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

              Sunday, August 25, 2019, Vol. 23, No. 236

                            Headlines

AMERICAN CREDIT 2019-3: S&P Assigns B (sf) Rating to Class F Notes
AMERICREDIT AUTOMOBILE 2018-3: Moody's Hikes Class E Notes to Ba1
ASHFORD HOSPITALITY 2018-KEYS: Moody's Affirms B3 on F Certificates
AVENTURA MALL 2018-AVM: Moody's Affirms Ba1 Rating on HRR Certs
BEAR STEARNS 2005-EC1: Moody's Lowers Class M-2 Debt to B1(sf)

BHP TRUST 2019-BXHP: Moody's Gives (P)B2 Rating on Class HRR Certs
BRAVO RESIDENTIAL 2019-NQM1: Fitch Gives B2 Rating on Cl. B2 Debt
BX TRUST 2019-MMP: Moody's Assigns (P)B3 Rating on Class F Certs
CD 2019-CD8: Fitch Rates $8.832MM Class G-RR Certs 'B-sf'
CEDAR FUNDING X: S&P Assigns Prelim BB- (sf) Rating to Cl. E Notes

CF TRUST 2019-MF1: S&P Assigns B- (sf) Rating to Class F Certs
CIM TRUST 2019-J1: DBRS Assigns Prov. B Rating on Class B-5 Certs
CIM TRUST 2019-J1: Moody's Assigns (P)B2 Rating on Cl. B-5 Debt
CITIGROUP 2019-IMC1: S&P Assigns Prelim B (sf) Rating on B-2 Certs
CITIGROUP COMMERCIAL 2013-GC17: Fitch Affirms B Rating on F Debt

CITIGROUP COMMERCIAL 2019-GC41: Fitch Rates Class F Certs 'BB-sf'
CITIGROUP MORTGAGE 2019-IMC1: DBRS Gives (P)B Rating on B2 Certs
COMM MORTGAGE 2016-COR1: Fitch Affirms B-sf Rating on 2 Tranches
CREDIT SUISSE 2003-C3: Fitch Lowers Class J Certs Rating to Csf
CSMC 2019-AFC1: S&P Assigns B+ (sf) Rating to Class B-2 Notes

DBUBS 2011-LC2: Moody's Affirms B3 Rating on 2 Tranches
DEUTSCHE FINANCIAL 1998-I: Moody's Hikes Class M Debt Rating to B3
DIAMOND RESORTS 2019-1: S&P Assigns BB+ (sf) Rating to Cl. D Notes
FLAGSHIP CREDIT 2019-3: S&P Assigns BB- (sf) Rating to Cl. E Notes
FREDDIE MAC 2019-3: DBRS Finalizes B(low) Rating on Class M Certs

FREDDIE MAC 2019-FTR2: S&P Rates Class B-1B Notes 'B- (sf)'
GEA SEASIDE: Seeks to Hire Nasseh Sirounis Law as Special Counsel
GOLDENTREE LOAN 5: S&P Assigns B- (sf) Rating to Class F Notes
GS MORTGAGE 2017-485L: S&P Affirms BB- (sf) Rating on HRR Certs
GS MORTGAGE 2019-SL1: Fitch Rates $15MM Class B2 Notes 'Bsf'

HOMEWARD OPPORTUNITIES 2019-2: DBRS Gives (P)B Rating on B2 Certs
HOMEWARD OPPORTUNITIES 2019-2: S&P Rates Class B-2 Certs 'B'
HPS LOAN 15-2019: S&P Assigns B- (sf) Rating to $5MM Class F Notes
JP MORGAN 2006-LDP7: Fitch Cuts Rating on Class A-J Certs to Csf
JP MORGAN 2013-C17: Fitch Affirms Bsf Rating on Class F Certs

JP MORGAN 2019-5: Moody's Hikes Class B-4 Debt Rating to Ba3(sf)
JP MORGAN 2019-6: DBRS Gives Prov. B Rating on Class B-5 Certs
JP MORGAN 2019-6: Moody's Assigns (P)B3 Rating on Class B-5 Debt
KENTUCKY HIGHER 2010-1: Fitch Lowers Class A-2 Debt to BBsf
KKR CLO 26: Moody's Assigns Ba3 Rating on $29.7MM Class E Notes

M360 2019-CRE2: DBRS Assigns Prov. B(low) Rating on Class G Notes
MORGAN STANLEY 2001-TOP3: Fitch Affirms Dsf Rating on 7 Tranches
MORGAN STANLEY 2015-C26: Fitch Affirms B-sf Rating on Cl. F Certs
NEW RESIDENTIAL 2019-4: DBRS Finalizes B Rating on 10 Note Classes
NEW RESIDENTIAL 2019-4: Moody's Assigns B1 Rating on Cl. B-7 Debt

OCTAGON INVESTMENT 43: Moody's Gives (P)Ba3 Rating on Class E Notes
PIKES PEAK 4: Moody's Assigns Ba3 Rating on $18MM Class E Notes
PREFERREDPLUS TRUST CZN-1: Moody's Cuts $34.5MM Certs to Caa3
RAIT CRE I: Fitch Cuts Class D Debt Rating 'CCsf'
ROMARK CLO III: Moody's Assigns Ba3 Rating on $22.3MM Cl. D Notes

SDART 2019-3: Moody's Rates $95.880MM Class E Notes 'B1'
SEQUOIA MORTGAGE 2019-3: Moody's Gives Ba3 Rating on Cl. B-4 Debt
SLM STUDENT 2012-1: Fitch Lowers Ratings on 2 Tranches to Bsf
SOUND POINT XIV: Moody's Affirms Ba3 Rating on $35MM Cl. E Notes
SOUTHWICK PARK: S&P Assigns BB- (sf) Rating on Class E Notes

STRUCTURED AGENCY 2017-HRP1: Fitch Ups Rating on 7 Tranches to BB+
STWD LTD 2019-FL1: DBRS Finalizes B(low) Rating on Class G Notes
VOYA CLO 2016-2: Moody's Rates $16.4MM Class D-R Notes 'Ba3'
WELLFLEET CLO 2019-1: Moody's Rates $21.5MM Class D Notes 'Ba3'
WELLS FARGO 2015-NXS4: Fitch Affirms B-sf Rating on 2 Tranches

WELLS FARGO 2019-C52: Fitch Assigns B-sf Rating on Cl. G-RR Certs
WEST CLO 2014-1: Moody's Raises $20MM Class D Notes Rating to Ba2
WFRBS COMMERCIAL 2012-C8: Moody's Affirms B2 Rating on Cl. G Certs
WHITEBOX CLO I: S&P Assigns BB- (sf) Rating to $16MM Class D Notes

                            *********

AMERICAN CREDIT 2019-3: S&P Assigns B (sf) Rating to Class F Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to American Credit
Acceptance Receivables Trust 2019-3's asset-backed notes.

The note issuance is an ABS transaction backed by subprime auto
loan receivables.

The ratings reflect:

-- The availability of approximately 66.3%, 59.8%, 50.0%, 42.0%,
37.3%, and 33.8% credit support for the class A, B, C, D, E, and F
notes, respectively, based on stressed cash flow scenarios
(including excess spread). These credit support levels provide more
than 2.32x, 2.07x, 1.68x, 1.36x, 1.25x, and 1.10x coverage of S&P's
expected net loss range of 27.75%-28.75% for the class A, B, C, D,
E, and F notes, respectively.

-- The timely interest and principal payments made to the rated
notes by the assumed legal final maturity dates under S&P's
stressed cash flow modeling scenarios that S&P believes are
appropriate for the assigned ratings. The expectation that under a
moderate ('BBB') stress scenario, all else being equal, S&P's
ratings on the class A, B, and C notes would not be lowered from
its 'AAA (sf)', 'AA (sf)', and 'A (sf)' ratings, respectively,
during the first year; the rating on the class D notes would remain
within two rating categories of its 'BBB (sf)' rating during the
first year; and the ratings on the class E and F notes would remain
within two rating categories of the 'BB (sf)' and 'B (sf)' ratings,
respectively, in the first year, though the notes are expected to
default by their legal final maturity date with approximately
87%-100% and 0%-2% of principal repayment, respectively. These
potential rating movements are within the limits specified in S&P's
credit stability criteria.

-- The collateral characteristics of the subprime automobile loans
securitized in this transaction.

-- The backup servicing arrangement with Wells Fargo Bank N.A.

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

-- The transaction's legal structure.

  RATINGS ASSIGNED
  American Credit Acceptance Receivables Trust 2019-3

  Class       Rating       Amount (mil. $)(i)
  A           AAA (sf)                 117.99
  B           AA (sf)                   33.83
  C           A (sf)                    62.70
  D           BBB (sf)                  44.89
  E           BB (sf)                   24.75
  F           B (sf)                    18.65



AMERICREDIT AUTOMOBILE 2018-3: Moody's Hikes Class E Notes to Ba1
-----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of nine notes from
four transactions sponsored and serviced by AmeriCredit Financial
Services, Inc. (Unrated) and twelve notes from six transactions
sponsored and serviced by GM Financial (General Motors Financial
Company, Inc.) (Baa3, Stable).

The complete rating actions are as follows:

Issuer: AmeriCredit Automobile Receivables Trust 2015-1

  Class E Notes, Upgraded to Aaa (sf); previously on Apr 5, 2019
  Upgraded to Aa3 (sf)

Issuer: AmeriCredit Automobile Receivables Trust 2017-2

  Class D Notes, Upgraded to Aa2 (sf); previously on Apr 5, 2019
  Upgraded to Aa3 (sf)

Issuer: AmeriCredit Automobile Receivables Trust 2018-2

  Class C Notes, Upgraded to Aa1 (sf); previously on Apr 5, 2019
  Upgraded to Aa2 (sf)

  Class D Notes, Upgraded to A3 (sf); previously on Aug 15, 2018
  Definitive Rating Assigned Baa2 (sf)

  Class E Notes, Upgraded to Ba1 (sf); previously on Aug 15, 2018
  Definitive Rating Assigned Ba2 (sf)

Issuer: AmeriCredit Automobile Receivables Trust 2018-3

  Class B Notes, Upgraded to Aaa (sf); previously on Nov 21, 2018
  Definitive Rating Assigned Aa1 (sf)

  Class C Note, Upgraded to Aa1 (sf); previously on Nov 21, 2018
  Definitive Rating Assigned Aa3 (sf)

  Class D Notes, Upgraded to A3 (sf); previously on Nov 21, 2018
  Definitive Rating Assigned Baa2 (sf)

  Class E Notes, Upgraded to Ba1 (sf); previously on Nov 21, 2018
  Definitive Rating Assigned Ba2 (sf)

Issuer: GM Financial Consumer Automobile Receivables Trust 2017-2

  Class D Notes, Upgraded to Aaa (sf); previously on Apr 5, 2019
  Upgraded to Aa1 (sf)

Issuer: GM Financial Consumer Automobile Receivables Trust 2017-3

  Class D Notes, Upgraded to Aa1 (sf); previously on Apr 5, 2019
  Upgraded to Aa2 (sf)

Issuer: GM Financial Consumer Automobile Receivables Trust 2018-1

  Class C Notes, Upgraded to Aaa (sf); previously on Apr 5, 2019
  Upgraded to Aa1 (sf)

  Class D Notes, Upgraded to Aa2 (sf); previously on Apr 5, 2019
  Upgraded to Aa3 (sf)

Issuer: GM Financial Consumer Automobile Receivables Trust 2018-4

  Class C Notes, Upgraded to Aa1 (sf); previously on Apr 5, 2019
  Upgraded to Aa2 (sf)

  Class D Notes, Upgraded to Aa3 (sf); previously on Apr 5, 2019
  Upgraded to A1 (sf)

Issuer: GM Financial Consumer Automobile Receivables Trust 2019-1

  Class B Notes, Upgraded to Aaa (sf); previously on Jan 16, 2019
  Definitive Rating Assigned Aa2 (sf)

  Class C Notes, Upgraded to Aa1 (sf); previously on Jan 16, 2019
  Definitive Rating Assigned Aa3 (sf)

  Class D Notes, Upgraded to Aa3 (sf); previously on Jan 16, 2019
  Definitive Rating Assigned A2 (sf)

Issuer: GM Financial Consumer Automobile Receivables Trust 2019-2

  Class B Notes, Upgraded to Aaa (sf); previously on Apr 17, 2019
  Definitive Rating Assigned Aa1 (sf)

  Class C Notes, Upgraded to Aa2 (sf); previously on Apr 17, 2019
  Definitive Rating Assigned Aa3 (sf)

  Class D Notes, Upgraded to A1 (sf); previously on Apr 17, 2019
  Definitive Rating Assigned A2 (sf)

RATINGS RATIONALE

The upgrades resulted from the buildup of credit enhancement owing
to structural features including a sequential pay structure,
non-declining reserve account and overcollateralization.

The lifetime cumulative net loss expectation was decreased from
9.50% to 9.25% for the AmeriCredit 2015-1, decreased from 10.25% to
10.00% for the AmeriCredit 2017-2, and decreased from 9.50% to
9.00% for both AmeriCredit 2018-2 and 2018-3. The CNL expectations
were decreased from 0.85% to 0.75% for the GM Financial 2017-2 and
2019-1, and decreased from 0.85% to 0.80% for the GM Financial
2019-2. The CNL expectations for the GM Financial 2017-3, 2018-1
and 2018-4 transactions remain unchanged at 0.75%.

PRINCIPAL METHODOLOGY

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

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

Up

Levels of credit protection that are greater than necessary to
protect investors against current expectations of loss could lead
to an upgrade of the ratings. Losses could decline from Moody's
original expectations as a result of a lower number of obligor
defaults or greater recoveries from the value of the vehicles
securing the obligors promise of payment. The US job market and the
market for used vehicles are also primary drivers of the
transaction's performance. Other reasons for better-than-expected
performance include changes in servicing practices to maximize
collections on the loans or refinancing opportunities that result
in a prepayment of the loan.

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could lead to a
downgrade of the ratings. Losses could increase from Moody's
original expectations as a result of a higher number of obligor
defaults or a deterioration in the value of the vehicles securing
the obligors promise of payment. The US job market and the market
for used vehicles are also primary drivers of the transaction's
performance. Other reasons for worse-than-expected performance
include poor servicing, error on the part of transaction parties,
lack of transactional governance and fraud.


ASHFORD HOSPITALITY 2018-KEYS: Moody's Affirms B3 on F Certificates
-------------------------------------------------------------------
Moody's Investors Service, affirmed the ratings on seven classes in
Ashford Hospitality Trust 2018-KEYS, Commercial Mortgage
Pass-Through Certificates, Series 2018-KEYS as follows:

Cl. A, Affirmed Aaa (sf); previously on Jul 16, 2018 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Jul 16, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on Jul 16, 2018 Definitive
Rating Assigned A3 (sf)

Cl. D, Affirmed Baa3 (sf); previously on Jul 16, 2018 Definitive
Rating Assigned Baa3 (sf)

Cl. E, Affirmed Ba3 (sf); previously on Jul 16, 2018 Definitive
Rating Assigned Ba3 (sf)

Cl. F, Affirmed B3 (sf); previously on Jul 16, 2018 Definitive
Rating Assigned B3 (sf)

Cl. X-CP*, Affirmed Ba2 (sf); previously on Jul 16, 2018 Definitive
Rating Assigned Ba2 (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 ratio
and Moody's stressed debt service coverage ratio, are within
acceptable ranges. The rating on the 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, an increase in
defeasance 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 15, 2019 Distribution Date, the transaction's
aggregate certificate balance remains unchanged at $982 million
from securitization. The 7-year (including five one-year
extensions), interest only, floating rate loans are secured by fee
and leasehold interests in hotels totaling 7,270 guestrooms located
across 16 states and 22 MSAs. There is mezzanine debt of
approximately $288 million held outside of the trust.

The collateral under the mortgage loan is comprised of six pools
(Pools A through Pool F) totaling 34 hotel properties diversified
across full-service (19 hotels), select-service (10 hotels) and
extended-stay (5 hotels) segments. All but two properties (Lakeway
Resort & Spa and One Ocean Resort & Spa) are affiliated with
nationally recognized flags including Marriott International, Inc,
Starwood Hotels & Resorts Worldwide, LLC, Hilton Worldwide
Holdings, Inc, and Hyatt Hotels Corporation. The portfolio's Hotel
Operating Profit (EBITDA) after FF&E Reserve for the trailing
twelve month period ending May 2019 was approximately $141 million,
up from approximately $127 million at securitization. Five of the
six pools showed increases in Hotel Operating Profit (EBITDA) after
FF&E Reserve during this period, while the EBITDA for Pool C
declined 2% as compared to securitization.

The first mortgage balance of $982 million represents a Moody's
stabilized LTV of 106%. Moody's Total Debt LTV (inclusive of the
mezzanine debt) is 137%. Moody's first mortgage stressed debt
service coverage ratio (DSCR) is 1.13X and Moody's total stressed
DSCR is 0.88X. There are no outstanding interest shortfalls or
losses as of the current Distribution Date.


AVENTURA MALL 2018-AVM: Moody's Affirms Ba1 Rating on HRR Certs
---------------------------------------------------------------
Moody's Investors Service, affirmed the ratings on five classes in
Aventura Mall Trust 2018-AVM, Commercial Mortgage Pass-Through
Certificates, Series 2018-AVM as follows:

Cl. A, Affirmed Aaa (sf); previously on Jun 29, 2018 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Jun 29, 2018 Definitive
Rating Assigned Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on Jun 29, 2018 Definitive
Rating Assigned A3 (sf)

Cl. D, Affirmed Baa2 (sf); previously on Jun 29, 2018 Definitive
Rating Assigned Baa2 (sf)

Cl. HRR, Affirmed Ba1 (sf); previously on Jun 29, 2018 Definitive
Rating Assigned Ba1 (sf)

RATINGS RATIONALE

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

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
defeasance 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 these ratings was "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017.

DEAL PERFORMANCE

As of the July 8, 2019 Distribution Date, the transaction's
aggregate certificate balance remains unchanged at $750 million
from securitization. The 10-year fixed rate loan matures in July
2028. The interest-only, first lien mortgage loan with an
outstanding principal balance is $1.75 billion. The trust assets
consist of eight promissory notes, including four senior notes
($406.7 million) and four junior notes ($343.3 million), which
combined have an aggregate principal balance of $750 million. The
remaining $1.0 billion notes have been contributed to 15 other CMBS
transactions and are pari passu with the trust senior notes and
senior to the trust junior notes.

The property is the largest mall in the state of Florida and
contains five anchors (Macy's, Bloomingdale's, Macy's Men's and
Home, J. C. Penney and Nordstrom). The collateral for the loan
totals 1.2 million SF and includes the J. C. Penney anchor space
and the pad sites ground leased to the other four. The property
benefits from a large mix of luxury and mass market tenants that
appeal to a wide variety of shoppers.

The sponsor recently completed a $230 million expansion which added
a new 226,641 SF two level wing on the east side of the mall. The
new wing is anchored by a two-story Zara, a two-story Topshop /
Topman and a 20,218 SF Apple cube store at the expansion entrance.
The property was 100% leased as of the December 2018 rent roll.

The property achieved net cash flow (NCF) of $35.3 million in the
first quarter of 2019, compared to $135.5 million for the year
2018. The first mortgage balance of $1.75 billion represents a
Moody's stabilized LTV of 85% and Moody's first mortgage DSCR is
0.89X. There are no outstanding interest shortfalls or losses as of
the current Distribution Date.


BEAR STEARNS 2005-EC1: Moody's Lowers Class M-2 Debt to B1(sf)
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of six tranches
from five transactions backed by Alt-A, Subprime, and Scratch and
Dent Loans issued by multiple issuers.

Complete rating actions are as follows:

Issuer: Bear Stearns Asset Backed Securities I Trust 2005-EC1

  Cl. M-2, Downgraded to B1 (sf); previously on Oct 14, 2016
  Upgraded to Ba1 (sf)

Issuer: Bear Stearns Asset Backed Securities Trust 2004-HE6

  Cl. M-1, Downgraded to Baa3 (sf); previously on Mar 5, 2013
  Downgraded to A3 (sf)

Issuer: Bear Stearns Asset-Backed Securities Trust 2003-SD3

  Cl. M-1, Downgraded to Baa3 (sf); previously on Jul 5, 2012
  Downgraded to Baa2 (sf)

Issuer: C-BASS Mortgage Loan Trust, Series 2005-CB4

  Cl. M-5, Downgraded to B2 (sf); previously on Jul 29, 2016
  Upgraded to B1 (sf)

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2004-4

  Cl. M-2, Downgraded to B1 (sf); previously on Jun 18, 2013
  Upgraded to Baa1 (sf)

  Cl. M-3, Downgraded to B1 (sf); previously on Oct 28, 2015
  Upgraded to Baa3 (sf)

RATINGS RATIONALE

The rating downgrades are due to the outstanding interest
shortfalls on these bonds which are not expected to be recouped as
the bonds have weak reimbursement mechanism for interest
shortfalls. As of July 2019 remittance, Class M-1 from Bear Stearns
Asset Backed Securities Trust 2004-HE6 had $24,192.14 and Classes
M-2 and M-3 from Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2004-4 had $97,379.06 and $85,354.84 of unpaid
interest shortfall respectively. The remaining bonds in the rating
action have outstanding interest shortfall ranging from $1,866.28
to $99,815.13. The rating actions also reflect recent performance
of the underlying pools and Moody's updated loss expectations on
the 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 July 2019 from 3.9% in July
2018. Moody's forecasts an unemployment central range of 3.5% to
4.5% for the 2019 year. Deviations from this central scenario could
lead to rating actions in the sector. House prices are another key
driver of US RMBS performance. Moody's expects house prices to
continue to rise in 2019. Lower increases than Moody's expects or
decreases could lead to negative rating actions. Finally,
performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


BHP TRUST 2019-BXHP: Moody's Gives (P)B2 Rating on Class HRR Certs
------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to seven
classes of CMBS securities, issued by BHP Trust 2019-BXHP,
Commercial Mortgage Pass-Through Certificates, Series 2019-BXHP:

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

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

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

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

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

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

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

RATINGS RATIONALE

The certificates are collateralized by a single loan backed by a
portfolio of 25 fee simple interests and two leaseholds interest in
27 select-service hotels. The single borrower underlying the
mortgage is comprised of nine special-purpose bankruptcy-remote
entities, each of which is indirectly owned and controlled by
Blackstone Real Estate Income Trust, Inc.

Moody's approach to rating this transaction involved the
application of its Large Loan and Single Asset/Single Borrower CMBS
methodology. The rating approach for securities backed by a single
loan compares the credit risk inherent in the underlying collateral
with the credit protection offered by the structure. The
structure's credit enhancement is quantified by the maximum
deterioration in property value that the securities are able to
withstand under various stress scenarios without causing an
increase in the expected loss for various rating levels. In
assigning single borrower ratings, 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.

The first mortgage balance of $415,000,000 represents a Moody's LTV
of 101.1%. The Moody's first mortgage actual DSCR is 2.85X and
Moody's first mortgage actual stressed DSCR is 1.21X.

Loan collateral is comprised of the borrower's fee (25 properties)
and leasehold (2 properties) interests in 27 select-service hotel
properties. The portfolio contains a total of 3,681 guestrooms
located across 12 states. The largest state concentration is
Florida, with nine properties totaling 1,083 keys and representing
32.5% of the ALA and 33.5% of the TTM net cash flow. The largest
hotel, Residence Inn Arlington Pentagon City, represents 16.5% of
the ALA.

Notable strengths of the transaction include: brand affiliation,
major markets, portfolio diversity, capital investment, and
experienced sponsorship.

Notable credit challenges of the transaction include: new supply
for select markets, property type performance volatility, the
loan's floating-rate and interest-only mortgage loan profile, and
credit negative legal features.

Moody's rating approach considers sequential pay in connection with
a collateral release as a credit neutral benchmark. Although the
loans' release premium mitigates the risk of a ratings downgrade
due to adverse selection, the pro rata payment structure limits
ratings upgrade potential as mezzanine classes are prevented from
building enhancement. The benefit received from pooling through
cross-collateralization is also reduced.

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

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

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.

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


BRAVO RESIDENTIAL 2019-NQM1: Fitch Gives B2 Rating on Cl. B2 Debt
-----------------------------------------------------------------
Fitch Ratings has assigned ratings to residential mortgage-backed
transaction BRAVO Residential Funding Trust 2019-NQM1 (BRAVO
2019-NQM1), issued by a private fund managed by Pacific Investment
Management Company LLC. The notes are supported by 724 loans with a
total balance of approximately $324.18 million as of the cutoff
date.

More than 80% of the pool was previously securitized in
transactions from 2016 and 2017 that have since been collapsed.
Approximately 69% of the pool is designated as non-Qualified
Mortgage, 23% consists of higher priced QM and close to 3%
comprises Safe Harbor QM while for the remainder the Ability to
Repay (ATR) does not apply.

BRAVO Residential Funding Trust 2019-NQM1

            Current Rating        Prior Rating
Class A1   LT AAAsf New Rating  previously at AAA(EXP)sf
Class A2   LT AAsf  New Rating  previously at AA(EXP)sf
Class A3   LT Asf   New Rating  previously at A(EXP)sf
Class B1   LT BBsf  New Rating  previously at BB(EXP)sf
Class B2   LT Bsf   New Rating  previously at B(EXP)sf
Class B3   LT NRsf  New Rating  previously at NR(EXP)sf
Class M1   LT BBBsf New Rating  previously at BBB(EXP)sf

KEY RATING DRIVERS

Non-Prime Credit Quality (Concern): The pool has a weighted average
(WA) model credit score of 717 and a Fitch derived WA
mark-to-market combined loan-to-value ratio (CLTV) of 64%. Of the
pool, 18% (by unpaid principal balance [UPB]) consists of borrowers
with prior credit events within the past seven years and 32% had a
debt to income (DTI) ratio of over 43%. Investor properties and
those run as investor properties for loss modelling (i.e.
nonpermanent residents) account for 8.8% of the pool.

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

Seasoned Performing Collateral (Positive): The pool has a WA loan
age of just over 36 months, and more than 90% of the pool is
seasoned for at least two years. The pool has benefited from rising
home prices since origination resulting in a drop of CLTV from 73.4
% at origination to 64.0%. Close to 83% of the pool has paid on
time for the past two years, while less than 9% has experienced a
delinquency within the last 12 months. Almost 4% of the pool was 30
days delinquent as of the cutoff date.

One Month Bank Statement Loans (Negative): Approximately 26% of the
pool was originated by Sterling Bank and Trust, FSB (Sterling) and
was underwritten to a one-month bank statement program for income
documentation. Fitch increased default expectations by 1.4x and
doubled the ATR adjustment for these loans. In addition to higher
credit enhancement, the risk is mitigated by Sterling's established
track record with the product (dating back to 2011) as well as the
considerably stronger credit profile and borrower equity on this
portion of the pool compared to the pool in aggregate. These
attributes also contribute to a strong defense to ATR claims.

To better benchmark the expected performance for the product, Fitch
looked at historical proxy performance for stated income loans with
FICOs greater than or equal to 680 and CLTVs from 50%-65% and
compared it to all prime full documentation performance. The
Sterling proxy data had fewer defaults than prime full
documentation loans in each vintage, which shows that historically
borrowers with attributes similar to Sterling's program have shown
an Ability-to-Repay comparable to prime full documentation loans.

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

Low Operational Risk (Positive): Certain investment vehicles
managed by PIMCO have a long operating history of aggregating
residential mortgage loans. PIMCO is assessed as 'Above Average' by
Fitch. The servicers for this transaction are Rushmore Loan
Management Servicer LLC (rated RPS2), Sterling Bank and Trust, FSB
(not rated by Fitch) and Select Portfolio Servicing, Inc. (rated
RPS1-).  Nationstar Mortgage LLC will be master servicer and is
rated 'RMS2+'. Strong loan quality was evidenced with third-party
due diligence performed by two Acceptable - Tier 1 diligence firms
on 100% of the pool. The issuer's retention of at least 5% of the
transaction's fair market value helps ensure an alignment of
interest between the issuer and investors.

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

Modified Sequential Payment Structure (Mixed): The structure
distributes principal pro rata among the senior notes while
shutting out the subordinate bonds from principal until all senior
notes  have been reduced to zero. If either of the cumulative loss
trigger event or the delinquency trigger event occurs over the
measurement period , principal will be distributed sequentially to
the class A-1, A-2 and A-3 notes until they are reduced to zero.

R&W Framework (Concern): The seller will be providing loan-level
representations and warranties to the trust. While the reps for
this transaction are substantively consistent with those listed in
Fitch's published criteria and provide a solid alignment of
interest, Fitch added approximately 118bps to the expected loss at
the 'AAAsf' rating category to reflect the non-investment-grade
counterparty risk of the provider and the lack of an automatic
review of defaulted loans, other than for loans with a realized
loss that have a complaint or counterclaim of a violation of ATR.
The lack of an automatic review is mitigated by the ability of
holders of 25% of the total outstanding aggregate class balance to
initiate a review.

Updated Valuations (Mixed): Given the seasoning of the loans,
updated property values were provided for all loans in the
transaction. In Fitch's analysis, the following waterfall was used
to determine the applicable value: if a BPO was provided, that
value was incorporated; if the loan was previously securitized, the
HDI value was used due to a property value review during the
previous securitization; otherwise, the HDI value was haircut by
10%.  

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

RATING SENSITIVITIES

Fitch's analysis incorporates a sensitivity analysis to demonstrate
how the ratings would react to steeper market value declines (MVDs)
than assumed at the MSA level. The implied rating sensitivities are
only an indication of some of the potential outcomes and do not
consider other risk factors that the transaction may become exposed
to or may be considered in the surveillance of the transaction.
Three sets of sensitivity analyses were conducted at the state and
national levels to assess the effect of higher MVDs for the subject
pool.

This defined stress sensitivity analysis demonstrates how the
ratings would react to steeper market value declines at the
national level. The analysis assumes market value declines of 10%,
20% and 30%, in addition to the model-projected 3.3%.

The defined rating sensitivities determine the stresses to MVDs
that would reduce a rating by one full category, to non-investment
grade and to 'CCCsf'.


BX TRUST 2019-MMP: Moody's Assigns (P)B3 Rating on Class F Certs
----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to eight
classes of CMBS securities, issued by BX Trust 2019-MMP, Commercial
Mortgage Pass-Through Certificates, Series 2019-MMP

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

Cl. X-CP*, Assigned (P)Baa2 (sf)

Cl. X-NCP*, Assigned (P)Baa2 (sf)

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

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

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

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

Cl. F, Assigned (P)B3 (sf)

* Reflects interest-only classes

RATINGS RATIONALE

The certificates are collateralized by one floating rate loan
secured by a fee simple interests in eleven multifamily properties
located across three Manhattan neighborhoods. Collectively, the
properties include a total of 637 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 1.64x and
Moody's first mortgage DSCR at a 9.25% stressed constant is 0.61x.

The trust loan balance of $271.7 million represents a Moody's LTV
ratio of 126.8% 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 subject
transaction is secured by eleven properties.

Positive features of the transaction include the property type,
strong location, capital investment, expert sponsorship and fresh
equity. Offsetting these strengths are high Moody's LTV, lack of
asset diversification, property age, floating rate interest profile
and credit negative legal features.

Moody's also grades properties on a scale of 0 to 5 (best to worst)
and considers those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The collateral's
overall property quality grade is 0.65.

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 class were "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in July 2017 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.

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

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

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

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

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

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

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.


CD 2019-CD8: Fitch Rates $8.832MM Class G-RR Certs 'B-sf'
---------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to CD 2019-CD8 Mortgage Trust Commercial Mortgage
Pass-Through Certificates, Series 2019-CD8.

  -- $10,401,000 class A-1 'AAAsf'; Outlook Stable;

  -- $7,644,000 class A-2 'AAAsf'; Outlook Stable;

  -- $16,457,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $180,750,000 class A-3 'AAAsf'; Outlook Stable;

  -- $334,331,000 class A-4 'AAAsf'; Outlook Stable;

  -- $49,070,000 class A-M 'AAAsf'; Outlook Stable;

  -- $40,237,000 class B 'AA-sf'; Outlook Stable;

  -- $38,275,000 class C 'A-sf'; Outlook Stable;

  -- $24,535,000b class D 'BBBsf'; Outlook Stable;

  -- $19,628,000b class E 'BBB-sf'; Outlook Stable;

  -- $21,591,000b class F 'BB-sf'; Outlook Stable;

  -- $8,832,000bc class G-RR 'B-sf'; Outlook Stable;

  -- $598,653,000a class X-A 'AAAsf'; Outlook Stable;

  -- $78,512,000ab class X-B 'A-sf'; Outlook Stable;

  -- $44,163,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $21,591,000ab class X-F 'BB-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $16,684,000bc class H-RRc;

  -- $16,684,305bc class J-RR;

  -- $26,000,000bd VRR Interest.

(a)Notional amount and interest only.

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

(c)Horizontal credit-risk retention interest.

(d)Vertical credit-risk retention interest.

Since Fitch published its expected ratings on Aug. 5, 2019, 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 $75,000,000 to $257,000,000 and
$258,081,000 to $440,081,000, respectively. The final class
balances for class A-3 and class A-4 are $180,750,000 and
$334,331,000, respectively. The classes reflect the final ratings
and deal structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 33 loans secured by 58
commercial properties having an aggregate principal balance of
$811,119,305 as of the cut-off date. The loans were contributed to
the trust by German American Capital Corporation, Citi Real Estate
Funding Inc., Cantor Commercial Real Estate Lending, L.P. and MUFG
Principal Commercial Capital.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 82.2% of the properties
by balance, cash flow analysis of 92.3% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch trust leverage is slightly worse
than other recent Fitch-rated, fixed-rate, multiborrower
transactions. The pool's Fitch LTV of 105.6% is worse than the YTD
2019 LTV average of 102.0% for other Fitch-rated multiborrower
transactions. Additionally, the pool's Fitch DSCR of 1.21x is
in-line with the YTD 2019 Fitch average DSCR of 1.21x for other
Fitch-rated multiborrower transactions.

