800,000 class A-2 'AAAsf'; Outlook Stable;

-- $161,560,000a class A-3 'AAAsf'; Outlook Stable;

-- $0a class A-3-1 'AAAsf'; Outlook Stable;

-- $0ab class A-3-X1 'AAAsf'; Outlook Stable;

-- $0a class A-3-2 'AAAsf'; Outlook Stable;

-- $0ab class A-3-X2 'AAAsf'; Outlook Stable;

-- $26,900,000 class A-SB 'AAAsf'; Outlook Stable;

-- $208,568,000a class A-4 'AAAsf'; Outlook Stable;

-- $0a class A-4-1 'AAAsf'; Outlook Stable;

-- $0ab class A-4-X1 'AAAsf'; Outlook Stable;

-- $0a class A-4-2 'AAAsf'; Outlook Stable;

-- $0ab class A-4-X2 'AAAsf'; Outlook Stable;

-- $535,728,000b class X-A 'AAAsf'; Outlook Stable;

-- $149,238,000be class X-B 'AA-sf'; Outlook Stable;

-- $68,879,000a class A-S 'AAAsf'; Outlook Stable;

-- $0a class A-S-1 'AAAsf'; Outlook Stable;

-- $0ab class A-S-X1 'AAAsf'; Outlook Stable;

-- $0a class A-S-2 'AAAsf'; Outlook Stable;

-- $0ab class A-S-X2 'AAAsf'; Outlook Stable;

-- $49,746,000a class B 'AA-sf'; Outlook Stable;

-- $0a class B-1 'AA-sf'; Outlook Stable;

-- $0ab class B-X1 'AA-sf'; Outlook Stable;

-- $0a class B-2 'AA-sf'; Outlook Stable;

-- $0ab class B-X2 'AA-sf'; Outlook Stable;

-- $30,613,000a class C 'A-sf'; Outlook Stable;

-- $0a class C-1 'A-sf'; Outlook Stable;

-- $0ab class C-X1 'A-sf'; Outlook Stable;

-- $0a class C-2 'A-sf'; Outlook Stable;

-- $0ab class C-X2 'A-sf'; Outlook Stable;

-- $33,483,000bc class X-D 'BBB-sf'; Outlook Stable;

-- $15,307,000bc class X-F 'BB-sf'; Outlook Stable;

-- $19,134,000c class D 'BBBsf'; Outlook Stable;

-- $14,349,000c class E 'BBB-sf'; Outlook Stable;

-- $15,307,000c class F 'BB-sf'; Outlook Stable;

-- $7,653,000cd class G-RR 'B-sf'; Outlook Stable.

The following class is not rated by Fitch:

-- $23,917,112cd class H-RR.

(a) Exchangeable Certificates. The class A-3, A-4, A-S, B and C
certificates are exchangeable certificates. Each class of
exchangeable certificates may be exchanged for the corresponding
classes of exchangeable certificates and vice versa. The dollar
denomination of each of the received classes of certificates must
be equal to the dollar denomination of each of the corresponding
classes of exchangeable certificates. Class A-3 may be surrendered
(or received) for the received (or surrendered) classes A-3-1 and
A-3-X1. Class A-3 may be surrendered (or received) for the received
(or surrendered) classes A-3-2 and A-3-X2. Class A-4 may be
surrendered (or received) for the received (or surrendered) classes
A-4-1 and A-4-X1. Class A-4 may be surrendered (or received) for
the received (or surrendered) classes A-4-2 and A-4-X2. Class A-S
may be surrendered (or received) for the received (or surrendered)
classes A-S-1 and A-S-X1. Class A-S may be surrendered (or
received) for the received (or surrendered) classes A-S-2 and
A-S-X2. Class B may be surrendered (or received) for the received
(or surrendered) classes B-1 and B-X1. Class B may be surrendered
(or received) for the received (or surrendered) classes B-2 and
B-X2. Class C may be surrendered (or received) for the received (or
surrendered) classes C-1 and C-X1. Class C may be surrendered (or
received) for the received (or surrendered) classes C-2 and C-X2.

(b) Notional amount and interest only.

(c) Privately placed and pursuant to Rule 144A

(d) Horizontal Residual Interest Component of the L-Shaped Risk
Retention

(e) The rating of class X-B changed from 'A- sf' to 'AA-sf' due to
class C being a WAC class.

The ratings are based on information provided by the issuer as of
July 13, 2021.

TRANSACTION SUMMARY

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 43 loans secured by 60
commercial properties having an aggregate principal balance of
$765,326,113 as of the cut-off date. The loans were contributed to
the trust by Morgan Stanley Mortgage Capital Holdings LLC, Argentic
Real Estate Finance LLC, Starwood Mortgage Capital LLC, and Bank of
America, National Association. The Master Servicer is expected to
be Midland Loan Services, Inc. and the Special Servicer is expected
to be Argentic Services Company LP.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 30.9% of the properties
by balance, cash flow analyses of 83.3% of the pool and asset
summary reviews on 100% of the pool.

Coronavirus Impact: The ongoing containment effort related to the
coronavirus pandemic may have an adverse impact on near-term
revenue (i.e. bad debt expense, rent relief) and operating expenses
(i.e. sanitation costs) for some properties in the pool.

Per the offering documents, all the loans are current and are not
subject to any ongoing forbearance requests.

KEY RATING DRIVERS

Average Fitch Leverage Compared with Recent Transactions: The pool
has average leverage compared with other recent multiborrower
transactions rated by Fitch. The pool's trust Fitch LTV of 100.2%
is worse than the 2020 average of 99.6%, but better than the 2021
YTD average of 101.6%. Additionally, the pool's Fitch debt service
coverage ratio (DSCR) of 1.49x is better than the 2020 and 2021 YTD
averages of 1.32x and 1.39x, respectively. Excluding the credit
opinion loan (9.8%), Fitch trust DSCR and LTV are 1.43x and 103.4%,
respectively.

Above-Average Amortization. Based on the scheduled balances at
maturity, the pool will pay down by 6.3%, which is above the 2020
and 2021 YTD averages of 5.3% and 4.5%, respectively. Twenty-two
loans (62.6%) are full interest-only loans, which is lower than the
2020 and 2021 YTD averages of 67.7% and 72.2%, respectively. Eleven
loans (20.3%) are partial interest-only loans, which is slightly
higher than the 2020 and 2021 YTD averages of 20.0% and 17.6%,
respectively.

Investment-Grade Credit Opinion Loans: 300 East 34th Street,
representing 9.8% of the pool, is the only loan in the pool that
received an investment-grade credit opinion. This is down from the
average of 24.5% for 2020 transactions and 15.0% for 2021 YTD
transactions. 300 East 34th Street received a standalone credit
opinion of 'BBB-sf'.

Property Type Exposure. Loans secured by retail properties
represent 30.0% of the pool by balance including three of the top
10 and six of the top 20. The total retail concentration is much
larger than the 2020 average of 16.3% and the 2021 YTD average of
17.0%. Loans secured by office properties represent 27.7% of the
pool by balance, below the 2020 and YTD 2021 averages of 41.2% and
40.0%, respectively. Loans secured by multifamily properties
represent 23.4% of the pool, higher than the 2020 and 2021 YTD
averages of 16.3% and 14.7%. The pool does not have any loans
secured by hotel properties.

Slightly Higher Concentrated Pool: The pool exhibits an
above-average loan concentration index (LCI) of 422, which is
greater than the YTD 2021 average of 405 but lower than the 2020
average of 440. The 10 largest loans represent 55.4% of the pool by
cutoff balance, which is greater than the YTD 2021 average of 53.5%
but lower than the 2020 average of 56.8%. For this transaction,
losses estimated by Fitch's deterministic test at 'AAAsf' exceeded
the base model loss estimate.

RATING SENSITIVITIES

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

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

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

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

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

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

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

-- 10% NCF Decline: 'AAAsf'/'A+sf'/'BBB+sf'/'BBB-sf'/'BBB
    sf'/'BB-sf'/'B-sf'

-- 20% NCF Decline: 'AA-sf'/'BBB+sf'/'BBB-sf'/'BB+sf'/'Bsf
    '/'CCCsf'/'CCCsf'

-- 30% NCF Decline: 'A-sf'/'BBB-sf'/'BB
    sf'/'CCCsf'/'CCCsf'/'CCCsf'/'CCCsf

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 Ernst & Young LLP. The third-party due diligence
described in Form 15E focused on a comparison and re-computation of
certain characteristics with respect to each of the mortgage loans.
Fitch considered this information in its analysis and it did not
have an effect on Fitch's analysis or conclusions.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


NEWSTAR FAIRFIELD: Fitch Affirms BB- Rating on Class D-N Notes
--------------------------------------------------------------
Fitch Ratings has affirmed 12 classes of notes issued by five
middle market (MM) collateralized loan obligations (CLOs) managed
by First Eagle Private Credit, LLC and First Eagle Alternative
Credit EU, LLC (collectively, First Eagle). In addition, Fitch
revised the Rating Outlooks to Stable from Negative for the class
B-1-N, B-2-N, C-N and D-N notes in Newstar Fairfield Fund CLO, Ltd.
(F/K/A Fifth Street SLF II, Ltd.) (NewStar Fairfield). All other
tranches remain on Stable Rating Outlook.

    DEBT                 RATING           PRIOR
    ----                 ------           -----
First Eagle Commercial Loan Funding 2016-1 LLC

A-1a-R 32010LAA2   LT  AAAsf   Affirmed   AAAsf
A-1b-R 32010LAN4   LT  AAAsf   Affirmed   AAAsf

NewStar Arlington Senior Loan Program LLC

A-R 65251PAY9      LT  AAAsf   Affirmed   AAAsf

First Eagle Berkeley Fund CLO LLC (fka NewStar Berkeley Fund CLO
LLC)

A-R 65251XAN6      LT  AAAsf   Affirmed   AAAsf

Newstar Fairfield Fund CLO, Ltd. (F/K/A Fifth Street SLF II, Ltd.)

A-1-N 65252BAA1    LT  AAAsf   Affirmed   AAAsf
A-2-N 65252BAC7    LT  AAsf    Affirmed   AAsf
B-1-N 65252BAE3    LT  A-sf    Affirmed   A-sf
B-2-N 65252BAJ2    LT  A-sf    Affirmed   A-sf
C-N 65252BAG8      LT  BBB-sf  Affirmed   BBB-sf
D-N 65252CAA9      LT  BB-sf   Affirmed   BB-sf

Lake Shore MM CLO II, Ltd. (f/k/a THL Credit Lake Shore MM CLO II,
Ltd.)

A-1 87249XAA3      LT  AAAsf   Affirmed   AAAsf
A-2 87249XAC9      LT  AAAsf   Affirmed   AAAsf

TRANSACTION SUMMARY

The five CLOs included in this review are middle market (MM) CLOs
backed by portfolios of primarily senior secured loans and actively
managed by First Eagle. The CLOs span various vintages, ranging
from 2016 to 2019. First Eagle Berkeley Fund CLO LLC (First Eagle
Berkeley) exited its reinvestment period in October 2020 and all
other CLOs remain in their respective reinvestment periods.

KEY RATING DRIVERS

Stable Credit Quality, Asset Security and Portfolio Composition

The rating actions reflect the stable collateral performance of the
portfolios since the transactions' last reviews: Lake Shore MM CLO
II was last reviewed in November 2020, while all other transactions
were last reviewed in September 2020. Exposure to defaulted assets
averaged 1.9% of the current portfolios, down from an average 4.5%
at the last reviews. The average Fitch-weighted average rating
factor (WARF) of performing portfolios was relatively unchanged at
42.5 (B-/CCC) and the average portfolio exposure to assets
considered 'CCC' rating category and below (excluding defaults)
increased slightly to 22.5% from the average of 22.0%. In addition,
issuers with a Fitch-derived rating (floor of CCC-) with a Negative
Rating Outlook decreased to average 8% of portfolios from 18%.

The portfolios also have strong recovery prospects, with senior
secured loans comprising 96% of the portfolios on average. 'AAAsf'
recovery assumptions currently stand at an average 36.2%, compared
to an average of 34.0% at their last reviews. Obligor counts for
the portfolios average 123 obligors and the largest ten exposures
average 16.5% of portfolios.

Asset credit quality, asset security, and portfolio composition are
captured in rating default rate (RDR), rating recovery rate (RRR),
and rating loss rate (RLR) produced by Fitch's Portfolio Credit
Model (PCM). For First Eagle Berkeley, which exited its
reinvestment period, credit enhancement (CE) levels for the class
A-R notes exceed the 'AAAsf' RLR.

For deals in their reinvestment periods, the PCM RLRs from current
portfolios were compared to the RLRs corresponding to the original
Fitch Stressed Portfolio (FSP) at the initial rating assignment. In
addition, Fitch considered cash flow modelling results for NewStar
Fairfield whose classes B-1-N, B-2-N, C-N and D-N notes were
assigned Rating Outlook Negative at last review.

Cash Flow Analysis

Fitch conducted an updated cash flow analysis of NewStar Fairfield,
applied across all scenarios outlined in Fitch's CLOs and Corporate
CDOs Rating Criteria.

The results of the cash flow analysis for the current portfolio
improved from the last review, with model-implied ratings (MIR) in
line with the current ratings of the class A-1-N and D-N notes, one
notch higher for the class A-2-N notes and two notches higher for
each of the class B-1-N, B-2-N and C-N notes.

Fitch did not upgrade the notes to their respective MIRs because
the CLO remains in its reinvestment period until April 2023, which
allows the manager to change portfolio composition. As a result,
Fitch affirmed all classes of notes in NewStar Fairfield with
Stable Rating Outlooks, as well as all other rated notes from the
other CLOs included in this review. The Stable Rating Outlooks
reflect Fitch's expectation that the classes have sufficient levels
of credit protection to withstand potential deterioration in the
credit quality of the portfolios in stress scenarios commensurate
with such classes' rating.

RATING SENSITIVITIES

Fitch conducted rating sensitivity analysis on the closing date of
each CLO, incorporating increased levels of defaults and reduced
levels of recovery rates, among other sensitivities, as defined in
its CLOs and Corporate CDOs Rating Criteria. For more information
on Fitch's Stressed Portfolio and initial model-implied rating
sensitivities, please refer to the presale/new issuance report of
each transaction.

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

-- For NewStar Fairfield, a 25% reduction of the mean default
    rate across all ratings and a 25% increase of the recovery
    rate at all rating levels, would lead to an upgrade of up to
    two notches for the class A-2-N, B-1-N and B-2-N notes and
    five notches for the class C-N notes and D-N notes, based on
    the model-implied ratings.

-- An upgrade scenario would not be applicable to the class A-1-N
    notes in NewStar Fairfield, as well as the rated notes in the
    four other CLOs in this review since they are already rated at
    the highest rating level (AAAsf).

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

-- Downgrades may occur if realized and projected losses in the
    respective portfolios are higher than those assumed at closing
    in the Fitch Stressed Portfolio and that are not offset by the
    increase in the CLO notes' CE levels.

-- For NewStar Fairfield, a 25% increase of the mean default rate
    across all ratings and a 25% decrease of the recovery rate at
    all rating levels would lead to a downgrade of one notch for
    the class A-1-N, B-1-N and B-2N notes, three notches for the
    A-2-N notes, four notches for the class C-N notes and more
    than two rating categories for the class D-N notes based on
    the model-implied ratings.

