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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, November 17, 2019, Vol. 23, No. 320

                            Headlines

BBCMS 2019-BWAY: Fitch to Rate $45.1MM Class E Certs BB-sf
BBCMS MORTGAGE 2017-C1: Fitch Affirms B-sf Rating on 2 Tranches
CD 2017-CD6: Fitch Affirms B-sf Rating on Class G-RR Debt
CIM TRUST 2019-J2: Moody's Assigns B2 Rating on Class B-5 Debt
CITIGROUP COMMERCIAL 2019-GC43: Fitch Rates Class J-RR Certs B-sf

COMM 2019-GC44: Fitch to Rate $9.8MM Class G-RR Certs 'B-sf'
COMM 2019-GC44: Moody's Assigns (P)B3 Rating on Cl. 180W-C Certs
CREDIT SUISSE 2006-CF1: Moody's Lowers Class M-2 Debt Rating to B1
CSAIL 2019-C18: Fitch to Rate 2 Certificate Classes 'B-sf'
FREDDIE MAC 2019-4: Fitch to Rate Class M Debt 'B-(EXP)'

GREENWICH CAPITAL 2004-GG1: Moody's Lowers Class G Certs to B1
GS MORTGAGE 2016-RENT: Fitch Affirms B-sf Rating on Cl. F Certs
GS MORTGAGE 2019-GSA1: Fitch Assigns B-sf Rating on Cl. G-RR Certs
GSAMP TRUST 2005-NC1: Moody's Lowers Class M-1 Debt Rating to B1
HOME BOUND HEALTHCARE: Gets Interim Cash Access Thru Dec. 1

JP MORGAN 2011-C3: Fitch Lowers Ratings on 3 Tranches to CCC
MONROE CAPITAL IX: Moody's Rates $29.250MM Class E Notes Ba3
MORGAN STANLEY 2004-IQ8: Fitch Affirms D Ratings on 5 Tranches
PRUDENTIAL SECURITIES 1999-C2: Moody's Affirms C on 2 Classes
TOWD POINT 2019-4: Moody's Assigns Ba3 Rating on 3 Tranches

WELLS FARGO 2011-C4: Fitch Lowers Class F Certs Rating to Bsf
WELLS FARGO 2017-C42: Fitch Affirms B-sf Rating on Cl. X-F Certs

                            *********

BBCMS 2019-BWAY: Fitch to Rate $45.1MM Class E Certs BB-sf
----------------------------------------------------------
Fitch Ratings issued a presale report on BBCMS 2019-BWAY Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series
2019-BWAY.

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

  -- $187,400,000 class A 'AAAsf'; Outlook Stable;

  -- $187,400,000a class X-CP 'AAAsf'; Outlook Stable;

  -- $187,400,000a class X-NCP 'AAAsf'; Outlook Stable;

  -- $36,600,000 class B 'AA-sf'; Outlook Stable;

  -- $24,500,000 class C 'A-sf'; Outlook Stable;

  -- $38,800,000 class D 'BBB-sf'; Outlook Stable;

  -- $45,100,000 class E 'BB-sf'; Outlook Stable;

  -- $17,600,000b class HRR 'B+sf'; Outlook Stable.

(a)Notional amount and interest only

(b)Horizontal credit risk retention interest, which represents
approximately 5.00% of the certificate balance, notional amount or
percentage of each class certificates.

The expected ratings are based on information provided by the
issuer as of Nov. 11, 2019.

BBCMS 2019-BWAY Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2019-BWAY, represent the beneficial ownership
interest in a two-year (with three, one-year extension options),
floating-rate, interest only first-lien mortgage loan with an
original principal balance of $350.0 million. The mortgage loan is
secured by the leasehold interest in 1407 Broadway, a 43-story,
office tower totaling 1.1 million square feet in New York City.

The loan proceeds were used to pay off the existing $286.0 million
debt, return $52.0 million of equity to the sponsor, and fund
upfront reserves and closing costs. The expected closing date for
the transaction is Nov. 26, 2019

KEY RATING DRIVERS

Strong Infill Manhattan Location: The property is located between
38th Street and 39th Street in Manhattan in close proximity to
Manhattan's public transportation hubs, including Times Square,
Grand Central Terminal, New York Penn Station, and the Port
Authority Bus Terminal. In addition, the property is located one
block from Bryant Park, a 10-acre outdoor space with six million
annual visitors, and the property benefits from the recent
development of the Hudson Yards district, a $25 billion mixed-use
development that opened in March 2019, located six blocks to the
west. According to Reis, the subject is located within the Penn
Station submarket (within the New York Metro office market), which
reports an average vacancy of 3.60% and average asking rent of
$57.19 per square foot (psf) as of 3Q19. Class A average asking
rents are $75.57 psf as of 3Q19.

Fitch Leverage: The $350.0 million mortgage loan has a Fitch DSCR
and LTV of 1.03x and 85.9%, respectively, and debt of $313 psf. The
sponsor acquired the property in 2015 for $330.0 million.

Short-term Leasehold Interest: The Estate of Sol Goldman owns the
land, and 1407 Broadway is subject to a 76-year ground lease
through December 2030, with one remaining fixed-rent, 18-year
renewal option, which would extend the ground lease through
December 2048. The fully extended loan term is five years, which
would result in 24 years remaining on the ground lease at loan
maturity. Fitch conducted break-even analysis to determine the
maximum coupon required to maintain a 1.00x DSCR at loan maturity,
assuming a fully amortizing loan concurrent with the expiration of
the ground lease. Assuming Fitch's current in-place stressed cash
flow, the break-even refinance coupon is 7.9% for the scheduled
balloon balance of the entire loan.

Recent Leasing and Capital Expenditures: The property is currently
93.8% leased with a weighted average lease term of 5.4 years to 152
tenants, including Comcast (9.3% NRA), S. Rothschild (4.2% NRA) and
Vince Camuto (3.8% NRA). The sponsor has increased occupancy from
75.3% to 93.8% by executing approximately 700,000 square feet (sf)
of new and renewal leases. In addition, the property underwent a
$61.1 million renovation from 2015 to 2018. Major projects included
the common areas ($9.2 million), lobby ($8.3 million), retail
storefronts ($6.5 million) and HVAC ($5.5 million).

Experienced Ownership: The sponsor for the loan is an affiliate of
Shorenstein Company, LLC. Starting in 1992, Shorenstein has
sponsored 12 closed-end investment funds with total equity
commitments of $8.7 billion, of which Shorenstein committed $723.5
million. Those funds have invested in properties totaling 65.4
million sf. The company currently owns over 25 million sf in 20
markets.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 10.6% below
the Underwritten Issuer NCF. Unanticipated further declines in
property-level NCF could result in higher defaults and loss
severities on defaulted loans, and could result in potential rating
actions on the certificates.

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3 - ESG issues are credit
neutral or have only a minimal credit impact on the transaction,
either due to their nature or the way in which they are being
managed by the transaction.


BBCMS MORTGAGE 2017-C1: Fitch Affirms B-sf Rating on 2 Tranches
---------------------------------------------------------------
Fitch Ratings affirmed 16 classes of BBCMS Mortgage Trust 2017-C1
commercial mortgage pass-through certificates, series 2017-C1.

RATING ACTIONS

BBCMS 2017-C1

Class A-1 07332VAZ8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 07332VBA2;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 07332VBC8;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 07332VBD6;  LT AAAsf Affirmed;  previously at AAAsf

Class A-S 07332VBE4;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 07332VBB0; LT AAAsf Affirmed;  previously at AAAsf

Class B 07332VBF1;    LT AA-sf Affirmed;  previously at AA-sf

Class C 07332VBG9;    LT A-sf Affirmed;   previously at A-sf

Class D 07332VAA3;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 07332VAC9;    LT BB-sf Affirmed;  previously at BB-sf

Class F 07332VAE5;    LT B-sf Affirmed;   previously at B-sf

Class X-A 07332VBJ3;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 07332VBH7;  LT AA-sf Affirmed;  previously at AA-sf

Class X-D 07332VAL9;  LT BBB-sf Affirmed; previously at BBB-sf

Class X-E 07332VAN5;  LT BB-sf Affirmed;  previously at BB-sf

Class X-F 07332VAQ8;  LT B-sf Affirmed;   previously at B-sf

KEY RATING DRIVERS

Stable Performance: The overall pool performance remains stable
from issuance. There is one specially serviced loan (0.42% of the
pool). As of the October 2019 distribution date, the pool's
aggregate balance has been reduced by approximately 6.2% to $845
million, from $856 million at issuance. There are six loans on the
servicer's watchlist, none of which are considered a Fitch Loan of
Concern.

Minimal Changes to Credit Enhancement: There has been little change
to credit support given the recent issuance of the deal.
Amortization in the near term will be limited as 13 loans
representing 47.9% of the pool are full-term interest-only and 18
loans representing 22.8% of the pool are partial interest-only, of
which 13 loans representing 20.5% of the pool have not yet begun
amortizing. At issuance, the pool was scheduled to amortize by 7.4%
prior to maturity.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable due to the overall
stable performance of the pool. Future upgrades may occur with
improved pool performance and additional paydown or defeasance.
Downgrades may be possible should a material asset-level or
economic event adversely affect pool performance.