Concentrated Pool: The pool is more concentrated than recent
Fitch-rated multiborrower transactions. The top 10 loans represent
60.8% of the pool by balance, which is higher than the YTD 2019
multiborrower transaction average of 52.5%. The pool's LCI score of
494 is higher than the YTD 2019 average of 395.

Investment Grade Credit Opinion Loans: Three loans, comprising
16.3% of the pool, have investment grade credit opinions. This is
above the YTD 2019 average of 13.2% for other recent Fitch-rated
multiborrower transactions. Woodlands Mall (8.6%) has an
investment-grade credit opinion of 'BBB-sf*' on a standalone basis.
Moffett Towers II - Buildings 3 & 4 (4.2%) has an investment-grade
credit opinion of 'BBB-sf*' on a standalone basis. Crescent Club
(3.4%) has an investment-grade credit opinion of 'BBBsf*' on a
standalone basis. Excluding investment-grade credit opinions, the
pool has a Fitch LTV and DSCR of 113.6% and 1.17x, respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 8.1% below
the most recent year's net operating income (NOI) for properties
for which a full-year NOI was provided, excluding properties that
were stabilizing during this period. Unanticipated further declines
in property-level NCF could result in higher defaults and loss
severities on defaulted loans and in potential rating actions on
the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the CD
2019-CD8 certificates and found that the transaction displays
average sensitivities to further declines in NCF. In a scenario in
which NCF declined a further 20% from Fitch's NCF, a downgrade of
the junior 'AAAsf' certificates to 'AA+sf' could result. In a more
severe scenario, in which NCF declined a further 30% from Fitch's
NCF, a downgrade of the junior 'AAAsf' certificates to 'A+sf' could
result.


CEDAR FUNDING X: S&P Assigns Prelim BB- (sf) Rating to Cl. E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Cedar
Funding X CLO Ltd.'s floating-rate notes.

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

The preliminary ratings are based on information as of Aug. 21,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect S&P's assessment of:

-- The diversification of the collateral pool.

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  
  Cedar Funding X CLO Ltd.

  Class                    Rating        Amount (mil. $)

  A                        AAA (sf)               258.00
  B                        AA (sf)                 46.00
  C (deferrable)           A (sf)                  24.00
  D (deferrable)           BBB- (sf)               24.00
  E (deferrable)           BB- (sf)                16.00
  Subordinated notes       NR                      35.75

  NR--Not rated.


CF TRUST 2019-MF1: S&P Assigns B- (sf) Rating to Class F Certs
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to CF Trust 2019-MF1's
commercial mortgage pass-through certificates.

The certificate issuance is a commercial mortgage-backed securities
(CMBS) transaction backed by a portion of a two-year,
floating-rate, interest-only mortgage loan with three one-year
extension options, secured by the fee interests in 34 Class-C
multifamily properties located in the Midwest and Southeast regions
of the U.S.

The ratings reflect the collateral's historic and projected
performance, the sponsor's and the manager's experience, the
trustee-provided liquidity, the loan terms, and the transaction's
structure. S&P Global Ratings determined that the mortgage loan has
a beginning and ending loan-to-value ratio of 107.1% based on its
value.

  RATINGS ASSIGNED
  CF Trust 2019-MF1

  Class       Rating      Amount (mil. $)
  A           AAA (sf)             67.961
  X-CP        BBB- (sf)           112.175(i)
  X-NCP       BBB- (sf)           112.175(i)
  X-G         NR                   14.747(i)
  B           AA- (sf)             17.654
  C           A- (sf)              13.124
  D           BBB- (sf)            13.436
  E           BB- (sf)             15.623
  F           B- (sf)              16.405
  G           NR                   14.747
  HRR(ii)     NR                    8.400

(i)Notional balance. The notional amount of the class X-CP and
X-NCP certificates will equal the certificate balances of the class
A, B, C, and D certificates, and the notional amount of the class
X-G certificates will equal the certificate balance of the class G
certificates.
(ii)Non-offered horizontal risk retention certificates, which will
be retained by Cantor Commercial Real Estate Lending L.P. as the
retaining sponsor.
NR--Not rated.


CIM TRUST 2019-J1: DBRS Assigns Prov. B Rating on Class B-5 Certs
-----------------------------------------------------------------
DBRS, Inc. assigned the following provisional ratings to the
Mortgage Pass-Through Certificates, Series 2019-J1 (the
Certificates) to be issued by CIM Trust 2019-J1:

-- $214.2 million Class 1-A-1 at AAA (sf)
-- $214.2 million Class 1-A-2 at AAA (sf)
-- $214.2 million Class 1-A-3 at AAA (sf)
-- $160.6 million Class 1-A-4 at AAA (sf)
-- $160.6 million Class 1-A-5 at AAA (sf)
-- $160.6 million Class 1-A-6 at AAA (sf)
-- $53.5 million Class 1-A-7 at AAA (sf)
-- $53.5 million Class 1-A-8 at AAA (sf)
-- $53.5 million Class 1-A-9 at AAA (sf)
-- $171.3 million Class 1-A-10 at AAA (sf)
-- $171.3 million Class 1-A-11 at AAA (sf)
-- $171.3 million Class 1-A-12 at AAA (sf)
-- $42.8 million Class 1-A-13 at AAA (sf)
-- $42.8 million Class 1-A-14 at AAA (sf)
-- $42.8 million Class 1-A-15 at AAA (sf)
-- $10.7 million Class 1-A-16 at AAA (sf)
-- $10.7 million Class 1-A-17 at AAA (sf)
-- $10.7 million Class 1-A-18 at AAA (sf)
-- $25.2 million Class 1-A-19 at AAA (sf)
-- $25.2 million Class 1-A-20 at AAA (sf)
-- $25.2 million Class 1-A-21 at AAA (sf)
-- $239.4 million Class 1-A-22 at AAA (sf)
-- $239.4 million Class 1-A-23 at AAA (sf)
-- $239.4 million Class 1-A-24 at AAA (sf)
-- $239.4 million Class 1-A-IO1 at AAA (sf)
-- $214.2 million Class 1-A-IO2 at AAA (sf)
-- $214.2 million Class 1-A-IO3 at AAA (sf)
-- $214.2 million Class 1-A-IO4 at AAA (sf)
-- $160.6 million Class 1-A-IO5 at AAA (sf)
-- $160.6 million Class 1-A-IO6 at AAA (sf)
-- $160.6 million Class 1-A-IO7 at AAA (sf)
-- $53.5 million Class 1-A-IO8 at AAA (sf)
-- $53.5 million Class 1-A-IO9 at AAA (sf)
-- $53.5 million Class 1-A-IO10 at AAA (sf)
-- $171.3 million Class 1-A-IO11 at AAA (sf)
-- $171.3 million Class 1-A-IO12 at AAA (sf)
-- $171.3 million Class 1-A-IO13 at AAA (sf)
-- $42.8 million Class 1-A-IO14 at AAA (sf)
-- $42.8 million Class 1-A-IO15 at AAA (sf)
-- $42.8 million Class 1-A-IO16 at AAA (sf)
-- $10.7 million Class 1-A-IO17 at AAA (sf)
-- $10.7 million Class 1-A-IO18 at AAA (sf)
-- $10.7 million Class 1-A-IO19 at AAA (sf)
-- $25.2 million Class 1-A-IO20 at AAA (sf)
-- $25.2 million Class 1-A-IO21 at AAA (sf)
-- $25.2 million Class 1-A-IO22 at AAA (sf)
-- $239.4 million Class 1-A-IO23 at AAA (sf)
-- $239.4 million Class 1-A-IO24 at AAA (sf)
-- $239.4 million Class 1-A-IO25 at AAA (sf)
-- $46.4 million Class 2-A-1 at AAA (sf)
-- $5.5 million Class 2-A-2 at AAA (sf)
-- $51.9 million Class 2-A-3 at AAA (sf)
-- $51.9 million Class 2-A-4 at AAA (sf)
-- $46.4 million Class 2-A-5 at AAA (sf)
-- $5.5 million Class 2-A-6 at AAA (sf)
-- $51.9 million Class 2-A-IO1 at AAA (sf)
-- $46.4 million Class 2-A-IO2 at AAA (sf)
-- $5.5 million Class 2-A-IO3 at AAA (sf)
-- $51.9 million Class 2-A-IO4 at AAA (sf)
-- $30.7 million Class A-M at AAA (sf)
-- $4.8 million Class B-1 at AA (sf)
-- $2.9 million Class B-2 at A (sf)
-- $3.8 million Class B-3 at BBB (sf)
-- $2.0 million Class B-4 at BB (sf)
-- $613.0 thousand Class B-5 at B (sf)

Classes 1-A-IO1, 1-A-IO2, 1-A-IO3, 1-A-IO4, 1-A-IO5, 1-A-IO6,
1-A-IO7, 1-A-IO8, 1-A-IO9, 1-A-IO10, 1-A-IO11, 1-A-IO12, 1-A-IO13,
1-A-IO14, 1-A-IO15, 1-A-IO16, 1-A-IO17, 1-A-IO18, 1-A-IO19,
1-A-IO20, 1-A-IO21, 1-A-IO22, 1-A-IO23, 1-A-IO24, 1-A-IO25,
2-A-IO1, 2-A-IO2, 2-A-IO3 and 2-A-IO4 are interest-only
certificates. The class balances represent notional amounts.

Classes 1-A-1, 1-A-2, 1-A-3, 1-A-4, 1-A-5, 1-A-7, 1-A-8, 1-A-9,
1-A-10, 1-A-11, 1-A-12, 1-A-13, 1-A-14, 1-A-16, 1-A-17, 1-A-19,
1-A-20, 1-A-22, 1-A-23, 1-A-24, 1-A-IO2, 1-A-IO3, 1-A-IO4, 1-A-IO5,
1-A-IO8, 1-A-IO9, 1-A-IO10, 1-A-IO11, 1-A-IO12, 1-A-IO13, 1-A-IO14,
1-A-IO17, 1-A-IO20, 1-A-IO23, 1-A-IO24, 1-A-IO25, 2-A-3, 2-A-4,
2-A-5, 2-A-6, 2-A-IO4 and A-M are exchangeable certificates. These
classes can be exchanged for a combination of exchange certificates
as specified in the offering documents.

Classes 1-A-1, 1-A-2, 1-A-3, 1-A-4, 1-A-5, 1-A-6, 1-A-7, 1-A-8,
1-A-9, 1-A-10, 1-A-11, 1-A-12, 1-A-13, 1-A-14, 1-A-15, 1-A-16,
1-A-17, 1-A-18, 2-A-1 and 2-A-5 are super-senior certificates.
These classes benefit from additional protection from
senior-support certificates (Classes 1-A-19, 1-A-20, 1-A-21, 2-A-2,
2-A-6 and A-M) with respect to loss allocation.

The AAA (sf) ratings on the Certificates reflect the 5.00% of
credit enhancement provided by subordinated certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 3.45%, 2.50%, 1.25%, 0.60% and 0.40% of credit enhancement,
respectively.

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

This transaction is a securitization of a portfolio of first-lien
fixed-rate prime residential mortgages funded by the issuance of
the Certificates. The Certificates are backed by 414 loans with a
total principal balance of $306,611,428 as of the Cut-Off Date
(August 1, 2019).

The mortgage loans are divided into two collateral groups based on
original terms to maturity. Group 1 (82.2% of the aggregate pool)
consists of fully amortizing fixed-rate mortgages (FRMs) with
original terms to maturity of 30 years, while Group 2 (17.8% of the
aggregate pool) consists of fully amortizing FRMs with original
terms to maturity of 15 years.

The originators for the aggregate mortgage pool are Quicken Loans
Inc. (Quicken; 38.2%); Guaranteed Rate Inc. (12.1%); loanDepot.com,
LLC (10.9%); Home Point Financial Corporation (8.2%); Sierra
Pacific Mortgage Company, Inc. (5.6%); and various other
originators, each comprising no more than 5.0% of the pool by
principal balance. On the Closing Date, the Seller, Fifth Avenue
Trust, will acquire the mortgage loans from Bank of America, N.A.
(BANA; rated AA (low) with a Stable trend by DBRS). Through bulk
purchases, BANA generally acquired the mortgage loans underwritten
(1) to its jumbo whole-loan acquisition guidelines (40.4%), (2) to
Fannie Mae or Freddie Mac's Automated Underwriting System (10.7%),
(3) to the Quicken guidelines (38.2%) or (4) pursuant to the
guidelines of the related originator (10.7%). DBRS conducted an
operational risk assessment on BANA's aggregator platform, as well
as certain originators, and deemed them acceptable.

Shellpoint Mortgage Servicing will service 100% of the mortgage
loans, directly or through sub-servicers. Wells Fargo Bank, N.A.
(rated AA with a Stable trend by DBRS) will act as Master Servicer,
Securities Administrator and Custodian. Wilmington Savings Fund
Society, FSB will serve as Trustee. Chimera Funding TRS LLC will
serve as the Representations and Warranties (R&W) Provider.

The holder of a majority of the most subordinate class of
certificates (the Controlling Holder) has the option to engage an
asset manager to review the Servicer's actions regarding the
mortgage loans, which include determining whether the Servicer is
making modifications or servicing the loans in accordance with the
pooling and servicing agreement.

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

The Group 1 and Group 2 senior certificates will be backed by
collateral from each respective pool. The subordinate certificates
will be cross-collateralized between the two pools. This is
generally known as a Y-structure. The ratings reflect transactional
strengths that include high-quality underlying assets,
well-qualified borrowers, satisfactory third-party due diligence on
all the loans and structural enhancements.

This transaction employs an R&W framework that contains certain
weaknesses, such as unrated entities providing R&W, unrated
entities (the R&W Provider) providing a backstop and sunset
provisions on the backstop. To capture the perceived weaknesses,
DBRS reduced the originator scores for all loans in this pool. A
lower originator score results in increased default and loss
assumptions and provides additional cushions for the rated
securities.

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


CIM TRUST 2019-J1: Moody's Assigns (P)B2 Rating on Cl. B-5 Debt
---------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to 36
classes of residential mortgage-backed securities issued by CIM
Trust 2019-J1. The ratings range from (P)Aaa (sf) to (P)B2 (sf).

CIM Trust 2019-J1 is a two-pool Y-structure securitization of 15
and 30-year prime residential mortgages. The first pool consists of
all 30-year fixed rate mortgages (Group 1) and the second pool
consists of all 15-year fixed rate mortgages (Group 2).

This transaction represents the first non-investor prime jumbo
issuance by Chimera Investment Corporation (the sponsor) in 2019.
The transaction includes 414 fixed rate, first lien-mortgages.
There are 56 GSE-eligible high balance (10.7% by balance) and 358
prime jumbo (89.3% by loan balance) mortgage loans in the pool. The
mortgage loans for this transaction have been acquired by the
affiliate of the sponsor, Fifth Avenue Trust (the Seller) from Bank
of America, National Association (BANA). Approximately 89.3% of the
loans by balance, were acquired by BANA through its jumbo whole
loan purchase program from various mortgage loan originators or
sellers underwritten to various originators or Chimera acquisition
criteria. All other mortgage loans (10.7% by loan balance), were
high balance conforming loans acquired by BANA through its whole
loan purchase program from United Shore Financial Services LLC and
loanDepot.com, LLC, which were originated pursuant to Fannie Mae
guidelines with no overlays. All of the loans are designated as
qualified mortgages (QM) either under the QM safe harbor or the GSE
temporary exemption under the Ability-to-Repay (ATR) rules.
Shellpoint Mortgage Servicing (SMS) will service the loans and
Wells Fargo Bank, N.A. (Aa2) will be the master servicer. SMS will
be the servicer and responsible for advancing principal and
interest and servicing advances, with the master servicer backing
up SMS' advancing obligations if SMS cannot fulfill them.

Two third-party review (TPR) firms verified the accuracy of the
loan level information that Moody's received from the Sponsor.
These firms conducted detailed credit, property valuation, data
accuracy and compliance reviews on 100% of the mortgage loans in
the collateral pool. In addition, all Stearns Lending loans (13
loans) were reviewed by two independent TPR firms. The TPR results
indicate that there are no material compliance, credit, or data
issues and no appraisal defects.

Moody's analyzed the underlying mortgage loans using Moody's
Individual Loan Analysis (MILAN) model. Moody's also compared the
collateral pool to other prime jumbo securitizations. In addition,
Moody's adjusted its expected losses based on qualitative
attributes, including the financial strength of the representation
and warranties (R&W) provider. Its expected losses in a base case
scenario are 0.35% and 0.15% for Group 1 and Group 2, respectively,
and reach 4.95% and 1.70% for Group 1 and Group 2, respectively, at
a stress level consistent with its Aaa(sf) rating scenario for.

CIM 2019-J1 has a shifting interest structure with a five-year
lockout period that benefits from a senior subordination floor and
a subordinate floor. Moody's coded the cash flow to each of the
certificate classes using Moody's proprietary cash flow tool. In
its analysis of tail risk, Moody's considered the increased risk
from borrowers with more than one mortgage in the pool.

The complete rating actions are as follows:

Issuer: CIM Trust 2019-J1

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

Cl. 1-A-2, Assigned (P)Aaa (sf)

Cl. 1-A-3, Assigned (P)Aaa (sf)

Cl. 1-A-4, Assigned (P)Aaa (sf)

Cl. 1-A-5, Assigned (P)Aaa (sf)

Cl. 1-A-6, Assigned (P)Aaa (sf)

Cl. 1-A-7, Assigned (P)Aaa (sf)

Cl. 1-A-8, Assigned (P)Aaa (sf)

Cl. 1-A-9, Assigned (P)Aaa (sf)

Cl. 1-A-10, Assigned (P)Aaa (sf)

Cl. 1-A-11, Assigned (P)Aaa (sf)

Cl. 1-A-12, Assigned (P)Aaa (sf)

Cl. 1-A-13, Assigned (P)Aaa (sf)

Cl. 1-A-14, Assigned (P)Aaa (sf)

Cl. 1-A-15, Assigned (P)Aaa (sf)

Cl. 1-A-16, Assigned (P)Aaa (sf)

Cl. 1-A-17, Assigned (P)Aaa (sf)

Cl. 1-A-18, Assigned (P)Aaa (sf)

Cl. 1-A-19, Assigned (P)Aa1 (sf)

Cl. 1-A-20, Assigned (P)Aa1 (sf)

Cl. 1-A-21, Assigned (P)Aa1 (sf)

Cl. 1-A-22, Assigned (P)Aaa (sf)

Cl. 1-A-23, Assigned (P)Aaa (sf)

Cl. 1-A-24, Assigned (P)Aaa (sf)

Cl. 2-A-1, Assigned (P)Aaa (sf)

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

Cl. 2-A-3, Assigned (P)Aaa (sf)

Cl. 2-A-4, Assigned (P)Aaa (sf)

Cl. 2-A-5, Assigned (P)Aaa (sf)

Cl. 2-A-6, Assigned (P)Aaa (sf)

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

Cl. B-1, Assigned (P)A1 (sf)

Cl. B-2, Assigned (P)A2 (sf)

Cl. B-3, Assigned (P)Baa2 (sf)

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

Cl. B-5, Assigned (P)B2 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Its expected losses in a base case scenario are 0.35% and 0.15% for
Group 1 and Group 2, respectively, and reach 4.95% and 1.70% for
Group 1 and Group 2, respectively, at a stress level consistent
with its Aaa(sf) rating scenario. Moody's arrived at these expected
losses using its MILAN model.

Its loss estimates are based on a loan-by-loan assessment of the
securitized collateral pool as of the cut-off date using Moody's
Individual Loan Level Analysis (MILAN) model. Loan-level
adjustments to the model included adjustments to borrower
probability of default for higher and lower borrower debt-to-income
ratios (DTIs), for borrowers with multiple mortgaged properties,
self-employed borrowers, and for risks related to mortgaged
properties in Homeownership associations (HOAs) in super lien
states. Its loss levels and provisional ratings on the certificates
also took into consideration qualitative factors such as the
results of the third-party due diligence review, origination
quality, the servicing arrangement, alignment of interest of the
sponsor with investors, the representations and warranties (R&W)
framework, and the transaction's legal structure and
documentation.

Collateral Description

Moody's assessed the collateral pool as of the cut-off date of
August 1, 2019. CIM 2019-J1 is a securitization of 414 mortgage
loans with an aggregate principal balance of $306,611,428. The
transaction will have two-pool Y-structure securitization of 15 and
30-year prime residential mortgages. The first pool consists of all
30-year fixed rate mortgages (Group 1) and the second pool consists
of all 15-year fixed rate mortgages (Group 2).

This transaction consists of fixed-rate fully amortizing loans,
which will not expose the borrowers to any interest rate shock for
the life of the loan or to refinance risk. All of the mortgage
loans are secured by first liens on one- to four- family
residential properties, condominiums, planned unit developments and
one co-opertaive. The loans have a weighted average seasoning of
approximately 7 months (7 months and 5 months for Group 1 and Group
2, respectively).

Overall, the credit quality of the mortgage loans backing this
transaction is in line with recently issued prime jumbo
transactions. The WA FICO of the aggregate pool is 770 with a WA
LTV of 66.2% and WA CLTV of 66.4%. Approximately 32.5% (by loan
balance) of the pool has a LTV ratio greater than 75% compared to
39.5% in CIM 2018-J1. High LTV loans generally have a higher
probability of default and higher loss severity compared to lower
LTV loans.

There are 108 seasoned loans in the pool that were originated
before August 2018. These 108 loans had a weighted average current
primary borrower median FICO of 767 as compared to weighted average
original primary borrower median FICO of 762. In addition, 23 out
of 108 loans had 30 days or delinquent in the past. Most of these
delinquencies were due to servicing transfer as reported by the
issuer. All loans are current as of the cut-off date. Since
origination, the loans in the pool have performed well with minimal
historical delinquencies. 25 of the mortgage loans, representing
5.8% of the aggregate stated balance of the pool as of the Cut-off
Date, have been 30 days or more delinquent since origination, but
are now current under the methodology used by the Mortgage Bankers
Association (the "MBA Method"). For 21 of these mortgage loans that
had been 30 days or more delinquent prior to the Cut-off Date, the
delinquency occurred around the time of a servicing transfer and
the sponsor believes that these delinquencies were related to the
transfer of the servicing on such mortgage loans. For the remaining
four loans, there were true delinquencies in the past but are all
self-cured as of the cut-off date. Origination

There are 18 originators in the transaction, some of which may have
limited history of securitizing prime jumbo mortgages. The largest
originators in the pool with more than 5% by balance are Quicken
Loans Inc (38.1%), Guaranteed Rate, Inc. (12.1%), loanDepot.com,
LLC (10.9%), Home Point Financial Corporation (8.2%), and Sierra
Pacific Mortgage Company Inc (5.6%). Of note, Stearns Lending
recently filed for bankruptcy. Two independent third party review
firms reviewed all Stearns Lending loans and no material exceptions
were noted by the TPR firms. R&Ws from Stearns will be assign
through to the trust and Chimera will provide backstop R&Ws which
expires after 5 years subject to performance.

Underwriting guidelines:

Approximately 89.3% of the loans by loan balance, are prime jumbo
loans of which 40.4% were underwritten to Chimera's underwriting
guidelines and 48.8% of the loans were underwritten to respective
originator guidelines. 10.7% of the loans are conforming loans and
were originated in conformance to GSE guidelines with no overlays.
The GSE-eligible loans also do not include loans originated under
the GSEs' affordability programs such as HomeReady and
HomePossible. None of the GSE-eligible loans were originated under
streamlined documentation programs such as DU Refi Plus.

Moody's increased its base case and Aaa loss expectations for all
loans underwritten to Chimera's underwriting guidelines, as Moody's
considers the underwriting guidelines to be slightly weaker. For
loans that were not acquired under Chimera's guidelines Moody's
made adjustments based on the origination quality of such loans. Of
note, Moody's increased its base case and Aaa loss expectations for
Quicken loans(38.1% of the collateral balance), loans originated by
Home Point (8.2% of the collateral balance) and Stearns lending
loans (3.8% of the collateral balance).

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

Two third party review (TPR) firms verified the accuracy of the
loan-level information that Moody's received from the sponsor.
These firms conducted detailed credit, property valuation, data
integrity and regulatory compliance reviews on 100% of the mortgage
pool. In addition a FICO refresh was ordered on loans which were
aged between 6 months from origination and July 2019. The TPR
results indicated compliance with the originators' and aggregators'
underwriting guidelines for the vast majority of the loans, no
material compliance issues, and no material appraisal defects.

Each originator will provide comprehensive loan level reps and
warranties for their respective loans. BANA will assign each
originator's R&W to the seller, who will in turn assign to the
depositor, which will assign to the trust. To mitigate the
potential concerns regarding the originators' ability to meet their
respective R&W obligations, the seller will backstop the R&Ws for
all originators loans. The seller's obligation to backstop third
party R&Ws will terminate 5 years after the closing date, subject
to certain performance conditions. The seller will also provide the
gap reps.

The R&W framework is adequate in part because the results of the
independent TPRs revealed a high level of compliance with
underwriting guidelines and regulations, as well as overall
adequate appraisal quality. These results give confidence that the
loans do not systemically breach the R&Ws the originators have made
and that the originators are unlikely to face material repurchase
requests in the future. The loan-level R&Ws are strong and, in
general, either meet or exceed the baseline set of credit-neutral
R&Ws Moody's identified for US RMBS. Among other considerations,
the R&Ws address property valuation, underwriting, fraud, data
accuracy, regulatory compliance, the presence of title and hazard
insurance, the absence of material property damage, and the
enforceability of mortgage.

Tail Risk and Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
shrinks, senior bonds are exposed to increased performance
volatility, known as tail risk. The transaction provides for a
senior subordination floor of 1.65% of the closing pool balance,
which mitigates tail risk by protecting the senior bonds from
eroding credit enhancement over time. Additionally there is a
subordination lock-out amount which is 1.45% of the closing pool
balance.

Of note, as per its US RMBS surveillance methodology, Moody's will
not maintain ratings on securities in the deal once any of the
underlying pools has decreased to an effective number (The
effective number is a measure of the pool diversity that looks
beyond the nominal number of borrowers in a pool to take into
account the actual size of their loans and express this number in
terms of equally sized exposures) of borrowers of 15 or below. For
instance, if the effective number of borrowers in group 2 becomes
15 or below, Moody's will not maintain ratings on any of the
securities in the deal.

Exposure to extraordinary expenses

Extraordinary trust expenses in this transaction are deducted from
net WAC. Moody's believes there is a very low likelihood that the
rated certificates in CIM 2019-J1 will incur any losses from
extraordinary expenses or indemnification payments from potential
future lawsuits against key deal parties. Firstly, the loans are of
prime quality and were originated under a regulatory environment
that requires tighter controls for originations than pre-crisis,
which reduces the likelihood that the loans have defects that could
form the basis of a lawsuit. Secondly, the transaction has
reasonably well-defined processes in place to identify loans with
defects on an ongoing basis. In this transaction, an independent
breach reviewer must review loans for breaches of representations
and warranties when certain clearly defined triggers have been
breached which reduces the likelihood that parties will be sued for
inaction. Furthermore, the issuer has disclosed results of the
credit, compliance and valuation review of 100% of the mortgage
loans by independent third parties.

Other Considerations

In CIM 2019-J1, the controlling holder has the option to hire at
its own expense the independent reviewer upon the occurrence of a
review event. If there is no controlling holder (no single entity
holds a majority of the Class Principal Amount of the most
subordinate class of certificates outstanding), the trustee shall,
upon receipt of a direction of the certificateholders of more than
25% of the aggregate voting interest of all certificates and upon
receipt of the deposit, appoint an independent reviewer at the cost
of the trust. However, if the controlling holder does not hire the
independent reviewer, the holders of more than 50% of the aggregate
voting interests of all outstanding certificates may direct (at
their expense) the trustee to appoint an independent reviewer. In
this transaction, the controlling holder can be the depositor or a
seller (or an affiliate of these parties). If the controlling
holder is affiliated with the depositor, seller or Sponsor, then
the controlling holder may not be motivated to discover and enforce
R&W breaches for which its affiliate is responsible.

The servicer will not commence foreclosure proceedings on a
mortgage loan unless the servicer has notified the controlling
holder at least five business days in advance of the foreclosure
and the controlling holder has not objected to such action. If the
controlling holder objects, the servicer has to obtain three
appraisals from the appraisal firms as listed in the pooling and
servicing agreement. The cost of the appraisals are borne by the
controlling holder. The controlling holder will be required to
purchase such mortgage loan at a price equal to the highest of the
three appraisals plus accrued and unpaid interest on such mortgage
loan as of the purchase date. If the servicer cannot obtain three
appraisals there are alternate methods for determining the purchase
price . If the controlling holder fails to purchase the mortgage
loan within the time frame, the controlling holder forfeits any
foreclosure rights thereafter. Moody's considers this credit
neutral because a) the appraiser is chosen by the servicer from the
approved list of appraisers, b) the fair value of the property is
decided by the servicer, based on third party appraisals, and c)
the controlling holder will pay the fair price and accrued
interest.

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.


CITIGROUP 2019-IMC1: S&P Assigns Prelim B (sf) Rating on B-2 Certs
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Citigroup
Mortgage Loan Trust 2019-IMC1's (CMLTI 2019-IMC1's) mortgage
pass-through certificates.

The issuance is an RMBS transaction backed by first-lien fixed- and
adjustable-rate fully amortizing residential mortgage loans (some
with interest-only periods) secured by single-family residential
properties, planned-unit developments, condominiums, and two- to
four-family residential properties to both prime and nonprime
borrowers. The loans are primarily nonqualified mortgage loans.

The preliminary ratings are based on information as of Aug. 22,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The pool's collateral composition,
-- The credit enhancement provided for this transaction,
-- The transaction's associated structural mechanics,
-- The representation and warranty (R&W) framework for this
transaction,
-- The geographic concentration, and
-- The mortgage originator, Impac Mortgage Corp.

  PRELIMINARY RATINGS ASSIGNED
  Citigroup Mortgage Loan Trust 2019-IMC1

  Class      Rating(i)     Amount ($)
  A-1        AAA (sf)     253,262,000
  A-2        AA+ (sf)      13,416,000
  A-3        A (sf)        40,790,000
  M-1        BBB (sf)      21,030,000
  B-1        BB (sf)       17,403,000
  B-2        B (sf)        11,422,000
  B-3        NR             5,257,635
  A-IO-S     NR              Notional(ii)
  XS         NR              Notional(ii)
  BC(iii)    NR             5,257,635
  R          NR                   N/A

(i)The collateral and structural information reflects the term
sheet dated Aug. 19, 2019. The preliminary ratings reflect the
ultimate payment of interest and principal.
(ii)The notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period.
(iii)A combination of classes B-3, A-IO-S, and XS may be exchanged
for class BC.
NR--Not rated.
N/A--Not applicable.


CITIGROUP COMMERCIAL 2013-GC17: Fitch Affirms B Rating on F Debt
----------------------------------------------------------------
Fitch Ratings has upgraded five classes of Citigroup Commercial
Mortgage Trust commercial mortgage pass-through certificates,
series 2013-GC17.

CGCMT 2013-GC17
   
Class A-3   LT AAAsf  Affirmed  previously at AAAsf
Class A-4   LT AAAsf  Affirmed  previously at AAAsf
Class A-AB  LT AAAsf  Affirmed  previously at AAAsf
Class A-S   LT AAAsf  Affirmed  previously at AAAsf
Class B     LT AAsf   Upgrade   previously at AA-sf
Class C     LT Asf    Upgrade   previously at A-sf
Class D     LT BBBsf  Upgrade   previously at BBB-sf
Class E     LT BBsf   Affirmed  previously at BBsf
Class F     LT Bsf    Affirmed  previously at Bsf
Class PEZ   LT Asf    Upgrade   previously at A-sf
Class X-A   LT AAAsf  Affirmed  previously at AAAsf
Class X-B   LT AAsf   Upgrade   previously at AA-sf
Class X-C   LT BBsf   Affirmed  previously at BBsf

KEY RATING DRIVERS

Increased Credit Enhancement: The upgrades to classes B, C, D, PEZ
and X-B reflect increased credit enhancement from loan payoffs and
continued scheduled amortization since Fitch's last rating action.
As of the July 2019 distribution date, the pool's aggregate
principal balance has paid down by 28.4% to $620.9 million from
$867.0 million at issuance. Since Fitch's last rating action, five
loans ($120.5 million) were repaid at or prior to their scheduled
2018 maturity date, including the former largest loan, Ernst &
Young Tower ($86.9 million). Five loans (4.6% of pool) have been
defeased. The majority of the pool (49 loans; 84.7% of pool) is
currently amortizing and six loans (15.3%) are full-term,
interest-only.

Stable Performance and Loss Expectations: The majority of the
remaining pool has continued to exhibit stable performance since
issuance, with loss expectations in line with the prior rating
action. There have been no realized losses since issuance.
Cumulative interest shortfalls of approximately $410,000 are
currently affecting class G.

