/raid1/www/Hosts/bankrupt/TCR_Public/190707.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

              Sunday, July 7, 2019, Vol. 23, No. 187

                            Headlines

AIMCO CLO 10: Moody's Assigns Ba3 Rating on $18.7MM Cl. E Notes
ALL STUDENT IV: Moody's Cuts Ratings on 5 Tranches to Caa3
ATRIUM HOTEL 2018-ATRM: DBRS Confirms B(low) Rating on Cl. F Certs
AVERY POINT VII: Moody's Affirms B3 Rating on $7.2MM Class F Notes
BUCKEYE TOBACCO: Moody's Lowers Rating on 4 Tranches to Ca

BX TRUST 2019-RP: Fitch Rates $28.5MM Class F Certs 'B-'
CABELA'S CREDIT 2013-I: DBRS Confirms BB Rating on Class D Notes
CARVANA AUTO 2019-2: Moody's Assigns B2 Rating on Class E Notes
CITIGROUP COMMERCIAL 2012-GC8: Fitch Affirms Cl. F Certs at Bsf
CMLS ISSUER 2014-1: Fitch Affirms BBsf Rating on Class F Certs

COLT 2019-3: Fitch Rates $2.3MM Class B-1 Certs 'B+'
CSAIL 2019-C16: Fitch Gives B- Rating on $7.87MM Class G-RR Certs
CSMC TRUST 2017-CHOP: DBRS Confirms BB(low) Rating on Cl. E Certs
CSMC TRUST 2017-MOON: Fitch Affirms BB-sf Rating on Class E Certs
FOURSIGHT CAPITAL 2019-1: Moody's Rates $11.9MM Class F Notes 'B2'

FREED ABS 2018-1: DBRS Confirms BB(high) Rating on Class C Notes
GREENWICH CAPITAL 2007-GG11: Fitch Affirms D Rating on 12 Tranches
HORIZON AIRCRAFT II: Fitch Rates $41MM Series C Notes 'BBsf'
JP MORGAN 2012-C6: Moody's Affirms B2 Rating on Class H Debt
JP MORGAN 2016-JP2: Fitch Affirms BB-sf Rating on Class E Certs

JP MORGAN 2019-5: Moody's Assigns B3 Rating on Cl. B-5 Debt
JPMCC COMMERCIAL 2019-COR5: Fitch Rates $6.9MM Cl. G-RR Certs B-sf
KEY COMMERCIAL 2019-S2: DBRS Assigns Prov. B Rating on Cl. F Certs
LB COMMERCIAL 1999-C1: Moody's Affirms C Ratings on 2 Tranches
LB-UBS COMMERCIAL 2007-C1: Fitch Affirms D Rating on 6 Tranches

LENDMARK FUNDING 2019-1: DBRS Gives Prov. BB Rating on Cl. D Notes
MARLIN RECEIVABLES 2018-1: Fitch Affirms BBsf Rating on Cl. E Debt
MORGAN STANLEY 2011-C3: Moody's Affirms B2 Rating on Cl. G Certs
NEW RESIDENTIAL 2019-3: Moody's Assigns (P)B1 Rating on 5 Tranches
NEW RESIDENTIAL 2019-NQM3: DBRS Finalizes B Rating on Cl. B-2 Notes

NOMURA CRE 2007-2: Fitch Lowers Rating on Class D Debt to 'Dsf'
OBX TRUST 2019-INV2: Moody's Assigns B3 Rating on Class B-5 Debt
PREFERREDPLUS TRUST CZN-1: Moody's Cuts $34MM Certs Rating to Caa2
REALT 2019-1: DBRS Finalizes B Rating on Class G Certificates
RMF BUYOUT 2019-1: Moody's Rates Class M4 Debt 'Ba2'

SCF EQUIPMENT 2018-1: Moody's Confirms B1 Rating on Cl. F Notes
SUTHERLAND COMMERCIAL 2019-SBC8: DBRS Finalizes B Rating on G Certs
TOWD POINT 2017-6: Fitch Rates $85.92MM Class B3 Notes 'Bsf'
TOWD POINT 2018-1: Fitch Rates $24.45MM Class B2 Notes 'Bsf'
TOWD POINT 2019-HE1: Fitch Rates $5.36MM Class B2 Notes 'Bsf'

WACHOVIA BANK 2005-C20: Moody's Hikes Class G Certs Rating to Caa2
WAMU COMMERCIAL 2007-SL2: Moody's Hikes Class E Certs Rating to B3
WFRBS COMMERCIAL 2019-C9: Moody's Affirms B2 Rating Class F Certs
[*] DBRS Reviews 742 Classes From 39 US RMBS Transactions

                            *********

AIMCO CLO 10: Moody's Assigns Ba3 Rating on $18.7MM Cl. E Notes
---------------------------------------------------------------
Moody's Investors Service assigned ratings to two classes of notes
issued by AIMCO CLO 10, Ltd.

Moody's rating action is as follows:

US$292,500,000 Class A Senior Secured Floating Rate Notes due 2032
(the "Class A Notes"), Assigned Aaa (sf)

US$18,700,000 Class E Junior Secured Deferrable Floating Rate Notes
due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

The Class A Notes and the Class E 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.

AIMCO 10 is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90% of the portfolio must consist of
senior secured loans and eligible investments, and up to 10% of the
portfolio may consist of second lien loans and unsecured loans. The
portfolio is approximately 83% ramped as of the closing date.

Allstate Investment Management Company 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 three other
classes of secured notes and one class of subordinated notes.

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

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

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

Par amount: $450,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 3022

Weighted Average Spread (WAS): 3.25%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 47.5%

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 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.


ALL STUDENT IV: Moody's Cuts Ratings on 5 Tranches to Caa3
----------------------------------------------------------
Moody's Investors Service downgraded the ratings of eight tranches
issued by All Student Loan Corporation, Series IV (Access to Loans
for Learning Corporation, Series IV), which is backed by student
loans originated under the Federal Family Education Loan Program.
The loans are guaranteed by the US government for a minimum of 97%
of defaulted principal and accrued interest.

The complete rating actions are as follow:

Issuer: All Student Loan Corporation, Series IV (Access to Loans
for Learning Corporation, Series IV)

Sr Ser. IVA-11, Downgraded to Caa2; previously on Nov 15, 2016
Downgraded to B3

Senior Ser. IV-A-8, Downgraded to Caa2; previously on Nov 15, 2016
Downgraded to B3

Senior Ser. IV-A-10, Downgraded to Caa2; previously on Nov 15, 2016
Downgraded to B3

Senior Ser. IV-A-14, Downgraded to Caa3; previously on Nov 15, 2016
Downgraded to Caa1

Senior Ser. IV-A-15, Downgraded to Caa3; previously on Nov 15, 2016
Downgraded to Caa1

Senior Ser. IV-A-16, Downgraded to Caa3; previously on Nov 15, 2016
Downgraded to Caa1

Senior Ser. IV-A-17, Downgraded to Caa3; previously on Nov 15, 2016
Downgraded to Caa1

Senior Ser. IV-A-18, Downgraded to Caa3; previously on Nov 15, 2016
Downgraded to Caa1

RATINGS RATIONALE

The primary rationale for the downgrades is continued decrease of
collateral base and under collateralization. High coupon cost has
been eroding the collateral base of this transaction, causing
steady declines in the overall parity ratio (the ratio of total
assets to the sum of the balances for all outstanding bonds), to
96.2% as of March 2019 from 97.9% as of March 2018.

Moody's analysis indicates that the tranches will not pay off by
final maturity dates in either some or all of Moody's 28 cash flow
scenarios, thus causing the tranches to incur expected losses that
are higher than the expected loss benchmarks set in Moody's
idealized loss tables for the previous ratings.

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

Up

Among the factors that could drive the ratings up are lower than
expected borrower usage of deferment, forbearance and IBR, higher
than expected voluntary prepayment rates, prepayments with proceeds
from sponsor repurchases of student loan collateral.

Down

Among the factors that could drive the ratings down are lower than
expected levels of voluntary prepayments, higher than expected
borrower usage of deferment, forbearance and IBR, declining credit
quality of the US government.



ATRIUM HOTEL 2018-ATRM: DBRS Confirms B(low) Rating on Cl. F Certs
------------------------------------------------------------------
DBRS Limited confirmed all classes of Commercial Mortgage
Pass-Through Certificates, Series 2018-ATRM issued by Atrium Hotel
Portfolio Trust 2018-ATRM as follows:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since closing in June 2018 with an original trust
balance of $635.0 million. The collateral consists of 24 hotels
assets, including 16 full-service hotels, four extended-stay
hotels, and four limited-service hotels, totaling 5,734 keys
located across 12 states, all of which are cross-collateralized and
cross-defaulted. All hotels, except for one, operate under various
flags owned by Hilton Hotels & Resorts (Hilton) or Marriott
International. The majority of the properties, representing 68.9%
of the allocated loan balance, operate as Embassy Suites by Hilton.
Other flags within the portfolio include Courtyard by Marriott,
Residence Inn by Marriott, Renaissance, Marriott as well as
Sheraton Hotels and Resorts. Loan proceeds, along with a $112.4
million equity infusion from Atrium Holding Company (Atrium or the
sponsor), retired $672.2 million of existing debt, established
$61.9 million of upfront reserves and covered $13.3 million in
closing costs. The 24 collateral assets were acquired by the
sponsor as part of a 35-hotel portfolio and with other various
assets out of a bankruptcy reorganization of John Q Hammons
Revocable Trust, JQH Entities and its affiliates. The loan is a
two-year floating-rate interest-only (IO) mortgage loan with five
one-year extension options.

All but one of the hotels in the portfolio are required to go
through property improvement plan (PIP) renovations as a result of
the ownership change with total costs estimated at $101.0 million
for the portfolio. In addition to the $16.0 million upfront PIP
reserve, the sponsor was required to deposit an additional $51.0
million over the first five years ($40.0 million in the first 12
months) and make ongoing furniture, fixtures, and equipment reserve
deposits equal to 4.0% of gross revenue. According to the June 2019
reporting, the PIP reserve had an ending balance of $48.2 million
with $1.4 million deposited during the month. Based on previous
disbursements from the PIP reserve and guest reviews for some of
the hotels that mentioned ongoing renovations, DBRS confirms that
the PIP projects appear to be underway as scheduled. Most recently,
the servicer disbursed $2.3 million from the PIP reserve account to
the borrower.

According to the year-end (YE) 2018 Operating Statement Analysis
Report, the portfolio reported a weighted-average (WA) occupancy
rate, average daily rate (ADR) and RevPAR of 70.4%, $130.42 and
$92.52, respectively, which has remained relatively unchanged
compared with the trailing 12-month period ending February 2018
Smith Travel Research report, which reported figures of 70.8%,
$133.94, and $94.86, respectively. Comparing those time periods,
the portfolio reported an occupancy decline of 0.4%, an ADR decline
of 2.6% and a RevPAR decline of 2.5%. According to the YE2018
financials, the loan reported a debt service coverage ratio (DSCR)
of 2.33 times (x) compared with the DBRS Term DSCR of 2.04x at
issuance. Although the DSCR has improved over the DBRS figures at
issuance, this is a factor of a lower in-place interest rate
compared with the stressed scenario assumed by DBRS as the in-place
cash flows are actually down by 7.7% from the DBRS Net Cash Flow
figure derived at issuance at YE2018. The decline in cash flow
since issuance was primarily driven by a 25.7% increase in general
and administrative expenses for the portfolio overall; DBRS
believes that this is likely the result of one-time expenses
related to the financing and ongoing PIP renovations. Although the
individual properties generally reported year-over-year cash flow
declines in 2018, DBRS believes that these trends will generally
improve as capital projects are complete and all rooms are fully
online.

The DBRS Debt Yield and DBRS Term DSCR of 11.5% and 2.04x,
respectively, are moderate considering the portfolio is primarily
securitized by suburban full- and limited-service hotels and the
portfolio's insurable replacement cost of $1.2 billion (excluding
land value) is substantially higher than the whole-loan amount of
$635.0 million.

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

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


AVERY POINT VII: Moody's Affirms B3 Rating on $7.2MM Class F Notes
------------------------------------------------------------------
Moody's Investors Service has assigned ratings to four classes of
CLO refinancing notes issued by Avery Point VII CLO, Limited.

Moody's rating action is as follows:

US$252,000,000 Class A-R Senior Secured Floating Rate Notes Due
2028 (the "Class A-R Notes"), Assigned Aaa (sf)

US$45,700,000 Class B-R Senior Secured Floating Rate Notes Due 2028
(the "Class B-R Notes"), Assigned Aa2 (sf)

US$21,800,000 Class C-R Senior Secured Deferrable Floating Rate
Notes Due 2028 (the "Class C-R Notes"), Assigned A2 (sf)

US$26,650,000 Class D-R Senior Secured Deferrable Floating Rate
Notes Due 2028 (the "Class D-R Notes"), Assigned Baa3 (sf)

Additionally, Moody's has taken rating actions on the following
outstanding notes originally issued by the Issuer on December 22,
2015 (the "Original Closing Date"):

US$21,200,000 Class E Senior Secured Deferrable Floating Rate Notes
Due 2028 (the "Class E Notes"), Affirmed Ba3 (sf); previously on
December 22, 2015 Definitive Rating Assigned Ba3 (sf)

US$7,200,000 Class F Senior Secured Deferrable Floating Rate Notes
Due 2028 (the "Class F Notes"), Affirmed B3 (sf); previously on
December 22, 2015 Definitive Rating Assigned B3 (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 our 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% of
the portfolio must consist of senior secured loans and eligible
investments, and up to 10% of the portfolio may consist of second
liens loans and unsecured loans.

Bain Capital Credit, 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 three 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 June 27, 2019 in
connection with the refinancing of certain classes of secured notes
originally issued on December 22, 2015. 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
subordinated notes that remains outstanding.

In addition to the issuance of the Refinancing Notes, a variety of
other changes to transaction features will occur in connection with
the refinancing. These include: extension of non-call period for
refinancing notes and changes to certain collateral quality tests.

Moody's rating actions on the Class E Notes and Class F Notes
reflect the refinancing and the associated changes to the
transaction features.

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: $398,528,451

Defaulted par: $2,230,071

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2850 (corresponding to a
weighted average default probability of 24.55%)

Weighted Average Spread (WAS): 3.40%

Weighted Average Recovery Rate (WARR): 47 %

Weighted Average Life (WAL): 6.55 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.


BUCKEYE TOBACCO: Moody's Lowers Rating on 4 Tranches to Ca
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 4 tranches in
4 tobacco settlement revenue securitizations, and downgraded the
ratings of 10 tranches in 3 tobacco settlement revenue
securitizations.

The complete rating actions are as follows:

Issuer: Buckeye Tobacco Settlement Financing Authority, Tobacco
Settlement Asset-Backed Bonds, Series 2007 (State of Ohio)

Series 2007-A-3 Senior Convertible Capital Appreciation Turbo Term
Bonds, Downgraded to Caa3 (sf); previously on Jul 6, 2015
Downgraded to Caa1 (sf)

Series 2007A-2-1 Senior Current Interest Turbo Term Bonds,
Downgraded to Ca (sf); previously on Oct 4, 2018 Downgraded to Caa3
(sf)

Series 2007A-2-2 Senior Current Interest Turbo Term Bonds,
Downgraded to Ca (sf); previously on Oct 4, 2018 Downgraded to Caa3
(sf)

Series 2007A-2-3 Senior Current Interest Turbo Term Bonds,
Downgraded to Ca (sf); previously on Oct 4, 2018 Downgraded to Caa3
(sf)

Series 2007A-2-4 Senior Current Interest Turbo Term Bonds,
Downgraded to Ca (sf); previously on Oct 4, 2018 Downgraded to Caa3
(sf)

Issuer: California County Tobacco Securitization Agency (Los
Angeles County Securitization Corporation) Series 2006A Convertible
Turbo Bonds

Cl. 2006A-1, Upgraded to A2 (sf); previously on Aug 1, 2018
Upgraded to A3 (sf)

Issuer: Northern Tobacco Securitization Corporation, Series 2006

2006-A-1, Upgraded to A2 (sf); previously on Jul 23, 2018 Upgraded
to A3 (sf)

Issuer: The California County Tobacco Securitization Agency (
Fresno County Tobacco Funding Corporation), Series 2002

Ser. 2002 Term Bonds 2, Upgraded to Aa3 (sf); previously on Aug 1,
2018 Upgraded to A2 (sf)

Issuer: The California County Tobacco Securitization Agency (Merced
County Tobacco Funding Corporation) - Tobacco Settlement
Asset-Backed Refunding Bonds

2005A-1, Upgraded to A2 (sf); previously on Aug 27, 2018 Upgraded
to A3 (sf)

Issuer: Tobacco Settlement Authority (Iowa), Series 2005

2005B TNs, Downgraded to B3 (sf); previously on Feb 20, 2014
Confirmed at B2 (sf)

2005-C1 TNs, Downgraded to B3 (sf); previously on Feb 20, 2014
Confirmed at B2 (sf)

2005-C2 TNs, Downgraded to B3 (sf); previously on Feb 20, 2014
Confirmed at B2 (sf)

2005-C3 TNs, Downgraded to B3 (sf); previously on Feb 20, 2014
Confirmed at B2 (sf)

Issuer: Tobacco Settlement Finance Authority (Taxable Tobacco
Settlement Asset-Backed Bonds, Series 2007) West Virginia

2007A TT CIBS, Downgraded to B3 (sf); previously on Feb 20, 2014
Confirmed at B2 (sf)

RATINGS RATIONALE

The downgrade actions are primarily a result of the increasing
decline of total domestic cigarette shipments in recent years.
Total domestic cigarette shipments as measured by federal excise
tax data and reported by the National Association of Attorneys
General (NAAG) for the past 3 years, 2016-2018, have declined by
4.06%, 4.46% and 4.73%, respectively. The downgraded lower-priority
tranches with legal final maturities ranging from 2028-2047 are
especially sensitive to the increasing cigarette shipment declines.
These tranches have relatively high leverage and longer maturities.
Therefore, they have less capacity to withstand a steady, prolonged
decline of cigarette shipment decline.

The upgrade actions are primarily driven by further deleveraging,
the availability of significant cash reserves and relatively
short-term maturities, which minimizes the impact of future
cigarette shipment declines.

For Buckeye Tobacco Settlement Financing Authority, Tobacco
Settlement Asset-Backed Bonds, Series 2007 (State of Ohio), the
downgrade actions are primarily a result of increasing decline of
total domestic cigarette shipments and the amount available in the
reserve account. The reserve is currently 62% of the required
amount. An Event of Default ("EOD") will occur if there is a
failure to pay down any of the bonds in full by their legal final
maturity. The bonds are paid down in the order of bond maturity
until the occurrence of an EOD, at which time the cash allocation
will switch to pro-rata.

Moody's currently expects that US cigarette shipment volumes will
fall at 4% to 5% during the next 12-18 months.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's
Approach to Rating Tobacco Settlement Revenue Securitizations"
published in November 2018.

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

Up

Moody's could upgrade the ratings if the annual rate of decline in
the volume of domestic cigarette shipments decreases, if future
arbitration proceedings and subsequent recoveries for settling
states become more expeditious than they currently are, or if
additional settlements are entered into which benefit the bonds.

Down

Moody's could downgrade the ratings if the annual rate of decline
in the volume of domestic cigarette shipments increases, if
subsequent recoveries from future arbitration proceedings for
settling states take longer than Moody's assumption of 15-20 years,
if an arbitration panel finds that a settling state was not
diligent in enforcing a certain statute which could lead to a
significant decline in cash flow to that state, or if additional
settlements are entered into which reduce the cash flow to the
bonds.


BX TRUST 2019-RP: Fitch Rates $28.5MM Class F Certs 'B-'
--------------------------------------------------------
Fitch Ratings has assigned the following rating and Rating Outlooks
to BX Trust 2019-RP, Commercial Mortgage Pass-Through Certificates,
Series 2019-RP:

  -- $101,650,000 class A 'AAAsf'; Outlook Stable;

  -- $21,850,000 class B 'AA-sf'; Outlook Stable;

  -- $15,200,000 class C 'A-sf'; Outlook Stable;

  -- $19,950,000 class D 'BBB-sf'; Outlook Stable;

  -- $31,350,000 class E 'BB-sf'; Outlook Stable;

  -- $28,500,000 class F 'B-sf'; Outlook Stable.

Fitch does not rate the following non-offered, vertical risk
retention interest:

  -- $11,500,000 class VRR.

All offered classes are expected to be privately placed and
pursuant to Rule 144A. The ratings do not reflect final ratings and
are based on information provided by the issuer as of June 26,
2019.

The BX Trust 2019-RP Commercial Mortgage Pass-Through Certificates
represent the beneficial interest in a trust that holds a two-year,
floating-rate, interest-only $230.0 million mortgage loan with
three one-year extension options secured by the fee interests in 12
retail properties with a total of 2.2 million sf located in seven
states. Eleven of the 12 collateral properties were previously
securitized in WFCG 2015-BXRP, and all collateral properties were
part of the sponsor's $1.9 billion, 71-retail property acquisition
from American Realty Capital Properties (ARCP) in 2014.

Loan proceeds, together with $4.5 million of additional sponsor
equity, were used to refinance existing debt of $224.0 million,
fund $3.6 million of upfront reserves and pay $6.9 million of
closing costs. The certificates will follow a sequential-pay
structure; however, so long as there is no event of default, any
voluntary prepayments (up to the first 20% of the loan), including
property releases, will be applied to the certificates on a
pro-rata basis. The deal is scheduled to close on June 27, 2019.

KEY RATING DRIVERS

Fitch Leverage: The $230.0 million whole loan has a Fitch debt
service coverage ratio (DSCR) and loan to value (LTV) ratio of
1.00x and 89.6%, respectively. The sponsor acquired all the
collateral properties in 2014, and contributed an additional $4.5
million of equity toward the subject refinance.

Diverse Portfolio: The loan is secured by 12 retail properties
located in seven states. The three states with the largest
concentrations are Colorado (one property; 32.6% of the allocated
loan amount), Georgia (two properties; 18.7%) and Florida (two
properties; 17.8%). The portfolio consists of almost 150 unique
tenants with approximately 200 leases in place. No tenant leases
more than 9.8% of the NRA or accounts for more than 8.1% of base
rent.

Institutional Sponsorship and Management: The loan is sponsored by
Blackstone Real Estate Partners VII L.P. (Blackstone) and SITE
Centers Corp. (SITE; fka DDR Corp.). The portfolio will be managed
by SITE. SITE (BBB/Stable) owns and manages 174 shopping centers in
the US with reported portfolio occupancy of 93.0% as of March 2019.
Blackstone reported over $512.0 billion in assets under management
as of March 2019.

Stagnant Tenant Sales: Sixty-five tenants, representing 589,306sf,
or 26.6% of NRA, reported sales for the trailing 12 months (TTM)
ended April 2019. Overall tenant sales have stagnated to between
$253psf and $260psf since 2016. Anchor tenants over 20,000sf
reported TTM sales of $236psf, which results in a 6.6% occupancy
cost. Junior anchor tenants (10,000sf-20,000sf) reported TTM sales
and occupancy cost of $250psf and 9.0%, respectively, while
reported TTM sales and occupancy cost for in-line tenants (under
10,000sf) were $318psf and 10.1%.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 13.0% below
the most recent TTM NCF and 2.6% below the issuer's underwritten
NCF. Unanticipated further declines in property-level NCF could
result in higher defaults and loss severities on defaulted loans,
and could result in potential rating actions on the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the BX
Trust 2019-RP certificates and found that the transaction displays
average sensitivities to further declines in NCF. In a scenario in
which NCF declined a further 20% from Fitch's NCF, a downgrade of
the 'AAAsf' certificates to 'A+sf' could result. In a more severe
scenario, in which NCF declined a further 30% from Fitch's NCF, a
downgrade of the 'AAAsf' certificates to 'BBBsf' could result. The
presale report includes a detailed explanation of additional
stresses and sensitivities.


CABELA'S CREDIT 2013-I: DBRS Confirms BB Rating on Class D Notes
----------------------------------------------------------------
DBRS, Inc. confirmed the ratings of Class A, Class B, Class C and
Class D of the Cabela's Credit Card Master Note Trust Series 2013-I
U.S. asset-backed security transaction at AAA (sf), A (high) (sf),
BBB (sf) and BB (sf), respectively. Performance of the securities
is such that credit enhancement levels are sufficient to cover
DBRS's loss expectations at their respective rating levels.

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

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

  -- The transaction parties' capabilities with regard to
     origination, underwriting, and servicing.

  -- The credit quality of the collateral pool and historical
     performance.


CARVANA AUTO 2019-2: Moody's Assigns B2 Rating on Class E Notes
---------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to the notes
issued by Carvana Auto Receivables Trust 2019-2 (CRVNA 2019-2).
This is the second 144A auto loan transaction for Carvana, LLC
(Carvana), an indirect wholly owned subsidiary of Carvana Co. (B3
stable). The notes are backed by a pool of retail automobile loan
contracts originated by Carvana, who is also the administrator of
the transaction. Bridgecrest Credit Company, LLC (Bridgecrest
Credit), an indirect wholly owned subsidiary of DriveTime Auto
Group (B3 stable), will be the servicer of the transaction.