BEST/WORST CASE RATING SCENARIO

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

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

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

DATA ADEQUACY

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other nationally
recognized statistical rating organizations and/or European
securities and markets authority-registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk-presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


OAKTREE CLO 2021-1: S&P Assigns B- (sf) Rating on Class F Notes
---------------------------------------------------------------
S&P Global Ratings assigned its ratings to Oaktree CLO 2021-1
Ltd./Oaktree CLO 2021-1 LLC's floating-rate notes.

The note issuance is a CLO securitization governed by investment
criteria and backed primarily by broadly syndicated
speculative-grade (rated 'BB+' or lower) senior secured term loans.
The transaction is managed by Oaktree Capital Management L.P.

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

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

  Ratings Assigned

  Oaktree CLO 2021-1 Ltd./Oaktree CLO 2021-1 LLC

  Class A-1, $252.00 million: AAA (sf)
  Class A-2, $8.00 million: AAA (sf)
  Class B, $44.00 million: AA (sf)
  Class C (deferrable), $24.00 million: A (sf)
  Class D (deferrable), $24.00 million: BBB- (sf)
  Class E (deferrable), $15.00 million: BB- (sf)
  Class F (deferrable), $5.00 million: B- (sf)
  Subordinated notes, $35.30 million: Not rated



OCEANVIEW MORTGAGE 2021-3: Moody's Gives (P)B3 Rating to B-5 Certs
------------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to
fifty-six classes of residential mortgage-backed securities issued
by Oceanview Mortgage Trust (OCMT) 2021-3. The ratings range from
(P)Aaa (sf) to (P)B3 (sf).

Oceanview Asset Selector, LLC is the sponsor of OCMT 2021-3, a
third securitization of performing prime jumbo mortgage loans
backed by 386 first lien, fully amortizing, fixed-rate qualified
mortgage (QM) loans, with an aggregate unpaid principal balance
(UPB) of $351,439,638. The transaction benefits from a collateral
pool that is of high credit quality, and is further supported by an
unambiguous R&W framework, 100% third-party review (TPR) and a
shifting interest structure that incorporates a subordination
floor. 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 seller, Oceanview Acquisitions I, LLC (also the servicing
administrator), indirectly acquired the mortgage loans from various
third-party sellers through one or more affiliates of the seller.
Both the seller and the sponsor are wholly-owned subsidiaries of
Oceanview U.S. Holdings Corp. Community Loan Servicing, LLC (CLS)
(f/k/a Bayview Loan Servicing, LLC) will service 100% of the
mortgage loans. There is no master servicer in this transaction.
The servicing administrator will generally be required to fund
principal and interest (P&I) advances and servicing advances unless
such advances are deemed non-recoverable.

Three TPR firms verified the accuracy of the loan level
information. The firms conducted detailed credit, property
valuation, data accuracy and compliance reviews on 100% of the
mortgage loans in the collateral pool.

Transaction credit strengths include the high credit quality of the
collateral pool, the strong TPR results for credit, compliance and
valuations, and the unambiguous R&W framework. Transaction credit
weaknesses include having no master servicer to oversee the primary
servicer, unlike typical prime jumbo transactions Moody's have
rated.

Moody's analyzed the underlying mortgage loans using Moody's
Individual Loan Analysis (MILAN) model. Moody's also compared the
collateral pool to other prime jumbo securitizations and adjusted
Moody's expected losses based on qualitative attributes, including
the financial strength of the R&W provider and TPR results.

The complete rating action is as follows.

Issuer: Oceanview Mortgage Trust 2021-3

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)Aaa (sf)

Cl. A-18, Assigned (P)Aaa (sf)

Cl. A-19, Assigned (P)Aaa (sf)

Cl. A-20, Assigned (P)Aaa (sf)

Cl. A-21, Assigned (P)Aaa (sf)

Cl. A-22, Assigned (P)Aaa (sf)

Cl. A-23, Assigned (P)Aaa (sf)

Cl. A-24, Assigned (P)Aaa (sf)

Cl. A-25, Assigned (P)Aaa (sf)

Cl. A-IO1*, Assigned (P)Aaa (sf)

Cl. A-IO2*, Assigned (P)Aaa (sf)

Cl. A-IO3*, Assigned (P)Aaa (sf)

Cl. A-IO4*, Assigned (P)Aaa (sf)

Cl. A-IO5*, Assigned (P)Aaa (sf)

Cl. A-IO6*, Assigned (P)Aaa (sf)

Cl. A-IO7*, Assigned (P)Aaa (sf)

Cl. A-IO8*, Assigned (P)Aaa (sf)

Cl. A-IO9*, Assigned (P)Aaa (sf)

Cl. A-IO10*, Assigned (P)Aaa (sf)

Cl. A-IO11*, Assigned (P)Aaa (sf)

Cl. A-IO12*, Assigned (P)Aaa (sf)

Cl. A-IO13*, Assigned (P)Aaa (sf)

Cl. A-IO14*, Assigned (P)Aaa (sf)

Cl. A-IO15*, Assigned (P)Aaa (sf)

Cl. A-IO16*, Assigned (P)Aaa (sf)

Cl. A-IO17*, Assigned (P)Aaa (sf)

Cl. A-IO18*, Assigned (P)Aaa (sf)

Cl. A-IO19*, Assigned (P)Aaa (sf)

Cl. A-IO20*, Assigned (P)Aaa (sf)

Cl. A-IO21*, Assigned (P)Aaa (sf)

Cl. A-IO22*, Assigned (P)Aaa (sf)

Cl. A-IO23*, Assigned (P)Aaa (sf)

Cl. A-IO24*, Assigned (P)Aaa (sf)

Cl. A-IO25*, Assigned (P)Aaa (sf)

Cl. A-IO26*, Assigned (P)Aaa (sf)

Cl. B-1, Assigned (P)Aa3 (sf)

Cl. B-2, Assigned (P)A3 (sf)

Cl. B-3, Assigned (P)Baa3 (sf)

Cl. B-4, Assigned (P)Ba3 (sf)

Cl. B-5, Assigned (P)B3 (sf)

*Reflects Interest-Only Classes

RATINGS RATIONALE

Summary credit analysis and rating rationale

Moody's expected loss for this pool in a baseline scenario-mean is
0.34%, in a baseline scenario-median is 0.20%, and reaches 2.77% at
stress level consistent with Moody's Aaa rating.

The action reflects the coronavirus pandemic's residual impact on
the ongoing performance of RMBS as the US economy continues on the
path toward normalization. Economic activity will continue to
strengthen in 2021 because of several factors, including the
rollout of vaccines, growing household consumption and an
accommodative central bank policy. However, specific sectors and
individual businesses will remain weakened by extended pandemic
related restrictions. Moody's regard the coronavirus outbreak as a
social risk under its ESG framework, given the substantial
implications for public health and safety.

Moody's increased its model-derived median expected losses by 10%
(6.75% for the mean) and Moody's Aaa loss by 2.5% to reflect the
likely performance deterioration resulting from the slowdown in US
economic activity due to the coronavirus outbreak. These
adjustments are lower than the 15% median expected loss and 5% Aaa
loss adjustments Moody's made on pools from deals issued after the
onset of the pandemic until February 2021. Moody's reduced
adjustments reflect the fact that the loan pool in this deal does
not contain any loans to borrowers who are not currently making
payments. For newly originated loans, post-COVID underwriting takes
into account the impact of the pandemic on a borrower's ability to
repay the mortgage. For seasoned loans, as time passes, the
likelihood that borrowers who have continued to make payments
throughout the pandemic will now become non-cash flowing due to
COVID-19 continues to decline.

Moody's base its ratings on the certificates on the credit quality
of the mortgage loans, the structural features of the transaction,
Moody's assessments of the origination quality and servicing
arrangement, the strength of the TPR and the R&W framework of the
transaction.

Collateral Description

The pool characteristics are based on the July 1, 2021 cut-off
tape. This transaction consists of 386 first lien, fully
amortizing, fixed-rate QM loans, all of which have original terms
to maturity of 20, 25 or 30 years, with an aggregate unpaid
principal balance of $351,439,638. All of the mortgage loans are
secured by first liens on single-family residential properties,
planned unit developments and condominiums. The mortgage loans are
approximately 4 months seasoned and are backed by full
documentation.

Geographic concentration is relatively low where the three largest
states in the transaction, California, Virginia and Texas account
for 22.6%, 10.3%, and 9.8%, by UPB, respectively. Overall, the
credit quality of the mortgage loans backing this transaction is
similar to that of transactions issued by other prime issuers. The
WA original FICO for the pool is 782 and the WA CLTV is 67.9%.

None of the mortgage loans as of the cut-off date have an original
principal balance that conformed to the guidelines of Fannie Mae
and Freddie Mac at the time of origination, including mortgage
loans with original loan amounts meeting the high-cost area loan
limits established by the Federal Housing Finance Agency and were
eligible to be purchased by Fannie Mae or Freddie Mac. As of the
cut-off date, all of the mortgage loans were contractually current
under the MBA method with respect to payments of P&I.

As of the cut-off date, none of the borrowers of the mortgage loans
are currently subject to a forbearance plan or are in the process
of being subject to a forbearance plan, including as a result of
COVID-19. In the event a borrower enters into a forbearance plan,
including as a result of COVID-19, after the cut-off date, but
prior to the closing date, such mortgage loan will be removed from
the pool.

Overall, the credit quality of the mortgage loans backing this
transaction is similar to transactions issued by other prime
issuers.

Origination Quality

Oceanview Acquisitions I, LLC is the seller, servicing
administrator and R&W provider for this securitization and is a
wholly owned subsidiary of Oceanview Holdings Ltd. (together with
its affiliates and subsidiaries Oceanview). Oceanview is a wholly
owned subsidiary of Bayview Opportunity V Oceanview L.P., a pooled
investment vehicle managed by Bayview Asset Management (Bayview or
BAM).

The seller does not originate residential mortgage loans or fund
the origination of residential mortgage loans. Instead, the seller
acquired the mortgage loans directly from Bayview Acquisitions LLC,
an affiliate of the seller (affiliated loan purchaser), which in
turn acquired the mortgage loans directly from third parties. The
affiliated loan purchaser maintains eligibility criteria for use in
the process of acquiring third-party originated loans and provides
these criteria to third parties that sell mortgage loans to the
affiliated loan purchaser to enable those third parties to
determine whether mortgage loans they consider selling to the
affiliated loan purchaser will meet such criteria.

For this transaction, the acquisition criteria includes the
affiliated loan purchaser's standard prime jumbo program. The
mortgage loans acquired under this program do not meet the
eligibility standards for purchase by Fannie Mae or Freddie Mac
primarily due to loan size. This program is designed to target
mortgagors with outstanding credit and reserves that are seeking a
mortgage loan with flexible underwriting guidelines. All mortgage
loans originated under this program are eligible for safe harbor
protection under the ATR rules and a QM designation is in the loan
file.

Oceanview is managed by a seasoned group of mortgage veterans with
industry tenure that averages over two decades. BAM is a fully
integrated investment platform focused on investments in mortgage
and consumer- related credit. Overall, Oceanview's non-agency
originations team benefits from a connection to other parts of the
Bayview organization. For example, along with CLS, Bayview has a
full suite of originations capabilities including sales,
processing, underwriting, closing and post-closing, capital
markets, and outsourcing. Overall, the same functional teams that
drive BAM's investment processes are resources for Oceanview.
Oceanview utilizes its full time employees (FTEs) in concert with
dedicated FTEs from affiliated BAM entities. This operating
leverage is achieved vis-a-vis a fulfillment services agreement.

However, because the non-agency program offered by Oceanview has
been established only recently, there is no available performance
information and more time is needed to assess Oceanview's ability
to consistently produce high-quality mortgage loans.

Servicing Arrangement

Moody's assess the overall servicing arrangement for this pool as
adequate, given the ability, scale and experience of CLS as a
servicer. However, compared to other prime jumbo transactions which
typically have a master servicer, servicer oversight for this
transaction is relatively weaker. While third-party reviews of CLS'
servicing operations will be conducted periodically by the GSEs,
the Consumer Financial Protection Bureau (CFPB) and state
regulators, such oversight may lack the depth and frequency that a
master servicer would ordinarily provide. However, Moody's did not
adjust Moody's expected losses for the weaker servicing arrangement
due to the following: (1) CLS was established in 1999 and is an
experienced primary and special servicer of residential mortgage
loans, (2) CLS is an approved servicer for both Fannie Mae and
Freddie Mac, (3) CLS had no instances of non-compliance for its
2019 Regulation AB or Uniformed Single Audit Program (USAP)
independent servicer reviews, (4) CLS has an experienced management
team and uses Black Knight's MSP servicing platform, the largest
and most highly utilized mortgage servicing system, and (5) the R&W
framework mandates reviews of poorly performing mortgage loans by a
third-party if a threshold event occurs.

Third-Party Review

The transaction benefits from a TPR on 100% of the loans for
regulatory compliance, credit and property valuation. The due
diligence results confirm compliance with the originator's
underwriting guidelines for the vast majority of loans, no material
regulatory compliance issues, and no material property valuation
issues. The loans that had exceptions to the originator's
underwriting guidelines had significant compensating factors that
were documented.

Representations & Warranties

Moody's assessed the R&W framework based on three factors: (a) the
financial strength of the remedy provider; (b) the strength of the
R&Ws (including qualifiers and sunsets) and (c) the effectiveness
of the enforcement mechanisms. Moody's evaluated the impact of
these factors collectively on the ratings in conjunction with the
transaction's specific details and in some cases, the strengths of
some of the factors can mitigate weaknesses in others. Moody's also
considered the R&W framework in conjunction with other transaction
features, such as the independent due diligence, custodial receipt,
and property valuations, as well as any sponsor alignment of
interest, to evaluate the overall exposure to loan defects and
inaccurate information.

The seller makes the loan level R&Ws for the mortgage loans. The
loan-level R&Ws meet or exceed the baseline set of credit-neutral
R&Ws Moody's have identified for US RMBS. R&W breaches are
evaluated by an independent third-party using a set of objective
criteria. The transaction requires mandatory independent reviews of
loans that become 120 days delinquent and those that liquidate at a
loss to determine if any of the R&Ws are breached.

However, Moody's applied an adjustment in Moody's model analysis to
account for the risk that the R&W provider (unrated) may be unable
to repurchase defective loans in a stressed economic environment
(similar to the economic experience in 2008-2009 when a steep
decline in house prices triggered a financial crisis), given that
it is a non-bank entity whose monoline business of mortgage
origination and servicing is highly correlated with the economy.

Transaction Structure

OCMT 2021-3 has one pool with a shifting interest structure that
benefits from a subordination 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 prepayments to the senior
bond for a specified period of time, and increasing amounts of
prepayments to the subordinate bonds thereafter, but only if loan
performance satisfies delinquency and loss tests.

Tail Risk & Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
balance declines, senior bonds are exposed to eroding credit
enhancement over time, and increased performance volatility as a
result. To mitigate this risk, the transaction provides for a
senior subordination floor of 1.50% of the cut-off date pool
balance, and as subordination lock-out amount of 1.50% of the
cut-off date pool balance. The floors are consistent with the
credit neutral floors for the assigned ratings according to Moody's
methodology.