Fitch Loans of Concern: Fitch has designated two loans (4.6% of
pool) as Fitch Loans of Concern (FLOCs), both of which are among
the top 15, including one of which is in special servicing (2%).
The largest FLOC, Park Place Shopping Center (2.7%), is secured by
a retail center in Vallejo, CA. The property's Raley's grocery
anchor tenant closed in June 2017, ahead of its September 2017
lease expiration, and property occupancy remains low at 52.6% as of
March 2019, compared with 92.4% in December 2016. The second FLOC,
SpringHill Suites - Willow Grove, PA (2%), transferred to special
servicing in April 2017 for payment default and remains delinquent
as of July 2019. The lender was the successful bidder at the recent
foreclosure sale, with title scheduled to transfer to the lender by
August 2019. Property-level net cash flow as of YE 2018 had
declined over 50% from the issuer's underwritten amount, due
primarily to a decline in rates and occupancy, as well as increased
expenses.

Alternative Loss Considerations: Fitch's analysis included an
additional sensitivity scenario to further support the upgrades to
classes B, C, D, PEZ and X-B, that factored in the paydown of the
defeased loans and applied a 50% loss on the Park Place Shopping
Center loan to reflect the potential for outsized losses given the
high property vacancy and the borrower's lack of progress in
re-leasing the vacant anchor space, as well as a 100% loss on the
specially serviced SpringHill Suites - Willow Grove, PA loan to
reflect possible further performance declines. This sensitivity
scenario supports the rating upgrades.

ADDITIONAL CONSIDERATIONS

Pool Concentrations: Retail properties represent 62.2% of the
current pool by balance and include 11 of the top 15 loans (46.2%).
The retail exposure includes the largest loan, Miracle Mile Shops
(11.9%), a regional mall located along the Las Vegas Strip that has
reported strong in-line tenant sales above $800 per square foot
(psf) since issuance, and the second largest loan, The Outlet
Shoppes at Atlanta (11.7%), a retail outlet center located in
Woodstock, GA, approximately 30 miles north of Atlanta.

Additionally, four loans (9.4% of pool) are sponsored by Bon Aviv
Holdings LLC, including three loans in the top 15 (8.2%). All four
of these loans are secured by retail properties.

RATING SENSITIVITIES

The Rating Outlooks for all classes remain Stable due to the
overall stable pool performance, increasing credit enhancement and
expected continued paydown. Future rating upgrades may occur with
improved pool performance and additional defeasance or paydown.
Rating downgrades may be possible should overall performance
decline significantly.


CITIGROUP COMMERCIAL 2019-GC41: Fitch Rates Class F Certs 'BB-sf'
-----------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Citigroup Commercial Mortgage Trust 2019-GC41
commercial mortgage pass-through certificates, series 2019-GC41:

  -- $11,821,000 class A-1 'AAAsf'; Outlook Stable;

  -- $128,061,000 class A-2 'AAAsf'; Outlook Stable;

  -- $10,109,000 class A-3 'AAAsf'; Outlook Stable;

  -- $210,000,000 class A-4 'AAAsf'; Outlook Stable;

  -- $482,910,000 class A-5 'AAAsf'; Outlook Stable;

  -- $19,488,000 class A-AB 'AAAsf'; Outlook Stable;

  -- $971,728,000a class X-A 'AAAsf'; Outlook Stable;

  -- $109,339,000 class A-S 'AAAsf'; Outlook Stable;

  -- $69,299,000 class B 'AA-sf'; Outlook Stable;

  -- $50,819,000 class C 'A-sf'; Outlook Stable;

  -- $120,118,000ab class X-B 'A-sf'; Outlook Stable;

  -- $58,519,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $26,180,000ab class X-F 'BB-sf'; Outlook Stable;

  -- $32,340,000b class D 'BBBsf'; Outlook Stable;

  -- $26,179,000b class E 'BBB-sf'; Outlook Stable;

  -- $26,180,000b class F 'BB-sf'; Outlook Stable;

  -- $12,320,000bc class GRR 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $43,119,964bc class JRR;

  -- $44,650,000bd class VRR Interest.

(a) Notional amount and interest only.

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

(c) Horizontal credit-risk retention interest.

(d) Vertical credit-risk retention interest.

Since Fitch published its expected ratings on July 30, 2019, the
following changes occurred: the balances for class A-4 and class
A-5 were finalized. At the time that the expected ratings were
assigned, the exact initial certificate balances of class A-4 and
class A-5 were unknown and expected to be approximately
$693,106,000 in aggregate, subject to a 5% variance. The final
class balances for class A-4 and class A-5 are $210,000,000 and
$482,910,000, respectively. Additionally, the following class
balances have changed: A-1 balance reduced to $11,821,000 from
$11,825,000, A-2 balance reduced to $128,061,000 from $128,097,000,
A-3 balance reduced to $10,109,000 from $10,112,000, A-AB reduced
to $19,488,000 from $19,494,000, A-S balance reduced to
$109,339,000 from $109,370,000, B reduced to $69,299,000 from
$69,319,000, C reduced to $50,819,000 from $50,833,000, D reduced
to $32,340,000 from $32,349,000, E reduced to $26,179,000 from
$26,187,000, F reduced to $26,180,000 from $26,187,000, GRR reduced
to $12,320,000 from $12,324,000, JRR reduced to $43,119,964 from
$43,131,964, VRR increased to $44,650,000 from $44,300,000, and the
interest only balances reference the same classes with the ratings
reflecting the lowest rated class. The classes reflect the final
ratings and deal structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 43 loans secured by 100
commercial properties having an aggregate principal balance of
$1,276,634,964 as of the cut-off date. The loans were contributed
to the trust by Goldman Sachs Mortgage Securities, Citi Real Estate
Funding Inc. and German American Capital Corporation.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 82.3% of the properties
by balance, cash flow analysis of 85.1% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch leverage is better compared with
other recent Fitch-rated, fixed-rate, multiborrower transactions.
The pool's Fitch DSCR of 1.26x is better than the YTD 2019 and 2018
averages of 1.21x and 1.22x, respectively. The pool's Fitch LTV of
103.9% is slightly worse than the YTD 2019 and 2018 averages of
102.0%. Excluding investment-grade credit opinion loans, the pool
has a Fitch DSCR and LTV of 1.26x and 111.4%, respectively.

Limited Amortization: There are 27 loans that are full interest
only (80.5% of the pool), eight loans (9.2% of the pool) that are
partial interest only, eight loans (10.3% of the pool) that are
amortizing balloon loans and two ARD loans (9.0% of the pool).
Based on the scheduled balance at maturity, the pool will pay down
by just 2.7%, which is below the YTD 2019 and 2018 averages of 6.1%
and 7.2% respectively.

Investment-Grade Credit Opinion Loans: Four loans comprising 18.0%
of the pool, have investment-grade credit opinions. This is above
the YTD 2019 and 2018 averages of 13.2% and 13.6%, respectively.
Hudson Yards (7.8% of the pool) received a credit opinion of
'A-sf'* on a standalone basis. Grand Canal Shoppes (4.7% of the
pool), Moffett Towers II - Buildings 3 & 4 (4.3% of the pool) and
The Centre (1.2% of the pool) each received standalone credit
opinions of 'BBB-sf'*.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 6.9% below
the most recent year's net operating income (NOI) for properties
for which a full-year NOI was provided, excluding properties that
were stabilizing during this period. Unanticipated further declines
in property-level NCF could result in higher defaults and loss
severities on defaulted loans and in potential rating actions on
the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the
CGCMT 2019-GC41 certificates and found that the transaction
displays average sensitivities to further declines in NCF. In a
scenario in which NCF declined a further 20% from Fitch's NCF, a
downgrade of the junior 'AAAsf' certificates to 'A+sf' could
result. In a more severe scenario, in which NCF declined a further
30% from Fitch's NCF, a downgrade of the junior 'AAAsf'
certificates to 'BBB+sf' could result.


CITIGROUP MORTGAGE 2019-IMC1: DBRS Gives (P)B Rating on B2 Certs
----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following Mortgage
Pass-Through Certificates, Series 2019-IMC1 (the Certificates) to
be issued by Citigroup Mortgage Loan Trust 2019-IMC1 (CMLTI
2019-IMC1 or the Trust):

-- $245.8 million Class A-1 at AAA (sf)
-- $20.8 million Class A-2 at AA (sf)
-- $40.8 million Class A-3 at A (sf)
-- $21.0 million Class M-1 at BBB (sf)
-- $17.4 million Class B-1 at BB (sf)
-- $11.4 million Class B-2 at B (sf)

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

The AAA (sf) rating on the Class A-1 Certificates reflects 32.20%
of credit enhancement provided by subordinated Certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 26.45%, 15.20%, 9.40%, 4.60% and 1.45% of credit
enhancement, respectively.

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate, prime, expanded prime and non-prime first-lien
residential mortgages funded by the issuance of the Certificates.
The Certificates are backed by 932 mortgage loans with a total
principal balance of $362,580,636 as of the Cut-Off Date (August 1,
2019).

Impac Mortgage Corp (Impac) is the Originator of the loans, and Fay
Servicing LLC (Fay) is the Servicer.

The mortgages were originated under the following programs:

(1) iQM Bank Statement — Generally made to self-employed
borrowers using bank statements to support self-employed income for
qualification purposes.

(2) iQM Agency Plus — Generally made to prime borrowers with loan
amounts exceeding the government-sponsored enterprise (GSE) loan
limits who may fall outside the Qualified Mortgage (QM)
requirements based on debt-to-income or loans that have special
features that do not meet GSE guidelines.

(3) iQM Investor Program — Generally made to borrowers seeking
business-purpose loans for investment properties.

(4) iQM Asset Qualification — Generally made to borrowers with
significant assets equal to 60 months of all other monthly debts or
more.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's Ability-to-Repay (ATR) rules, they
were made to borrowers who generally do not qualify for the agency,
government or private-label non-agency prime jumbo products for
various reasons. In accordance with the QM/ATR rules, 64.2% of the
loans, including 1.9% made to investors that could not be verified
as being for business purposes, are designated as non-QM.
Approximately 35.8% of the loans are made to investors for business
purposes and, hence, are not subject to the QM/ATR rules.

Within the investor loan population, 26.7% of the aggregate pool
comprises loans originated through a debt service coverage ratio
(DSCR) program. Such DSCR borrowers were qualified using property
cash flows rather than traditional income. This transaction has a
larger concentration of DSCR loans than typical DBRS-rated non-QM
deals, which have ranged from approximately 0.0% to 17.2%. Of the
DSCR loans, 73.0% have a current lease in place, which contains a
rental value used in the DSCR calculation. In its analysis, DBRS
applies penalties to DSCR loans as described in the Key Probability
of Default Drivers section of the related presale. DBRS also
considers whether a borrower has a lease in place and reduces the
penalty for such loan.

Citigroup Global Markets Realty Corp. (CGMRC) is the Mortgage Loan
Seller and Sponsor of the transaction. DBRS rates the Long-Term
Issuer Rating and Long-Term Senior Debt of CGMRC's parent company,
Citigroup Inc., at A (high) with a Stable trend and its Short-Term
Instruments at R-1 (low) with a Stable trend. Citigroup Mortgage
Loan Trust Inc. is the Depositor and an affiliate of the Sponsor.

Wells Fargo Bank, N.A. (Wells Fargo; rated AA with a Stable trend
by DBRS) will act as the Custodian. U.S. Bank National Association
(rated AA (high) with a Stable Trend by DBRS) will serve as Trust
Administrator.

The Sponsor, directly or indirectly through a majority-owned
affiliate, will retain an eligible vertical residual interest in at
least 5% of the Certificates issued by the Issuer (other than the
Class R Certificates) to satisfy the credit risk-retention
requirements under Section 15G of the Securities Exchange Act of
1934 and the regulations promulgated thereunder.

On or after the earlier of (1) the two-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, the Clean-up Call Party has the option to purchase all the
mortgage loans from the Trust at a price equal to the aggregate
outstanding balance of the mortgage loans plus accrued and unpaid
interest as well as unreimbursed advances and fees. The Controlling
Holder (the majority holder of the most subordinate certificates
outstanding) will serve as the Clean-up Call Party unless the
Controlling Holder is the Mortgage Loan Seller or an affiliate, in
which case the Servicer will act as the Clean-up Call Party.

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

The transaction employs a sequential-pay cash flow structure with a
pro-rata principal distribution among the senior tranches.
Principal proceeds can be used to cover interest shortfalls on the
Certificates as the outstanding senior Certificates are paid in
full. Furthermore, the excess spread can be used to cover realized
losses first before being allocated to unpaid cap carryover amounts
up to
Class B-2.

The ratings reflect transactional strengths that include the
following:

-- Strong Representations and Warranties Framework
-- Robust Loan Attributes and Pool Composition
-- Satisfactory Third-Party Due Diligence Review
-- Improved Underwriting Standards
-- Compliance with the ATR Rules

The transaction also includes the following challenges and
mitigating factors:

-- Certain Non-Prime, Non-QM and Investor Loans
-- Servicer Advances of Delinquent Principal and Interest
-- Servicer's Financial Capability

Notwithstanding the above mitigating factors, DBRS adjusted the
expected losses upward across all rating categories to account for
the aforementioned challenges.

These strengths and challenges, along with other transaction
details, are discussed in depth in the relevant sections of the
presale report.

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


COMM MORTGAGE 2016-COR1: Fitch Affirms B-sf Rating on 2 Tranches
----------------------------------------------------------------
Fitch Ratings has affirmed German American Capital Corp.'s COMM
Mortgage Securities Trust 2016-COR1 commercial mortgage
pass-through certificates.

COMM 2016-COR1

Class A-1    LT AAAsf   Affirmed  previously at AAAsf
Class A-2    LT AAAsf   Affirmed  previously at AAAsf
Class A-3    LT AAAsf   Affirmed  previously at AAAsf
Class A-4    LT AAAsf   Affirmed  previously at AAAsf
Class A-M    LT AAAsf   Affirmed  previously at AAAsf
Class A-SB   LT AAAsf   Affirmed  previously at AAAsf
Class B      LT AA-sf   Affirmed  previously at AA-sf
Class C      LT A-sf    Affirmed  previously at A-sf
Class D      LT BBB-sf  Affirmed  previously at BBB-sf
Class E      LT BB-sf   Affirmed  previously at BB-sf
Class F      LT B-sf    Affirmed  previously at B-sf
Class X-A    LT AAAsf   Affirmed  previously at AAAsf
Class X-B    LT AA-sf   Affirmed  previously at AA-sf
Class X-C    LT BBB-sf  Affirmed  previously at BBB-sf
Class X-E    LT BB-sf   Affirmed  previously at BB-sf
Class X-F    LT B-sf    Affirmed  previously at B-sf

KEY RATING DRIVERS

Stable Loss Expectations: The overall pool continues to exhibit
stable performance and loss expectations remain stable since
issuance. Since Fitch's last rating action, the previous specially
serviced asset, Comfort Inn Jamestown (0.7% of the pool), was
liquidated which resulted in better than expected recoveries and
reduced the class A-1 certificates by $2.9 million; losses were
isolated to the non-rated class G certificates. One loan, the USC
Student Housing Portfolio (0.8% of the pool), is defeased. As of
the August 2019 remittance, there are no specially serviced or
delinquent loans. No loans were on the master servicer's watchlist
and there are no Fitch Loans of Concern.

Minimal Changes to Credit Enhancement: As of the August 2019
remittance, the pool's aggregate balance has been paid down by 2.5%
to $868.0 million from $890.7 million at issuance. Fifteen loans
(53.2% of the pool) are interest only for the full loan term,
including nine loans (45.6% of the pool) in the top 15. Fourteen
loans (24.6% of the pool) are partial interest only, including four
loans (13.3% of the pool) in the top 15. Ten loans of the 14
partial interest only loans (18.0% of the pool) are now amortizing.
The remaining loans in the pool are amortizing. Based on the
scheduled balance at maturity, the pool is only expected to be
reduced by 9.4%.

High Retail Concentration: Fifteen loans (28.1% of the pool) are
secured by retail properties including three loans (15.6%) in the
top 15, none of which are regional malls. The largest loan,
Glendale Fashion Center (9.4% of the pool), is secured by a 263,882
sf retail property located in Glendale, CA. The property is
anchored by a Ralph's, Nordstrom Rack and Ross Dress for Less. Per
the most recent tenant sales report as of YE 2018, sales at the
property have improved to $497 psf from $466 psf at YE 2017 and
$461 psf at issuance.

Investment Grade Credit Opinion Loans: Two loans (4.2% of the pool)
received stand-alone investment grade credit opinions at issuance.
Westfield San Francisco Shopping Centre (2.7%) received a credit
opinion of 'Asf' and Grant and Geary Center (1.5% of the pool)
received an investment grade credit opinion of 'A+sf'.

RATING SENSITIVITIES

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


CREDIT SUISSE 2003-C3: Fitch Lowers Class J Certs Rating to Csf
---------------------------------------------------------------
Fitch Ratings has downgrade one class and affirmed five classes of
Credit Suisse First Boston Mortgage Securities Corp. series 2003-C3
commercial mortgage pass-through certificates.

Credit Suisse First Boston Mortgage Securities Corp. 2003-C3

                     Current Rating     Prior Rating
Class J 22541QEG3   LT Csf Downgrade  previously at CCsf
Class K 22541QEH1   LT Dsf Affirmed   previously at Dsf
Class L 22541QEJ7   LT Dsf Affirmed   previously at Dsf
Class M 22541QEK4   LT Dsf Affirmed   previously at Dsf
Class N 22541QEL2   LT Dsf Affirmed   previously at Dsf
Class O 22541QEM0   LT Dsf Affirmed   previously at Dsf

KEY RATING DRIVERS

Significant Concentration of Specially Serviced Loans and High
Expected Losses: The downgrade to class J reflects a greater
certainty of loss. Loss expectations on the real-estate owned (REO)
assets, which comprise 66% of the current pool, have increased
since Fitch's last rating action and significant losses upon
liquidation are anticipated.

The largest asset in the pool (34%) is an REO retail center located
in Las Vegas, NV. The loan became REO in November 2016 after
experiencing cash flow issues and declines since 2012. Per recent
servicer updates, occupancy has improved to 70% as of August 2019
due to two recently executed leases, compared to a low of 27% in
2018. The Lowes pad is subject to a sandwich ground lease, which
was initially set to expire in January 2020 and recently extended
for five years. Per servicer commentary, the short-term extension
and recent Lowes store closings have created uncertainty for the
center. The servicer is currently reviewing recent REO sale bids.

The second specially serviced loan is collateralized by an office
property in Elmsford, NY (32%). The previously modified loan had
transferred to special servicing for the second time in January
2015 for a second payment and maturity default. The servicer filed
for foreclosure in April 2017, and the loan became REO in October
2018. Per servicer updates, previously identified code violations
and required repairs for the garage portion of the collateral has
been completed. Per the May 2019 rent roll, the property is 46%
occupied. The property is currently being marketed for sale.

Credit Enhancement Decline; Non-Recoverable Servicer Advances:
Credit enhancement has declined over the past 12 months as class K
is being reduced due to the lack of advancing by the master
servicer as a result of non-recoverable servicer advances. The
reduction is in the amount of principal payments no longer
advanced.  Any recoveries of these amounts to the remaining classes
will be reallocated after the final dispositions of the specially
serviced loans. One loan (9.2% of the pool) is fully defeased.

Concentrated Pool: The pool is highly concentrated with only four
of the original 250 loans remaining. The transaction balance has
been reduced by 99.3%, to $11.9 million as of July 2019 from $1.7
billion at issuance. This includes $52.5 million in incurred losses
to date (or 3.0% of the original pool balance). Due to the
concentrated nature of the pool, Fitch performed a look-through
analysis that grouped the remaining loans based on the likelihood
of repayment, in addition to potential losses from the liquidation
of specially serviced assets. Based on this analysis, losses to
class J are considered imminent.

Aside from the defeased loan, there is one performing loan (25%)
secured by a single tenant industrial property in Mooresville, NC.
The single tenant's lease expiration is co-terminus with the loans
maturity date in March 2023. The fully amortizing loan has had
stable performance since issuance, with first quarter 2019 debt
service coverage ratio reporting at 2.27x.

RATING SENSITIVITIES

The remaining classes' ratings are distressed and reflect the
expectation of losses on the specially serviced loans. Further
downgrades to class J will occur as losses are realized. No
upgrades are expected due to high loss expectations on the
remaining pool.


CSMC 2019-AFC1: S&P Assigns B+ (sf) Rating to Class B-2 Notes
-------------------------------------------------------------
S&P Global Ratings assigned its ratings to CSMC 2019-AFC1 Trust's
mortgage-backed notes.

The note issuance is a residential mortgage-backed securities
(RMBS) transaction backed by first-lien, fixed- and
adjustable-rate, fully amortizing residential mortgage loans to
both prime and nonprime borrowers.

The ratings reflect:

-- The pool's collateral composition;
-- The transaction's credit enhancement;
-- The transaction's associated structural mechanics;
-- The transaction's representation and warranty framework; and
-- The geographic concentration.

  RATINGS ASSIGNED
  CSMC 2019-AFC1 Trust

  Class     Rating(i)      Amount ($)
  A-1       AAA (sf)      282,009,000
  A-2       AA (sf)        20,283,000
  A-3       A (sf)         29,891,000
  M-1       BBB (sf)       11,743,000
  B-1       BB (sf)         7,295,000
  B-2       B+ (sf)         2,491,000
  B-3       NR              2,135,516
  A-IO-S    NR               Notional(ii)
  XS        NR               Notional(ii)
  PT(iii)   NR               Notional(iii)
  R         NR                    N/A

(i)The ratings assigned to the classes address the ultimate payment
of interest and principal.
(ii)Notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period.
(iii)Certain initial exchangeable notes are exchangeable for the
exchangeable notes and vice versa.
NR--Not rated.
N/A--Not applicable.


DBUBS 2011-LC2: Moody's Affirms B3 Rating on 2 Tranches
-------------------------------------------------------
Moody's Investors Service affirmed the ratings on 12 classes in
DBUBS 2011-LC2 Commercial Mortgage Trust, Commercial Mortgage
Pass-Through Certificates, Series 2011-LC2:

Cl. A-1, Affirmed Aaa (sf); previously on Dec 21, 2018 Affirmed Aaa
(sf)

Cl. A-1C, Affirmed Aaa (sf); previously on Dec 21, 2018 Affirmed
Aaa (sf)

Cl. A-1FL, Affirmed Aaa (sf); previously on Dec 21, 2018 Affirmed
Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on Dec 21, 2018 Affirmed Aaa
(sf)

Cl. B, Affirmed Aaa (sf); previously on Dec 21, 2018 Affirmed Aaa
(sf)

Cl. C, Affirmed Aa3 (sf); previously on Dec 21, 2018 Affirmed Aa3
(sf)

Cl. D, Affirmed Baa2 (sf); previously on Dec 21, 2018 Affirmed Baa2
(sf)

Cl. E, Affirmed Ba3 (sf); previously on Dec 21, 2018 Affirmed Ba3
(sf)

Cl. F, Affirmed B3 (sf); previously on Dec 21, 2018 Affirmed B3
(sf)

Cl. FX*, Affirmed B3 (sf); previously on Dec 21, 2018 Affirmed B3
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Dec 21, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed B1 (sf); previously on Dec 21, 2018 Affirmed B1
(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, Moody's stressed debt service coverage
ratio (DSCR) and the transaction's Herfindahl Index (Herf), are
within acceptable ranges.

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

Moody's rating action reflects a base expected loss of 1.8% of the
current pooled balance, essentially the same as at Moody's last
review. Moody's base expected loss plus realized losses is now 1.4%
of the original pooled balance, compared to 1.1% 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, loan concentration, an
increase in realized and expected losses from specially serviced
and troubled loans or interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the July 12, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 42% to $1.24 billion
from $2.14 billion at securitization. The certificates are
collateralized by 41 mortgage loans ranging in size from less than
1% to 16% of the pool, with the top ten loans (excluding
defeasance) constituting 68% of the pool. One loan, constituting 2%
of the pool, has an investment-grade structured credit assessment.
Ten loans, constituting 13% 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 nine, compared to a Herf of 12 at Moody's last
review.

Eight loans, constituting 25% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

One loan has been liquidated from the pool, resulting in an
aggregate realized loss of $7.7 million.

There are no loans in special servicing. Moody's has identified two
troubled loans due to either declining performance or recent tenant
departures. The troubled loans are secured by a retail property in
Chicago, Illinois and a full service hotel in Houston, Texas.

Moody's received full year 2017 and full or partial year 2018
operating results for 100% of the pool (excluding specially
serviced and defeased loans). Moody's weighted average conduit LTV
is 82%, compared to 81% 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
10% to the most recently available net operating income (NOI).
Moody's value reflects a weighted average capitalization rate of
9.2%.

Moody's actual and stressed conduit DSCRs are 1.47X and 1.25X,
respectively, compared to 1.49X and 1.26X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The loan with a structured credit assessment is the Angelica
Portfolio Loan ($20.5 million -- 1.7% of the pool), which is
secured by 12 industrial facilities located in eight states. The
properties are 100% occupied by Angelica Corporation under a
20-year lease, expiring in January 2030. The average age of the
collateral is 25 years. Due to the single tenant exposure, Moody's
utilized a lit/dark analysis on this portfolio. Moody's structured
credit assessment and stressed DSCR are a2 (sca.pd) and 1.66X,
respectively.

The top three conduit loans represent 46% of the pool balance. The
largest loan is the US Steel Tower Loan ($192.6 million -- 15.6% of
the pool), which is secured by a 64-story, Class A office building
located in downtown Pittsburgh, Pennsylvania. The property serves
as the headquarters for US Steel and the University of Pittsburgh
Medical Center (UPMC). The property was 86% leased as of March
2019, compared to 87% as of September 2017. Property performance
has improved and the loan has amortized 12% since securitization.
Moody's LTV and stressed DSCR are 75% and 1.33X, respectively,
compared to 76% and 1.32X at the last review.

The second largest loan is the Willowbrook Mall Loan ($185.6
million -- 15.0% of the pool), which is secured by a 400,00 square
foot (SF) portion of a 1.5 million SF regional mall located in
Houston, Texas. Anchors include Macy's, Macy's Men and Furniture,
Sears and J.C. Penney. All anchors own their own improvements and
are not part of the collateral. Total property occupancy was 99% as
of March 2019, unchanged from the occupancy in September 2017. The
property has continued to report strong tenant sales with
comparable in-line tenants less than 10,000 SF of $641 per square
foot for the trailing twelve month period ending September 2018.
Additionally, net operating income (NOI) has increased by more than
20% since securitization. The loan has amortized nearly 14% since
securitization and Moody's LTV and stressed DSCR are 79% and 1.19X,
respectively, compared to 81% and 1.17X at the last review.

The third largest loan is the 498 7th Avenue Loan ($184.3 million
-- 14.9% of the pool), which is secured by a 25-story office
building located between 36th and 37th Street in the Garment
District of New York City. As of March 2019 the property was 86%
leased, compared to 96% as of December 2017. The former largest
tenant, Group M Worldwide (41% of NRA), had a November 2018 lease
expiration, and the second largest tenant LN Holdings (21% of NRA)
vacated upon lease expiration in January 2019. The property has
experienced strong leasing activity in backfilling the vacated
space from its former two largest tenants. The servicer indicated
1999SEIU Healthcare Workers East plans to lease approximately 61%
of the NRA with a buildout expected to take 18 months. Furthermore,
the servicer has reported recent leasing activity with several
other tenants. The loan has amortized 8% since securitization.
Moody's LTV and stressed DSCR are 90% and 1.05X, respectively,
compared to 87% and 1.09X at the last review.

The fourth largest loan is the Barneys Chicago Loan ($70.8 million
-- 5.7% of the pool), which is secured by a 6 story retail property
located in Chicago, Illinois. The property was constructed in 2009
and is located on East Oak Street, 3 blocks west of Michigan Ave in
downtown Chicago. The property was built-to-suit for Barney's and
served as the flagship store for Barneys in Chicago. Barneys filed
for Chapter 11 bankruptcy in August 2019 and announced that they
will be closing this location. Barneys currently leases 95% of the
NRA through 2024 and represented approximately 86% of the 2018 base
rental revenue. The remainder of the square footage and base rent
is from Citibank, which recently renewed their lease through 2025.
If Barney's were to cease paying rent, the property's cash flow
would no longer cover its loan debt service payments and, in the
absence of a replacement tenant, would reduce the loan's ability to
refinance at loan maturity in May 2021. The property benefits from
its premier location in a high-density trade area within the Gold
Coast neighborhood of Chicago. However, finding a replacement
tenant for the higher floors could pose a challenge and potential
need for redevelopment to other uses. The loan benefits from
amortization and has amortized nearly 12% since securitization.
Moody's has identified this loan as a troubled loan due to the
heightened default risk in connection with the recent tenant
departure announcement.


DEUTSCHE FINANCIAL 1998-I: Moody's Hikes Class M Debt Rating to B3
------------------------------------------------------------------
Moody's Investors Service upgraded the ratings of nine tranches
from four transactions, backed by Second Lien and Manufactured
Housing loans, issued by multiple issuers.

Complete rating actions are as follows:

Issuer: Bombardier Capital Mortgage Securitization Corp 1999-A

A-4, Upgraded to A1 (sf); previously on Mar 9, 2018 Upgraded to
Baa1 (sf)

A-5, Upgraded to A1 (sf); previously on Mar 9, 2018 Upgraded to
Baa1 (sf)

Issuer: IndyMac MH Contract 1997-1

Cl. A-2, Upgraded to Aa2 (sf); previously on Dec 10, 2018 Upgraded
to A1 (sf)

Cl. A-3, Upgraded to Aa2 (sf); previously on Dec 10, 2018 Upgraded
to A1 (sf)

Cl. A-4, Upgraded to Aa2 (sf); previously on Dec 10, 2018 Upgraded
to A1 (sf)

Cl. A-5, Upgraded to Aa2 (sf); previously on Dec 10, 2018 Upgraded
to A1 (sf)

Cl. A-6, Upgraded to Aa2 (sf); previously on Dec 10, 2018 Upgraded
to A1 (sf)

Issuer: CSFB Home Equity Pass-Through Certificates, Series 2004-5

Cl. M-2, Upgraded to Ba1 (sf); previously on Dec 26, 2018 Upgraded
to B1 (sf)

Issuer: Deutsche Financial Capital Securitization LLC, Series
1998-I

Class M, Upgraded to B3 (sf); previously on May 12, 2016 Upgraded
to Caa2 (sf)

RATINGS RATIONALE

The rating upgrades are a result of the increase in credit
enhancement available to the bonds. The credit enhancement for Cl.
M-2 from CSFB Home Equity Pass-Through Certificates, Series 2004-5
has built from 37% to 56% over the past year owing to high CPR and
excess spread. At deal closing, approximately 76% of the initial
mortgage loans in the pool were balloon loans. 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 July 2019 from 3.9% in July
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 changes resulting from
servicing transfers, or other policy or regulatory shifts can
impact the performance of these transactions.


DIAMOND RESORTS 2019-1: S&P Assigns BB+ (sf) Rating to Cl. D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Diamond Resorts Owner
Trust 2019-1's timeshare loan-backed notes series 2019-1.

The note issuance is an ABS transaction backed by vacation
ownership interval (timeshare) loans

The ratings reflect S&P Global Ratings' opinion of the credit
enhancement that is available in the form of subordination,
overcollateralization, a reserve account, and available excess
spread, among other factors.

  RATINGS ASSIGNED
  Diamond Resorts Owner Trust 2019-1

  Class       Rating       Amount (mil. $)
  A           AAA (sf)              262.14
  B           A (sf)                 84.56
  C           BBB (sf)               50.73
  D           BB+ (sf)               16.92



FLAGSHIP CREDIT 2019-3: S&P Assigns BB- (sf) Rating to Cl. E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Flagship Credit Auto
Trust 2019-3's automobile receivables-backed notes.

The note issuance is an ABS transaction backed by subprime auto
loan receivables.

The ratings reflect:

-- The availability of approximately 45.2%, 39.4%, 31.1%, 24.5%,
and 19.8% credit support (including excess spread) for the class A,
B, C, D, and E notes, respectively, based on stressed cash flow
scenarios. These credit support levels provide coverage of
approximately 3.50x, 3.00x, 2.30x, 1.75x, and 1.40x S&P's
12.25%-12.75% expected cumulative net loss range for the class A,
B, C, D, and E notes, respectively. These break-even scenarios
cover total cumulative gross defaults (using a recovery assumption
of 40%) of approximately 75%, 66%, 52%, 41%, and 33%,
respectively.

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

-- The expectation that under a moderate ('BBB') stress scenario,
all else being equal, S&P's ratings on the class A and B notes
would not be lowered by more than one rating category from its 'AAA
(sf)' and 'AA (sf)' ratings, respectively, throughout the
transaction's life. Similarly, S&P expects that its ratings on the
class C and D notes would not be lowered more than two rating
categories from its 'A (sf)' and 'BBB (sf)' ratings, respectively.
The rating on the class E notes would remain within two rating
categories of S&P's 'BB- (sf)' rating within the first year, but
the class would eventually default under the 'BBB' stress scenario
after receiving 62%-73% of its principal. The above rating
movements are within the one-category rating tolerance for 'AAA'
and 'AA' rated securities during the first year and three-category
tolerance over three years; a two-category rating tolerance for
'A', 'BBB', and 'BB' rated securities during the first year; and a
three-category tolerance for 'A' and 'BBB' rated securities over
three years. 'BB' rated securities may default under a 'BBB' stress
scenario. These parameters are in accordance with " Methodology:
Credit Stability Criteria," published May 3, 2010."

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

-- The characteristics of the collateral pool being securitized.

-- The transaction's payment and legal structures.

