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

              Sunday, January 20, 2019, Vol. 23, No. 19

                            Headlines

BAYVIEW COMMERCIAL 2003-2: Moody's Cuts IO Debt Rating to Caa1
BEAR STEARNS 2003-TOP10: Fitch Hikes Class N Certs Rating to B-sf
BEAR STEARNS 2004-PWR5: Fitch Affirms Dsf Rating on Class N Certs
BEAR STEARNS 2004-PWR6: S&P Cuts Class M Certs Rating to CCC
BLACK DIAMOND 2013-1: S&P Affirms BB Rating on Class D Notes

BLADE ENGINE: Fitch Lowers Ratings on 2 Debt Tranches to CCC
CD 2017-CDE: Fitch Affirms B-sf Rating on $14.7MM Class F Certs
COBALT CMBS 2007-C3: S&P Lowers Class C Certs Rating to D
COMM 2012-LC4: Fitch Cuts $1.8MM Class F Certs Rating to CCCsf
CPS AUTO 2019-A: DBRS Assigns Prov. BB Rating on Class E Notes

CPS AUTO 2019-A: S&P Gives Prelim BB-(sf) Rating on $25.7MM E Notes
CREDIT SUISSE 2008-C1: S&P Cuts Ratings on 3 Certs Classes to D
DEUTSCHE BANK 2015-CCRE22: Fitch Affirms Class E Certs at BB-sf
GREENWICH CAPITAL 2004-GG1: Fitch Affirms Csf Rating on 2 Tranches
GS MORTGAGE 2013-GCJ12: S&P Lowers Class F Certs Rating to B+

GSRPM MORTGAGE 2004-1: Moody's Lowers Class B-1 Debt Rating to B2
JP MORGAN 2013-C10: Fitch Affirms B Rating on $12.7MM Class F Notes
LB-UBS COMMERCIAL 2007-C6: Moody's Affirms Class A-J Certs at B2
MAGNETITE LTD IX: Moody's Affirms Ba3 Rating on Class D Notes
MORGAN STANLEY 2007-IQ15: Fitch Hikes Rating on $33.4MM B Debt to B

MORGAN STANLEY 2016-UBS9: Fitch Affirms B-sf Rating on Cl. F Certs
NEW RESIDENTIAL 2019-NQM1: DBRS Gives (P)BB Rating on B-1 Notes
NEW RESIDENTIAL 2019-NQM1: S&P Gives Prelim B Rating on B-2 Notes
NYT 2019-NYT: Fitch to Rate $24.4MM Class F Certificates BB-sf
OFSI FUND V: S&P Affirms B+ Rating on Class B-3L Notes

ONEMAIN FINANCIAL 2019-1: DBRS Gives (P)BB Rating on E Notes
ONEMAIN FINANCIAL 2019-1: S&P Assigns Prelim BB Rating on E Notes
REALT 2015-1: Fitch Affirms BB Rating on C$3.8MM Class F Certs
TRAPEZA CDO XI: Moody's Hikes Class B Notes Rating to Ba1
UBS COMMERCIAL 2012-C1: Fitch Affirms Bsf Rating on Class F Certs

WELLS FARGO 2011-C4: Fitch Lowers $18.5MM Cl. F Certs Rating to BB
WELLS FARGO 2019-1: Moody's Assigns (P)Ba1 Rating on Class B-4 Debt
[*] Moody's Takes Action on $162.9MM of RMBS Issued 2004-2006
[*] Moody's Takes Action on $195MM Subprime RMBS Issued 2006-2007
[*] S&P Lowers Ratings on 10 Classes From Four U.S. RMBS Deals

[*] S&P Takes Various Actions on 15 Classes From Nine US RMBS Deals
[*] S&P Takes Various Actions on 54 Classes From 19 US RMBS Deals

                            *********

BAYVIEW COMMERCIAL 2003-2: Moody's Cuts IO Debt Rating to Caa1
--------------------------------------------------------------
Moody's Investors Service downgraded one interest-only tranche from
the 2003-2 transaction, reflecting the performance of the
transaction. The transaction is issued by Bayview Commercial Asset
Trust 2003-2 and is backed by small business loans secured
primarily by small commercial real estate properties in the U.S.
owned by small businesses and investors.

The complete rating action is as follow

Issuer: Bayview Commercial Asset Trust 2003-2

Cl. IO, Downgraded to Caa1 (sf); previously on Jan 14, 2016
Downgraded to B3 (sf)

RATINGS RATIONALE

The downgrade is primarily due to the increase in cumulative net
losses, which are currently at 5.05% as of the December
distribution date.

PRINCIPAL METHODOLOGY

The methodologies used in this rating were "Moody's Global Approach
to Rating SME Balance Sheet Securitizations" published in August
2017 and "Moody's Approach to Rating Structured Finance
Interest-Only (IO) Securities" published in June 2017.

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

Up

The IO class may be subject to ratings upgrades if there is an
improvement in the credit quality of its collateral pool, subject
to the rating limits and provisions of the IO methodology.

Down

The IO class may be subject to ratings downgrades if there is a
decline in credit quality of referenced collateral pools, subject
to the rating limits and provisions of the IO methodology.


BEAR STEARNS 2003-TOP10: Fitch Hikes Class N Certs Rating to B-sf
-----------------------------------------------------------------
Fitch Ratings has upgraded one class of Bear Stearns Commercial
Mortgage Securities Trust (BSCMS), series 2003-TOP10 commercial
mortgage pass-through certificates

KEY RATING DRIVERS

Increased Credit Enhancement: The upgrade reflects the increased
credit enhancement after better than expected recoveries on the
largest remaining real estate owned (REO) asset, Power Plaza
Shopping Center (56.9% of the pool balance at the prior rating
action). During the prior rating action, Fitch modeled a 57% loss
severity on the REO asset, which would have affected class N.
However, the asset was liquidated without a loss in October 2018,
resulting in a significant improvement in credit enhancement.

Concentrated Pool: Due to the highly concentrated nature of the
pool, Fitch performed a sensitivity analysis, which grouped the
remaining loans based on loan structural features, collateral
quality and performance and ranked them by their perceived
likelihood of repayment. The ratings reflect this sensitivity
analysis

Only four of the original 171 loans remain, all of which are fully
amortizing. As of the December 2018 distribution date, the pool's
aggregate principal balance has been reduced by 99.5% to $6.1
million from $1.2 billion at issuance. There have been $8.5 million
(0.7% of the original pool balance) in realized losses. There are
no loans in special servicing, no Fitch Loans of Concern, and no
loans on the servicer's watchlist. No classes have interest
shortfalls.

Resolution of REO Asset: Loss expectations for the pool have
declined after the largest remaining asset, Power Plaza Shopping
Center, was paid in full. The REO asset was a 112,155 sf shopping
center in Vacaville, CA that transferred to special servicing in
August 2014 for imminent default. The asset went REO in April 2016
and the special servicer began working to lease up vacant space and
stabilize the property. In October 2018, the asset was sold and the
trust was repaid in full.

All four of the remaining loans are fully amortizing and have been
paid down by at least 65% since issuance. The weighted-average
Fitch LTV for these loans is 16.9% and the weighted-average DSCR is
2.16x. The remaining loans consist of two retail centers in
secondary markets, a NNN-leased Walgreens in Katy, TX, and a
161-unit mobile home park in Ventura County, CA.

Maturity Profile: One loan (26%) matures in 2022 and three loans
(74%) mature in 2023.

RATING SENSITIVITIES

The Rating Outlook on class N has been assigned as Stable due to
increased credit enhancement, continued amortization, and the
stable performance of the remaining loans. Future upgrades are
possible with continued amortization or if loans are defeased.
Downgrades are unlikely due to the strong credit profile of the
remaining loans.

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

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

Fitch has upgraded the following rating:

  -- $2.5 million class N to 'BBsf' from 'Csf'; Outlook Stable
Assigned.

Fitch does not rate the $3.6 million class O. Classes A-1 through M
have been paid in full. Fitch previously withdrew the ratings on
the interest-only classes X-1 and X-2.


BEAR STEARNS 2004-PWR5: Fitch Affirms Dsf Rating on Class N Certs
-----------------------------------------------------------------
Fitch Ratings has upgraded two and affirmed seven classes of Bear
Stearns Commercial Mortgage Securities Trust, Commercial Mortgage
Pass-Through Certificates, series 2004-PWR5.

KEY RATING DRIVERS

Significant Defeasance: The two largest loans in the pool (85.1% of
the pool) are fully defeased. The upgrade of class L to 'AAAsf'
reflects the class now being fully covered by defeased collateral,
after the payoff of New Castle Marketplace in November 2018 as well
as ongoing scheduled amortization.

As of the December 2018 distribution, the pool's aggregate
principal balance was reduced by 95.8% to $52.0 million from $1.233
billion at issuance. The defeased loans are scheduled to mature in
April 2019 resulting in the full payoff of classes F through L.
Class M is 16.7% covered by defeased collateral.

Stable Loss Expectations: The performance of the remaining pool
collateral, which consists of six fully amortizing loans (14.9%),
remains stable.

All remaining loans are current with none considered Fitch Loans of
Concern. The loans are secured by a parking garage (6.6%), four
retail or mixed use-retail properties (7.9%), and a mobile home
community (0.4%) primarily located in secondary markets. These
loans, which mature in 2019 (86%) and 2024 (14%), are significantly
de-leveraged with a weighted average Fitch stressed loan-to-value
ratio of 25.7%.

Concentrated Pool; Alternative Loss Consideration: The pool is
highly concentrated with only eight of the original 130 loans
remaining. Due to the concentrated nature of the pool, Fitch
performed a look-through analysis which grouped the remaining loans
based on the likelihood of repayment and credit characteristics.
The upgrade to class M was capped at 'BBBsf' to reflect the
collateral quality of the remaining pool.

RATING SENSITIVITIES

The Stable Outlooks on classes F through L reflect the significant
defeasance and expected payoff by April 2019. Classes F through L
are fully covered by defeased collateral. The Stable Outlook to
class M reflects the continued expected paydown to the class from
defeasance, loan payoffs and scheduled amortization. Further
upgrades to class M are possible with substantial paydown or
defeasance. Downgrade to the class is unlikely.

DUE DILIGENCE USAGE

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

Fitch has upgraded the following classes:

  -- $6.2 million class L to 'AAAsf' from 'Asf'; Outlook Stable;

  -- $4.6 million class M to 'BBBsf' from 'BBsf'; Outlook Stable.

Fitch has affirmed the following classes:

  -- $296,529 class F at 'AAAsf'; Outlook Stable;

  -- $9.3 million class G at 'AAAsf'; Outlook Stable;

  -- $18.5 million class H at 'AAAsf'; Outlook Stable;

  -- $4.6 million class J at 'AAAsf'; Outlook Stable;

  -- $4.6 million class K at 'AAAsf'; Outlook Stable;

  -- $3.9 million class N at 'Dsf'; RE 100%;

  -- $0 class P at 'Dsf'; RE 0%.

The class A-1, A-2, A-3, A-4, A-5, B, C, D and E certificates have
paid in full. Fitch does not rate the fully-depleted class Q
certificates. Fitch previously withdrew the ratings on the
interest-only class X-1 and X-2 certificates.


BEAR STEARNS 2004-PWR6: S&P Cuts Class M Certs Rating to CCC
------------------------------------------------------------
S&P Global Ratings lowered its rating on the class M commercial
mortgage pass-through certificates from Bear Stearns Commercial
Mortgage Securities Trust 2004-PWR6, a U.S. commercial
mortgage-backed securities (CMBS) transaction. In addition, S&P
affirmed its ratings on 10 classes from the same transaction.

The downgrade reflects class M's susceptibility to liquidity
interruption from the specially serviced and watchlist loans, as
well as credit support erosion that S&P anticipates will occur upon
the eventual resolution of the specially serviced Northway Plaza
Shopping Center loan ($2.5 million, representing 2.8% of the
collateral pool balance as of the Dec. 11, 2018, trustee remittance
report).

For the affirmations on the principal- and interest-paying
certificates, S&P's expectation of credit enhancement was in line
with the affirmed rating levels.

While available credit enhancement levels suggest positive rating
movements on classes H, J, K, and L, our analysis also considered
the susceptibility to reduced liquidity support from the specially
serviced Northway Plaza Shopping Center loan and refinancing risk
on the Plymouth Square Shopping Center loan ($21.8 million, 24.2%).
The Plymouth Square Shopping Center loan matures in May 2019 and is
on the master servicer's watchlist due to low reported occupancy,
which was 68.4%, according to the Sept. 26, 2018, rent roll.

S&P affirmed its 'AAA (sf)' rating on the class X-1 interest-only
(IO) certificates based on our criteria for rating IO securities.

TRANSACTION SUMMARY

As of the Dec. 11, 2018, trustee remittance report, the collateral
pool balance was $90.0 million, which is 8.4% of the pool balance
at issuance. The pool currently includes 12 loans, down from 95
loans at issuance. One loan is with the special servicer, two
($30.9 million, 34.3%) are on the master servicer's watchlist, and
four ($39.6 million, 44.0%) are defeased.

Excluding the defeased and specially serviced loans, S&P calculated
a 1.67x S&P Global Ratings weighted average debt service coverage
(DSC) and a 37.2% S&P Global Ratings weighted average loan-to-value
ratio using a 7.83% S&P Global Ratings weighted average
capitalization rate for the remaining performing loans.

To date, the transaction has experienced $13.6 million in principal
losses, or 1.3% of the original pool trust balance. S&P expects
losses to reach approximately 1.4% of the original pool trust
balance in the near term, based on losses incurred to date and
additional losses S&P expects upon the eventual resolution of the
specially serviced loan.

CREDIT CONSIDERATIONS

As of the Dec. 11, 2018, trustee remittance report, the Northway
Plaza Shopping Center loan was the sole loan with the special
servicer, C-III Asset Management LLC. The loan, which has a
reported foreclosure-in-process payment status, is secured by a
79,315-sq.-ft. retail property in Columbia, S.C. The loan was
transferred to the special servicer on Oct. 6, 2016, due to payment
default (net cash flow was not sufficient to cover the required
waterfall). The reported occupancy and net operating income DSC
were 53.3% and 0.36x, respectively, for the third quarter of 2018.
C-III stated that it is working on remediating environmental issues
at the property. The master servicer has deemed the loan
nonrecoverable. S&P expects a significant loss (greater than 60%)
upon its eventual resolution.

  RATING LOWERED

  Bear Stearns Commercial Mortgage Securities Trust 2004-PWR6
  Commercial mortgage pass-through certificates

                 Rating
  Class     To          From
  M         CCC (sf)    B- (sf)

  RATINGS AFFIRMED

  Bear Stearns Commercial Mortgage Securities Trust 2004-PWR6
  Commercial mortgage pass-through certificates

  Class     Rating

  C         AAA (sf)
  D         AAA (sf)
  E         AAA (sf)
  F         AAA (sf)
  G         AAA (sf)
  H         AA+ (sf)
  J         A+ (sf)
  K         BBB+ (sf)
  L         BB+ (sf)
  X-1       AAA (sf)


BLACK DIAMOND 2013-1: S&P Affirms BB Rating on Class D Notes
------------------------------------------------------------
S&P Global Ratings raised its ratings on the class A-2-R, B-R, and
C-R notes from Black Diamond CLO 2013-1 Ltd.

S&P said, "We also removed the class A-2-R and B-R ratings from
CreditWatch, where we placed them with positive implications on
Oct. 26, 2018. At the same time, we affirmed our 'AAA (sf)' and 'BB
(sf)' ratings on the class A-1-R and D notes, respectively, from
the same transaction."

The rating actions follow S&P's review of the transaction's
performance using data from the Dec. 5, 2018, trustee report.

The upgrades reflect the transaction's $112.18 million in paydowns
to the class A-1-R notes since S&P's July 17, 2017, rating actions.
These paydowns resulted in improved reported overcollateralization
(O/C) ratios since the June 7, 2017, trustee report, which S&P used
for its previous rating actions:

-- The class A O/C ratio improved to 147.67% from 131.06%.
-- The class B O/C ratio improved to 127.79% from 119.42%.
-- The class C O/C ratio improved to 116.21% from 112.05%.
-- The class D O/C ratio improved to 108.46% from 106.85%.

S&P said, "The collateral portfolio's credit quality has slightly
deteriorated since our last rating actions. Collateral obligations
with ratings in the 'CCC' category have increased, with $20.49
million reported as of the Dec. 5, 2018, trustee report, compared
with $11.84 million reported as of the June 7, 2017, trustee
report. However, despite the slightly larger concentrations in the
'CCC' category, the transaction has benefited from a drop in the
weighted average life due to underlying collateral's seasoning,
with 3.6 years reported as of the Dec. 5, 2018, trustee report,
compared with 4.7 years reported at the time of our last rating
action.

"The upgrades reflect the improved credit support at the prior
rating levels; the affirmations reflect our view that the credit
support available is commensurate with the current rating levels.

On a standalone basis, the results of the cash flow analysis
indicated a higher rating on the class C-R notes. However, because
of the transaction's increased concentration of 'CCC' rated
collateral obligations, and additional sensitivity runs that
considered the presence of assets trading at distressed prices,
S&P's limited the upgrade on this class to offset future potential
credit migration in the underlying collateral.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction as reflected in
the aforementioned 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. In addition, our analysis 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 all of the rated
outstanding classes have adequate credit enhancement available at
the rating levels associated with these 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 will take rating actions as we deem
necessary."

  RATINGS RAISED AND REMOVED FROM CREDITWATCH POSITIVE

  Black Diamond CLO 2013-1 Ltd.
                   Rating
  Class         To          From

  A-2-R         AAA (sf)     AA (sf)/Watch POS
  B-R           AA+ (sf)     A (sf)/Watch POS

  RATING RAISED
  Black Diamond CLO 2013-1 Ltd.
                   Rating
  Class         To          From
  C-R           A- (sf)     BBB (sf)

  RATINGS AFFIRMED
  Black Diamond CLO 2013-1 Ltd.
  Class         Rating
  A-1-R         AAA (sf)
  D             BB (sf)



BLADE ENGINE: Fitch Lowers Ratings on 2 Debt Tranches to CCC
------------------------------------------------------------
Fitch Ratings has downgraded Blade Engine Securitization LTD as
outlined below:

  -- Series A-1 to 'CCCsf' Recovery Estimate 60% from 'Bsf' Rating
Outlook Negative;

  -- Series A-2 to 'CCCsf' Recovery Estimate 60% from 'Bsf' Rating
Outlook Negative;

  -- Series B to 'Csf' Recovery Estimate 20% from 'CCsf'.

