/raid1/www/Hosts/bankrupt/TCR_Public/190609.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, June 9, 2019, Vol. 23, No. 159

                            Headlines

1211 AVENUE 2015-1211: Fitch Affirms BB Rating on Class E Certs
AEGIS ASSET 2005-4: Moody's Hikes Class M2 Debt Rating to 'Ba1'
AMERICREDIT AUTOMOBILE 2019-2: Moody's Gives (P)Ba2 to E Notes
APEX CREDIT 2019: Moody's Rates $21MM Class D Notes 'Ba3'
BBCMS TRUST 2015-SRCH: Fitch Affirms BB+ Rating on Class E Notes

BENEFIT STREET XVII: S&P Assigns Prelim BB- Rating to Cl. E Notes
BUSINESS JET 2019-1: S&P Assigns Prelim BB (sf) Rating to C Notes
CIFC FUNDING 2019-III: Moody's Rates $34.2MM Class D Notes 'Ba3'
COMM 2016-667M: S&P Affirms BB (sf) Rating on Class E Certificates
COMM 2019-521F: S&P Assigns Prelim B- (sf) Rating to Class F Certs

DEUTSCHE BANK 2011-LC3: Fitch Cuts Class F Certs Rating to 'B-'
FINANCE OF AMERICA 2018-HB1: Moody's Hikes Class M4 Debt to Ba1
FREDDIE MAC 2019-HRP1: S&P Assigns Ratings to 50 Classes of Notes
GS MORTGAGE 2016-GS4: S&P Affirms B-(sf) Rating on Cl. X-225 Certs
GS MORTGAGE 2019-SOHO: Moody's Gives (P)Ba2) Rating to HRR Certs

HERTZ VEHICLE II: Fitch Rates $48.51MM Class D Notes 'BBsf'
HILDENE TRUPS 2019-P12B: Moody's Rates $42.7MM Class B Notes 'Ba2'
JP MORGAN 2004-C2: Fitch Hikes Class N Certs Rating to 'BBsf'
JP MORGAN 2008-C2: Fitch Cuts $94.8MM A-M Debt Rating to 'Csf'
JP MORGAN 2019-INV1: Moody's Assigns B3 Rating on Class B-5 Notes

LB COMMERCIAL 2007-C3: S&P Affirms B+ Ratings on 2 Classes of Certs
LCM 29: S&P Assigns BB- (sf) Rating to $13.6MM Class E Notes
LEGACY BENEFITS 2004-I: Moody's Confirms Caa3 Rating on B Notes
LOANCORE 2019-CRE3: DBRS Gives (P)B(low) Rating on Class F Notes
MADISON PARK X: S&P Rates $37.5MM Class E-R-2 Notes 'BB- (sf)'

MARGARITAVILLE 2019-MARG: DBRS Gives (P)B(low) on Class G Certs
MCA FUND II: DBRS Confirms BB Rating on Class C Notes
MIDOCEAN CREDIT VI: Moody's Rates Class $20MM Class E-R Notes Ba3
MMCAPS FUNDING XVIII: Moody's Hikes Class C-3 Notes Rating to Ba3
MORGAN STANLEY 2019-H6: Fitch to Rate Class J-RR Certs 'B-sf'

NIAGARA PARK: S&P Assigns Prelim BB- (sf) Rating to Class E Notes
ORANGE LAKE 2019-A: Fitch Assigns 'BBsf' Rating on Class D Debt
PALMER SQUARE 2015-1: S&P Assigns Prelim BB- Rating to D-R2 Notes
SEQUOIA MORTGAGE 2019-2: Moody's Rates Class B-4 Debt 'Ba3'
TRIMARAN CAVU 2019-1: S&P Rates $24.2MM Class E Notes 'BB- (sf)'

UNITED AUTO 2019-1: DBRS Finalizes B Rating on Class F Notes
WELLS FARGO 2017-C38: Fitch Affirms B- Rating on $11.2MM F Certs
WELLS FARGO 2019-2: Fitch Rates $2.214MM Class B-4 Certs 'BBsf'
WELLS FARGO 2019-2: Moody's Assigns Ba3 Rating on Class B-4 Debt
WESTLAKE AUTOMOBILE 2019-2: S&P Gives Prelim B+ Rating to F Notes

[*] DBRS Reviews 518 Classes From 41 US RMBS Transactions
[*] Fitch Took Actions Then Withdrew Ratings on 6 US CMBS Deals
[*] S&P Takes Various Actions on 32 Classes From 15 US RMBS Deals
[*] S&P Takes Various Actions on 66 Classes From 8 US RMBS Deals

                            *********

1211 AVENUE 2015-1211: Fitch Affirms BB Rating on Class E Certs
---------------------------------------------------------------
Fitch Ratings has affirmed eight classes of 1211 Avenue of the
Americas Trust 2015-1211 commercial mortgage pass-through
certificates.

KEY RATING DRIVERS

Stable to Improved Cash Flow Since Issuance: The Fitch stressed
cash flow improved from issuance. As of the March 2019 rent roll,
occupancy has improved to 95.9% from 91.5% at issuance and Fitch
cash flow has improved to $103.6 million from $95.5 million at
issuance.

Above Average Property Quality in Strong Location: 1211 Avenue of
the Americas consists of a 45-story, class A office building
located in Midtown Manhattan. The property is adjacent to
Rockefeller Center and in close proximity to subway lines and major
transportation hubs.

Strong Historical Occupancy: The top five tenants account for
approximately 87% of net rentable area (NRA) and include
Twenty-First Century Fox, Inc (59.2% of NRA; rated A), Ropes & Gray
(16.4% of NRA), Axis Reinsurance (6.1% of NRA; A+), RBC (3.1% of
NRA; AA) and Nordea (2.2% of NRA; AA-). Tenants with
investment-grade credit ratings account for approximately 70.6% of
the NRA.

Major Tenant Renewal: Approximately 52% of NRA, which is leased to
Twenty-First Century Fox, Inc was scheduled to expire Nov. 30,
2020; Fox Corp suites (31% NRA) renewed through Nov. 30, 2025 and
News Corp suites (22% NRA) renewed through Nov. 30, 2027.

Sponsorship and Property Manager: The loan sponsor is Ivanhoe
Cambridge Inc. The property is sub managed by Cushman & Wakefield
and Callahan Capital Properties LLC.

Asset Concentration: The transaction is secured by a single
property and is, therefore, more susceptible to single-event risk
related to the market, sponsor or the largest tenants occupying the
property.

Interest Only Loan for the Entire Term: As of the May 2019
distribution date, the transaction's balance remained at $1.035
billion, unchanged from issuance. The 10-year, fixed-rate,
interest-only loan matures in August 2025.

RATING SENSITIVITIES

The Rating Outlooks remain Stable for all classes. Overall loan
performance has been stable to improving since issuance. Occupancy
increased to 95.9% as of the March 2019 rent roll from 91.5% at
issuance. With continued sustained improvement in performance,
future upgrades are possible, although may be limited due to tenant
rollover at or close to maturity.

1211 Avenue of the Americas Trust 2015-1211
   
  Class A-1A1    AAAsf     Affirmed
  
  Class A-1A2    AAAsf     Affirmed
   
  Class B        AA-sf     Affirmed
  
  Class C        A-sf      Affirmed
  
  Class D        BBB-sf    Affirmed

  Class E        BBsf      Affirmed

  Class X-A      AAAsf     Affirmed
  
  Class X-B      AA-sf     Affirmed



AEGIS ASSET 2005-4: Moody's Hikes Class M2 Debt Rating to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 5 tranches,
and downgraded ratings of 4 tranches from four transactions backed
by Subprime and Alt-A loans issued by multiple issuers.

Complete rating actions are as follows:

Issuer: Aegis Asset Backed Securities Trust 2005-4

Cl. M1, Upgraded to Aaa (sf); previously on May 5, 2017 Upgraded to
Aa3 (sf)

Cl. M2, Upgraded to Ba1 (sf); previously on May 5, 2017 Upgraded to
Ba3 (sf)

Issuer: Argent Securities Inc., Series 2005-W5

Cl. A-1, Upgraded to A2 (sf); previously on Apr 27, 2017 Upgraded
to Baa1 (sf)

Issuer: Bear Stearns Asset-Backed Securities Trust 2003-AC7

Cl. A-1, Downgraded to B3 (sf); previously on Feb 14, 2017
Downgraded to B1 (sf)

Cl. A-2, Downgraded to B3 (sf); previously on Feb 14, 2017
Downgraded to B1 (sf)

Cl. A-3, Downgraded to B3 (sf); previously on Feb 14, 2017
Downgraded to B1 (sf)

Cl. A-4, Downgraded to B3 (sf); previously on Feb 14, 2017
Downgraded to B1 (sf)

Issuer: Nomura Home Equity Loan Trust 2005-HE1

Cl. M-4, Upgraded to Aa1 (sf); previously on Feb 3, 2017 Upgraded
to A1 (sf)

Cl. M-5, Upgraded to Baa2 (sf); previously on Feb 3, 2017 Upgraded
to Ba1 (sf)

RATINGS RATIONALE

The actions reflect the recent performance of the underlying pools
and reflect Moody's updated loss expectations on the pools. The
ratings downgraded are due recent deterioration in deal performance
and erosion of credit enhancement available to these bonds. The
ratings upgraded are a result of improving performance of the
related pools and/or 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.


AMERICREDIT AUTOMOBILE 2019-2: Moody's Gives (P)Ba2 to E Notes
--------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to the
notes to be issued by AmeriCredit Automobile Receivables Trust
2019-2. This is the second AMCAR auto loan transaction of the year
for AmeriCredit Financial Services, Inc. (AFS; Unrated). The notes
will be backed by a pool of retail automobile loan contracts
originated by AFS, who is also the servicer and administrator for
the transaction.

The complete rating actions are as follows:

Issuer: AmeriCredit Automobile Receivables Trust 2019-2

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

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

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

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

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

Class C Notes, Assigned (P)Aa3 (sf)

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

Class E Notes, Assigned (P)Ba2 (sf)

RATINGS RATIONALE

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

Moody's median cumulative net loss expectation for the 2019-2 pool
is 10.0% and the loss at a Aaa stress is 38.0%. Moody's based its
cumulative net loss expectation and loss at a Aaa stress on an
analysis of the credit quality of the underlying collateral; the
historical performance of similar collateral, including
securitization performance and managed portfolio performance; the
ability of AFS to perform the servicing functions; and current
expectations for the macroeconomic environment during the life of
the transaction.

At closing, the Class A notes, Class B notes, Class C notes, Class
D, and Class E notes are expected to benefit from 35.20%, 27.95%,
18.95%, 10.10%, and 7.75% of hard credit enhancement, respectively.
Hard credit enhancement for the notes consists of a combination of
overcollateralization, a non-declining reserve account, and
subordination. The notes may also benefit from excess spread.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Auto Loan- and Lease-Backed ABS" published in
March 2019.

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

Up

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

Down

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


APEX CREDIT 2019: Moody's Rates $21MM Class D Notes 'Ba3'
---------------------------------------------------------
Moody's Investors Service has assigned ratings to one class of
loans incurred and four classes of notes issued by Apex Credit CLO
2019 Ltd.

Moody's rating action is as follows:
123456789012345678901234567890123456789012345678901234567890123456
  US$285,950,000 Class A Loans maturing in 2032 (the "Class A
  Loans"), Assigned Aa1 (sf)

  US$15,050,000 Class A Senior Secured Floating Rate Notes due
  2032 (the "Class A Notes"), Assigned Aa1 (sf)

  US$23,000,000 Class B Secured Deferrable Floating Rate Notes
  due 2032 (the "Class B Notes"), Assigned A2 (sf)

  US$23,000,000 Class C Secured Deferrable Floating Rate Notes
  due 2032 (the "Class C Notes"), Assigned Baa3 (sf)

  US$21,000,000 Class D Secured Deferrable Floating Rate Notes
  due 2032 (the "Class D Notes"), Assigned Ba3 (sf)

The Class A Loans, the Class A 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.

Apex 2019 is a managed cash flow CLO. The Rated Debt will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 92.5% of the portfolio must consist of
senior secured loans and eligible investments, and up to 7.5% of
the portfolio may consist of second lien loans and unsecured loans.
The portfolio is approximately 75% ramped as of the closing date.

Apex Credit Partners 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 subordinated
notes.

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the Rated Debt 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: 60

Weighted Average Rating Factor (WARF): 2650

Weighted Average Spread (WAS): 3.75%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 45.0%

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.


BBCMS TRUST 2015-SRCH: Fitch Affirms BB+ Rating on Class E Notes
----------------------------------------------------------------
Fitch Ratings has affirmed eight classes of BBCMS Trust 2015-SRCH
Mortgage Trust commercial mortgage pass-through certificates.

KEY RATING DRIVERS

Stable Performance and Property Cash Flow: Property level
performance is stable, and the year-end (YE) 2018 net cash flow is
in line with issuance expectations. The most recent
servicer-reported NCF DSCR as of YE 2018 was 2.0x.

Superior Collateral Quality in Strong Location: The loan is secured
by the fee simple interest in three newly constructed,
single-tenant office buildings, totaling 943,056 square feet (sf),
leased to Google, Inc. in Sunnyvale, CA. The three buildings hold a
LEED-Gold designation and will be some of the most technologically
advanced in the area. The complex also includes a 52,500-square
foot amenities building for the sole use of tenants, which includes
fitness and weight equipment, studios for classes, full locker
rooms and an outdoor pool.

Single-Tenant Lease Exposure: The three buildings are leased by
Google, which has no outs in its lease and has invested
approximately $188.6 million ($200 per square foot [psf]) in its
buildout. Google is one of the world's largest technology companies
with an estimated market capitalization of $800 billion as of May
2019. It is also one of the largest landlords and occupiers of
space in the Silicon Valley market. The company has leased three
other office buildings in the development (Phase II).

Amortization: The loan is interest-only for the first four years
and eight months and then amortizes on a 30-year schedule,
resulting in seven years of amortization. The loan is still in the
interest-only period and is expected to start amortizing in August
2020. At maturity, the trust balloon balance is estimated to be
$372.1 million ($395/sf), resulting in an approximate 13.5%
reduction to the initial loan amount.

Reserves: Up-front reserves of approximately $71 million were
funded to address all outstanding landlord obligations, including
tenant improvements, leasing costs and free rent periods. Nearly
all of the reserves have been used, and only a small amount
remains. The loan includes a cash flow sweep to be used to build
reserves to $25 psf during the final two years of the lease term if
Google does not give notice to renew.

RATING SENSITIVITIES

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

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

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

Fitch has affirmed the following ratings:

  -- $58.0 million class A-1 notes at 'AAAsf'; Outlook Stable;

  -- $202.0 million class A-2 notes at 'AAAsf'; Outlook Stable;

  -- $260.0 million interest-only class X-A* at 'AAAsf';
     Outlook Stable;

  -- $140.0 million interest-only class X-B* at 'A-sf';
     Outlook Stable;

  -- $46.0 million class B notes at 'AA-sf'; Outlook Stable;

  -- $39.0 million class C notes at 'A-sf'; Outlook Stable;

  -- $55.0 million class D notes at 'BBB-sf'; Outlook Stable;

  -- $30.0 million class E notes at 'BB+sf'; Outlook Stable.

  * Notional amount and interest only.


BENEFIT STREET XVII: S&P Assigns Prelim BB- Rating to Cl. E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Benefit
Street Partners CLO XVII Ltd./Benefit Street Partners CLO XVII
LLC's floating-rate notes.

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

The preliminary ratings are based on information as of June 5,
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 diversification of the collateral pool.

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

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

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

  PRELIMINARY RATINGS ASSIGNED

  Benefit Street Partners CLO XVII Ltd./Benefit Street Partners   
  CLO XVII LLC

  Class              Rating               Amount
                                        (mil. $)

  A-1                AAA (sf)             310.00
  A-2                NR                    10.00
  B                  AA (sf)               51.00
  C                  A (sf)                39.00
  D                  BBB- (sf)             30.00
  E                  BB- (sf)              16.25
  Subordinate notes  NR                    51.95

  NR--Not rated.


BUSINESS JET 2019-1: S&P Assigns Prelim BB (sf) Rating to C Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Business Jet
Securities 2019-1 LLC's class A, B, and C fixed-rate notes.

The note issuance is an asset-backed securities (ABS) transaction
backed by 35 loans and leases, and the corresponding security or
ownership interests in the underlying aircraft, and shares and
beneficial interests in entities that directly and indirectly
receive aircraft portfolio cash flows, among others.

The preliminary ratings are based on information as of June 5,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The likelihood of timely interest on the class A notes
(excluding the post-anticipated repayment date (ARD) additional
interest or deferred post-ARD additional interest) on each payment
date; the timely interest on the class B notes (excluding the
post-ARD additional interest or deferred post-ARD additional
interest) when class A notes are no longer outstanding on each
payment date; and the ultimate payment of interest and principal on
the class A, B, and C notes on or before the legal final maturity
at the respective rating stress ('A', 'BBB', and 'BB',
respectively).

-- The approximately 67% loan-to-value ratio (LTV, based on the
aggregate asset value) on the class A notes, the 77% LTV on the
class B notes, and the 83% LTV on the class C notes.

-- A fairly diversified and young portfolio of business jets which
are either on loan, financial lease, or operational lease to
corporates or high net worth individuals.

-- The scheduled amortization profile, which is straight line over
12.5 years for the class A and B notes and seven years for the
class C notes. However, the amortization of all classes will switch
to full turbo after year seven.

-- The transaction's debt service coverage ratios, net loss
trigger, and utilization trigger, a failure of which will result in
sequential turbo amortization of the notes. The transaction's LTV
test (class A notes balance divided by aggregate asset value), a
failure of which will result in turbo amortization of the class A
notes until the test is brought back to compliance.

-- The subordination of class C notes' interest and principal to
the class A and B notes'interest and principal. The sequential
partial sweep payments to the class A and B notes to the extent of
25% of remaining available funds after all payments to the class A
and B notes for 85 payment dates from closing.

-- A liquidity reserve account, which is available to cover senior
expenses and interest on the class A and B notes. The amount
available will equal nine months of interest on the class A and B
notes, fully funded at closing.

  PRELIMINARY RATINGS ASSIGNED
  Business Jet Securities 2019-1 LLC

  Class       Rating       Amount (mil. $)
  A           A (sf)               417.400
  B           BBB (sf)              62.300
  C           BB (sf)               37.400


CIFC FUNDING 2019-III: Moody's Rates $34.2MM Class D Notes 'Ba3'
----------------------------------------------------------------
Moody's Investors Service has assigned ratings to five classes of
notes issued by CIFC Funding 2019-III, Ltd.

Moody's rating action is as follows:

  US$372,000,000 Class A-1A Senior Secured Floating Rate Notes
  due 2032 (the "Class A-1A Notes"), Assigned Aaa (sf)

  US$64,200,000 Class A-2 Senior Secured Floating Rate Notes due
  2032 (the "Class A-2 Notes"), Assigned Aa2 (sf)

  US$28,200,000 Class B Mezzanine Secured Deferrable Floating Rate
  Notes due 2032 (the "Class B Notes"), Assigned A2 (sf)

  US$35,400,000 Class C Mezzanine Secured Deferrable Floating Rate
  Notes due 2032 (the "Class C Notes"), Assigned Baa3 (sf)

  US$34,200,000 Class D Junior Secured Deferrable Floating Rate
  Notes due 2032 (the "Class D Notes"), Assigned Ba3 (sf)

The Class A-1A Notes, the Class A-2 Notes, the Class B Notes, the
Class C Notes and the Class D Notes are referred to herein,
collectively, as the "Rated Notes."

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.

