/raid1/www/Hosts/bankrupt/TCR_Public/190728.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 28, 2019, Vol. 23, No. 208

                            Headlines

AJAX MORTGAGE 2019-D: DBRS Assigns Prov. B Rating on B-2 Notes
AMERICREDIT AUTOMOBILE 2018-3: DBRS Confirms BB on Class E Debt
BHMS 2018-ATLS: DBRS Confirms BB(low) Rating on Class HRR Certs
CARLYLE GLOBAL 2015-1: Moody's Rates $7.275MM Cl. F-R Notes 'B3'
CD 2007-CD4: Moody's Hikes Rating on Class A-J Certs to Caa2

CHC COMMERCIAL 2019-CHC: DBRS Finalizes B(high) Rating on HRR Certs
COMM MORTGAGE 2013-GAM: Fitch Affirms BB-sf Rating on Class F Debt
CONN RECEIVABLES 2018-A: Fitch Hikes Rating on Class C Notes to Bsf
CSFB MORTGAGE 2003-C3: Moody's Affirms C Rating on 2 Tranches
DRYDEN 43: Moody's Assigns Ba3 Rating to $30MM Class E-RR Notes

DT AUTO 2019-3: DBRS Assigns Prov. BB Rating on $23.5MM Cl. E Notes
FLAGSTAR MORTGAGE 2017-2: Moody's Hikes Cl. B-5 Debt Rating to Ba2
GOLUB CAPITAL 35B: Moody's Gives Ba3 Rating on $28MM Cl. E-R Notes
GOLUB CAPITAL 43: Moody's Assigns Ba3 Rating on $24.4MM Cl. E Notes
GS MORTGAGE 2015-GC34: Fitch Affirms B-sf Rating on Class F Certs

GS MORTGAGE 2017-GS7: Fitch Affirms B-sf Rating on Cl. H-RR Certs
HALCYON LOAN 2014-2: Moody's Lowers Rating on Cl. E Notes to Caa3
HALCYON LOAN 2015-2: Moody's Cuts Rating on Class F Notes to Caa2
HAMPTON ROADS: Moody's Hikes 2007-A Cl. II & III Bonds to Ba2
HAYFIN KINGSLAND XI: Moody's Rates $22.8MM Class E Notes 'Ba3'

JP MORGAN 2019-MFP: Moody's Assigns B3 Rating on Class F Certs
KAYNE CLO 5: Moody's Assigns Ba3 Rating on $26.2MM Class E Notes
KEY COMMERCIAL 2019-S2: DBRS Finalizes B Rating on Class F Certs
MONARCH BEACH 2018-MBR: DBRS Confirms B(high) Rating on G Certs
MORGAN STANLEY 2019-H7: Fitch Rates $8.403MM Class G-RR Debt 'B-sf'

NEWSTAR CLARENDON: Moody's Affirms Ba3 Rating on Class E Notes
OCP CLO 2019-17: Moody's Assigns Ba3 Rating on $20MM Cl. E Notes
OCTAGON INVESTMENT 44: Moody's Rates $23.750MM Class E Notes 'Ba3'
RAAC TRUST 2006-SP3: Moody's Hikes Class M-2 Debt Rating to Caa1
SASCO TRUST 2005-9XS: Moody's Hikes Rating on Class M1 Debt to B2

SBL COMMERCIAL 2016-KIND: Moody's Affirms B3 Rating on Cl. F Certs
SEQUOIA MORTGAGE 2019-CH2: Moody's Gives B1 Rating on Cl. B-4 Debt
SIERRA TIMESHARE 2019-2: Fitch Assigns BBsf Rating on Cl. D Debt
SLM STUDENT 2003-12: Fitch Affirms BBsf Rating on Class B-1 Notes
SOUND POINT IX: Moody's Assigns B3 Rating on $10MM Cl. F-RR Notes

SYMPHONY CLO XVIII: Moody's Affirms Ba3 Rating on $20MM Cl. E Notes
TRINITAS CLO XI: Moody's Rates $27.775MM Class E Notes 'Ba3'
UNITED AUTO 2018-2: DBRS Hikes Rating on Class F Notes to BB
WFRBS COMMERCIAL 2013-C13: Moody's Affirms B2 Rating on F Certs
WFRBS COMMERCIAL 2014-C23: Fitch Downgrades Cl. F Certs to B-sf

Z CAPITAL 2019-1: Moody's Assigns Ba3 Rating on $25MM Cl. E Notes

                            *********

AJAX MORTGAGE 2019-D: DBRS Assigns Prov. B Rating on B-2 Notes
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following
Mortgage-Backed Securities, Series 2019-D (the Notes) to be issued
by Ajax Mortgage Loan Trust 2019-D (AJAX 2019-D or the Trust):

-- $140.4 million Class A-1 at AAA (sf)
-- $6.1 million Class A-2 at AA (sf)
-- $10.1 million Class A-3 at A (low) (sf)
-- $9.3 million Class M-1 at BBB (low) (sf)
-- $7.5 million Class B-1 at BB (sf)
-- $7.1 million Class B-2 at B (sf)

The AAA (sf) rating on the Notes reflects the 27.35% of credit
enhancement provided by subordinated Notes in the pool. The AA
(sf), A (low) (sf), BBB (low) (sf), BB (sf) and B (sf) ratings
reflect 24.20%, 18.95%, 14.15 %, 10.25% and 6.60% of credit
enhancement, respectively.

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

The transaction is a securitization of a portfolio of seasoned
performing and re-performing first-lien residential mortgages
funded by the issuance of the Notes. The Notes are backed by 857
loans with a total principal balance of approximately $193,301,213
as of the Cut-Off Date (June 30, 2019).

The portfolio is approximately 149 months seasoned. As of the
Cut-Off Date, 94.0% of the pool is current, 3.7% is 30 days
delinquent under the Mortgage Bankers Association (MBA) delinquency
method and 2.3% is in bankruptcy (all bankruptcy loans are
performing or 30 days delinquent). Approximately 67.7% of the pool
has been zero times 30 (0 x 30) days delinquent for the past 24
months, 90.7% has been 0 x 30 for the past 12 months and 95.2% has
been 0 x 30 for the past six months.

Modified loans comprise 89.9% of the portfolio. The modifications
happened more than two years ago for 96.2% of the modified loans.
Within the pool, 266 mortgages (38.0% of the pool) have
non-interest-bearing deferred amounts, which equate to 7.1% of the
total principal balance. Included in the deferred amounts are the
Home Affordable Modification Program and proprietary principal
forgiveness amounts, which comprise 0.2% of the total principal
balance.

In accordance with the Consumer Financial Protection Bureau
Qualified Mortgage (QM) and Ability-to-Repay (ATR) rules, one loan
is designated as QM Safe Harbor, one loan as QM Rebuttable
Presumption and one loan as non-QM. Approximately 99.7% of the
loans are not subject to the QM rules.

Prior to the Closing Date, Great Ajax Operating Partnership L.P.
(Ajax), in its capacity as the Sponsor, acquired the loans from
various unaffiliated third-party sellers. The mortgage loans were
acquired by Ajax between 2013 and 2018. To satisfy the credit risk
retention requirements, the Sponsor or a majority-owned affiliate
of the Sponsor will retain at least a 5% eligible horizontal
interest in the securities.

As of the Cut-Off Date, Gregory Funding LLC is the Servicer for all
the loans in the pool.

Since 2013, Ajax and its affiliates have issued 27 securitizations
under the Ajax Mortgage Loan Trust shelf prior to AJAX 2019-D.
These issuances were backed by seasoned, re-performing or
non-performing loans. Only one of the previously issued Ajax deals,
AJAX 2017-B, was rated by DBRS. DBRS reviewed the historical
performance of the Ajax shelf; however, the non-rated deals
generally exhibit much worse collateral attributes than the rated
deals with regard to delinquencies at issuance. The prior Ajax
transactions currently exhibit high levels of delinquencies and
losses, which are expected given the nature of these severely
distressed assets.

There will not be advancing of delinquent principal or interest on
the mortgage loans by the Servicer or any other party to the
transaction; however, the Servicer is obligated to make advances in
respect of real estate assessments, taxes, and insurance and
reasonable costs and expenses incurred in the course of servicing
and disposing of properties.

Beginning three years after the Closing Date, the Issuer, at the
direction of the Depositor, has the option to redeem all of the
Notes at a price equal to the remaining note amount of the Notes
plus accrued and unpaid interest and any unpaid expenses and
reimbursement amounts (Aggregate Redemption Price). Additionally,
beginning three years after the Closing Date, the Issuer, at the
direction of the Depositor, has the option to redeem one or more of
the most senior notes outstanding at a price (Class Redemption
Price) for each class equal to the sum of the remaining note amount
of such class and any accrued and unpaid interest due through the
redemption date. When the rated Notes are outstanding, the Issuer
has the option to sell any mortgage loan to an affiliate or
non-affiliate provided that the proceeds of such sale are equal to
the aggregate outstanding note amount of the rated Notes and,
beginning with the second payment date, certain post-sale debt
enhancement requirements are met.

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

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.

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


AMERICREDIT AUTOMOBILE 2018-3: DBRS Confirms BB on Class E Debt
---------------------------------------------------------------
DBRS, Inc. reviewed 18 outstanding, publicly rated classes from
AmeriCredit Automobile Receivables Trust, Series 2015-1, 2017-3 and
2018-3. Of the 18 classes reviewed, DBRS confirmed nine classes,
upgraded five classes as well as discontinued four classes due to
repayment. For the confirmed ratings, performance trends are such
that credit enhancement levels are sufficient to cover DBRS's
expected losses at their current respective rating levels. For the
upgraded ratings, performance trends are such that credit
enhancement levels are sufficient to cover DBRS's expected losses
at their new respective rating levels.

The Affected Ratings are:

AmeriCredit Automobile Receivables Trust 2015-1

Class C       Confirmed     AAA(sf)
Class D       Upgraded      AAA(sf)
Class E       Upgraded      AA(high)(sf)
Class B       Disc.-Repaid  Discontinued

AmeriCredit Automobile Receivables Trust 2017-3

Class A-3     Confirmed     AAA(sf)
Class B       Upgraded      AAA(sf)
Class C       Upgraded      AA(high)(sf)
Class D       Upgraded      A(low)(sf)
Class A-2-A   Disc-Repaid   Discontinued
Class A-2-B   Disc-Repaid   Discontinued

AmeriCredit Automobile Receivables Trust 2018-3

Class A-1     Disc-Repaid   Discontinued
Class A-1-A   Confirmed     AAA(sf)
Class A-2-B   Confirmed     AAA(sf)
Class A-3     Confirmed     AAA(sf)
Class B       Confirmed     AA(sf)
Class C       Confirmed     A(sf)
Class D       Confirmed     BBB(sf)
Class E       Confirmed     BB(sf)

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

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

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

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


BHMS 2018-ATLS: DBRS Confirms BB(low) Rating on Class HRR Certs
---------------------------------------------------------------
DBRS Limited confirmed the ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2018-ATLS issued by BHMS
2018-ATLS (the Trust) as follows:

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

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction since issuance. The $1.2 billion Trust loan closed
in July 2018 and is secured by the Atlantis, a 2,917-key luxury
beachfront resort located on Paradise Island in the Bahamas. The
collateral also includes the fee interest in amenities including,
but not limited to, 40 restaurants and bars, a 60,000 square feet
(sf) casino, the 141-acre Aquaventure waterpark, 73,391 sf of
retail space and spa facilities and 500,000 sf of meeting and group
space. The resort includes a luxury tower with an additional 495
rooms owned by third parties as condo-hotel units and 392 timeshare
rooms located at the Harborside Resort, both of which are not a
part of the collateral. The loan is sponsored by BREF ONE, LLC, a
subsidiary of Brookfield Asset Management Inc. (rated A (low) with
a Stable trend by DBRS). The hotel is managed by the
sponsor-affiliate Brookfield Hospitality Management with a 20-year
management agreement that expires in 2034. There is also a
franchise agreement in place with Marriott International, under the
Autograph Collection that runs through 2034.

Loan proceeds of $1.2 billion along with $650.0 million in
mezzanine debt spread across three loans were used to refinance
existing debt of $1.7 billion (previously secured in the BHMS
2014-ATLS Mortgage Trust transaction), return $148.9 million of
sponsor equity and cover closing costs, thus leaving $635.0 million
of cash equity remaining behind the transaction. The loan has a
two-year interest-only (IO) original term with five one-year
extension options that are also fully IO. Approximately $213
million ($73,020 per key) in capital improvements were completed by
the sponsor between 2012 and 2017 in order to compete with the
newly constructed competition. The sponsor had plans at issuance to
complete an $8.0 million ($32,000 per key) renovation to upgrade
soft and case goods for The Royal; however, proceeds were not
reserved upfront. Per the servicer, the budget increased to $9.0
million and the renovation will begin on August 2019 with a
completion date in December 2019.

Per the year-end (YE) 2018 financials, the loan reported a net cash
flow (NCF) figure of $118.3 million, well below the DBRS NCF figure
of $147.8 million derived at issuance and the normalized YE2017 NCF
of $173.2 million. The YE2018 departmental income decreased $30.5
million from the DBRS NCF and decreased $25.9 million from the
YE2017 departmental income. While revenues have been declining year
over year since 2015, the considerable drop in 2018 could be due to
a discrepancy in Other Income reported by the servicer. DBRS is
verifying whether all Other Income is being reported by the
servicer in the YE2018 financials.

The revenue declines over since 2017 is most likely due to the
opening of the 2,019-key Baha Mar, a direct competitor that opened
7.3 miles from the collateral in April and November 2017. Baha
Mar's highest-luxury tower, Rosewood, opened in June 2018. Baha Mar
is a $3.5 billion luxury resort that features three towers of
different hotel brands, including the Grand Hyatt, SLS, and
Rosewood, as well as a 100,000 of a casino. Baha Mar caters to a
more affluent adult clientele, rather than families, and does not
offer water and marine attractions that are key demand and revenue
drivers at the subject. Baha Mar does offer the largest casino in
the Caribbean, which is expected to drive down casino revenue at
the subject.

Based on the trailing 12-month (T-12) ending March 31, 2019, Smith
Travel Research (STR) report, The Royal (1,201 keys) reported
occupancy rate, average daily rate (ADR) and revenue-per-available
room (RevPAR) figures of 68.2%, $240 and $164, respectively,
compared with the competitive set's figures of 65.7%, $266 and
$175, respectively. The Royal's figures were an improvement from
the T-12 ending March 31, 2018, occupancy rate, ADR and RevPAR of
59.7%, $241 and $144, respectively. According to the T-12 ending
April 30, 2019, STR report, The Cove (600 keys) reported T-12
occupancy rate, ADR and RevPAR figures of 74.0%, $441 and $326,
respectively, compared with the competitive set's figures of 63.6%,
$379 and $241, respectively. The Cove's figures were a moderate
improvement from the T-12 ending March 31, 2018, occupancy rate,
ADR and RevPAR of 70.1%, $429 and $300, respectively.

The Tourism Today Network, run by the Bahamas Ministry of Tourism,
noted that international visitors to Nassau/Paradise Island were up
23.4% between January 2019 to May 2019, and air arrivals increased
every month of 2018 as a result of the new resorts that opened on
the island between 2017 and 2018. It is likely that much of the new
tourist traffic is being drawn to the new Baha Mar due to the
brand-new amenities and accommodations on the island. DBRS
performed an internal assessment of the Commonwealth of the Bahamas
on June 25, 2019, and rated it BBB category, the same rating at
issuance.

Classes X-CP 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.


CARLYLE GLOBAL 2015-1: Moody's Rates $7.275MM Cl. F-R Notes 'B3'
----------------------------------------------------------------
Moody's Investors Service assigned ratings to six classes of CLO
refinancing notes issued by Carlyle Global Market Strategies CLO
2015-1, Ltd.

Moody's rating action is as follows:

US$310,400,000 Class A-R2 Senior Secured Floating Rate Notes Due
2031 (the "Class A-R2 Notes"), Assigned Aaa (sf)

US$60,150,000 Class B-R2 Senior Secured Floating Rate Notes Due
2031 (the "Class B-R2 Notes"), Assigned Aa2 (sf)

US$22,300,000 Class C-R2 Mezzanine Secured Deferrable Floating Rate
Notes Due 2031 (the "Class C-R2 Notes"), Assigned A2 (sf)

US$29,585,000 Class D-R2 Mezzanine Secured Deferrable Floating Rate
Notes Due 2031 (the "Class D-R2 Notes"), Assigned Baa3 (sf)

US$23,765,000 Class E-R Junior Secured Deferrable Floating Rate
Notes Due 2031 (the "Class E-R Notes"), Assigned Ba3 (sf)

US$7,275,000 Class F-R Junior Secured Deferrable Floating Rate
Notes Due 2031 (the "Class F-R Notes"), 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 its methodology.