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 rating all classes except
interest-only classes was "Moody's Approach to Rating US RMBS Using
the MILAN Framework" published in April 2020.


OHA CREDIT 6: S&P Assigns Prelim BB- (sf) Rating on E-R Notes
-------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class X,
A-R, B-R, C-R, D-R, and E-R replacement notes from OHA Credit
Funding 6 Ltd./OHA Credit Funding 6 LLC, a CLO originally issued in
July 2020 that is managed by Oak Hill Advisors L.P.

The preliminary ratings are based on information as of July 13,
2021. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the July 20, 2021, refinancing date, the proceeds from the
replacement notes will be used to redeem the original notes. S&P
said, "At that time, we expect to withdraw our ratings on the
original notes and assign ratings to the replacement notes.
However, if the refinancing doesn't occur, we may affirm our
ratings on the original notes and withdraw our preliminary ratings
on the replacement notes."

The replacement notes will be issued via a proposed supplemental
indenture, which outlines the terms of the replacement notes.
According to the proposed supplemental indenture:

-- The non-call period will be extended by approximately two years
to July 20, 2023.

-- The reinvestment period will be extended by approximately three
years to July 20, 2026.

-- The legal final maturity date (of the replacement notes and the
existing subordinated notes) will be extended by approximately
three years to July 20, 2034.

-- Additional assets will be purchased on the first refinancing
date, increasing the target par amount to $550 million. There will
not be an additional effective date or ramp-up period, and the
first payment date following the refinancing will be Oct. 20,
2021.

-- There will be no additional subordinated notes issued on the
refinancing date.

-- The class X notes will be issued on the first refinancing date
and are expected to be paid down using interest proceeds during the
first eight payment dates in equal installments of $187,500
beginning on the first payment date and ending July 20, 2023.

-- The required minimum overcollateralization and interest
coverage ratios will be amended.

-- The transaction is adding the ability to purchase workout
related assets. In addition, the transaction has adopted benchmark
replacement language and made updates to conform to current rating
agency methodology.

-- The original indenture is being discharged, and a new indenture
will be put in place on the refinancing date.

-- Of the identified underlying collateral obligations, 100.00%
have credit ratings assigned by S&P Global Ratings.

-- Of the identified underlying collateral obligations, 97.18%
have recovery ratings assigned by S&P Global Ratings.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults, and
recoveries upon default, under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the notes remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Preliminary Ratings Assigned

  OHA Credit Funding 6 Ltd./OHA Credit Funding 6 LLC

  Class X, $1.50 million: AAA (sf)
  Class A-R, $341.00 million: AAA (sf)
  Class B-R, $77.00 million: AA (sf)
  Class C-R (deferrable), $33.00 million: A (sf)
  Class D-R (deferrable), $33.00 million: BBB- (sf)
  Class E-R (deferrable), $22.00 million: BB- (sf)
  Subordinated notes, $37.75 million: Not rated



REGIONAL 2021-2: S&P Assigns Prelim BB (sf) Rating on Class D Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Regional
Management Issuance Trust 2021-2's personal consumer loan-backed
notes.

The note issuance is an ABS securitization backed by personal
consumer loan receivables.

The preliminary ratings are based on information as of July 12,
2021. 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 availability of approximately 51.89%, 46.07%. 39.65% and
31.68% credit support to the class A, B, C, and D notes,
respectively, in the form of subordination, overcollateralization,
a reserve account, and excess spread. These credit support levels
are sufficient to withstand stresses commensurate with the
preliminary ratings on the notes based on our stressed cash flow
scenarios.

-- S&P's worst-case weighted average base-case loss assumption for
this transaction is 15.24%. This base-case loss assumption is a
function of the transaction-specific reinvestment criteria, actual
Regional Management Corp. (Regional) loan performance to date, and
a moderate adjustment in response to the COVID-19 pandemic-related
macroeconomic environment. S&P's base-case loss assumption also
reflects year-over-year performance volatility observed in annual
loan vintages across time.

-- In addition to running stressed cash flows, which in each
instance showed timely interest and principal payments made by the
legal final maturity date, S&P conducted liquidity analyses to
assess the impact of a temporary disruption in loan principal and
interest payments over the next 12 months as a result of the
COVID-19 pandemic. These included elevated deferment levels and a
reduction of voluntary prepayments to 0%. Based on its analyses,
the note interest payments and transaction expenses are a small
component of the total collections from the pool of receivables,
and accordingly, S&P believes the transaction could withstand
temporary, material declines in collections and still make full and
timely liability payments.

-- To date, Regional's central facilities and local branches
remain open and operational. Regional has the capacity to shift
branch employees to other branches as needed, and in May 2020,
began rolling out the option to close loans remotely, as opposed to
within branches, for certain borrowers.

-- In response to the COVID-19 pandemic, Regional tightened
underwriting and enhanced servicing procedures for its portfolio.
Regional selectively eliminated loans to lower-credit grade
borrowers, reduced advances to lower-credit grade existing
borrowers, and lowered lending limits to new borrowers across all
risk levels. Since the third quarter of 2020, Regional has
gradually begun to reverse some of these policies.

-- Regional has introduced new payment deferral options to
borrowers negatively impacted by the COVID-19 pandemic. While
deferment levels rose and peaked in April 2020, they decreased
through July 2020 to historic trend levels. Transaction documents
dictate that a reinvestment criteria event will occur if loans in
deferment status during the previous collection period exceed 10.0%
of the aggregate principal balance.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal, the assigned preliminary ratings
will be within the limits specified in the credit stability section
of "S&P Global Ratings Definitions," published Jan. 5, 2021.

-- The timely interest and full principal payments expected to be
made under stressed cash flow modeling scenarios appropriate to the
assigned preliminary ratings.

-- The characteristics of the pool being securitized and
receivables expected to be purchased during the revolving period.

-- The operational risks associated with Regional's decentralized
business model.

-- The transaction's payment and legal structures.

  Preliminary Ratings Assigned

  Regional Management Issuance Trust 2021-2

  Class A, $151.760 million(i): AA- (sf)
  Class B, $15.040 million(i): A- (sf)
  Class C, $16.130 million(i): BBB- (sf)
  Class D, $17.070 million(i): BB (sf)

(i)The actual size of the tranches and the respective interest
rates will be determined on the pricing date.



SREIT 2021-FLWR: DBRS Gives Prov. B(low) Rating on Class F Certs
----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2021-FLWR to
be issued by SREIT Trust 2021-FLWR (SREIT 2021-FLWR):

-- Class A at AAA (sf)
-- Class X-CP at BBB (sf)
-- Class X-NCP at BBB (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class D at BBB (low) (sf)
-- Class E at BB (low) (sf)
-- Class F at B (low) (sf)

All trends are Stable.

The balances for Classes X-CP and X-NCP are notional.

The SREIT 2021-FLWR single-asset/single-borrower transaction is
collateralized by the borrower's fee-simple interest in 16 Class A
multifamily properties totaling 5,260 units across six states in
the southeastern United States. An affiliate of Starwood Real
Estate Income Trust (Starwood or the sponsor) is using loan
proceeds of $796.5 million ($151,426 per unit), along with borrower
cash equity of $387.5 million, to acquire the portfolio for
approximately $1.1 billion ($216,300 per unit). The sponsor is in
the process of acquiring one of the properties, Century at the
Ballpark, and the acquisition will likely be finalized after the
transaction's closing date. An earn-out escrow in the amount of
$41.09 million will be established at closing and will be released
to the sponsor once the acquisition of Century at the Ballpark has
been finalized. If the property is ultimately not acquired, then
the earn-out proceeds will be used to pay down the principal
balance. For the purposes of net cash flow (NCF), valuation, and
sizing analysis, DBRS Morningstar assumed that the sponsor
completed the acquisition of Century at Ballpark.

The properties generally exhibit high-quality finishes and
comprehensive amenities as they all were constructed between 2006
and 2017, and seven of the assets, totaling 2,432 units, were built
within the past five years. In addition to the high-quality
collateral, DBRS Morningstar generally views the markets contained
in the portfolio as highly desirable for multifamily development,
with strong growth potential and favorable population statistics. A
significant portion of the portfolio is in Texas and Florida,
representing 78.2% of the total units in the portfolio and 76.8% of
the total purchase price. Recent population data indicate these two
states have had the most success in attracting new residents. Both
Texas and Florida were two of the 10 fastest growing states between
2010 and 2020, according to census results. Texas saw a population
growth rate of 15.9% and Florida experienced a population growth
rate of 14.6% over that time period, both significantly higher than
the national population growth rate of 6.6%.

Although the portfolio is currently well occupied with a physical
occupancy rate of 95.9% as of April 27, 2021, rental collections
have not been as strong. Specifically, between May 2020 and April
2021, the portfolio achieved monthly collection rates between 95.6%
and 97.1%. Furthermore, the portfolio collected about 96.3% of
rental payments on average over the trailing 12 months (T-12) ended
April 30, 2021. These collection figures are generally above the
national averages provided by the National Multifamily Housing
Council, which reported collection rates ranging from 93.2% to
95.9% between January and May 2021. However, the subject collection
figures are still weaker than what newer Class A multifamily assets
are typically able to achieve. In addition, although the assets are
generally in high-growth markets, the DBRS Morningstar Market Ranks
associated with the individual assets are generally considered
weaker than more densely populated urban locations. Approximately
58.2% of the portfolio is in a DBRS Morningstar Market Rank of 3 or
4, which indicates a more suburban location and generally exhibits
higher historical probabilities of default within the conduit
universe. However, the cross-collateralized and geographically
diversified nature of the portfolio mitigates some of the market
risk.

The transaction benefits from experienced sponsorship in Starwood,
a private investment company with significant ownership and
management experience in commercial real estate around the world.
Founded in 1991, the firm has approximately $80 billion in assets
under management and has acquired more than $115 billion of real
estate assets, including properties within every major real estate
asset class. Starwood also has significant experience in the
multifamily space as the company and its affiliates own nearly 350
multifamily properties totaling approximately 88,000 units
nationwide. Furthermore, Starwood owns 265 properties totaling
72,000 units that are in the same markets or metropolitan
statistical areas (MSAs) as the properties contained within the
portfolio. The portfolio serving as collateral for the SREIT
2021-FLWR transaction was acquired through a public, nonlisted,
externally managed real estate investment trust that had
approximately $6.2 billion of assets under management as of March
31, 2021.

Compared with other property types, multifamily assets generally
benefit from staggered lease rollover and lower expense ratios.
While revenue is quick to decline in a downturn because of the
short-term nature of the leases, it is also quick to respond when
the market improves. During the Coronavirus Disease (COVID-19)
pandemic, multifamily properties have been much more resilient in
generating cash flow and collecting rent when compared with other
property types such as retail and office.

Loan proceeds and borrower contributed equity of $387.5 million
(34.1% of the total purchase price) are being used to acquire the
collateral in an arm's-length transaction, representing significant
skin in the game for the sponsor. DBRS Morningstar generally views
acquisition financings more favorably as the sponsors are generally
more committed to the collateral's success when they have
significant cash equity at stake.

In addition to being in high-population-growth markets, the assets
have also experienced strong year-over-year rent growth as the
properties have been successful at attracting and retaining tenants
while still raising rents. For instance, in Q1 2021, there were
1,193 leases signed including both new and renewal leases,
representing 22.7% of the total portfolio units. These leases were
signed at rental rates that were on average 3.6% higher than the
previous leases for the same units.

The properties securing the transaction are generally in strong,
high-growth markets. The population of the MSAs contained in the
portfolio on average grew at a rate more than double the growth of
the United States between 2010 and 2019. Approximately 78.2% of the
units are in Texas or Florida, which are two of the fastest growing
states in the U.S.

The portfolio allocated loan amount is not heavily concentrated on
one particular asset. The average allocated purchase price is 6.3%
across the portfolio, with only one property (Travesia) accounting
for more than 10% of the total purchase price. Furthermore, no
asset makes up more than 10% of the total portfolio's net operating
income over the T-12 ended March 31, 2021. As a result, a temporary
cash flow decline at one property will likely not result in a debt
service shortfall.

Although the portfolio was well occupied as of the date of this
report, the historical occupancy of the portfolio is slightly
weaker. The portfolio was approximately 90.6% occupied in January
2019 and approximately 92.8% occupied for F2019. If occupancy
reverts to levels experienced in 2019, revenue could decline and
lower the cash flows available to service the loan. Furthermore,
collections at the property for the T-12 ended April 30, 2021, were
approximately 96.3%, which adds additional economic loss to the
portfolio's revenue.

The loan has a partial pro rata/sequential-pay structure, which
allows for pro rata paydowns across the capital structure for the
first 20% of the unpaid principal balance. DBRS Morningstar
considers this structure to be credit negative, particularly at the
top of the capital stack. Under a partial pro rata structure,
deleveraging of the senior notes through the release of individual
properties occurs at a slower pace compared with a sequential-pay
structure. To account for this structure, DBRS Morningstar applied
a penalty to the transaction's loan-to-value (LTV) hurdles.

The borrower/sponsor/arranger can release individual properties
with customary debt yield and LTV tests. The prepayment premium for
the release of individual assets is 105.0% of the allocated loan
amount (aggregate prior releases must not exceed 15.0% of the
original principal balance) and 110.0% of the allocated loan amount
for the release of individual assets thereafter. Because these
release premiums are designed to reduce the risk of adverse
selection over time, DBRS Morningstar considers the release premium
to be weaker than a generally credit-neutral standard of 115.0%
and, as a result, applied a penalty to the transaction's capital
structure to account for the weak deleveraging premium.

The DBRS Morningstar LTV on the $796.5 million whole loan is
substantial at 120.6%. To account for the high leverage, DBRS
Morningstar reduced its LTV benchmark targets by 2.5% across the
capital structure. The high leverage point and the lack of
scheduled amortization pose potentially elevated refinance risk at
loan maturity. The DBRS Morningstar LTV on the last dollar of rated
debt is much lower at 98.5%.

The loan is full-term interest only (IO), providing no reduction in
the loan basis over the loan term. The lack of principal
amortization increases refinance risk at maturity. The DBRS
Morningstar NCF results in a strong total debt IO debt service
coverage ratio (DSCR) of approximately 3.07 times, providing a
significant amount of cash flow cushion in times of economic
turmoil. However, the interest rate on the debt is floating and
based on one-month Libor, which is at a historic low and could
increase in the future, plus a spread of 160 basis points. Any
marginal increase on the base rate will incrementally lower the
DSCR and cash flow cushion for the portfolio.

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


STARWOOD MORTGAGE 2021-3: DBRS Finalizes B Rating on Cl. B-2 Certs
------------------------------------------------------------------
DBRS, Inc. finalized provisional ratings on the Mortgage
Pass-Through Certificates, Series 2021-3 issued by Starwood
Mortgage Residential Trust 2021-3 (STAR 2021-3):

-- $234.2 million Class A-1 at AAA (sf)
-- $24.1 million Class A-2 at AA (low) (sf)
-- $17.7 million Class A-3 at A (sf)
-- $14.8 million Class M-1 at BBB (sf)
-- $9.9 million Class B-1 at BB (sf)
-- $5.9 million Class B-2 at B (sf)

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

The AAA (sf) rating on the Class A-1 Notes reflects 24.60% of
credit enhancement provided by subordinate notes. The AA (low)
(sf), A (sf), BBB (sf), BB (sf), and B (sf) ratings reflect 16.85%,
11.15%, 6.40%, 3.20%, and 1.30% of credit enhancement,
respectively.

