/raid1/www/Hosts/bankrupt/TCR_Public/190512.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

              Sunday, May 12, 2019, Vol. 23, No. 131

                            Headlines

AASET TRUST 2017-1: Fitch Affirms BB Rating on Class C Notes
ALESCO PREFERRED XII: Moody's Hikes $70MM Class B Notes to Ba1
BAMLL COMMERCIAL 2016-ISQR: S&P Affirms BB- (sf) Rating on E Certs
BANC OF AMERICA 2007-4: Fitch Hikes $13.3MM Class G Certs to 'Bsf'
BANC OF AMERICA 2007-5: Fitch Cuts $99.7MM Class A-J Certs to CC

BEAR STEARNS 2006-IM1: Moody's Hikes Rating on 2 Tranches to Ca
BEAR STEARNS 2007-TOP26: DBRS Confirms C Ratings on 4 Debt Classes
BLUEMOUNTAIN CLO 2013-1: S&P Keeps D-R Notes Rating on Watch Neg.
BX TRUST 2019-IMC: DBRS Assigns Prov. BB Rating(low) on G Certs
CAPITALSOURCE REAL 2006-A: Fitch Affirms C Ratings on 3 Tranches

CITIGROUP MORTGAGE 2019-RP1: DBRS Finalizes B Rating on B-2 Notes
CSAIL 2016-C6: Fitch Affirms B- Rating on Class X-F Certs
CWABS ASSET-BACKED 2006-12: Moody's Hikes Class 2-A-3 Certs to B2
FIRST FRANKLIN: Moody's Cuts Class S Debt Rating to Csf
FLAGSHIP CREDIT 2019-2: S&P Assigns Prelim BB- Rating on E Notes

FREDDIE MAC 2019-2: Fitch to Rate $96.43MM Class M Certs 'B-sf'
FREDDIE MAC 2019-HQA2: S&P Assigns B+(sf) to 16 Classes of Notes
FREED 2019-1: DBRS Finalizes BB (high) Rating on Class C Notes
GLS AUTO 2018-1: S&P Raises Class C Notes Rating to BB+ (sf)
GLS AUTO 2019-2: S&P Rates Class D Notes 'BB- (sf)'

GOLDMAN SACHS 2013-G1: Fitch Affirms BB Rating on $22MM DM Debt
GS MORTGAGE 2019-GC39: Fitch to Rate $7.7MM Class G-RR Certs 'B-sf'
INSTITUTIONAL MORTGAGE 2012-2: Fitch Affirms B Rating on G Certs
JP MORGAN 2004-CIBC8: Moody's Hikes Class K Certs Rating to Caa1
JP MORGAN 2010-C2: Fitch Cuts Ratings on 2 Tranches to CCC

JP MORGAN 2019-3: DBRS Finalizes B Rating on Class B-5 Certs
LADDER CAPITAL 2017-LC26: Fitch Affirms B- on $7MM Class F Certs
LB-UBS COMMERCIAL 2006-C1: S&P Affirms CCC- Rating on Cl. D Certs
LOANCORE 2019-CRE2: DBRS Assigns (P)B(low) Rating on Class G Notes
MARINER CLO 7: Moody's Rates $15.5MM Class E Notes 'Ba3'

METLIFE SECURITIZATION 2019-1: DBRS Finalizes B Rating on B2 Notes
MONROE CAPITAL VIII: Moody's Rates $32.4MM Class E Notes '(P)Ba3'
MORGAN STANLEY 2012-C4: Moody's Lowers Class F Certs Rating to B1
N-STAR REL VIII: Fitch Cuts Rating on $22.5MM Class N Debt to C
NASSAU LTD 2019-I: Moody's Gives Ba3 Rating on $28.25MM Cl. D Notes

OLYMPIC TOWER 2017-OT: Fitch Affirms BB- Rating on Class E Certs
PARK AVENUE 2019-1: S&P Assigns BB- (sf) Rating to Class D Notes
PARK AVENUE 2019-1: S&P Assigns Prelim BB-(sf) Rating to D Notes
RALI TRUST 2006-QO9: Moody's Cuts Class AXP Debt Rating to 'C'
REGATTA II FUNDING: S&P Assigns Prelim BB- Rating to D-R2 Notes

RESIDENTIAL REINSURANCE 2019-I: S&P Rates Class 13 Notes 'B-(sf)'
SDART 2019-2: Fitch to Rate $99.1MM Class E Notes 'BBsf'
SLM PRIVATE 2003-A: Fitch Affirms BB+ Rating on Class B Debt
UNITED AUTO 2019-1: S&P Assigns Prelim B(sf) Rating to Cl. F Notes
VISIO 2019-1 TRUST: S&P Assigns B (sf) Rating to Class B-2 Notes

WELLS FARGO 2016-BNK1: Fitch Affirms B- Ratings on 2 Tranches
WELLS FARGO 2019-2: Fitch to Rate $2.214MM Class B-4 Certs 'BBsf'
WELLS FARGO 2019-2: Moody's Gives (P)Ba3 Rating on Class B-4 Debt
[*] DBRS Reviews 358 Classes From 32 US RMBS Transactions
[*] DBRS Reviews 639 Classes From 68 US ReREMIC/RMBS Transactions

[*] Moody's Cuts Ratings on 3 Tranches From 3 US RMBS Deals to 'C'
[*] Moody's Hikes $250.4MM of RMBS Deals Issued 2015-2018
[*] Moody's Hikes Ratings on $986.4 Million of RMBS Deals
[*] Moody's Takes Action on $161.3MM of RMBS Issued 2003-2007
[*] S&P Lowers Ratings on 42 Classes From 26 U.S. RMBS Deals

[*] S&P Puts Ratings on 17 Classes From 13 CLOs on Watch Negative

                            *********

AASET TRUST 2017-1: Fitch Affirms BB Rating on Class C Notes
------------------------------------------------------------
Fitch Ratings has affirmed all classes of AASET 2017-1 Trust as
follows:

  -- Class A notes at 'Asf'; Outlook Stable;

  -- Class B notes at 'BBBsf'; Outlook Stable;

  -- Class C notes at 'BBsf'; Outlook Stable.

KEY RATING DRIVERS

The affirmation of the class A, B and C notes reflects overall
stable performance to date. However, in recent months, the
transaction has experienced some stress following the bankruptcy
and subsequent repossession of an aircraft from Shaheen Air along
with varying levels of arrears from a number of airlines. This
includes the largest airline in the pool, Jet Airways, which has
grounded all flights. As a result, utilization, lease collections
and the debt service coverage ratio have declined since close.
However, LTV levels have declined and recent sales prices of five
aircraft were in line with recent appraisals. Further, each class
has paid below its scheduled principal balance. Under updated cash
flow modeling scenarios, all classes are able to pass stress
scenarios consistent with or higher than their current ratings.
Positive rating actions are not being taken on the class B and C
notes due to their subordinated position in the waterfall and the
potential for volatile future performance.

Assumptions for cash flow modeling scenarios remain consistent with
the initial review, with a few exceptions. Maintenance expenses for
the next 12 months were taken from the servicer report.
Additionally, the following unrated airlines were assumed to have
issuer default ratings of 'CCC': Flynas, New Gen Airways, Ukraine
International Airlines and Sriwijaya Air. Finally, Jet Airways was
assumed to immediately default, resulting in repossession and
remarketing costs and downtime.

RATING SENSITIVITIES

Due to the correlation between global economic conditions and the
airline industry, the ratings may be affected by the strength of
the macro-environment over the remaining term of this transaction.
Global economic conditions that are inconsistent with Fitch's
expectations and stress parameters could lead to negative rating
actions. In the initial rating analysis, Fitch found the
transaction to have minimal sensitivity to the timing or severity
of assumed recessions. Fitch found that greater default probability
of the leases would have a material impact on the ratings. In
addition, Fitch found the timing or degree of technological
advancement in the commercial aviation space and the impacts these
changes would have on values, lease rates and utilization would
have a moderate impact on the ratings.


ALESCO PREFERRED XII: Moody's Hikes $70MM Class B Notes to Ba1
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by Alesco Preferred Funding XII, Ltd.:

  US$370,000,000 Class A-1 First Priority Senior Secured Floating
  Rate Notes Due 2037 (current outstanding balance of
  $133,577,204), Upgraded to Aa1 (sf); previously on May 9, 2016
  Upgraded to Aa2 (sf)

  US$87,000,000 Class A-2 Second Priority Senior Secured Floating
  Rate Notes Due 2037, Upgraded to Aa3 (sf); previously on May 9,
  2016 Upgraded to A1 (sf)

  US$70,000,000 Class B Deferrable Third Priority Secured Floating
  Rate Notes Due 2037, Upgraded to Ba1 (sf); previously on May 9,
  2016 Upgraded to Ba2 (sf)

Alesco Preferred Funding XII, Ltd. issued in October 2006, is a
collateralized debt obligation (CDO) backed by a portfolio of bank
and insurance trust preferred securities (TruPS).

RATINGS RATIONALE

The rating actions are primarily a result of the deleveraging of
the Class A-1 notes and an increase in the transaction's
over-collateralization (OC) ratios since May 2018.

The Class A-1 notes have paid down by approximately 38.5% or $83.5
million since May 2018, using principal proceeds from the
redemption of the underlying assets and the diversion of excess
interest proceeds. Based on Moody's calculations, the OC ratios for
the Class A-1, Class A-2 and Class B notes have improved to 253.2%
,153.3% and 116.4%, respectively, from May 2018 levels of 193.3%,
138.2% and 112.4%, respectively. Moody's gave full par credit in
its analysis to one deferring asset with a total par of $11.5
million that meets certain criteria. Since May 2018, assets with a
total par of $78.7 million have redeemed at par. The Class A-1
notes will continue to benefit from the diversion of excess
interest and the use of proceeds from redemptions of any assets in
the collateral pool.

Moody's rating actions took into account a stress scenario for
highly levered bank holding company issuers. The transaction's
portfolio includes TruPS issued by a number of bank holding
companies with significant amounts of other debt on their balance
sheet which may increase the risk presented by their subsidiaries.
To address the risk from higher debt burden at the bank holding
companies, Moody's conducted a stress scenario in which it made
adjustments to the RiskCalc credit scores for these highly
leveraged holding companies. This stress scenario was an important
consideration in the rating actions.

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 (after treating
deferring securities as performing if they meet certain criteria)
of $338.2 million, defaulted/deferring par of $39.3 million, a
weighted average default probability of 8.02% (implying a WARF of
738), and a weighted average recovery rate upon default of 10%.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's
Approach to Rating TruPS CDOs" published in March 2019.

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

The performance of the rated notes is subject to uncertainty. The
performance of the rated notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The portfolio consists primarily
of unrated assets whose default probability Moody's assesses
through credit scores derived using RiskCalc or credit assessments.
Because these are not public ratings, they are subject to
additional estimation uncertainty.


BAMLL COMMERCIAL 2016-ISQR: S&P Affirms BB- (sf) Rating on E Certs
------------------------------------------------------------------
S&P Global Ratings affirmed its ratings on seven classes of
commercial mortgage pass-through certificates from BAMLL Commercial
Mortgage Securities Trust 2016-ISQR, a U.S. commercial
mortgage-backed securities (CMBS) transaction. For the affirmations
on the principal- and interest-paying classes, S&P's credit
enhancement expectation was in line with the affirmed rating
levels.

S&P affirmed its ratings on the class X-A and X-B interest-only
(IO) certificates based on its criteria for rating IO securities,
in which the ratings on the IO securities would not be higher than
that of the lowest rated reference class. Class X-A's notional
balance references class A and class X-B references classes B and
C.  

This is a stand-alone (single borrower) transaction backed by a
portion of a 10-year fixed-rate IO mortgage whole loan secured by
the borrower's fee interest in a class A office complex comprised
of three 12-story office buildings totaling 1.16 million sq. ft. in
Washington D.C. S&P's property-level analysis included a
re-evaluation of the office property that secures the whole loan
and considered the slightly declining servicer-reported net
operating income (due primarily to higher reported expenses and
flat revenues) and relatively stable occupancy for the past five
years (2014 through 2018). S&P's analysis considered the property's
prime location and tenant roster, and excluded certain operating
expense amounts reported by the master servicer that are associated
with partnership level expenses (representing about 7-8% of the
total reported 2017 and 2018 operating expenses) and not actual
operation of the property. The rating agency then derived its
sustainable in-place net cash flow (NCF), which it divided by a
6.75% S&P Global Ratings capitalization rate to determine its
expected-case value. This yielded an overall S&P Global Ratings
loan-to-value ratio and debt service coverage (DSC) of 82.1% and
2.23x, respectively, on the whole loan balance.

The IO mortgage whole loan had an initial and current $450.0
million balance, pays a per annum fixed rate of 3.615%, and matures
on Aug. 10, 2026. The whole loan is split into three A and one B
notes. According to the April 16, 2019, trustee remittance report,
the $166.7 million senior note A-1 and $203.3 million subordinate
note B (totaling $370.0 million) are in the trust. The $30.0
million senior note A-2-1 is in Morgan Stanley Bank of America
Merrill Lynch Trust 2016-C31, the $30.0 million senior note A-2-2
is in Morgan Stanley Capital I Trust 2016-BNK2, and the $20.0
million senior note A-3 is in Morgan Stanley Bank of America
Merrill Lynch Trust 2016-C30, all of which are U.S. CMBS
transactions. The A notes are pari passu to each other and senior
to note B. The borrower is permitted to obtain up to $100.0 million
in mezzanine financing, subject to performance hurdles. The master
servicer, Wells Fargo Bank N.A. (Wells Fargo), confirmed that no
mezzanine debt has been incurred to date. In addition, the trust
has not incurred any principal losses.

Wells Fargo reported a DSC of 2.01x on the trust balance for the
nine months ended Sept. 30, 2018, and year-end 2018 occupancy was
86.3% according to the master servicer. Based on the Dec. 31, 2018,
rent roll, the five largest tenants make up 66.9% of the
collateral's total net rentable area (NRA). In addition, 12.6%,
4.2%, and 9.0% of the NRA have leases that expire in 2019, 2020,
and 2021, respectively, and 0.7% of the NRA is on a month-to-month
basis.

  RATINGS AFFIRMED
  BAMLL Commercial Mortgage Securities Trust 2016-ISQR
  Commercial mortgage pass-through certificates

  Class     Rating
  A         AAA (sf)
  B         AA- (sf)
  C         A- (sf)
  D         BBB- (sf)
  E         BB- (sf)
  X-A       AAA (sf)
  X-B       A- (sf)


BANC OF AMERICA 2007-4: Fitch Hikes $13.3MM Class G Certs to 'Bsf'
------------------------------------------------------------------
Fitch Ratings has upgraded one class and affirmed nine classes of
Banc of America Commercial Mortgage Trust commercial mortgage
pass-through certificates series 2007-4.

KEY RATING DRIVERS

Better than Expected Recoveries: The upgrade reflects the
increasing credit enhancement as a result of amortization and asset
dispositions. Since Fitch's prior rating action in February 2019,
five specially serviced assets were disposed with better than
expected recoveries. The five loans totaled $40.7 million in
outstanding balance and approximately $20.2 million was recovered
resulting in total losses of $20.5 million.

Increased Credit Enhancement: Since the previous rating action, the
pool's balance has decreased by approximately $41 million, from $69
million to $28 million. Credit enhancement for class G will
increase with continued paydown. As of the April 2019 distribution
date, the transaction has paid down 98.7% since issuance to $28
million from $2.2 billion. Interest shortfalls are currently
affecting classes J through N.

Fitch Loan of Concern: The largest loan in the pool remains a Fitch
Loan of Concern due to the binary risk associated with the loan.
The FedEx Portland loan (62% of the pool) is secured by a single
tenant property in Portland, Oregon. FedEx operates on a ground
lease and the warehouse was built to suit in 2007. The loan matures
in April 2022 and FedEx's lease expires in June 2022. The balloon
payment equates to a recovery of $136 per square foot.

The remaining loan is secured by a multi-tenant neighborhood center
located in Brentwood, CA. The property is anchored by Walgreen's
(48% of the NRA) and Walgreen's lease expires in July of 2032. The
loan matures in September 2022.

Concentrated Pool: The pool is highly concentrated with only three
performing loans remaining, inclusive of one fully defeased loan
(4% of the pool). Due to the concentrated nature of the pool, Fitch
performed a sensitivity analysis that grouped the remaining loans
and ranked them by their perceived likelihood of repayment. The
ratings reflect this sensitivity analysis.

RATING SENSITIVITIES

The Rating Outlook on class G remains Stable due to high credit
enhancement and continued deleveraging of the pool. Further
upgrades to class G are unlikely due to the concentrated nature of
the pool.

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 the following rating:

  -- $13.3 million class G to 'Bsf' from 'CCCsf'; Outlook Stable
assigned.

Fitch has affirmed the following classes:

  -- $14.7 million 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%;

  -- $0 class M at 'Dsf'; RE 0%;

  -- $0 class N at 'Dsf'; RE 0%;

  -- $0 class O at 'Dsf'; RE 0%;

  -- $0 class P at 'Dsf'; RE 0%;

  -- $0 class Q at 'Dsf'; RE 0%.

Fitch does not rate class S. Classes A-1, A-2, A-3, A-SB, A-4,
A-1A, A-M, A-J, B, C, D, E, and F have paid in full. The rating on
class XW was previously withdrawn.


BANC OF AMERICA 2007-5: Fitch Cuts $99.7MM Class A-J Certs to CC
----------------------------------------------------------------
Fitch Ratings has downgraded three and affirmed 13 classes of Banc
of America Commercial Mortgage Trust, commercial mortgage
pass-through certificates, series 2007-5.

KEY RATING DRIVERS

Increased Loss Expectations; High Concentration of Specially
Serviced Loans/Assets: The downgrades reflect a greater certainty
of loss due to an increase in loss expectations on the specially
serviced loans/assets (69.3% of pool) since the last rating action.
Six of the seven remaining loans/assets are specially serviced,
including four real estate owned assets (31.6%), one non-performing
matured balloon loan (25%) and one loan classified in foreclosure
(12.7%). Significant losses are expected due to continued
performance deterioration and uncertainty surrounding their
ultimate workout and disposition.

The largest specially serviced loan is 4000 Wisconsin Avenue (25%
of pool), which is secured by the leasehold interest in three,
five-story office buildings totalling 491,311 square foot (sf)
located in the Uptown office submarket of Washington, D.C. The loan
transferred to special servicing in June 2017 for imminent default.
Fannie Mae (87% of NRA), vacated the property in December 2018 to
move into new headquarters in downtown D.C. The property remains
vacant. The latest appraisal valued the property at $0 due to
ground lease obligations and redevelopment costs. The collateral is
subject to an unsubordinated 75-year, ground lease expiring in
January 2061, with a substantial monthly payment. The special
servicer has indicated foreclosure has commenced.

Increased Credit Enhancement: As of the April 2019 remittance
report, the pool has been reduced by 88.6% to $211.8 million from
$1.86 billion at issuance. Realized losses to date total $120.2
million (6.5% of original pool balance). Cumulative interest
shortfalls totalling $28.1 million are currently affecting classes
A-J through K and classes O through S.

Maturity Schedule: The only performing loan (30.7% of pool) is
scheduled to mature in June 2022. The 708 Third Avenue loan is
secured by a 405,939 sf office building located between East 44th
Street and East 45th Street in the Grand Central submarket of
Manhattan. In August 2018, the property began a $45 million
repositioning plan to more closely align with properties in the
Grand Central submarket, including a renovated lobby and luxurious
finishes. The property was 83.5% occupied as of December 2018.

RATING SENSITIVITIES

Further downgrades to the remaining distressed classes will occur
as losses are realized or if losses exceed Fitch's expectations. No
upgrades are expected due to high loss expectations on the
remaining pool.

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 the following classes:

  -- $99.7 million class A-J to 'CCsf' from 'CCCsf; RE 85%;

  -- $20.9 million class B to 'Csf' from 'CCsf'; RE 0%;

  -- $13.9 million class C to 'Csf' from 'CCsf'; RE 0%.

Fitch has affirmed the following classes:

  -- $20.9 million class D at 'Csf; RE 0%;

  -- $18.6 million class E at 'Csf; RE 0%;

  -- $11.6 million class F at 'Csf; RE 0%;

  -- $18.6 million class G at 'Csf; RE 0%;

  -- $7.6 million 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%;

  -- $0 class M at 'Dsf; RE 0%;

  -- $0 class N at 'Dsf; RE 0%;

  -- $0 class O at 'Dsf; RE 0%;

  -- $0 class P at 'Dsf; RE 0%;

  -- $0 class Q at 'Dsf; RE 0%.

Fitch does not rate the class S certificates. The class A-1, A-2,
A-3, A-SB, A-4, A-1A and A-M certificates have paid in full. Fitch
previously withdrew the rating on the interest-only class XW
certificates.


BEAR STEARNS 2006-IM1: Moody's Hikes Rating on 2 Tranches to Ca
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of three
tranches issued by Bear Stearns Asset Backed Securities I Trust
2006-IM1 backed by Alt-A mortgage loans.

Complete rating actions are as follows:

Issuer: Bear Stearns Asset Backed Securities I Trust 2006-IM1

  Cl. A-1, Upgraded to Caa2 (sf); previously on Oct 20, 2010
  Downgraded to Ca (sf)

  Cl. A-3, Upgraded to Ca (sf); previously on Oct 20, 2010
  Downgraded to C (sf)

  Cl. A-6, Upgraded to Ca (sf); previously on Oct 20, 2010
  Downgraded to C (sf)

RATINGS RATIONALE

The actions reflect the recent performance of the underlying pool
and Moody's updated loss expectations on the pool. The rating
upgrades are a result of improving performance of the related pool
and an increase in credit enhancement available to the bonds.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in February 2019.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in April 2019 from 3.9% in April
2018. 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
this transaction.


BEAR STEARNS 2007-TOP26: DBRS Confirms C Ratings on 4 Debt Classes
------------------------------------------------------------------
DBRS Limited confirmed all classes of the Commercial Mortgage
Pass-Through Certificates, Series 2007-TOP26 issued by Bear Stearns
Commercial Mortgage Securities Trust, Series 2007-TOP26 (the Trust)
as follows:

-- Class AM at AAA (sf)
-- Class A-J at C (sf)
-- Class B at C (sf)
-- Class C at C (sf)
-- Class D at C (sf)

DBRS maintained the Interest in Arrears designation for Classes
A-J, B, C and D. None of the Classes have ratings that carry trends
with the exception of Class AM, which carries a Stable trend.

The rating actions are largely reflective of DBRS's outlook for the
second-largest loan remaining in the pool, One AT&T Center
(Prospectus ID#2, 35.4% of the pool), which is secured by a 1.5
million square foot office building in downtown St. Louis,
Missouri, and has been in default since May 2017. In addition, as
of the April 2019 remittance, the largest loan in the pool, One Dag
Hammarskjold Plaza (Prospectus ID#1, 49.5% of the pool), has been
fully defeased. Given the combined loan balance, the outlook for
the remaining Classes hinges directly on these two loans.

As of the April 2019 remittance, there has been a collateral
reduction of 85.6% since issuance because of scheduled loan
amortization, repayments, and liquidations. Of the original 237
loans secured at issuance, there are only 12 loans remaining in the
pool, with an outstanding principal balance of $303.1 million.
There are two loans, representing 2.1% of the pool, on the
servicer's watchlist, and five loans, representing 45.8% of the
pool, in special servicing. The largest specially serviced loan,
One AT&T Center, was transferred to the special servicer in May
2017. This turn of events had been anticipated for several years
given the building's largely dark status for several years prior to
the transfer after the single tenant, AT&T, began moving employees
from the building to another location nearby. The building remains
vacant and is real estate owned, with the special servicer working
to sell the property through an auction that was scheduled to
conclude in April 2019. According to the May 2018 appraisal, the
property was valued at $21.1 million, well below the issuance value
of $207.0 million. The limited parking at the property will
continue to be a hurdle, and a potential buyer would need to incur
significant capex to sufficiently redevelop the property in order
to release it. Given the drastic value decline and the property's
fully vacant status that has held over several years, DBRS expects
this loan to be disposed from the Trust at a loss severity
approaching 100%. For additional information on this loan, please
see the loan commentary on the DBRS Viewpoint platform, for which
information is provided below.

In anticipation of One AT&T Center's eventual liquidation, along
with potential losses stemming from the resolution of the four
other specially serviced loans, DBRS expects Classes B, C, D, and
unrated E to be completely wiped out, with additional losses
flowing through into Class A-J. However, as One Dag Hammarskjold
Plaza is fully defeased and has a current trust balance of $150.0
million, Class AM will be fully insulated from potential losses,
supporting the confirmation of the AAA (sf) rating for that Class.


BLUEMOUNTAIN CLO 2013-1: S&P Keeps D-R Notes Rating on Watch Neg.
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1-R2 and
A-2-R2 replacement notes from BlueMountain CLO 2013-1 Ltd., a
collateralized loan obligation (CLO) originally issued in 2013 that
is managed by BlueMountain Capital Management LLC. S&P withdrew its
ratings on the original class A-1-R and A-2-R notes following
payment in full on the May 8, 2019, refinancing date. At the same
time, S&P affirmed its ratings on the class B-R and C-R notes.

On the May 8, 2019, refinancing date, the proceeds from the class
A-1-R2 and A-2-R2 replacement note issuances were used to redeem
the original class A-1-R and A-2-R notes as outlined in the
transaction document provisions. Therefore, S&P withdrew its
ratings on the original notes in line with their full redemption,
and S&P assigned ratings to the replacement A-1-R2 and A-2-R2
notes.

The replacement notes are being issued via a supplemental indenture
at a lower spread over three-month LIBOR than the corresponding
original notes.

There is no change to the reinvestment period duration, which ends
in January 2021, or to the transaction's legal final maturity,
scheduled for January 2029.

The assigned ratings reflect S&P's opinion that the credit support
available is commensurate with the associated rating levels.

On a standalone basis, the results of the cash flow analysis
indicated a higher rating on the class B-R notes. The credit
support is, in S&P's opinion, still in line with the current rating
level for this class and the class C-R notes. The risks from
declines in overcollateralization ratios since S&P's last rating
actions in December 2016 and losses on the underlying portfolio are
currently offset by smaller portfolio exposures comparatively to
'CCC' rated and non-performing collateral as well as seasoning of
the underlying portfolio.

The class D-R notes were placed on CreditWatch with negative
implications on May 6, 2019. The supplemental indenture has not
impacted the rating or CreditWatch placement, which is expected to
be resolved within 90 days of the placement date.

"Our review of this transaction included a cash flow analysis,
based on the portfolio and transaction as reflected in the trustee
report, to estimate future performance. In line with our criteria,
our cash flow scenarios applied forward-looking assumptions on the
expected timing and pattern of defaults, and recoveries upon
default, under various interest rate and macroeconomic scenarios,"
S&P said, adding that its analysis considered the transaction's
ability to pay timely interest or ultimate principal, or both, to
each of the rated tranches.

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

  RATINGS ASSIGNED

  BlueMountain CLO 2013-1 Ltd.
  Replacement class          Rating        Amount (mil $)
  A-1-R2                     AAA (sf)              310.00
  A-2-R2                     AA (sf)                62.00

  RATINGS WITHDRAWN

  BlueMountain CLO 2013-1 Ltd.
                           Rating
  Original class       To              From
  A-1-R                NR              AAA (sf)
  A-2-R                NR              AA (sf)

  RATINGS AFFIRMED

  BlueMountain CLO 2013-1 Ltd.
  Class                   Rating
  B-R                     A (sf)
  C-R                     BBB (sf)

  OTHER OUTSTANDING RATING
  Class                    Rating
  D-R                      BB (sf)/Watch Neg

  NR--Not rated.


BX TRUST 2019-IMC: DBRS Assigns Prov. BB Rating(low) on G Certs
---------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-IMC to
be issued by BX Trust 2019-IMC:

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

All trends are Stable. Classes X-CP and X-NCP are notional.

The collateral for the loan contains some of the premier trade-room
space of two major separate bi-annual trade markets in the United
States known as the High Point Markets and the Las Vegas Markets.
The majority of the portfolio was compiled in a series of
transactions from 2011 through 2015 by International Market
Centers, Inc. (IMC), and certain affiliates of The Blackstone Group
L.P. (Blackstone) acquired IMC for $1.5 billion and was securitized
in the BX 2017-IMC transaction. The collateral is substantially the
same as the BX 2017-IMC transaction, with the addition of the 300
East Green properties. The Las Vegas properties represent the only
space used for the Winter and Summer Las Vegas Markets, and the
properties are set up in a campus-like setting, which would make it
difficult for newly constructed competitive supply to affect the
performance of the property. While there are other competitive
properties in High Point, North Carolina, for the Spring and Fall
High Point Markets, the portfolio contains the main building
complex for the High Point Markets, the International Home
Furnishings Center, and other High Point properties are located
within walking distance of this property. IMC estimates that the
subject portfolio contains 88.0% of the Class A showroom space in
the High Point market, and there is no other property owner of
showroom space in High Point that owns more than 4.0% of the total
available square footage. There is sentiment among buyers that they
will find more product introductions at High Point than in any
other market. In total, there were 88,812 buyers that went to the
Las Vegas and High Point Markets in 2018, which represents a
variance of 27.4% and 6.6% over the 2011 and 2015 total buyer
attendance figures, respectively. DBRS views the possibility of the
Las Vegas Markets and the High Point Markets moving to another city
as a highly unlikely occurrence over the course of the loan term or
in the medium term after the fully extended loan term due to the
historical and current draw to the markets, as well as the strength
of the portfolio's management firm, IMC, in playing a major role in
conducting these markets.