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

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. ESG issues are credit neutral
or have only a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by
transaction.


CD 2017-CD6: Fitch Affirms B-sf Rating on Class G-RR Debt
---------------------------------------------------------
Fitch Ratings affirmed 16 classes of CD 2017-CD6 Mortgage Trust
Series 2017-CD6.

RATING ACTIONS

CD 2017-CD6

Class A-1 125039AA5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 125039AB3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 125039AC1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 125039AE7;  LT AAAsf Affirmed;  previously at AAAsf

Class A-5 125039AF4;  LT AAAsf Affirmed;  previously at AAAsf

Class A-M 125039AH0;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 125039AD9; LT AAAsf Affirmed;  previously at AAAsf

Class B 125039AJ6;    LT AA-sf Affirmed;  previously at AA-sf

Class C 125039AK3;    LT A-sf Affirmed;   previously at A-sf

Class D 125039AQ0;    LT BBBsf Affirmed;  previously at BBBsf

Class E-RR 125039AS6; LT BBB-sf Affirmed; previously at BBB-sf

Class F-RR 125039AU1; LT BB-sf Affirmed;  previously at BB-sf

Class G-RR 125039AW7; LT B-sf Affirmed;   previously at B-sf

Class X-A 125039AG2;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 125039AL1;  LT AA-sf Affirmed;  previously at AA-sf

Class X-D 125039AN7;  LT BBBsf Affirmed;  previously at BBBsf

KEY RATING DRIVERS

Stable Loss Expectations: Pool performance has been stable since
issuance; therefore, overall modeled losses are in line with
issuance expectations. As of October 2019, the pool has no
delinquent or specially serviced loans. The pool has 10 loans
(12.1% of outstanding loan balance) on the servicer's watchlist for
performance decline, high vacancy, deferred maintenance and a mall
anchor departure. However, only two loans (3.9%) have the
designation of Fitch Loan of Concern (FLOC) for concentrated tenant
rollover and declining sales and occupancy.

Minimal Change to Credit Enhancement: There has been limited
limited amortization, no defeasance and no disposed loans since
issuance. As of the October 2019 distribution date, the pool's
aggregate principal balance has been reduced by 1.4% to $1.047
billion from $1.062 billion at issuance. At issuance, the pool was
scheduled to amortize by 10.8% of the initial pool balance by
maturity. Fifteen loans representing 34.7% of the pool balance are
interest only for the full term, and an additional 20 loans
representing 29.8% of the pool were structured with partial
interest-only periods, none of which have begun amortizing.

Fitch Loans of Concern: One Imeson (2.6%) is collateralized by a
1.7 million sf warehouse/distribution center, located in
Jacksonville, FL. Komyo America Co. accounts for 365,000 sf at the
subject (21.4%) and has two leases scheduled to expire between
March and September 2020. The servicer is uncertain whether the
tenant intends to continue leasing the space. According to the June
2019 rent roll, Komyo America Co. comprises approximately 8% of the
subject's annual rent.

Gurnee Mills (1.4%), is secured by a 1.7 million sf interest in a
1.9 million sf regional mall is located in Gurnee, IL, roughly 45
miles north of Chicago. The mall is anchored by non-collateral
tenants Marcus Cinema, Burlington, Value City Furniture, and
collateral tenants Bass Pro Shops, Kohl's, and Macy's. Occupancy
has been trending downward over the past several years as follows:
88% (2017), 81% (2018) and 80% (June 2019). The property lost
anchor tenant Sears Grand (12% NRA, 6% rent) in summer 2018 prior
to its April 2019 lease expiration date. Neiman Marcus Last Call
(2.8% NRA) also vacated its space in 1Q18 prior to its lease
expiration date in January 2020. Sales have declined since
issuance. Comparable in line sales for tenants occupying less than
10,000 sf were $332 psf at YE 2018, up from $313 psf at YE 2017,
but down from $347 psf at issuance. Macy's reported sales of $122
sf at YE 2018, flat from $122 psf at YE 2017, but down from $134
psf at issuance. Bass Pro Shops had sales of $169 psf at YE 2018,
down from $179 psf at YE 2017 and $189 psf at issuance.

RATING SENSITIVITIES

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


CIM TRUST 2019-J2: Moody's Assigns B2 Rating on Class B-5 Debt
--------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to 23 classes
of residential mortgage-backed securities issued by CIM Trust
2019-J2. The ratings range from Aaa (sf) to B2 (sf).

CIM Trust 2019-J2 is a securitization of 30-year prime residential
mortgages.

This transaction represents the second non-investor prime jumbo
issuance by Chimera Investment Corporation in 2019. The transaction
includes 441 fixed rate, first lien-mortgages. There are 19
GSE-eligible high balance (3.3% by balance) and 422 prime jumbo
(96.7% 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 from Bank of America, National
Association. Approximately 24.8% 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
Chimera's acquisition criteria, 59.9% of the loans were
underwritten to Quicken Loans' guidelines and 12.0% of the loans
were underwritten to loanDepot's guidelines. All other mortgage
loans (3.3% by loan balance), were high balance conforming loans
acquired by BANA through its whole loan purchase program from two
different originators, 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 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. 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 0.50% and reach 5.13% at a stress level consistent
with its Aaa(sf) rating scenario.

CIM 2019-J2 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 considersed the increased risk
from borrowers with more than one mortgage in the pool.

The complete rating actions are as follows:

Issuer: CIM Trust 2019-J2

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 Aa1 (sf)

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

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

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

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

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

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

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

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

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

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

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Its expected losses in a base case scenario are 0.50% ,
respectively, and reach 5.13% 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 but were not limited to
adjustments for origination quality and third party review (TPR)
scope and results. Its loss levels and ratings on the certificates
also took into consideration qualitative factors such as 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.

Moody's published an updated methodology for rating and monitoring
US RMBS backed by government-sponsored enterprises (GSEs) and
private label prime first-lien mortgage loans originated during or
after 2009, "Moody's Approach to Rating US RMBS Using the MILAN
Framework" published on October 30, 2019, which replaces the
methodology titled "Moody's Approach to Rating US Prime RMBS"
published on November 15, 2018. The application of this updated
methodology resulted in a higher expected loss in a baseline
scenario and stress level consistent with its Aaa scenario but did
not lead to a change in ratings from the provisional ratings.

Collateral Description

Moody's assessed the collateral pool as of the cut-off date of
October 1, 2019. Four mortgage loans were dropped due to
delinquencies from the time of assigning provisional ratings. CIM
2019-J2 is a securitization of 441 mortgage loans with an aggregate
principal balance of $337,945,089.

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, and planned unit
developments. The loans have a weighted average seasoning of
approximately two months.

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 70.3% and WA CLTV of 70.3%. Approximately 42.8% (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.

Origination

There are 13 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. (Quicken Loans, 59.9%), loanDepot.com, LLC (loanDepot,
14.3%), Home Point Financial Corporation (Home Point, 10.0%), and
JMAC Lending, Inc. (5.5%).

Underwriting guidelines:

Approximately 96.7% of the loans by loan balance, are prime jumbo
loans of which 24.8% were underwritten to Chimera's underwriting
guidelines and 71.9% of the loans were underwritten to respective
originator guidelines. 3.3% of the loans are conforming loans and
were originated in conformance to GSE guidelines with no overlays.

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
loans originated by Quicken Loans (59.9% of the collateral
balance), Home Point loans (10.0% of the collateral balance) and
all other loans underwritten to Chimera's underwriting guidelines.

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

Two third party review (TPR) firms verified the accuracy of the
loan-level information that Moody's received from the sponsor.
These firms conducted detailed credit, property valuation, data
integrity and regulatory compliance reviews on 100% of the mortgage
pool. The TPR 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 five 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 1.75% 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 1.35% of the closing pool
balance.

Moody's calculates the credit neutral floors for a given target
rating as shown in its principal methodology. The senior
subordination floor is equal to an amount which is the sum of the
balance of the six largest loans at closing multiplied by the
higher of their corresponding MILAN Aaa severity or a 35% severity.
The senior subordination floor of 1.75% and subordinate floor of
1.35% are consistent with the credit neutral floors for the
assigned ratings.

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-J2 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-J2, 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 certificate holders 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 COMMERCIAL 2019-GC43: Fitch Rates Class J-RR Certs B-sf
-----------------------------------------------------------------
Fitch Ratings assigned the following ratings and Rating Outlooks to
Citigroup Commercial Mortgage Trust 2019-GC43 commercial mortgage
pass-through certificates, series 2019-GC43:

  -- $8,955,000 class A-1 'AAAsf'; Outlook Stable;

  -- $41,294,000 class A-2 'AAAsf'; Outlook Stable;

  -- $133,000,000 class A-3 'AAAsf'; Outlook Stable;

  -- $434,302,000 class A-4 'AAAsf'; Outlook Stable;

  -- $13,585,000 class A-AB 'AAAsf'; Outlook Stable;

  -- $685,233,000b class X-A 'AAAsf'; Outlook Stable;

  -- $54,097,000 class A-S 'AAAsf'; Outlook Stable;

  -- $57,479,000 class B 'AA-sf'; Outlook Stable;

  -- $42,827,000 class C 'A-sf'; Outlook Stable;

  -- $57,479,000ab class X-B 'AA-sf'; Outlook Stable;

  -- $47,335,000ab class X-D 'BBB-sf'; Outlook Stable;

  -- $15,778,000ab class X-F 'BB+sf'; Outlook Stable;

  -- $11,271,000ab class X-G 'BB-sf'; Outlook Stable;

  -- $27,048,000a class D 'BBBsf'; Outlook Stable;

  -- $20,287,000a class E 'BBB-sf'; Outlook Stable;

  -- $15,778,000a class F 'BB+sf'; Outlook Stable;

  -- $11,271,000a class G 'BB-sf'; Outlook Stable;

  -- $9,016,000ac class J-RR 'B-sf'; Outlook Stable.