The complete rating actions are as follows:

Issuer: Carvana Auto Receivables Trust 2019-2

$90,000,000, 2.60%, Class A-2 Notes, Definitive Rating Assigned Aaa
(sf)

$90,340,000, 2.58%, Class A-3 Notes, Definitive Rating Assigned Aaa
(sf)

$71,675,000, 2.74%, Class B Notes, Definitive Rating Assigned Aa1
(sf)

$47,705,000, 3.00%, Class C Notes, Definitive Rating Assigned A2
(sf)

$53,815,000, 3.28% , Class D Notes, Definitive Rating Assigned Baa3
(sf)

$38,540,000, 5.01%, Class E Notes, Definitive Rating Assigned B2
(sf)

RATINGS RATIONALE

The ratings are based on the quality of the underlying collateral
originated by Carvana and its expected performance, the strength of
the capital structure, the experience and expertise of Bridgecrest
Credit as the servicer and the presence of First Associates Loan
Servicing, LLC (unrated) as the backup servicer.

Moody's median cumulative net loss expectation for the 2019-2 pool
is 11% and the loss at a Aaa stress is 50%. The loss levels for
2019-2 are unchanged relative to 2019-1, the last transaction we
rated. Moody's based its cumulative net loss expectation on an
analysis of the credit quality of the underlying collateral; the
historical performance of similar collateral including Carvana's
managed portfolio performance; the ability of Bridgecrest Credit to
perform the servicing functions; and current expectations for the
macroeconomic environment during the life of the transaction.

The Class A notes, Class B notes, Class C notes Class D notes and
Class E notes benefit from 49.05%, 33.80%, 23.65%, 12.20% and 4.00%
of hard credit enhancement, respectively. Hard credit enhancement
for the notes consists of a combination of overcollateralization, a
non-declining reserve account and subordination except for the
Class E notes which do not benefit from 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 subordinated 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.


CITIGROUP COMMERCIAL 2012-GC8: Fitch Affirms Cl. F Certs at Bsf
---------------------------------------------------------------
Fitch Ratings has affirmed nine classes of Citigroup Commercial
Mortgage Trust 2012-GC8 commercial mortgage pass-through
certificates.

CGCMT 2012-GC8

                       Current Rating      Previous Rating
Class A-4 17318UAD6;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-AB 17318UAE4; LT AAAsf  Affirmed;  previously at AAAsf
Class A-S 17318UAF1;  LT AAAsf  Affirmed;  previously at AAAsf
Class B 17318UAG9;    LT AA-sf  Affirmed;  previously at AA-sf
Class C 17318UAH7;    LT A-sf   Affirmed;  previously at A-sf
Class D 17318UAJ3;    LT BBB-sf Affirmed;  previously at BBB-sf
Class E 17318UAS3;    LT BBsf   Affirmed;  previously at BBsf
Class F 17318UAT1;    LT Bsf    Affirmed;  previously at Bsf
Class X-A 17318UAK0;  LT AAAsf  Affirmed;  previously at AAAsf

KEY RATING DRIVERS

Loss Expectations: Fitch Ratings' base case loss expectations have
decreased slightly since Fitch's prior rating action in July 2018
due to paydown and new leasing at several properties securing
larger loans. Fitch remains concerned about Pinnacle at Westchase's
ability to backfill the large amount of rolling space at comparable
rents given overall weak market conditions in Houston. Fitch
performed an additional sensitivity test on this loan that assumes
an outsized 75% loss. The Negative Rating Outlooks on classes E and
F are partially a result of this sensitivity test.

Fitch Loans of Concern: Four loans (25.5% of the pool) have been
identified as Fitch Loans of Concern (FLOCs), including the largest
loan in the pool. The Miami Center loan (13.9%) is secured by a
35-story office property located on Biscayne Bay in downtown Miami,
FL. Between June 2012 and December 2018, occupancy at the subject
property had fallen from 83.7% to 68%. The master servicer has
triggered a cash flow sweep as the loan has failed several debt
service coverage ratio (DSCR) tests. The borrower hopes that a
recently completed $20 million renovation to the lobby and
elevators will help attract new tenants and improve occupancy.

The second largest FLOC, Pinnacle at Westchase (9.7%), an office
property in Houston, TX, has dealt with occupancy issues. At
issuance, the largest tenant, Conoco Phillips, leased nearly half
of the total square footage. However, the tenant moved into a newly
built headquarters and the space became dark in 2016. Phillips 66
was able to sublease 53% of its space to Empyrean Benefit
Solutions. Per the most recent rent roll, the borrower entered into
a direct lease with Empyrean Benefit Solutions from August 2019 to
January 2025. The second largest tenant, MHWirth, occupies 42% of
the NRA and its lease expires in January 2020. By March 2020, the
property could roughly be 25% occupied. All loans have remained
current, and no loans have transferred to special servicing.

Defeasance and Paydown; Increased Credit Enhancement: Fourteen
loans totaling approximately 18.9% of the pool are defeased.
Additionally, the pool has paid down approximately 29.5% since
issuance. At Fitch's prior review, 12 loans totaling approximately
15.2% of the pool had been defeased, and the transaction had paid
down 24.7% since issuance.


CMLS ISSUER 2014-1: Fitch Affirms BBsf Rating on Class F Certs
--------------------------------------------------------------
Fitch Ratings has affirmed eight classes of CMLS Issuer Corp.'s
commercial mortgage pass-through certificates, series 2014-1 and
revised the Rating Outlook on class F to Negative from Stable.

CMLS Issuer Corporation 2014-1

                      Current Rating      Prior Rating
Class A-1 125824AA0; LT AAAsf  Affirmed;  previously at AAAsf
Class A-2 125824AB8; LT AAAsf  Affirmed;  previously at AAAsf
Class B 125824AC6;   LT AAsf   Affirmed;  previously at AAsf
Class C 125824AD4;   LT Asf    Affirmed;  previously at Asf
Class D 125824AE2;   LT BBBsf  Affirmed;  previously at BBBsf
Class E 125824AF9;   LT BBB-sf Affirmed;  previously at BBB-sf
Class F 125824AG7;   LT BBsf   Affirmed;  previously at BBsf
Class G 125824AH5;   LT Bsf    Affirmed;  previously at Bsf

KEY RATING DRIVERS

Stable Loss Expectations: Pool-level base case losses and overall
collateral performance have remained within expectations since
Fitch's last rating action. While approximately 14.9% of the loans
in the pool have been designated Fitch Loans of Concern (FLOCs),
all but one of these loans (Spring Garden Place, 5.4%) have partial
or full recourse to the sponsor. Fitch expects loan-level losses to
remain low, given that 82.6% of the loans in the pool featured
partial or full recourse at issuance and given the low historical
delinquency and loss rates associated with Canadian CMBS loans.

Improved Credit Enhancement: Credit enhancement has improved since
issuance due to loan amortization and payoffs. The pool has paid
down approximately 18.2% since issuance. Credit enhancement will
continue to improve given above-average amortization with the loans
in the pool scheduled to amortize 24.1% by maturity.

Pool Concentration: The top 15 loans in the pool account for 84.5%
of total pool balances when accounting for loans that are
cross-collateralized and cross-defaulted. When accounting for
cross-collateralized and cross-defaulted loans only 27 of the
original 33 loans in the pool remain.

Energy Market Concentration: The pool includes three loans (14.3%)
in Alberta or Saskatchewan, areas that have experienced volatility
from the energy sector in the past few years. Two of the three
loans are FLOCs, Clearwater Suites (3.6%) and Fairway Greens
Saskatoon (4.9%).

Clearwater Suites' performance has substantially declined
concurrently with the Fort McMurray Hotel market as a result of
declining oil and gas prices. As of the trailing twelve month
period ended April 2018, the property reflected average occupancy
of 43.2% and has not reflected cash flow above 1.05x since YE 2014.
The property also suffered significant damage from the Fort
McMurray wildfires and an unrelated flood, though the property has
since been fully repaired.

Fairway Greens Saskatoon has exhibited a decline in its most recent
reported cash flow and is currently on the servicer watch list. The
loan was also recently assumed, and there has been no financial
reporting on the collateral property since assumption. The last
financial statements provided reflect trailing twelve month
performance as of July 2017 and indicated a DSCR of 1.19x.

Alternative Loss Considerations: Fitch ran a sensitivity test that
assumed additional losses on two FLOCs, Spring Garden Place (5.4%)
and Clearwater Suites (3.6%). The sensitivity test assumed a 50%
loss on Clearwater Suites to address performance concerns related
to the decline in oil and gas prices and a 25% loss on Spring
Garden Place to address increased vacancy. Although Clearwater
Suites has recourse to the sponsor, losses were assumed as both the
property performance and the guarantor's financial profile
continues to decline. The Spring Garden Place loan is non-recourse.
The Negative Outlooks on classes F and G reflect this analysis.


COLT 2019-3: Fitch Rates $2.3MM Class B-1 Certs 'B+'
----------------------------------------------------
Fitch Ratings has assigned the following ratings to the residential
mortgage-backed certificates to be issued by COLT 2019-3 Mortgage
Loan Trust:

  -- $273,154,000 class A-1 certificates 'AAAsf'; Outlook Stable;

  -- $25,158,000 class A-2 certificates 'AAsf'; Outlook Stable;

  -- $37,266,000 class A-3 certificates 'Asf'; Outlook Stable;

  -- $17,592,000 class M-1 certificates 'BBBsf'; Outlook Stable;

  -- $13,809,000 class B-1 certificates 'BBsf'; Outlook Stable;

  -- $2,378,000 class B-2 certificates 'B+sf'; Outlook Stable.

Fitch will not rate the following classes:

  -- $8,972,698 class B-3 certificates;

  -- $378,329,698 class A-IO-S notional certificates;

  -- $378,329,698 class X notional certificates;

  -- $0 class R certificates.

The certificates are supported by 624 loans with a total balance of
approximately $378.33 million as of the cutoff date.

All the loans in the pool were originated by Caliber Home Loans,
Inc. Approximately 63% of the pool is designated as Non-Qualified
Mortgage (QM), 20% consist of higher priced QM (HPQM) and close to
15% are Safe Harbor QM (SHQM), while for the remainder ability to
repay (ATR) does not apply.

Following the publication of Fitch's expected ratings, the issuer
increased the credit enhancement to the B2 class. The increased
credit enhancement resulted in a rating of 'B+sf' compared with the
expected rating of 'Bsf'.

KEY RATING DRIVERS

Non-Prime Credit Quality (Concern): The pool has a weighted average
(WA) model credit score of 721 and a WA combined loan to value
ratio (CLTV) of 83%. Of the pool, 25% (by Unpaid Principal Balance
[UPB]) consists of borrowers with prior credit events within the
past seven years and 41% had a debt to income (DTI) ratio of over
43%. Investor properties and those run as investor properties for
loss modelling (i.e.: Non Permanent Residents) account for 2.4% of
the pool.

Fitch applied default penalties to account for these attributes,
and loss severity (LS) was adjusted to reflect the increased risk
of ATR challenges.

Primarily Full Income Documentation (Positive): The loans in the
mortgage pool were underwritten in material compliance with the
Appendix Q documentation standards defined by ATR, which is not
typical for non-prime RMBS. Mortgage pools of all other active
non-prime RMBS issuers include a significant percentage of
non-traditional income documentation. While a due diligence review
identified roughly 65% of loans (by count) as having minor
variations to Appendix Q, Fitch views those differences as
immaterial and substantially all loans as having full income
documentation. The COLT series transactions that are comprised of
100% Caliber origination are the only non-prime RMBS issued with
more than 95% full income documentation.

Excess Cashflow (Positive): The transaction benefits from a
material amount of excess cashflow that provides benefit to the
rated notes before being paid out to the class X. In Fitch's
analysis, the excess is used to protect against realized losses
(resulting in required subordination below Fitch's collateral loss
expectations) as well as timely payment of interest for all classes
in their respective rating stress. To the extent that the
collateral weighted average coupon (WAC) and corresponding excess
is reduced through a rate mod, Fitch would view the impact as
credit neutral as the mod would reduce the borrower's probability
of default, resulting in a lower loss expectation.

Low Operational Risk (Positive): Fitch has reviewed Caliber and
Hudson Americas L.P.'s (Hudson's) origination and acquisition
platforms and found them to have sound underwriting and operational
control environments. Caliber has a long operating history and has
one of the largest and most established Non-QM programs in the
sector. Hudson's oversight of Caliber's origination of Non-QM loans
reduces the risk of manufacturing defects. Strong loan quality was
shown with third-party due diligence performed by an Acceptable -
Tier 1 diligence firm on 100% of the pool. The issuer's retention
of at least 5% of the transaction's fair market value helps to
ensure an alignment of interest between the issuer and investors.

Alignment of Interests (Positive): The transaction benefits from an
alignment of interests between the issuer and investors. LSRMF
Acquisitions I, LLC (LSRMF), as sponsor and securitizer, or an
affiliate will retain a horizontal interest in the transaction
equal to not less than 5% of the aggregate fair market value of all
certificates in the transaction. Lastly, the representations and
warranties are provided by Caliber, which is owned by LSRMF
affiliates and, therefore, also aligns the interest of the
investors with those of LSRMF to maintain high-quality origination
standards and sound performance, as Caliber will be obligated to
repurchase loans due to rep breaches.

Modified Sequential Payment Structure (Mixed): The structure
distributes collected principal pro rata among the class A
certificates while shutting out the subordinate bonds from
principal until all three classes have been reduced to zero. To the
extent that any of the cumulative loss trigger event, the
delinquency trigger event or the credit enhancement trigger event
occurs in a given period, principal will be distributed
sequentially to the class A-1, A-2 and A-3 certificates until they
are reduced to zero.

R&W Framework (Concern): As originator, Caliber will be providing
loan-level representations and warranties to the trust. While the
reps for this transaction are substantively consistent with those
listed in Fitch's published criteria and provide a solid alignment
of interest, Fitch added approximately 165 bps to the expected loss
at the 'AAAsf' rating category to reflect the non-investment-grade
counterparty risk of the provider and the lack of an automatic
review of defaulted loans, other than for loans with a realized
loss that have a complaint or counterclaim of a violation of ATR
Rules in a foreclosure proceeding. The lack of an automatic review
is mitigated by the ability of holders of 25% of the total
outstanding aggregate class balance to initiate a review.

Servicing and Master Servicer (Positive): Servicing will be
performed on 100% of the loans by Caliber. Fitch rates Caliber
'RPS2-'/Negative due to its fast-growing portfolio and regulatory
scrutiny. Wells Fargo Bank, N.A. (Wells Fargo), rated
'RMS1-'/Stable, will act as master servicer and securities
administrator. Advances required but not paid by Caliber will be
paid by Wells Fargo.

Performance Triggers (Mixed): Credit enhancement, delinquency and
loan loss triggers convert principal distribution to a straight
sequential payment priority in the event of poor asset performance.
The delinquency trigger is based only on the current month and not
on a rolling six-month average. The triggers for this transaction
should help to protect the A-1 and A-2 classes from a high stress
scenario by cutting off principal payments to more junior classes
and ensuring a higher amount of protection as compared to when the
triggers are passing.

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 7.1%. 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'.


CSAIL 2019-C16: Fitch Gives B- Rating on $7.87MM Class G-RR Certs
-----------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to CSAIL 2019-C16 Commercial Mortgage Trust pass-through
certificates, series 2019-C16:

  -- $19,153,000 class A-1 'AAAsf'; Outlook Stable;

  -- $160,200,000 class A-2 'AAAsf'; Outlook Stable;

  -- $339,980,000 class A-3 'AAAsf'; Outlook Stable;

  -- $31,923,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $615,241,000b class X-A 'AAAsf'; Outlook Stable;

  -- $66,938,000b class X-B 'A-sf'; Outlook Stable;

  -- $63,985,000 class A-S 'AAAsf'; Outlook Stable;

  -- $31,501,000 class B 'AA-sf'; Outlook Stable;

  -- $35,437,000 class C 'A-sf'; Outlook Stable;

  -- $23,783,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $23,783,000a class D 'BBB-sf'; Outlook Stable;

  -- $18,546,000,000ac class E-RR 'BBB-sf'; Outlook Stable;

  -- $20,672,000ac class F-RR 'BB-sf'; Outlook Stable;

  -- $7,875,000ac class G-RR 'B-sf'; Outlook Stable.

The following class is not rated by Fitch:

  -- $34,454,331ac class NR-RR.

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

(b) Notional amount and interest-only.

(c) Horizontal credit risk retention interest representing no less
than 5% of the estimated fair value of all classes of regular
certificates issued by the issuing entity as of the closing date.

Since Fitch published its expected ratings on June 11, 2019, the
following changes occurred: The balances for class A-2 and class
A-3 were finalized and the balances for classes X-D, class D and
class E-RR changed. At the time that the expected ratings were
assigned, the exact initial certificate balances of class A-2 and
class A-3 were unknown and expected to be within the range of
$75,000,000 to $295,000,000 and $205,180,000 to $425,180,000,
respectively. The final class balances for class A-2 and class A-3
are $160,200,000 and $339,980,000, respectively. Additionally, at
the time that the expected ratings were assigned, the class balance
for class D was $24,413,000, the class balance for X-D was
$24,413,000 and the class balance for class E-RR was $17,916,000.
The final class balance for class D is $23,783,000, the final class
balance for class X-D is $23,783,000 and the final class balance
for class E-RR is $18,546,000. The ratings for those classes did
not change. The classes reflect the final ratings and deal
structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 47 loans secured by 96
commercial properties having an aggregate principal balance of
$787,509,331 as of the cut-off date. The loans were contributed to
the trust by: Column Financial, Inc., Societe Generale Financial
Corporation, Ladder Capital Finance LLC, Starwood Mortgage Capital
LLC and CIBC Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 72.7% of the properties
by balance, cash flow analysis of 84.6% and asset summary reviews
on 100.0% of the pool.

KEY RATING DRIVERS

Higher than Average Leverage Relative to Recent Transactions: The
pool's Fitch DSCR of 1.14x is worse than the YTD 2019 average of
1.22x and the 2018 average of 1.22x. The pool's Fitch LTV of 108.9%
is worse than the YTD 2019 average of 101.8% and the 2018 average
of 102.0%. Excluding the credit opinion loans, the Fitch DSCR is
1.12x and the Fitch LTV is 113.5%.

High Hotel Exposure: Loans secured by hotel properties represent
30.6% of the pool by balance. Four of the top 10 loans (19.3% of
the pool) are backed by hotel properties. The pool's total hotel
concentration far exceeds both the YTD 2019 average of 13.7% and
the 2018 average of 14.7%.

Investment-Grade Credit Opinion Loans: Two loans totaling 10.2% of
the pool have stand-alone investment-grade credit opinions. The
largest loan in the transaction, 3 Columbus Circle (6.4% of the
pool), received a credit opinion of 'BBB-sf*', and 787 Eleventh
Avenue (3.8%) also received a credit opinion of 'BBB-sf*'.


CSMC TRUST 2017-CHOP: DBRS Confirms BB(low) Rating on Cl. E Certs
-----------------------------------------------------------------
DBRS, Inc. confirmed the ratings on all classes of the Commercial
Mortgage Pass-Through Certificates, Series 2017-CHOP issued by CSMC
Trust 2017-CHOP as follows:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction. The $780.0 million mortgage loan closed in June
2017 and is secured by the fee and leasehold interests in a
portfolio of 48 select-service, limited-service and extended-stay
hotels, totaling 6,401 keys, located in 21 different states across
the United States. The hotels operate under eight different flags
across three hotel brands that include Marriott, Hilton and Hyatt.
The sponsors, Colony NorthStar, Inc. and Chatham Lodging Trust,
acquired the collateral assets in 2014 as part of a larger $1.1
billion hotel portfolio, which included four additional hotel
assets that do not serve as collateral.

Each individual property serving as collateral has been renovated
at some point since acquisition or is currently undergoing a
capital expenditure plan, as at issuance the sponsor planned to
invest an additional $68.4 million across the portfolio during the
fully extended five-year loan term. Loan proceeds, along with $79.1
million of equity, were used to refinance $817.0 million of
existing portfolio debt, fund $16.0 million of upfront property
improvement plan (PIP) reserves across the portfolio and cover
closing costs, as well as $4.7 million in other upfront reserves.
The interest-only (IO) loan had an initial 24-month term, which
expired in June 2019; however, the servicer confirmed that the
borrower has exercised the first of three 12-month extension
options.

As of the June 2019 remittance report, there have been no property
releases since issuance and the PIP reserve account had a remaining
balance of $5.4 million. Renovations were recently completed at the
Residence Inn Nashville Airport and Residence Inn Dallas DFW
Airport North Irving properties. The borrower provided a renovation
report dated May 2019 that detailed approximately $16.8 million
will be invested into 13 separate properties with a projected
completion date in Q4 2020. Renovations averaging $21,481 per key
will be completed at the Courtyard Baltimore Fort Meade, Chapel
Hill Aloft, Springhill Suites Danbury, Residence Inn Houston
Westchase and Residence Inn Tucson Williams Centre properties.

There were 46 properties, representing 96.5% of the trust balance
that provided trailing 12-month (T-12) ending December 31, 2018,
and Smith Travel Research reports. The portfolio reported overall
improvement in 2018 with a weighted-average (WA) occupancy rate, WA
average daily rate (ADR) and WA revenue per available room (RevPAR)
of 77.0%, $129.54 and $99.88, respectively, compared to the T-12
ending December 31, 2017, WA occupancy rate, WA ADR and WA RevPAR
of 75.7%, $124.29 and $94.24, respectively. The portfolio also
outperformed the DBRS WA occupancy rate of 71.6%, WA ADR of $124.22
and WA RevPAR of $88.99 assumed at issuance.

The loan reported a year-end (YE) 2018 debt service coverage ratio
(DSCR) of 1.92x compared to the YE2017 DSCR of 1.82x. The DBRS Term
DSCR of 1.19x was calculated based on stressed debt service
payments given the variable interest rate component; however, this
would be adjusted to 1.68x based on the actual debt service
payments. The improvement in 2018 was due to revenue growth, as the
portfolio's WA occupancy rate and WA ADR both increased. Revenue
growth is expected to continue as the sponsor continues to complete
renovations to properties throughout the portfolio; however, DBRS
is also mindful the lodging industry may be in the later stages of
the real estate cycle. It should be noted that the loan was placed
on the servicer's watchlist in September 2018 due to major deferred
maintenance at one property, defined as a tripping hazard at the
Hampton Inn White Plains Tarrytown (2.7% of the loan balance).

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

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


CSMC TRUST 2017-MOON: Fitch Affirms BB-sf Rating on Class E Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed all classes of CSMC Trust 2017-MOON
commercial mortgage pass-through certificates.

CSMC 2017-MOON
                     Current Rating       Previous Rating   
Class A 12651XAA2;   LT AAAsf  Affirmed;  previously at AAAsf
Class B 12651XAE4;   LT AA-sf  Affirmed;  previously at AA-sf
Class C 12651XAG9;   LT A-sf   Affirmed;  previously at A-sf
Class D 12651XAJ3;   LT BBB-sf Affirmed;  previously at BBB-sf
Class E 12651XAL8;   LT BB-sf  Affirmed;  previously at BB-sf
Class HRR 12651XAN4; LT BB-sf  Affirmed;  previously at BB-sf
Class X 12651XAC8;   LT AAAsf  Affirmed;  previously at AAAsf

KEY RATING DRIVERS

Stable Performance and Property Cash Flow: The affirmations reflect
the stable performance of the collateral, which consists of the fee
interest in a 605,897 square foot (sf) office building located at
300 E Street SW in Washington, D.C. and known as Two Independence
Square. The interest-only loan has only had two years of seasoning
since issuance in June 2017. Occupancy as of the year-end 2018 rent
roll was 100%, in line with issuance. The YE 2018 net cash flow has
increased 1.3%% from YE 2017 and is in line with issuance
expectations. The servicer reported DSCR (NCF) was reported to be
2.53x for YE 2018.

Loan Structure: The total $225.7 million mortgage loan consists of
four pari passu A-notes totaling $164.0 million, of which the $64.0
million note A-1 is included in CSMC 2017-MOON, and a $61.7 million
B-note, also included in the trust. The $100 million of companion
A-notes will not be part of the assets of the trust and have been
contributed to two conduit secularization (WFCM 2017-C39 and CSAIL
2017-CX9).

Fitch Leverage: The $125.7 million mortgage loan has a Fitch DSCR
and LTV of 1.03x and 85.7%, respectively, and debt of $373 psf.

Investment-Grade Tenancy: The office portion of the property (98.6%
of NRA) is 100% leased to the Government Services Administration
through August 2028 (six years beyond the loan term with no early
termination or contraction provisions) on behalf of the U.S.
National Aeronautics and Space Administration (NASA). The property
serves as the worldwide headquarters for NASA. The remaining space
is leased to three small retail tenants.

Asset Quality: The LEED Certified Gold building was originally
constructed in 1992 and received approximately $86.3 million in
upgrades from 2012 to 2014 to the building interior and security
features, including NASA investing approximately $45.4 million in
its space. Property amenities include a 235-seat auditorium,
769-space underground parking facility and rooftop terrace.
Specialized construction for NASA includes high-tech computer and
conference rooms, recording studios, sound control, separate
systems for backup and 24-hour operation.

Well Located: Two Independence Square is located in the Southwest
Washington, D.C. sub market, just south of the National Mall and
Capitol Building, an area with a concentration of GSA facilities
and the headquarters for 19 federal agencies.

Single Asset: 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.


FOURSIGHT CAPITAL 2019-1: Moody's Rates $11.9MM Class F Notes 'B2'
------------------------------------------------------------------
Moody's Investors Service, assigned definitive ratings to the notes
issued by Foursight Capital Automobile Receivables Trust 2019-1.
This is the first auto loan transaction of the year for Foursight
Capital LLC (Foursight; unrated) and the third rated by Moody's.
The notes are backed by a pool of retail automobile loan contracts
originated by Foursight, who is also the servicer and administrator
for the transaction.