  RATINGS ASSIGNED
  Flagship Credit Auto Trust 2019-3

  Class      Rating      Amount (mil. $)
  A          AAA (sf)             215.41
  B          AA (sf)               29.45
  C          A (sf)                38.71
  D          BBB (sf)              31.30
  E          BB- (sf)              19.19



FREDDIE MAC 2019-3: DBRS Finalizes B(low) Rating on Class M Certs
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional rating on the following
Mortgage-Backed Security, Series 2019-3 (the Certificate) issued by
Freddie Mac Seasoned Credit Risk Transfer Trust, Series 2019-3 (the
Trust):

-- $73.0 million Class M at B (low) (sf)

The B (low) (sf) rating on the Certificate reflects 5.75% of credit
enhancement provided by subordinated certificates in the pool.

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

This transaction is a securitization of a portfolio of seasoned,
re-performing first-lien residential mortgages funded by the
issuance of the certificates, which are backed by 13,018 loans with
a total principal balance of $2,245,765,518 as of the Cut-Off Date
(June 30, 2019).

The mortgage loans were either purchased by Freddie Mac from
securitized Freddie Mac Participation Certificates or retained by
Freddie Mac in whole-loan form since their acquisition. The loans
are currently held in Freddie Mac's retained portfolio and will be
deposited into the Trust on the Closing Date (August 14, 2019).

The loans are approximately 141 months seasoned and have all been
modified. Each mortgage loan was modified under either
Government-Sponsored Enterprise (GSE) Home Affordable Modification
Program (HAMP) or GSE non-HAMP modification programs. Within the
pool, 4,262 mortgages have forborne principal amounts as a result
of a modification, which equates to 10.5% of the total unpaid
principal balance as of the Cut-Off Date. For 72.2% of the modified
loans, the modifications happened more than two years ago.

The loans are all current as of the Cut-Off Date. Furthermore,
52.1% of the mortgage loans have been zero times 30 days delinquent
for at least the past 24 months under the Mortgage Bankers
Association delinquency methods. There are 56 loans that are
subject to the Consumer Financial Protection Bureau's Qualified
Mortgage (QM) rules and are designated as Temporary QM Safe Harbor,
according to the third-party due diligence results. Additionally,
there are 557 loans (4.3%) whose QM status is not available; DBRS
assumed these loans to be non-QM.

The mortgage loans will be serviced by Specialized Loan Servicing
LLC. There will not be any advancing of delinquent principal or
interest on any mortgages by the servicer; however, the servicer is
obligated to advance to third parties any amounts necessary for the
preservation of mortgaged properties or real estate-owned
properties acquired by the Trust through foreclosure or a loss
mitigation process.

Freddie Mac will serve as the Sponsor, Seller and Trustee of the
transaction as well as Guarantor of the senior certificates (Class
HT, Class HA, Class HB, Class HV, Class HZ, Class MT, Class MA,
Class MC, Class MD, Class IM, Class MB, Class MV, Class MZ, Class
M55D, Class M55E, Class M55G and Class M55I Certificates).
Wilmington Trust National Association (Wilmington Trust; rated A
(high) with a Positive trend by DBRS) will serve as Trust Agent.
Wells Fargo Bank, N.A. (rated AA with a Stable trend by DBRS) will
serve as the Custodian for the Trust. U.S. Bank National
Association (rated AA (high) with a Stable trend by DBRS) will
serve as the Securities Administrator for the Trust and will also
act as Paying Agent, Registrar, Transfer Agent, and Authenticating
Agent.

Freddie Mac, as the Seller, will make certain representations and
warranties (R&W) with respect to the mortgage loans. It will be the
only party from which the Trust may seek indemnification (or, in
certain cases, a repurchase) as a result of a breach of R&Ws. If a
breach review trigger occurs during the warranty period, the Trust
Agent, Wilmington Trust, will be responsible for the enforcement of
R&Ws. The warranty period will only be effective through August 12,
2022 (approximately three years from the Closing Date), for
substantially all R&Ws other than the real estate mortgage
investment conduit R&W, which will not expire.

The mortgage loans will be divided into three loan groups: Group H,
Group M, and Group M55. The Group H loans (4.9% of the pool) were
subject to step-rate modifications and had not yet reached their
final step-rate as of May 31, 2019. As of the Cut-Off Date, the
borrower, while still current, has not made any payments accrued at
such final step-rate. Group M loans (85.5% of the pool) and Group
M55 loans (9.6% of the pool) were subject to either fixed-rate
modifications or step-rate modifications that have reached their
final step-rates, and as of the Cut-Off Date, the borrowers have
made at least one payment after such mortgage loans reached their
respective final step rates. Each Group M loan has a mortgage
interest rate less than or equal to 5.5% and has no forbearance or
may have forbearance and any mortgage interest rate. Each Group M55
loan has a mortgage interest rate greater than 5.5% and has no
forbearance.

Principal and interest (P&I) on the senior certificates (the
Guaranteed Certificates) will be guaranteed by Freddie Mac. The
Guaranteed Certificates will be backed by collateral from each
group, respectively. The remaining certificates (including the
subordinate, non-guaranteed, interest-only mortgage insurance and
residual certificates) will be cross-collateralized among the three
groups.

The transaction employs a pro-rata pay cash flow structure among
the senior group certificates with a sequential-pay feature among
the subordinate certificates. Certain principal proceeds can be
used to cover interest shortfalls on the rated Class M
certificates. Senior classes benefit from guaranteed P&I payments
by the Guarantor, Freddie Mac; however, such guaranteed amounts, if
paid, will be reimbursed to Freddie Mac from the P&I collections
prior to any allocation to the subordinate certificates. The senior
principal distribution amounts vary subject to the satisfaction of
a step-down test. Realized losses are allocated sequentially in
reverse order.

The rating reflects transactional strengths that include underlying
assets that have generally performed well through the crisis (all
loans are current as of the Cut-Off Date, and the entire pool has
remained consistently current for the past 12 months under the MBA
method). Additionally, a third-party due diligence review, albeit
on less than 100% of the portfolio with respect to regulatory
compliance and payment histories, was performed on a sample that
exceeds DBRS's criteria. The due diligence results and findings on
the sampled loans were satisfactory.

This transaction employs a weak R&W framework that includes a
36-month sunset without an R&W reserve account, substantial
knowledge qualifiers and fewer mortgage loan representations
relative to DBRS's criteria for seasoned pools. In addition, a
breach review will only trigger if a loan had a foreclosure sale,
short sale or deed in lieu of foreclosure sale completed or was
charged off by the Servicer or has been modified by the Servicer
(due to a hardship or by a court of competent jurisdiction). DBRS
increased loss expectations from the model results to capture the
weaknesses in the R&W framework. Other mitigating factors include
(1) significant loan seasoning and very clean performance history
in the past two years, (2) Freddie Mac as the R&W provider and (3)
a satisfactory third-party due diligence review.

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

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


FREDDIE MAC 2019-FTR2: S&P Rates Class B-1B Notes 'B- (sf)'
-----------------------------------------------------------
S&P Global Ratings assigned its ratings to Freddie Mac STACR Trust
2019-FTR2's notes.

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

The ratings reflect:

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

-- The credit quality of the collateral included in the reference
pool—roughly half of such collateral is covered by mortgage
insurance backstopped by Freddie Mac;

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

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

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

  RATINGS ASSIGNED
  Freddie Mac STACR TRUST 2019-FTR2

  Class           Rating           Amount (mil. $)
  A-H(i)          NR                11,108,249,748
  M-1             BBB- (sf)             82,000,000
  M-1H(i)         NR                    33,111,396
  M-2             B+ (sf)              114,000,000
  M-2R            B+ (sf)              114,000,000
  M-2S            B+ (sf)              114,000,000
  M-2T            B+ (sf)              114,000,000
  M-2U            B+ (sf)              114,000,000
  M-2I            B+ (sf)              114,000,000
  M-2A            BB+ (sf)              57,000,000
  M-2AR           BB+ (sf)              57,000,000
  M-2AS           BB+ (sf)              57,000,000
  M-2AT           BB+ (sf)              57,000,000
  M-2AU           BB+ (sf)              57,000,000
  M-2AI           BB+ (sf)              57,000,000
  M-2AH(i)        NR                    23,577,977
  M-2B            B+ (sf)               57,000,000
  M-2BR           B+ (sf)               57,000,000
  M-2BS           B+ (sf)               57,000,000
  M-2BT           B+ (sf)               57,000,000
  M-2BU           B+ (sf)               57,000,000
  M-2BI           B+ (sf)               57,000,000
  M-2RB           B+ (sf)               57,000,000
  M-2SB           B+ (sf)               57,000,000
  M-2TB           B+ (sf)               57,000,000
  M-2UB           B+ (sf)               57,000,000
  M-2BH(i)        NR                    23,577,977
  B-1             B- (sf)               42,000,000
  B-1A            B+ (sf)               21,000,000
  B-1AR           B+ (sf)               21,000,000
  B-1AI           B+ (sf)               21,000,000
  B-1AH(i)        NR                     7,777,849
  B-1B            B- (sf)               21,000,000
  B-1BH(i)        NR                     7,777,849
  B-2             NR                    46,000,000
  B-2A            NR                    23,000,000
  B-2AR           NR                    23,000,000
  B-2AI           NR                    23,000,000
  B-2AH(i)        NR                     5,777,849
  B-2B            NR                    23,000,000
  B-2BH(i)        NR                     5,777,849
  B-3H(i)         NR                    11,511,143

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


GEA SEASIDE: Seeks to Hire Nasseh Sirounis Law as Special Counsel
-----------------------------------------------------------------
GEA Seaside Investment Inc. seeks approval from the U.S. Bankruptcy
Court for the Middle District of Florida to hire Nasseh Sirounis
Law, P.A. as its special counsel.

The firm will represent the Debtor in various state court matters
and foreclosure actions.  Its hourly rates range from $275 to
$395.

Christopher Nasseh, Esq., at Nasseh Sirounis, disclosed in court
filings that he does not hold any interest adverse to the Debtor or
its bankruptcy estate.

The firm can be reached at:

     Christopher Nasseh, Esq.
     Nasseh Sirounis Law, P.A.
     640 Bryn Mawr St.
     Orlando, FL 32804
     Phone: +1 407-776-8600

              About GEA Seaside Investment Inc.

GEA Seaside Investment Inc. sought protection under Chapter 11 of
the Bankruptcy Code (Bankr. M.D. Fla. Case No. 18-00800) on March
12, 2018.  Judge Jerry A. Funk presides over the case.  The Debtor
is represented by Adam Law Group, P.A. as its legal counsel.

No official committee of unsecured creditors has been appointed in
the Chapter 11 case of GEA Seaside Investment Inc. as of April 30,
according to a court docket.


GOLDENTREE LOAN 5: S&P Assigns B- (sf) Rating to Class F Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to Goldentree Loan
Management US CLO 5 Ltd./Goldentree Loan Management US CLO 5 LLC 's
floating-rate notes.

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

The ratings reflect S&P's view of:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED

  Goldentree Loan Management US CLO 5 Ltd./Goldentree Loan
  Management US CLO 5 LLC

  Class                Rating      Amount (mil. $)
  X                    AAA (sf)               4.20
  A                    AAA (sf)             381.00
  B                    AA (sf)               60.00
  C (deferrable)       A (sf)                51.00
  D (deferrable)       BBB- (sf)             36.00
  E (deferrable)       BB- (sf)              25.50
  F (deferrable)       B- (sf)               12.00
  Subordinated notes   NR                    33.20

  NR--Not rated.


GS MORTGAGE 2017-485L: S&P Affirms BB- (sf) Rating on HRR Certs
---------------------------------------------------------------
S&P Global Ratings affirmed its ratings on six classes of
commercial mortgage pass-through certificates from GS Mortgage
Securities Corporation Trust 2017-485L, a U.S. commercial
mortgage-backed securities (CMBS) transaction.

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

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

This is a stand-alone (single borrower) transaction backed by a
10-year fixed-rate IO whole mortgage loan secured by the borrower's
fee interest in a 32-story tower totaling 935,452 sq. ft. (861,676
sq. ft. is class A office space, 22,978 sq. ft. is retail space,
27,986 sq. ft. is storage space, and 22,812 sq. ft. is a 100-stall
parking space) at 485 Lexington Ave. in midtown Manhattan. S&P's
property-level analysis included a reevaluation of the office
property that secures the loan and considered the servicer-reported
net operating income for 2017 and 2018, the borrower's leasing
efforts to stabilize the property's occupancy and operating
performance, the property's unique premier location, and the rating
agency's stabilized assumptions at issuance. S&P's analysis
factored in the current available operating performance data
provided by the master servicer: specifically, a higher in place
occupancy (84.1% compared to 68.8% at issuance) with average gross
in-place office rent at about $70.15 per sq. ft., resulting in the
rating agency's underwritten in-place base rent of $52.6 million,
compared to $42.3 million at issuance. The rating agency derived
its sustainable in-place net cash flow, which it divided by a 6.25%
S&P Global Ratings capitalization rate to determine its
expected-case value. This yielded an overall S&P Global Ratings
loan-to-value ratio and debt service coverage (DSC) of 79.7% and
1.92x, respectively, on the loan balance.

The IO mortgage loan had an initial and current $350.0 million
balance, pays a per annum fixed rate of 3.99%, and matures on Feb.
5, 2027. In addition, there is a $100.0 million mezzanine loan
outstanding. Furthermore, the trust has not incurred any principal
losses.

The master servicer, Midland Loan Services, reported a 1.45x DSC on
the trust balance for the year ended Dec. 31, 2018, and occupancy
was 84.1% according to the June 30, 2019, rent roll, up from the
reported 80.9% and 69.0% occupancy for year-end 2018 and 2017,
respectively. Based on the June 2019 rent roll, the five largest
tenants make up 41.1% of the collateral's total net rentable area
(NRA). In addition, 5.5%, 3.7%, and 26.4% of the NRA have leases
that expire in 2019, 2020, and 2021, respectively. The majority of
the space expiring in 2021 is from the largest tenant, The
Travelers (176,838 sq. ft., 18.9%), on Aug. 31, 2021.

  RATINGS AFFIRMED
  GS Mortgage Securities Corporation Trust 2017-485L
  Commercial mortgage pass-through certificates

  Class     Rating
  A         AAA (sf)
  B         AA- (sf)
  C         A- (sf)
  HRR       BB- (sf)
  X-A       AAA (sf)
  X-B       AA- (sf)


GS MORTGAGE 2019-SL1: Fitch Rates $15MM Class B2 Notes 'Bsf'
------------------------------------------------------------
Fitch Ratings assigns the following ratings to GS Mortgage-Backed
Securities Trust 2019-SL1:

  -- $183,403,000 class A1 notes 'AAAsf'; Outlook Stable;

  -- $24,374,000 class A2 notes 'AAsf'; Outlook Stable;

  -- $19,602,000 class M1 notes 'Asf'; Outlook Stable;

  -- $21,306,000 class M2 notes 'BBBsf'; Outlook Stable;

  -- $17,897,000 class B1 notes 'BBsf'; Outlook Stable;

  -- $15,341,000 class B2 notes 'Bsf'; Outlook Stable;

  -- $207,777,000 class A3 exchangeable notes 'AAsf';
     Outlook Stable;

  -- $227,379,000 class A4 exchangeable notes 'Asf';
     Outlook Stable;

  -- $248,685,000 class A5 exchangeable notes 'BBBsf';
     Outlook Stable.

Fitch will not be rating the following classes:

  -- $18,067,000 class B3 notes;

  -- $17,045,000 class B4 notes;

  -- $23,863,000 class B5 notes;

  -- $340,898,000 class A6 exchangeable notes.

The issuer will also be retaining an uncertificated amount equal to
5% of the transaction, also not rated:

  -- $17,942,892 class risk retention.

The notes are supported by one collateral group that consists of
5,585 seasoned and re-performing second lien mortgages with a total
balance of approximately $358.8 million, which includes $11.6
million, or 3.2%, of the aggregate pool balance in
non-interest-bearing deferred principal amounts, as of the cut-off
date. Distributions of principal and interest (P&I) and loss
allocations are based on a traditional senior subordinate,
sequential-pay structure.

The sequential-pay structure locks out principal to the
subordinated notes until the most senior notes outstanding are paid
in full. The servicer will not be advancing delinquent P&I
payments.

KEY RATING DRIVERS

Closed-End Second Liens (Negative): The collateral pool consists of
100% closed-end, second lien, seasoned performing loans and RPLs
with a weighted average (WA) model credit score of 688, sustainable
loan to value ratio (sLTV) of 92.2% and seasoning of approximately
158 months. Fitch assumes 100% loss severity (LS) on all defaulted
second lien loans. Because observed second lien defaults are
comparable to first liens when controlling for combined LTV (CLTV)
and other credit attributes, Fitch did not apply an additional
default penalty for the lien position.

Seasoned Performing Loans (Positive): 99.4% of the loans have been
paying on time for the past 24 months. Borrowers that have been
current for at least the past 36 months (72.5%) received a 35%
reduction to Fitch's 'AAAsf' probability of default (PD) and those
current between 24 months and 36 months received a 26.25% 'AAAsf'
reduction. The third-party pay history review found 0.6% of the
loans have a prior delinquency. No loans are currently delinquent.


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

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

Moderate Operational Risk (Neutral): Operational risk is considered
modestly higher for this pool relative to other Fitch rated
seasoned and RPL transactions, due to the limited due diligence
(DD) sample size. Goldman Sachs Mortgage Company (GSMC) has a long
operating history of aggregating residential mortgage loans and is
assessed as 'Average' for seasoned collateral by Fitch. The
servicer for this transaction is Specialized Loan Servicing (SLS;
RPS2).

Representation Framework (Negative): GSMC is the rep and warranty
(R&W) provider until the 13th payment date. The R&W and enforcement
framework contains knowledge qualifiers and has been assessed by
Fitch as Tier 2. Expected losses were increased by 334bps at the
'AAAsf' level due to the R&W tier, the sunsetting of the R&W
provider after 13 months and partial funding of a reserve fund. The
increase in Fitch's expected loss should help protect against
defaults and losses from loan defects in excess of amounts on
deposit in the reserve fund. In addition, the issuer's retention of
at least 5% of the bonds helps align the interests of the issuer
with investors.

Limited Life of Rep Provider (Negative): GSMC, as rep provider,
will only be obligated to repurchase a loan due to breaches prior
to the payment date in August 2020. Thereafter, a reserve fund will
be available to cover amounts due to noteholders for loans
identified as having rep breaches. The rep provider will not be
responsible to repurchase a loan where a realized loss was due to a
breach in a compliance related R&W. Instead, a compliance reserve
account will be established for the first 12 months.

Due Diligence Review Results (Neutral): Operational risk is
considered moderate for this transaction since not all loans were
diligenced by third-party review (TPR) firms; approximately 31% of
loans by UPB and loan count were reviewed. Fitch assumed 100% LS on
all defaulted loans, which mitigates the risk of less than 100%
diligence review. The DD was performed by a Tier 1 and a Tier 3 TPR
firm, AMC Diligence, LLC and Recovco Mortgage Management, LLC.
Approximately 14% of the loans assigned received a 'C' or 'D' grade
for compliance, primarily due to missing documentation, which is
consistent with industry averages. However, the 'C' and 'D' loans
compliance findings were past the statute of limitations and
unlikely to increase losses or result in breaches. The 100% LS
protects against any additional losses from the compliance
findings.

Deferred Amounts (Negative): Non-interest-bearing principal
forbearance amounts totaling $11.6 million (3.2%) of the UPB are
outstanding on 706 loans. Fitch included the deferred amounts when
calculating the borrower's CLTV and sustainable LTV (sLTV), despite
the lower payment and amounts not owed during the term of the loan.
The inclusion resulted in a higher PD than if there were no
deferrals. Because deferred amounts are due and payable by the
borrower at maturity, Fitch believes that borrower default behavior
for these loans will resemble that of the higher CLTVs, as property
sale or refinancing will be limited relative to those borrowers
with more equity.

CRITERIA APPLICATION

Fitch analyzed the transaction in accordance with its criteria, as
described in its report, "U.S. RMBS Rating Criteria." This
incorporates a review of the originators' lending platforms or
aggregator's acquisition process, as well as an assessment of the
transaction's R&Ws provided by the originators and arranger, which
were found to be consistent with the ratings assigned to the
certificates.

Fitch's analysis incorporated two criteria variations from the
"U.S. RMBS Seasoned, Re-Performing and Non-Performing Loan Rating
Criteria" and one variation from the "U.S. RMBS Rating Criteria."
The first variation relates to the tax/title review. An updated
tax/title review was not completed on 2,197 loans. While a
tax/title review was not completed, Fitch's analysis already
assumed that these loans were not in first-lien position, and Fitch
assumes 100% LS for all second liens. There was no rating impact
due to this variation.

The second variation is that a due diligence compliance and data
integrity review was not completed on 3,859 loans. Fitch's model
assumes 100% LS for all second liens and therefore no additional
adjustment was made to Fitch's expected losses. There was no rating
impact from application of this variation.

The final variation relates to Recovco's TPR assessment. Recovco
reviewed approximately 11% of the loans in the pool. Fitch
performed a TPR assessment on Recovco 21 months ago; although this
review is just outside the active 18-month cutoff per Fitch's
criteria, Fitch is currently working with the TPR firm to complete
an updated review. Additionally, Recovco is an active TPR in RMBS
and Fitch has received and reviewed reports from Recovco and
believes they follow industry standards.

RATING SENSITIVITIES

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines (MVDs)
than assumed at both the metropolitan statistical area (MSA) and
national levels. The implied rating sensitivities are only an
indication of some of the potential outcomes and do not consider
other risk factors that the transaction may become exposed to or be
considered in the surveillance of the transaction. Three sets of
sensitivity analyses were conducted at the state and national
levels to assess the effect of higher MVDs for the subject pool.

Fitch conducted sensitivity analysis determining how the ratings
would react to steeper MVDs at the national level. The analysis
assumes MVDs of 10%, 20%, and 30%, in addition to the
model-projected 4.7% at the base case. The analysis indicates there
is some potential rating migration with higher MVDs, compared with
the model projection.

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

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

A third-party due diligence review was completed on a sample of 31%
of the loans in this transaction. The sample size and the scope of
the review were consistent with Fitch's methodology for seasoned
2nd lien mortgages. Fitch was provided with Form ABS Due
Diligence-15E (Form 15E) as prepared by AMC Diligence, LLC (AMC)
Recovco Mortgage Management, LLC, who were engaged to perform a
regulatory compliance, tax and title and data integrity third-party
due diligence review on the loans.

The diligence results indicated comparable operational risk to the
recent other Fitch-reviewed RPL transactions. Approximately 14% of
the loans reviewed for regulatory compliance due diligence were
assigned a 'C' or 'D' grade primarily due to missing documentation.
The grades reflect regulatory compliance only. The regulatory
compliance review covered applicable federal, state and local
high-cost loan and/or anti-predatory laws, as well as the Truth In
Lending Act (TILA) and Real Estate Settlement Procedures Act
(RESPA). Typically, Fitch makes a LS adjustment for this, but
expected loss adjustments were not applied for the due diligence
findings given that a 100% LS is already assumed.


HOMEWARD OPPORTUNITIES 2019-2: DBRS Gives (P)B Rating on B2 Certs
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following Mortgage
Pass-Through Certificates, Series 2019-2 (the Certificates) to be
issued by Homeward Opportunities Fund I Trust 2019-2 (the Trust):

-- $244.6 million Class A-1 at AAA (sf)
-- $26.1 million Class A-2 at AA (sf)
-- $42.7 million Class A-3 at A (sf)
-- $23.8 million Class M-1 at BBB (sf)
-- $18.5 million Class B-1 at BB (sf)
-- $11.7 million Class B-2 at B (sf)

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

The AAA (sf) rating on the Class A-1 Certificates reflects 35.30%
of credit enhancement provided by subordinated Certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 28.40%, 17.10%, 10.80%, 5.90% and 2.80% of credit
enhancement, respectively.

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate, prime, expanded prime and non-prime first-lien
residential mortgages funded by the issuance of the Certificates.
The Certificates are backed by 543 mortgage loans with a total
principal balance of $378,122,169 as of the Cut-Off Date (August 1,
2019).

The originators for the underlying mortgage pool are Sprout
Mortgage Corporation (Sprout; 59.6%); 5th Street Capital, Inc.
(40.0%); and various other originators, each comprising less than
0.3% of the mortgage loans. The Servicer of the loans is
Specialized Loan Servicing LLC (SLS).

The Sprout mortgages were originated under the following programs:

(1) Income Per Bank Statements (34.6%) — Generally made to
self-employed borrowers using bank statements to support
self-employed income for qualification purposes.

(2) Jumbo Special Feature (13.3%) — Generally made to prime
borrowers with loan amounts exceeding the government-sponsored
enterprise (GSE) loan limits who may fall outside the Qualified
Mortgage (QM) requirements based on debt-to-income (DTI) or loans
that have special features that do not meet GSE guidelines.

(3) Investor Debt Service Coverage (6.2%) — Generally made to
borrowers seeking business-purpose loans for investment
properties.

(4) Asset Depletion (5.5%) — Generally made to borrowers with
significant assets equal to 110% or more of the original mortgage
balance.

For the other originators, the mortgage loans were originated
through similar programs.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's Ability-to-Repay (ATR) rules, they
were made to borrowers who generally do not qualify for an agency,
government or private-label non-agency prime jumbo products for
various reasons. In accordance with the QM/ATR rules, 83.0% of the
loans are designated as non-QM. Approximately 17.0% of the loans
are made to investors for business purposes and, hence, are not
subject to the QM/ATR rules.

Homeward Opportunities Fund I LP (HOF I) is the Sponsor and the
Servicing Administrator of the transaction. HOF I Asset Selector
LLC serves as the Asset Selector for securitizations sponsored by
HOF I and, for this transaction, determined which mortgage loans
would be included in the pool. The Sponsor, Depositor,
Administrator, Asset Selector, and Servicing Administrator are
affiliates or the same entity.

Wells Fargo Bank, N.A. (Wells Fargo; rated AA with a Stable trend
by DBRS) will act as the Master Servicer. U.S. Bank National
Association (rated AA (high) with a Stable trend by DBRS) will
serve as Trustee, Securities Administrator, Certificate Registrar,
and Custodian.

The Sponsor, directly or indirectly through a majority-owned
affiliate, will retain an eligible horizontal residual interest in
at least 5% of the Certificates issued by the Issuer (other than
the Class R Certificates) to satisfy the credit risk-retention
requirements under Section 15G of the Securities Exchange Act of
1934 and the regulations promulgated thereunder.

On or after the earlier of (1) the two-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, the Depositor has the option to purchase all outstanding
Certificates at a price equal to the outstanding class balance plus
accrued and unpaid interest, including any cap carryover amounts.

After such purchase, the Depositor then has the option to complete
a qualified liquidation, which requires (1) a complete liquidation
of assets within the Trust and (2) proceeds to be distributed to
the appropriate holders of regular or residual interests.

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

The transaction employs a sequential-pay cash flow structure with a
pro-rata principal distribution among the senior tranches.
Principal proceeds can be used to cover interest shortfalls on the
Certificates as the outstanding senior Certificates are paid in
full. Furthermore, the excess spread can be used to cover realized
losses first before being allocated to unpaid cap carryover amounts
up to Class B-1.

The ratings reflect transactional strengths that include the
following:

(1) Robust Loan Attributes and Pool Composition:

-- The mortgage loans in this portfolio generally exhibit expanded
prime characteristics and robust loan attributes as reflected in
credit scores, combined loan-to-value (LTV) ratios, borrower
household income, and liquid reserves.

-- As the loans move down the credit spectrum in terms of
documentation and occupancy, certain characteristics, such as lower
LTVs, higher income and/or more significant reserves, suggest the
consideration of compensating factors for riskier pools.

-- The pool comprises 13.1% fixed-rate mortgages, which have the
lowest default risk because of the stability of monthly payments,
and 86.9% hybrid adjustable-rate mortgages with initial fixed
periods of five years to ten years, allowing borrowers sufficient
time to credit cure before rates reset.

(2) Satisfactory Third-Party Due Diligence Review: Third-party due
diligence firms conducted property valuation and credit on 100% of
the loans in the pool and compliance reviews on all applicable
loans. Data integrity checks were also performed on the pool.

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

-- Full documentation generally consists of one to two years of
W-2s (or two years of personal and business tax returns for
self-employed borrowers), two months of asset statements and verbal
verification of employment. Borrowers must execute and submit an
IRS Form 4506-T.

-- For borrowers using bank statements as income, generally one
borrower must be self-employed, and income must be supported by 12
months or 24 months of personal or business bank statements.

-- The appraisal review process incorporates validation through a
desk review. In addition, for larger loan amounts, second full
appraisals are required.

-- Minimum reserve, maximum LTV, and maximum DTI requirements are
in place and may vary based on certain characteristics, including
documentation type, loan amount, credit score and interest-only
flag.

(4) Compliance with the ATR Rules: All of the mortgage loans,
except for the business-purpose investor loans, were underwritten
in accordance with the eight underwriting factors of the ATR
rules.

The transaction also includes the following challenges and
mitigating factors:

(1) Representations and Warranties (R&W) Framework: The R&W
framework is substantially weaker than that of a post-crisis prime
securitization. Instead of an automatic review when a loan becomes
seriously delinquent, this transaction employs an optional review
only when realized losses occur (unless the alleged breach relates
to an ATR or Truth in Lending Act–Real Estate Settlement
Procedures Act Integrated Disclosure violation). In addition,
rather than engaging a third-party due diligence firm to perform
the R&W review, the Controlling Holder (initially, the Sponsor) has
the option to perform the review in-house or use a third-party
reviewer. Finally, the R&W provider (the Sponsor) is a fund with a
finite life, which essentially creates a sunset on the R&W. DBRS
notes the following mitigating factors:

-- The Certificateholders representing a 25% interest in the
Certificates may direct the Trustee to commence a separate review
of the related mortgage loan, to the extent that they disagree with
the Controlling Holder's determination of a breach or if the
Controlling Holder elects not to review a loan that incurred a
realized loss.

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

-- DBRS conducted an aggregator review on Neuberger Berman and an
originator review of Sprout and deems both to be acceptable.

-- The Sponsor or an affiliate of the Sponsor will retain a 5%
horizontal residual interest in the Certificates, aligning Sponsor
and investor interest in the capital structure.

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

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

-- All loans, except for the business-purpose investor loans, were
originated to meet the eight underwriting factors as required by
the ATR rules.

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

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

-- For loans in this portfolio, borrower credit events (4.9% of
the pool) generally happened more than two years prior to
origination. In its analysis, DBRS applies additional penalties for
borrowers with recent credit events within the past two years (0.1%
of the pool).

-- For investor loans, DBRS applies 1.7 times (x) to 1.8x penalty
to default frequency relative to owner-occupied loans, holding
other attributes constant, to address the higher default risk
associated with investment properties. In addition, DBRS applies
further penalties to the Investor Debt Service Coverage loans (6.9%
of the pool), which were underwritten using property cash
flow/rental income to qualify borrowers for income. The investor
loans in this pool generally have a better credit profile than the
overall pool with a weighted-average (WA) current FICO of 723 and
WA original combined LTV of 66.4%. In addition, for investment
property loans underwritten using borrower income, which comprises
11.2% of the pool, the WA DTI is 33.9%.

(3) Servicer Advances of Delinquent Principal and Interest: The
Servicer will advance scheduled principal and interest on
delinquent mortgages until such loans become 180 days delinquent or
until such advances are deemed unrecoverable. This will likely
result in lower loss severities to the transaction because advanced
principal and interest will not have to be reimbursed from the
Trust upon the liquidation of the mortgages but will increase the
possibility of periodic interest shortfalls to the
Certificateholders. Mitigating factors include the fact that (a)
principal proceeds can be used to pay interest shortfalls to the
Certificates as the outstanding senior Certificates are paid in
full and (b) subordination levels are greater than expected losses,
which may provide for payment of interest to the Certificates. DBRS
ran cash flow scenarios that incorporated principal and interest
advancing up to 180 days for delinquent loans; the cash flow
scenarios are discussed in more detail in the Cash Flow Analysis
section of the related report.

(4) Servicer's Financial Capability: In this transaction, as the
Servicer, SLS is responsible for funding advances to the extent
required. The Servicer is an unrated entity and may face financial
difficulties in fulfilling its servicing advance obligations in the
future. Consequently, the transaction employs Wells Fargo as the
Master Servicer. If the Servicer fails in its obligation to make
advances, Wells Fargo will be obligated to fund such servicing
advances.

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 Certificates. 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 Certificates.

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


HOMEWARD OPPORTUNITIES 2019-2: S&P Rates Class B-2 Certs 'B'
------------------------------------------------------------
S&P Global Ratings assigned its ratings to Homeward Opportunities
Fund I Trust 2019-2's (HOF I Trust 2019-2) mortgage pass-through
certificates.

The certificate issuance is an RMBS transaction backed by
first-lien fixed- and adjustable-rate fully amortizing residential
mortgage loans (some with interest-only periods) generally secured
by single-family residential properties, planned-unit developments,
condominiums, and two- to four-family residential properties to
prime and nonprime borrowers. The loans are primarily nonqualified
mortgage loans.

The ratings reflect:

-- The pool's collateral composition;
-- The credit enhancement provided for this transaction;
-- The transaction's associated structural mechanics;
-- The representation and warranty framework for this
transaction;
-- The transaction's geographic concentration; and
-- The mortgage aggregator, Neuberger Berman Investment Advisors
LLC, as investment manager for HOF I Trust 2019-2.

  RATINGS ASSIGNED
  Homeward Opportunities Fund I Trust 2019-2
  Class       Rating            Amount ($)
  A-1         AAA (sf)         244,645,000
  A-2         AA (sf)           26,090,000
  A-3         A (sf)            42,728,000
  M-1         BBB (sf)          23,821,000
  B-1         BB (sf)           18,528,000
  B-2         B (sf)            11,722,000
  B-3         NR                10,588,169
  A-IO-S      NR                  Notional(i)
  X           NR                  Notional(i)
  R           NR                       N/A

(i)The notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period.
NR--Not rated.
N/A--Not applicable.