The following classes are not rated by Fitch:

  -- $32,684,165ac class K-RR 'NR';

  -- $35,250,000ad class VRR 'NR'.

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

(b) Notional amount and interest-only.

(c) Horizontal credit risk retention interest representing
approximately 1.2877% of the estimated fair value of all classes of
regular certificates issued by the issuing entity as of the closing
date.

(d) Eligible vertical credit-risk retention interest (VRR) will
consist of approximately 3.7625% of the certificate balance,
notional amount, or percentage interest of each class of
certificates.

Since Fitch published its expected ratings on Oct. 21, 2019, the
balances for class A-3, A-4 and X-B were finalized. At the time the
expected ratings were assigned, the exact initial certificate
balances for class A-3 and A-4 were unknown and expected to be
approximately $567,320,000 in aggregate, subject to a 5% variance.
The final class balances for class A-3 and A-4 are $133,000,000 and
$434,302,000, respectively. In addition, class X-B decreased from
$100,306,000 to $57,479,000, as it now reflects the aggregate
certificate balance of the related class B. Fitch's rating on class
X-B has been updated to 'AA-sf' to reflect the rating of the lowest
referenced tranche, of which payable interest has an impact on the
interest-only payments. The classes reflect the final ratings and
deal structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 34 loans secured by 75
commercial properties with an aggregate principal balance of
$936,873,165 as of the cut-off date. The loans were contributed to
the trust by Goldman Sachs Mortgage Company and Citi Real Estate
Funding, Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 75.2% of the properties
by balance, cash flow analysis of 90.4%, and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Higher Pool Concentration Relative to Recent Transactions: The top
10 loans represent 67.4% of the pool by balance, which is higher
than the 2018 and 2019 YTD multiborrower transaction averages of
50.6% and 51.0%, respectively. The pool's loan concentration index
(LCI) score of 541 and sponsor concentration index (SCI) score of
649 are also above the YTD 2019 averages of 381 and 402,
respectively.

Fitch Leverage: The pool's Fitch DSCR of 1.26x is higher than
average when compared to the 2018 and 2019 YTD averages of 1.22x
and 1.24x, respectively. In addition, the pool's LTV of 105.5% is
higher than the 2018 and 2019 YTD average of 102.0% and 101.4%,
respectively.

Credit Opinion Loans: Two loans representing 16.5% of the pool are
credit assessed. The 30 Hudson Yards loan (9.0% of the pool)
received a stand-alone credit opinion of 'A-sf*', and the Grand
Canal Shoppes loan (7.5% of the pool) received a stand-alone credit
opinion of 'BBB-sf*'. Excluding the credit opinion loans, the Fitch
DSCR and LTV are 1.27x and 112.1%, respectively.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 9.0% 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-GC43 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 'Asf' 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.


COMM 2019-GC44: Fitch to Rate $9.8MM Class G-RR Certs 'B-sf'
------------------------------------------------------------
Fitch Ratings issued a presale report on COMM 2019-GC44 Mortgage
Trust commercial mortgage pass-through certificates, series
2019-GC44.

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

  -- $23,338,000 class A-1 'AAAsf'; Outlook Stable;

  -- $138,840,000 class A-2 'AAAsf'; Outlook Stable;

  -- $55,469,000 class A-3 'AAAsf'; Outlook Stable;

  -- $29,564,000 class A-SB 'AAAsf'; Outlook Stable;

  -- $125,500,000a class A-4 'AAAsf'; Outlook Stable;

  -- $317,697,000a class A-5 'AAAsf'; Outlook Stable;

  -- $808,764,000b class X-A 'AAAsf'; Outlook Stable;

  -- $118,356,000 class A-M 'AAAsf'; Outlook Stable;

  -- $40,685,000 class B 'AA-sf'; Outlook Stable;

  -- $35,753,000 class C 'A-sf'; Outlook Stable;

  -- $76,438,000bc class X-B 'A-sf'; Outlook Stable;

  -- $41,918,000bc class X-D 'BBB-sf'; Outlook Stable;

  -- $18,493,000bc class X-F 'BB-sf'; Outlook Stable;

  -- $23,425,000c class D 'BBBsf'; Outlook Stable;

  -- $18,493,000c class E 'BBB-sf'; Outlook Stable;

  -- $18,493,000c class F 'BB-sf'; Outlook Stable;

  -- $9,863,000ce class G-RR 'B-sf'; Outlook Stable.

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

  -- $30,822,346ce class H-RR;

  -- $25,800,000cd class RR Certificates;

  -- $12,200,000cd class RR Interest.

  -- The transaction includes five classes of non-offered, loan
specific certificates (non-pooled rake classes) related to the
companion loan of 180 Water. Classes 180W-A, 180W-B, 180W-C, 180W-D
and 180W VRR Interest are all not rated by Fitch.

(a) The initial certificate balances of class A-4 and A-5 are
unknown and expected to be $443,197,000 in aggregate, subject to a
5% variance. The certificate balances will be determined based on
the final pricing of those classes of certificates. The expected
class A-4 balance range is $75,000,000 to $176,000,000, and the
expected class A-5 balance range is $267,197,000 to $368,197,000.

(b) Notional amount and interest only.

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

(d) Vertical credit risk retention interest.

(e) Horizontal risk retention.

The expected ratings are based on information provided by the
issuer as of Nov. 12, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 43 loans secured by 55
commercial properties having an aggregate principal balance of
$1,024,298,346 as of the cut-off date. The loans were contributed
to the trust by Goldman Sachs Mortgage Company, Citi Real Estate
Funding Inc., and German American Capital Corporation.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 65.9% of the properties
by balance, cash flow analysis of 78.6% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Fitch Leverage: The pool's Fitch LTV of 100.0% is better than the
2019 YTD and 2018 averages of 102.5% and 102.0%, respectively, for
other recent Fitch-rated multiborrower transactions. Additionally,
the pool's Fitch DSCR of 1.26x is better than the 2019 YTD and 2018
averages of 1.24x and 1.22x, respectively. Excluding
investment-grade credit opinion loans, the pool has a Fitch DSCR
and LTV of 1.26x and 109.9%, respectively.

Investment-Grade Credit Opinions: Five loans, representing 24.9% of
the pool, have investment-grade credit opinions. This is
significantly above the 2019 YTD and 2018 averages of 13.8% and
13.6%, respectively. Midtown Center (3.2% of the pool) received a
credit opinion of 'BBBsf*' on a stand-alone basis. Century Plaza
Towers 1 (7.3%), 180 Water (6.1% of the pool), 225 Bush (4.9% of
the pool) and The Essex Site 2 (3.4% of the pool) each received
stand-alone credit opinions of 'BBB-sf*'.

Investment-Grade Credit Opinions: Five loans, representing 24.9% of
the pool, have investment-grade credit opinions. This is
significantly above the 2019 YTD and 2018 averages of 13.8% and
13.6%, respectively. Midtown Center (3.2% of the pool) received a
credit opinion of 'BBBsf*' on a stand-alone basis. Century Plaza
Towers 1 (7.3%), 180 Water (6.1% of the pool), 225 Bush (4.9% of
the pool) and The Essex Site 2 (3.4% of the pool) each received
stand-alone credit opinions of 'BBB-sf*'.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 12.6% 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 COMM
2019-GC44 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 'BBB+sf'
could result.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3 - ESG issues are credit
neutral or have only a minimal credit impact on the transaction,
either due to their nature or the way in which they are being
managed by the transaction.


COMM 2019-GC44: Moody's Assigns (P)B3 Rating on Cl. 180W-C Certs
----------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to 10
classes of CMBS securities, issued by COMM 2019-GC44 Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series
2019-GC44 as follows:

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

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

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

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

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

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

Cl. A-M, Assigned (P)Aa3 (sf)

Cl. 180W-A, Assigned (P)Baa3 (sf)

Cl. 180W-B, Assigned (P)Ba3 (sf)

Cl. 180W-C, Assigned (P)B3 (sf)

RATINGS RATIONALE

The Certificates are collateralized by 43 fixed rate loans secured
by 55 properties. 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.

The Moody's Actual DSCR of 2.36x (2.03x excluding credit assessed
loans) is better than the 2018 conduit/fusion transaction average
of 1.69x, and better than the trailing four quarters ending Q3 2019
conduit/fusion transactions average of 1.67x. The Moody's Stressed
DSCR of 0.97x (0.92x excluding credit assessed loans) is largely
in-line with the trailing four quarters ending Q3 2019
conduit/fusion transaction average of 1.00x.