The complete rating actions are as follows:

Issuer: Foursight Capital Automobile Receivables Trust 2019-1

$86,000,000, 2.58% Class A-2 Notes, Definitive Rating Assigned Aaa
(sf)

$40,310,000, 2.67% Class A-3 Notes, Definitive Rating Assigned Aaa
(sf)

$14,780,000, 2.78% Class B Notes, Definitive Rating Assigned Aa2
(sf)

$14,560,000, 3.07% Class C Notes, Definitive Rating Assigned A1
(sf)

$14,330,000, 3.27% Class D Notes, Definitive Rating Assigned Baa1
(sf)

$12,050,000, 4.30% Class E Notes, Definitive Rating Assigned Ba1
(sf)

$11,930,000, 5.57% Class F Notes, Definitive Rating Assigned B2
(sf)

RATINGS RATIONALE

The ratings are based on the quality of the underlying collateral
and its expected performance, the strength of the capital
structure, the experience and expertise of Foursight as the
servicer and administrator, a performance guarantee for the
servicing and custodian function from Jefferies Financial Group
(Baa3) and the backup servicing arrangement.

The definitive rating for the Class C, D and E notes, which are
rated A1 (sf), Baa1 (sf) and Ba1 (sf), respectively, are one notch
higher than their provisional rating, (P)A2 (sf), (P)Baa2 (sf) and
(P)Ba2 (sf). This difference is a result of the transaction closing
with a lower weighted average cost of funds (WAC) than Moody's
modeled when the provisional ratings were assigned. The WAC
assumptions as well as other structural features, were provided by
the issuer.

Moody's cumulative net loss expectation for the 2019-1 pool is
9.50% and the loss at a Aaa stress is 42%, both higher than the
9.00% cumulative net loss expectation and loss at a Aaa stress of
40% assigned to 2018-2. The higher loss assumptions for 2019-1 are
as a result of the worse collateral characteristics compared to the
2018-2 transaction. 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

At closing, the Class A notes, Class B notes, Class C notes, Class
D notes, Class E notes and Class F notes are expected to benefit
from 34.50%, 28.00%, 21.60%, 15.30%, 10.00% and 4.75% of hard
credit enhancement respectively. Hard credit enhancement for the
notes consists of a combination of overcollateralization, a
non-declining reserve account, and subordination, except for the
Class F notes, which do not benefit from 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 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.


FREED ABS 2018-1: DBRS Confirms BB(high) Rating on Class C Notes
----------------------------------------------------------------
DBRS, Inc. confirmed six outstanding ratings on FREED ABS Trust
2018-1 and 2018-2. The confirmations are a result of performance
trends and credit enhancement levels being sufficient to cover
DBRS's expected losses at their current rating levels.

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

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

  -- The transaction parties' capabilities with regard to
     origination, underwriting, and servicing.

  -- Credit quality of the collateral pool and historical
     performance.

DBRS confirms these ratings:

FREED ABS Trust 2018-1
                      Rating Confirmed
                      ----------------
Class A Notes        A(sf)
Class B Notes        BBB(sf)
Class C Notes        BB(high(sf)

FREED ABS Trust 2018-2
                      Rating Confirmed
                      ----------------
Class A Notes        A(sf)
Class B Notes        BBB(sf)
Class C Notes        BB(high(sf)


GREENWICH CAPITAL 2007-GG11: Fitch Affirms D Rating on 12 Tranches
------------------------------------------------------------------
Fitch Ratings has downgraded one class and affirmed 12 classes of
Greenwich Capital Commercial Funding Corporation Commercial
Mortgage Pass-Through Certificates, series 2007-GG11.

Greenwich Capital Commercial Funding Corp. 2007-GG11

                      Current Rating    Prior Rating
                      --------------    ------------
Class D 20173VAL4; LT CCsf Downgrade;  previously at CCCsf
Class E 20173VAM2; LT Dsf  Affirmed;   previously at Dsf
Class F 20173VAN0; LT Dsf  Affirmed;   previously at Dsf
Class G 20173VAP5; LT Dsf  Affirmed;   previously at Dsf
Class H 20173VAR1; LT Dsf  Affirmed;   previously at Dsf
Class J 20173VAT7; LT Dsf  Affirmed;   previously at Dsf
Class K 20173VAV2; LT Dsf  Affirmed;   previously at Dsf
Class L 20173VAX8; LT Dsf  Affirmed;   previously at Dsf
Class M 20173VAZ3; LT Dsf  Affirmed;   previously at Dsf
Class N 20173VBB5; LT Dsf  Affirmed;   previously at Dsf
Class O 20173VBD1; LT Dsf  Affirmed;   previously at Dsf
Class P 20173VBF6; LT Dsf  Affirmed;   previously at Dsf
Class Q 20173VBH2; LT Dsf  Affirmed;   previously at Dsf

KEY RATING DRIVERS

Increased Loss Expectations: The downgrade of class D reflects the
greater certainty of loss since Fitch's last rating action. Losses
are considered probable due to increased loss expectations on the
three remaining assets in the pool, which have all become
real-estate owned (REO) since the last rating action.

The largest REO asset is The Center at Evergreen (45.1% of pool), a
two-building, 43,404 square foot (sf) suburban office complex
located in Evergreen, CO. The loan transferred to special servicing
in March 2017 due to imminent maturity default. The property
suffered from volatile occupancy and declining rents due to poor
submarket conditions. The asset became REO in October 2018.
Occupancy has recently declined further to 74% following the
departure of Kaiser Permanente (13.1% of NRA) in December 2018. In
addition, the largest tenant, US Bank (22.3% of NRA), has a lease
expiration in May 2020.

The next largest REO asset, Walgreen Madison (29.1%), is a
leasehold interest in a 14,490 sf single-tenant retail property
located in Madison, OH, approximately 40 miles outside of
Cleveland. The property is 100% NNN leased to Walgreens
(BBB/Negative) through 2081; the single tenant has a termination
option in 2032. The loan transferred to special servicing in July
2017 due to maturity default and the asset became REO in February
2019. The special servicer is currently marketing the asset for
sale.

The third largest REO asset, Hanes Square (25.9%), is an 18,326 sf
unanchored retail center located in Winston-Salem, NC. The loan
transferred to special servicing in July 2017 due to maturity
default and the imminent lease roll of the two largest tenants,
David's Bridal (54.9% of NRA) and Panera Bread (24.6% of NRA).
While David's Bridal extended their lease through 2027, Panera
Bread and Long Jewelers (9.5% of NRA) vacated during first quarter
2019 and third quarter 2018, respectively. As a result, occupancy
plummeted to 54.9%. The sole remaining tenant at the property,
David's Bridal, had filed for Chapter 11 bankruptcy in November
2018 and subsequently emerged from bankruptcy in January 2019.

Minimal Changes to Credit Enhancement: There have been minimal
changes to credit enhancement since the last rating action. As of
the June 2019 distribution date, the pool's aggregate principal
balance has been reduced by 99.5% to $12.4 million from $2.69
billion at issuance, or 0.8% since Fitch's last rating action.
Realized losses since issuance total $252.3 million (9.4% of the
original pool balance). Cumulative interest shortfalls totaling
$32.9 million are currently affecting classes E through S.


HORIZON AIRCRAFT II: Fitch Rates $41MM Series C Notes 'BBsf'
------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Outlooks to
the Horizon Aircraft Finance II Limited notes:

  -- $375,000,000 series A notes 'Asf'; Outlook Stable;

  -- $69,000,000 series B notes 'BBBsf'; Outlook Stable;

  -- $41,000,000 series C notes 'BBsf'; Outlook Stable.

The aircraft ABS notes will be issued by Horizon Aircraft Finance
II Limited (Horizon Cayman) as listed. The issuer is a Cayman
Islands limited company with tax residency in Ireland, which will
co-issue the notes with Horizon Aircraft Finance II LLC (Horizon
USA). Horizon USA is a special purpose Delaware LLC and wholly
owned subsidiary of Horizon Cayman. Horizon expects to use the
rated note and equity proceeds to acquire the initial 20 aircraft,
fund the maintenance reserve account (MRA), security deposit and
series C reserve accounts, pay certain expenses and fund the
expense account.

The pool will be serviced by BBAM US LP (BBAM US; U.S. servicer)
and BBAM Aviation Services Limited (Irish servicer; collectively
the Servicers), both wholly owned subsidiaries of BBAM LP (BBAM;
not rated [NR] by Fitch), with the notes secured by each aircraft's
future lease and residual cash flows. This is the third Fitch-rated
aircraft ABS serviced by BBAM, and the company has serviced three
prior aircraft ABS (BBAIR NR by Fitch; ECAF I and Horizon I both
rated by Fitch). BBAM is one of the largest aircraft servicing and
management companies in the world.

KEY RATING DRIVERS

Strong Collateral Quality - 100% Liquid Narrowbody Aircraft: The
pool comprises solely of 20 narrowbody (NB), mostly Tier 1 aircraft
including 12 B737-800 (60.9%), six A320-200 (32.8%), one B737-900ER
(4.2%), and one A319-100 (2.1%). The weighted average (WA) age is
8.5 years, similar to recent transactions.

Lease Term and Maturity Schedule - Negative: The WA original lease
term is 10.2 years with 4.6 years remaining. This is a credit
negative as these maturing leases will have less certainty as to
cash flows, and the aircraft will be subject to remarketing costs
and downtime. 50.9% of the leases mature in 2020-2023, with seven
leases (28.8%) maturing in 2020, risks that Fitch took into account
when applying asset assumptions and stresses.

Lessee Credit Risk - Diverse / Weaker Credits: There are 16 airline
lessees with a significant amount of unrated/speculative-grade
airlines, typical of aircraft ABS. The pool is diverse with the top
three totaling 32.3% and 24.9% flag-carriers. Fitch assumed unrated
lessees would perform consistently with either a 'B' or 'CCC'
Issuer Default Rating (IDR) to accurately reflect the default risk
in the pool. Lessee ratings were further stressed during assumed
future recessions and as aircraft reach Tier 3 classification. The
concentration of assumed 'CCC' lessees total 46.5%, compared to
27.3% in Horizon I, and is on the higher end of recent ABS
transactions.

Operational and Servicing Risk - Strong Servicing Capability: BBAM
was founded in 1989 and is a very experienced/tenured aircraft
servicer/manager. Fitch believes BBAM is a capable servicer as
evidenced by its experienced team, the servicing of their managed
fleet and prior serviced/managed securitizations. Horizon Aircraft
Manager Co., Ltd. (Asset Manager), a wholly owned subsidiary of
BBAM and affiliate of the Servicers, will be the Asset Manager,
which Fitch views positively.

Transaction Structure - Consistent: Credit enchancement comprises
overcollateralization, a liquidity facility and a cash reserve. The
initial loan to value (LTV) ratios for the series A, B and C notes
are 65.7%, 77.8% and 85.0%, respectively, based on the average of
half-life base values adjusted for maintenance by Alton.

Aviation Market Cyclicality: Commercial aviation has been subject
to significant cyclicality due to macroeconomic and geopolitical
events. Fitch's analysis assumes multiple periods of significant
volatility over the life of the transaction.

Asset Value and Lease Rate Volatility: Downturns are typically
marked by reduced aircraft utilization rates, values and lease
rates as well as deteriorating lessee credit quality. Fitch employs
aircraft value stresses in its analysis, which takes into account
age and marketability to simulate the decline in lease rates
expected over the course of an aviation market downturn, and
decrease to potential residual sales proceeds.

RATING SENSITIVITIES

The performance of aircraft ABS can be affected by various factors,
which, in turn, could have an impact on the assigned ratings. Fitch
conducted multiple rating sensitivity analyses to evaluate the
impact of changes to a number of the variables in the analysis.
These sensitivity scenarios were also considered in determining the
ratings.

Lease Rate Factor Stress Scenario

Increased competition, largely from newly established APAC lessors,
has contributed to declining lease rates in the aircraft leasing
market over the past few years. Additionally, certain variants have
been more prone to value declines and lease rates due to oversupply
issues. Fitch performed a sensitivity analysis assuming lease rate
factors (LRFs) would not increase after an aircraft reached 11
years of age, providing a material haircut to future lease cash
flow generation. Per Fitch's criteria LRF curve, no subsequent
leases were executed at a LRF greater than 1.13%. This scenario
highlights the effect of increased competition in the aircraft
leasing market, particularly for mid- to end-of-life aircraft over
the past few years, and stresses the pool to a higher degree by
assuming lease rates well below observed market rates. Under this
scenario, the cash flow declined from the primary scenario by
approximately 7%. All three series pass their respective rating
scenarios and are unlikely to experience rating downgrades.

'CCC' Unrated Lessee Stress Scenario

Fitch evaluated a scenario in which all unrated airlines are
assumed to carry a 'CCC' rating. This scenario mimics a prolonged
recessionary environment in which airlines are susceptible to an
increased likelihood of default. This would, in turn, subject the
aircraft pool to more downtime and expenses as repossession and
remarketing events would increase. Under this scenario, the notes
show greater sensitivity with a sharper decline in cash flow by
10%-15% from the primary scenario, along with increased expenses.
This level of stress could result in the series A and C notes being
considered for a downgrade by up to one rating category each.

Technological Obsolescence Stress Scenario

The last sensitivity scenario is to address technological
replacement risk for current technology equipment. All aircraft in
the pool face replacement programs over the next decade,
particularly the A320ceo and B737 NG aircraft in the form of
A320neo and B737 MAX aircraft. Therefore, Fitch utilized a scenario
in which demand, and thus values, of existing aircraft would fall
significantly due to the replacement technology. The first
recession was assumed to occur two years following close, and all
recessionary value decline stresses were increased 10% at each
rating category. Fitch utilized a 25% residual assumption rather
than the base level of 50% to stress end-of-life proceeds for each
asset in the pool. Lease rates drop fairly significantly under this
scenario, and aircraft are essentially sold for scrap at the end of
their useful lives. Despite the declines, all three series pass
their respective rating scenarios and are unlikely to experience
rating downgrades.


JP MORGAN 2012-C6: Moody's Affirms B2 Rating on Class H Debt
------------------------------------------------------------
Moody's Investors Service upgraded the rating on one class and
affirmed the ratings on eleven classes in J.P. Morgan Chase
Commercial Mortgage Securities Trust 2012-C6, Commercial Mortgage
Pass-Through Certificates Series 2012-C6:

Cl. A-3, Affirmed Aaa (sf); previously on Jun 8, 2018 Affirmed Aaa
(sf)

Cl. A-S, Affirmed Aaa (sf); previously on Jun 8, 2018 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Jun 8, 2018 Affirmed Aaa
(sf)

Cl. B, Upgraded to Aa1 (sf); previously on Jun 8, 2018 Affirmed Aa2
(sf)

Cl. C, Affirmed A1 (sf); previously on Jun 8, 2018 Affirmed A1
(sf)

Cl. D, Affirmed A3 (sf); previously on Jun 8, 2018 Affirmed A3
(sf)

Cl. E, Affirmed Baa3 (sf); previously on Jun 8, 2018 Affirmed Baa3
(sf)

Cl. F, Affirmed Ba2 (sf); previously on Jun 8, 2018 Affirmed Ba2
(sf)

Cl. G, Affirmed Ba2 (sf); previously on Jun 8, 2018 Affirmed Ba2
(sf)

Cl. H, Affirmed B2 (sf); previously on Jun 8, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Jun 8, 2018 Affirmed Aaa
(sf)

Cl. X-B*, Affirmed Ba3 (sf); previously on Jun 8, 2018 Affirmed Ba3
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The rating on Cl. B was upgraded based on an increase in credit
support resulting from loan paydowns and amortization as well as a
significant increase in defeasance. The deal has paid down 6.7%
since Moody's last review and defeasance increased to 18.0% of the
current pool balance from 0% at the last review.

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

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

Moody's rating action reflects a base expected loss of 2.5% of the
current pooled balance, compared to 2.6% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.0% of the
original pooled balance, compared to 2.2% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the June 17, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 31% to $778.1
million from $1.13 billion at securitization. The certificates are
collateralized by 35 mortgage loans ranging in size from less than
1% to 15.0% of the pool, with the top ten loans (excluding
defeasance) constituting 50.4% of the pool. Three loans,
constituting 18.0% of the pool, have defeased and are secured by US
government securities.

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

Eleven loans, constituting 21.1% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

No loans are currently in special servicing. One loan have been
liquidated from the pool, resulting in an aggregate realized loss
of $2.9 million (a loss severity of 41%).

Moody's received full year 2018 operating results for 94% of the
pool, and full or partial year 2019 operating results for 61% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 94%, compared to 91% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 15% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 9.9%.

Moody's actual and stressed conduit DSCRs are 1.58X and 1.21X,
respectively, compared to 1.63X and 1.22X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 28.3% of the pool balance.
The largest loan is the Arbor Place Mall loan ($108.0 million --
13.9% of the pool), which is secured by an approximately 546,000 SF
portion of a 1.16 million SF super-regional mall located in
Douglasville, Georgia. The property was built in 1999 and is
anchored by Dillard's, Belk, Macy's, J.C. Penney, and Sears. All
anchors except for J.C. Penney are owned by the respective tenant
and are not part of the collateral. As of the March 2019 rent roll,
the collateral and inline space ( 10,000 SF) were 98% and 96%,
respectively. The property's year-end 2018 net operating income
(NOI) has increased approximately 10% since securitization as a
result of increased revenue and lower expenses. The loan has
amortized 11% since securitization and Moody's LTV and stressed
DSCR are 118% and 0.96X, respectively, compared to 118% and 0.94X
at the last review.

The second largest loan is the Northwoods Mall loan ($64.5 million
-- 8.3% of the pool), which is secured by an approximately 404,000
SF portion of a 791,000 SF regional mall located in North
Charleston, South Carolina. The mall is anchored by J.C. Penney,
Dillard's, and Belk. All anchors except for J.C. Penney are owned
by their respective tenant and are not part of the collateral. At
securitization, Sears was included as a non-collateral anchor,
however, Sears vacated its space in 2017. Burlington Coat Factory
subsequently backfilled a portion of the Sears space with a lease
start date in March 2018. Additionally, the loan's sponsor, CBL
Properties, recently announced plan to open an approximately 46,000
SF Round1 Bowling & Amusement at the property with construction
set to being later this year. As of the March 2019 rent roll, the
collateral and inline spaces ( 10,000 SF) were 97% and 95%,
respectively. The property's year-end 2018 net operating income
(NOI) has increased approximately 22% since securitization as a
result of increased revenue and lower expenses. The loan has
amortized 12% since securitization and Moody's LTV and stressed
DSCR are 98% and 1.10X, respectively, compared to 95% and 1.13X at
the last review.

The third largest loan is the Innisfree Hotel Portfolio loan ($47.8
million -- 6.1% of the pool), which is secured by three
limited-service beachfront hotels with direct access to the Gulf of
Mexico shores. The 137-room Hilton Garden and 119-room Holiday Inn
Express properties are located in Orange Beach, Georgia, and the
181-room Hampton Inn is located in Penacola Beach, Florida. As of
December 2018, the portfolio occupancy and ADR were 70.6% and
$183.61, respectively, resulting in a RevPar of $129.64. The loan
has amortized 10% since securitization and Moody's LTV and stressed
DSCR are 92% and 1.29X, respectively.



JP MORGAN 2016-JP2: Fitch Affirms BB-sf Rating on Class E Certs
---------------------------------------------------------------
Fitch Ratings has affirmed 13 classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust 2016-JP2 commercial mortgage
pass-through certificates.

JPMCC 2016-JP2

                      Current Rating        Prior Rating
                      --------------        ------------
Class A-1 46590MAN0;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-2 46590MAP5;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-3 46590MAQ3;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-4 46590MAR1;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-S 46590MAV2;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-SB 46590MAS9; LT AAAsf  Affirmed;  previously at AAAsf
Class B 46590MAW0;    LT AA-sf  Affirmed;  previously at AA-sf
Class C 46590MAX8;    LT A-sf   Affirmed;  previously at A-sf
Class D 46590MAC4;    LT BBB-sf Affirmed;  previously at BBB-sf
Class E 46590MAE0;    LT BB-sf  Affirmed;  previously at BB-sf
Class X-A 46590MAT7;  LT AAAsf  Affirmed;  previously at AAAsf
Class X-B 46590MAU4;  LT AA-sf  Affirmed;  previously at AA-sf
Class X-C 46590MAA8;  LT BBB-sf Affirmed;  previously at BBB-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: Overall pool performance
remains in line with Fitch's expectations and there have been no
material changes to the pool or loss expectations since issuance;
therefore, the original rating analysis was considered in affirming
the transaction. There are currently no delinquent or specially
serviced loans. Ten loans (12.9%) are on the master servicer's
watchlist for occupancy and performance declines, upcoming rollover
and deferred maintenance, six (10.1%) of which are considered Fitch
loans of concern (FLOC).

Fitch Loans of Concern: The largest FLOC, Four Penn Center (2.3% of
the pool) is secured by a 21-story, 522,600 square foot Class A
office building located in the central business district in
Philadelphia, Pennsylvania. Property occupancy declined to 58.3% as
of March 2019, down from 60% in September 2018 and 84% at issuance,
mainly due to the largest tenant, RELX, downsizing to 15.6% of the
NRA (from 25.9%) and Federal Insurance Company, which formerly
occupied 11.3% of the NRA, vacating at its March 2018 lease
expiration. As part of RELX's downsizing, the tenant also renewed
its lease to September 2025 from June 2018. However, per the master
servicer, the lender has approved a major lease request for a
173,000 sf tenant (GSA - Environmental Protection Agency), which
represents approximately 33% of the property's NRA. The GSA space
does include the former Federal Insurance Co. space. This is
expected to improve occupancy to approximately 90%.

The second-largest FLOC, 700 17th Street (2.2%) is secured by a
182,505 sf office property located in Denver, CO. The largest
tenants are Machol & Johannes (13.2%), expiration March 2021; TGS
Management (7.6%), expiration October 2019; and Colorado National
Bank (6.5%), expiration September 2019. While the property's
occupancy has improved to 93% as of March 2019 from 84% in March
2018 and 90% at issuance, it has a large energy tenancy
concentration and a significant amount (approximately 50%) of
upcoming rollover between 2019-2020. The most recent servicer
reported NOI debt service coverage ratio (DSCR) as of year-end 2018
is 1.30x compared with 1.34x as of September 2018 but down from
1.57x (year-end 2016). Fitch applied a total 20% NOI decline in its
analysis to account for the high upcoming rollover and energy
tenancy concentration.

The third-largest FLOC, Aloft Milwaukee (2.1%) is secured by a
hotel property located in Milwaukee, WI The loan is on the master
servicer's watchlist due to declining in revenues as the year-end
2018 NOI is down 16% from year-end 2017 and 25% from issuance. Per
the most recent servicer provided STR report as of March 2019, the
property reported occupancy of 69.5%, ADR $146, RevPAR $102
comparedwitho 68.8%, $139, $96 for its compeititve set with
penetration rates for occupancy, ADR, and RevPAR of 101.0%, 105.2%,
106.2%, respectively.

Minimal Changes to Credit Enhancement: As of the June 2019
distribution date, the pool's aggregate balance has been reduced by
1.7% to $923.1 million, from $939.2 million at issuance. The
largest loan, Center 21 (8.7% of the pool), has been defeased since
Fitch's last rating action. At issuance, based on the scheduled
balance at maturity, the pool will pay down 11.1% of the initial
pool balance. Five full-term interest-only loans comprise 26.0% of
the pool. Twenty loans representing 47.2% of the pool are partial
interest-only, and 22 loans representing 26.7% of the pool are
balloon.

Pool Concentrations: Ten loans (25.2%), including three in the top
15, are secured by retail properties, Opry Mills (8.7%), The Shops
at Crystal (5.4%) and Hagerstown Premium Outlets (3.3%). At
issuance, the sixth-largest loan, The Shops at Crystal, was given
an investment-grade credit opinion of 'BBB+sf' on a stand-alone
basis. Hotel loans represent 16.5% of the pool, including three
(9.6%) in the top 15. Hotels have the highest probability of
default in Fitch's multiborrower CMBS model. The largest 10 loans
account for 54.9% of the pool by balance. At issuance, two
sponsors, Simon Property Group and CIM Commercial Trust
Corporation, each comprised more than 10% of the pool with 12% and
11%, respectively.

High Concentration of Pari Passu Loans: Nine loans (47.1% of pool)
are pari passu, all of which are in the top 15.


JP MORGAN 2019-5: Moody's Assigns B3 Rating on Cl. B-5 Debt
-----------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to 22
classes of residential mortgage-backed securities issued by J.P.
Morgan Mortgage Trust 2019-5. The ratings range from Aaa (sf) to B3
(sf).

The certificates are backed by 923 30-yearfully-amortizing
fixed-rate mortgage loans with a total balance of $636,423,931 as
of the June 1, 2019 cut-off date. All of the mortgage loans have a
30-year term, except for one which has a 20-year term. Similar to
prior JPMMT transactions, JPMMT 2019-5 includes conforming mortgage
loans (36% by loan balance) mostly originated by United Shore
Financial Services, LLC d/b/a United Wholesale Mortgage and Shore
Mortgage (United Shore) and Quicken Loans Inc. (Quicken),
underwritten to the government sponsored enterprises (GSE)
guidelines in addition to prime jumbo non-conforming mortgages
purchased by J.P. Morgan Mortgage Acquisition Corp. (JPMMAC),
sponsor and mortgage loan seller, from various originators and
aggregators. United Shore, and Quicken Loans Inc. originated 46%
and 31% of the mortgage pool, respectively.