KEY RATING DRIVERS

The downgrade of the class A notes reflects the increasing LTV
levels, driven by a portfolio of engines with declining liquidity,
which have in turn resulted in engine sales proceeds below recent
appraised values. The downgrade also reflects the further potential
for decreased cash flow available to service the notes and the
results of Fitch's cash flow analysis. Under this analysis, the
class A notes are unable to pass Fitch's primary 'Bsf' modeling
scenario, but do receive approximately 60% of their outstanding
principal balance. Considering the transaction's performance to
date and the results of the cash flow modeling analysis, Fitch
considers the eventual default of the class A notes to be a real
possibility.

The downgrade of the class B notes reflects the inability of cash
flow to service the class, leading to continuous draws on the
Junior Cash Account. As the Junior Cash Account continues to be
depleted, class B is expected to miss interest payments sometime in
the next 12 months. Further, future principal payments to the class
are expected to be minimal and only come from engine sales
proceeds. As a result, the eventual default of the class B notes
appears inevitable.

Assumptions used in Fitch's cash flow modeling for the primary
'Bsf' scenario were unchanged from the prior review.

RATING SENSITIVITIES

Due to the correlation between the global economic conditions and
the airline industry, the ratings may be impacted by the strength
of the macro-environment over the remaining term of the
transaction. Global economic scenarios that are inconsistent with
Fitch's expectations could lead to further negative rating actions.
For example, the occurrence of an extended global recession of
significantly greater severity than the last two experienced, and
the resulting strain on aircraft engine lease cash flow could lead
to a downgrade of the notes.


CD 2017-CDE: Fitch Affirms B-sf Rating on $14.7MM Class F Certs
---------------------------------------------------------------
Fitch Ratings has affirmed all classes of CD 2017-CD3 Mortgage
Trust Commercial Mortgage Pass-Through Certificates, Series
2017-CD3.

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The affirmations reflect
the overall stable performance and loss expectations with no
material changes to pool metrics since issuance. There have been no
specially serviced loans since issuance.

The largest loan, 229 West 43rd Street Retail Condo (7.6% of pool),
was previously on the servicer's watchlist due to Guy's American
Bar & Kitchen (6.4% of NRA) vacating in December 2017 prior to its
November 2032 lease expiration, as well as OHM/Todd English Food
Hall (4.9%) terminating their lease prior to its July 2031 lease
expiration after failing to open by its rent commencement date.
Ribbon Worldwide re-leased all of the former Guy's American Bar &
Kitchen space with rent payments beginning in March 2018 through
February 2034. As of the June 2018 servicer provided rent roll,
Ribbon Worldwide's annual base rent was $144 per square foot (psf),
which is 21.4% higher than the previous tenant's base rent of $118
psf. Occupancy was 95.1% as of June 2018.

Minimal Change to Credit Enhancement: As of the December 2018
distribution date, the pool's aggregate balance has been reduced by
0.7% to $1.33 billion from $1.32 billion at issuance. All original
52 loans remain in the pool. Sixteen loans (51.4% of pool) are full
term interest-only, 23 loans (23.6%) are amortizing and the
remaining 13 loans (25%) are currently in their partial
interest-only period. Based on the scheduled balance at maturity,
the pool will pay down by 6.9%.

ADDITIONAL CONSIDERATIONS

Fitch Loan of Concern: Fitch designated one loan outside of the top
15 as a Fitch Loan of Concern. The Comfort Inn & Suites Pittsburgh
loan (0.8% of pool), which is secured by a 223-room limited service
hotel located in Pittsburgh, PA, has reported a significant decline
in occupancy to 38% as of TTM June 2018, compared to 64% at YE
2016. The borrower attributed the decline in performance to a
nearby office park that has lost several large businesses. NOI debt
service coverage ratio (DSCR) was 1.14x for TTM June 2018, compared
to 0.99x at YE 2017 and 2.51x at YE 2016.

Pool Concentration: The top 10 loans represent 52.8% of the pool.
The largest property type in the transaction is office,
representing 46.5% of the pool, followed by retail at 20.3%, hotel
at 15.5% and mixed-use at 10.4%.

RATING SENSITIVITIES

The Rating Outlooks for all classes remain Stable due to overall
stable collateral performance and no material changes since
issuance. Fitch does not foresee positive or negative ratings
migration unless a material economic or asset level event changes
the underlying transaction's portfolio-level metrics.

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

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

Fitch has affirmed the following ratings:

  -- $20.2 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $38.3 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $200 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $589.3 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $54.8 million class A-AB at 'AAAsf'; Outlook Stable;

  -- $78.1 million class A-S at 'AAAsf'; Outlook Stable;

  -- $61.9 million class B at 'AA-sf'; Outlook Stable;

  -- $63.5 million class C at 'A-sf'; Outlook Stable;

  -- $76.5 million(a) class D 'BBB-sf'; Outlook Stable;

  -- $35.8 million(a)(d) class E 'BB-sf'; Outlook Stable;

  -- $14.7 million class(a)(d) F 'B-sf'; Outlook Stable;

  -- $980.8 million(b) class X-A 'AAAsf'; Outlook Stable;

  -- $61.9 million(b) class X-B 'AA-sf'; Outlook Stable;

  -- $76.5 million(a)(b) class X-D 'BBB-sf'; Outlook Stable;

  -- $19 million(e) class V-A 'AAAsf'; Outlook Stable;

  -- $1.2 million(e) class V-B 'AA-sf'; Outlook Stable;

  -- $1.2 million(e) class V-C 'A-sf'; Outlook Stable;

  -- $1.5 million(e) class V-D 'BBB-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $60.2 million(a)(d) class G;

  -- $2.1 million(e) class V-E.

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

(b) Notional amount and interest only.

(c) Vertical credit risk retention interest representing 1.9% of
the pool balance (as of the closing date).

(d) Horizontal credit risk retention interest representing 3.18% of
the pool balance (as of the closing date).

(e) Exchangeable certificates.


COBALT CMBS 2007-C3: S&P Lowers Class C Certs Rating to D
---------------------------------------------------------
S&P Global Ratings lowered its rating to 'D (sf)' from 'CCC- (sf)'
on the class C commercial mortgage pass-through certificates from
Cobalt CMBS Commercial Mortgage Trust 2007-C3, a U.S. commercial
mortgage-backed securities (CMBS) transaction.

The downgrade reflects principal loss that impacted the class, as
detailed on the Dec. 17, 2018, trustee remittance report. According
to our policy and procedures, we will discontinue the 'D (sf)'
rating any time after it has been outstanding for at least 30
days.

The December 2018 trustee remittance report reported $75.8 million
in realized losses, which resulted from the liquidation of seven
specially serviced assets. The four-largest specially serviced
loans contributed $63.8 million of the loss to the trust. The
largest loan by balance, Zale Corporate Headquarters, liquidated at
a 60.5% loss severity of its $37.4 million beginning balance at
liquidation. Sheraton Suites Wilmington, DE ($33.3 million
beginning balance at liquidation), Lynnhaven North Shopping Center
($24.1 million), and Chant Portfolio – Pool 2 ($21.8 million) are
the second-, third-, and fourth-largest loans in the portfolio.
They liquidated at 47.8%, 69.2%, and 39.3% loss severity of their
respective beginning balances. The remaining three loans had a
combined realized loss of $12.0 million.

Consequently, classes D, E and F (classes D and F are currently
rated 'D (sf)', while class F is not rated by S&P Global Ratings)
experienced a 100% loss of their respective beginning balance,
while class C experienced a loss of $15.0 million of its beginning
balance (74.16%).


COMM 2012-LC4: Fitch Cuts $1.8MM Class F Certs Rating to CCCsf
--------------------------------------------------------------
Fitch Ratings has downgraded one class and affirmed seven classes
of German American Capital Corp.'s COMM 2012-LC4 commercial
mortgage pass-through certificates. Fitch has also revised the
Rating Outlook on class C to Negative from Stable.

KEY RATING DRIVERS

Increased Loss Expectations: Fitch's base case expected loss
reflects higher loss expectations on the Susquehanna Valley Mall
loan, which transferred to special servicing in March 2018 for
imminent monetary default. The loan is secured by a 628,063 square
foot (sf) regional mall located in Selinsgrove, PA. The property
suffered declines in performance due to the loss of anchors JC
Penney (collateral) in November 2015, Sears (non-collateral) in
March 2017, BonTon (collateral) in April 2018 and Weis Markets
(collateral) in October 2018, in addition to weak in-line sales.
The mall is anchored by Boscovs and is currently 69.4% occupied
with in-line sales of $298 per square foot at year-end (YE) 2017.
Per the special servicer, a receiver was appointed in October 2018
and they are currently pursuing foreclosure. In addition to the
Susquehanna Valley Mall, Fitch also remains concerned with Square
One Mall (13%), Puerto Rico Retail Portfolio (8%), Alamance
Crossing (7%) and Montebello Town Square (2%).

High Retail Concentration: Retail properties account for 60% of the
pool, an increase from 41% at issuance. Retail properties include
three (23%) regional malls and exposure to retailers Sears, Macy's,
JC Penney, Best Buy and Barnes and Noble. The majority of Fitch's
increased loss expectations in the base case and in the sensitivity
scenario are due to the larger retail properties within the top 15.


Improved Credit Enhancement: Credit enhancement has improved since
issuance due to ongoing amortization, loan payoffs and defeasance.
As of December 2018, the pool has paid down 26.5%, primarily due to
the September 2017 payoff of the sixth-largest loan in the pool
(Hartman Portfolio; $46.8 million). The majority of the pool, (28
loans, 81.1%) have been amortizing since issuance and the eighth
largest loan, Piatt Place (4.5%), is the only partial interest-only
loan in the pool and has been amortizing since 2014. The remaining
three loans (14.4%) are full-term interest only. Additionally, two
loans (8.0%) have been fully defeased.

Fitch Loans of Concern: Fitch has designated six loans (34.8%) as
FLOCs including five loans (32.8%) in the top 15, of which one
(3.7%) is specially serviced. The largest FLOC, Square One Mall is
secured by a 541,128 sf portion of a 928,667 sf two-story enclosed
regional mall located in Saugus, MA. The mall is shadow-anchored by
Sears and Macy's (both non-collateral), and features other major
tenants including Dick's Sporting Goods, Best Buy, BD's Furniture,
TJ Maxx, Old Navy, and H&M. The mall was flagged as a FLOC due to
exposure to troubled retailers, declining NOI and near-term roll.
The Sears box is owned by Seritage Growth Properties, and while the
store is not on recent store closing lists, it has consolidated to
operating on the first floor and the second floor is vacant. The
third largest tenant, BD Furniture (11%), has a lease expiring in
April 2019.

Puerto Rico Retail Portfolio is secured by four
cross-collateralized and cross-defaulted retail properties totaling
554,490 sf. It has been flagged as a FLOC and is currently on the
master servicer's watchlist due to the properties sustaining major
hurricane damage resulting from Hurricane Maria. Per the master
servicer, repairs have been fully completed at two of the four
properties and the borrower has received insurance proceeds.

Montebello Town Square is secured by a 251,489 sf retail center
located in Montebello, CA, built in 1992. At issuance, the property
was anchored by Sears, Toys 'R' Us, AMC Theatres and Petco. The
loan is currently on the master servicer's watchlist due to the
bankruptcy of two anchor tenants Toys 'R' Us 46,270 sf (18% GLA)
and Sears (42% GLA) which have vacated. Additionally, Sears filed
bankruptcy in October 2018 and announced in November this location
is on their list of store closings and will close in January 2019.


The two additional FLOCs each account for 2% of the pool. Hickory
Glen Apartments is secured by a multifamily property consisting of
129 units located in Springfield, IL. The loan is on the master
servicer's watchlist as the property's occupancy has declined to
75.6% as of June 2018 from 81.4% prior year. The most recent
reported DSCR as of June 2018 is 1.53x. The smallest FLOC, Wood
Forest Apartments (0.8%) is secured by a student housing property
consisting of 152 units located in Nacogdoches, TX. The loan was
previously specially serviced and returned to the master servicer
as a corrected loan in November 2018 and is currently on the master
servicer watchlist as it is being monitored for three consecutive
loan payments. The property is 62.5% occupied as of June 2018 with
a DSCR of 0.45x.

Alternative Loss Considerations: Fitch applied an additional
sensitivity scenario of a 25% loss severity on Square One Mall, 20%
on the Puerto Rico Retail Portfolio, 15% on Alamance Crossing, and
25% on Montebello Town Square all to reflect the potential for
outsized losses given lack of updated sales, exposure to weaker
anchors/troubled retailers, additional vacancy, loss of anchor
tenants and major hurricane damage/ongoing renovations. In
addition, Fitch applied a 100% loss on the Susquehanna Valley Mall
as it has transferred to special servicing and may become REO. The
sensitivity scenario also factored in the expected paydown of the
transaction from defeased loans. The Negative Rating Outlooks on
Classes C, D and E reflect this scenario.

RATING SENSITIVITIES

Rating Outlook Negative for classes C thru E indicate that future
downgrades to the classes are possible if the performance of the
larger Fitch Loans of Concern further deteriorates and/or
additional loans default. Classes D and below may be subject to
multiple notch downgrades if loans with increased loss assumptions
in Fitch's sensitivity test approach maturity without performance
improvement, or if these loans default and/or transfer to special
servicing. Ratings Outlooks for classes A-4 thru B remain Stable
due to sufficient credit enhancement and continued amortization and
defeasance. Upgrades are possible, and may occur with improved pool
performance and additional paydown or defeasance. However, upgrades
may be limited given the concentration of regional malls, as these
may have difficulty refinancing given declines in performance and a
potentially higher interest rate environment.

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

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

Fitch has downgraded and assigned a Recovery Estimate to the
following class:

  -- $11.8 million class F to 'CCCsf' from 'Bsf'; RE 100%.

Fitch has also affirmed and revised the Rating Outlooks on the
following classes:

  -- $409.5 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $93 million class A-M at 'AAAsf'; Outlook Stable;

  -- Interest-Only class X-A at 'AAA'; Outlook Stable;

  -- $44.7 million class B at 'AAsf'; Outlook Stable;

  -- $32.9 million class C at 'Asf'; Outlook to Negative from
Stable;

  -- $52.9 million class D at 'BBB-sf'; Outlook Negative;

  -- $15.3 million class E at 'BBsf'; Outlook Negative.

Classes A-1, A-2 and A-3 have paid in full. Fitch does not rate the
class G and HP certificates, or the interest-only class X-B.


CPS AUTO 2019-A: DBRS Assigns Prov. BB Rating on Class E Notes
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
notes to be issued by CPS Auto Receivables Trust 2019-A (CPS
2019-A):

-- $123,491,000 Class A Notes rated AAA (sf)
-- $40,015,000 Class B Notes rated AA (sf)
-- $35,245,000 Class C Notes rated A (sf)
-- $29,944,000 Class D Notes rated BBB (sf)
-- $25,705,000 Class E Notes rated BB (sf)

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

-- Transaction capital structure, proposed ratings and form and
sufficiency of available credit enhancement.

-- Credit enhancement will be in the form of
overcollateralization, subordination, amounts held in the reserve
fund and excess spread. Credit enhancement levels are sufficient to
support the DBRS-projected expected cumulative net loss assumption
under various stress scenarios.

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

-- The capabilities of Consumer Portfolio Services, Inc. (CPS)
with regard to originations, underwriting and servicing.

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

-- The CPS senior management team has considerable experience and
a successful track record within the auto finance industry, having
managed the company through multiple economic cycles.

-- The quality and consistency of provided historical static pool
data for CPS originations and performance of the CPS auto loan
portfolio.

-- The May 29, 2014, settlement of the Federal Trade Commission
(FTC) inquiry relating to allegedly unfair trade practices.

-- CPS paid imposed penalties and restitution payments to
consumers.

-- CPS has made considerable improvements to the collections
process, including management changes, upgraded systems and
software as well as implementation of new policies and procedures
focused on maintaining compliance.

-- CPS will be subject to ongoing monitoring of certain processes
by the FTC.

-- The legal structure and presence of legal opinions that address
the true sale of the assets to the Issuer, the non-consolidation of
the special-purpose vehicle with CPS, that the trust has a valid
first-priority security interest in the assets and the consistency
with DBRS's "Legal Criteria for U.S. Structured Finance"
methodology.

The CPS 2019-A transaction represents the 32nd securitization
completed by CPS since 2010 and will offer both senior and
subordinate rated securities. The receivables securitized in CPS
2019-A will be subprime automobile loan contracts secured primarily
by used automobiles, light-duty trucks, vans and minivans.

The rating on the Class A Notes reflects the 54.40% of initial hard
credit enhancement provided by the subordinated notes in the pool
(49.40%), the Reserve Account (1.00%) and overcollateralization
(4.00%). The ratings on the Class B, Class C, Class D and Class E
Notes reflect 39.30%, 26.00%, 14.70% and 5.00% of initial hard
credit enhancement, respectively. Additional credit support may be
provided from excess spread available in the structure.

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


CPS AUTO 2019-A: S&P Gives Prelim BB-(sf) Rating on $25.7MM E Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to CPS Auto
Receivables Trust 2019-A's asset-backed notes.

The note issuance is asset-backed securities (ABS) transaction
backed by subprime auto loan receivables.

The preliminary ratings are based on information as of Jan. 10,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflects:

-- The availability of approximately 56.74%, 48.32%, 39.64%,
31.15%, and 24.10% of credit support for the class A, B, C, D, and
E notes, respectively, based on stressed cash flow scenarios
(including excess spread). These credit support levels provide
coverage of approximately 3.10x, 2.60x, 2.10x, 1.60x, and 1.23x our
17.75%-18.75% expected cumulative net loss (CNL) range for the
class A, B, C, D, and E notes, respectively. Additionally, credit
enhancement, including excess spread for classes A, B, C, D, and E,
covers breakeven cumulative gross losses of approximately 92%, 78%,
66%, 52%, and 40%, respectively.