The pooled trust loan balance of $1,024,298,346 represents a
Moody's LTV ratio of 104.3% (112.9% excluding credit assessed
loans), which is lower than the 2018 conduit/fusion transaction
average of 113.2% and higher than the trailing four quarters ending
Q3 2019 transaction average of 111.9%. There are five loans in the
pool structured with additional debt in the form of subordinate
debt, mezzanine debt, or debt-like preferred equity. With the
additional debt, the Moody's total debt LTV ratio rises to 109.3%
(114.4% excluding credit assessed loans).

Moody's also considers both loan level diversity and property level
diversity when selecting a ratings approach. With respect to loan
level diversity, the pool's loan level Herfindahl score is 27.9.
The transaction loan level diversity profile is lower than the
Moody's-rated transactions during the prior four quarters, which
averaged 30.5. With respect to property level diversity, the pool's
property level Herfindahl score is 34.4.

The following notable strengths of the transaction include:

(i) CRE quality is very strong: The pool's weighted average
Property Quality Grade is 1.88 (2.21 excluding SCAs), which is much
stronger than the Moody's 2018 conduit/fusion average quality grade
of 2.42. Moreover, the pool's top 10 loans have a very strong
weighted average Property Quality Grade of 1.48. Of these, eight
were assigned quality grades of 2.00 or less.

(ii) Market composition: Loans representing approximately 47.0% of
the pool balance are secured by real estate located in the top tier
major MSAs of New York (12.4%), Los Angeles (11.9%), San
Francisco/Oakland/San Jose (8.5%), Boston (8.4%) and Chicago
(5.8%). Moreover, properties located in small markets collateralize
loans represent only 10.5% of the pool balance.

(iii) Share of multiple-property loans: Five loans (15.3% of the
pool balance) are secured by multiple properties and/or cross
collateralized assets.

The following notable concerns of the transaction include:

(i) High Moody's LTV: The pool has a weighted average Moody's LTV
("MLTV") ratio of 104.3% (112.9% excluding SCAs).

(ii) High full-term IO loan share: The amortization profile for the
underlying assets contains a high concentration of loans with
interest-only debt service components. Twenty-seven loans (63.1% of
the pool balance) are structured with interest-only payment
schedules for the entire term of the loan, eight loans (19.9% of
the pool balance) are structured with an initial interest-only
period followed by fixed amortization payments, and eight loans
(17.0% of the pool balance) are structured with amortization during
the entire loan term prior to a balloon payment obligation.

(iii) Single tenant share: The pool contains four loans comprised
of 12 properties (13.0% of the pool balance) that are leased to
single tenants.

(iv) Low share of acquisition financing: Only eight loans (19.9% of
the pool balance) represent acquisition financing.

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 pool's weighted
average property quality grade is 1.88 (2.21 excluding credit
assessed loans), which is better than the average score of 2.42
calculated across Moody's-rated multi-borrower transactions during
the prior four quarters.

The principal methodology used in these ratings was "Approach to
Rating US and Canadian Conduit/ Fusion CMBS" published in July
2017.

Moody's analysis of credit enhancement levels for conduit deals is
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate Moody's uses to estimate Moody's value). Moody's fuses the
conduit results with the results of its analysis of
investment-grade structured credit assessed loans and any conduit
loan that represents 10% or greater of the current pool balance.

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.


CREDIT SUISSE 2006-CF1: Moody's Lowers Class M-2 Debt Rating to B1
------------------------------------------------------------------
Moody's Investors Service downgraded the rating of Class M-2 from
Credit Suisse Mortgage Capital Trust 2006-CF1.

Complete rating action is as follows:

Issuer: Credit Suisse Mortgage Capital Trust 2006-CF1

Cl. M-2, Downgraded to B1 (sf); previously on Feb 4, 2013 Upgraded
to Ba2 (sf)

RATINGS RATIONALE

The rating downgrade on Class M-2 is primarily due to the
outstanding interest shortfalls on the bond that are not expected
to be reimbursed. The action also reflects the recent performance
of the underlying collateral and Moody's updated loss expectation
on the pool.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in October 2019 from 3.8% in
October 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.


CSAIL 2019-C18: Fitch to Rate 2 Certificate Classes 'B-sf'
----------------------------------------------------------
Fitch Ratings issued a presale report on CSAIL 2019-C18 Commercial
Mortgage Trust pass-through certificates series 2019-C18.

TRANSACTION SUMMARY

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

  -- $25,306,000e class A-1 'AAAsf'; Outlook Stable;

  -- $65,479,000e class A-2 'AAAsf'; Outlook Stable;

  -- $122,500,000ae class A-3 'AAAsf'; Outlook Stable;

  -- $232,534,000ae class A-4 'AAAsf'; Outlook Stable;

  -- $36,487,000e class A-SB 'AAAsf'; Outlook Stable;

  -- $52,537,000e class A-S 'AAAsf'; Outlook Stable;

  -- $534,843,000be class X-A 'AAAsf'; Outlook Stable;

  -- $32,728,000e class B 'AA-sf'; Outlook Stable;

  -- $31,866,000e class C 'A-sf'; Outlook Stable;

  -- $64,594,000be class X-B 'A-sf'; Outlook Stable;

  -- $20,671,000ce class D 'BBBsf'; Outlook Stable;

  -- $17,225,000ce class E 'BBB-sf'; Outlook Stable;

  -- $37,896,000bce class X-D 'BBB-sf'; Outlook Stable;

  -- $17,225,000ce class F 'BB-sf'; Outlook Stable;

  -- $17,225,000bce class X-F 'BB-sf'; Outlook Stable;

  -- $6,890,000ce class G 'B-sf'; Outlook Stable;

  -- $6,890,000bce class X-G 'B-sf'; Outlook Stable.

The following class is not expected to be rated by Fitch:

  -- $27,561,002cd class NR-RR.

(a) The initial certificate balances of classes A-3 and A-4 are
unknown and expected to be $355,034,000 in aggregate, subject to a
5% variance. The expected class A-3 balance range is $75,000,000 to
$170,000,000, and the expected class A-4 balance range is
$185,034,000 to $280,034,000. The certificate balances for class
A-3 and class A-4 are assumed at the midpoint of the range for each
class.

(b) Notional amount and interest-only.

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

(d) Horizontal credit risk retention interest representing
approximately 0.91% of the estimated fair value of all classes of
regular certificates issued by the issuing entity as of the closing
date.

(e) Class includes vertical credit risk retention interest
representing no less than 4.12% of the approximate initial
certificate balance.

The expected ratings are based on information provided by the
issuer as of Nov. 12, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 55 loans secured by 80
commercial properties having an aggregate principal balance of
$689,009,002 as of the cut-off date. The loans were contributed to
the trust by Column Financial, Inc., Societe Generale Financial
Corporation, UBS AG, New York Branch, Rialto Real Estate Fund III -
Debt, LP and CIBC Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 67.3% of the properties
by balance, cash flow analysis of 76.3% and asset summary reviews
on 100.0% of the pool.

KEY RATING DRIVERS

Above-Average Leverage Relative to Recent Transactions: The pool
has above-average leverage relative to other recent Fitch-rated
multiborrower transactions. The pool's Fitch DSCR of 1.25x is above
both the YTD 2019 average of 1.24x and the 2018 average of 1.22x.
The pool's Fitch LTV of 106.1% is worse than the YTD 2019 average
of 102.5% and the 2018 average of 102.0%.

High Multifamily Exposure: Loans secured by multifamily properties
represent 31.8% of the pool by balance. Four of the top 10 loans
are backed by multifamily properties. The total multifamily
concentration exceeds both the YTD 2019 average of 13.5% and the
2018 average of 11.6%. Multifamily properties in Fitch's model have
a lower probability of default than other property types, all else
equal.

Less Concentrated Pool: The top 10 loans total 44.7% of the pool,
which is lower than the average of 51.2% for YTD 2019 and the
average of 50.6% for 2018. The pool's loan concentration index
(LCI) is 310 and the sponsor concentration index (SCI) is 484. The
LCI is below the respective average of 381 as of YTD 2019 and the
SCI is above the respective average of 403 as of YTD 2019.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 10.3% 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
CSAIL 2019-C18 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 'Asf' could result. In a more
severe scenario, in which NCF declined a further 30% from Fitch's
NCF, a downgrade of the junior 'AAAsf' certificates to 'BBBsf'
could result.


FREDDIE MAC 2019-4: Fitch to Rate Class M Debt 'B-(EXP)'
--------------------------------------------------------
Fitch Ratings expects to rate Freddie Mac's risk-transfer
transaction, Seasoned Credit Risk Transfer Trust Series 2019-4.