The Issuer is a managed cash flow collateralized loan obligation
(CLO). 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 first lien senior secured loans
and eligible investments, and up to 10% of the portfolio may
consist of second lien loans and unsecured loans.

Carlyle CLO Management L.L.C. will continue to 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 extended 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 July 22, 2019 in
connection with the refinancing of all classes of the secured notes
some of which have been previously refinanced on July 20, 2017 and
all have been originally issued on March 10, 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 the reinvestment
period; extensions of the stated maturity and non-call period;
changes to certain collateral quality tests; and changes to the
overcollateralization test levels.

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.

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: $482,500,438

Defaulted par: $4,541,889

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2976

Weighted Average Spread (WAS): 3.42%

Weighted Average Recovery Rate (WARR): 48.0%

Weighted Average Life (WAL): 8 years

Methodology Underlying the Rating Action:

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

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

The performance of the Refinancing Notes is subject to uncertainty.
The performance of the Refinancing 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 Refinancing Notes.


CD 2007-CD4: Moody's Hikes Rating on Class A-J Certs to Caa2
------------------------------------------------------------
Moody's Investors Service upgraded the rating on one class and
affirmed the ratings on two classes in CD 2007-CD4 Commercial
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2007-CD4 as follows:

Cl. A-J, Upgraded to Caa2 (sf); previously on Mar 15, 2018 Affirmed
Caa3 (sf)

Cl. XC*, Affirmed C (sf); previously on Mar 15, 2018 Affirmed C
(sf)

Cl. XW*, Affirmed C (sf); previously on Mar 15, 2018 Affirmed C
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The rating on Cl. A-J was upgraded due to lower than anticipated
realized losses from previously liquidated loans. The Class A-J
certificate balance has been reduced by 98% from its original
balance and has experienced a 17% realized loss as a result of
previously liquidated loans.

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 59.1% of the
current pooled balance, compared to 61.6% at Moody's last review.
Moody's base expected loss plus realized losses is now 12.8% of the
original pooled balance, compared to 13.1% 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 rating all classes except
interest-only classes was "Moody's Approach to Rating Large Loan
and Single Asset/Single Borrower CMBS" published in July 2017. The
methodologies used in rating interest-only classes were "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 70% of the pool is in
special servicing. In this approach, Moody's determines a
probability of default for each specially serviced loan that it
expects will generate a loss and estimates a loss given default
based on a review of broker's opinions of value (if available),
other information from the special servicer, available market data
and Moody's internal data. The loss given default for each loan
also takes into consideration repayment of servicer advances to
date, estimated future advances and closing costs. Translating the
probability of default and loss given default into an expected loss
estimate, Moody's then applies the aggregate loss from specially
serviced loans to the most junior class and the recovery as a pay
down of principal to the most senior class.

DEAL PERFORMANCE

As of the July 12, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by more than 99% to
$11.8 million from $6.6 billion at securitization. The certificates
are collateralized by four mortgage loans.

Eighty-five loans have been liquidated from the pool, resulting in
an aggregate realized loss of $836 million (for an average loss
severity of 60%). Two loans, constituting 70% of the pool, are
currently in special servicing. The largest specially serviced loan
is the Pinetree Center Loan ($5.5 million -- 46.5% of the pool),
which is secured by an approximately 75,000 SF retail property
located in Thomasville, Georgia. As of May 2019, the property was
only 16% leased due to the departure of its former grocery anchor
tenant. The asset has been REO since June 2017 and the special
servicer indicated it was included in a June 2019 auction.

The second largest specially serviced loan is the OSI Collection
Services Loan ($2.8 million -- 23.9% of the pool), which is secured
by a fully vacant, 43,000 SF suburban office building located in
Dublin, Ohio. The loan transferred to special servicing in December
2016 due to balloon payment / maturity default and the asset became
REO in May 2018. The former single tenant vacated at their lease
expiration date of March 2019. The special servicer indicated their
current strategy is to lease up the property and perform necessary
capital improvements to better position the asset for sale.

Moody's estimates an aggregate $7.0 million loss for the specially
serviced loans (84% expected loss on average).

The two non-specially serviced loans represent 29.6% of the pool
balance. The largest loan is the Rite Aid -- Vancouver Loan ($2.2
million -- 18.8% of the pool), which is secured by a single tenant
retail property leased to Rite Aid. The property is located 15
miles northeast of the Portland, Oregon CBD. The loan is fully
amortizing and has amortized down by 45% since securitization.
Moody's LTV and stressed DSCR are 53% and 1.81X, respectively.

The other performing loan is the Gardens at Pryor Creek Loan ($1.3
million -- 10.8% of the pool), which is secured by a multifamily
property located in Pryor, Oklahoma, approximately 40 miles
northeast of Tulsa. The property was 86% leased as of December 2018
compared to 93% in 2017. The loan has amortized by approximately
19% since securitization and Moody's LTV and stressed DSCR are 65%
and 1.45X, respectively.


CHC COMMERCIAL 2019-CHC: DBRS Finalizes B(high) Rating on HRR Certs
-------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of Commercial Mortgage Pass-Through Certificates issued by
CHC Commercial Mortgage Trust 2019-CHC:

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

All trends are Stable.

DBRS also discontinued and withdrew its provisional rating on the
Class X-CP certificates.

The Class X balance is notional and based on the aggregate
Certificate Balance of the Class B, Class C and Class D
certificates. Class HRR represents the Eligible Horizontal Residual
Interest that is to be purchased by a third-party purchaser. The
third-party purchaser of the HRR certificates is ACREFI Mortgage
Lending, LLC, an affiliate of Apollo Commercial Real Estate
Finance, Inc.

The loan is secured by the borrower's fee and leasehold interests
in 156 properties located across 28 states. The geographically
diverse portfolio, consists of a variety of medical and senior
housing-related property types, including Medical Office Buildings
(MOB), Independent Living Facilities (ILF), Assisted Living
Facilities (ALF), Skilled Nursing Facilities (SNF) and
hospital-related properties. The properties fall under three
operating segments: (1) MOB, (2) Triple Net (NNN) Leased and (3)
RIDEA (REIT Investment Diversification and Empowerment Act)
Facilities.

The MOB segment comprises approximately 3.0 million square feet
across 88 buildings in 18 states. Based on the May 1, 2019, rent
rolls, the MOB properties have a total occupancy of 80.1%, which is
in line with historical levels of 80.0% in 2017 and 78.1% in 2018.
The MOB properties benefit from 80 of the 88 buildings being
located on or near a health-care campus or anchored by a
health-care system, which has translated into an especially high
renewal rate of 87.0%. Overall, the performance of the MOB
portfolio has been stable for the past several years.

The NNN Leased segment includes 57 properties that skew toward more
operationally intensive uses. The properties are composed of 37 SNF
facilities, nine hospital/long-term acute care hospitals and 11 ALF
properties. These 57 properties are leased across 19 individual
leases, composed of either multi-property master leases or
individual leases with a total base rent of $64.8 million. Based on
the operators' trailing 12 month (TTM) ending March 2019 property
financials, the look-through cash flows (EBITDAR) cover the base
rent at 1.22 times (x), which is similar to the 1.20x coverage in
2018 and below the 1.35x coverage in 2017. Weakness, particularly
due to higher expenses in the SNF properties, has caused the
sponsor to reset rents at levels that the properties can support.
In 2019, two leases were restructured lower by a total of nearly
$5.0 million. DBRS took into account the declining EBITDAR trends
and added additional conservatism to the net cash flows (NCFs).
Additionally, DBRS's NCFs for the NNN Leased portfolio are based on
the underlying properties' look-through cash flows rather than the
NNN rent, with relatively high cap rates applied based on the
operating business nature of the properties.

The RIDEA portfolio consists of 11 properties that provide for a
third-party management agreement and allow the landlord (borrower)
to retain the income from the underlying operation without a lease
in place. The 11 properties contain predominately ILF and ALF beds,
which together comprise approximately 86.3% of the beds in the
RIDEA facilities. ILF and ALF properties are generally private-pay,
limiting the portfolio's exposure to changes in Medicare in
Medicaid reimbursements. SNF revenue accounted for approximately
16.3% of total RIDEA revenue, according to the TTM ending March
2019 financials. The RIDEA properties experienced a considerable
decline in SNF Medicare reimbursements and SNF private-pay revenue
in 2017 from the prior year, and only a small portion of this
decline was made up through higher Medicaid reimbursements. The
declining trend has continued in 2018 and 2019, albeit at a lower
rate. Memory care revenue has historically been a minor contributor
to the RIDEA portfolio. However, the Lincolnwood property underwent
a $8.1 million renovation in 2018 and early 2019 and is budgeted to
contribute over $2.0 million of additional revenue to the
portfolio. The RIDEA properties benefit from a higher portion of
private-pay sources; however, DBRS did factor in additional
conservatism in its determination of NCFs.

Mortgage loan proceeds of approximately $1.02 billion, $489.8
million of mezzanine loans and sponsor equity of $146.0 million
will refinance existing debt of $1.62 billion, fund upfront
reserves and pay closing costs. The existing debt is the remaining
portion of a $2.6 billion securitization in 2015, GARH 2015-NRF.
The collateral in that transaction totaled 217 properties, and over
time, the number of properties has decreased due to sales or
releases. The 2015 securitization has performed as agreed.

The DBRS loan-to-value (LTV), based on a weighted-average (WA) DBRS
cap rate of 11.72%, is 90.8% and supports the last dollar of
mortgage debt rated at B (high). While the DBRS LTV is relatively
high, the DBRS Term debt service coverage ratio (DSCR) on the
mortgage debt is still quite high at 2.91x, and the DBRS LTV at the
last dollar of investment-grade-rated debt is much lower at 62.3%
through Class D, rated A (low) (sf). When the $489.8 million of
subordinate mezzanine debt is added to the first mortgage, the DBRS
LTV is much higher at 134.3%. Despite the increase in total
leverage, the DBRS Term DSCR on the entire $1.51 billion financing
package still covers at 1.47x.

The loan collateral consists of the fee and leasehold interest in
156 health care-related properties located in 28 states. The
properties fall under the following three categories: (1) MOB, (2)
NNN and (3) RIDEA Facilities.

The loan is sponsored by Colony Capital, an international
investment firm that has been active in the real estate industry
since 1991 and was founded concurrently with the acquisition of a
portfolio from Resolution Trust Corporation. Colony Capital's 27
years of investment experience have led to their current real
estate interests being valued at approximately $43 billion as of
year-end 2018. The sponsor's health-care portfolio included 413
properties scattered across the United States, consisting of 192
ILFs, 108 MOBs, 99 SNFs and 14 hospitals as of Q4 2018. The
non-recourse carveout guarantor for the loan is NorthStar
Healthcare JV, LLC, which is required to maintain a minimum net
worth of $300.0 million throughout the loan term, exclusive of the
subject properties.

In aggregate, the WA DBRS cap rate is 11.72%, which results in a
DBRS value of $1,127,726,732 based on the concluded NCF of
$132,170,120. This results in a DBRS LTV of 90.84% on the mortgage
loan and 134.27% on the total debt stack of $1,514,234,681. The
assumed WA DBRS cap rate is a significant stress over the
appraiser's WA cap rate of 7.4%.

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


COMM MORTGAGE 2013-GAM: Fitch Affirms BB-sf Rating on Class F Debt
------------------------------------------------------------------
Fitch Ratings has affirmed all classes of COMM 2013-GAM Mortgage
Trust with Stable Rating Outlooks.

COMM 2013-GAM Mortgage Trust
   
Class A-1 12624UAA2; LT AAAsf  Affirmed;  previously at AAAsf
Class A-2 12624UAC8; LT AAAsf  Affirmed;  previously at AAAsf
Class B 12624UAJ3;   LT AA-sf  Affirmed;  previously at AA-sf
Class C 12624UAL8;   LT Asf    Affirmed;  previously at Asf
Class D 12624UAN4;   LT BBBsf  Affirmed;  previously at BBBsf
Class E 12624UAQ7;   LT BBB-sf Affirmed;  previously at BBB-sf
Class F 12624UAS3;   LT BB-sf  Affirmed;  previously at BB-sf
Class X-A 12624UAE4; LT AAAsf  Affirmed;  previously at AAAsf

KEY RATING DRIVERS

Stable Collateral Net Cash Flow: The affirmation is due to
relatively stable collateral performance since Fitch's last rating
action. Physical occupancy has declined to 91.3% from 97.8% at
March 2019 and 99.1% at March 2018 and 97.9% at March 2017. The
decline is due to the departure of Kohl's in April 2019, who
continues to pay rent as their lease expires in 2031.  The servicer
reported YE 2018 net cash flow (NCF) debt service coverage ratio
(DSCR) was 1.85x, compared to 1.81x at YE 2017, 1.80x at YE 2016
and 1.71x at issuance.  Fitch's analysis includes an additional
vacancy assumption to address the departure of Kohl's and lease
rollover in 2019.  The Fitch NCF was $29.4 million as of YE 2018
compared with $27.9 million at issuance.

Improved In-line Sales; Declining Anchor Sales: Comparable in-line
sales were $647 (psf as of TTM September 2018, compared with $635
psf as of TTM March 2018, $611 psf at March 2017, $650 psf at YE
2015, $580 psf at YE 2014 and $501 psf at issuance. Macy's sales
declined to $177 psf as of TTM September 2018 from $204 psf at YE
2015 and $225 psf at issuance, while Macy's Men's & Furniture
declined to $140 psf as of TTM September 2018 from $173 psf at
issuance. JCPenney's sales have declined to $144 psf as of TTM
September 2018 from $168 psf at YE 2015 and $197 psf at issuance.
BJ's Wholesale Club has increased to $899 psf from $896 psf at YE
2015 but declined from $928 psf at issuance. Sears sales have
remained relatively stable at $241 psf from $242 psf at issuance.

Amortization: The loan will amortize by $60 million over the
eight-year loan term. As of the July 2019 distribution date, the
pool's aggregate certificate balance has paid down approximately
13.2% as a result of scheduled amortization.

Single Asset Concentration: The transaction is secured by a single
property and, therefore, is more susceptible to single-event risk
related to the market, sponsor, or the largest tenants occupying
the property. The asset is well located in a densely populated
area. The loan sponsor is an entity controlled by Macerich Company,
an experienced owner of regional shopping centers and malls.

RATING SENSITIVITIES

The Rating Outlooks remain Stable, which reflects the relatively
stable collateral performance. Upgrades may occur with continued
stable to improved performance. Downgrades may occur should
performance significantly deteriorate. Fitch will continue to
monitor the mall's performance to ensure that revenues and expenses
considered at the time of Fitch's initial ratings remain in line
over the loan's term.


CONN RECEIVABLES 2018-A: Fitch Hikes Rating on Class C Notes to Bsf
-------------------------------------------------------------------
Fitch Ratings has taken the following rating actions on Conn's
Receivables Funding 2018-A, LLC, which consists of notes backed by
retail loans originated and serviced by Conn Appliances, Inc.:

  -- Class A notes affirmed at 'BBBsf'; Outlook Stable;

  -- Class B notes affirmed at 'BBsf'; Outlook revised to Positive
     from Stable;

  -- Class C notes upgraded to 'Bsf' from 'B-sf'; Outlook revised
     to Positive from Stable.

The affirmation of the class A and class B notes and the upgrade of
the class C notes is due to performance in line with expectations
and growth in credit enhancement (CE) since closing. As of the July
15, 2019 distribution date, overcollateralization (OC) of the class
A, B, and C notes are 68.95%, 50.23%, and 31.50%, respectively, an
increase from 48.00%, 31.50%, and 15.00%, respectively, at closing.
CE will continue to build since no cash will be released until all
notes are paid in full, and the notes will continue to pay pro-rata
as long as the 23.00% total OC threshold is maintained.

Although the model implied ratings of the notes are slightly higher
than their respective current ratings, Fitch affirmed or upgraded
the notes due to various other considerations. Conn's 2018-A
includes greater concentrations of re-aged accounts compared to
older Conn's transactions, driving uncertainty regarding future
performance. Further, Fitch is taking a cautious approach to
unsecured consumer credit, particularly at the subprime level,
given its view that the credit cycle is in its late stages. Despite
that, Fitch has revised the Outlooks on the class B and C notes to
Positive from Stable, reflecting the CE build-up since closing and
expected further increase in CE due to the turbo nature of the
transaction.

KEY RATING DRIVERS

Collateral Quality: The 2018-A trust pool consists of 100%
fixed-rate consumer loans originated and serviced by Conn
Appliances, Inc. The pool exhibits a weighted average FICO score of
608 at closing.

The lifetime base case default rate for the 2018-A pool is assumed
to be approximately 25.00%, equal to the original lifetime base
case default rate at closing. After taking into account defaults
that have already been recognized, remaining defaults of
approximately 27.66% were assumed. Defaults are mitigated by the CE
that will continue to build due to no cash being released from the
trust until all notes are paid in full.