HPS LOAN 15-2019: S&P Assigns B- (sf) Rating to $5MM Class F Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to HPS Loan Management
15-2019 Ltd./HPS Loan Management 15-2019 LLC's floating-rate
notes.

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

The ratings reflect S&P's view of:

-- The diversification of the collateral pool, which consists
primarily of broadly syndicated speculative-grade (rated 'BB+' and
lower) senior secured term loans that are governed by collateral
quality tests.

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

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

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

  RATINGS ASSIGNED

  HPS Loan Management 15-2019 Ltd./HPS Loan Management 15-2019 LLC

  Class                Rating       Amount (mil. $)

  A-1                  AAA (sf)             307.50
  A-2                  NR                    17.50
  B                    AA (sf)               50.00
  C (deferrable)       A (sf)                35.00
  D (deferrable)       BBB (sf)              27.50
  E (deferrable)       BB- (sf)              22.50
  F (deferrable)       B- (sf)                5.00
  Subordinated notes   NR                    42.35

  NR--Not rated.


JP MORGAN 2006-LDP7: Fitch Cuts Rating on Class A-J Certs to Csf
----------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed 11 classes of J.P.
Morgan Chase Commercial Mortgage Securities Corp, commercial
mortgage pass-through certificates, series 2006-LDP7.

J.P. Morgan Chase Commercial Mortgage Securities Corp. 2006-LDP7

                     Current Rating     Prior Rating
Class A-J 46628FAN1 LT Csf Downgrade  previously at CCsf
Class B 46628FAP6   LT Csf Affirmed   previously at Csf
Class C 46628FAQ4   LT Csf Affirmed   previously at Csf
Class D 46628FAR2   LT Csf Affirmed   previously at Csf
Class E 46628FAS0   LT Csf Affirmed   previously at Csf
Class F 46628FAU5   LT Dsf Affirmed   previously at Dsf
Class G 46628FAW1   LT Dsf Affirmed   previously at Dsf
Class H 46628FAY7   LT Dsf Affirmed   previously at Dsf
Class J 46628FBA8   LT Dsf Affirmed   previously at Dsf
Class K 46628FBC4   LT Dsf Affirmed   previously at Dsf
Class L 46628FBE0   LT Dsf Affirmed   previously at Dsf
Class M 46628FBG5   LT Dsf Affirmed   previously at Dsf

KEY RATING DRIVERS

Increased Loss Expectations; High Concentration of REO Assets: The
downgrade to class A-J reflects a greater certainty of loss. Loss
expectations on the real-estate owned (REO) assets, which comprise
95.9% of the current pool, have increased since Fitch's last rating
action, and significant losses upon liquidation are anticipated.

The largest asset is the REO Westfield Centro Portfolio (74.5% of
the current pool). The loan, which was originally secured by a
portfolio of five retail centers totaling 2.4 million square feet,
was transferred to special servicing in May 2014 for imminent
default due to a significant decline in portfolio cashflow as a
result of a decline in anchor and in-line occupancy and increasing
operating expenses. The asset became REO in 2016. Three of the five
properties were sold between the third quarter of 2017 and first
quarter of 2019. The remaining two properties, Westfield West Park
in Cape Girardeau, MO and Westfield Eagle Rock  in Los Angeles, CA,
are both regional malls with exposure to struggling retailers.
Westfield West Park, which was 75% occupied as of June 2019, is
anchored by Macy's, JCPenney and Ashley Home Furniture. The space
currently occupied by Ashley Home Furniture has historically
suffered from frequent tenant turnover. Westfield Eagle Rock, which
was 95% occupied as of June 2019, is anchored by Macy's and Target.
Based on the significant outstanding loan exposure and the most
recent 2019 appraisal valuations for these two remaining
properties, significant losses are expected.

Increased Credit Enhancement:  Although credit enhancement for
class A-J has increased slightly due to overall better recoveries
than expected on a modified loan that was paid off since the last
rating action, the pool remains highly concentrated with only 15
loans/assets remaining, eight of which are REO. As of the July 2019
remittance report, the pool has been reduced by 91.8% to $322.3
million from $3.94 billion at issuance. Realized losses to date
total $287.3 million (7.3% of original pool balance). Cumulative
interest shortfalls totalling $54.4 million are currently affecting
classes B through NR.

RATING SENSITIVITIES

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


JP MORGAN 2013-C17: Fitch Affirms Bsf Rating on Class F Certs
-------------------------------------------------------------
Fitch Ratings has affirmed 11 classes of JP Morgan Chase Commercial
Mortgage Securities Trust commercial mortgage pass-through
certificates series 2013-C17.

Fitch has issued a focus report on this transaction. The report
provides a detailed and up-to-date perspective on key credit
characteristics of the JPMBB 2013-C17 transaction and
property-level performance of the related trust loans.

JPMBB 2013-C17

             Current Rating       Prior Rating
Class A-3   LT AAAsf  Affirmed  previously at AAAsf
Class A-4   LT AAAsf  Affirmed  previously at AAAsf
Class A-S   LT AAAsf  Affirmed  previously at AAAsf
Class A-SB  LT AAAsf  Affirmed  previously at AAAsf
Class B     LT AA-sf  Affirmed  previously at AA-sf
Class C     LT A-sf   Affirmed  previously at A-sf
Class D     LT BBB-sf Affirmed  previously at BBB-sf
Class E     LT BBsf   Affirmed  previously at BBsf
Class EC    LT A-sf   Affirmed  previously at A-sf
Class F     LT Bsf    Affirmed  previously at Bsf
Class X-A   LT AAAsf  Affirmed  previously at AAAsf

KEY RATING DRIVERS

Increased Credit Enhancement to Offset Higher Loss Expectations:
The rating affirmations reflect the generally stable performance of
the majority of the pool. Current loss expectations are slightly
higher than at issuance due to the Fitch Loans of Concern (FLOCs)
but are offset by increased credit enhancement from loan
amortization and payoffs. Since the last rating action, six loans
have been disposed resulting in $119 million in principal paydown.


As of the July 2019 distribution date, the pool's aggregate
principal balance had been reduced by 25.9% to $802.4 million from
$1.1 billion at issuance. Seven loans totaling 21.5% of the pool
are designated as FLOCs, including three of the top 15. Aggregate
pool-level NOI for YE 2018 is in line with prior-year reporting and
remains 7% above the NOI at issuance. There are no specially
serviced loans, and the pool has incurred $4.8 million in losses to
the not rated (NR) class.

Fitch Loans of Concern: The largest FLOC is The Aire loan (10.6%),
which is secured by a 310-unit multifamily property located in New
York, NY. A cash flow sweep was triggered in 2017 due to the DSCR
falling below the required threshold. As of YE 2018, the NOI debt
service coverage ratio (DSCR) was 0.90x, compared with 0.80x at YE
2017, 1.05x at YE 2016 and 1.16x at issuance. According to servicer
updates, the decline in cash flow is due to the significant
concessions being offered at the property to offset soft market
conditions. As of March 2019, occupancy at the property was 97%.

The second largest FLOC is the Springfield Plaza loan (3.6%), which
is secured by a 427,000 sf, anchored, retail center located in
Springfield, MA. As of May 2019, occupancy declined to 65%,
primarily due to K-Mart vacating after filing for Chapter 11
bankruptcy. According to servicer updates, the property has
garnered some positive leasing momentum recently, with a tenant
signing a 10-year lease for 25,500 sf that will commence in
September 2019. Furthermore, one letter of intent was recently
issued for 55,000 sf, and another one is expected in the coming
weeks for a significant amount of space.

The third FLOC in the top 15 is the 801 Travis Loan (3.4%), which
is secured by a 220,000-sf office property located in Houston, TX.
The property has been negatively affected by the volatile oil and
gas industry. As of March 2019, occupancy was reported at 61%, a
significant decline from 83% at issuance. The servicer-reported YE
2018 NOI DSCR was 0.87x, compared with 1.17x at YE 2017 and 1.47x
at YE 2016. The decline in NOI is attributed to vacancy as well as
higher real estate taxes.

The next largest FLOC is the SpringHill Suites (Albany-Colonie)
loan (1.3%), which is secured by a 119-room, limited-service hotel
located in Colonie, NY. YE 2018 NOI DSCR was reported at 1.0x,
declining from 1.16x at YE 2017 and 1.27x at YE 2016. The property
has been outperformed by its competitive set with RevPar
penetration of only 74%. No other FLOC represents more than 1.17%
of the pool.

Additional Considerations

Pool Concentrations: 31.6% of the pool is secured by retail
properties, 24% by office, 23.5% by multifamily and 9.3% by
lodging. The pool has an above-average concentration of multifamily
properties and a below-average concentration of hotel properties
for similar vintages.

RATING SENSITIVITIES

The Stable Rating Outlooks on the senior classes reflect the
overall stable performance of the pool and continued expected
paydown from amortization. Rating upgrades may occur with improved
pool performance and additional paydown or defeasance. The Negative
Rating Outlook on class F reflects concerns over the FLOCs; the
class could be subject to downgrade should performance on these
loans continue to decline.

Deutsche Bank is the trustee for the transaction and serves as the
backup advancing agent. Deutsche Bank's Long-Term Issuer Default
Rating (IDR) is currently 'BBB'/'F2'/Outlook Evolving . Fitch
relies on the master servicer Wells Fargo (A+/F1/ Stable), which is
currently the primary advancing agent, as counterparty. Fitch
provided ratings confirmation on Dec. 24, 2018.


JP MORGAN 2019-5: Moody's Hikes Class B-4 Debt Rating to Ba3(sf)
----------------------------------------------------------------
Moody's Investors Service upgraded the rating of one tranche from
J.P. Morgan Mortgage Trust 2019-5, a securitization backed by prime
quality residential mortgage loans.

The complete rating action is as follows:

Issuer: J.P. Morgan Mortgage Trust 2019-5

  Cl. B-4, Upgraded to Ba3 (sf); previously on Jun 28, 2019
  Definitive Rating Assigned B1 (sf)

RATINGS RATIONALE

The rating action reflects the correction of an error. In prior
rating actions on this note, an error was made in the derivation of
macroeconomic forecasts used as an input into the collateral
analysis. The rating action reflects the appropriate macroeconomic
forecasts.

For JPMMT 2019-5, its expected loss in a base case scenario
decreased from 0.55% at the time of deal closing to 0.50% following
the correction of the error. The pool loss at a stress level
consistent with the Aaa (sf) ratings did not change for this
transaction.

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

Down

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

Up

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


JP MORGAN 2019-6: DBRS Gives Prov. B Rating on Class B-5 Certs
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following Mortgage
Pass-Through Certificates, Series 2019-6 (the Certificates) to be
issued by J.P. Morgan Mortgage Trust 2019-6:

-- $741.5 million Class A-1 at AAA (sf)
-- $694.2 million Class A-2 at AAA (sf)
-- $578.5 million Class A-3 at AAA (sf)
-- $433.9 million Class A-4 at AAA (sf)
-- $144.6 million Class A-5 at AAA (sf)
-- $342.4 million Class A-6 at AAA (sf)
-- $236.1 million Class A-7 at AAA (sf)
-- $91.5 million Class A-8 at AAA (sf)
-- $98.4 million Class A-9 at AAA (sf)
-- $46.3 million Class A-10 at AAA (sf)
-- $115.7 million Class A-11 at AAA (sf)
-- $115.7 million Class A-11-X at AAA (sf)
-- $115.7 million Class A-12 at AAA (sf)
-- $115.7 million Class A-13 at AAA (sf)
-- $47.3 million Class A-14 at AAA (sf)
-- $47.3 million Class A-15 at AAA (sf)
-- $617.9 million Class A-16 at AAA (sf)
-- $123.6 million Class A-17 at AAA (sf)
-- $741.5 million Class A-X-1 at AAA (sf)
-- $741.5 million Class A-X-2 at AAA (sf)
-- $115.7 million Class A-X-3 at AAA (sf)
-- $47.3 million Class A-X-4 at AAA (sf)
-- $11.8 million Class B-1 at AA (sf)
-- $15.8 million Class B-2 at A (sf)
-- $8.3 million Class B-3 at BBB (sf)
-- $5.1 million Class B-4 at BB (sf)
-- $2.8 million Class B-5 at B (sf)

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

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

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

The AAA (sf) ratings on the Certificates reflect the 6.00% of
credit enhancement provided by subordinated certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 5.00%, 2.90%, 1.55%, 0.85% and 0.65% of credit enhancement,
respectively.

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

The Certificates are backed by 1,131 loans with a total principal
balance of $788,861,418 as of the Cut-Off Date (August 1, 2019).

The pool consists of fully amortizing fixed-rate mortgages with
original terms to maturity of up to 30 years. Approximately 28.2%
of the loans in the pool are conforming mortgage loans
predominantly originated by Quicken Loans Inc. (Quicken) and
JPMorgan Chase Bank, N.A. (JPMCB; rated AA with a Stable trend by
DBRS), which were eligible for purchase by Fannie Mae or Freddie
Mac. JPMCB generally delegates conforming loan underwriting
authority to correspondent lenders and does not subsequently review
those loans. Details on the underwriting of conforming loans can be
found in the Key Probability of Default Drivers section of the
related presale report.

The originators for the aggregate mortgage pool are United Shore
Financial Services LLC (50.9%), Quicken (27.5%), JPMCB (8.5%) and
various other originators, each comprising less than 5.0% of the
mortgage loans. Approximately 2.5% of the loans sold to the
mortgage loan seller were acquired by MAXEX Clearing LLC, which
purchased such loans from the related originators or an
unaffiliated third party that directly or indirectly purchased such
loans from the related originators.

The mortgage loans will be serviced or sub-serviced by NewRez LLC
doing business as Shellpoint Mortgage Servicing (SMS; 73.1%),
Quicken (17.9%), JPMCB (8.5%) and various other services, each
comprising less than 5.0% of the mortgage loans. Servicing will be
transferred from SMS to JPMCB on the servicing transfer date
(October 1, 2019, or a later date) as determined by the Issuing
Entity and JPMCB. For this transaction, the servicing fee payable
for mortgage loans serviced by JPMCB and SMS (which will be
subsequently serviced by JPMCB), is composed of three separate
components: the aggregate base servicing fee, the aggregate
delinquent servicing fee, and the aggregate additional servicing
fee. These fees vary based on the delinquency status of the related
loan and will be paid from interest collections before distribution
to the securities.

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

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

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

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

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


JP MORGAN 2019-6: Moody's Assigns (P)B3 Rating on Class B-5 Debt
----------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to 22
classes of residential mortgage-backed securities issued by J.P.
Morgan Mortgage Trust 2019-6. The ratings range from (P)Aaa (sf) to
(P)B3 (sf).

The certificates are backed by 1,131 30-year, fully-amortizing
fixed-rate mortgage loans with a total balance of $788,861,418 as
of the August 1, 2019 cut-off date. Similar to prior JPMMT
transactions, JPMMT 2019-6 includes GSE-eligible mortgage loans
(28% by loan balance) mostly originated by United Shore Financial
Services, LLC d/b/a United Wholesale Mortgage and Shore Mortgage,
Quicken Loans Inc. and JPMorgan Chase Bank, National Association,
underwritten to the government sponsored enterprises guidelines in
addition to prime jumbo non-GSE eligible (non-conforming) mortgages
purchased by J.P. Morgan Mortgage Acquisition Corp., sponsor and
mortgage loan seller, from various originators and aggregators.
United Shore, Quicken and JPMCB originated approximately 51%, 28%
and 9% of the mortgage pool, respectively. With respect to the
mortgage loans, each originator or the aggregator, as applicable,
made a representation and warranty that the mortgage loan
constitutes a qualified mortgage (QM) under the qualified mortgage
rule.

New Penn Financial, LLC d/b/a Shellpoint Mortgage Servicing
(Shellpoint), JPMCB and Quicken will be the servicers for majority
of the pool. Shellpoint will act as interim servicer for the JPMCB
mortgage loans until the servicing transfer date, which is expected
to occur on or about October 1, 2019, but may occur on a later date
as determined by the issuing entity. After the servicing transfer
date, these mortgage loans will be serviced by JPMCB.

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

The complete rating actions are as follows:

Issuer: J.P. Morgan Mortgage Trust 2019-6

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

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

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

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

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

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

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

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

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

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

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

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

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

Cl. A-14, Assigned (P)Aa1 (sf)

Cl. A-15, Assigned (P)Aa1 (sf)

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

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

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

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

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

Cl. B-4, Assigned (P)Ba3 (sf)

Cl. B-5, Assigned (P)B3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected cumulative net loss on the aggregate pool is 0.45%
in a base scenario and reaches 4.90% at a stress level consistent
with the Aaa (sf) ratings.

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

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

Aggregation/Origination Quality

Moody's considers JPMMAC's aggregation platform to be adequate and
Moody's did not apply a separate loss-level adjustment for
aggregation quality. In addition to reviewing JPMMAC as an
aggregator, Moody's has also reviewed the originators contributing
a significant percentage of the collateral pool (above 10%). For
these originators, Moody's reviewed their underwriting guidelines
and their policies and documentation (where available). Moody's
increased its base case and Aaa (sf) loss expectations for certain
originators of non-conforming loans where Moody's does not have
clear insight into the underwriting practices, quality control and
credit risk management. Moody's did not make an adjustment for
GSE-eligible loans, regardless of the originator, since those loans
were underwritten in accordance with GSE guidelines.

Servicing arrangement

Moody's considers the overall servicing arrangement for this pool
to be adequate given the strong servicing arrangement of the
servicers, as well as the presence of a strong master servicer to
oversee the servicers. The servicers are contractually obligated to
the issuing entity to service the related mortgage loans. However,
the servicers may perform their servicing obligations through
sub-servicers. In this transaction, Nationstar (rated B2) 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, N.A. (rated Aa3) will be
obligated to do so to the extent such advance is determined by the
securities administrator to be recoverable.

JPMCB (servicer): JPMCB, a wholly-owned bank subsidiary of JPMorgan
Chase & Co., is a seasoned servicer with over 20 years of
experience servicing residential mortgage loans and has
demonstrated adequate servicing ability as a primary servicer of
prime residential mortgage loans. JPMCB also is the originator with
respect to the JPMCB serviced mortgage loans and is an affiliate of
the mortgage loan seller, of the depositor and of J.P. Morgan
Securities LLC, an initial purchaser. Third-party mortgage loans
(including those serviced by JPMCB for certain unconsolidated
affiliates of JPMCB) serviced by JPMCB (by aggregate unpaid
principal balance) were $519.6 billion as of December 31, 2018. In
addition to servicing mortgage loans securitized by the Depositor,
JPMCB also services mortgage loans that are held in its portfolio
and whole loans that are sold to a variety of investors.

Shellpoint (servicer): Shellpoint has demonstrated adequate
servicing ability as a primary servicer of prime residential
mortgage loans. Shellpoint, an approved servicer in good standing
with Ginnie Mae, Fannie Mae and Freddie Mac, has the necessary
processes, staff, technology and overall infrastructure in place to
effectively service the transaction.

Nationstar (master servicer): Nationstar is the master servicer for
the transaction and provides oversight of the servicers. Nationstar
is a mortgage servicer and lender formed in 1994 originally under
the name Nova Credit Corporation that engages in servicing
activities for itself as well as various third parties, primarily
as a "high touch" servicer and originating primarily GSE-eligible
residential mortgage loans. On August 21, 2017 Nationstar Mortgage
became known as Mr. Cooper for its mortgage servicing and
originations operations. Moody's considers Nationstar's master
servicing operation to be above average compared to its peers.
Nationstar has strong reporting and remittance procedures and
strong compliance and monitoring capabilities. The company's senior
management team has on average more than 20 years of industry
experience, which provides a solid base of knowledge and
leadership. Nationstar's oversight encompasses loan administration,
default administration, compliance, and cash management. Nationstar
is an indirectly held, wholly owned subsidiary of Nationstar
Mortgage Holdings Inc. Moody's rates Nationstar at B2 negative.

Collateral Description

JPMMT 2019-6 is a securitization of a pool of 1,131 30-year,
fully-amortizing fixed-rate mortgage loans with a total balance of
$788,861,418 as of the cut-off date, with a weighted average (WA)
remaining term to maturity of 360 months, and a WA seasoning of 3.5
months. The borrowers in this transaction have high FICO scores and
sizeable equity in their properties. The WA current FICO score is
772 and the WA original combined loan-to-value ratio (CLTV) is 70%.
The characteristics of the loans underlying the pool are generally
comparable to other JPMMT transactions backed by prime mortgage
loans that Moody's has rated.

In this transaction, about 28% of the pool by loan balance was
underwritten to Fannie Mae's and Freddie Mac's guidelines
(GSE-eligible loans). The GSE-eligible loans in this transaction
have a high average current loan balance of $610,124. The high
GSE-eligible loan balance in JPMMT 2019-6 is attributable to the
large number of properties located in high-cost areas, such as the
metro areas of Los Angeles-Long Beach-Anaheim, CA (14%), San
Francisco-Oakland-Hayward (12%) and the greater San Diego- San
Francisco-New York metropolitan areas (17% combined). The top
10-metropolitan statistical areas account for 60% of the pool.

With respect to the mortgage loans, each originator or the
aggregator, as applicable, made a representation and warranty that
the mortgage loan constitutes a qualified mortgage (QM) under the
qualified mortgage rule. To satisfy the requirements of the QM rule
for a non-conforming mortgage loan, a borrower's debt-to-income
ratio cannot exceed 43%. With respect to the GSE-eligible mortgage
loans, each originator made a representation and warranty as to the
loans originated by it, that such mortgage loans were qualified
mortgages under the QM rule because those mortgage loans were
eligible for purchase by Fannie Mae or Freddie Mac.

Servicing Fee Framework

The servicing fee for loans serviced by Shellpoint and JPMCB will
be based on a step-up incentive fee structure with a monthly base
fee of $20 per loan and additional fees for servicing delinquent
and defaulted loans. PennyMac Corp., Quicken, TIAA, FSB and USAA
Federal Savings Bank., will be paid a monthly flat servicing fee
equal to one-twelfth of 0.25% of the remaining principal balance of
the mortgage loans. Shellpoint will act as interim servicer for the
JPMCB mortgage loans until the servicing transfer date, October 1,
2019 or such later date as determined by the issuing entity and
JPMCB.

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

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

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

Third-party Review and Reps & Warranties

Three third party review firms, AMC Diligence, LLC (AMC), Clayton
Services LLC (Clayton) and Opus Capital Markets Consultants, LLC
(Opus) (collectively, TPR firms) verified the accuracy of the
loan-level information that Moody's received from the sponsor.
These firms conducted detailed credit, valuation, regulatory
compliance and data integrity reviews on 100% of the mortgage pool.
The TPR results indicated compliance with the originators'
underwriting guidelines for majority of loans, no material
compliance issues, and no appraisal defects. Of the loans in the
securitization population reviewed by AMC, after all documents were
presented, two (2) loans had an overall loan grade of "C" as these
loans were missing a secondary valuation initially which was
subsequently provided. Of the loans reviewed by Opus, two (2) loans
had an overall loan grade of "C", due to valuation variances not
being within acceptable tolerance (above 10%). Overall, the loans
that had exceptions to the originators' underwriting guidelines had
strong documented compensating factors such as low DTIs, low LTVs,
high reserves, high FICOs, or clean payment histories. The TPR
firms also identified minor compliance exceptions for reasons such
as inadequate RESPA disclosures (which do not have assignee
liability) and TILA/RESPA Integrated Disclosure (TRID) violations
related to fees that were out of variance but then were cured and
disclosed. Except for three of the four loans graded "C" by AMC and
Opus and certain other loans with solely AVM valuations, Moody's
did not make any adjustments to its expected or Aaa (sf) loss
levels due to the TPR results.

The property valuation review consisted of reviewing the valuation
materials utilized at origination to ensure the appraisal report
was complete and in conformity with the underwriting guidelines.
The TPR firms also compared third-party valuation products to the
original appraisals. The property valuation portion of the TPR was
conducted using, among other things, a field review, a third-party
collateral desk appraisal (CDA), broker price opinion (BPO),
automated valuation model (AVM) or a Collateral Underwriter (CU)
risk score. In some cases, a CDA, BPO or AVM was not provided
because these loans were originated under United Shore's High
Balance Nationwide program (i.e. non-conforming loans underwritten
using Fannie Mae's Desktop Underwriter Program) and had a CU risk
score less than or equal to 2.5. Moody's considers the use of CU
risk score for non-conforming loans to be credit negative due to
(1) the lack of human intervention which increases the likelihood
of missing emerging risk trends, (2) the limited track record of
the software and limited transparency into the model and (3) GSE
focus on non-jumbo loans which may lower reliability on jumbo loan
appraisals. However, Moody's did not apply an adjustment to the
loss for such loans since the sample size and valuation result of
the loans that were reviewed using a CDA (a more accurate
third-party valuation product) were sufficient and the original
appraisal balances for such loans were not significantly higher
than that of appraisal values for GSE-eligible loans.

In addition, there were loans for which the original appraisal was
evaluated using only AVMs. Moody's believes that utilizing only
AVMs as a comparison to verify the original appraisals is much
weaker and less accurate than utilizing CDAs for the entire pool.
Moody's took this framework into consideration and applied an
adjustment to the loss for such loans.

JPMMT 2019-6's R&W framework is in line with that of other JPMMT
transactions where an independent reviewer is named at closing, and
costs and manner of review are clearly outlined at issuance. Its
review of the R&W framework considers the financial strength of the
R&W providers, scope of R&Ws (including qualifiers and sunsets) and
enforcement mechanisms. The R&W providers vary in financial
strength. Moody's made no adjustments to the loans for which JPMCB
(Aa2), TIAA, FSB (d/b/a TIAA Bank) and USAA Federal Savings Bank (a
subsidiary of USAA Capital Corporation, rated Aa1) provided R&Ws
since they are highly rated entities. In contrast, the rest of the
R&W providers are unrated and/or financially weaker entities,
including United Shore and Quicken. Moody's applied an adjustment
to the loans for which these entities provided R&Ws. No party will
backstop or be responsible for backstopping any R&W providers who
may become financially incapable of repurchasing mortgage loans.
With respect to the mortgage loan representations and warranties
made by such originators or the aggregator, as applicable, as of a
date prior to the closing date, JPMMAC will make a "gap"
representation covering the period from the date as of which such
representation and warranty is made by such originator or the
aggregator, as applicable, to the cut-off date or closing date, as
applicable.

For loans that JPMMAC acquired via the MAXEX platform, MAXEX under
the assignment, assumption and recognition agreement with JPMMAC,
will make the R&Ws. The R&Ws provided by MAXEX to JPMMAC and
assigned to the trust are in line with the R&Ws found in the JPMMT
transactions.

Trustee and Master Servicer

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

Tail Risk & Subordination Floor

This deal has a standard shifting-interest structure, with a
subordination floor to protect against losses that occur late in
the life of the pool when relatively few loans remain (tail risk).
When the total senior subordination is less than 0.80% of the
original pool balance, the subordinate bonds do not receive any
principal and all principal is then paid to the senior bonds. In
addition, if the subordinate percentage drops below 6.00% of
current pool balance, the senior distribution amount will include
all principal collections and the subordinate principal
distribution amount will be zero. The subordinate bonds themselves
benefit from a floor. When the total current balance of a given
subordinate tranche plus the aggregate balance of the subordinate
tranches that are junior to it amount to less than 0.65% of the
original pool balance, those tranches do not receive principal
distributions. The principal those tranches would have received is
directed to pay more senior subordinate bonds pro-rata.

Transaction Structure

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

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

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

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

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

Down

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

Up

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


KENTUCKY HIGHER 2010-1: Fitch Lowers Class A-2 Debt to BBsf
-----------------------------------------------------------
Fitch Ratings has taken various rating actions on Kentucky Higher
Education Student Loan Corp Trusts.

In the past year, prepayment rates (voluntary and involuntary) for
the trusts have declined, resulting in a slower decrease in the
weighted average remaining term of the loans resulting in higher
maturity risk for the transactions.

KHESLC 2010-1 and 2013-1: Fitch's student loan ABS cash flow model
indicates that the notes are not paid in full on or prior to their
legal final maturity under the 'AAAsf' through 'Bsf' stresses. The
'BBsf' ratings assigned to both transactions reflect marginal
failures of the base case maturity stresses and a change in the
future economic environment could result in full repayment of bonds
by maturity dates.

KHESLC 2013-2: Fitch's student loan ABS cash flow model indicates
the notes fail the 'BBB' through 'AAA' maturity stress scenarios.
The downgrade to 'Asf' represents application of a two category
difference from the model implied ratings, as allowed by criteria.


KHESLC 2015-1: Fitch's student loan ABS cash flow model indicates
that the notes are not paid in full on or prior to the legal final
maturity dates under the 'Asf' through 'AAAsf' maturity stress
scenarios. The downgrade to 'Asf' represents application of a one
category difference from the model-implied ratings, as allowed by
criteria.

The transactions' actual servicing fees were used to perform
cashflow modeling.

Kentucky Higher Education Student Loan Corporation, Series 2010-1
   
  Class A-2 49130NCC1; LT BBsf Downgrade; previously at BBBsf

Kentucky Higher Education Student Loan Corporation, Series 2013-2
   
  Class A-1 49130NCH0; LT Asf Downgrade; previously at AAsf

Kentucky Higher Education Student Loan Corporation, Series 2013-1
   
  Class A-1 49130NCG2; LT BBsf Affirmed; previously at BBsf

Kentucky Higher Education Student Loan Corporation, Series 2015-1
   
  Class A-1 49130NCX5; LT Asf Downgrade; previously at AAsf

KEY RATING DRIVERS

U.S. Sovereign Risk: The trust's 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. For the 2015-1 trust, 52.5% of the loans are
rehabilitated FFELP loans. The U.S. sovereign rating is currently
'AAA'/Outlook Stable.

Collateral Performance:

Fitch assumes base case default rates of 19.3%, 31.5%, 23.0% and
37.3% for KHESLC 2010-1, 2013-1, 2013-2and 2015-1, respectively.
The 'AAA' credit stress scenario default rates are 57.8%, 94.5%,
69.0% and 100% for KHESLC 2010-1, 2013-1, 2013-2 and 2015-1,
respectively. The base case default assumptions imply constant
default rates of 3%, 6.5%, 4.5% and 6.5% for KHESLC 2010-1, 2013-1,
2013-2 and 2015-1, respectively. Fitch is also maintaining
sustainable constant prepayment rates (voluntary & involuntary) of
8.5%, 12% and 10% for KHESLC 2010-1, 2013-2 and 2015-1,
respectively, and revising the sustainable constant prepayment rate
for KHESLC 2013-1 to 10% from 12%.

The TTM deferment levels are 4.06%, 9.76%, 7.16% and 8.61% for
KHESLC 2010-1, 2013-1, 2013-2 and 2015-1, respectively. The TTM
forbearance levels are 2.90%, 6.50%, 5.43% and 7.31% for KHESLC
2010-1, 2013-1, 2013-2 and 2015-1, respectively. The TTM
income-based repayment levels (prior to adjustment) are 18.82%,
35.60%, 34.24% and 28.92% for KHESLC 2010-1, 2013-1, 2013-2 and
2015-1, respectively.

For all the transactions, the claim reject rate is assumed to be
0.25% in the base case and 2.0% in the 'AAA' case. The borrower
benefits are 0.49%, 0.08%, 0.19%,and 0.18% for KHESLC 2010-1,
2013-1, 2013-2 and 2015-1, respectively, based on information
provided by the servicer.

Fitch's student loan ABS cash flow model indicates that the notes
are not paid in full on or prior to the legal final maturity under
the 'AAAsf' through 'Bsf' stresses for KHESLC 2010-1 and 2013-1.
However their ratings are downgraded to 'BBsf', which is in line
with criteria. KHESLC 2013-2 fails the 'AAAsf' through 'BBBsf'
maturity scenarios. The notes are downgraded to 'Asf', in line with
criteria. KHESLC 2015-1 fails the the 'AAAsf' through 'Asf'
maturity stresses scenarios. The notes are downgraded to 'Asf', in
line with criteria.

Basis and Interest Rate Risk: Basis risk for this transaction
arises from any rate and reset frequency mismatch between interest
rate indices for SAP and the securities. As of March 31, 2019 all
notes in 2010-1 are indexed to 3-month LIBOR and all notes in
2013-1, 2013-2 and 2015-1 are indexed to one-month LIBOR. For
2010-1, 96.9% of the trust student loans are indexed to one-month
LIBOR and rest are indexed to 91 day T-Bill. For 2013-1, 99.4% of
the trust student loans are indexed to one-month LIBOR, and the
rest are indexed to 91 day T-Bill. For 2013-2, 93.8% of the trust
student loans are indexed to one-month LIBOR and the rest are
indexed to 91 day T-Bill. For 2015-1, 96.8% of the trust student
loans are indexed to one-month LIBOR, and the rest are indexed to
91 Day T-Bill.

Payment Structure: Credit enhancement (CE) is provided by excess
spread and a reserve account. As of March 31, 2019, total reported
parity is 111.75%, 120.53%, 117.15% and 109.13% for 2010-1, 2013-1,
2013-2 and 2015-1, respectively. Liquidity support is provided by a
reserve, which is currently sized at its floor of $350,000,
$845,700, $576,000 and $250,000 for 2010-1, 2013-1, 2013-2 and
2015-1, respectively. 2010-1 releases cash as long as it maintains
its 110% parity, or until it meets the earlier of the 10% pool
factor or the May 2020 payment date. The 2013-1, 2013-2 and 2015-1
transactions have a turbo structure and will not release cash until
the notes are paid in full.