RATING ACTIONS

Seasoned Credit Risk Transfer Trust 2019-4

Class A-IO;  LT NR(EXP)sf; Expected Rating

Class B;     LT NR(EXP)sf; Expected Rating

Class B-IO;  LT NR(EXP)sf; Expected Rating

Class BBIO;  LT NR(EXP)sf; Expected Rating

Class BX;    LT NR(EXP)sf; Expected Rating

Class BXS;   LT NR(EXP)sf; Expected Rating

Class HA;    LT NR(EXP)sf; Expected Rating

Class HB;    LT NR(EXP)sf; Expected Rating

Class HT;    LT NR(EXP)sf; Expected Rating

Class HV;    LT NR(EXP)sf; Expected Rating

Class HZ;    LT NR(EXP)sf; Expected Rating

Class IM;    LT NR(EXP)sf; Expected Rating

Class M;     LT B-(EXP)sf; Expected Rating

Class M55D;  LT NR(EXP)sf; Expected Rating

Class M55E;  LT NR(EXP)sf; Expected Rating

Class M55G;  LT NR(EXP)sf; Expected Rating

Class M55I;  LT NR(EXP)sf; Expected Rating

Class MA;    LT NR(EXP)sf; Expected Rating

Class MB;    LT NR(EXP)sf; Expected Rating

Class MC;    LT NR(EXP)sf; Expected Rating

Class MD;    LT NR(EXP)sf; Expected Rating

Class MT;    LT NR(EXP)sf; Expected Rating

Class MV;    LT NR(EXP)sf; Expected Rating

Class MZ;    LT NR(EXP)sf; Expected Rating

Class XS-IO; LT NR(EXP)sf; Expected Rating

TRANSACTION SUMMARY

SCRT 2019-4 represents Freddie Mac's 13th seasoned credit risk
transfer transaction issued. SCRT 2019-4 consists of three
collateral groups that comprise 12,347 seasoned performing and
re-performing mortgages, with a total balance of approximately
$2.35 billion, of which $329.9 million, or 14.1%, is in
non-interest-bearing deferred principal amounts as of the cutoff
date. The three collateral groups represent loans that have
additional interest rate increases outstanding due to the terms of
the modification, and those that are expected to remain fixed for
the remainder of the term. Among the loans that are fixed, the
groups are further distinguished by loans that include a portion of
principal forbearance as well as the interest rate on the loans.
The distribution of principal and interest (P&I) and loss
allocations to the rated note is based on a senior subordinate,
sequential structure.

KEY RATING DRIVERS

Distressed Performance History (Negative): The collateral pool
comprises primarily peak-vintage re-performing loans (RPLs), all of
which have been modified. Roughly 75% of the pool have been paying
on time for the past 24 months, per the Mortgage Bankers
Association (MBA) methodology, and none of the loans have
experienced a delinquency within the past

12 Months: The pool has a weighted average (WA) sustainable loan to
value ratio (sLTV) of 85.7%, and the WA model FICO score is 678.

Low Operational Risk (Positive): Operational risk is well
controlled for this transaction. Freddie Mac has an established
track record in residential mortgage activities and is assessed as
an 'Above Average' aggregator by Fitch. Select Portfolio Servicing,
Inc. (SPS) is the named servicer for this transaction and is rated
'RPS1-' for primary servicing functions.

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

Representation Framework (Negative): Fitch considers the
representation, warranty and enforcement (RW&E) mechanism construct
for this transaction as weaker than that of other Fitch-rated RPL
deals. The weakness is due to the exclusion of a number of reps
that Fitch views as consistent with a full framework as well as the
limited diligence that may have otherwise acted as a mitigant.
Additionally, Freddie Mac as rep provider will only be obligated to
repurchase a loan, pay an indemnity loss amount or cure the
material breach prior to Nov. 10, 2022. However, Fitch believes
that the defect risk is lower relative to other RPL transactions
because the loans were subject to Freddie Mac's loan-level review
process in place at the time the loan became delinquent. Therefore,
Fitch treated the construct as Tier 3 and increased its 'B-sf'
expected loss expectations by 19bps to account for the weaknesses
in the reps.

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

No Servicer P&I Advances (Mixed): The servicer will not advance
delinquent monthly payments of P&I, which reduces liquidity to the
trust. However, as P&I advances made on behalf of loans that become
delinquent and eventually liquidate reduce liquidation proceeds to
the trust, the loan-level loss severities (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, provides for ultimate
payment of interest to the rated class.

Third-Party Due Diligence Review (Negative): Third-party due
diligence was conducted on a statistically random sample of
approximately 15.4% of the transaction. The review was performed by
a TPR firm assessed as 'Acceptable - Tier 1' by Fitch.
Approximately 37% of the sample received a diligence grade of 'C'
or 'D' for regulatory compliance exceptions; approximately 45% of
these exceptions are due to missing final documentation that
prevented conclusive testing of predatory lending. Fitch adjusted
its 'B-sf' loss expectations by


GREENWICH CAPITAL 2004-GG1: Moody's Lowers Class G Certs to B1
--------------------------------------------------------------
Moody's Investors Service, affirmed the ratings on six classes and
downgraded the rating on one class in Greenwich Capital Commercial
Funding Corp., 2004-GG1, Commercial Mortgage Pass-Through
Certificates, Series 2004-GG1, as follows:

Cl. F, Affirmed Baa1 (sf); previously on Aug 23, 2018 Affirmed Baa1
(sf)

Cl. G, Downgraded to B1 (sf); previously on Aug 23, 2018 Affirmed
Ba2 (sf)

Cl. H, Affirmed Caa3 (sf); previously on Aug 23, 2018 Affirmed Caa3
(sf)

Cl. J, Affirmed C (sf); previously on Aug 23, 2018 Affirmed C (sf)

Cl. K, Affirmed C (sf); previously on Aug 23, 2018 Affirmed C (sf)

Cl. L, Affirmed C (sf); previously on Aug 23, 2018 Affirmed C (sf)

Cl. XC*, Affirmed C (sf); previously on Aug 23, 2018 Affirmed C
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The rating on Cl. F was affirmed based on the transaction key
metrics, including Moody's loan-to-value (LTV) ratio, being within
acceptable ranges. The ratings on four P&I classes were affirmed
because the ratings are consistent with Moody's expected loss plus
realized losses.

The rating on Cl. G was downgraded due to ongoing interest
shortfalls caused by 100% of the remaining collateral being in
special servicing. The interest shortfalls to this class are
expected to continue primarily due to the appraisal reduction and
previous A-note / B-note modification for the remaining asset in
the pool.

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

Moody's rating action reflects a base expected loss of 42.3% of the
current pooled balance, compared to 39.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 4.6% of the
original pooled balance, compared to 4.5% 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 an improvement in pool
performance.

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the October 11, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 96% to $103.1
million from $2.6 billion at securitization. The certificates are
collateralized by a previously modified A/B note split secured by
one property. As of the October 2019 remittance statement
cumulative interest shortfalls were $17.7 million. Moody's
anticipates interest shortfalls will continue because of the
exposure to modified loan and specially serviced loans. Interest
shortfalls are caused by special servicing fees, including workout
and liquidation fees, appraisal entitlement reductions (ASERs),
loan modifications and extraordinary trust expenses.

Twenty loans have been liquidated from the pool at a loss,
contributing to an aggregate realized loss of $77.1 million (for an
average loss severity of 32%).

The remaining loans are the Aegon Center - A Note Loan ($82.0
million -- 79.5% of the pool) and the Aegon Center - B Note ($21.1
million -- 20.5% of the pool), which are secured by a 34-story,
Class A, office building located in the CBD of Louisville,
Kentucky. The property has been rebranded from the Aegon Center to
400 West Market following the departure of Aegon in early 2013. In
addition to the office component, the collateral also consists of
the leasehold interest in an adjacent 504-space parking garage. The
original loan was transferred to the special servicer in March 2012
due to imminent monetary default, but was returned to the master
servicer in November 2013 after a loan modification. The
modification resulted in an A-note / B-note split, temporarily
reduced the A-note interest rate, and extended the maturity of the
loan through April 2019. Both loans returned to special servicing
in March 2019. The property was 81% leased as of September 2019.
Moody's has assumed a significant loss on the $21.1 million B Note.
The special servicer indicated they are pursuing foreclosure while
marketing the note for sale.


GS MORTGAGE 2016-RENT: Fitch Affirms B-sf Rating on Cl. F Certs
---------------------------------------------------------------
Fitch Ratings affirmed all classes of GS Mortgage Securities
Corporation Trust 2016-RENT commercial mortgage pass-through
certificates series 2016-RENT.

RATING ACTIONS

GS Mortgage Securities Corporation Trust 2016-RENT

Class A 36251GAA2;   LT AAAsf Affirmed;  previously at AAAsf

Class B 36251GAG9;   LT AA-sf Affirmed;  previously at AA-sf

Class C 36251GAJ3;   LT A-sf Affirmed;   previously at A-sf

Class D 36251GAL8;   LT BBB-sf Affirmed; previously at BBB-sf

Class E 36251GAN4;   LT BB-sf Affirmed;  previously at BB-sf

Class F 36251GAQ7;   LT B-sf Affirmed;   previously at B-sf

Class X-A 36251GAC8; LT AAAsf Affirmed;  previously at AAAsf

Class X-B 36251GAE4; LT AA-sf Affirmed;  previously at AA-sf

KEY RATING DRIVERS

Stable Performance: The underlying portfolio performance is
generally in line with Fitch's issuance expectations. Occupancy as
of March 2019 has dipped slightly to 90.4% from 93.6% at issuance.
The servicer-reported YE 2018 NCF of $32.5 million is in line with
Fitch's NCF at issuance.