Fitch applied a 2.2x stress at the 'BBBsf' level, reflecting the
high absolute value of the historical defaults, along with the
variability of default performance in recent years and the high
geographic concentration. The recovery rate on defaulted loans for
each note is assumed to be 5%.

Dependence on Trust Triggers: The trust depends on three trust
triggers (Cumulative Net Loss Trigger, Annualized Net Loss Trigger,
and Recovery Trigger) in order to ensure the payments due on the
senior notes during times of degrading collateral performance. The
triggers help protect the senior notes in stressed scenarios, but
can constrain the subordinate notes due to the switch to sequential
pay structure redirecting funds to the senior notes.

A shortened version of the 18-month WAL default timing curve as
shown in the Global Consumer ABS Criteria was utilized in order to
recognize all defaults within the life of the transaction.

Rating Cap at 'BBBsf': Due to higher loan defaults in recent years,
management changes at Conn's, and Conn's credit risk profile, Fitch
has placed a rating cap on this transaction at 'BBBsf'.

Servicing Capabilities: Conn Appliances, Inc. has a long track
record as an originator, underwriter and servicer. The credit risk
profile of the entity is mitigated by the backup servicing provided
by Systems & Services Technologies, Inc. (SST), which has committed
to a servicing transition period of 30 days. Fitch considers all
parties to be adequate servicers for this pool based on prior
experience and capabilities.

RATING SENSITIVITIES

Unanticipated increases in the frequency of defaults or charge-offs
on borrower accounts could produce loss levels higher than the base
case and would likely result in declines of CE and remaining loss
coverage levels available to the notes. Decreased CE may make
certain ratings on the notes susceptible to potential negative
rating actions, depending on the extent of the decline in coverage.


Fitch conducts sensitivity analysis by stressing a transaction's
initial base case charge-off assumption by an additional 10%, 25%,
and 50%, and examining the rating implications. The increases of
the base case charge-offs are intended to provide an indication of
the rating sensitivity of the notes to unexpected deterioration of
a transaction's performance.

During the sensitivity analysis, Fitch examines the magnitude of
the multiplier compression by projecting the expected cash flows
and loss coverage levels over the life of investments under higher
than the initial base case charge-off assumptions. Fitch models
cash flows with the revised charge-off estimates while holding
constant all other modelling assumptions.

Rating sensitivity to increased charge-off rate:

  -- Class A, B, and C current ratings (Remaining Defaults as a
     percent of current: 27.66%): 'BBBsf', 'BBsf', 'Bsf';

  -- Increase base case by 10% for class A, B, and C: 'BBBsf',
     'BBsf', 'Bsf';

  -- Increase base case by 25% for class A, B, and C: 'BBB-sf',
     'BBsf', 'Bsf';

  -- Increase base case by 50% for class A, B, and C: 'BB+sf',
     'B+sf', less than 'CCCsf'.


CSFB MORTGAGE 2003-C3: Moody's Affirms C Rating on 2 Tranches
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings on three classes in
CSFB Mortgage Securities Corp. Commercial Mtge Pass-Through Ctfs.
2003-C3 as follows:

Cl. J, Affirmed Caa3 (sf); previously on Mar 2, 2018 Affirmed Caa3
(sf)

Cl. K, Affirmed C (sf); previously on Mar 2, 2018 Affirmed C (sf)

Cl. A-X*, Affirmed C (sf); previously on Mar 2, 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 Moody's expected plus realized losses.

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 61.1% of the
current pooled balance, compared to 38.4% at Moody's last review.
Moody's base expected loss plus realized losses is now 3.5% of the
original pooled balance, compared to 3.3% at the last review.

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

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

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

Factors that could lead to a downgrade of the ratings include a
decline in the performance of the pool, 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 classes was "Moody's Approach to Rating Large Loan
and Single Asset/Single Borrower CMBS" published in July 2017. The
methodologies used in rating interest-only classes were Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 66% of the pool is in
special servicing. In this approach, Moody's determines a
probability of default for each specially serviced and troubled
loan that it expects will generate a loss and estimates a loss
given default based on a review of broker's opinions of value (if
available), other information from the special servicer, available
market data and Moody's internal data. The loss given default for
each loan also takes into consideration repayment of servicer
advances to date, estimated future advances and closing costs.
Translating the probability of default and loss given default into
an expected loss estimate, Moody's then applies the aggregate loss
from specially serviced loans to the most junior classes and the
recovery as a pay down of principal to the most senior classes.

DEAL PERFORMANCE

As of the July 15, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by over 99% to $11.9
million from $1.7 billion at securitization. The certificates are
collateralized by four mortgage loans ranging in size from 9% to
34% of the pool. One loan, constituting 9% of the pool have
defeased and are secured by US government securities.

Nineteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $52.5 million (for an average loss
severity of 41.5%). Two loans, constituting 66.1% of the pool, are
currently in special servicing and have been deemed non-recoverable
by the master servicer. The largest specially serviced loan is the
Buffalo Square Shopping Center Loan ($4.0 million -- 33.9% of the
pool), which is secured by a leasehold interest in 31,845 SF out of
a 177,000 SF retail center located in Las Vegas, Nevada. The
collateral is subject to a sandwich ground lease and the sandwich
ground lease is subject to a master ground lease of the entire
retail center. The property also faces future ground rent
escalations. The loan was transferred to the special servicer in
July 2014 due to the borrower changing the property manager without
noteholder consent. The loan subsequently became REO November 2016.
The property was 70% occupied as of April 2019, compared to 65% in
November 2017, and 95% in November 2016. Moody's anticipates a
significant loss on this loan.

The other specially serviced loan is The Crossroads Loan ($3.8
million -- 32.2% of the pool), which is secured by a Class B office
building located in Elmsford, New York, near White Plains. The loan
was first transferred to the special servicer in December 2012 due
to maturity default. The loan was extended through January 2015 but
returned to the special servicer due to maturity default. The loan
became REO in November 2018. The property was 46% occupied as of
May 2019, compared to 57% in November 2016. The special servicer
indicated the property is being marketed for sale.

Moody's estimates an aggregate $7.3 million loss for the specially
serviced loans (94% expected loss on average).

The only non-defeased performing loan is the Polar Plastics Loan
($3.0 million -- 24.6% of the pool), which is secured by a 385,000
SF manufacturing facility located in Mooresville, North Carolina
approximately 30 miles north of Charlotte. The property is 100%
leased to Pactiv Corporation through March 2023. Moody's value
incorporated a Lit/Dark analysis to account for the single-tenant
risk. The loan is fully amortizing, has amortized 69% since
securitization and is scheduled to pay-off in March 2023. Moody's
LTV is below 40%.


DRYDEN 43: Moody's Assigns Ba3 Rating to $30MM Class E-RR Notes
---------------------------------------------------------------
Moody's Investors Service assigned ratings to five classes of CLO
refinancing notes issued by Dryden 43 Senior Loan Fund.

Moody's rating action is as follows:

US$381,000,000 Class A-R Senior Secured Floating Rate Notes Due
2029 (the "Class A-R Notes"), Assigned Aaa (sf)

US$75,000,000 Class B-R Senior Secured Floating Rate Notes Due 2029
(the "Class B-R Notes"), Assigned Aa2 (sf)

US$33,000,000 Class C-R Mezzanine Secured Deferrable Floating Rate
Notes Due 2029 (the "Class C-R Notes"), Assigned A2 (sf)

US$33,000,000 Class D-RR Mezzanine Secured Deferrable Floating Rate
Notes Due 2029 (the "Class D-RR Notes"), Assigned Baa3 (sf)

US$30,000,000 Class E-RR Junior Secured Deferrable Floating Rate
Notes Due 2029 (the "Class E-RR Notes"), Assigned Ba3 (sf)

RATINGS RATIONALE

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

The Issuer is a managed cash flow collateralized loan obligation
(CLO). 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 first lien senior secured loans,
cash, and eligible investments, and up to 10% of the portfolio may
consist of second liens loans and unsecured loans.

PGIM, Inc. 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 two year reinvestment period.

The Issuer has issued the Refinancing Notes on July 22, 2019 in
connection with the refinancing of all classes of secured notes
previously partially refinanced on July 20, 2018 and originally
issued on August 22, 2016. On the Refinancing Date, the Issuer used
the proceeds from the issuance of the Refinancing Notes and one
other class of secured 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 and one other
class of secured notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: extension of the non-call period and changes to certain
collateral quality tests.

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: $599,464,163

Defaulted par: $982,500

Diversity Score: 90

Weighted Average Rating Factor (WARF): 2850 (corresponding to a
weighted average default probability of 25.30%)

Weighted Average Spread (WAS): 3.10%

Weighted Average Recovery Rate (WARR): 47.50%

Weighted Average Life (WAL): 7.09 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.


DT AUTO 2019-3: DBRS Assigns Prov. BB Rating on $23.5MM Cl. E Notes
-------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Notes to be issued by DT Auto Owner Trust 2019-3 (DTAOT 2019-3 or
the Issuer):

-- $215,020,000 Class A Notes at AAA (sf)
-- $49,090,000 Class B Notes at AA (sf)
-- $77,720,000 Class C Notes at A (sf)
-- $73,130,000 Class D Notes at BBB (sf)
-- $23,520,000 Class E Notes at BB (sf)

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

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

-- DTAOT 2019-3 provides for Class A, B, C, D and E coverage
multiples slightly below the DBRS range of multiples set forth in
the criteria for this asset class. DBRS believes that this is
warranted, given the magnitude of expected loss and structural
features of the transaction.

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

-- The quality and consistency of the provided historical static
pool data for DriveTime Automotive Group, Inc. (DriveTime)
originations and the performance of the DriveTime auto loan
portfolio.

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

The DTAOT 2019-3 transaction represents a securitization of a
portfolio of motor vehicle retail installment sales contracts
originated by DriveTime Car Sales Company, LLC (the Originator).
The Originator is a direct, wholly-owned subsidiary of DriveTime.
DriveTime is a leading used vehicle retailer in the United States
that focuses primarily on the sale and financing of vehicles to the
subprime market.

The provisional rating on the Class A Notes reflects the 59.45% of
initial hard credit enhancement provided by the subordinated notes
in the pool, the Reserve Account (1.50%) and overcollateralization
(14.25%). The ratings on Class B, C, D and E Notes reflect 49.85%,
34.65%, 20.35% and 15.75% of initial hard credit enhancement,
respectively. Additional credit support may be provided from excess
spread available in the structure.

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


FLAGSTAR MORTGAGE 2017-2: Moody's Hikes Cl. B-5 Debt Rating to Ba2
------------------------------------------------------------------
Moody's Investors Service upgraded the ratings of 17 tranches from
four transactions, backed by first-lien, fully amortizing,
fixed-rate prime quality residential mortgage loans with strong
credit characteristics.

Issuer: Flagstar Mortgage Trust 2017-2

Cl. B-2, Upgraded to A1 (sf); previously on Nov 15, 2018 Upgraded
to A2 (sf)

Cl. B-4, Upgraded to Baa3 (sf); previously on Nov 15, 2018 Upgraded
to Ba1 (sf)

Cl. B-5, Upgraded to Ba2 (sf); previously on Nov 15, 2018 Upgraded
to B1 (sf)

Issuer: Flagstar Mortgage Trust 2018-2

Cl. A-13, Upgraded to Aa1 (sf); previously on May 3, 2018
Definitive Rating Assigned Aa2 (sf)

Cl. A-14, Upgraded to Aa1 (sf); previously on May 3, 2018
Definitive Rating Assigned Aa2 (sf)

Cl. B-1, Upgraded to Aa3 (sf); previously on May 3, 2018 Definitive
Rating Assigned A1 (sf)

Cl. B-2, Upgraded to A2 (sf); previously on May 3, 2018 Definitive
Rating Assigned A3 (sf)

Cl. B-3, Upgraded to Baa2 (sf); previously on May 3, 2018
Definitive Rating Assigned Baa3 (sf)

Cl. B-4, Upgraded to Ba1 (sf); previously on May 3, 2018 Definitive
Rating Assigned Ba3 (sf)

Cl. B-5, Upgraded to B1 (sf); previously on May 3, 2018 Definitive
Rating Assigned B3 (sf)

Issuer: Flagstar Mortgage Trust 2018-4

Cl. A-1, Upgraded to Aaa (sf); previously on Jun 28, 2018
Definitive Rating Assigned Aa1 (sf)

Cl. A-10, Upgraded to Aa1 (sf); previously on Jun 28, 2018
Definitive Rating Assigned Aa2 (sf)

Issuer: Flagstar Mortgage Trust 2018-5

Cl. B-1, Upgraded to Aa3 (sf); previously on Sep 20, 2018
Definitive Rating Assigned A1 (sf)

Cl. B-2, Upgraded to A2 (sf); previously on Sep 20, 2018 Definitive
Rating Assigned A3 (sf)

Cl. B-3, Upgraded to Baa2 (sf); previously on Sep 20, 2018
Definitive Rating Assigned Baa3 (sf)

Cl. B-4, Upgraded to Ba1 (sf); previously on Sep 20, 2018
Definitive Rating Assigned Ba2 (sf)

Cl. B-5, Upgraded to B1 (sf); previously on Sep 20, 2018 Definitive
Rating Assigned B2 (sf)

Flagstar Mortgage Trust 2017-2, Flagstar Mortgage Trust 2018-2,
Flagstar Mortgage Trust 2018-4 and Flagstar Mortgage Trust 2018-5
are backed by pools of prime quality, fixed rate, first-lien
mortgage loans. The loans were originated and serviced by Flagstar
Bank.

The rating upgrades are primarily due to an increase in credit
enhancement available to the bonds and a decrease in its projected
pool losses. The actions reflect the recent strong performance of
the underlying pools with minimal, if any, serious delinquencies to
date.

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 as fewer loans remain in pool ("tail risk"). The
transactions provide for a credit enhancement floor to the senior
bonds which mitigates tail risk by protecting the senior bonds from
eroding credit enhancement over time.

Its updated loss expectations on the pools incorporate, amongst
other factors, its assessment of the representations and warranties
frameworks of the transactions, the due diligence findings of the
third party reviews received at the time of issuance, and the
strength of the transactions' originators and servicers.

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

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.


GOLUB CAPITAL 35B: Moody's Gives Ba3 Rating on $28MM Cl. E-R Notes
------------------------------------------------------------------
Moody's Investors Service assigned ratings to five classes of CLO
refinancing notes issued by Golub Capital Partners CLO 35(B), Ltd.

Moody's rating action is as follows:

US$321,600,000 Class A-R Senior Secured Floating Rate Notes Due
2029 (the "Class A-R Notes"), Assigned Aaa (sf)

US$53,200,000 Class B-R Senior Secured Floating Rate Notes Due 2029
(the "Class B-R Notes"), Assigned Aa2 (sf)

US$25,100,000 Class C-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class C-R Notes"), Assigned A2 (sf)

US$33,500,000 Class D-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class D-R Notes"), Assigned Baa3 (sf)

US$28,600,000 Class E-R Secured Deferrable Floating Rate Notes Due
2029 (the "Class E-R Notes"), Assigned Ba3 (sf)

RATINGS RATIONALE

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

The Issuer is a managed cash flow collateralized loan obligation.
The Refinancing Notes are collateralized primarily by a portfolio
of broadly syndicated senior secured corporate loans. At least
95.0% of the portfolio must consist of first lien senior secured
loans, cash, and eligible investments, and up to 5.0% of the
portfolio may consist of second lien loans and senior unsecured
loans.

OPAL BSL LLC will direct the selection, acquisition and disposition
of the assets on behalf of the Issuer and may engage in trading
activity, including discretionary trading, during the transaction's
remaining two 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 issued the Refinancing Notes on July 22, 2019 in
connection with the refinancing of all classes of the secured notes
originally issued on July 6, 2017. On the Refinancing Date, the
Issuer used proceeds from the issuance of the Refinancing Notes,
along with the proceeds of additional subordinated 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 and additional
subordinated notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: extension of non-call period; changes to certain
collateral quality tests; changes to the overcollateralization test
levels; and the replacement of GC Advisors LLC by OPAL BSL LLC as
Collateral Manager.

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.

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: $502,500,000

Defaulted par: $0

Diversity Score: 60

Weighted Average Rating Factor (WARF): 3013

Weighted Average Spread (WAS): 3.55%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 47.00%

Weighted Average Life (WAL): 7 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 Refinancing Notes is subject to uncertainty.
The performance of the Refinancing 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 Refinancing Notes.