-- S&P said, "Our expectation that under a moderate stress
scenario of 1.60x our expected net loss level, all else equal, the
preliminary ratings on the class A through C notes would remain
within one rating category while they are outstanding, and the
preliminary rating on the class D notes would not decline by more
than two rating categories within its life. The preliminary rating
on the class E notes would remain within two rating categories
during the first year, but the class would eventually default under
the 'BBB' stress scenario after receiving 33%-57% of its principal.
These rating migrations are consistent with our credit stability
criteria."

-- The preliminary rated notes' underlying credit enhancement in
the form of subordination, overcollateralization (O/C), a reserve
account, and excess spread for the class A through E notes.

-- The timely interest and principal payments made to the
preliminary rated notes under S&P's stressed cash flow modeling
scenarios, which it believes are appropriate for the assigned
preliminary ratings.

-- The transaction's payment and credit enhancement structure,
which includes a noncurable performance trigger.

  PRELIMINARY RATINGS ASSIGNED

  CPS Auto Receivables Trust 2019-A
  Class      Rating      Amount mil. $)
  A          AAA (sf)           123.491
  B          AA (sf)             40.015
  C          A (sf)              35.245
  D          BBB (sf)            29.944
  E          BB- (sf)            25.705



CREDIT SUISSE 2008-C1: S&P Cuts Ratings on 3 Certs Classes to D
---------------------------------------------------------------
S&P Global Ratings lowered its ratings on three classes of
commercial mortgage pass-through certificates to 'D(sf)' from
Credit Suisse Commercial Mortgage Trust Series 2008-C1, a U.S.
commercial mortgage-backed securities transaction.

The downgrades on classes A-J, B, and C reflect accumulated
interest shortfalls that we expect to remain outstanding for the
foreseeable future. In addition, we anticipate these classes to
experience credit support erosion upon the eventual resolution of
the two remaining assets, both of which are with the special
servicer.

According to the Dec. 17, 2018, trustee remittance report, the
trust reported $148,324 in monthly interest shortfalls primarily
from appraisal subordinate entitlement reduction amounts totaling
$138,492 and special servicing fees totaling $17,755. The current
reported interest shortfalls have affected all classes subordinate
to and including class A-J.      

TRANSACTION SUMMARY     

As of the Dec. 17, 2018, trustee remittance report, the collateral
pool balance was $85.2 million, which is 9.6% of the pool balance
at issuance. The pool currently includes one loan and one real
estate owned (REO) asset, both of which are specially serviced,
down from 60 loans at issuance.

To date, the transaction has experienced $92.0 million in principal
losses, or 10.4% of the original pool trust balance. S&P expects
losses to reach approximately 16.4% of the original pool trust
balance in the near term, based on losses incurred to date and
additional losses it expects upon the eventual resolution of the
two specially serviced assets.     

CREDIT CONSIDERATIONS     

As of the Dec. 17, 2018, trustee remittance report, two assets in
the pool were with the special servicer, C-III Asset Management LLC
(C-III).

The Killeen Mall REO asset ($82.0 million, 96.2%) is the largest
asset in the pool and has a total reported exposure of $86.6
million. The asset is a 386,759-sq.-ft. retail property in Killeen,
Texas. The loan was transferred to the special servicer on June 14,
2017, due to maturity default. The property became REO on Feb. 6,
2018. According to C-III, the Sears tenant at this location is
expected to close March 2019. Following Sears' store closure, the
collateral occupancy is expected to drop to 63.5%. An appraisal
reduction amount of $28.2 million is in effect against this asset.
S&P expects a significant loss (greater than 60%) upon this asset's
eventual resolution.     

The University Center Professional Building II loan ($3.2 million,
3.8%) has a total reported exposure of $3.5 million. The loan is
secured by a 31,372-sq.-ft. office building in Palm Desert, Calif.
The loan, which has a foreclosure in process payment status, was
transferred to the special servicer on June 9, 2017, due to
maturity default. S&P expects a minimal loss (less than 25%) upon
this loan's eventual resolution.

  RATINGS LOWERED

  Credit Suisse Commercial Mortgage Trust Series 2008-C1
  Commercial mortgage pass-through certificates

  Class      To         From

  A-J        D (sf)     B+ (sf)
  B          D (sf)     CCC (sf)
  C          D (sf)     CCC- (sf)


DEUTSCHE BANK 2015-CCRE22: Fitch Affirms Class E Certs at BB-sf
---------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of Deutsche Bank Securities,
Inc. commercial mortgage pass-through certificates series
2015-CCRE22.

KEY RATING DRIVERS

Overall Stable Loss Expectations: The affirmations are based on the
overall stable performance of the underlying collateral. One loan
(2.1% of the current pool balance) is in special servicing and four
loans (10.9%) have been designated as Fitch Loans of Concern
(FLOC). Three loans (1.5%) have been defeased. There have been no
realized losses to date.

Minimal Change to Credit Enhancement: As of the December 2018
distribution date, the pool's aggregate principal balance has been
paid down by 3.4% to $1.25 billion from $1.30 billion at issuance.
Excluding the specially serviced loan, all other loans are current.
As property-level performance is generally in line with issuance
expectations, the original rating analysis was considered in
affirming the transaction. Interest shortfalls are currently
impacting the non-rated class H.

Fitch Loans of Concern: Four loans (10.9%), including the specially
serviced loan, have been designated as FLOCs. The largest FLOC is
One Riverway (6.3%), an office building in Houston, TX. During
Hurricane Harvey, the basement and first floor of the property
suffered significant water damage. Per the borrower, the final
repairs were expected to be complete by YE 2018. Additionally, the
servicer-reported YE 2017 NOI is approximately 33% lower than YE
2016 due to a decline in revenue. Per the servicer commentary, NOI
has declined due to a decline in occupancy; however, occupancy
declined only 4% between YE 2016 and YE 2017. Fitch will continue
to monitor loan for changes in performance. Other FLOCs include
Patriots Park (2.1%), the specially serviced loan; 1424 K Street
Northwest and 3300-3340 New York Ave (1.8%), two
cross-collateralized office and industrial properties in Washington
D.C. with declining occupancy and cash flow; and Pacific View Plaza
(0.7%), an office property in Carlsbad, CA where several large
tenants departed, reducing occupancy to 47% as of 2Q18.

Specially Serviced Loan: The 16th largest loan in the pool,
Patriots Park (2.1%), transferred to special servicing in November
2018 for non-monetary default after the borrower completed a
non-permitted equity transfer resulting in changes to the
ownership/guarantor structure. The borrower is cooperating with the
special servicer to complete a forbearance agreement that will
include a full payoff in July 2019. The loan is collateralized by a
723,667 sf suburban office complex in Reston, VA. The property is
100% occupied by the Government Services Agency through two leases,
one ending in September 2032 and one ending in March 2033. As of
the 3Q18 financials, the property was performing at a 2.28x DSCR.

Limited Amortization: Eight loans, representing 31.2% of the pool,
are full term interest-only, and 26 loans, representing 42.1% of
the pool, are partial interest-only. The remainder of the pool
consists of 29 balloon loans representing 26.8% by balance, with
loan terms of five to 10 years. Based on the scheduled balance at
initial loan maturity, the pool will pay down by 10.7%.

New York City and Leased Fee Concentration: Seven loans (28.8%) are
secured by properties located in New York City, including the
largest loan in the pool. In addition, three loans in the pool
(10.4%) are secured by leased fee properties located in New York
City and Portland, OR.

RATING SENSITIVITIES

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

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

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

Fitch has affirmed the following ratings:

  -- $2.6 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $178.9 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $109 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $200 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $293.5 million class A-5 at 'AAAsf'; Outlook Stable;

  -- $79.8 million class A-SB at 'AAAsf'; Outlook Stable;

  -- $81 million class A-M at 'AAAsf'; Outlook Stable;

  -- $944.8 million* class X-A at 'AAAsf'; Outlook Stable;

  -- $132.9 million* class X-B at 'AA-sf'; Outlook Stable;

  -- $213.9 million class PEZ at 'A-sf'; Outlook Stable;

  -- $76.2 million class B at 'AA-sf'; Outlook Stable;

  -- $56.7 million class C at 'A-sf'; Outlook Stable;

  -- $68.1 million class D at 'BBB-sf'; Outlook Stable;

  -- $27.6 million class E at 'BB-sf'; Outlook Stable.

  * Notional amount and interest only.

Fitch does not rate the class F, G, H, and X-D certificates. Fitch
previously withdrew the rating on the class X-C certificates.


GREENWICH CAPITAL 2004-GG1: Fitch Affirms Csf Rating on 2 Tranches
------------------------------------------------------------------
Fitch Ratings has affirmed all classes of Greenwich Capital
Commercial Funding Corp. Commercial Mortgage Trust 2004-GG1.

KEY RATING DRIVERS

Concentrated Pool: The pool is comprised almost exclusively of one
loan, Aegon Center, which accounts for 99.8% of the pool. The
remaining two loans are fully amortizing with between two and four
remaining payments, and performing loan collateral. Ratings are
dependent upon the performance of the collateral for this loan and
reflect Fitch's recovery estimates for each of the remaining
classes.

The largest loan, Aegon Center, is collateralized by a 633,000-sf
office property, now known as 400 West Market Street, located in
downtown Louisville, KY. Since issuance, one of the major tenants,
Aegon (32.6% of NRA), vacated prior to its lease expiration. The
property subsequently transferred to special servicing and returned
to master servicing, following the bifurcation of the original note
into an A note ($82 million) and a B note ($21.1 million).
Occupancy and cash flow have yet to return to their issuance levels
following Aegon's departure and given a weak office submarket. As
of September 2018, the servicer reported occupancy and NOI DSCR
were 72% and 1.32x, respectively. The loan matures in April of
2019, and the borrower has not responded regarding their plans to
pay off the loan.

Stable Loss Expectations and Performance of Largest Loan: Loss
expectations are largely unchanged since the last rating action,
given limited changes to pool composition. The largest loan in the
pool, Aegon Center, accounts for 99.8% of the pool and drives loss
expectations and ratings.

High Credit Enhancement: Credit enhancement remains high; however,
the ratings are dependent on the largest loan's performance.

RATING SENSITIVITIES

The Rating Outlooks on classes F and G remain Stable based on the
overall stable performance of the largest loan in the pool, the
Aegon Center, and stable credit enhancement. Further downgrades to
the distressed classes are possible as losses are realized.

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

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

Fitch has affirmed the following classes:

  -- $14.5 million class F at 'Asf'; Outlook Stable;

  -- $26 million class G at 'BBsf'; Outlook Stable;

  -- $39 million class H at 'CCsf'; RE 100%;

  -- $6.5 million class J at 'Csf'; RE 60%;

  -- $13 million class K at 'Csf'; RE 0%.

  -- $4.2 million class L at 'Dsf'; RE 0%;

  -- $0 class M at 'Dsf'; RE 0%;

  -- $0 class N at 'Dsf'; RE 0%;

  -- $0 class O at 'Dsf'; RE 0%.


GS MORTGAGE 2013-GCJ12: S&P Lowers Class F Certs Rating to B+
-------------------------------------------------------------
S&P Global Ratings raised its ratings on three classes of
commercial mortgage pass-through certificates from GS Mortgage
Securities Trust 2013-GCJ12, a U.S. commercial mortgage-backed
securities transaction. In addition, S&P lowered its rating on
class F and affirmed its ratings on eight other classes from the
same transaction.

For the upgrades and affirmations on the principal- and
interest-paying certificates, S&P's credit enhancement expectation
was generally in line with the raised or affirmed rating levels.
The upgrades also reflect the reduction in trust balance.

S&P said, "The downgrade on class F reflects credit support erosion
that we anticipate will occur upon the eventual resolution of the
three loans ($129.1 million, 13.3%) with the special servicer
(discussed below), as well as reduced liquidity support available
to this class due to ongoing interest shortfalls. We also
considered the potential for further reduction in liquidity support
in the event appraisal reduction amounts are implemented on the
specially serviced loans.

"While available credit enhancement levels suggest further positive
rating movements on classes B and C and a positive rating movement
on class D, our analysis also considered the susceptibility to
reduced liquidity support from the three specially serviced loans,
particularly with respect to the Queens Crossing loan ($68.1
million, 7.0%), which has reported leasing discrepancies that the
special servicer is working to resolve with the borrower (details
below).

"We affirmed our 'AAA (sf)' rating on the class X-A interest-only
(IO) certificates and raised our rating to 'A (sf)' on the class
X-B 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. The notional balance on
class X-A references classes A-1, A-2, A-3, A-4, A-AB, and A-S. The
notional balance on class X-B references classes B and C."

TRANSACTION SUMMARY

As of the Dec. 12, 2018, trustee remittance report, the collateral
pool balance was $970.2 million, which is 81.0% of the pool balance
at issuance. The pool currently includes 73 loans, down from 78
loans at issuance. Three of these loans are with the special
servicer, five ($40.8 million, 4.2%) are defeased, and nine ($69.9
million, 7.2%) are on the master servicer's watchlist.

Excluding the defeased and specially serviced loans, we calculated
a 1.53x S&P Global Ratings weighted average debt service coverage
(DSC) and 77.9% S&P Global Ratings weighted average loan-to-value
(LTV) ratio using a 7.84% S&P Global Ratings weighted average
capitalization rate for the remaining performing loans.

The top 10 nondefeased loans have an aggregate outstanding pool
trust balance of $459.9 million (47.4%). Adjusting the
servicer-reported numbers, S&P calculated an S&P Global Ratings
weighted average DSC and LTV of 1.63x and 77.4%, respectively, for
eight of the top 10 nondefeased loans. The remaining loans are
specially serviced and discussed below.

To date, the transaction has not experienced any principal losses.
S&P expects losses to reach approximately 1.9% of the original pool
trust balance in the near term, based on losses it expects upon the
eventual resolution of the three specially serviced loans.

CREDIT CONSIDERATIONS

As of the Dec. 12, 2018, trustee remittance report, three loans in
the pool were with the special servicer, Rialto Capital Advisors
LLC (Rialto). Details of the two largest specially serviced loans,
both of which are top 10 loans, are as follows:

-- The Queens Crossing loan is the second-largest nondefeased loan
in the pool and has a total reported exposure of $68.1 million. The
loan is secured by a 179,186–sq.-ft. mixed-use
(multifamily/office/retail) property in Flushing, New York. The
loan, which has a reported current payment status, was transferred
to the special servicer on July 4, 2018, because of non-monetary
default. Rialto stated that it is evaluating its options and
working through some leasing discrepancies. The reported DSC and
occupancy as of the six months ended June 30, 2018, were 1.05x and
100.0%, respectively. S&P expects a minimal loss (less than 25%),
if any, upon this loan's eventual resolution.

-- The Eagle Ridge Village loan ($56.7 million, 5.8%) is the
third-largest nondefeased loan in the pool and has a total reported
exposure of $57.1 million. The loan is secured by a 648-unit
multifamily property in Evans Mills, New York. The loan, which has
a late but less than one-month delinquent payment status, was
transferred to the special servicer on Jan. 17, 2018, because of
imminent default. Rialto indicated that it is evaluating its
options and in discussions with the borrower. The reported DSC and
occupancy as of the six months ended June 30, 2018, were 0.79x and
67.0%, respectively. S&P expects a moderate loss (26-59%) upon this
loan's eventual resolution.  

The remaining loan with the special servicer has a balance that
represents less than 0.5% of the total pool trust balance. S&P
estimated losses for the three specially serviced loans, arriving
at a weighted-average loss severity of 17.4%.

  RATINGS RAISED

  GS Mortgage Securities Trust 2013-GCJ12
  Commercial mortgage pass-through certificates
                Rating
  Class     To          From
  B         AA (sf)     AA- (sf)
  C         A (sf)      A- (sf)
  X-B       A (sf)      A- (sf)

  RATING LOWERED

  GS Mortgage Securities Trust 2013-GCJ12
  Commercial mortgage pass-through certificates
  
               Rating
  Class     To          From
  F         B+ (sf)     BB- (sf)

  RATINGS AFFIRMED

  GS Mortgage Securities Trust 2013-GCJ12
  Commercial mortgage pass-through certificates
  Class     Rating
  A-2       AAA (sf)
  A-3       AAA (sf)
  A-4       AAA (sf)
  A-AB      AAA (sf)
  A-S       AAA (sf)
  D         BBB- (sf)
  E         BB (sf)
  X-A       AAA (sf)



GSRPM MORTGAGE 2004-1: Moody's Lowers Class B-1 Debt Rating to B2
-----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of Cl. B-1 from
GSRPM Mortgage Loan Trust 2004-1.

Complete rating action is as follows:

Issuer: GSRPM Mortgage Loan Trust 2004-1

Cl. B-1, Downgraded to B2 (sf); previously on Oct 27, 2015
Downgraded to B1 (sf)

RATINGS RATIONALE

The rating downgrade of Cl. B-1 reflects the outstanding unpaid
interest shortfall of $142,474.55 which is not expected to be
recouped as the bond has a weak reimbursement mechanism for
interest shortfalls.

The principal methodology used in this rating was "US RMBS
Surveillance Methodology" published in January 2017.

The Credit Rating for this tranche was assigned in accordance with
Moody's existing Methodology entitled "US RMBS Surveillance
Methodology," dated 1/31/2017.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate
The unemployment rate fell to 3.9% in December 2018 from 4.1% in
December 2017. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2019 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Lower increases than
Moody's expects or decreases could lead to negative rating actions.
Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions.


JP MORGAN 2013-C10: Fitch Affirms B Rating on $12.7MM Class F Notes
-------------------------------------------------------------------
Fitch Ratings has affirmed 10 classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust commercial mortgage
pass-through certificates, series 2013-C10.

KEY RATING DRIVERS

Increased Credit Enhancement; Generally Stable Performance: The
majority of the pool continues to exhibit relatively stable
performance since issuance. As of the December 2018 remittance
reporting, the pool's aggregate principal balance has paid down by
28.5% to $914 million from $1.28 billion at issuance. Since Fitch's
last rating action, five loans totaling $103 million (9% of the
pool balance at the last rating action) were paid out of the pool.
There have been no realized losses since issuance. Five loans (9.8%
of current pool) are defeased. The majority of the pool (33 loans,
86.8% of the pool) is currently amortizing. Five loans (13.2% of
the pool) are full-term interest only.