CIFC Funding 2019-III is a managed cash flow CLO. The issued notes
will be collateralized primarily by broadly syndicated senior
secured corporate loans. At least 90.0% of the portfolio must
consist of first lien senior secured loans and eligible
investments, and up to 10.0% of the portfolio may consist of second
lien loans and unsecured loans. The portfolio is over 95% ramped as
of the closing date.

CIFC CLO Management II 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 Notes, the Issuer issued one other class
of secured 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 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: $600,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2831

Weighted Average Spread (WAS): 3.45%

Weighted Average Coupon (WAC): 6.50%

Weighted Average Recovery Rate (WARR): 47.50%

Weighted Average Life (WAL): 9 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 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.


COMM 2016-667M: S&P Affirms BB (sf) Rating on Class E Certificates
------------------------------------------------------------------
S&P Global Ratings affirmed its ratings on six classes of
commercial mortgage pass-through certificates from COMM 2016-667M
Mortgage Trust, 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.

"We affirmed our rating on the class X-A interest-only (IO)
certificates based on our criteria for rating IO securities, in
which the rating on the IO security would not be higher than that
of the lowest rated reference class. Class X-A's notional amount
references class A," S&P said.

This is a stand-alone (single borrower) transaction backed by a
portion of a 10-year fixed-rate IO whole mortgage loan secured by
the borrower's fee interest in a 273,983-sq.-ft. class A office
building at 667 Madison Ave. in midtown Manhattan. 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, which is due
primarily to lower occupancy and slightly higher operating expenses
for 2017 and 2018. S&P's analysis considered the property's premier
unique location and above-average historical performance, as well
as the rating agency's stabilized assumptions at issuance. The
rating agency then derived its sustainable in-place net cash flow
(NCF), which it divided by a 6.25% S&P capitalization rate and
added present value of incremental value ($22.7 million) to reach
86.0% stabilized occupancy to determine its expected-case value.
This yielded an overall S&P loan-to-value ratio and debt service
coverage (DSC) of 76.6% and 2.34x, respectively, on the whole loan
balance.

The IO whole mortgage loan had an initial and current $254.0
million balance, pays a per annum fixed rate of 3.199%, and matures
on Oct. 6, 2026. The whole loan is split into two pari passu A and
one subordinate B notes. According to the May 10, 2019, trustee
remittance report, the $143.0 million senior note A-1 and $71.0
million subordinate note B (totaling $214.0 million) are in the
trust. The $40.0 million senior note A-2 is in CD 2016-CD2 Mortgage
Trust, a U.S. CMBS transaction. 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, KeyBank Real Estate Capital
(KeyBank), confirmed that no mezzanine debt has been incurred to
date. In addition, the trust has not incurred any principal
losses.

KeyBank reported a DSC of 2.19x on the trust balance for the year
ended Dec. 31, 2018, and occupancy was 74.2% according to the March
31, 2019, rent roll. Based on the March 2019 rent roll, the five
largest tenants make up 37.5% of the collateral's total net
rentable area (NRA). In addition, 6.2%, 0.0%, and 2.3% of the NRA
have leases that expire in 2019, 2020, and 2021, respectively.
S&P's analysis also considered a future tenant, as per the March
2019 rent roll, with a five-year lease for 31,408 sq. ft.
commencing on July 1, 2019, which it expects will bring occupancy
up to 85.7%.

  RATINGS AFFIRMED
  COMM 2016-667M Mortgage Trust
  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)


COMM 2019-521F: S&P Assigns Prelim B- (sf) Rating to Class F Certs
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to COMM
2019-521F Mortgage Trust's commercial mortgage pass-through
certificates series 2019-521F.

The note issuance is a commercial mortgage-backed securities
transaction backed by a two-year, floating-rate commercial mortgage
loan totaling $242.0 million, with three, one-year extension
options.

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

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

  PRELIMINARY RATINGS ASSIGNED
  COMM 2019-521F Mortgage Trust
  Class             Rating            Amount ($)
  A                 AAA (sf)         108,585,000
  X-CP              BBB- (sf)         40,299,000(i)
  X-EXT             BBB- (sf)         40,299,000(i)
  B                 AA- (sf)          24,130,000
  C                 A- (sf)           18,107,000
  D                 BBB- (sf)         22,192,000
  E                 BB- (sf)          30,172,000
  F                 B- (sf)           26,714,000
  VRR interest(ii)  NR                12,100,000

(i)Notional balance. The notional amount of the class X
certificates will be equal to the certificate balance of the class
C and D certificates.
(ii)Non-offered vertical risk retention certificates, which will be
retained by Deutsche Bank AG, New York Branch as the retaining
sponsor.
NR--Not rated.


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

KEY RATING DRIVERS

Higher Loss Expectations; Fitch Loans of Concern (FLOCs): The
increased loss expectations reflect the transfer of two loans (4.1%
- Western Lights Shopping Center and Ba Mar Basin) to special
servicing since Fitch's last rating action in addition to the high
retail concentration (48%) and exposure to and/or vacant anchor
tenants including Macy's, JC Penney's, Sears, Nordstrom, and other
retailers such as Toys R Us; occupancy declines; secondary markets;
near-term rollover; and single tenant exposure. Eight loans (39.2%)
are considered FLOCs, of which six (35%) are currently on the
master servicer's watchlist.

The largest FLOC is the Dover Mall and Commons (16.6%) located in
Dover, DE with exposure to collateral anchors Macy's and Sears and
non-collateral anchor JC Penney. Sears closed this location and
vacated in August 2018. The space remains vacant. As of year-end
(YE) 2018, the mall's in-line occupancy was 70.4% with total mall
occupancy at 86.4%. The most recent servicer reported NOI is 1.39x
as of September 2018 down from 1.49x as of YE 2017 and 1.52x as of
YE 2016. There is approximately 26% upcoming rollover in 2019; 10%
in 2020. Per the most recent trailing twelve month November 2017
Tenant Sales report, the projected YE 2017 comparable in-line sales
for tenants less than 10,000 sf was $362/sf compared with $379/sf
as of YE 2016 and $369/sf at issuance. Dick's Sporting Goods
projected YE 2017 sales of $177/sf compared with $184/sf as of YE
2016. Macy's did not report sales.

Fitch's base case loss includes an additional 20% stress to NOI, on
top of using a higher minimum NOI haircut of 10% pool wide due to
the increased pool concentration. The additional 20% stress
reflects the lack of updated sales, declining/lack of anchor sales,
vacant Sears space, dated mall and near-term lease rollover
concerns. In addition, Fitch also performed an additional
sensitivity scenario on the loan, which assumed a 50% loss severity
of the loan's balance to reflect the potential for outsized losses.
Both the base case and the sensitivity scenario contributed to the
Negative Rating Outlooks assigned to class E and maintained on
class F.

The next largest FLOC is Albany Mall (5.1%) located in Albany, GA
with exposure to collateral anchor Dillard's and non-collateral
anchors Sears, JC Penney and Belk. Sears closed its location and
vacated in March 2017 and Toys R Us also closed and vacated in
August 2018. Both spaces remain vacant. Occupancy has fluctuated
since issuance due to tenants vacating. As of December 2018, the
property's occupancy has declined to 82% compared with 90% in March
2017. The most recent NOI DSCR as of September 2018 is 1.26x, down
from 1.39x at YE 2017 and below 1.72x at issuance. There is
approximately 15.5% upcoming rollover in 2019. Fitch requested
recent tenant sales from the master servicer, but they were not
received.

The third largest FLOC is Montgomery Plaza (5.1%) located in
Albuquerque, NM. The property is 70.9% ocupied with average rent of
$12.67 psf compared with YE 2016 ocupancy of 73.6% and 87% at YE
2015. Per the March 2019 rent roll, the tenant Technical Trades
Institute's Expansion Space (2.9%) expired in December 2018 and the
borrower is in lease negotiations with the tenant. The decline in
occupancy in 2016 was due to tenant IT'Z Pizza (53,670 sf
atthat13.6% NRA) vacating after their lease expired in May 2016 as
they closed the location. At Fitch's last review, the servicer
reported there was an LOI was received from Gravity Par with a 10
year term and rent of $11.19/sf for the IT'Z Pizza space; however,
the space remains vacant. Fitch requested an update on leasing
activity, but has not received a response.

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

The fifth largest FLOC is Feasterville Shopping Center (2.7%), a
110,632 sf retail center anchored by Giant Foods, located in
Feasterville, PA. The anchor tenant, Giant Foods, which occupied
47% GLA vacated their space in September 2018 at lease expiration
as the tenant moved to another location. Per the OSAR commentary,
Bell's Market is expected to occupy the space in July 2019.
Additional tenants include Altitude Trampoline (28%), with a leasee
expiring in April of 2027, which took over the vacant Office Max
space in 2017, and Lamberti's Cucina (4%) with a lease expiring in
December of 2020.

The remaining loan of concern (1.3%) is an office property in
Syracuse, NY with upcoming rollover of a large tenant and deferred
maintenance issues.

RATING SENSITIVITIES

The downgrade of Class F and the Negative Outlooks on classes E and
F reflect concerns with the Dover Mall & Commons loan as well as
the overall high retail concentration within the pool. Further
downgrades are possible if performance of the Dover Mall and
Commons and the larger Fitch loans of concern show further
declines. Fitch's additional sensitivity scenario incorporates a
50% loss on the Dover Mall and Commons loan to reflect the
potential for outsized losses. Rating Outlooks for classes A-4
through D remain Stable due to overall relatively stable
performance of the majority of the pool, continued amortization,
and defeasance. Rating Outlooks for classes PM-1 thru PM-5 remain
stable as these classes are secured by Providence Place Mall on a
stand-alone basis and performance of the mall remains stable since
issuance. Fitch's base case loss incorporated a higher NOI and cap
rate scenario pool wide (assuming a 10% NOI decline and 100 bps
increase to the default cap rates) and the ratings and Outlooks of
classes A-4 through D reflect this analysis. Upgrades may occur
with improved pool performance and additional paydown or
defeasance; however, they may be limited due to the high retail
concentration.

DBUBS 2011-LC3
   
Class A-4  Affirmed     AAAsf
   
Class A-M  Affirmed     AAAsf
   
Class B    Affirmed     AAAsf
  
Class C    Affirmed     Asf
   
Class D    Affirmed     BBB-sf
   
Class E    Affirmed     BBsf
  
Class F    Downgrade    B-sf
   
Class PM-1 Affirmed     AAAsf
  
Class PM-2 Affirmed     AAsf
  
Class PM-3 Affirmed     Asf
   
Class PM-4 Affirmed     BBBsf
  
Class PM-5 Affirmed     BBB-sf
  
Class PM-X Affirmed     AAAsf
   
Class X-A  Affirmed     AAAsf


FINANCE OF AMERICA 2018-HB1: Moody's Hikes Class M4 Debt to Ba1
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 13 tranches
backed by Nationstar HECM Loan Trust and Finance of America
Structured Securities Trust. The collateral backing these
transactions consists of first-lien inactive home equity conversion
mortgages (HECMs) covered by Federal Housing Administration (FHA)
insurance secured by properties in the US along with Real-Estate
Owned (REO) properties acquired through conversion of ownership of
reverse mortgage loans that are covered by FHA insurance.

The complete rating actions are as follows:

Issuer: Finance of America Structured Securities Trust 2018-HB1

Cl. M2, Upgraded to A1 (sf); previously on Oct 4, 2018 Definitive
Rating Assigned A3 (sf)

Cl. M3, Upgraded to Baa1 (sf); previously on Oct 4, 2018 Definitive
Rating Assigned Baa3 (sf)

Cl. M4, Upgraded to Ba1 (sf); previously on Oct 4, 2018 Definitive
Rating Assigned Ba3 (sf)

Issuer: Nationstar HECM Loan Trust 2018-1

Class M2, Upgraded to Aa2 (sf); previously on Nov 30, 2018 Upgraded
to Aa3 (sf)

Class M3, Upgraded to A1 (sf); previously on Nov 30, 2018 Upgraded
to A3 (sf)

Class M4, Upgraded to Baa1 (sf); previously on Nov 30, 2018
Upgraded to Baa3 (sf)

Issuer: Nationstar HECM Loan Trust 2018-2

Cl. M1, Upgraded to Aa2 (sf); previously on Jul 30, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. M2, Upgraded to A1 (sf); previously on Jul 30, 2018 Definitive
Rating Assigned A3 (sf)

Cl. M3, Upgraded to Baa2 (sf); previously on Jul 30, 2018
Definitive Rating Assigned Baa3 (sf)

Issuer: Nationstar HECM Loan Trust 2018-3

Cl. M1, Upgraded to Aa2 (sf); previously on Nov 27, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. M2, Upgraded to A2 (sf); previously on Nov 27, 2018 Definitive
Rating Assigned A3 (sf)

Cl. M3, Upgraded to Baa2 (sf); previously on Nov 27, 2018
Definitive Rating Assigned Baa3 (sf)

Cl. M4, Upgraded to Ba2 (sf); previously on Nov 27, 2018 Definitive
Rating Assigned Ba3 (sf)

RATINGS RATIONALE

The rating actions are primarily due to the buildup in credit
enhancement since issuance due to the liquidations to date. The
current pool factors are 63% for Nationstar HECM Loan Trust 2018-1,
72% for Nationstar HECM Loan Trust 2018-2, 78% for Finance of
America Structured Securities Trust 2018-HB1 and 88% for Nationstar
HECM Loan Trust 2018-3. Additionally, a large percentage of the
loans that were Due and Payable at the time of closing have now
moved into REO or Foreclosure, indicating that the collections from
these loans are either imminent or in the near future. The rating
actions take into consideration the most updated performance which
includes improvements in credit enhancement and liquidations to
date.

The methodologies used in these ratings were "Moody's Approach to
Rating Securitisations Backed by Non-Performing and Re-Performing
Loans" published in February 2019 and "Moody's Global Approach to
Rating Reverse Mortgage Securitizations" published in May 2015.

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of stresses could drive the
ratings down. Transaction performance depends greatly on the US
macro economy and housing market. Property markets could
deteriorate from its original expectations resulting in
depreciation in the value of the mortgaged property and slower
property sales.

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.


FREDDIE MAC 2019-HRP1: S&P Assigns Ratings to 50 Classes of Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Freddie Mac
STACR Trust 2019-HRP1's notes.

The note issuance is a residential mortgage-backed securities
(RMBS) transaction backed by high original loan-to-value, seasoned,
fully amortizing, 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 preliminary ratings are based on information as of June 6,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary 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, which consists of mostly prime, high original loan-to-value,
seasoned, fully amortizing, fixed-rate mortgages partly 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 the 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.

  PRELIMINARY RATINGS ASSIGNED
  Freddie Mac STACR Trust 2019-HRP1

  Class        Rating             Amount ($)
  A-H(i)       NR              5,377,031,554
  M-1          A+ (sf)            33,000,000
  M-1H(i)      NR                 13,254,035
  M-2          BBB+ (sf)         112,000,000
  M-2R         BBB+ (sf)         112,000,000
  M-2S         BBB+ (sf)         112,000,000
  M-2T         BBB+ (sf)         112,000,000
  M-2U         BBB+ (sf)         112,000,000
  M-2I         BBB+ (sf)         112,000,000
  M-2A         A- (sf)            56,000,000
  M-2AR        A- (sf)            56,000,000
  M-2AS        A- (sf)            56,000,000
  M-2AT        A- (sf)            56,000,000
  M-2AU        A- (sf)            56,000,000
  M-2AI        A- (sf)            56,000,000
  M-2AH(i)     NR                 22,053,684
  M-2B         BBB+ (sf)          56,000,000
  M-2BR        BBB+ (sf)          56,000,000
  M-2BS        BBB+ (sf)          56,000,000
  M-2BT        BBB+ (sf)          56,000,000
  M-2BU        BBB+ (sf)          56,000,000
  M-2BI        BBB+ (sf)          56,000,000
  M-2RB        BBB+ (sf)          56,000,000
  M-2SB        BBB+ (sf)          56,000,000
  M-2TB        BBB+ (sf)          56,000,000
  M-2UB        BBB+ (sf)          56,000,000
  M-2BH(i)     NR                 22,053,684
  M-3          BB+ (sf)           52,000,000
  M-3R         BB+ (sf)           52,000,000
  M-3S         BB+ (sf)           52,000,000
  M-3T         BB+ (sf)           52,000,000
  M-3U         BB+ (sf)           52,000,000
  M-3I         BB+ (sf)           52,000,000
  M-3A         BBB- (sf)          26,000,000
  M-3AR        BBB- (sf)          26,000,000
  M-3AS        BBB- (sf)          26,000,000
  M-3AT        BBB- (sf)          26,000,000
  M-3AU        BBB- (sf)          26,000,000
  M-3AI        BBB- (sf)          26,000,000
  M-3AH(i)     NR                 10,135,965
  M-3B         BB+ (sf)           26,000,000
  M-3BR        BB+ (sf)           26,000,000
  M-3BS        BB+ (sf)           26,000,000
  M-3BT        BB+ (sf)           26,000,000
  M-3BU        BB+ (sf)           26,000,000
  M-3BI        BB+ (sf)           26,000,000
  M-3RB        BB+ (sf)           26,000,000
  M-3SB        BB+ (sf)           26,000,000
  M-3TB        BB+ (sf)           26,000,000
  M-3UB        BB+ (sf)           26,000,000
  M-3BH(i)     NR                 10,135,965
  B-1          B+ (sf)            42,000,000
  B-1A         BB- (sf)           21,000,000
  B-1AR        BB- (sf)           21,000,000
  B-1AI        BB- (sf)           21,000,000
  B-1AH(i)     NR                  7,908,772
  B-1B         B+ (sf)            21,000,000
  B-1BH(i)     NR                  7,908,772
  B-2          NR                 42,000,000
  B-2A         NR                 21,000,000
  B-2AR        NR                 21,000,000
  B-2AI        NR                 21,000,000
  B-2AH(i)     NR                  7,908,772
  B-2B         NR                 21,000,000
  B-2BH(i)     NR                  7,908,772
  B-3H(i)      NR                 14,454,386

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


GS MORTGAGE 2016-GS4: S&P Affirms B-(sf) Rating on Cl. X-225 Certs
------------------------------------------------------------------
S&P Global Ratings affirmed its ratings on 11 loan-specific
(nonpooled) classes of commercial mortgage pass-through
certificates from GS Mortgage Securities Trust 2016-GS4, a U.S.
commercial mortgage-backed securities (CMBS) transaction.

The affirmations on the class AMA-A, AMA-B, AMA-C, and AMA-D raked
certificates reflect S&P's re-evaluation of the AMA Plaza loan (the
AMA). The AMA raked certificates derived 100% of their cash flow
from a subordinate nonpooled component of the whole loan. The
rating agency's property analysis concluded relatively stable
operating performance with an S&P debt service coverage (DSC) of
1.88x, and using a capitalization rate of 7.00%, it derived an S&P
loan-to-value (LTV) ratio of 104.0% on the whole loan balance.

The affirmations on the class 225-A, 225-B, 225-C, 225-D, and 225-E
raked certificates reflect S&P's re-evaluation of the 225 Bush
Street loan (the 225). The 225 raked certificates derive 100% of
their cash flow from a subordinate nonpooled component of the whole
loan. The rating agency's property analysis considered the
relatively stable operating performance with an S&P DSC of 1.88x,
and using a capitalization rate of 7.25%, it derived an S&P LTV
ratio of 95.8% on the whole loan balance.

The affirmations on the class X-AMA and X-225 interest-only (IO)
certificates is based on S&P's criteria for rating IO securities,
in which the ratings on the IO securities would not be higher than
that of the lowest-rated reference class. The notional amount on
class X-AMA references classes AMA-A, AMA-B, AMA-C, and AMA-D; and
class X-225 references classes 225-A, 225-B, 225-C, 225-D, and
225-E.