GOLUB CAPITAL 43: Moody's Assigns Ba3 Rating on $24.4MM Cl. E Notes
-------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to six
classes of notes to be issued by Golub Capital Partners CLO 43(B),
Ltd

Moody's rating action is as follows:

US$248,000,000 Class A Senior Secured Floating Rate Notes due 2032
(the "Class A Notes"), Assigned (P)Aaa (sf)

US$30,000,000 Class B-1 Senior Secured Floating Rate Notes due 2032
(the "Class B-1 Notes"), Assigned (P)Aa2 (sf)

US$15,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2032
(the "Class B-2 Notes"), Assigned (P)Aa2 (sf)

US$20,000,000 Class C Secured Deferrable Floating Rate Notes due
2032 (the "Class C Notes"), Assigned (P)A2 (sf)

US$25,000,000 Class D Secured Deferrable Floating Rate Notes due
2032 (the "Class D Notes"), Assigned (P)Baa3 (sf)

US$24,400,000 Class E Secured Deferrable Floating Rate Notes due
2032 (the "Class E Notes"), Assigned (P)Ba3 (sf)

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

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

RATINGS RATIONALE

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

Golub 43(B) is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 95% of the portfolio must consist of
first lien senior secured loans, cash and eligible investments, and
up to 5% of the portfolio may consist of second lien loans and
unsecured loans. Moody's expects the portfolio to be approximately
95% ramped as of the closing date.

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

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

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

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

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

Par amount: $400,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2975

Weighted Average Spread (WAS): 3.30%

Weighted Average Coupon (WAC): 6.50%

Weighted Average Recovery Rate (WARR): 46.5%

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.


GS MORTGAGE 2015-GC34: Fitch Affirms B-sf Rating on Class F Certs
-----------------------------------------------------------------
Fitch Ratings affirmed 15 classes of GS Mortgage Securities Trust
commercial mortgage pass-through certificates, series 2015-GC34.

GSMS 2015-GC34
   
Class A-1 36250VAA0;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-2 36250VAB8;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-3 36250VAC6;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-4 36250VAD4;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-AB 36250VAE2; LT AAAsf  Affirmed;  previously at AAAsf
Class A-S 36250VAH5;  LT AAAsf  Affirmed;  previously at AAAsf
Class B 36250VAJ1;    LT AA-sf  Affirmed;  previously at AA-sf
Class C 36250VAL6;    LT A-sf   Affirmed;  previously at A-sf
Class D 36250VAM4;    LT BBB-sf Affirmed;  previously at BBB-sf
Class E 36250VAP7;    LT BB-sf  Affirmed;  previously at BB-sf
Class F 36250VAR3;    LT B-sf   Affirmed;  previously at B-sf
Class PEZ 36250VAK8;  LT A-sf   Affirmed;  previously at A-sf
Class X-A 36250VAF9;  LT AAAsf  Affirmed;  previously at AAAsf
Class X-B 36250VAG7;  LT AA-sf  Affirmed;  previously at AA-sf
Class X-D 36250VAN2;  LT BBB-sf Affirmed;  previously at BBB-sf

KEY RATING DRIVERS

Increased Loss Expectations: While the majority of the pool
continues to exhibit stable performance, Fitch's loss expectations
have increased since the last rating action, primarily due to the
Fitch Loans of Concern (FLOCs; 14.4% of pool). The Negative Rating
Outlooks on classes E and F reflect concerns over these loans.

Fitch Loans of Concern: Fitch has designated nine loans (14.4% of
pool) as FLOCs, including three of the top 15 loans (8.1%). The
largest FLOC, Bluejay Grocery Portfolio (3.3%), is secured by a
portfolio of four single-tenant grocery store properties located in
secondary and tertiary markets across Wisconsin, Indiana and New
York. Two of the collateral grocery stores (Marsh Kokomo in Kokomo,
IN and Copps Madison in Madison, WI) closed in 2017, reducing the
physical portfolio occupancy to 52.8% as of March 2019 from 100% at
issuance. Although a portion of the former Marsh Kokomo store
(9,200 sf; 3.9% of total portfolio net rentable area [NRA]) was
re-leased to Family Dollar for five years starting in April 2019,
portfolio vacancy remains high, and the Tops Lockport store
recently received a rent reduction due to the grocer's parent
company Chapter 11 bankruptcy filing in February 2018. The second
largest FLOC, Woodlands Corporate Center and 7049 Williams Road
Portfolio (2.8%), is secured by a portfolio of eight office/flex
properties located in Suburban Buffalo, NY, which has experienced
continued cash flow declines and faces a moderate level of lease
rollover through YE 2021. Additionally, the portfolio's largest
tenant, Silipos, received a nearly 47% rent reduction as part of
its recent 10-year lease renewal. The third largest FLOC, Regalia
Mansfield/Dolce (2%), which is secured by a multifamily property in
Mansfield, TX, has been negatively affected by the influx of new
supply in the market and a significant increase in operating
expenses in 2018.

The other FLOCs outside of the top 15 (6.3%) include a portfolio of
three Hyatt-flagged hotel properties in Austin, San Antonio and
Dallas, TX (Hyatt Place Texas Portfolio; 1.5%) with performance
declines following the completion of renovations at each of the
properties in early 2017; a multifamily property in Southfield, MI
(Carnegie Park; 1.5%) that suffered performance declines following
fire damage to 40 of the 176 units in February 2017; and an office
property in Blue Ash, OH (Pfeiffer Woods; 1.3%) with substantial
performance declines following the departure of two major tenants
totaling approximately 55% of the NRA between December 2016 and
March 2017. The remainder of the FLOCs (three loans; combined 2%)
were flagged for declines in occupancy and/or cash flow or exposure
to tenants with recent bankruptcy filings.

Minimal Changes to Credit Enhancement: As of the July 2019
distribution date, the pool's aggregate principal balance has paid
down by 2.4% to $828.1 million from $848.4 million at issuance. The
transaction is expected to pay down by 11.9%, based on scheduled
loan maturity balances. Three loans (8.7% of pool) are full-term
interest only and six loans (33.9%) still have a partial
interest-only component during their remaining loan term compared
to 62.5% of the original pool at issuance. One loan (US Storage
Center Portfolio, 0.5%) is defeased.

ADDITIONAL CONSIDERATIONS

Resolution of Specially Serviced Loan: The third largest loan,
Hammons Hotel Portfolio (8.2% of pool), was returned to the master
servicer on July 1, 2019 after spending nearly two years with the
special servicer and is no longer considered a FLOC. The loan had
transferred to special servicing in July 2016 due to the borrower
and its parent company filing for Chapter 11 bankruptcy. The loan
was reinstated in March 2019 following a transfer of interest to a
qualified equityholder and corresponding settlement. The collateral
hotels have continued to demonstrate stable performance trends
since issuance.  

Pool and Loan Concentrations: The top 10 loans comprise 55.9% of
the current pool by balance. Loans secured by office and retail
properties represent 25.5% and 23% of the pool, respectively.


GS MORTGAGE 2017-GS7: Fitch Affirms B-sf Rating on Cl. H-RR Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed 16 classes of GS Mortgage Securities
Trust 2017-GS7 commercial mortgage pass-through certificates.

GSMS 2017-GS7
   
Class A-1 36254CAS9;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-2 36254CAT7;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-3 36254CAU4;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-4 36254CAV2;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-AB 36254CAW0; LT AAAsf  Affirmed;  previously at AAAsf
Class A-S 36254CAZ3;  LT AAAsf  Affirmed;  previously at AAAsf
Class B 36254CBA7;    LT AA-sf  Affirmed;  previously at AA-sf
Class C 36254CBB5;    LT A-sf   Affirmed;  previously at A-sf
Class D 36254CAA8;    LT BBB+sf Affirmed;  previously at BBB+sf
Class E 36254CAE0;    LT BBB-sf Affirmed;  previously at BBB-sf
Class F-RR 36254CAG5; LT BBB-sf Affirmed;  previously at BBB-sf
Class G-RR 36254CAJ9; LT BB-sf  Affirmed;  previously at BB-sf
Class H-RR 36254CAL4; LT B-sf   Affirmed;  previously at B-sf
Class X-A 36254CAX8;  LT AAAsf  Affirmed;  previously at AAAsf
Class X-B 36254CAY6;  LT A-sf   Affirmed;  previously at A-sf
Class X-D 36254CAC4;  LT BBB-sf Affirmed;  previously at BBB-sf

KEY RATING DRIVERS

Stable Overall Performance: Loss expectations remain stable and
collateral level performance remains in line with issuance
expectations. There are no delinquent or special serviced loans,
and there are no Fitch Loans of Concern. As there have been no
material changes to the pool since issuance, the original rating
analysis was considered in affirming the transaction.

Limited Amortization: There has been minimal change to credit
enhancement since issuance. The pool was securitized in August 2017
and has amortized by only 0.42% since issuance. Twelve loans
representing 65% of the pool, including 10 in the top 15, are
interest-only for the full term and will not amortize at all. An
additional 14 loans representing 19.7% of the pool were structured
with partial interest-only terms and will amortize in the future.

Highly Concentrated Pool: The pool is concentrated and consists of
32 loans, which is well below other Fitch rated 2017 vintage
transactions that average 49 loans. The largest 10 loans compose
64.4% of the pool.

High Office Concentration: The largest property-type concentration
is office at 50.2% of the pool, followed by retail at 16.8% and
mixed-use at 14.9%. The pool's office concentration is
substantially above the 2017 and the 2016 averages for office of
39.8% and 28.7%, respectively, for other Fitch-rated multi-borrower
transactions.


HALCYON LOAN 2014-2: Moody's Lowers Rating on Cl. E Notes to Caa3
-----------------------------------------------------------------
Moody's Investors Service has upgraded the rating on the following
notes issued by Halcyon Loan Advisors Funding 2014-2 Ltd.:

  US$38,500,000 Class B-R Senior Secured Deferrable Floating Rate
  Notes Due April 2025, Upgraded to Aa1 (sf); previously on
  December 5, 2018 Upgraded to Aa3 (sf)

Moody's also downgrades the rating on the following notes:

  US$5,500,000 Class E Senior Secured Deferrable Floating Rate
  Notes Due April 2025, Downgraded to Caa3 (sf); previously on
  December 5, 2018 Downgraded to Caa2 (sf)

Halcyon Loan Advisors Funding 2014-2 Ltd., issued in April 2014 and
partially refinanced in April 2017, is a collateralized loan
obligation (CLO) backed primarily by a portfolio of senior secured
loans. The transaction's reinvestment period ended in April 2018.

RATINGS RATIONALE

The upgrade action is primarily a result of deleveraging of the
senior notes and an increase in the transaction's senior
over-collateralization (OC) ratios since December 2018. The Class
A-1A-R and Class A-1B-R notes have been paid down by approximately
35.0% or $68.6 million since then. Based on the trustee's June 2019
report, the Class B OC ratio is 128.97%, versus the October 2018
level of 122.61%.

The downgrade action on the Class E notes is primarily due to par
erosion and a decrease in the OC ratio. Based on the trustee's June
2019 report, the Class E OC ratio (as reflected in the interest
diversion test ratio) has further decreased to 101.90% from 103.72%
in October 2018.

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

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base case,
Moody's analyzed the collateral pool as having a performing par and
principal proceeds balance of $312.0 million, defaulted par of
$19.7 million, a weighted average default probability of 17.98%
(implying a WARF of 2811), a weighted average recovery rate upon
default of 47.55%, a diversity score of 50 and a weighted average
spread of 3.86% (before accounting for LIBOR floors).

Methodology Underlying the Rating Action:

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


HALCYON LOAN 2015-2: Moody's Cuts Rating on Class F Notes to Caa2
-----------------------------------------------------------------
Moody's Investors Service has upgraded the rating on the following
notes issued by Halcyon Loan Advisors Funding 2015-2 Ltd.:

  US$56,000,000 Class B-R Senior Secured Floating Rate Notes due
  2027, Upgraded to Aaa (sf); previously on October 25, 2018
  Assigned Aa1 (sf)

Moody's also downgraded the rating on the following notes:

  US$10,000,000 Class F Secured Deferrable Floating Rate Notes
  due 2027, Downgraded to Caa2 (sf); previously on June 24, 2015
  Assigned B3 (sf)

Halcyon Loan Advisors Funding 2015-2 Ltd., initially issued in June
2015 and partially refinanced in October 2018, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans. The transaction's reinvestment period will end in July
2019.

RATINGS RATIONALE

The upgrade rating action reflects the benefit of the short period
of time remaining before the end of the deal's reinvestment period
in July 2019. In light of the reinvestment restrictions during the
amortization period which limit the ability of the manager to
effect significant changes to the current collateral pool, Moody's
analyzed the deal assuming a higher likelihood that the collateral
pool characteristics will continue to satisfy certain covenant
requirements. In particular, Moody's assumed that the deal will
benefit from lower WARF and higher spread levels compared to their
trigger levels. Moody's modeled WARF of 2749 and spread of 3.69%
compared to the trigger levels of 2804 and 3.55%, respectively.

On the other hand, the downgrade action on the Class F notes is
primarily due to par erosion and a decrease in the OC ratio since
October 2018. Based on the trustee's June 2019 report, the Class E
OC ratio (as reflected in the interest diversion test ratio) has
decreased to 104.1% from 106.1% in October 2018.

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

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base case,
Moody's analyzed the collateral pool as having a performing par and
principal proceeds balance of $478.9 million, defaulted par of
$18.4 million, a weighted average default probability of 19.58%
(implying a WARF of 2749), a weighted average recovery rate upon
default of 47.53%, a diversity score of 71 and a weighted average
spread of 3.69%.

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.


HAMPTON ROADS: Moody's Hikes 2007-A Cl. II & III Bonds to Ba2
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on Hampton Roads
PPV, LLC, Military Housing Taxable Revenue Bonds, 2007 Series A
Class II Bonds and 2007 Series A Class III Bonds to Ba2 from Ba3
and revised the outlook to stable from positive. Additionally,
Moody's has affirmed the Baa3 rating on Military Housing Taxable
Revenue Bonds, 2007 Series A Class I Bonds and maintained the
stable outlook. Approximately $253 million of outstanding bonds are
affected by this rating action.

RATINGS RATIONALE

The upgrade of Class II Bonds and Class III Bonds to Ba2 from Ba3
reflects Hampton Roads PPV, LLC's improved and sustained financial
performance evidenced by maintenance of healthy debt service
coverage ratios and sound occupancy levels. The healthy coverage
serves as a buffer against potential changes in the Basic Allowance
for Housing, the main source of revenue. However, the type of
tenants (ship-based unaccompanied service members) the Project
serves, the lack of a satisfactory debt service reserve fund (DSRF)
to rely on at times of volatile operating performance, and overall
limited ability to generate excess cash flow to build reserves for
the long-term recapitalization of the Project constrain the
ratings. The affirmation of the Class I Bonds rating indicates that
the improved metrics continue to align with the assigned rating.

RATING OUTLOOK

The outlook is stable based on its expectation that the Project's
financial and operating performance will remain consistent with the
rating levels, supported by demand for the Project and management's
track record of cost control.

FACTORS THAT COULD LEAD TO AN UPGRADE

  - For all tranches, significant and sustained increases in debt
service coverage ratios coupled with strong project occupancy
and/or cash funding of DSRF or replacement of current surety bond
provider with another of higher credit quality.

FACTORS THAT COULD LEAD TO A DOWNGRADE

  - For all tranches, sustained or significant declines in debt
service coverage ratios, occupancy or the BAH with Class II and
Class III bonds being the most vulnerable due to their tighter
coverage relative to Class I Bonds.

LEGAL SECURITY

All three classes of bonds are limited obligations of the Issuer,
Hampton Roads PPV LLC, payable solely from the assets and revenues
pledged under the Indenture, including revenues generated by the
operation of the residential rental housing units, and a first
mortgage lien on the Issuer's leasehold interest in the Project
land and a first mortgage lien on the Project improvements. The
revenues consist primarily of deposit into the Trust Indenture of
the BAH for military tenants.

PROFILE

The Issuer and Borrower, is Hampton Roads PPV, LLC a limited
liability company. The issuer has two members: Homeport Hampton
Roads, LLC, (HHR), Managing Member, and The United States of
America, Department of the Navy (DON). HHR has two members: Hunt
ELP LTD. An affiliate of Hunt Building Company, and ACC OP (Hampton
Roads), LLC, an affiliate of American Campus Communities Inc.
(ACC). Hampton Roads PPV, LLC was created on December 2007, under
the PPP program. It contracted with the DOD for the acquisition,
development, management and operation of the Project located in
Norfolk and Newport News, Virginia. The term of the contract is 50
years, expiring in 2057.


HAYFIN KINGSLAND XI: Moody's Rates $22.8MM Class E Notes 'Ba3'
--------------------------------------------------------------
Moody's Investors Service assigned ratings to five classes of debt
issued by Hayfin Kingsland XI, Ltd.