The loan sponsors, certain affiliates of the Blackstone funds
commonly known as Blackstone Real Estate Partners VIII and
Blackstone Tactical Opportunities Fund II - Q L.P., are considered
very strong due to their extensive holdings in the showroom space
industry and ample financial resources. The collateral benefits
from the management of IMC, which is the largest operator of
premier showroom space for the furniture, gift, home decor, rug,
and apparel industries in the world. The sponsor cashed out $173.9
million as a result of this refinancing. Since most of the
portfolio was assembled in 2015 by IMC, management has been able to
increase the portfolio net operating income to $134.9 million in
2018 from $98.4 million in 2015, a variance of 37.1%. The sponsor
and management have been able to increase the performance of the
portfolio by increasing rents and reducing operating and leasing
cost expenses, while maintaining a stable average portfolio
occupancy rate. The portfolio averaged a total physical occupancy
rate of 83.5% from 2015 to 2018, ranging from 83.0% in 2015 and
2017 to 84.1% in 2018.

There is rollover risk at the initial loan maturity in April 2021
and fully extended loan maturity in April 2024. There are 664
leases, cumulatively representing 35.0% of the net rentable area
(NRA) and 34.3% of the DBRS Gross Rent, with leases that expire
prior to the initial loan maturity. There are 1,136 leases,
cumulatively representing 81.1% of the NRA and 81.2% of the DBRS
Gross Rent, with leases that expire prior to the fully extended
loan maturity. However, from 2012 to 2018, the portfolios exhibited
a straight-line average annual renewal rate of 88.9%, ranging from
82.0% in 2012 to 96.0% in 2013 and 2014. The total amount of annual
renewal leasing square feet (sf)-to-total leasing sf has increased
to 79.4% in 2018 from 61.9% in 2015, which have lower leasing costs
compared with new leasing costs. The re-leasing spread rate from
2015 to 2018 averaged 4.5% and ranged from 2.3% in 2018 to 8.1% in
2017, indicating that management has been able to increase rental
rates while maintaining a stabilized occupancy. Further, relatively
high rollover is to be expected as leases in excess of six years
are not typical in the furniture tradeshow industry.

The portfolio is secured by a non-traditional property type:
showroom properties. This property type is vulnerable to high net
cash flow (NCF) volatility because of the relatively short-term
leases compared with other commercial properties, which can cause
the NCF to quickly deteriorate in a declining market. A unique
attribute about this property type is the amount of revenue
attributable to Temporary License Agreement (TLA) tenants and
Tradeshow Revenue, as this source of revenue has averaged 9.5% of
total effective gross income before other income from 2015 to 2018.
TLA tenants are typically signing short-term exhibitor license
agreements with IMC for temporary space to display products during
the markets. This space serves as an incubator for new industry
players that want to get in front of buyers and presents a unique
revenue generator that accounts for the high fragmentation within
the furniture and home decor industries. Another unique attribute
of the property type is that outside of the tradeshow dates, leased
spaces generally are either idle or being reconfigured for the next
tradeshow, although a few tenants will "office out" of their space
outside of the tradeshows. Due to the uniqueness of the property
type, there is limited market data, such as comparable property
rents, vacancies, operating expense and leasing costs, available.

The DBRS value of $1.234 billion represents a 25.1% discount to the
as-is appraised value of $1.647 billion but results in a DBRS
Loan-to-Value (LTV) of 93.2%, which is indicative of high-leverage
financing. However, DBRS utilized a conservative cap rate of
10.50%, which is 235 basis points higher than the appraiser's
weighted-average cap rate of 8.32%. DBRS utilized a conservative
cap rate to account for the non-traditional-property type of the
collateral. Despite the high mortgage leverage, term default risk
is considered modest based on the DBRS Term Debt Service Coverage
Ratio (DSCR) of 1.94 times (x), which is derived using a stressed
LIBOR of 3.26%, based on DBRS's "Interest Rate Stresses for U.S.
Structured Finance Transactions" methodology, and a spread of
2.55%. The term DSCR would be 1.47x, assuming the YE2015 NCF, which
is still very healthy and does not account for the value and NCF
growth created by the sponsor and management over the past four
years. The associated DBRS Debt Yield based on the cumulative
investment-grade-rated proceeds is high at 13.7%. Additionally, the
investment-grade-rated proceeds represent a 57.3% LTV relative to
the appraiser's market valuation.

DBRS identified four loans on eight properties within the
portfolio, representing 48.0% of the allocated loan amount, that
incurred losses after the prior securitization due to high
leverage, significant declines in the DSCRs and/or maturity
default: World Market Center Building A, World Market Center
Building B, Historic Market Square/Market Square Tower/Market
Square Suites, Furniture Plaza/Plaza Suites, the Commerce & Design
Building, National Furniture Mart, Hamilton Market and South Main.
These properties were securitized in the GECMC 2002-1A, BSCMS
2005-PW10, CD 2006-CD3 and BSCMS 2007-PW15 transactions at a total
original balance of $775.5 million and incurred total losses of
$362.3 million. The current allocated loan amounts of $552.1
million for the properties that took losses represent variances of
-28.8% to the $775.4 original balances of the financings that took
substantial losses. IMC acquired the current portfolio in 2011 and
has increased the performance of these properties. These properties
were both previously securitized in CGBAM 2016-IMC and BX 2017-IMC,
and the loans performed as agreed upon.

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

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


CAPITALSOURCE REAL 2006-A: Fitch Affirms C Ratings on 3 Tranches
----------------------------------------------------------------
Fitch Ratings has affirmed eight classes of CapitalSource Real
Estate Loan Trust 2006-A.

KEY RATING DRIVERS

The ratings of classes B, C and D were capped to reflect the
increasing pool and loan concentrations and adverse selection
concerns.

CapitalSource 2006-A is collateralized by senior commercial real
estate (CRE) debt (97.6% of the pool are whole loans/A-notes) and
residential mortgage-backed securities bonds (RMBS; 2.4%). The
current pool consists of 14 assets, whereby 42.6% by balance is
comprised of defaulted loans (38.1%) and Fitch Loans of Concern
(FLOCs; 4.5%). Non-traditional and non-cash flowing properties
comprise the majority of the pool, with healthcare and undeveloped
land loans accounting for 59.5% and 29.4% of the pool,
respectively. The largest three loans account for 84.4% of the
pool.

The largest loan (55% of pool) is comprised of 22
cross-collateralized and cross-defaulted loans secured by a
portfolio of 28 healthcare properties totaling 2,070 beds, which
include nine assisted living facilities and 19 skilled nursing
facilities, located primarily in secondary markets solely within
the state of Indiana. The properties in the portfolio are included
in a master lease agreement and managed by Miller's Health Systems;
an extension of the expired master lease is under negotiation.
According to the asset manager, portfolio net operating income in
2018 was $30.5 million, compared with $30.3 million in 2017.
Revenue sources in 2018, according to the asset manager, include
Medicaid (approximately 39% of total revenues), private pay (24%),
Medicare (13%) and an intergovernmental transfer (IGT) program
available in Indiana (16%).

The Rating Outlooks for classes B and C were revised to Positive
from Stable as future upgrades may be possible with greater
certainty of the refinanceability of the largest loan as it
approaches its September 2021 maturity. While a full recovery on
the loan is expected based on Fitch's current stressed valuation,
there remain concerns about the interest-only loan's ability to
refinance at maturity given the volatility associated with
healthcare properties, as well as the stability of the portfolio's
revenue stream. Should the loan default at maturity, available
interest proceeds may be affected for the timely rated class B.

The second and third largest loans (18.8% and 10.6% of the pool,
respectively) are secured by undeveloped land in the Poconos
Mountain of Pennsylvania and the Grand Bahamas Island. The RMBS
bonds have a weighted-average Fitch rating of 'B+'/'B'.

Fitch's base case loss expectation is 34.2%. Since the last rating
action and as of the April 2019 trustee report, principal paydowns
totaled $16.9 million from an asset payoff, a loan disposition and
scheduled amortization. Realized losses since the last rating
action from the disposition of an A-note secured by over 6,000
acres of undeveloped land located in Edgewater and New Smyrna
Beach, FL totaled $33.4 million and were better than previously
expected. The A/B and C/D/E overcollateralization (OC) and interest
coverage (IC) tests passed; however, the class F/G/H OC and IC
tests failed. Classes H and J are capitalizing their missed
interest.

The distressed ratings of classes E through J were based upon a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
loans and FLOCs, factoring in anticipated recoveries relative to
each class' credit enhancement.

The largest contributor to Fitch's loss expectation is the second
largest loan (18.8% of pool), which is secured by over 2,000 acres
of undeveloped land located in the Pocono Mountains of
Pennsylvania. The borrower's initial business plan included the
development of the site with retail and multifamily; however, the
plan stalled because of the economic downturn. The lender is
currently pursing foreclosure. The Pocono real estate market is
struggling with little development in the area. Fitch modeled a
full loss on this loan in its base case scenario.

This transaction was analyzed according to Fitch's 'U.S. CREL CDO
Surveillance Criteria', which applies stresses to property cash
flows and debt service coverage ratio tests to project future
default levels for the underlying portfolio. Recoveries are based
on stressed cash flows and Fitch's long-term capitalization rates.
Cash flow modeling was not performed as it would provide no
additional analytical value given the derived rating default rates
provide little distinction among the various rating stresses.

CapitalSource 2006-A was initially issued as a $1.3 billion CRE
collateralized debt obligation managed by CapitalSource Finance,
LLC, a subsidiary of CapitalSource, Inc. In 2010, NS Advisors II,
LLC became the delegated collateral manager for the CDO under the
delegation provisions of the indenture. All collateral manager
responsibilities and fees were delegated to NS Advisors at that
time. In addition, an amendment to the servicing agreement replaced
the special servicer of the CDO with NS Servicing, LLC. NS
Servicing assumed all rights, interests, duties, and obligations as
special servicer under the servicing agreement previously held by
CapitalSource. NS Advisors was previously a wholly-owned subsidiary
of NorthStar Realty Finance Corp. In January 2017, NRF, along with
Northstar Asset Management, merged with Colony Capital, Inc. to
form Colony Northstar Inc.

RATING SENSITIVITIES

The Positive Rating Outlooks on classes B and C reflect the
increasing CE and expected continued paydowns. Future upgrades may
be possible with greater certainty of the refinanceability of the
largest loan as it approaches its 2021 maturity and with continued
paydowns and/or better than expected recoveries on the remaining
assets in the pool. However, Fitch generally will cap ratings at
'BBBsf' when the majority of the remaining pool consists of
distressed and/or concentrated collateral. Distressed classes D
through J may be subject to downgrade should loan performance
decline, if realized losses exceed Fitch's expectations and/or
should further losses be 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 affirmed the ratings for the following classes and
revised the Rating Outlooks where noted:

  -- $31.3 million class B at 'BBsf'; Outlook to Positive from
Stable;

  -- $62.4 million class C at 'Bsf'; Outlook to Positive from
Stable;

  -- $30.2 million class D at 'CCCsf'; RE 100%;

  -- $30.2 million class E at 'CCCsf'; RE 50%;

  -- $26.7 million class F at 'CCsf'; RE 0%;

  -- $33.2 million class G at 'Csf'; RE 0%.

  -- $31.9 million class H at 'Csf'; RE 0%;

  -- $51.6 million class J at 'Csf'; RE 0%.

Class A-2A, A-1A, A-1R and A-2B notes have paid in full.


CITIGROUP MORTGAGE 2019-RP1: DBRS Finalizes B Rating on B-2 Notes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage-Backed Notes, Series 2019-RP1 issued by Citigroup Mortgage
Loan Trust 2019-RP1:

-- $162.6 million Class A-1 at AAA (sf)
-- $14.7 million Class M-1 at AA (sf)
-- $16.8 million Class M-2 at A (low) (sf)
-- $15.9 million Class M-3 at BBB (low) (sf)
-- $7.5 million Class B-1 at BB (low) (sf)
-- $9.8 million Class B-2 at B (sf)

The AAA (sf) rating on the Class A-1 Notes reflects the 38.00% of
credit enhancement provided by subordinated Notes in the pool. The
AA (sf), A (low) (sf), BBB (low) (sf), BB (low) (sf) and B (sf)
ratings reflect credit enhancement of 32.40%, 26.00%, 19.95%,
17.10% and 13.35%, 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 seasoned
performing and re-performing first-lien residential mortgages. The
Notes are backed by 1,330 loans with a total principal balance of
$262,812,561 as of the Cut-Off Date (March 31, 2019).

The loans are approximately 150 months seasoned. As of the Cut-Off
Date, all loans are current, including 3.1% bankruptcy-performing
loans. Approximately 49.7% and 93.1% of the mortgage loans have
been zero times 30 days delinquent for the past 24 months and 12
months, respectively, under the Mortgage Bankers Association
delinquency method.

The portfolio contains 88.8% modified loans. The modifications
happened more than two years ago for 62.9% of the modified loans.
Within the pool, 687 mortgages have aggregate non-interest-bearing
deferred amounts of $29,577,691. Included in the deferred amounts
are proprietary principal forgiveness and Home Affordable
Modification Program principal reduction alternative amounts
(collectively, the PRA amounts) of $572,484. The non-PRA amounts of
$29,005,206 comprise approximately 11.1% of the total principal
balance.

There are no loans in the pool that are subject to the Consumer
Financial Protection Bureau Ability-to-Repay and Qualified Mortgage
rules.

The Sponsor and Seller, Citigroup Global Markets Realty Corp.
(CGMRC) acquired the mortgage loans from various sellers who
originated the loans between June 18, 1990, and June 6, 2014, and
will contribute the loans to the Trust through an affiliate,
Citigroup Mortgage Loan Trust Inc. (the Depositor). As the Sponsor,
CGMRC or one of its majority-owned affiliates will acquire and
retain a 5% eligible vertical interest in each class of Notes
(other than the Class R Notes) to satisfy the credit risk retention
requirements. The loans were originated and previously serviced by
various entities through purchases in the secondary market. As of
the Cut-Off Date, the loans are serviced by Fay Servicing, LLC.

There will not be any advancing of delinquent principal or interest
on any mortgages by the Servicer or any other party to the
transaction; however, the servicer is obligated to make advances in
respect of homeowner association fees, taxes, and insurance as well
as reasonable costs and expenses incurred in the course of
servicing and disposing of properties.

The transaction employs a sequential-pay cash flow structure.
Principal proceeds can be used to cover interest shortfalls on the
Notes, but such shortfalls on Class M-2 and more subordinate
principal and interest (P&I) bonds will not be paid from principal
proceeds until the more senior classes are retired.

The lack of P&I advances on delinquent mortgages may increase the
possibility of periodic interest shortfalls to the Noteholders;
however, principal proceeds can be used to pay interest to the
Notes sequentially, and subordination levels are greater than
expected losses for the rated Notes, which may provide for timely
payment of interest to the rated Notes.

The ratings reflect transactional strengths that include underlying
assets that demonstrate improving performance in the recent past
and strong representations and warranties (R&W) provider (CGMRC).
Additionally, a comprehensive third-party due diligence review was
performed on the portfolio with respect to regulatory compliance,
servicing comments, data integrity, payment histories, and title
and tax review. Updated broker price opinions, desk appraisals,
comparative market analyses or 2055 values were provided for 100%
of the pool; however, reconciliations were not performed on the
updated values.

The transaction employs an R&W framework that includes certain
weaknesses such as knowledge qualifiers, a fraud representation
that is limited to the time period when the Seller owned the loans,
and carve-outs for loans with known findings or unavailable
information. Mitigating factors include (1) a financially strong
R&W provider (CGMRC), (2) a comprehensive due diligence review, (3)
automatic or designated breach review triggers dependent on certain
conditions and (4) significant loan seasoning and relatively clean
performance history in recent years.

The DBRS ratings of AAA (sf) and AA (sf) address the timely payment
of interest and full payment of principal by the legal final
maturity date in accordance with the terms and conditions of the
related Notes. The DBRS ratings of A (low) (sf), BBB (low) (sf), BB
(low) (sf) and B (sf) address the ultimate payment of interest and
full payment of principal by the legal final maturity date in
accordance with the terms and conditions of the related Notes.


CSAIL 2016-C6: Fitch Affirms B- Rating on Class X-F Certs
---------------------------------------------------------
Fitch Ratings affirms 16 classes of Credit Suisse Commercial
Mortgage Trust's CSAIL 2016-C6 commercial mortgage trust
pass-through certificates.

KEY RATING DRIVERS

Stable Performance and Loss Expectations: Overall pool performance
and loss expectations have remained relatively stable since
issuance. There have been no specially serviced loans since
issuance. Seven loans (8.1% of pool) are currently on the master
servicer's watchlist, of which six or 5.5% have been designated as
Fitch Loans of Concern (FLOCs).

Minimal Change to Credit Enhancement: As of the May 2019
distribution date, the pool's aggregate balance has paid down by
1.4% to $756.3 million from $767.5 million at issuance. Seven loans
representing 41.1% of the pool are full-term interest only and 25
loans representing 40.4% of the pool are partial-term interest
only. The remainder of the pool consists of 18 balloon loans
representing 18.5% of the pool, with loan terms of five to 10
years. At issuance, based on the scheduled balance at maturity, the
pool is expected to pay down 7.5% during the term.

Fitch Loans of Concern: The largest FLOC, Holiday Inn & Suites Ann
Arbor (1.2% of pool), is secured by a 107-key limited-service hotel
property located in Ann Arbor, MI. Property net operating income as
of trailing-twelve month September 2018 dropped 41% from year-end
2017. Per the master servicer, the borrower has stated the decline
in performance is a result of the property undergoing a property
improvement plan, which was expected to be completed in July 2018.
Fitch has requested an update from the master servicer regarding
completion of the PIP but has not received a response. The most
recent servicer-reported NOI debt service coverage ratio as of TTM
September 2018 was 0.81x, down from 1.38x YE 2017 and 1.67x at
issuance.

The second largest FLOC, Arbor Hill Apartments (1.2%), is secured
by a 208-unit multifamily complex located in San Antonio, TX. The
property's occupancy declined to 74% as of YE 2018 from 91% at
issuance. Per the master servicer, the borrower indicated the
decline in performance since issuance was mainly due to staff
turnover, including the loss of the property's manager, in addition
to increased expenses. Since hiring a new property manager in
January 2018, occupancy has improved to 84% at YE 2018. The most
recent servicer-reported NOI DSCR as of YE 2018 was 0.99x, down
from 1.15x YE 2017 and 1.42x at issuance.

The third largest FLOC, Holiday Inn Express - Little Rock (1.1%),
is secured by a 150-key limited-service hotel property located in
Little Rock, AR. Per the master servicer, property cash flow has
been negatively affected by increased repairs and maintenance
expenses since issuance. The property is currently 64.4% occupied.
Fitch requested an update on property performance and a recent STR
report from the servicer, but they have not been received.

The fourth largest FLOC, Confederate Point Apartments (1.0%), is
secured by a 208-unit multifamily complex consisting of 28
two-story buildings located in Jacksonville, FL. Property
performance was affected by a recent fire in one of the buildings
that comprised eight units. Per the master servicer, the demolition
work has already been performed on the four, fire-side units, and
the required demolition work on the remaining four units not
destroyed by the fire has been contracted out. Per the June 2018
rent roll, the property was 93% occupied.

The remaining two FLOCs (totaling 1% of the pool) include a
239-unit multifamily property located in Kingsport, TN whose
occupancy has declined significantly to 46% as of September 2018
from 74% at YE 2017 as the property is currently undergoing major
renovations and an 11,244 sf office property located in Orlando, FL
where the loan's NOI DSCR has dropped below 1.0x in 2017. Fitch
expects performance to improve due to a new tenant who is now
making rental payments.

ADDITIONAL CONSIDERATIONS

Pool and Loan Concentrations: The top 15 loans represent 73% of the
pool. Retail exposure is limited to 13 loans (19.5% of pool). Of
the retail properties, there is one regional mall, Quaker Bridge
Mall (Lawrenceville, NJ; 8.7%), with exposure to anchors including
Macy's and JC Penney, as well as a former vacant non-collateral
Sears box. One loan (2.6%) matures in 2020, three (6%) in 2021, one
(11.6%) in 2022 and the remainder (79.2%) in 2025 and 2026.

Investment-Grade Credit Opinion Loan: At issuance, two loans, GLP
Industrial Portfolio B (11.7% of pool) and GLP Industrial Portfolio
A (5.5%), received investment-grade credit opinions of 'A+sf' and
'Asf', respectively, on a stand-alone basis. The sponsor for both
of these loans is Global Logistics Properties, Ltd, which is
currently rated 'BBB' by Fitch.

RATING SENSITIVITIES

Rating Outlooks for all classes remain Stable due to overall stable
performance and continued amortization. Upgrades may occur with
improved pool performance and additional paydown or defeasance.
Downgrades are possible should loan performance deteriorate
significantly.

CSAIL 2016-C6

Debt/Entity             Affirmed Rating
-----------             ---------------
Class A-1 12636MAA6        AAAsf
Class A-2 12636MAB4        AAAsf
Class A-3 12636MAC2        AAAsf
Class A-4 12636MAD0        AAAsf
Class A-5 12636MAE8        AAAsf
Class A-S 12636MAJ7        AAAsf
Class A-SB 12636MAF5       AAAsf
Class B 12636MAK4          AA-sf
Class C 12636MAL2          A-sf
Class D 12636MAV0          BBB-sf
Class E 12636MAX6          BB-sf
Class F 12636MAZ1          B-sf
Class X-A 12636MAG3        AAAsf
Class X-B 12636MAH1        AA-sf
Class X-E 12636MAP3        BB-sf
Class X-F 12636MAR9        B-sf


CWABS ASSET-BACKED 2006-12: Moody's Hikes Class 2-A-3 Certs to B2
-----------------------------------------------------------------
Moody's Investors Service has upgraded Class 2-A-3 from CWABS
Asset-Backed Certificates Trust 2006-12.

The complete rating actions are as follows:

Issuer: CWABS Asset-Backed Certificates Trust 2006-12

Cl. 2-A-3, Upgraded to B2 (sf); previously on Jul 13, 2018 Upgraded
to Caa2 (sf)

RATINGS RATIONALE

The rating action is a result of the recent performance of the
underlying pool and reflects Moody's updated loss expectation on
the pool. The rating upgrade is a result of improving performance
of the related pool.

The principal methodology used in this rating was "US RMBS
Surveillance Methodology" published in February 2019.

The Credit Rating for CWABS Asset-Backed Certificates Trust 2006-12
was assigned in accordance with Moody's existing methodology
entitled "US RMBS Surveillance Methodology," dated 2/22/2019.
Please note that on 5/8/2019, Moody's released a Request for
Comment, in which it has requested market feedback on the use of an
updated version of third-party cash flow modeling software for
certain structured finance asset classes. If the revised update is
implemented as proposed, the Credit Rating on CWABS Asset-Backed
Certificates Trust 2006-12 may be negatively or positively
affected. The final rating outcome will overlay qualitative
judgments and considerations such as performance to date and
structural features.

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 3.6% in April 2019 from 3.9% in April
2018. 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.


FIRST FRANKLIN: Moody's Cuts Class S Debt Rating to Csf
-------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 7 tranches
and downgraded the rating of one tranche from four transactions,
backed by subprime, Alt-A and option ARM loans, issued by multiple
issuers.

The complete rating actions are as follows:

Issuer: Greenpoint Mortgage Funding Trust 2007-AR1

Cl. 2-A1A, Upgraded to B3 (sf); previously on Dec 9, 2010 Confirmed
at Caa2 (sf)

Issuer: Lehman XS Trust Series 2006-GP2

Cl. 1-A5A, Upgraded to B3 (sf); previously on Oct 22, 2010
Confirmed at Caa2 (sf)

Cl. 2-A1, Upgraded to Caa2 (sf); previously on Oct 22, 2010
Confirmed at Caa3 (sf)

Cl. 3-A1, Upgraded to Caa2 (sf); previously on Oct 22, 2010
Confirmed at Caa3 (sf)

Issuer: First Franklin Mortgage Loan Trust 2004-FF1

Cl. M-1, Upgraded to A3 (sf); previously on Mar 29, 2016 Upgraded
to Baa2 (sf)

Cl. S*, Downgraded to C (sf); previously on Nov 29, 2017 Downgraded
to Caa2 (sf)

Issuer: MortgageIT Trust 2005-1

Cl. 1-A-1, Upgraded to Aa3 (sf); previously on Feb 12, 2015
Upgraded to A3 (sf)

Cl. 1-A-2, Upgraded to A1 (sf); previously on Aug 22, 2016 Upgraded
to Baa1 (sf)

  * Reflects Interest-Only Class

RATINGS RATIONALE

The rating upgrades are primarily due to increases in credit
enhancement available to the bonds and improved underlying
collateral pool performance. The rating downgrade on the
interest-only bond, Class S of First Franklin 2004-FF1, reflects
the nonpayment of interest for an extended period of 13 months as
of the distribution date in April 2019. For this bond, the coupon
rate is subject to a calculation that has reduced the required
interest distribution to zero. The reduction to zero is generally
attributed to weak performance and/or rate reduction on the
collateral due to underlying loan modifications. Because the coupon
on this bond is subject to changes in interest rates and/or
collateral composition, there is a remote possibility that it may
receive interest in the future. The actions also reflect the recent
performance as well as Moody's updated losses expectations on the
underlying pools.

The principal methodology used in rating all classes except
interest-only classes was "US RMBS Surveillance Methodology"
published in February 2019. The methodologies used in rating
interest-only classes were "US RMBS Surveillance Methodology"
published in February 2019 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

Factors that would lead to an upgrade or downgrade of the 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 3.6% in April 2019 from 3.9% in April
2018. 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.

An IO bond may be upgraded or downgraded, within the constraints
and provisions of the IO methodology, based on lower or higher
realized and expected loss due to an overall improvement or decline
in the credit quality of the referenced bonds and/or pools.

Finally, the performance of RMBS continues to remain highly
dependent on servicer procedures. Any changes resulting from
servicing transfers, or other policy or regulatory shifts can
impact the performance of these transactions.


FLAGSHIP CREDIT 2019-2: S&P Assigns Prelim BB- Rating on E Notes
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Flagship
Credit Auto Trust 2019-2's automobile receivables-backed notes.

The note issuance is an asset-backed securities transaction backed
by subprime auto loan receivables.

The preliminary ratings are based on information as of May 8, 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 44.5%, 38.5%, 29.9%, 23.3%,
and 19.7% credit support (including excess spread) for the class A,
B, C, D, and E notes, respectively, based on stressed cash flow
scenarios. These credit support levels provide coverage of
approximately 3.50x, 3.00x, 2.30x, 1.75x, and 1.40x S&P's
12.25%-12.75% expected cumulative net loss (CNL) range for the
class A, B, C, D, and E notes, respectively. These break-even
scenarios cover total cumulative gross defaults (using a recovery
assumption of 40%) of approximately 74%, 64%, 50%, 39%, and 33%,
respectively.

-- The timely interest and principal payments made under stressed
cash flow modeling scenarios that are appropriate to the assigned
ratings.

-- The expectation that under a moderate ('BBB') stress scenario,
all else being equal, S&P's ratings on the class A and B notes
would not be lowered by more than one rating category from its
preliminary 'AAA (sf)' and 'AA (sf)' ratings, respectively,
throughout the transaction's life. Similarly, S&P expects that its
ratings on the class C and D notes would not be lowered more than
two rating categories from its preliminary 'A (sf)' and 'BBB (sf)'
ratings, respectively. The rating on the class E notes would remain
within two rating categories of S&P's preliminary 'BB- (sf)' rating
within the first year, but the class would eventually default under
the 'BBB' stress scenario after receiving 40%-50% of its principal.
The above rating movements are within the one-category rating
tolerance for 'AAA' and 'AA' rated securities during the first year
and three-category tolerance over three years; a two-category
rating tolerance for 'A', 'BBB', and 'BB' rated securities during
the first year; and a three-category tolerance for 'A' and 'BBB'
rated securities over three years. 'BB' rated securities may
default under a 'BBB' stress scenario. These parameters are in
accordance with "Methodology: Credit Stability Criteria," May 3,
2010.

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

-- The characteristics of the collateral pool being securitized.

-- The transaction's payment and legal structures.

  PRELIMINARY RATINGS ASSIGNED

  Flagship Credit Auto Trust 2019-2

  Class      Rating       Type           Interest        Amount
                                         rate(i)       (mil. $)
  A          AAA (sf)     Senior         Fixed           218.47
  B          AA (sf)      Subordinate    Fixed            29.92
  C          A (sf)       Subordinate    Fixed            39.31
  D          BBB (sf)     Subordinate    Fixed            31.63
  E          BB- (sf)     Subordinate    Fixed            19.66

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


FREDDIE MAC 2019-2: Fitch to Rate $96.43MM Class M Certs 'B-sf'
---------------------------------------------------------------
Fitch Ratings expects to rate Freddie Mac's risk-transfer
transaction, Seasoned Credit Risk Transfer Trust Series 2019-2
(SCRT 2019-2) as follows:

  -- $96,431,000 class M certificates 'B-sf'; Outlook Stable.

Fitch will not be rating the following classes:

  -- $166,254,000 class HT exchangeable certificates;

  -- $124,690,000 class HA certificates;

  -- $41,564,000 class HB exchangeable certificates;

  -- $20,782,000 class HV certificates;

  -- $20,782,000 class HZ certificates;

  -- $1,855,361,000 class MT exchangeable certificates;

  -- $1,391,521,000 class MA certificates;

  -- $463,840,000 class MB exchangeable certificates;

  -- $231,920,000 class MV certificates;

  -- $231,920,000 class MZ certificates;

  -- $142,064,000 class M55D certificates;

  -- $142,064,000 class M55E exchangeable certificates;

  -- $142,064,000 class M55G exchangeable certificates;

  -- $25,829,818 class M55I notional exchangeable certificates;

  -- $150,674,756 class B certificates;

  -- $2,163,679,000 class A-IO notional certificates;

  -- $247,105,756 class B-IO notional certificates;

  -- $150,674,756 class BX exchangeable certificates;

  -- $150,674,756 class BBIO exchangeable certificates;

  -- $150,674,756 class BXS exchangeable certificates.

The 'B-sf' rating for the M certificates reflects the 6.25%
subordination provided by the class B.