Since S&P only rates the loan-specific certificates, its
property-level analysis included a re-evaluation of the AMA Plaza
and 225 Bush Street whole loans using servicer-reported net
operating income for 2017 and 2018, the borrowers' 2019 budgets,
and the most recent available rent rolls.

As of the May 10, 2019, trustee remittance report, the AMA
nonpooled classes have an aggregate balance of $101.6 million and
the 225 nonpooled classes have an aggregate balance of $113.0
million, the balances of which were unchanged from issuance. The
nonpooled classes have not incurred any principal losses to date.

Details on the two aforementioned loans are as follows:

-- The AMA Plaza loan has a $304.0 million whole loan balance that
is split into a $100.0 million trust senior note A-1 that
references the pooled certificates, a $30.0 million nontrust senior
note A-2 that is pari passu with the note A-1, a $101.6 million
subordinate note B that is junior to the senior notes and
references the AMA loan-specific certificates, and a $72.4 million
nontrust subordinate note C that is junior to the senior notes and
note B. The whole loan is IO, pays a 3.5255% weighted average fixed
interest rate, and matures on Oct. 6, 2021. The whole loan is
secured by floors 14 and above of a 52-story class A office
building totaling 1.12 million sq. ft. and an adjacent 902-stall
parking garage in Chicago. The master servicer, Wells Fargo Bank
N.A. (Wells Fargo), reported a 2.35x DSC on the whole loan balance
for the year ended Dec. 31, 2018, and occupancy was 95.1% according
to the March 31, 2019, rent roll. Based on the March 2019 rent
roll, the five largest tenants make up 65.6% of the collateral net
rentable area (NRA). In addition, 0.4%, 2.7%, and 0.3% of the NRA
have leases that expire in 2019, 2020, and 2021, respectively.

-- The 225 Bush Street loan has a $235.0 million whole loan
balance that is divided into a $100.0 million trust senior note A-1
that references the pooled certificates, a $22.0 million nontrust
senior note A-2 that is pari passu with the note A-1, and a $113.0
million subordinate note B that is junior to the senior notes and
references the 225 loan-specific certificates. The whole loan is
IO, pays a 3.951% weighted average fixed interest rate and matures
on Nov. 6, 2021. The whole loan is secured by a 22-story,
575,363-sq.-ft. office building in San Francisco. Wells Fargo
reported a 2.29x DSC on the whole loan balance for the nine months
ended Sept. 30, 2018, and occupancy was 86.7% according to the Dec.
31, 2018, rent roll. Based on the December 2018 rent roll, the five
largest tenants make up 47.7% of the collateral NRA. Specifically,
while the lease of the largest tenant, Twitch Interactive (14.4% of
the NRA) expires in August 2021, according to media reports, the
tenant has signed a lease totaling 185,000 sq. ft. in another
building in 2016. In addition, 5.8%, 15.7%, and 22.7% of the NRA
have leases that expire in 2019, 2020, and 2021, respectively, and
3.6% of the NRA have leases that were on a month-to-month basis.

  RATINGS AFFIRMED
  GS Mortgage Securities Trust 2016-GS4
  Commercial mortgage pass-through certificates
  Class     Rating
  AMA-A     AA- (sf)
  AMA-B     A- (sf)
  AMA-C     BBB- (sf)
  AMA-D     BB- (sf)
  X-AMA     BB- (sf)
  225-A     AA- (sf)
  225-B     A- (sf)
  225-C     BBB- (sf)
  225-D     BB- (sf)
  225-E     B- (sf)
  X-225     B- (sf)


GS MORTGAGE 2019-SOHO: Moody's Gives (P)Ba2) Rating to HRR Certs
----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to eight
classes of CMBS securities, issued by GS Mortgage Securities
Corporation Trust 2019-SOHO, Commercial Mortgage Pass-Through
Certificates, Series 2019-SOHO

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

Cl. X-CP*, Assigned (P)Baa1 (sf)

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

Cl. C, Assigned (P)A3 (sf)

Cl. D, Assigned (P)Baa3 (sf)

Cl. E, Assigned (P)Ba3 (sf)

Cl. F, Assigned (P)B2 (sf)

Cl. HRR, Assigned (P)B2 (sf)

  * Reflects interest-only classes

RATINGS RATIONALE

The certificates are collateralized by one floating rate loan
secured by a fee simple interest in One SoHo Square, a 791,808 SF,
newly-redeveloped office property (with ground floor retail)
located in New York, NY. The ratings are based on the collateral
and the structure of the transaction.

Moody's approach to rating CMBS deals combines both commercial real
estate and structured finance analysis. Based on commercial real
estate analysis, Moody's determines the credit quality of each
mortgage loan and calculates an expected loss on a loan specific
basis. Under structured finance, the credit enhancement for each
certificate typically depends on the expected frequency, severity,
and timing of future losses. Moody's also considers a range of
qualitative issues as well as the transaction's structural and
legal aspects.

The credit risk of loans is determined primarily by two factors: 1)
Moody's assessment of the probability of default, which is largely
driven by each loan's DSCR, and 2) Moody's assessment of the
severity of loss upon a default, which is largely driven by each
loan's LTV ratio.

Moody's DSCR is based on its assessment of the portfolio's
stabilized NCF. The Moody's first mortgage DSCR is 1.94x and
Moody's first mortgage DSCR at a 9.25% stressed constant is 0.82x.

The trust loan balance of $730.0 million represents a Moody's LTV
ratio of 108.4% which is in line with the 2018 Large Loan and
Single Asset/Single Borrower CMBS transaction average 108.3%. With
the additional debt, the Moody's total debt LTV ratio rises to
133.7%.

Moody's also considers both loan level diversity and property level
diversity when selecting a ratings approach. The subject
transaction is secured by a single property.

Positive features of the transaction include location, property
quality, credit tenancy, leasing momentum, and strong sponsorship.
Offsetting these strengths are the lack of diversification, the
loan's floating-rate and interest-only mortgage loan profile, lack
of ongoing reserves, and credit negative loan structure and legal
features.

Moody's also grades properties on a scale of 0 to 5 (best to worst)
and considers those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The collateral's
overall property quality grade is 0.75.

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

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

Moody's analysis considers the following inputs to calculate the
proposed IO rating based on the published methodology: original and
current bond ratings and credit estimates; original and current
bond balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology.

These ratings: (a) are based solely on information in the public
domain and/or information communicated to Moody's by the issuer at
the date it was prepared and such information has not been
independently verified by Moody's and (b) must be construed solely
as a statement of opinion and not a statement of fact or an offer,
invitation, inducement or recommendation to purchase, sell or hold
any securities or otherwise act in relation to the issuer or any
other entity or in connection with any other matter. Moody's does
not guarantee or make any representation or warranty as to the
correctness of any information, rating or communication relating to
the issuer. Moody's shall not be liable in contract, tort,
statutory duty or otherwise to the issuer or any other third party
for any loss, injury or cost caused to the issuer or any other
third party, in whole or in part, including by any negligence (but
excluding fraud, dishonesty and/or willful misconduct or any other
type of liability that by law cannot be excluded) on the part of,
or any contingency beyond the control of Moody's, or any of its
employees or agents, including any losses arising from or in
connection with the procurement, compilation, analysis,
interpretation, communication, dissemination, or delivery of any
information or rating relating to the issuer.

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

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range may
indicate that the collateral's credit quality is stronger or weaker
than Moody's had previously anticipated. Factors that may cause an
upgrade of the ratings include significant loan paydowns or
amortization, an increase in the pool's share of defeasance or
overall improved pool performance. Factors that may cause a
downgrade of the ratings include a decline in the overall
performance of the pool, loan concentration, increased expected
losses from specially serviced and troubled loans or interest
shortfalls.

Moody's ratings address only the credit risks associated with the
transaction. Other non-credit risks have not been addressed and may
have a significant effect on yield to investors.


HERTZ VEHICLE II: Fitch Rates $48.51MM Class D Notes 'BBsf'
-----------------------------------------------------------
Fitch Ratings has assigned the following ratings and Outlooks to
the series 2019-2 ABS notes issued by Hertz Vehicle Financing II LP
(HVF II):

HVF II, Series 2019-2

  -- $576,525,000 class A notes 'AAAsf'; Outlook Stable;

  -- $132,752,000 class B notes 'Asf'; Outlook Stable;

  -- $40,723,000 class C notes 'BBBsf'; Outlook Stable;

  -- $48,510,000 class D notes 'BBsf'; Outlook Stable;

  -- $46,474,000 class RR notes 'NRsf'.

KEY RATING DRIVERS

Transaction Analysis: Fitch analyzed the structural features
present in the series, including monthly mark-to-market vehicle
value tests and minimum monthly vehicle depreciation, by stressing
the liquidation timing, vehicle depreciation, disposition losses
and expected carrying costs of the transaction at various rating
levels to determine an expected loss level (ELL) for each rating
category. Credit enhancement (CE) consists of subordination,
letter(s) of credit and dynamic overcollateralization (OC) that
will shift according to the fleet mix. The levels for the series
cover or are well within range of Fitch's maximum and minimum ELL
for each class under the respective ratings.

Collateral Analysis - Diverse Vehicle Fleet: HVF II's fleet is
deemed diverse under Fitch's criteria due to the high degree of
manufacturer, model, segment and geographic diversification in the
Hertz, Dollar and Thrifty rental fleets. Concentration limits,
based on a number of characteristics, are present to help mitigate
risks related to overconcentrations. Original Equipment
Manufacturers (OEMs) with PV concentrations in HVF II have all
improved their financial position in recent years and are well
positioned to meet repurchase agreement obligations. As of the
cutoff date, 97.3% of the fleet is from OEMs with an
investment-grade Issuer Default Rating (IDR).

Vehicle Value Risks - Fluctuating Fleet Performance: Depreciation
experience within Hertz's fleet has been volatile since 2014 for
risk vehicles and remains elevated due to weak wholesale values for
compact cars, a segment that comprises the significant majority of
the HVF II fleet. Despite this, vehicle disposition losses have
been minimal for both risk and program vehicles and depreciation
for 2018 were relatively less volatile than recent years.

Adequate Fleet Servicer and Fleet Management: Hertz is deemed an
adequate servicer and administrator, as evidenced by its historical
fleet management and securitization performance to date. Sagent
Auto, LLC, which is wholly owned by Fiserv, Inc., is the backup
disposition agent, while Lord Securities Corporation (Lord
Securities) is the backup administrator.

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

Macroeconomic and Auto Industry Risks: The economic environment and
state of the travel and auto industries and the wholesale vehicle
market can have a material impact on the ratings. Fitch took these
risks into consideration as well as future expectations and their
impact on a transaction, when deriving the ELL for this series.

RATING SENSITIVITIES

Fitch's rating sensitivity analysis focuses on two scenarios
involving potentially extreme market disruptions that would force
the agency to redefine its stress assumptions. The first examines
the effect of moving Fitch's bankruptcy/liquidation timing scenario
to eight months at 'AAAsf' with subsequent increases to each rating
level. The second considers the effect of moving the disposition
stresses to the higher end of the range at each rating level for a
diverse fleet. For example, the 'AAAsf' stress level would move
from 24% to 28%. Finally, the last example shows the impact of both
stresses on the structure. The purpose of these stresses is to
demonstrate the potential rating impact on a transaction if one or
a combination of these scenarios occurs.

Fitch determined ratings by applying expected loss levels for
various rating scenarios until the proposed CE exceeded the
expected losses from the sensitivity. For all sensitivity
scenarios, the class A notes show little sensitivity under each of
the scenarios with potential downgrades only occurring under the
combined stress scenario. Two-notch to one-level downgrades would
occur to the subordinate notes under each scenario with greater
sensitivity to the disposition stress scenario. Under the combined
scenario, the subordinate notes would be placed under greater
stress and could experience multiple-level downgrades.

A sufficient increase in either the timing of the liquidation of
the fleet or increases to disposition fees could cause a downgrade
of the class A notes to 'AAsf'. To approach non-investment-grade
rating levels or down to 'CCCsf', in addition to the combined
scenario, depreciation costs would need to increase to previously
unseen levels for the platform, increasing at least to two times
the highest monthly depreciation levels seen for both the program
and non-program vehicles at the height of the recession.


HILDENE TRUPS 2019-P12B: Moody's Rates $42.7MM Class B Notes 'Ba2'
------------------------------------------------------------------
Moody's Investors Service has assigned ratings to two classes of
notes issued by Hildene TruPS Resecuritization 2019-P12B, LLC.

Moody's rating action is as follows:

  US$52,250,000 Class A Notes due December 2033 (the "Class A
  Notes"), Definitive Rating Assigned A1 (sf)

  US$42,700,000 Class B Notes due December 2033 (the "Class B
  Notes"), Definitive Rating Assigned Ba2 (sf)

The Class A Notes and the Class B Notes are referred to herein,
together, as the "Rated Notes."

RATINGS RATIONALE

The rationale for the ratings is based on a consideration of the
risks associated with the portfolio of Preferred Term Securities
XII, Ltd. and structure as described in its methodology.

The Rated Notes are secured by the following securities that were
issued by the Underlying TruPS CDO on December 17, 2003:

  US$118,050,000 of the $205,900,000 Floating Rate Class B-1
  Mezzanine Notes due December 2033 (the "Class B-1 Notes")

  US$3,000,000 of the $19,000,000 Fixed/Floating Rate Class
  B-2 Mezzanine Notes due December 2033 (the "Class B-2
  Notes")

  US$14,200,000 of the $37,700,000 Fixed/Floating Rate Class
  B-3 Mezzanine Notes due December 2033 (the "Class B-3
  Notes")

The Class B-1 Notes, the Class B-2 Notes and the Class B-3 Notes
are referred to herein, collectively as the "Underlying
Securities".

Hildene Structured Advisors, LLC will serve as collateral servicer
for this transaction. The transaction prohibits any asset purchases
or substitutions at any time.

In addition to the Rated Notes, the Issuer issued one class of
subordinated notes.

The transaction incorporates a par coverage test which, if
triggered, divert interest proceeds to pay down the notes in order
of seniority. The transaction also includes an interest diversion
feature during which, from the closing date through the March 2021
payment date, 100% of the interest at a junior step in the priority
of interest payments will be used to pay the principal on the Class
A Notes until the Class A Notes' principal has been paid in full,
then to the payment of principal of the Class B Notes. The interest
diversion feature resumes on the March 2026 payment date at which
point 60% of the interest at that step in the priority of payments
will be applied to paying down the notes.

The portfolio of the Underlying TruPS CDO consists of mainly TruPS
issued by US regional and community banks, the majority of which
Moody's does not publicly rate. Moody's assesses the default
probability of bank obligors that do not have public ratings
through credit scores derived using RiskCalc, an econometric model
developed by Moody's Analytics. Moody's evaluation of the credit
risk of the bank obligors in the pool relies on FDIC Q4-2018
financial data. Moody's assumes a fixed recovery rate of 10% for
bank obligations.

Moody's ratings on the Rated Notes took into account a stress
scenario for highly levered bank holding company issuers. The
Underlying TruPS CDO portfolio includes trust preferred securities
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 assigned
ratings.

For modeling purposes, Moody's used the following base-case
assumptions for the Underlying TruPS CDO's portfolio:

Par amount: $376,762,000

Weighted Average Rating Factor (WARF): 570

Weighted Average Spread (WAS): 2.85%

Weighted Average Recovery Rate (WARR): 10.0%

Weighted Average Life (WAL): 9.68 years

In addition to the quantitative factors that Moody's explicitly
models, qualitative factors were part of the rating committee
consideration. Moody's considers the structural protections in the
transaction, the risk of an event of default, the legal environment
and specific documentation features. All information available to
rating committees, including macroeconomic forecasts, inputs from
other Moody's analytical groups, market factors, and judgments
regarding the nature and severity of credit stress on the
transaction, influenced the final rating decision.

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.


JP MORGAN 2004-C2: Fitch Hikes Class N Certs Rating to 'BBsf'
-------------------------------------------------------------
Fitch Ratings has upgraded two classes and affirmed one class of
J.P. Morgan Chase Commercial Mortgage Securities Corp., commercial
mortgage pass-through certificates, series 2004-C2 (JPMCC 2004-C2).


KEY RATING DRIVERS

Improved Loss Expectations: The upgrades and removal from Rating
Watch Evolving of classes M and N reflect the paydown of the
Employers Reinsurance Corporation II loan (59.6% of pool balance at
Fitch's last rating action). The classes were placed on Rating
Watch Evolving due to the binary outcome and their reliance on
recoveries from the Employers Reinsurance Corporation II loan,
which was secured by a suburban office property located in Kansas
City, MO. Fitch was awaiting confirmation that the former
subtenant, Burns & McDonnell Engineering Company, had executed a
direct lease for the entire building. Burns & McDonnell previously
subleased 59.6% of the NRA from Swiss RE, which vacated in October
2006. The borrower had confirmed with the master servicer their
intention to pay off the loan following the execution of the lease.
Were the lease not to have been executed, losses would have been
probable. The loan paid in full on April 1, 2019, one month prior
to its May 1, 2019 anticipated repayment date, and the payoff was
reported on the May 2019 remittance.

Pool Concentration: The pool is highly concentrated with only nine
of the original 134 loans remaining. Of the remaining loans, four
(28.4%) are fully defeased, four (52.2%) are fully amortizing, and
one (19.4%) is in special-servicing.

The specially-serviced loan, Hillside MHP Portfolio (19%), is
secured by a portfolio of 122 manufactured homes spanning three
communities in Mount Morris, Nunda and Silver Springs, NY. The loan
transferred to special servicing in April 2014 for maturity
default. A receiver was appointed in August 2016 and a Motion for
Summary Judgment (MSJ) was filed in October 2016. The foreclosure
and note sale procedures will occur following the court's ruling on
the MSJ, which remains pending.

Increased Credit Enhancement: As of the May 2019 remittance report,
the pool's aggregate principal balance has been reduced by 99.1% to
$10 million from $1.06 billion at issuance. Since Fitch's last
rating action, in addition to the Employers Reinsurance Corporation
II loan paying in full, the North Shore Apartments loan (8% of
current pool balance) is fully-defeased. Realized losses to date
total 1.2% of the original pool balance. Interest shortfalls are
currently affecting class P and the non-rated class NR.

RATING SENSITIVITIES

The Stable Outlooks on classes M and N reflect increased credit
enhancement from significant paydown and defeasance since Fitch's
last rating action. Upgrades are unlikely due to adverse selection,
remaining collateral quality and pool concentrations. A downgrade
to the distressed class P is likely as losses are realized.

J. P. Morgan Chase Commercial Mortgage Securities Corp. 2004-C2
   
Class M (46625M4K2); Upgraded to AAAsf

Class N (46625M4M8); Upgraded to BBsf

Class P (46625M4P1); Affirmed at Csf



JP MORGAN 2008-C2: Fitch Cuts $94.8MM A-M Debt Rating to 'Csf'
--------------------------------------------------------------
Fitch Ratings has downgraded one class and affirmed 16 classes of
J.P. Morgan Chase Commercial Mortgage Securities Trust series
2008-C2.

KEY RATING DRIVERS

Losses Considered Inevitable: Due to the modification of the Westin
Portfolio (96% of the pool), principal losses to all remaining
classes are considered inevitable.

The Westin Portfolio loan (96% of the pool) is secured by two
Westin resort hotels: the 487-room Westin La Paloma in Tucson, AZ
and the 416-room oceanfront Westin Hilton Head, in Hilton Head, SC.
The loan also has a pari passu piece, which is in a transaction not
rated by Fitch. The loan transferred to the special servicer in
2008 due to a payment default and significant drop in property
performance related to the financial crisis. The borrower
subsequently filed for bankruptcy.