Fitch Loans of Concern: Fitch has identified seven loans (15.5% of
the pool balance) as Fitch Loans of Concern with two loans (9.5% of
the pool) in the top 15, including West County Center and Platinum
Tower. West County Center is a regional mall with revenue declines,
declining anchor sales, and nearby competition. Platinum Tower is
secured by a 312,591 sf urban office property located in Atlanta,
Georgia. Occupancy has increased to 69% as of June 2018 from 52% at
YE 2017; a decrease from 94% at securitization. Two leases
accounting for approximately 20% of net rentable area expired in
2017. The tenants vacated their spaces. According to the servicer,
the borrower is in the process of finalizing leases for vacant
units. Fitch will continue to monitor these loans.

REO Asset: The Fashion Outlets of Santa Fe (1% of the pool balance)
is a 124,504 sf outlet mall asset located 10 miles southwest of
downtown Santa Fe, New Mexico. The asset transferred to special
servicing in April 2017 and a foreclosure sale was completed May
2018. Occupancy at the property has decreased to 49.6% as of the
October 2018 rent roll from 74.4% as of October 2017. Fitch modeled
a 100% loss in its analysis of this asset.

High Retail Concentration: The pool has a retail concentration of
46.5% including seven retail loans totaling 35.2% of the pool in
the top 15. Regional mall exposure consists of two top 15 loans
(20.2% of the pool) and one specially serviced asset (1.1% of the
pool).

Alternative Loss Consideration: Fitch performed an additional
sensitivity on West County Center to address the potential for
outsized losses. The sensitivity analysis assumed a 15% loss of the
loan which contributed to the Negative Rating Outlook on class F.

RATING SENSITIVITIES

The Negative Rating Outlooks on class F reflects the potential for
downgrades as a result of expected losses from the specially
serviced asset and the potential for further performance declines
of West County Center. The Stable Rating Outlooks for classes A-4
through E reflect the generally stable pool performance and
expected continued paydown. Future rating upgrades may occur with
improved pool performance and additional defeasance or paydown.

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

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

Fitch has affirmed the following ratings:

  -- $14,957,582 class A-4 notes at 'AAAsf'; Outlook Stable;

  -- $430,080,000 class A-5 notes at 'AAAsf'; Outlook Stable;

  -- $85,517,403 class A-SB notes at 'AAAsf'; Outlook Stable;

  -- $107,059,000 class A-S notes at 'AAAsf'; Outlook Stable;

  -- $84,689,000 class B notes at 'AA-sf'; Outlook Stable;

  -- $55,926,000 class C notes at 'A-sf'; Outlook Stable;

  -- $47,937,000 class D notes at 'BBB-sf'; Outlook Stable;

  -- $30,360,000 class E notes at 'BBsf'; Outlook Stable;

  -- $12,783,000 class F notes at 'Bsf'; Outlook Negative;

  -- $637,613,984 class X-A* notes at 'AAAsf'; Outlook Stable.

Classes A-1, A-2, and A-3 have repaid in full. Fitch does not rate
the class NR and X-B certificates.

*Notional amount and interest only.


LB-UBS COMMERCIAL 2007-C6: Moody's Affirms Class A-J Certs at B2
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on two classes
and affirmed the ratings on ten classes in LB-UBS Commercial
Mortgage Trust 2007-C6 Commercial Mortgage Pass-Through
Certificates, Series 2007-C6, as follows:

Class A-M, Upgraded to A3 (sf); previously on February 9, 2018
Affirmed Baa2 (sf)

Class A-MFL, Upgraded to A3 (sf); previously on February 9, 2018
Affirmed Baa2 (sf)

Class A-J, Affirmed B2 (sf); previously on February 9, 2018
Affirmed B2 (sf)

Class B, Affirmed Caa1 (sf); previously on February 9, 2018
Affirmed Caa1 (sf)

Class C, Affirmed Caa2 (sf); previously on February 9, 2018
Affirmed Caa2 (sf)

Class D, Affirmed Caa3 (sf); previously on February 9, 2018
Affirmed Caa3 (sf)

Class E, Affirmed C (sf); previously on February 9, 2018 Affirmed C
(sf)

Class F, Affirmed C (sf); previously on February 9, 2018 Affirmed C
(sf)

Class G, Affirmed C (sf); previously on February 9, 2018 Affirmed C
(sf)

Class H, Affirmed C (sf); previously on February 9, 2018 Affirmed C
(sf)

Class J, Affirmed C (sf); previously on February 9, 2018 Affirmed C
(sf)

Class X*, Affirmed C (sf); previously on February 9, 2018
Downgraded to C (sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on two P&I classes were upgraded based primarily on an
increase in credit support resulting from loan paydowns and
amortization. The deal has paid down 17.5% since Moody's last
review.

The ratings on nine P&I classes were affirmed because the ratings
are consistent with expected recovery of principal and interest
from specially and troubled loans as well as losses from previously
liquidated loans.

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

Moody's rating action reflects a base expected loss of 49.4% of the
current pooled balance, compared to 46.9% at Moody's last review.
Moody's base expected loss plus realized losses is now 13.0% of the
original pooled balance, compared to 13.4% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

The Credit Rating for LB-UBS Commercial Mortgage Trust 2007-C6,
Class X was assigned in accordance with Moody's existing
Methodology entitled "Moody's Approach to Rating Structured Finance
Interest-Only (IO) Securities" dated June 2017.

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 76% of the pool is in
special servicing and Moody's has identified additional troubled
loans representing 2% of the pool. In this approach, Moody's
determines a probability of default for each specially serviced and
troubled loan that it expects will generate a loss and estimates a
loss given default based on a review of broker's opinions of value
(if available), other information from the special servicer,
available market data and Moody's internal data. The loss given
default for each loan also takes into consideration repayment of
servicer advances to date, estimated future advances and closing
costs. Translating the probability of default and loss given
default into an expected loss estimate, Moody's then applies the
aggregate loss from specially serviced and troubled loans to the
most junior class(es) and the recovery as a pay down of principal
to the most senior class(es).

DEAL PERFORMANCE

As of the December 17, 2018 distribution date, the transaction's
aggregate certificate balance has decreased by 86% to $424.4
million from $2.98 billion at securitization. The certificates are
collateralized by 53 mortgage loans ranging in size from less than
1% to 55.8% of the pool, with the top ten loans (excluding
defeasance) constituting 96.1% of the pool. All but three of the
remaining loans are currently in special servicing.

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

The three loans not in special servicing, constituting 21.9% 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-eight loans have been liquidated from the pool, resulting in
an aggregate realized loss of $178.4 million (for an average loss
severity of 37%). Forty-nine loans, constituting 76% of the pool,
are currently in special servicing. The largest specially serviced
exposure is the PECO Portfolio Loans ($236.7 million -- 55.8% of
the pool), which is secured by 39 cross-collateralized and
cross-defaulted loans. The loans are secured by 39 retail
properties located across 13 states. The average property size is
109,000 SF with no individual asset representing more than 6% of
the total SF or 7% of the total portfolio loan balance. The loans
transferred to special servicing in August 2012 due to imminent
default. All 39 PECO loans have become became real-estate owned
(REO) with thirteen properties having already been sold.

The second largest specially serviced loan is the Lakeland Town
Center Loan ($25.1 million -- 5.9% of the pool), which is secured
by a 304,000 SF grocery-anchored retail center in Lakeland,
Florida. The loan transferred to special servicing in October 2016
for imminent default. The special servicer indicated that the loan
is being dual-tracked with the foreclosure action until a
resolution is achieved.

The third largest specially serviced loan is the Hickory Grove Loan
($13.3 million -- 3.1% of the pool), which is secured by a 232,540
total SF retail property located in Cleveland, Tennessee. The loan
transferred to special servicing in July 2017 for maturity default
and became REO in June 2018. As of March 2018, the property was
100% leased, compared to 93% in December 2017. The loan's actual
DSCR has been below 1.00X since 2013 and financial performance has
declined annually since 2016.

The remaining eight specially serviced loans are secured by a mix
of property types. Moody's has also assumed a high default
probability for one poorly performing loan, constituting 2.4% of
the pool, and has estimated an aggregate loss of $207 million (a
62% expected loss on average) from these specially serviced and
troubled loans.

As of the December 17, 2018 remittance statement cumulative
interest shortfalls totaled $37.1 million and impacted up to Class
D. Moody's anticipates interest shortfalls will continue because of
the exposure to specially serviced loans and/or modified loans.
Interest shortfalls are caused by special servicing fees, including
workout and liquidation fees, appraisal entitlement reductions
(ASERs), loan modifications and extraordinary trust expenses.

The three remaining performing loans represent 21.9% of the pool
balance. The largest performing loan is the Islandia Shopping
Center -- A Note Loan ($59.9 million -- 14.1% of the pool), which
is secured by a 377,000 SF anchored retail center located in
Islandia, New York. The property is anchored by Walmart and Stop &
Shop. The property was 96% leased as of September 2018, compared to
95% as of September 2017. A modification to the original loan in
2014 included an A/B note split and created a $10.1 B note. Moody's
identified the B note as a troubled loan and assumed a significant
loss. Moody's A Note LTV and stressed DSCR on the A Note are 115.6%
and 0.80X, respectively.

The second largest loan is the Portsmouth Station Shopping Center
Loan ($19.3 million -- 4.6% of the pool), which is secured by a
147,000 SF anchored retail shopping center in Manassas, Virginia.
As of September 2018, the property was 94% leased, compared to 96%
as of September 2017. This loan has amortized 7% since
securitization. The property's largest tenant Toys R Us (31% of the
NRA) vacated in 2018 as part of its bankruptcy. The space was
subsequently leased to a temporary tenant and the servicer recently
indicated a lease was executed with a regional furniture chain to
fill the space. Moody's LTV and stressed DSCR are 118.9% and 0.84X,
respectively.

The third largest loan is the Tower Square Retail Loan ($13.8
million -- 3.3% of the pool), which is secured by a 71,000 SF
shadow-anchored retail center in Eden Prairie, Minnesota. The
property is located across the street from a Walmart Supercenter
and is shadow-anchored by a Target. As of December 2018, the
property was 83% leased, compared to 82% as of June 2017. This loan
has amortized 7% since securitization. Moody's LTV and stressed
DSCR are 135.9% and 0.78X, respectively.


MAGNETITE LTD IX: Moody's Affirms Ba3 Rating on Class D Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by Magnetite IX, Limited:

US$40,000,000 Class A-2-R Senior Secured Floating Rate Notes due
2026, Upgraded to Aaa (sf); previously on June 16, 2017 Assigned
Aa1 (sf)

US$28,000,000 Class B-R Deferrable Mezzanine Floating Rate Notes
due 2026, Upgraded to Aa3 (sf); previously on June 16, 2017
Assigned A1 (sf)

US$24,000,000 Class C-R Deferrable Mezzanine Floating Rate Notes
due 2026, Upgraded to Baa1 (sf); previously on June 16, 2017
Assigned Baa3 (sf)

Moody's also affirmed the ratings on the following notes:

US$256,000,000 Class A-1-R Senior Secured Floating Rate Notes due
2026 (current outstanding balance of $235,889,069), Affirmed Aaa
(sf); previously on June 16, 2017 Assigned Aaa (sf)

US$20,000,000 Class D Deferrable Mezzanine Floating Rate Notes due
2026, Affirmed Ba3 (sf); previously on July 17, 2014 Assigned Ba3
(sf)

US$5,000,000 Class E Deferrable Mezzanine Floating Rate Notes due
2026, Affirmed B2 (sf); previously on July 17, 2014 Assigned B2
(sf)

Magnetite IX, Limited, initially issued in July 2014, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans. The transaction's reinvestment
period ended in July 2018.

RATINGS RATIONALE

These rating actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's
over-collateralization (OC) ratios since the end of reinvestment
period in July 2018. The Class A-1-R notes have been paid down by
approximately 7.86% or $20.1 million since then. Based on the
trustee's November 2018 report, the OC ratios for the Class A,
Class B, Class C and Class D notes are reported at 135.2%, 122.8%,
113.8% and 107.3%, respectively, versus July 2018 levels of 132.9%,
121.4%, 113.0% and 106.9%, respectively.

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

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base case,
Moody's analyzed the collateral pool as having a performing par and
principal proceeds balance of $373.1 million, no defaulted par, a
weighted average default probability of 18.85% (implying a WARF of
2658), a weighted average recovery rate upon default of 49.88%, a
diversity score of 62 and a weighted average spread of 2.91%
(before accounting for LIBOR floors).

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
August 2017.

The Credit Rating for Magnetite IX, Limited was assigned in
accordance with Moody's existing Methodology entitled "Moody's
Global Approach to Rating Collateralized Loan Obligations," dated
August 31, 2017.

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

This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings:

1) Macroeconomic uncertainty: CLO performance is subject to
uncertainty about credit conditions in the general economy.

2) Collateral Manager: Performance can also be affected positively
or negatively by a) the manager's investment strategy and behavior
and b) differences in the legal interpretation of CLO documentation
by different transactional parties owing to embedded ambiguities.

3) Collateral credit risk: A shift towards collateral of better
credit quality, or better credit performance of assets
collateralizing the transaction than Moody's current expectations,
can lead to positive CLO performance. Conversely, a negative shift
in credit quality or performance of the collateral can have adverse
consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace. Deleveraging of the CLO
could accelerate owing to high prepayment levels in the loan market
and/or collateral sales by the manager, which could have a
significant impact on the notes' ratings. Note repayments that are
faster than Moody's current expectations will usually have a
positive impact on CLO notes, beginning with those with the highest
payment priority.

5) Weighted Average Spread (WAS): CLO performance can be sensitive
to WAS, which is a key factor driving the amount of excess spread
available as credit enhancement when a deal fails its
over-collateralization or interest coverage tests. A decrease in
excess spread, including as a result of losing the net interest
benefit of LIBOR floors, or because market conditions make it
difficult for the deal to source assets of appropriate credit
quality in order to maintain its WAS target, would reduce the
effective credit enhancement available for the notes.


MORGAN STANLEY 2007-IQ15: Fitch Hikes Rating on $33.4MM B Debt to B
-------------------------------------------------------------------
Fitch Ratings has upgraded two and affirmed nine classes of Morgan
Stanley Capital I Trust, commercial mortgage pass-through
certificates, series 2007-IQ15.

KEY RATING DRIVERS

Defeasance: The upgrades reflect increased defeasance. Since
Fitch's last rating action, the two largest loans, the cross
collateralized $19.5 million U-Haul Portfolio 3A loan (22.2%) and
$18.8 million U-Haul Portfolio 3B loan (21.5%) have been fully
defeased (43.7% of pool). Class A-J and approximately 42% of the
current class B balance are covered by defeased collateral.

Increasing Credit Enhancement/Recent Dispositions: Since Fitch's
last rating action, the pool balance has been reduced by 11.8% from
continued amortization in addition to the December 2018 disposition
of the largest specially serviced loan/asset, Shops at Stoughton
($9.3 million at disposition), which was disposed with only
$525,431 in realized losses to the trust, which was lower than
expected contributing to the upgrade to Class B as losses are no
longer expected.

Concentrated Pool: Only 17 of the original 134 loans remain. Due to
the concentrated nature of the pool, Fitch performed a sensitivity
analysis that grouped the remaining loans based on the likelihood
of repayment and expected losses from the liquidation of specially
serviced loans and/or underperforming or overleveraged loans.

As of the December 2018 distribution date, the pool's aggregate
principal balance has been reduced by 95.7% to $87.7 million from
$2.05 billion at issuance. There have been $170.1 million (8.3% of
original pool balance) in realized losses to date. Cumulative
interest shortfalls of $11.3 million are currently affecting
classes D through P.

High Loss Expectations and Concentration of Specially Serviced
Loans/Assets: Fitch's overall loss expectations on the specially
serviced loans/REO assets remain high. Three loans totaling $18.2
million (20.8% of pool) are currently in special servicing
including two REO assets (12.4%) and one in foreclosure (8.4%).
Fitch expects losses for these assets to be significant based on
the servicer's most recent values. The distressed classes are
reliant on their recoveries.

The largest specially serviced loan, Peace Corporate Industrial
(9.8% of pool), is secured by a 304,704 sf industrial/warehouse
property located in DeKalb, IL. The loan was transferred to special
servicing in June 2016 and became REO as of June 2017. The servicer
has been successful in lease up and stabilizing occupancy since 3M
(previously 91.3% NRA) vacated at its lease expiration in July
2016. Per the September 2018 rent roll, the property is currently
95.2% occupied by two tenants. CEVA Logistics U.S., Inc. occupies
206,479 sf (67.8% NRA) with leases executed between December 2017
and June 2018 and expiration in December 2022. School Tool Box
began leasing 83,500 sf starting in May 2018 with lease expiration
in December 2023.

Fitch Loans of Concern: In addition to the specially serviced loans
(20.8% of pool), two performing loans (15.6%) were designated Fitch
Loans of Concern (FLOCs) due to tenancy concerns and low DSCR. The
largest loan is secured by a 212,800 sf single-tenant Kmart in
Sayville, NY (14.6% of pool). DSCR has remained low since issuance,
reporting at 1.01x as of year to date (YTD) September 2018. Kmart's
current lease is through December 2020, approximately 1.5 years
prior to the loan maturity in June 2022. There is a cash flow sweep
in-place due to failed completion of repairs. Sears, the parent
company of Kmart, filed for bankruptcy in the fourth quarter of
2018. Per servicer updates, the tenant has not yet indicated intent
to vacate.

The remaining loan (1% of pool) is secured by a 52,359 sf office
building in Norfolk, VA with a DSCR of 0.55x as of YTD March 2018.
The property is only 51% occupied by a single tenant with a current
lease expiring in June 2019. The subject loan matures in April
2022.

The non-defeased performing loans include 10 fully amortizing loans
(17.5% of pool) with generally stable performance and relatively
lower leverage, maturing between 2019 and 2027. In addition, there
are two balloon loans maturing in April 2019 (3.4%) and June 2022
(14.6%).