SCRT 2019-2 represents Freddie Mac's 11th seasoned credit risk
transfer transaction issued. SCRT 2019-2 consists of three
collateral groups backed by 12,406 seasoned performing and
re-performing mortgages, with a total balance of approximately
$2.41 billion, of which $301.6 million, or 12.5%, was in
non-interest-bearing deferred principal amounts as of the cutoff
date. The three collateral groups represent loans that have
additional interest rate increases outstanding due to the terms of
the modification, and those that are expected to remain fixed for
the remainder of the term. Among the loans that are fixed, the
groups are further distinguished by loans that include a portion of
principal forbearance as well as the interest rate on the loans.
The distribution of principal and interest and loss allocations to
the rated note is based on a senior subordinate, sequential
structure.

KEY RATING DRIVERS

Distressed Performance History (Negative): The collateral pool
comprises primarily peak-vintage re-performing loans, all of which
have been modified. Roughly 62% of the pool has been paying on time
for the past 24 months, per the Mortgage Bankers Association
methodology, and none of the loans have experienced a delinquency
within the past 12 months. The pool has a weighted average
sustainable loan to value ratio of 85.5%, and the WA model FICO
score is 675.

Low Operational Risk (Positive): Fitch considers this transaction
to have low operational risk. Federal Home Loan Mortgage Corp. has
an established track record in residential mortgage activities and
has an 'Above Average' aggregator assessment from Fitch. The
transaction also benefits from Select Portfolio Servicing, Inc. as
the named servicer for this transaction, which is rated 'RPS1-' and
'RSS1-' for primary and special servicing functions. In the
aggregate, the operational assessments were a net benefit to the
transaction at the 'B-sf' rating stress of approximately 40bps.

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

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement mechanism construct for
this transaction as weaker than that of other Fitch-rated RPL
deals. The weakness is due to the exclusion of a number of reps
that Fitch views as consistent with a full framework as well as the
limited diligence that may have otherwise acted as a mitigant.
Additionally, Freddie Mac as rep provider will only be obligated to
repurchase a loan, pay an indemnity loss amount or cure the
material breach prior to May 13, 2022. However, Fitch believes that
the defect risk is lower relative to other RPL transactions because
the loans were subject to Freddie Mac's loan-level review process
in place at the time the loan became delinquent. Therefore, Fitch
treated the construct as Tier 3 and increased its 'B-sf' expected
loss expectations by 20bps to account for the weaknesses in the
reps.

Sequential-Pay Structure (Positive): Once the initial CE of the
senior bonds has reached the target amount and if all performance
triggers are passing, principal is allocated pro rata among the
senior and subordinate classes with the most senior-subordinate
bond receiving the full subordinate share. This structure is a
positive to the rated class as it results in a faster paydown and
allows them to receive principal earlier than under a fully
sequential structure. However, to the extent any of the performance
triggers are failing, principal is distributed sequentially to the
senior classes until triggers pass or the senior classes are paid
in full.

No Servicer P&I Advances (Mixed): The servicer will not advance
delinquent monthly payments of P&I, which reduces liquidity to the
trust. However, as P&I advances made on behalf of loans that become
delinquent and eventually liquidate reduce liquidation proceeds to
the trust, the loan-level loss severities are less for this
transaction than for those where the servicer is obligated to
advance P&I. Structural provisions and cash flow priorities,
together with increased subordination, provides for ultimate
payment of interest to the rated class.

Third-Party Due Diligence Review (Negative): Third-party due
diligence was conducted on a statistically random sample of
approximately 18% of the transaction. The review was performed by a
TPR firm assessed as 'Acceptable - Tier 1' by Fitch. Approximately
9% of the sample received a diligence grade of 'C' or 'D' for
regulatory compliance exceptions; about one-third of these
exceptions are due to missing final documentation that prevented
conclusive testing of predatory lending. Fitch adjusted its 'B-sf'
loss expectations by less than 5bps to account for loans that could
not be tested; however, it is expected that most of these loans
would not be in violation if the testing can be completed.

CRITERIA APPLICATION

Fitch analyzed the transaction in accordance with its criteria, as
described in its October 2018 report, "U.S. RMBS Rating Criteria."
This incorporates a review of the aggregator's lending platforms,
as well as an assessment of the transaction's R&W and due diligence
results, which were found to be consistent with the ratings
assigned to the bonds.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines than
assumed at both the MSA and national levels. The implied rating
sensitivities are only an indication of some of the potential
outcomes and do not consider other risk factors that the
transaction may become exposed to or be considered in the
surveillance of the transaction.

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0%, in addition to the
model projected 11.6% at the 'B-sf' level. The analysis indicates
that there is some potential rating migration with higher MVDs,
compared with the model projection.

Fitch also conducted defined rating sensitivities that determine
the stresses to MVDs that would reduce a rating by one full
category, to non-investment grade, and to 'CCCsf'. For example,
additional MVDs of 4% would potentially move the 'B-sf' rated class
down to 'CCCsf' respectively.

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

Fitch was provided with due diligence information from the
third-party diligence provider. The due diligence focused on
regulatory compliance, pay history, the presence of key documents
in the loan file and data integrity on a sample of the loans in the
pool. Additionally, an updated tax and title search was conducted
on all of the loans in the transaction. Fitch received
certifications indicating that the loan-level due diligence was
conducted in accordance with Fitch's published standards. The
certifications also stated that the company performed its work in
accordance with the independence standards, per Fitch's criteria,
and that the due diligence analysts performing the review met
Fitch's criteria of minimum years of experience. Fitch considered
this information in its analysis and based on the findings, Fitch
made the following adjustments:

Fitch made an adjustment on 117 loans that were subject to federal,
state and/or local predatory testing. The loans contained material
violations, including an inability to test for high-cost violations
or confirm compliance, which could expose the trust to potential
assignee liability. These loans were marked as "indeterminate."
Typically, the HUD issues are related to missing the final HUD,
illegible HUDs, incomplete HUDs due to missing pages or only having
estimated HUDs where the final HUD1 was not used to test for
high-cost loans. To mitigate this risk, Fitch assumed a 100% LS for
loans in the states that fall under Freddie Mac's "do not purchase"
list of high cost or "high risk." Fifteen loans were affected by
this approach. For the remaining 97 loans, where the properties are
not located in the states that fall under Freddie Mac's do not
purchase list, the likelihood of all loans being high cost is
lower. However, Fitch assumes the trust could potentially incur
additional legal expenses. Fitch increased its LS expectations by
5% for these loans to account for the risk.


FREDDIE MAC 2019-HQA2: S&P Assigns B+(sf) to 16 Classes of Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Freddie Mac STACR Trust
2019-HQA2's notes.

The note issuance is a residential mortgage-backed securities
(RMBS) transaction backed by fully amortizing high loan-to-value
first-lien fixed-rate residential mortgage loans secured by one- to
four-family residences, planned-unit developments, condominiums,
cooperatives, and manufactured housing to mostly prime borrowers.

The ratings reflect:

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

-- The credit quality of the collateral included in the reference
pool--most of which is covered by mortgage insurance backstopped by
Freddie Mac;

-- A credit-linked note structure that reduces the counterparty
exposure to Freddie Mac for periodic principal payments but, at the
same time, relies on credit premium payments from Freddie Mac (a
highly rated counterparty) to make monthly interest payments and to
make up for any investment losses;

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

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

  RATINGS ASSIGNED
  Freddie Mac STACR Trust 2019-HQA2

  Class       Rating                Amount ($)
  A-H(i)      NR                18,626,873,629
  M-1         BBB (sf)             140,000,000
  M-1H(i)     NR                    55,045,797
  M-2         B+ (sf)              280,000,000
  M-2R        B+ (sf)              280,000,000
  M-2S        B+ (sf)              280,000,000
  M-2T        B+ (sf)              280,000,000
  M-2U        B+ (sf)              280,000,000
  M-2I        B+ (sf)              280,000,000
  M-2A        BB+ (sf)             140,000,000
  M-2AR       BB+ (sf)             140,000,000
  M-2AS       BB+ (sf)             140,000,000
  M-2AT       BB+ (sf)             140,000,000
  M-2AU       BB+ (sf)             140,000,000
  M-2AI       BB+ (sf)             140,000,000
  M-2AH(i)    NR                    55,045,797
  M-2B        B+ (sf)              140,000,000
  M-2BR       B+ (sf)              140,000,000
  M-2BS       B+ (sf)              140,000,000
  M-2BT       B+ (sf)              140,000,000
  M-2BU       B+ (sf)              140,000,000
  M-2BI       B+ (sf)              140,000,000
  M-2RB       B+ (sf)              140,000,000
  M-2SB       B+ (sf)              140,000,000
  M-2TB       B+ (sf)              140,000,000
  M-2UB       B+ (sf)              140,000,000
  M-2BH(i)    NR                    55,045,797
  B-1         NR                   125,000,000
  B-1A        NR                    62,500,000
  B-1AR       NR                    62,500,000
  B-1AI       NR                    62,500,000
  B-1AH(i)    NR                    25,270,609
  B-1B        NR                    62,500,000
  B-1BH(i)    NR                    25,270,609
  B-2         NR                    70,000,000
  B-2A        NR                    35,000,000
  B-2AR       NR                    35,000,000
  B-2AI       NR                    35,000,000
  B-2AH(i)    NR                    13,761,449
  B-2B        NR                    35,000,000
  B-2BH(i)    NR                    13,761,449
  B-3H(i)     NR                    19,504,580  

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


FREED 2019-1: DBRS Finalizes BB (high) Rating on Class C Notes
--------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of notes (the Notes) issued by FREED ABS Trust 2019-1
(FREED 2019-1):

-- $249,550,000 Class A Notes at A (sf)
-- $102,090,000 Class B Notes at BBB (high) (sf)
-- $56,710,000 Class C Notes at BB (high) (sf)

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

(1) The transaction's form and sufficiency of available credit
    enhancement.

    -- Subordination, overcollateralization, amounts held in the
       Reserve Fund and excess spread create credit enhancement
       levels that are commensurate with the proposed ratings.

    -- Transaction cash flows are sufficient to repay investors
       under all A (sf), BBB (high) (sf) and BB (high) (sf) stress
       scenarios in accordance with the terms of the FREED 2019-1
       transaction documents.

(2) Structural features of the transaction that require the Notes
    to enter into full turbo principal amortization if certain
    triggers are breached or if credit enhancement deteriorates.

(3) The experience, underwriting and servicing capabilities of
    Freedom Financial Asset Management, LLC (FFAM).

(4) The experience, underwriting and origination capabilities of
    Cross River Bank (CRB).

(5) The ability of Wilmington Trust National Association (rated
    A (high) with a Positive trend by DBRS) to perform duties as
    a Backup Servicer and the ability of Portfolio Financial
    Servicing Company to perform duties as a Backup Servicer
    Subcontractor.

(6) The annual percentage rate (APR) charged on the loans and
    CRB's status as the true lender.

    -- All loans included in FREED 2019-1 are originated by CRB,
       a New Jersey state-chartered Federal Deposit Insurance
       Corporation-insured bank.

    -- Loans originated by CRB are all within the New Jersey
       state usury limit of 30.00%.

    -- The weighted-average APR of the loans in the pool is
       22.11%.

    -- Loans may be in excess of individual state usury laws;
       however, CRB as the true lender is able to export rates
       that preempt state usury rate caps.

    -- Loans originated to borrowers in states with active
       litigation (Second Circuit (New York, Connecticut,
       Vermont), Colorado and West Virginia) are excluded
       from the pool.

    -- The FREED 2019-1 loan pool includes loans originated
       to borrowers in Maryland, a state with active litigation.
       DBRS incorporated an additional stressed cash flow analysis

       assuming that loans to borrowers in Maryland with APRs
above
       the state usury cap of 24% were subsequently reduced to the
       state usury cap. Transaction cash flows are sufficient to
       repay investors under all A (sf ), BBB (high) (sf ) and
       BB (high) (sf) stress scenarios.

    -- Under the Loan Sale Agreement, FFAM is obligated to
       repurchase any loan if there is a breach of representation
       and warranty that materially and adversely affects the
       interests of the purchaser.

(7) The legal structure and legal opinions that address the true
    sale of the personal loans, the non-consolidation of the
    trust, that the trust has a valid first-priority security
    interest in the assets and consistency with the DBRS
    "Legal Criteria for U.S. Structured Finance."


GLS AUTO 2018-1: S&P Raises Class C Notes Rating to BB+ (sf)
------------------------------------------------------------
S&P Global Ratings raised its ratings on seven classes from GLS
Auto Receivables Trust's series 2017-1 and 2018-1.

The rating actions reflect collateral performance to date and S&P's
expectations regarding future collateral performance, as well as
each transaction's structure and credit enhancement. Additionally,
S&P incorporated secondary credit factors, including credit
stability, payment priorities under various scenarios, and sector-
and issuer-specific analyses. Considering all these factors, the
rating agency believes the creditworthiness of the notes remains
consistent with the raised ratings.

"We maintain a rating cap of 'AA (sf)' that we had placed on Global
Lending Services LLC's (GLS's) transactions. Factors include the
company's short operating history and limited but improving
profitability," S&P said.

"These transactions are performing better than our initial
expectations. As a result, we lowered our loss expectation because
of lower-than-expected default frequencies and our view of future
collateral performance," S&P said.

  Table 1
  Collateral Performance (%)
  As of the April 2019 distribution date

                           Pool   Current   60+ day
  Series           Mo.   factor       CNL   delinq.
  2017-1            22    50.55      8.63      6.26
  2018-1            16    64.72      5.16      4.06

  Mo.--Month.
  CNL--cumulative net loss.

  Table 2
  CNL Expectations (%)
                                                             
                 Original        Revised
                 lifetime       lifetime
  Series         CNL exp.       CNL exp.
  2017-1      21.00-22.00    19.25-20.25
  2018-1      21.00-22.00    19.25-20.25

  CNL exp.--Cumulative net loss expectations.

Each transaction contains a sequential principal payment structure
in which the notes are paid principal by seniority. Each also has
credit enhancement in the form of a nonamortizing reserve account,
overcollateralization, subordination for the higher-rated tranches,
and excess spread. The credit enhancement for each of the
transactions is at the specified target or floor, and each class'
credit support continues to increase as a percentage of the
amortizing collateral balance.

The rating actions reflect S&P's view that the total credit support
as a percentage of the amortizing pool balance, compared with its
expected remaining losses, is commensurate with the raised
ratings.

  Table 3 Hard Credit Support (%)
  As of the April 2019 distribution date

                                Total hard      Current total hard
                            credit support          credit support
  Series          Class     at issuance(i)       (% of current)(i)
  2017-1          A-2                44.30                   89.09
  2017-1          B                  31.80                   64.37
  2017-1          C                  20.80                   42.61
  2017-1          D                  11.80                   24.79
  2018-1          A                  31.50                   53.13
  2018-1          B                  19.75                   34.97
  2018-1          C                  11.50                   22.23

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

"We considered the current hard credit enhancement compared with
the expected remaining cumulative net losses for those classes for
which hard credit enhancement alone -- without credit to the
stressed excess spread -- was sufficient, in our opinion, to
upgrade the notes," S&P said.

For the other classes, S&P incorporated a cash flow analysis to
assess the loss coverage level, giving credit to stressed excess
spread. S&P's various cash flow scenarios included forward-looking
assumptions on recoveries, timing of losses, and voluntary absolute
prepayment speeds that it believes are appropriate given each
transaction's performance to date. Aside from its break-even cash
flow analysis, S&P also conducted sensitivity analyses for these
series to determine the impact that a moderate ('BBB') stress
scenario would have on its ratings if losses began trending higher
than its revised base-case loss expectation.

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

  RATINGS RAISED

  GLS Auto Receivables Trust
                                Rating
  Series      Class          To            From
  2017-1      A-2            AA (sf)       A (sf)
  2017-1      B              AA (sf)       A- (sf)
  2017-1      C              A+ (sf)       BBB (sf)
  2017-1      D              BBB (sf)      BB (sf)
  2018-1      A              AA (sf)       A (sf)
  2018-1      B              A- (sf)       BBB (sf)
  2018-1      C              BB+ (sf)      BB (sf)


GLS AUTO 2019-2: S&P Rates Class D Notes 'BB- (sf)'
---------------------------------------------------
S&P Global Ratings assigned its ratings to GLS Auto Receivables
Issuer Trust 2019-2's automobile receivables-backed notes series
2019-2.

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

The ratings reflect:

-- The availability of approximately 50.1%, 40.7%, 32.7%, and
25.8% of credit support for the class A, B, C, and D notes,
respectively, based on stressed cash flow scenarios (including
excess spread). These credit support levels provide coverage of
approximately 2.50x, 2.00x, 1.55x, and 1.22x S&P's 19.25%-20.25%
expected cumulative net losses for the class A, B, C, and D notes,
respectively.

-- The expectation that under a moderate ('BBB') stress scenario
(1.55x S&P's expected loss level), all else being equal, S&P's
rating on the class A and B notes will remain within one rating
category of the assigned 'AA (sf)' and 'A (sf)' ratings, and S&P's
rating on the class C notes will remain within two rating
categories of the assigned 'BBB (sf)' rating. The class D notes
will remain within two rating categories of the assigned 'BB- (sf)'
rating during the first year, but will eventually default under the
'BBB' stress scenario. These rating movements are within the limits
specified by the rating agency's credit stability criteria."

-- S&P's analysis of over five years of origination static pool
data and securitization performance data on Global Lending Services
LLC's seven Rule 144A securitizations.

-- The collateral characteristics of the subprime automobile loans
securitized in this transaction, including the representation in
the transaction documents that all contracts in the pool have made
a least one payment.

-- The notes' underlying credit enhancement in the form of
subordination, overcollateralization, a reserve account, and excess
spread for the class A, B, C, and D notes.

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

  RATINGS ASSIGNED

  GLS Auto Receivables Issuer Trust 2019-2

  Class      Rating     Amount (mil. $)

  A          AA (sf)             213.81
  B          A (sf)               58.42
  C          BBB (sf)             44.20
  D          BB- (sf)             33.57


GOLDMAN SACHS 2013-G1: Fitch Affirms BB Rating on $22MM DM Debt
---------------------------------------------------------------
Fitch Ratings has affirmed seven classes of Goldman Sachs & Co. GS
Mortgage Securities Trust series 2013-G1.

KEY RATING DRIVERS

Concentration: The transaction is secured by three single asset
loans, and therefore, is more susceptible to event risk related to
the respective markets, sponsors, or largest tenants occupying the
properties.

Retail Market Concerns: Fitch's existing concerns on the retail
sector remain heightened regarding the health of retail sales, the
impact of e-commerce on traditional retailing, and the growing
number of store closures as a result of both bankruptcy and
business rationalization. While JC Penney and Macy's have announced
store closings, none of the affected locations are at the subject
properties. Sears (non-collateral) terminated its lease in January
2019, prior to its December 2035 lease expiration at the Deptford
Mall. Fitch requested confirmation of co-tenancy triggers and will
continue to monitor the mall's performance.

Improved Property Cash Flow - All three malls have showed
improvements in property level cash flows despite declining sales
trends over the last several years. Property revenue, operating
expenses and capital expenditures were normalized to reflect
sustainable performance.

Leverage & Structure - Rating-specific DSCR hurdles reflect
transaction leverage, structural features and individual property
characteristics.

Experienced Ownership and Management: All three loans are sponsored
by large national real estate investment trusts focused on regional
and super-regional shopping centers. The Great Lakes loan sponsor
is Taubman Centers, Inc. The Deptford loan is sponsored by The
Macerich Partnership, L.P. The Katy Mills loan is sponsored by a
joint venture between Simon Property Trust and Kan Am USA.

RATING SENSITIVITIES

The Rating Outlook for all classes remains Stable. Future upgrades
are unlikely given Fitch's concerns with overall regional mall
performance but are possible with significant sales and cash flow
improvements. Conversely, downgrades would be considered should
property performance decline materially.

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:

  -- $34.7 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $295.7 million class A-2 at 'AAAsf'; Outlook Stable;

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

  -- $76 million class B at 'AAsf'; Outlook Stable;

  -- $49.7 million class C at 'Asf'; Outlook Stable;

  -- $38.3 million class D at 'BBBsf'; Outlook Stable;

  -- $22 million class DM* at 'BBsf'; Outlook Stable.

  * Class DM represents the interest solely in the subordinate note
of the Deptford Mall loan.


GS MORTGAGE 2019-GC39: Fitch to Rate $7.7MM Class G-RR Certs 'B-sf'
-------------------------------------------------------------------
Fitch Ratings has issued a presale report on GS Mortgage Securities
Trust 2019-GC39 commercial mortgage pass-through certificates,
Series 2019-GC39.

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

  -- $13,478,000 class A-1 'AAAsf'; Outlook Stable;

  -- $122,528,000 class A-2 'AAAsf'; Outlook Stable;

  -- $175,000,000 class A-3 'AAAsf'; Outlook Stable;

  -- $209,062,000 class A-4 'AAAsf'; Outlook Stable;

  -- $21,171,000 class A-AB 'AAAsf'; Outlook Stable;

  -- $622,424,000a class X-A 'AAAsf'; Outlook Stable;

  -- $69,588,000a class X-B 'A-sf'; Outlook Stable;

  -- $81,185,000 class A-S 'AAAsf'; Outlook Stable;

  -- $35,761,000 class B 'AA-sf'; Outlook Stable;

  -- $33,827,000 class C 'A-sf'; Outlook Stable;

  -- $18,364,000b class D 'BBBsf'; Outlook Stable;

  -- $32,861,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $14,497,000b class E 'BBB-sf'; Outlook Stable;

  -- $15,464,000b class F 'BB-sf'; Outlook Stable;

  -- $7,732,000bce class G-RR 'B-sf'; Outlook Stable.

The following classes are not expected to be rated by Fitch:

  -- $25,129,711bce class H-RR;

  -- $29,343,000bd class VRR Interest.

(a) Notional amount and interest only.

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

(c) Horizontal credit-risk retention interest.

(d) Vertical credit-risk retention interest.

(e) The initial certificate balance of each of the Class F, Class
G-RR and Class H-RR certificates is subject to change based on
final pricing of all certificates and the final determination of
the Class G-RR and Class H-RR certificates.

The expected ratings are based on information provided by the
issuer as of May 5, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 36 loans secured by 64
commercial properties having an aggregate principal balance of
$802,541,712 as of the cut-off date. The loans were contributed to
the trust by Goldman Sachs Mortgage Securities and Citi Real Estate
Funding Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 81.4% of the properties
by balance, cash flow analysis of 88.7% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Credit Opinion Loans: Three loans representing 23.4% of the pool
have investment-grade credit opinions, which is above both the 2018
average of 13.6% and YTD 2019 average of 10.8%. Fitch's DSCR and
LTV net of the credit opinion loans are 1.16x and 107.2%,
respectively.

Pool Concentration: The top 10 loans in the pool comprise 63.9% of
the pool, reflecting higher concentration than the 2018 and YTD
2019 averages of 50.6% and 50.7%, respectively. The pool's 520/520
LCI and SCI also indicate higher loan and sponsor concentration
than the 2018 and YTD 2019 averages of 373/375 and 398/404,
respectively.

Fitch Leverage: The pool's Fitch leverage is slightly better
compared with other Fitch-rated, fixed-rate, multiborrower
transactions. The pool's Fitch DSCR of 1.19x is approximately in
line with the 2018 and YTD 2019 averages of 1.22x and 1.21x,
respectively. The pool's Fitch LTV of 98.2% is better than the 2018
and YTD 2019 averages of 102.0% and 102.3%, respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow was 13.7% below the
most recent year's net operating income for properties for which a
full-year NOI was provided, excluding properties that were
stabilizing during this period. Unanticipated further declines in
property-level NCF could result in higher defaults and loss
severities on defaulted loans and in potential rating actions on
the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the GSMS
2019-GC39 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 junior 'AAAsf' certificates to 'A-sf' could result. In a more
severe scenario, in which NCF declined a further 30% from Fitch's
NCF, a downgrade of the junior 'AAAsf' certificates to 'BBBsf'
could result.


INSTITUTIONAL MORTGAGE 2012-2: Fitch Affirms B Rating on G Certs
----------------------------------------------------------------
Fitch Ratings has affirmed nine classes of Institutional Mortgage
Capital, commercial mortgage pass-through certificates series
2012-2. All currencies are denominated in Canadian dollars.

KEY RATING DRIVERS

Generally Stable Loss Expectations: Overall loss expectations have
remained stable since Fitch's last rating action. There are
currently no delinquent or specially serviced loans, but four loans
(31.9%) have been designated as Fitch Loans of Concern (FLOC). The
underperformance of these properties is mitigated by the recourse
provisions of many of these loans (48.1% of the pool is secured by
full recourse loans).

The largest loan in the pool, Cedars Apartments (13.7%), has been
designated a FLOC. The loan is secured by a 276-unit apartment
building located in Calgary, AB. The property has been under
economic stress due to the downturn in the Alberta energy market.
Occupancy improved from 80% as of year-end (YE) 2016 to 88% as of
YE 2017 and 91% as of YE 2018. However, the YE 2017 net operating
income (NOI) is down 12% from YE 2016 and 22% from YE 2012
primarily due to a decline in rental rates. The YE 2017 debt
service coverage ratio was reported to be 1.01x. Fitch's loss
expectations for this loan have increased based on the NOI decline
and low DSCR, however the loan has full recourse to the borrower
and sponsor.

The second largest FLOC is the Lakewood Apartments loan (9.4%),
which is secured by a 111-unit apartment building in Fort McMurray,
AB. The loan was in special servicing in February 2016 due to the
downturn in the energy markets, but returned to master servicer in
early 2017 and remains current. In May 2016, the Fort McMurray area
was evacuated due to wildfires, but the collateral did not sustain
structural damage. Demand at the property increased due to local
residents that were displaced by the fires and workers brought in
for restoration efforts. However, that demand has since dissipated.
Occupancy was reported to be 63% as of YE 2018 compared to 73% at
YE 2017. The loan maturity was extended to November 2019 and has
full recourse to the same borrower and sponsor as the Cedars
Apartments loan.

Changes in Credit Enhancement: As of the April 2019 distribution
date, the pool's aggregate principal balance has been reduced 41.9%
to $139.5 million from $240.2 million at issuance. Credit
enhancement continues to increase with transaction paydown.

Pool Concentration: The pool is concentrated with only 17 loans
remaining. The top five and 10 account for 53.9% and 84.6% of the
pool, respectively. There is also sponsor concentration with three
loans in the top five (31.2%) having the same sponsor group,
2668921 Manitoba Ltd and related entities. Additionally, the pool
has three loans (30.4%) backed by properties in Alberta, which has
experienced volatility from the energy sector in the past few
years.

Maturities: Four loans (21.5%) are scheduled to mature in 2019,
including the Lakewood Apartments loan. The remainder of the pool
matures in 2020 (4%), 2021 (12%) and 2022 (62.4%).

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.

Loans with Recourse: Of the remaining pool, 82.9% of the loans
feature full or partial recourse to the borrowers and/or sponsors.

RATING SENSITIVITIES

The Rating Outlook on classes E, F and G remain Negative.
Downgrades could be possible if the Lakewood Apartments loan
defaults or becomes delinquent. Additionally, the volatility in
energy markets and the impact on loan performance, property values,
and borrower's ability to refinance could also lead to downgrades.
However, any potential losses could be mitigated by loan recourse
provisions. If performance of the Lakewood Apartments improves, the
Outlooks may be revised to Stable. The Rating Outlooks on the
senior classes remain Stable as the classes have benefited from an
increase in credit enhancement from loan payoffs and scheduled
amortization. As the pool becomes more concentrated, upgrades may
be limited, but are possible with continued paydown and if the
performance of the FLOCs stabilize.

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 ratings:

  -- $40.5 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $63.0 million class A-2 at 'AAAsf'; Outlook Stable;

  -- Interest-only class XP at 'AAAsf'; Outlook Stable;

  -- $6.0 million class B at 'AAsf'; Outlook Stable;

  -- $8.4 million class C at 'Asf'; Outlook Stable;

  -- $7.2 million class D at 'BBBsf'; Outlook Stable;

  -- $3.6 million class E at 'BBB-sf'; Outlook Negative;

  -- $3 million class F* at 'BBsf'; Outlook Negative;

  -- $2.4 million class G* at 'Bsf'; Outlook Negative.

  * Non-offered certificates.

Fitch does not rate the $5.4 million class H or the interest-only
class XC.


JP MORGAN 2004-CIBC8: Moody's Hikes Class K Certs Rating to Caa1
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on three classes
and affirmed the ratings on three classes in J.P. Morgan Chase
Commercial Mortgage Securities Corp. Series 2004-CIBC8, Commercial
Pass-Through Certificates, Series 2004-CIBC8

Cl. H, Upgraded to Aa1 (sf); previously on Aug 24, 2018 Upgraded to
Baa1 (sf)

Cl. J, Upgraded to Ba1 (sf); previously on Aug 24, 2018 Upgraded to
B1 (sf)

Cl. K, Upgraded to Caa1 (sf); previously on Aug 24, 2018 Upgraded
to Caa2 (sf)

Cl. L, Affirmed C (sf); previously on Aug 24, 2018 Affirmed C (sf)

Cl. M, Affirmed C (sf); previously on Aug 24, 2018 Affirmed C (sf)

Cl. X-1*, Affirmed C (sf); previously on Aug 24, 2018 Affirmed C
(sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on the three P&I classes, Cl. H, Cl. J, and Cl. K, were
upgraded primarily due to an increase in credit support since
Moody's last review, resulting from paydowns and amortization. The
pool has paid down by 40% since Moody's last review. Furthermore,
while Class H is now fully covered by defeasance, the class had
experienced previous interest shortfalls.

The ratings on the Cl. L and Cl. M were affirmed because the
ratings are consistent with Moody's expected loss plus realized
losses.

The rating on the IO class, Cl. X-1 was affirmed based on the
credit quality of the referenced classes.