As part of the bankruptcy, the loan was modified in 2012 to a
30-year loan term and a 0% interest rate, with fixed monthly
payments of $248,800 ($500,000 total for both transactions). The
payments are applied to the outstanding loan principal balance. The
loan was returned to the master servicer in September 2018 and now
has a final maturity in 2033 at which time a balloon payment of
approximately $60 million is due.

As a result of this modification, the transaction is incurring
monthly modification expenses of approximately $584,000 per month.
Per the transaction waterfall, the incoming principal is applied as
a realized loss to the most subordinate class and used to pay
interest due to the senior class AM bonds. As such, realized losses
of approximately $3 million per year will be applied to class AJ
until it is reduced to zero then will begin to affect class AM.
Losses to the AM class are thus considered inevitable given the
mismatch between the amounts due to the bondholders and the
incoming cash amounts from the loan.

The Westin portfolio performance as of September 2018; occupancy
was 70%, ADR was $149.44, RevPAR was $104.6, and the debt service
coverage ratio was 4.17x.

The second remaining loan, Lofts at New Roc (4% of the pool), is
secured by a 98 unit Class A cooperative housing property. The
property was built in 2001 and renovated in 2006 and is located in
New Rochelle, NY. The property consists of studio, 1, 2 and 3
bedroom units, with 43 being owner occupied or sponsor owned and 55
units operated by a Canadian investment bank as rental units. The
borrower hasn't provided YE 2017 or YE 2018 financials. The loan
matures in March 2022.

Decreased Credit Enhancement: As of the May 2019 remittance report,
the pool balance has been reduced by 90.9% to $105.7 million from
$1.166 billion at issuance. To date, realized losses total $214.3
million (18.4% of original pool balance). Cumulative interest
shortfalls totaling $58.5 million are currently affecting classes
A-M through NR. Since the prior rating action in June 2018, one
loan totaling $4.9 million has paid off. Monthly principal losses
of approximately $250,000 will affect the transaction for the
remaining life of the deal.

RATING SENSITIVITIES

A further downgrade to the remaining distressed class will occur as
losses are realized. No upgrades are expected due to inevitable
principal losses to the remaining classes as a result of the
bankruptcy modification to the Westin Portfolio loan.

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

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

Fitch has downgraded the following class:

  -- $94.8 million class A-M to 'Csf' from 'CCsf'; Revise RE from
25% to 50%.

Fitch has affirmed the following ratings:

  -- $10.9 million class A-J at 'Dsf'; RE 0%;

  -- $0 class B at 'Dsf'; RE 0%;

  -- $0 class C at 'Dsf'; RE 0%;

  -- $0 class D at 'Dsf'; RE 0%;

  -- $0 class E at 'Dsf'; RE 0%;

  -- $0 class F at 'Dsf'; RE 0%;

  -- $0 class G at 'Dsf'; RE 0%;

  -- $0 class H at 'Dsf'; RE 0%;

  -- $0 class J at 'Dsf'; RE 0%;

  -- $0 class K at 'Dsf'; RE 0%;

  -- $0 class L at 'Dsf'; RE 0%;

  -- $0 class M at 'Dsf'; RE 0%;

  -- $0 class N at 'Dsf'; RE 0%;

  -- $0 class P at 'Dsf'; RE 0%;

  -- $0 class Q at 'Dsf'; RE 0%;

  -- $0 class T at 'Dsf'; RE 0%.

Class 'NR' is not rated.


JP MORGAN 2019-INV1: Moody's Assigns B3 Rating on Class B-5 Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to 22
classes of residential mortgage-backed securities issued by J.P.
Morgan Mortgage Trust 2019-INV1. The ratings range from Aaa (sf) to
B3 (sf). JPMMT 2019-INV1 is the first JPMMT transaction backed by
100% investment property loans.

The certificates are backed by 919 25 and 30-year, fully-amortizing
fixed-rate investment property mortgage loans with a total balance
of $338,840,065 as of the May 1, 2019, cut-off date. Similar to
prior JPMMT transactions, JPMMT 2019-INV1 includes conforming
mortgage loans (86.1% by loan balance) mostly originated by
JPMorgan Chase Bank, National Association (Chase), AmeriHome
Mortgage Company, LLC (AmeriHome) and Caliber Home Loans, Inc.
(Caliber) underwritten to the government sponsored enterprises
(GSE) guidelines. The remaining 13.9% is comprised of prime jumbo
non-conforming investor mortgages purchased by J.P. Morgan Mortgage
Acquisition Corp. (JPMMAC), sponsor and mortgage loan seller, from
various originators and aggregators. Chase, AmeriHome and Caliber
originated 54.2%, 18.2% and 6.8% of the mortgage pool,
respectively.

Chase, New Penn Financial, LLC d/b/a Shellpoint Mortgage Servicing
(Shellpoint) and AmeriHome will be the servicers for majority of
the pool. Shellpoint will act as interim servicer for these
mortgage loans from May 30, 2019, until the servicing transfer
date, which is expected to occur on or about July 1, 2019. After
the servicing transfer date, these mortgage loans will be serviced
by Chase. With respect to the Mortgage Loans serviced by AmeriHome,
Cenlar FSB will be the subservicer.

The servicing fee for loans serviced by Chase and Shellpoint will
be based on a step-up incentive fee structure with a monthly base
fee of $20 per loan and additional fees for delinquent or defaulted
loans. All other servicers will be paid a monthly flat servicing
fee equal to one-twelfth of 0.25% of the remaining principal
balance of the mortgage loans. Nationstar Mortgage LLC will be the
master servicer and Citibank, N.A. will be the securities
administrator and Delaware trustee. Pentalpha Surveillance LLC will
be the representations and warranties breach reviewer.
Distributions of principal and interest and loss allocations are
based on a typical shifting interest structure that benefits from
senior and subordination floors.

The complete rating actions are as follows:

Issuer: J.P. Morgan Mortgage Trust 2019-INV1

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-4, Definitive Rating Assigned Aaa (sf)

Cl. A-5, Definitive Rating Assigned Aaa (sf)

Cl. A-6, Definitive Rating Assigned Aaa (sf)

Cl. A-7, Definitive Rating Assigned Aaa (sf)

Cl. A-8, Definitive Rating Assigned Aaa (sf)

Cl. A-9, Definitive Rating Assigned Aaa (sf)

Cl. A-10, Definitive Rating Assigned Aaa (sf)

Cl. A-11, Definitive Rating Assigned Aaa (sf)

Cl. A-12, Definitive Rating Assigned Aaa (sf)

Cl. A-13, Definitive Rating Assigned Aaa (sf)

Cl. A-14, Definitive Rating Assigned Aa1 (sf)

Cl. A-15, Definitive Rating Assigned Aa1 (sf)

Cl. A-16, Definitive Rating Assigned Aaa (sf)

Cl. A-17, Definitive Rating Assigned Aaa (sf)

Cl. B-1, Definitive Rating Assigned Aa3 (sf)

Cl. B-2, Definitive Rating Assigned A2 (sf)

Cl. B-3, Definitive Rating Assigned Baa2 (sf)

Cl. B-4, Definitive Rating Assigned Ba2 (sf)

Cl. B-5, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 0.80%
in a base scenario and reaches 9.65% at a stress level consistent
with the Aaa (sf) ratings.

Moody's calculated losses on the pool using its US Moody's
Individual Loan Analysis (MILAN) model based on the loan-level
collateral information as of the cut-off date. Loan-level
adjustments to the model results included adjustments to
probability of default for higher and lower borrower debt-to-income
ratios (DTIs), for borrowers with multiple mortgaged properties,
self-employed borrowers, and for the default risk of Homeownership
association (HOA) properties in super lien states. Its final loss
estimates also incorporate adjustments for origination quality and
the financial strength of representation & warranty (R&W)
providers.

Moody's bases its definitive ratings on the certificates on the
credit quality of the mortgage loans, the structural features of
the transaction, the origination quality, the servicing
arrangement, the strength of the third party due diligence and the
R&W framework of the transaction.

Aggregation/Origination Quality

Moody's considers JPMMAC's aggregation platform to be adequate and
it did not apply a separate loss-level adjustment for aggregation
quality. In addition to reviewing JPMMAC as an aggregator, it has
also reviewed the originators contributing a significant percentage
of the collateral pool. For these originators, it  reviewed their
underwriting guidelines and their policies and documentation (where
available). Moody's increased its base case and Aaa (sf) loss
expectit does not have clear insight into the underwriting
practices, quality control and credit risk management. Moody's did
not make an adjustment for GSE-eligible loans, regardless of the
originator, since those loans were underwritten in accordance with
GSE guidelines.

Servicing arrangement

Moody's considers the overall servicing arrangement for this pool
to be adequate given the strong servicing arrangement of the
servicers, as well as the presence of a strong master servicer to
oversee the servicers. In this transaction, Nationstar Mortgage LLC
(Nationstar) will act as the master servicer. The servicers are
required to advance principal and interest on the mortgage loans.
To the extent that the servicers are unable to do so, the master
servicer will be obligated to make such advances. In the event that
the master servicer, Nationstar (rated B2), is unable to make such
advances, the securities administrator, Citibank (rated Aa3) will
be obligated to do so.

JPMorgan Chase Bank, National Association (servicer): Chase is a
seasoned servicer with over 20 years of experience servicing
residential mortgage loans and has demonstrated adequate servicing
ability as a primary servicer of prime residential mortgage loans.
As of June 30, 2018, Chase was servicing a portfolio of about $762
billion.

AmeriHome Mortgage company, LLC (servicer): AmeriHome will be one
of the named primary servicers for this transaction and Cenlar FSB
will sub-service the portfolio for AmeriHome. As of December 2018,
AmeriHome's servicing portfolio totaled approximately 284,000 loans
with an unpaid principal balance of approximately $64 billion.

Cenlar FSB (subservicer for AmeriHome loans): Cenlar operates as a
subsidiary of Cenlar Capital Corporation and is based in Ewing, NJ.
Cenlar FSB is a federally chartered savings bank. Cenlar's core
business includes servicing and subservicing residential loans. As
of December 2018, Cenlar's servicing portfolio consisted of
approximately 2.4 million loans for an unpaid principal balance of
$577.4 billion. Cenlar is the largest sub-servicer by volume in the
country.

Shellpoint Mortgage Servicing (servicer): Shellpoint has
demonstrated adequate servicing ability as a primary servicer of
prime residential mortgage loans. Shellpoint has the necessary
processes, staff, technology and overall infrastructure in place to
effectively service the transaction.

Nationstar Mortgage LLC (master servicer): Nationstar is the master
servicer for the transaction and provides oversight of the
servicers. Moody's considers Nationstar's master servicing
operation to be above average compared to its peers. Nationstar has
strong reporting and remittance procedures and strong compliance
and monitoring capabilities. The company's senior management team
has on average more than 20 years of industry experience, which
provides a solid base of knowledge and leadership. Nationstar's
oversight encompasses loan administration, default administration,
compliance, and cash management. Nationstar is an indirectly held,
wholly owned subsidiary of Nationstar Mortgage Holdings Inc.
Moody's rates Nationstar Mortgage Holdings Inc. at B2 stable.

Collateral Description

The JPMMT 2019-INV1 transaction is a securitization of 919
investment property mortgage loans secured by fixed rate, first
liens on one-to-four family residential investment properties,
planned unit developments, condominiums, townhouses and attached
planned unit developments with an unpaid principal balance of
$338,840,065. All of the loans have a 25-year original (2 loans) or
a 30-year original term (917 loans). The mortgage pool has a WA
seasoning of 6 months. The loans in this transaction have strong
borrower characteristics with a weighted average original primary
borrower FICO score of 772 and a weighted-average original combined
loan-to-value ratio (CLTV) of 66.0%. In addition, 29.8% of the
borrowers are self-employed and refinance loans comprise about
40.6% of the aggregate pool. The pool has a high geographic
concentration with 47.4% of the aggregate pool located in
California; 17.9% located in the Los Angeles-Long Beach-Anaheim, CA
MSA and 8.0% located in San Francisco-Oakland-Hayward, CA MSA. The
characteristics of the loans underlying the pool are generally
comparable to other recent prime RMBS transactions backed primarily
by 100% investment property 30-year mortgage loans that Moody's has
rated.

Servicing Fee Framework

The servicing fee for loans serviced by Chase and Shellpoint will
be based on a step-up incentive fee structure with a monthly base
fee of $20 per loan and additional fees for servicing delinquent
and defaulted loans. The other servicers, like AmeriHome and First
Republic Bank, will be paid a monthly flat servicing fee equal to
one-twelfth of 0.25% of the remaining principal balance of the
mortgage loans. Shellpoint will act as interim servicer until the
servicing transfer date, July 1, 2019 or such later date as
determined by the issuing entity and Chase.

While this fee structure is common in non-performing mortgage
securitizations, it is relatively new to rated prime mortgage
securitizations which typically incorporate a flat 25 basis point
servicing fee rate structure. By establishing a base servicing fee
for performing loans that increases with the delinquency of loans,
the fee-for-service structure aligns monetary incentives to the
servicer with the costs of the servicer. The servicer receives
higher fees for labor-intensive activities that are associated with
servicing delinquent loans, including loss mitigation, than they
receive for servicing a performing loan, which is less
labor-intensive. The fee-for-service compensation is reasonable and
adequate for this transaction because it better aligns the
servicer's costs with the deal's performance. Furthermore, higher
fees for the more labor-intensive tasks make the transfer of these
loans to another servicer easier, should that become necessary. By
contrast, in typical RMBS transactions a servicer can take actions,
such as modifications and prolonged workouts, that increase the
value of its mortgage servicing rights.

The incentive structure includes an initial monthly base servicing
fee of $20 for all performing loans and increases according to a
pre-determined delinquent and incentive servicing fee schedule.

The delinquent and incentive servicing fees will be deducted from
the available distribution amount and Class B-6 net WAC. The
transaction does not have a servicing fee cap, so, in the event of
a servicer replacement, any increase in the base servicing fee
beyond the current fee will be paid out of the available
distribution amount.

Third-party Review and Reps & Warranties

Three third party review (TPR) firms verified the accuracy of the
loan-level information that Moody's received from the sponsor.
These firms conducted detailed credit, valuation, regulatory
compliance and data integrity reviews on 100% of the mortgage pool.
The TPR results indicated compliance with the originators'
underwriting guidelines for the vast majority of loans, no material
compliance issues, and no appraisal defects. The loans that had
exceptions to the originators' underwriting guidelines had strong
documented compensating factors such as low DTIs, low LTVs, high
reserves, high FICOs, or clean payment histories. The TPR firms
also identified minor compliance exceptions for reasons such as
inadequate RESPA disclosures (which do not have assignee liability)
and TILA/RESPA Integrated Disclosure (TRID) violations related to
fees that were out of variance but then were cured and disclosed.
Moody's did not make any adjustments to its expected or Aaa (sf)
loss levels due to the TPR results.

JPMMT 2019-INV1's R&W framework is in line with that of other JPMMT
transactions where an independent reviewer is named at closing, and
costs and manner of review are clearly outlined at issuance. Its
review of the R&W framework takes into account the financial
strength of the R&W providers, scope of R&Ws (including qualifiers
and sunsets) and enforcement mechanisms. The R&W does not cover
high cost loan for the 13.9% non-conforming prime jumbo mortgage
loans in this pool. However the TPR firms as part of their due
diligence tested for high cost loans in the pool and did not find
any such loans in this pool. In addition, seven loans in this pool
are cash out refinance loans and are taken for personal use. JPMMAC
is representing that these seven mortgage loans are "Qualified
Mortgage-Agency Safe Harbor".

The R&W providers vary in financial strength. JPMorgan Chase Bank,
National Association (rated Aa2) is the R&W provider for
approximately 55.6% (by loan balance) of the pool. Moody's made no
adjustments to the loans for which Chase and First Republic Bank
(rated Baa1) provided R&Ws since they are highly rated entities. In
contrast, the rest of the R&W providers are unrated and/or
financially weaker entities. Moody's applied an adjustment to the
loans for which these entities provided R&Ws. No party will
backstop or be responsible for backstopping any R&W providers who
may become financially incapable of repurchasing mortgage loans.

For loans that JPMMAC acquired via the MAXEX platform, MAXEX under
the assignment, assumption and recognition agreement with JPMMAC,
will make the R&Ws. The R&Ws provided by MAXEX to JPMMAC and
assigned to the trust are in line with the R&Ws found in the JPMMT
transactions. Five Oaks Acquisition Corp. will backstop the
obligations of MaxEx with respect to breaches of the mortgage loan
representations and warranties made by MaxEx.

Trustee and Master Servicer

The transaction Delaware trustee is Citibank. The custodian's
functions will be performed by Wells Fargo Bank, N.A. and Chase.
The paying agent and cash management functions will be performed by
Citibank. Nationstar Mortgage LLC, as master servicer, is
responsible for servicer oversight, and termination of servicers
and for the appointment of successor servicers. In addition,
Nationstar is committed to act as successor if no other successor
servicer can be found. The master servicer is required to advance
principal and interest if the servicer fails to do so. If the
master servicer fails to make the required advance, the securities
administrator is obligated to make such advance.

Tail Risk & Subordination Floor

This deal has a standard shifting-interest structure, with a
subordination floor to protect against losses that occur late in
the life of the pool when relatively few loans remain (tail risk).
When the total senior subordination is less than 2.30% of the
original pool balance, the subordinate bonds do not receive any
principal and all principal is then paid to the senior bonds. In
addition, if the subordinate percentage drops below 12.00% of
current pool balance, the senior distribution amount will include
all principal collections and the subordinate principal
distribution amount will be zero. The subordinate bonds themselves
benefit from a floor. When the total current balance of a given
subordinate tranche plus the aggregate balance of the subordinate
tranches that are junior to it amount to less than 1.20% of the
original pool balance, those tranches do not receive principal
distributions. The principal those tranches would have received is
directed to pay more senior subordinate bonds pro-rata.

Transaction Structure

The transaction uses the shifting interest structure in which the
senior bonds benefit from a number of protections. Funds collected,
including principal, are first used to make interest payments to
the senior bonds. Next, principal payments are made to the senior
bonds. Next, available distribution amounts are used to reimburse
realized losses and certificate write-down amounts for the senior
bonds (after subordinate bond have been reduced to zero i.e. the
credit support depletion date). Finally, interest and then
principal payments are paid to the subordinate bonds in sequential
order.

Realized losses are allocated in a reverse sequential order, first
to the lowest subordinate bond. After the balance of the
subordinate bonds is written off, losses from the pool begin to
write off the principal balance of the senior support bond, and
finally losses are allocated to the super senior bonds.

In addition, the pass-through rate on the bonds (other than the
Class A-R Certificates) is based on the net WAC as reduced by the
sum of (i) the reviewer annual fee rate and (ii) the capped trust
expense rate. In the event that there is a small number of loans
remaining, the last outstanding bonds' rate can be reduced to
zero.

The Class A-11 Certificates will have a pass-through rate that will
vary directly with the rate of one-month LIBOR and the Class A-11-X
Certificates will have a pass-through rate that will vary inversely
with the rate of one-month LIBOR.

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 of the subordinate bonds up. Losses could decline from
Moody's original expectations as a result of a lower number of
obligor defaults or appreciation in the value of the mortgaged
property securing an obligor's promise of payment. Transaction
performance also depends greatly on the US macro economy and
housing market.


LB COMMERCIAL 2007-C3: S&P Affirms B+ Ratings on 2 Classes of Certs
-------------------------------------------------------------------
S&P Global Ratings lowered its rating on the class B commercial
mortgage pass-through certificates from LB Commercial Mortgage
Trust 2007-C3, a U.S. commercial mortgage-backed securities (CMBS)
transaction. In addition, S&P affirmed its ratings on classes A-J
and A-JFL from the same transaction.

The downgrade on class B reflects its susceptibility to liquidity
interruption from the four specially serviced assets ($163.6
million, 84.3%), as well as credit support erosion that S&P
anticipates will occur upon the eventual resolution of these
assets.