JPMorgan Chase Bank, N.A. and Quicken Loans Inc. will be the
servicers for majority of the pool. NewRez LLC f/k/a New Penn
Financial, LLC d/b/a Shellpoint Mortgage Servicing (Shellpoint)
will act as interim servicer for certain mortgage loans (currently
62% by loan balance) until the servicing transfer date, which is
expected to occur on or about August 1, 2019. After the servicing
transfer date, these mortgage loans will be serviced by Chase.

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. Quicken and 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. (Citibank) 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 2019-5

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 Aa2 (sf)

Cl. A-15, Definitive Rating Assigned Aa2 (sf)

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

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

Cl. B-1, Definitive Rating Assigned A1 (sf)

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

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

Cl. B-4, Definitive Rating Assigned B1 (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 0.55%
in a base scenario and reaches 6.45% 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
Moody's did not apply a separate loss-level adjustment for
aggregation quality. In addition to reviewing JPMMAC as an
aggregator, Moody's has also reviewed the originators contributing
a significant percentage of the collateral pool. For these
originators, Moody's reviewed their underwriting guidelines and
their policies and documentation (where available). Moody's
increased its base case and Aaa (sf) loss expectations for certain
originators of non-conforming loans, such as United Shore, Quicken,
New Penn Financial, LLC, and USAA Federal Savings Bank (USAA),
where Moody's 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, N.A. (servicer): Chase, the second largest
mortgage servicer in the U.S., 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.

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 at B2.

Collateral Description

JPMMT 2019-5 is a securitization of a pool of 923 fully-amortizing
fixed-rate mortgage loans with a total balance of $636,423,931 as
of the cut-off date, with a weighted average (WA) remaining term to
maturity of 356 months, and a WA seasoning of 3 months. All of the
mortgage loans have a 30-year term, except for one which has a
20-year term. The borrowers in this transaction have high FICO
scores and sizeable equity in their properties. The WA current FICO
score is 765 and the WA original combined loan-to-value ratio
(CLTV) is 73.0%. The characteristics of the loans underlying the
pool are generally comparable to other JPMMT transactions backed by
prime mortgage loans that Moody's has rated.

In this transaction, about 36% of the pool by loan balance was
underwritten to Fannie Mae's and Freddie Mac's guidelines
(conforming loans). The conforming loans in this transaction have a
high average current loan balance at $605,860. The high conforming
loan balance of loans in JPMMT 2019-5 is attributable to the large
number of properties located in high-cost areas, such as the metro
areas of Los Angeles (17%), San Francisco (12%), and New York City
(5%). United Shore and Quicken Loans Inc. originated 46% and 31%
respectively. The remaining originators each account for less than
10% of the principal balance of the loans in the pool.

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 will be paid a monthly
flat servicing fee equal to one-twelfth of 0.25% of the remaining
principal balance of the mortgage loans. As stated earlier,
Shellpoint will act as interim servicer until the servicing
transfer date, August 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 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. Finally, with respect to
appraisal quality, TPR firms' 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 firms also compared third party
valuation products to the original appraisals. While the TPR
secondary values generally substantiated the original valuations,
certain loans had secondary valuation review which were done using
automated valuation models (AVMs). Moody's believes that because
the deal is utilizing AVMs as a comparison to verify the original
appraisals, this is much weaker (due to accuracy concerns) than if
they had done desk reviews (CDAs) for the entire pool. Therefore,
Moody's applied an adjustment to loans for which only an AVM was
conducted.

JPMMT 2019-5'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 providers vary in financial strength. JPMorgan Chase Bank,
N.A. (rated Aa2), is the R&W provider for approximately 7.62% (by
loan balance) of the pool. Moody's made no adjustments to the loans
for which Chase, TIAA, FSB (d/b/a TIAA Bank) and USAA (a subsidiary
of USAA Capital Corporation which is rated Aa1) 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. JPMMAC will not backstop 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 1.10% 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 6.00% 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 0.75% 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.


JPMCC COMMERCIAL 2019-COR5: Fitch Rates $6.9MM Cl. G-RR Certs B-sf
------------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to JPMCC Commercial Mortgage Securities Trust 2019-COR5
commercial mortgage pass-through certificates series 2019-COR5:

  -- $14,650,000 class A-1 'AAAsf'; Outlook Stable;

  -- $66,432,000 class A-2 'AAAsf'; Outlook Stable;

  -- $162,850,000 class A-3 'AAAsf'; Outlook Stable;

  -- $218,498,000 class A-4 'AAAsf'; Outlook Stable;

  -- $26,615,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $546,683,000b class X-A 'AAAsf'; Outlook Stable;

  -- $65,497,000b class X-B 'A-sf'; Outlook Stable;

  -- $57,638,000 class A-S 'AAAsf'; Outlook Stable;

  -- $34,932,000 class B 'AA-sf'; Outlook Stable;

  -- $30,565,000 class C 'A-sf'; Outlook Stable;

  -- $17,000,000ab class X-D 'BBBsf'; Outlook Stable.

  -- $17,000,000a class D 'BBBsf'; Outlook Stable;

  -- $17,059,000ac class E-RR 'BBB-sf'; Outlook Stable;

  -- $16,592,000ac class F-RR 'BB-sf'; Outlook Stable;

  -- $6,987,000ac class G-RR 'B-sf'; Outlook Stable.

The following class is not rated:

  -- $28,819,121ac class H-RR 'NR'.

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

(b) Notional amount and interest-only.

(c) Horizontal credit risk retention interest representing no less
than 5% of the estimated fair value of all classes of regular
certificates issued by the issuing entity as of the closing date.

Since Fitch published its expected ratings on June 5, 2019, the
balances for class A-3, A-4, D, E-RR and X-D were finalized. When
expected ratings were assigned, the class A-3 and class A-4
balances were estimated within the ranges of $75,000,000 to
$180,000,000 and the range of $201,348,000 to $306,348,000,
respectively. The final class sizes for class A-3 and class A-4 are
$162,850,000 and $218,498,000, respectively. When expected ratings
were assigned, the class D, class E-RR and class X-D balances were
estimated at $16,244,000, $16,244,000 and $17,815,000,
respectively. The final class sizes for class D, class E-RR and
class X-D are $17,000,000, $17,059,000 and $17,000,000,
respectively.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 46 loans secured by 135
commercial properties having an aggregate principal balance of
$698,637,121 as of the cut-off date. The loans were originated by
JPMorgan Chase Bank, National Association (f) and LoanCore Capital
Markets LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 81.8% of the properties
by balance, cash flow analysis of 96.0% and asset summary reviews
on 100.0% of the pool.

(f) One of the mortgage loans being sold by JPMorgan Chase Bank,
National Association, the SWVP Portfolio mortgage loan, is part of
a whole loan that was co-originated by Societe Generale Financial
Corporation and JPMCB. The loan has been or will be purchased by
JPM or an affiliate.

KEY RATING DRIVERS

Higher Fitch Leverage than Recent Transactions: The pool's leverage
is higher than that of recent Fitch-rated multiborrower
transactions. The pool's Fitch loan-to-value (LTV) of 103.3% is
higher than 2018 and YTD 2019 averages of 102.0% and 101.6%,
respectively. The pool's Fitch debt service coverage ratio (DSCR)
of 1.12x is below the 2018 and YTD 2019 averages of 1.22x and
1.23x, respectively.

Investment-Grade Credit Opinion Loans: Twenty loans comprising
15.0% of the transaction received an investment-grade credit
opinion. This is above the YTD 2019 and 2018 averages of 8.3% and
13.2%, respectively. 3 Columbus Circle (7.2% of the pool) and ICON
UES (3.6%) each received stand-alone credit opinions of 'BBB-sf'*.
The ICON 18 loans (4.3%) have credit opinions ranging from
'BBB-sf*' to 'BBB+sf*' on a stand-alone basis. Excluding these
loans, the pool's Fitch DSCR and LTV are 1.09x and 109.1%,
respectively.

Limited Amortization: Thirty loans (57.1% of the pool) are full
term interest only and 10 loans (21.9% of the pool) are partial
interest only. The pool is scheduled to amortize just 6.4% of the
initial pool balance by maturity, which is lower than the 2018
average of 7.2%, but slightly higher than the YTD 2019 average of
6.2%.


KEY COMMERCIAL 2019-S2: DBRS Assigns Prov. B Rating on Cl. F Certs
------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-S2 to be
issued by Key Commercial Mortgage Trust 2019-S2:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-S at AAA (sf)
-- Class B at AA (low) (sf)
-- Class IO at A (sf)
-- Class C at A (low) (sf)
-- Class D at BBB (low) (sf)
-- Class E at BB (sf)
-- Class F at B (sf)

All trends are Stable.

The Class IO balance is notional.

The collateral consists of 29 fixed-rate loans secured by 36
commercial and multifamily properties. The transaction is of a
sequential-pay pass-through structure. The conduit pool was
analyzed to determine the provisional ratings, reflecting the
long-term probability of loan default within the term. When the
cut-off loan balances were measured against the DBRS Stabilized Net
Cash Flow and their respective actual constants, four loans,
representing 14.7% of the pool, have a DBRS Term Debt Service
Coverage Ratio (DSCR) below 1.15 times (x), including two loans,
representing 7.6% of the pool, that have a DBRS Term DSCR below
1.00x, a threshold indicative of a higher likelihood of mid-term
default.

The deal has favorable credit metrics, as evidenced by an issuance
weighted-average (WA) loan-to-value (LTV) ratio and balloon WA LTV
of 64.7% and 55.0%, respectively. Only two loans, comprising 7.2%
of the trust balance, have Issuance As-Is LTVs of 75.0% or higher.
The deal exhibits ample property-type diversification, with no
single property type accounting for more than 22.3% of the pool by
allocated loan balance. The largest concentrations include
self-storage, office, retail and industrial, which account for
22.2%, 19.3%, 15.0% and 12.0% of the pool by allocated loan
balance, respectively. Furthermore, only one loan, representing
8.4% of the pool by allocated loan balance, is secured by two hotel
properties. Hotels have the highest cash flow volatility of all
property types, as their income, which is derived from daily
contracts rather than multiyear leases, and their expenses, which
are often mostly fixed, account for a relatively large proportion
of revenue. As a result, cash revenue can decline swiftly in the
event of a downturn and cash flow may decline more exponentially
because of high operating leverage. However, the loan is secured by
two extended-stay hotels that have a much more stable cash flow
profile than traditional hotels.

Fourteen loans, representing 47.2% of the pool, are secured by
properties located in markets ranked one or two, which are
considered more rural or tertiary in nature, including five of the
top ten loans (Forestbrook Village, Coeymans Industrial Portfolio,
Pacific Rim Apartments, Sea Breeze MHC and 5950 North Main Street).
Further, only two loans (Broadway Ace Hardware & Storage and Siete
II Office Building), representing 7.3% of the pool, are secured by
a property modeled with a market rank of six, which is typically
lighter urban in nature. Only one loan (180 North Wacker Drive),
representing 7.0% of the pool, is secured by a property located in
a market ranked seven, while no loans are secured by properties in
markets ranked eight. Markets ranked seven and eight are generally
denser urban in nature and benefit from greater liquidity, even
during times of economic stress.

The pool is relatively concentrated based on loan size, as there
are only 29 loans and it has a concentration profile similar to a
pool of 23 equally sized loans. The ten largest loans represent
52.2% of the pool by allocated loan balance, and the largest three
loans represent 21.0% of the pool by allocated loan balance. While
the concentration profile is like a pool of 23 equally sized loans
— which is typically worse than most fixed-rate conduit
transactions — the transaction benefits from favorable
property-type diversification. The pooling simulation analysis
within the CMBS Insight Model implicitly accounts for loan
concentration, which results in high AAA loss estimates given the
relatively low pool-level expected loss of 2.5%.

Class IO is an interest-only (IO) certificate that references a
single rated tranche or multiple rated tranches. The IO rating
mirrors the lowest-rated reference tranche adjusted upward by one
notch if senior in the waterfall.


LB COMMERCIAL 1999-C1: Moody's Affirms C Ratings on 2 Tranches
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings on three classes in
LB Commercial Mortgage Trust 1999-C1 as follows:

Cl. H, Affirmed B1 (sf); previously on Mar 28, 2018 Upgraded to B1
(sf)

Cl. J, Affirmed C (sf); previously on Mar 28, 2018 Affirmed C (sf)

Cl. X*, Affirmed C (sf); previously on Mar 28, 2018 Affirmed C
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on the two P&I classes were affirmed because the
ratings are consistent with the pool's realized loss and Moody's
expected recovery of principal and interest from the remaining
loans in the pool. Cl. J has already experienced a 94% realized
loss as a result of previously liquidated loans.

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

Moody's does not anticipate losses from the remaining collateral in
the current environment. However, over the remaining life of the
transaction, losses may emerge from macro stresses to the
environment and changes in collateral performance. Its ratings
reflect the potential for future losses under varying levels of
stress. Moody's base expected loss plus realized losses is now 2.7%
of the original pooled balance, compared to 2.7% at the last
review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the June 17, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by over 99% to $2.5
million from $1.58 billion at securitization. The certificates are
collateralized by two mortgage loans.

Thirty-two loans have been liquidated from the pool, resulting in
an aggregate realized loss of $42.1 million (for an average loss
severity of 35%). There are no loans currently in special
servicing.

The largest remaining loan is the Bed, Bath & Beyond Loan ($1.6
million -- 64.7% of the pool), which is secured by a single tenant
occupied retail property located in Newport News, Virginia, across
from the Patrick Henry Mall. The single tenant is Bed, Bath &
Beyond which has a lease expiring in January 2020, coterminous with
the maturity date of the loan. The loan has amortized over 66% and
Moody's LTV and stressed DSCR are 94% and 1.09X, respectively.

The other remaining loan is the Spalding Center Shopping Center
Loan ($885,975 -- 35.3% of the pool), which is secured by an
approximately 59,000 SF neighborhood shopping center located in
Norcross, Georgia approximately 30 miles from the Atlanta CBD. The
property's former anchor, Gold's Gym (47% of NRA), terminated their
lease in April 2017, however, the borrower signed a five-year lease
with Energy Fitness Group to take-over the Gold's Gym space. The
property was 90% occupied as of June 2019, compared to 89% in June
2017. The loan is on the master servicer's watchlist due to low
DSCR, however, the loan is fully amortizing, has amortized 68%
since securitization and matures in July 2023. Moody's LTV and
stressed DSCR are 45% and 2.51X, respectively.


LB-UBS COMMERCIAL 2007-C1: Fitch Affirms D Rating on 6 Tranches
---------------------------------------------------------------
Fitch Ratings has upgraded one and affirmed seven classes of LB-UBS
Commercial Mortgage Trust commercial mortgage pass-through
certificates series 2007-C1.

LB-UBS Commercial Mortgage Trust 2007-C1

Debt              Current Rating    Prior Rating
----                --------------    ------------
Class F 50179AAN7  LT CCsf Upgrade previously at Csf
Class G 50179AAS6  LT Csf Affirmed previously at Csf
Class H 50179AAT4  LT Dsf Affirmed previously at Dsf
Class J 50179AAU1  LT Dsf Affirmed previously at Dsf
Class K 50179AAV9  LT Dsf Affirmed previously at Dsf
Class L 50179AAW7  LT Dsf Affirmed previously at Dsf
Class M 50179AAX5  LT Dsf Affirmed previously at Dsf
Class N 50179AAY3  LT Dsf Affirmed previously at Dsf

KEY RATING DRIVERS

REO Assets Remain: Although all of the remaining assets in the pool
are real estate owned (REO), the upgrade of Class F reflects a
reduced certainty of losses to the class. The largest asset, GTECH
Office Campus (46.5% of the pool), is 100% occupied by GTECH with a
lease expiration in 2027 and the Fitch value currently exceeds the
remaining balance in class F. However, disposition timing remains
uncertain as the servicer has no plans to market the property for
sale at this time and the loan's total exposure will continue to
increase.

Based on the total exposure of the assets and the most recent
appraisal values, most of which reflct loan-to-values (LTVs) above
100%, significant losses are expected to impact the remaining
distressed classes.

Increasing Credit Enhancement: Since Fitch's last rating action,
Midtown Plaza Shopping Center (previously 17.8% of the pool
balance), was disposed with better than expected recoveries. The
disposition reduced the class F certificates by $14.2 million and
losses were limited to the class H certificates, which are
currently rated 'Dsf'. The pool has been reduced by 98% to $66.5
million from $3.7 billion at issuance. Interest shortfalls
totalling $43.7 million are currently impacting all remaining
classes.

Highly Concentrated Pool: Of the remaining REO assets, four (48.9%
of the pool) are secured by retail properties, primarily located in
secondary and tertiary markets. The remaining two assets are
secured by office properties (51.1% of the pool) located in
secondary markets. Due to the extremely concentrated nature of the
pool, Fitch performed a look-through analysis that grouped the
remaining assets based on the likelihood of repayment, in addition
to the potential losses from the liquidation of the specially
serviced asset. Based on this analysis, the remaining classes G and
H are expected to incur losses.

RATING SENSITIVITIES

The upgrade of class F reflects the expected paydown from
recoveries and improvement in credit enhancement upon the
successful liquidation of the larger REO assets. Upgrades are
unlikely but possible should the special servicer dispose of assets
in the near term and recoveries be higher than expected.

The remaining distressed class ratings reflect the expectation of
losses associated with the REO assets. Should realized losses be
higher than expected, downgrades are possible.



LENDMARK FUNDING 2019-1: DBRS Gives Prov. BB Rating on Cl. D Notes
------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following notes to
be issued by Lendmark Funding Trust 2019-1 (Series 2019-1):

-- $278,720,000 Series 2019-1, Class A rated AA (sf)
-- $21,019,000 Series 2019-1, Class B rated A (sf)
-- $32,898,000 Series 2019-1, Class C rated BBB (low) (sf)
-- $17,363,000 Series 2019-1, Class D rated BB (sf)

RATING RATIONALE/DESCRIPTION

  -- The transaction's capital structure, proposed ratings and form
and sufficiency of available credit enhancement.

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

  -- Lendmark Financial Services, LLC's (Lendmark) capabilities
with regard to originations, underwriting, and servicing.

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

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

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


MARLIN RECEIVABLES 2018-1: Fitch Affirms BBsf Rating on Cl. E Debt
------------------------------------------------------------------
Fitch Ratings has affirmed the ratings on the notes issued by
Marlin Receivables 2018-1 LLC.

Marlin Receivables 2018-1 LLC

                      Current Rating     Prior Rating
Class A-2 571183AB8; LT AAAsf Affirmed; previously at AAAsf
Class A-3 571183AC6; LT AAAsf Affirmed; previously at AAAsf
Class B 571183AD4;   LT AAsf  Affirmed; previously at AAsf
Class C 571183AE2;   LT Asf   Affirmed; previously at Asf
Class D 571183AF9;   LT BBBsf Affirmed; previously at BBBsf
Class E 571183AG7;   LT BBsf  Affirmed; previously at BBsf

KEY RATING DRIVERS

The affirmation of the outstanding notes reflects loss coverage
levels consistent with the respective rating categories. The
Positive Outlook for the class B, C, D and E notes along with
Stable Outlook for the class A notes reflect Fitch's expectation
for loss coverage and credit enhancement to continue to improve as
the transaction amortizes.

As of the June 2019 reporting period, 61+ day delinquencies are at
83bps. Cumulative gross defaults (CGD) are at 96bps and are
projecting below the initial base case loss proxy of 4.50%. Hard CE
has increased to 37.75%, 29.30%, 20.04%, 15.59% and 12.03% for
classes A, B, C, D and E, respectively. This is up from 23.35%,
18.60%, 13.40%, 10.90% and 8.90% for each respective class at
close.

Based on the transaction's performance to date, Fitch revised the
CGD assumption under the stressed loss approach to 4.00% from 4.50%
at close. Fitch's stressed cash flow assumptions were unchanged
from close. Under these assumptions, loss coverage for the class A,
B, C, D and E notes are able to support multiples in excess of the
'AAAsf,' 'AAsf', 'Asf', 'BBBsf' and 'BBsf' categories,
respectively. However, given recent increases in CGD's, rating
upgrades were not assigned during this review. Fitch will continue
to monitor the recent increasing defaults and may consider future
positive rating actions if this trend stabilizes given the general
overall strong performance to date. Current obligor concentrations
have declined from initial levels; thus, Fitch believes the
transactions have limited exposure to obligor concentration risk.
As such, the primary rating approach is the stressed loss approach.


MORGAN STANLEY 2011-C3: Moody's Affirms B2 Rating on Cl. G Certs
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on ten classes in
Morgan Stanley Capital I Trust 2011-C3, Commercial Mortgage
Pass-Through Certificates, Series 2011-C3 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Jun 1, 2018 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Jun 1, 2018 Affirmed Aaa
(sf)

Cl. A-J, Affirmed Aaa (sf); previously on Jun 1, 2018 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa1 (sf); previously on Jun 1, 2018 Affirmed Aa1
(sf)

Cl. C, Affirmed A1 (sf); previously on Jun 1, 2018 Affirmed A1
(sf)

Cl. D, Affirmed A3 (sf); previously on Jun 1, 2018 Affirmed A3
(sf)

Cl. E, Affirmed Baa3 (sf); previously on Jun 1, 2018 Affirmed Baa3
(sf)

Cl. F, Affirmed Ba2 (sf); previously on Jun 1, 2018 Affirmed Ba2
(sf)

Cl. G, Affirmed B2 (sf); previously on Jun 1, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Jun 1, 2018 Affirmed Aaa
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

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

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

Moody's rating action reflects a base expected loss of 2.3% of the
current pooled balance, compared to 1.4% at Moody's last review.
Moody's base expected loss plus realized losses is now 1.2% of the
original pooled balance, compared to 0.9% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the June 17, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 46% to $803 million
from $1.49 billion at securitization. The certificates are
collateralized by 41 mortgage loans ranging in size from less than
1% to 16.8% of the pool, with the top ten loans (excluding
defeasance) constituting 70% of the pool. One loan, constituting
1.4% of the pool, has an investment-grade structured credit
assessment. Nine loans, constituting 8.5% of the pool, have
defeased and are secured by US government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 12, compared to 15 at Moody's last review.

Nine loans, constituting 38% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package. As part of Moody's
ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

No loans have been liquidated from the pool, and there are
currently no loans in special servicing.

Moody's received full year 2017 operating results for 100% of the
pool, and full year 2018 operating results for 97% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 90%, compared to 85% at Moody's last review.
Moody's conduit component excludes loans with structured credit
assessments, defeased and CTL loans, and specially serviced and
troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 20% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.6%.

Moody's actual and stressed conduit DSCRs are 1.52X and 1.22X,
respectively, compared to 1.56X and 1.24X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The loan with a structured credit assessment is the 420 East 72nd
Street Coop Loan ($11.0 million -- 1.4% of the pool), which is
secured by a twenty-story co-op building located in the Lenox Hill
neighborhood of Manhattan in New York City. Moody's structured
credit assessment is aaa (sca.pd).

The top three conduit loans represent 39% of the pool balance. The
largest loan is the Park City Center Loan ($135.3 million -- 16.8%
of the pool), which is secured by a 1.2 million square foot (SF)
super-regional mall located in Lancaster, Pennsylvania. The
property is also encumbered by a $42 million mezzanine loan. The
mall features five anchor spaces, currently occupied by Boscov's
(non-collateral), J.C. Penney, and Kohl's; two remaining anchor
spaces are currently vacant following the closure of Bon Ton in
2018 and Sears in 2019. As of March 2019, the total property was
78% leased, compared to 82% in December 2018 and 98% in December
2017. Total inline space was 89% occupied in December 2018,
compared to 94% in December 2017. The property has an Apple store,
with the next closest Apple store over 49 miles away. The loan has
amortized 12% since securitization and the year-end 2018 NOI was
approximately 6% higher than underwritten levels. The master
servicer reported that the borrower is in negotiations with a
replacement tenant to backfill the former Bon-Ton space. The loan
matured in June 2016 and an initial 30-day forbearance period was
executed as the Borrower works towards refinancing the debt.

The second largest loan is the Belden Village Loan ($95.7 million
-- 11.9% of the pool), which is secured by a 419,000 SF portion of
a 818,000 SF regional mall located 18 miles south of Akron in
Canton, Ohio. The non-collateral anchors are Dillard's and Sears.
As of December 2018, inline and the total mall were 97% and 99%
leased, respectively, compared to 99% and 99% in the prior year.
Retail competition consists of Chapel Hill Mall, located 21 miles
north, and The Strip, a power center located just north of the
subject property. Seritage Growth Properties, which owns the Sears
space, has announced plans to reduce the store's footprint at the
property, carving out space for Dave & Busters as a potential
tenant. The loan has amortized 4% since securitization and Moody's
LTV and stressed DSCR are 105% and 1.05X, respectively, compared to
88% and 1.17X at the last review.

The third largest loan is the Oxmoor Center Loan ($82.9 million --
10.3% of the pool), which is secured by a leasehold interest in a
941,000 SF super-regional mall in Louisville, Kentucky. The center
is currently anchored by Macy's, Von Maur, and Dick's Sporting
Goods. Sears, a former anchor, closed their space in early 2018.
The Borrower announced it is working to backfill the former Sears
space with TopGolf and three additional restaurants. All anchors
own the improvements with the exception of Dick's Sporting Goods.
As of December 2018, the inline space and total mall were 89% and
81% leased, respectively, compared to 87% and 97% in December 2017.
The property has an Apple store, with the next closest Apple store
over 60 miles away. Due to declines in revenues and increased
expenses, property performance declined between 2018 and 2017,
however, the property's 2018 NOI was approximately 6% above
underwritten levels. The loan has amortized 12% since
securitization. Moody's LTV and stressed DSCR are 84% and 1.19X,
respectively, compared to 80% and 1.25X at the last review.