Moody's rating action reflects a base expected loss of 21.7% of the
current pooled balance, compared to 13.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.5% of the
original pooled balance, essentially the same as at last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in these ratings, except the
interest-only class was "Moody's Approach to Rating Large Loan and
Single Asset/Single Borrower CMBS" published in July 2017. The
methodologies used in rating the interest-only class were "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

DEAL PERFORMANCE

As of the April 12, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $22.8 million
from $1.3 billion at securitization. The certificates are
collateralized by eight mortgage loans ranging in size from 5% to
28% of the pool. Two loans, constituting 19% of the pool, have
defeased and are secured by US government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 4, compared to 5 at Moody's last review.

One loan, constituting 6.4% of the pool, is on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package. As part of Moody's
ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Fourteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $27 million (for an average loss
severity of 19%). One loan, constituting 24% of the pool, is
currently in special servicing. The specially serviced loan is the
Holualoa Centre East Loan ($5.5 million - 24.0% of the pool), which
is secured by a 95,000 square foot office property located in
Tucson, Arizona. The loan transferred to special servicing in
February 2014 ahead of the March 2014 loan maturity date. The
property is currently REO and was only 31% occupied as of June
2018. Moody's estimates a significant loss for this loan.

As of the April 2019 remittance statement, cumulative interest
shortfalls were approximately $2 million and impact up to Class K.
Moody's anticipates interest shortfalls will continue because of
the exposure to the specially serviced loan. Interest shortfalls
are caused by special servicing fees, including workout and
liquidation fees, appraisal entitlement reductions (ASERs), loan
modifications and extraordinary trust expenses.

Moody's received full year 2017 operating results for 100% of the
pool, and full or partial year 2018 operating results for 60% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 25.9%, compared to 37.8% at Moody's
last review. Moody's conduit component includes the five
non-defeased and performing loans. Moody's net cash flow reflects a
weighted average haircut of 16% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 9.6%.

Moody's actual and stressed conduit DSCRs are 1.57X and 4.56X,
respectively, compared to 1.50X and 3.49X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three non-defeased performing loans represent 45% of the
pool balance and are all fully amortizing. The largest performing
loan is the Precise Technology, Inc. Loan ($6 million -- 28% of the
pool), which is secured by a 616,000 square foot portfolio of five
crossed loans, secured by industrial properties located in five
U.S. states. The portfolio is 100% leased to a single tenant and
Moody's value incorporates a lit/dark analysis to account for the
tenant concentration risk. The tenants lease expiration is
coterminous with the loan maturity date in October 2023. The loan
has amortized 63% since securitization and Moody's LTV and stressed
DSCR are 20% and greater than 4.00X, respectively.

The second largest loan is the Franciscan Metro Center Loan ($2.3
million -- 9.9% of the pool), which is secured by a retail center
in Los Angeles, California. The property was 91% leased as of
December 2018, compared to 89% leased in June 2017. The loan has
amortized 62% since securitization and Moody's LTV and stressed
DSCR are 28% and 3.48X, respectively.

The third largest loan is the 11798 East Oswego Street Loan ($1.7
million -- 7.5% of the pool), which is secured by a 47,000 square
foot retail property located in Englewood, CO. As of December 31,
2018 the property was 100% occupied by 24 Hour Fitness with a lease
that is coterminous with the loan maturity date in April 2022. The
loan has amortized 73% since securitization and Moody's LTV and
stressed DSCR are 15% and greater than 4.00X, respectively.


JP MORGAN 2010-C2: Fitch Cuts Ratings on 2 Tranches to CCC
----------------------------------------------------------
Fitch Ratings has downgraded two and affirmed seven classes of J.P.
Morgan Chase Commercial Mortgage Finance Corp., commercial mortgage
pass-through certificates, series 2010-C2. In addition, the Rating
Outlook on one class was revised to Negative from Stable.

KEY RATING DRIVERS

Increased Loss Expectations; High Regional Mall Exposure: The
downgrades reflect increased loss expectations for the remaining
pool since Fitch's last rating action, driven primarily by
performance deterioration of the retail Fitch Loans of Concern.
Fitch has designated five loans (41.4% of the pool) as FLOCs,
including three regional mall loans (29.1%) and two office loans
(12.3%). No loans are currently specially serviced or defeased.

The three regional mall loans, The Mall at Greece Ridge (Greece,
NY; 12.1% of the pool), Shops at Sunset Place (South Miami, FL;
11.8%) and Valley View Mall (La Crosse, WI; 5.2%), were designated
as FLOCs because of anchor closures, lease rollover concerns,
declining tenant sales, significant market competition and/or
tertiary market locations. Bryan Tower (11.4%), an office tower in
Dallas, TX, and Park Place One (0.9%), an office property in
Springfield, IL, were flagged for significant occupancy
declines/concerns.

Pool/Maturity Concentrations: The transaction is highly
concentrated. Only 13 of the original 30 loans remain. All
remaining loans mature between July and October 2020. The largest
loan, Arizona Mills, accounts for 28.2% of the pool and is secured
by a regional mall in Tempe, AZ, which has exhibited stable
performance since issuance.

Increased Credit Enhancement: Credit enhancement has increased
since the last rating action from continued amortization and the
prepayment of three loans ($30.1 million balance at disposition)
with yield maintenance. As of the April 2019 distribution date, the
pool's aggregate principal balance has paid down by 51.1% to $538.5
million from $1.1 billion at issuance. Only one loan (3.8%) is
full-term, interest only and the remaining 12 loans (96.2%) are
currently amortizing.

Alternative Loss Considerations: To factor in upcoming refinance
concerns, Fitch performed an additional sensitivity scenario on The
Mall at Greece Ridge, The Shops at Sunset Place, Bryan Tower and
Valley View Mall, which assumed potential outsized losses of 35%,
50%, 25% and 35% on their respective balloon balances. The scenario
also factored in the expected paydown of the transaction from loans
that are not designated as FLOCs. This scenario contributed to the
revision of the Rating Outlook of class C to Negative and
maintaining the Negative Outlooks on classes D through F.

RATING SENSITIVITIES

The Negative Rating Outlooks on classes C through F reflect
refinance concerns and additional sensitivity analysis performed on
the FLOCs. These classes could be downgraded should performance of
The Mall at Greece Ridge, The Shops at Sunset Place, Bryan Tower
and/or Valley View Mall loans further decline and/or if these loans
fail to pay at maturity. Rating upgrades, although unlikely due to
pool concentrations, may occur with improved pool performance and
additional paydown or defeasance. The Rating Outlooks on classes
A-3 and B remain Stable due to increasing credit enhancement and
expected continued paydown. Distressed rated classes G and H may be
further downgraded as losses are realized or if losses exceed
Fitch's expectations.

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 the following classes and assigned Recovery
Estimates (REs) as indicated:

  -- $13.8 million class G to 'CCCsf'; RE 100% from 'Bsf';

  -- $2.8 million class H to 'CCCsf'; RE 70% from 'B-sf'.

Fitch has affirmed the following classes and revised Rating
Outlooks as indicated:

  -- $337.5 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $37.2 million class B at 'AAsf'; Outlook Stable;

  -- $53.7 million class C at 'Asf'; Revise Outlook to Negative
from Stable;

  -- $33 million class D at 'BBB+sf'; Outlook Negative;

  -- $22 million class E at 'BBB-sf'; Outlook Negative;

  -- $16.5 million class F at 'BBsf'; Outlook Negative;

  -- Interest-Only class X-A at 'AAAsf'; Outlook Stable.

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


JP MORGAN 2019-3: DBRS Finalizes B Rating on Class B-5 Certs
------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage Pass-Through Certificates, Series 2019-3 (the
Certificates) issued by J.P. Morgan Mortgage Trust 2019-3:

-- $364.1 million Class A-1 at AAA (sf)
-- $340.8 million Class A-2 at AAA (sf)
-- $272.7 million Class A-3 at AAA (sf)
-- $204.5 million Class A-4 at AAA (sf)
-- $68.2 million Class A-5 at AAA (sf)
-- $160.6 million Class A-6 at AAA (sf)
-- $112.0 million Class A-7 at AAA (sf)
-- $43.9 million Class A-8 at AAA (sf)
-- $54.5 million Class A-9 at AAA (sf)
-- $13.7 million Class A-10 at AAA (sf)
-- $68.2 million Class A-11 at AAA (sf)
-- $68.2 million Class A-11-X at AAA (sf)
-- $68.2 million Class A-12 at AAA (sf)
-- $68.2 million Class A-13 at AAA (sf)
-- $23.2 million Class A-14 at AAA (sf)
-- $23.2 million Class A-15 at AAA (sf)
-- $291.3 million Class A-16 at AAA (sf)
-- $72.8 million Class A-17 at AAA (sf)
-- $364.1 million Class A-X-1 at AAA (sf)
-- $364.1 million Class A-X-2 at AAA (sf)
-- $68.2 million Class A-X-3 at AAA (sf)
-- $23.2 million Class A-X-4 at AAA (sf)
-- $4.6 million Class B-1 at AA (sf)
-- $7.7 million Class B-2 at A (sf)
-- $4.8 million Class B-3 at BBB (sf)
-- $3.3 million Class B-4 at BB (sf)
-- $775.0 thousand Class B-5 at B (sf)

Classes A-11-X, A-X-1, A-X-2, A-X-3 and A-X-4 are interest-only
notes. The class balances represent notional amounts.

Classes A-1, A-2, A-3, A-4, A-5, A-7, A-12, A-13, A-14, A-16, A-17,
A-X-2 and A-X-3 are exchangeable certificates. These classes can be
exchanged for a combination of depositable certificates as
specified in the offering documents.

Classes A-2, A-3, A-4, A-5, A-6, A-7, A-8, A-9, A-10, A-11, A-12
and A-13 are super-senior certificates. These classes benefit from
additional protection from the senior support certificates (Classes
A-14 and A-15) with respect to loss allocation.

The AAA (sf) ratings on the Certificates reflect the 6.00% of
credit enhancement provided by subordinated certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 4.80%, 2.80%, 1.55%, 0.70% and 0.50% of credit enhancement,
respectively.

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

The Certificates are backed by 591 loans with a total principal
balance of $387,326,703 as of the Cut-Off Date (April 1, 2019).

The pool consists of fully amortizing fixed-rate mortgages with
original terms to maturity of 30 years. Approximately 39.2% of the
loans in the pool are conforming mortgage loans predominantly
originated by JPMorgan Chase Bank, N.A. (JPMCB; rated AA with a
Stable trend by DBRS) and AmeriHome Mortgage Company, LLC
(AmeriHome), which were eligible for purchase by Fannie Mae or
Freddie Mac. JPMCB generally delegates conforming loan underwriting
authority to correspondent lenders and does not subsequently review
those loans. Details on the underwriting of conforming loans can be
found in the Key Probability of Default Drivers section of the
related report.

The originators for the aggregate mortgage pool are United Shore
Financial Services, LLC doing business as (dba) United Wholesale
Mortgage and Shore Mortgage (24.3%), JPMCB (22.3%), AmeriHome
(15.8%), loanDepot.com, LLC (10.1%), Quicken Loans Inc. (7.2%) and
various other originators, each comprising less than 5.0% of the
mortgage loans. Approximately 14.0% of the loans sold to the
mortgage loan seller were acquired by MAXEX Clearing LLC, which
purchased such loans from the related originators or an
unaffiliated third party that directly or indirectly purchased such
loans from the related originators.

The mortgage loans will be serviced or sub-serviced by NewRez LLC
formerly known as New Penn Financial, LLC dba Shellpoint Mortgage
Servicing, LLC (SMS, 60.0%), JPMCB (22.3%), Cenlar FSB (15.8%) and
Nationstar Mortgage LLC (Nationstar, 1.8%). Servicing will be
transferred from SMS to JPMCB on the servicing transfer date (June
1, 2019, or a later date) as determined by the issuing entity and
JPMCB. For this transaction, the servicing fee payable for mortgage
loans serviced by JPMCB and SMS (which will be subsequently
serviced by JPMCB), is composed of three separate components: the
aggregate base servicing fee, the aggregate delinquent servicing
fee, and the aggregate additional servicing fee. These fees vary
based on the delinquency status of the related loan and will be
paid from interest collections before distribution to the
securities.

Nationstar will act as the Master Servicer. Citibank, N.A. (rated
AA (low) with a Stable trend by DBRS) will act as Securities
Administrator and Delaware Trustee. JPMCB and Wells Fargo Bank,
N.A. (rated AA with a Stable trend by DBRS) will act as Custodians.
Pentalpha Surveillance LLC will serve as the representations and
warranties (R&W) Reviewer.

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

The ratings reflect transactional strengths that include
high-quality underlying assets, well-qualified borrowers and a
satisfactory third-party due diligence review.

This transaction employs an R&W framework that contains certain
weaknesses such as materiality factors, some unrated R&W providers,
knowledge qualifiers and sunset provisions that allow for certain
R&Ws to expire within three to six years after the Closing Date.
The framework is perceived by DBRS to be limiting compared with
traditional lifetime R&W standards in certain DBRS-rated
securitizations. To capture the perceived weaknesses in the R&W
framework, DBRS reduced the originator scores in this pool. A lower
originator score results in increased default and loss assumptions
and provides additional cushions for the rated securities.


LADDER CAPITAL 2017-LC26: Fitch Affirms B- on $7MM Class F Certs
----------------------------------------------------------------
Fitch Ratings has affirmed all classes of Ladder Capital Commercial
Mortgage Trust 2017-LC26 commercial mortgage pass-through
certificates.

KEY RATING DRIVERS

Relatively Stable Performance: Overall pool performance and loss
expectations have remained relatively stable since issuance. There
have been no realized losses to date. Fitch has designated five
loans (9.1% of pool) as Fitch Loans of Concern, which includes two
top 15 loans (6.4%), one of which is specially serviced (4.1%), and
three loans outside of the top 15 (2.7%).

The seventh largest loan, 55-59 Chrystie Street (4.1% of the pool),
was transferred to special servicing in May 2018 for imminent
monetary default. The loan is secured by a mixed-use building in
Manhattan's Chinatown neighborhood. Occupancy has dropped to 12% as
of October 2018 from 100% at issuance due to the borrower's
reported attempt to transition space at the property from
traditional office/retail tenants to shorter-term tenants and event
spaces. A receiver, which was appointed in October 2018, is
reportedly in negotiations with a tenant to lease the building. A
judgement of foreclosure was granted in March 2019, with a
foreclosure sale projected for May 2019, according to the special
servicer. The special servicer continues to negotiate with the
borrower, while foreclosure proceeds.

The 14th largest loan, Midway Shopping Center (2.3% of pool), is
secured by a retail property located in Wyoming, PA. Occupancy at
the property fell from 94% to 65% at YE 2018, mainly due to the
closure of Bon-Ton (28.2% of NRA) upon their bankruptcy and Luzerne
Paintball (4.2% of NRA) vacating upon its September 2018 lease
expiration. At issuance, it was noted that three tenants, AT&T,
Wine&Spirit, and Pet Value (combined 4.3% of NRA), have co-tenancy
clause in relation to Bon-Ton. Other major tenants at the property
include Price Chopper and Harbor Freight Tools, which both have
leases extending more than five years beyond loan maturity.

Outside the top 15, three loans (2.7% of pool) were flagged due to
rollover concerns or are secured by single-tenant properties. The
Walmart Fayetteville loan (1%), which is secured by a single tenant
retail center located in Fayetteville, NC, became dark in November
2018 after Walmart closed its store at the property. Walmart has
indicated they intend to honor all terms of the lease through 2035
and are currently marketing the space for sublease. The Four
Corners Shopping Center loan (0.9%), which is secured by a retail
center in Arlington, TX, faces the upcoming rollover of its anchor
tenant Kroger (34.6% of NRA) at the end of October 2019. Cash
management and a sweep were triggered due to Kroger not renewing
its lease 18 months prior to the lease expiration. The Schletter
Industrial loan (0.7%) is secured by a single tenant industrial
property located in Shelby, NC; the sole tenant, Schletter Inc.,
declared bankruptcy in April 2018.

Minimal Change in Credit Enhancement: As of the April 2019
distribution date, the pool's aggregate principal balance has paid
down by 1.2% to $618.0 million from $625.7 million at issuance.
Thirty-four loans representing 38.9% of the pool are interest-only
for the full term and an additional seven loans representing 16.8%
of the pool were structured with a partial interest-only component
and have not yet begun to amortize.

ADDITIONAL CONSIDERATIONS

Pool Concentration: The top 15 loans comprise 72.2% of the pool.
Loans secured by hotel properties account for 18.2% of the pool and
those secured by single-tenant properties account for 30.3%.
Geographically, 33.0% of the pool is backed by properties in the
New York City and Los Angeles metros.

Investment-Grade Credit Opinion Loan: One loan, Two Riverfront
Plaza (8.8% of pool), received an investment-grade credit opinion
of 'BBB-sf' on a stand-alone basis at issuance.

RATING SENSITIVITIES

The Stable Rating Outlooks for classes A-1 through F reflect the
stable performance for the majority of the pool and expected
continued amortization. Downgrades may occur should the performance
of the 55-59 Chrystie Street and Midway Shopping Center loans
continue to deteriorate. Future upgrades may occur with improved
pool performance and additional paydown or defeasance.

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 classes:

  -- $12.5 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $89.6 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $32 million class A-SB at 'AAAsf'; Outlook Stable;

  -- $125 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $171.2 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $434.2 million* class X-A at 'AAAsf'; Outlook Stable;

  -- $39.1 million class A-S at 'AAAsf'; Outlook Stable;

  -- $28.9 million class B at 'AA-sf'; Outlook Stable;

  -- $32.1 million class C at 'A-sf'; Outlook Stable;

  -- $100.0 million* class X-B at 'A-sf'; Outlook Stable;

  -- $36 million class D at 'BBB-sf'; Outlook Stable;

  -- $36 million* class X-D at 'BBB-sf'; Outlook Stable;

  -- $17.2 million class E at 'BB-sf'; Outlook Stable;

  -- $7 million class F at 'B-sf'; Outlook Stable.

  * Notional amount and interest only

Fitch does not rate the class G certificate. The class E
certificate represents the horizontal credit risk retention
interest. There is also a vertical risk retention interest
representing approximately 1.97% of the total pool balance. The
current implied balance of the VRR interest is $12,181,526.  


LB-UBS COMMERCIAL 2006-C1: S&P Affirms CCC- Rating on Cl. D Certs
-----------------------------------------------------------------
S&P Global Ratings lowered its ratings on two classes of commercial
mortgage pass-through certificates from LB-UBS Commercial Mortgage
Trust 2006-C1, a U.S. commercial mortgage-backed securities (CMBS)
transaction. In addition, S&P affirmed its rating on class D from
the same transaction.
          
The downgrades on classes B and C, and affirmation on class D,
reflect their susceptibility to reduced liquidity support from the
three specially serviced assets ($76.9 million, 97.0%), as well as
credit support erosion that S&P anticipates will occur upon the
eventual resolution of the specially serviced assets.          

TRANSACTION SUMMARY

As of the April 17, 2019, trustee remittance report, the collateral
pool balance was $79.3 million, which is 3.2% of the pool balance
at issuance. The pool currently includes two loans and two real
estate owned (REO) assets, down from 145 loans at issuance. Three
of these assets are with the special servicer and one ($2.4
million, 3.0%) is on the master servicer's watchlist.

S&P calculated a 1.07x S&P Global Ratings' debt service coverage
(DSC) and 101.1% S&P Global Ratings' loan-to-value ratio using a
9.00% S&P Global Ratings' capitalization rate for the sole
performing loan, Park City Shopping Center.

To date, the transaction has experienced $188.9 million in pool
principal losses, or 7.7% of the original pool trust balance. S&P
expects losses to reach approximately 9.3% 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 three specially serviced assets.          

CREDIT CONSIDERATIONS

As of the April 17, 2019, trustee remittance report, three assets
in the pool were with the special servicer, LNR Partners LLC (LNR).
Details of the largest specially serviced asset are below.         


The Triangle Town Center loan ($74.6 million, 94.2%) is the largest
asset in the pool and has a reported total exposure of $75.5
million. The loan is secured by approximately 473,000 sq. ft. of a
1.44 million-sq.-ft. regional mall, lifestyle center and retail
center in Raleigh, N.C. The loan, which has a nonperforming matured
balloon payment status, was transferred to the special servicer on
Aug. 30, 2018, because the borrower indicated that they were unable
to pay off the loan upon its Dec. 5, 2018, maturity date and did
not wish to exercise their extension option. The reported DSC as of
Dec. 31, 2018, was 1.54x and occupancy for the collateral was
88.5%, according to the Dec. 31, 2018, rent rolls. LNR indicated
that it is exploring various resolution strategies. While a $23.7
million appraisal reduction amount has been reported on the loan,
the associated appraisal subordinate entitlement reduction amount
has not caused interest shortfalls to the trust, as the master
servicer advanced the full accrued monthly principal and interest
amount on the loan according to the April 2019 trustee remittance
report. S&P expects a moderate loss (26%-59%) upon this loan's
eventual resolution.

The two remaining assets with the special servicer have individual
balances that each represent less than 1.9% of the total pool trust
balance. S&P estimated losses for the three specially serviced
assets, arriving at a weighted-average loss severity of 49.9%.     
    

  RATINGS LOWERED      

  LB-UBS Commercial Mortgage Trust 2006-C1
  Commercial mortgage pass-through certificates
                Rating  
  Class     To          From
  B         B- (sf)     BB- (sf)
  C         CCC (sf)    B+ (sf)

  RATING AFFIRMED      

  LB-UBS Commercial Mortgage Trust 2006-C1
  Commercial mortgage pass-through certificates     

  Class     Rating     
  D         CCC- (sf)


LOANCORE 2019-CRE2: DBRS Assigns (P)B(low) Rating on Class G Notes
------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
floating-rate notes to be issued by LoanCore 2019-CRE2 Issuer Ltd.
(the Issuer):

-- Class A Senior Secured Floating Rate Notes at AAA (sf)
-- Class AS Secured Floating Rate Notes at AAA (sf)
-- Class B Secured Floating Rate Notes at AA (low) (sf)
-- Class C Secured Floating Rate Notes at A (low) (sf)
-- Class D Secured Floating Rate Notes at BBB (high) (sf)
-- Class E Floating Rate Notes at BBB (low) (sf)
-- Class F Floating Rate Notes at BB (low) (sf)
-- Class G Floating Rate Notes at B (low) (sf)

All trends are Stable.

Classes E, F, and G will be non-offered notes and retained by the
seller.

The initial collateral consists of 33 floating-rate mortgages
secured by 49 mostly transitional properties with a cut-off balance
totaling approximately $1.057 billion, excluding approximately
$120.2 million of future funding commitments and $830.4 million of
funded companion participations. Most loans are in a period of
transition with plans to stabilize and improve asset value. During
the Reinvestment Period, the Issuer may acquire, with principal
repayment proceeds, additional loans or include funded Future
funding participation and funded companion participations.

Because of the floating-rate nature of the loans, the index DBRS
used (one-month LIBOR) was the lower of a DBRS stressed rate that
corresponded to the remaining fully extended term of the loans or
the strike price of the interest rate cap with the respective
contractual loan spread added to determine a stressed interest rate
over the loan term. When the cut-off balances were measured against
the DBRS As-Is Net Cash Flow (NCF), 28 loans, comprising 87.1% of
the pool balance, had a DBRS As-Is Debt Service Coverage Ratio
(DSCR) below 1.00 times (x), a threshold indicative of default
risk. Additionally, the DBRS Stabilized DSCR for 20 loans,
comprising 63.6% of the initial pool balance, are below 1.00x,
which is indicative of elevated refinance risk. The properties are
often transitioning with potential upside in cash flow; however,
DBRS does not give full credit to the stabilization if there are no
holdbacks or if other loan structural features in place are
insufficient to support such treatment. Furthermore, even with the
structure provided, DBRS generally does not assume the assets to
stabilize above market levels.

The loans are generally secured by traditional property types
(i.e., retail, multifamily, office, hotel and industrial).
Additionally, only one of the multifamily loans in the pool is
currently secured by a student housing property, which often
exhibits higher cash flow volatility than traditional multifamily
properties. The properties are also primarily located in core
markets with the overall pool's weighted-average (WA) DBRS Market
Rank at a very high 5.5. Six loans, totaling 22.0% of the pool, are
in markets with a DBRS Market Rank of 8; six loans, totaling 24.3%
of the pool, are in markets with a DBRS Market Rank of 7; and five
loans, totaling 14.8% of the pool, are in markets with a Market
Rank of 6. The market ranks correspond to zip codes that are more
urbanized in nature. Four loans in the pool, totaling 23.7% of the
total pool balance, are backed by a property with a quality deemed
to be Above Average by DBRS. Further, four loans, totaling 15.1% of
the pool, are backed by properties considered to have Average +
property quality. Finally, the borrowers of all 33 loans have
purchased LIBOR rate caps that have a range of between 2.5% and
4.0% to protect against rising interest rates over the term of the
loan.

All loans have floating interest rates, and all loans interest only
during the original term with original term ranges from 24 months
to 36 months, creating interest rate risk. All loans have extension
options, and in order to qualify for these options, the loans must
meet minimum DSCR and loan-to-value (LTV) requirements.
Furthermore, the borrowers of all 33 loans have purchased LIBOR
rate caps that have a range of between 2.5% and 4.0% to protect
against rising interest rates over the term of the loan. Based on
the weighted initial pool balances, the overall WA DBRS As-Is DSCR
and DBRS Stabilized DSCR of 0.72x and 1.00x, respectively, are
reflective of high-leverage financing.

The DBRS As-Is DSCR is based on the DBRS In-Place NCF and debt
service calculated using a stressed interest rate. The WA stressed
rate used is 6.2%, which is greater than the current WA interest
rate of 5.7% (based on WA mortgage spread and an assumed 2.5%
one-month LIBOR index). The assets are generally well positioned to
stabilize, and any realized cash flow growth would help to offset a
rise in interest rates and improve the overall debt yield of the
loans. DBRS associates its loss given default (LGD) based on the
assets' DBRS As-Is LTV, which does not assume that the
stabilization plan and cash flow growth will ever materialize. Such
DBRS As-Is LTV is considered reasonable at 77.1% given the credit
enhancement levels at each rating category and the excellent mix of
markets exhibited by the pool.

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

Twenty loans, totaling only 63.7% of the initial pool balance,
represent refinance financing. The refinance financings within this
securitization generally do not require the respective sponsor(s)
to contribute material cash equity as a source of funding in
conjunction with the mortgage loan, resulting in a lower sponsor
cost basis in the underlying collateral. Of the 20 refinance loans,
six, representing 16.5% of the pool, have a current occupancy of
less than 80.0% and 12 accounts for $63.4 million of the $120.2
million of future funding (52.8%). This suggests that at least half
of the refinance loans are near stabilization, which would
partially mitigate the higher risk associated with a sponsor's
lower cost basis.


MARINER CLO 7: Moody's Rates $15.5MM Class E Notes 'Ba3'
--------------------------------------------------------
Moody's Investors Service has assigned ratings to two classes of
notes issued and one class of loans incurred by Mariner CLO 7,
Ltd.

Moody's rating action is as follows:

  US$224,000,000 Class A Loans maturing 2032 (the "Class A
  Loans"), Assigned Aaa (sf)

  US$40,000,000 Class A Floating Rate Notes due 2032
  (the "Class A Notes"), Assigned Aaa (sf)

  US$15,500,000 Class E Mezzanine Deferrable Floating Rate
  Notes due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

The Class A Loans, the Class A Notes and the Class E Notes are
referred to herein, collectively, as the "Rated Debt."

RATINGS RATIONALE

The rationale for the rating is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in its methodology.

Mariner CLO 7 is a managed cash flow CLO. The issued notes and
incurred loans will be collateralized primarily by broadly
syndicated senior secured corporate loans. At least 90% of the
portfolio must consist of first lien senior secured loans and
eligible principal investments, and up to 10% of the portfolio may
consist of second lien loans and unsecured loans. The portfolio is
approximately 95% ramped as of the closing date.

Mariner Investment Group, LLC will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's five year reinvestment period.
Thereafter, subject to certain restrictions, the Manager may
reinvest unscheduled principal payments and proceeds from sales of
credit risk assets.

In addition to the Rated Debt, the Issuer issued three other
classes of notes and subordinated notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes and loans in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in March 2019.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $400,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2825

Weighted Average Spread (WAS): 3.35%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 47.75%

Weighted Average Life (WAL): 9.0 years

Methodology Underlying the Rating Action:

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

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

The performance of the Rated Debt is subject to uncertainty. The
performance of the Rated Debt is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Debt.


METLIFE SECURITIZATION 2019-1: DBRS Finalizes B Rating on B2 Notes
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Residential Mortgage-Backed Notes, Series 2019-1 (the Securities)
issued by MetLife Securitization Trust 2019-1(the Trust):

-- $403.1 million Class A1 at AAA (sf)
-- $324.5 million Class A1A at AAA (sf)
-- $78.5 million Class A1B at AAA (sf)
-- $16.9 million Class M1 at AA (sf)
-- $12.4 million Class M2 at A (sf)
-- $15.3 million Class M3 at BBB (sf)
-- $11.5 million Class B1 at BB (sf)
-- $7.4 million Class B2 at B (sf)

Class A1 is an exchangeable note. This class can be exchanged for
combinations of exchange notes as specified in the offering
documents.

The AAA (sf) ratings on the Notes reflect the 15.55% of credit
enhancement provided by subordinated notes in the pool. The AA
(sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect 12.00%,
9.40%, 6.20%, 3.80% and 2.25% 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 seasoned
performing and re-performing first-lien residential mortgages. The
Securities are backed by 2,096 loans with a total principal balance
of $477,272,970 as of the Cut-Off Date (March 31, 2019).
The portfolio is approximately 146 months seasoned, and of the
loans, 84.1% are modified. Within the pool, 847 mortgages have
non-interest-bearing deferred amounts, which equate to
approximately 6.0% of the total principal balance.

All the loans were current as of the Cut-Off Date and all the loans
have been zero times 30 days delinquent (0 x 30) for at least the
past 24 months under the Mortgage Bankers Association (MBA)
delinquency method. Additionally, 99.98% of the loans have been 0 x
30 for at least the past 36 months under the MBA delinquency
method. None of the loans are subject to the Consumer Financial
Protection Bureau's Qualified Mortgage (QM) rules.