RATING SENSITIVITIES

The Outlooks for class A-J and class B are considered Stable. .
Further upgrades are not likely due to the concentrated collateral
quality of the remaining pool. A downgrade to Class C is expected
if losses are realized.

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

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

Fitch has upgraded and assigned Outlooks to the following classes:

  -- $24.3 million class A-J to 'AAAsf' from 'Asf'; Outlook
Stable;

  -- $33.4 million class B to 'Bsf' from 'CCCsf'; Outlook Stable.

Fitch has affirmed the following ratings:

  -- $15.4 million class C at 'Csf'; RE 50%;

  -- $14.7 million class D at 'Dsf'; RE 0%;

  -- $0 class E at 'Dsf'; RE 0%;

  -- $0 class F at 'Dsf'; RE 0%;

  -- $0 class G at 'Dsf'; RE 0%;

  -- $0 class H at 'Dsf'; RE 0%;

  -- $0 class J at 'Dsf'; RE 0%;

  -- $0 class K at 'Dsf'; RE 0%;

  -- $0 class L at 'Dsf'; RE 0%.

The class A-1, A-2, A-3, A-4, A-1A and A-M certificates have paid
in full. Fitch does not rate the class M, N, O and P certificates.
Fitch had previously withdrawn the ratings on the interest-only
class X1 certificates.


MORGAN STANLEY 2016-UBS9: Fitch Affirms B-sf Rating on Cl. F Certs
------------------------------------------------------------------
Fitch Ratings has affirmed 15 classes of Morgan Stanley Capital I
Trust Commercial Mortgage Pass-Through Certificates, series
2016-UBS9.

KEY RATING DRIVERS

Stable Loss Expectations: The affirmations reflect the generally
stable performance of the pool. There have been no material changes
to the pool since issuance; therefore, the original rating analysis
was considered in affirming the transaction. There have been no
realized losses or specially serviced loans to date. No loans have
been designated Fitch Loans of Concern (FLOCs).

Minimal Changes in Credit Enhancement: As of the December 2018
distribution date, the pool's aggregate principal balance has been
reduced by 2.0% to $653.1 million from $666.6 million at issuance.
Six loans (26.6%) are full-term, interest-only and four loans
(22.4%) remain in partial interest-only periods. No loans have
defeased or paid off since issuance. Loan maturities and
anticipated repayment dates (ARD) are concentrated in 2025 (40.1%)
and 2026 (44.0%), with limited maturities scheduled in 2022 (8.6%),
2023 (3.0%) and 2031 (4.3%).

ADDITIONAL CONSIDERATIONS

Pool Concentrations: The top five and 10 loans in the transaction
represent 42.6% and 69.2% of the current pool balance,
respectively. The largest property type concentration is office
(33.3%), followed by retail (25.1%), industrial (19.9%) and self
storage (8.9%).

Premium Outlet Concentration: Two of the top 15 loans in the pool
(9.0%) are secured by premium outlet centers from related
sponsors.

Ellenton Premium Outlets (5.9% of the pool) is secured by a
476,481-sf outlet center located in Ellenton, FL, which is situated
between Bradenton/Sarasota to the south and Tampa/St. Petersburg to
the north. The servicer reported a YE 2017 NOI DSCR of 2.63x. As of
the June 2018 rent roll, the property was 91.5% leased, down from
94.6% at YE 2017 and 97.7% at YE 2016. The largest tenants include
VF Factory Outlet (4.9% of NRA; through December 2021), Saks Fifth
Avenue Off Fifth (4.2%; October 2021) and the Nike Factory Store
(3.2%; January 2020). Leases totaling approximately 22.0% of NRA
roll by YE 2019. Comparable inline sales were $431 psf for TTM June
2018, compared with $413 psf in 2017 and $482 psf in 2013.
Occupancy costs averaged 13.4%, as of June 2018.

Grove City Premium Outlets (3.1% of the pool) is secured by a
531,200-sf outlet center located in Grove City, PA, approximately
50 miles north of Pittsburgh. The servicer reported a YE 2017 NOI
DSCR of 2.86x. As of the June 2018 rent roll, the property was
85.4% leased, down from 87.3% at YE 2017 and 92.6% at YE 2016. The
largest tenants include VF Factory Outlet (5.0%; November 2019),
Old Navy (3.8%; January 2021) and the Nike Factory Store (3.1%;
June 2023). Leases totaling approximately 22.5% of NRA roll by YE
2019. Comparable inline sales were $360 psf for 2017, compared with
$365 psf for 2016 and $333 at issuance.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable. Fitch does not
foresee positive or negative ratings migration until a material
economic or asset-level event changes the transaction's overall
portfolio-level metrics. No loans are scheduled to mature until
2022 (8.6% of the pool).

DUE DILIGENCE USAGE PURSUANT TO SEC RULE 17G-10

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

Fitch has affirmed the following ratings:

  -- $16.3 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $73.5 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $46.1 million class A-SB at 'AAAsf'; Outlook Stable;

  -- $125.0 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $192.2 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $47.5 million class A-S at 'AAAsf'; Outlook Stable;

  -- $40.0 million class B at 'AA-sf'; Outlook Stable;

  -- $30.0 million class C at 'A-sf'; Outlook Stable;

  -- $34.2 million class D at 'BBB-sf'; Outlook Stable;

  -- $15.0 million class E at 'BB-sf'; Outlook Stable;

  -- $6.7 million class F at 'B-sf'; Outlook Stable.

  -- $453.1 million class X-A* at 'AAAsf'; Outlook Stable;

  -- $87.5 million class X-B* at 'AA-sf'; Outlook Stable;

  -- $34.2 million class X-D* at 'BBB-sf'; Outlook Stable;

  -- $15.0 million class X-E* at 'BB-sf'; Outlook Stable;

  * Notional amount and interest-only.

Fitch does not rate the class G, H, X-FG or X-H certificates.


NEW RESIDENTIAL 2019-NQM1: DBRS Gives (P)BB Rating on B-1 Notes
---------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the Mortgage-Backed
Notes, Series 2019-NQM1 (the Notes) issued by New Residential
Mortgage Loan Trust 2019-NQM1 (the Trust or the Issuer) as
follows:

-- $192.6 million Class A-1 at AAA (sf)
-- $27.8 million Class A-2 at AA (sf)
-- $33.6 million Class A-3 at A (sf)
-- $14.6 million Class M-1 at BBB (sf)
-- $11.2 million Class B-1 at BB (sf)
-- $7.4 million Class B-2 at B (sf)

The AAA (sf) rating on the Notes reflects the 34.60% of credit
enhancement provided by subordinated Notes in the pool. The AA
(sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect 25.15%,
13.75%, 8.80%, 5.00% and 2.50% of credit enhancement,
respectively.

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

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate, prime, expanded prime and non-prime first-lien
residential mortgages funded by the issuance of the Notes. The
Notes are backed by 532 loans with a total principal balance of
$294,491,925 as of the Cut-Off Date (January 1, 2019).

All the loans were originated by New Penn Financial, LLC (New Penn)
or by a correspondent and underwritten by New Penn and Shellpoint
Mortgage Servicing (SMS) is the Servicer. The mortgages were
originated under the following programs:

(1) SmartSelf and SmartSelf Plus (69.9%) — Generally made to
self-employed borrowers using bank statements to support
self-employed income for qualification purposes.

(2) SmartEdge and SmartEdge Plus (23.3%) — Generally made to
borrowers seeking flexible financing options (interest-only (IO)
loans or higher debt-to-income ratios (DTI)), who may have a recent
credit event (two or more years seasoned) that may preclude
prequalification for another program.

(3) SmartVest (5.6%) — Generally made to borrowers who are
experienced real estate investors looking to purchase or refinance
an investment property that is held for business purposes.

(4) High Balance Extra (0.7%) — Generally made to prime borrowers
with loan amounts exceeding the government-sponsored enterprise
(GSE) loan limits that may fall outside the Qualified Mortgage (QM)
requirements based on documentation and DTI.

(5) SmartTrac (0.3%) — Generally made to borrowers seeking
flexible financing options (IO loans or higher DTI) that may have a
recent credit event (one to two or more years seasoned) that may
preclude prequalification for another program.

(6) Smart Condo (0.2%) — Generally made to prime borrowers
seeking flexible financing options for condominium properties that
do not meet agency guidelines.

New Residential Investment Corp. is the Sponsor of the transaction.
Nationstar Mortgage LLC (Nationstar) will act as the Master
Servicer. Citibank, N.A. (rated A (high) with a Positive trend by
DBRS), will act as the Paying Agent, Note Registrar and Owner
Trustee. U.S. Bank National Association (rated AA (high) with a
Stable trend by DBRS) will serve as Indenture Trustee. Citicorp
Trust Delaware, National Association will serve as the Delaware
Trustee. Wells Fargo Bank, N.A. (rated AA with a Stable trend by
DBRS) will serve as Custodian.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau (CFPB) ability-to-repay (ATR) rules,
they were made to borrowers who generally do not qualify for
agency, government or private-label non-agency prime jumbo products
for various reasons. In accordance with the CFPB QM/ATR rules, 0.2%
of the loans are designated as QM Safe Harbor and 77.6% as non-QM.
Approximately 22.2% of the loans are made to investors for business
purposes and, hence, are not subject to the QM/ATR rules.

The Servicer will generally fund advances of delinquent principal
and interest on any mortgage until such loan becomes 180 days
delinquent and they are obligated to make advances in respect of
taxes, insurance premiums and reasonable costs incurred in the
course of servicing and disposing of properties.

The Sponsor intends to retain 5% of the fair value of all the Notes
issued by the Issuer (other than the Class R 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 60 or more days
delinquent under the Mortgage Bankers Association (MBA) method or
any real estate-owned (REO) property acquired in respect of a
mortgage loan at a price equal to the stated principal balance of
such loan, provided that such repurchases in aggregate do not
exceed 10% of the total principal balance as of the Cut-off Date
(Optional Repurchase Price).

On or after the earlier of (1) the payment date occurring in
January 2021 or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, the Depositor has the option to purchase all of the
outstanding mortgage loans, thereby retiring the Notes, at a price
equal to the outstanding aggregate stated principal balance of the
mortgage loans plus accrued and unpaid interest.

The transaction employs a sequential-pay cash flow structure with a
pro-rata principal distribution among the senior tranches.
Principal proceeds can be used to cover interest shortfalls on the
Notes as the outstanding senior Notes are paid in full.

The ratings reflect transactional strengths that include the
following:

(1) Robust Loan Attributes and Pool Composition: The mortgage loans
in this portfolio generally exhibit expanded prime characteristics
and robust loan attributes as reflected in credit scores, combined
loan-to-value (LTV) ratios, borrower household income and liquid
reserves. As the programs move down the credit spectrum, certain
characteristics, such as lower LTVs, suggest the consideration of
compensating factors for riskier pools. The pool comprises 46.1%
fixed-rate mortgages, which have the lowest default risk because of
the stability of monthly payments. The pool comprises 53.9% hybrid
adjustable-rate mortgages (ARMs) with initial fixed periods of five
to ten years, allowing borrowers sufficient time to credit cure
before rates reset.

(2) ATR Rules and Appendix Q Compliance: All of the mortgage loans,
except for the business-purpose investor loans, were underwritten
in accordance with the eight underwriting factors of the ATR rules.
In addition, New Penn's underwriting standards for the SmartEdge,
SmartEdge Plus, SmartTrac and SmartCondo programs generally comply
with the Standards for Determining Monthly Debt and Income as set
forth in Appendix Q of Regulation Z with respect to income
verification and the calculation of DTI ratios; however, in certain
instances, loans were permitted to have deviations from Appendix
Q.

(3) Satisfactory Third-Party Due Diligence Review: A third-party
due diligence firm conducted property valuation, credit and
compliance reviews on 100% of the loans in the pool. Data integrity
checks were also performed on the pool.

(4) Improved Underwriting Standards: Whether for prime or non-prime
mortgages, generally, underwriting standards have improved
significantly from the pre-crisis era with respect to certain
attributes such as income, asset and employment verification, as
well as appraisal and reserve requirements.

-- Full documentation generally consists of two years of W-2s (or
two years of personal and business tax returns for self-employed
borrowers), two months of asset statements and a verbal or written
verification of employment. Borrowers must execute and submit an
IRS Form 4506-T, and a tax transcript from the IRS using the
executed Form 4506-T is obtained.

-- For loans in the SmartSelf and SmartSelf Plus programs, one
borrower must be self-employed and income must be supported by 12
or 24 months of personal or business bank statements.

-- New Penn's appraisal review process incorporates validation
through either a second full appraisal, a desk review or a field
review.

-- Minimum reserve and maximum LTV requirements vary based on
program, loan amount, credit score and DTI.

The transaction also includes the following challenges and
mitigating factors:

(1) Representations and Warranties (R&W) Framework: The R&W
framework is considerably weaker than that of a post-crisis prime
jumbo securitization. Instead of an automatic review when a loan
becomes seriously delinquent, this transaction employs an optional
review only when realized losses occur (unless the alleged breach
relates to an ATR or TILA-RESPA Integrated Disclosure violation).
In addition, rather than engaging a third-party due diligence firm
to perform the R&W review, the Controlling Holder (initially the
Depositor) has the option to perform the review in house or use a
third-party reviewer. Finally, the R&W provider (the Seller) is an
unrated entity, has limited performance history of expanded prime,
non-QM securitizations and may potentially experience financial
stress that could result in the inability to fulfill repurchase
obligations. DBRS notes the following mitigating factors:

-- The Noteholders representing 25% interest in the Notes may
direct the Trustee to commence a separate review of the related
mortgage loan, to the extent they disagree with the Controlling
Holder's determination of a breach.

-- Third-party due diligence was conducted on 100% of the loans
included in the pool. A comprehensive due diligence review
mitigates the risk of future R&W violations.

-- DBRS conducted an originator review of New Penn and deems it to
be operationally sound.

-- The Sponsor or an affiliate of the Sponsor will retain 5% of
each class of Notes (other than the Class R Notes), aligning
Sponsor and investor interest in the capital structure.

-- Notwithstanding the above, DBRS adjusted the originator score
downward to account for the potential inability to fulfill
repurchase obligations, the lack of performance history as well as
the weaker R&W framework. A lower originator score results in
increased default and loss assumptions and provides additional
cushions for the rated securities.

(2) Non-Prime, Non-QM and Investor Loans: Compared with post-crisis
prime jumbo transactions, this portfolio contains mortgages
originated to borrowers with weaker credit and prior derogatory
credit events as well as large concentrations of non-QM and
investor loans. DBRS notes the following mitigating factors:

-- All loans, except for the business-purpose investor loans, were
originated to meet the eight underwriting factors as required by
the ATR rules. Also, certain loans were underwritten to comply with
the standards set forth in Appendix Q.

-- Underwriting standards have improved substantially since the
pre-crisis era.

-- The DBRS RMBS Insight model incorporates loss severity penalties
for non-QM and QM Rebuttable Presumption loans, as explained
further in the Key Loss Severity Drivers section of the related
presale report.

-- For loans in this portfolio, borrower credit events had
generally happened more than two years ago, on average, prior to
origination. In its analysis, DBRS applies additional penalties for
borrowers with recent credit events within the past two years (two
loans, representing


NEW RESIDENTIAL 2019-NQM1: S&P Gives Prelim B Rating on B-2 Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to New
Residential Mortgage Loan Trust 2019-NQM1's mortgage-backed notes.

The note issuance is a residential mortgage-backed securities
transaction backed by U.S. residential mortgage loans.

The preliminary ratings are based on information as of Jan. 9,
2019. 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 credit enhancement provided for this transaction;
-- The transaction's associated structural mechanics;
-- The transaction's representation and warranty (R&W) framework;
and
-- The mortgage originator.

  PRELIMINARY RATINGS ASSIGNED

  New Residential Mortgage Loan Trust 2019-NQM1

  Class       Rating        Amount ($)
  A-1         AAA (sf)     192,597,000
  A-2         AA (sf)       27,830,000
  A-3         A (sf)        33,572,000
  M-1         BBB (sf)      14,577,000
  B-1         BB (sf)       11,191,000
  B-2         B (sf)         7,362,000
  B-3         NR             7,362,924
  XS-1        NR              Notional(i)
  XS-2        NR              Notional(i)
  A-IO-S      NR              Notional(i)
  R           NR                   N/A

(i)Notional amount equals the loans' aggregate stated principal
balance.
NR--Not rated.
N/A--Not applicable.


NYT 2019-NYT: Fitch to Rate $24.4MM Class F Certificates BB-sf
--------------------------------------------------------------
Fitch Ratings has issued a presale report on NYT 2019-NYT Mortgage
Trust Commercial Mortgage Pass-Through Certificates.

Fitch expects to rate the transaction and assign Rating Outlooks as
follows:

  -- $261,250,000 class A 'AAAsf'; Outlook Stable;

  -- $90,250,000a class X-CP 'BBB-sf'; Outlook Stable;

  -- $90,250,000a class X-EXT' BBB-sf'; Outlook Stable;

  -- $52,250,000 class B 'AA-sf'; Outlook Stable;

  -- $35,150,000 class C 'A-sf'; Outlook Stable;

  -- $55,100,000 class D 'BBB-sf'; Outlook Stable;

  -- $61,037,000 class E 'BB-sf'; Outlook Stable;

  -- $24,463,000 class F 'BB-sf'; Outlook Stable.

Fitch does not expect to rate the following non-offered class:

  -- $25,750,000b VRR Interest.

(a) Notional amount and interest-only.

(b) Vertical credit risk retention interest.

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


The expected ratings are based on information provided by the
issuer as of Jan. 7, 2019.

The certificates will represent the beneficial interests in four
senior promissory notes, which, together with four junior
promissory notes that will not be included in the trust, evidences
a two-year (with five, one-year extension options), floating-rate,
whole loan secured by a first lien mortgage on the leasehold
interest of the borrower in five ground floor retail condominium
units and 23 office condominium units spanning floors 28 through 52
of the New York Times Building, located at 620 Eight Avenue in New
York, NY. The total building is 1.3 million sf, while the
collateral portion is 738,385 sf consisting of 709,678 sf of
office, 23,044 sf of ground floor retail and 5,663 sf of
storage/other space. The closing of the transaction is scheduled
for Jan. 30, 2019.