NEW RESIDENTIAL 2019-3: Moody's Assigns (P)B1 Rating on 5 Tranches
------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to 31
classes of notes issued by New Residential Mortgage Loan Trust
2019-3. The NRMLT 2019-3 transaction is a $388.8 million
securitization of first lien, seasoned performing and re-performing
mortgage loans with weighted average seasoning of 175 months, a
weighted average updated LTV ratio of 44.9% and a weighted average
updated FICO score of 725. Based on the OTS methodology, 92.6% of
the loans by scheduled balance have been current every month for at
least in the past 24 months using OTS methodology. Additionally,
the pool consists of 25.7% adjustable-rate mortgages (ARMs) and
20.4% of the loans in the pool (by balance) have been previously
modified. Nationstar Mortgage LLC (Nationstar Mortgage) will act as
primary servicer. Nationstar Mortgage will act as master servicer
and successor servicer and NewRez LLC d/b/a Shellpoint Mortgage
Servicing (Shellpoint) will act as the special servicer.

The complete rating action is as follows:

Issuer: New Residential Mortgage Loan Trust 2019-3

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

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

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

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

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

Cl. A-2, Provisional Rating Assigned (P)Aa1 (sf)

Cl. B-1, Provisional Rating Assigned (P)Aa2 (sf)

Cl. B-1A, Provisional Rating Assigned (P)Aa2 (sf)

Cl. B-1B, Provisional Rating Assigned (P)Aa2 (sf)

Cl. B-1C, Provisional Rating Assigned (P)Aa2 (sf)

Cl. B-1D, Provisional Rating Assigned (P)Aa2 (sf)

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

Cl. B-2A, Provisional Rating Assigned (P)A3 (sf)

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

Cl. B-2C, Provisional Rating Assigned (P)A3 (sf)

Cl. B-2D, Provisional Rating Assigned (P)A3 (sf)

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

Cl. B-3A, Provisional Rating Assigned (P)Baa3 (sf)

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

Cl. B-3C, Provisional Rating Assigned (P)Baa3 (sf)

Cl. B-3D, Provisional Rating Assigned (P)Baa3 (sf)

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

Cl. B-4A, Provisional Rating Assigned (P)Ba2 (sf)

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

Cl. B-4C, Provisional Rating Assigned (P)Ba2 (sf)

Cl. B-5, Provisional Rating Assigned (P)B1 (sf)

Cl. B-5A, Provisional Rating Assigned (P)B1 (sf)

Cl. B-5B, Provisional Rating Assigned (P)B1 (sf)

Cl. B-5C, Provisional Rating Assigned (P)B1 (sf)

Cl. B-5D, Provisional Rating Assigned (P)B1 (sf)

Cl. B-7, Provisional Rating Assigned (P)Ba3 (sf)

RATINGS RATIONALE

Its losses on the collateral pool equal 1.95% in an expected
scenario and reach 12.00% at a stress level consistent with the Aaa
ratings on the senior classes. Moody's based its expected losses
for the pool on its estimates of (1) the default rate on the
remaining balance of the loans and (2) the principal recovery rate
on the defaulted balances. The final expected losses for the pool
reflect the third party review findings and its assessment of the
representations and warranties framework for this transaction.
Also, the transaction contains a mortgage loan sale provision, the
exercise of which is subject to potential conflicts of interest. As
a result of this provision, Moody's increased its expected losses
for the pool.

To estimate the losses on the pool, Moody's used an approach
similar to its surveillance approach. Under this approach, Moody's
applied expected annual delinquency rates, conditional prepayment
rates (CPRs), loss severity rates and other variables to estimate
future losses on the pool. Its assumptions on these variables are
based on the observed performance of seasoned modified and
non-modified loans, the collateral attributes of the pool including
the percentage of loans that were delinquent in the past 36 months.
For this pool, Moody's used default burnout assumptions similar to
those detailed in its "US RMBS Surveillance Methodology" for Alt-A
loans originated pre 2005. Moody's then aggregated the
delinquencies and converted them to losses by applying
pool-specific lifetime default frequency and loss severity
assumptions. Of note, since the overall profile of this pool is
more similar to RPL pools, Moody's applied similar RPL loss
assumptions to this pool to derive collateral losses.

Collateral Description

NRMLT 2019-3 is a securitization of seasoned performing and
re-performing residential mortgage loans which the seller, NRZ
Sponsor V LLC, has purchased in connection with the termination of
various securitization trusts. Similar to prior NRMLT transactions
Moody's has rated, all of the collateral was sourced from
terminated securitizations. Approximately 20.4% of the loans had
previously been modified and are now current and cash flowing and
25.7% of the collateral consists of ARM loans. The transaction is
comprised of 3,143 loans.

The updated value of properties in this pool were provided by a
third party firm using a home data index (HDI) and/or an updated
broker price opinion (BPO). BPOs were provided for a sample of 622
out of the 3,143 properties contained within the securitization.
HDI values were provided for all but one property contained within
the securitization. The weighted average updated LTV ratio on the
collateral is 44.9%, implying an average of 55.1% borrower equity
in the properties.

Third-Party Review and Representations & Warranties

Two third party due diligence providers, AMC and Recovco, conducted
a compliance review on a sample of 257 and 603 seasoned mortgage
loans respectively for the initial due diligence pool. The
regulatory compliance review consisted of a review of compliance
with the federal Truth in Lending Act (TILA) as implemented by
Regulation Z, the federal Real Estate Settlement Procedures Act
(RESPA) as implemented by Regulation X, the disclosure requirements
and prohibitions of Section 50(a)(6), Article XVI of the Texas
Constitution, federal, state and local anti-predatory regulations,
federal and state specific late charge and prepayment penalty
regulations, and document review.

AMC found that 229 out of 257 loans had compliance exceptions with
30 having rating agency grade C or D level exceptions. Recovco
reviewed 603 loans and found that 89 loans have a rating of C or D,
fourr loans have a rating of A and the remaining 510 loans have a
rating of B. Also, based on information provided by the seller,
there were additional loans dropped from the securitization due to
compliance exceptions.

Based on its analysis of the TPR reports, Moody's determined that a
portion of the loans with some cited violations are at enhanced
risk of having violated TILA through an under-disclosure of the
finance charges or other disclosure deficiencies. Although the TPR
report indicated that the statute of limitations for borrowers to
rescind their loans has already passed, borrowers can still raise
these legal claims in defense against foreclosure as a set off or
recoupment and win damages that can reduce the amount of the
foreclosure proceeds. Such damages include up to $4,000 in
statutory damages, borrowers' legal fees and other actual damages.
Moody's increased its losses for these loans to account for such
damages.

AMC and Recovco reviewed the findings of various title search
reports covering 158 and 390 mortgage loans respectively in the
preliminary sample population in order to confirm the first lien
position of the related mortgages. Overall, AMC's review confirmed
that 157 mortgages were in first lien position. For the one
remaining loan reviewed by AMC, proof of first lien position could
only be confirmed using the final title policy as of loan
origination. Recovco reported that 385 of the mortgage loans it
reviewed were in first-lien position and for the remaining five
loans it reviewed, proof of first lien position could only be
confirmed using the final title policy as of loan origination.

The seller, NRZ Sponsor V LLC, is providing a representation and
warranty for missing mortgage files. To the extent that the master
servicer, related servicer or depositor has actual knowledge, or a
responsible officer of the Indenture Trustee has received written
notice, of a defective or missing mortgage loan document or a
breach of a representation or warranty regarding the completeness
of the mortgage file or the accuracy of the mortgage loan
documents, and such missing document, defect or breach is
preventing or materially delaying the (a) realization against the
related mortgaged property through foreclosure or similar loss
mitigation activity or (b) processing of any title claim under the
related title insurance policy, the party with such actual
knowledge will give written notice of such breach, defect or
missing document, as applicable, to the seller, indenture trustee,
depositor, master servicer and related servicer. Upon notification
of a missing or defective mortgage loan file, the seller will have
120 days from the date it receives such notification to deliver the
missing document or otherwise cure the defect or breach. If it is
unable to do so, the seller will be obligated to replace or
repurchase the mortgage loan.

Trustee, Custodian, Paying Agent, Servicers, Master Servicer,
Successor Servicer and Special Servicer

The transaction indenture trustee is Wilmington Trust, National
Association. The custodian functions will be performed by Wells
Fargo Bank, N.A. The paying agent and cash management functions
will be performed by Citibank, N.A. In addition, Nationstar
Mortgage, as master servicer, is responsible for servicer
oversight, termination of servicers, and the appointment of
successor servicers. Having Nationstar Mortgage as a master
servicer mitigates servicing-related risk due to the performance
oversight that it will provide. Shellpoint will serve as the
special servicer and, as such, will be responsible for servicing
mortgage loans that become 60 or more days delinquent. Nationstar
Mortgage will serve as the designated successor servicer for
Shellpoint.

Nationstar Mortgage will act as the primary servicer of the
collateral pool. Moody's considers the overall servicing
arrangement to be adequate.

Transaction Structure

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to increasingly receive principal
prepayments after an initial lock-out period of five years,
provided two performance tests are met. To pass the first test, the
delinquent and recently modified loan balance cannot exceed 50% of
the subordinate bonds outstanding. To pass the second test,
cumulative losses cannot exceed certain thresholds that gradually
increase over time.

Because a shifting interest structure allows subordinated bonds to
pay down over time as the loan pool shrinks, senior bonds are
exposed to tail risk, i.e., risk of back-ended losses when fewer
loans remain in the pool. The transaction provides for a senior and
subordination floor that helps to reduce this tail risk.
Specifically, the subordination floor prevents subordinate bonds
from receiving any principal if the amount of subordinate bonds
outstanding falls below 2.25% of the cut-off date principal
balance. There is also a provision that prevents subordinate bonds
from receiving principal if the credit enhancement for the Class
A-1 note falls below its percentage at closing, 13.50%. In
addition, there are provisions that "lock out" certain subordinate
bonds and allocate principal to more senior subordinate bonds if,
for a given class, credit enhancement levels decline below their
initial percentages or below 2.25% of the cut-off date principal
balance. These provisions have been incorporated into its cash flow
model and are reflected in its ratings

Other Considerations

The transaction contains a mortgage loan sale provision, the
exercise of which is subject to potential conflicts of interest.
The servicers in the transaction may sell mortgage loans that
become 60 or more days delinquent according to the MBA methodology
to any party in the secondary market in an arms-length transaction
and at a fair market value. For such sale to take place, the
related servicer must determine, in its reasonable commercial
judgment, that such sale would maximize proceeds on a present value
basis. If the sponsor or any of its subsidiaries is the purchaser,
the related servicer must obtain at least two additional
independent bids. The transaction documents provide little detail
on the method of receipt of bids and there is no set minimum sale
price. Such lack of detail creates a risk that the independent bids
could be weak bids from purchasers that do not actively participate
in the market. Furthermore, the transaction documents provide
little detail regarding how servicers should conduct present value
calculations when determining if a note sale should be pursued. The
special servicer, Shellpoint, is an affiliate of the sponsor. The
servicer in the transaction, Nationstar Mortgage, has a commercial
relationship with the sponsor outside of the transaction. These
business arrangements could lead to conflicts of interest. Moody's
took this into account and adjusted its losses accordingly.

When analyzing the transaction, Moody's reviewed the transaction's
exposure to large potential indemnification payments owed to
transaction parties due to potential lawsuits. In particular,
Moody's assessed the risk that the indenture trustee would be
subject to lawsuits from investors for a failure to adequately
enforce the R&Ws against the seller. Moody's believes that NRMLT
2019-3 is adequately protected against such risk primarily because
the loans in this transaction are highly seasoned with a weighted
average seasoning is approximately 175 months. Although some loans
in the pool were previously delinquent and modified, the loans all
have a substantial history of payment performance. This includes
payment performance during the recent recession. As such, if loans
in the pool were materially defective, such issues would likely
have been discovered prior to the securitization. Furthermore,
third party due diligence was conducted on a significant random
sample of the loans for issues such as data integrity, compliance,
and title. As such, Moody's did not apply adjustments in this
transaction to account for indemnification payment risk.

In addition, prior to closing, the collateral pool has
approximately $291,801 of unreimbursed servicing advances such as
taxes and insurance. The mortgage borrower is responsible for
reimbursing the servicer for the pre-existing servicing advances.
The servicer may choose to set the pre-existing advances as escrow
to be repaid by the borrower as part of monthly mortgage payments.
However, in the event the borrower defaults on the mortgage prior
to fully repaying the pre-existing servicing advances, the servicer
will recoup the outstanding amount of pre-existing advances from
the loan liquidation proceeds. The amount of pre-existing servicing
advances only represent 7.5 basis points of total pool balance. As
borrowers make monthly mortgage payments, this amount would likely
decrease. Moreover, its loan loss severity assumption incorporates
reimbursement of servicing advances from liquidation proceeds.

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 loss could drive
the ratings up. Losses could decline from its 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. Other reasons for
better-than-expected performance include changes to servicing
practices that enhance collections or refinancing opportunities
that result in prepayments.

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 its 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.


NEW RESIDENTIAL 2019-NQM3: DBRS Finalizes B Rating on Cl. B-2 Notes
-------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the Mortgage-Backed
Notes, Series 2019-NQM3 (the Notes) issued by New Residential
Mortgage Loan Trust 2019-NQM3 (the Issuer) as follows:

-- $213.2 million Class A-1 at AAA (sf)
-- $22.7 million Class A-2 at AA (sf)
-- $25.6 million Class A-3 at A (sf)
-- $15.8 million Class M-1 at BBB (sf)
-- $11.9 million Class B-1 at BB (sf)
-- $7.0 million Class B-2 at B (sf)

The AAA (sf) rating on the Notes reflects the 30.00% of credit
enhancement provided by subordinated Notes in the pool. The AA
(sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect 22.55%,
14.15%, 8.95%, 5.05% and 2.75% of credit enhancement,
respectively.

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

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate, prime, expanded prime and non-prime first-lien
residential mortgages funded by the issuance of the Notes. The
Notes are backed by 638 loans with a total principal balance of
$304,602,771 as of the Cut-Off Date (June 1, 2019).

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

(1) SmartSelf and SmartSelf Plus (63.3%) — Generally made to
self-employed borrowers using bank statements to support
self-employed income for qualification purposes.

(2) SmartEdge and SmartEdge Plus (22.0%) — Generally made to
borrowers seeking flexible financing options (interest-only (IO)
loans or higher debt-to-income ratios (DTIs)) who may have a hard
recent credit event (two or more years seasoned) that may preclude
prequalification for another program.

(3) SmartVest (11.4%) — Generally made to borrowers who are
experienced real estate investors looking to purchase or refinance
an investment property that is held for business purposes.

(4) Portfolio Express ReFi (0.8%) — Generally made to existing
borrowers seeking flexible-rate and term refinancing options who do
not meet agency guidelines.

(5) Smart Funds (0.6%) — Generally made to prime borrowers with
significant assets who can purchase the property with their assets
but choose to use a financing instrument for cash flow purposes.

(6) SmartTrac (0.6%) — Generally made to borrowers seeking
flexible financing options (IO loans or higher DTIs) that may have
had a recent credit event (one to two or more years seasoned) that
may preclude prequalification for another program.

(7) SmartCondo (0.5%) — Generally made to prime borrowers seeking
flexible financing options for condominium properties that do not
meet agency guidelines.

(8) High-Balance Extra (0.4%) — Generally made to prime borrowers
with loan amounts exceeding the government-sponsored-enterprise
loan limits that may fall outside the Qualified Mortgage (QM)
requirements based on documentation and DTI.

(9) Portfolio Debt Consolidation (0.3%) — Generally made to
existing borrowers seeking flexible refinance options to help
consolidate debt who do not meet agency guidelines.

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

Although the applicable mortgage loans were originated to satisfy
the Consumer Financial Protection Bureau (CFPB) Ability-to-Repay
(ATR) rules, they were made to borrowers who generally do not
qualify for agency, government or private-label non-agency prime
jumbo products for various reasons. In accordance with the CFPB
QM/ATR rules, 74.3% of the loans are designated as non-QM.
Approximately 25.7% of the loans are made to investors for business
purposes and, hence, are not subject to the QM/ATR rules.

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

Through a majority-owned affiliate, the Sponsor intends to retain
at least 5% of each class of Notes issued by the Issuer (other than
the Class R Notes) to satisfy the credit risk retention
requirements under Section 15G of the Securities Exchange Act of
1934 and the regulations promulgated thereunder.

The Seller will have the option, but not the obligation, to
repurchase any mortgage loan that becomes 60 or more days
delinquent under the Mortgage Bankers Association method or any
real estate–owned property acquired in respect of a mortgage loan
at a price equal to the stated principal balance of such loan,
provided that such repurchases in aggregate do not exceed 10% of
the total principal balance as of the Cut-Off Date (Optional
Repurchase Price).

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

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

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

The ratings reflect transactional strengths that include the
following:

-- Robust loan attributes and pool composition,
-- ATR rules and Appendix Q compliance,
-- Satisfactory third-party due diligence review and
-- Improved underwriting standards.

The transaction also includes the following challenges:

-- Representations and warranties framework,
-- Non-prime, non-QM and investor loans,
-- Limited Servicer advances of delinquent principal and interest

     and
-- Servicer's financial capability.

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


NOMURA CRE 2007-2: Fitch Lowers Rating on Class D Debt to 'Dsf'
---------------------------------------------------------------
Fitch Ratings has downgraded one class and affirmed 10 classes of
Nomura CRE CDO 2007-2, Ltd./LLC.

Nomura CRE CDO 2007-2, Ltd./LLC

                              Current Rating    Prior Rating
Class D Fltg Notes Due 2042;  LT Dsf Downgrade; previously at Csf
Class E Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class F Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class G Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class H Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class J Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class K Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class L Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class M Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class N Fltg Notes Due 2042;  LT Csf Affirmed;  previously at Csf
Class O Fltg Notes Due 2042; LT Csf Affirmed;  previously at Csf

KEY RATING DRIVERS

Class D was downgraded to 'D' from 'C' as a Notice of Event of
Default was issued due to a default in the payment of interest on
the class D notes.

Default of the remaining rated classes is considered inevitable.
The collateralized debt obligation (CDO) is under-collateralized in
excess of $260 million. The balance of the most senior outstanding
class D notes of $28.8 million exceeds the remaining collateral of
$25.2 million. All remaining classes have negative credit
enhancement.

As of the May 2019 trustee report, the CDO is failing all
over-collateralization and interest coverage tests. Since the last
rating action, and as of the May 2019 trustee report, no additional
loans have been disposed. The transaction remains highly
concentrated with only four assets remaining, two defaulted
commercial real estate CDO bonds (61.1% of collateral) and two
whole loans (38.9%) secured by retail properties in Baton Rouge, LA
and Kennewick, WA.


OBX TRUST 2019-INV2: Moody's Assigns B3 Rating on Class B-5 Debt
----------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to 38
classes of residential mortgage-backed securities issued by OBX
2019-INV2 Trust. The ratings range from Aaa (sf) to B3 (sf).

OBX 2019-INV2, the third rated issue from Onslow Bay Financial LLC
in 2019, is a prime RMBS securitization of fixed-rate,
agency-eligible mortgage loans secured by first liens on non-owner
occupied residential properties with original terms to maturity of
mostly 30 years. All the loans are underwritten in accordance with
Freddie Mac or Fannie Mae underwriting guidelines, which take into
consideration, among other factors, the income, assets, employment
and credit score of the borrower. All the loans were underwritten
using one of the government-sponsored enterprises' automated
underwriting systems and received an "Approve" or "Accept"
recommendation.

The mortgage loans for this transaction were acquired by the seller
and sponsor, Onslow Bay, either directly from Quicken Loans Inc.
(75.7%), JPMorgan Chase Bank, N.A. (13.7%), or from various
mortgage lending institutions, each of which originated less than
4% of the mortgage loans in the pool.

Quicken Loans Inc., Select Portfolio Servicing, Inc., and
Specialized Loan Servicing LLC will service 75.7%, 19.9%, and 4.4%
of the aggregate balance of the mortgage pool, respectively, and
Wells Fargo Bank, N.A. (Wells Fargo) will be the master servicer.
Certain servicing advances and advances for delinquent scheduled
interest and principal payments will be funded, unless the related
mortgage loan is 120 days or more delinquent or the servicer
determines that such delinquency advances would not be recoverable.
The master servicer is obligated to fund any required monthly
advances if the servicer fails in its obligation to do so. The
master servicer and servicer will be entitled to reimbursements for
any such monthly advances from future payments and collections with
respect to those mortgage loans.

OBX 2019-INV2 has a shifting interest structure with a five-year
lockout period that benefits from a senior subordination floor and
a subordination floor. Moody's coded the cash flow to each of the
notes using Moody's proprietary cash flow model. In its analysis of
tail risk, Moody's considered the increased risk from borrowers
with more than one mortgage in the pool.

The complete rating actions are as follows:

Issuer: OBX 2019-INV2 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 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. 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 Aaa (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. A-25, Definitive Rating Assigned Aa1 (sf)

Cl. A-26, Definitive Rating Assigned Aaa (sf)

Cl. A-27, Definitive Rating Assigned Aaa (sf)

Cl. A-28, Definitive Rating Assigned Aaa (sf)

Cl. A-29, Definitive Rating Assigned Aaa (sf)

Cl. A-30, Definitive Rating Assigned Aaa (sf)

Cl. A-31, Definitive Rating Assigned Aaa (sf)

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

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

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

Cl. B-2A, 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 0.90%
in a base scenario and 9.90% at a stress level consistent with the
Aaa (sf) ratings.

Its loss estimates are based on a loan-by-loan assessment of the
securitized collateral pool as of the cut-off date using Moody's
Individual Loan Level Analysis model. Loan-level adjustments to the
model included adjustments to borrower probability of default for
higher and lower borrower debt-to-income ratios (DTIs), for
borrowers with multiple mortgaged properties, self-employed
borrowers, and for risks related to mortgaged properties in
Homeowner associations in super lien states. Its final loss
estimates also incorporate adjustments for origination quality and
the strength of the representation and warranty (R&W) framework.

Moody's bases its definitive ratings on the notes 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 OBX 2019-INV2 transaction is a securitization of 1,087 mortgage
loans secured by fixed-rate, agency-eligible first liens on
non-owner occupied one-to-four family residential properties,
planned unit developments and condominiums with an unpaid principal
balance of $383,759,828. All the loans have a 30-year original
term, except for one which has a 25-year original term. The
mortgage pool has a WA seasoning of about 6 months. The loans in
this transaction have strong borrower credit characteristics with a
weighted average original FICO score of 770 and a weighted-average
original combined loan-to-value ratio (CLTV) of 64.9%. In addition,
20.4% of the borrowers are self-employed and refinance loans
comprise about 54.2% of the aggregate pool. The pool has a high
geographic concentration with 58.5% of the aggregate pool located
in California, with 17.0% located in the Los Angeles-Long
Beach-Anaheim MSA and 14.5% located in the San
Francisco-Oakland-Hayward MSA. The characteristics of the loans
underlying the pool are generally comparable to other recent prime
RMBS transactions backed primarily by 30-year mortgage loans that
Moody's has rated.

Origination Quality

Majority of the mortgage loans in the pool were originated by
Quicken Loans (75.7%) and JPMorgan Chase Bank, N.A. (13.7%).
Moody's applied an adjustment to the loss levels for loans
originated by Quicken Loans due to the relatively worse performance
of their agency-eligible investment property mortgage loans
compared to similar loans from other originators in the Freddie Mac
and Fannie Mae database. All the loans comply with Freddie Mac and
Fannie Mae underwriting guidelines, which take into consideration,
among other factors, the income, assets, employment and credit
score of the borrower. All the loans received an "Approve" or
"Accept" recommendation from one of the government-sponsored
enterprises' (GSE) automated underwriting systems (AUS).

Servicing Arrangement

Quicken Loans will make principal and interest advances (subject to
a determination of recoverability) for the mortgage loans that it
services. The P&I Advancing Party (Onslow Bay) will make principal
and interest advances (subject to a determination of
recoverability) for the mortgage loans serviced by SPS and SLS to
the extent that such delinquency advances exceed amounts on deposit
for future distribution, the excess servicing strip fee that would
otherwise be paid to the Class A-IO-S notes and the P&I Advancing
Party fee.

The master servicer is obligated to fund any required monthly
advances if a servicer or any other party obligated to advance
fails in its obligation to do so. The master servicer and servicers
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.

No advances of delinquent principal or interest will be made for
mortgage loans that become 120 days or more delinquent under the
MBA method. Subsequently, if there are mortgage loans that are 120
days or more delinquent on any payment date, there will be a
reduction in amounts available to pay principal and interest
otherwise payable to note holders.

Unlike the previous OBX Trust transaction Moody's rated, with
respect to the mortgage loans serviced by SPS and SLS, the
controlling holder has the right (i) to oversee certain matters
relating to the servicing of defaulted mortgage loans (such as
approving any modifications and actions relating to the management
of REO property), (ii) to direct the master servicer to terminate a
servicer upon an uncured servicing event of default under the
related servicing agreement, and (iii) to direct the transaction
parties to take certain actions in connection with a proposed
acquisition of a mortgaged property as a result of an eminent
domain proceeding by a governmental entity.