This securitization consists of a portfolio of fixed- and
adjustable-rate, expanded prime and nonprime first-lien residential
mortgages funded by the issuance of the Mortgage Pass-Through
Certificates, Series 2021-3 (the Certificates). The Certificates
are backed by 333 mortgage loans with a total principal balance of
$310,648,885 as of the Cut-Off Date (June 1, 2021).

Subsequent to the issuance of the related Presale Report on June
22, 2021, there were minimal loan drops and balance updates. The
Notes are backed by 338 mortgage loans with a total principal
balance of $317,239,423 in the Presale Report. Unless specified
otherwise, all the statistics regarding the mortgage loans in this
press release are based on the Presale Report balance.

The originators for the mortgage pool are Luxury Mortgage Corp.
(Luxury Mortgage; 68.5%), HomeBridge Financial Services, Inc.
(Homebridge; 21.9%), and other originators that each comprise less
than 10% of the mortgage pool. The Servicer of the loans is Select
Portfolio Servicing, Inc. (SPS). DBRS Morningstar conducted a
review of Starwood's residential mortgage platform and believes the
company is an acceptable mortgage loan aggregator. However, DBRS
Morningstar has not performed an operational risk review on Luxury
Mortgage and Homebridge.

The collateral pool is about four months seasoned on a weighted
average (WA) basis, although seasoning may span from one up to 61
months. All loans in the pool are current as of the Cut-Off Date.
Approximately 5.9% of the pool have missed at least one payment in
the past 24 months. The rest of the loans (94.1% of the pool) have
been current over the same period.

All acquired mortgage loans are underwritten and funded by the
originators on a delegated basis pursuant to either Starwood
proprietary guidelines or approved originator underwriting
guidelines.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's (CFPB) Qualified Mortgage (QM) and
Ability-to-Repay (ATR) rules where applicable, they were made to
borrowers who generally do not qualify for agency, government, or
private-label nonagency prime jumbo products for various reasons.
In accordance with the QM/ATR rules, approximately 72.7% of the
loans are designated as non-QM.

Approximately 27.2% of the loans are made to investors for business
purposes and, hence, are not subject to the QM/ATR rules. The
mortgage loans were underwritten to program guidelines for
business-purpose loans that are designed to rely on the
property-level cash flows for approximately 16.9% of the loans, and
mortgagor's credit profile and debt-to-income ratio, property
value, and the available assets, where applicable, for
approximately 9.8% of the loans. Since the loans were made to
investors for business purposes, they are exempt from the CFPB ATR
rules and TILA/RESPA Integrated Disclosure rule.

For investor loans originated to investors under debt service
coverage ratio (DSCR) programs (16.9% of the pool), lenders use
property cash flow or the DSCR to qualify borrowers for income. The
DSCR is typically calculated as market rental value (validated by
an appraisal report) divided by the principal, interest, taxes,
insurance, and association dues (PITIA).

For this transaction, the Servicer will fund advances of delinquent
principal and interest (P&I) until loans become 180 days delinquent
or are otherwise deemed unrecoverable. Additionally, the Servicer
is obligated to make advances with respect to taxes, insurance
premiums, and reasonable costs incurred in the course of servicing
and disposing properties.

The Sponsor, directly or indirectly through a majority-owned
affiliate, is expected to retain an eligible horizontal residual
interest consisting of a portion of the Class B-3 Certificates and
all of the Class XS Certificates, representing at least 5% of the
Certificates, to satisfy the credit risk-retention requirements
under Section 15G of the Securities Exchange Act of 1934 and the
regulations promulgated thereunder.

On or after the earlier of (1) the distribution date in June 2024
or (2) the date when the aggregate stated principal balance of the
mortgage loans is reduced to 30% of the Cut-Off Date balance,
Starwood Non-Agency Securities Holdings, LLC as Optional Redemption
Holder may redeem all outstanding Certificates (Optional
Redemption) at a price equal to the greater of (a) unpaid balances
of the mortgage loans plus accrued, unpaid interest and the fair
market value of all real estate-owned (REO) properties, and
deferred amounts (excluding the forbearance Amounts as of the
Cut-Off Date) and (b) the sum of the remaining aggregate balance of
the Certificates plus accrued and unpaid interest, and any fees,
expenses, and indemnity payments due and unpaid to the transaction
parties, including any unreimbursed servicing advances (Optional
Redemption Price). The Optional Redemption Holder is an entity
designated by the Depositor and a 50% affiliate of the Depositor.

Additionally, if on any date on which the unpaid mortgage loan
balance and the value of REO properties has declined to less than
8% of the initial mortgage loan balance as of the Cut-Off Date, the
Master Servicer will also have the right to purchase at the
Optional Clean-Up Call Price all of the mortgages, REO properties,
and any other properties from the Issuer. However, following
receipt of notice of the Master Servicer's intent to exercise the
Optional Clean-Up Call, the Servicing Administrator will have 30
days to exercise an Optional Redemption.

The Seller (SMRF TRS LLC) will have the option, but not the
obligation, to repurchase any mortgage loan that becomes 90 or more
days delinquent under the Mortgage Bankers Association (MBA) Method
(or in the case of any mortgage loan that has been subject to a
forbearance plan related to the impact of the Coronavirus Disease
(COVID-19) pandemic, on any date from and after the date on which
such loan becomes more than 90 days delinquent under the MBA Method
from the end of the forbearance period) at the repurchase price
(par plus interest), provided that such repurchases in aggregate do
not exceed 10% of the total principal balance as of the Cut-Off
Date (excluding any loan repurchased by the Seller related to a
breach of a representation and warranty).

The transaction's cash flow structure is similar to that of other
non-QM securitizations. The transaction employs a sequential-pay
cash flow structure with a pro rata principal distribution among
the senior tranches subject to certain performance triggers related
to cumulative losses or delinquencies exceeding a specified
threshold (a Trigger Event). Principal proceeds can be used to
cover interest shortfalls on the Class A-1 and Class A-2
Certificates (IIPP) before being applied sequentially to amortize
the balances of the senior and subordinated certificates. For the
Class A-3 Notes (only after a Credit Event) and for the mezzanine
and subordinate classes of notes (both before and after a Credit
Event), principal proceeds can be used to cover interest shortfalls
as the more senior Certificates are paid in full. Also, the excess
spread can be used to cover realized losses first before being
allocated to unpaid Cap Carryover Amounts due to Class A-1 down to
Class B-2.

CORONAVIRUS IMPACT

The coronavirus pandemic and the resulting isolation measures have
caused an immediate economic contraction, leading to sharp
increases in unemployment rates and income reductions for many
consumers. DBRS Morningstar saw increases in delinquencies for many
residential mortgage-backed securities (RMBS) asset classes shortly
after the onset of the pandemic.

Such mortgage delinquencies were mostly in the form of forbearance,
which are generally short-term payment reliefs that may perform
very differently from traditional delinquencies. At the onset of
the pandemic, the option to forebear mortgage payments was so
widely available, driving forbearance to a very high level. When
the dust settled, coronavirus-induced forbearance in 2020 performed
better than expected, thanks to government aid, low loan-to-value
ratios, and good underwriting in the mortgage market in general.
Across nearly all RMBS asset classes, delinquencies have been
gradually trending down in recent months as the forbearance period
comes to an end for many borrowers.

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



TCW CLO 2021-2: S&P Assigns Prelim BB- (sf) Rating on Class E Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to TCW CLO
2021-2 Ltd./TCW CLO 2021-2 LLC's floating-rate notes.

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

The preliminary ratings are based on information as of July 12,
2021. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

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

  Preliminary Ratings Assigned

  TCW CLO 2021-2 Ltd./TCW CLO 2021-2 LLC

  Class X, $4.0 million: AAA (sf)
  Class AS, $244.0 million: AAA (sf)
  Class AJ, $12.0 million: AAA (sf)
  Class B, $48.0 million: AA (sf)
  Class C (deferrable), $24.0 million: A (sf)
  Class D (deferrable), $24.0 million: BBB- (sf)
  Class E (deferrable), $16.0 million: BB- (sf)
  Subordinated notes, $37.5 million: Not rated



TRK 2021-INV1: S&P Assigns Prelim B (sf) Rating on Class B-2 Certs
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to TRK
2021-INV1 Trust's mortgage pass-through certificates series
2021-INV1.

The certificate issuance is an RMBS transaction backed by
first-lien, fixed- rate, adjustable-rate, fully amortizing, and
interest-only residential mortgage loans secured primarily by
single-family residences, planned unit developments, condominiums,
townhouses, and two- to four-family homes to both prime and
nonprime borrowers. The pool consists of 1,092 business-purpose
rental, non-owner-occupied residential mortgage loans (including 94
cross-collateralized loans) backed by 1,407 properties that are
exempt from qualified mortgage and ability-to-repay rules.

The preliminary ratings are based on information as of July 14,
2021. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The pool's collateral composition;

-- The transaction's credit enhancement, associated structural
mechanics, geographic concentration, and representation and
warranty framework;

-- The mortgage aggregator and mortgage originator; and

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

  Preliminary Ratings Assigned(i)

  TRK 2021-INV1 Trust

  Class A-1, $147,786,000: AAA (sf)
  Class A-2, $14,128,000: AA (sf)
  Class A-3, $23,884,000: A (sf)
  Class M-1, $12,222,000: BBB (sf)
  Class B-1, $11,325,000: BB (sf)
  Class B-2, $7,849,000: B (sf)
  Class B-3, $7,064,808: Not rated
  Class A-IO-S, notional(ii): Not rated
  Class XS, notional(ii): Not rated
  Class P, $100: Not rated
  Class R, not applicable: Not rated

(i)The collateral and structural information in this report
reflects the term sheet dated July 14, 2021. 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 equals the loans' aggregate unpaid
principal balance.



US AUTO FUNDING 2019-1: Moody's Hikes Class C Notes From Ba1
------------------------------------------------------------
Moody's Investors Service has upgraded 4 classes of bonds issued by
2 auto loan securitizations. The bonds are backed by pools of
retail automobile loan contracts originated by U.S. Auto Sales,
Inc. (not rated), an affiliate of U.S. Auto Finance. USASF
Servicing LLC (USASF), a wholly owned subsidiary of U.S. Auto
Finance, is the servicer for these transactions.

The complete rating action is as follows:

Issuer: U.S. Auto Funding Trust 2019-1

Class B Notes, Upgraded to A2 (sf); previously on Apr 17, 2019
Definitive Rating Assigned Baa2 (sf)

Class C Notes, Upgraded to A3 (sf); previously on Mar 3, 2020
Upgraded to Ba1 (sf)

Issuer: U.S. Auto Funding Trust 2020-1

Class A Notes, Upgraded to A2 (sf); previously on Aug 18, 2020
Definitive Rating Assigned Baa1 (sf)

Class B Notes, Upgraded to Baa1 (sf); previously on Aug 18, 2020
Definitive Rating Assigned Baa3 (sf)

RATINGS RATIONALE

The upgrades are primarily driven by the buildup of credit
enhancement due to structural features including a sequential pay
structure, non-declining reserve account and
overcollateralization.

The ratings are based on the quality of the underlying collateral
and its expected performance, the strength of the capital
structure, the experience and expertise of USASF and US Auto
Finance as the servicer and administrator respectively and the
presence of Wells Fargo Bank N.A. (Wells Fargo, Aa1(cr)) as named
backup servicer.

Moody's lifetime cumulative net loss expectation is 34% for the
2019-1 transaction and 36% for the 2020-1 transaction. The loss
expectations reflect updated performance trends on the underlying
pools.

PRINCIPAL METHODOLOGY

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

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

Up

Levels of credit protection that are greater than necessary to
protect investors against current expectations of loss could lead
to an upgrade of the ratings. Losses could decline from Moody's
original expectations as a result of a lower number of obligor
defaults or greater recoveries from the value of the vehicles
securing the obligors' promise of payment. The US job market and
the market for used vehicles are also primary drivers of the
transaction's performance. Other reasons for better-than-expected
performance include changes in servicing practices to maximize
collections on the loans or refinancing opportunities that result
in a prepayment of the loan.

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could lead to a
downgrade of the ratings. Losses could increase from Moody's
original expectations as a result of a higher number of obligor
defaults or a deterioration in the value of the vehicles securing
the obligors' promise of payment. The US job market and the market
for used vehicles are also primary drivers of the transaction's
performance. Other reasons for worse-than-expected performance
include poor servicing, error on the part of transaction parties,
lack of transactional governance and fraud.


WELLS FARGO 2014-C22: Fitch Affirms CCC Rating on 4 Tranches
------------------------------------------------------------
Fitch Ratings has affirmed all classes of Wells Fargo Bank, N.A.'s
WFRBS Commercial Trust Series 2014-C22 commercial mortgage trust
pass-through certificates.

   DEBT                RATING          PRIOR
   ----                ------          -----
WFRBS 2014-C22

A-3 92890KAY1    LT  AAAsf  Affirmed   AAAsf
A-4 92890KAZ8    LT  AAAsf  Affirmed   AAAsf
A-5 92890KBA2    LT  AAAsf  Affirmed   AAAsf
A-S 92890KBC8    LT  AAAsf  Affirmed   AAAsf
A-SB 92890KBB0   LT  AAAsf  Affirmed   AAAsf
B 92890KBF1      LT  AA-sf  Affirmed   AA-sf
C 92890KBG9      LT  A-sf   Affirmed   A-sf
D 92890KAJ4      LT  Bsf    Affirmed   Bsf
E 92890KAL9      LT  CCCsf  Affirmed   CCCsf
F 92890KAN5      LT  CCCsf  Affirmed   CCCsf
X-A 92890KBD6    LT  AAAsf  Affirmed   AAAsf
X-C 92890KAA3    LT  CCCsf  Affirmed   CCCsf
X-D 92890KAC9    LT  CCCsf  Affirmed   CCCsf

KEY RATING DRIVERS

Decreasing Loss Expectations: While losses remain high, overall
pool losses have declined since Fitch's last rating action,
primarily due to improving performance of the Stamford Plaza
Portfolio. Fitch's current ratings incorporate a base case loss of
7.1%. The Negative Rating Outlook reflects losses that could reach
9.8% when factoring in additional pandemic-related stresses, as
well as the additional sensitivity on the Stamford Plaza Portfolio
loan.

Stamford Plaza Portfolio (7.74% of the pool) is the third largest
loan in the pool and the largest Fitch Loan of Concern (FLOC). It
is secured by two 15-story class A office buildings and two
16-story class A office buildings comprised of 982,483 sf located
in Stamford, CT. While occupancy for the portfolio remained
relatively flat at 68% as of YE 2020), YE 2020 NOI increased 21.8%
from YE 2019, due to base rent increases and the burn off of
certain free rent periods. Media reports also indicate
approximately 47,000 sf of recent new leasing in early 2021.

The partial interest-only period ended in August 2019, and the loan
began amortizing, resulting in a YE 2020 NOI DSCR of 0.73x compared
with YE 2019 NOI DSCR of 0.72x and 0.95x at YE 2018. The Stamford
office market remains soft with submarket vacancy of approximately
25%. While occupancy has declined, the loan remains current and is
not scheduled to mature until 2024, leaving some time for lease-up
and stabilization. Expected losses for this loan have decreased
given the increase in cash flow, positive leasing momentum and
continued amortization.