KEY RATING DRIVERS
High Aggregate Leverage: The $515.0 million mortgage loan has a
Fitch debt service coverage ratio (DSCR) and loan-to-value (LTV) of
1.05x and 83.9%, respectively, and debt of $697 psf. The total debt
package includes a $120.0 million b-note and $115.0 million
mezzanine loan, resulting in a total debt Fitch DSCR and LTV of
0.72x and 122.2%, respectively.

Accessible NYC CBD Location: The subject occupies the entire block
along Eighth Avenue in between West 40th and West 41st Streets in
the Times Square neighborhood of the New York CBD. The collateral
features immediate access to public transportation, with the Port
Authority Bus Terminal located directly across the street, and the
Times Square subway station within a five-minute walk.

Historical Occupancy: The property is fully leased and has
maintained near 100% occupancy for the past three years.
Approximately 84.5% of the NRA, including four of the five largest
tenants, has been in occupancy for 10 or more years.

Institutional Sponsorship: The sponsors of the loan are owned by
affiliates of Brookfield Property Partners, a global leader in real
estate investment and management. Brookfield Property Partners is a
publically listed (NYSE: BPY) real estate company of Brookfield
Asset Management. BPY's portfolio includes an ownership interest in
approximately 150 office properties totalling 99 million sf and 125
retail properties totalling 123 million sf.

RATING SENSITIVITIES

For this transaction, Fitch's NCF was 14.3% below the TTM ended
June 2018 NCF. Fitch evaluated the sensitivity of the ratings
assigned to the NYT 2019-NYT certificates and found that the
transaction displays average sensitivities to further declines in
NCF. In a scenario in which NCF declined a further 20% from Fitch's
NCF, a downgrade of the 'AAAsf' certificates to 'Asf' could result.
In a more severe scenario, in which NCF declined a further 30% from
Fitch's NCF, a downgrade of the 'AAAsf' certificates to 'BBB-sf'
could result.


OFSI FUND V: S&P Affirms B+ Rating on Class B-3L Notes
------------------------------------------------------
S&P Global Ratings raised its ratings on the class A-3F-R, A-3L-R,
and B-1L-R notes from OFSI Fund V Ltd.

S&P said, "We also removed these ratings from CreditWatch, where we
had placed them with positive implications on Oct. 26, 2018. At the
same time, we affirmed our ratings on the A-2F-R, A-2L-R, B-2L, and
B-3L notes from the same transaction.

"The rating actions follow our review of the transaction's
performance using data from the Dec. 7, 2018, trustee report."

The upgrades reflect the transaction's $104.26 million in
collective paydowns to the class A-1LA, A-1LB-R, A-2F-R, and A-2L-R
notes since S&P's April 2018 rating actions. These paydowns
resulted in improved reported overcollateralization (O/C) ratios
since the March 9, 2018, trustee report, which S&P used for its
previous rating actions:

-- The senior class A O/C ratio improved to 604.47% from 169.52%.
-- The class A O/C ratio improved to 230.44% from 139.39%.
-- The class B-1L O/C ratio improved to 158.69% from 123.37%.
-- The class B-2L O/C ratio improved to 124.11% from 111.86%.
-- The class B-3L O/C ratio improved to 114.56% from 108.01%.

The collateral portfolio's credit quality has remained fairly
stable since S&P's last rating actions. Collateral obligations with
ratings in the 'CCC' category have decreased, with $9.38 million
reported as of the December 2018 trustee report, compared with
$15.28 million reported as of the March 2018 trustee report.
However, 'CCC' exposure remains elevated at more than 11% of the
aggregate collateral balance.

As a result of amortization in the underlying collateral, the
portfolio has become more concentrated, comprising 57 assets from
42 obligors, down from 105 assets from 81 obligors. In addition,
the weighted average spread has declined slightly, which affected
the interest coverage (I/C) tests of the junior tranches.  Both the
B-2L and B-3L notes I/C tests are currently failing, although they
have relatively strong O/C ratios.

The upgrades reflect the improved credit support at the prior
rating levels; the affirmations reflect S&P's view that the credit
support available is commensurate with the current rating levels.

On a standalone basis, the results of the cash flow analysis
indicated higher ratings on the class B-1L-R, B-2L, and B-3L notes.
S&P said, "Though the B-2L and B-3L I/C ratios are failing, our
cash flow models take into account that these tranches can defer
their interest. However, given the portfolio's heightened exposure
to 'CCC' rated collateral obligations, assets trading at distressed
prices, obligor concentration, and decline in weighted average
spread, we limited the upgrade to the class B-1L-R notes and
affirmed our ratings on the class B-2L and B-3L notes to offset
future potential credit migration in the underlying collateral and
increased concentration in the portfolio as the assets mature or
prepay."

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction as reflected in
the aforementioned 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. In addition, our analysis 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 all of the rated
outstanding classes have adequate credit enhancement available at
the rating levels associated with these 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 we  will take further rating actions
as we deem necessary."

  RATINGS RAISED AND REMOVED FROM CREDITWATCH POSITIVE

  OFSI Fund V, Ltd.                   Rating
  Class         To          From
  A-3F-R        AAA (sf)    AA+ (sf)/Watch Pos
  A-3L-R        AAA (sf)    AA+ (sf)/Watch Pos
  B-1L-R        AA+ (sf)    A+ (sf)/Watch Pos

  RATINGS AFFIRMED

  OFSI Fund V, Ltd.
  Class         Rating
  A-2F-R        AAA (sf)
  A-2L-R        AAA (sf)
  B-2L          BB+ (sf)
  B-3L     B+ (sf)



ONEMAIN FINANCIAL 2019-1: DBRS Gives (P)BB Rating on E Notes
------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
notes to be issued by OneMain Financial Issuance Trust 2019-1
(OMFIT 2019-1):

-- $315,690,000 Series 2019-1, Class A at AAA (sf)
-- $42,970,000 Series 2019-1, Class B at AA (sf)
-- $27,610,000 Series 2019-1, Class C at A (sf)
-- $34,810,000 Series 2019-1, Class D at BBB (sf)
-- $42,500,000 Series 2019-1, Class E at BB (sf)

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

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

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

-- OneMain Financial, Inc.'s (OneMain) capabilities with regards
to originations, underwriting and servicing.

-- The credit quality of the collateral and performance of
OneMain's consumer loan portfolio. DBRS used a hybrid approach in
analyzing the OneMain portfolio that incorporates elements of
static pool analysis, employed for assets such as consumer loans,
and revolving asset analysis, employed for such assets as credit
card master trusts.

-- The legal structure and presence of legal opinions that address
the true sale of the assets to the Issuer, the non-consolidation of
the special-purpose vehicle with OneMain, that the trust has a
valid first-priority security interest in the assets and the
consistency with DBRS's "Legal Criteria for U.S. Structured
Finance."

The OMFIT 2019-1 transaction represents the eleventh securitization
of a portfolio of non-prime and subprime personal loans originated
through OneMain's branch network.

Credit enhancement in the transaction consists of
overcollateralization (OC), subordination, excess spread and a
reserve account. The initial amount of OC is 3.45% of the aggregate
loan principal balance. The subordination in the transaction refers
to the Class B Notes, Class C Notes, Class D Notes and Class E
Notes, which are subordinated to the Class A Notes. The reserve
account is 0.50% of the initial loan principal balance. It is
funded at inception and is non-declining. Initial Class A credit
enhancement of 34.75% includes a 0.50% reserve account, OC of 3.45%
and 30.80% subordination. Initial Class B credit enhancement of
25.80% includes a 0.50% reserve account, OC of 3.45% and 21.85%
subordination. Initial Class C credit enhancement of 20.05%
includes a 0.50% reserve account, OC of 3.45% and 16.10%
subordination. Initial Class D credit enhancement of 12.80%
includes a 0.50% reserve account, OC of 3.45% and 8.85%
subordination. Initial Class E credit enhancement of 3.95% includes
a 0.50% reserve account, OC of 3.45% . Interest on the Notes is
payable monthly at a fixed rate.

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


ONEMAIN FINANCIAL 2019-1: S&P Assigns Prelim BB Rating on E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to OneMain
Financial Issuance Trust 2019-1's personal consumer loan-backed
notes.

The note issuance is an asset-backed securities transaction backed
by personal consumer loan receivables.

The preliminary ratings are based on information as of Jan. 10,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The availability of approximately 53.0%, 46.1%, 41.4%, 33.5%,
and 27.2% credit support to the class A, B, C, D, and E 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 S&P's stressed cash flow
scenarios.

-- S&P said, "Our expectation that under a moderate ('BBB') stress
scenario, all else being equal, our ratings on the class A and B
notes will remain within one rating category of the assigned
preliminary 'AAA (sf)' and 'AA (sf)' ratings, respectively, for the
life of the deal; our ratings on the class C and D notes will
remain within two rating categories of the assigned preliminary 'A
(sf)' and 'BBB (sf)', respectively, for the life of the deal; and
our rating on the class E notes will remain within two rating
category of the assigned preliminary 'BB (sf)' rating in the next
12 months but the class would ultimately default under a BBB
scenario." The above rating movements are within the one-category
rating tolerance for 'AAA' and 'AA' rated securities and a
two-category rating tolerance for 'A', 'BBB', and 'BB' rated
securities during the first year; 'BB' rated securities are
permitted to default within three years under a 'BBB' stress
scenario.

-- 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 transaction's payment and legal structures.

  PRELIMINARY RATINGS ASSIGNED
  OneMain Financial Issuance Trust 2019-1

  Class     Rating      Type            Interest        Amount
                                        rate           (mil. $)(i)
  A         AAA (sf)    Senior          Fixed          315.690
  B         AA (sf)     Subordinate     Fixed           42.970
  C         A (sf)      Subordinate     Fixed           27.610
  D         BBB (sf)    Subordinate     Fixed           34.810
  E         BB (sf)     Subordinate     Fixed           42.500

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



REALT 2015-1: Fitch Affirms BB Rating on C$3.8MM Class F Certs
--------------------------------------------------------------
Fitch Ratings has affirmed eight classes of Real Estate Asset
Liquidity Trust's commercial mortgage pass-through certificates,
series 2015-1. All currencies are in Canadian dollars (CAD).

KEY RATING DRIVERS

Higher Loss Expectations/Fitch Loans of Concern: Overall loss
expectations have increased since Fitch's prior review primarily
due to the performance decline of the largest loan in the pool,
Alta Vista Manor Retirement Ottawa (9.2%). The loan is secured by a
174-unit independent living property located in Ottawa, ON and is a
Fitch Loan of Concern (FLOC). As of November 2018, occupancy has
declined to 75% from 96% at issuance resulting in a net operating
income (NOI) decline of 55%. The servicer reports that competition
and other economic factors have caused the drop in occupancy. The
loan, however, remains current and is fully guaranteed by the
sponsor, which is a joint venture (JV) between Welltower, Inc. and
Revera, Inc., two leading owner/operators in the senior housing
sector. The JV acquired the original sponsor, Regal Lifestyle
Communities, Inc., in October 2015.

The 16A Street Multi-Res Calgary loan (1%) is another FLOC, which
is secured by a 24 unit multi-family property located in Calgary,
AB. The property NOI has declined 40% since issuance due to lower
rental revenues and an increase in property taxes. In addition,
occupancy is down slightly to 83% compared to 88% at issuance.

Increasing Credit Enhancement: Credit enhancement has increased
since issuance due to continued amortization. As of the December
2018 distribution date, the pool's aggregate principal balance has
paid down by 9.3% to $303.6 million from $334.8 million at
issuance. The pool has a weighted average amortization term of 25.7
years, which represents faster amortization than U.S. conduit
loans. There are no partial or full interest-only loans.

Canadian Loan Attributes: The ratings reflect strong Canadian
commercial real estate loan performance, including a low
delinquency rate and low historical losses of less than 0.1%, as
well as positive loan attributes such as short amortization
schedules, recourse to the borrower and additional guarantors.
Approximately 80% of the loans feature full or partial recourse to
the borrowers and/or sponsors.

RATING SENSITIVITIES

The Rating Outlook for class G has been revised to Negative from
Stable due to Fitch's concerns with the performance of the Alta
Vista Manor Retirement Ottawa loan, as occupancy and NOI has
declined since issuance. A downgrade is possible with continued
underperformance or in the unlikely event that the loan defaults.
Conversely, the Negative Outlook may be revised with improved
performance of the loan. Outlooks on classes A-1 through F remain
Stable due to increasing credit enhancement, continued paydown, and
overall stable collateral performance. Fitch does not foresee
positive or negative ratings migration for these classes unless a
material economic or asset level event changes the underlying
transaction's portfolio-level metrics.

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

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

Fitch affirms the following classes and revises the Outlook for
class G as indicated:

  -- CAD$131.9 million class A-1 at 'AAAsf'; Outlook Stable;

  -- CAD$126.5 million class A-2 at 'AAAsf'; Outlook Stable;

  -- CAD$8 million class B at 'AAsf'; Outlook Stable;

  -- CAD$10 million class C at 'Asf'; Outlook Stable;

  -- CAD$9.6 million class D at 'BBBsf'; Outlook Stable;

  -- CAD$4.2 million class E at 'BBB-sf'; Outlook Stable;

  -- CAD$3.8 million class F at 'BBsf'; Outlook Stable;

  -- CAD $3.3 million class G at 'Bsf'; Outlook to Negative from
Stable.

Fitch does not rate the class H or X certificates.


TRAPEZA CDO XI: Moody's Hikes Class B Notes Rating to Ba1
---------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by Trapeza CDO XI, Ltd.:

US$281,000,000 Class A-1 First Priority Senior Secured Floating
Rate Notes Due 2041 (current balance of $81,315,004), Upgraded to
Aa1 (sf); previously on November 6, 2017 Upgraded to Aa2 (sf)

US$53,000,000 Class A-2 Second Priority Senior Secured Floating
Rate Notes Due 2041, Upgraded to Aa3 (sf); previously on November
6, 2017 Upgraded to A1 (sf)

US$20,000,000 Class A-3 Third Priority Senior Secured Floating Rate
Notes Due 2041, Upgraded to A2 (sf); previously on November 6, 2017
Affirmed Baa1 (sf)

US$25,000,000 Class B Fourth Priority Secured Deferrable Floating
Rate Notes Due 2041, Upgraded to Ba1 (sf); previously on November
6, 2017 Upgraded to Ba3 (sf)

US$33,000,000 Class C Fifth Priority Secured Deferrable Floating
Rate Notes Due 2041 (current balance including deferred interest of
$38,833,456), Upgraded to Caa3 (sf); previously on March 27, 2009
Downgraded to C (sf)

Trapeza CDO XI, Ltd., issued on November 8, 2006, is a
collateralized debt obligation (CDO) backed mainly by a portfolio
of bank and REIT trust preferred securities (TruPS).

RATINGS RATIONALE

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

The Class A-1 notes have paid down by approximately 29.1% or $33.3
million since January 2018, using principal proceeds from the
redemption of the underlying assets and the diversion of excess
interest proceeds. Since then, four assets with a total par of
$29.5 million have redeemed at par. Based on Moody's calculations,
the OC ratios for the Class A-1, Class A-2, Class A-3, Class B, and
Class C notes have improved to 279.5%, 169.2%, 147.3%, 126.8%, and
104.2%, respectively, from January 2018 levels of 242.7%, 158.4%,
140.1%, 122.0%, and 102.0%, respectively. Since January 2018, the
Class B notes' deferred interest balance has been paid in full and
the Class C notes have begun receiving current interest.
Additionally, Class A-1 notes will continue to benefit from the use
of proceeds from redemptions of any assets in the collateral pool
as the Class C OC test continues to fail.

The deal has also benefited from improvement in the credit quality
of the underlying portfolio. According to Moody's calculations, the
weighted average rating factor (WARF) improved to 1857 from 2101 in
January 2018.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's
Approach to Rating TruPS CDOs" published in October 2016.

The Credit Ratings on the notes issued by Trapeza CDO XI, Ltd. were
assigned in accordance with Moody's existing Methodology entitled
"Moody's Approach to Rating TruPS CDOs," dated October 7, 2016.
Please note that on November 14, 2018, Moody's released a Request
for Comment, in which it has requested market feedback on potential
revisions to its Methodology for TruPS CDOs. If the revised
Methodology is implemented as proposed, we do not expect the
changes to affect the Credit Ratings on notes issued by Trapeza CDO
XI, Ltd. Please refer to Moody's Request for Comment, titled
"Proposed Update to Moody's Approach to Rating TruPS CDOs," for
further details regarding the implications of the proposed
Methodology revisions on certain Credit Ratings.

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

This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings, as described below:

1) Macroeconomic uncertainty: TruPS CDOs performance could be
negatively affected by uncertainty about credit conditions in the
general economy. Moody's has a stable outlook on the US banking
sector.

2) Portfolio credit risk: Credit performance of the assets
collateralizing the transaction that is better than Moody's current
expectations could have a positive impact on the transaction's
performance. Conversely, asset credit performance weaker than
Moody's current expectations could have adverse consequences on the
transaction's performance.

3) Deleveraging: One source of uncertainty in this transaction is
whether deleveraging from unscheduled principal proceeds and excess
interest proceeds will continue and at what pace. Note repayments
that are faster than Moody's current expectations could have a
positive impact on the notes' ratings, beginning with the notes
with the highest payment priority.

4) Exposure to non-publicly rated assets: The deal contains a large
number of securities whose default probability Moody's assesses
through credit scores derived using RiskCalc™ or credit
estimates. Because these are not public ratings, they are subject
to additional uncertainties.

Moody's obtained a loss distribution for this CDO's portfolio by
simulating defaults using Moody's CDOROM™, which used Moody's
assumptions for asset correlations and fixed recoveries in a Monte
Carlo simulation framework. Moody's then used the resulting loss
distribution, together with structural features of the CDO, as an
input in its CDOEdge™ cash flow model.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, and weighted average recovery rate,
are based on its methodology and could differ from the trustee's
reported numbers. In its base case, Moody's analyzed the underlying
collateral pool as having a performing par and principal proceeds
balance (after treating deferring securities as performing if they
meet certain criteria) of $227.3 million, defaulted/deferring par
of $53.0 million, a weighted average default probability of 22.1%
(implying a WARF of 1857), and a weighted average recovery rate
upon default of 11.2%.