Operational Capabilities: Day-to-day servicing is provided by
KHESLC and Nelnet Servicing LLC is the back-up servicer. Fitch
considers both to be acceptable servicers of FFELP student loans.

RATING SENSITIVITIES

'AAAsf' rated tranches of most FFELP securitizations will likely
move in tandem with the U.S. sovereign rating, given the strong
linkage to the U.S. sovereign by nature of the reinsurance and SAP
provided by ED. Sovereign risks are not addressed in Fitch's
sensitivity analysis.

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.  

For Kentucky 2010:

Credit Stress Rating Sensitivity

  -- Default increase 25%: class A 'CCCsf';

  -- Default increase 50%: class A 'CCCsf';

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

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

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'CCCsf';

  -- CPR decrease 50%: class A 'CCCsf';

  -- IBR Usage increase 25%: class A 'CCCsf';

  -- IBR Usage increase 50%: class A 'CCCsf';

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

  -- Remaining Term increase 50%: class A 'CCCsf'.
                
For Kentucky 2013-1:     
           
Credit Stress Rating Sensitivity

  -- Default increase 25%: class A 'CCCsf';

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

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

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

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'CCCsf';

  -- CPR decrease 50%: class A 'CCCsf';

  -- IBR Usage increase 25%: class A 'CCCsf';

  -- IBR Usage increase 50%: class A 'CCCsf';

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

  -- Remaining Term increase 50%: class A 'CCCsf'.
                        
For Kentucky 2013-2:

Credit Stress Rating Sensitivity

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

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

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

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

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'CCCsf';

  -- CPR decrease 50%: class A 'CCCsf';

  -- IBR Usage increase 25%: class A 'CCCsf';

  -- IBR Usage increase 50%: class A 'CCCsf';

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

  -- Remaining Term increase 50%: class A 'CCCsf'.
                
For Kentucky 2015-1

Credit Stress Rating Sensitivity

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

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

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

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

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'CCCsf';

  -- CPR decrease 50%: class A 'CCCsf';

  -- IBR Usage increase 25%: class A 'Bsf';

  -- IBR Usage increase 50%: class A 'CCCsf'.

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

  -- Remaining Term increase 50%: class A 'CCCsf'.
                                            
It is important to note that the 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.


KKR CLO 26: Moody's Assigns Ba3 Rating on $29.7MM Class E Notes
---------------------------------------------------------------
Moody's Investors Service assigned ratings to six classes of notes
issued by KKR CLO 26 Ltd.

Moody's rating action is as follows:

US$310,000,000 Class A-1 Senior Secured Floating Rate Notes due
2032 (the "Class A-1 Notes"), Definitive Rating Assigned Aaa (sf)

US$39,000,000 Class B-1 Senior Secured Floating Rate Notes due 2032
(the "Class B-1 Notes"), Definitive Rating Assigned Aa2 (sf)

US$9,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2032
(the "Class B-2 Notes"), Definitive Rating Assigned Aa2 (sf)

US$25,000,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class C Notes"), Definitive Rating Assigned A2 (sf)

US$30,000,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class D Notes"), Definitive Rating Assigned Baa3
(sf)

US$29,700,000 Class E Senior Secured Deferrable Floating Rate Notes
due 2032 (the "Class E Notes"), Definitive Rating Assigned Ba3
(sf)

The Class A-1 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.

KKR CLO 26 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 98% ramped as of
the closing date.

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

In addition to the Rated Notes, the Issuer issued one other class
of secured notes and 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): 2980

Weighted Average Spread (WAS): 3.30%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 48.50%

Weighted Average Life (WAL): 9.17 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.


M360 2019-CRE2: DBRS Assigns Prov. B(low) Rating on Class G Notes
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Floating-Rate Notes, Series 2019-CRE2 (the Notes) to be issued by
M360 2019-CRE2, Ltd. (the Issuer):

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

All trends are Stable. Classes A, A-S, B, C, D, and E represent the
offered certificates. Classes F and G are non-offered certificates
and will be retained by the Issuer.

The initial collateral consists of 32 floating-rate mortgages
secured by 32 mostly transitional properties with a cut-off balance
totaling $306.0 million, excluding approximately $71.7 million of
future funding commitments. Included in the loan count and cut-off
balance are two Targeted Mortgage Assets, representing $18.8
million, which have not yet closed. In addition, there is a 90-day
Ramp-Up Period during which the Issuer may acquire additional
eligible loans subject to the Eligibility Criteria, resulting in a
maximum pool balance of $360.0 million. Most loans are in a period
of transition with plans to stabilize and improve asset value.
During the Reinvestment Period, the Issuer may acquire future
funding commitments and additional eligible loans subject to the
Eligibility Criteria. The transaction stipulates a $1.0 million
threshold on pari-passu participation acquisitions before a Rating
Agency Condition (RAC) is required if there is already
participation of the underlying loan in the trust.

For the floating-rate loans, DBRS used the one-month LIBOR index,
which is based on the lower of a DBRS stressed rate that
corresponded with the remaining fully extended term of the loans or
the strike price of the interest rate cap with the respective
contractual loan spread added to determine a stressed interest rate
over the loan term. When the cut-off balances were measured against
the DBRS As-Is net cash flow, 27 loans, comprising 87.6% of the
initial pool, had a DBRS As-Is debt service coverage ratio (DSCR)
below 1.00 times (x), a threshold indicative of default risk.
Additionally, the DBRS Stabilized DSCR for 13 loans, comprising
45.5% of the initial pool balance, is below 1.00x, which is
indicative of elevated refinance risk. The properties are often
transitioning with potential upside in cash flow; however, DBRS
does not give full credit to the stabilization if there are no
holdbacks or if other loan structural features in place are
insufficient to support such treatment. Furthermore, even with the
structure provided, DBRS generally does not assume the assets to
stabilize above market levels. The transaction will have a
sequential-pay structure.

The pool is fairly diverse by commercial real estate collateralized
loan obligation (CRE CLO) standards with a diversity profile
equivalent to that of a pool with 25 equally sized loans (including
three projected ramp-up loans). The loans are generally secured by
traditional property types (i.e., retail, multifamily, office and
industrial) with only 7.5% of the pool secured by hotels.
Additionally, only one of the multifamily loans (Lafayette
University Place, representing 3.1% of the initial pool balance) in
the pool is currently secured by a student-housing property, which
often exhibits higher cash flow volatility than traditional
multifamily properties. Six loans, representing 19.2% of the
initial pool balance, are represented by properties which are
primarily located in core markets with a DBRS Market Rank of 5 to
7. These higher DBRS Market Ranks correspond with zip codes that
are more urbanized or densely suburban in nature. Four loans in the
pool, totaling 22.5% of the DBRS sample by cut-off date pool
balance, are backed by a property with a quality deemed to be
Average (+) by DBRS.

The weighted-average (WA) DBRS As-Is loan-to-value (LTV) ratio,
which includes all future funding in the calculation, is high at
9.5%, reflecting the highly transitional nature of the pool with
substantial future funding as well as the general high leverage.
The high LTV results in a very high WA DBRS expected loss of 9.5%
for the pool, which translates to credit enhancement levels at each
rating category that is relatively high compared with other CRE
CLOs.

The pool consists of mostly transitional assets. Given the nature
of the assets, DBRS determined a sample size, representing 74.9% of
the pool cut-off date balance. Physical site inspections were also
performed, including management meetings. DBRS also notes that,
when DBRS analysts are visiting the markets, they may actually
visit properties more than once to follow the progress (or lack
thereof) toward stabilization.

Nine of the sampled loans, comprising 31.4% of the pool balance,
were analyzed with Weak or Bad (Litigious) sponsorship strengths.
Three of the loans – Brushy Creek Corporate Center, Hughes Plaza
Office and The Park at Riverwoods – are among the pool's top ten
largest loans. DBRS applied a probability of default (POD) penalty
to loans analyzed with Weak or Bad (Litigious) sponsorship
strength. Additionally, for all non-sampled loans in the pool, DBRS
applied a Weak sponsorship strength to account for the pool's
overall exposure. In total, 23 loans, representing 60.8% of the
pool cut-off date balance, were analyzed with Weak or Bad
(Litigious) sponsorship and received POD adjustments.

All 32 loans have floating interest rates and all loans are
interest-only (IO) during the original term with original terms
ranging from 12 months to 36 months, creating interest rate risk.
All loans are short-term loans and, even with extension options,
they have a fully extended maximum loan term of five years.
Additionally, for the floating-rate loans, DBRS used the one-month
LIBOR index, which is based on the lower of a DBRS stressed rate
that corresponded with the remaining fully extended term of the
loans or the strike price of the interest rate cap with the
respective contractual loan spread added to determine a stressed
interest rate over the loan term. Additionally, all have extension
options and, in order to qualify for these options, the loans must
meet minimum leverage requirements.

The participations conveyed to the Issuer will not include record
title to the underlying mortgage in the name of the Issuer, but
instead will include help from the Seller. This is contrary to
standard CRE CLO structures, where the issuer or institutional
custodian generally holds title to the participation loans. In the
case of a bankruptcy, the issuer has a lesser claim to the loan
since it does not own the title. As a result, the issuer's ability
to recover under such participation is subject to the credit risk
of the entity that holds legal title to the underlying collateral.
Payments to the issuer will be affected if the legal titleholder of
the participated assets files bankruptcy or is declared insolvent.
The Issuer informed DBRS that the risk of M360 2019-CRE2 Seller,
LLC becoming involved in bankruptcy is diminished because the
entity will be limited to only acquiring mortgage loans and
participations therein and not engaging in other business.
Furthermore, it will be limited on indebtedness to only that debt
arising in connection with the loan participations.

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

Twenty-six loans, totaling only 89.3% of the initial pool balance,
represent refinance financing. The refinance financings within this
securitization generally do not require the respective sponsor(s)
to contribute material cash equity as a source of funding in
conjunction with the mortgage loan, resulting in a lower sponsor
cost basis in the underlying collateral. Of the 26 refinance loans,
13 loans, representing 39.8% of the pool, have a current occupancy
of less than 80.0% and four of the refinance loans account for
$26.6 million of the $71.7 million of future funding (37.1%). This
suggests that at least one-third of the refinance loans are near
stabilization, which would partially mitigate the higher risk
associated with a sponsor's lower cost basis.

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


MORGAN STANLEY 2001-TOP3: Fitch Affirms Dsf Rating on 7 Tranches
----------------------------------------------------------------
Fitch Ratings has upgraded one and affirmed seven classes of Morgan
Stanley Dean Witter Capital I Trust (MSDW) commercial mortgage
pass-through certificates series 2001-TOP3.

Morgan Stanley Dean Witter Capital I Trust 2001-TOP3

                    Current Rating     Prior Rating   
Class E 61746WHM5  LT BBBsf Upgrade  previously at BBsf
Class F 61746WHN3  LT Dsf Affirmed   previously at Dsf
Class G 61746WHP8  LT Dsf Affirmed   previously at Dsf
Class H 61746WHQ6  LT Dsf Affirmed   previously at Dsf
Class J 61746WHR4  LT Dsf Affirmed   previously at Dsf
Class K 61746WHS2  LT Dsf Affirmed   previously at Dsf
Class L 61746WHT0  LT Dsf Affirmed   previously at Dsf
Class M 61746WHU7  LT Dsf Affirmed   previously at Dsf

KEY RATING DRIVERS

Increase in Credit Enhancement: The upgrade to class E reflects
increased credit enhancement since Fitch's last rating action from
continued scheduled amortization and one loan paying off at
maturity. As of the July 2019 distribution date, the pool's
aggregate principal balance has been reduced by 98.6% to $14.5
million from $1.03 billion at issuance. Realized losses to date
total $57.0 million (5.54% of original pool balance). Interest
shortfalls are currently affecting classes G and J through N.

Stable Loss Expectations: The performance of the remaining pool has
been stable since Fitch's last rating action. All nine of the
remaining loans are current. Three loans (13.1% of pool) are fully
defeased. Three loans are fully amortizing, low leveraged loans
(combined, 11.6%) secured by an industrial property in Charlotte,
NC and two self storage properties in Bakersfield, CA. The largest
loan in the pool (29.6%) is secured by a 56,963 square foot (sf)
retail property in Belle Harbor, NY that is currently fully
occupied by Stop & Shop on a lease through the end of May 2021,
co-terminus with the loan's maturity.

Fitch has designated two loans (45.6%) as Fitch Loans of Concern
(FLOCs) as they are secured  by vacant properties with dark grocer
anchors. The largest FLOC, Marsh's Supermarket Store (27.4%), is
secured by a 56,777 sf property located in Indianapolis, IN. The
property was formerly 100% occupied by Marsh Supermarkets, but the
tenant filed for bankruptcy in May 2017 and has since vacated. The
borrower is actively marketing the property for lease and has kept
debt service current. The next largest FLOC, Kash N' Karry Grocery
Store (18.2%), is secured by a 48,119 sf retail property formerly
occupied by Sweetbay (parent company, Ahold Delhaize NV, is rated
BBB+), which went dark in 2013; the tenant is expected to continue
paying rent until its lease expires in April 2020.

Concentrated Pool; Additional Sensitivity: Due to the concentrated
nature of the pool, Fitch performed a sensitivity analysis that
grouped the remaining loans based on loan structural features,
collateral quality and performance and ranked them by their
perceived likelihood of repayment. The ratings reflect this
sensitivity analysis. To support the upgrade of class E, Fitch
performed an additional sensitivity scenario that applied
conservative and potential outsized losses of 75% on the two FLOCs,
Marsh's Supermarket Store and Kash N' Karry Grocery Store, as well
as a 50% loss on the A&P (Waldbaums) Belle Harbor loan due to
refinance concerns.

Significant Upcoming Loan Maturities: 100% of the pool matures in
2021.

Strong Amortization: All of the loans in the pool are amortizing,
including six (24.8% of pool) that are fully amortizing.

RATING SENSITIVITIES

No further upgrades to class E are likely without significant
defeasance or paydown. The rating of class E reflects the quality
of the remaining collateral and the concentrated nature of the
pool. While unlikely, Class E could be subject to downgrade should
loans expected to repay fail to repay at maturity and transfer to
special servicing. The remaining classes have realized losses and
will remain at 'Dsf'.


MORGAN STANLEY 2015-C26: Fitch Affirms B-sf Rating on Cl. F Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of Morgan Stanley Bank of
America Merrill Lynch Trust, commercial mortgage pass-through
certificates, series 2015-C26.

MSBAM 2015-C26
   
Class A-2 61690VAV0   LT AAAsf   Affirmed  previously at AAAsf
Class A-3 61690VAX6   LT AAAsf   Affirmed  previously at AAAsf
Class A-4 61690VAY4   LT AAAsf   Affirmed  previously at AAAsf
Class A-5 61690VAZ1   LT AAAsf   Affirmed  previously at AAAsf
Class A-S 61690VBB3   LT AAAsf   Affirmed  previously at AAAsf
Class A-SB 61690VAW8  LT AAAsf   Affirmed  previously at AAAsf
Class B 61690VBC1     LT AA-sf   Affirmed  previously at AA-sf
Class C 61690VBD9     LT A-sf    Affirmed  previously at A-sf
Class D 61690VAE8     LT BBB-sf  Affirmed  previously at BBB-sf
Class E 61690VAG3     LT BB-sf   Affirmed  previously at BB-sf
Class F 61690VAJ7     LT B-sf    Affirmed  previously at B-sf
Class X-A 61690VBA5   LT AAAsf   Affirmed  previously at AAAsf
Class X-B 61690VAA6   LT AA-sf   Affirmed  previously at AA-sf
Class X-D 61690VAC2   LT BBB-sf  Affirmed  previously at BBB-sf

KEY RATING DRIVERS

Relatively Stable Performance: Although loss expectations have
increased slightly, mainly due to the Fitch Loans of Concern
(FLOCs), the majority of the pool has exhibited relatively stable
performance since issuance. No loans have transferred to special
servicing since issuance, and there have been no realized losses to
date. Three loans (5.6% of pool) have been designated as FLOCs,
including the fifth largest loan, Wallace Student Housing Portfolio
(3.9%).

The Wallace Student Housing Portfolio loan is secured by three
student housing properties totaling 954 beds; two of the
properties, Whistlebury & Whistlebury Walk (488 beds) and Waterford
Place (148 beds), are located in Athens, GA and one property,
College Station (318 beds), is located in Milledgeville, GA.
Portfolio occupancy and cash flow have been negatively affected by
superior competition at all three properties, as well as ongoing
renovations at the College Station property. Portfolio occupancy
declined to 78.1% at YE 2018 from 94.5% at March 2017 and 94.3% at
September 2016. A restated servicer-provided OSAR indicated
portfolio-level NOI dropped 33.8% between 2017 and 2018; as a
result, NOI DSCR declined to 0.96x for YE 2018 from 1.56x at YE
2017 and 1.64x at YE 2016. The renovations at the College Station
property include interior renovations on 60 units and exterior
renovations on all buildings. Per the most recent servicer
commentary, these property renovations were expected to be
completed in the first quarter of 2019; however, as of the May 2019
rent roll, occupancy was only 41.5% and it appears stabilization
remains ongoing. New construction has also begun on a 12,000-sf
student center, a 75-foot pool, a gated entrance and two additional
parking lots at the property. The College Station property faces
competition from Station on McIntosh Apartments (located 0.6 miles
southeast of the subject). The Whistlebury & Whistlebury Walk
property faces competition from The Standard (immediately west of
the subject). The Waterford Place property faces competition from
The Mark Athens (immediately north of the subject). All three of
these competing properties are new construction and considered
superior to the subject properties in the portfolio.

The two FLOCs outside of the top 15 are El Paso Medical Office
(0.9%), which is secured by a medical office property located in El
Paso, TX and Bay Harbor Island Hotel (0.8%), which is secured by a
46-key full-service hotel located in Bay Harbor Islands, FL. The El
Paso Medical Office property has experienced cash flow and
occupancy declines due to two tenants (10.7% of NRA) vacating upon
lease expiration and the largest tenant reducing its footprint to
24.6% of NRA from 31.7% of NRA. Occupancy dropped to 69% at YE 2018
from 82.3% at YE 2017 and 80% at YE 2016. YE 2018 NOI DSCR declined
to 0.65x at YE 2018 from 1.20x at YE 2017 and 1.92x at YE 2016. The
Bay Harbor Island Hotel property has continued to underperform
since issuance due to competition. Property stabilization remains
ongoing from renovations completed in 2017, as well as a change in
property management. Occupancy was 70% at March 2019, compared to
60.4% at YE 2017, 73.6% at YE 2016 and 82% in June 2015. The
trailing-12-month March 2019 NOI DSCR was 0.14x, down from 0.52x at
YE 2017 and 0.86x at YE 2016.

Minimal Change to Credit Enhancement: As of the July 2019
distribution date, the pool's aggregate balance has paid down by
4.3% to $1.0 billion from $1.05 billion at issuance. Eight loans
(33.5% of pool) are full-term interest-only and 13 loans (16.1%)
remain within their partial interest-only period. Two loans (2.5%)
have been defeased since the last rating action, including one loan
in the top 15, Landmark at City Park (2.4%). Near-term maturities
are limited to one loan (0.9%) in 2020; the majority matures in
2024 (10%) and 2025 (89.2%).

ADDITIONAL CONSIDERATIONS

Manhattan Concentration: The three largest loans (30.1% of pool)
are located in Manhattan and include 535-545 Fifth Avenue (11%),
Herald Center (10%) and 11 Madison Avenue (9.1%). These three
properties are considered to be in very strong locations for office
and retail, including the Grand Central office market/Lower Fifth
Avenue, Herald Square and Midtown South submarkets. At issuance, 11
Madison Avenue was assigned an investment-grade credit opinion of
'A-sf' on a stand-alone basis.

Limited Retail and Hotel Concentration; Pool Concentration: Retail
and hotel loans comprise 10.4% and 6.9% of the current pool,
respectively. The top 10 loans comprise 53% of the current pool.

RATING SENSITIVITIES

The Rating Outlooks for all classes remain Stable due to overall
stable pool performance and expected continued amortization. Future
rating upgrades may occur with improved pool performance and/or
additional paydown or defeasance. Rating downgrades are possible
should overall pool performance decline significantly.


NEW RESIDENTIAL 2019-4: DBRS Finalizes B Rating on 10 Note Classes
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage-Backed Notes, Series 2019-4 (the Notes) issued by New
Residential Mortgage Loan Trust 2019-4 (NRMLT or the Trust):

-- $416.5 million Class A-1 at AAA (sf)
-- $416.5 million Class A-IO at AAA (sf)
-- $416.5 million Class A-1A at AAA (sf)
-- $416.5 million Class A-1B at AAA (sf)
-- $416.5 million Class A-1C at AAA (sf)
-- $416.5 million Class A-1D at AAA (sf)
-- $416.5 million Class A1-IOA at AAA (sf)
-- $416.5 million Class A1-IOB at AAA (sf)
-- $416.5 million Class A1-IOC at AAA (sf)
-- $416.5 million Class A1-IOD at AAA (sf)
-- $451.5 million Class A-2 at AA (sf)
-- $416.5 million Class A at AAA (sf)
-- $34.9 million Class B-1 at AA (sf)
-- $34.9 million Class B1-IO at AA (sf)
-- $34.9 million Class B-1A at AA (sf)
-- $34.9 million Class B-1B at AA (sf)
-- $34.9 million Class B-1C at AA (sf)
-- $34.9 million Class B-1D at AA (sf)
-- $34.9 million Class B1-IOA at AA (sf)
-- $34.9 million Class B1-IOB at AA (sf)
-- $34.9 million Class B1-IOC at AA (sf)
-- $26.6 million Class B-2 at A (sf)
-- $26.6 million Class B2-IO at A (sf)
-- $26.6 million Class B-2A at A (sf)
-- $26.6 million Class B-2B at A (sf)
-- $26.6 million Class B-2C at A (sf)
-- $26.6 million Class B-2D at A (sf)
-- $26.6 million Class B2-IOA at A (sf)
-- $26.6 million Class B2-IOB at A (sf)
-- $26.6 million Class B2-IOC at A (sf)
-- $22.4 million Class B-3 at BBB (sf)
-- $22.4 million Class B3-IO at BBB (sf)
-- $22.4 million Class B-3A at BBB (sf)
-- $22.4 million Class B-3B at BBB (sf)
-- $22.4 million Class B-3C at BBB (sf)
-- $22.4 million Class B-3D at BBB (sf)
-- $22.4 million Class B3-IOA at BBB (sf)
-- $22.4 million Class B3-IOB at BBB (sf)
-- $22.4 million Class B3-IOC at BBB (sf)
-- $16.8 million Class B-4 at BB (sf)
-- $16.8 million Class B-4A at BB (sf)
-- $16.8 million Class B-4B at BB (sf)
-- $16.8 million Class B-4C at BB (sf)
-- $16.8 million Class B4-IOA at BB (sf)
-- $16.8 million Class B4-IOB at BB (sf)
-- $16.8 million Class B4-IOC at BB (sf)
-- $8.4 million Class B-5 at B (sf)
-- $8.4 million Class B-5A at B (sf)
-- $8.4 million Class B-5B at B (sf)
-- $8.4 million Class B-5C at B (sf)
-- $8.4 million Class B-5D at B (sf)
-- $8.4 million Class B5-IOA at B (sf)
-- $8.4 million Class B5-IOB at B (sf)
-- $8.4 million Class B5-IOC at B (sf)
-- $8.4 million Class B5-IOD at B (sf)
-- $25.2 million Class B-7 at B (sf)

Classes A-IO, A1-IOA, A1-IOB, A1-IOC, A1-IOD, B1-IO, B1-IOA,
B1-IOB, B1-IOC, B2-IO, B2-IOA, B2-IOB, B2-IOC, B3-IO, B3-IOA,
B3-IOB, B3-IOC, B4-IOA, B4-IOB, B4-IOC, B5-IOA, B5-IOB, B5-IOC, and
B5-IOD are interest-only notes. The class balances represent
notional amounts.

Classes A-1A, A-1B, A-1C, A-1D, A1-IOA, A1-IOB, A1-IOC, A1-IOD,
A-2, A, B-1A, B-1B, B-1C, B-1D, B1-IOA, B1-IOB, B1-IOC, B-2A, B-2B,
B-2C, B-2D, B2-IOA, B2-IOB, B2-IOC, B-3A, B-3B, B-3C, B-3D, B3-IOA,
B3-IOB, B3-IOC, B-4A, B-4B, B-4C, B4-IOA, B4-IOB, B4-IOC, B-5A,
B-5B, B-5C, B-5D, B5-IOA, B5-IOB, B5-IOC, B5-IOD and B-7 are
exchangeable notes. These classes can be exchanged for combinations
of initial exchangeable notes as specified in the offering
documents.

The AAA (sf) ratings on the Notes reflect the 25.50% of credit
enhancement provided by subordinated notes in the pool. The AA
(sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect 19.25%,
14.50%, 10.50%, 7.50% and 6.00% of credit enhancement,
respectively.

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

This transaction is a securitization of a seasoned portfolio of
performing and re-performing first-lien residential mortgages
funded by the issuance of the Notes. The Notes are backed by 3,965
loans with a total principal balance of $559,098,578 as of the
Cut-Off Date (July 1, 2019).

The loans are significantly seasoned with a weighted-average (WA)
age of 177 months. As of the Cut-off Date, 94.2% of the pool is
current, 4.5% is 30 days delinquent under the Mortgage Bankers
Association (MBA) delinquency method and 1.4% is in bankruptcy (all
bankruptcy loans are performing or 30 days delinquent).
Approximately 64.2% and 79.1% of the mortgage loans have been zero
times 30 days delinquent for the past 24 months and 12 months,
respectively, under the MBA delinquency method. The portfolio
contains 47.2% modified loans. The modifications happened more than
two years ago for 82.1% of the modified loans. The entire pool is
exempt from the Ability-to-Repay/Qualified Mortgage rules because
of seasoning.

The Seller, NRZ Sponsor IX LLC (NRZ), acquired the loans prior to
the Closing Date in connection with the termination of various
securitization trusts. Upon acquiring the loans, NRZ, through an
affiliate, New Residential Funding 2019-4 LLC, will contribute the
loans to the Trust. As the Sponsor, New Residential Investment
Corp., through a majority-owned affiliate, will acquire and retain
a 5% eligible vertical interest in each class of securities to be
issued (other than the residual notes) to satisfy the credit risk
retention requirements under Section 15G of the Securities Exchange
Act of 1934 and the regulations promulgated thereunder. These loans
were originated and previously serviced by various entities through
purchases in the secondary market.

As of the Cut-off Date, 61.0% of the pool is serviced by Nationstar
Mortgage LLC doing business as (d/b/a) Mr. Cooper Group, Inc.
(Nationstar), 36.1% by PHH Mortgage Corporation/Ocwen Loan
Servicing, 1.2% by NewRez, LLC d/b/a Shellpoint Mortgage Servicing,
0.9% by Select Portfolio Servicing, Inc. and 0.8% by Wells Fargo
Bank, N.A. (Wells Fargo; rated AA with a Stable trend by DBRS).
Nationstar will also act as the Master Servicer, and Shellpoint
Mortgage Servicing will act as the Special Servicer.

The Seller will have the option to repurchase any loan that becomes
60 or more days delinquent under the MBA method or any real
estate-owned property acquired in respect of a mortgage loan at a
price equal to the principal balance of the loan (Optional
Repurchase Price), provided that such repurchases will be limited
to 10% of the principal balance of the mortgage loans as of the
Cut-Off Date.

Unlike other seasoned re-performing loan securitizations, the
Servicer in this transaction will advance principal and interest on
delinquent mortgages to the extent that such advances are deemed to
be recoverable.

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

The ratings reflect transactional strengths that include underlying
assets with significant seasoning, relatively clean payment
histories and robust loan attributes with respect to credit scores,
product types and loan-to-value ratios. Additionally, NRMLT
securitizations have historically exhibited fast voluntary
prepayment rates.

The transaction employs a relatively weak representations and
warranties framework that includes an unrated representation
provider (NRZ), certain knowledge qualifiers and fewer mortgage
loan representations relative to DBRS criteria for seasoned pools.

Satisfactory third-party due diligence was performed on the pool
for regulatory compliance, title/lien and payment history. Updated
Home Data Index and/or broker price opinions were provided for the
pool; however, a reconciliation was not performed on the updated
values.

Certain loans have missing assignments or endorsements as of the
Closing Date. Given the relatively clean performance history of the
mortgages and the operational capability of the servicers, DBRS
believes that the risk of impeding or delaying foreclosure is
remote.

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


NEW RESIDENTIAL 2019-4: Moody's Assigns B1 Rating on Cl. B-7 Debt
-----------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to 32 classes
of notes issued by New Residential Mortgage Loan Trust 2019-4. The
NRMLT 2019-4 transaction is a $559 million securitization of 3,965
first lien, seasoned performing and re-performing fixed-rate
mortgage loans with weighted average seasoning of 176 months, a
weighted average updated LTV ratio of 52.2% and a non-zero weighted
average updated FICO score of 690. Based on the OTS methodology,
80.5% of the loans by scheduled balance have been continuously
current for the past 24 months. Approximately 47.2% of the loans in
the pool (by scheduled balance) have been previously modified.
Nationstar Mortgage LLC, PHH Mortgage Corporation, Shellpoint
Mortgage Servicing, Select Portfolio Servicing, Inc. and Wells
Fargo Bank, N.A. (Wells Fargo) will service approximately 61.0%,
36.1%, 1.2%, 0.9% and 0.8% of the loans (by scheduled balance),
respectively. Nationstar will act as master servicer and successor
servicer and Shellpoint will act as the special servicer.

The complete rating action is as follows:

Issuer: New Residential Mortgage Loan Trust 2019-4

Cl. A, Definitive Rating Assigned Aaa (sf)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Cl. B-5, Definitive Rating Assigned B2 (sf)

Cl. B-5A, Definitive Rating Assigned B2 (sf)

Cl. B-5B, Definitive Rating Assigned B2 (sf)

Cl. B-5C, Definitive Rating Assigned B2 (sf)

Cl. B-5D, Definitive Rating Assigned B2 (sf)

Cl. B-7, Definitive Rating Assigned B1 (sf)

RATINGS RATIONALE

Its losses on the collateral pool equal 4.30% in an expected
scenario and reach 21.30% at a stress level consistent with the Aaa
(sf) ratings on the senior classes. Moody's based its expected
losses for the pool on its estimates of (1) the default rate on the
remaining balance of the loans and (2) the principal recovery rate
on the defaulted balances. The final expected losses for the pool
reflect the third-party review (TPR) findings and its assessment of
the representations and warranties (R&Ws) framework for this
transaction. Also, the transaction contains a mortgage loan sale
provision, the exercise of which is subject to potential conflicts
of interest. As a result of this provision, Moody's increased its
expected losses for the pool.

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

Collateral Description

NRMLT 2019-4 is a securitization of 3,965 seasoned performing and
re-performing fixed-rate residential mortgage loans which the
seller, NRZ Sponsor IX LLC, has purchased in connection with the
termination of various securitization trusts. Similar to prior
NRMLT transactions Moody's has rated, nearly all of the collateral
was sourced from terminated securitizations. Approximately 47.2% of
the loans had previously been modified.

The updated value of properties in this pool were provided by a
third-party firm using a home data index (HDI) and/or an updated
broker price opinion (BPO). BPOs were provided for a sample of 622
out of the 3,143 properties contained within the securitization.
HDI values were provided for all but one property contained within
the securitization. The weighted average updated LTV ratio on the
collateral is 52.2%, implying an average of 47.8% borrower equity
in the properties.

Third-Party Review ("TPR") and Representations & Warranties
("R&W")

Two third-party due diligence providers, AMC and Recovco, conducted
a regulatory compliance review on a sample of 1,008 and 622
seasoned mortgage loans respectively for the initial due diligence
pool. The regulatory compliance review consisted of a review of
compliance with the federal Truth in Lending Act (TILA) as
implemented by Regulation Z, the federal Real Estate Settlement
Procedures Act (RESPA) as implemented by Regulation X, the
disclosure requirements and prohibitions of Section 50(a)(6),
Article XVI of the Texas Constitution, federal, state and local
anti-predatory regulations, federal and state specific late charge
and prepayment penalty regulations, and document review.

AMC found that 170 out of 1,008 loans had compliance exceptions
with rating agency grade C or D. Recovco reviewed 622 loans and
found that 76 loans have a rating of C or D.

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

AMC and Recovco reviewed the findings of various title search
reports covering 741 and 354 mortgage loans respectively in the
preliminary sample population in order to confirm the first lien
position of the related mortgages. Overall, AMC's review confirmed
that 739 mortgages were in first lien position. For the two
remaining loans reviewed by AMC, proof of first lien position could
only be confirmed using the final title policy as of loan
origination. Recovco reported that 354 of the mortgage loans it
reviewed were in first-lien position.

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

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

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

Nationstar, PHH Mortgage, Shellpoint, SPS and Wells Fargo will
service approximately 61.0%, 36.1%, 1.2%, 0.9% and 0.8% of the
loans by scheduled balance, respectively. Moody's considers the
overall servicing arrangement to be adequate.