The affirmations on classes A-J and A-JFL reflect S&P's credit
enhancement expectations, which are in line with the current rating
levels.

While available credit enhancement levels actually suggest positive
rating movements on classes A-J and A-JFL, S&P's analysis also
considered the potential for reduced liquidity support to these
classes from the specially serviced assets. This includes the
potential for the master servicer to recoup its prior advances on
assets deemed nonrecoverable. S&P also considered the potential
refinancing risk on the three remaining performing loans ($30.4
million, 15.7%), which are secured by retail properties and mature
in July 2022.

TRANSACTION SUMMARY

As of the May 17, 2019, trustee remittance report, the collateral
pool balance was $194.0 million, which is 6.0% of the pool balance
at issuance. The pool currently includes five loans and two real
estate owned (REO) assets, down from 117 loans at issuance. Four of
these assets are with the special servicer, one ($6.5 million,
3.4%) is on the master servicer's watchlist, and none are
defeased.

Excluding the specially serviced assets, S&P calculated a 1.20x S&P
Global Ratings weighted average debt service coverage (DSC) and
73.2% S&P Global Ratings weighted average loan-to-value ratio using
a 7.39% S&P Global Ratings weighted average capitalization rate for
the three performing loans.

To date, the transaction has experienced $230.0 million in
principal losses, or 7.1% of the original pool trust balance. S&P
expects losses to reach approximately 10.5% of the original pool
trust balance in the near term, based on losses incurred to date
and additional losses S&P expects upon the eventual resolution of
the four specially serviced assets.

CREDIT CONSIDERATIONS     

As of the May 17, 2019, trustee remittance report, four assets in
the pool were with the special servicer, LNR Partners LLC. Details
of the two largest specially serviced assets are as follows:

The University Mall REO asset ($92.0 million, 47.4%) is the largest
asset in the pool and with the special servicer. The asset has a
total reported exposure of $97.1 million and consists of 434,933
sq. ft. of a 609,493-sq.-ft. retail property in South Burlington,
Vt. The loan was transferred to the special servicer on July 6,
2015, due to imminent default and the property became REO on Oct.
31, 2016. The master servicer has deemed the asset nonrecoverable.
According to the special servicer, it is evaluating its liquidation
options. Recent marketing efforts to liquidate the asset from the
trust have ceased because it did not achieve the desired prices.
S&P currently expects a moderate loss (26%-59%) upon the asset's
eventual resolution, but the potential for significant loss (60% or
greater) is possible given the continued buildup in the asset
exposure amount.

The 50 Danbury Road loan ($59.8 million, 30.8%) is the
second-largest asset in the pool and has a total reported exposure
of $61.9 million. The loan, which has a nonperforming matured
balloon payment status, is secured by a 219,041-sq.-ft. office
property in Wilton, Conn. The loan was transferred to the special
servicer on Feb. 27, 2015, due to imminent default. The master
servicer deemed the loan nonrecoverable. The reported occupancy as
of Dec. 31, 2018, was 45.0%. S&P expects a significant loss upon
the loan's eventual resolution.

The other two assets with the special servicer each have individual
balances that represent less than 3.5% of the total pool trust
balance. S&P estimated losses for the four specially serviced
assets, arriving at a weighted-average loss severity of 64.0%.

  RATING LOWERED

  LB Commercial Mortgage Trust 2007-C3     
  Commercial mortgage pass-through certificates     

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

  RATINGS AFFIRMED      

  LB Commercial Mortgage Trust 2007-C3     
  Commercial mortgage pass-through certificates     

  Class     Rating     

  A-J       B+ (sf)     
  A-JFL     B+ (sf)


LCM 29: S&P Assigns BB- (sf) Rating to $13.6MM Class E Notes
------------------------------------------------------------
S&P Global Ratings assigned ratings to LCM 29 Ltd./LCM 29 LLC's
floating-rate notes.

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

The ratings reflect:

-- The diversified collateral pool.

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

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

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

  RATINGS ASSIGNED

  LCM 29 Ltd./LCM 29 LLC  

  Class                 Rating       Amount (mil. $)
  X                     AAA (sf)                2.00
  A-1                   AAA (sf)              240.00
  A-2                   NR                     20.00
  B                     AA (sf)                44.00
  C (deferrable)        A (sf)                 24.00
  D (deferrable)        BBB- (sf)              24.00
  E (deferrable)        BB- (sf)               13.60
  Subordinated notes    NR                     36.60

  NR--Not rated.


LEGACY BENEFITS 2004-I: Moody's Confirms Caa3 Rating on B Notes
---------------------------------------------------------------
Moody's Investors Service has confirmed the rating of the Class B
notes issued by Legacy Benefits Life Insurance Settlements 2004-I
LLC. This transaction is a securitization of a small pool of
insurance policies (primarily life insurance policies and single
premium life annuities).

The complete rating action is as follows:

Issuer: Legacy Benefits Life Insurance Settlements 2004-1 LLC

  Cl. B, Confirmed at Caa3 (sf); previously on Mar 6, 2019
  Downgraded to Caa3 (sf) and Placed Under Review for Possible
  Downgrade

RATINGS RATIONALE

The rating action on the Class B notes is driven by the receipt of
the current list of outstanding policies backing the transaction
and the most recent annual statements, which indicate that the
level of collateralization for the Class B notes remains consistent
with a Caa3 (sf) rating.


LOANCORE 2019-CRE3: DBRS Gives (P)B(low) Rating on Class F Notes
----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
floating-rate notes to be issued by LoanCore 2019-CRE3 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 (low) (sf)
-- Class E Floating Rate Notes at BB (low) (sf)
-- Class F Floating Rate Notes at B (low) (sf)

All trends are Stable.

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

The initial collateral consists of 22 floating-rate mortgages
secured by 38 mostly transitional properties with a cut-off balance
totaling approximately $415.9 million, excluding approximately
$60.7 million of future funding commitments and $52.2 million of
funded companion participations. Most loans are in a period of
transition with plans to stabilize and improve asset value. During
the Funded Companion Acquisition Period, the Issuer may acquire
funded Future Funding Participations and Funded Companion
Participations with principal repayment proceeds.

Because of the floating-rate nature of the loans, DBRS used the
one-month LIBOR index, which 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), 20 loans, comprising 92.6% of
the initial 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 13 loans,
comprising 55.3% of the initial pool balance, is 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 transaction will have a pro-rata principal pay structure on the
first reduction of 10.0% of the aggregate collateral interest
cut-off balance and then revert to a sequential-pay structure.

The properties are primarily located in core markets with the
overall pool's weighted-average (WA) DBRS Market Rank at a very
high 5.4. Four loans, totaling 18.2% of the pool, are in markets
with a DBRS Market Rank of 8 while seven loans, totaling 31.8% of
the pool, are in markets with a DBRS Market Rank of 7 and 6. The
market ranks correspond to zip codes that are more urbanized in
nature. The loans are generally secured by traditional property
types (i.e., retail, multifamily, office, hotel and industrial).
Additionally, only one multifamily loan in the pool is currently
secured by a student-housing property, which often exhibits higher
cash flow volatility than traditional multifamily properties, and
only one loan is secured by hotel property. Four loans in the pool,
totaling 21.6% of the total pool balance, are backed by a property
with a quality deemed to be Above Average by DBRS. Furthermore, two
loans totaling 13.2% of the pool is backed by properties considered
to have Average + property quality. Finally, the borrowers of all
22 loans have purchased LIBOR rate caps ranging between 3.0% and
4.0% to protect against rising interest rates over the term of the
loan.

All loans have floating interest rates with original term ranges
from 24 months to 36 months, creating interest rate risk. All loans
are short-term loans and, even with extension options, have a fully
extended maximum loan term of five years. All loans have interest
rate caps ranging from 3.0% to 4.0%. Furthermore, DBRS applied the
lessor of the interest rate cap or the DBRS stressed forward
interest rate based on the DBRS "Interest Rate Stresses for U.S.
Structured Finance Transactions" methodology. Additionally, all
have extension options and, in order to qualify for these options,
the loans must meet minimum DSCR and loan-to-value (LTV)
requirements. The transaction is structured with the first 10.0% of
the principal paid on a pro-rata basis. DBRS stressed the model by
paying off the best 10.0% performing loan(s), effectively
neutralizing credit drift and diversity deterioration.

Based on the weighted initial pool balances, the overall WA DBRS
As-Is DSCR and DBRS Stabilized DSCR of 0.64x and 1.03x,
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 6.1%, which is greater than the current WA interest rate of
5.6% (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 also improve the overall debt yield of the
loans. DBRS associates its loss given default (LGD) based on the
assets' DBRS As-Is LTV that does not assume that the stabilization
plan and cash flow growth will ever materialize but does account
for the loan is fully funded. The DBRS As-Is LTV is considered
reasonable at 76.0%, 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 that the loan is fully
funded.

Thirteen loans, totaling only 57.9% 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. Six of the 13 refinance
loans, representing 47.8% of the pool, have a current occupancy of
less than 80.0% and eight of the refinance loans account for $28.4
million or 46.7% of the $60.7 million of future funding. 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.

All ratings are subject to surveillance, which could result in
ratings being upgraded, downgraded, and placed under review,
confirmed or discontinued by DBRS.

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


MADISON PARK X: S&P Rates $37.5MM Class E-R-2 Notes 'BB- (sf)'
---------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R-2, B-R-2,
C-R-2, D-R-2, and E-R-2 replacement notes from Madison Park Funding
X Ltd., a collateralized loan obligation (CLO) originally issued in
2012 that is managed by Credit Suisse Asset Management LLC. S&P
withdrew its ratings on the original class A-R, B-R, C-R, D-R, and
E-R notes following payment in full on the June 6, 2019,
refinancing date.

On the June 6, 2019, refinancing date, the proceeds from the class
A-R-2, B-R-2, C-R-2, D-R-2, and E-R-2 replacement note issuances
were used to redeem the original class A-R, B-R, C-R, D-R, and E-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 is assigning ratings to the
replacement 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 assigned ratings reflect our opinion that the credit support
available is commensurate with the associated rating levels," S&P
said.

"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
  Madison Park Funding X Ltd.

  Replacement class          Rating        Amount (mil $)
  A-R-2                      AAA (sf)              488.25
  B-R-2                      AA (sf)                88.50
  C-R-2                      A (sf)                 59.25
  D-R-2                      BBB- (sf)              39.50
  E-R-2                      BB- (sf)               37.50

  RATINGS WITHDRAWN
  Madison Park Funding X Ltd.

                            Rating
  Original class       To         From
  A-R                  NR         AAA (sf)
  B-R                  NR         AA+ (sf)
  C-R                  NR         A+ (sf)
  D-R                  NR         BBB+ (sf)
  E-R                  NR         BB (sf)

  NR--Not rated.


MARGARITAVILLE 2019-MARG: DBRS Gives (P)B(low) on Class G Certs
---------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-MARG to
be issued by Margaritaville Beach Resort Trust 2019-MARG:

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

The Class X-CP and X-EXT balances are notional. All trends are
Stable.

The subject property is an AAA Four Diamond-rated luxury resort in
Hollywood, Florida, situated on 6.2 acres of beachfront property
between the Atlantic Ocean and the Intracoastal Stranahan River.
The resort offers 349 guest rooms, each featuring a private terrace
with an ocean/intracoastal view, 30,000 square feet (sf) of
indoor/outdoor event space, an adult-only pool, two family-friendly
pools, a surf simulator, 11,000 of the spa, eight branded food and
beverage outlets, and 465 parking spaces. The property benefits
from its proximity to two major airports: Fort Lauderdale-Hollywood
International Airport located approximately 7.5 miles north and
Miami International Airport located approximately 23.4 miles south.
The sponsor, KSL Capital Partners, LLC, purchased the resort for
$194.0 million in April 2018 from the developer, Starwood Capital
Group, which built the property and opened Margaritaville Hollywood
Beach Resort for business in 2015. Loan proceeds of $180.0 million
are being used to retire outstanding debt of $123.6 million, return
$49.3 million of equity to the sponsor ($60 million of implied
sponsor equity remains in the deal), cover upfront reserves of $2.1
million for a room reconfiguration project that will add 20 guest
rooms to the resort and pay for $4.9 million of closing costs.

The property has shown strong performance since opening in 2015
with its net cash flow increasing to $16.9 million as of the
trailing 12-month period ending March 2019 (the T-12 period) from
$11.7 million as of YE2016. As of the T-12 period, the resort
reported an occupancy rate and average daily rate (ADR) of 81.7%
and $284.71, respectively, resulting in a revenue per available
room (RevPAR) figure of $232.50. The T-12 period RevPAR represents
a 10.81% increase over YE2017 and a 15.79% increase over YE2016.
Margaritaville Hollywood Beach Resort has performed exceptionally
well compared with its competitive set, showing occupancy, ADR and
RevPAR penetrations of 106.0%, 111.0%, and 117.0%, respectively,
according to a January 2019 STR report.

This loan is structured with $1.98 million of upfront reserves to
cover a room configuration project that the sponsor plans to
complete by September 2019 and improvements to the LandShark Bar &
Grill, Margaritaville Coffee Shop and resort corridors to be
completed by YE2019. By reconfiguring 14 underutilized suites and
converting the 2,834 of Jimmy Buffett Presidential Suite, the
sponsor will add 20 new guest rooms to the resort, which is
projected to drive an additional $520,000 of room revenue and $1.9
million in total additional revenue in 2020.

There is no incoming supply identified in the appraisal that is
expected to be a direct competitor to the subject property. A
638-key Hard Rock Hotel is currently under construction in
Hollywood with an expected opening date in Q3 2019. This property
is a non-beachfront asset with a large casino that targets a
different guest profile than the Margaritaville Hollywood Beach
Resort, and the appraiser does not consider it to be a direct
competitor. The appraisal also mentions the construction of the
Four Seasons Fort Lauderdale Beach, a 150-key luxury resort
expected to come online in Q1 2020 that is not anticipated to
compete directly with Margaritaville because of its projected
higher price point. Most of the competitive set and possible future
competition is considered to be beachfront property primarily
located in the Fort Lauderdale market. The subject property
benefits from its beachfront location but is at a slight
disadvantage to some of its competitors as a result of its distance
from well-known Fort Lauderdale.

The DBRS value of $149,095,849 represents a 39.9% discount to the
appraised value of $240.0 million. In addition, the DBRS cap rate
of 10.489% is likely approximately 298 basis points above a current
market cap rate, allowing for significant reversion to the mean in
lodging valuation metrics. Given the property's Above Average
quality, strong sponsorship and management as well as the loan's
moderate leverage, DBRS expects loan performance to be strong
during the five-year term (fully extended) and, although the risk
is elevated based on DBRS stressed metrics, refinance at maturity
is considered likely.

All ratings will be subject to ongoing surveillance, which could
result in ratings being upgraded, downgraded, and placed under
review, confirmed or discontinued by DBRS.

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


MCA FUND II: DBRS Confirms BB Rating on Class C Notes
-----------------------------------------------------
DBRS, Inc. confirmed ratings of the Class A Notes, the Class B
Notes and the Class C Deferrable Notes (together, the Notes) issued
by MCA Fund II Holding LLC pursuant to the Indenture dated as of
June 28, 2017, between MCA Fund II Holding LLC as Issuer and Wells
Fargo Bank, N.A. (rated AA with a Stable trend by DBRS) as Trustee
and Calculation Agent. DBRS also confirmed the rating of the
Liquidity Loan Facility (the Liquidity Facility) with MCA Fund II
Holding LLC as Issuer, Barclays Bank PLC (rated "A" with a Stable
trend by DBRS) as Liquidity Lender and Wells Fargo Bank, N.A. as
Trustee and Calculation Agent, as follows:

-- Class A Notes confirmed at A (sf)
-- Class B Notes confirmed at BBB (sf)
-- Class C Deferrable Notes confirmed at BB (sf)
-- Liquidity Facility confirmed at A (sf)

The ratings of the Class A Notes, the Class B Notes and the
Liquidity Facility address the timely payment of interest and the
ultimate payment of principal on or before the Final Maturity Date.
The rating of the Class C Deferrable Notes addresses the ultimate
payment of interest and the ultimate payment of principal on or
before the Final Maturity Date.

The ratings confirmed on the Class A Notes and the Liquidity
Facility differs from the ratings implied by the quantitative
model, which would have been higher than the confirmed ratings.
DBRS considers these differences to be a material deviation from
the model. The reason for this material deviation is that the Class
A Notes and Liquidity Facility are exposed to counterparty risks in
the form of future capital calls that are not fully captured in the
model output.

The Notes are backed by a portfolio of limited partnership
interests in a leveraged buyout, mezzanine debt and venture capital
private equity funds. Each class of Notes is able to withstand a
percentage of tranche defaults from a Monte Carlo asset analysis
commensurate with its respective rating.

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


MIDOCEAN CREDIT VI: Moody's Rates Class $20MM Class E-R Notes Ba3
-----------------------------------------------------------------
Moody's Investors Service has assigned ratings to five classes of
CLO refinancing notes issued by MidOcean Credit CLO VI.

Moody's rating action is as follows:

  US$242,000,000 Class A-R Floating Rate Notes due 2029
  (the "Class A-R Notes"), Assigned Aaa (sf)

  US$58,000,000 Class B-R Floating Rate Notes due 2029 (the
  "Class B-R Notes"), Assigned Aa2 (sf)

  US$26,000,000 Class C-R Deferrable Floating Rate Notes due
  2029 (the "Class C-R Notes"), Assigned A2 (sf)

  US$22,000,000 Class D-R Deferrable Floating Rate Notes due 2029
  (the "Class D-R Notes"), Assigned Baa3 (sf)

  US$20,000,000 Class E-R Deferrable Floating Rate Notes due 2029
  (the "Class E-R Notes"), Assigned Ba3 (sf)

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.

The Issuer is a managed cash flow collateralized loan obligation.
The issued notes are collateralized primarily by a portfolio of
broadly syndicated senior secured corporate loans. At least 90.0%
of the portfolio must consist of first lien senior secured loans,
cash, and eligible investments, and up to 10.0% of the portfolio
may consist of second liens loans and unsecured loans.

MidOcean Credit Fund Management LP 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 remaining 1.9 year reinvestment
period. Thereafter, subject to certain restrictions, the Manager
may reinvest unscheduled principal payments and proceeds from sales
of credit risk assets.

The Issuer has issued the Refinancing Notes on May 29, 2019 in
connection with the refinancing of all classes of secured notes
originally issued on December 20, 2016. On the Refinancing Date,
the Issuer used the proceeds from the issuance of the Refinancing
Notes, to redeem in full the Refinanced Original Notes. On the
Original Closing Date, the issuer also issued one class of income
notes that remains outstanding.

In addition to the issuance of the Refinancing Notes, other changes
to the transaction features will occur in connection with the
refinancing. These include: extension of the non-call period; and
changes to collateral quality matrix and modifiers.

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

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. For modeling
purposes, Moody's used the following base-case assumptions

Performing par and principal proceeds balance: $399,265,476

Defaulted par: $1,709,467

Diversity Score: 55

Weighted Average Rating Factor (WARF): 2764 (corresponding to a
weighted average default probability of 22.50%)

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 5.00%

Weighted Average Recovery Rate (WARR): 47.0%

Weighted Average Life (WAL): 5.73 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 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.