Prior to the Closing Date, Metropolitan Life Insurance Company
(MetLife), in its capacity as the Sponsor and as the Seller,
acquired the loans from various unaffiliated third-party sellers.
As the Sponsor, MetLife and/or one or more majority-owned
affiliates of the Sponsor will collectively acquire and retain a 5%
eligible vertical interest in each class of securities to be issued
(other than the Class R certificates) to satisfy credit risk
retention requirements.

As of the Closing Date, the loans will be serviced by Select
Portfolio Servicing, Inc. (SPS).

There will not be any advancing of delinquent principal or interest
on any mortgages by the Servicer or any other party to the
transaction; however, the Servicer is obligated to make advances in
respect of homeowner association fees, taxes and insurance,
installment payments on energy improvement liens and reasonable
costs and expenses incurred in the course of servicing and
disposing of properties.

The transaction employs a sequential-pay cash flow structure.
Principal proceeds can be used to cover interest shortfalls on the
Securities, but such shortfalls on Class M2 and more subordinate
bonds will not be paid until the more senior classes are retired.

The ratings reflect transactional strengths that include underlying
assets that generally performed well through the crisis and an
experienced Servicer. Additionally, a satisfactory third-party due
diligence review was performed on the portfolio with respect to
regulatory compliance, payment history and data capture as well as
title and tax review. Updated broker price opinions or exterior
appraisals were provided for 100.0% of the pool; however,
reconciliation was not performed on the updated values.

The transaction employs a relatively strong representations and
warranties framework, but has a few limitations such as certain
knowledge qualifiers and fewer mortgage loan representations
relative to DBRS criteria for seasoned pools.

The transaction employs a representations and warranties (R&Ws)
framework that includes a trigger review event that may result in
potential breaches of R&Ws being reviewed at a much later date,
certain knowledge qualifiers and fewer mortgage loan
representations relative to DBRS criteria for seasoned pools.
Mitigating factors include (1) a financially strong counterparty,
MetLife, which is providing mortgage loan R&Ws for the life of the
transaction; (2) significant loan seasoning and clean performance
history in recent years; (3) a comprehensive due diligence review;
(4) a relatively strong R&W enforcement mechanism, including
directing noteholder review and binding arbitration; and (5) for
R&Ws with knowledge qualifiers, even if the Seller did not have
actual knowledge of the breach, the Seller is still required to
remedy the breach in the same manner as if no knowledge qualifier
had been made.

The DBRS ratings of AAA (sf) and AA (sf) address the timely payment
of interest and full payment of principal by the legal final
maturity date in accordance with the terms and conditions of the
related notes. The DBRS ratings of A (sf), BBB (sf), BB (sf) and B
(sf) address the ultimate payment of interest and full payment of
principal by the legal final maturity date in accordance with the
terms and conditions of the related notes and certificates.


MONROE CAPITAL VIII: Moody's Rates $32.4MM Class E Notes '(P)Ba3'
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to five
classes of notes to be issued by Monroe Capital MML CLO VIII, Ltd.


Moody's rating action is as follows:

US$252,000,000 Class A Senior Floating Rate Notes due 2031 (the
"Class A Notes"), Assigned (P)Aaa (sf)

US$49,500,000 Class B Floating Rate Notes due 2031 (the "Class B
Notes"), Assigned (P)Aa2 (sf)

US$27,000,000 Class C Deferrable Mezzanine Floating Rate Notes due
2031 (the "Class C Notes"), Assigned (P)A2 (sf)

US$32,850,000 Class D Deferrable Mezzanine Floating Rate Notes due
2031 (the "Class D Notes"), Assigned (P)Baa3 (sf)

US$32,400,000 Class E Deferrable Mezzanine Floating Rate Notes due
2031 (the "Class E Notes"), Assigned (P)Ba3 (sf)

The Class A Notes, the Class B Notes, the Class C Notes, the Class
D Notes and the Class E Notes are referred to herein, collectively,
as the "Rated Notes."

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions. Upon a conclusive review of a
transaction and associated documentation, Moody's will endeavor to
assign definitive ratings. A definitive rating, if any, may differ
from a provisional rating.

RATINGS RATIONALE

The rationale for the ratings is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in its methodology.

Monroe Capital MML CLO VIII is a managed cash flow CLO. The issued
notes will be collateralized primarily by small and medium
enterprise loans. At least 95% of the portfolio must consist of
senior secured loans and eligible investments, and up to 5% of the
portfolio may consist of second lien loans and senior unsecured
loans. Moody's expects the portfolio to be approximately 70% ramped
as of the closing date.

Monroe Capital Asset Management LLC will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's four year reinvestment period.
Thereafter, the Manager may not reinvest in new assets and all
principal proceeds, including sale proceeds, will be used to
amortize the notes in accordance with the priority of payments.

In addition to the Rated Notes, the Issuer will issue subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in March 2019.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $450,000,000

Diversity Score: 43

Weighted Average Rating Factor (WARF): 3700

Weighted Average Spread (WAS): 4.45%

Weighted Average Coupon (WAC): 7.5%

Weighted Average Recovery Rate (WARR): 47.0%

Weighted Average Life (WAL): 8.0 years

Methodology Underlying the Rating Action:

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

The CLO permits the manager to determine RiskCalc-derived rating
factors, based on modifications to certain pre-qualifying
conditions applicable to the use of RiskCalc, for obligors
temporarily ineligible to receive Moody's credit estimates. Such
determinations are limited to a small portion of the portfolio and
permits certain modifications for a limited time. The rating
analysis included rating factor stress scenarios.

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

The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.


MORGAN STANLEY 2012-C4: Moody's Lowers Class F Certs Rating to B1
-----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings on eight classes
and downgraded the ratings on three classes in Morgan Stanley
Capital I Trust 2012-C4, Commercial Mortgage Pass-Through
Certificates, Series 2012-C4, as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Jul 20, 2018 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Jul 20, 2018 Affirmed Aaa
(sf)

Cl. A-S, Affirmed Aaa (sf); previously on Jul 20, 2018 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa2 (sf); previously on Jul 20, 2018 Affirmed Aa2
(sf)

Cl. C, Affirmed A2 (sf); previously on Jul 20, 2018 Affirmed A2
(sf)

Cl. D, Affirmed Baa1 (sf); previously on Jul 20, 2018 Affirmed Baa1
(sf)

Cl. E, Affirmed Ba1 (sf); previously on Jul 20, 2018 Affirmed Ba1
(sf)

Cl. F, Downgraded to B1 (sf); previously on Jul 20, 2018 Affirmed
Ba3 (sf)

Cl. G, Downgraded to Caa1 (sf); previously on Jul 20, 2018 Affirmed
B3 (sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Jul 20, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Downgraded to B2 (sf); previously on Jul 20, 2018
Affirmed B1 (sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

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

The ratings on two P&I classes were downgraded primarily due to the
continued decline in performance of the largest loan in the pool,
The Shoppes at Buckland Hills loan.

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

The rating on one IO class, Cl. X-B, was downgraded due to the
decline in the credit quality of its referenced classes. Class X-B
references seven P&I classes (Class B thru Class H).

Moody's rating action reflects a base expected loss of 4.3% of the
current pooled balance, compared to 3.8% at Moody's last review.
Moody's base expected loss plus realized losses is now 3.6% of the
original pooled balance, compared to 3.3% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except interest-only
classes were "Moody's Approach to Rating Large Loan and Single
Asset/Single Borrower CMBS" published in July 2017 and "Approach to
Rating US and Canadian Conduit/Fusion 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, "Approach to Rating US and
Canadian Conduit/Fusion CMBS" published in July 2017, and "Moody's
Approach to Rating Structured Finance Interest-Only (IO)
Securities" published in February 2019.

DEAL PERFORMANCE

As of the May 17, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 33% to $737.7
million from $1.099 billion at securitization. The certificates are
collateralized by 30 mortgage loans ranging in size from less than
1% to 15.6% of the pool, with the top ten loans (excluding
defeasance) constituting 65.3% of the pool. One loan, constituting
7.9% of the pool, has an investment-grade structured credit
assessment. Three loans, constituting 9.5% of the pool, have
defeased and are secured by US government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 14, compared to 15 at Moody's last review.

Six loans, constituting 12.2% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package. As part of Moody's
ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

One loan has been liquidated from the pool, resulting in an
aggregate realized loss of $7.9 million (for a loss severity of
42%). There are no loans currently in special servicing.

Moody's received full year 2017 operating results for 100% of the
pool, and full or partial year 2018 operating results for over 99%
of the pool (excluding specially serviced and defeased loans).
Moody's weighted average conduit LTV is 98%, compared to 97% at
Moody's last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow
reflects a weighted average haircut 18% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 9.9%.

Moody's actual and stressed conduit DSCRs are 1.38X and 1.17X,
respectively, compared to 1.39X and 1.15X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The loan with a structured credit assessment is the ELS Portfolio
Loan ($58.4 million -- 7.9% of the pool), which is secured by a
portfolio of eight manufactured housing communities located in
Florida (2), Nevada (2), Virginia (1), Arizona (1), California (1),
and Massachusetts (1). The sponsor, Equity Lifestyle Properties, is
a Chicago-based, self-administered, self-managed REIT. The
portfolio was 85% leased as of September 2018, compared to 93% at
securitization. The portfolio's net operating income (NOI) has
continued to improve since securitization. Moody's structured
credit assessment and stressed DSCR are aa2 (sca.pd) and 1.85X,
respectively, compared to aa2 (scca.pd) and 1.83X at the last
review.

The top three conduit loans represent 30.4% of the pool balance.
The largest loan is The Shoppes at Buckland Hills Loan ($115.4
million -- 15.6% of the pool), which is secured by a 535,000 square
feet (SF) component of a 1.1 million SF regional mall located in
the Buckland Hills section of Manchester, Connecticut,
approximately 10 miles north of Hartford. The mall was originally
built in 1990 and subsequently renovated and expanded in 2003. The
property's anchors include Macy's, Macy's Mens & Home and Sears,
and Dick's Sporting Goods (only Dick's is included as part of the
collateral). The property's trade area covers the northeastern
suburbs of Hartford and parts of the north-central part of
Connecticut. The property competes with a number of regional malls
and power centers, including the Westfarms Mall, a Taubman property
that is the dominant regional mall in the Hartford MSA. As of
December 2018, the collateral component of the property was 97%
leased, with inline occupancy of 97%. Despite the stable occupancy,
performance of the property has trended down since securitization,
with NOI declining approximately 14% since securitization as a
result of lower revenue. Additionally, comparative inline sales
(tenants less than 10,000 SF) at the property are down
approximately 16% over the same period. Moody's LTV and stressed
DSCR are 146% and 0.78X, respectively, compared to 133% and 0.85X
at the last review.

The second largest loan is the GPB Portfolio I Loan ($55.4 million
-- 7.5% of the pool), which is secured by an eleven property retail
portfolio located across two states: Massachusetts (10) and New
Jersey (1). The portfolio was 99% leased as of December 2018,
compared to 98% as of December 2017. The loan has amortized 11%
since securitization and Moody's LTV and stressed DSCR are 72% and
1.27X, respectively, compared to 74% and 1.25X at the last review.

The third largest loan is the 9 MetroTech Center Loan ($53.5
million -- 7.2% of the pool), which is secured by a nine-story,
single-tenant office building located in the CBD of Brooklyn, New
York. The property was built-to-suit for the New York City Fire
Department (FDNY) in 1996 and serves as the department's
headquarters and the city emergency command center. In addition to
approximately 317,000 SF of office space, the building also
contains a two-story, below-grade, 137 space parking garage. The
FDNY lease commenced in October 1997 and featured a 20-year term,
with one, 10-year extension option exercisable with 18-months
notice. The FDNY exercised this option and extended their lease
through October 2028. Moody's value incorporates a lit/dark
analysis due to the single tenant exposure. Moody's LTV and
stressed DSCR are 90% and 1.13X, respectively, compared to 88% and
1.13X at the last review.


N-STAR REL VIII: Fitch Cuts Rating on $22.5MM Class N Debt to C
---------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed 12 classes of N-Star
REL CDO VIII, Ltd./LLC.

KEY RATING DRIVERS

The affirmation of classes A-2 and B reflects sufficient credit
enhancement relative to Fitch's loss expectations. The Rating
Outlook for class B was revised to Stable from Negative to reflect
the increased CE and better than expected recoveries on asset/loan
dispositions since the last rating action. The downgrade of the
distressed class N reflects a greater certainty of loss due to high
loss expectations for the remainder of the pool relative to the
class' CE.

Fitch's base case loss expectation is 74.2%. Since the last rating
action and as of the April 2019 trustee report, the transaction
received principal paydown totaling $32.5 million from four asset
payoffs, a loan disposition and scheduled amortization. Realized
losses since the last rating action totaled $84.4 million, which
were better than previously expected. All overcollateralization and
interest coverage tests were passing.

The collateralized debt obligation is very concentrated. N-Star
VIII is collateralized by commercial real estate loans (95.4% of
pool), which are primarily subordinate debt positions, and one
commercial real estate collateralized debt obligation bond (CRE
CDO; 4.6%). The current pool consists of 10 assets, whereby 74.6%
by balance is comprised of defaulted loans (23.1%) and Fitch Loans
of Concern (FLOCs; 51.5%).

As of the April 2019 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: preferred equity
(56.7%), whole loans/A-notes (22.2%), mezzanine loans (16.5%) and
CRE CDOs (4.6%). Property type concentrations include construction
(30.5%), hotel (20.9%), healthcare (20.9%), retail (11.3%),
undeveloped land (8.3%) and multifamily (3.5%). Fitch modeled
significant to full losses on these CREL assets as the majority are
either highly leveraged, subordinate debt positions and/or
non-traditional or non-cash flowing property types with minimal to
no recoveries expected. The CRE CDO bond is rated 'CCCsf' by
Fitch.

The distressed ratings for classes C through N are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
loans and FLOCs, factoring in anticipated recoveries relative to
the CE of each class.

The largest contributor to Fitch's loss expectation is a preferred
equity position (30.5% of pool) on a planned construction project
of a super-regional mall and retail/entertainment facility located
in East Rutherford, NJ. The project's original business plan from
2006 stalled due to the economic downturn and multiple delays and
cost overruns. The overall project designs have been updated with
the selection of a new replacement developer to include a planned
amusement/water park and the originally planned
entertainment/retail center. The original loan was restructured
whereby the existing lender debt was subordinated to additional
debt from new construction financing and new equity contributions
by the selected replacement developer. Although construction
activity is progressing and leases have been executed, Fitch
remains concerned with the uncertainty and timing surrounding the
ultimate completion of the project. Fitch modeled a full loss on
this subordinate interest in its base case stress scenario.

This transaction was analyzed according to Fitch's 'U.S. CREL CDO
Surveillance Criteria', which applies stresses to property cash
flows and debt service coverage ratio tests to project future
default levels for the underlying portfolio. Recoveries are based
on stressed cash flows and Fitch's long-term capitalization rates.
Cash flow modeling was not performed as it would provide no
additional analytical value given 100% of the pool was modeled to
default in all of the rating stresses.

N-Star VIII was initially issued as a $900 million CRE CDO, with a
five-year reinvestment period that ended in February 2012. In
November 2009, $31.1 million in notes were surrendered to the
trustee for cancellation. The CRE CDO is managed by NS Advisors,
LLC, which was previously a wholly owned subsidiary of NorthStar
Realty Finance Corp. (NRF). In January 2017, NRF, along with
Northstar Asset Management, merged with Colony Capital, Inc. to
form Colony Northstar Inc.

RATING SENSITIVITIES

The Stable Rating Outlook on classes A-2 and B reflects the
increasing CE and expected continued paydowns. Future upgrades are
expected to be limited due to the increasing pool concentration and
adverse selection, but may be possible with better than expected
recoveries on the remaining assets. The distressed classes C
through N may be subject to downgrade should loan performance
decline, if realized losses exceed Fitch's expectations and/or
should further losses be 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 downgraded the following class:

  -- $22.5 million class N to 'Csf' from 'CCsf'; RE 0%.

In addition, Fitch has affirmed and revised Rating Outlooks to the
following classes as indicated:

  -- $22.3 million class A-2 at 'Bsf'; Outlook Stable;

  -- $60.3 million class B at 'Bsf'; Outlook to Stable from
Negative;

  -- $24.3 million class C at 'CCCsf'; RE 0%;

  -- $17.1 million class D at 'CCsf'; RE 0%;

  -- $22.1 million class E at 'CCsf'; RE 0%;

  -- $25.2 million class F at 'CCsf'; RE 0%;

  -- $9.1 million class G at 'CCsf'; RE 0%;

  -- $20.7 million class H at 'CCsf'; RE 0%;

  -- $12 million class J at 'CCsf'; RE 0%;

  -- $18.9 million class K at 'CCsf'; RE 0%;

  -- $22.1 million class L at 'CCsf'; RE 0%;

  -- $14.9 million class M at 'CCsf'; RE 0%;

The class A-1 and A-R notes were paid in full. Fitch does not rate
the preferred shares.


NASSAU LTD 2019-I: Moody's Gives Ba3 Rating on $28.25MM Cl. D Notes
-------------------------------------------------------------------
Moody's Investors Service has assigned ratings to five classes of
notes issued and one class of loans incurred by Nassau 2019-I Ltd.


Moody's rating action is as follows:

US$70,000,000 Class AN-A Senior Secured Floating Rate Notes due
2031 (the "Class AN-A Notes"), Assigned Aaa (sf)

US$296,875,000 Class AL Loans maturing in 2031 (the "Class AL
Loans"), Assigned Aa1 (sf)

US$13,125,000 Class AN-B Senior Secured Floating Rate Notes due
2031 (the "Class AN-B Notes"), Assigned Aa2 (sf)

US$21,750,000 Class B Senior Secured Deferrable Floating Rate Notes
due 2031 (the "Class B Notes"), Assigned A2 (sf)

US$30,000,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2031 (the "Class C Notes"), Assigned Baa3 (sf)

US$28,250,000 Class D Secured Deferrable Floating Rate Notes due
2031 (the "Class D Notes"), Assigned Ba3 (sf)

The Class AN-A Notes, the Class AL Loans, the Class AN-B Notes, the
Class B Notes, the Class C Notes and the Class D Notes are referred
to herein, collectively, as the "Rated Debt."

RATINGS RATIONALE

The rationale for the ratings is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in its methodology.

Nassau 2019-I is a managed cash flow CLO. The issued notes and
incurred loans will be collateralized primarily by broadly
syndicated senior secured corporate loans. At least 90% of the
portfolio must consist of first lien senior secured loans, cash,
and eligible investments, and up to 10% of the portfolio may
consist of second lien loans, unsecured loans and first-lien
last-out loans. The portfolio is approximately 80% ramped as of the
closing date.

NCC CLO Manager LLC will direct the selection, acquisition and
disposition of the assets on behalf of the Issuer and may engage in
trading activity, including discretionary trading, during the
transaction's four year reinvestment period. Thereafter, subject to
certain restrictions, the Manager may reinvest unscheduled
principal payments and proceeds from sales of credit risk assets.

In addition to the Rated Debt, the Issuer issued subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes and loans in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in March 2019.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount: $500,000,000

Diversity Score: 80

Weighted Average Rating Factor (WARF): 3006

Weighted Average Spread (WAS): 3.90%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.5%

Weighted Average Life (WAL): 8 years

Methodology Underlying the Rating Action:

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

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

The performance of the Rated Debt is subject to uncertainty. The
performance of the Rated Debt is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Debt.


OLYMPIC TOWER 2017-OT: Fitch Affirms BB- Rating on Class E Certs
----------------------------------------------------------------
Fitch Ratings has affirmed Olympic Tower 2017-OT Mortgage Trust
Commercial Mortgage Pass-Through Certificates (Olympic Tower
2017-OT).

KEY RATING DRIVERS

The affirmations reflect the stable performance of the collateral,
which consists of the leasehold interest in the office and retail
portions within 21 stories of a 52-story high-end mixed use
property located on Fifth Avenue in Midtown Manhattan. The property
continues to exhibit strong occupancy at 99%. Per the servicer, the
YE 2018 net cash flow (NCF) debt service coverage ratio was 1.86x
for this interest only loan.

High Quality Asset in Prime Office and Retail Location: The
property consists of approximately 410,600 rentable sf of class A
office space within the Plaza submarket and 113,600 rentable sf of
retail space along Fifth Avenue, between East 51st and East 52nd
Streets in midtown Manhattan. The property's public spaces
re-opened earlier this year after a multimillion dollar
renovation.

Strong Historical Occupancy and Long-Term Leases: Per the Sept. 30,
2018 rent roll, the property was 99% occupied; it has maintained an
average historical occupancy of over 97% since 2008. The top four
tenants, which account for 80% of the NRA, have a weighted average
remaining lease term of approximately 12 years.

Diverse and High Quality Tenant Base: The property is leased to
over 20 office and retail tenants. It serves as the headquarters
location for several of the tenants, including the NBA (36.6% of
NRA), MSD Capital (8.4% of NRA), and Richemont North America (23.8%
of NRA) and as current flagship locations for Cartier (10.5% of
NRA) and Versace USA (3.8% of NRA). The property leases space to
other luxury retailers including Furla, Longchamp, Armani Exchange,
Jimmy Choo and H. Stern.

Retail: While the subject's retail submarket has long been
considered a premier shopping district, recently, several high
profile tenants have vacated the area. To account for this current
market turnover, Fitch applied a 10% vacancy stress to the retail
base rent, which contributes approximately two-thirds of the
property's base rent. The overall average retail in place rents are
well below the appraiser's view of the market rents at issuance.

Fitch Leverage: The $760 million mortgage loan has a Fitch stressed
DSCR and loan-to-value of 1.02x and 85.9%, respectively, and debt
of $1,450 psf.

The total debt package includes mezzanine financing in the amount
of $240 million that is not included in the trust.

Experienced Sponsorship and Property Management: The sponsorship is
a joint venture between OMERS Administration Corporation and Crown
Acquisitions, Inc. Oxford Properties Group is the global real
estate investment, development and management arm of OMERS, and has
over $40 billion of assets. Oxford has a portfolio that totals
approximately 60 million sf and over 150 properties located in
Canada, Western Europe and the U.S. Crown Acquisitions ownership
interests include over 35 assets located in major markets such as
New York, London and Miami.

RATING SENSITIVITIES

The Rating Outlook for all classes remains Stable. No rating
actions are anticipated unless there are material changes in
property occupancy or cash flow. The property performance is
consistent with issuance.

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:

  -- $230,597,000 class A at 'AAAsf'; Outlook Stable;

  -- $230,597,000 interest-only class X-A at 'AAAsf'; Outlook
Stable;

  -- $35,990,000 interest only class X-B at 'AA-sf'; Outlook
Stable;

  -- $35,990,000 class B at 'AA-sf'; Outlook Stable;

  -- $28,821,000 class C at 'A-sf'; Outlook Stable;

  -- $56,092,000 class D at 'BBB-sf'; Outlook Stable;

  -- $104,500,000 class E at 'BB-sf'; Outlook Stable.

Fitch does not rate the VRR Interest.


PARK AVENUE 2019-1: S&P Assigns BB- (sf) Rating to Class D Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Park Avenue
Institutional Advisers CLO Ltd. 2019-1/Park Avenue Institutional
Advisers CLO LLC 2019-1's fixed- and floating-rate notes.

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

The ratings reflect:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  Park Avenue Institutional Advisers CLO Ltd. 2019-1/Park Avenue  

  Institutional Advisers CLO LLC 2019-1

  Class                Rating       Amount (mil. $)
  A-1                  AAA (sf)              247.00
  A-2A                 AA (sf)                37.00
  A-2B                 AA (sf)                20.00
  B (deferrable)       A (sf)                 24.00
  C (deferrable)       BBB- (sf)              22.50
  D (deferrable)       BB- (sf)               15.50
  Subordinated notes   NR                     32.65

  NR--Not rated.


PARK AVENUE 2019-1: S&P Assigns Prelim BB-(sf) Rating to D Notes
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Park Avenue
Institutional Advisers CLO Ltd. 2019-1/Park Avenue Institutional
Advisers CLO LLC 2019-1's fixed- and floating-rate notes.

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

The preliminary ratings are based on information as of May 3, 2019.
Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The diversified collateral pool;

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Park Avenue Institutional Advisers CLO Ltd. 2019-1/Park Avenue  

  Institutional Advisers CLO LLC 2019-1

  Class                Rating       Amount (mil. $)
  A-1                  AAA (sf)              247.00
  A2-A                 AA (sf)                37.00
  A2-B                 AA (sf)                20.00
  B (deferrable)       A (sf)                 24.00
  C (deferrable)       BBB- (sf)              22.50
  D (deferrable)       BB- (sf)               15.50
  Subordinated notes   NR                     32.65

  NR--Not rated.


RALI TRUST 2006-QO9: Moody's Cuts Class AXP Debt Rating to 'C'
--------------------------------------------------------------
Moody's Investors Service has downgraded the rating of Class AXP
from RALI Series 2006-QO9 Trust and the rating of Class M-2 from
Securitized Asset Backed Receivables LLC Trust 2005-OP2, backed by
option ARM loans and subprime loans respectively.

The complete rating actions are as follows:

Issuer: RALI Series 2006-QO9 Trust

  Cl. AXP*, Downgraded to C (sf); previously on Feb 13, 2019
  Upgraded to Ca (sf)

Issuer: Securitized Asset Backed Receivables LLC Trust 2005-OP2

  Cl. M-2, Downgraded to B1 (sf); previously on Apr 20, 2016
  Upgraded to Ba3 (sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

The rating downgrade of Class AXP from RALI Series 2006-QO9 Trust
is primarily due to the correction of a data input error in the
prior analysis. Class AXP is an interest-only (IO) bond that
references multiple bonds. The rating on an IO bond referencing
multiple bonds is the weighted average of the current ratings of
its referenced bonds based on their current balances which are
grossed up, if any, by their realized losses. The prior analysis
was based on incorrect balances for some of the bonds referenced by
this multi-bond IO.

The rating downgrade of Class M-2 from Securitized Asset Backed
Receivables LLC Trust 2005-OP2 is due to the outstanding interest
shortfalls on the bond which are not expected to be recouped. As of
the distribution date in March 2019, Class M-2 has a total Unpaid
Interest Amount of $31,753.

The actions also reflect the recent performance as well as Moody's
updated losses expectations on the underlying pools.

The principal methodology used in rating all deals except
interest-only classes was "US RMBS Surveillance Methodology"
published in February 2019. The methodologies used in rating
interest-only classes were "US RMBS Surveillance Methodology"
published in February 2019 and "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2019.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in April 2019 from 3.9% in April
2018. 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.

An IO bond may be upgraded or downgraded, within the constraints
and provisions of the IO methodology, based on lower or higher
realized and expected loss due to an overall improvement or decline
in the credit quality of the referenced bonds and/or pools.

Finally, the performance of RMBS continues to remain highly
dependent on servicer procedures. Any changes resulting from
servicing transfers, or other policy or regulatory shifts can
impact the performance of these transactions.


REGATTA II FUNDING: S&P Assigns Prelim BB- Rating to D-R2 Notes
---------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1-R2, A-2-R2, B-R2, C-R2, and D-R2 replacement notes from Regatta
II Funding L.P., a collateralized loan obligation (CLO) that
originally closed in February 2013, was subsequently refinanced in
December 2016, and is managed by Napier Park Global Capital (US)
LP. The replacement notes will be issued via a proposed
supplemental indenture.

The preliminary ratings are based on information as of May 6, 2019,
and reflect S&P's opinion that the credit support available is
commensurate with the associated rating level. Subsequent
information may result in the assignment of final ratings that
differ from the preliminary ratings.

On the May 15, 2019, refinancing date, the proceeds from the
issuance of the replacement notes are expected to redeem the class
A-1-R, A-2-R, B-R, C-R, and D-R notes. At that time, S&P
anticipates withdrawing the ratings on the refinanced notes and
assigning ratings to the new replacement notes. S&P said, however,
that if the refinancing doesn't occur, it may affirm the ratings on
the refinanced notes and withdraw its preliminary ratings on the
replacement notes.

The replacement notes are being issued via a proposed supplemental
indenture, which, in addition to outlining the terms of the
replacement notes, will also issue the replacement notes at lower
spreads than the original class A-1-R, A-2-R, B-R, C-R, and D-R
notes.

Along with outlining the terms of the replacement notes, the
supplemental indenture will extend the weighted average life test.
Additionally, the non-call period for the transaction will be
re-established to end in March 2020. The transaction is currently
in its reinvestment period, which is expected to end in January
2021. The replacement notes will have the same stated maturity as
the original notes, which is expected to be January 2029.

  REPLACEMENT AND ORIGINAL NOTE ISSUANCES

  Replacement notes
  Class                Amount        Interest
                     (mil. $)        rate (%)
  A-1-R2              261.00     LIBOR + 1.25
  A-2-R2               46.70     LIBOR + 1.85
  B-R2                 28.00     LIBOR + 2.70
  C-R2                 20.00     LIBOR + 3.70
  D-R2                 17.50     LIBOR + 6.95

  Original notes
  Class               Amount        Interest
                  (mil. $)        rate (%)
  A-1-R              261.00     LIBOR + 1.54
  A-2-R               46.70     LIBOR + 2.15
  B-R                 28.00     LIBOR + 2.90
  C-R                 20.00     LIBOR + 4.30
  D-R                 17.50     LIBOR + 7.59

On a standalone basis, the results of the cash flow analysis
indicated a lower rating on the class D-R2 notes than its assigned
preliminary rating level. However, S&P expects the transaction to
benefit from the drop in the weighted average cost of debt as a
result of this refinance. Since the time of S&P's last rating
actions on the transaction, the O/C levels have remained stable
with cushions above their respective triggers. As the transaction
enters its amortization period following the end of its
reinvestment period, the transaction may begin to pay down the
rated notes sequentially, which, all else remaining equal, will
begin to increase the overcollateralization levels. In addition,
because the transaction currently has minimal exposure to 'CCC' and
'D' rated collateral obligations and no exposure to long-dated
assets (i.e., assets maturing after the CLO's stated maturity), S&P
believes it is not currently exposed to large risks that would
impair the assigned preliminary rating on the class D-R2 notes.