In addition to the quantitative factors Moody's explicitly models,
qualitative factors are part of rating committee considerations.
Moody's considers the structural protections in the transaction,
the risk of an event of default, recent deal performance under
current market conditions, the legal environment and specific
documentation features. All information available to rating
committees, including macroeconomic forecasts, inputs from other
Moody's analytical groups, market factors, and judgments regarding
the nature and severity of credit stress on the transactions, can
influence the final rating decision.

The portfolio of this CDO contains mainly TruPS issued by small to
medium sized U.S. community banks and REIT companies that Moody's
does not rate publicly. To evaluate the credit quality of bank
TruPS that do not have public ratings, Moody's uses RiskCalc™, an
econometric model developed by Moody's Analytics, to derive credit
scores. Moody's evaluation of the credit risk of most of the bank
obligors in the pool relies on the latest FDIC financial data. For
REIT TruPS that do not have public ratings, Moody's REIT group
assesses their credit quality using the REIT firms' annual
financials.


UBS COMMERCIAL 2012-C1: Fitch Affirms Bsf Rating on Class F Certs
-----------------------------------------------------------------
Fitch Ratings affirms nine classes of UBS Commercial Trust 2012-C1
commercial mortgage pass-through certificates.

KEY RATING DRIVERS

Improved Credit Enhancement, Significant Defeasance: The pool has
benefited from increased credit enhancement due to loan payoffs,
scheduled amortization and defeased collateral. Eleven loans
(25.2%) are fully defeased, including three of the top 10 loans in
the pool. As of the December 2018 distribution date, the pool's
aggregate principal balance had been paid down by 17.4% to $1.1
billion from $1.3 billion at issuance. Six loans have paid off
since issuance. Only two loans (14.1%) are interest-only; all
remaining loans are currently amortizing. No loans mature or have
their anticipated repayment dates (ARD) prior to 2021 (16.7%) or
2022 (81.7%).

Stable Performance/Marginal Increase in Expected Losses: The
majority of the pool continues to exhibit stable performance. Since
the last rating action, increased loss estimates are primarily
driven by the performance decline of the six Fitch Loans of Concern
(FLOCs; 8.2%).

Alternative Loss Consideration, Poughkeepsie Galleria: The Negative
Outlook on class F reflects concerns surrounding the refinance risk
of the Poughkeepsie Galleria (7.1% of the pool). The loan is
secured by a 691,325 sf portion of a two-level enclosed regional
mall located in Poughkeepsie, NY, a secondary market approximately
70 miles north of New York City. The servicer-reported cash flow
has been trending downward over the last several years, and the
servicer-reported YTD September 2018 NOI debt service coverage
ratio (DSCR) was 1.17x. While collateral occupancy remains high at
88.5%, the center's anchors include a non-collateral Sears and
JCPenney, which had TTM August 2018 reported sales of $88 psf.
In-line sales are not strong at $376 psf. Fitch is concerned about
the loan's ability to refinance at maturity in November 2021. Fitch
performed an additional sensitivity scenario that assumed a
potential outsized loss of 40% on this loan.

Fitch Loans of Concern: Six loans (8.2%) are designated FLOCs,
including one specially serviced asset (1.5%). The largest FLOC is
the Meadows Crossing loan (2.2%), which is secured by a 189-unit
(748 bed) off-campus student housing complex located in Allendale,
MI, less than a half mile from Grand Valley State University.
Performance has declined due to higher vacancy related to increased
competition in the submarket. The next largest FLOC is the REO,
Emerald Coast Hotel Portfolio, which consists of two limited
service hotels located in West Virginia. The loan transferred to
special servicing after the borrower filed Chapter 11; the loan
became REO in November 2017. The Westminster Square loan (1.5%) is
secured by a 195,000 sf office property located in downtown
Providence, RI that has occupancy issues. Per the most recent 2018
rent roll, the property was 74.6% with an additional 40% of the NRA
scheduled to roll over the next year. The remaining three FLOCs
include loans secured by a four property office portfolio (1.5%),
which has seen a large tenant that occupied 19% of the NRA
reportedly vacate, a three property hotel portfolio (1.3%), which
had a YE 2017 NOI DSCR below 1.0x, and a 31,000 sf retail center
(0.2%) located in Hurst, TX, which had a most recent
servicer-reported occupancy of 60%. Fitch will continue to monitor
these loans/assets.

RATING SENSITIVITIES

The Negative Outlook on class F reflects the potential for
downgrade due to concerns surrounding the refinance risk associated
with the Poughkeepsie Galleria as well as the performance issues of
the FLOCs. Rating downgrade to this class may occur should
performance of these loans continue to decline. Rating Outlooks for
the senior classes remain Stable due to the significant credit
enhancement, defeasance, and the stable performance of the majority
of the remaining pool and continued expected amortization. Rating
upgrades may be limited due to increasing pool concentration and
adverse selection.

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

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


Fitch has affirmed the following ratings and revised outlooks as
indicated:

  -- $639.2 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $61.3 million class A-AB at 'AAAsf'; Outlook Stable;

  -- $113.1 million class A-S at 'AAAsf'; Outlook Stable;

  -- Interest only class X-A at 'AAAsf'; Outlook Stable;

  -- $66.5 million class B at 'AAAsf'; Outlook Stable;

  -- $49.9 million class C at 'AAsf'; Outlook Stable;

  -- $74.9 million class D at 'BBB-sf'; Outlook Stable;

  -- $26.6 million class E at 'BBsf'; Outlook Stable;

  -- $23.3 million class F at 'Bsf'; Outlook to Negative from
Stable.

Class A-1 and A-2 have paid in full. Fitch does not rate the class
G or X-B interest-only certificates.


WELLS FARGO 2011-C4: Fitch Lowers $18.5MM Cl. F Certs Rating to BB
------------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed 10 classes of Wells
Fargo Bank, N.A. (WFRBS) commercial mortgage pass-through
certificates series 2011-C4.

KEY RATING DRIVERS

Increased Loss Expectations: Overall loss expectations have
increased since Fitch Ratings' prior rating action. Fitch remains
concerned about the ability of two regional malls, Fox River Mall
(13.9%) and Eastgate Mall (2.46%), to refinance at maturity. Fitch
considers these two loans, as well as the Quail Springs loan
(2.14%), Fitch Loans of Concern (FLOC). In addition, two loans
(2.49%) remain in special servicing and are considered FLOCs.

Fitch Loans of Concern: Fitch has designated five FLOCs
representing approximately 21% of the pool's balance, including two
loans in special servicing (2.49%).

The first FLOC is the largest loan in the pool, the Fox River Mall.
The property is a 1.2 million sf (648,728 sf collateral) regional
mall located in Appleton, WI. The mall is anchored by
non-collateral JC Penney, Target and Macy's as well as Scheel's,
which is part of the collateral. As of September 2018, in-line
sales had fallen at the property to $338 psf from $385 psf at
issuance. The loan matures in June of 2021.

The second FLOC is the ninth largest loan in the pool, the Eastgate
Mall. The mall is an 853,040 sf (561,250 sf collateral) regional
mall located in the suburbs of Cincinnati, OH. The mall is anchored
by Dillard's, JC Penney, Sears and Kohl's. Sales have declined
since issuance and the loan matures in April 2021.

The third FLOC is Quail Springs, the 12th largest loan in the pool.
The loan is secured by a 298,610 sf suburban office property
located in Oklahoma City, OK. In 2015 and 2016, the two largest
tenants occupying approximately 50% of the net rentable area
vacated.

The fourth FLOC is the specially serviced Wausau Center (1.59%)
asset. The property became real estate owned (REO) in August of
2017. The mall is currently 27% occupied with all three anchors
remaining vacant. The special servicer is working to stabilize the
rent roll and preparing the property for sale.

The final FLOC is the specially serviced Park Place Student Housing
(0.9%) loan. The loan is secured by a student housing property in
Fredonia, NY. The loan originally transferred to special servicing
in 2014 for imminent default and has remained with the servicer
since. The loan remains current.

Increased Credit Enhancement: Credit enhancement has increased
since Fitch's prior rating action. Seven loans paid off at maturity
and an additional three loans defeased, including the second
largest loan in the pool (10.2% of the pool's balance). As of the
December 2018 remittance date, the pool had paid down approximately
30%, and 30% of the pool's balance is currently defeased.

Alternative Loss Considerations: In addition to modeling a base
case loss, Fitch performed an additional sensitivity scenario. A
25% loss severity was applied to the Fox River Mall due to property
type, location, declining performance and an upcoming maturity
date. Fitch took the defeasance adjusted credit enhancement into
consideration in the alternative loss scenario. The Negative
Outlooks on classes E and F, and the downgrade to class G reflect
this scenario analysis.

ADDITIONAL CONSIDERATIONS

Retail and Regional Mall Concentration: There is a high amount
retail exposure within the pool. Loans secured by retail properties
represent 47% of the pool, with four retail loans in the top 10.
This includes two regional mall properties: Fox River Mall (13.9%)
in Appleton, WI and Eastgate Mall (2.5%) located in Union Township,
OH. Both malls have direct or indirect exposure to Sears, Macy's,
and JC Penney, all of which have reported recent store closures.
The transaction is also concentrated in loan size, with the top 15
loans representing 68.42% of the pool's balance.

RATING SENSITIVITIES

Rating Outlooks on classes A3 through D remain Stable due to
increasing credit enhancement, continued paydown and relatively
stable collateral performance for the majority of the pool. The
Rating Outlook on class E has been revised to Negative from Stable
to reflect the potential downgrade concerns as a result of the
expected losses from the specially serviced assets as well as the
retail and regional mall exposure within the pool. Classes F and G
remain on Outlook Negative due to the FLOCs and retail/regional
mall exposure. Near-term upgrades are unlikely but possible with
significant paydown, defeasance and improved performance among the
FLOCs. Furthermore, downgrades to classes E and F are possible if
FLOC performance continues to deteriorate.

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

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

Fitch has downgraded the following ratings:

  -- $18.5 million class G to 'CCCsf' from 'Bsf'; RE 75%.

Fitch has affirmed the following ratings and revises Outlooks as
indicated:

  -- $9.6 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $90 million class A-FL at 'AAAsf'; Outlook Stable;

  -- $0 class A-FX at 'AAAsf'; Outlook Stable;

  -- $681.4 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $781 million* X-A at 'AAAsf'; Outlook Stable;

  -- $42.6 million class B at 'AAsf'; Outlook Stable;

  -- $42.6 million class C at 'A+sf'; Outlook Stable;

  -- $33.3 million class D at 'A-sf'; Outlook Stable;

  -- $51.8 million class E at 'BBB-sf'; Outlook to Negative from
Stable;

  -- $20.4 million class F at 'BBsf'; Outlook Negative.

  * Notional and interest-only.

The class A-1 and A-2 certificates have paid in full. Fitch does
not rate the class H or X-B certificates.


WELLS FARGO 2019-1: Moody's Assigns (P)Ba1 Rating on Class B-4 Debt
-------------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to 24
classes of residential mortgage-backed securities issued by Wells
Fargo Mortgage Backed Securities 2019-1 Trust. The ratings range
from (P)Aaa (sf) to (P)Ba1 (sf).

WFMBS 2019-1 is the first prime issuance by Wells Fargo Bank, N.A.
(the sponsor) in 2019. The mortgage loans for this transaction are
originated by Wells Fargo Bank, N.A. generally in accordance with
the non-conforming underwriting guidelines. All of the loans are
designated as qualified mortgages (QM) under the QM safe harbor
rules.

Wells Fargo Bank, N.A. will service all the loans and will also be
the master servicer for this transaction. The servicer will be
primarily responsible for funding certain servicing advances and
delinquent scheduled interest and principal payments for the
mortgage loans, unless the servicer determines that such amounts
would not be recoverable. In the event a servicer event of default
has occurred and the Trustee terminates the servicer as a result
thereof, the master servicer shall fund any advances that would
otherwise be required to be made by the terminated servicer (to the
extent the terminated Servicer has failed to fund such advances
until such time as a successor servicer is appointed and commences
servicing the mortgage loans). The master servicer and servicer
will be entitled to be reimbursed for any such monthly advances
from future payments and collections (including insurance and
liquidation proceeds) with respect to those mortgage loans.

The WFMBS 2019-1 transaction is a securitization of 1,017 30-year,
fixed rate, prime residential mortgage loans with an unpaid
principal balance of $711,662,431. The pool has strong credit
quality and consists of borrowers with high FICO scores,
significant equity in their properties and liquid cash reserves.
The pool has clean pay history and is seasoned for almost 6
months.

The securitization has a shifting interest structure with a
five-year lockout period that benefits from a senior subordination
floor and a subordinate floor.

The complete rating actions are as follows:

Issuer: Wells Fargo Mortgage Backed Securities 2019-1 Trust

Cl. A-1, Assigned (P)Aaa (sf)

Cl. A-2, Assigned (P)Aaa (sf)

Cl. A-3, Assigned (P)Aaa (sf)

Cl. A-4, Assigned (P)Aaa (sf)

Cl. A-5, Assigned (P)Aaa (sf)

Cl. A-6, Assigned (P)Aaa (sf)

Cl. A-7, Assigned (P)Aaa (sf)

Cl. A-8, Assigned (P)Aaa (sf)

Cl. A-9, Assigned (P)Aaa (sf)

Cl. A-10, Assigned (P)Aaa (sf)

Cl. A-11, Assigned (P)Aaa (sf)

Cl. A-12, Assigned (P)Aaa (sf)

Cl. A-13, Assigned (P)Aaa (sf)

Cl. A-14, Assigned (P)Aaa (sf)

Cl. A-15, Assigned (P)Aaa (sf)

Cl. A-16, Assigned (P)Aaa (sf)

Cl. A-17, Assigned (P)Aa1 (sf)

Cl. A-18, Assigned (P)Aa1 (sf)

Cl. A-19, Assigned (P)Aaa (sf)

Cl. A-20, Assigned (P)Aaa (sf)

Cl. B-1, Assigned (P)Aa3 (sf)

Cl. B-2, Assigned (P)A1 (sf)

Cl. B-3, Assigned (P)Baa1 (sf)

Cl. B-4, Assigned (P)Ba1 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 0.25%
in a base scenario and reaches 3.50% at a stress level consistent
with the Aaa (sf) ratings.

Our loss estimates are based on a loan-by-loan assessment of the
securitized collateral pool as of the cut-off date using Moody's
Individual Loan Level Analysis (MILAN) model. Loan-level
adjustments to the model included adjustments to borrower
probability of default for higher and lower borrower debt-to-income
ratios (DTIs), for borrowers with multiple mortgaged properties,
self-employed borrowers, origination channels and for the default
risk of Homeownership association (HOA) properties in super lien
states. The model combines loan-level characteristics with economic
drivers to determine the probability of default for each loan, and
hence for the portfolio as a whole. Severity is also calculated on
a loan-level basis. The pool loss level is then adjusted for
borrower, zip code, and MSA level concentrations.

We base our provisional ratings on the certificates on the credit
quality of the mortgage loans, the structural features of the
transaction, our assessments of the origination quality and
servicing arrangement, the strength of the third party due
diligence and the R&W framework of the transaction.

Collateral Description

The WFMBS 2019-1 transaction is a securitization of 1,017 first
lien residential mortgage loans with an unpaid principal balance of
$711,662,431. The loans in this transaction have strong borrower
characteristics with a weighted average original FICO score of 780
and a weighted-average original loan-to-value ratio (LTV) of 73.2%.
In addition, 11.2% of the borrowers are self-employed and refinance
loans comprise 13.0% of the aggregate pool. 7.8% (by loan balance)
of the pool comprised of construction to permanent loans. The
construction to permanent is a two part loan where the first part
is for the construction and then it becomes a permanent mortgage
once the property is complete. For all the loans in the pool, the
construction was complete and because the borrower cannot receive
cash from the permanent loan proceeds or anything above the
construction cost, we treated these loans as a rate term refinance
rather than a cash out refinance loan. The pool has a high
geographic concentration with 39.6% of the aggregate pool located
in California and 16.2% located in the New York-Newark-Jersey City
MSA. The characteristics of the loans underlying the pool are
generally comparable to other recent prime RMBS transactions backed
by 30-year mortgage loans that we have rated.

Origination Quality

The mortgage loans for this transaction are originated by Wells
Fargo Bank generally in accordance with the non-conforming
underwriting guidelines. After considering the non-conforming
underwriting guidelines from Wells Fargo Bank, we made no
adjustments to our base case and Aaa loss expectations. Majority of
the loans are originated through retail channel i.e. 80.9% of the
pool and the remaining pool i.e. 19.1% is originated through
correspondent channel.

Third Party Review and Reps & Warranties (R&W)

One independent third-party review firm, Clayton Services LLC , was
engaged to conduct due diligence for the credit, regulatory
compliance, property valuation, and data accuracy for all of the
1,030 loans in the initial population of this transaction (100% of
the mortgage pool).

The credit review consisted of a review of the documentation in
each loan file relating to the creditworthiness of the borrowers,
and an assessment of whether the characteristics of the mortgage
loans and the borrowers reasonably conformed to Wells Fargo's
underwriting guidelines. Where there were exceptions to guidelines,
the TPR firm noted compensating factors. Additionally, the TPR firm
evaluated evidence of the borrower's willingness and ability to
repay the obligation and examined Data Verify/Fraudgaurd/Interthinx
or similar risk evaluation reports ordered by Wells Fargo or
Clayton.

Clayton Services LLC 's regulatory compliance review consisted of a
review of compliance with the Truth in Lending Act and the Real
Estate Settlement Procedures Act among other federal, state and
local regulations. Additionally, the TPR firm applied SFIG's
enhanced RMBS 3.0 TRID Compliance Review Scope.

The TPR firm's property valuation review consisted of reviewing the
valuation materials utilized at origination to ensure the appraisal
report was complete and in conformity with the underwriting
guidelines. The TPR firm also compared third party valuation
products to the original appraisals. 10% negative variances were
reported and in some cases additional appraisals were performed.