Collateral Quality: Fitch assigned the portfolio a property quality
grade of 'B+' at issuance. As of that time, the sponsor had already
spent $32.9 million in capital improvements since acquiring the
portfolio, including $22.7 million on unit conversions and
renovations and $10.2 million on base-building upgrades with plans
to continue renovating units as they became vacant. As of September
2019, approximately 301 units (17.4% of the portfolio) have
undergone a heavy turn/renovation beyond the standard paint and
clean since YE 2015.

Strong Multifamily Market: The properties are all located in the
tight San Francisco multifamily market. The 61 properties are
located in several central neighborhoods, including Nob Hill,
Mission, Pacific Heights, Downtown San Francisco, Russian Hill and
the Marina District. Per Reis, the average vacancy rate was 3.9%
for third-quarter 2019, down from 4.8% for 2018.

Below Market Rents: All the units in the portfolio are subject to
rent-control restrictions. Given the pace of rent growth in the San
Francisco market over the last three years, the gap between the
portfolio's average monthly rate and the market rate has widened.
The portfolio is achieving an average monthly rate of $2,567 per
unit, according to the YE 2018 statement. In the aggregate,
in-place rents are approximately 26.5% below market, compared with
28% below market at issuance. Reis projects rental rates will
continue to grow year-over-year by 3.3% on average over the next
four years.

High Fitch Leverage: Fitch's stressed DSCR and loan to value for
the whole loan debt are 0.83x and 105.1%, respectively, based on a
1.6% discount to the YE 2018 net cash flow and an 8.00% refinance
constant and a 7.00% cap rate.

Additional Debt: The trust loan is pari passu with two non-trust
notes totaling $130,250,000. In addition, there is a non-trust
mezzanine loan of $196,500,000.

Loan Structure: A capex reserve account was funded at issuance in
the amount of $19 million to reimburse the sponsor for unit
renovation and turnover costs. Monthly deposits continue to be made
to this fund, which has a current balance of approximately
$219,000. Monthly real estate taxes and insurance are escrowed.
Additionally, a cash management event will be triggered in the
event that the debt service coverage ratio (DSCR) dips below
1.10x.

RATING SENSITIVITIES

The Rating Outlooks on all classes remain Stable. Rating changes
are not anticipated unless there is a material change in the
portfolio's occupancy or cash flow. Overall performance has been
consistent with issuance expectations.

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

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


GS MORTGAGE 2019-GSA1: Fitch Assigns B-sf Rating on Cl. G-RR Certs
------------------------------------------------------------------
Fitch Ratings assigned ratings and Rating Outlooks to GS Mortgage
Securities Trust 2019-GSA1 commercial mortgage pass-through
certificates, series 2019-GSA1.

RATING ACTIONS

Goldman Sachs Mortgage Securities Trust 2019-GSA1

Class A-1;  LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-2;  LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-3;  LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-4;  LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-AB; LT AAAsf New Rating;  previously at AAA(EXP)sf

Class A-S;  LT AAAsf New Rating;  previously at AAA(EXP)sf

Class B;    LT AA-sf New Rating;  previously at AA-(EXP)sf

Class C;    LT A-sf New Rating;   previously at A-(EXP)sf

Class D;    LT BBBsf New Rating;  previously at BBB(EXP)sf

Class E;    LT BBB-sf New Rating; previously at BBB-(EXP)sf

Class F-RR; LT BB-sf New Rating;  previously at BB-(EXP)sf

Class G-RR; LT B-sf New Rating;   previously at B-(EXP)sf

Class H-RR; LT NRsf New Rating;   previously at NR(EXP)sf

Class X-A;  LT AAAsf New Rating;  previously at AAA(EXP)sf

Class X-B;  LT AA-sf New Rating;  previously at A-(EXP)sf

Class X-D;  LT BBB-sf New Rating; previously at BBB-(EXP)sf

TRANSACTION SUMMARY

Since Fitch published its expected ratings on Oct. 22, 2019, the
balances for class A-3, A-4 and X-B were finalized. At the time the
expected ratings were assigned, the exact initial certificate
balances for class A-3 and A-4 were unknown and expected to be
approximately $542,578,000 in aggregate, subject to a 5% variance.
The final class balances for class A-3 and A-4 are $181,247,000 and
$361,331,000, respectively. In addition, class X-B decreased in
size to $39,971,000 from $76,701,000 as it now reflects the
aggregate certificate balance of the related class B. Fitch's
rating on class X-B has been updated to 'AA-sf' to reflect the
rating of the lowest referenced tranche whose payable interest has
an impact on the interest-only payments. The classes reflect the
final ratings and deal structure.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 49 loans secured by 84
commercial properties having an aggregate principal balance of
$864,235,961 as of the cut-off date. The loans were contributed to
the trust by Argentic Real Estate Finance LLC, Goldman Sachs
Mortgage Securities, Starwood Mortgage Capital LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 74.0% of the properties
by balance, cash flow analysis of 86.2% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

High Fitch Leverage: The pool's Fitch LTV is 109.6%, which is above
the 2018 and 2019 YTD averages of 102.0% and 101.8%, respectively,
for other Fitch-rated multiborrower transactions. The pool's Fitch
DSCR of 1.27x is higher than both the 2018 and 2019 YTD averages of
1.22x and 1.25x, respectively; however, the pool's weighted average
coupon was just 3.82%.

Low Mortgage Coupons: The pool's weighted average (WA) mortgage
rate is 3.82%, which is well below historical averages and lower
than the YTD 2019 average of 4.56%, for Fitch-rated conduit
multiborrower transactions. Fitch accounted for increased refinance
risk in a higher interest rate environment by reviewing an interest
rate sensitivity that assumes an interest rate floor of 5.0% for
the term risk for most property types, 4.5% for multifamily
properties and 6.0% for hotel properties, in conjunction with
Fitch's stressed refinance rates, which were 9.47% on a WA basis.

Above-Average Multifamily Exposure: The pool's multifamily
concentration is 27.1%, which is significantly above the 2018 and
YTD 2019 averages of 11.6% and 13.6%, respectively. Loans secured
by multifamily properties have a lower than average probability of
default in Fitch's multiborrower model, all else equal.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 9.7% below
the most recent year's NOI for properties for which a full-year NOI
was provided, excluding properties that were stabilizing during
this period. Unanticipated further declines in property-level NCF
could result in higher defaults and loss severities on defaulted
loans and in potential rating actions on the certificates.

Fitch evaluated the sensitivity of the ratings assigned to the GSMS
2019-GSA1 certificates and found that the transaction displays
average sensitivities to further declines in NCF. In a scenario in
which NCF declined a further 20% from Fitch's NCF, a downgrade of
the junior 'AAAsf' certificates to 'A+sf' could result. In a more
severe scenario, in which NCF declined a further 30% from Fitch's
NCF, a downgrade of the junior 'AAAsf' certificates to 'BBBsf'
could result.


GSAMP TRUST 2005-NC1: Moody's Lowers Class M-1 Debt Rating to B1
----------------------------------------------------------------
Moody's Investors Service downgraded the rating of one tranche from
GSAMP Trust 2005-NC1, backed by subprime mortgage loans.

The complete rating action is as follows:

Issuer: GSAMP Trust 2005-NC1

Cl. M-1, Downgraded to B1 (sf); previously on Feb 21, 2014 Upgraded
to Ba2 (sf)

RATINGS RATIONALE

The rating downgrade on Class M-1 is primarily due to the
outstanding interest shortfalls on the bond that are not expected
to be reimbursed. As of October 2019, the Class M-1 has an
outstanding interest shortfall of $55.1K. The action also reflects
the recent performance of the underlying collateral and Moody's
updated loss expectation on the pool.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.6% in October 2019 from 3.8% in
October 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, the performance of RMBS continues to remain highly
dependent on servicer procedures. Any changes resulting from
servicing transfers, or other policy or regulatory shifts can
impact the performance of this transaction.


HOME BOUND HEALTHCARE: Gets Interim Cash Access Thru Dec. 1
-----------------------------------------------------------
The Bankruptcy Court authorized Home Bound Healthcare, Inc., to use
cash collateral for the period from Nov. 1, 2019 to Dec. 1, 2019,
pursuant to the budget.  

As adequate protection, (i) the Internal Revenue Service; (ii) the
Illinois Department of Revenue and (iii) CadleRock Joint Venture,
LP are granted replacement liens on the property of the Debtor's
estate and on all the revenues, profits and avails generated
therefrom after the Petition Date, with the same validity, extent
and priority as the liens held pre-petition.  The Debtor will pay
as additional adequate protection (i) $5,000 to the IRS; (ii)
$1,000 to IDOR; and (iii) $1,500 to CadleRock, on Nov. 15, 2019.

The Debtor is also directed to cure any missing tax returns by
filing said returns by the due date.

The Debtor's motion is set for status on Nov. 27, 2019 at 10 a.m.

                 About Home Bound Healthcare

Home Bound Healthcare, Inc., is a home health care company that
offers outpatient therapy, nursing, occupational, and
rehabilitation services.