Fitch modeled a base case loss of 24% for the Stamford Portfolio,
which equates to a value of $192 psf, below recent comparable sales
in the submarket. Fitch conducted an additional sensitivity
analysis on the loan, which assumed a loss of 49%, based on a more
conservative recovery estimate given the soft Stamford market. The
sensitivity analysis contributed to the Negative Outlooks on
classes A-S through C. With continued stabilization the Rating
Outlook on these classes may be revised to Stable.

There are seven loans (4.4% of the pool) that have transferred to
Special Servicing, two of which (0.67% of the pool) transferred
since Fitch's last rating action, and two loans (2.20% of the pool)
that have been in Special Servicing for more than three years
resulting in an increased certainty of realized losses. Four of the
specially serviced loans (1.38%) are secured by hotels that
incurred operational stress due to the pandemic and requested
relief. It is possible that several of these loans will return to
the master servicer in the coming months as travel demand resumes.

In addition to the Stamford Plaza Portfolio, there are three
additional non-specially serviced loans (6.3% of pool) flagged as
FLOCs due to actual or expected performance deterioration.

Increasing Credit Enhancement: Five loans (1.9% of the original
pool balance) have repaid since the last rating action, either
prepaying with a premium or prepaying during an open period. As of
the July 2021 distribution date, the pool's aggregate principal
balance had paid down by 15.63% to $1.26 billion from $1.488
billion at issuance. Twelve loans are fully defeased ($79.8
million; 6.35% of the pool). Three non-defeased loans (2.21%) are
scheduled to mature in 2021, one of which (1.82%) is in Special
Servicing. There are no other scheduled maturities until 2024.

Coronavirus Exposure: Ten hotel loans (10.1% of the pool) were
modeled with an additional NOI haircut to the YE 2019 or YE 2018
NOI, given the significant declines to 2020 NOI related to reduced
foot traffic and/or temporary closures related to the pandemic.

RATING SENSITIVITIES

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

-- Stable to improved asset performance coupled with paydown
    and/or defeasance. With continued stabilization of the
    Stamford Plaza Portfolio and resolution of the larger loans in
    special servicing, the Outlooks for classes A-S, B and C could
    be revised to Stable. Upgrades of classes B and C would likely
    occur with a significant improvement in credit enhancement
    (CE) and/or defeasance; however, increased concentrations,
    further underperformance of FLOCs, Specially Serviced loans,
    or new delinquencies/defaults may prevent this.

-- An upgrade to class D would be limited based on sensitivity to
    concentrations, or the potential for future concentration.
    Classes would not be upgraded above 'Asf' if there were a
    likelihood for interest shortfalls. Upgrades to classes E and
    F are not likely due to actual or expected performance decline
    for FLOCs, but could occur if performance of the FLOCs
    improves or loans currently in special servicing resolve with
    better than expected losses.

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

-- An increase in pool level losses from underperforming loans.
    Downgrades to 'AAAsf' rated classes are not considered likely
    due to the position in the capital structure, but may occur at
    'AAAsf' rated classes should interest shortfalls occur.

-- Downgrades of classes B, C and D are possible should Fitch's
    projected losses increase due to declines in pool performance,
    additional loan defaults, or greater than expected losses on
    the Specially Serviced loans. Downgrades of classes E and F
    are possible should the performance of the FLOCs fail to
    stabilize or decline further.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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 2015-C31: DBRS Confirms B(low) Rating on F Certs
------------------------------------------------------------
DBRS, Inc. confirmed the ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2015-C31 issued by Wells Fargo
Commercial Mortgage Trust 2015-C31 as follows:

-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-S at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class X-A at AAA (sf)
-- Class X-B at AA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class PEX at A (low) (sf)
-- Class X-D at BBB (sf)
-- Class D at BBB (low) (sf)
-- Class E at BB (low) (sf)
-- Class F at B (low) (sf)

The trends on Classes E and F are Negative. All other trends are
Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance, when the transaction consisted of
102 fixed-rate loans secured by 118 commercial and multifamily
properties with an initial trust balance of $988.5 million. As of
the June 2021 remittance report, 92 loans remain in the transaction
with a current trust balance of $895.5 million, representing a
collateral reduction of approximately 9.4% since issuance resulting
from amortization and the successful repayment of 10 loans. Six
loans, representing 3.6% of the current pool balance, are fully
defeased.

The transaction is concentrated by property type as 27 loans,
representing 47.1% of the current trust balance, are secured by
retail and hospitality properties, with office properties
representing the third-highest concentration at 19.6% of the
current trust balance.

As of the June 2021 remittance, three loans, representing 8.6% of
the pool, are in special servicing. The largest loan in special
servicing is Sheraton Lincoln Harbor Hotel (Prospectus ID#2; 6.7%
of the pool), was liquidated from the pool in the analysis for this
review. The loan is secured by a 358-key full-service hotel in
Weehawken, New Jersey. The loan transferred to special servicing in
January 2021 for imminent default. The servicer has confirmed the
borrower will no longer be funding shortfalls and has expressed a
desire to transfer the title to the property to the trust. The
collateral hotel's performance was deteriorating prior to the
pandemic, with the YE2019 net cash flow (NCF) down 24.7% compared
with at issuance. The March 2021 appraisal obtained by the special
servicer estimated an as-is value of $87.4 million, which reflects
a 31.7% decrease from the issuance appraisal of $128.0 million.
Given the hotel's challenges prior to the onset of the pandemic and
the likelihood that the property will continue to struggle even as
travel begins to increase, DBRS Morningstar believes the as-is
value could further deteriorate and assumed a conservative haircut
to the March 2021 value in the liquidation analysis, which resulted
in a loss severity in excess of 25.0%.

As of the June 2021 remittance, 24 loans, representing 35.9% of the
pool, are on the servicer's watchlist. The majority of the
watchlisted loans are being monitored for cash flow concerns that
have generally been driven by disruptions related to the pandemic.
DBRS Morningstar notes concerns associated with the pool's largest
loan, 745 Atlantic Avenue (Prospectus ID#1; 7.8% of the pool),
which is secured by a 174,231-square-foot Class A office building
in the Boston central business district. According to the
servicer's watchlist commentary, the property's largest tenant,
WeWork, which is in place on a lease representing 75.0% of the net
rentable area and expiring in 2029, ceased paying rent in March and
has since gone dark. The subject lease does not contain any
termination or contraction options and, according to the servicer,
the borrower plans to pursue legal remedies related to WeWork's
departure and cessation of payments due under the terms of the
lease.

The loan was structured with cash management and a cash trap to be
triggered with certain events, including WeWork going dark or
ceasing rent payments, and the servicer's watchlist commentary
confirmed cash management is being initiated. The June 2021 loan
level reserve report showed only nominal reserves on the loan as
leasing reserves and tax and insurance impounds were not required
at closing. The cash management provision will trigger the
collection of reserves and the borrower does have the option to
post an LOC of up to $5.0 million in lieu of the reserve
collections. The loan, which funded the acquisition of the property
with a sponsor equity contribution of just over $48.0 million to
close the transaction, has not been delinquent to date. Given the
low physical occupancy rate for the property with the WeWork
departure and the uncertainty surrounding the outcome of the
borrower's pursuit of legal remedies against the tenant, the loan
was analyzed with a significant probability of default penalty to
increase the expected loss in the analysis for this review.

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



WELLS FARGO 2021-C60: Fitch Affirms B- Rating on J-RR Certs
-----------------------------------------------------------
Fitch Ratings has issued a presale report on Wells Fargo Commercial
Mortgage Trust 2021-C60, commercial mortgage pass-through
certificates, Series 2021-C60.

Fitch expects to rate the transaction and assign Rating Outlooks as
follows:

-- $17,659,000 Class A-1 'AAAsf'; Outlook Stable;

-- $45,569,000 Class A-2 'AAAsf'; Outlook Stable;

-- $24,458,000 Class A-SB 'AAAsf'; Outlook Stable;

-- $200,000,000a Class A-3 'AAAsf'; Outlook Stable;

-- $0b Class A-3-1 'AAAsf'; Outlook Stable;

-- $0bc Class A-3-X1 'AAAsf'; Outlook Stable;

-- $0b Class A-3-2 'AAAsf'; Outlook Stable;

-- $0bc Class A-3-X2 'AAAsf'; Outlook Stable;

-- $236,357,000a Class A-4 'AAAsf'; Outlook Stable;

-- $0b Class A-4-1 'AAAsf'; Outlook Stable;

-- $0bc Class A-4-X1 'AAAsf'; Outlook Stable;

-- $0b Class A-4-2 'AAAsf'; Outlook Stable;

-- $0bc Class A-4-X2 'AAAsf'; Outlook Stable;

-- $524,043,000c Class X-A 'AAAsf'; Outlook Stable;

-- $121,653,000c Class X-B 'A-sf'; Outlook Stable;

-- $58,019,000 Class A-S 'AAAsf'; Outlook Stable;

-- $0b Class A-S-1 'AAAsf'; Outlook Stable;

-- $0bc Class A-S-X1 'AAAsf'; Outlook Stable;

-- $0b Class A-S-2 'AAAsf'; Outlook Stable;

-- $0bc Class A-S-X2 'AAAsf'; Outlook Stable;

-- $34,624,000 Class B 'AA-sf'; Outlook Stable;

-- $0b Class B-1 'AA-sf'; Outlook Stable;

-- $0bc Class B-X1 'AA-sf'; Outlook Stable;

-- $0b Class B-2 'AA-sf'; Outlook Stable;

-- $0bc Class B-X2 'AA-sf'; Outlook Stable;

-- $29,010,000 Class C 'A-sf'; Outlook Stable;

-- $0b Class C-1 'A-sf'; Outlook Stable;

-- $0bc Class C-X1 'A-sf'; Outlook Stable;

-- $0b Class C-2 'A-sf'; Outlook Stable;

-- $0bc Class C-X2 'A-sf'; Outlook Stable;

-- $11,192,000cd Class X-D 'BBB+sf'; Outlook Stable;

-- $11,192,000d Class D 'BBB+sf'; Outlook Stable;

-- $14,074,000de Class E-RR 'BBBsf'; Outlook Stable;

-- $17,780,000de Class F-RR 'BBB-sf'; Outlook Stable;

-- $9,358,000de Class G-RR 'BB+sf'; Outlook Stable;

-- $9,358,000de Class H-RR 'BB-sf'; Outlook Stable; and

-- $7,486,000de Class J-RR 'B-sf'; Outlook Stable.

The following classes are not expected to be rated by Fitch:

-- $8,422,000de Class K-RR;

-- $11,230,000de Class L-RR; and

-- $14,037,042de Class M-RR.

(a) The initial certificate balances of class A-3 and class A-4 are
not yet known but expected to be $436,357,000 in aggregate, subject
to a 5% variance. The certificate balances will be determined based
on the final pricing of those classes of certificates. The expected
class A-3 balance range is $0 - $200,000,000, and the expected
class A-4 balance range is $236,357,000 - $436,357,000. The
balances of classes A-3 and A-4 shown above comprise the
hypothetical balance for A-3 if A-4 were sized at the minimum of
its range. In the event that the class A-4 certificates are issued
with an initial certificate balance of $436,357,000, the class A-3
certificates will not be issued.

(b) Exchangeable Certificates. The class A-3, A-4, A-S, B and C
certificates are exchangeable certificates. Each class of
exchangeable certificates may be exchanged for the corresponding
classes of exchangeable certificates and vice versa. The dollar
denomination of each of the received classes of certificates must
be equal to the dollar denomination of each of the corresponding
classes of exchangeable certificates. Class A-3 may be surrendered
(or received) for the received (or surrendered) classes A-3-1 and
A-3-X1. Class A-3 may be surrendered (or received) for the received
(or surrendered) classes A-3-2 and A-3-X2. Class A-4 may be
surrendered (or received) for the received (or surrendered) classes
A-4-1 and A-4-X1. Class A-4 may be surrendered (or received) for
the received (or surrendered) classes A-4-2 and A-4-X2. Class A-S
may be surrendered (or received) for the received (or surrendered)
classes A-S-1 and A-S-X1. Class A-S may be surrendered (or
received) for the received (or surrendered) classes A-S-2 and
A-S-X2. Class B may be surrendered (or received) for the received
(or surrendered) classes B-1 and B-X1. Class B may be surrendered
(or received) for the received (or surrendered) classes B-2 and
B-X2. Class C may be surrendered (or received) for the received (or
surrendered) classes C-1 and C-X1. Class C may be surrendered (or
received) for the received (or surrendered) classes C-2 and C-X2.

(c) Notional amount and interest only.

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

(e) Horizontal risk retention.

The expected ratings are based on information provided by the
issuer as of July 12, 2021.

TRANSACTION SUMMARY

The certificates represent the beneficial ownership interest in the
trust, the primary assets of which are 61 loans secured by 107
commercial properties having an aggregate principal balance of
$748,633,043 as of the cutoff date. The loans were contributed to
the trust by LMF Commercial, LLC, Wells Fargo Bank, National
Association, Column Financial, Inc., UBS AG, BSPRT CMBS Finance,
LLC and Ladder Capital Finance LLC. The Master Servicer is expected
to be Wells Fargo Bank, National Association and the Special
Servicer is expected to be Midland Loan Services, a Division of PNC
Bank, National Association.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 25.3% of the properties
by balance, cash flow analyses of 89.1% of the pool and asset
summary reviews on 100% of the pool.

Coronavirus Impact: The ongoing containment effort related to the
coronavirus pandemic may have an adverse impact on near-term
revenue (i.e. bad debt expense, rent relief) and operating expenses
(i.e. sanitation costs) for some properties in the pool. Per the
offering documents, all of the loans are current and are not
subject to any ongoing forbearance requests.

KEY RATING DRIVERS

Leverage Exceeds That of Recent Transactions: This transaction's
leverage is higher than other multiborrower transactions recently
rated by Fitch. The pool's Fitch debt service coverage ratio (DSCR)
of 1.24x is lower than the 2021 YTD and 2020 averages of 1.39x and
1.32x, respectively. Additionally, the pool's Fitch loan-to-value
(LTV) of 108.1% is higher than the 2021 YTD and 2020 averages of
101.6% and 99.6%, respectively.

Investment-Grade Credit Opinion Loans: Only two loans representing
9.4% of the pool received an investment-grade credit opinion. The
Grace Building loan (6.7% of the pool) received an investment-grade
credit opinion of 'A-sf*' and The Westchester loan (2.7% of the
pool) received an investment-grade credit opinion of 'BBB-sf*'.
This is below the 2021 YTD average of 15.2% and considerably below
the 2020 average 24.5%.

Diverse Pool: The pool's 10 largest loans comprise 46.5% of the
pool's cutoff balance, which is a lower concentration than the 2021
YTD or 2020 averages of 54.2% and 56.8%, respectively. The Loan
Concentration Index (LCI) of 333 is lower than the 2021 YTD and
2020 averages of 410 and 440, respectively. The Sponsor
Concentration Index (SCI) of 335 is also lower than the 2021 YTD
and 2020 averages of 436 and 474, respectively, and indicates there
is little sponsor concentration.