Transaction Structure

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

Because a shifting interest structure allows subordinated bonds to
pay down over time as the loan pool shrinks, senior bonds are
exposed to tail risk, i.e., risk of back-ended losses when fewer
loans remain in the pool. The transaction provides for a senior and
subordination floor that helps to reduce this tail risk.
Specifically, the subordination floor prevents subordinate bonds
from receiving any principal if the amount of subordinate bonds
outstanding falls below 4.50% of the cut-off date principal
balance. There is also a provision that prevents subordinate bonds
from receiving principal if the credit enhancement for the Class
A-1 note falls below its percentage at closing, 25.50%. In
addition, there are provisions that "lock out" certain subordinate
bonds and allocate principal to more senior subordinate bonds if,
for a given class, credit enhancement levels decline below their
initial percentages or below 4.50% of the cut-off date principal
balance. These provisions have been incorporated into its cash flow
model and are reflected in its ratings

Other Considerations

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

When analyzing the transaction, Moody's reviewed the transaction's
exposure to large potential indemnification payments owed to
transaction parties due to potential lawsuits. In particular,
Moody's assessed the risk that the indenture trustee would be
subject to lawsuits from investors for a failure to adequately
enforce the R&Ws against the seller. Moody's believes that NRMLT
2019-4 is adequately protected against such risk primarily because
the loans in this transaction are highly seasoned with a weighted
average seasoning of approximately 176 months. Although some loans
in the pool were previously delinquent and modified, the loans all
have a substantial history of payment performance. This includes
payment performance during the last recession. As such, if loans in
the pool were materially defective, such issues would likely have
been discovered prior to the securitization. Furthermore, third
party due diligence was conducted on a significant random sample of
the loans for issues such as data integrity, compliance, and title.
As such, Moody's did not apply adjustments in this transaction to
account for indemnification payment risk.

In addition, prior to closing, the collateral pool has
approximately $1,091,768 of unreimbursed servicing advances such as
taxes and insurance. The mortgage borrower is responsible for
reimbursing the related servicer for the pre-existing servicing
advances. The related servicer may choose to set the pre-existing
advances as escrow to be repaid by the borrower as part of monthly
mortgage payments. However, in the event the borrower defaults on
the mortgage prior to fully repaying the pre-existing servicing
advances, the related servicer will recoup the outstanding amount
of pre-existing advances from the loan liquidation proceeds. The
amount of pre-existing servicing advances only represents
approximately 20 basis points of total pool balance. As borrowers
make monthly mortgage payments, this amount would likely decrease.
Moreover, its loan loss severity assumption incorporates
reimbursement of servicing advances from liquidation proceeds.

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

Up

Levels of credit protection that are higher than necessary to
protect investors against current expectations of loss could drive
the ratings up. Losses could decline from its original expectations
as a result of a lower number of obligor defaults or appreciation
in the value of the mortgaged property securing an obligor's
promise of payment. Transaction performance also depends greatly on
the US macro economy and housing market. Other reasons for
better-than-expected performance include changes to servicing
practices that enhance collections or refinancing opportunities
that result in prepayments.

Down

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

The methodologies used in these ratings were "Moody's Approach to
Rating Securitizations Backed by Non-Performing and Re-Performing
Loans" published in February 2019 and "US RMBS Surveillance
Methodology" published in February 2019.


OCTAGON INVESTMENT 43: Moody's Gives (P)Ba3 Rating on Class E Notes
-------------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to five
classes of notes to be issued by Octagon Investment Partners 43,
Ltd.

Moody's rating action is as follows:

  US$310,000,000 Class A-1 Senior Secured Floating Rate Notes due
  2032 (the "Class A-1 Notes"), Assigned (P)Aaa (sf)

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

  US$27,250,000 Class C Secured Deferrable Floating Rate Notes
  due 2032 (the "Class C Notes"), Assigned (P)A2 (sf)

  US$30,750,000 Class D Secured Deferrable Floating Rate Notes
  due 2032 (the "Class D Notes"), Assigned (P)Baa3 (sf)

  US$22,000,000 Class E Secured Deferrable Floating Rate Notes
  due 2032 (the "Class E Notes"), Assigned (P)Ba3 (sf)

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

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

RATINGS RATIONALE

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

Octagon 43 is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90.0% of the portfolio must consist of
first lien senior secured loans, cash, and eligible investments,
and up to 10.0% of the portfolio may consist of second lien loans
and unsecured loans. Moody's expects the portfolio to be
approximately 85% 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 will issue one class 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): 2775

Weighted Average Spread (WAS): 3.6%

Weighted Average Spread (WAC): 6.5%

Weighted Average Recovery Rate (WARR): 46%

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.


PIKES PEAK 4: Moody's Assigns Ba3 Rating on $18MM Class E Notes
---------------------------------------------------------------
Moody's Investors Service assigned ratings to five classes of notes
issued by Pikes Peak CLO 4.

Moody's rating action is as follows:

US$256,000,000 Class A Senior Secured Floating Rate Notes due 2032
(the "Class A Notes"), Assigned Aaa (sf)

US$43,200,000 Class B Senior Secured Floating Rate Notes due 2032
(the "Class B Notes"), Assigned Aa2 (sf)

US$21,200,000 Class C Mezzanine Secured Deferrable Floating Rate
Notes due 2032 (the "Class C Notes"), Assigned A2 (sf)

US$24,800,000 Class D Mezzanine Secured Deferrable Floating Rate
Notes due 2032 (the "Class D Notes"), Assigned Baa3 (sf)

US$18,800,000 Class E Junior Secured Deferrable Floating Rate Notes
due 2032 (the "Class E Notes"), Assigned Ba3 (sf)

The Class A Notes, the Class B 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.

Pikes Peak CLO 4 is a managed cash flow CLO. The issued notes will
be collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90.0% of the portfolio must consist of
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 may not consist of any collateral obligations
issued by obligors whose principal business is directly derived
from the production or marketing of controversial weapons
(including antipersonnel landmines, cluster weapons and chemical
weapons), the development of nuclear weapons programs or the
production of nuclear weapons or thermal coal. The portfolio is
approximately 60% ramped as of the closing date.

Partners Group US Management CLO 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 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): 2897

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 47.5%

Weighted Average Life (WAL): 9.0 years

Methodology Underlying the Rating Action:

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

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

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


PREFERREDPLUS TRUST CZN-1: Moody's Cuts $34.5MM Certs to Caa3
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of the following certificates issued by PREFERREDPLUS Trust
Series CZN-1:

  US$34,500,000 PREFERREDPLUS Trust Series CZN-1 Certificates,
  Downgraded to Caa3; previously on July 1, 2019 Downgraded
  to Caa2

RATINGS RATIONALE

The rating action is a result of the change in the rating of the
7.05% Debentures due October 01, 2046 issued by Frontier
Communications Corporation which was downgraded to Caa3 on August
12, 2019.

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

Methodology Underlying the Rating Action:

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

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

The ratings will be sensitive to any change in the rating of the
7.05% Debentures due October 01, 2046 issued by Frontier
Communications Corporation.


RAIT CRE I: Fitch Cuts Class D Debt Rating 'CCsf'
-------------------------------------------------
Fitch Ratings has upgraded one, affirmed four and downgraded three
classes of RAIT CRE CDO I Ltd.

RAIT CRE CDO I Ltd/LLC

                     Current Rating       Prior Rating
Class B 751020AC2   LT Bsf   Upgrade    previously at CCCsf
Class C 751020AD0   LT CCCsf Affirmed   previously at CCCsf
Class D 751020AE8   LT CCsf  Downgrade  previously at CCCsf
Class E 751020AF5   LT CCsf  Affirmed   previously at CCsf
Class F 751020AG3   LT CCsf  Affirmed   previously at CCsf
Class G 751020AH1   LT CCsf  Affirmed   previously at CCsf
Class H 751020AJ7   LT Csf   Downgrade  previously at CCsf
Class J 751020AL2   LT Csf   Downgrade  previously at CCsf

KEY RATING DRIVERS

The upgrade to class B reflects increased credit enhancement since
Fitch's last rating action. Although credit enhancement is high
relative to Fitch's loss expectations, the rating of class B was
capped at 'Bsf' due to pool and obligor concentrations, as well as
adverse selection of the remaining collateral.  Fitch designated
73.3% of the pool as Fitch Loans of Concern, including 23% that
have defaulted.

Further, class B is the most senior class and therefore requires
timely payment of interest. Based on the current interest coverage,
available interest and principal proceeds from the underlying
collateral are expected to be sufficient to cover the class'
ongoing interest obligation.

Since the last rating action, 10 loan interests were either paid in
full or disposed, with realized losses totalling nearly $80
million. Principal pay down over the same period was approximately
$45.7 million. Class J, which has negative credit enhancement,
continues to capitalize interest due to the failure of the F/G/H
overcollateralization and interest coverage tests.

The remaining pool consists of interests from approximately 18
different assets. As of the July 2019 trustee report and per Fitch
categorization, the CDO is substantially invested as follows: whole
loans/A-notes (69.1% of the pool), mezzanine debt (14.6%), and
preferred equity (16.3%). Many of the remaining loans have been
previously modified, including maturity extensions, since
origination. Further, RAIT affiliates now have ownership interests
in five of the CDO assets, totaling approximately $88.7 million
(56.4%). Fitch expects significant losses upon default for many of
these loan interests as they are considered overleveraged.

Fitch's base case loss expectation is 64.6%. Under Fitch's
methodology, 100% of the portfolio is modeled to default in the
base case stress scenario, defined as the 'B' stress. Modeled
recoveries are 35.4%.

The largest contributor to Fitch's base case loss expectation is a
whole loan (18.5% of the pool) secured by a neighborhood shopping
center located in Raritan, NJ, which was previously anchored by
Stop & Shop (47% of NRA) through 2017. Stop & Shop, which had been
in occupancy since 1987, decided to vacate at its lease expiration
due to local competition. Per the June 30, 2019 rent roll,
occupancy at the center is only 8.9%. The property has negative
cash flow and debt service is currently covered by the sponsorship,
which is a RAIT affiliate. A new anchor tenant is being pursued.
Fitch modeled a substantial loss in its base case scenario on this
loan.

The next largest contributor to Fitch's base case loss expectation
is a whole loan (16.6%) secured by three high end medical office
buildings totaling 151,299 sf located in Colorado Springs, CO,
approximately three miles northeast of the CBD. The property is
situated between the Penrose and Memorial Hospitals, two of the
three major hospitals in Colorado Springs. Per the June 30, 2019
rent rolls, the portfolio was 90.2% leased, with about 5% of the
NRA scheduled to roll over the next year. The largest tenant is
Colorado Springs Health Partners (CSHP; 56.7% of NRA), which has
lease expirations in October 2020 and February 2021. The sponsor is
reportedly in talks with CSHP regarding an early lease extension
and possible downsizing. Submarket conditions are weak. Per Reis
(2Q19), the Northwest office market has a vacancy rate of 32.7%
with asking rents of $18.47 psf. The average in place rent at the
subject is slightly below market at $17.22 psf. The sponsor is a
RAIT affiliate. Fitch's modeled loss in the base case is below the
average modeled loss for the pool on this whole loan.

This transaction was analyzed according to Fitch's "U.S. CREL CDO
Surveillance Criteria," which applies stresses to property cash
flows and DSCR tests to project future default levels for the
underlying portfolio. Recoveries are based on stressed cash flows
and Fitch's long-term capitalization rates. Cash flow modeling was
not performed as it was not expected to provide any additional
analytical value.

The 'CCCsf' and below ratings for classes C through J are based on
a deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern, factoring in anticipated
recoveries relative to each class's credit enhancement.

RAIT CRE CDO I is managed by RAIT Partnership, L.P., a subsidiary
of RAIT Financial Trust.

RATING SENSITIVITIES

A further upgrade to class B is not likely given the increasing
portfolio concentration, adverse selection, and significant
percentage of Fitch Loans of Concern. Classes C through J are
subject to downgrade should further losses be realized or should
classes default at or before maturity.


ROMARK CLO III: Moody's Assigns Ba3 Rating on $22.3MM Cl. D Notes
-----------------------------------------------------------------
Moody's Investors Service assigned ratings to five classes of notes
issued by Romark CLO - III Ltd.

Moody's rating action is as follows:

US$274,120,000 Class A-1 Senior Floating Rate Notes due 2032 (the
"Class A-1 Notes"), Assigned Aaa (sf)

US$46,750,000 Class A-2 Senior Floating Rate Notes due 2032 (the
"Class A-2 Notes"), Assigned Aa2 (sf)

US$19,330,000 Class B Deferrable Mezzanine Floating Rate Notes due
2032 (the "Class B Notes"), Assigned A2 (sf)

US$25,710,000 Class C Deferrable Mezzanine Floating Rate Notes due
2032 (the "Class C Notes"), Assigned Baa3 (sf)

US$22,310,000 Class D Deferrable Mezzanine Floating Rate Notes due
2032 (the "Class D Notes"), Assigned Ba3 (sf)

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

RATINGS RATIONALE

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

Romark CLO - III is a managed cash flow CLO. The issued notes will
be collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90.0% of the portfolio must consist of
first lien senior secured loans and eligible investments, and up to
10.0% of the portfolio may consist of second lien loans and
unsecured loans. The portfolio is approximately 70% ramped as of
the closing date.

Romark CLO Advisors 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 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: $425,000,000

Diversity Score: 70

Weighted Average Rating Factor (WARF): 2844

Weighted Average Spread (WAS): 3.30%

Weighted Average Coupon (WAC): 7.50%

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 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.


SDART 2019-3: Moody's Rates $95.880MM Class E Notes 'B1'
--------------------------------------------------------
Moody's Investors Service assigned definitive ratings to the notes
issued by Santander Drive Auto Receivables Trust 2019-3. This is
the third SDART auto loan transaction of the year for Santander
Consumer USA Inc. (SC; unrated). The notes are backed by a pool of
retail automobile loan contracts originated by SC, who is also the
servicer and administrator for the transaction.

The complete rating actions are as follows:

Issuer: Santander Drive Auto Receivables Trust 2019-3

  $194,000,000, 2.208%, Class A-1 Notes, Definitive Rating
  Assigned P-1 (sf)

  $160,000,000, 2.28%, Class A-2-A Notes, Definitive Rating
  Assigned Aaa (sf)

  $100,000,000, One Month Libor + 0.33%, Class A-2-B Notes,
  Definitive Rating Assigned Aaa (sf)

  $111,910,000, 2.16%, Class A-3 Notes, Definitive Rating
  Assigned Aaa (sf)

  $133,290,000, 2.28%, Class B Notes, Definitive Rating
  Assigned Aa1 (sf)

  $181,220,000, 2.49%, Class C Notes, Definitive Rating
  Assigned Aa2 (sf)

  $119,840,000, 2.68%, Class D Notes, Definitive Rating
  Assigned Baa1 (sf)

  $95,880,000, 3.64%, Class E Notes, Definitive Rating
  Assigned B1 (sf)

RATINGS RATIONALE

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

Moody's median cumulative net loss expectation for SDART 2019-3 is
15.0% and loss at a Aaa stress is 47.0%, both of which are the same
as the prior rated transaction, SDART 2019-2. Moody's based its
cumulative net loss expectation and loss at a Aaa stress on an
analysis of the credit quality of the underlying collateral; the
historical performance of similar collateral, including
securitization performance and managed portfolio performance; the
ability of SC to perform the servicing functions; and current
expectations for the macroeconomic environment during the life of
the transaction.

At closing the Class A notes, Class B notes, Class C notes, Class D
notes and Class E notes benefit from 52.60%, 41.20%, 25.70%, 15.45%
and 7.25% of hard credit enhancement, respectively. Hard credit
enhancement for the notes consists of a combination of
overcollateralization, a non-declining reserve account and
subordination, except from Class E, which does not have
subordination. The notes may also benefit from excess spread.

PRINCIPAL METHODOLOGY

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

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

Up

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

Down

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


SEQUOIA MORTGAGE 2019-3: Moody's Gives Ba3 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 2019-3. The certificates are backed by one pool of
prime quality, first-lien mortgage loans, including 128 agency high
balance mortgage loans. The assets of the trust consist of 504
fully amortizing, fixed-rate mortgage loans. The borrowers in the
pool have high FICO scores, significant equity in their properties
and liquid cash reserves. Nationstar Mortgage LLC will serve as the
master servicer for this transaction. There are four servicers for
this pool: Shellpoint Mortgage Servicing ("Shellpoint", 85.6% by
loan balance), First Republic Bank (13.5%), HomeStreet Bank (0.8%)
and TIAA, FSB (0.2%).

The complete rating actions are as follows:

Issuer: Sequoia Mortgage Trust 2019-3

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

RATINGS RATIONALE

Summary Credit Analysis

Moody's expected cumulative net loss on the aggregate pool is 0.35%
in a base scenario and reaches 4.30% at a stress level consistent
with the Aaa (sf) ratings. Its loss estimates are based on a
loan-by-loan assessment of the securitized collateral pool using
Moody's Individual Loan Level Analysis (MILAN) model. Loan-level
adjustments to the model included: adjustments to borrower
probability of default for higher and lower borrower DTIs,
borrowers with multiple mortgaged properties, self-employed
borrowers, origination channels and at a pool level, for the
default risk of HOA properties in super lien states. The adjustment
to its Aaa stress loss below the model output also includes
adjustments related to aggregation and origination quality. The
model combines loan-level characteristics with economic drivers to
determine the probability of default for each loan, and hence for
the portfolio as a whole. Severity is also calculated on a
loan-level basis. The pool loss level is then adjusted for
borrower, zip code, and MSA level concentrations.

Collateral Description

The SEMT 2019-3 transaction is a securitization of 504 first-lien
residential mortgage loans, with an aggregate unpaid principal
balance of $366,998,501. There are 90 originators in this pool with
United Shore Financial Services, LLC (United Shore, 14.4%) and
First Republic Bank (13.5%) being the largest. None of the
originators other than United Shore and First Republic Bank
contributed 10% or more of the principal balance of the loans in
the pool. There is approximately 6% of the pool by loan balance (33
loans) seasoned over 18-months with weighted average seasoning of
about four years, compared to 46% (318 loans) for SEMT 2019-2 with
similar average seasoning. Moody's analyzed these loans taking into
consideration borrower payment history, additional mortgages taken
by the borrower since origination of the first lien loans and
updated FICO scores to arrive at its loss levels.

Moody's received information on the total debt for the seasoned
loans post-origination with only 13 loans showing additional liens
after origination. However, given the amount of seasoned loans is
not substantial compared to previous transaction and given the
loans have been current for since origination Moody's did not make
any adjustment. Additionally, it should be noted that at some point
in time the junior lien loans may or may not have been paid in full
at the time of this transaction. Moody's did not receive updated
property values for 20 of the seasoned loans. Of note, Redwood will
provide representation and warranty that all mortgaged properties
are in substantially the same condition as it was at the time of
the appraisal. However, to account for the uncertainties of
property values for these seasoned loans Moody's made further
adjustment to its losses.

The loan-level third party due diligence review (TPR) encompassed
credit underwriting, property value and regulatory compliance. In
addition, Redwood will backstop the rep and warranty repurchase
obligation of all originators other than First Republic Bank. The
loans were all aggregated by Redwood Residential Acquisition
Corporation. Moody's considers Redwood, the mortgage loan seller,
to have strong aggregation and origination practices compared to
peers.

Borrowers of the mortgage loans backing this transaction have a
demonstrated ability to save and to manage credit. In addition, the
69% of the borrowers in the pool have more than 24 months of liquid
cash reserves or enough money to pay the mortgage for two years
should there be an interruption to the borrower's cash flow.
Consistent with prudent credit management, the borrowers have high
FICO scores with a weighted average score of 769. In general, the
borrowers have high income, significant liquid assets and a stable
employment history, all of which have been verified as part of the
underwriting process and reviewed by the TPR firms. Borrowers also
have significant equity in their homes (WA original CLTV 70.8%)
consistent with recent SEMT transactions.

Approximately, 5.4% of the mortgage loans by aggregate stated
principal balance are secured by mortgaged properties located in
the areas that the Federal Emergency Management Agency (FEMA) had
designated for federal assistance during the prior 12 months.
Redwood has engaged a third party to inspect these properties. No
material visible damage was detected from the inspection and the
related mortgage was included in the transaction pool.
Representations and warranties as to the mortgage loans will have
been made to the effect that in general, the mortgage loans will be
free of material damage as of the closing date.

Structural considerations

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

Moody's believes there is a low likelihood that the rated
securities of SEMT 2019-3 will incur any losses from extraordinary
expenses or indemnification payments owing to potential future
lawsuits against key deal parties. First, the loans are of prime
quality and were originated under a regulatory environment that
requires tighter controls for originations than pre-crisis, which
reduces the likelihood that the loans have defects that could form
the basis of a lawsuit. Second, Redwood, who initially retains the
subordinate classes and provides a back-stop to the representations
and warranties of all the originators except for First Republic
Bank, has a strong alignment of interest with investors, and is
incentivized to actively manage the pool to optimize performance.
Third, historical performance of loans aggregated by Redwood has
been very strong to date. Fourth, the transaction has reasonably
well defined processes in place to identify loans with defects on
an ongoing basis. In this transaction, an independent breach
reviewer must review loans for breaches of representations and
warranties when a loan becomes 120 days delinquent, which reduces
the likelihood that parties will be sued for inaction.

Tail Risk & Subordination Floor

The transaction cash flows follow a shifting interest structure
that allows subordinated bonds to receive principal payments under
certain defined scenarios. Because a shifting interest structure
allows subordinated bonds to pay down over time as the loan pool
shrinks, senior bonds are exposed to increased performance
volatility, known as tail risk. The transaction provides for a
subordination floor of 1.85% 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

Three TPR firms conducted a due diligence review of nearly 100% of
the mortgage loans in the pool. Generally, the TPR firms conducted
a review for credit, property valuation, compliance and data
integrity ("full review loans"). The TPR firms randomly selected 65
mortgage loans for limited review that were originated by First
Republic Bank and PrimeLending, A Plainscapital Company.

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

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

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

After a review of the TPR appraisal findings, Moody's notes that
there are two loans with final grade 'D' due to escrow holdback
distribution amounts. The review for these loans was incomplete
because the related appraisals were subject to the completion of
renovation work or missing evidence of disbursement of escrow
funds. In the event the escrow funds greater than 10% have not been
disbursed within six months of the closing date, the seller shall
repurchase the affected escrow holdback mortgage loan, on or before
the date that is six months after the closing date at the
applicable repurchase price. There are three other loans with final
grade 'C' due to compliance related issues. One such mortgage loan
was related to escrow holdback. The other mortgage loans were
identified as having TRID related waiver as the total fee amount
exceeded the tolerance limit and borrower not receiving the initial
CD three days prior to consummation. Moody's did not make any
adjustment to the losses, as the seller has taken steps to
remediate both issues and Moody's deems these issues to be not
significant.

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

In line with other SEMT transactions, the loan-level R&Ws for SEMT
2019-3 are strong and, in general, either meet or exceed the
baseline set of credit-neutral R&Ws Moody's identified for US
RMBS.

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

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

Trustee & Master Servicer

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

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

Down

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

Up

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


SLM STUDENT 2012-1: Fitch Lowers Ratings on 2 Tranches to Bsf
-------------------------------------------------------------
Fitch Ratings has downgraded the ratings on all outstanding classes
of SLM Student Loan Trust 2012-1. The Rating Outlooks remain
Stable.

Fitch downgraded the class A-3 notes to 'Bsf' from 'BBsf' due to
the increased margin by which these classes miss their legal final
maturity date under Fitch's base case scenarios for cash flow
modeling. The weighted average remaining term has increased by
approximately seven months over the past year.

Fitch also downgraded the class B notes to 'Bsf' from 'BBsf', as
the rating on these notes are constrained by the ratings of the
class A-3 notes, per Fitch's criteria, because they can be affected
as a result of actions investors may take post an event of default
on the class A-3 notes.

All the notes are rated 'Bsf', supported by qualitative factors
such as Navient's ability to call the notes upon reaching 10% pool
factor and the revolving credit agreement established by Navient.
The trust has entered into a revolving credit agreement with
Navient by which it may borrow funds at maturity in order to pay
off the notes. Because Navient has the option but not the
obligation to lend to the trust, Fitch does not give quantitative
credit to this agreement. However, the agreement does provide
qualitative comfort that Navient is committed to limiting
investors' exposure to maturity risk.

SLM Student Loan Trust 2012-1
   
  Class A-3 78446WAC1; LT Bsf Downgrade; previously at BBsf

  Class B 78446WAD9;   LT Bsf Downgrade; previously at BBsf

KEY RATING DRIVERS

U.S. Sovereign Risk: The trust 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'/Outlook Stable.

Collateral Performance: Based on transaction-specific performance
to date, Fitch assumes a base case cumulative default rate of
24.50% and a 73.50% default rate under the 'AAA' credit stress
scenario. Fitch is maintaining a sustainable constant default rate
of 4.0% and revising the sustainable constant prepayment rate
(voluntary and involuntary) to 11.00% from 12.50% to conduct 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 levels of deferment, forbearance, and
income-based repayment (prior to adjustment) are 8.55%, 16.46% and
24.07%, 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
0.04%, based on information provided by the sponsor.

Fitch's student loan ABS cash flow model indicates that the class
A-3 notes fail to be paid in full by their maturity dates in
Fitch's base cases. If the breach of the class A-3 maturity date
triggers an event of default, interest payments will be diverted
away from the class B notes, causing them to fail the base case
stresses as well.

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 June 2019, approximately 99.94% of the student
loans are indexed to LIBOR, and 0.06% are indexed to T-Bill. 100%
of the notes are indexed to one-month LIBOR. Fitch applies its
standard basis and interest rate stresses to this transaction, as
per criteria.

Payment Structure: Credit enhancement (CE) is provided by excess
spread, overcollateralization, and for the class A notes,
subordination. As of June 2019, Fitch senior and total effective
parity ratios (including the reserve) are 110.60% (9.58% CE) and
101.29% (1.27% CE), respectively. Liquidity support is provided by
a reserve account currently sized at its floor of $764,728.

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 'CCCsf'; class B 'CCCsf';

  -- Default increase 50%: class A 'CCCsf'; class B 'CCCsf';

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

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

Maturity Stress Rating Sensitivity

  -- CPR decrease 25%: class A 'CCCsf'; class B 'CCCsf';

  -- CPR decrease 50%: class A 'CCCsf'; class B 'CCCsf';

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

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

  -- 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 XIV: Moody's Affirms Ba3 Rating on $35MM Cl. E Notes
----------------------------------------------------------------
Moody's Investors Service assigned a rating to one class of CLO
refinancing notes issued by Sound Point CLO XIV, Ltd.

Moody's rating action is as follows:

  US$451,500,000 Class A-R Senior Secured Floating Rate Notes due
  2029 (the "Class A-R Notes"), Assigned Aaa (sf)

Additionally, Moody's has taken rating actions on the following
outstanding notes originally issued by the Issuer on November 17,
2016 (the "Original Closing Date"):

  US$55,500,000 Class B-1 Senior Secured Floating Rate Notes due
  2029 (the "Class B-1 Notes"), Affirmed Aa2 (sf); previously
  on November 17, 2016 Definitive Rating Assigned Aa2 (sf)

  US$25,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2029
  (the "Class B-2 Notes"), Affirmed Aa2 (sf); previously on
  November 17, 2016 Definitive Rating Assigned Aa2 (sf)

  US$42,000,000 Class C Mezzanine Secured Deferrable Floating
  Rate Notes due 2029 (the "Class C Notes"), Affirmed A2 (sf);
  previously on November 17, 2016 Definitive Rating Assigned
  A2 (sf)

  US$35,000,000 Class D Mezzanine Secured Deferrable Floating
  Rate Notes due 2029 (the "Class D Notes"), Affirmed Baa3 (sf);
  previously on November 17, 2016 Definitive Rating Assigned
  Baa3 (sf)

  US$35,000,000 Class E Junior Secured Deferrable Floating Rate
  Notes due 2029 (the "Class E Notes"), Affirmed Ba3 (sf);
  previously on November 17, 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. Additionally, the rating actions on
the Class B-1, Class B-2, Class C, Class D and Class E Notes are
supported by the refinancing, which increases excess spread
available as credit enhancement to the 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
92.5% of the portfolio must consist of first lien senior secured
loans, cash, and eligible investments, and up to 7.5% of the
portfolio may consist of second liens loans and unsecured loans.

Sound Point Capital Management, LP will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's remaining 1.4 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 August 19, 2019 in
connection with the refinancing of one class of secured notes
originally issued on the Original Closing Date. 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 five classes
of secured notes and one class of subordinated notes that remain
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 non-call period for
the Class A-R Notes.

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: $698,530,000

Defaulted par: $1,470,000

Diversity Score: 73

Weighted Average Rating Factor (WARF): 2838 (corresponding to a
weighted average default probability of 22.18%)

Weighted Average Spread (WAS): 3.71%

Weighted Average Recovery Rate (WARR): 47.18%

Weighted Average Life (WAL): 5.25 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.


SOUTHWICK PARK: S&P Assigns BB- (sf) Rating on Class E Notes
------------------------------------------------------------
S&P Global Ratings assigned its ratings to Southwick Park CLO
Ltd./Southwick Park CLO LLC's fixed- and floating-rate notes.

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

The ratings reflect:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  Southwick Park CLO Ltd./Southwick Park CLO LLC
  Class                Rating    Amount (mil. $)
  A-1                  NR                 320.00
  A-2                  AAA (sf)            10.00
  B-1                  AA (sf)             28.75
  B-2                  AA (sf)             20.00
  C (deferrable)       A (sf)              29.75
  D (deferrable)       BBB- (sf)           30.00
  E (deferrable)       BB- (sf)            21.50
  Subordinated notes   NR                  43.45

  NR--Not rated.



STRUCTURED AGENCY 2017-HRP1: Fitch Ups Rating on 7 Tranches to BB+
------------------------------------------------------------------
Fitch Ratings has taken various rating actions on 48 classes from
four private label and agency Credit Risk Transfer transactions
issued in 2017 and 2018. These include two Government Sponsored
Enterprise CRT transactions, one private label CRT transaction and
one private label Mortgage Insurance CRT transaction. Fitch has
affirmed 41 and upgraded seven classes.  After the review, 37
classes have a Positive Outlook, reflecting an increased likelihood
of upgrades in the near future.

Structured Agency Credit Risk Debt Notes, Series 2017-HRP1

                        Current Rating       Prior Rating
Class M-2 3137G0SN0     LT Bsf    Affirmed   previously at Bsf
Class M-2A 3137G0SF7    LT BB+sf  Upgrade    previously at BBsf
Class M-2AD 3137G0SH3   LT BB+sf  Upgrade    previously at BBsf
Class M-2AI 3137G0SZ3   LT BB+sf  Upgrade    previously at BBsf
Class M-2AR 3137G0SV2   LT BB+sf  Upgrade    previously at BBsf
Class M-2AS 3137G0SW0   LT BB+sf  Upgrade    previously at BBsf
Class M-2AT 3137G0SX8   LT BB+sf  Upgrade    previously at BBsf
Class M-2AU 3137G0SY6   LT BB+sf  Upgrade    previously at BBsf
Class M-2B 3137G0SG5    LT Bsf    Affirmed   previously at Bsf
Class M-2BD 3137G0SJ9   LT Bsf    Affirmed   previously at Bsf
Class M-2BI 3137G0TE9   LT Bsf    Affirmed   previously at Bsf
Class M-2BR 3137G0TA7   LT Bsf    Affirmed   previously at Bsf
Class M-2BS 3137G0TB5   LT Bsf    Affirmed   previously at Bsf
Class M-2BT 3137G0TC3   LT Bsf    Affirmed   previously at Bsf
Class M-2BU 3137G0TD1   LT Bsf    Affirmed   previously at Bsf
Class M-2D 3137G0ST7    LT Bsf    Affirmed   previously at Bsf
Class M-2I 3137G0SU4    LT Bsf    Affirmed   previously at Bsf
Class M-2R 3137G0SP5    LT Bsf    Affirmed   previously at Bsf
Class M-2S 3137G0SQ3    LT Bsf    Affirmed   previously at Bsf
Class M-2T 3137G0SR1    LT Bsf    Affirmed   previously at Bsf
Class M-2U 3137G0SS9    LT Bsf    Affirmed   previously at Bsf

L Street Securities, Series 2017-PM1
   
Class M-1 693458AC5    LT BBBsf   Affirmed   previously at BBBsf
Class M-2 693458AD3    LT Bsf     Affirmed   previously at Bsf
Class M-2A 693458AH4   LT BBB-sf  Affirmed   previously at BBB-sf
Class M-2B 693458AJ0   LT BBsf    Affirmed   previously at BBsf
Class M-2C 693458AK7   LT Bsf     Affirmed   previously at Bsf

Bellemeade Re 2018-2 Ltd.
   
Class B-1 07877DAD8    LT BBBsf   Affirmed   previously at BBBsf
Class M-1A 07877DAA4   LT A+sf    Affirmed   previously at A+sf
Class M-1B 07877DAB2   LT A-sf    Affirmed   previously at A-sf
Class M-1C 07877DAC0   LT BBBsf   Affirmed   previously at BBBsf

Structured Agency Credit Risk Trust 2018-HRP1
   
Class M-2 3137G0VC0    LT BB-sf   Affirmed   previously at BB-sf
Class M-2A 3137G0UY3   LT BB+sf   Affirmed   previously at BB+sf
Class M-2AI 3137G0VN6  LT BB+sf   Affirmed   previously at BB+sf
Class M-2AR 3137G0VJ5  LT BB+sf   Affirmed   previously at BB+sf
Class M-2AS 3137G0VK2  LT BB+sf   Affirmed   previously at BB+sf
Class M-2AT 3137G0VL0  LT BB+sf   Affirmed   previously at BB+sf
Class M-2AU 3137G0VM8  LT BB+sf   Affirmed   previously at BB+sf
Class M-2B 3137G0UZ0   LT BB-sf   Affirmed   previously at BB-sf
Class M-2BI 3137G0VT3  LT BB-sf   Affirmed   previously at BB-sf
Class M-2BR 3137G0VP1  LT BB-sf   Affirmed   previously at BB-sf
Class M-2BS 3137G0VQ9  LT BB-sf   Affirmed   previously at BB-sf
Class M-2BT 3137G0VR7  LT BB-sf   Affirmed   previously at BB-sf
Class M-2BU 3137G0VS5  LT BB-sf   Affirmed   previously at BB-sf
Class M-2I 3137G0VH9   LT BB-sf   Affirmed   previously at BB-sf
Class M-2R 3137G0VD8   LT BB-sf   Affirmed   previously at BB-sf
Class M-2S 3137G0VE6   LT BB-sf   Affirmed   previously at BB-sf
Class M-2T 3137G0VF3   LT BB-sf   Affirmed   previously at BB-sf
Class M-2U 3137G0VG1   LT BB-sf   Affirmed   previously at BB-sf

KEY RATING DRIVERS

The four transactions reviewed were Freddie Mac Structured Agency
Credit Risk (STACR) 2017-HRP1 and 2018-HRP1, L Street Securities
2017-PM1 (PennyMac), and Bellemeade 2018-2 (Arch).