S&P's review of this transaction included a cash flow analysis,
based on the portfolio and transaction as reflected in the trustee
report, to estimate future performance. In line with its criteria,
S&P's 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, S&P's analysis considered the transaction's ability to
pay timely interest or ultimate principal, or both, to each of the
rated tranches. The results of the cash flow analysis -- and other
qualitative factors as applicable -- demonstrated, in S&P's 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 rating actions as we
deem necessary," S&P said.

  PRELIMINARY RATINGS ASSIGNED
  Regatta II Funding L.P.

  Replacement class         Rating     Amount (mil. $)
  A-1-R2                    AAA (sf)            261.00
  A-2-R2                    AA (sf)              46.70
  B-R2                      A (sf)               28.00
  C-R2                      BBB (sf)             20.00
  D-R2                      BB- (sf)             17.50
  NR--Not rated.


RESIDENTIAL REINSURANCE 2019-I: S&P Rates Class 13 Notes 'B-(sf)'
-----------------------------------------------------------------
S&P Global Ratings said it has assigned a rating of 'B-(sf)' to the
$75,000,000 Series 2019-I Class 13 notes to be issued by
Residential Reinsurance 2019 Ltd. (Res Re 2019) due June 6, 2023.
The notes cover losses in all 50 states and the District of
Columbia from tropical cyclone, earthquake (including fire
following), severe thunderstorm, winter storm, wildfire, volcanic
eruption, meteorite impact, and other perils (including, in each
case, flood losses arising from automobile policies and renters'
policies) on an annual aggregate basis.

The ratings are based on the lowest of the natural-catastrophe
(nat-cat) risk factor ('b-'), the rating on the assets in the
Regulation 114 trust account ('AAAm'), and the rating on the ceding
insurer (various operating affiliates/subsidiaries of USAA, all
currently rated AA+/Stable/--).

The base-case one-year probability of attachment, expected loss,
and probability of exhaustion are 2.06%, 0.98%, and 0.44%,
respectively. Using the warm sea surface temperature results, these
percentages are 2.45%, 1.16%, and 0.52%, respectively.
Additionally, this issuance has a variable reset. Beginning with
the initial reset in June 2020, the attachment probability and
expected loss can be reset to maximums of 2.56% and 1.23%,
respectively. This maximum attachment probability using the warm
sea surface temperature results, was used as the baseline to
determine the nat-cat risk factor for the remaining risk periods.

Based on AIR's analysis, on a historical basis, there have not been
any years when the modeled losses exceeded the initial attachment
level of the notes.


SDART 2019-2: Fitch to Rate $99.1MM Class E Notes 'BBsf'
--------------------------------------------------------
Fitch Ratings expects to assign the following ratings to the notes
issued by Santander Drive Auto Receivables Trust (SDART) 2019-2:

  -- $165,300,000 class A-1 'F1+sf';

  -- $130,000,000 class A-2a 'AAAsf'; Outlook Stable;

  -- $130,000,000 class A-2b 'AAAsf'; Outlook Stable;

  -- $143,790,000 class A-3 'AAAsf'; Outlook Stable;

  -- $128,280,000 class B 'AAsf'; Outlook Stable;

  -- $160,930,000 class C 'Asf'; Outlook Stable;

  -- $144,610,000 class D 'BBBsf'; Outlook Stable;

  -- $99,120,000 class E 'BBsf'; Outlook Stable.

KEY RATING DRIVERS

Collateral -- Stable Credit Quality: 2019-2 is backed by collateral
that is generally consistent with 2017-2018 pools, with a weighted
average FICO score of 600, down from 615 in 2019-1, and internal WA
loss forecast score of 550. WA seasoning is two months and the pool
is geographically diverse. New vehicles total 41% of the pool, down
from 48.6% in 2019-1. While the transaction's percentage of
extended-term loans remains elevated at 93.4%,
greater-than-72-month term loans total 16.5%, down from recent
transactions.

Forward-Looking Approach to Derive Base Case Loss Proxy: Fitch
considered economic conditions and future expectations by assessing
key macroeconomic and wholesale market conditions when deriving the
series loss proxy. Consistent with recent transactions, an
additional stress was applied to 75-month loans in deriving the
loss proxy as performance for these contracts has been volatile.
Although within range of 2010-2012 performance, SC's 2013-2017
losses are tracking higher but ABS performance remains within
Fitch's initial expectations, consistently exhibiting stronger
performance than that of the managed portfolio. Fitch arrived at a
forward-looking credit loss expectation of 17.00%.

Payment Structure -- Sufficient Credit Enhancement: Initial hard
credit enhancement (CE) totals 52.2%, 41.2%, 27.4%, 15.0% and 6.5%
for classes A, B, C, D and E, respectively. Hard CE is lower by
0.55% for the class A notes, and also lower for the subordinate
notes compared with 2019-1. Excess spread is expected to be 9.79%
per annum. Initial CE is sufficient to withstand Fitch's base case
CNL proxy for all classes of notes at each class's respective loss
coverage multiple.

Seller/Servicer Operational Review - Consistent
Origination/Underwriting/Servicing: Santander Consumer USA Inc.
(SC) demonstrates adequate abilities as originator, underwriter and
servicer, as evidenced by historical portfolio and securitization
performance. Fitch rates SC's ultimate parent Banco Santander, S.A.
'A-'/'F2'/Stable Outlook. Fitch deems SC capable to service this
transaction.

Legal Structure Integrity: The legal structure of the transaction
should provide that a bankruptcy of SC would not impair the
timeliness of payments on the securities.

RATING SENSITIVITIES

Unanticipated increases in the frequency of defaults and loss
severity on defaulted receivables could produce loss levels higher
than the base case. This in turn could result in Fitch taking
negative rating actions on the notes.

Fitch evaluated the sensitivity of the ratings assigned to 2019-2
to increased credit losses over the life of the transaction.
Fitch's analysis found that the transaction displays some
sensitivity to increased defaults and credit losses. This analysis
exhibited a potential downgrade of one or two categories under
Fitch's moderate (1.5x base case loss) scenario, and potentially
distressed ratings or defaults for the class E bonds. The notes
could experience downgrades of three or more rating categories,
potentially leading to distressed ratings (below Bsf) or possibly
default, under Fitch's severe (2x base case loss) scenario.


SLM PRIVATE 2003-A: Fitch Affirms BB+ Rating on Class B Debt
------------------------------------------------------------
Fitch Ratings has affirmed 54 tranches from 12 SLM Private Credit
Student Loan Trust transactions, two SLM Private Education Loan
Trust transactions and two Navient Private Education Loan Trust
transactions. The affirmations include SLM 2006-B's class A-5W
notes, which are a portion of the A-5 notes receiving interest and
principal payments pro rata with the A-5 notes.

The affirmations reflect the current transactions' portfolio
performance that, despite some recent deterioration for younger
deals, remains within Fitch's expectations, and sufficient credit
enhancement at each bond's corresponding rating level.

In line with Fitch's "U.S. Private Student Loan ABS Rating
Criteria," (Fitch's PSL Criteria) SLM PE 2013-B and SLM PE 2013-C
were not modeled for this review, as all bonds are at the highest
level of 'AAAsf, none of the variables affecting transaction
performance has changed beyond that expected as of last review, and
CE levels have increased since last review.

Fitch has affirmed the ratings as follows:

SLM 2002-A

  -- Class A-2 at 'AAAsf'; Outlook Stable.

SLM 2003-A

  -- Class A-3 at 'A-sf'; Outlook Stable;

  -- Class A-4 at 'A-sf'; Outlook Stable;

  -- Class B at 'BB+sf'; Outlook Stable;

  -- Class C at 'CCsf'; Recovery Estimate (RE) at 50%.

SLM 2003-B

  -- Class A-3 at 'A-sf'; Outlook Stable;

  -- Class A-4 at 'A-sf'; Outlook Stable;

  -- Class B at 'BBsf'; Outlook Stable;

  -- Class C at 'CCsf'; RE at 50%.

SLM 2003-C

  -- Class A-3 at 'A-sf'; Outlook Stable;

  -- Class A-4 at 'A-sf'; Outlook Stable;

  -- Class A-5 at 'A-sf'; Outlook Stable;

  -- Class B at 'BBsf'; Outlook Stable;

  -- Class C at 'CCsf'; RE at 50%.

SLM 2004-A

  -- Class A-3 at 'AAsf'; Outlook Stable;

  -- Class B at 'Asf'; Outlook Stable.

SLM 2004-B

  -- Class A-3 at 'AAAsf'; Outlook Stable;

  -- Class A-4 at 'AAsf'; Outlook Stable;

  -- Class B at 'Asf'; Outlook Stable;

  -- Class C at 'BBBsf'; Outlook Stable.

SLM 2005-A

  -- Class A-3 at 'AAAsf'; Outlook Stable;

  -- Class A-4 at 'A+sf'; Outlook Stable;

  -- Class B at 'A-sf'; Outlook Stable;

  -- Class C at 'BBBsf'; Outlook Stable.

SLM 2005-B

  -- Class A-4 at 'A+sf'; Outlook Stable;

  -- Class B at 'A-sf'; Outlook Stable;

  -- Class C at 'BBBsf'; Outlook Stable.

SLM 2006-A

  -- Class A-5 at 'A+sf'; Outlook Stable;

  -- Class B at 'Asf'; Outlook Stable;

  -- Class C at 'BBBsf'; Outlook Stable.

SLM 2006-B

  -- Class A-5 at 'Asf'; Outlook Stable;

  -- Class A-5W at 'Asf'; Outlook Stable;

  -- Class B at 'BBB+sf'; Outlook Stable;

  -- Class C at 'BBB-sf'; Outlook Stable.
    
SLM 2006-C

  -- Class A-5 at 'AA-sf'; Outlook Stable;

  -- Class B at 'Asf'; Outlook Stable;

  -- Class C at 'BBB-sf'; Outlook Stable.

SLM 2007-A

  -- Class A-4 at 'A-sf'; Outlook Stable;

  -- Class B at 'BBBsf'; Outlook Stable;

  -- Class C-1 at 'BB+sf'; Outlook Stable;

  -- Class C-2 at 'BB+sf'; Outlook Stable.

SLM PE 2013-B

  -- Class A-2A at 'AAAsf'; Outlook Stable;

  -- Class A-2B at 'AAAsf'; Outlook Stable;

  -- Class B at 'AAAsf'; Outlook Stable.

SLM PE 2013-C

  -- Class A-2A at 'AAAsf'; Outlook Stable;

  -- Class A-2B at 'AAAsf'; Outlook Stable;

  -- Class B at 'AAAsf'; Outlook Stable.

Navient PE 2015-A

  -- Class A-2A at 'AAAsf'; Outlook Stable;

  -- Class A-2B at 'AAAsf'; Outlook Stable;

  -- Class A-3 at 'AAAsf'; Outlook Stable;

  -- Class B at 'AAsf'; Outlook Stable.

Navient PE 2016-A

  -- Class A-2A at 'AAAsf'; Outlook Stable;

  -- Class A-2B at 'AAAsf'; Outlook Stable;

  -- Class B at 'AAsf'; Outlook Stable.

Key Rating Drivers

Collateral Performance: All trusts are collateralized by private
student loans, originated by SLM Corp. (BB+/Stable/B) and Navient
Corp. (BB/Stable/B). Loans in the SLM trusts were originated under
the Signature Education Loan Program, LAWLOANS program, MBA Loans
program, and MEDLOANS program. SLM 2007-A, SLM PE trusts and
Navient PE trusts also included loans originated under the Direct
to Consumer and Private Credit Consolidation programs. SLM PE and
Navient PE also comprise Navient's Smart Option program, launched
in 2009.

For transactions modelled for this surveillance review, Fitch's
remaining default projections are as follows:

SLM 2002-A: 5.0%

SLM 2003-A: 7.3%

SLM 2003-B: 7.4%

SLM 2003-C: 7.4%

SLM 2004-A: 7.3%

SLM 2004-B: 7.5%

SLM 2005-A: 9.3%

SLM 2005-B: 9.4%

SLM 2006-A: 9.9%

SLM 2006-B: 11.1%

SLM 2006-C: 11.1%

SLM 2007-A: 12.3%

Navient 2015-A: 13.6%

Navient 2016-A: 13.4%

The recovery assumption is 18.0% for all transactions, unchanged
from previous surveillance reviews.

For SLM 2002-A, SLM 2003-A, SLM 2003-B, SLM 2003-C, SLM 2004-A, SLM
2004-B, SLM 2005-A, and SLM 2005-B, Fitch applied a low default
stress multiple in the multiple range envisaged by Fitch's PSL
Criteria, resulting in a 3.5x multiple at 'AAAsf'. For SLM 2006-A,
SLM 2006-B, SLM 2006-C, 2007-A, Navient 2015-A, and Navient 2016-A,
Fitch applied a medium/low default stress multiple of 3.75x
multiple at 'AAAsf'. The assumed multiples are unchanged from
previous surveillance reviews.

Payment Structure: For all transactions, available CE is sufficient
to provide loss coverage in line with the assigned rating category.
CE is provided by a combination of overcollateralization (OC; the
excess of the trust's asset balance over the bond balance), excess
spread, and subordination of more junior notes. As reflected in the
assigned ratings, the class C notes for SLM 2003-A, 2003-B and
2003-C are currently under collateralized. SLM 2004-A's OC is
slightly below the target OC floor as of last payment date, with
parity still increasing over recent periods. All other deals are at
or above their OC floor level.

Operational Capabilities: Navient Solutions LLC is the servicer for
all the loans in the trusts. Fitch has reviewed the servicing
operations of Navient and considers it to be an effective private
student loan servicer.

Variations from Criteria

For this surveillance review, the rating assigned to SLM 2004-B's
class C notes is four notches below the model-implied rating,
constituting a variation to the 'U.S. Private Student Loan ABS
Rating Criteria'. The rating action takes into account a recent
uptick in defaults and the subordinated position of the Class C
notes in the priority of payments.

RATING SENSITIVITIES

Rating sensitivities provide greater insight into the model-implied
sensitivities the transaction faces when one or two risk factors
are stressed while holding others equal. The modeling process first
uses the estimation and stress of base-case default and recovery
assumptions to reflect asset performance in a stressed environment.
Second, structural protection was analyzed with Fitch's GALA Model.
The results should only be considered as one potential outcome, as
the transaction is exposed to multiple risk factors that are all
dynamic variables.

Please note that tranches rated 'CCCsf' or below are not included
in these sensitivities.

SLM 2002-A

Expected impact on the note rating of increased defaults (class
A-2):

Current Ratings: 'AAAsf'

Increase base case defaults by 10%: 'AAAsf';

Increase base case defaults by 25%: 'AAAsf';

Increase base case defaults by 50%: 'AA+sf'.

Expected impact on the note rating of reduced recoveries (class
A-2):

Current Ratings: 'AAAsf'

Reduce base case recoveries by 10%: 'AAAsf';

Reduce base case recoveries by 20%: 'AAAsf';

Reduce base case recoveries by 30%: 'AAAsf'.

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-2):

Current Ratings: 'AAAsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'AAAsf';

Increase base case defaults and reduce base case recoveries each by
25%: 'AAAsf';

Increase base case defaults and reduce base case recoveries each by
50%: 'AA+sf'.

SLM 2003-A

Expected impact on the note rating of increased defaults (class
A-3/A-4/B):

Current Ratings: 'A-sf'/'A-sf'/'BB+sf'

Increase base case defaults by 10%: 'BBB+sf'/'BBB+sf'/'BB+sf';

Increase base case defaults by 25%: 'BBBsf'/'BBBsf'/'BB+sf';

Increase base case defaults by 50%: 'BBB-sf'/'BBB-sf'/'BBsf'.

Expected impact on the note rating of reduced recoveries (class
A-3/A-4/B):

Current Ratings: 'A-sf'/'A-sf'/'BB+sf'

Reduce base case recoveries by 10%: 'A-sf'/'A-sf'/'BB+sf';

Reduce base case recoveries by 20%: 'A-sf'/'A-sf'/'BB+sf';

Reduce base case recoveries by 30%: 'A-sf'/'A-sf'/'BB+sf'.

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-3/A-4/B):

Current Ratings: 'A-sf'/'A-sf'/'BB+sf'

Increase base case defaults and reduce base case recoveries each by
10%: 'BBB+sf'/'BBB+sf'/'BB+sf';

Increase base case defaults and reduce base case recoveries each by
25%: 'BBBsf'/'BBBsf'/'BB+sf';

Increase base case defaults and reduce base case recoveries each by
50%: 'BB+sf'/'BB+sf'/'BB-sf'.

SLM 2003-B

Expected impact on the note rating of increased defaults (class
A-3/A-4/B):

Current Ratings: 'A-sf'/'A-sf'/'BBsf'

Increase base case defaults by 10%: 'BBBsf'/'BBBsf'/'BBsf'

Increase base case defaults by 25%: 'BBB-sf'/'BBB-sf'/'BBsf'

Increase base case defaults by 50%: 'BBsf'/'BBsf'/'CCCsf'.

Expected impact on the note rating of reduced recoveries (class
A-3/A-4/B):

Current Ratings: 'A-sf'/'A-sf'/'BBsf'

Reduce base case recoveries by 10%: 'BBB+sf'/'BBB+sf'/'BBsf'

Reduce base case recoveries by 20%: 'BBB+sf'/'BBB+sf'/'BBsf'

Reduce base case recoveries by 30%: 'BBBsf'/'BBBsf'/'BBsf'.

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-3/A-4/B):

Current Ratings: 'A-sf'/'A-sf'/'BBsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'BBBsf'/'BBBsf'/'BBsf'

Increase base case defaults and reduce base case recoveries each by
25%: 'BB+sf'/'BB+sf'/'BB-sf'

Increase base case defaults and reduce base case recoveries each by
50%: 'B+sf'/'B+sf'/'CCCsf'.

SLM 2003-C

Expected impact on the note rating of increased defaults (class
A-3/A-4/A-5/B):

Current Ratings: 'A-sf'/'A-sf'/'A-sf'/'BBsf'

Increase base case defaults by 10%:

'BBBsf'/'BBBsf'/'BBBsf'/'BBsf';

Increase base case defaults by 25%:

'BBB-sf'/'BBB-sf'/'BBB-sf'/'BB-sf';

Increase base case defaults by 50%:

'BBsf'/'BBsf'/'BBsf'/'CCCsf'.

Expected impact on the note rating of reduced recoveries (class
A-3/A-4/A-5/B):

Current Ratings: 'A-sf'/'A-sf'/'A-sf'/'BBsf'

Reduce base case recoveries by 10%:

'BBB+sf'/'BBB+sf'/'BBB+sf'/'BBsf';

Reduce base case recoveries by 20%:

'BBBsf'/'BBBsf'/'BBBsf'/'BBsf';

Reduce base case recoveries by 30%: 'BBBsf'/'BBBsf'/'BBBsf'/'BBsf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-3/A-4/A-5/B):

Current Ratings: 'A-sf'/'A-sf'/'A-sf'/'BBsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'BBBsf'/'BBBsf'/'BBBsf'/'BBsf';

Increase base case defaults and reduce base case recoveries each by
25%: 'BB+sf'/'BB+sf'/'BB+sf'/'B+sf';

Increase base case defaults and reduce base case recoveries each by
50%: 'B+sf'/'B+sf'/'B+sf'/'CCCsf'.

SLM 2004-A

Expected impact on the note rating of increased defaults (class
A-3/B):

Current Ratings: 'AAsf/'Asf'

Increase base case defaults by 10%: 'AA-sf'/'Asf';

Increase base case defaults by 25%: 'A+sf'/'A-sf';

Increase base case defaults by 50%: 'A-sf'/'BBB+sf'.

Expected impact on the note rating of reduced recoveries (class
A-3/B):

Current Ratings: 'AAsf/'Asf'

Reduce base case recoveries by 10%: 'AAsf'/'Asf';

Reduce base case recoveries by 20%: 'AAsf'/'Asf';

Reduce base case recoveries by 30%: 'AAsf'/'Asf'.

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-3/B):

Current Ratings: 'AAsf/'Asf'

Increase base case defaults and reduce base case recoveries each by
10%: 'AA-sf'/'Asf';

Increase base case defaults and reduce base case recoveries each by
25%: 'A+sf'/'A-sf';

Increase base case defaults and reduce base case recoveries each by
50%: 'A-sf'/'BBBsf'.

SLM 2004-B

Expected impact on the note rating of increased defaults (class
A-3/A-4/B/C):

Current Ratings: 'AAAsf'/'AAsf'/'Asf'/'BBB

Increase base case defaults by 10%: 'AAAsf'/'AA-sf'/'Asf'/'BBBsf';

Increase base case defaults by 25%:

'AAAsf'/'A+sf'/'A-sf'/'BBBsf';

Increase base case defaults by 50%:

'AAAsf'/'Asf'/'BBBsf'/'BBB-sf'.

Expected impact on the note rating of reduced recoveries (class
A-3/A-4/B/C):

Current Ratings: 'AAAsf'/'AAsf'/'Asf'/'BBBsf'

Reduce base case recoveries by 10%: 'AAAsf'/'AAsf'/'Asf'/'BBBsf';

Reduce base case recoveries by 20%:'AAAsf'/'AAsf'/'Asf'/'BBBsf';

Reduce base case recoveries by 30%:'AAAsf'/'AAsf'/'Asf'/'BBBsf'.

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-3/A-4/B/C):

Current Ratings: 'AAAsf'/'AAsf'/'Asf'/'BBBsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'AAAsf'/'AA-sf'/'Asf'/'BBBsf';

Increase base case defaults and reduce base case recoveries each by
25%: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf';

Increase base case defaults and reduce base case recoveries each by
50%: 'AAAsf'/'A-sf'/'BBBsf'/'BBB-sf'.

SLM 2005-A

Expected impact on the note rating of increased defaults (class
A-3/A-4/B/C):

Current Ratings: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults by 10%: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults by 25%: 'AAAsf'/'Asf'/'BBB+sf'/'BBBsf'

Increase base case defaults by 50%:
'AAAsf'/'BBB+sf'/'BBB-sf'/'BB+sf'

Expected impact on the note rating of reduced recoveries (class
A-3/A-4/B/C):

Current Ratings: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf'

Reduce base case recoveries by 10%: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf'

Reduce base case recoveries by 20%: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf'

Reduce base case recoveries by 30%: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-3/A-4/B/C):

Current Ratings: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'AAAsf'/'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults and reduce base case recoveries each by
25%: 'AAAsf'/'Asf'/'BBBsf'/'BBBsf

Increase base case defaults and reduce base case recoveries each by
50%: 'AAAsf'/'BBBsf'/'BB+sf'/'BBsf

SLM 2005-B

Expected impact on the note rating of increased defaults (class
A-4/B/C):

Current Ratings: 'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults by 10%: 'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults by 25%: 'Asf'/'BBB+sf'/'BBBsf'

Increase base case defaults by 50%: 'BBB+sf'/'BBB-sf'/'BB+sf'

Expected impact on the note rating of reduced recoveries
(A-4/B/C):

Current Ratings: 'A+sf'/'A-sf'/'BBBsf'

Reduce base case recoveries by 10%: 'A+sf'/'A-sf'/'BBBsf'

Reduce base case recoveries by 20%: 'A+sf'/'A-sf'/'BBBsf'

Reduce base case recoveries by 30%: 'A+sf'/'A-sf'/'BBBsf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-4/B/C):

Current Ratings:'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults and reduce base case recoveries each by
25%: 'A-sf'/'BBBsf'/'BBB-sf'

Increase base case defaults and reduce base case recoveries each by
50%: 'BBBsf'/'BB+sf'/'BBsf'

SLM 2006-A

Expected impact on the note rating of increased defaults (class
A-5/B/C):

Current Ratings: 'A+sf'/'Asf'/'BBBsf'

Increase base case defaults by 10%: 'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults by 25%: 'Asf'/'BBB+sf'/'BBB-sf'

Increase base case defaults by 50%: 'BBB+sf'/'BBB-sf'/'BBsf'

Expected impact on the note rating of reduced recoveries (class
A-5/B/C):

Current Ratings: 'A+sf'/'Asf'/'BBBsf'

Reduce base case recoveries by 10%: 'A+sf'/'Asf'/'BBBsf'

Reduce base case recoveries by 20%: 'A+sf'/'Asf'/'BBBsf'

Reduce base case recoveries by 30%: 'A+sf'/'Asf'/'BBBsf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-5/B/C):

Current Ratings: 'A+sf'/'A-sf'/'BBBsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'Asf'/'A-sf'/'BBBsf'

Increase base case defaults and reduce base case recoveries each by
25%: 'A-sf'/'BBBsf'/'BBB-sf'

Increase base case defaults and reduce base case recoveries each by
50%: 'BBBsf'/'BB+sf'/'BBsf'

SLM 2006-B

Expected impact on the note rating of increased defaults (class
A-5/A-5W/B/C):

Current Ratings: 'Asf'/'Asf'/'BBB+sf'/'BBB-sf'

Increase base case defaults by 10%: 'Asf'/'Asf'/'BBB+sf'/'BBB-sf'

Increase base case defaults by 25%:
'BBB+sf'/'BBB+sf'/'BBBsf'/'BB+sf'

Increase base case defaults by 50%:
'BBBsf'/'BBBsf'/'BB+sf'/'BB-sf'

Expected impact on the note rating of reduced recoveries (class
A-5/A-5W/B/C):

Current Ratings: 'Asf'/'Asf'/'BBB+sf'/'BBB-sf'

Reduce base case recoveries by 10%: 'Asf'/'Asf'/'BBB+sf'/'BBB-sf'

Reduce base case recoveries by 20%: 'Asf'/'Asf'/'BBB+sf'/'BBB-sf'

Reduce base case recoveries by 30%: 'Asf'/'Asf'/'BBB+sf'/'BBB-sf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-5/A-5W/B/C):

Current Ratings: 'Asf'/'Asf'/'BBB+sf'/'BBB-sf'

Increase base case defaults and reduce base case recoveries each by
10%: 'Asf'/'Asf'/'BBB+sf'/'BBB-sf'

Increase base case defaults and reduce base case recoveries each by
25%: 'BBB+sf'/'BBB+sf'/'BBB-sf'/'BB+sf'

Increase base case defaults and reduce base case recoveries each by
50%: 'BBB-sf'/'BBB-sf'/'BBsf'/'B+sf'

SLM 2006-C

Expected impact on the note rating of increased defaults (class
A-5/B/C):

Current Ratings: 'AA-sf/'Asf'/'BBB-sf'

Increase base case defaults by 10%: 'AA-sf'/'Asf'/'BBB-sf'

Increase base case defaults by 25%: 'AA-sf'/'Asf'/'BBB-sf'

Increase base case defaults by 50%: 'Asf'/'BBB+sf'/'BBsf'.

Expected impact on the note rating of reduced recoveries (class
A-5/B/C):

Current Ratings: 'AA-sf/'Asf'/'BBB-sf'

Reduce base case recoveries by 10%: 'AA-sf'/'Asf'/'BBB-sf'

Reduce base case recoveries by 20%: 'AA-sf'/'Asf'/'BBB-sf'

Reduce base case recoveries by 30%: 'AA-sf'/'Asf'/'BBB-sf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-5/B/C):

Current Ratings: 'AA-sf/'Asf'/'BBB-sf'

Increase base case defaults and reduce base case recoveries each by
10%: 'AA-sf'/'Asf'/'BBB-sf'

Increase base case defaults and reduce base case recoveries each by
25%: 'AA-sf'/'Asf'/'BB+sf

Increase base case defaults and reduce base case recoveries each by
50%: 'Asf'/'BBBsf'/'B+sf'

SLM 2007-A

Expected impact on the note rating of increased defaults (class
A-4/B/C-1/C-2):

Current Ratings: 'A-sf'/'BBBsf'/'BB+sf'/'BB+sf'

Increase base case defaults by 10%:'A-sf'/'BBBsf'/'BB+sf'/'BB+sf'

Increase base case defaults by 25%:'A-sf'/'BBBsf'/'BBsf'/'BBsf'

Increase base case defaults by 50%:'BBBsf'/'BB+sf'/'Bsf'/'Bsf'

Expected impact on the note rating of reduced recoveries (class
A-4/B/C-1/C-2):

Current Ratings: 'A-sf'/'BBBsf'/'BB+sf'/'BB+sf'

Reduce base case recoveries by 10%:'A-sf'/'BBBsf'/'BB+sf'/'BB+sf'

Reduce base case recoveries by 20%:'A-sf'/'BBBsf'/'BB+sf'/'BB+sf'

Reduce base case recoveries by 30%:'A-sf'/'BBBsf'/'BB+sf'/'BB+sf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-4/B/C-1/C-2):

Current Ratings: 'A-sf'/'BBBsf'/'BB+sf'/'BB+sf'

Increase base case defaults and reduce base case recoveries each by
10%: 'A-sf'/'BBBsf'/'BB+sf'/'BB+sf'

Increase base case defaults and reduce base case recoveries each by
25%: 'BBB+sf'/'BBBsf'/'BBsf'/'BBsf'

Increase base case defaults and reduce base case recoveries each by
50%: 'BBB-sf'/'BBsf'/'CCCsf'/'CCCsf'

Navient 2015-A

Expected impact on the note rating of increased defaults (class
A-2A/A-2B/A-3/B):

Current Ratings: 'AAAsf'/'AAAsf'/'AAAsf'/'AAsf'

Increase base case defaults by 10%: 'AAAsf'/'AAAsf'/'AAsf'/'Asf'

Increase base case defaults by 25%: 'AA+sf'/'AA+sf'/'AA-sf'/'A-sf'

Increase base case defaults by 50%: 'AA-sf'/'AA-sf'/'Asf'/'BBBsf'

Expected impact on the note rating of reduced recoveries (class
A-2A/A-2B/A-3/B):

Current Ratings: 'AAAsf'/'AAAsf'/'AAAsf'/'AAsf'

Reduce base case recoveries by 10%:'AAAsf'/'AAAsf'/'AA+sf'/'A+sf'

Reduce base case recoveries by 20%:'AAAsf'/'AAAsf'/'AA+sf'/'A+sf'

Reduce base case recoveries by 30%:'AAAsf'/'AAAsf'/'AA+sf'/'A+sf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-2A/A-2B/A-3/B):

Current Ratings: 'AAAsf'/'AAAsf'/'AAAsf'/'AAsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'AAAsf'/'AAAsf'/'AAsf'/'Asf'

Increase base case defaults and reduce base case recoveries each by
25%: 'AA+sf'/'AA+sf'/'A+sf'/'A-sf'

Increase base case defaults and reduce base case recoveries each by
50%: 'A+sf'/'A+sf'/'Asf'/'BBBsf'

Navient 2016-A

Expected impact on the note rating of increased defaults (class
A-2A/A-2B/B):

Current Ratings: 'AAAsf'/'AAAsf'/'AAsf'

Increase base case defaults by 10%:'AA-sf'/'AA-sf'/'A-sf'

Increase base case defaults by 25%: 'A+'/'A+'/'BBB+'

Increase base case defaults by 50%: 'A-'/'A-'/'BBB-'

Expected impact on the note rating of reduced recoveries (class
A-2A/A-2B/B):

Current Ratings: 'AAAsf'/'AAAsf'/'AAsf'

Reduce base case recoveries by 10%: 'AAsf'/'AAsf'/'Asf'

Reduce base case recoveries by 20%: 'AAsf'/'AAsf'/'Asf'

Reduce base case recoveries by 30%: 'AAsf'/'AAsf'/'Asf'

Expected impact on the note rating of increased defaults and
reduced recoveries (class A-2A/A-2B/B):

Current Ratings: 'AAAsf'/'AAAsf'/'AAsf'

Increase base case defaults and reduce base case recoveries each by
10%: 'AA-sf'/'AA-sf'/'A-sf'

Increase base case defaults and reduce base case recoveries each by
25%: 'A+sf'/ 'A+sf'/ 'BBB+sf'

Increase base case defaults and reduce base case recoveries each by
50%: 'A-sf'/'A-sf'/'BB+sf'

For SLM PE trusts that were not modeled for this review,
unanticipated increases in the frequency of defaults or write-offs
on customer accounts could produce loss levels higher than the base
case and would likely result in declines of CE and remaining loss
coverage levels available to the investments. Decreased CE may make
certain ratings on the investments susceptible to potential
negative rating actions, depending on the extent of the decline in
coverage.