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

Two 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, property valuation, data
integrity and regulatory compliance reviews on 100% of the mortgage
pool. The TPR checked to ensure that all the reviewed loans were in
compliance with (AUS) underwriting guidelines and AUS loan
eligibility requirements with generally no material compliance,
credit data or valuation issues. The results indicated that
majority of reviewed loans were in compliance with the underwriting
guidelines, government regulations. There were generally no
material findings. In cases where there were findings, there were
significant and satisfactory compensating factors.

The R&W provider is the sponsor (Onslow Bay), an unrated entity
that may not have the financial wherewithal to purchase defective
loans. However, all the loans in the pool had independent due
diligence review and the results of the review revealed compliance
with underwriting guidelines and regulations, as well as overall
strong valuation quality. These results indicate that the loans
most likely do not breach the R&Ws. Also, the transaction benefits
from unqualified R&Ws and an independent breach reviewer. The R&Ws
do not protect against issues discovered and disclosed during the
due diligence review. The R&W's are not subject to sunset, other
than the six-year statute of limitations for R&W claims in New
York. Moody's increased its loss levels to account for some
weaknesses in the overall R&W framework due to the financial
weakness of the R&W provider and the lack of a repurchase mechanism
for loans experiencing an early payment default and weaknesses in
the review procedures compared to other prime jumbo transactions.

Tail Risk and Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
shrinks, senior bonds are exposed to increased performance
volatility, known as tail risk. The transaction provides for a
senior subordination floor of 2.00% of the initial aggregate
balance of the pool, which mitigates tail risk by protecting the
senior bonds from eroding credit enhancement over time.
Additionally, there is a subordination lock-out amount equal to
0.90% of the initial aggregate balance of the pool. Based on its
tail risk analysis, the levels of the floors are slightly lower
than its credit neutral floors, but not sufficiently so to merit an
adjustment.

Exposure to Extraordinary expenses

Extraordinary trust expenses in this transaction are deducted
directly from the available distribution amount. Moody's believes
there is a very low likelihood that the rated notes in this
transaction will incur any losses from extraordinary expenses or
indemnification payments from potential future lawsuits against key
deal parties. Firstly, 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. Secondly, 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
certain clearly 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 credit, compliance and
valuation review of 100% of the mortgage loans by independent third
parties. Thirdly, extraordinary trust expenses (except for those
associated with servicing transfers) are capped at $275,000 which
limits the exposure of the trust to potential losses due to such
extraordinary trust expenses. Moody's made an adjustment to its
loss levels to account for the risk of losses due to such
extraordinary trust expenses.

Other Transaction Parties

Wilmington Savings Fund Society, FSB will act as the trustee for
this transaction. Wells Fargo will act as a paying agent, master
servicer, note registrar and custodian for this transaction. In its
capacity as custodian, Wells Fargo will hold the collateral
documents, which include, the original note and mortgage and any
intervening assignments of mortgage.

Wells Fargo provides oversight of the servicer. Moody's considers
Wells Fargo as a strong master servicer of residential loans. Wells
Fargo's oversight encompasses loan administration, default
administration, compliance and cash management.

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.


PREFERREDPLUS TRUST CZN-1: Moody's Cuts $34MM Certs Rating to Caa2
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of the following certificates issued by PREFERREDPLUS Trust
Series CZN-1:

US$34,500,000 PREFERREDPLUS Trust Series CZN-1 Certificates,
Downgraded to Caa2; previously on March 8, 2018 Downgraded to Caa1

RATINGS RATIONALE

The rating action is a result of the change in the rating of 7.05%
Debentures due October 1, 2046 issued by Frontier Communications
Corporation which was downgraded to Caa2 on June 26, 2019.

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction.

Methodology Underlying the Rating Action:

The principal methodology used in this rating was "Moody's Approach
to Rating Repackaged Securities" published in March 2019.

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

The rating will be sensitive to any change in the rating of the
7.05% Debentures due October 1, 2046 issued by Frontier
Communications Corporation.


REALT 2019-1: DBRS Finalizes B Rating on Class G Certificates
-------------------------------------------------------------
DBRS Limited finalized its provisional ratings on the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2019-1 issued by Real Estate Asset Liquidity Trust (REALT), Series
2019-1 (the Issuer):

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

All trends are Stable.

Classes D-2, E, F and G will be privately placed. The Class X
balance is notional.

The collateral consists of 43 fixed-rate loans, four pari passu
co-ownership interests and one senior co-ownership interest
(collectively, the loans) secured by 77 commercial properties. The
transaction is of a sequential-pay pass-through structure. The
conduit pool was analyzed to determine the ratings, reflecting the
long-term probability of loan default within the term and its
liquidity at maturity. When the cut-off loan balances were measured
against the DBRS Stabilized Net Cash Flow (NCF) and their
respective actual constants, one loan, representing 4.9% of the
total pool, had a DBRS Term Debt Service Coverage Ratio below 1.15
times, which is a threshold indicative of a high likelihood of
mid-term default.

Twenty-eight loans, representing 60.4% of the pool, were considered
to have meaningful recourse to the respective sponsor; all else
being equal, recourse loans typically have a lower probability of
default and were analyzed as such. Based on the DBRS sample and
analysis, three loans (18.5% of the pool) were considered to be of
Above Average property quality and three loans (11.0% of the pool)
of Average (+) property quality. Higher-quality properties are more
likely to retain existing tenants and more easily attract new
tenants, resulting in more stable performance. All loans in the
pool amortize for the entire term, with 23.4% of the pool
amortizing on schedules that are 25 years or fewer, and the
remaining loans amortizing on schedules that are between 25 and 30
years.

The DBRS sample included 32 of the 48 loans in the pool,
representing 87.5% of the pool by loan balance. Site inspections
were performed on 50 of the 77 properties in the portfolio (64.2%
of the pool by loan balance). The DBRS-sampled loans had an average
NCF variance of -4.95% from the Issuer's NCF and ranged from -11.9%
(Leima Office Building) to -0.9% (Group Guzzo Retail Terrebonne).
For the non-sampled loans, DBRS applied the average NCF variances
of Royal Bank of Canada–originated loans and acquired loans,
respectively.

Class X, which is interest only (IO), references multiple rated
tranches. The IO rating mirrors the lowest-rated applicable
reference obligation tranche adjusted upward by one notch if senior
in the waterfall.


RMF BUYOUT 2019-1: Moody's Rates Class M4 Debt 'Ba2'
----------------------------------------------------
Moody's Investors Service assigned definitive ratings to five
classes of residential mortgage-backed securities (RMBS) issued by
RMF Buyout Issuance Trust 2019-1. The ratings range from Aaa (sf)
to Ba2 (sf). The definitive rating on Class M2, Class M3 and Class
M4 is higher than the provisional rating assigned because the
actual coupon of all the notes is lower than the coupon used for
assigning the provisional ratings.

The certificates are backed by a pool that includes 761 inactive
home equity conversion mortgages (HECMs) and 129 real estate owned
(REO) properties. The servicer for the deal is Reverse Mortgage
Funding, LLC.

The complete rating actions are as follows:

Issuer: RMF Buyout Issuance Trust 2019-1

Cl. A, Definitive Rating Assigned Aaa (sf)
Cl. M1, Definitive Rating Assigned Aa3 (sf)
Cl. M2, Definitive Rating Assigned A2 (sf)
Cl. M3, Definitive Rating Assigned Baa2 (sf)
Cl. M4, Definitive Rating Assigned Ba2 (sf)

RATINGS RATIONALE

The collateral backing RBIT 2019-1 consists of first-lien inactive
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. If a borrower or
their estate fails to pay the amount due upon maturity or otherwise
defaults, the sale of the property is used to recover the amount
owed. The mortgage assets were acquired from Ginnie Mae sponsored
HECM mortgage backed (HMBS) securitizations or from the collapse of
private-label securitizations by an unrelated third-party sponsor.
All of the mortgage assets are covered by FHA insurance for the
repayment of principal up to certain amounts.

There are 890 mortgage assets with a balance of $187,137,765. The
assets are in either default, due and payable, bankruptcy,
foreclosure or REO status. Loans that are in default may cure or
move to due and payable; due and payable loans may cure or move to
foreclosure; and foreclosure loans may cure or move to REO. 19.3%
of the assets are in default of which 2.8% (of the total assets)
are in default due to non-occupancy and 16.5% (of the total assets)
are in default due to delinquent taxes and insurance. 19.6% of the
assets are due and payable, 4.0% are in bankruptcy status and 43.1%
are in foreclosure. Finally, 13.9% of the assets are REO properties
and were acquired through foreclosure or deed-in-lieu of
foreclosure on the associated loan. This transaction has a
relatively high percentage of REO properties when compared to RBIT
2018-1. All else equal, a higher percentage of REO properties
suggests that a larger percentage of assets will be liquidated
shortly after closing and therefore the weighted average life may
be shorter.

The initial weighted average loan-to-value-plus-insurance ratio is
52.8%, which is lower than RBIT 2018-1. This implies that, all else
equal, more loans in this pool will have their insurance claims
capped by the MCA. Also, the weighted average LTV ratio is 120.1%
which is higher than in most other inactive HECM transactions
Moody's has rated. As such, borrowers in this pool tend to have
less equity in their homes compared to most prior transactions
which may lead to lower cure and repayment rates.

There are 28 loans in this transaction, 2.6% of the asset balance,
backed by properties in Puerto Rico. Puerto Rico HECMs pose
additional risk due to the poor state of the Puerto Rico economy,
declining population, and bureaucratic foreclosure process.
Furthermore, Puerto Rico is still struggling to recover from
Hurricane Maria. In August 2018, HUD extended the foreclosure
moratorium in areas affected by Hurricane Maria for an additional
month. The moratorium ended on September 15, 2018. Even though the
moratorium has now been lifted, there are likely to be additional
delays due to court related backlogs, additional foreclosure
procedures for impacted properties, and difficulties in tracking
down borrowers or their heirs.

Of note, RMF has received a civil investigative demand from the
U.S. Department of Justice relating to allegations that RMF
submitted noncompliant properties and property appraisals for
reverse mortgage insurance by the FHA. There are 21 mortgages
(which represents approximately 1.6% of total UPB of the pool)
originated by RMF (or one of its approved partners) in this pool
which are within the scope of the demand. Moody's has not made any
adjustments for these 21 mortgages because the allegations would
not affect the validity of the FHA insurance for the affected
mortgages. Per 12 U.S.C. § 1709(e), the statutory incontestability
clause prevents HUD from asserting origination errors against a
subsequent holder of the loan, except for such holder's own fraud
or misrepresentation. At the closing of the securitization, RMF
will transfer the mortgage to the acquisition trust and the
acquisition trustee on behalf of the acquisition trust would be the
subsequent holder of the loans. Any monetary damages associated
with the allegations would be paid by RMF (or its affiliates) and
would not be passed on to the noteholders. There is a strong
mechanism to ensure continuous advancing for the assets in the pool
along with a clear and efficient process for choosing a successor
servicer that protects the noteholders if this alleged violation
adversely affects RMF's ability to perform its obligations under
the sale and servicing agreement.

Servicing

RMF will be the named servicer for the portfolio under the sale and
servicing agreement. RMF has the necessary processes, staff,
technology and overall infrastructure in place to effectively
oversee the servicing of this transaction. RMF will use Compu-Link
Corporation, d/b/a Celink ("Celink") as subservicer to service the
mortgage assets. Based on an operational review of RMF, it has
adequate sub-servicing monitoring processes, a seasoned servicing
oversight team and direct system access to the sub-servicers' core
systems. In addition, a third party will review RMF's monthly
servicing reports on a quarterly basis to ensure data accuracy
throughout the life of the transaction.

As is the RBIT 2018-1 deal, a firm of independent accountants or a
due-diligence review firm (the verification agent) will perform
quarterly procedures with respect to the monthly servicing reports
delivered by the servicer to the trustee. These procedures will
include comparison of the underlying records relating to the
subservicer's servicing of the loans and determination of the
mathematical accuracy of calculations of loan balances stated in
the monthly servicing reports delivered to the trustee. Any
material exceptions identified as a result of the procedures will
be described in the verification agent's report. To the extent the
verification agent identifies errors in the monthly servicing
reports, the servicer will be obligated to correct them.

Transaction Structure

The securitization has a sequential liability structure amongst six
classes of notes with structural subordination. All funds
collected, prior to an acceleration event, are used to make
interest payments to the notes, then principal payments to the
Class A notes, then to a redemption account until the amount on
deposit in the redemption account is sufficient to cover future
principal and interest payments for the subordinate notes up to
their expected final payment dates. The subordinate notes will not
receive principal until the beginning of their respective target
amortization periods (in the absence of an acceleration event). The
notes benefit from structural subordination as credit enhancement,
and an interest reserve account funded with cash received from the
initial purchasers of the notes for liquidity and credit
enhancement.

The transaction is callable on or after six months with a 1.0%
premium and on or after 12 months without a premium. The mandatory
call date for the Class A notes is in August 2021. For the Class M1
notes, the expected final payment date is in December 2021. For the
Class M2 notes, the expected final payment date is in February
2022. For the Class M3 notes, the expected final payment date is in
April 2022. For the Class M4 notes, the expected final payment date
is in July 2022. Finally, for the Class M5 notes, the expected
final payment date is in October 2022. For each of the subordinate
notes, there are target amortization periods that conclude on the
respective expected final payment dates. The legal final maturity
of the transaction is 10 years.

Available funds to the transaction are expected to primarily come
from the liquidation of REO properties and receipt of FHA insurance
claims. These funds will be received with irregular timing. In the
event that there are insufficient funds to pay interest in a given
period, the interest reserve account may be utilized. Additionally,
any shortfall in interest will be classified as an available funds
cap shortfall. These available funds cap carryover amounts will
have priority of payments in the waterfall and will also accrue
interest at the respective note rate.

Certain aspects of the waterfall are dependent upon RMF remaining
as servicer. Servicing fees and servicer related reimbursements are
subordinated to interest and principal payments while RMF is
servicer. However, servicing advances will instead have priority
over interest and principal payments in the event that RMF defaults
and a new servicer is appointed.

The transaction provides a strong mechanism to ensure continuous
advancing for the assets in the pool. Specifically, if the servicer
fails to advance and such failure is not remedied for a period of
15 days, the sub-servicer can fund their advances from collections
and from an interim advancing reserve account. Given the
significant amount of advancing required to service inactive HECMs
with tax delinquencies, this provision helps to minimize
operational disruption in the event RMF encounters financial
difficulties.

In addition, the transaction establishes a clear and efficient
process for choosing a successor servicer following the removal of
the servicer. Specifically, the servicer will provide a list of
eligible successor servicers to the indenture trustee on a
semiannual basis and if the controlling noteholders have directed
the indenture trustee to terminate the servicer, a successor
servicer will be selected based on a voting process that does not
require a supermajority of the senior noteholders to actively
consent.

Third-Party Review

A third party firm conducted a review of certain characteristics of
the mortgage assets on behalf of RMF. The review focused on data
integrity, FHA insurance coverage verification, accuracy of
appraisal recording, accuracy of occupancy status recording,
borrower age documentation, identification of excessive corporate
advances, documentation of servicer advances, and identification of
tax liens with first priority in Texas. Also, broker price opinions
(BPOs) were ordered for 177 properties in the pool.

The third party review (TPR) firm conducted an extensive data
integrity review. Certain data tape fields, such as the mortgage
insurance premium (MIP) rate, the current UPB, current interest
rate, and marketable title date were reviewed against RMF's
servicing system. However, a significant number of data tape fields
were reviewed against imaged copies of original documents of
record, screen shots of HUD's HERMIT system, or HUD documents. Some
key fields reviewed in this manner included the original note rate,
the debenture rate, foreclosure first legal date, and the called
due date.

Certain of the TPR results were in line with recent inactive HECM
transactions that Moody's has rated including the results related
to the accuracy of reported valuations, the presence of FHA
insurance, the existence of property preservation expenses in
excess of FHA reimbursement thresholds, and the accuracy of
reported disbursements. However, other TPR results were weak
compared to previous inactive HECM transactions such as the high
rate of exceptions related to the tax and insurance disbursement,
and borrower age documentation. RBIT 2019-1's TPR results showed a
10.7% initial-tape exception rate related to the tax and insurance
disbursement and a 12.5% initial-tape exception rate related to
borrower age documentation. In its analysis, Moody's applied
adjustments to account for the TPR results in certain areas.

Reps & Warranties (R&W)

RMF is the loan-level R&W provider and is not rated. This
relatively weak financial profile is mitigated by the fact that RMF
will subordinate its servicing advances, servicing fees, and MIP
payments in the transaction and thus has significant alignment of
interests. Another factor mitigating the risks associated with a
financially weak R&W provider is that a third-party due diligence
firm conducted a review on the loans for evidence of FHA
insurance.

RMF represents that the mortgage loans are covered by FHA insurance
that is in full force and effect. RMF provides further R&Ws
including those for title, first lien position, enforceability of
the lien, and the condition of the property. Although RMF provides
a no fraud R&W covering the origination of the mortgage loans,
determination of value of the mortgaged properties, and the sale
and servicing of the mortgage loans, the no fraud R&W is made only
as to the initial mortgage loans. Aside from the no fraud R&W, RMF
does not provide any other R&W in connection with the origination
of the mortgage loans, including whether the mortgage loans were
originated in compliance with applicable federal, state and local
laws. Although certain representations are knowledge qualified, the
transaction documents contain language specifying that if a
representation would have been breached if not for the knowledge
qualifier then RMF will repurchase the relevant asset as if the
representation had been breached.

Upon the identification of an R&W breach, RMF has to cure the
breach. If RMF is unable to cure the breach, RMF must repurchase
the loan within 90 days from receiving the notification. Moody's
believes the absence of an independent third party reviewer who can
identify any breaches to the R&W makes the enforcement mechanism
weak in this transaction. Also, RMF, in its good faith, is
responsible for determining if a R&W breach materially and
adversely affects the interests of the trust or the value the
collateral. This creates the potential for a conflict of interest.

When analyzing the transaction, Moody's reviewed the transaction's
exposure to large potential indemnification payments owed to
transaction parties due to potential lawsuits. In particular,
Moody's assessed the risk that the acquisition trustee would be
subject to lawsuits from investors for a failure to adequately
enforce the R&Ws against the seller. Moody's believes that RBIT
2019-1 is adequately protected against such risk in part because a
third-party data integrity review was conducted on a significant
random sample of the loans. In addition, the third-party due
diligence firm verified that all of the loans in the pool are
covered by FHA insurance.

Trustee & Master Servicer

The acquisition and owner trustee for the RBIT 2019-1 transaction
is Wilmington Savings Fund Society, FSB. The paying agent and cash
management functions will be performed by U.S. Bank National
Association. U.S. Bank National Association will also serve as the
claims payment agent and as such will be the HUD mortgagee of
record for the mortgage assets in the pool.

Methodology

The methodologies used in these ratings were "Moody's Approach to
Rating Securitizations 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 2019.

Its quantitative asset analysis is based on a loan-by-loan modeling
of expected payout amounts given the structure of FHA insurance and
with various stresses applied to model parameters depending on the
target rating level.

FHA insurance claim types: funds come into the transaction
primarily through the sale of REO properties and through FHA
insurance claim receipts. There are uncertainties related to the
extent and timing of insurance proceeds received by the trust due
to the mechanics of the FHA insurance. HECM mortgagees may suffer
losses if a property is sold for less than its appraised value.

The amount of insurance proceeds received from the FHA depends on
whether a sales based claim (SBC) or appraisal based claim (ABC) is
filed. SBCs are filed in cases where the property is successfully
sold within the first six months after the servicer has acquired
marketable title to the property. ABCs are filed six months after
the servicer has obtained marketable title if the property has not
yet been sold. For an SBC, HUD insurance will cover the difference
between (i) the loan balance and (ii) the higher of the sales price
and 95.0% of the latest appraisal, with the transaction on the hook
for losses if the sales price is lower than 95.0% of the latest
appraisal. For an ABC, HUD only covers the difference between the
loan amount and 100% of appraised value, so failure to sell the
property at the appraised value results in loss.

Moody's expects ABCs to have higher levels of losses than SBCs. The
fact that there is a delay in the sale of the property usually
implies some adverse characteristics associated with the property.
FHA insurance will not protect against losses to the extent that an
ABC property is sold at a price lower than the appraisal value
taken at the six month mark of REO. Additionally, ABCs do not cover
the cost to sell properties (broker fees) while SBCs do cover these
costs. For SBCs, broker fees are reimbursable up to 6.0%
ordinarily. Its base case expectation is that properties will be
sold for 13.5% less than their appraisal value for ABCs. To make
this assumption, Moody's considered industry data and the
historical experience of RMF. Moody's stressed this percentage at
higher credit rating levels. At a Aaa rating level, Moody's assumed
that ABC appraisal haircuts could reach up to 30.0%.

In its asset analysis, Moody's also assumed there would be some
losses for SBCs, albeit lower amounts than for ABCs. Based on
historical performance, in the base case scenario Moody's assumed
that SBCs would suffer 1.0% losses due to a failure to sell the
property for an amount equal to or greater than 95.0% of the most
recent appraisal. Moody's stressed this percentage at higher credit
rating levels. At a Aaa rating level, Moody's assumed that SBC
appraisal haircuts could reach up to 11.0% (i.e., 6.0% below
95.0%).

Under its analytical approach, each loan is modeled to go through
both the ABC and SBC process with a certain probability. Each loan
will thus have both of the sales disposition payments and
associated insurance payments (fourr payments in total). All
payments are then probability weighted and run through a modeled
liability structure. For the base case scenario Moody's assumed
that 85% of claims would be SBCs and the rest would be ABCs.
Moody's stressed this assumption and assumed higher ABC percentages
for higher rating levels. At a Aaa rating level, Moody's assumed
that 85% of insurance claims would be submitted as ABCs.

Liquidation process: each mortgage asset is categorized into one of
fourr categories: default, due and payable, foreclosure and REO. In
its analysis, Moody's assumes loans that are in referred status to
be either in foreclosure or REO category. The loans are assumed to
move through each of these stages until being sold out of REO.
Moody's assumed that loans would be in default status for six
months. Due and payable status is expected to last six to 12 months
depending on the default reason. Foreclosure status is based on the
state in which that the related property is located and is further
stressed at higher rating levels. The base case foreclosure
timeline is based on FHA timeline guidance. REO disposition is
assumed to take place in six months with respect to SBCs and 12
months with respect to ABCs.

Debenture interest: the receipt of debenture interest is dependent
upon performance of certain actions within certain timelines by the
servicer. If these timeline and performance benchmarks are not met
by the servicer, debenture interest is subject to curtailment. Its
base case assumption is that 90.0% of debenture interest will be
received by the trust. Moody's stressed the amount of debenture
interest that will be received at higher rating levels. Its
debenture interest assumptions reflect the requirement that RMF
(not rated) reimburse the trust for debenture interest curtailments
due to servicing errors or failures to comply with HUD guidelines.

Additional model features: Moody's incorporated certain additional
considerations into its analysis, including the following:

  -- In most cases, the most recent appraisal value was used as the
property value in its analysis. However, for seasoned appraisals
Moody's applied a 15.0% haircut to account for potential home price
depreciation between the time of the appraisal and the cut-off
date.

  -- Mortgage loans with borrowers that have significant equity in
their homes are likely to be paid off by the borrowers or their
heirs rather than complete the foreclosure process. Moody's
estimated which loans would be bought out of the trust by comparing
each loans' appraisal value (post haircut) to its UPB.

  -- Moody's assumed that foreclosure costs will average $4,500 per
loan, two thirds of which will be reimbursed by the FHA. Moody's
then applied a negative adjustment to this amount based on the TPR
results.

  -- Moody's estimated monthly tax and insurance advances based on
cumulative tax and insurance advances to date.

Moody's ran additional stress scenarios that were designed to mimic
expected cash flows in the case where RMF is no longer the
servicer. Moody's assumes the following in the situation where RMF
is no longer the servicer:

  -- Servicing advances and servicing fees: While RMF subordinates
their recoupment of servicing advances, servicing fees, and MIP
payments, a replacement servicer will not subordinate these
amounts.

  -- RMF indemnifies the trust for lost debenture interest due to
servicing errors or failure to comply with HUD guidelines. In the
event of a bankruptcy, RMF will not have the financial capacity to
do so.

  -- A replacement servicer may require an additional fee and thus
Moody's assumes a 25 bps strip will take effect if the servicer is
replaced.

  -- One third of foreclosure costs will be removed from sales
proceeds to reimburse a replacement servicer (one third of
foreclosure costs are not reimbursable under FHA insurance). This
is typically on the order of $1,500 per loan.

Furthermore, to account for risks posed by Puerto Rican loans,
Moody's considered the following for loans backed by properties
located in Puerto Rico:

  -- To account for delays in the foreclosure process in Puerto
Rico due to the hurricanes, Moody's assumed extended foreclosure
timelines across rating levels and assumed five years as its Aaa
foreclosure timeline.

  -- Moody's assumed that all insurance claims will be submitted as
ABCs. In addition, Moody's assumed that properties will sell for
significantly lower than their appraised values.

Moody's also applied a small adjustment in its analysis to account
for the risks associated with certain damaged properties that are
located in areas impacted by Hurricane Florence or Hurricane
Michael.

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.