The two STACR HARP transactions were last reviewed in January 2019.
This is the first surveillance review of the PennyMac and Arch
deals since their initial rating in 2018 less than one year ago.

The seven upgraded classes in STACR 2017-HRP1 reflect continued
improvements in the relationship of credit enhancement (CE) to
expected pool loss since the prior rating review in January 2019.

Strong Asset Performance (Positive): Asset performance has been
generally better than initial expectations to date. Serious
delinquency is less than 70 bps of the outstanding transaction
balance for all deals in this review.  The loss to date remains at
less than 3 bps for the two STACR HARP transactions, less than 14
bps for the L Street transaction, and less than 1 bp for the
Bellemeade transaction.

Deleveraging (Positive):   As the bonds delever over time due to
principal distributions, the relationship between CE and expected
loss generally improves.  The top rated bond for the two STACR HARP
transactions have gained roughly 26 bps of CE on average since
their last review in January 2019.  The top rated bond for the L
Street and Bellemeade transactions have gained 13 bps and 156 bps
of CE respectively since their initial rating.  All of the
transactions in this review follow a straight sequential pay
structure among the subordinate bonds.  

The rating committee deviated from the model proposed ratings for
certain classes in STACR 2017-HRP1 and for Bellemeade 2018-2.  For
STACR 2017-HRP1, the senior classes were upgraded one rating tick
instead of affirmed due to the close proximity to a rating
threshold to receive an upgrade.  For Bellemeade 2018-2, the top
two classes were affirmed rather than upgraded due to a pending
criteria change that is expected to result in an affirmation of the
classes at their current rating. The pending criteria change is
described in the exposure draft of the "U.S. RMBS Loan Loss Model"
and is expected to reduce the seasoning benefit for loans
originated after 2010.  Even with the more conservative criteria,
the Bellemeade 2018-2 classes are experiencing positive rating
pressure and were assigned a Positive Outlook.

RATING SENSITIVITIES

Fitch's analysis includes rating stress scenarios from 'CCCsf' to
'AAAsf'. The 'CCCsf' scenario is intended to be the most-likely
base-case scenario. Rating scenarios above 'CCCsf' are increasingly
more stressful and less likely to occur. Although many variables
are adjusted in the stress scenarios, the primary driver of the
loss scenarios is the home price forecast assumption. In the 'Bsf'
scenario, Fitch assumes home prices decline 10% below their
long-term sustainable level. The home price decline assumption is
increased by 5% at each higher rating category up to a 35% decline
in the 'AAAsf' scenario.

The ratings of bonds currently rated 'Bsf' or higher will be
sensitive to future mortgage borrower behavior, which historically
has been strongly correlated with home price movements. Despite
recent positive trends, Fitch currently expects home prices to
decline in some regions before reaching a sustainable level. While
Fitch's ratings reflect this home price view, the ratings of
outstanding classes may be subject to revision to the extent actual
home price and mortgage performance trends differ from those
currently projected by Fitch.

Additionally, because of the counterparty dependence on Freddie Mac
for the HARP transactions, Fitch's rating on the notes could be
affected by the Issuer Default Rating (IDR) if the IDR was to fall
below the credit rating implied by the relationship of CE to
expected reference mortgage pool loss. The L Street and Bellemeade
transaction are also subject to counterparty dependency as the
ratings on those notes are ultimately limited by the IDR of the
banks in which the cash collateral accounts are held.

CRITERIA VARIATION

This review includes a criteria variation that relates to the "U.S.
RMBS Rating Criteria" for the L Street and Bellemeade deals. The
cash flow analysis described in Fitch's "U.S. RMBS Rating Criteria"
was not applied to these transactions, which is a criteria
variation as the "U.S RMBS Rating Criteria" requires a cash flow
analysis for all deals except CRT transactions issued by one of the
GSEs. The cash flow analysis described in the criteria does not
influence the rating decision for this type of structure since
principal payments to the rated bonds are made in a sequential
priority for the life of the transaction. In addition, for this
transaction, interest is paid by the issuer through premium
coverage amounts from the ceding insurer.

CUSTOMIZED MODEL

This review includes a model variation for the "U.S. RMBS Loan Loss
Model".  The variation is to add back in a seasoning credit for
loans originated post 2010 that was removed in the most recent
version of the model as described in the exposure draft.
Surveillance reviews are required to be analysed under the current
production version which includes the seasoning credit.


STWD LTD 2019-FL1: DBRS Finalizes B(low) Rating on Class G Notes
----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of Floating-Rate Notes, Series 2019-FL1 issued by STWD
2019-FL1, Ltd.:

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

All trends are Stable.

The initial collateral consists of 20 floating-rate mortgages and
one fixed-rate mortgage secured by 38 mostly transitional
properties, with a cut-off balance totaling $1.1 billion, excluding
approximately $116 million of future funding commitments. Most
loans are in a period of transition with plans to stabilize and
improve asset value. During the Reinvestment Period, the Issuer may
acquire future funding commitments and additional eligible loans
subject to the Eligibility Criteria. The transaction stipulates a
$5 million threshold on pari passu participation acquisitions
before a rating agency confirmation is required if there is already
participation of the underlying loan in the trust.

For the floating-rate loans, DBRS used the one-month LIBOR index,
which is based on the lower of a DBRS stressed rate that
corresponded to the remaining fully extended term of the loans or
the strike price of the interest rate cap with the respective
contractual loan spread added to determine a stressed interest rate
over the loan term. When the cut-off balances were measured against
the DBRS As-Is net cash flow (NCF), nine loans, comprising 37.7% of
the initial pool, had a DBRS As-Is debt service coverage ratio
(DSCR) below 1.00 times (x), a threshold indicative of default
risk. Additionally, the DBRS Stabilized DSCR for two loans,
comprising 6.5% of the initial pool balance, are below 1.00x, which
is indicative of elevated refinance risk. The properties are often
transitioning with potential upside in cash flow; however, DBRS
does not give full credit to the stabilization if there are no
holdbacks or if other loan structural features in place are
insufficient to support such treatment. Furthermore, even with the
structure provided, DBRS generally does not assume the assets to
stabilize above market levels. The transaction has a sequential-pay
structure.

The loans are generally secured by traditional property types
(i.e., retail, multifamily, office, and hotel). Additionally, none
of the multifamily loans in the pool is currently secured by a
student housing property, which often exhibits higher cash flow
volatility than traditional multifamily properties. The properties
are primarily located in core markets with the overall pool's
weighted-average (WA) DBRS Market Rank at a very high 5.4. Five
loans, totaling 32.5% of the pool, are in markets with a DBRS
Market Rank of 7, and another two are within markets with a Market
Rank of 6, totaling 16.4% of the pool. These higher DBRS Market
Ranks correspond to zip codes that are more urbanized in nature.
As-measured including all future funding in the calculation, the WA
As-Is loan-to-value (LTV) is low at 76.8%. Further, the WA
As-Stabilized LTV is also quite low at 65.3%. The WA As-Is LTV and
the WA As-Stabilized LTV reflect downward as-is and stabilized
value adjustments made to three loans by DBRS. Please see the model
adjustment section in the related report for more on the
above-mentioned adjustments. Nine loans in the pool, totaling 65.3%
of the DBRS sample by cut-off date pool balance, are backed by a
property with a quality deemed to be Average (+) by DBRS. The
borrowers of all 20 floating-rate loans have purchased LIBOR rate
caps that have a range of between 2.5% up to 3.5% to protect
against rising interest rates over the term of the loan. The Class
F Notes, Class G Notes, and Preferred Shares will be retained by
STWD CLO Retention Holder, LLC, and an affiliate of the trust asset
seller. The Class F Notes, Class G Notes, and Preferred Shares
represent 14.9% of the transaction balance.

The pool consists of mostly transitional assets. Given the nature
of the assets, DBRS determined a sample size, representing 81.0% of
the pool cut-off date balance. This is higher than the typical
sample size for traditional conduit CMBS transactions. Physical
site inspections were also performed, including management
meetings. DBRS also notes that when DBRS analysts are visiting the
markets, they may actually visit properties more than once to
follow the progress (or lack thereof) toward stabilization. The
service is also in constant contact with the borrowers to track
progress.

Twenty loans, comprising 91.0% of the cut-off date pool balance,
have floating interest rates, and the aforementioned loans are
interest-only during the original term and have original term
ranges from 15 months to 60 months, creating interest rate risk. Of
the floating-interest rate loans, 73.1% are short-term loans, and
even with extension options, they have a fully extended maximum
loan term of five years. Additionally, for the floating-rate loans,
DBRS used the one-month LIBOR index, which is based on the lower of
a DBRS stressed rate that corresponded to the remaining fully
extended term of the loans or the strike price of the interest rate
cap with the respective contractual loan spread added to determine
a stressed interest rate over the loan term. The floating-rate
loans have extension options, and in order to qualify for these
options, the loans must meet minimum DSCR and LTV requirements.

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

Thirteen loans, totaling only 67.5% of the initial pool balance,
represent refinance financing. The refinance financings within this
securitization generally do not require the respective sponsor(s)
to contribute material cash equity as a source of funding in
conjunction with the mortgage loan, resulting in a lower sponsor
cost basis in the underlying collateral. Of the 20 refinance loans,
four loans representing 26.1% of the pool have a current occupancy
of less than 80.0%, and four of the refinance loans account for
$67.5 million of the $116 million of future funding (58.2%). This
suggests that at least half of the refinance loans are near
stabilization, which would partially mitigate the higher risk
associated with a sponsor's lower cost basis.

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


VOYA CLO 2016-2: Moody's Rates $16.4MM Class D-R Notes 'Ba3'
------------------------------------------------------------
Moody's Investors Service assigned ratings to five classes of
refinancing notes issued by Voya CLO 2016-2, Ltd.

Moody's rating action is as follows:

  US$259,000,000 Class A-1-R Floating Rate Notes due 2028 (the
  "Class A-1-R Notes"), Assigned Aaa (sf)

  US$45,900,000 Class A-2-R Floating Rate Notes due 2028 (the
  "Class A-2-R Notes"), Assigned Aa2 (sf)

  US$25,600,000 Class B-R Deferrable Floating Rate Notes due
  2028 (the "Class B-R Notes"), Assigned A2 (sf)

  US$21,200,000 Class C-R Deferrable Floating Rate Notes due
  2028 (the "Class C-R Notes"), Assigned Baa3 (sf)

  US$16,400,000 Class D-R Deferrable Floating Rate Notes due
  2028 (the "Class D-R Notes"), Assigned Ba3 (sf)

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

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 first lien senior secured
loans and eligible investments, and up to 10.0% of the portfolio
may consist of second liens loans and unsecured loans.

Voya Alternative Asset Management LLC will direct the selection,
acquisition and disposition of the assets on behalf of the Issuer
and may engage in trading activity, including discretionary
trading, during the transaction's 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 has issued the Refinancing Notes on August 16, 2019 in
connection with the refinancing of all classes of secured notes and
one class of combination securities originally issued on July 19,
2016. On the Refinancing Date, the Issuer used the proceeds from
the issuance of the Refinancing Notes to redeem in full the
Refinanced Original Notes. On the Original Closing Date, the issuer
also issued one class of 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 weighted average
life test and the non-call period, as well as 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 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:

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

Performing par and principal proceeds balance: $399,133,898

Defaulted par: $187,180

Diversity Score: 90

Weighted Average Rating Factor (WARF): 2890 (corresponding to a
weighted average default probability of 25.6%)

Weighted Average Spread (WAS): 3.30%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 47.80%

Weighted Average Life (WAL): 7.00 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.


WELLFLEET CLO 2019-1: Moody's Rates $21.5MM Class D Notes 'Ba3'
---------------------------------------------------------------
Moody's Investors Service assigned ratings to seven classes of
notes issued by Wellfleet CLO 2019-1, Ltd.

Moody's rating action is as follows:

US$256,000,000 Class A-1 Senior Secured Floating Rate Notes due
2032 (the "Class A-1 Notes"), Assigned Aaa (sf)

US$5,000,000 Class A-2A Senior Secured Floating Rate Notes due 2032
(the "Class A-2A Notes"), Assigned Aa2 (sf)

US$43,000,000 Class A-2B Senior Secured Floating Rate Notes due
2032 (the "Class A-2B Notes"), Assigned Aa2 (sf)

US$18,000,000 Class B Mezzanine Secured Deferrable Floating Rate
Notes due 2032 (the "Class B Notes"), Assigned A2 (sf)

US$19,500,000 Class C-1 Mezzanine Secured Deferrable Floating Rate
Notes due 2032 (the "Class C-1 Notes"), Assigned Baa3 (sf)

US$5,000,000 Class C-2 Mezzanine Secured Deferrable Fixed Rate
Notes due 2032 (the "Class C-2 Notes"), Assigned Baa3 (sf)

US$21,500,000 Class D Junior Secured Deferrable Floating Rate Notes
due 2032 (the "Class D Notes"), Assigned Ba3 (sf)

The Class A-1 Notes, the Class A-2A Notes, the Class A-2B Notes,
the Class B Notes, the Class C-1 Notes, the Class C-2 Notes and the
Class D 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.

Wellfleet 2019-1 is a managed cash flow CLO. The issued notes will
be collateralized primarily by broadly syndicated senior secured
corporate loans. At least 92.5% of the portfolio must consist of
senior secured loans and eligible investments, and up to 7.5% of
the portfolio may consist of second lien loans and senior unsecured
loans. The portfolio is approximately 95% ramped as of the closing
date.

Wellfleet 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 subordinated
notes and combination 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: 70

Weighted Average Rating Factor (WARF): 2835

Weighted Average Spread (WAS): 3.5%

Weighted Average Coupon (WAC): 7.0%

Weighted Average Recovery Rate (WARR): 47%

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.


WELLS FARGO 2015-NXS4: Fitch Affirms B-sf Rating on 2 Tranches
--------------------------------------------------------------
Fitch Ratings has affirmed 18 classes of Wells Fargo Commercial
Mortgage Trust Pass-Through Certificates series 2015-NXS4.

WFCM 2015-NXS4

                       Current Rating        Prior Rating
Class A-1 94989XAY1   LT AAAsf  Affirmed   previously at AAAsf
Class A-2A 94989XAZ8  LT AAAsf  Affirmed   previously at AAAsf
Class A-2B 94989XBA2  LT AAAsf  Affirmed   previously at AAAsf
Class A-3 94989XBB0   LT AAAsf  Affirmed   previously at AAAsf
Class A-4 94989XBC8   LT AAAsf  Affirmed   previously at AAAsf
Class A-S 94989XBE4   LT AAAsf  Affirmed   previously at AAAsf
Class A-SB 94989XBD6  LT AAAsf  Affirmed   previously at AAAsf
Class B 94989XBH7     LT AA-sf  Affirmed   previously at AA-sf
Class C 94989XBJ3     LT A-sf   Affirmed   previously at A-sf
Class D 94989XBL8     LT BBBsf  Affirmed   previously at BBBsf
Class E 94989XAL9     LT BBB-sf Affirmed   previously at BBB-s
Class F 94989XAN5     LT BB-sf  Affirmed   previously at BB-sf
Class G 94989XAQ8     LT B-sf   Affirmed   previously at B-sf
Class X-A 94989XBF1   LT AAAsf  Affirmed   previously at AAAsf
Class X-B 94989XBG9   LT AA-sf  Affirmed   previously at AA-sf
Class X-D 94989XBK0   LT BBB-sf Affirmed   previously at BBB-sf
Class X-F 94989XAA3   LT BB-sf  Affirmed   previously at BB-sf
Class X-G 94989XAC9   LT B-sf   Affirmed   previously at B-sf

KEY RATING DRIVERS

Increased Loss Expectations: Overall, the pool continues to exhibit
generally stable performance; however, since the prior rating
action, three loans (3.78% of the pool's balance) have transferred
to special servicing, bringing the total number of specially
serviced loans to four (4.51% of the pool's balance). Inclusive of
the specially serviced loans, there are now seven (15.79% of the
pool's balance) Fitch Loans of Concern (FLOCs), which are the major
contributors for the increase in loss expectations.

The largest FLOC is the One Court Square loan (9.24%). The loan is
collateralized by a single-tenant office property located in Long
Island City, NY. Citibank currently leases all 1.4 million sf of
space in the building; however, Citi will be reducing their
footprint by 1 million-sf (70% of net rentable area [NRA]) at
lease-end in May of 2020, months before the loan matures in
September. While Citibank will be reducing its footprint, the
property has exhibited positive leasing momentum. Earlier this
year, Centene Corporation signed a lease for 331,912 sf of space
with an option for 134,068 sf in additional space. The rent and
delivery of the space occurred in July 2019. In addition, Altice, a
telecommunications company, signed a lease for 103,133 sf for 12
years, beginning in May 2020. There is also an option that allows
Altice to lease three additional floors (approximately 30,000 sf
per floor). Moreover, the servicer reports that the borrower has
indicated that it is planning to refinance the loan in the fourth
quarter of 2019.

The second largest FLOC is the Somerset Park loan (2.71%), which is
secured by a 206,829 sf suburban office property located in
Raleigh, NC. At issuance, it was noted that 100% of the in-place
NRA was scheduled to roll during the loan term, with the largest
concentration occurring in 2019.  In March 2019, the largest
tenant, Itron Inc. (38.1% NRA), vacated the property at lease
expiration. In addition, the second largest tenant, USDA (37.8%
NRA), is scheduled to expire on Aug. 31, 2019. However, the
servicer reports that USDA is preparing a renewal request. The loan
was structured with an upfront leasing cost reserve of $1.5 million
and ongoing reserves of $1.00 psf, capped at $2.0 million.
According to servicer reporting, the balance as of August 2019 was
$3.3 million. The high modeled losses for the loan are due to the
significant lease rollover and its expected impact on the
property's future cash flow. Per the servicer, a cash flow sweep is
currently in place due to Itron Inc. vacating, and as of June 2019,
the property was 52.55% occupied.

Minimal Changes to Credit Enhancement: The pool has paid down by
2.15% resulting in minimal increases in credit enhancement to the
senior classes. Five of the largest 10 loans, representing 27.97%
of the pool, are full-term interest-only loans. In total, there are
nine full-term interest-only loans representing 32.1% of the pool.
Additionally, there are 24 loans representing 38% of the pool that
are partial interest-only loans. Based on the scheduled balance at
maturity, the pool will pay down 9.8%, which is lower than the 2015
average of 12.3%.

As of the July 2019 distribution date, the pool's aggregate
principal balance has been reduced to $757.8 million from $774.5
million at issuance. Per the servicer reporting, two loans (2.94%
of the pool) are defeased. Interest shortfalls are currently
affecting class H. There are currently 14 loans (25.4% of the pool)
on the servicer's watchlist, however, only seven loans (15.79%),
including four specially serviced loans, are considered FLOCs.

ADDITIONAL CONSIDERATIONS

Pool Concentrations: Compared to other 2015 vintage transactions,
the deal has higher concentrations in retail, hotel, and
single-tenant properties. Retail concentration is currently 30.3%
of the pool. Loans collateralized by hotel properties represent
18.3% of the pool and 24.0% of the pool is securitized by
single-tenant properties.

RATING SENSITIVITIES

The Negative Outlooks on class G and the interest-only class X-G
continue to reflect concerns over the largest loan in the pool, One
Court Square. Additionally, modeled losses have increased since the
prior rating action due to several FLOCs. A downgrade to these
classes is possible if a replacement tenant (or tenants) cannot be
found for the One Court Square property or if FLOC performance
continues to deteriorate. Conversely, the Outlooks could be revised
back to Stable with positive leasing momentum and or increased
performance amongst the FLOCs. The Outlooks on classes A-1 through
F and X-A through X-F remain stable due to the relatively stable
performance of the pool and the continued paydown.


WELLS FARGO 2019-C52: Fitch Assigns B-sf Rating on Cl. G-RR Certs
-----------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Wells Fargo Commercial Mortgage Trust 2019-C52
commercial mortgage pass-through certificates, series 2019-C52:

  -- $26,626,000 class A-1 'AAAsf'; Outlook Stable;

  -- $43,907,000 class A-2 'AAAsf'; Outlook Stable;

  -- $28,568,000 class A-3 'AAAsf'; Outlook Stable;

  -- $47,444,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $177,000,000 class A-4 'AAAsf'; Outlook Stable;

  -- $306,623,000 class A-5 'AAAsf'; Outlook Stable;

  -- $630,168,000b class X-A 'AAAsf'; Outlook Stable;

  -- $172,666,000b class X-B 'A-sf'; Outlook Stable;

  -- $93,400,000 class A-S 'AAAsf'; Outlook Stable;

  -- $45,012,000 class B 'AA-sf'; Outlook Stable;

  -- $34,254,000 class C 'A-sf'; Outlook Stable;

  -- $25,387,000ac class D-RR 'BBBsf'; Outlook Stable;

  -- $16,879,000ac class E-RR 'BBB-sf'; Outlook Stable;

  -- $15,754,000ac class F-RR 'BB-sf'; Outlook Stable;

  -- $9,003,000ac class G-RR 'B-sf'; Outlook Stable;

The following class is not rated:

  -- $30,383,221ac class H-RR 'NR'.

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

(b) Notional amount and interest-only.

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

Since Fitch published its expected ratings on June 5, 2019, the
balances for class A-4, A-5, X-B, C and D-RR were finalized. When
expected ratings were assigned, the class A-4 and class A-5
balances were estimated within the ranges of $100,000,000 to
$240,000,000 and the range of $243,623,000 to $383,623,000,
respectively. The final class sizes for class A-4 and class A-5 are
$177,000,000 and $306,623,000, respectively. When expected ratings
were assigned, the class C, class X-B and class D-RR balances were
estimated at $36,009,000, $174,421,000 and $23,632,000,
respectively. The final class sizes for class C, class X-B and
class D-RR are $34,254,000, $172,666,000 and $25,387,000,
respectively.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 67 loans secured by 126
commercial properties with an aggregate principal balance of
$900,240,222 as of the cut-off date. The loans were contributed to
the trust by Argentic Real Estate Finance LLC, Rialto Mortgage
Finance, LLC, Barclays Capital Real Estate Inc., Ladder Capital
Finance LLC, BSPRT CMBS Finance LLC and Wells Fargo Bank, National
Association.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 60.3% of the properties
by balance, cash flow analysis of 75.7%, and asset summary reviews
on 100.0% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch trust leverage is better when
compared with other recent Fitch-rated, fixed-rate, multiborrower
transactions. The pool's Fitch debt service coverage ratio (DSCR)
of 1.30x is significantly better than the 2018 and 2019 YTD
averages of 1.22x and 1.22x, respectively, for other Fitch-rated
multiborrower transactions. The pool's Fitch loan-to-value (LTV) of
100.7% is in line with the 2018 and 2019 YTD averages of 102.0% and
101.8%, respectively.

Above-Average Pool Diversification: The pool is less concentrated
than recent Fitch-rated multiborrower transactions. The largest 10
loans comprise 39.2% of the pool, which is significantly below the
2018 average of 50.6% and YTD 2019 average of 51.3%. The
concentration results in an LCI of 255, which is lower than the
respective 2018 and 2019 YTD averages of 373 and 382.

Investment Grade Credit Opinion Loan: Fitch assigned Moffett Towers
- Buildings 3 & 4 a standalone credit opinion of 'BBB-'. Excluding
investment-grade credit opinions, the pool has a Fitch DSCR and LTV
of 1.29x and 102.7%, respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 10.4% below
the most recent year's NOI for properties for which a full-year NOI
was provided, excluding properties that were stabilizing during
this period. Unanticipated further declines in property-level NCF
could result in higher defaults and loss severities on defaulted
loans and in potential rating actions on the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the WFCM
2019-C52 certificates and found that the transaction displays
average sensitivities to further declines in NCF. In a scenario in
which NCF declined a further 20% from Fitch's NCF, a downgrade of
the junior 'AAAsf' certificates to 'A-sf' could result. In a more
severe scenario, in which NCF declined a further 30% from Fitch's
NCF, a downgrade of the junior 'AAAsf' certificates to 'BBB-sf'
could result.


WEST CLO 2014-1: Moody's Raises $20MM Class D Notes Rating to Ba2
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by West CLO 2014-1 Ltd.:

  US$49,500,000 Class A-2-R Senior Secured Floating Rate Notes
  Due July 20, 2026, Upgraded to Aaa (sf); previously on
  September 20, 2017 Assigned Aa1 (sf)

  US$20,250,000 Class B-R Senior Secured Deferrable Floating
  Rate Notes Due July 20, 2026, Upgraded to Aa1 (sf);
  previously on September 20, 2017 Assigned A1 (sf)

  US$29,250,000 Class C-R Senior Secured Deferrable Floating
  Rate Notes Due July 20, 2026, Upgraded to A3 (sf);
  previously on September 20, 2017 Assigned Baa2 (sf)

  US$20,250,000 Class D Senior Secured Deferrable Floating
  Rate Notes Due July 20, 2026, Upgraded to Ba2 (sf);
  previously on July 25, 2014 Assigned Ba3 (sf)

West CLO 2014-1 Ltd., issued in July 2014 and partially refinanced
in September 2017, is a managed cashflow CLO. The notes are
collateralized primarily by a portfolio of broadly syndicated
senior secured corporate loans. The transaction's reinvestment
period ended in July 2018.

RATINGS RATIONALE

These rating actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's
over-collateralization (OC) ratios since August 2018. The Class
A-1-R notes have been paid down by approximately 58% or $169.9
million since then. Based on the trustee's August 2019 report, the
OC ratios for the Class A, Class B, Class C and Class D notes are
reported at 158.68%, 141.98%, 123.24% and 112.93%, respectively,
versus August 2018 levels of 130.21%, 122.93%, 113.75% and 108.16%,
respectively.

Nevertheless, the credit quality of the portfolio has deteriorated
since August 2018. Based on the trustee's August 2019 report, the
weighted average rating factor is currently 3294 compared to 2915
in August 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 $274.3 million, no defaulted par, a
weighted average default probability of 21.86% (implying a WARF of
3262), a weighted average recovery rate upon default of 48.26%, a
diversity score of 41 and a weighted average spread of 3.61%.

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.


WFRBS COMMERCIAL 2012-C8: Moody's Affirms B2 Rating on Cl. G Certs
------------------------------------------------------------------
Moody's Investors Service upgraded the ratings on four classes and
affirmed the ratings on nine classes in WFRBS Commercial Mortgage
Trust 2012-C8, Commercial Mortgage Pass-Through Certificates,
Series 2012-C8, as follows:

Cl. A-FL, Affirmed Aaa (sf); previously on May 17, 2018 Affirmed
Aaa (sf)

Cl. A-FX, Affirmed Aaa (sf); previously on May 17, 2018 Affirmed
Aaa (sf)

Cl. A-3, Affirmed Aaa (sf); previously on May 17, 2018 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on May 17, 2018 Affirmed
Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on May 17, 2018 Affirmed Aaa
(sf)

Cl. B, Upgraded to Aa1 (sf); previously on May 17, 2018 Affirmed
Aa2 (sf)

Cl. C, Upgraded to A1 (sf); previously on May 17, 2018 Affirmed A2
(sf)

Cl. D, Upgraded to A3 (sf); previously on May 17, 2018 Affirmed
Baa1 (sf)

Cl. E, Affirmed Baa3 (sf); previously on May 17, 2018 Affirmed Baa3
(sf)

Cl. F, Affirmed Ba2 (sf); previously on May 17, 2018 Affirmed Ba2
(sf)

Cl. G, Affirmed B2 (sf); previously on May 17, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on May 17, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Upgraded to Aa1 (sf); previously on May 17, 2018 Affirmed
Aa2 (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

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

The ratings on three P&I classes were upgraded based primarily on
an increase in credit support resulting from loan paydowns and
amortization, as well as a significant increase in defeasance. The
deal has paid down approximately 27% since securitization and 16.5%
of the current pool balance is now defeased.

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

The rating on one IO class, Cl. X-B, was upgraded due to the
increase in the credit quality of its referenced class resulting
from principal paydowns, amortization and defeasance.

Moody's rating action reflects a base expected loss of 2.3% of the
current pooled balance, compared to 1.9% at Moody's last review.
Moody's base expected loss plus realized losses is now 1.7% of the
original pooled balance, compared to 1.4% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the July 2019 distribution date, the transaction's aggregate
certificate balance has decreased by 27% to $952.3 million from
$1.3 billion at securitization. The certificates are collateralized
by 67 mortgage loans ranging in size from less than 1% to 14.5% of
the pool, with the top ten loans (excluding defeasance)
constituting 57% of the pool. Nineteen loans, constituting 16.5% of
the pool, have defeased and are secured by US government
securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 15, compared to 19 at Moody's last review.

Eleven loans, constituting 15% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

One loan has been liquidated from the pool, resulting in a minimal
realized loss and a loss severity of 0.2%. The only specially
serviced loan is the Springhill Suites -- San Angelo loan ($6.9
million -- 0.7% of the pool), which is secured by a 96-key limited
service hotel, built in 2010 and located in San Angelo, Texas. The
loan transferred to the special servicer in May 2016 for imminent
monetary default, was foreclosed upon in December 2017 and is now
REO. A property improvement plan (PIP) was completed in 2018 and
the asset manager continues to work with the property manager to
increase performance post renovation.

Moody's received full year 2018 operating results for 93% of the
pool (excluding specially serviced and defeased loans). Moody's
weighted average conduit LTV is 88%, compared to 89% at Moody's
last review. Moody's conduit component excludes loans with
structured credit assessments, defeased and CTL loans, and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 13% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 9.7%.

Moody's actual and stressed conduit DSCRs are 1.67X and 1.24X,
respectively, compared to 1.67X and 1.23X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 30% of the pool balance. The
largest loan is the 100 Church Street Loan ($137.6 million -- 14.5%
of the pool), which represents a pari passu interest in a $211.1
million mortgage loan. The loan is secured by a 1.1 million square
foot (SF), Class B office property in downtown Manhattan. As of
March 2019, the property was 98% leased, largely unchanged since
2016 and up from 84% at securitization. The 2018 net operating
income (NOI) declined slightly due to lease rollover and a free
rent period for a newly signed tenant. The loan has amortized 8%
since securitization and Moody's LTV and stressed DSCR are 89% and
1.09X, respectively, compared to 92% and 1.06X at Moody's last
review.

The second largest loan is the Northridge Fashion Center Loan
($78.5 million -- 8.2% of the pool), which represents a pari passu
portion of a $216.4 million mortgage loan. The loan is secured by a
644,000 SF portion of a 1.5 million SF super-regional mall located
in Northridge, California. The mall's non-collateral anchors
include Macy's, Macy's Men and Home and JC Penney. The
non-collateral anchor space formerly occupied by Sears went dark in
2018. As of December 2018, the in-line space was 96% leased and the
total property was 99% leased. However, excluding the vacant Sears
space, the total occupancy declines to 81%. Property performance
has improved since securitization due to higher rental revenues and
the 2018 reported NOI was 13% higher than in 2012. The loan has
amortized 12% since securitization and Moody's LTV and stressed
DSCR are 87% and 1.12X, respectively, compared to 90% and 1.09X at
Moody's last review.

The third largest loan is the BJ's Portfolio Loan ($68.1 million --
7.2% of the pool), which is secured by the first mortgage liens on
six properties consisting of five retail stores of BJ's Wholesale
Club and one industrial center serving as a BJ's Distribution
facility. The portfolio is located in five different states:
Massachusetts, Pennsylvania, Maryland, New Jersey and Florida. The
portfolio is 100% occupied by a single tenant, BJ's Wholesale Club,
Inc. Due to the single tenant exposure, Moody's valuation reflects
a lit/dark analysis. Moody's LTV and stressed DSCR are 99% and
1.12X, respectively, compared to 98% and 1.13X at Moody's last
review.


WHITEBOX CLO I: S&P Assigns BB- (sf) Rating to $16MM Class D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Whitebox CLO I
Ltd./Whitebox CLO I LLC's floating-rate notes.

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

The ratings reflect:

-- The diversified collateral pool, which consists primarily of
broadly syndicated speculative-grade (rated 'BB+' and lower) senior
secured term loans that are governed by collateral quality tests.

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

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

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

  RATINGS ASSIGNED
  Whitebox CLO I Ltd./Whitebox CLO I LLC

  Class                Rating         Amount (mil. $)
  AN-A                 AAA (sf)                 43.56
  A-L                  AA (sf)                 249.28
  AN-B                 AA (sf)                  11.16
  B (deferrable)       A (sf)                   22.00
  C (deferrable)       BBB- (sf)                24.00
  D (deferrable)       BB- (sf)                 16.00
  Subordinated notes   NR                       35.45

  NR--Not rated.



                            *********

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