Above Average Amortization: The pool is scheduled to amortize by
6.1% of the initial pool balance prior to maturity, which is above
the 2021 YTD and 2020 averages of 4.4% and 5.3%, respectively.
Twenty-nine loans (59.5%) are full interest-only loans, which is
below the 2021 YTD and 2020 averages of 73.1% and 67.7%,
respectively. At origination, 16 loans (21.9%) were partial
interest-only loans, which is above the 2021 YTD average of 16.7%
and slightly above the 2020 average of 20.0%. One loan, TownePlace
Suites - La Place (1.2%), was partial interest-only and is
currently amortizing.

RATING SENSITIVITIES

This section provides insight into the sensitivity of ratings when
one assumption is modified, while holding others equal. For U.S.
CMBS, the sensitivity reflects the impact of changes to property
net cash flow (NCF) in up- and down-environments. The result below
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:

-- Improvement in cash flow increases property value and capacity
    to meet its debt service obligations.

The table below indicates the model implied rating sensitivity to
changes in one variable, Fitch NCF:

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

-- 20% NCF Increase:
    'AAAsf'/'AAAsf'/'AAAsf'/'AAsf'/'A+sf'/'BBB+sf'/'BBB-sf'/'BBB
    sf'.

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

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

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

-- 10% NCF Decline: 'Asf'/'BBB+sf'/'BBB-sf'/'BB+sf'/'BBsf'/'B
    sf'/'CCCsf'/ 'CCCsf'/'CCCsf'.

-- 20% NCF Decline: 'BBB+sf'/'BBB-sf'/'BB-sf'/'Bsf'/'CCCsf
    '/'CCCsf'/'CCCsf'/'CCCsf'/'CCCsf'.

-- 30% NCF Decline: 'BB+sf'/'B+sf'/'CCCsf'/'CCCsf'/'CCCsf'/
    'CCCsf'/'CCCsf'/'CCCsf'/'CCCsf'.

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 Ernst & Young LLP. The third-party due diligence
described in Form 15E focused on Ernst & Young LLP. Fitch
considered this information in its analysis and it did not have an
effect on Fitch's analysis or conclusions.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


WFRBS COMMERCIAL 2013-C18: Fitch Lowers Class F Certs to 'Csf'
--------------------------------------------------------------
Fitch Ratings has downgraded three and affirmed eight classes of
commercial mortgage pass-through certificates from WFRBS Commercial
Mortgage Trust 2013-C18. The Rating Outlooks for three classes have
been revised to Negative from Stable.

    DEBT               RATING          PRIOR
    ----               ------          -----
WFRBS 2013-C18

A-4 96221QAD5    LT  AAAsf  Affirmed   AAAsf
A-5 96221QAE3    LT  AAAsf  Affirmed   AAAsf
A-S 96221QAG8    LT  AAAsf  Affirmed   AAAsf
A-SB 96221QAF0   LT  AAAsf  Affirmed   AAAsf
B 96221QAJ2      LT  AA-sf  Affirmed   AA-sf
C 96221QAK9      LT  A-sf   Affirmed   A-sf
D 96221QAM5      LT  B-sf   Downgrade  BBB-sf
E 96221QAP8      LT  CCCsf  Downgrade  B-sf
F 96221QAR4      LT  Csf    Downgrade  CCCsf
PEX 96221QAL7    LT  A-sf   Affirmed   A-sf
X-A 96221QAH6    LT  AAAsf  Affirmed   AAAsf

KEY RATING DRIVERS

Increased Loss Expectations: Fitch's loss projections have
increased since the last rating action, primarily due to continued
performance decline for specially serviced loans. Twelve loans
representing 50.1% of the pool have been flagged as Fitch Loans of
Concern (FLOC), including four specially serviced loans, three of
which are in the top 15. Fitch's current ratings incorporate a base
case loss of 11.4%. The Negative Outlooks reflect losses that could
reach 13.3% when factoring in additional pandemic-related
stresses.

The largest specially serviced loan is Hotel Felix (6.5% of the
pool). The loan is secured by a 225-key, full-service boutique
hotel in Chicago's River North neighborhood. The building was
originally constructed in 1926 as an apartment building and was
converted to hotel use in 2009 following a $36 million
redevelopment. The loan previously transferred to special servicing
in April 2018 and was modified in December 2018, terms of which
included a three-year extension of the interest-only period. The
prior default stemmed from declined cash flow attributed to
significant increase in real estate taxes and new supply to the
submarket.

The loan again transferred to special servicing in April 2020 for
payment default and remains delinquent. Occupancy and RevPAR had
been in year-over-year decline prior to the pandemic. The hotel was
closed for most of 2020 due to the effects of the pandemic, and
loan performance continued to decline. A receiver was appointed in
January 2021, but the special servicer has not yet indicated a
workout strategy. The property is not taking reservations as of
July 2021. Chicago-based Oxford Capital Group is the sponsor for
this loan, as well as the second largest specially serviced loan.
Fitch's stressed value is based on the TTM June 2019 NOI and a 12%
cap rate, resulting in a 52% modeled loss.

The second largest specially serviced loan is HIE at Magnificent
Mile (3.1% of the pool). It is secured by a 174-key,
limited-service hotel in Chicago, two blocks west of Michigan
Avenue. The property was originally developed in 1927 as the Hotel
Cass and was most recently renovated in 2007 following the current
sponsor's acquisition. This loan shares common sponsorship with the
Hotel Felix loan. Performance has declined year-over-year since
issuance, taking a significant dip when the loan began amortizing
in 2016. Increasing real estate taxes and market competition have
further stressed performance. This loan had been on the watchlist
since 2018 for low DSCR.

The loan transferred to special servicing in April 2020 for payment
default and remains delinquent. The asset was closed temporarily
for a period last year due to the effects of the pandemic. A
receiver was appointed in January 2021 but the special servicer has
not yet indicated a workout strategy. The property does not appear
to be open as of July 2021. Fitch's stressed value is based on the
YE 2019 NOI and a 12% cap rate, resulting in a 55% modeled loss.

The third largest specially serviced loan is Cedar Rapids Office
Portfolio (3.0% of the pool). The portfolio comprises two office
properties that are located in downtown Cedar Rapids, Iowa. Town
Center is a three-building office complex and 600 3rd Avenue SE is
a neighboring office building. The loan was transferred to special
servicing in May 2017 due to payment default. The assets became REO
in June 2020.

The largest tenant at issuance was Rockwell Collins, which occupied
73,139 sf (39.3% NRA) on a lease that expired in September 2016.
The borrower previously voided certain provisions to the lease
without noteholder consent and subsequently executed a new lease
with Hibu, a replacement tenant without noteholder consent. A
receiver was appointed in June 2017. Receiver efforts, including
executing new leases and negotiating terms with Hibu (now occupying
40.7% NRA), have alleviated much of the concern surrounding
concentrated tenant roll. Neither of the properties are currently
marketed for sale. Despite recent leasing activity, the projected
loss remains high at 88%.

The base case loss expectations for these loans is a primary driver
for the downgrades.

Interest Shortfalls: There is increased propensity for interest
shortfalls as two of the largest loans remain in payment default.
The pool has become more concentrated and unpaid interest, due to
the continued delinquency of the Hotel Felix and HIE Magnificent
Mile loans, has reached class D. Fitch has limited tolerance for
untimely interest to investment-grade rated classes. Concern for
ongoing interest shortfalls contributed to the Negative Outlooks.

Improved Credit Support: Subordination to the bonds has increased
since the last rating action due to the repayment of six loans from
the trust, contributing to $158.4 million principal paydown. As of
the June 2021 remittance, the pool's aggregate principal balance
has been reduced by 32.7% to $698.5 million from $1.0 billion at
issuance. Six loans representing 3.7% of the pool are fully
defeased. There are no scheduled maturities until 2023.

Coronavirus Exposure: There are eleven loans representing 35.2% of
the pool backed by retail properties. Eight loans representing
23.2% of the pool are backed by hotels, including three that are in
special servicing. Six loans representing 7.4% of the pool are
backed by multifamily properties. Additional stresses were applied
to three retail properties, three hotels and one multifamily
property related to ongoing performance concerns in light of the
pandemic. This treatment contributed to the Negative Outlooks.

RATING SENSITIVITIES

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

-- Significantly improved performance coupled with paydown and/or
    defeasance. An upgrade to class B would occur with
    stabilization of the FLOCs, but would be limited as
    concentrations increase. Upgrades of classes C and PEX would
    only occur with significant improvement in credit enhancement
    and stabilization of the FLOCs. Classes would not be upgraded
    above 'Asf' if there is likelihood for interest shortfalls. An
    upgrade to classes D through F is not likely, unless
    performance of the FLOCs improves and if performance of the
    remaining pool is stable.

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

-- An increase in pool-level losses from underperforming or
    specially serviced loans. Downgrades to the classes rated
    'AAAsf' are not considered likely due to position in the
    capital structure, but may occur at 'AAAsf' or 'AAsf' should
    interest shortfalls occur. Downgrades to classes C, PEX and D
    are possible should the specially serviced hotel loans fail to
    resolve or additional loans default. Downgrades to the
    distressed classes are expected as losses are realized.

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.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means 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.


[*] DBRS Confirms Ratings on All Classes in 4 Student Loan Deals
----------------------------------------------------------------
DBRS, Inc. confirmed its ratings on all classes of securities
included in four College Ave Student Loans transactions.

The affected rating is available at https://bit.ly/2VFk8hx

The confirmations are based on the following analytical
considerations:

-- The transaction assumptions consider DBRS Morningstar's set of
macroeconomic scenarios for select economies related to the
Coronavirus Disease (COVID-19) pandemic, available in its
commentary "Global Macroeconomic Scenarios: June 2021 Update,"
published on June 18, 2021. DBRS Morningstar initially published
macroeconomic scenarios on April 16, 2020, which have been
regularly updated. The scenarios were last updated on June 18,
2021, and are reflected in DBRS Morningstar's rating analysis.

-- The assumptions consider the moderate and adverse macroeconomic
scenarios outlined in the commentary, with the moderate scenario
serving as the primary anchor for the current ratings. The moderate
scenario factors in continued success in containment during the
second half of 2021, enabling the continued relaxation of
restrictions.

-- Collateral performance is within expectations and cumulative
net losses remain low. Forbearance and delinquency levels remain
relatively stable.

-- Transaction capital structure and credit enhancement levels are
sufficient for the current ratings.

-- Credit enhancement is in the form of overcollateralization,
reserve accounts, and excess spread, with senior notes benefiting
from the subordination of junior notes. Credit enhancement levels
are sufficient to support the DBRS Morningstar-expected default and
loss severity assumptions under various stress scenarios.

Notes: The principal methodology is DBRS Morningstar Master U.S.
ABS Surveillance (May 26, 2021), which can be found on
dbrsmorningstar.com under Methodologies & Criteria.


[*] DBRS Reviews 105 Classes from 33 U.S. RMBS Transactions
-----------------------------------------------------------
DBRS, Inc. reviewed 105 classes from 33 U.S. ReREMIC and
residential mortgage-backed security (RMBS) transactions. Of the
105 classes reviewed, DBRS Morningstar upgraded 17 ratings,
confirmed 39 ratings, downgraded seven ratings, and discontinued 42
ratings.

The affected rating is available at https://bit.ly/3qOrlau

The rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new rating levels. The rating confirmations reflect asset
performance and credit-support levels that are consistent with the
current ratings. The rating downgrades reflect the unlikely
recovery of the bonds’ principal loss amount. The discontinued
ratings reflect the transactions exercising their cleanup call
option or the full repayment of principal to bondholders.

The pools backing the reviewed ReREMIC and RMBS transactions
consist of legacy prime, subprime, Alt-A, Scratch and Dent, option
adjustable-rate mortgage, ReREMIC, mortgage insurance-linked notes,
reverse mortgage, non-Qualified Mortgage, and single-family rental
collateral.

The ratings assigned to the securities listed below differ from the
ratings implied by the quantitative model. DBRS Morningstar
considers this difference to be a material deviation; however, in
this case, the ratings on the subject securities may either reflect
additional seasoning being warranted to substantiate a further
upgrade or actual deal/tranche performance that is not fully
reflected in the projected cash flows/model output.

-- Financial Asset Securities Corp. AAA Trust 2005-2, Series
2005-2, Class A3

-- Financial Asset Securities Corp. AAA Trust 2005-2, Series
2005-2, Class II-X

-- Credit Suisse First Boston Mortgage Securities Corp., CSMC
Series 2009-6R, CSMC Series 2009-6R, Class 1-A5

-- CSMC Series 2010-9R, CSMC Series 2010-9R, Class 49-A-4

-- CSMC Series 2015-6R, CSMC Series 2015-6R, Class 2-A-1

-- Deutsche ALT-A Securities, Inc. Re-REMIC Trust, Series
2007-RS1, Re-REMIC Trust Certificates, Series 2007-1, Class A-2

-- Deutsche ALT-A Securities, Inc. Re-REMIC Trust, Series
2007-RS1, Re-REMIC Trust Certificates, Series 2007-1, Class A-3

-- Bellemeade Re 2020-1 Ltd., Mortgage Insurance-Linked Notes,
Series 2020-1, Class B-1

CORONAVIRUS DISEASE (COVID-19) IMPACT

The coronavirus pandemic and the resulting isolation measures have
caused an immediate economic contraction, leading to sharp
increases in unemployment rates and income reductions for many
consumers. DBRS Morningstar saw increases in delinquencies for many
RMBS asset classes, shortly after the onset of coronavirus.

Such mortgage delinquencies were mostly in the form of forbearance,
which are generally short-term payment reliefs that may perform
very differently from traditional delinquencies. At the onset of
coronavirus, because the option to forebear mortgage payments was
so widely available, it drove forbearance to a very high level.
When the dust settled, coronavirus-induced forbearance in 2020
performed better than expected, thanks to government aid and good
underwriting in the mortgage market in general. Across nearly all
RMBS asset classes, delinquencies have been gradually trending down
in recent months as the forbearance period comes to an end for many
borrowers.

Notes: The principal methodologies are the U.S. RMBS Surveillance
Methodology (February 21, 2020) and RMBS Insight 1.3: U.S.
Residential Mortgage-Backed Securities Model and Rating Methodology
(April 1, 2020), which can be found on dbrsmorningstar.com under
Methodologies & Criteria.


[*] DBRS Reviews 114 Classes from 14 U.S. RMBS Transactions
-----------------------------------------------------------
DBRS, Inc. reviewed 114 classes from 14 U.S. residential
mortgage-backed security (RMBS) transactions. Of the 114 classes
reviewed, DBRS Morningstar confirmed 110 ratings, upgraded three
ratings, and discontinued one rating.

The affected rating is available at https://bit.ly/3ytmLkm

The rating confirmations reflect asset performance and
credit-support levels that are consistent with the current ratings.
The rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new rating levels. The discontinuation reflects full
repayment of principal to bondholders.

The pools backing the reviewed RMBS transactions consist of -Prime,
Alt-A, Option-Adjustable-Rate-Mortgage, Scratch and Dent,
Second-Lien, Reperforming, and Subprime collateral.

The ratings assigned to the securities listed below differ from the
ratings implied by the quantitative model. DBRS Morningstar
considers this difference to be a material deviation; however, in
this case, the ratings on the subject securities may either reflect
additional seasoning being warranted to substantiate a further
upgrade or certain structural features that are not fully captured
in the quantitative model output.