Moody's rating action is as follows:

US$256,000,000 Class A Loans maturing in 2032 (the "Class A
Loans"), Definitive Rating Assigned Aaa (sf)

US$39,600,000 Class B Senior Secured Floating Rate Notes Due 2032
(the "Class B Notes"), Definitive Rating Assigned Aa2 (sf)

US$20,200,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes Due 2032 (the "Class C Notes"), Definitive Rating Assigned A2
(sf)

US$26,600,000 Class D Mezzanine Secured Deferrable Floating Rate
Notes Due 2032 (the "Class D Notes"), Definitive Rating Assigned
Baa3 (sf)

US$22,800,000 Class E Junior Secured Deferrable Floating Rate Notes
Due 2032 (the "Class E Notes"), Definitive Rating Assigned Ba3
(sf)

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

RATINGS RATIONALE

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

Hayfin Kingsland XI is a managed cash flow CLO. The issued debt
will be collateralized primarily by broadly syndicated senior
secured corporate loans. At least 92.5% of the portfolio must
consist of senior secured loans, and up to 7.5% of the portfolio
may consist of second lien loans or unsecured loans. The portfolio
is approximately 80% ramped as of the closing date.

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

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

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

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

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

Par amount: $400,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 3009

Weighted Average Spread (WAS): 3.50%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 47.0%

Weighted Average Life (WAL): 9.0 years

Methodology Underlying the Rating Action:

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

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

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


JP MORGAN 2019-MFP: Moody's Assigns B3 Rating on Class F Certs
--------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to seven
classes of CMBS securities, issued by J.P. Morgan Chase Commercial
Mortgage Securities Trust 2019-MFP, Commercial Mortgage
Pass-Through Certificates, Series 2019-MFP:

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. X-CP*, Definitive Rating Assigned A3 (sf)

Cl. B, Definitive Rating Assigned Aa3 (sf)

Cl. C, Definitive Rating Assigned A3 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba3 (sf)

Cl. F, Definitive Rating Assigned B3 (sf)

* Reflects interest-only classes

RATINGS RATIONALE

The certificates are collateralized by one floating rate loan
secured by a fee simple interests in 43 multifamily properties
located across 10 states. Collectively, the properties include a
total of 8,671 apartment units. The ratings are based on the
collateral and the structure of the transaction.

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

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

Moody's DSCR is based on its assessment of the portfolio's
stabilized NCF. The Moody's first mortgage DSCR is 1.39x and
Moody's first mortgage DSCR at a 9.25% stressed constant is 0.76x.

The trust loan balance of $481.0 million represents a Moody's LTV
ratio of 131.5% which is greater than the 2018 Large Loan and
Single Asset/Single Borrower CMBS transaction average 108.3%.

Moody's also considers both loan level diversity and property level
diversity when selecting a ratings approach. The pool's loan level
HERF is 31.

Positive features of the transaction include location, property
type, geographic diversity, portfolio granularity, substantial
capital improvement reserves, and strong sponsorship. Offsetting
these strengths are the high Moody's LTV, the loan's floating-rate
and interest-only mortgage loan profile, the portfolio average age
and quality, cash management structure, and certain legal
considerations.

Moody's also grades properties on a scale of 0 to 5 (best to worst)
and considers those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The collateral's
overall property quality grade is 2.75.

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

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

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

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

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

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

The ratings do not represent any assessment of (i) the likelihood
or frequency of prepayment on the mortgage loans, (ii) the
allocation of net aggregate prepayment interest shortfalls, (iii)
whether or to what extent prepayment premiums might be received, or
(iv) in the case of any class of interest-only certificates, the
likelihood that the holders thereof might not fully recover their
investment in the event of a rapid rate of prepayment of the
mortgage loans.


KAYNE CLO 5: Moody's Assigns Ba3 Rating on $26.2MM Class E Notes
----------------------------------------------------------------
Moody's Investors Service assigned ratings to six classes of notes
issued by Kayne CLO 5, Ltd.

Moody's rating action is as follows:

  US$281,600,000 Class A Senior Secured Floating Rate Notes due
  2032 (the "Class A Notes"), Assigned Aaa (sf)

  US$27,950,000 Class B-1 Senior Secured Floating Rate Notes due
  2032 (the "Class B-1 Notes"), Assigned Aa2 (sf)

  US$20,000,000 Class B-2 Senior Secured Fixed Rate Notes due  
  2032 (the "Class B-2 Notes"), Assigned Aa2 (sf)

  US$21,350,000 Class C Mezzanine Secured Deferrable Floating
  Rate Notes due 2032 (the "Class C Notes"), Assigned A2 (sf)

  US$26,400,000 Class D Mezzanine Secured Deferrable Floating
  Rate Notes due 2032 (the "Class D Notes"), Assigned Baa3 (sf)

  US$26,200,000 Class E Junior Secured Deferrable Floating Rate
  Notes due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

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

RATINGS RATIONALE

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

Kayne CLO 5 is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 95% of the portfolio must consist of
first lien senior secured loans, cash and eligible investments, and
up to 5% of the portfolio may consist of second lien loans and
unsecured loans. The portfolio is approximately 85% ramped as of
the closing date.

Kayne Anderson Capital Advisors, L.P. (the "Manager") 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 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: $440,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2850

Weighted Average Spread (WAS): 3.15%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 48.0%

Weighted Average Life (WAL): 9.0 years

Methodology Underlying the Rating Action:

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

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

The performance of the Rated 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.


KEY COMMERCIAL 2019-S2: DBRS Finalizes B Rating on Class F Certs
----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2019-S2 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 X 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 X balance is notional.

The collateral consists of 29 fixed-rate loans secured by 36
commercial and multifamily properties. The transaction employs 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 the loss of 2.5%.

Class X 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.


MONARCH BEACH 2018-MBR: DBRS Confirms B(high) Rating on G Certs
---------------------------------------------------------------
DBRS, Inc. confirmed all classes of Commercial Mortgage
Pass-Through Certificates, Series 2018-MBR issued by Monarch Beach
Resort Trust 2018-MBR (the Trust):

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

All trends are Stable.

The rating confirmations reflect the stable performance of the
transaction since issuance. The first mortgage loan is secured by a
400-key, five-diamond luxury resort located along the Southern
California coastline in Dana Point, California. Originally
constructed in 2001, the property offers an award-winning 18-hole
championship golf course, eight food and beverage outlets, a 30,000
square foot (sf) destination wellness spa and access to an
exclusive private beach club. The sponsor, KSL Capital Partners,
acquired the asset in 2014 for $316.9 million and invested $47.6
million ($119,100 per key) in renovations prior to issuance. The
$238.0 million interest-only (IO) trust loan and $102.0 million of
mezzanine debt retired $226.1 million of existing debt, returned
$107.9 million of sponsor equity and covered closing costs. The
sponsor had approximately $25.0 million of cash equity remaining in
the project at issuance.

The subject's financial performance continued to improve in 2018,
following the extensive renovation that was completed in 2016. The
Trust loan reported a year-end (YE) 2018 debt service coverage
ratio (DSCR) of 2.41 times (x) compared with the DBRS Term DSCR of
1.75x derived at issuance. The DSCR improvement over the DBRS
figures at issuance is a factor of a lower in-place interest rate
compared with the stressed scenario assumed by DBRS at issuance as
well as a 9.8% increase in the in-place cash flows at YE2018 over
the DBRS Net Cash Flow figure derived at issuance. The YE2018 DSCR,
inclusive of the mezzanine debt, was reported at 1.25x.

According to the trailing 12-month (T-12) ending December 2018
Smith Travel Research report, the subject's occupancy rate, average
daily rate (ADR) and revenue per available room (RevPAR) were
64.6%, $393.16 and $253.97, respectively. These figures were an
improvement over the T-12 ending December 2017 occupancy rate, ADR
and RevPAR of 61.6%, $382.80 and $235.76, respectively. However,
the resort underperformed compared with the competitive set's
occupancy rate, ADR and RevPAR of 70.7%, $429.09 and $303.33,
respectively. The subject caters to more corporate clients rather
than leisure clients as the subject features more meeting spaces
and ballrooms compared to its competitors. The reliance on group
demand to fill a large majority of room nights yields additional
risk, should corporations cut back on event spending at upscale
resorts.

The 161-room Rosewood Miramar Beach Montecito, identified in the
appraisal as a potential competitor, had its grand opening on April
2019. DBRS did not consider this as a direct competitor as the
property is located 153 miles north of the collateral near Santa
Barbara, California. Rosewood Miramar Beach Montecito also is
considerably smaller than the subject and seems to focus more on
the luxury leisure guest, whereas the Monarch Beach Resort is
heavily focused on group and event bookings. No additional new
supply was identified at this time and the subject continues to
benefit from high barriers to entry.

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.


MORGAN STANLEY 2019-H7: Fitch Rates $8.403MM Class G-RR Debt 'B-sf'
-------------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Morgan Stanley Capital I Trust 2019-H7 commercial
mortgage pass-through certificates, series 2019-H7:

  -- $19,200,000 class A-1 'AAAsf'; Outlook Stable;

  -- $29,900,000 class A-2 'AAAsf'; Outlook Stable;

  -- $26,600,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $205,000,000 class A-3 'AAAsf'; Outlook Stable;

  -- $242,191,000 class A-4 'AAAsf'; Outlook Stable;

  -- $522,891,000b class X-A 'AAAsf'; Outlook Stable;

  -- $130,723,000b class X-B 'A-sf'; Outlook Stable;

  -- $62,560,000 class A-S 'AAAsf'; Outlook Stable;

  -- $33,614,000 class B 'AA-sf'; Outlook Stable;

  -- $34,549,000 class C 'A-sf'; Outlook Stable;

  -- $15,873,000ab class X-D 'BBBsf'; Outlook Stable;

  -- $15,873,000a class D 'BBBsf'; Outlook Stable;

  -- $22,410,000ac class E-RR 'BBB-sf'; Outlook Stable;

  -- $17,741,000ac class F-RR 'BB-sf'; Outlook Stable;

  -- $8,403,000abc class G-RR 'B-sf'; Outlook Stable.

The following class is not rated by Fitch:

  -- $28,946,514ac class H-RR.

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

(b) Notional amount and interest-only.

(c) Horizontal credit risk retention interest.

The ratings are based on information provided by the issuer as of
July 24, 2019.

Since Fitch published its expected ratings on July 9, 2019, the
following changes have occurred: The balances for class A-3 and
class A-4 were finalized. At the time that the expected ratings
were assigned, the exact initial certificate balances of class A-3
and class A-4 were unknown and expected to be within the range of
$100,000,000 - $205,000,000 and $242,191,000 - $347,191,000,
respectively. The final class balances for class A-3 and class A-4
are $205,000,000 and $242,191,000, respectively.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 53 loans secured by 81
commercial properties having an aggregate principal balance of
$746,987,514 as of the cut-off date. The loans were contributed to
the trust by Morgan Stanley Mortgage Capital Holdings LLC, Argentic
Real Estate Finance LLC, Starwood Mortgage Capital LLC and Cantor
Commercial Real Estate Lending, L.P.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 69.1% of the properties
by balance, cash flow analysis of 81.9% of the pool and asset
summary reviews on 100.0% of the pool.

KEY RATING DRIVERS

High Fitch Leverage: The pool's Fitch loan-to-value (LTV) is
106.3%, which is above the 2018 and 2019 YTD average of 102.0% for
other Fitch-rated multiborrower transactions. Additionally, the
pool's Fitch debt service coverage ratio (DSCR) of 1.17x is lower
than the 2018 and 2019 YTD averages of 1.22x and 1.21x,
respectively.

Investment-Grade Credit Opinion Loans: Three loans, representing
14.5% of the pool, received an investment-grade credit opinion on a
stand-alone basis. This is above the 2018 and 2019 YTD averages of
13.6% and 12.7%, respectively. Net of these loans, the Fitch LTV
and DSCR are 111.9% and 1.17x, respectively, for this transaction.
Loans with investment-grade credit opinions include Shoppes at
Grand Canal (9.4%), Tower 28 (3.5%), and 3 Columbus Circle (1.7%).
Each of these loans received an investment-grade credit opinion of
'BBB-sf*'.

Above-Average Pool Diversification: The pool is more diverse than
recent Fitch-rated transactions. The largest 10 loans comprise
48.5% of the pool, which is lower than the average top 10
concentrations for 2018 and 2019 YTD of 52.0% and 50.6%,
respectively. The concentration results in an LCI of 360, which is
lower than the 2018 and 2019 YTD averages of 373 and 392,
respectively. Additionally, the pool's SCI is lower than the 2018
average of 398 and 2019 YTD average of 412.


NEWSTAR CLARENDON: Moody's Affirms Ba3 Rating on Class E Notes
--------------------------------------------------------------
Moody's Investors Service assigned ratings to three classes of CLO
refinancing notes issued by NewStar Clarendon Fund CLO LLC.

Moody's rating action is as follows:

  US$188,383,544 Class A-R Senior Secured Floating Rate Notes due
  2027 (the "Class A-R Notes"), Assigned Aaa (sf)

  US$42,700,000 Class B-R Senior Secured Floating Rate Notes due
  2027 (the "Class B-R Notes"), Assigned Aa1 (sf)

  US$25,500,000 Class C-R Secured Deferrable Floating Rate Notes
  due 2027 (the "Class C-R Notes"), Assigned A1 (sf)

Additionally, Moody's has taken rating actions on the following
outstanding notes originally issued by the Issuer on January 15,
2015:

  US$24,700,000 Class D Secured Deferrable Floating Rate Notes
  Due 2027 (the "Class D Notes"), Upgraded to Baa2 (sf);
  previously on January 15, 2015 Assigned Baa3 (sf)

  US$33,300,000 Class E Secured Deferrable Floating Rate Notes
  Due 2027 (the "Class E Notes"), Affirmed Ba3 (sf); previously
  on January 15, 2015 Assigned Ba3 (sf)

RATINGS RATIONALE

The rationale for the ratings is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in its methodology. In particular, the rating actions on
the Class D and Class E Notes is supported by the refinancing,
which increases excess spread available as credit enhancement to
the rated notes. Additionally, the upgrade rating action on the
Class D Notes results from deleveraging of the deal since the end
of the reinvestment period in January 2019.

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

First Eagle Private Credit, LLC will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may not engage in trading activity since the transaction's
reinvestment period ended in January 2019.

The Issuer has issued the Refinancing Notes on July 25, 2019 in
connection with the refinancing of certain classes of secured notes
originally issued on January 15, 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 two classes of subordinated
notes that remain outstanding.

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: $338,206,551

Defaulted par: $16,790,467.50

Diversity Score: 45

Weighted Average Rating Factor (WARF): 4033 (corresponding to a
weighted average default probability of 26.02%)

Weighted Average Spread (WAS): 4.97%

Weighted Average Recovery Rate (WARR): 47.09%

Weighted Average Life (WAL): 3.52 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.


OCP CLO 2019-17: Moody's Assigns Ba3 Rating on $20MM Cl. E Notes
----------------------------------------------------------------
Moody's Investors Service assigned ratings to five classes of notes
issued by OCP CLO 2019-17, Ltd.

Moody's rating action is as follows:

US$1,500,000 Class X Senior Secured Floating Rate Notes due 2032
(the "Class X Notes"), Assigned Aaa (sf)

US$305,000,000 Class A-1 Senior Secured Floating Rate Notes due
2032 (the "Class A-1 Notes"), Assigned Aaa (sf)

US$10,000,000 Class A-2A Senior Secured Floating Rate Notes due
2032 (the "Class A-2A Notes"), Assigned Aaa (sf)

US$10,000,000 Class A-2B Senior Secured Fixed Rate Notes due 2032
(the "Class A-2B Notes"), Assigned Aaa (sf)

US$20,000,000 Class E Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

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

RATINGS RATIONALE

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

OCP 2019-17 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
first lien senior secured loans, cash, and eligible investments,
and up to 10% of the portfolio may consist of second lien loans and
unsecured loans. The portfolio is approximately 75% ramped as of
the closing date.

Onex Credit Partners, LLC (the "Manager") 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 four other
classes of secured notes, one class of preference shares, 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: $500,000,000

Diversity Score: 75

Weighted Average Rating Factor (WARF): 2699

Weighted Average Spread (WAS): 3.10%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 48.50%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

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


OCTAGON INVESTMENT 44: Moody's Rates $23.750MM Class E Notes 'Ba3'
------------------------------------------------------------------
Moody's Investors Service assigned ratings to two classes of notes
issued by Octagon Investment Partners 44, Ltd.

Moody's rating action is as follows:

  US$325,000,000 Class A Senior Secured Floating Rate Notes
  due 2032 (the "Class A Notes"), Assigned Aaa (sf)

  US$23,750,000 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 ratings is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in its methodology.

Octagon 44 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
first lien senior secured loans, cash, and eligible investments,
and up to 10% of the portfolio may consist of second lien loans and
unsecured loans. The portfolio is approximately 80% ramped as of
the closing date.