MMCAPS FUNDING XVIII: Moody's Hikes Class C-3 Notes Rating to Ba3
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by MMCapS Funding XVIII, Ltd.:

  US$185,100,000 Class A-1 Floating Rate Notes Due 2039 (current
  balance of $95,501,348), Upgraded to Aa1 (sf); previously on
  June 27, 2017 Upgraded to Aa2 (sf)

  US$21,800,000 Class A-2 Floating Rate Notes Due 2039, Upgraded
  to Aa2 (sf); previously on June 27, 2017 Upgraded to Aa3 (sf)

  US$20,100,000 Class B Floating Rate Notes Due 2039, Upgraded to
  Aa3 (sf); previously on June 27, 2017 Upgraded to A1 (sf)

  US$55,900,000 Class C-1 Floating Rate Deferrable Interest Notes
  Due 2039 (current balance of $59,107,094, including deferred
  interest balance), Upgraded to Ba3 (sf); previously on June 27,
  2017 Upgraded to B2 (sf)

  US$12,000,000 Class C-2 Fixed/Floating Rate Deferrable Interest
  Notes Due 2039 (current balance of $13,731,067, including
  deferred interest balance), Upgraded to Ba3 (sf); previously
  on June 27, 2017 Upgraded to B2 (sf)

  US$4,000,000 Class C-3 Fixed Rate Deferrable Interest Notes Due
  2039 (current balance of $4,946,812, including deferred interest
  balance), Upgraded to Ba3 (sf); previously on June 27, 2017
  Upgraded to B2 (sf)

  US$10,000,000 Combination Notes Due 2039 (current rated balance
  of $10,169,542, including deferred interest balance), Upgraded
  to Caa1 (sf); previously on June 27, 2017 Upgraded to Caa3 (sf)

MMCapS Funding XVIII, Ltd., issued in December 2006, is a
collateralized debt obligation (CDO) backed by a portfolio of bank
trust preferred securities (TruPS).

The Combination Notes, issued in December 2006, were originally
composed of components representing $7.0 million of Class C-1 Notes
and $3.0 million of Subordinate Income Notes issued by MMCapS
Funding XVIII, Ltd.

RATINGS RATIONALE

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

The Class A-1 notes have paid down by approximately 10.2% or $10.8
million since May 2018, using principal proceeds from the
redemption of an underlying asset and the diversion of excess
interest proceeds. Based on Moody's calculations, the OC ratios for
the Class A-1, Class A-2, Class B, and Class C notes have improved
to 241.88%, 196.93%, 168.12%, and 107.35%, respectively, from May
2018 levels of 216.35%, 179.67%, 155.38%, and 101.32%,
respectively. Additionally, the Class C OC ratio has been passing
its trigger since September 2018, therefore, excess interest was
used to pay approximately $1.5 million of the Class C deferred
interest balance since then. The Class C Notes will continue to
benefit from the repayment of the deferred interest balance as long
as the Class C OC test continues to pass (current level of 107.43%
versus a trigger of 103.98%).

The deal has also benefited from improvement in the credit quality
of the underlying portfolio. According to Moody's calculations, the
weighted average rating factor (WARF) improved to 562 from 591 in
May 2018.

Moody's rating of the Combination Notes addresses only the ultimate
receipt of the Combination Notes' Rated Balance by the holders of
the Combination Notes. Moody's rating of the Combination Notes does
not address any other payments or additional amounts that a holder
of the Combination Notes may receive pursuant to the underlying
documents.

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 of $231.0 million,
defaulted/deferring par of $44.7million, a weighted average default
probability of 6.32% (implying a WARF of 562), and a weighted
average recovery rate upon default of 10.0%.

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 RiskCalcâ„¢ or credit
assessments. Because these are not public ratings, they are subject
to additional estimation uncertainty.


MORGAN STANLEY 2019-H6: Fitch to Rate Class J-RR Certs 'B-sf'
-------------------------------------------------------------
Fitch Ratings has issued a presale report on Morgan Stanley Capital
I Trust 2019-H6 commercial mortgage pass-through certificates,
series 2019-H6.

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

  -- $18,000,000 class A-1 'AAAsf'; Outlook Stable;

  -- $21,100,000 class A-2 'AAAsf'; Outlook Stable;

  -- $27,300,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $140,000,000c class A-3 'AAAsf'; Outlook Stable;

  -- $274,382,000c class A-4 'AAAsf'; Outlook Stable;

  -- $480,782,000b class X-A 'AAAsf'; Outlook Stable;

  -- $121,055,000b class X-B 'A-sf'; Outlook Stable;

  -- $63,532,000 class A-S 'AAAsf'; Outlook Stable;

  -- $26,615,000 class B 'AA-sf'; Outlook Stable;

  -- $30,908,000 class C 'A-sf'; Outlook Stable;

  -- $14,938,000abe class X-D 'BBBsf'; Outlook Stable;

  -- $14,938,000a class D 'BBBsf'; Outlook Stable;

  -- $11,676,000ade class E-RR 'BBB-sf'; Outlook Stable;

  -- $10,303,000ade class F-RR 'BBB-sf'; Outlook Stable;

  -- $7,727,000ab class G-RR 'BB+sf'; Outlook Stable;

  -- $10,302,000ad class H-RR 'BB-sf'; Outlook Stable;

  -- $6,869,000ad class J-RR 'B-sf'; Outlook Stable.

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

  -- $23,180,759ad class K-RR.

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

(b) Notional amount and interest-only.

(c) The initial certificate balances of classes A-3 and A-4 are
unknown and expected to be approximately $414,382,000 in aggregate,
subject to a 5% variance. The expected class A-3 balance range is
$90,000,000 to $190,000,000 and the expected class A-4 balance
range is $224,382,000 to $324,382,000. The balances shown reflect
the midpoint of the ranges.

(d) Horizontal credit risk retention interest.

(e) The initial certificate balance of each class of the Class E-RR
and Class F-RR certificates and the initial notional amount of the
Class X-D certificates are subject to change based on final pricing
of all certificates (other than the Class R certificates) and the
final determination of the fair market value of the Class F-RR,
Class G-RR, Class H-RR, Class J-RR and Class K-RR certificates.

The expected ratings are based on information provided by the
issuer as of May 28, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 46 loans secured by 255
commercial properties having an aggregate principal balance of
$686,832,759 as of the cut-off date. The loans were contributed to
the trust by Morgan Stanley Mortgage Capital Holdings LLC, Argentic
Real Estate Finance LLC, Starwood Mortgage Capital LLC and Cantor
Commercial Real Estate Lending, L.P.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 76.2% of the properties
by balance, cash flow analysis of 88.2% and asset summary reviews
on 100.0% of the pool.

KEY RATING DRIVERS

Fitch Leverage: Overall, the pool's Fitch DSCR of 1.22x is average
when compared with the 2018 average of 1.22x and the 2019 YTD
average of 1.21x. The pool's Fitch LTV of 102.4% is slightly above
the 2018 average of 102.0% and in-line with the 2019 YTD average of
102.5%.

Credit Opinion Loans: Four loans, representing 13.9% of the pool
received an investment-grade credit opinion on a stand-alone basis
including: ILPT Hawaii Portfolio (5.8% of pool) with an
investment-grade credit opinion of 'BBBsf*', Tower 28 (4.4% of
pool) with an investment-grade credit opinion of 'BBB-sf*', 65
Broadway (2.3% of pool) with an investment-grade credit opinion of
'BBB-sf*' and 3 Columbus Circle (1.5% of pool) with an
investment-grade credit opinion of 'BBB-sf*'. Overall, this
transaction has a similar proportion of credit opinion loans when
compared with the 2018 and 2019 YTD averages of 13.6% and 10.1%,
respectively, for other recent Fitch-rated multiborrower
transactions. The pool's Fitch stressed debt service coverage ratio
(DSCR) and loan to value (LTV) net of credit opinion loans are
1.21x and 107.9%, respectively.

Pool Concentration: The pool is less diverse than recent
Fitch-rated multiborrower transactions. The 10 largest loans
account for 57.1% of the pool, compared with the 2018 and 2019 YTD
averages of 50.6% and 49.3%, respectively. Additionally, the loan
concentration index (LCI) is 457, which worse than average when
compared with the 2018 average of 373 and 2019 YTD average of 363
for other Fitch rated multiborrower transactions.

Property Type Concentration: The pool has high exposure to hotel
properties, which, at 21.9% of the pool, exceeds 2018 and 2019 YTD
average concentrations of 14.7% and 13.7%, respectively. Three of
the top ten loans are backed by hotel properties. Loans secured by
hotel properties have a higher probability of default than other
commercial property types in Fitch's multiborrower model, all else
equal.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 14.7% below
the most recent year's NOI 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 MSC
2019-H6 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 'BBB-sf'
could result.


NIAGARA PARK: S&P Assigns Prelim BB- (sf) Rating to Class E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Niagara Park
CLO Ltd./Niagara Park CLO LLC's floating-rate notes.

The note issuance is a collateralized loan obligation (CLO)
transaction backed by a diversified collateral pool, which consists
primarily of broadly syndicated speculative-grade senior secured
term loans that are governed by collateral quality tests.

The preliminary ratings are based on information as of June 6,
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
  Niagara Park CLO Ltd./Niagara Park CLO LLC

  Class                Rating       Amount (mil. $)
  A                    NR                   288.000
  B                    AA (sf)               51.300
  C (deferrable)       A (sf)                28.575
  D (deferrable)       BBB- (sf)             27.000
  E (deferrable)       BB- (sf)              14.175
  Subordinated notes   NR                    44.120

  NR--Not rated.


ORANGE LAKE 2019-A: Fitch Assigns 'BBsf' Rating on Class D Debt
---------------------------------------------------------------
Fitch Ratings has assigned ratings to the notes issued by Orange
Lake Timeshare Trust 2019-A.

KEY RATING DRIVERS

Borrower Risk - Weakening Borrower Credit Quality: OLTT 2019-A's WA
FICO score is 710, which is second lowest for an OLTT transaction
after 2006-A's at 652. In addition to weaker FICO scores, 2019-A
also includes loans originated through rebranded Silverleaf resort
sales centers. These were not part of 2018-A, but were previously
included in 2016-A. Further, this is the first transaction since
2006-A that includes borrowers with FICO scores of 550-599 in the
pool.

Forward-Looking Approach on CGD Proxy - Weakening Performance: The
2016 and 2017 vintages are experiencing higher default rates than
observed during the recent recession due principally to integration
challenges following the Silverleaf acquisition in 2015. Fitch
accounted for these performance trends in deriving its cumulative
gross default (CGD) proxy of 21.50% by focusing on extrapolations
of the 2007-2009 and 2015-2017 vintages.

Fitch takes into consideration the strength of the economy, and
future expectations in its analysis, by assessing key macroeconomic
indicators correlated with timeshare loan performance, such as GDP
and the unemployment rate. These were accounted for in the
derivation of Fitch's CGD proxy for 2019-A.

Structural Analysis - Sufficient CE Structure: Initial hard credit
enhancement (CE) is 71.15%, 41.80%, 22.50% and 4.00% for class A,
B, C and D notes, respectively. Hard CE is composed of
overcollateralization (OC), a reserve account and subordination.
Soft CE is also provided by excess spread and is approximately
10.65% per annum. The structure is sufficient to cover multiples of
3.50x, 2.50x, 1.75x and 1.25x for 'AAAsf', 'Asf', 'BBBsf' and
'BBsf', respectively.

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

RATING SENSITIVITIES

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

Thus, Fitch conducts sensitivity analysis by stressing both a
transaction's initial base case CGD and prepayment assumptions by
1.5x and 2.0x, and examining the rating implications on all classes
of issued notes. The 1.5x and 2.0x increases of the base case CGD
and prepayment assumptions represent moderate and severe stresses,
respectively, and are intended to provide an indication of the
rating sensitivity of notes to unexpected deterioration of a
trust's performance.

Orange Lake Timeshare Trust 2019-A

                 Rating To      Rating From
   
Class A           AAA             AA(EXP)

Class B           A               A(EXP)

Class C           BBB             BBB(EXP)

Class D           BB              BB(EXP)


PALMER SQUARE 2015-1: 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-2-2R, B-R2, C-R2, and D-R2 replacement notes from Palmer
Square CLO 2015-1 Ltd., a collateralized loan obligation (CLO)
originally issued on May 21, 2015, that is managed by Palmer Square
Capital Management LLC. The replacement notes will be issued via a
proposed second supplemental indenture.

"The preliminary ratings reflect our opinion that the credit
support available is commensurate with the associated rating
levels. The preliminary ratings are based on information provided
as of June 4, 2019," S&P said. "Subsequent information may result
in the assignment of final ratings that differ from the preliminary
ratings."

On the June 17, 2019, second refinancing date, the proceeds from
the issuance of the replacement notes are expected to redeem the
outstanding notes. At that time, S&P anticipates withdrawing the
ratings on the outstanding notes and assigning ratings to the
replacement notes. However, if the refinancing doesn't occur, S&P
said it may affirm the ratings on the outstanding notes and
withdraw its preliminary ratings on the replacement notes.

The replacement notes are being issued via a proposed second
supplemental indenture, which, in addition to outlining the terms
of the replacement notes, will also:

-- Lower the spreads of the class A-1-R2, A-2-R2, B-R2, and C-R2
notes
-- Extend the weighted average life test by one year
-- Extend the non-call period by one year

  REPLACEMENT AND ORIGINAL NOTE ISSUANCES

  Second Refinancing Replacement Notes
  Class                Amount (mil. $)      Interest Rate (%)
  A-1-R2                        457.00   3 Month Libor + 1.22
  A-2-R2                         84.20   3 Month Libor + 1.65
  B-R2                           56.50   3 Month Libor + 2.25
  C-R2                           36.10   3 Month Libor + 3.15
  D-R2                           33.10   3 Month Libor + 6.25
  Subordinated Notes             76.40                    N/A

  First Refinancing Replacement Notes
  Class                Amount (mil. $)      Interest Rate (%)
  A-1-R                         457.00   3 Month Libor + 1.30
  A-2-R                          84.20   3 Month Libor + 1.85
  B-R                            56.50   3 Month Libor + 2.55
  C-R                            36.10   3 Month Libor + 3.50
  D-R                            33.10   3 Month Libor + 6.20
  Subordinated Notes             76.40                    N/A

  Original Notes
  Class                Amount (mil. $)      Interest Rate (%)
  A-1                           263.80   3 Month Libor + 1.50
  A-2                            53.45   3 Month Libor + 2.05
  B                              33.15   3 Month Libor + 2.85
  C                              21.15   3 Month Libor + 3.40
  D                              19.45   3 Month Libor + 4.95
  Subordinated Notes             44.80                    N/A

  N/A--Not applicable.

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 S&P's
criteria, its 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.

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

  PRELIMINARY RATINGS ASSIGNED
  Palmer Square CLO 2015-1 Ltd.

  Replacement class       Rating      Amount (mil. $)
  A-1-R2                  AAA (sf)              457.0
  A-2-R2                  AA (sf)                84.2
  B-R2                    A (sf)                 56.5
  C-R2                    BBB (sf)               36.1
  D-R2                    BB- (sf)               33.1
  Subordinated Notes      NR                     76.4

  NR--Not rated.


SEQUOIA MORTGAGE 2019-2: Moody's Rates Class B-4 Debt 'Ba3'
-----------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to the
classes of residential mortgage-backed securities issued by Sequoia
Mortgage Trust 2019-2. The certificates are backed by one pool of
prime quality, first-lien mortgage loans, including 171 agency high
balance mortgage loans. The assets of the trust consist of 634
fully amortizing, fixed-rate mortgage loans. The borrowers in the
pool have high FICO scores, significant equity in their properties
and liquid cash reserves. Nationstar Mortgage LLC will serve as the
master servicer for this transaction. There are six servicers for
this pool: Cenlar FSB (45.8% by loan balance), Quicken Loans
Inc.("Quicken Loans", 23.0%), Shellpoint Mortgage Servicing
(20.8%), First Republic Bank (9.1%), HomeStreet Bank (0.7%) and
Associated Bank, N.A. (0.6%).

The complete rating actions are as follows:

Issuer: Sequoia Mortgage Trust 2019-2

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-4, Definitive Rating Assigned Aaa (sf)

Cl. A-5, Definitive Rating Assigned Aaa (sf)

Cl. A-6, Definitive Rating Assigned Aaa (sf)

Cl. A-7, Definitive Rating Assigned Aaa (sf)

Cl. A-8, Definitive Rating Assigned Aaa (sf)

Cl. A-9, Definitive Rating Assigned Aaa (sf)

Cl. A-10, Definitive Rating Assigned Aaa (sf)

Cl. A-11, Definitive Rating Assigned Aaa (sf)

Cl. A-12, Definitive Rating Assigned Aaa (sf)

Cl. A-13, Definitive Rating Assigned Aaa (sf)

Cl. A-14, Definitive Rating Assigned Aaa (sf)

Cl. A-15, Definitive Rating Assigned Aaa (sf)

Cl. A-16, Definitive Rating Assigned Aaa (sf)

Cl. A-17, Definitive Rating Assigned Aaa (sf)

Cl. A-18, Definitive Rating Assigned Aaa (sf)

Cl. A-19, Definitive Rating Assigned Aa1 (sf)

Cl. A-20, Definitive Rating Assigned Aa1 (sf)

Cl. A-21, Definitive Rating Assigned Aa1 (sf)

Cl. A-22, Definitive Rating Assigned Aaa (sf)

Cl. A-23, Definitive Rating Assigned Aaa (sf)

Cl. A-24, Definitive Rating Assigned Aaa (sf)

Cl. B-1, Definitive Rating Assigned Aa3 (sf)

Cl. B-2, Definitive Rating Assigned A3 (sf)

Cl. B-3, Definitive Rating Assigned Baa3 (sf)

Cl. B-4, Definitive Rating Assigned Ba3 (sf)

RATINGS RATIONALE

Summary Credit Analysis

Moody's expected cumulative net loss on the aggregate pool is 0.30%
in a base scenario and reaches 4.30% 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 using
Moody's Individual Loan Level Analysis (MILAN) model. Loan-level
adjustments to the model included: adjustments to borrower
probability of default for higher and lower borrower DTIs,
borrowers with multiple mortgaged properties, self-employed
borrowers, origination channels and at a pool level, for the
default risk of HOA properties in super lien states. The adjustment
to its Aaa stress loss below the model output also includes
adjustments related to aggregation and origination quality. 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.

Collateral Description

The SEMT 2019-2 transaction is a securitization of 634 first-lien
residential mortgage loans, with an aggregate unpaid principal
balance of $400,835,590. There are 131 originators in this pool
with Quicken Loans (25.0%) being the largest. None of the
originators other than Quicken Loans contributed 10.0% or more of
the principal balance of the loans in the pool. Unlike prior SEMT
transactions, approximately 46.1% of the pool by loan balance (318
loans) is seasoned over 18-months with an weighted average
seasoning of about four years. Moody's analyzed these loans taking
into consideration borrower payment history, additional mortgages
taken by the borrower since origination of the first lien loans and
updated FICO scores to arrive at its loss levels.

Moody's received information on the total debt for the seasoned
loans post-origination. Of the 318 seasoned loans in the pool, 73
loans also had some form of junior mortgage debt after the
origination date of the first lien loans. Moody's made an
adjustment to its collateral losses to account for the increased
probability of default due to an increase in borrower leverage.

Moody's did not receive updated property values for any of the
seasoned loans. Of note, Redwood Residential Acquisition
Corporation will provide representation and warranty that all
mortgaged properties are in substantially the same condition as it
was at the time of the appraisal. However, to account for the
uncertainties of property values for these seasoned loans it made
further adjustment to its losses. The loan-level third party due
diligence review (TPR) encompassed credit underwriting, property
value and regulatory compliance. In addition, Redwood will backstop
the rep and warranty repurchase obligation of all originators other
than First Republic Bank. The loans were all aggregated by Redwood
Residential Acquisition Corporation. Moody's considers Redwood, the
mortgage loan seller, to have strong aggregation and origination
practices compared to peers.