UNITED AUTO 2019-1: S&P Assigns Prelim B(sf) Rating to Cl. F Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to United Auto
Credit Securitization Trust 2019-1's automobile receivables-backed
notes series 2019-1.

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

The preliminary ratings are based on information as of May 8, 2019.
Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The availability of approximately 58.5%, 50.9%, 42.0%, 32.3%,
26.9%, and 23.4% (pre-haircut) credit support for the class A, B,
C, D, E, and F notes, respectively, based on stressed break-even
cash flow scenarios (including excess spread). These credit support
levels provide coverage of approximately 2.90x, 2.50x, 2.05x,
1.55x, 1.27x, and 1.10x S&P's expected net loss range of
19.50%-20.50% for the class A, B, C, D, E, and F notes,
respectively.

-- The likelihood of timely interest and principal payments by the
assumed legal final maturity dates under stressed cash flow
modeling scenarios that are appropriate for the assigned
preliminary ratings.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal, the ratings on the class A and B
notes would not be lowered, the rating on the class C notes would
not decline by more than one rating category, and the rating on the
class D notes would not decline by more than two rating categories
over their life. Under this scenario, the ratings on the class E
and F notes would not decline by more than two rating categories
from S&P's preliminary 'BB (sf)' and 'B (sf)' ratings,
respectively, in the first year but would ultimately default. These
potential rating movements are consistent with S&P's credit
stability criteria.

-- Credit enhancement in the form of subordination,
overcollateralization, a reserve account, and excess spread.

-- The collateral characteristics of the subprime pool being
securitized. It is approximately five months seasoned, with a
weighted average original term of approximately 45 months and an
average remaining term of about 40 months. As a result, S&P expects
that the pool will pay down more quickly than many other subprime
pools that are usually characterized by longer weighted average
original and remaining terms.

-- S&P's analysis of seven years of static pool data following the
credit crisis and after United Auto Credit Corp. (UACC) centralized
its operations and shifted toward shorter loan terms.

-- S&P also reviewed the performance of UACC's three outstanding
securitizations as well as its paid off securitizations. UACC's
more than 20-year history of originating, underwriting, and
servicing subprime auto loans.

-- The transaction's payment and legal structures.

  PRELIMINARY RATINGS ASSIGNED
  United Auto Credit Securitization Trust 2019-1

  Class     Rating(i)       Amount (mil. $)
  A         AAA (sf)                 142.50
  B         AA (sf)                   32.18
  C         A (sf)                    33.70
  D         BBB (sf)                  39.84
  E         BB (sf)                   21.92
  F         B (sf)                    14.86

(i)The rating on each class of securities is preliminary and
subject to change at any time.


VISIO 2019-1 TRUST: S&P Assigns B (sf) Rating to Class B-2 Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Visio 2019-1 Trust's
mortgage pass-through notes.

The note issuance is a residential mortgage-backed securities
(RMBS) transaction backed by first-lien fixed- and adjustable-rate
fully amortizing investment property mortgage loans secured by
single-family residential properties, planned-unit developments,
condominiums, and two- to four-family residential properties to
both prime and nonprime borrowers. The pool has 879 loans; all
loans are business-purpose investor loans and are exempt from the
qualified mortgage/ability-to-repay rules.

The ratings reflect:

-- The pool's collateral composition;
-- The credit enhancement provided for this transaction;
-- The transaction's associated structural mechanics;
-- The representation and warranty framework for this transaction;
and
-- The mortgage originator, Visio Financial Services Inc.

  RATINGS ASSIGNED
  Visio 2019-1 Trust
  Class     Rating        Amount ($)
  A-1       AAA (sf)     111,648,000
  A-2       AA (sf)       12,098,000
  A-3       A (sf)        20,135,000
  M-1       BBB (sf)      10,456,000
  B-1       BB (sf)        9,073,000
  B-2       B (sf)         6,395,000
  B-3       NR             3,024,582
  XS        NR              Notional(i)
  R         NR                   N/A
  
(i)Notional amount equals the loans' unpaid principal balance.
NR--Not rated.
N/A--Not applicable.


WELLS FARGO 2016-BNK1: Fitch Affirms B- Ratings on 2 Tranches
-------------------------------------------------------------
Fitch Ratings has affirmed 15 classes of Wells Fargo Commercial
Mortgage Trust 2016-BNK1 commercial mortgage pass through
certificates.

KEY RATING DRIVERS

Minimal Change to Credit Enhancement: As of the April 2019
distribution date, the pool's aggregate principal balance has been
reduced by 1.86% to $854.4 million from $870.6 million at issuance.
Five loans (16.2%) have been designated Fitch Loans of Concern
(FLOCs) including two loans (8.3%) that have transferred to special
servicing since the prior review. Twelve loans (38.2% of the
current pool balance) are full-term interest only and 10 loans
(29.4%) are partial-term interest-only, four of which (9.8%) have
begun amortizing. There are no defeased loans and interest
shortfalls are currently impacting classes G and RRI.

Increased Loss Expectations: While overall pool performance remains
stable, loss expectations have increased due to the transfer of two
loans, including the third largest loan in the pool (7.9%), to
special servicing.

The third largest loan in the pool, One Stamford Forum, is a
504,471 sf office building located in Stamford, CT, where the
borrower, One Stamford Realty L.P., and major tenant Purdue Pharma,
are 100% owned for the benefit of the Sackler family. Purdue
Pharma, which occupies this property as their U.S. headquarters, is
a privately owned pharmaceutical company that focuses on pain
medication, including OxyContin. Purdue Pharma currently occupies
92% of the NRA through a direct lease and sublease and has executed
a "wraparound lease" for the remainder of the building beginning in
January 2021 and extending until 2031. The loan transferred to
special servicing on March 15, 2019 for imminent monetary default
due to recent media reports indicating that Purdue Pharma has
consulted restructuring experts and is considering a bankruptcy
filing as a result of approximately 1,900 lawsuits, including 36 by
state attorney generals. Fitch's base case loss on the loan
incorporates an additional stress on the cash flow.

Fitch Loans of Concern: Including One Stamford Forum, five loans
(16.2%) are designated as FLOCs. The second largest FLOC is Simon
Premium Outlets (4.2%), a portfolio of three outlet malls in
tertiary locations. Portfolio occupancy has declined to 84% at YE
2018 compared to 93% at YE 2016 and total portfolio sales declined
9.6% to $195.2 million at YE 2017, compared to $215.9 million at
issuance.

The third largest FLOC is Courtyard Marriott - Baldwin Park (2.1%),
a 195-key limited service hotel in the Los Angeles metro where net
cash flow has consistently declined since issuance due to the
steady deterioration of RevPAR. At issuance, Fitch noted that three
new hotels, totaling 646 keys, were scheduled to come online by
late 2017. Smaller FLOCs include a shopping center with a dark
grocery anchor and a single-tenant retail property where the
single-tenant has filed bankruptcy and plans to close this
location.

Alternative Loss Considerations: Due to the transfer of One
Stamford Forum to special servicing, Fitch ran a sensitivity
scenario on this loan and assumed a 67% loss severity based on a
dark value analysis to reflect the potential for outsized losses
given the possibility for significant vacancy in a high vacancy
submarket. This scenario is driving the Negative Rating Outlooks on
classes D, X-D, E, X-E, F, and X-F.

ADDITIONAL CONSIDERATIONS

Retail Concentration: Loans collateralized by retail properties
account for 26% of the pool including one regional mall (9.4%) and
a portfolio of three outlet malls in tertiary locations (4.2%). The
largest loan in the pool is The Shops at Crystals (9.4%), a
high-end regional mall in Las Vegas, NV. Property performance has
remained stable since issuance and total mall sales were $1,355 psf
for 2018, $1,459 psf for 2017, $1,450 for 2016, and $1,330 psf at
YE 2015.

RATING SENSITIVITIES

The Negative Rating Outlooks on classes D, X-D, E, X-E, F, and X-F
reflect the additional sensitivity analysis applied to One Stamford
Forum. Downgrades to these classes are possible should the
performance of One Stamford Forum deteriorate or if Purdue Pharma
were to declare bankruptcy or the loan becomes delinquent on debt
service. Downgrades are also possible if the other FLOCs continue
to deteriorate. The Stable Outlooks on all other classes reflect
the stable performance of the majority of the pool and increasing
credit enhancement from continued amortization. Rating upgrades,
while unlikely in the near term may occur with improved pool
performance and additional paydown or defeasance.

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 and has revised Outlooks
where indicated:

  -- $20.8 million class A-1 notes at 'AAAsf'; Outlook Stable;

  -- $45.8 million class A-SB notes at 'AAAsf'; Outlook Stable;

  -- $230.0 million class A-2 notes at 'AAAsf'; Outlook Stable;

  -- $267.0 million class A-3 notes at 'AAAsf'; Outlook Stable;

  -- $67.2 million class A-S notes at 'AAAsf'; Outlook Stable;

  -- 563.5 million class X-A* notes at 'AAAsf'; Outlook Stable;

  -- $44.5 million class B notes at 'AA-sf'; Outlook Stable;

  -- $150.9 million class X-B* notes at 'A-sf'; Outlook Stable;

  -- $39.3 million class C notes at 'A-sf'; Outlook Stable;

  -- $39.3 million class D notes at 'BBB-sf'; Outlook to Negative
from Stable;

  -- $39.3 million class X-D* notes at 'BBB-sf'; Outlook to
Negative from Stable;

  -- $18.6 million class E notes at 'BB-sf'; Outlook to Negative
from Stable;

  -- $18.6 million class X-E* notes at 'BB-sf'; Outlook to Negative
from Stable;

  -- $8.3 million class F notes at 'B-sf'; Outlook to Negative from
Stable;

  -- $8.3 million class X-F* notes at 'B-sf'; Outlook to Negative
from Stable.

  * Notional amount and interest-only.

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


WELLS FARGO 2019-2: Fitch to Rate $2.214MM Class B-4 Certs 'BBsf'
-----------------------------------------------------------------
Fitch Ratings expects to rate Wells Fargo Mortgage Backed
Securities 2019-2 Trust as follows:

  -- $470,480,000 class A-1 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $470,480,000 class A-2 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $352,860,000 class A-3 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $352,860,000 class A-4 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $117,620,000 class A-5 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $117,620,000 class A-6 exchangeable certificates 'AAAsf';
Outlook Stable;

-- $282,288,000 class A-7 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $282,288,000 class A-8 certificates 'AAAsf'; Outlook Stable;

  -- $188,192,000 class A-9 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $188,192,000 class A-10 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $70,572,000 class A-11 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $70,572,000 class A-12 certificates 'AAAsf'; Outlook Stable;

  -- $76,453,000 class A-13 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $76,453,000 class A-14 certificates 'AAAsf'; Outlook Stable;

  -- $41,167,000 class A-15 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $41,167,000 class A-16 certificates 'AAAsf'; Outlook Stable;

  -- $55,433,000 class A-17 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $55,433,000 class A-18 certificates 'AAAsf'; Outlook Stable;

  -- $525,913,000 class A-19 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $525,913,000 class A-20 exchangeable certificates 'AAAsf';
Outlook Stable;

  -- $525,913,000 class A-IO1 notional certificates 'AAAsf';
Outlook Stable;

  -- $470,480,000 class A-IO2 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $352,860,000 class A-IO3 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $117,620,000 class A-IO4 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $282,288,000 class A-IO5 notional certificates 'AAAsf';
Outlook Stable;

  -- $188,192,000 class A-IO6 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $70,572,000 class A-IO7 notional certificates 'AAAsf'; Outlook
Stable;

  -- $76,453,000 class A-IO8 notional certificates 'AAAsf'; Outlook
Stable;

  -- $41,167,000 class A-IO9 notional certificates 'AAAsf'; Outlook
Stable;

  -- $55,433,000 class A-IO10 notional certificates 'AAAsf';
Outlook Stable;

  -- $525,913,000 class A-IO11 notional exchangeable certificates
'AAAsf'; Outlook Stable;

  -- $11,072,000 class B-1 certificates 'AAsf'; Outlook Stable;

  -- $7,751,000 class B-2 certificates 'Asf'; Outlook Stable;

  -- $4,428,000 class B-3 certificates 'BBBsf'; Outlook Stable;

  -- $2,214,000 class B-4 certificates 'BBsf'; Outlook Stable.

Fitch will not be rating the following class:

  -- $2,215,652 class B-5 certificates.

Fitch expects to rate the residential mortgage-backed certificates
issued by WFMBS 2019-2. The certificates are supported by 836 prime
fixed-rate mortgage loans with a total balance of approximately
$553.59 million as of the cutoff date. All of the loans were
originated by Wells Fargo Bank, N.A. or were acquired from its
correspondents. This is the third post-crisis issuance from Wells
Fargo.

KEY RATING DRIVERS

Very High-Quality Mortgage Pool (Positive): The collateral
attributes are among the strongest of post crisis RMBS rated by
Fitch. The pool consists of mainly 30-year fixed-rate fully
amortizing loans to borrowers with strong credit profiles, low
leverage and large liquid reserves. All loans are Safe Harbor
Qualified Mortgages (SHQM). The loans are seasoned an average of
four months.

The pool has a weighted average original FICO score of 772, which
is indicative of very high credit-quality borrowers. Approximately
51% has original FICO scores at or above 780. In addition, the
original WA combined loan-to-value ratio of 73.5% represents
substantial borrower equity in the property. The pool's attributes,
together with Wells Fargo's sound origination practices, support
Fitch's very low default risk expectations.

Low Operational Risk (Positive): Operational risk is very well
controlled for in this transaction. Wells Fargo has an extensive
operating history in residential mortgage originations and is
assessed as an 'Above Average' originator by Fitch. The entity has
a diversified sourcing strategy and utilizes an effective
proprietary underwriting system for its retail originations. Wells
Fargo will perform primary and master servicing for this
transaction; these functions are rated 'RPS1-' and 'RMS1-',
respectively, by Fitch.

Tier 2 R&W Framework (Neutral): While the loan-level
representations and warranties for this transaction are
substantially consistent with a Tier I framework, the nature of the
prescriptive breach tests, which limit the breach reviewers ability
to identify or respond to issues not fully anticipated at closing,
resulted in a Tier 2 framework. The pool received a neutral
treatment at the 'AAAsf' level due to the strong financial
condition of the R&W provider, Wells Fargo.

Due Diligence Review Results (Positive): A very low incidence of
material defects were found in the third-party due diligence
performed on 100% of loans in the transaction pool. The due
diligence was performed by Clayton, which is assessed by Fitch as
an 'Acceptable - Tier 1' TPR firm. The due diligence results
indicated strong origination processes and 99.3% of the population
was graded 'A' or 'B'. The model credit for the high percentage of
loan level due diligence combined with the adjustments for loan
exceptions reduced the 'AAAsf' loss expectation by 19 bps.

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

To mitigate tail risk, which arises as the pool seasons and fewer
loans are outstanding, a subordination floor of 1.20% of the
original balance will be maintained for the senior certificates.

Full Servicer Advancing (Neutral): The pool benefits from advances
of delinquent principal and interest until the servicer, Wells
Fargo, the primary servicer of the pool deems them non-recoverable.
Fitch's loss severities reflect reimbursement of amounts advanced
by the servicer from liquidation proceeds based on its liquidation
timelines assumed at each rating stress.

Extraordinary Expense Treatment (Neutral): The trust provides for
expenses, including indemnification amounts, reviewer fees and
costs of arbitration, to be paid by the net WA coupon of the loans,
which does not affect the contractual interest due on the
certificates. Furthermore, the expenses to be paid from the trust
are capped at $350,000 per annum (with the exception of independent
reviewer breach review fee), which can be carried over each year,
subject to the cap until paid in full.

CRITERIA APPLICATION

Fitch analyzed the transaction in accordance with its criteria, as
described in its report, "U.S. RMBS Rating Criteria." This
incorporates a review of the originators' lending platforms, as
well as an assessment of the transaction's R&Ws provided by the
originators and arranger, which were found to be consistent with
the ratings assigned to the certificates.

Fitch's analysis incorporated one criteria variation from the "U.S.
RMBS Rating Criteria", which relates to Fitch's assessment of the
transaction's R&W framework. While the R&W scorecard assesses the
framework as a Tier 1, the framework is treated as a Tier 2 given
the prescriptive testing construct with no reviewer latitude. There
is no impact to the ratings due to the strong financial strength of
the R&W provider.

RATING SENSITIVITIES

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

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10%, 20% and 30%, in addition to the
model-projected 5%. The analysis indicates that there is some
potential rating migration with higher MVDs, compared with the
model projection.

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


WELLS FARGO 2019-2: Moody's Gives (P)Ba3 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 2019-2 Trust. The ratings range
from (P)Aaa (sf) to (P)Ba3 (sf).

WFMBS 2019-2 is the second prime issuance by Wells Fargo Bank, N.A.
in 2019. The mortgage loans for this transaction are originated by
Wells Fargo Bank generally in accordance with the non-conforming
underwriting guidelines. All of the loans are designated as
qualified mortgages 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 2019-2 transaction is a securitization of 836 primarily
30-year, fixed rate, prime residential mortgage loans with an
unpaid principal balance of $553,593,652. 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 over 4 months.

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

The complete rating actions are as follows:

Issuer: WFMBS 2019-2

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)A3 (sf)

Cl. B-3, Assigned (P)Baa3 (sf)

Cl. B-4, Assigned (P)Ba3 (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.

Its 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 model. Loan-level adjustments to the
model included adjustments to borrower probability of default for
higher and lower borrower debt-to-income ratios, for borrowers with
multiple mortgaged properties, self-employed borrowers, origination
channels and for the default risk of Homeownership association
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.

Moody's bases its ratings on the certificates on the credit quality
of the mortgage loans, the structural features of the transaction,
its assessments of the origination quality and servicing
arrangement, the strength of the third party due diligence and the
R&W framework of the transaction.

Collateral Description

The WFMBS 2019-2 transaction is a securitization of 836 first lien
residential mortgage loans with an unpaid principal balance of
$553,593,652. 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 of 73.3%. In
addition, 7.5% of the borrowers are self-employed and refinance
loans comprise 15.4% of the aggregate pool. 13.9% (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, Moody's treated these loans as a rate term
refinance rather than a cash out refinance loan. The pool has a
high geographic concentration with 35.9% of the aggregate pool
located in California and 15.2% located in the New
York-Newark-Jersey City MSA. The characteristics of the loans
underlying the pool are slightly stronger than recent prime RMBS
transactions backed by 30-year mortgage loans that Moody's has
rated.

Origination Quality

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, Moody's made no
adjustments to its base case and Aaa loss expectations. Majority of
the loans are originated through retail channel i.e. 76.9% of the
pool and the remaining pool i.e. 23.1% 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
836 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. There were two
loans with a compliance grade C due to understatement of finance
charges. A remediation was provided in the form of Extended Lock
Fee Credit and documented.

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.
There were four loans that have property valuation grade C due to
more than 10% negative variances after multiple valuations. Any
loans with appraisal dates older than a year from expected deal
settlement were refreshed with BPOs. LTVs are original and were not
recalculated to include updated value. Most recent property values
were provided for 11 loans and in some cases it was significantly
lower than the original appraised value. Moody's ran a sensitivity
to account for this but did not made adjustment to its losses for
these loans as it was not material.

The overall TPR results were in line with its 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 length of mortgage/rental history,
missing verbal verification of employment 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. As a result, Moody's did not
make any adjustment to its losses for this.

Wells Fargo Bank, as the originator, makes the loan-level
representation and warranties for the mortgage loans. The
loan-level R&Ws are strong and, in general, either meet or exceed
the baseline set of credit-neutral R&Ws Moody's has identified for
US RMBS. Further, R&W breaches are evaluated by an independent
third party using a set of objective criteria. 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. Moody's believes 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 an 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 a dedicated
credit risk, compliance and legal teams oversee fraud risk in
addition to compliance and operational risks. Moody's did not make
any adjustment to its base case and Aaa loss expectations for
R&Ws.

Tail Risk and Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
shrinks, senior bonds are exposed to increased performance
volatility, known as tail risk. The transaction provides for a
senior and subordinate 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 its tail risk
analysis, the level of senior and subordinate floor in WFMBS 2019-2
provides adequate protection against potential tail risk. In
addition, if the subordinate percentage drops below 5.00% 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 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 2019-2
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. Moody's believes there is
a very low likelihood that the rated certificates in WFMBS 2019-2
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 100% of the mortgage loans by an
independent third party (Clayton Services LLC). Moody's 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 2019-2, unlike other prime jumbo transactions, Well 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.


[*] DBRS Reviews 358 Classes From 32 US RMBS Transactions
---------------------------------------------------------
DBRS, Inc. reviewed 358 classes from 32 U.S. residential
mortgage-backed security (RMBS) transactions. Of the 358 classes
reviewed, DBRS upgraded six ratings, confirmed 339 ratings,
downgraded seven ratings and discontinued six ratings. The
downgraded ratings will also be subsequently discontinued due to
the transaction exercising its cleanup call option.

The rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new rating levels. The rating confirmations reflect asset
performance and credit support levels that are consistent with the
current ratings. The rating downgrades reflect the unlikeliness of
recovering the bonds' principal loss amount. The discontinued
ratings are the result of the full repayment of principal to
bondholders.

The rating actions are the result of DBRS's application of "RMBS
Insight 1.3: U.S. Residential Mortgage-Backed Securities Model and
Rating Methodology" published on September 27, 2018.

The pools backing these U.S. RMBS transactions consist of subprime
and Alt-A collateral.

The ratings for the securities listed below differ from the ratings
implied by the quantitative model. DBRS considers this difference
to be a material deviation, but in this case, the ratings of the
subject notes reflect certain risks that are not fully reflected in
the projected cash flows or model output or additional seasoning
required to substantiate further upgrade.

-- Aegis Asset Backed Securities Trust 2005-2, Mortgage-Backed
Notes, Series 2005-2, Class M3

-- Accredited Mortgage Loan Trust 2006-1, Asset-Backed Notes,
Series 2006-1, Class A-4

-- Accredited Mortgage Loan Trust 2006-1, Asset-Backed Notes,
Series 2006-1, Class M-1

-- ACE Securities Corp. Home Equity Loan Trust, Series 2004-HE4,
Asset-Backed Pass-Through Certificates, Series 2004-HE4, Class M-1

-- ACE Securities Corp. Home Equity Loan Trust, Series 2005-RM1,
Asset-Backed Pass-Through Certificates, Series 2005-RM1, Class M-3

-- C-BASS 2004-CB4 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB4, Class A-6

-- C-BASS 2004-CB5 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB5, Class M-1

-- C-BASS 2004-CB5 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB5, Class M-2

-- C-BASS 2004-CB5 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB5, Class M-3

-- C-BASS 2004-CB5 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB5, Class B-1

-- C-BASS 2004-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB6, Class M-2

-- C-BASS 2004-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB6, Class M-3

-- C-BASS 2004-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB6, Class B-1

-- C-BASS 2004-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB6, Class B-2

-- C-BASS 2004-CB8 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB8, Class M-1

-- C-BASS 2004-CB8 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB8, Class M-2

-- C-BASS 2004-CB8 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB8, Class M-3

-- C-BASS 2005-CB1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB1, Class M-1

-- C-BASS 2005-CB1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB1, Class M-2

-- C-BASS 2005-CB1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB1, Class M-3

-- C-BASS 2005-CB1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB1, Class B-1

-- C-BASS 2005-CB2 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB2, Class M-2

-- C-BASS 2005-CB2 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB2, Class M-3

-- C-BASS 2005-CB4 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB4, Class M-2

-- C-BASS 2005-CB4 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB4, Class M-3

-- C-BASS 2005-CB4 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB4, Class M-4

-- C-BASS 2005-CB4 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB4, Class M-5

-- C-BASS 2005-CB5 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB5, Class M-1

-- C-BASS 2005-CB5 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB5, Class M-2

-- C-BASS 2005-CB5 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB5, Class M-3

-- C-BASS 2005-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB6, Class A-3

-- C-BASS 2005-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB6, Class M-1

-- C-BASS 2005-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB7, Class M-1

-- C-BASS 2005-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2005-CB7, Class M-2

-- C-BASS 2005-CB8 Trust, C-Bass Mortgage Loan Asset-Backed
Certificates, Series 2005-CB8, Class AF-3

-- C-BASS 2005-CB8 Trust, C-Bass Mortgage Loan Asset-Backed
Certificates, Series 2005-CB8, Class AF-4

-- C-BASS 2005-CB8 Trust, C-Bass Mortgage Loan Asset-Backed
Certificates, Series 2005-CB8, Class AF-5

-- C-BASS 2006-CB1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB1, Class AV-1

-- C-BASS 2006-CB1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB1, Class AF-2

-- C-BASS 2006-CB1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB1, Class AF-3

-- C-BASS 2006-CB1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB1, Class AF-4

-- C-BASS 2006-CB2 TRUST, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB2, Class AV

-- Credit Suisse First Boston Mortgage Securities Corp. Home
Equity Asset Trust 2006-2, Home Equity Pass-Through Certificates,
Series 2006-2, Class 2-A-4

-- Credit Suisse First Boston Mortgage Securities Corp. Home
Equity Asset Trust 2006-2, Home Equity Pass-Through Certificates,
Series 2006-2, Class M-1

-- Nomura Home Equity Loan, Inc., Home Equity Loan Trust, Series
2006-HE1, Asset-Backed Certificates, Series 2006-HE1, Class M-1

-- Nomura Home Equity Loan, Inc., Home Equity Loan Trust, Series
2006-HE3, Asset-Backed Certificates, Series 2006-HE3, Class I-A-1

-- Park Place Securities Inc., Series 2004-WHQ2, Asset-Backed
Pass-Through Certificates, Series 2004-WHQ2, Class M-4

-- Park Place Securities Inc., Series 2005-WCH1, Asset-Backed
Pass-Through Certificates, Series 2005-WCH1, Class M-4

-- Park Place Securities Inc., Series 2005-WCH1, Asset-Backed
Pass-Through Certificates, Series 2005-WCH1, Class M-5

-- Securitized Asset Backed Receivables LLC Trust 2005-OP2,
Mortgage Pass-Through Certificates, Series 2005-OP2, Class M-1

-- Securitized Asset Backed Receivables LLC Trust 2005-OP2,
Mortgage Pass-Through Certificates, Series 2005-OP2, Class M-2

-- Securitized Asset Backed Receivables LLC Trust 2005-OP2,
Mortgage Pass-Through Certificates, Series 2005-OP2, Class M-3

-- Structured Asset Securities Corporation Mortgage Loan Trust
2005-S3, Mortgage Pass-Through Certificates, Series 2005-S3, Class
M4

-- Structured Asset Securities Corporation Mortgage Loan Trust
2005-S3, Mortgage Pass-Through Certificates, Series 2005-S3, Class
M5

The Affected Ratings are available at https://bit.ly/2WxxvM9


[*] DBRS Reviews 639 Classes From 68 US ReREMIC/RMBS Transactions
-----------------------------------------------------------------
DBRS, Inc. reviewed 639 classes from 68 U.S. resecuritized real
estate mortgage investment conduit (ReREMIC) and residential
mortgage-backed security (RMBS) transactions. Of the 639 classes
reviewed, DBRS upgraded 178 ratings, confirmed 448 ratings,
downgraded two ratings and discontinued 11 ratings.

The rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new rating levels. The rating confirmations reflect asset
performance and credit-support levels that are consistent with the
current ratings. The rating downgrades reflect the transactions'
negative trends in delinquency and projected loss activity. The
discontinued ratings are the result of the full repayment of
principal to bondholders.