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

In addition to the Rated Notes, the Issuer issued three 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: $500,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 3100

Weighted Average Spread (WAS): 3.55%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.50%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

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

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

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


RAAC TRUST 2006-SP3: Moody's Hikes Class M-2 Debt Rating to Caa1
----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of six tranches from
four transactions, backed by Scratch and Dent mortgage loans,
issued by Residential Asset Mortgage Products, Inc., acting as the
Depositary.

The complete rating actions are as follows:

Issuer: RAAC Series 2005-RP1 Trust

Cl. M-3, Upgraded to Aaa (sf); previously on Oct 19, 2018 Upgraded
to Aa2 (sf)

Issuer: RAAC Series 2006-RP1 Trust

Cl. M-2, Upgraded to Aa3 (sf); previously on Jan 30, 2018 Upgraded
to A2 (sf)

Issuer: RAAC Series 2006-SP3 Trust

Cl. M-1, Upgraded to Aa1 (sf); previously on Jan 30, 2018 Upgraded
to A1 (sf)

Cl. M-2, Upgraded to Caa1 (sf); previously on Feb 14, 2017 Upgraded
to Caa3 (sf)

Issuer: RAAC Series 2007-SP2 Trust

Cl. A-2, Upgraded to A2 (sf); previously on Feb 20, 2018 Upgraded
to Baa1 (sf)

Cl. A-3, Upgraded to Baa1 (sf); previously on Feb 20, 2018 Upgraded
to Baa3 (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to an improvement in the
credit enhancement available to the bonds. The rating actions also
reflect the recent performance and Moody's updated loss
expectations on the underlying pools.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in June 2019 from 4.0% in June
2018. Moody's forecasts an unemployment central range of 3.5% to
4.5% for the 2019 year. Deviations from this central scenario could
lead to rating actions in the sector. House prices are another key
driver of US RMBS performance. Moody's expects house prices to
continue to rise in 2019. Lower increases than Moody's expects or
decreases could lead to negative rating actions. Finally,
performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
this transaction.


SASCO TRUST 2005-9XS: Moody's Hikes Rating on Class M1 Debt to B2
-----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of Cl. M1 from
Structured Asset Securities Corp (SASCO) Trust 2005-9XS, backed by
Alt-A loans.

Complete rating actions are as follow:

Issuer: Structured Asset Securities Corp Trust 2005-9XS

Cl. M1, Upgraded to B2 (sf); previously on Dec 24, 2018 Upgraded to
Caa2 (sf)

RATINGS RATIONALE

The rating action reflects the recent performance of the underlying
pools and Moody's updated loss expectations. The rating upgrade is
primarily due to improved underlying collateral pool performance
and an increase in credit enhancement available to the bond.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.7% in June 2019 from 4.0% in June
2018. Moody's forecasts an unemployment central range of 3.5% to
4.5% for the 2019 year. Deviations from this central scenario could
lead to rating actions in the sector.

House prices are another key driver of US RMBS performance. Moody's
expects house prices to continue to rise in 2019. Lower increases
than Moody's expects or decreases could lead to negative rating
actions.


SBL COMMERCIAL 2016-KIND: Moody's Affirms B3 Rating on Cl. F Certs
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings on eight classes in
SBL Commercial Mortgage Trust 2016-KIND, Commercial Mortgage
Pass-Through Certificates, Series 2016-KIND as follows:

Cl. A, Affirmed Aaa (sf); previously on Feb 14, 2018 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa3 (sf); previously on Feb 14, 2018 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on Feb 14, 2018 Affirmed A3
(sf)

Cl. D, Affirmed Baa3 (sf); previously on Feb 14, 2018 Affirmed Baa3
(sf)

Cl. E, Affirmed Ba3 (sf); previously on Feb 14, 2018 Affirmed Ba3
(sf)

Cl. F, Affirmed B3 (sf); previously on Feb 14, 2018 Affirmed B3
(sf)

Cl. G, Affirmed Caa2 (sf); previously on Feb 14, 2018 Affirmed Caa2
(sf)

Cl. X*, Affirmed Aa3 (sf); previously on Feb 14, 2018 Affirmed Aa3
(sf)

* Reflects interest-only classes

RATINGS RATIONALE

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

The rating on the interest only (IO) class was affirmed based on
the credit quality of the referenced classes.

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,defeasance of
the loan, or an improvement in loan performance.

Factors that could lead to a downgrade of the ratings include a
decline in the performance of the loan or interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the July 11, 2019 Payment Date, the transaction's aggregate
certificate balance has decreased to approximately $545 million
from $550 million at securitization due to scheduled amortization.
The fixed rate loan matures in November 2025 and calls for
amortization equal to 0.25% annually during years 1-3; 0.50%
annually during years 4-5; 1.0% annually during years 6-8 and 2.0%
annually thereafter. The Borrower may prepay the loan, in whole or
in part, at any time without penalty or premium.

The certificates are collateralized by a single loan backed by a
first lien commercial mortgage related to a portfolio of 550 early
childhood education centers operated by KinderCare, a leading
operator of for-profit early childhood education centers. All 550
properties are subject to a 15-year absolute triple net Master
Lease with a fixed base rent for the first five years with rent
bumps in the fifth and tenth lease years equal to the lesser of (i)
10% of the prior year's rent and (ii) the All Urban Consumers, All
Items, Not Seasonally Adjusted CPI increase. The Master Lease
includes two, five-year extensions for all of the sites with at
least twelve months prior notice.

The loan collateral is comprised of the borrower's fee interest in
550 childcare centers located across 37 states. Three states make
up 30% of the portfolio's total square footage including Illinois
(60 properties; 13% of the allocated loan amount; 11% of total
square footage), California (49 properties; 13% of the allocated
loan amount; 10% of total square footage), and Texas (50
properties; 7% of the allocated loan amount; 9% of total square
footage). The portfolio's occupancy for the trailing twelve month
period ending March 2019 was 69.2%, compared to the same period in
the prior year of 68.8%. The overall occupancy has continued to
increase since securitization.

The first mortgage balance of $545 million represents a Moody's
stabilized LTV of 116%. Inclusive of the $90.0 million mezzanine
loan held outside of the trust, the Moody's stabilized LTV is 136%.
Moody's first mortgage stressed debt service coverage ratio (DSCR)
is 1.21X and Moody's total stressed DSCR is 1.04X. There are no
outstanding interest shortfalls or losses as of the current Payment
Date.


SEQUOIA MORTGAGE 2019-CH2: Moody's Gives B1 Rating on Cl. B-4 Debt
------------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to the
classes of residential mortgage-backed securities issued by Sequoia
Mortgage Trust 2019-CH2, except for the interest-only classes. The
certificates are backed by one pool of prime quality, first-lien
mortgage loans.

SEMT 2019-CH2 is the eighth securitization that includes loans
acquired by Redwood Residential Acquisition Corporation, a
subsidiary of Redwood Trust, Inc., under its expanded credit prime
loan program called "Redwood Choice". Redwood's Choice program is a
prime program with credit parameters outside of Redwood's
traditional prime jumbo program, "Redwood Select". The Choice
program expands the low end of Redwood's FICO range to 661 from
700, while increasing the high end of eligible loan-to-value ratios
from 85% to 90%. The pool also includes loans with non-QM
characteristics (34.2%), such as debt-to-income ratios up to
55.68%. Non-QM loans were acquired by Redwood under each of the
Select and Choice programs.

The assets of the trust consist of fixed-rate fully amortizing
loans and one interest only loan. The mortgage loans have an
original term to maturity of 30 years except for two loans which
have an original term to maturity of 20 years. The loans were
sourced from multiple originators and acquired by Redwood.

All of the loans conform to the Seller's guidelines, except for
loans originated by First Republic Bank with Redwood overlays, TIAA
FSB (FKA EverBank), high balance agency conforming loans
underwritten to GSE guidelines with Redwood overlays and loans
purchased under reliance letter. One loan from loan Depot was
purchased on a reliance letter and underwritten to loan Depot
guidelines. The two out of eight loans from Guaranteed Rate were
purchased based on reliance letter and underwritten to Guaranteed
Rate Flex Jumbo guidelines. First Republic Bank originated loans
conform with First Republic Bank's guidelines with Redwood
overlays.

The transaction benefits from nearly 100% due diligence of data
integrity, credit, property valuation, and compliance conducted by
an independent third-party firm.

Nationstar Mortgage LLC (d.b.a. "Mr. Cooper Group Inc.") will act
as the master servicer of the loans in this transaction. Shellpoint
Mortgage Servicing ("Shellpoint"), Quicken Loans Inc. ("Quicken
Loans"), TIAA, FSB, First Republic Bank and HomeStreet Bank will be
primary servicers on the deal.

The complete rating actions are as follows:

Issuer: Sequoia Mortgage Trust 2019-CH2

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Cl. B-4, Definitive Rating Assigned B1 (sf)

RATINGS RATIONALE

Summary Credit Analysis

Moody's expected cumulative net loss on the aggregate pool is 0.85%
in a base scenario and reaches 9.65% at a stress level consistent
with Aaa (sf) ratings. The MILAN CE may be different from the
credit enhancement that is consistent with a Aaa (sf) rating for a
tranche, because the MILAN CE does not take into account the
structural features of the transaction. Moody's took this
difference into account in its ratings of the senior classes. Its
loss estimates are based on a loan-by-loan assessment of the
securitized collateral pool using Moody's Individual Loan Level
Analysis (MILAN) model. Loan-level adjustments to the model
included: adjustments to borrower probability of default for higher
and lower borrower DTIs, borrowers with multiple mortgaged
properties, self-employed borrowers, origination channels and at a
pool level, for the default risk of HOA properties in super lien
states. The adjustment to its Aaa stress loss above the model
output also includes adjustments related to origination quality.
The model combines loan-level characteristics with economic drivers
to determine the probability of default for each loan, and hence
for the portfolio as a whole. Severity is also calculated on a
loan-level basis. The pool loss level is then adjusted for
borrower, zip code, and MSA level concentrations.

Collateral Description

The SEMT 2019-CH2 transaction is a securitization of 474 first lien
residential mortgage loans, with an aggregate unpaid principal
balance of $348,773,680. Five loans dropped from the pool compared
to the provisional ratings. Moody's revised its Aaa (sf) stress
level loss projection to 9.65% as compared to 9.70% in provisional
ratings, due to slight changes in the collateral composition. There
are 115 originators in this pool. 87.7% of the loans by balance are
serviced by Shellpoint and 8.5% by Quicken Loans. The remaining
originators contributed less than 5% of the principal balance of
the loans in the pool. The loan-level third party due diligence
review (TPR) encompassed credit underwriting, property value and
regulatory compliance. In addition, Redwood has agreed to backstop
the rep and warranty repurchase obligation of all originators other
than First Republic Bank.

SEMT 2019-CH2 includes loans acquired by Redwood under its Choice
program. Although the borrowers in SEMT 2019-CH2 are not the super
prime borrowers included in traditional SEMT transactions from a
FICO and LTV perspective, these borrowers are prime borrowers with
a demonstrated ability to manage household finance. On average,
borrowers in this pool have made a 23.7% down payment on a mortgage
loan of $735,809. In addition, 67.3% of borrowers have more than 24
months of liquid cash reserves or enough money to pay the mortgage
for two years should there be an interruption to the borrower's
cash flow. The WA FICO is 746, which is lower than traditional SEMT
transactions, which has averaged 771 in 2018 SEMT transactions. The
lower WA FICO for SEMT 2019-CH2 may reflect recent mortgage lates
(0x30x3, 1x30x12, 2x30x24) which are allowed under the Choice
program, but not under Redwood's traditional product, Redwood
Select (0x30x24). While the WA FICO may be lower for this
transaction compared to previous transactions, Moody's believes
that the limited mortgage lates are less likely to demonstrate a
history of financial mismanagement.

Moody's also notes that SEMT 2019-CH2 is the eighth SEMT Choice
transaction to include a slightly lower number of non-QM loans
(139) compared to SEMT 2019-CH1 (151) SEMT 2018-CH3 (155), SEMT
2018-CH2 (156) and SEMT 2018-CH1 (157) with the exception of SEMT
2018-CH4 (148).

Redwood's Choice program was launched by Redwood in April 2016. In
contrast to Redwood's traditional program, Select, Redwood's Choice
program allows for higher LTVs, lower FICOs, non-occupant
co-borrowers, non-warrantable condos, limited loans with adverse
credit events, among other loan attributes. Under both Select and
Choice, Redwood also allows for loans with non-QM features, such as
interest-only, DTIs greater than 43%, asset depletion, among other
loan attributes.

However, Moody's notes that Redwood historically has been on
average stronger than its peers as an aggregator of prime jumbo
loans, including a limited number of non-QM loans in previous SEMT
transactions. As of the June 2019 remittance report, there have
been no losses on Redwood-aggregated transactions that Moody's has
rated recently, and delinquencies to date have also been very low.
While in traditional SEMT transactions, Moody's has factored this
qualitative strength into its analysis, in SEMT 2019-CH2, Moody's
has a neutral assessment of the Choice Program until Moody's is
able to review a longer performance history of Choice mortgage
loans.

Structural considerations

Similar to recent rated Sequoia Mortgage Trust transactions, in
this transaction, Redwood is adding a feature prohibiting the
servicer, or securities administrator, from advancing principal and
interest to loans that are 120 days or more delinquent. These loans
on which principal and interest advances are not made are called
the Stop Advance Mortgage Loans. The balance of the SAML will be
removed from the principal and interest distribution amounts
calculations. Moody's views the SAML concept as something that
strengthens the integrity of senior and subordination relationships
in the structure. Yet, in certain scenarios the SAML concept, as
implemented in this transaction, can lead to a reduction in
interest payment to certain tranches even when more subordinated
tranches are outstanding. The senior/subordination relationship
between tranches is strengthened as the removal of SAML in the
calculation of the senior percentage amount, directs more principal
to the senior bonds and less to the subordinate bonds. Further,
this feature limits the amount of servicer advances that could
increase the loss severity on the liquidated loans and preserves
the subordination amount for the most senior bonds. On the other
hand, this feature can cause a reduction in the interest
distribution amount paid to the bonds; and if that were to happen
such a reduction in interest payment is unlikely to be recovered.
The final ratings on the bonds, which are expected loss ratings,
take into consideration its expected losses on the collateral and
the potential reduction in interest distributions to the bonds.
Furthermore, the likelihood that in particular the subordinate
tranches could potentially permanently lose some interest as a
result of this feature was considered. As such, Moody's
incorporated some additional sensitivity runs in its cashflow
analysis in which Moody's increases the tranche losses due to
potential interest shortfalls during the loan's liquidation period
in order to reflect this feature and to assess the potential impact
to the bonds.

Moody's believes there is a low likelihood that the rated
securities of SEMT 2019-CH2 will incur any losses from
extraordinary expenses or indemnification payments owing to
potential future lawsuits against key deal parties. First, the
loans are prime quality and were originated under a regulatory
environment that requires tighter controls for originations than
pre-crisis, which reduces the likelihood that the loans have
defects that could form the basis of a lawsuit. Second, Redwood (or
a majority-owned affiliate of the sponsor), who will retain credit
risk in accordance with the U.S. Risk Retention Rules and provides
a back-stop to the representations and warranties of all the
originators except for First Republic Bank, has a strong alignment
of interest with investors, and is incentivized to actively manage
the pool to optimize performance. Third, the transaction has
reasonably well defined processes in place to identify loans with
defects on an ongoing basis. In this transaction, an independent
breach reviewer must review loans for breaches of representations
and warranties when a loan becomes 120 days delinquent, which
reduces the likelihood that parties will be sued for inaction.

Tail Risk & Senior Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
shrinks, senior bonds are exposed to increased performance
volatility, known as tail risk. The transaction provides for a
senior subordination floor of 1.90% ($6,626,699) of the closing
pool balance, which mitigates tail risk by protecting the senior
bonds from eroding credit enhancement over time.

Third-party Review and Reps & Warranties

Two TPR firms conducted a due diligence review of 100% of the
mortgage loans in the pool. For 474 loans, the TPR firm conducted a
review for credit, property valuation, compliance and data
integrity ("full review") and limited review for 4 First Republic
and PrimeLending loans. For the 4 loans, Redwood Trust elected to
conduct a limited review, which did not include a TPR firm check
for TRID compliance.

For the full review loans, the third party review found that the
majority of reviewed loans were compliant with Redwood's
underwriting guidelines and had no valuation or regulatory defects.
Most of the loans that were not compliant with Redwood's
underwriting guidelines had strong compensating factors.
Additionally, the third party review didn't identify material
compliance-related exceptions relating to the TILA-RESPA Integrated
Disclosure (TRID) rule for the full review loans.

No TRID compliance reviews were performed on the three
PrimeLending, and one First Republic Bank limited review loans.
Therefore, there is a possibility that some of these loans could
have unresolved TRID issues. Moody's reviewed the initial
compliance findings of loans for the First Republic Bank and
PrimeLending loans where a full review was conducted. The due
diligence report did not indicate any significant credit, valuation
or compliance concerns. As a result, Moody's did not increase its
Aaa loss.