Home Bound Healthcare, based in Flossmoor, IL, filed a Chapter 11
petition (Bankr. N.D. Ill. Case No. 19-05760) on March 5, 2019.  In
the petition signed by Julieta Mitra, president, the Debtor was
estimated to have $500,000 to $1 million in assets and $1 million
to $10 million in liabilities.  The Hon. Janet S. Baer oversees the
case.  John D. Ioakimidis, Esq., at John D. Ioakimidis, Attorney at
Law, serves as bankruptcy counsel to the Debtor.


JP MORGAN 2011-C3: Fitch Lowers Ratings on 3 Tranches to CCC
------------------------------------------------------------
Fitch Ratings downgraded four classes and affirmed five classes of
J.P. Morgan Chase Commercial Mortgage Securities Corp. Commercial
Mortgage Pass-Through Certificates series 2011-C3.

RATING ACTIONS

JPMCC 2011-C3

Class A-4 46635TCG5; LT AAAsf Affirmed;  previously at AAAsf

Class B 46635TAU6;   LT AAsf Affirmed;   previously at AAsf

Class C 46635TAX0;   LT Asf Affirmed;    previously at Asf

Class D 46635TBA9;   LT BBB+sf Affirmed; previously at BBB+sf

Class E 46635TBD3;   LT Bsf Downgrade;   previously at BBB-sf

Class G 46635TBK7;   LT CCCsf Downgrade; previously at BBsf

Class H 46635TBN1;   LT CCCsf Downgrade; previously at Bsf

Class J 46635TBR2;   LT CCCsf Downgrade; previously at B-sf

Class X-A 46635TAN2; LT AAAsf Affirmed;  previously at AAAsf

KEY RATING DRIVERS

Increased Loss Expectations: The downgrades of classes E, G, H and
J reflect the four Fitch Loans of Concern (FLOCs; 55.5%), which
include two regional malls (36.5%), the Holyoke Mall and Sangertown
Square, that have suffered performance deterioration. Both mall
loans share the same sponsor and mature in January 2021 and
February 2021, respectively; substantial losses are possible if
they are unable to obtain refinancing at maturity.

The pool has become increasingly concentrated with only 16 of the
original 45 loans remaining. The largest loan, the Holyoke Mall,
accounts for 28.2% of the pool, while the top five loans account
for 76.3% of the pool. Five non-defeased loans (41.2%) are secured
by retail properties, including the two regional malls designated
as FLOCs.

Fitch Loans of Concern: The largest FLOC, the Holyoke Mall (28.2%),
is secured by a 1.3 million sf portion of a 1.5 million sf regional
mall located in Holyoke, MA. Collateral occupancy declined to
approximately 74.2% as of the September 2019 rent roll from 88.1%
at YE 2017 after Babies "R" Us (2.7% of NRA), Sears (13.5%), and
A.C. Moore (1.7%) vacated in 2018 and Forever 21 downsized its
space by 37,319 sf (2.8%) in July 2018. Best Buy (3.8%) and
JCPenney (11.2%) recently extended their leases through January
2025 and October 2025, respectively. In-line sales were $421 psf
(excluding Apple) as of TTM September 2018 (the most recent
available reporting).

The second FLOC, The Galleria Office Towers (17.7%), is secured by
three adjacent office buildings totaling 1.1 million sf and located
in downtown Houston, TX. Property occupancy declined to 65.1% as of
the July 2019 rent roll from 75.2% at YE 2018 following the
departures of UBS Financial Services (4.4%) and Merrill Lynch
Wealth Management (4.3%) in March 2019 and May 2019, respectively.
Ten tenants representing approximately 20.9% of NRA have exposure
to the oil and gas sector.

The third FLOC, Sangertown Square (8.3%), is secured by an 894,127
sf regional mall located in New Hartford, NY. After Sears vacated
its collateral anchor space in July 2015, Boscov's re-leased the
space within the year; however, cash flow declined substantially as
Sears paid approximately $1.2 million in expense reimbursements
annually, whereas Boscov's currently pays none. While collateral
occupancy recovered to 95.5% as of the August 2019 rent roll, the
servicer-reported YTD June 2019 NOI debt service coverage ratio
fell to 1.13x from 1.48x at YE 2014 prior to Sears' departure.
In-line sales were reported as $326 psf as of TTM September 2018.

The fourth FLOC, Time Warner Building - Syracuse (1.3%), is secured
by a 108,602 sf single-tenant office property located in East
Syracuse, NY that has significant potential for maturity default
due to the tenant's lease expiration at loan maturity in November
2020.

Increased Credit Enhancement: As of the October 2019 distribution
date, the pool's aggregate principal balance paid down by 55.9% to
$658.2 million from $1.503 billion at issuance. Only one loan, the
specially serviced Turnpike Mall, has disposed since Fitch's last
rating action with a loss of $11.1 million (69.9% of issuance
balance). Total deal losses since issuance have increased to $17.0
million. Four loans (20.1%) are fully defeased. There are no
specially serviced or delinquent loans. All remaining loans are
currently amortizing. The entire pool is scheduled to mature
between October 2020 and March 2021. Interest shortfalls totaling
$93,431 are currently affecting the non-rated (NR) class.

Alternative Loss Considerations: Fitch performed an additional
sensitivity scenario that assumed potential outsized losses of 50%,
100% and 50%, respectively, on the balloon balances of the Holyoke
Mall, Sangertown Square and Time Warner Building - Syracuse loans.
The downgrades to classes E, G, H and J and the Negative Rating
Outlooks on classes A-4, B, C, D, E and X-A reflect the base case
and alternative loss scenarios, respectively.

RATING SENSITIVITIES

The Negative Rating Outlooks on classes A-4, B, C, D, E and X-A
reflect refinance concerns and additional sensitivity analysis
performed on the FLOCs, particularly the Holyoke Mall. These
classes may be downgraded should performance of the FLOCs decline
further, transfer to special servicing or if they fail to pay off
at maturity. Rating upgrades, although unlikely due to increasing
pool concentration and adverse selection, may occur with improved
pool performance and additional paydown or defeasance. The
distressed classes G, H and J may be downgraded further as losses
are realized or as the likelihood of losses becomes more apparent.

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

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

ESG CONSIDERATIONS

JPMCC 2011-C3 has an ESG Relevance Score of 4 for exposure to
social impacts due to the pool's exposure to two regional malls
that are underperforming as a result of a sustained structural
shift in consumer preference to shopping, which has a negative
impact on the credit profile, and is relevant to the Ratings and
Outlooks.


MONROE CAPITAL IX: Moody's Rates $29.250MM Class E Notes Ba3
------------------------------------------------------------
Moody's Investors Service assigned ratings to nine classes of debt
issued by Monroe Capital MML CLO IX, Ltd.

Moody's rating action is as follows:

US$50,000,000 Class A Senior Floating Rate Loans maturing 2031 (the
"Class A Loans"), Definitive Rating Assigned Aaa (sf)

US$190,000,000 Class A-1 Senior Floating Rate Notes Due 2031 (the
"Class A-1 Notes"), Definitive Rating Assigned Aaa (sf)

US$12,000,000 Class A-2 Senior Fixed Rate Notes Due 2031 (the
"Class A-2 Notes"), Definitive Rating Assigned Aaa (sf)

US$39,000,000 Class B-1 Floating Rate Notes Due 2031 (the "Class
B-1 Notes"), Definitive Rating Assigned Aa2 (sf)

US$6,000,000 Class B-2 Fixed Rate Notes Due 2031 (the "Class B-2
Notes"), Definitive Rating Assigned Aa2 (sf)

US$33,500,000 Class C-1 Deferrable Mezzanine Floating Rate Notes
Due 2031 (the "Class C-1 Notes"), Definitive Rating Assigned A2
(sf)

US$7,000,000 Class C-2 Deferrable Mezzanine Fixed Rate Notes Due
2031 (the "Class C-2 Notes"), Definitive Rating Assigned A2 (sf)

US$27,000,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2031 (the "Class D Notes"), Definitive Rating Assigned Baa3 (sf)

US$29,250,000 Class E Deferrable Mezzanine Floating Rate Notes Due
2031 (the "Class E Notes"), Definitive Rating Assigned Ba3 (sf)

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

RATINGS RATIONALE

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

Monroe Capital MML IX is a managed cash flow CLO. The issued debt
will be collateralized primarily by small and medium enterprise
loans. At least 95% of the portfolio must consist of first lien
senior secured loans and eligible investments, and up to 5.0% of
the portfolio may consist of second lien loans and unsecured loans.
The portfolio is approximately 72% ramped as of the closing date.

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

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

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

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

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

Par amount: $450,000,000

Diversity Score: 45

Weighted Average Rating Factor (WARF): 3463

Weighted Average Spread (WAS): 4.45%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 46.5%

Weighted Average Life (WAL): 8.00 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.

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

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

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


MORGAN STANLEY 2004-IQ8: Fitch Affirms D Ratings on 5 Tranches
--------------------------------------------------------------
Fitch Ratings affirmed seven classes of Morgan Stanley Capital I
Trust, Commercial Mortgage Trust Pass-Through Certificates, series
2004-IQ8.