Borrowers of the mortgage loans backing this transaction have a
demonstrated ability to save and to manage credit. In addition, the
60.9% of the borrowers in the pool have more than 24 months of
liquid cash reserves or enough money to pay the mortgage for two
years should there be an interruption to the borrower's cash flow.
Consistent with prudent credit management, the borrowers have high
FICO scores with a weighted average score of 766. In general, the
borrowers have high income, significant liquid assets and a stable
employment history, all of which have been verified as part of the
underwriting process and reviewed by the TPR firms. Borrowers also
have significant equity in their homes (WA original CLTV 70.4%)
consistent with recent SEMT transactions.

Approximately, 10.98% of the mortgage loans by aggregate stated
principal balance are secured by mortgaged properties located in
the areas that the Federal Emergency Management Agency (FEMA) had
designated for federal assistance during the prior 12 months.
Redwood has engaged a third party to inspect these properties. No
material visible damage was detected from the inspection and the
related mortgage was included in the transaction pool.
Representations and warranties as to the mortgage loans will have
been made to the effect that in general, the mortgage loans will be
free of material damage as of the closing date.

Structural considerations

Similar to recently rated Sequoia transactions, in this
transaction, Redwood is adding a feature prohibiting the servicer,
or securities administrator, from advancing principal and interest
to loans that are 120 days or more delinquent. These loans on which
principal and interest advances are not made are called the Stop
Advance Mortgage Loans ("SAML"). The balance of the SAML will be
removed from the principal and interest distribution amounts
calculations. In its opinion, the SAML feature strengthens the
integrity of senior and subordination relationships in the
structure. Yet, in certain scenarios the SAML feature, as
implemented in this transaction, can lead to a reduction in
interest payments to certain tranches even when more subordinated
tranches are outstanding. The senior/subordination relationship
between tranches is strengthened since the removal of SAML in the
calculation of the senior percentage amount directs more principal
to the senior bonds and less to the subordinate bonds. Further,
this feature limits the amount of servicer advances that could
increase the loss severity on the liquidated loans and preserves
the subordination amount for the most senior bonds. On the other
hand, this feature can cause a reduction in the interest
distribution amount paid to the bonds; and if that were to happen
such a reduction in interest payment is unlikely to be recovered.
The final ratings on the bonds take into consideration its expected
losses on the collateral and the potential reduction in interest
distributions to the bonds. Furthermore, the likelihood that the
subordinate tranches could potentially permanently lose some
interest as a result of this feature was considered.

Moody's believes there is a low likelihood that the rated
securities of SEMT 2019-2 will incur any losses from extraordinary
expenses or indemnification payments owing to potential future
lawsuits against key deal parties. First, the loans are of prime
quality 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, Redwood, who initially retains the
subordinate classes and provides a back-stop to the representations
and warranties of all the originators except for First Republic
Bank, has a strong alignment of interest with investors, and is
incentivized to actively manage the pool to optimize performance.
Third, historical performance of loans aggregated by Redwood has
been very strong to date. Fourth, 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 must review loans for breaches of representations and
warranties when a loan becomes 120 days delinquent, which reduces
the likelihood that parties will be sued for inaction.

Tail Risk & Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
shrinks, senior bonds are exposed to increased performance
volatility, known as tail risk. The transaction provides for a
subordination floor of 1.45% of the closing pool balance, which
mitigates tail risk by protecting the senior bonds from eroding
credit enhancement over time.

Third-party Review and Reps & Warranties

Two TPR firms conducted a due diligence review of nearly 100% of
the mortgage loans in the pool. Generally, the TPR firms conducted
a review for credit, property valuation, compliance and data
integrity ("full review loans"). The TPR firms randomly selected 32
mortgage loans for limited review that were originated by First
Republic Bank.

Generally, for the full review loans, the sponsor or the originator
corrected all material errors identified by following defined
methods of error resolution under the TRID rule or TILA 130(b) as
per the proposed SFIG TRID framework. The sponsor or the originator
provided the borrower with a corrected Closing Disclosure and
letter of explanation as well as a refund where necessary. All
technical errors on the Loan Estimate were subsequently corrected
on the Closing Disclosure. Moody's believes that the TRID
noncompliance risk to the trust is immaterial due to the good-faith
efforts to correct the identified conditions.

No TRID compliance reviews were performed on the limited review
loans. Therefore, there is a possibility that some of these loans
could have unresolved TRID issues. Moody's reviewed the initial
compliance findings of loans from the same originator where a full
review was conducted and there were no material compliance
findings. As a result, it did not increase its Aaa stress loss.

Original property valuation was verified using an additional
valuation tool including, but not limited to, Collateral Desktop
Analysis (CDA), field review, Broker Price Opinion (BPO),
Collateral Underwriter's (CU) score, and/or Automated Valuation
Model (AVM). Moody's applied a negative adjustment to loans for
which property valuation was verified using AVM, since it considers
AVMs to be typically less accurate than desk reviews and field
reviews.

After a review of the TPR appraisal findings, Moody's notes that
there are 3 loans with final grade 'D' due to escrow holdback
distribution amounts. The review for these loans was incomplete
because the related appraisals were subject to the completion of
renovation work or missing evidence of disbursement of escrow
funds. In the event the escrow funds greater than 10% have not been
disbursed within six months of the closing date, the seller shall
repurchase the affected escrow holdback mortgage loan, on or before
the date that is six months after the closing date at the
applicable repurchase price. There are two other loans with final
grade 'C' due to compliance related issues. One such mortgage loan
was identified as having no evidence to support initial closing
disclosure sent to non-borrowing spouse. The other mortgage loan
was identified as having TRID related waiver as the total fee
amount exceeded the tolerance limit. Given that the seller has the
obligation to repurchase, it did not make an adjustment for these
loans.

Each of the originators makes the loan-level R&Ws for the loans it
originated, except for loans acquired by Redwood from the FHLB
Chicago. The mortgage loans purchased by Redwood from the FHLB
Chicago were originated by various participating financial
institution originators. For these mortgage loans, FHLB Chicago
will provide the loan-level R&Ws that are assigned to the trust.

In line with other SEMT transactions, the loan-level R&Ws for SEMT
2019-2 are strong and, in general, either meet or exceed the
baseline set of credit-neutral R&Ws it identified for US RMBS.

Among other things, the R&Ws address property valuation,
underwriting, fraud, data accuracy, regulatory compliance, the
presence of title and hazard insurance, the absence of material
property damage, and the enforceability of the mortgage.

The R&W providers vary in financial strength, which include some
financially weaker originators. To mitigate this risk, Redwood will
backstop any R&W providers who may become financially incapable of
repurchasing mortgage loans, except for First Republic Bank, which
is one of the strongest originators. Moreover, a third-party due
diligence firm conducted a detailed review on the loans of all of
the originators, which mitigates the risk of unrated and
financially weaker originators.

Trustee & Master Servicer

The transaction trustee is Wilmington Trust, National Association.
The paying agent and cash management functions will be performed by
Citibank, N.A. and the custodian functions will be performed by
Wells Fargo Bank, N.A., rather than the trustee. In addition,
Nationstar Mortgage LLC, as master servicer, is responsible for
servicer oversight, and termination of servicers and for the
appointment of successor servicers. In addition, Nationstar
Mortgage LLC is committed to act as successor if no other successor
servicer can be found. If servicers and the master servicer fail in
their obligation to fund any required advances, Citbank, N.A., as
the securities administrator will be obligated to do so.

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's original expectations
as a result of a higher number of obligor defaults or deterioration
in the value of the mortgaged property securing an obligor's
promise of payment. Transaction performance also depends greatly on
the US macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of loss could drive
the ratings up. Losses could decline from Moody's original
expectations as a result of a lower number of obligor defaults or
appreciation in the value of the mortgaged property securing an
obligor's promise of payment. Transaction performance also depends
greatly on the US macro economy and housing market.

Methodology

The principal methodology used in these ratings was "Moody's
Approach to Rating US Prime RMBS" published in November 2018.

Significant weight was put on judgment taking into account the
results of the modeling tools as well as the aggregate impact of
the third-party review and the quality of the servicers and
originators.


TRIMARAN CAVU 2019-1: S&P Rates $24.2MM Class E Notes 'BB- (sf)'
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Trimaran Cavu 2019-1
Ltd.'s fixed- and floating-rate notes.

The note issuance is a collateralized loan obligation (CLO)
transaction backed by primarily broadly syndicated
speculative-grade 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.

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

RATINGS ASSIGNED
Trimaran Cavu 2019-1 Ltd.

Class                       Rating   Amount (mil. $)
A-1                         AAA (sf)  354.00
A-2(i)                      NR         34.80
B(i)                        AA (sf)    66.00
C-1 (deferrable)(i)         A (sf)     23.00
C-2 (deferrable)            A (sf)     14.20
D (deferrable)(i)           BBB- (sf)  31.20
E (deferrable)(i)           BB- (sf)   24.20
Subordinated notes          NR         62.50

Exchangeable note combinations
                      Max. princ.
Class          Rating    Amount (mil. $)
Combination 1(iv)
A-2-1(ii)                   NR         34.80
A-2-1X(iii)                 NR           N/A
Combination 2(iv)
A-2-2(ii)                   NR         34.80
A-2-2X(iii)                 NR           N/A
Combination 3(iv)
A-3-3(ii)                   NR         34.80
A-3-3X(iii)                 NR           N/A
Combination 4(iv)
A-4-4(ii)                   NR         34.80
A-4-4X(iii)                 NR           N/A
Combination 5(iv)
B-1(ii)                AA (sf)         66.00
B-1X(iii)              AA (sf)           N/A
Combination 6(iv)
B-2 (deferrable)(ii)   AA (sf)         66.00
B-2X(iii)              AA (sf)           N/A
Combination 7(iv)
B-3(ii)                AA (sf)         66.00
B-3X(iii)              AA (sf)           N/A
Combination 8(iv)
B-4(ii)                AA (sf)         66.00
B-4X(iii)              AA (sf)           N/A
Combination 9(iv)
C-1-1(ii)               A (sf)         23.00
C-1-1X(iii)             A (sf)           N/A
Combination 10(iv)
C-1-2(ii)               A (sf)         23.00
C-1-2X(iii)             A (sf)           N/A
Combination 11(iv)
C-1-3(ii)               A (sf)         23.00
C-1-3X(iii)             A (sf)           N/A
Combination 12(iv)
C-1-4(ii)               A (sf)         23.00
C-1-4X(iii)             A (sf)           N/A
Combination 13(iv)
D-1(ii)              BBB- (sf)         31.20
D-1X(iii)            BBB- (sf)           N/A
Combination 14(iv)
D-2(ii)              BBB- (sf)         31.20
D-2X(iii)            BBB- (sf)           N/A
Combination 15(iv)
D-3(ii)              BBB- (sf)         31.20
D-3X(iii)            BBB- (sf)           N/A
Combination 16(iv)
D-4(ii)              BBB- (sf)         31.20
D-4X(iii)            BBB- (sf)           N/A
Combination 17(iv)
E-1(ii)               BB- (sf)         24.20
E-1X(iii)             BB- (sf)           N/A
Combination 18(iv)
E-2(ii)               BB- (sf)         24.20
E-2X(iii)             BB- (sf)           N/A
Combination 19(iv)
E-3(ii)               BB- (sf)         24.20
E-3X(iii)             BB- (sf)           N/A
Combination 20(iv)
E-4(ii)               BB- (sf)         24.20
E-4X(iii)             BB- (sf)           N/A

(i)The class A-2, B, C-1, D, and E notes will be exchangeable for
proportionate interest in combinations of MASCOT P&I notes and
interest-only notes of their respective classes. In aggregate, the
cost of debt, outstanding balance, stated maturity, subordination
levels, and payment priority following such an exchange would
remain the same. Reference the exchangeable note combinations
section for combinations.
(ii)MASCOT P&I notes will have the same principal balance as the
class A-2, B, C-1, D, and E notes, as applicable, surrendered in
the exchange.
(iii)Interest-only notes earn a fixed rate of interest on its
notional balance and is not entitled to any payments of principal.
The notional balance will equal the principal balance of the
corresponding MASCOT P&I note of such combination.
(iv)Applicable combinations will have an aggregate interest rate
equal to that of the exchanged note.
P&I--Principal and interest.
NR--Not rated.
N/A--Not applicable.


UNITED AUTO 2019-1: DBRS Finalizes B Rating on Class F Notes
------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of notes issued by United Auto Credit Securitization Trust
2019-1 (UACST 2019-1 or the Issuer):

-- $142,500,000 Class A Notes rated AAA (sf)
-- $32,180,000 Class B Notes rated AA (sf)
-- $33,700,000 Class C Notes rated A (sf)
-- $39,840,000 Class D Notes rated BBB (low) (sf)
-- $21,920,000 Class E Notes rated BB (sf)
-- $14,860,000 Class F Notes rated B (sf)

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

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

-- Credit enhancement is in the form of over-collateralization,
subordination, amounts held in the reserve account and excess
spread. Credit enhancement levels are sufficient to support
DBRS-projected expected cumulative net loss assumptions under
various stress scenarios.

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

-- United Auto Credit Corporation's (UACC or the Company)
capabilities with regard to originations, underwriting and
servicing and the existence of an experienced and capable backup
servicer.

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

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

-- UACC successfully consolidated its business into a centralized
servicing platform and consolidated originations into two regional
buying centers. The Company retained experienced managers and staff
at the servicing center and buying centers.

-- UACC continues to evaluate and fine-tune its underwriting
standards as necessary. UACC has a risk management system allowing
centralized oversight of all underwriting and substantial
technology systems, which provide daily metrics on all
originations, servicing and collections of loans.

-- The credit quality of the collateral and performance of the
Company's auto loan portfolio.

-- UACC originates collateral that generally has shorter terms,
higher down payments, lower book values and higher borrower income
requirements than some other subprime auto loan originators.

-- UACST 2019-1 provides for Class F Notes with an assigned rating
of B (sf). While the DBRS "Rating U.S. Retail Auto Loan
Securitizations" methodology does not set forth a range of
multiples for this asset class at the B (sf) level, the analytical
approach for this rating level is consistent with that contemplated
by the methodology. The typical range of multiples applied in the
DBRS stress analysis for a B (sf) rating is 1.00 times (x) to
1.25x.

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

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


WELLS FARGO 2017-C38: Fitch Affirms B- Rating on $11.2MM F Certs
----------------------------------------------------------------
Fitch Ratings affirms 15 classes of Wells Fargo Commercial Mortgage
Trust 2017-C38 commercial mortgage pass-through certificates.

KEY RATING DRIVERS

Stable Loss Expectations: Pool performance and loss expectations
remain stable. There are no specially serviced loans, no loans have
paid off and there have been no delinquent loans since issuance.
Fitch identified three loans (1.6% of the pool) as Fitch Loans of
Concern (FLOCs) due to upcoming lease rollover risk and declining
performance.

The largest loan in the pool is the General Motors Building (10.1%
of the pool). The loan is secured by a class A, 50-story, 1.7
million sf office building located in the Plaza District of
Manhattan. The property also includes 151k sf of retail, which
includes the iconic Apple cube. At issuance, it was noted that
Under Armour was expected to build out a new flagship retail
location at the property. However, the plans are currently on hold.
Apple continues to occupy the proposed Under Armour space under a
temporary basis until the renovation to Apple's permanent retail
space is completed. Fitch requested an update from the master
servicer on the expected completion date of the Apple space, but a
response was not received. The property serves as the global
headquarters for its largest tenant, Weil, Gotshal & Manges (20.6%
of the NRA).

The largest FLOCs is the Hilton Garden Inn - Ames (1.2% of the
pool). The loan is currently on the servicer's watchlist for
declining performance and occupancy since issuance. As of December
2018, occupancy was reported at 66% from 70% at YE 2017 and 74% at
issuance and NOI DSCR declined to 1.41x from 1.73x at YE 2017 and
1.90x at issuance. Fitch's adjusted NOI at issuance remains lower
than the current reported NOI. Per the December 2018 STR report,
ADR and RevPar were reported as $136 and $90, respectively; RevPar
has declined since YE 2017 due to the declining occupancy.
Additionally, the hotel reported positive penetration rates for
occupancy, ADR and RevPar. Per the master servicer, the borrower
intends to increase marketing and advertising to increase occupancy
at the property. Fitch will continue to monitor the loan for
further updates.

Minimal Change to Credit Enhancement: As of the May 2019
remittance, the pool has been reduced by 0.9% to $1.144 billion
from $1.154 billion at issuance. Based on the scheduled balance at
maturity, the pool is only expected to be reduced by 7.1%. Eighteen
loans (57.1% of the pool) are interest only, including 12 loans in
the top 15 (General Motors Building [10.1%], Del Amo Fashion Center
[5.2%], 245 Park Avenue [4.8%], Starwood Capital Group Hotel
Portfolio [4.4%], Long Island Prime Portfolio - Melville [4.2%],
225 & 233 Park Avenue South [3.9%], Market Street - The Woodlands
[3.9%], iStar Leased Fee Portfolio [3.6%], Amazon Lakeland [2.9%],
ExchangeRight Net Leased Portfolio [2.9%], 2851 Junction [2.5%],
123 William Street [2.4%]). Twelve loans (13.4%) are partial
interest only, including two loans in the top 15 (Valley Creek
Corporate Center [3.0%] and Raleigh Marriott City Center [2.6%]).
The remaining loans are amortizing.

Investment Grade Credit Opinion Loans: Four of the top 15 loans
(24.0%) at issuance were assigned standalone investment grade
credit opinions; The General Motors Building (10.1%), the Del Amo
Fashion Center (5.2%), 245 Park Avenue (4.8%) and 225 Park Avenue
(3.9%) received investment grade standalone credit opinions of
'AAAsf', 'BBBsf', 'BBB-sf' and 'BBB-sf', respectively.

RATING SENSITIVITIES

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

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

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

Fitch has affirmed the following ratings:

  -- $22.4 million class A-1 at 'AAAsf'; Outlook Stable;

  -- $42.5 million class A-2 at 'AAAsf'; Outlook Stable;

  -- $8.6 million class A-3 at 'AAAsf'; Outlook Stable;

  -- $36.1 million class A-SB at 'AAAsf'; Outlook Stable;

  -- $300.0 million class A-4 at 'AAAsf'; Outlook Stable;

  -- $366.3 million class A-5 at 'AAAsf'; Outlook Stable;

  -- $119.4 million class A-S at 'AAAsf'; Outlook Stable;

  -- $50.6 million class B at 'AA-sf'; Outlook Stable;

  -- $44.9 million class C at 'A-sf'; Outlook Stable;

  -- $49.2 million class D at 'BBB-sf'; Outlook Stable;

  -- $22.5 million class E at 'BB-sf'; Outlook Stable;

  -- $11.2 million class F at 'B-sf'; Outlook Stable;

  -- $775.9 million class X-A* at 'AAAsf'; Outlook Stable;

  -- $214.9 million class X-B* at 'A-sf'; Outlook Stable;

  -- $49.2 million class X-D* at 'BBB-sf'; Outlook Stable.

  * Notional amount and interest only.

Fitch does not rate the class G or Vertical Risk Retention Interest
(VRRI) certificates.


WELLS FARGO 2019-2: Fitch Rates $2.214MM Class B-4 Certs 'BBsf'
---------------------------------------------------------------
Fitch Ratings has assigned the following ratings to Wells Fargo
Mortgage Backed Securities 2019-2 Trust (WFMBS 2019-2):

  -- $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 rates 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 (WA) 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 (R&Ws) 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 Assigns Ba3 Rating on Class B-4 Debt
----------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to 24
classes of residential mortgage-backed securities issued by Wells
Fargo Mortgage Backed Securities 2019-2 Trust. The ratings range
from Aaa (sf) to 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 (QM) under the QM safe harbor rules.