SCF EQUIPMENT 2018-1: Moody's Confirms B1 Rating on Cl. F Notes
---------------------------------------------------------------
Moody's Investors Service upgraded five classes of notes and
confirmed one class of note issued by SCF Equipment Leasing 2017-2
LLC and SCF Equipment Leasing 2018-1 LLC/SCF Equipment Leasing
Canada 2018 Limited Partnership Series 2018-1 (2017-2, and 2018-1,
respectively). The transactions are securitizations of equipment
loans and leases and owner-occupied commercial real estate loans
originated by Stonebriar Commercial Finance LLC (Stonebriar) as
well as, in the case of 2018-1, its Canadian counterpart Stonebriar
Commercial Finance Canada Inc., and serviced by Stonebriar. The
equipment loans and leases are backed primarily by collateral that
includes corporate aircraft, railcars, and manufacturing and
assembly equipment.

The complete rating actions are as follows:

Issuer: SCF Equipment Leasing 2017-2 LLC

Class A Equipment Contract Backed Notes, Upgraded to Aa2 (sf);
previously on Apr 10, 2019 Upgraded to Aa3 (sf)

Class B Equipment Contract Backed Notes, Upgraded to A3 (sf);
previously on Apr 10, 2019 Upgraded to Baa1 (sf)

Class C Equipment Contract Backed Notes, Upgraded to Baa3 (sf);
previously on Apr 10, 2019 Upgraded to Ba1 (sf)

Issuer: SCF Equipment Leasing 2018-1 LLC/SCF Equipment Leasing
Canada 2018 Limited Partnership Series 2018-1

Class C Notes, Upgraded to Aa2 (sf); previously on Apr 10, 2019
Upgraded to Aa3 (sf)

Class D Notes, Upgraded to A3 (sf); previously on Apr 10, 2019
Upgraded to Baa1 (sf)

Class F Notes, Confirmed at B1 (sf); previously on Apr 10, 2019 B1
(sf) Placed Under Review for Possible Downgrade

RATINGS RATIONALE

The actions reflect multiple factors:

  - Confirmation of plan of restructuring of an obligor in
bankruptcy to which the 2017-2 and 2018-1 transactions have
exposure

  - Build-up in credit enhancement levels since transaction last
rating action as a result of deleveraging and transaction
performance

  - Credit risks associated with transactions, such as residual
value risk, obligor concentrations, and exposure to balloon loans

The upgrade actions are driven by a recent plan of restructuring
confirmation of an obligor in bankruptcy. Per the plan supplement
filed by the obligor, none of the Stonebriar leases were rejected
(the lease of equipment to the obligor in bankruptcy represents
7.0% and 8.3% of outstanding pool balance including residual for
2017-2 and 2018-1, respectively).

The actions also reflect build-up in credit enhancement levels for
the affected classes of notes in the transactions due to
deleveraging from the sequential pay structures,
overcollateralization and non-declining reserve accounts. The
2017-2 and 2018-1 transactions feature overcollateralization (OC)
targets of 5.5% of original pool balance, which represents 8.2% and
8.0% of the outstanding pool balances, respectively, as of the June
20, 2019 distribution report. Each of the deals also feature
non-declining reserve accounts of 1.5% of original balance, which
in each case is fully funded, at 2.2%. Additionally, the
transactions have exhibited strong performance with no cumulative
net losses to date.

Along with the strong performance, Moody's continued to consider
credit risks associated with the transaction, such as the
substantial residual value risk. The transactions are exposed to
the market value of the equipment if lessees return the equipment
upon maturity of the leases. Residual risk in the transaction is
partially mitigated by the required return conditions under most of
the leases which incentivize the lessees to either renew the lease
or purchase the equipment at the end of the lease term. However,
lease renewals instead of equipment purchases would result in
slower pay down of the notes.

Moody's considered greater volatility in projected asset values,
which were provided at transaction closing. Over time, the age of
the asset valuations may lead to volatility in the determination of
recovery values of the loans and leases backing the transaction. To
take this into consideration, Moody's performed sensitivity
analysis on the projected future asset values received at the
closing of the transaction.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's
Approach to Rating ABS Backed by Equipment Leases and Loans"
published in March 2019.

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

Up

Moody's could upgrade the ratings on the notes if levels of credit
protection are greater than necessary to protect investors against
current expectations of loss. Moody's updated expectations of loss
may be better than its original expectations because of lower
frequency of default by the underlying obligors or lower than
expected depreciation in the value of the equipment and commercial
real estate that secure the obligor's promise of payment. As the
primary drivers of performance, positive changes in the US macro
economy and the strong performance of various sectors where the
obligors operate could also affect the ratings. In addition, faster
than expected reduction in residual value exposure could prompt
upgrade of ratings.

Down

Moody's could downgrade the ratings of the notes if levels of
credit protection are insufficient to protect investors against
current expectations of loss. Moody's updated expectations of loss
may be worse than its original expectations because of higher
frequency of default by the underlying obligors or a greater than
expected deterioration in the value of the equipment and commercial
real estate that secure the obligor's promise of payment. As the
primary drivers of performance, negative changes in the US macro
economy and the weak performance of various sectors where the
obligors operate could also affect Moody's ratings. Other reasons
for worse performance than Moody's expectations could include poor
servicing, error on the part of transaction parties, lack of
transaction governance and fraud.


SUTHERLAND COMMERCIAL 2019-SBC8: DBRS Finalizes B Rating on G Certs
-------------------------------------------------------------------
DBRS, Inc. finalizes provisional ratings on the following classes
of Commercial Mortgage Pass-Through Certificates, Series 2019-SBC8
issued by Sutherland Commercial Mortgage Trust 2019-SBC8:

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

All trends are Stable.

The collateral consists of 1,223 individual loans secured by 1,223
commercial and multifamily properties with an average loan balance
of $248,854. The transaction is configured with a modified pro-rata
pay pass-through structure. Given the complexity of the structure
and granularity of the pool, DBRS applied its "North American CMBS
Multi-borrower Rating Methodology" (CMBS Methodology) and the "RMBS
Insight 1.3: U.S. Residential Mortgage-Backed Securities Model and
Rating Methodology" (RMBS Methodology).

CMBS Methodology

Of the 1,223 individual loans, 275 loans, representing 20.2% of the
pool, have a fixed interest rate with a straight average of 7.9%.
The floating-rate loans are structured with interest-rate floors
ranging from 0.0% to 1.125% with a straight average of 0.08% and
interest-rate margin ranging from 1.25% to 5.875% with a straight
average of 3.23%. To determine the probability of default (POD) and
loss given default inputs in the CMBS Insight Model, DBRS applied a
stress to the various indexes that corresponded with the remaining
fully extended term of the loans and added the respective
contractual loan spread to determine a stressed interest rate over
the loan term. DBRS looked to the greater of the interest-rate
floor or the DBRS stressed index rate when calculating stressed
debt service. The DBRS weighted-average (WA) modeled coupon rate
was 6.331%. The loans have original term lengths of ten- to 30-year
basis and amortize over periods of 15 to 40 years. When the cut-off
loan balances were measured against the DBRS Net Cash Flow and
their respective actual constants or stressed interest rates, there
were 155 loans, representing 12.1% of the pool, with term debt
service coverage ratios (DSCRs) below 1.15 times (x), a threshold
indicative of a higher likelihood of term default.

The pool has an average original term length of 319 months or 26.6
years with an average remaining term of 156 months or 13 years.
Based on the original loan balance and the appraisal at
origination, the pool had an average loan-to-value (LTV) ratio of
63.8%. Based on the current loan amount, which reflects 37.2%
amortization, and the appraisal at origination, the pool has an
average LTV of 39.2%. DBRS applied a pool average LTV of 56.1%,
which reflects a more recently obtained broker's opinion of value
(BOV) for loans located in more urban markets and the lesser of the
updated BOV or the original appraised value for loans located in
all other markets. Furthermore, all but 38 of 1,223 loans fully
amortize over their respective remaining loan terms, resulting in
96.4% expected amortization; this amount of amortization is not
represented in typical commercial mortgage-backed security (CMBS)
conduit pools. DBRS research indicates that, for CMBS conduit
transactions securitized between 2000 and 2018, average
amortization by year has ranged between 7.5% to 22.0% with an
overall median of 12.5%.

As contemplated and explained in DBRS's "Rating North American CMBS
Interest-Only Certificates" methodology, the most significant risk
to an interest-only (IO) cash flow stream is term default risk. As
noted in that methodology, for a pool of approximately 63,000 CMBS
loans that fully cycled through to their maturity dates, DBRS noted
that the average total default rate across all property types was
approximately 17%; the refinance default rate was 6% (approximately
one-third of the total rate); and the term default rate was
approximately 11%. DBRS recognizes the muted impact of refinance
risk on IOs by notching the IO rating up by one notch from the
Reference Obligation rating. When using the ten-year Idealized
Default Table default probability to derive a POD for a CMBS bond
from its rating, DBRS estimates that, in general, a one-third
reduction in the CMBS Reference Obligation POD maps to a tranche
rating that is approximately one notch higher than the Reference
Obligation or the Applicable Reference Obligation, whichever is
appropriate. Therefore, following similar logic regarding term
default risk supported the rationale for DBRS to reduce the POD in
the CMBS Insight Model by one notch because refinance risk is
largely absent for this pool of loans.

RMBS Methodology

The DBRS CMBS Insight Model does not contemplate the ability to
prepay loans, which is generally seen as credit positive since a
prepaid loan cannot default.

The CMBS predictive model was calibrated using loans which have
prepayment lockout features. Those loans' historical prepayment
performance is close to 0 conditional prepayment rate (CPR). If the
CMBS predictive model had an expectation of prepayments, DBRS would
expect the default levels to be reduced. Any loan that prepays is
removed from the pool and can no longer default. This collateral
pool does not have any prepayment lockout features. The historical
prepayments have averaged around 12.5% and have been in a range
from 4.5% to 26.0%. DBRS expects that this pool will continue to
have some prepayments over the remainder of the transaction. DBRS
applied the following to calculate a default rate prepayment
haircut: using Intex Dealmaker, DBRS calculated a lifetime constant
default rate (CDR) rate that approximated the default rate for each
rating category. While applying the same lifetime CDR, DBRS applied
a 2.0% CPR. When holding the CDR constant and applying 2.0% CPR,
the cumulative default amount declined. The percentage change in
the cumulative default prior to and after applying the prepayments
was then applied to the cumulative default assumption to calculate
a fully adjusted cumulative default assumption.

The fully adjusted default assumption and model generated severity
figures from the DBRS CMBS Insight Model were then applied to the
RMBS Cash Flow Model, which is adept at modeling pro-rata
structures on loan pools in excess of 1,000 loans.

Historically, this pool has had a CPR ranging from just above 25.0%
in 2009 to a low of approximately 5.0% in 2018. The initial CPR in
2008 was about 15.0%, but the linear trend has reduced to just
above 10.0% as of the end of 2018. As part of the RMBS Cash Flow
Model, DBRS incorporated three CPR stresses – 5.0%, 10.0% and
15.%.

Additional assumptions in the RMBS Cash Flow Model include a
22-month recovery lag period, 100% servicer advancing and three
default curves (uniform, front and back). The shape and duration of
the default curves were based on the RMBS seasoned loss curves;
however, the timing was adjusted to consider the 22-month recovery
lag period. Lastly, rates were stressed, both upward and downward,
based on their respective loan indices, including the one-year,
three-year, five-year Constant Maturity Treasury and six-month
LIBOR.

The pool is relatively diverse based on loan size with an average
balance of $248,854, a concentration profile equivalent to that of
a pool with 708 equal-sized loans and a top-ten loan concentration
of only 5.1%. Increased pool diversity helps to insulate the
higher-rated classes from event risk. The loans are mostly secured
by traditional property types (i.e., retail, multifamily, office
and industrial) with no exposure to higher-volatility property
types, such as hotels, self-storage or manufactured housing
community. Furthermore, the loans have a DBRS average market rank
of 4.9 with 1.6% in a market ranked 8 and 33.6% in a market ranked
6 or 7, indicative of more urban markets with more liquidity.
Furthermore, only 4.7% of the pool is located in markets with a
DBRS rank of either a 1 or 2, indicative of traditional tertiary or
rural markets. Moreover, the pool has reduced term risk as
supported by the strong WA DBRS DSCR of 2.58x, including the DBRS
stressed interest rates. Furthermore, the pool has a cut-off LTV of
29.9% based on the BOVs dated between October 2018 and June 2019.
Based on the origination appraised value and the cut-off balance,
the pool still have a relatively low WA LTV of 39.3%. All but 38
loans in the pool fully amortize over their respective loan terms
between 180 and 360 months, thus virtually eliminating refinance
risk. Lastly, on average, the loans have a loan term of 26.6 years
with 13.6 years of seasoning. Seasoned loans typically have a lower
default rate because of market value appreciation.

The pool is heavily concentrated with mixed-use (41.0% of the pool)
and multifamily (27.7% of the pool) properties. Based on the DBRS
inspections, the loans classified as mixed-use represented
buildings with street-level commercial space and several floors of
multifamily units above. Based on DBRS research, multifamily
properties securitized in conduit transactions have had lower
default rates than most other property types. Just over
three-quarters of the loans by pool balance are located in strong
suburban or urban markets, which typically have a stronger tenant
demand for multifamily properties.

Of the 50 loans on which DBRS performed exterior inspections, 22
loans, representing 3.8% of the pool (35.3% of the DBRS sample),
were modeled with Average (-) to Below Average property quality
and, on an overall basis, the mean DBRS property quality was
between Average and Average (-). Lower-quality properties are less
likely to retain existing tenants, resulting in less stable
performance. DBRS increased the POD for these loans to account for
the elevated risk. Furthermore, DBRS modeled any uninspected loans
as Average (-), which has a slightly increased POD level.

Limited property-level information was available for DBRS to
review. Asset Summary Reports, Property Condition Reports (PCR),
Phase I/II Environmental reports, appraisals, and historical
financial cash flows were not provided in conjunction with this
securitization. DBRS received a BOV, but not the actual report, for
all loans and the appraised value from origination. To calculate
the LTV for the DBRS model, DBRS relied on the BOV figure for
assets located in urban markets identified with a DBRS Market Rank
of 6, 7, or 8 as more likely to experience value appreciation since
loan origination. For all other loans, DBRS assumed a value based
on the lower of the appraisal or BOV. This hybrid assumption
produced an averaged modeled LTV of 58.3% versus an LTV of 46.6%
based solely on the BOV and the original loan amount. The DBRS LTV
of 58.3% is also significantly greater than the LTV of 29.9% based
on the cut-off loan amount and the BOV figure. While 63.3% of the
loans DBRS inspected were of Average property quality, DBRS applied
an Average - property quality to all non-sampled loans, given the
lack of PCRs, which increases the default stress. No environmental
reports were provided; however, only 6.6% of the pool consists of
secured industrial properties, which would typically have an
increased risk of environmental concerns originating at the
property. DBRS was unable to perform a loan-level cash flow
analysis on loans in the DBRS sample. Based on cash flow analysis
from another small balance commercial loan pool, DBRS applied a
-15.5% reduction to the BOV-estimated NOI for this transaction.
This cash flow reduction is well above the median historical
reduction of -8.0% and provides meaningful stress to the default
levels.

DBRS was provided no borrower information, net worth or liquidity
information and very limited credit history. DBRS modeled loans
with Weak borrower strength, which increases the stress on the
default rate. Furthermore, DBRS was provided a 24-month pay history
on each loan. Any loan with more than two late pays within this
period or two consecutive late pays were modeled with additional
stress to the default rate. This assumption was applied to 92
loans, representing 7.4% of the pool balance. Finally, a borrower
FICO score as of May 1, 2019, was provided on 848 of the 1,223
loans with an average FICO score of 736. While the CMBS Methodology
does not contemplate FICO scores, the RMBS Methodology does and
would characterize a FICO score of 736 as "near-prime," where prime
is considered greater than 750. A borrower with a FICO score of 736
could generally be described as potentially having had previous
credit events (foreclosure, bankruptcy, etc.) but, if they did, it
is likely that these credit events were cleared about two to five
years ago.

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


TOWD POINT 2017-6: Fitch Rates $85.92MM Class B3 Notes 'Bsf'
------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Towd Point Mortgage Trust 2017-6 (TPMT 2017-6):

  -- $1,161,754,000 class A1 notes 'AAAsf'; Outlook Stable;

  -- $117,912,000 class A2 notes 'AAAsf'; Outlook Stable;

  -- $1,279,666,000 class A3 exchangeable notes 'AAAsf'; Outlook
Stable;

  -- $91,405,000 class M1 notes 'Asf'; Outlook Stable;

  -- $1,371,071,000 class A4 exchangeable notes 'Asf'; Outlook
Stable;

  -- $100,545,000 class M2 notes 'Asf'; Outlook Stable;

  -- $73,124,000 class B1 notes 'BBBsf'; Outlook Stable;

  -- $27,421,000 class B2 notes 'BBsf'; Outlook Stable;

  -- $85,921,000 class B3 notes 'Bsf'; Outlook Stable.

Fitch will not be rating the following classes:

  -- $85,920,000 class B4 notes;

  -- $84,093,066 class B5 notes.

The bond balances represent the balances as of transaction closing
on Nov. 30, 2017. However, Fitch analyzed the transaction based on
the current bond balances and collateral attributes as of the May
2019 remittance date. This data is reflected throughout this
commentary.

The notes are supported by one collateral group that consists of
8,672 seasoned performing, re-performing and non-performing
mortgages with a total balance of approximately $1.58 billion,
which includes $194.99 million, or 12.4%, of the aggregate pool
balance in non-interest-bearing deferred principal amounts.

KEY RATING DRIVERS

Distressed Performance History (Negative): The collateral pool
consists primarily of peak-vintage, seasoned performing and RPLs,
including loans that have been paying for the past 24 months, which
Fitch identifies as "clean current" (73.2%). Additionally, 8.0% of
the pool was delinquent as of the statistical calculation date, and
the remaining 18.8% of loans are current but have recent
delinquencies or incomplete pay strings, identified as "dirty
current." Of the loans, 85.3% have received modifications.

Low Operational Risk (Positive): The operational risk is well
controlled for in this transaction. FirstKey Mortgage, LLC has a
well-established track record in RPL activities and carries an
'average' aggregator assessment from Fitch. The loans are
approximately 151 months seasoned, reducing the risk of
misrepresentation at origination. Additionally, the transaction
benefits from third-party due diligence on approximately 95.8% of
the pool by UPB, and the diligence results generally indicate low
risk for an RPL transaction. In addition, the issuer's retention of
at least 5% of the bonds contributes to the overall low operational
risk of the transaction.

Inclusion of Second Liens (Negative): While the collateral pool
consists primarily of first-lien, seasoned RPLs, FirstKey has also
included approximately 3.0% (by unpaid principal balance [UPB]) of
closed-end second-lien loans. The expected losses were adjusted to
account for the increased risk associated with this collateral
type.

Inclusion of Investor Cash Flow Loans (Negative): Approximately
2.3% (by UPB) of the loans in the pool are investor cash flow
loans, which are backed by multiple properties. Fitch applied a
haircut to the property value of these loans to account for a
possible distressed sale or bulk sale of the underlying
properties.

Low Aggregate Servicing Fee (Mixed): Fitch determined that the
stated aggregate servicing fee of 30 bps may be insufficient to
attract subsequent servicers under a period of poor performance and
high delinquencies. To account for the potentially higher fee
needed to obtain a subsequent servicer, Fitch's cash flow analysis
assumed a 35-bp servicing fee.

Third-Party Due Diligence (Negative): A third-party due diligence
review was conducted and focused on regulatory compliance, pay
history and a tax and title lien search. Of the loans reviewed, the
third-party review (TPR) firm's due diligence review resulted in
approximately 8.8% (by loan count) 'C' and 'D' graded loans,
meaning the loans had material violations or lacked documentation
to confirm regulatory compliance.

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement (RW&E) mechanism construct
for this transaction to generally be consistent with what it views
as a Tier 2 framework, due to the inclusion of knowledge qualifiers
and the exclusion of loans from certain reps as a result of
third-party due diligence findings. To account for the Tier 2 R&W
framework, Fitch increased its 'AAAsf' loss expectations by 190 bps
to account for a potential increase in defaults and losses arising
from weaknesses in the reps.

Limited Life of Rep Provider (Negative): FirstKey, as rep provider,
was only obligated to repurchase a loan due to breaches prior to
the payment date in December 2018. Thereafter, a reserve fund will
be available to cover amounts due to noteholders for loans
identified as having rep breaches. Amounts on deposit in the
reserve fund, as well as the increased level of subordination, will
be available to cover additional defaults and losses resulting from
rep weaknesses or breaches occurring on or after the payment date
in December 2018.

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

Sequential-Pay Structure (Positive): The transaction's cash flow is
based on a sequential-pay structure whereby the subordinate classes
do not receive principal until the senior classes are repaid in
full. Losses are allocated in reverse-sequential order.
Furthermore, the provision to re-allocate principal to pay interest
on the 'AAAsf' rated notes prior to other principal distributions
is highly supportive of timely interest payments to those classes
in the absence of servicer advancing.

Deferred Amounts (Negative): Non-interest-bearing principal
forbearance amounts totaling $194.99 million (12.4%) of the UPB are
outstanding on 2,878 loans. Fitch included the deferred amounts
when calculating the borrower's loan-to-value ratio (LTV) and
sustainable LTV (sLTV), despite the lower payment and amounts not
owed during the term of the loan. The inclusion resulted in a
higher probability of default (PD) and LS than if there were no
deferrals. Fitch believes that borrower default behavior for these
loans will resemble that of the higher LTVs, as exit strategies
(that is, sale or refinancing) will be limited relative to those
borrowers with more equity in the property.


TOWD POINT 2018-1: Fitch Rates $24.45MM Class B2 Notes 'Bsf'
------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Towd Point Mortgage Trust 2018-1 (TPMT 2018-1):

  -- $437,349,000 class A1 notes 'AAAsf'; Outlook Stable;

  -- $44,713,000 class A2 notes 'AAsf'; Outlook Stable;

  -- $482,062,000 class A3 exchangeable notes 'AAsf'; Outlook
Stable;

  -- $34,932,000 class M1 notes 'Asf'; Outlook Stable;

  -- $516,994,000 class A4 exchangeable notes 'Asf'; Outlook
Stable;

  -- $34,932,000 class M2 notes 'BBBsf'; Outlook Stable;

  -- $20,959,000 class B1 notes 'BBsf'; Outlook Stable;

  -- $24,452,000 class B2 notes 'Bsf'; Outlook Stable.

Fitch will not be rating the following classes:

  -- $24,453,000 class B3 notes;

  -- $34,932,000 class B4 notes;

  -- $41,918,620 class B5 notes.

The bond balances represent the balances as of transaction closing
on Feb. 28, 2018. However, Fitch's analysis incorporated updated
loan-level data (based on May 2019 remittance data) provided by the
issuer. This updated data included, amongst other data points,
updated balances, credit scores, and pay histories. Fitch did not
receive updated property values but utilized the property values
provided prior to the deal closing in 2018 and did not apply any
indexation credit.

The notes are supported by one collateral group that consists of
4,040 seasoned performing, re-performing, and non-performing
mortgages with a total balance of approximately $604.4 million,
which includes $33.3 million, or 5.5%, of the aggregate pool
balance in non-interest-bearing deferred principal amounts.

KEY RATING DRIVERS

Distressed Performance History (Negative): The collateral pool
consists primarily of peak-vintage, seasoned performing and RPLs,
including loans that have been paying for the past 24 months, which
Fitch identifies as "clean current" (48.4%). Additionally, 14.6% of
the pool was delinquent as of the May 2019 remittance date, and the
remaining 37.0% of loans are current but have recent delinquencies
or incomplete pay strings, identified as "dirty current." Of the
loans, 84.5% have received modifications.

Low Operational Risk (Positive): The operational risk is well
controlled for in this transaction. FirstKey Mortgage, LLC
(FirstKey) has a well-established track record in RPL activities
and carries an 'average' aggregator assessment from Fitch. The
loans are approximately 153 months seasoned, reducing the risk of
misrepresentation at origination. Additionally, the transaction
benefits from third-party due diligence on approximately 97.1% of
the pool by UPB, and the diligence results generally indicate low
risk for an RPL transaction. In addition, the issuer's retention of
at least 5% of the bonds contributes to the overall low operational
risk of the transaction.

Inclusion of Second Liens (Negative): While the collateral pool
consists primarily of first-lien, seasoned RPLs, FirstKey has also
included approximately 0.3% (by UPB) of closed-end second-lien
loans. The expected losses were adjusted to account for the
increased risk associated with this collateral type.

Low Aggregate Servicing Fee (Mixed): Fitch determined that the
stated aggregate servicing fee of 30 bps may be insufficient to
attract subsequent servicers under a period of poor performance and
high delinquencies. To account for the potentially higher fee
needed to obtain a subsequent servicer, Fitch's cash flow analysis
assumed a 35-bp servicing fee.

Third-Party Due Diligence (Negative): A third-party due diligence
review was conducted and focused on regulatory compliance, pay
history and a tax and title lien search. Of the loans reviewed, the
third-party review (TPR) firm's due diligence review resulted in
approximately 14.2% (by loan count) 'C' and 'D' graded loans,
meaning the loans had material violations or lacked documentation
to confirm regulatory compliance.

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement (RW&E) mechanism construct
for this transaction to be generally consistent with what it views
as a Tier 2 framework, due to the inclusion of knowledge qualifiers
and the exclusion of loans from certain reps as a result of
third-party due diligence findings. To account for the Tier 2
framework, Fitch increased its 'AAAsf' loss expectations by 211 bps
to account for a potential increase in defaults and losses arising
from weaknesses in the reps.