The property valuation review conducted by the TPR firm consisted
of (i) a review of all of the appraisals for full review loans,
checking for issues with the comparables selected in the appraisal
and (ii) a value supported analysis for all loans. After a review
of the TPR appraisal findings, Moody's found the exceptions to be
minor in nature and did not pose a material increase in the risk of
loan loss. Moody's notes that there are 5 loans with final grade
'D' due to escrow holdback distribution amounts. The review for
these loans was incomplete because the related appraisals were
subject to the completion of renovation work or missing evidence of
disbursement of escrow funds. In the event the escrow funds greater
than 10% have not been disbursed within six months of the closing
date, the seller shall repurchase the affected escrow holdback
mortgage loan, on or before the date that is six months after the
closing date at the applicable repurchase price. Given that the
seller has the obligation to repurchase, Moody's did not make an
adjustment for these loans.

Moody's has received the results of the inspection report or
appraisal confirmation for all the mortgage loans secured by
properties in the areas affected by FEMA disaster areas. The
results indicate that the properties did not receive any material
damage. SEMT 2019-CH2 includes a representation that the pool does
not include properties with material damage that would adversely
affect the value of the mortgaged property.

The originators and Redwood have provided unambiguous
representations and warranties (R&Ws) including an unqualified
fraud R&W. There is provision for binding arbitration in the event
of dispute between investors and the R&W provider concerning R&W
breaches.

Trustee & Master Servicer

The transaction trustee is Wilmington Trust, National Association.
The paying agent and cash management functions will be performed by
Citibank, N.A. (Citibank) and the custodian functions will be
performed by Wells Fargo Bank, N.A., rather than the trustee. In
addition, Nationstar Mortgage LLC, as Master Servicer, is
responsible for servicer oversight, and termination of servicers
and for the appointment of successor servicers. In addition,
Nationstar Mortgage LLC is committed to act as successor if no
other successor servicer can be found.

Servicing arrangement

There are five servicers in this pool: Shellpoint Mortgage
Servicing (87.72%), Quicken Loans (8.53%), HomeStreet Bank (2.43%),
First Republic Bank (0.75%) and TIAA, FSB (0.57%).

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, is unable to make such advances,
the securities administrator, Citibank will be obligated to do so.

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.

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.


SIERRA TIMESHARE 2019-2: Fitch Assigns BBsf Rating on Cl. D Debt
----------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Outlooks to
notes issued by Sierra Timeshare 2019-2 Receivables Funding LLC.

Sierra Timeshare 2019 2 Receivables Funding LLC

      Current Rating        Prior Rating
Class A   LT AAAsf New Rating;  previously at AAA(EXP)sf
Class B   LT Asf   New Rating;  previously at A(EXP)sf
Class C   LT BBBsf New Rating;  previously at BBB(EXP)sf
Class D   LT BBsf  New Rating;  previously at BB(EXP)sf

KEY RATING DRIVERS

Borrower Risk - Stable Collateral Quality: Approximately 72.0% of
Sierra 2019-2 consist of WVRI-originated loans; the remainder are
WRDC loans. Fitch has determined that, on a like-for-like FICO
basis, WRDC's receivables perform better than WVRI's. The weighted
average (WA) original FICO score of the pool is 725. Overall, the
2019-2 pool shows a marginal decrease in WRDC loans and moderate
shift upward in the FICO band concentrations for the WVRI platform
relative to the 2019-1 transaction.

Forward-Looking Approach on CGD Proxy - Stabilizing CGD
Performance: Similar to other timeshare originators, Wyndham
Destinations' delinquency and default performance exhibited notable
increases in the 2007-2008 vintages, stabilizing in 2009 and
thereafter. However, more recent vintages, from 2014-2016, have
begun to show increasing gross defaults versus vintages back to
2009, partially driven by increased paid product exits (PPEs).
Fitch's cumulative gross default (CGD) proxy for this pool is
19.40% (unchanged from 2019-1). Furthermore, given the expected
stable economic conditions, no adjustments were made to Fitch's CGD
proxy.

Structural Analysis - Lower CE Structure: Initial hard credit
enhancement (CE) is expected to be 61.65%, 36.30%, 14.40% and 4.50%
for class A, B, C and D notes, respectively, decreased for class A,
B and C, and unchanged for class D from 2019-1. Hard CE comprises
overcollateralization, a reserve account and subordination. Soft CE
is also provided by excess spread and is expected to be 10.34% per
annum. Loss coverage for all notes are able to support default
multiples of 3.50x, 2.50x, 1.75x and 1.25x for 'AAAsf', 'Asf',
'BBBsf' and 'BBsf', respectively.

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

Legal Structure Integrity: The legal structure of the transaction
should provide that a bankruptcy of Wyndham Destinations and
Wyndham Consumer Finance, Inc. would not impair the timeliness of
payments on the securities.

RATING SENSITIVITIES

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

Fitch conducts sensitivity analysis by stressing a transaction's
initial base case CGD to the level required to reduce each rating
by one full category, to non-investment grade (BBsf) and to
'CCCsf'. Fitch also stresses base prepayment assumptions by 1.5x
and 2.0x and examines the rating implications on all classes of
issued notes. The 1.5x and 2.0x increases of the prepayment
assumptions represent moderate and severe stresses, respectively,
and are intended to provide an indication of the rating sensitivity
of notes to unexpected deterioration of a trust's performance.


SLM STUDENT 2003-12: Fitch Affirms BBsf Rating on Class B-1 Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed the ratings on the SLM Student Loan
Trust 2003-12 notes. Fitch's affirmation of the class A-6 notes at
'AAsf'/Stable reflects the cross-currency swap in the transaction.
The treatment of the swap constitutes a criteria variation. Fitch
affirmed the class B notes at 'BBsf'/Stable. The transaction was
cash flow modeled using actual fees rather than the standard fees
from Fitch's criteria.

SLM Student Loan Trust 2003-12
   
Class A-6 78442GKF2; LT AAsf Affirmed; previously at AAsf

Class B-1 78442GKD7; LT BBsf Affirmed; previously at BBsf

KEY RATING DRIVERS

U.S. Sovereign Risk: The trusts' collateral comprises 100% Federal
Family Education Loan Program (FFELP) loans, with guaranties
provided by eligible guarantors and reinsurance provided by the
U.S. Department of Education (ED) for at least 97% of principal and
accrued interest. The U.S. sovereign rating is currently
'AAA'/Stable.

Collateral Performance: Based on transaction-specific performance
to date, Fitch assumes a base case cumulative default rate of
15.00% and a 45.00% default rate under the 'AAA' credit stress
scenario. Fitch is maintaining a sustainable constant default rate
of 2.4% and a sustainable constant prepayment rate (voluntary and
involuntary) of 8.5% in cash flow modeling. Fitch applies the
standard default timing curve. The claim reject rate is assumed to
be 0.50% in the base case and 3.0% in the 'AAA' case. The TTM
average of deferment, forbearance, and income-based repayment
(prior to adjustment) are 3.49%, 8.05%, and 16.73%, respectively,
and are used as the starting point in cash flow modeling.
Subsequent declines or increases are modeled as per criteria. The
borrower benefit is assumed to be approximately 0.19% based on
information provided by the sponsor.

Basis and Interest Rate Risk: Basis risk for this transaction
arises from any rate and reset frequency mismatch between interest
rate indices for Special Allowance Payments (SAP) and the
securities. As of May 2019, approximately 87.41% of the student
loans are indexed to LIBOR, and 12.59% are indexed to T-Bill. The
class B notes are indexed to three-month U.S. LIBOR, while the
class A-6 notes are indexed to three-month GBP LIBOR swapped into
U.S. LIBOR through a cross-currency swap. Fitch applies its
standard basis and interest rate stresses to this transaction as
per criteria.

Payment Structure: Credit enhancement (CE) is provided by
overcollateralization (OC), excess spread and for the class A
notes, subordination. As of May 2019, senior and total effective
parity ratios (including the reserve) are 105.46% (5.18% CE) and
100.63% (0.63% CE), respectively. Liquidity support is provided by
a reserve account currently sized at its floor of $3,759,518. The
transaction will continue to release cash as long as the current
100% total parity (excluding the reserve) is maintained.

Operational Capabilities: Day-to-day servicing is provided by
Navient Solutions, LLC. Fitch believes Navient to be an acceptable
servicer due to its extensive track record as the largest servicer
of FFELP loans.

RATING SENSITIVITIES

Fitch conducted a CE sensitivity analysis by stressing both the
related lifetime default rate and basis spread assumptions. In
addition, Fitch conducted a maturity sensitivity analysis by
running different assumptions for the IBR usage and prepayment
rate. The results should only be considered as one potential model
implied outcome as the transaction is exposed to multiple risk
factors that are all dynamic variables.

Credit Stress Rating Sensitivity

  -- Default increase 25%: class A 'AAAsf'; class B 'BBsf';

  -- Default increase 50%: class A 'AAAsf'; class B 'BBsf';

  -- Basis Spread increase 0.25%: class A 'AAAsf'; class B
'CCCsf';

  -- Basis Spread increase 0.5%: class A 'Asf'; class B 'CCCsf'.

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'AAAsf'; class B 'BBBsf';

  -- CPR decrease 50%: class A 'AAAsf'; class B 'BBBsf';

  -- IBR Usage increase 25%: class A 'AAAsf'; class B 'BBBsf';

  -- IBR Usage increase 50%: class A 'AAAsf'; class B 'BBBsf'.

  -- Remaining Term increase 25%: class A 'CCCsf'; class B
'CCCsf';

  -- Remaining Term increase 50%: class A 'CCCsf'; class B
'CCCsf'.

Stresses are intended to provide an indication of the rating
sensitivity of the notes to unexpected deterioration in trust
performance. Rating sensitivity should not be used as an indicator
of future rating performance.


SOUND POINT IX: Moody's Assigns B3 Rating on $10MM Cl. F-RR Notes
-----------------------------------------------------------------
Moody's Investors Service assigned ratings to six classes of CLO
refinancing notes issued by Sound Point CLO IX, Ltd.

Moody's rating action is as follows:

US$325,000,000 Class A-RR Senior Secured Floating Rate Notes Due
2032 (the "Class A-RR Notes"), Assigned Aaa (sf)

US$55,000,000 Class B-RR Senior Secured Floating Rate Notes Due
2032 (the "Class B-RR Notes"), Assigned Aa2 (sf)

US$25,000,000 Class C-RR Mezzanine Secured Deferrable Floating Rate
Notes Due 2032 (the "Class C-RR Notes"), Assigned A2 (sf)

US$30,500,000 Class D-RR Mezzanine Secured Deferrable Fixed Rate
Notes Due 2032 (the "Class D-RR Notes"), Assigned Baa3 (sf)

US$24,500,000 Class E-RR Junior Secured Deferrable Floating Rate
Notes Due 2032 (the "Class E-RR Notes"), Assigned Ba3 (sf)

US$10,000,000 Class F-RR Junior Secured Deferrable Floating Rate
Notes Due 2032 (the "Class F-RR Notes"), 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 its methodology.

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

Sound Point Capital Management, LP (the "Manager") will continue to
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 extended five 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 July 22, 2019 in
connection with the refinancing of all classes of the secured
notes, previously refinanced in part on October 20, 2017 and
originally issued on July 16, 2015. On the Refinancing Date, the
Issuer used proceeds from the issuance of the Refinancing Notes and
additional subordinated notes to redeem in full the Refinanced
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 and additional
subordinated notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: extension of the reinvestment period; extensions of the
stated maturity and non-call period; changes to certain collateral
quality tests; and changes to the overcollateralization test
levels.

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.

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:

Portfolio par: $500,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2738

Weighted Average Spread (WAS): 3.55%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.5%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

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

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

The performance of the Refinancing Notes is subject to uncertainty.
The performance of the Refinancing 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 Refinancing Notes.


SYMPHONY CLO XVIII: Moody's Affirms Ba3 Rating on $20MM Cl. E Notes
-------------------------------------------------------------------
Moody's Investors Service assigned a rating to one class of CLO
refinancing notes issued by Symphony CLO XVIII, Ltd.

Moody's rating action is as follows:

  US$310,000,000 Class A-R Senior Floating Rate Notes Due
  2028 (the "Class A-R Notes"), Assigned Aaa (sf)

Additionally, Moody's affirmed the ratings on the following
outstanding notes originally issued by the Issuer on December 12,
2016:

  US$70,000,000 Class B Senior Floating Rate Notes Due 2028
  (the "Class B Notes"), Affirmed Aa2 (sf); previously on
  December 13, 2016 Definitive Rating Assigned Aa2 (sf)

  US$28,750,000 Class C Deferrable Mezzanine Floating Rate
  Notes Due 2028 (the "Class C Notes"), Affirmed A2 (sf);
  previously on December 13, 2016 Definitive Rating Assigned
  A2 (sf)

  US$31,250,000 Class D Deferrable Mezzanine Floating Rate
  Notes Due 2028 (the "Class D Notes"), Affirmed Baa3 (sf);
  previously on December 13, 2016 Definitive Rating Assigned
  Baa3 (sf)

  US$20,000,000 Class E Deferrable Mezzanine Floating Rate
  Notes Due 2028 (the "Class E Notes"), Affirmed Ba3 (sf);
  previously on December 13, 2016 Definitive Rating Assigned
  Ba3 (sf)

RATINGS RATIONALE

The rationale for the ratings is based on a consideration of the
risks associated with the CLO's portfolio and structure as
described in its methodology. In particular, the rating affirmation
on the Class B, Class C, Class D and Class E Notes is supported by
the refinancing, which increases excess spread available as credit
enhancement to the rated notes.

The Issuer is a managed cash flow collateralized loan obligation
(CLO). 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
lien loans and unsecured loans.

Symphony Asset Management LLC will continue to 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 two 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 July 23, 2019 in
connection with the refinancing of one class of secured notes
originally issued on December 12, 2016. On the Refinancing Date,
the Issuer used 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 four other classes of secured
notes and one class of subordinated notes that remain outstanding.

In addition to the issuance of the Refinancing Notes, other changes
to transaction features will occur in connection with the
refinancing. This includes extension of the non-call period.

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.

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: $497,103,262

Defaulted par: $741,941

Diversity Score: 66

Weighted Average Rating Factor (WARF): 2685

Weighted Average Spread (WAS): 3.25%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 48.00%

Weighted Average Life (WAL): 5.75 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 Refinancing Notes.


TRINITAS CLO XI: Moody's Rates $27.775MM Class E Notes 'Ba3'
------------------------------------------------------------
Moody's Investors Service assigned ratings to seven classes of
notes issued and one class of loans incurred by Trinitas CLO XI,
Ltd.

Moody's rating action is as follows:

US$173,910,000 Class A-1 Floating Rate Notes Due 2032 (the "Class
A-1 Notes"), Assigned Aaa (sf)

US$5,610,000 Class A-2 Floating Rate Notes Due 2032 (the "Class A-2
Notes"), Assigned Aaa (sf)

US$204,820,000 Class A Loan Maturing in 2032 (the "Class A Loan"),
Assigned Aa1 (sf)

US$30,660,000 Class B-1 Floating Rate Notes Due 2032 (the "Class
B-1 Notes"), Assigned Aa2 (sf)

US$3,000,000 Class B-2 Fixed Rate Notes Due 2032 (the "Class B-2
Notes"), Assigned Aa2 (sf)

US$24,750,000 Class C Deferrable Floating Rate Notes Due 2032 (the
"Class C Notes"), Assigned A2 (sf)

US$35,475,000 Class D Deferrable Floating Rate Notes Due 2032 (the
"Class D Notes"), Assigned Baa3 (sf)

US$27,775,000 Class E Deferrable Floating Rate Notes Due 2032 (the
"Class E Notes"), Assigned Ba3 (sf)

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

RATINGS RATIONALE

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

Trinitas XI is a managed cash flow CLO. The issued notes and
incurred loan will be collateralized primarily by broadly
syndicated senior secured corporate loans. At least 92.5% of the
portfolio must consist of first lien senior secured loans and
eligible investments, and up to 7.5% of the portfolio may consist
of second lien loans and unsecured loans. The portfolio is
approximately 90% ramped as of the closing date.

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

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

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the 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: $550,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2820

Weighted Average Spread (WAS): 3.64%

Weighted Average Coupon (WAC): 6.00%

Weighted Average Recovery Rate (WARR): 46.75%

Weighted Average Life (WAL): 9 years

Methodology Underlying the Rating Action:

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

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

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


UNITED AUTO 2018-2: DBRS Hikes Rating on Class F Notes to BB
------------------------------------------------------------
DBRS, Inc. reviewed 16 ratings from three United Auto Credit
Securitization Trust transactions. Of the 16 outstanding publicly
rated classes reviewed, DBRS upgraded 11, confirmed two and
discontinued three due to repayment. For the ratings that were
upgraded, performance trends are such that credit enhancement
levels are sufficient to cover DBRS's expected losses at their new
respective rating levels. For the ratings that were confirmed,
performance trends are such that credit enhancement levels are
sufficient to cover DBRS's expected losses at their current
respective rating levels.