The overall TPR results were in line with our expectations
considering the clear underwriting guidelines and overall processes
and procedures that Wells Fargo has in place. Many of the grade B
loans were underwritten using underwriter discretion where the
compensating factors were not clearly documented in the loan file.
Areas of discretion included missing verbal verification of
employment, verification of closing funds and assets and
explanation for multiple credit exceptions. The due diligence firm
noted that these exceptions are minor and/or provided an
explanation of compensating factors. Several of the compensating
factors listed were sufficient to explain the underwriting
exception. We also inquired to Wells Fargo for some of these loans
and analyzed the responses provided by them. The responses provided
by Wells and the compensating factors were adequate in our view. As
a result, we did not make any adjustment to our losses for this.

Wells Fargo Bank, as the originator, makes the loan-level
representation and warranties (R&Ws) for the mortgage loans. The
loan-level R&Ws are strong and, in general, either meet or exceed
the baseline set of credit-neutral R&Ws we have identified for US
RMBS. Further, R&W breaches are evaluated by an independent third
party using a set of objective criteria. Similar to JPMMT
transactions, the transaction contains a "prescriptive" R&W
framework. The originator makes comprehensive loan-level R&Ws and
an independent reviewer will perform detailed reviews to determine
whether any R&Ws were breached when loans become 120 days
delinquent, the property is liquidated at a loss above a certain
threshold, or the loan is 30 to 119 days delinquent and is modified
by the servicer. These reviews are prescriptive in that the
transaction documents set forth detailed tests for each R&W that
the independent reviewer will perform. We believe that Wells
Fargo's robust processes for verifying and reviewing the
reasonableness of the information used in loan origination along
with effectively no knowledge qualifiers mitigates any risks
involved. Wells Fargo has anti-fraud software tools that are
integrated with the loan origination system (LOS) and utilized
pre-closing for each loan. In addition, Wells Fargo has dedicated
credit risk, compliance and legal teams oversee fraud risk in
addition to compliance and operational risks. We did not make any
adjustment to our base case and Aaa loss expectations for R&Ws.

Tail Risk and Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
shrinks, senior bonds are exposed to increased performance
volatility, known as tail risk. The transaction provides for a
senior subordination floor of 1.20% of the closing pool balance,
which mitigates tail risk by protecting the senior bonds from
eroding credit enhancement over time. Based on our tail risk
analysis, the level of senior subordination floor in WFMBS 2019-1
provides adequate protection against potential tail risk. In
addition, if the subordinate percentage drops below 5.75% of
current pool balance, the senior distribution amount will include
all principal collections and the subordinate principal.
Additionally there is a subordination lock-out amount which is
1.20% of the closing pool balance.

Transaction structure

The securitization has a shifting interest structure that benefits
from a senior subordination floor and a subordinate floor. Funds
collected, including principal, are first used to make interest
payments and then principal payments to the senior bonds, and then
interest and principal payments to each subordinate bond. As in all
transactions with shifting interest structures, the senior bonds
benefit from a cash flow waterfall that allocates all unscheduled
principal collections to the senior bond for a specified period of
time, and increasing amounts of unscheduled principal collections
to the subordinate bonds thereafter, but only if loan performance
satisfies delinquency and loss tests.

All certificates in this transaction are subject to a net WAC cap.
Realized losses are allocated reverse sequentially among the
subordinate and senior support certificates and on a pro-rata basis
among the super senior certificates.

Exposure to Extraordinary expenses

Extraordinary Trust Expenses that will reduce amounts available to
make distributions on the Certificates and will be applied to
reduce the Net WAC Rate. However, certain extraordinary trust
expenses (such as servicing transfer costs) in the WFMBS 2019-1
transaction are deducted directly from the available distribution
amount. The remaining trust expenses (which have an annual cap of
$350,000 per year for i) Wells Fargo CTS Annual Expense Cap, ii)
Trustee Annual Expense Cap and iii) Independent Reviewer Expense
Cap) are deducted from the Net WAC Rate. We believe there is a very
low likelihood that the rated certificates in WFMBS 2019-1 will
incur any losses from extraordinary expenses or indemnification
payments from potential future lawsuits against key deal parties.
First, the loans are prime quality, 100 percent qualified mortgages
and were originated under a regulatory environment that requires
tighter controls for originations than pre-crisis, which reduces
the likelihood that the loans have defects that could form the
basis of a lawsuit. Second, the transaction has reasonably well
defined processes in place to identify loans with defects on an
ongoing basis. In this transaction, an independent breach reviewer
(Opus Capital Markets Consultants, LLC), named at closing must
review loans for breaches of representations and warranties when
certain clear defined triggers have been breached, which reduces
the likelihood that parties will be sued for inaction. Furthermore,
the issuer has disclosed the results of a compliance, credit,
valuation and data integrity review covering a sample of the
mortgage loans by an independent third party (Clayton Services
LLC). We did not make an adjustment for extraordinary expenses
because most of the trust expenses will reduce the net WAC as
opposed to the available funds.

Other Considerations

In WFMBS 2019-1, unlike other prime jumbo transactions, Wells Fargo
Bank is both the servicer and master servicer for the deal.
However, in the case of the termination of the servicer, the master
servicer must consent to the trustee's selection of a successor
servicer, and the successor servicer must have a net worth of at
least $15 million and be Fannie or Freddie approved. The master
servicer shall fund any advances that would otherwise be required
to be made by the terminated servicer (to the extent the terminated
servicer has failed to fund such advances) until such time as a
successor servicer is appointed. Additionally, in the case of the
termination of the master servicer, the trustee will be required to
select a successor master servicer in consultation with the
Depositor. The termination of the master servicer will not become
effective until either the Trustee or successor master servicer has
assumed the responsibilities and obligations of the master servicer
which also includes the advancing obligation.

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.


[*] Moody's Takes Action on $162.9MM of RMBS Issued 2004-2006
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of six tranches
and downgraded the ratings of seven tranches from five
transactions, issued by multiple issuers.

Complete rating actions are as follows:

Issuer: Aames Mortgage Investment Trust 2005-1

Cl. M5, Downgraded to Caa1 (sf); previously on Jul 17, 2014
Upgraded to B2 (sf)

Issuer: Asset Backed Securities Corporation Home Equity Loan Trust
NC 2005-HE8

M3, Downgraded to B1 (sf); previously on Nov 22, 2016 Upgraded to
Ba2 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2006-EC2

Cl. M-1, Downgraded to B1 (sf); previously on Apr 23, 2013 Upgraded
to Ba2 (sf)

Cl. M-2, Downgraded to B3 (sf); previously on Apr 9, 2018 Upgraded
to B1 (sf)

Issuer: CWABS, Inc. Asset-Backed Certificates, Series 2004-3

Cl. 1-A, Upgraded to A2 (sf); previously on Oct 12, 2016 Confirmed
at Baa2 (sf)

Cl. 3-A-3, Upgraded to Aaa (sf); previously on May 24, 2018
Upgraded to Aa1 (sf)

Cl. 3-A-4, Upgraded to Aaa (sf); previously on May 24, 2018
Upgraded to Aa1 (sf)

Cl. M-1, Upgraded to Ba2 (sf); previously on Oct 2, 2017 Upgraded
to Ba3 (sf)

Cl. M-3, Upgraded to Ca (sf); previously on Apr 16, 2012 Downgraded
to C (sf)

Issuer: Soundview Home Loan Trust 2005-1

Cl. M-3, Downgraded to B1 (sf); previously on Mar 14, 2013 Affirmed
Baa3 (sf)

Cl. M-4, Downgraded to B1 (sf); previously on Mar 22, 2016 Upgraded
to Ba1 (sf)

Cl. M-5, Downgraded to B1 (sf); previously on Feb 1, 2017 Upgraded
to Ba2 (sf)

Cl. M-6, Upgraded to Caa3 (sf); previously on Mar 14, 2013 Affirmed
C (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to improvement in pool
performances and credit enhancement available to the bonds.

The rating downgrades are primarily due to outstanding interest
shortfalls on the bonds which are not expected to be recouped as
the impacted bonds have weak structural mechanisms to reimburse
accrued interest shortfalls. The downgrade of Cl. M5 from Aames
Mortgage Investment Trust 2005-1 is due to a weak interest promise
that caps the interest accrued on the class to interest collections
on the collateral. As of December 2018, the outstanding interest
shortfall is approximately $833,943 (4.48% of Cl. M5 original
balance). The downgrade of Cl. M2 from Bear Stearns Asset Backed
Securities I Trust 2006-EC2 is due to the weaker performance of the
underlying collateral. The rating actions reflect the recent
performance and Moody's updated loss expectations on the underlying
pools.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in January 2017.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.9% in December 2018 from 4.1% in
December 2017. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2019 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2019. Lower increases than
Moody's expects or decreases could lead to negative rating actions.
Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions.



[*] Moody's Takes Action on $195MM Subprime RMBS Issued 2006-2007
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of nine tranches
from four transactions, backed by Subprime loans, issued by
multiple issuers.

Complete rating actions are as follows:

Issuer: CWABS Asset-Backed Certificates Trust 2007-BC2

Cl. 2-A-3, Upgraded to Ba3 (sf); previously on Oct 17, 2016
Upgraded to Caa1 (sf)

Cl. 2-A-4, Upgraded to B3 (sf); previously on Oct 17, 2016 Upgraded
to Caa2 (sf)

Issuer: First Franklin Mortgage Loan Trust 2006-FF3

Cl. A-1, Upgraded to Aaa (sf); previously on Jul 19, 2016 Upgraded
to A1 (sf)

Cl. A-2B, Upgraded to A1 (sf); previously on Feb 13, 2018 Upgraded
to Baa2 (sf)

Cl. A-2C, Upgraded to A2 (sf); previously on Feb 13, 2018 Upgraded
to Baa3 (sf)

Issuer: First Franklin Mortgage Loan Trust 2006-FF8

Cl. I-A-1, Upgraded to Aa1 (sf); previously on May 18, 2017
Upgraded to Baa1 (sf)

Cl. II-A-3, Upgraded to A3 (sf); previously on Feb 13, 2018
Upgraded to Ba1 (sf)

Cl. II-A-4, Upgraded to Baa2 (sf); previously on Feb 13, 2018
Upgraded to Ba3 (sf)

Issuer: GSAMP Trust 2006-FM1

Cl. A-1, Upgraded to Caa2 (sf); previously on Jul 15, 2011
Downgraded to Ca (sf)

RATINGS RATIONALE

The actions reflect the recent performance of the underlying pools
and Moody's updated loss expectations on the pools. The upgrades on
First Franklin Mortgage Loan Trust 2006-FF3, First Franklin
Mortgage Loan Trust 2006-FF8, and CWABS Asset-Backed Certificates
Trust 2007-BC2 are primarily due to recent amortization and
increased subordination, while the upgrade on GSAMP Trust 2006-FM1
reflects information provided by the Trustee regarding how
principal payments are allocated to the senior certificates

CWABS Asset-Backed Certificates Trust 2007-BC2 Class 2-A-3, First
Franklin Mortgage Loan Trust 2006-FF8 Class II-A-3 and First
Franklin Mortgage Loan Trust 2006-FF3 Class A-2B have amortized
significantly in recent periods and have tranche factors of
approximately 24%, 13%, and 8% respectively as of Dec 2018. First
Franklin Mortgage Loan Trust 2006-FF8 Class II-A-4 and First
Franklin Mortgage Loan Trust 2006-FF3 Class A-2C have also
benefited as they are next in line to receive principal payments in
their respective transactions. Moreover, First Franklin Mortgage
Loan Trust 2006-FF3 Class A-1 and First Franklin Mortgage Loan
Trust 2006-FF8 Class I-A-1 have built significant group level
overcollateralization, to approximately 78% and 51% respectively.

For GSAMP Trust 2006-FM1, its analysis reflects an update to the
cash flow model used to reflect the current allocations of payments
being made by the trustee, contrary to allocations described in the
Pooling and Servicing Agreement (PSA) of the transaction. The PSA
for GSAMP Trust 2006-FM1 states that all the Class A certificates
shall receive principal pro-rata beginning on the date the
subordinate and Class-X certificates have been reduced to zero. The
subordinate and Class-X certificates for this transaction have
previously been reduced to zero; however, the trustee is
distributing group II principal payments pro-rata to the Class A-2C
and Class A-2D certificates rather than aggregating these payments
with group I principal payments and then distributing them to all
Class A certificates pro-rata.

The PSAs for First Franklin Mortgage Loan Trust 2006-FF3 and First
Franklin Mortgage Loan Trust 2006-FF8 incorporate similar language
for cash flow allocation. Although Moody's does not expect losses
in these transactions to exceed the balance of the subordinate
certificates, its analysis and related cash flow modeling consider
stress scenarios where this would occur.

The PSAs for these deals have similar principal waterfall language
and the same trustee as GSAMP Trust 2006-FM1, and its cash flow
models for these two transactions reflect a similar allocation of
principal payments, in the event that their subordinate and Class-X
certificates are reduced to zero, as that being made by the trustee
in GSAMP Trust 2006-FM1 (contrary to that described in the PSA of
the deals).

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in January 2017.

The Credit Ratings were assigned in accordance with Moody's
existing Methodology entitled "US RMBS Surveillance Methodology,"
dated 1/31/2017.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate
the unemployment rate fell to 3.9% in December 2018 from 4.1% in
December 2017. Moody's forecasts an unemployment central range of
3.5% to 4.5% for the 2019 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2019. Lower increases than
Moody's expects or decreases could lead to negative rating actions.
Performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions. Finally, a change in how the trustee allocates
principal in these or similar transactions could lead to rating
actions.



[*] S&P Lowers Ratings on 10 Classes From Four U.S. RMBS Deals
--------------------------------------------------------------
S&P Global Ratings, on Jan. 9, 2018, completed its review of 10
classes from four U.S. residential mortgage-backed securities
(RMBS) transactions issued in 2003 and 2004 and backed by prime
jumbo collateral. The review yielded 10 downgrades.

ANALYTICAL CONSIDERATIONS

S&P said, "The downgrades are based on the implementation of our
tail risk analysis per our criteria "U.S. RMBS Surveillance Credit
And Cash Flow Analysis For Pre-2009 Originations," published March
2, 2016. We apply this analysis when the transaction contains fewer
than 100 loans on the structure level or group level (group-level
analysis is performed only if the transaction has multiple groups
and cross-subordination is depleted)."

As RMBS transactions become more seasoned, the number of
outstanding mortgage loans backing them declines as loans are
prepaid or default. As a result, a liquidation and subsequent loss
on one or a small number of remaining loans at the tail end of a
transaction's life may have a disproportionate impact on remaining
credit enhancement, which could result in a level of credit
instability that is inconsistent with high ratings. According to
our criteria, additional minimum loss projection estimations are
calculated at each rating category based on a certain number of
loans defaulting and liquidating. To address the potential that
greater losses could result if the loans with higher balances were
to default, the criteria use the largest liquidation amounts for
each rating category.

S&P said, "If the transaction's structure contains multiple
collateral groups and cross-subordination remains outstanding, we
will apply our tail risk analysis on the structure level, since
cross-subordination is shared among all groups. In this scenario,
we would calculate tail risk caps using the structure-level loan
count irrespective of the groups' loan counts.

"If the transaction's structure contains multiple collateral groups
and cross-subordination no longer remains outstanding, we will
apply our tail risk analysis on the respective group since
group-level losses are not absorbed from cross-subordination. In
this scenario, we would calculate tail risk caps using the
group-level loan count, irrespective of the structure loan count."

A list of Affected Ratings can be viewed at:

     https://bit.ly/2sjbvHn



[*] S&P Takes Various Actions on 15 Classes From Nine US RMBS Deals
-------------------------------------------------------------------
S&P Global Ratings completed its review of 15 classes from nine
U.S. residential mortgage-backed securities (RMBS) transactions
issued between 2006 and 2010. All of these transactions are backed
by prime jumbo, Alternative-A, or negative-amortization collateral.
The review yielded one upgrade, two downgrades, six affirmations,
and six discontinuances.

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 include:

-- Underlying collateral performance/delinquency trends;
-- Loan modification criteria;
-- Tail risk; and
-- Available subordination and/or overcollateralization.

Rating Actions

The rating changes are the result of transaction-specific
collateral performance and/or structural characteristics, or the
application of specific criteria applicable to these classes.

The affirmations of ratings reflect our opinion that our projected
credit support and collateral performance on these classes has
remained relatively consistent with our prior projections.

A list of Affected Ratings can be viewed at:

            https://bit.ly/2ACu9P2



[*] S&P Takes Various Actions on 54 Classes From 19 US RMBS Deals
-----------------------------------------------------------------
S&P Global Ratings completed its review of 54 classes from 19 U.S.
residential mortgage-backed securities (RMBS) resecuritized real
estate mortgage investment conduit (re-REMIC) transactions issued
between 2004 and 2010. All of these transactions are backed by
alternative-A, negative-amortization (neg-am), and prime jumbo
collateral. The review yielded six upgrades, one downgrade, 39
affirmations, one withdrawal, and one discontinuance. Additionally,
S&P placed six ratings on CreditWatch with negative implications.

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 include:

-- Collateral performance/delinquency trends;
-- Historical interest shortfalls/missed interest payments;
-- Erosion of or increases in credit support;
-- Expected short duration;
-- Interest-only criteria; and
-- Available subordination and/or overcollateralization.

Rating Actions

S&P said, "The affirmations of ratings reflect our opinion that our
projected credit support and collateral performance on these
classes has remained relatively consistent with our prior
projections.

"We placed our 'AA+ (sf)' ratings on classes A-3, A-4, A-5, A-6,
A-11, and A-12 from WaMu Mortgage Pass-Through Certificates Series
2004-RS1 Trust on CreditWatch with negative implications. The
CreditWatch negative placements reflect our review of a legal
expense incurred in the October 2018 remittance period, which could
have a negative impact on our ratings on the affected classes.
After verifying with the trustee the nature of this expense and the
impact, if any, on these classes, we will take rating actions that
we consider appropriate per our criteria, including downgrades to
the low speculative-grade range and/or withdrawals."

A list of Affected Ratings can be viewed at:

           https://bit.ly/2Fk6ebf



                            *********

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