-- C-BASS 2007-SP1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2007-SP1, Class M-1

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class M-1

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class M-2

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class M-3

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class B-1

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class B-2

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class B-3

-- First Franklin Mortgage Loan Trust, Series 2005-FFH2, Mortgage
Pass-Through Certificates, Series 2005-FFH2, Class M3

-- MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage
Pass-Through Certificates, Series 2005-WMC1, Class M-4

-- MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage
Pass-Through Certificates, Series 2005-WMC1, Class M-5

-- Securitized Asset-Backed Receivables LLC Trust 2005-EC1,
Mortgage Pass-Through Certificates, Series 2005-EC1, Class M-2

-- Terwin Mortgage Trust 2004-19HE, Asset-Backed Certificates,
Series 2004-19HE, Class A-1

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class A-1

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class A-3

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class M-1

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class M-2

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class S

-- Terwin Mortgage Trust 2004-9HE, Asset-Backed Certificates,
Series 2004-9HE, Class A-1

-- Terwin Mortgage Trust 2004-9HE, Asset-Backed Certificates,
Series 2004-9HE, Class A-3

-- Terwin Mortgage Trust 2004-9HE, Asset-Backed Certificates,
Series 2004-9HE, Class M-1

-- Terwin Mortgage Trust 2004-9HE, Asset-Backed Certificates,
Series 2004-9HE, Class M-2

CORONAVIRUS IMPACT

The Coronavirus Disease (COVID-19) pandemic and the resulting
isolation measures caused an immediate economic contraction,
leading to sharp increases in unemployment rates and income
reductions for many consumers. DBRS Morningstar saw increases in
delinquencies for many RMBS asset classes, shortly after the onset
of the pandemic.

Such mortgage delinquencies were mostly in the form of
forbearances, which are generally short-term payment reliefs that
may perform very differently from traditional delinquencies. At the
onset of the pandemic, the option to forebear mortgage payments was
widely available, and it drove forbearance to a very high level.
When the dust settled, coronavirus-induced forbearance in 2020
performed better than expected, thanks to government aid and good
underwriting in the mortgage market in general. Across nearly all
RMBS asset classes, delinquencies have been gradually trending down
in recent months as the forbearance period comes to an end for many
borrowers.

In connection with the economic stress assumed under its moderate
scenario (see "Global Macroeconomic Scenarios: June 2021 Update,"
published on June 18, 2021), DBRS Morningstar may assume higher
loss expectations for pools with loans on forbearance plans.

Notes: The principal methodologies are the U.S. RMBS Surveillance
Methodology (February 21, 2020) and RMBS Insight 1.3: U.S.
Residential Mortgage-Backed Securities Model and Rating Methodology
(April 1, 2020), which can be found on dbrsmorningstar.com under
Methodologies & Criteria.



[*] S&P Takes Various Actions on 13 Exeter Automobiles Trusts
-------------------------------------------------------------
S&P Global Ratings raised its ratings on 35 classes of notes from
13 Exeter Automobile Receivables Trust transactions. At the same
time, S&P affirmed their ratings on three classes.

The rating actions reflect S&P's view of the transactions'
collateral performance to date, expected future collateral
performance, structures, and available credit enhancement. S&P
said, "In addition, we incorporated secondary credit factors,
including credit stability, payment priorities under various
scenarios, and sector- and issuer-specific analysis. Based on these
factors, we believe the notes' creditworthiness is consistent with
the raised and affirmed ratings."

Given S&P's improved economic outlook and the transactions'
better-than-expected performance, it lowered its loss expectations
on all 13 transactions.

  Table 1

  Collateral Performance (%)(i)

                       Pool   Current    60+ day   Extensions
  Series       Mo.   factor       CNL   delinq.
  2017-1       52     12.13     17.52      8.30          2.62
  2017-2       50     14.64     18.10      8.89          2.37
  2017-3       45     19.02     15.85      7.11          2.89
  2018-1       41     21.25     15.36      7.10          3.10
  2018-2       38     25.40     14.72      7.24          2.92
  2018-3       35     29.94     14.00      6.34          2.99
  2018-4       32     32.10     12.47      6.05          3.13
  2019-1       29     37.07     11.72      6.00          3.37
  2019-2       26     42.58     10.77      6.14          3.54
  2019-3       23     47.83      8.95      5.77          3.32
  2019-4       20     52.34      7.75      5.67          3.29
  2020-1       17     59.45      6.31      5.30          3.12
  2020-2       12     68.33      3.35      4.08          2.80

(i)As of the June 2021 distribution date.
Mo.--Month.
Delinq.—Delinquencies.
CNL--cumulative net loss.

  Table 2
  CNL Expectations (%)

                Original             Former           Revised
                lifetime           lifetime          lifetime
  Series        CNL exp.           CNL exp.(i)       CNL exp.(ii)
  2017-1     19.75-20.75        19.50-20.50       Up to 18.00
  2017-2     20.10-21.10        20.50-21.50       18.75-19.25
  2017-3     20.00-21.00        20.00-21.00       17.75-18.75
  2018-1     20.00-21.00        20.25-21.25       17.75-18.75
  2018-2     20.50-21.50        20.50-21.50       18.25-19.25
  2018-3     20.50-21.50        20.50-21.50       18.75-19.75
  2018-4     20.50-21.50        20.50-21.50       17.75-18.75
  2019-1     20.50-21.50        22.25-23.25       18.50-19.50
  2019-2     20.50-21.50        22.50-23.50       19.00-20.00
  2019-3     20.50-21.50        22.75-23.75       18.75-19.75
  2019-4     20.50-21.50        23.00-24.00       19.00-20.00
  2020-1     20.50-21.50        23.00-24.00       19.00-20.00
  2020-2     23.75-24.75                N/A       19.00-20.00

(i)As of January 2020 for series 2018-3 and 2018-4, and as of
October 2020 for the other series.
(ii)As of June 2021.

CNL exp.--Cumulative net loss expectations.
N/A–-Not applicable.

Each transaction contains a sequential principal payment structure
in which the notes are paid principal by seniority. Each
transaction also has credit enhancement in the form of a
nonamortizing reserve account, overcollateralization, subordination
for the higher-rated tranches, and excess spread. Each
transaction's overcollateralization is structured to build over
time to its target (as a percentage of the current pool balance)
and then amortize equal to a percentage of the outstanding
collateral, subject to a floor equal to a certain percentage of the
initial receivables. The overcollateralization and reserve accounts
for each of the transactions are currently at the specified target
or floor, and each class' credit support continues to increase as a
percentage of the amortizing collateral balance.

In addition, the overcollateralization for each transaction prior
to series 2019-4 can step up to a higher target
overcollateralization level if certain cumulative net loss (CNL)
triggers are breached. Overcollateralization step-up tests occur
every three months and are curable on any following test dates if
the CNL rate is below the specified threshold. All series are
currently below their CNL trigger levels.

  Table 3
  Hard Credit Support (%)(i)
                             Total hard    Current total hard
                         credit support        credit support
  Series      Class         at issuance(ii)     (% of current)(ii)
  2017-1      D                    7.50                 32.49
  2017-2      D                    6.75                 26.41
  2017-3      C                   14.75                 65.26
  2017-3      D                    7.00                 24.52
  2018-1      D                   12.30                 47.19
  2018-1      E                    7.30                 23.66
  2018-2      D                   14.75                 51.46
  2018-2      E                    7.30                 22.12
  2018-3      C                   30.50                101.11
  2018-3      D                   15.00                 49.33
  2018-3      E                    7.75                 25.12
  2018-3      F                    5.00                 15.93
  2018-4      C                   30.75                 94.89
  2018-4      D                   14.75                 45.04
  2018-4      E                    7.30                 21.83
  2019-1      C                   31.25                 86.81
  2019-1      D                   15.80                 45.13
  2019-1      E                    7.00                 21.39
  2019-2      C                   29.75                 75.48
  2019-2      D                   13.75                 37.90
  2019-2      E                    6.00                 19.70
  2019-3      B                   44.25                 99.15
  2019-3      C                   29.75                 68.83
  2019-3      D                   13.75                 35.38
  2019-3      E                    6.00                 19.18
  2019-4      B                   43.90                 91.39
  2019-4      C                   29.20                 63.31
  2019-4      D                   13.00                 32.35
  2019-4      E                    5.50                 18.02
  2020-1      B                   43.90                 81.21
  2020-1      C                   29.20                 56.48
  2020-1      D                   13.00                 29.23
  2020-1      E                    5.50                 16.61
  2020-2      A                   59.15                 96.41
  2020-2      B                   46.05                 77.24
  2020-2      C                   31.70                 56.24
  2020-2      D                   22.10                 42.19
  2020-2      E                   11.85                 27.19

(i)As of the June 2021 distribution date.
(ii)Calculated as a percentage of the total gross receivable pool
balance, which consists of a reserve account,
overcollateralization, and, if applicable, subordination. Excess
spread is excluded from the hard credit support and can also
provide additional enhancement.

We incorporated an analysis of the current hard credit enhancement
compared to the expected remaining expected cumulative net loss for
those classes where hard credit enhancement alone without credit to
the expected excess spread was sufficient, in our view, to upgrade
the notes to or affirm the notes at 'AAA (sf)'. For other classes,
we incorporated a cash flow analysis to assess the loss coverage
level and liquidity risks related to payment of timely interest and
full principal by legal final maturity, giving credit to stressed
excess spread. Our various cash flow scenarios included
forward-looking assumptions on recoveries, timing of losses, and
voluntary absolute prepayment speeds that we believe are
appropriate, given each transaction's performance to date. In
addition to our break-even cash flow analysis, we also conducted a
base-case analysis to assess the expected loss coverage levels over
time and sensitivity analyses for these series to determine the
impact that a moderate ('BBB') stress scenario would have on our
ratings if losses began trending higher than our revised loss
expectation.

In our view, the results demonstrated that all of the classes have
adequate credit enhancement at the current rating levels. We will
continue to monitor the performance of the outstanding transactions
to ensure that the credit enhancement remains sufficient, in our
view, to cover our CNL expectations under our stress scenarios for
each of the rated classes.

  RATINGS RAISED

  Exeter Automobile Receivables Trust

                              Rating
  Series        Class     To           From
  2017-1        D         AAA (sf)     BBB+ (sf)
  2017-2        D         AAA (sf)     BBB- (sf)
  2017-3        C         AAA (sf)     AA- (sf)
  2017-3        D         A+ (sf)      BB+ (sf)
  2018-1        D         AAA (sf)     A (sf)
  2018-1        E         A (sf)       BB+ (sf)
  2018-2        D         AAA (sf)     A (sf)
  2018-2        E         BBB+ (sf)    BB+ (sf)
  2018-3        C         AAA (sf)     AA+ (sf)
  2018-3        D         AA (sf)      A- (sf)
  2018-3        E         BBB (sf)     BBB- (sf)
  2018-3        F         BB (sf)      BB- (sf)
  2018-4        C         AAA (sf)     AA (sf)
  2018-4        D         AA (sf)      A- (sf)
  2018-4        E         BBB+ (sf)    BB+ (sf)
  2019-1        D         AA- (sf)     BBB+ (sf)
  2019-1        E         BBB (sf)     BB (sf)
  2019-2        C         AAA (sf)     AA- (sf)
  2019-2        D         A (sf)       BBB+ (sf)
  2019-2        E         BBB- (sf)    BB (sf)
  2019-3        C         AAA (sf)     AA- (sf)
  2019-3        D         A (sf)       BBB+ (sf)
  2019-3        E         BBB- (sf)    BB (sf)
  2019-4        B         AAA (sf)     AA (sf)
  2019-4        C         AAA (sf)     A (sf)
  2019-4        D         A- (sf)      BBB (sf)
  2019-4        E         BB+ (sf)     BB (sf)
  2020-1        B         AAA (sf)     AA (sf)
  2020-1        C         AA (sf)      A (sf)
  2020-1        D         A- (sf)      BBB (sf)
  2020-1        E         BB+ (sf)     BB (sf)
  2020-2        B         AAA (sf)     AA (sf)
  2020-2        C         AA (sf)      A (sf)
  2020-2        D         A+ (sf)      BBB (sf)
  2020-2        E         BBB (sf)     BB (sf)

  RATINGS AFFIRMED

  Exeter Automobile Receivables Trust

  Series        Class     Rating
  2019-1        C         AAA (sf)
  2019-3        B         AAA (sf)
  2020-2        A         AAA (sf)



[*] S&P Takes Various Actions on 17 Collegiate Student Loan Trusts
------------------------------------------------------------------
S&P Global Ratings raised the ratings on three classes, lowered the
ratings on three classes, placed the ratings for eight classes on
CreditWatch positive, and affirmed the ratings on 11 classes from
National Collegiate Student Loan Trusts (12 discrete trusts and
five grantor trusts), all collateralized by private student loans
issued between 2003 and 2007. The remaining 21 ratings were
previously lowered to 'D (sf)' because the affected classes
breached their subordinate interest triggers and missed receiving
timely interest payments. The review excludes the series 2007-3,
2007-4, and master trust I that were recently reviewed.

S&P said, "The rating actions reflect our views regarding
collateral performance and associated credit enhancement levels.
Collateral performance since the last review has remained stable.
The pace of increase in cumulative defaults continues to decline,
and the percentage of loans that are in current repayment status
has increased. As a result, credit enhancement levels for some of
the classes of notes has stabilized or increased. Today's rating
actions also considered the trust's relevant structural
features--in particular, each trust's cost of funds, capital
structure, payment waterfalls, available credit enhancement, and
operational risk provisions.

"We have received notices that litigation between the transaction
parties is still ongoing. In our view, the servicer and special
servicer for these transactions are key transaction parties that
perform roles that affect the collateral's performance. At this
time, there is uncertainty as to how the resolution of the
litigation will affect the transactions and the roles of their
related servicers. In applying our operational risk criteria
framework, this uncertainty impacted our assessment of the maximum
potential rating. We have assessed the maximum rating on the notes
to be limited to the 'BB' category."

TRUST PERFORMANCE

Since S&P's last surveillance review, the pace of increasing
cumulative defaults for all 17 trusts has slowed. Additionally, the
percentage of loans in repayment that are currently making payments
have increased. The performance, in terms of the pace of defaults
and the percentage of loans in repayment, indicates that the trusts
are likely past their peak default periods.

The historical impact of poor collateral performance, as measured
by high levels of realized cumulative net losses, has led to
significant under-collateralization for all of the trusts. Based on
the information in the latest servicer report, total parity for all
trusts is in the range of 49%-80%. However, class parity for almost
all of the highest-priority notes that are currently receiving
principal payments have increased substantially since our last
review. For series 2004-1 and 2006-2, the class parity for the
highest-priority notes (class A-4 for both transactions) has
declined since our last review.

STRUCTURAL FEATURES

The reserve accounts for each of the trusts are currently at their
respective floors or are amortizing toward their floors. The
reserve accounts are available to pay note interest (except for the
interest on subordinate classes that have been reprioritized) and
fees, as well as principal at final maturity.

In addition to subordination of the lower classes of notes in each
trust, all of the trusts except for series 2003-1 and 2004-1 are
supported by interest reprioritization triggers. The triggers are
generally based on a cumulative default threshold or parity levels.
When a class's interest reprioritization trigger is breached, the
interest payment to that class will become subordinate to principal
payments of the most senior classes until targeted parity levels
are reached.