Limited Life of Rep Provider (Negative): FirstKey, as rep provider,
was only obligated to repurchase a loan due to breaches prior to
the payment date in March 2019. Thereafter, a reserve fund will be
available to cover amounts due to noteholders for loans identified
as having rep breaches. Amounts on deposit in the reserve fund, as
well as the increased level of subordination, will be available to
cover additional defaults and losses resulting from rep weaknesses
or breaches occurring on or after the payment date in March 2019.

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

Sequential-Pay Structure (Positive): The transaction's cash flow is
based on a sequential-pay structure whereby the subordinate classes
do not receive principal until the senior classes are repaid in
full. Losses are allocated in reverse-sequential order.
Furthermore, the provision to re-allocate principal to pay interest
on the 'AAAsf' and 'AAsf' rated notes prior to other principal
distributions is highly supportive of timely interest payments to
those classes in the absence of servicer advancing.

Deferred Amounts (Negative): Non-interest-bearing principal
forbearance amounts totaling $33.3 million (5.5%) of the UPB are
outstanding on 1,202 loans. Fitch included the deferred amounts
when calculating the borrower's loan-to-value ratio (LTV) and
sustainable LTV (sLTV), despite the lower payment and amounts not
being owed during the term of the loan. The inclusion resulted in a
higher probability of default (PD) and LS than if there were no
deferrals. Fitch believes that borrower default behavior for these
loans will resemble that of the higher LTVs, as exit strategies
(that is, sale or refinancing) will be limited relative to those
borrowers with more equity in the property.

RATING SENSITIVITIES

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

Fitch conducted sensitivity analysis determining 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 37.6% at 'AAAsf'. The analysis indicates there is
some potential rating migration with higher MVDs, compared with the
model projection.

Fitch also conducted sensitivity analysis to determine the stresses
to MVDs that would reduce a rating by one full category, to
non-investment grade, and to 'CCCsf'.


TOWD POINT 2019-HE1: Fitch Rates $5.36MM Class B2 Notes 'Bsf'
-------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Towd Point HE Trust 2019-HE1 (TPHT 2019-HE1):

  -- $182,731,000 class A1 notes 'AAAsf'; Outlook Stable;

  -- $27,906,000 class A2 notes 'AAsf'; Outlook Stable;

  -- $210,637,000 class A3 exchangeable notes 'AAsf'; Outlook
Stable;

  -- $27,637,000 class M1 notes 'Asf'; Outlook Stable;

  -- $238,274,000 class A4 exchangeable notes 'Asf'; Outlook
Stable;

  -- $9,392,000 class M2 notes 'BBBsf'; Outlook Stable;

  -- $8,586,000 class B1 notes 'BBsf'; Outlook Stable;

  -- $5,367,000 class B2 notes 'Bsf'; Outlook Stable.

Fitch will not rate the following classes:

  -- $2,147,000 class B3 notes;

  -- $1,878,000 class B4 notes;

  -- $2,683,633 class B5 notes;

  -- $12,000,000 class XA notes;

  -- $268,327,633 class XS1 notional certificates;

  -- $268,327,633 class XS2 notional certificates;

  -- $0 class D certificates.

This is the first post-crisis US RMBS transaction backed entirely
by HELOC collateral. The credit quality of the pool is unusually
strong and does not resemble pre-crisis HELOC pools. The majority
of the HELOCs are first-lien mortgages, the loans are seasoned and
performing over five years on average, the weighted-average credit
score is 755 and the mark-to-market loan-to-value is 61.3%
(sustainable loan-to-value of 65.5%). Additionally, the loan
balances are relatively large ($327,406 for first liens and $99,592
for second liens).

The collateral pool consists of 1,732 seasoned performing HELOCs
totaling $277.74 million of outstanding draws. As of the
statistical calculation date, approximately $126.48 million of the
collateral consists of second liens while the remaining $151.26
million comprises first liens. The maximum draw amount as of the
statistical calculation date is expected to be $351.09 million.

The most notable structural feature is the Variable Funding Account
that is used to fund future draws on the lines of credit.

KEY RATING DRIVERS

HELOC Collateral (Negative): This will be the first post-crisis
transaction issued where the collateral entirely comprises HELOCs.
Approximately 54% of the loans are first lien HELOCs with the
remaining 46% comprising second liens. All of the loans are
adjustable-rate mortgages (ARMs) that are still in an interest-only
(IO) period. Additionally, all of the loans in the pool are still
able to draw down additional amounts on their line of credit as
long as the balance remains below the credit limit. The first lien
portion is currently utilizing 70.6% of the total line and the
second lien portion is using 92.4%. Based on the ability of the
borrowers to draw down additional amounts and proposed structural
features that do not completely protect against larger unpaid
balances, the full draw amount was included in Fitch's loss
analysis.

Seasoned Performing Prime Credit Quality (Positive): The pool in
aggregate is seasoned more than five years, with the first lien
portion seasoned roughly eight years and the second lien portion
seasoned roughly two years. Nearly 94% of the first lien loans have
been performing for at least the past two years with 98% of the
second liens having paid on time for either two years or since
origination. Additionally, the pool exhibits a very strong credit
profile as shown by the 755-weighted average (WA) FICO as well as
the 65.5% sustainable loan-to-value ratio (sLTV) (68.9% sLTV
assuming full draw).

Variable Funding Account (VFA) (Positive): As of the statistical
calculation date, approximately 80% of the total available credit
limit amount was drawn on the HELOCs. Borrower draws following deal
closing will be funded first from the servicer and reimbursed from
principal collections received on the mortgage loans. To the extent
principal collected is insufficient, draws will be funded by the
servicer and reimbursed by the holder of the class D certificates
through deposits made into the VFA held by the Indenture Trustee.
Any draws funded by the class D certificate holder will result in a
corresponding increase in the class D certificate balance. Class D
receives a pro rata share of principal and losses concurrently with
the notes; however, if performance triggers fail, the deal reverts
to a straight sequential pay structure with the class D
certificates locked out from principal collected until the classes
A, M and B notes are paid in full and will absorb all losses up to
the outstanding balance, effectively increasing the available loss
protection to the A, M and B notes.

First Lien Amortization Profile (Negative): The first lien loans
have a unique amortization profile following the expiration of the
IO period. Starting in month 121, the amount of principal due is
equal to the difference between the amount currently drawn and the
new maximum current draw amount. The maximum draw amount for any
given period declines linearly over the remaining 240 months. To
the extent the borrower's current draw is less than the new maximum
amount, no principal payment is due. In Fitch's analysis, the
repayment terms for this product could result in a higher payment
shock compared to a traditional 20-year amortization term. To
account for this, Fitch increased its default assumption on these
loans by 15%.

Updated Property Valuation (Neutral): Fitch incorporated different
valuation products in its analysis based on the lien position and
seasoning of the loans. Updated valuations on the first lien
population consisted of 397 broker price opinions (BPOs) and 65
values based on automatic valuation models (AVMs), which were used
in accordance with Fitch's "US RMBS Seasoned and Re-Performing Loan
Rating Criteria" report. Of the second lien loans, 842 were applied
a Home Price Index (HPI) value of up to two years (due to the
limited seasoning no updated valuation was expected), while the
remaining 428 used Clear Capital's Home Data Index (HDI) value
haircut by 10%. Fitch applied indexation on a portion of the second
liens due to the high percentage of 'A' grades in respect of the
property valuation review as well as the 100% loss severity (LS)
applied to the second lien portion.

Moderate Operational Risk (Neutral): Operational risk is considered
to be low for this transaction. The loan pool consisted of seasoned
HELOC loans; approximately 67.9% of loans by UPB (100% of the first
liens, 29.6% of the second liens), (40.6% of the pool by loan count
- 100% of first liens, 19.1% of second liens) were reviewed for
compliance. In addition to the compliance review, the same second
lien sample was reviewed for credit and property valuation by a TPR
firm consistent with Fitch criteria. Approximately 19.3% of the
second liens by UPB (19.2% by loan count) received a pay history
review. Of the 704 loans reviewed by a TPR, all but 32, or 95%,
reviewed were graded 'A' or 'B'. The due diligence was performed by
AMC Diligence, LLC (AMC), a Tier 1 third-party review (TPR) firm,
and the results are in line with seasoned loan transactions.
FirstKey Mortgage, LLC (FirstKey) has a well-established track
record as an aggregator of seasoned performing and RPL mortgages
and has an 'Average' aggregator assessment from Fitch. All of the
loans were originated by two originators, and the sponsor's (or
it's affiliate's) retention of at least 5% of the bonds should help
mitigate the operation risk of the transaction.

Modified Sequential Structure (Positive): The transaction utilizes
a modified sequential pay structure in which principal collections
are paid pro-rata to classes A1, A2 and M1 subject to transaction
performance triggers with all classes below class M1 paying down
sequentially. The class D certificates will receive their pro rata
share of principal collections concurrently with classes A1, A2,
and M1 so long as performance triggers are passing. Additionally,
excess cash flow, following the retirement of the class XA notes,
can be used to pay down the notes in the same order of priority of
principal subject to the same triggers. To the extent any of the
triggers are failing, all allocations of principal and excess cash
flow are paid sequentially. In all instances, interest is paid
sequentially with losses distributed reverse sequentially.

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement (RW&E) mechanism construct
for this transaction generally consistent with what it views as a
Tier 2 framework, due to the inclusion of knowledge qualifiers and
the exclusion of certain reps that Fitch typically expects for
seasoned transactions. After a threshold event (which occurs when
realized loss exceeds the class principal balance of the class B3,
B4 and B5 notes), loan reviews for identifying breaches will be
conducted on loans that experience a realized loss of $10,000 or
more. To account for the Tier 2 framework, Fitch increased its
'AAAsf' loss expectations by roughly 125bps to account for a
potential increase in defaults and losses arising from weaknesses
in the reps.

Limited Life of Rep Provider (Negative): FirstKey, as rep provider,
will only be obligated to repurchase a loan due to breaches prior
to the payment date in July 2020. Thereafter, a reserve fund will
be available to cover amounts due to noteholders for loans
identified as having rep breaches. Amounts on deposit in the
reserve fund, as well as the increased level of subordination, will
be available to cover additional defaults and losses resulting from
rep weaknesses or breaches occurring on or after the payment date
in July 2020.


WACHOVIA BANK 2005-C20: Moody's Hikes Class G Certs Rating to Caa2
------------------------------------------------------------------
Moody's Investors Service upgraded the rating on one class in
Wachovia Bank Commercial Mortgage Trust 2005-C20, Commercial
Mortgage Pass-Through Certificates, Series 2005-C20, as follows:

Cl. G, Upgraded to Caa2 (sf); previously on May 3, 2018 Affirmed Ca
(sf)

RATINGS RATIONALE

The rating on Cl. G was upgraded based on loan paydowns and lower
anticipated losses from specially serviced loans. The balance of
Class G has decreased 87% from its original balance, including 9%
realized losses from previously liquidated loans.

Moody's does not anticipate losses from the remaining collateral in
the current environment. However, over the remaining life of the
transaction, losses may emerge from macro stresses to the
environment and changes in collateral performance. Its ratings
reflect the potential for future losses under varying levels of
stress. Moody's base expected loss plus realized losses is now 4.7%
of the original pooled balance, compared to 5.1% at the last
review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in this rating was "Moody's Approach
to Rating Large Loan and Single Asset/Single Borrower CMBS"
published in July 2017.

DEAL PERFORMANCE

As of the June 15, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 99.9% to $3.7
million from $3.66 billion at securitization. The certificates are
collateralized by three mortgage loans. One loan, constituting
15.9% of the pool, has defeased and is secured by US government
securities.

Eighteen loans have been liquidated from the pool with a loss,
resulting in or contributing to an aggregate realized loss of $172
million (for an average loss severity of 74%). One loan,
constituting 80% of the pool, is currently in special servicing.
The specially serviced loan is the NGP Rubicon GSA Pool Loan ($2.9
million), which represents a pari pasu portion in a $5.9 million
loan. The mortgage loan is currently secured by a portfolio
consisting of two remaining properties located in Alabama and
Colorado. The portfolio was originally secured by fourteen
properties with US government leases. The portfolio most recently
transferred to special servicing on April 23, 2015 for imminent
monetary default and twelve of the fourteen properties were
subsequently sold. The loan is cash managed. As of April 2019 the
properties were both fully occupied and the special servicer
indicated that both properties are being prepared for disposition.

The sole non-defeased performing loan is the Village Shops Loan
($154,047 -- 4.2% of the pool), which is secured by a retail strip
center located in Salem, Massachusetts. This is a fully amortizing
loan and has paid down approximately 90% since securitization. The
property is 100% leased as of December 2018. Moody's LTV is less
than 20%.



WAMU COMMERCIAL 2007-SL2: Moody's Hikes Class E Certs Rating to B3
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings on three classes and
upgraded the ratings on three classes in Wamu Commercial Mortgage
Securities Trust 2007-SL2, Commercial Mortgage Pass-Through
Certificates, Series 2007-SL2

Cl. C, Upgraded to A1 (sf); previously on Jun 22, 2018 Upgraded to
A3 (sf)

Cl. D, Upgraded to Ba1 (sf); previously on Jun 22, 2018 Upgraded to
Ba3 (sf)

Cl. E, Upgraded to B3 (sf); previously on Jun 22, 2018 Affirmed
Caa1 (sf)

Cl. F, Affirmed Caa3 (sf); previously on Jun 22, 2018 Affirmed Caa3
(sf)

Cl. G, Affirmed C (sf); previously on Jun 22, 2018 Affirmed C (sf)

Cl. X*, Affirmed Ca (sf); previously on Jun 22, 2018 Downgraded to
Ca (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on three P&I classes were upgraded based primarily on
an increase in credit support resulting from loan paydowns and
amortization. The deal has paid down 28% since Moody's last
review.

The ratings on two P&I classes were affirmed due to anticipated
losses from specially serviced and troubled loans.

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

Moody's rating action reflects a base expected loss of 8.6% of the
current pooled balance, compared to 9.5% at Moody's last review.
Moody's base expected loss plus realized losses is now 4.3% of the
original pooled balance, compared to 4.6% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the May 24, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 93% to $55.6 million
from $842.1 million at securitization. The certificates are
collateralized by 92 mortgage loans ranging in size from less than
1% to 6.1% of the pool, with the top ten loans (excluding
defeasance) constituting 31.8% of the pool.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 52, compared to 74 at Moody's last review.

Twenty-four loans, constituting 31.9% of the pool, are on the
master servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Seventy loans have been liquidated from the pool, resulting in an
aggregate realized loss of $31.8 million (for an average loss
severity of 44%). One loan, constituting 1.0% of the pool, is
currently in special servicing. The specially serviced loan is
secured by a ten unit multifamily property located South Gate, CA.
Moody's has also assumed a high default probability for ten poorly
performing loans, constituting 16.3% of the pool, and has estimated
an aggregate loss of $3.9 million (a 41% expected loss) from the
specially serviced and troubled loans.

Moody's received full year 2017 operating results for 89% of the
pool, and full or partial year 2018 operating results for 42% of
the pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 77%, compared to 78% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 13.7% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 9.3%.

Moody's actual and stressed conduit DSCRs are 1.69X and 1.49X,
respectively, compared to 1.84X and 1.46X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.



WFRBS COMMERCIAL 2019-C9: Moody's Affirms B2 Rating Class F Certs
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings on ten classes in
WFRBS Commercial Mortgage Trust 2012-C9, Commercial Pass-Through
Certificates, Series 2012-C9 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Jun 22, 2018 Affirmed Aaa
(sf)

Cl. A-S, Affirmed Aaa (sf); previously on Jun 22, 2018 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Jun 22, 2018 Affirmed
Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Jun 22, 2018 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on Jun 22, 2018 Affirmed A3
(sf)

Cl. D, Affirmed Baa3 (sf); previously on Jun 22, 2018 Affirmed Baa3
(sf)

Cl. E, Affirmed Ba2 (sf); previously on Jun 22, 2018 Affirmed Ba2
(sf)

Cl. F, Affirmed B2 (sf); previously on Jun 22, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Jun 22, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed A2 (sf); previously on Jun 22, 2018 Affirmed A2
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

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

The ratings on the IO classes were affirmed based on the credit
quality of their referenced classes.

Moody's rating action reflects a base expected loss of 3.1% of the
current pooled balance, compared to 2.9% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.3% of the
original pooled balance, compared to 2.4% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the June 17, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 27% to $768.6
million from $1.05 billion at securitization. The certificates are
collateralized by 64 mortgage loans ranging in size from less than
1% to 13% of the pool, with the top ten loans (excluding
defeasance) constituting 39% of the pool. Thirteen loans,
constituting 26.9% of the pool, have defeased and are secured by US
government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 18, compared to 21 at Moody's last review.

Seven loans, constituting 7.2% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

One loan has been liquidated from the pool, resulting in a minimal
loss of $378,996. There are no loans currently in special
servicing.

Moody's has assumed a high default probability for one poorly
performing loan, constituting less than 1% of the pool that is
secured by an office building in Ann Arbor, MI. Property
performance has declined due to a decline in occupancy.

Moody's received full year 2018 operating results for 98% of the
pool, and partial year 2019 operating results for 42% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 94%, compared to 92% at Moody's last review.
Moody's conduit component excludes loans with structured credit
assessments, defeased and CTL loans, and specially serviced and
troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 18% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.9%.

Moody's actual and stressed conduit DSCRs are 1.50X and 1.21X,
respectively, compared to 1.58X and 1.23X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 21.7% of the pool balance.
The largest loan is the Chesterfield Towne Center Loan ($99.7
million -- 13.0% of the pool), which is secured by a nearly one
million square foot (SF) regional mall plus an adjacent 72,000 SF
retail property located in North Chesterfield, Virginia,
approximately 10 miles west of the Richmond CBD. The mall's anchors
are Macy's, At Home, Sears and JC Penney. Sears and JC Penney
occupy their spaces on ground leases, while the Macy's and At Home
boxes are owned by the Borrower. As of March 2019, the property was
94% leased, compared to 95% in March 2018. Inline occupancy for the
same period was 88%, compared to 87% in March 2018. The loan has
amortized over 9% since securitization and Moody's LTV and stressed
DSCR are 110% and 1.01X, respectively, compared to 112% and 0.99X
at the last review.

The second largest loan is the Greenway Center Loan ($40.6 million
-- 5.3% of the pool), which is secured by an approximately 264,600
SF grocery-anchored retail center located in Greenbelt, Maryland,
approximately 10 miles northeast of the Washington D.C. CBD. The
property was 98% occupied as of March 2019 and has averaged 94%
occupancy since 2003. The property has sustained steady NOI growth
from securitization due to increased revenues. The loan has
amortized nearly 12% and Moody's LTV and stressed DSCR are 79% and
1.23X, respectively, compared to 81% and 1.20X at the last review.

The third largest loan is the 888 Bestgate Road Loan ($26.7 million
-- 3.5% of the pool), which is secured by an approximately 118,000
SF office building located in Annapolis, Maryland. The property was
69% leased as of March 2019, compared to 83% at year-end 2017.
Several tenants have vacated at their respective lease maturities.
Furthermore, there is significant upcoming tenant rollover over the
next three years with approximately 25% of the NRA expiring by the
end of 2020; 42% by 2021; and 57% by 2022. The loan has amortized
by 11% and Moody's LTV and stressed DSCR are 123% and 0.86X,
respectively, compared to 92% and 1.12X at the last review.


[*] DBRS Reviews 742 Classes From 39 US RMBS Transactions
---------------------------------------------------------
DBRS, Inc. reviewed 742 classes from 39 U.S. residential
mortgage-backed security (RMBS) transactions. Of the 742 classes
reviewed, DBRS upgraded 15 ratings, confirmed 723 ratings and
discontinued four ratings.

The rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new rating levels. The rating confirmations reflect asset
performance and credit support levels that are consistent with the
current ratings. The discontinued ratings are the result of full
repayment of principal to bondholders.

The rating actions are the result of DBRS's application of its
"RMBS Insight 1.3: U.S. Residential Mortgage-Backed Securities
Model and Rating Methodology" published on June 14, 2019.

The pools backing these U.S. RMBS transactions consist of Prime and
Re-REMIC collateral.

The ratings assigned to the securities listed below differ from the
ratings implied by the quantitative model. DBRS considers this
difference to be a material deviation but, in this case, the
ratings of the subject notes reflect small loan count, certain
structural features that are not fully reflected in the
quantitative model output or additional seasoning required to
substantiate further upgrades.

-- Citigroup Mortgage Loan Trust 2014-A, Mortgage Backed-Notes,
Series 2014-A, Class B-2

-- Citigroup Mortgage Loan Trust 2014-A, Mortgage Backed-Notes,
Series 2014-A, Class B-3

-- Citigroup Mortgage Loan Trust 2014-A, Mortgage Backed-Notes,
Series 2014-A, Class B-4

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B-3

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B-3A

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B-3B

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B-3C

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B3-IOA

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B3-IOB

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B3-IOC

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

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

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

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B4-IOA

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B4-IOB

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

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

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

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B5-IOA

-- New Residential Mortgage Loan Trust 2017-5, Mortgage-Backed
Notes, Series 2017-5, Class B5-IOB

-- New Residential Mortgage Loan Trust 2017-6, Mortgage-Backed
Notes, Series 2017-6, Class B-2

-- New Residential Mortgage Loan Trust 2017-6, Mortgage-Backed
Notes, Series 2017-6, Class B-2A

-- New Residential Mortgage Loan Trust 2017-6, Mortgage-Backed
Notes, Series 2017-6, Class B-2B

-- New Residential Mortgage Loan Trust 2017-6, Mortgage-Backed
Notes, Series 2017-6, Class B-2C

-- New Residential Mortgage Loan Trust 2017-6, Mortgage-Backed
Notes, Series 2017-6, Class B2-IO

-- New Residential Mortgage Loan Trust 2017-6, Mortgage-Backed
Notes, Series 2017-6, Class B2-IOA

-- New Residential Mortgage Loan Trust 2017-6, Mortgage-Backed
Notes, Series 2017-6, Class B2-IOB

-- New Residential Mortgage Loan Trust 2017-6, Mortgage-Backed
Notes, Series 2017-6, Class B2-IOC

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-2

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-2A

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-2B

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-2C

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-2D

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B2-IO

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B2-IOA

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B2-IOB

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B2-IOC

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-3

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-3A

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-3B

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-3C

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-3D

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B3-IO

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B3-IOA

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B3-IOB

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B3-IOC

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-4

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-4A

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-4B

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-4C

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B4-IOA

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B4-IOB

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B4-IOC

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-5

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-5A

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-5B

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-5C

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-5D

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B5-IOA

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B5-IOB

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B5-IOC

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B5-IOD

-- New Residential Mortgage Loan Trust 2018-3, Mortgage-Backed
Notes, Series 2018-3, Class B-7

-- CSMC Trust 2013-7, Mortgage Pass-Through Certificates, Series
2013-7, Class B-4

-- CSMC Trust 2013-7, Mortgage Pass-through Certificates, Series
2013-7, Class A-IO-S

-- CSMC 2017-HL2 Trust, Mortgage Pass-Through Certificates, Series
2017-HL2, Class B-2

-- CSMLT 2015-3 Trust, Mortgage Pass-Through Certificates, Series
2015-3, Class IO-S-1

-- CSMLT 2015-3 Trust, Mortgage Pass-Through Certificates, Series
2015-3, Class IO-S-2

-- CSMLT 2015-3 Trust, Mortgage Pass-Through Certificates, Series
2015-3, Class IO-S-3

-- CSMLT 2015-3 Trust, Mortgage Pass-Through Certificates, Series
2015-3, Class A-IO-S

-- J.P. Morgan Mortgage Trust 2013-3 Mortgage Pass-Through
Certificates, Series 2013-3, Class B-4

-- J.P. Morgan Mortgage Trust 2014-IVR3, Mortgage Pass-Through
Certificates, Series 2014-IVR3, Class B-3

-- J.P. Morgan Mortgage Trust 2014-IVR3, Mortgage Pass-Through
Certificates, Series 2014-IVR3, Class B-4

-- J.P. Morgan Mortgage Trust 2005-A4, Mortgage Pass-Through
Certificates, Series 2005-A4, Class 2-A-1

-- J.P. Morgan Mortgage Trust 2005-A4, Mortgage Pass-Through
Certificates, Series 2005-A4, Class 3-A-1

-- J.P. Morgan Mortgage Trust 2005-A4, Mortgage Pass-Through
Certificates, Series 2005-A4, Class 3-A-4

-- J.P. Morgan Mortgage Trust 2005-A4, Mortgage Pass-Through
Certificates, Series 2005-A4, Class 4-A-2

-- J.P. Morgan Mortgage Trust 2005-A4, Mortgage Pass-Through
Certificates, Series 2005-A4, Class B-1

-- CSMC Trust 2015-WIN1, Mortgage Pass-through Certificates,
Series 2015-WIN1, Class A-IO-S

-- Banc of America Funding 2016-R1 Trust, Resecuritization Trust
Securities, Class M2

-- Banc of America Funding 2016-R1 Trust, Resecuritization Trust
Securities, Class A5

The Affected Rating is Available at https://bit.ly/2Ljwm8i


                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

TCR subscribers have free access to our on-line news archive.
Point your Web browser to http://TCRresources.bankrupt.com/and use
the e-mail address to which your TCR is delivered to login.

                            *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.
Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Valerie Udtuhan, Howard C. Tolentino, Carmel Paderog,
Meriam Fernandez, Joel Anthony G. Lopez, Cecil R. Villacampa,
Sheryl Joy P. Olano, Psyche A. Castillon, Ivy B. Magdadaro, Carlo
Fernandez, Christopher G. Patalinghug, and Peter A. Chapman,
Editors.

Copyright 2019.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

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                   *** End of Transmission ***