The rating actions are a result of DBRS's application of the "RMBS
Insight 1.3: U.S. Residential Mortgage-Backed Securities Model and
Rating Methodology" published in September 2018.

The pools backing these ReREMIC and RMBS transactions consist of
prime, subprime, option adjustable-rate mortgages, Alt-A, scratch
and dent, second-lien, ReREMIC and agency credit collateral.

The ratings assigned to the securities below differ from the
ratings implied by the quantitative model. DBRS considers this
difference to be a material deviation, but in this case, the
ratings of the subject notes reflect a dependency on another
tranche's ratings, and a counterparty's rating as well as actual
deal or tranche performance that is not fully reflected in the
projected cash flows or model output.

-- Banc of America Funding 2014-R7 Trust, Resecuritization Trust
Securities, Class 2A1

-- Banc of America Funding 2014-R7 Trust, Resecuritization Trust
Securities, Class 2A6

-- Banc of America Funding 2014-R7 Trust, Resecuritization Trust
Securities, Class 2A7

-- BCAP LLC 2015-RR6 Trust, Resecuritization Trust Securities,
Class 1A1

-- BCAP LLC 2015-RR6 Trust, Resecuritization Trust Securities,
Class 1A2

-- Citigroup Mortgage Loan Trust 2009-8, Resecuritization Trust
Certificates, Series 2009-8, Class 6A2

-- Citigroup Mortgage Loan Trust 2009-10, Resecuritization Trust
Certificates, Series 2009-10, Class 2A2C

-- Citigroup Mortgage Loan Trust 2009-10, Resecuritization Trust
Certificates, Series 2009-10, Class 3A2

-- Citigroup Mortgage Loan Trust 2014-10, Resecuritization Trust
Securities, Series 2014-10, Class 4A3

-- CSMC Series 2015-5R, CSMC Series 2015-5R, Class 1-A-1

-- CSMC Series 2015-5R, CSMC Series 2015-5R, Class 2-A-4

-- CSMC Series 2015-5R, CSMC Series 2015-5R, Class 2-A-1

-- CSMC Series 2015-6R, CSMC Series 2015-6R, Class 2-A-1

-- CSMC Series 2015-6R, CSMC Series 2015-6R, Class 4-A-1

-- GSMSC Resecuritization Trust 2014-5R, Series 2014-5R
Resecuritization Trust Securities, Class 3A

-- GSMSC Resecuritization Trust 2015-3R, Resecuritization Trust
Securities, Series 2015-3R, Class 2A-1

-- GSMSC Resecuritization Trust 2015-3R, Resecuritization Trust
Securities, Series 2015-3R, Class 2A-1D

-- GSMSC Resecuritization Trust 2015-5R, Resecuritization Trust
Securities, Series 2015-5R, Class 1B

-- J.P. Morgan Mortgage Trust, Series 2008-R4, Series 2008-R4
Trust Certificates, Class 2-A-1

-- LVII Resecuritization Trust 2009-1, Mortgage Resecuritization
Notes, Series 2009-1, Class M-4

-- LVII Resecuritization Trust 2009-1, Mortgage Resecuritization
Notes, Series 2009-1, Class M-5

-- LVII Resecuritization Trust 2009-1, Mortgage Resecuritization
Notes, Series 2009-1, Class M-6

-- Morgan Stanley Resecuritization Trust 2013-R9, Resecuritization
Trust Securities, Class 5-A3

-- Morgan Stanley Resecuritization Trust 2013-R9, Resecuritization
Trust Securities, Class 5-A

-- Morgan Stanley Resecuritization Trust 2014-R9, Resecuritization
Pass-Through Certificates, Series 2014-R9, Class 3-A

-- Morgan Stanley Resecuritization Trust 2015-R3, Resecuritization
Pass-Through Securities, Series 2015-R3, Class 7-A1

-- Morgan Stanley Resecuritization Trust 2015-R3, Resecuritization
Pass-Through Securities, Series 2015-R3, Class 7-A2

-- Morgan Stanley Resecuritization Trust 2015-R3, Resecuritization
Pass-Through Securities, Series 2015-R3, Class 9-A2

-- RBSSP Resecuritization Trust 2009-6, Resecuritization Trust
Certificates, Series 2009-6, Class 9-A2

-- RBSSP Resecuritization Trust 2009-6, Resecuritization Trust
Certificates, Series 2009-6, Class 9-A4

-- RBSSP Resecuritization Trust 2009-6, Resecuritization Trust
Certificates, Series 2009-6, Class 10-A2

-- RBSSP Resecuritization Trust 2009-6, Resecuritization Trust
Certificates, Series 2009-6, Class 10-A4

-- C-BASS 2006-MH1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-MH1, Class M-2

-- C-BASS 2006-MH1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-MH1, Class B-1

-- Freddie Mac, Structured Agency Credit Risk Debt Notes, Series
2015-DN1, Class M-3

-- Freddie Mac, Structured Agency Credit Risk Debt Notes, Series
2015-DN1, Class M-3F

-- Freddie Mac, Structured Agency Credit Risk Debt Notes, Series
2015-DN1, Class M-3I

-- Freddie Mac, Structured Agency Credit Risk Debt Notes, Series
2015-DN1, Class MA

-- Freddie Mac, Structured Agency Credit Risk Debt Notes, Series
2016-HQA4, Class M-3AI

-- C-BASS 2007-SP1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2007-SP1, Class M-1

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class M-2

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class M-3

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class B-1

-- C-BASS 2004-CB7 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2004-CB7, Class B-2

-- First Franklin Mortgage Loan Trust, Series 2005-FFH2, Mortgage
Pass-Through Certificates, Series 2005-FFH2, Class M2

-- First Franklin Mortgage Loan Trust, Series 2005-FFH2, Mortgage
Pass-Through Certificates, Series 2005-FFH2, Class M3

-- MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage
Pass-Through Certificates, Series 2005-WMC1, Class M-3

-- MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage
Pass-Through Certificates, Series 2005-WMC1, Class M-4

-- MASTR Asset Backed Securities Trust 2005-WMC1, Mortgage
Pass-Through Certificates, Series 2005-WMC1, Class M-5

-- Securitized Asset-Backed Receivables LLC Trust 2005-EC1,
Mortgage Pass-Through Certificates, Series 2005-EC1, Class M-2

-- Terwin Mortgage Trust 2004-19HE, Asset-Backed Certificates,
Series 2004-19HE, Class A-1

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class A-1

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class A-3

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class M-1

-- Terwin Mortgage Trust 2004-7HE, Asset-Backed Certificates,
Series 2004-7HE, Class S

-- Terwin Mortgage Trust 2004-9HE, Asset-Backed Certificates,
Series 2004-9HE, Class A-1

-- Terwin Mortgage Trust 2004-9HE, Asset-Backed Certificates,
Series 2004-9HE, Class A-3

-- Terwin Mortgage Trust 2004-9HE, Asset-Backed Certificates,
Series 2004-9HE, Class M-1

-- Terwin Mortgage Trust 2004-13ALT, Asset-Backed Certificates,
Series 2004-13ALT, Class 2-PA-1

The Affected Ratings are available at https://bit.ly/2DYvcL4


[*] Moody's Cuts Ratings on 3 Tranches From 3 US RMBS Deals to 'C'
------------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches from three transactions, backed by Subprime loans, issued
by multiple issuers.

Complete rating actions are as follows:

Issuer: Merrill Lynch Mortgage Investors, Inc. 2003-WMC3

Cl. S*, Downgraded to C (sf); previously on Nov 29, 2017 Downgraded
to Caa3 (sf)

Issuer: Specialty Underwriting and Residential Finance Trust,
Series 2003-BC3

Cl. S*, Downgraded to C (sf); previously on Oct 27, 2017 Confirmed
at Caa3 (sf)

Issuer: Terwin Mortgage Trust, Series TMTS 2003-8HE

Cl. S*, Downgraded to C (sf); previously on Nov 29, 2017 Confirmed
at Caa2 (sf)

  * Reflects Interest Only Classes

RATINGS RATIONALE

The downgrade of the ratings to C (sf) reflects the nonpayment of
interest for an extended period of at least 12 months. For these
bonds, the coupon rate is subject to a calculation that has reduced
the required interest distribution to zero. Because the coupon on
these bonds is subject to changes in interest rates and/or
collateral composition, there is a remote possibility that they may
receive interest in the future. The ratings of C (sf) addresses the
loss of interest attributable to credit related reasons.

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

Factors that would lead to an upgrade or downgrade of the 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 3.8% in March 2019 from 4.1% in March
2018. 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 Hikes $250.4MM of RMBS Deals Issued 2015-2018
---------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 36 tranches
from five transactions issued by Mill City Mortgage Loan Trust and
six transactions issued by New Residential Mortgage Loan Trust
between 2015 and 2018. The transactions are backed by seasoned
performing and re-performing mortgage loans.

Complete rating actions are as follows:

Issuer: Mill City Mortgage Loan Trust 2015-1

Cl. M3, Upgraded to Aa1 (sf); previously on Nov 20, 2018 Upgraded
to Aa2 (sf)

Issuer: Mill City Mortgage Loan Trust 2017-1

Cl. B1, Upgraded to Baa1 (sf); previously on Nov 20, 2018 Upgraded
to Baa2 (sf)

Cl. M2, Upgraded to Aa1 (sf); previously on Nov 20, 2018 Upgraded
to Aa2 (sf)

Issuer: Mill City Mortgage Loan Trust 2017-2

Cl. M3, Upgraded to A2 (sf); previously on Nov 20, 2018 Upgraded to
A3 (sf)

Issuer: Mill City Mortgage Loan Trust 2017-3

Cl. A2, Upgraded to Aaa (sf); previously on Sep 29, 2017 Definitive
Rating Assigned Aa1 (sf)

Cl. A3, Upgraded to Aa1 (sf); previously on Sep 29, 2017 Definitive
Rating Assigned A1 (sf)

Cl. M1, Upgraded to Aaa (sf); previously on Nov 20, 2018 Upgraded
to Aa1 (sf)

Cl. M2, Upgraded to Aa2 (sf); previously on Nov 20, 2018 Upgraded
to A1 (sf)

Issuer: MILL CITY MORTGAGE LOAN TRUST 2018-3

Cl. M2, Upgraded to A2 (sf); previously on Sep 27, 2018 Definitive
Rating Assigned A3 (sf)

Issuer: New Residential Mortgage Loan Trust 2015-1

Cl. B-2, Upgraded to Aa2 (sf); previously on Jan 24, 2018 Upgraded
to Aa3 (sf)

Cl. B2-IO*, Upgraded to Aa2 (sf); previously on Jan 24, 2018
Upgraded to Aa3 (sf)

Cl. B-3, Upgraded to A2 (sf); previously on Jan 24, 2018 Upgraded
to A3 (sf)

Cl. B-4, Upgraded to A3 (sf); previously on Jan 24, 2018 Upgraded
to Baa3 (sf)

Cl. B-5, Upgraded to Baa3 (sf); previously on Jan 24, 2018 Upgraded
to Ba3 (sf)

Issuer: New Residential Mortgage Loan Trust 2015-2

Cl. B-3, Upgraded to A3 (sf); previously on Oct 25, 2018 Upgraded
to Baa1 (sf)

Cl. B-5, Upgraded to Ba2 (sf); previously on Oct 25, 2018 Upgraded
to Ba3 (sf)

Issuer: New Residential Mortgage Loan Trust 2016-1

Cl. B2-IO*, Upgraded to A1 (sf); previously on Mar 31, 2016
Definitive Rating Assigned A2 (sf)

Cl. B-2, Upgraded to A1 (sf); previously on Mar 31, 2016 Definitive
Rating Assigned A2 (sf)

Cl. B-3, Upgraded to A3 (sf); previously on Mar 31, 2016 Definitive
Rating Assigned Baa1 (sf)

Cl. B-4, Upgraded to Baa3 (sf); previously on Mar 31, 2016
Definitive Rating Assigned Ba1 (sf)

Cl. B-5, Upgraded to Ba2 (sf); previously on Mar 31, 2016
Definitive Rating Assigned B2 (sf)

Issuer: New Residential Mortgage Loan Trust 2016-2

Cl. B-2, Upgraded to A2 (sf); previously on May 31, 2016 Definitive
Rating Assigned A3 (sf)

Cl. B2-IO*, Upgraded to A2 (sf); previously on May 31, 2016
Definitive Rating Assigned A3 (sf)

Cl. B-4, Upgraded to Baa3 (sf); previously on May 31, 2016
Definitive Rating Assigned Ba3 (sf)

Cl. B-5, Upgraded to Ba3 (sf); previously on May 31, 2016
Definitive Rating Assigned B3 (sf)

Issuer: New Residential Mortgage Loan Trust 2016-3

Cl. B-4, Upgraded to Ba2 (sf); previously on Sep 29, 2016
Definitive Rating Assigned Ba3 (sf)

Issuer: New Residential Mortgage Loan Trust 2018-2

Cl. B-4, Upgraded to Baa3 (sf); previously on May 3, 2018
Definitive Rating Assigned Ba2 (sf)

Cl. B-4A, Upgraded to Baa3 (sf); previously on May 3, 2018
Definitive Rating Assigned Ba2 (sf)

Cl. B-4B, Upgraded to Baa3 (sf); previously on May 3, 2018
Definitive Rating Assigned Ba2 (sf)

Cl. B-4C, Upgraded to Baa3 (sf); previously on May 3, 2018
Definitive Rating Assigned Ba2 (sf)

Cl. B-5, Upgraded to B1 (sf); previously on May 3, 2018 Definitive
Rating Assigned B2 (sf)

Cl. B-5A, Upgraded to B1 (sf); previously on May 3, 2018 Definitive
Rating Assigned B2 (sf)

Cl. B-5B, Upgraded to B1 (sf); previously on May 3, 2018 Definitive
Rating Assigned B2 (sf)

Cl. B-5C, Upgraded to B1 (sf); previously on May 3, 2018 Definitive
Rating Assigned B2 (sf)

Cl. B-5D, Upgraded to B1 (sf); previously on May 3, 2018 Definitive
Rating Assigned B2 (sf)

Cl. B-7, Upgraded to Ba3 (sf); previously on May 3, 2018 Definitive
Rating Assigned B1 (sf)

*Reflects Interest Only Classes

RATINGS RATIONALE

The rating upgrades are driven by the stronger performance of the
underlying loans in the pools relative to initial expectations and
an increase in the credit enhancement available to the rated bonds
due to high prepayments. The actions reflect Moody's updated loss
expectations on the pools which incorporate its assessment of the
representations and warranties frameworks of the transactions and
the due diligence findings of the third party review at the time of
issuance.

The loans underlying the pools have fewer delinquencies and have
prepaid at a faster rate than originally anticipated, resulting in
an improvement in its loss projections for the pools. In estimating
defaults on these pools, Moody's used initial expected annual
delinquency rates of 5% to 12% and expected prepayment rates of 5%
to 13% based on the collateral characteristics of the individual
pools.

For transactions issued by Mill City Mortgage Loan Trust, the
rating upgrades further reflect the increase in credit enhancement
available to the bonds, owing to the sequential pay structure of
the transactions. The cash flow waterfall for transactions issued
by New Residential Mortgage Loan Trust follows 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 could be exposed to
increased performance volatility later in the transaction's life.
The transactions provide for a subordination floor which will
provide protection to the senior notes towards the tail end of the
transaction.

The methodologies used in rating all deals except interest-only
classes were "Moody's Approach to Rating Securitizations Backed by
Non-Performing and Re-Performing Loans" published in Februay 2019
and "US RMBS Surveillance Methodology" published in Februay 2019.
The methodologies used in rating interest-only classes were
"Moody's Approach to Rating Securitizations Backed by
Non-Performing and Re-Performing Loans" published in Februay 2019
and "US RMBS Surveillance Methodology" published in Februay 2019
and "Moody's Approach to Rating Structured Finance Interest-Only
Securities" published in Februay 2019.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in April 2019 from 3.9% in April
2018. 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 Hikes Ratings on $986.4 Million of RMBS Deals
---------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 33 tranches
from eight transactions issued by Towd Point Mortgage Trust and two
transactions issued by Citigroup Mortgage Loan Trust between 2015
and 2018. The transactions are backed by seasoned performing and
re-performing mortgage loans.

Complete rating actions are as follows:

Issuer: Citigroup Mortgage Loan Trust 2015-A

Cl. B-2, Upgraded to Aaa (sf); previously on Oct 18, 2018 Upgraded
to Aa1 (sf)

Cl. B-3, Upgraded to A1 (sf); previously on Oct 18, 2018 Upgraded
to A2 (sf)

Cl. B-4, Upgraded to Ba1 (sf); previously on Oct 18, 2018 Upgraded
to Ba3 (sf)

Issuer: Citigroup Mortgage Loan Trust 2018-RP2

Cl. B-1, Upgraded to Ba1 (sf); previously on Apr 17, 2018
Definitive Rating Assigned Ba3 (sf)

Cl. B-2, Upgraded to B1 (sf); previously on Apr 17, 2018 Definitive
Rating Assigned B3 (sf)

Cl. B-3, Upgraded to Ca (sf); previously on Apr 17, 2018 Definitive
Rating Assigned C (sf)

Cl. M-2, Upgraded to A2 (sf); previously on Apr 17, 2018 Definitive
Rating Assigned A3 (sf)

Issuer: Towd Point Mortgage Trust 2015-4

Cl. B1, Upgraded to Aa2 (sf); previously on Aug 14, 2017 Assigned
A2 (sf)

Cl. B2, Upgraded to Baa1 (sf); previously on Aug 14, 2017 Assigned
Baa3 (sf)

Cl. M2, Upgraded to Aaa (sf); previously on Aug 14, 2017 Assigned
Aa2 (sf)

Cl. M2A, Upgraded to Aaa (sf); previously on Aug 14, 2017 Assigned
Aa2 (sf)

Issuer: Towd Point Mortgage Trust 2015-6

Cl. B1, Upgraded to A2 (sf); previously on Aug 31, 2018 Upgraded to
A3 (sf)

Cl. B2, Upgraded to Baa2 (sf); previously on Aug 31, 2018 Upgraded
to Baa3 (sf)

Issuer: Towd Point Mortgage Trust 2016-1

Cl. B2, Upgraded to A3 (sf); previously on Aug 23, 2018 Assigned
Baa2 (sf)

Cl. B3, Upgraded to B2 (sf); previously on Aug 23, 2018 Assigned B3
(sf)

Issuer: Towd Point Mortgage Trust 2016-3

Cl. B1, Upgraded to A3 (sf); previously on Aug 31, 2018 Upgraded to
Baa1 (sf)

Cl. B2, Upgraded to Baa2 (sf); previously on Nov 16, 2017 Assigned
Baa3 (sf)

Cl. M1, Upgraded to Aaa (sf); previously on Aug 31, 2018 Upgraded
to Aa1 (sf)

Cl. M1A, Upgraded to Aaa (sf); previously on Aug 31, 2018 Upgraded
to Aa1 (sf)

Cl. M1B, Upgraded to Aaa (sf); previously on Aug 31, 2018 Upgraded
to Aa1 (sf)

Issuer: Towd Point Mortgage Trust 2016-5

Cl. A2, Upgraded to Aaa (sf); previously on Mar 30, 2018 Upgraded
to Aa1 (sf)

Cl. M2, Upgraded to A2 (sf); previously on Mar 30, 2018 Assigned A3
(sf)

Issuer: Towd Point Mortgage Trust 2017-5

Cl. A2, Upgraded to Aaa (sf); previously on Sep 4, 2018 Upgraded to
Aa1 (sf)

Cl. A3, Upgraded to Aaa (sf); previously on Nov 1, 2017 Definitive
Rating Assigned Aa1 (sf)

Cl. M2, Upgraded to A1 (sf); previously on Sep 4, 2018 Upgraded to
A2 (sf)

Issuer: Towd Point Mortgage Trust 2017-6

Cl. B2, Upgraded to B1 (sf); previously on Mar 16, 2018 Upgraded to
B2 (sf)

Cl. M1, Upgraded to A2 (sf); previously on Nov 30, 2017 Definitive
Rating Assigned A3 (sf)

Issuer: Towd Point Mortgage Trust 2018-1

Cl. A2, Upgraded to Aa2 (sf); previously on Feb 28, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. A3, Upgraded to Aa1 (sf); previously on Feb 28, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. B1, Upgraded to Baa3 (sf); previously on Feb 28, 2018
Definitive Rating Assigned Ba3 (sf)

Cl. B2, Upgraded to Ba3 (sf); previously on Feb 28, 2018 Definitive
Rating Assigned B3 (sf)

Cl. M1, Upgraded to A2 (sf); previously on Feb 28, 2018 Definitive
Rating Assigned A3 (sf)

Cl. M2, Upgraded to Baa2 (sf); previously on Feb 28, 2018
Definitive Rating Assigned Baa3 (sf)

RATINGS RATIONALE

The rating upgrades are driven by the stronger performance of the
underlying loans in the pools relative to initial expectations and
an increase in the credit enhancement available to the rated bonds
due to high prepayments. The actions reflect Moody's updated loss
expectations on the pools which incorporate its assessment of the
representations and warranties frameworks of the transactions, the
due diligence findings of the third party review at the time of
issuance, and the strength of the transaction's servicers. Fay
Servicing, LLC is the primary servicer of the collateral for
Citigroup Mortgage Loan Trust 2015-A and Citigroup Mortgage Loan
Trust 2018-RP2, and Select Portfolio Servicing, Inc is the primary
servicer for the majority of the collateral for transactions issued
by Towd Point Mortgage Trust.

The loans underlying the pools have fewer delinquencies and have
prepaid at a faster rate than originally anticipated, resulting in
an improvement in its loss projections for the pools. Moreover,
cumulative losses realized on the pools till date have been small
and are largely driven by modification losses recognized on
principal forborne amounts. Moody's bases its expected losses on a
pool of re-performing mortgage loans on its estimates of 1) the
default rate on the remaining balance of the loans and 2) the
principal recovery rate on the defaulted balances. Moody's
estimates of defaults are driven by annual delinquency assumptions
adjusted for roll-rates, prepayments and default burnout factors.
In estimating defaults on these pools, Moody's used initial
expected annual delinquency rates of 4% to 13% and expected
prepayment rates of 5% to 12% based on the collateral
characteristics of the individual pools.

The methodologies used in these ratings were "Moody's Approach to
Rating Securitizations Backed by Non-Performing and Re-Performing
Loans" published in Februay 2019 and "US RMBS Surveillance
Methodology" published in February 2019.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in April 2019 from 3.9% in April
2018. 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 $161.3MM of RMBS Issued 2003-2007
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of nine tranches
and downgraded the rating of one tranche from seven transactions,
backed by Alt-A and Subprime loans, issued by multiple issuers.

Complete rating actions are as follows:

Issuer: Carrington Mortgage Loan Trust, Series 2007-FRE1

Cl. A-2, Upgraded to Ba3 (sf); previously on Jan 17, 2017 Upgraded
to B2 (sf)

Issuer: Credit Suisse First Boston Mortgage Securities Corp. Series
2003-7

Cl. M-1, Upgraded to A2 (sf); previously on Jun 8, 2018 Upgraded to
Baa1 (sf)

Cl. M-3, Upgraded to Ba1 (sf); previously on Jun 8, 2018 Upgraded
to Ba2 (sf)

Issuer: GSAA Home Equity Trust 2005-5

Cl. B-1, Upgraded to B2 (sf); previously on Jul 5, 2018 Upgraded to
B3 (sf)

Cl. B-2, Upgraded to B2 (sf); previously on Jul 5, 2018 Upgraded to
Caa1 (sf)

Issuer: GSAA Home Equity Trust 2005-6

Cl. M-4, Upgraded to Caa2 (sf); previously on May 31, 2017 Upgraded
to Ca (sf)

Issuer: MASTR Asset Backed Securities Trust 2006-AM3

Cl. A-3, Upgraded to Ba2 (sf); previously on Apr 8, 2016 Upgraded
to B1 (sf)

Cl. A-4, Upgraded to B1 (sf); previously on Apr 8, 2016 Upgraded to
B3 (sf)

Issuer: Sequoia Mortgage Trust 2004-3

Cl. A, Upgraded to A2 (sf); previously on Dec 7, 2016 Upgraded to
Baa1 (sf)

Issuer: New Century Home Equity Loan Trust, Series 2004-1

Cl. M-1, Downgraded to B1 (sf); previously on Apr 14, 2014 Upgraded
to Ba2 (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to improvement in pools
performance and credit enhancement available to the bonds. The
rating downgrade on New Century Home Equity Loan Trust, Series
2004-1 Cl. M-1 is due to the outstanding interest shortfalls on
this bond, caused by the recoupment of non-recoverable servicer
advances, which are not expected to be reimbursed. As of April 2019
remittance data, Cl. M-1 has $141,197 of outstanding interest
shortfall. 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 February 2019.

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate
The unemployment rate fell to 3.8% in March 2019 from 4.0% in March
2018. 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.


[*] S&P Lowers Ratings on 42 Classes From 26 U.S. RMBS Deals
------------------------------------------------------------
S&P Global Ratings on May 8 completed its review of 42 classes from
26 U.S. residential mortgage-backed securities (RMBS) transactions
issued between 1999 and 2007. The review yielded 36 downgrades due
to observed principal write-downs and six downgrades due to the
application of the rating agency's interest shortfall criteria.

The lowered ratings due to outstanding principal write-downs
reflect S&P's assessment of the write-downs' impact on the affected
classes during recent remittance periods. All of the classes were
rated either 'CCC (sf)' or 'CC (sf)' before the May 8 rating
actions. All of the transactions in this review receive credit
enhancement from a combination of subordination, excess spread, and
overcollateralization (where applicable).

"In reviewing the classes with observed interest shortfalls, we
applied our interest shortfall criteria, which imposes a maximum
rating threshold on classes that have incurred interest shortfalls
resulting from credit or liquidity erosion," S&P said.

"In applying the criteria, we looked to see if the applicable class
received additional compensation beyond the imputed interest due as
direct economic compensation for the delay in interest payment,
which these classes did not. Therefore, in these instances, we used
the maximum length of time until full interest is reimbursed as
part of our analysis," S&P said, adding that this resulted in its
lowering of six of the ratings.

A list of Affected Ratings can be viewed at:

            https://bit.ly/2vN2ZSJ


[*] S&P Puts Ratings on 17 Classes From 13 CLOs on Watch Negative
-----------------------------------------------------------------
S&P Global Ratings placed its ratings on 17 classes from 13 U.S.
collateralized loan obligation (CLO) transactions on CreditWatch
with negative implications.

Two of these transactions were originally issued in 2012, three in
2013, and eight in 2014.

The CreditWatch negative placements follow S&P's observations of
one or more factors that typically have a more negative impact on
the junior notes in the transactions. Examples of such factors
include a drop in, or failure of, overcollateralization ratios; a
deterioration in credit quality of the portfolio; par losses; a
decline in weighted average spread; higher exposure to assets in
the CCC category; etc.

The impacted tranches are all in the 'BB (sf)' and 'B (sf)' ratings
categories and, since they are subordinate within their respective
capital structures, they are more vulnerable to distressed market
conditions and losses in the transaction. S&P believes the credit
support available to these notes may no longer be commensurate with
the current ratings.

"We typically resolve CreditWatch placements within 90 days after
we complete a comprehensive cash flow analysis and committee review
for each of the affected transactions. Since we recently proposed
revisions to our criteria, any potential rating changes will depend
on the final criteria adopted, as well as our assessment of the
given transaction at that point in time," S&P said.

"We will continue to monitor the transactions we rate and take
rating actions, including CreditWatch placements, as we deem
appropriate," S&P said.

  RATINGS PLACED ON CREDITWATCH NEGATIVE

  BlueMountain CLO 2013-1 Ltd.
                     Rating
  Class       To                    From
  D-R         BB (sf)/Watch Neg     BB (sf)

  THL Credit Wind River 2013-1 CLO Ltd.
                     Rating
  Class       To                    From
  D-R         BB (sf)/Watch Neg     BB (sf)

  ACIS CLO 2014-3 Ltd.
                     Rating
  Class       To                    From
  E           BB (sf)/Watch Neg     BB (sf)
  F           B+ (sf)/Watch Neg     B+ (sf)

  BNPP IP CLO 2014-1 Ltd.
                     Rating
  Class       To                    From
  D           BB (sf)/Watch Neg     BB (sf)

  BNPP IP CLO 2014-II Ltd.
                     Rating
  Class       To                    From
  E           BB (sf)/Watch Neg     BB (sf)

  CVP Cascade CLO-2 Ltd.
                     Rating
  Class       To                    From
  D           BB- (sf)/Watch Neg    BB- (sf)
  E           B- (sf)/Watch Neg     B- (sf)

  Flagship VII Ltd.
                     Rating
  Class       To                    From
  F           B- (sf)/Watch Neg     B- (sf)

  Halcyon Loan Advisors Funding 2012-1 Ltd.
                     Rating
  Class       To                    From
  D           B (sf)/Watch Neg      B (sf)

  Hull Street CLO Ltd.
                     Rating
  Class       To                    From
  E           BB- (sf)/Watch Neg    BB- (sf)
  F           B- (sf)/Watch Neg     B- (sf)

  MidOcean Credit CLO I
                     Rating
  Class       To                    From
  D-RR        BB (sf)/Watch Neg     BB (sf)

  THL Credit Wind River 2012-1 CLO Ltd.
                     Rating
  Class       To                    From
  E-R         BB (sf)/Watch Neg     BB (sf)

  WhiteHorse VII Ltd.
                    Rating
  Class       To                    From
  B-3L        B (sf)/Watch Neg      B (sf)

  Avery Point IV CLO Ltd.
                   Rating
  Class       To                    From
  E           BB- (sf)/Watch Neg    BB- (sf)
  F           B- (sf)/Watch Neg     B- (sf)


                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
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                            *********

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

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.
Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
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Sheryl Joy P. Olano, Psyche A. Castillon, Ivy B. Magdadaro, Carlo
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Editors.

Copyright 2019.  All rights reserved.  ISSN: 1520-9474.

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                   *** End of Transmission ***