At issuance, each of the trusts were structured to provide excess
spread over the transaction's life as additional credit
enhancement. Excess spread levels have been under pressure for each
trust, primarily because of under-collateralization. Additionally,
the series 2003-1 and 2004-1 transactions contain higher-cost
auction-rate notes. The coupons on the auction-rate notes have been
based on the maximum rate definitions in the indentures (generally
LIBOR plus a rating dependent margin) since the auction-rate market
failed.

RATIONALE

The grantor trusts are pass-through structures, and the ratings on
the certificates issued out of the related grantor trusts are
linked to the credit quality of the underlying notes repackaged
from the discrete trust.

The discrete trusts are impaired by substantial
under-collateralization levels due primarily to historical loss
performance. However, the credit enhancement as measured by class
parity has increased for current-paying senior notes in most of the
trusts due to recent improvement in collateral performance and
continued deleveraging. Additionally, the senior notes for trusts
with subordinate note interest triggers are generally able to
absorb greater losses than trusts without subordinate note
triggers. As discussed above, when an interest trigger is breached,
available funds in the trust's payment waterfall are used to make
principal payments to the senior notes before paying interest to
the subordinate notes.

S&P said, "We have placed the ratings for eight classes of notes on
CreditWatch with positive implications based on our review of the
growth in available credit enhancement relative to our expected
remaining net losses. This includes two classes in the 'CCC'
category discussed below. At the same time, we raised the ratings
on the class A-5-1 and A-5-2 from NCF Grantor Trust 2005-3 to 'BB
(sf)+' based on our review of their credit metrics as compared to
similar classes at the time of the last review. This is the maximum
rating for the notes given our operational risk assessment
discussed above. We also raised the ratings on A-5 class from
2006-3 series to 'BB (sf)' based on our review of the credit
metrics as compared to similar classes as the time of the last
review. We affirmed the 'BB (sf)+' ratings on four classes, two
from NCF Grantor Trust 2004-2 and two from NCF Grantor Trust
2005-1, despite their growth in available credit enhancement since
our last review due to the rating maximum imposed from our
operational risk assessment.

"Twelve classes were affected by the application of our criteria
for assigning 'CCC' and 'CC' ratings. The criteria states that we
rate an issuer or issue 'CC' when we expect default to be a virtual
certainty, regardless of the time to default. Accordingly, the 'CC
(sf)' ratings on nine classes reflect our belief that the classes
will default even under optimistic collateral performance scenarios
over a longer period of time based on their substantial
under-collateralization and their declining trend in hard
enhancement (despite recent improvements in collateral
performance). The 'CCC (sf)' rating on the class B notes for series
2005-1 reflects our view that the notes may still be vulnerable to
non-payment even though the class is no longer
under-collateralized. The class B notes for series 2004-2 and class
A-4 notes for series 2007-2 were previously rated in the 'CCC'
category, but we have placed them on CreditWatch positive due to
their growth in credit enhancement relative to our expected
remaining net losses.

"We previously lowered our ratings to 'D (sf)' on 21 of the class
B, C, and D notes from the discrete trusts because the affected
classes stopped receiving interest payments after their subordinate
interest triggers were breached (which occurs when the class senior
in the capital structure becomes under-collateralized). While some
of the classes have since started to receive interest payments due
to the increase in parity of the class senior in the capital
structure, we are not raising the ratings of these classes from 'D
(sf)' because we believe a further default is virtually certain
based on the current level of under-collateralization.

"We will continue to monitor the ongoing performance of these
trusts. In particular, we will continue to review available credit
enhancement, which is primarily a function of the pace of defaults,
principal amortization, excess spread, and the ongoing disputes
between the transaction parties."

  RATINGS RAISED

  NCF Grantor Trust 2005-3
  Series 2005-3
                    Rating
  Class      To               From
  A-5-1      BB+ (sf)         BB (sf)
  A-5-2      BB+ (sf)         BB (sf)

  National Collegiate Student Loan Trust 2006-3 (The)
  Series 2006-3
                    Rating
  Class      To               From
  A-5        BB (sf)          BB- (sf)


  RATINGS LOWERED

  National Collegiate Student Loan Trust 2004-1 (The)
  Series 2004-1
                    Rating
  Class      To               From
  A-4        CC (sf)          CCC (sf)

  NCF Grantor Trust 2004-1
  Series 2004-1
                    Rating
  Class      To               From
  A-1        CC (sf)          CCC (sf)  
  A-2        CC (sf)          CCC (sf)  


  RATINGS ON CREDIT WATCH POSITIVE

  National Collegiate Student Loan Trust 2003-1 (The)
  Series 2003-1
                    Rating
  Class      To                From
  A-7        B- (sf) CW Pos     B- (sf)

  National Collegiate Student Loan Trust 2004-2 (The)
  Series 2004-2
                    Rating
  Class      To                From
  B          CCC+ (sf) CW Pos  CCC+ (sf)

  National Collegiate Student Loan Trust 2006-1 (The)
  Series 2006-1
                    Rating
  Class      To                From
  A-5        B (sf) CW Pos     B (sf)

  National Collegiate Student Loan Trust 2006-4 (The)
  Series 2006-4
                    Rating
  Class      To                From
  A-4        B+ (sf) CW Pos    B+ (sf)

  National Collegiate Student Loan Trust 2007-1 (The)
  Series 2007-1
  Class             Rating
  Class      To                From
  A-4        B- (sf) CW Pos    B- (sf)

  National Collegiate Student Loan Trust 2007-2 (The)
  Series 2007-2
                    Rating
  Class      To                From
  A-4        CCC (sf) CW Pos   CCC (sf)

  NCF Grantor Trust 2005-2
  Series 2005-2
                    Rating
  Class      To               From
  A-5-1      B (sf) CW Pos    B (sf)
  A-5-2      B (sf) CW Pos    B (sf)


  RATINGS AFFIRMED

  National Collegiate Student Loan Trust 2003-1 (The)
  Series 2003-1
  Class      Rating
  B-1        CC (sf)      
  B-2        CC (sf)      

  National Collegiate Student Loan Trust 2004-1 (The)
  Series 2004-1
  Class      Rating
  B-1 ARC    CC (sf)      
  B-2 ARC    CC (sf)      

  National Collegiate Student Loan Trust 2004-2 (The)
  Series 2004-2
  Class      Rating
  C          D (sf)      

  National Collegiate Student Loan Trust 2005-1 (The)
  Series 2005-1
  Class      Rating
  B          CCC (sf)
  C          D (sf)      

  National Collegiate Student Loan Trust 2005-2 (The)
  Series 2005-2
  Class      Rating
  B          D (sf)      
  C          D (sf)      

  National Collegiate Student Loan Trust 2005-3
  Series 2005-3
  Class      Rating
  B          CC (sf)
  C          D (sf)      

  National Collegiate Student Loan Trust 2006-1 (The)
  Series 2006-1
  Class      Rating
  B          D (sf)      
  C          D (sf)      

  National Collegiate Student Loan Trust 2006-2 (The)
  Series 2006-2
  Class      Rating
  A-4        CC (sf)
  B          D (sf)      
  C          D (sf)      

  National Collegiate Student Loan Trust 2006-3 (The)
  Series 2006-3
  Class      Rating
  B          D (sf)      
  C          D (sf)      
  D          D (sf)      

  National Collegiate Student Loan Trust 2006-4 (The)
  Series 2006-4
  Class      Rating
  B          D (sf)      
  C          D (sf)      
  D          D (sf)      

  National Collegiate Student Loan Trust 2007-1 (The)
  Series 2007-1
  Class      Rating
  B          D (sf)      
  C          D (sf)      
  D          D (sf)      

  National Collegiate Student Loan Trust 2007-2 (The)
  Series 2007-2
  Class      Rating
  B          D (sf)      
  C          D (sf)      
  D          D (sf)      

  NCF Grantor Trust 2004-2
  Series 2004-2
  Class      Rating
  A-1        BB+ (sf)
  A-2        BB+ (sf)

  NCF Grantor Trust 2005-1
  Series 2005-1
  Class      Rating
  A-1        BB+ (sf)
  A-2        BB+ (sf)

  CW Pos--CreditWatch positive.



[*] S&P Takes Various Actions on 46 Classes from Nine US CLO Deals
------------------------------------------------------------------
S&P Global Ratings took various rating actions on 46 classes of
notes from nine U.S. cash flow CLO transactions. The affected
ratings include 13 that were placed on CreditWatch with positive
implications on April 16, 2021, following paydowns to the senior
notes. S&P raised its our ratings on 13 classes and removed them
from CreditWatch. At the same time, S&P raised nine of the ratings
that were not on CreditWatch and affirmed the remaining 24.

A list of Affected Ratings can be viewed at:

           https://bit.ly/3isx6qL

The nine transactions in this review all had at least one class
that was placed on CreditWatch positive following an increase in
their credit support, primarily due to paydowns. The rating actions
resolved these CreditWatch placements.

The CLOs have all exited their reinvestment period and are paying
down the notes in the order specified in their respective
documents. CLOs in their amortization phase possess dynamics that
can affect the analysis, such as paydowns that can increase the
credit support to the senior portion of the capital structure.
However, the benefit of this can be offset by increased
concentration risk. In some instances, the ratings were raised by
multiple rating categories.

S&P said, "The rating actions followed the application of our
global corporate CLO criteria and our credit and cash flow analysis
of each transaction. Our analysis of the transactions entailed a
review of their performance, and the ratings list below highlights
key performance metrics behind specific rating changes.

"In line with our criteria, our cash flow scenarios applied
forward-looking assumptions on the expected timing and pattern of
defaults, and recoveries upon default, under various interest rate
and default scenarios. Our analysis also considered the
transactions' ability to pay timely interest and/or ultimate
principal to each of the rated classes. The results of the cash
flow analysis and other qualitative factors, as applicable,
demonstrated that the rated outstanding classes have adequate
credit enhancement available at the current rating levels following
the rating actions, in our view."

While each class' indicative cash flow results were a primary
factor, S&P also incorporated various other considerations into its
decisions to raise, lower, affirm, or limited the ratings when
reviewing the indicative ratings suggested by its projected cash
flows. These considerations included:

-- Forward-looking scenarios for 'CCC' and 'CCC-' rated
collateral, as well as collateral with stressed market values;

-- Existing subordination or overcollateralization and recent
trends;

-- The cushion available for coverage ratios and comparative
analysis with other CLO classes with similar ratings;

-- Current concentration levels;

-- The risk of imminent default; and

-- Additional sensitivity runs to account for any of the above.

S&P's ratings on some classes were constrained by the application
of our largest-obligor default test, which is a supplemental stress
test included as part of its corporate CLO criteria. The test is
intended to address event and model risks that might be present in
rated transactions.

The upgrades primarily reflect the paydowns to the senior classes
and the resulting increase in credit support. The ratings affirmed
at the 'CCC' rating category or raised from the 'CCC' rating
category reflect our forward-looking analysis of existing 'CCC'
and/or 'CCC-' exposure, and the classes' vulnerability and
dependency on favorable market conditions.

The affirmations also indicate S&P's view that the current credit
enhancement available to those classes is still commensurate with
the current ratings.

S&P is aware that some CLO equity investors of Ocean Trails CLO IV,
one of the transactions included in the rating action, intend to
optionally redeem this transaction.

S&P will continue to review whether the ratings assigned to the
notes remain consistent with the credit enhancement available to
support them and take further rating actions as we deem necessary.



[*] S&P Takes Various Actions on 87 Classes from 29 US RMBS Deals
-----------------------------------------------------------------
S&P Global Ratings completed its review of 87 ratings from 29 U.S.
RMBS transactions issued between 2004 and 2007. All of these
transactions are backed by subprime collateral. The review yielded
42 upgrades, one downgrade, and 44 affirmations.

A list of Affected Ratings can be viewed at:

           https://bit.ly/2UbZ95u

Analytical Considerations

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 and/or structural
characteristics, and their potential effects on certain classes.
Some of these considerations may include:

-- Factors related to the COVID-19 pandemic;

-- Collateral performance or delinquency trends;

-- Available subordination and/or overcollateralization;

-- Expected short duration; and

-- Historical interest shortfalls or missed interest payments.

Rating Actions

The rating changes reflect S&P's opinion regarding the associated
transaction-specific collateral performance and/or structural
characteristics, and/or reflect the application of specific
criteria applicable to these classes.

S&P raised two ratings from two transactions by six and five
notches, respectively, due to increased credit support, as stated
below:

-- Class M-5 from RAMP Series 2005-EFC2 Trust was raised to 'AA
(sf)' from 'BBB (sf)' and its credit support increased to 80.69% in
May 2021 from 62.02% in December 2019; and

-- Class M-5 from RASC Series 2005-KS9 Trust was raised to 'BB+
(sf)' from 'B- (sf)' and its credit support increased to 59.62% in
May 2021 from 51.96% in June 2020.

S&P said, "We raised our rating on RASC Series 2007-KS4 Trust's
class A-3 certificates to 'BB (sf)' from 'CCC (sf)' due to its
expected short duration. Based on the classes' average recent
principal allocation, this class is projected to pay down in a
short period of time relative to projected loss timing, which
limits its exposure to potential losses.

"Additionally, we raised our rating on Park Place Securities Inc.,
series 2005-WCH1's class M-5 certificates to 'CCC (sf)' from 'D
(sf)'. This class was previously downgraded to 'D (sf)' because of
missed interest payments. These missed interest payments have been
fully reimbursed and interest payments have resumed in accordance
with the original terms.

"The ratings affirmations reflect our opinion that our projected
credit support and collateral performance on these classes have
remained relatively consistent with our prior projections."



[*] S&P Takes Various Actions on Four Classes from Two US RMBS Deal
-------------------------------------------------------------------
S&P Global Ratings completed its review of four classes from two
U.S. RMBS re-securitized real estate mortgage investment conduits
(re-REMIC) issued in 2006 and 2009. The review yielded two
upgrades, one downgrade, and one affirmation.

Analytical Considerations

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:

-- Underlying collateral l performance or delinquency trends;

-- Available subordination and/or overcollateralization; and

-- Payment priority.

Rating Actions

S&P said, "The rating changes reflect our view of the associated
transaction-specific collateral performance, structural
characteristics, and/or applicable criteria. See the ratings list
below for the specific rationales associated with the classes with
rating transitions.

"The affirmations reflect our view that our projected credit
support and collateral performance on these classes have remained
relatively consistent with our prior projections."

  Ratings List

  ISSUER NAME   
                                   RATING
     SERIES   CLASS    CUSIP     TO      FROM       MAIN
                                                    RATIONALE
  Citigroup Mortgage Loan Trust 2009-10

     2009-10  1A1   17316AAA8  AA+ (sf)  AA+ (sf)

  Citigroup Mortgage Loan Trust 2009-10

     2009-10  1A2   17316AAB6  B+ (sf)   BB+ (sf)   Underlying
                                                    bond
                                                    performance.

  CWHEQ Revolving Home Equity Loan Resecuitization Trust

     2006-RES 04-R-1a 23242YAU9 BBB+ (sf) BB+ (sf)  Underlying
                                                    bond   
                                                    performance.

  CWHEQ Revolving Home Equity Loan Resecuitization Trust

     2006-RES 04-R-1b  23242YAV7 BBB+ (sf)BB+ (sf)  Underlying
                                                    bond
                                                    performance.



                            *********

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