The Affected Ratings are:

                 Action        Rating

United Auto Credit Securitization Trust 2017-1

Class D Notes   Upgraded       AAA(sf)
Class E Notes   Upgraded       A(low)(sf)
Class B Notes   Disc.-Repaid   Discontinued
Class C Notes   Disc.-Repaid   Discontinued

United Auto Credit Securitization Trust 2018-1

Class B Notes   Confirmed      AAA(sf)
Class C Notes   Upgraded       AAA(sf)
Class D Notes   Upgraded       AA(sf)
Class E Notes   Upgraded       A(sf)
Class F Notes   Upgraded       BBB(sf)
Class A Notes   Disc.-Repaid   Discontinued

United Auto Credit Securitization Trust 2018-2

Class A Notes   Confirmed      AAA(sf)
Class B Notes   Upgraded       AAA(sf)
Class C Notes   Upgraded       AA(sf)
Class D Notes   Upgraded       A(low)(sf)
Class E Notes   Upgraded       BBB(low)(sf)
Class F Notes   Upgraded       BB(sf)

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

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

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

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


WFRBS COMMERCIAL 2013-C13: Moody's Affirms B2 Rating on F Certs
---------------------------------------------------------------
Moody's Investors Service affirmed the ratings on eleven classes in
WFRBS Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2013-C13 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Feb 15, 2018 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Feb 15, 2018 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Feb 15, 2018 Affirmed
Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on Feb 15, 2018 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa3 (sf); previously on Feb 15, 2018 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on Feb 15, 2018 Affirmed A3
(sf)

Cl. D, Affirmed Baa3 (sf); previously on Feb 15, 2018 Affirmed Baa3
(sf)

Cl. E, Affirmed Ba2 (sf); previously on Feb 15, 2018 Affirmed Ba2
(sf)

Cl. F, Affirmed B2 (sf); previously on Feb 15, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Feb 15, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed A2 (sf); previously on Feb 15, 2018 Affirmed A2
(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 ratings on the IO classes were affirmed based on the credit
quality of the referenced classes.

Moody's rating action reflects a base expected loss of 1.5% of the
current pooled balance, compared to 2.2% at Moody's last review.
Moody's base expected loss plus realized losses is now 1.2% of the
original pooled balance, compared to 2.0% 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 July 17, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 20.0% to $701.6
million from $876.7 million at securitization. The certificates are
collateralized by 85 mortgage loans ranging in size from less than
1% to 11.9% of the pool, with the top ten loans (excluding
defeasance) constituting 42.3% of the pool. Twenty loans,
constituting 7.6% of the pool, have investment-grade structured
credit assessments. Four loans, constituting 12.8% 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 25, compared to 27 at Moody's last review.

Sixteen loans, constituting 9.2% 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.

There have been no loans liquidated from the pool and there are 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 81% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 87%, compared to 88% 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 9.6%.

Moody's actual and stressed conduit DSCRs are 1.92X and 1.25X,
respectively, compared to 1.88X and 1.21X 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.

There are 20 loans with structured credit assessments ($53.5
million -- 7.6% of the pool) that are secured by multifamily
cooperative properties located in New Jersey and New York.

The top three conduit loans represent 23.3% of the pool balance.
The largest loan is the 301 South College Street Loan ($83.3
million -- 11.9% of the pool), which represents a pari-passu
interest in a $171.5 million mortgage loan. The loan is secured by
a 988,646 square foot Class A office tower located in the central
business district of Charlotte, North Carolina. The property was
100% leased as of December 2018, unchanged from the prior review.
The largest tenant, Wells Fargo, represents 69% of the net rentable
are (NRA) and has a lease expiration date in December 2021. Wells
Fargo recently announced plans to lease space at a nearby building
and to reduce its space at this property. The next largest tenants
include Womble Carlyle (6% of NRA; lease expiration June 2028) and
YMCA (4% of NRA; lease expiration January 2022). Moody's has
accounted for the tenant concentration risk via a lit-dark
analysis. After an intial 5-year interest only period the loan has
now amortized 2% since securitization. Moody's LTV and stressed
DSCR are 102% and 1.00X, respectively, compared to 103% and 0.99X
at the last review.

The second largest loan is the General Services Administration
(GSA) Portfolio Loan ($50 million -- 7.1% of the pool). The loan is
secured by 14 cross-collateralized and cross-defaulted office and
flex warehouse buildings totaling 341,000 SF and located throughout
11 states. The loan sponsor is GSA Realty Holdings, Inc. The
properties are collectively 100% leased to GSA tenants under 14
long-term leases. The loan is interest only for its entire term and
Moody's LTV and stressed DSCR are 89% and 1.13X, respectively, the
same as at last review.

The third largest loan is the 825-845 Lincoln Road Loan ($30
million -- 4.3% of the pool). The loan is secured by a 38,843 SF
retail property located in Lincoln Road Mall, an eight-block retail
cooridor within walking distance from the Atlantic Ocean and some
of South Beach's high end hotels, including the Ritz-Carlton, The
Delano, and The Shore Club. As of December 2018, the property was
100% leased to six tenants, including CB2 (15,200 SF, 39% of the
NRA), Urban Outfitters (13,126 SF, 34% of the NRA), and American
Eagle (4,500 SF, 12% of the NRA). The Urban Outfitters space serves
as a flagship store for the retailer. The loan is interest only for
its entire term and Moody's LTV and stressed DSCR are 58% and
1.48X, respectively, the same as at last review.


WFRBS COMMERCIAL 2014-C23: Fitch Downgrades Cl. F Certs to B-sf
---------------------------------------------------------------
Fitch Ratings has downgraded two classes and affirmed thirteen
classes of WFRBS Commercial Mortgage Trust 2014-C23 commercial
mortgage pass-through certificates and revised the Rating Outlooks
on classes E and X-C to Negative from Stable.

WFRBS 2014-C23

                        Current Rating       Prior Rating
Class A-2 92939HAV7;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-3 92939HAW5;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-4 92939HAX3;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-5 92939HAY1;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-S 92939HBA2;  LT AAAsf  Affirmed;  previously at AAAsf
Class A-SB 92939HAZ8; LT AAAsf  Affirmed;  previously at AAAsf
Class B 92939HBB0;    LT AA-sf  Affirmed;  previously at AA-sf
Class C 92939HBC8;    LT A-sf   Affirmed;  previously at A-sf
Class D 92939HAJ4;    LT BBB-sf Affirmed; previously at BBB-sf
Class E 92939HAL9;    LT BBsf   Affirmed;  previously at BBsf
Class F 92939HAN5;    LT B-sf   Downgrade; previously at Bsf
Class PEX 92939HBD6;  LT A-sf   Affirmed;  previously at A-sf
Class X-A 92939HBE4;  LT AAAsf  Affirmed;  previously at AAAsf
Class X-C 92939HAA3;  LT BBsf   Affirmed;  previously at BBsf
Class X-D 92939HAC9;  LT B-sf   Downgrade; previously at Bsf

KEY RATING DRIVERS

Increased Loss Expectations: The downgrade reflects increased loss
expectations since issuance primarily due to the Fitch Loans of
Concern (FLOCs). Seven loans (26.3% of the pool), six of which are
in the top 15 (25.3%), were designated as FLOCs for declining
occupancy and upcoming lease rollover concerns.

The largest FLOC, Crossings at Corona (8.3% of pool), is secured by
an 834,075 sf retail center located in Corona, CA. The property,
which is shadow-anchored by Target, has suffered from declining
occupancy after four collateral anchor tenants vacated. Toys R Us
(formerly 7.6% of NRA) and Sports Authority (4.5%) both vacated
upon filing for bankruptcy, while Bed Bath & Beyond (2.9%) and Cost
Plus (2.2%) both vacated upon their January 2019 lease expirations.
Occupancy as of March 2019 dropped to 81.1% from 86.1% at YE 2018,
93.1% at YE 2017 and 94.5% at YE 2016. Additionally, approximately
34% of the NRA is expected to roll between 2019 and 2020, including
Regal Cinemas (9.6% of NRA; lease expiry in November 2019),
Jerome's Furniture (5.1%; October 2020) and Ross Dress for Less
(3.6%; January 2020). As of YE 2018, the servicer-reported net
operating income (NOI) debt service coverage ratio (DSCR) declined
to 1.26x from 1.68x at YE 2017 and 1.89x at YE 2016.

The second largest FLOC is the DC Metro Portfolio (6.9% of pool),
which is secured by 15 mixed-use properties located throughout
Washington, D.C., Maryland and Virginia. Portfolio occupancy as of
December 2018 was 84.5%, compared with 80.3% at YE 2017, 89.5% at
YE 2016 and 91.2% at issuance. Despite the slight year-over-year
occupancy improvement between 2017 and 2018, operating expenses
increased 14% over that period, mainly driven by property insurance
and general and administrative expenses. Approximately 19% of the
NRA rolls between 2019 and 2020, including top tenants, Aquicore
(4.7% of NRA; lease expiry in July 2019) and Colombo Bank (4.2%;
July 2019). The YE 2018 servicer-reported NOI DSCR was 1.28x, down
from 1.34x at YE 2017, and 1.69x at YE 2016. The loan began
amortizing in March 2017.

The third largest FLOC, 677 Broadway (3.0% of pool), is secured by
a 177,039 sf office building located in Albany, NY. The property
has maintained above 90% occupancy since issuance; however,
approximately 32% of the NRA rolls between 2019 and 2020, including
the largest tenants, McNamee Lochner Titus & Will (12.8% of NRA;
lease expiry in April 2020), which had previously downsized its
space in 2015 by 8,500 sf, and Fuller O'Brien Gallagher (8.8%;
April 2020). The master servicer indicated the borrower is
currently in early negotiations to renew these leases, but nothing
has been finalized.

The fourth largest FLOC is Slatten Ranch Shopping Plaza (2.9% of
the pool), which is secured by a 118,250 sf anchored retail center
located in Antioch, CA. Property occupancy as of March 2019
declined to 85% from 96% at YE 2018 and 100% at YE 2017. The
occupancy decline is mainly attributed to Cost Plus (formerly 15%
of NRA) vacating upon its January 2019 lease expiration; the space
currently remains vacant. Additionally, 9% of the NRA is expected
to roll between 2019 and 2020, including top tenant Dress Barn
(6.2% of NRA; lease expiry in December 2020), which has filed for
bankruptcy. The master servicer expects the tenant will vacate the
property.

The fifth largest FLOC is the Culver City Portfolio (2.6% of pool),
which is secured by a 93,977-sf office portfolio located in Culver
City, CA. As of December 2018, the portfolio was 100% occupied;
however, approximately 52% of the NRA is rolling between 2019 and
2020, including top tenants The Tennis Channel (18.5% of NRA; lease
expiry in August 2019), Planet Hollywood (8.7%; June 2019) and
Oscar Health Plan (6.9%; October 2019). The master servicer
indicated Planet Hollywood is expected to vacate at lease
expiration, while the Tennis Channel has recently extended its
lease on a short-term basis through February 2020.

The sixth largest FLOC, the Shops at Starwood (1.7% of pool), is
secured by a 55,385 sf retail property located in Frisco, TX.  As
of December 2018, the property was 92% occupied; however, 38% of
the NRA is rolling between 2019 and 2020, including the top tenant
Judge Fite Company (9.8% of NRA; lease expiry in December 2019).
Per the master servicer, Judge Fite Company will likely not renew
its lease, and the borrower is currently seeking replacement
tenants. Additionally, the lease for the seventh largest tenant,
Glambo Lily (5.6% of NRA), expired in April 2019; per the master
servicer, the borrower is seeking a replacement tenant that can
better utilize the space

The remaining FLOC, East Forest Plaza II (1.0% of pool), is secured
by a 109,080 sf retail property located in Columbia, SC. Property
occupancy as of March 2019 declined to 74.1% after Fallas (formerly
23.0% of NRA) and Payless Shoes (2.9%) both vacated upon filing for
bankruptcy and subsequently closing all of their stores.
Additionally, the center's largest tenant, Hobby Lobby (55.1% of
NRA), has an upcoming lease expiration in October 2019; Fitch
requested from the master servicer a leasing update and any
potential co-tenancy triggers, but did not receive a response.

Increased Credit Enhancement: As of the July 2019 remittance, the
aggregate pool balance has been paid down by 6.4% to $880.6 million
from $940.8 million at issuance. Since Fitch's last rating action,
three loans were prepaid. Based on the scheduled balance at
maturity, the pool is expected to be reduced by 12.8%. Three loans
(2.4% of current pool) are defeased, including two additional loans
since the last rating action: Gateway Plaza (1%) and Extra Space
Palm Springs (0.2%). Upcoming maturities are limited to one loan,
Marriott Bakersfield (2.4%) in October 2019.

Additional Loss Considerations: Fitch performed an additional
sensitivity scenario by applying a potential outsized loss severity
of 25% to Crossings at Corona, Slatten Ranch Shopping Plaza and
Culver City Portfolio, while also factoring in the expected paydown
of the transaction from the defeased collateral and the upcoming
maturing loan. This sensitivity analysis contributed to the
Negative Rating Outlooks on classes E, F, X-C and X-D.

RATING SENSITIVITIES

The Negative Rating Outlooks on classes E, F, X-C and X-D reflect
an additional sensitivity scenario performed on the Crossings at
Corona, Slatten Ranch Shopping Plaza and Culver City Portfolio
loans and possible downgrade concerns should performance of the
larger FLOCs deteriorate further. The Rating Outlooks for classes
A-2 through D remain Stable due to the overall stable performance
for the majority of the pool and expected continued paydown and
amortization. Upgrades may occur with improved pool performance,
additional paydown and/or defeasance.


Z CAPITAL 2019-1: Moody's Assigns Ba3 Rating on $25MM Cl. E Notes
-----------------------------------------------------------------
Moody's Investors Service assigned ratings to eight classes of
notes issued by Z Capital Credit Partners CLO 2019-1 Ltd.

Moody's rating action is as follows:

US$55,000,000 Class A-1 Senior Secured Floating Rate Notes due 2031
(the "Class A-1 Notes"), Assigned Aaa (sf)

US$110,000,000 Class A-2 Senior Secured Floating Rate Notes due
2031 (the "Class A-2 Notes"), Assigned Aaa (sf)

US$11,000,000 Class A-3 Senior Secured Fixed Rate Notes due 2031
(the "Class A-3 Notes"), Assigned Aaa (sf)

US$1,850,000 Class A-X Amortizing Senior Secured Floating Rate
Notes due 2031 (the "Class A-X Notes"), Assigned Aaa (sf)

US$26,000,000 Class B Senior Secured Floating Rate Notes due 2031
(the "Class B Notes"), Assigned Aa2 (sf)

US$22,000,000 Class C Secured Deferrable Floating Rate Notes due
2031 (the "Class C Notes"), Assigned A2 (sf)

US$26,500,000 Class D Secured Deferrable Floating Rate Notes due
2031 (the "Class D Notes"), Assigned Baa3 (sf)

US$25,000,000 Class E Secured Deferrable Floating Rate Notes due
2031 (the "Class E Notes"), Assigned Ba3 (sf)

The Class A-1 Notes, the Class A-2 Notes, the Class A-3 Notes, the
Class A-X Notes, the Class B Notes, the Class C Notes, the Class D
Notes and the Class E Notes are referred to herein, collectively,
as the "Rated Notes."

RATINGS RATIONALE

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

Z Capital 2019-1 is a managed cash flow CLO. The issued notes will
be collateralized primarily by broadly syndicated senior secured
corporate loans. At least 88.75% of the portfolio must consist of
senior secured loans and eligible investments, and up to 11.25% of
the portfolio may consist of second lien loans and unsecured loans.
The portfolio is approximately 40% ramped as of the closing date.

Z Capital CLO Management, L.L.C. will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's four year reinvestment period.
Thereafter, no reinvestment is permitted and all principal payments
and proceeds from sales will be used to amortize the notes.

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

The transaction incorporates interest and par coverage tests which,
if triggered, divert interest and principal proceeds to pay down
the notes 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: $330,000,000

Diversity Score: 40

Weighted Average Rating Factor (WARF): 4085

Weighted Average Spread (WAS): 5.25%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 43.0%

Weighted Average Life (WAL): 8.0 years

Methodology Underlying the Rating Action:

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

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.


                            *********

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.

The TCR subscription rate is $975 for 6 months delivered via
e-mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Peter A.
Chapman at 215-945-7000.

                   *** End of Transmission ***