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

The WFMBS 2019-2 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: Wells Fargo Mortgage Backed Securities 2019-2 Trust

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-4, Definitive Rating Assigned Aaa (sf)

Cl. A-5, Definitive Rating Assigned Aaa (sf)

Cl. A-6, Definitive Rating Assigned Aaa (sf)

Cl. A-7, Definitive Rating Assigned Aaa (sf)

Cl. A-8, Definitive Rating Assigned Aaa (sf)

Cl. A-9, Definitive Rating Assigned Aaa (sf)

Cl. A-10, Definitive Rating Assigned Aaa (sf)

Cl. A-11, Definitive Rating Assigned Aaa (sf)

Cl. A-12, Definitive Rating Assigned Aaa (sf)

Cl. A-13, Definitive Rating Assigned Aaa (sf)

Cl. A-14, Definitive Rating Assigned Aaa (sf)

Cl. A-15, Definitive Rating Assigned Aaa (sf)

Cl. A-16, Definitive Rating Assigned Aaa (sf)

Cl. A-17, Definitive Rating Assigned Aa1 (sf)

Cl. A-18, Definitive Rating Assigned Aa1 (sf)

Cl. A-19, Definitive Rating Assigned Aaa (sf)

Cl. A-20, Definitive Rating Assigned Aaa (sf)

Cl. B-1, Definitive Rating Assigned Aa3 (sf)

Cl. B-2, Definitive Rating Assigned A3 (sf)

Cl. B-3, Definitive Rating Assigned Baa3 (sf)

Cl. B-4, Definitive Rating Assigned 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 (MILAN) model. Loan-level
adjustments to the model included adjustments to borrower
probability of default for higher and lower borrower debt-to-income
ratios (DTIs), for borrowers with multiple mortgaged properties,
self-employed borrowers, origination channels and for the default
risk of Homeownership association (HOA) properties in super lien
states. The model combines loan-level characteristics with economic
drivers to determine the probability of default for each loan, and
hence for the portfolio as a whole. Severity is also calculated on
a loan-level basis. The pool loss level is then adjusted for
borrower, zip code, and MSA level concentrations.

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 (LTV) 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 Bank'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 Bank 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 Bank 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 (R&Ws) for the mortgage loans.
Moody's analyzed the strength of the R&W provider, the R&Ws
themselves and the enforcement mechanisms. The R&W provider is
highly rated, the breach reviewer is independent and the breach
review process is thorough, transparent and objective. 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 Bank's robust processes for verifying and reviewing the
reasonableness of the information used in loan origination along
with effectively no knowledge qualifiers mitigates any risks
involved. Wells Fargo Bank has an anti-fraud software tools that
are integrated with the loan origination system (LOS) and utilized
pre-closing for each loan. In addition, Wells Fargo Bank has a
dedicated credit risk, compliance and legal teams oversee fraud
risk in addition to compliance and operational risks. Moody's did
not make any 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 a 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 Bank 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.


WESTLAKE AUTOMOBILE 2019-2: S&P Gives Prelim B+ Rating to F Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Westlake
Automobile Receivables 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 preliminary ratings are based on information as of June 5,
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 48.3%, 41.5%, 33.1%, 25.5%,
21.8%, and 18.5% credit support for the class A, B, C, D, E, and F
notes, respectively, based on stressed cash flow scenarios
(including excess spread). These provide approximately 3.50x,
3.00x, 2.30x, 1.75x, 1.50x, and 1.23x, respectively, of S&P's
13.00%-13.50% expected cumulative net loss range.

-- The transaction's ability to make timely interest and principal
payments under stressed cash flow modeling scenarios appropriate
for the assigned preliminary ratings.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal and for the transaction's life, its
rating on the class A notes would not likely be lowered from the
assigned preliminary rating; its ratings on the class B and C notes
would likely remain within one rating category of the assigned
preliminary ratings; and its rating on the class D notes would
likely remain within two rating categories of the assigned
preliminary rating. S&P's ratings on the class E and F notes would
likely remain within two rating categories of the assigned
preliminary ratings during the first year but would ultimately
default under its 'BBB' moderate stress scenario, which is within
the bounds of its credit stability criteria.

-- The collateral characteristics of the securitized pool of
subprime automobile loans.

-- The originator/servicer's long history in the
subprime/specialty auto finance business.

-- S&P's analysis of approximately 13 years (2006-2018) of static
pool data on the company's lending programs.

-- The transaction's payment, credit enhancement, and legal
structures.

  PRELIMINARY RATINGS ASSIGNED
  Westlake Automobile Receivables Trust 2019-2
  Class         Rating       Amount (mil. $)
  A-1           A-1+ (sf)             177.00
  A-2-A/A-2-B   AAA (sf)              360.70
  B             AA (sf)                79.40
  C             A (sf)                100.60
  D             BBB (sf)               94.20
  E             BB (sf)                41.50
  F             B+ (sf)                46.60


[*] DBRS Reviews 518 Classes From 41 US RMBS Transactions
---------------------------------------------------------
DBRS, Inc. reviewed 518 classes from 41 U.S. residential
mortgage-backed security (RMBS) transactions. Of the 518 classes
reviewed, DBRS upgraded 30 ratings, confirmed 487 ratings and
discontinued one rating.

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 discontinued rating is 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 RMBS transactions consist of prime,
subprime, Alt-A, non-Qualified Mortgage, and reperforming
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, as well as actual deal or tranche performance
that is not fully reflected in the projected cash flows or model
output.

-- Credit Suisse First Boston Mortgage Securities Corp. Adjustable
Rate Mortgage Trust 2005-5, Adjustable Rate Mortgage-Backed
Pass-Through Certificates, Series 2005-5, Class 6-A-2-1

-- Credit Suisse First Boston Mortgage Securities Corp. Adjustable
Rate Mortgage Trust 2005-5, Adjustable Rate Mortgage-Backed
Pass-Through Certificates, Series 2005-5, Class 6-A-2-2

-- C-BASS 2006-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB6, Class A-I

-- C-BASS 2006-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB6, Class A-II-3

-- C-BASS 2006-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB6, Class A-II-4

-- C-BASS 2006-CB6 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-CB6, Class M-1

-- C-BASS 2006-RP1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-RP1, Class M-2

-- C-BASS 2006-RP1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-RP1, Class M-3

-- C-BASS 2006-RP1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-RP1, Class B-1

-- C-BASS 2006-RP1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-RP1, Class B-2

-- C-BASS 2006-RP1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2006-RP1, Class B-3

-- C-BASS 2007-MX1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2007-MX1, Class A-2

-- C-BASS 2007-MX1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2007-MX1, Class A-3

-- C-BASS 2007-MX1 Trust, C-BASS Mortgage Loan Asset-Backed
Certificates, Series 2007-MX1, Class A-4

-- Citigroup Mortgage Loan Trust 2006-WFHE3, Asset-Backed
Pass-Through Certificates, Series 2006-WFHE3, Class M-2

-- Citigroup Mortgage Loan Trust 2006-WFHE3, Asset-Backed
Pass-Through Certificates, Series 2006-WFHE3, Class M-3

-- CWABS Asset-Backed Certificates Trust 2004-AB2, Asset-Backed
Certificates, Series 2004-AB2, Class M-2

-- CWABS Asset-Backed Certificates Trust 2004-AB2, Asset-Backed
Certificates, Series 2004-AB2, Class M-3

-- First Franklin Mortgage Loan Trust 2005-FFH3, Asset-Backed
Certificates, Series 2005-FFH3, Class M-3

-- Fremont Home Loan Trust 2005-D, Mortgage-Backed Certificates,
Series 2005-D, Class 2-A-4

-- Fremont Home Loan Trust 2005-D, Mortgage-Backed Certificates,
Series 2005-D, Class M1

-- GSAMP Trust 2005-HE3, Mortgage Pass-Through Certificates,
Series 2005-HE3, Class M-3

-- GSAMP Trust 2005-HE3, Mortgage Pass-Through Certificates,
Series 2005-HE3, Class M-4

-- Credit Suisse First Boston Mortgage Securities Corp. Home
Equity Asset Trust 2005-8, Home Equity Pass-Through Certificates,
Series 2005-8, Class M-1

-- Credit Suisse First Boston Mortgage Securities Corp. Home
Equity Asset Trust 2005-8, Home Equity Pass-Through Certificates,
Series 2005-8, Class M-2

-- Credit Suisse First Boston Mortgage Securities Corp. Home
Equity Asset Trust 2006-4, Home Equity Pass-Through Certificates,
Series 2006-4, Class 1-A-1

-- Credit Suisse First Boston Mortgage Securities Corp. Home
Equity Asset Trust 2006-4, Home Equity Pass-Through Certificates,
Series 2006-4, Class 2-A-4

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 1-A-1

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 1-A-2

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 2-A-1

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 2-A-2

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 3-A-2

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 3-A-3

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 3-A-4

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 4-A-1

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 5-A-2

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 5-A-3

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 6-A-1

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 6-A-2

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 7CB1

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 7CB2

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 8-A-1

-- J.P. Morgan Mortgage Trust 2005-A2, Mortgage Pass-Through
Certificates, Series 2005-A2, Class 9-A-1

-- Morgan Stanley ABS Capital I Inc. Trust 2005-WMC6, Mortgage
Pass-Through Certificates, Series 2005-WMC6, Class M-3

-- Morgan Stanley ABS Capital I Inc. Trust 2005-WMC6, Mortgage
Pass-Through Certificates, Series 2005-WMC6, Class M-4

-- Morgan Stanley Capital I Inc. Trust 2006-NC2, Mortgage
Pass-Through Certificates, Series 2006-NC2, Class A-1

-- Morgan Stanley Capital I Inc. Trust 2006-NC2, Mortgage
Pass-Through Certificates, Series 2006-NC2, Class A-2d

-- New Century Home Equity Loan Trust 2004-3, Asset-Backed Notes,
Series 2004-3, Class M-1

-- New Century Home Equity Loan Trust 2004-3, Asset-Backed Notes,
Series 2004-3, Class M-2

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B-5

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B-5A

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B-5B

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B-5C

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B-5D

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B5-IOA

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B5-IOB

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B5-IOC

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B5-IOD

-- New Residential Mortgage Loan Trust 2017-4, Mortgage-Backed
Notes, Series 2017-4, Class B-7

-- Angel Oak Mortgage Trust I, LLC 2017-1, Mortgage-Backed
Certificates, Series 2017-1, Class B-1

-- Angel Oak Mortgage Trust I, LLC 2017-1, Mortgage-Backed
Certificates, Series 2017-1, Class B-2

-- Angel Oak Mortgage Trust I, LLC 2017-2, Mortgage-Backed
Certificates, Series 2017-2, Class A-3

-- Angel Oak Mortgage Trust I, LLC 2017-2, Mortgage-Backed
Certificates, Series 2017-2, Class M-1

-- Angel Oak Mortgage Trust I, LLC 2017-3, Mortgage-Backed
Certificates, Series 2017-3, Class A-3

-- Angel Oak Mortgage Trust I, LLC 2017-3, Mortgage-Backed
Certificates, Series 2017-3, Class M-1

-- Angel Oak Mortgage Trust I, LLC 2017-3, Mortgage-Backed
Certificates, Series 2017-3, Class B-1

-- Angel Oak Mortgage Trust I, LLC 2017-3, Mortgage-Backed
Certificates, Series 2017-3, Class B-2

-- Angel Oak Mortgage Trust I, LLC 2018-2, Mortgage-Backed
Certificates, Series 2018-2, Class A-3

-- Angel Oak Mortgage Trust I, LLC 2018-2, Mortgage-Backed
Certificates, Series 2018-2, Class M-1

-- Angel Oak Mortgage Trust I, LLC 2018-2, Mortgage-Backed
Certificates, Series 2018-2, Class B-1

-- Angel Oak Mortgage Trust I, LLC 2018-2, Mortgage-Backed
Certificates, Series 2018-2, Class B-2

-- Angel Oak Mortgage Trust I, LLC 2018-3, Mortgage-Backed
Certificates, Series 2018-3, Class A-3

-- Angel Oak Mortgage Trust I, LLC 2018-3, Mortgage-Backed
Certificates, Series 2018-3, Class M-1

-- CSMC Trust 2017-RPL1, Mortgage-Backed Securities Series
2017-RPL1, Class M1

-- CSMC Trust 2017-RPL1, Mortgage-Backed Securities Series
2017-RPL1, Class M2

-- CSMC Trust 2017-RPL1, Mortgage-Backed Securities Series
2017-RPL1, Class B1

-- CSMC 2017-RPL3 Trust, Mortgage-Backed Notes, Series 2017-RPL3,
Class B-2

-- CSMC 2017-RPL3 Trust, Mortgage-Backed Notes, Series 2017-RPL3,
Class B2-IO

-- CSMC 2017-RPL3 Trust, Mortgage-Backed Notes, Series 2017-RPL3,
Class B-4

-- CSMC 2017-RPL3 Trust, Mortgage-Backed Notes, Series 2017-RPL3,
Class B-5

-- CSMC 2018-RPL9 Trust, Mortgage-Backed Notes, Series 2018-RPL9,
Class B-2

-- Freddie Mac Seasoned Credit Risk Transfer Trust, Series 2018-2,
Series 2018-2, Class M

-- Freddie Mac Seasoned Credit Risk Transfer Trust, Series 2018-3,
Series 2018-3, Class M

-- Freddie Mac Seasoned Credit Risk Transfer Trust, Series 2018-4,
Series 2018-4, Class M

-- Mill City Mortgage Loan Trust 2018-2, Mortgage Backed
Securities, Series 2018-2, Class A3

-- Mill City Mortgage Loan Trust 2018-2, Mortgage Backed
Securities, Series 2018-2, Class M2

-- New Residential Mortgage Loan Trust 2018-RPL1, Mortgage-Backed
Notes, Series 2018-RPL1, Class A-4

-- New Residential Mortgage Loan Trust 2018-RPL1, Mortgage-Backed
Notes, Series 2018-RPL1, Class M-1

-- New Residential Mortgage Loan Trust 2018-RPL1, Mortgage-Backed
Notes, Series 2018-RPL1, Class M-2

-- New Residential Mortgage Loan Trust 2018-RPL1, Mortgage-Backed
Notes, Series 2018-RPL1, Class B-1

-- New Residential Mortgage Loan Trust 2018-RPL1, Mortgage-Backed
Notes, Series 2018-RPL1, Class B-2

The Affected Ratings is Available at https://bit.ly/2wngXuV


[*] Fitch Took Actions Then Withdrew Ratings on 6 US CMBS Deals
---------------------------------------------------------------
Fitch Ratings, on May 23, 2019, took various actions in already
distressed bonds in six U.S. commercial mortgage-backed securities
(CMBS) transactions.

The issuers are:

  ML-CFC Commercial Mortgage Trust
  Morgan Stanley Capital I Trust
  Banc of America Commercial Mortgage Inc.
Greenwich Capital Commercial Funding Corporation

The ratings have been withdrawn as they are no longer considered by
Fitch to be relevant to the agency's coverage.

KEY RATING DRIVERS

Ten bonds in three transactions have been downgraded to 'Dsf', as
the bonds have incurred a principal write-down. All bonds were
previously rated 'Csf', which indicated that a default was
imminent.

Fitch has affirmed 30 classes in three transactions at 'Dsf' as a
result of previously incurred realized losses. The ratings on six
of these classes in one transaction have also been withdrawn as
they are no longer considered by Fitch to be relevant to the
agency's coverage. The trust balance has been reduced to zero.

RATING SENSITIVITIES

The downgrades are limited to the bonds with a principal
write-down. Any remaining bonds in the transaction have not been
analyzed as part of this review. No further rating changes are
expected as these bonds have incurred principal realized losses.
While the bonds that have defaulted are not expected to recover any
material amount of lost principal in the future, there is a limited
possibility this may happen. In this unlikely scenario, Fitch would
further review the affected classes.

The Affected Ratings are available at https://bit.ly/31bRh2D


[*] S&P Takes Various Actions on 32 Classes From 15 US RMBS Deals
-----------------------------------------------------------------
S&P Global Ratings completed its review of 32 classes from 15 U.S.
residential mortgage-backed securities (RMBS) transactions,
including 14 resecuritized real estate mortgage investment conduit
(re-REMIC) transactions, issued between 2003 and 2009. All of these
transactions are backed by prime jumbo, subprime, home equity line
of credit (HELOC), and Alternative-A collateral. The review yielded
five upgrades, four downgrades, 22 affirmations, and one
discontinuance.

ANALYTICAL CONSIDERATIONS

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes. Some of these considerations may include:

-- Collateral performance/delinquency trends;
-- Underlying collateral performance;
-- Available subordination and/or overcollateralization;
-- Erosion of or increases in credit support; and
-- Expected short duration.

RATING ACTIONS

"The rating changes reflect our opinion regarding the associated
transaction-specific collateral performance or structural
characteristics or reflect the application of specific criteria
applicable to these classes. Please see the ratings list below for
the specific rationales associated with each of the classes with
rating transitions," S&P said.

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

S&P lowered its ratings on classes A-2 and A-4 from CitiGroup
Mortgage Loan Trust, Series 2003-UP2 to reflect the impact of
passing triggers, which continue to divert principal to subordinate
classes, eroding projected credit support for the affected senior
classes. Hard credit support decreased to $684,000, as of April
2019, from $884,000 during the last year. Classes A-2 and A-4 are
also underlying classes to class IIA-1 from Citigroup Mortgage Loan
Trust Inc., Series 2004-RR1 and as such, class IIA-1 was also
downgraded to the same rating as that of the underlying classes.

A list of Affected Ratings can be viewed at:

           https://bit.ly/2WgZUtQ


[*] S&P Takes Various Actions on 66 Classes From 8 US RMBS Deals
----------------------------------------------------------------
S&P Global Ratings completed its review of 66 classes from eight
U.S. residential mortgage-backed securities (RMBS) transactions
issued between 2004 and 2005. All of these transactions are backed
by Alternative-A and negative amortization collateral. The review
yielded seven upgrades, 18 downgrades, 40 affirmations, and one
discontinuance. Of the seven raised ratings, two are corrections to
prior assigned ratings.

S&P said it corrected its ratings on classes 2-A1A and 2-A1B from
Structured Asset Securities Corp. Mortgage Loan Trust 2005-7XS.
These corrections are due to an update in the cash flow allocation
data provided by Intex Solutions Inc. (Intex), a third-party data
provider, according to the rating agency.

"While the internal model we use in determining our ratings on U.S.
RMBS transactions typically applies to our criteria assumptions, in
many cases, Intex provides the collateral composition and
structural modeling used as inputs to our analysis," S&P said.
"Therefore, the resulting collateral characteristics and structural
mechanics that use our input assumptions depend on the modeling and
data provided to us by Intex."

During this review, S&P observed that the cash flow results for
these Group 2 classes were inconsistent with the available credit
support. The rating agency subsequently determined that Intex was
not applying the cash flow allocation for these classes as per the
transaction documents and it informed Intex of the discrepancy. As
such, Intex corrected its cash flow allocation data to reflect what
was set forth in the transaction documents. Based on its updated
cash flow results and its current view of these classes' credit
risk, S&P has raised its ratings on classes 2-A1A and 2-A1B.

ANALYTICAL CONSIDERATIONS

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance or structural
characteristics (or both) and their potential effects on certain
classes. Some of these considerations may include:

-- Collateral performance/delinquency trends;
-- Historical missed interest payments;
-- Available subordination and/or overcollateralization; and
-- Erosion of or increases in credit support.

RATING ACTIONS

"The rating changes reflect our opinion regarding the associated
transaction-specific collateral performance and/or structural
characteristics, and/or reflect the application of specific
criteria applicable to these classes. Please see the ratings list
below for the specific rationales associated with each of the
classes with rating transitions," S&P said.

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

A list of Affected Ratings can be viewed at:

           https://bit.ly/2WEaWca


                            *********

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