RATING ACTIONS

Morgan Stanley Capital I Trust 2004-IQ8

Class G 61745MP64; LT AAAsf Affirmed; previously at AAAsf

Class H 61745MP72; LT BBsf Affirmed;  previously at BBsf

Class J 61745MP80; LT Dsf Affirmed;   previously at Dsf

Class K 61745MP98; LT Dsf Affirmed;   previously at Dsf

Class L 61745MQ22; LT Dsf Affirmed;   previously at Dsf

Class M 61745MQ30; LT Dsf Affirmed;   previously at Dsf

Class N 61745MQ48; LT Dsf Affirmed;   previously at Dsf

KEY RATING DRIVERS

Stable Loss Expectations: Pool performance and loss expectations
remain stable. No loans are delinquent and no loans are in special
servicing. Two loans (14.4% of pool) were designated Fitch Loans of
Concern (FLOCs) due to performance declines and rollover concerns.

Increased Credit Enhancement; Amortization; Lower Leverage: Credit
enhancement has increased as the pool has been reduced by
approximately 20% since the prior review from amortization and the
repayment of 11 loans ($354,887 combined balance at disposition),
of which eight paid at maturity, one prepaid with yield
maintenance, one prepaid with premium and one prepaid during the
open period.

Only eight of the original 100 loans remain, all, which are fully
amortizing. As of the October 2019 distribution date, the pool's
aggregate principal balance has been reduced by 98.9% to $8.4
million from $759.2 million at issuance. There have been $15.3
million (2% of original pool balance) in realized losses to date.
Cumulative interest shortfalls of $1.1 million are currently
affecting classes J through O.

Concentrated Pool: Due to the highly concentrated nature of the
pool, Fitch performed a sensitivity analysis, which 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.

All eight remaining loans are fully amortizing, have been
significantly paid down since issuance and have relatively low
leverage. The largest loan is secured by a single tenant Giant
grocery store (parent Ahold is rated BBB+sf/Stable) in Baltimore
City, MD (29.3% of pool) with loan maturity in August 2024 and
lease expiration in July 2024. Two loans are secured by
single-tenant Walgreens (rated BBBsf/Negative) (32.3%), located in
secondary markets with loan maturities in 2028 and 2029 and lease
expirations nearly co-terminus with maturity. The remaining loans
(38.4%) mature in 2024 and are backed by collateral primarily in
secondary markets.

Fitch Loans of Concern: Two loans (14.4% of pool) have been
designated as FLOCs. The Meridian Office Building (8.6%), secured
by a 30,582 sf office property located in Tempe, AZ, and Tooele
Landing (5.8%), secured by a 10,989 sf retail center located in
Tooele, UT, were both designated FLOCs for low DSCR and rollover
concerns. Both loans have remained current since issuance and
mature in 2024.

Loan Maturities: The loan maturity schedule includes six loans
(67.7%) in 2024, one loan (16.3%) in 2028 and one loan (16%) in
2029.

RATING SENSITIVITIES

The Outlooks for class G and class H are considered Stable. Class G
is currently the first-pay class, with continued increasing credit
enhancement from amortization and full repayment within
approximately nine months. While credit enhancement is also
expected to improve for class H from amortization, upward rating
migration is limited due to the collateral quality, the longer
dated maturities and the thin supporting tranche, which has
incurred losses. Downgrades, although unlikely, could occur if pool
performance declines significantly.

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

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3, which indicates ESG issues
are credit neutral or have only a minimal credit impact on MSCI
2004-IQ8, either due to their nature or the way in which they are
being managed by MSCI 2004-IQ8.


PRUDENTIAL SECURITIES 1999-C2: Moody's Affirms C on 2 Classes
-------------------------------------------------------------
Moody's Investors Service upgraded the rating on one class and
affirmed the ratings on two classes in Prudential Securities
Secured Financing Corporation 1999-C2, Commercial Mortgage
Pass-Through Certificates, Series 1999-C2, as follows:

Cl. N, Upgraded to Aa1 (sf); previously on May 2, 2018 Upgraded to
Ba1 (sf)

Cl. A-EC*, Affirmed C (sf); previously on May 2, 2018 Affirmed C
(sf)

Cl. A-EC2*, Affirmed C (sf); previously on May 2, 2018 Affirmed C
(sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on Cl. N was upgraded due to the class being fully
covered by defeasance, however, the class had previous interest
shortfalls for seven months between 2009 and 2010.

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

Moody's rating action reflects a base expected loss of 0.6% of the
current pooled balance. Moody's base expected loss plus realized
losses is now 2.0% of the original pooled balance.

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 an
increase in realized losses from specially serviced loans or
interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the October 18, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by over 99% to $4.5
million from $869 million at securitization. The certificates are
collateralized by four mortgage loans. Three loans, constituting
87% of the pool, have defeased and are secured by US government
securities. The other loan is in special servicing.

Seventeen loans have been liquidated from the pool, resulting in or
contributing to an aggregate realized loss of $17.3 million (for an
average loss severity of 14.6%).

The loan in special servicing is the Walgreens Drug Store Loan
($580,289 -- 12.8% of the pool), which is secured by a free
standing Walgreens located 20 miles west of the Detroit CBD in
Wayne, Michigan. The loan passed its anticipated repayment date
(ARD) in 2009 and has since amortized 81% from securitization. The
loan transferred to special servicing in August 2018 for monetary
default. Walgreens provided notice in October 2018 of its intent to
vacate if they were unable to lower the significantly above market
rent payments. Walgreens subsequently executed a lease extension
through 2059 with termination options every five years. The loan
became REO in August 2019 and the special servicer indicated the
property has been listed for sale.


TOWD POINT 2019-4: Moody's Assigns Ba3 Rating on 3 Tranches
-----------------------------------------------------------
Moody's Investors Service assigned definitive ratings to seventeen
classes of notes issued by Towd Point Mortgage Trust 2019-4.

The notes are backed by one pool of 21,631 re-performing first lien
residential mortgage loans with an aggregate unpaid principal
balance of $3,668,304,917. The borrowers have a non-zero updated
weighted average FICO score of 663 and a weighted average current
LTV of 77.0% as of September 30, 2019. Select Portfolio Servicing,
Inc. will be the primary servicer for the collateral pool. FirstKey
Mortgage, LLC will be the asset manager for the transaction.

The complete rating actions are as follows:

Issuer: Towd Point Mortgage Trust 2019-4

Cl. A1, Definitive Rating Assigned Aaa (sf)

Cl. A2, Definitive Rating Assigned Aa2 (sf)

Cl. A2A, Definitive Rating Assigned Aa2 (sf)

Cl. A2B, Definitive Rating Assigned Aa2 (sf)

Cl. A3, Definitive Rating Assigned Aa1 (sf)

Cl. A4, Definitive Rating Assigned A1 (sf)

Cl. A5, Definitive Rating Assigned Baa1 (sf)

Cl. M1, Definitive Rating Assigned A3 (sf)

Cl. M1A, Definitive Rating Assigned A3 (sf)

Cl. M1B, Definitive Rating Assigned A3 (sf)

Cl. M2, Definitive Rating Assigned Baa3 (sf)

Cl. M2A, Definitive Rating Assigned Baa3 (sf)

Cl. M2B, Definitive Rating Assigned Baa3 (sf)

Cl. B1, Definitive Rating Assigned Ba3 (sf)

Cl. B1A, Definitive Rating Assigned Ba3 (sf)

Cl. B1B, Definitive Rating Assigned Ba3 (sf)

Cl. B2, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected loss on TPMT 2019-4's collateral pool is 9.50% in
its base case scenario and 34.50% at a stress level consistent with
the Aaa (sf) rating. Its loss estimate takes into account the
historical performance of the loans that have similar collateral
characteristics as the loans in the pool, and also incorporate an
expectation of a continued strong credit environment for RMBS,
supported by a current strong housing price environment.

Moody's estimated expected losses using two approaches -- (1)
pool-level approach, and (2) re-performing loan level analysis. In
the pool-level approach, Moody's estimated losses on the pool by
applying its assumptions on expected future delinquencies, default
rates, loss severities and prepayments as observed on similar
seasoned collateral. Moody's projected future annual delinquencies
for eight years by applying an initial annual default rate
assumption adjusted for future years through delinquency burnout
factors. The delinquency burnout factors reflect its future
expectations of the economy and the U.S. housing market. Based on
the loan characteristics of the pool and the demonstrated pay
histories, Moody's applied an initial expected annual delinquency
rate of 10.00% for first lien loans for year one. Moody's then
calculated future delinquencies using default burnout and voluntary
conditional prepayment rate assumptions. Moody's aggregated the
delinquencies and converted them to losses by applying pool
specific lifetime default frequency and loss severity assumptions.
Its default, CPR and loss severity assumptions are based on actual
observed performance of agency-eligible and non-agency-eligible
seasoned performing, re-performing modified loans and prior TPMT
deals. In applying its loss severity assumptions, Moody's accounted
for the lack of principal and interest advancing in this
transaction.

Moody's also conducted a loan level analysis on TPMT 2019-4's
collateral pool. Moody's applied loan-level baseline lifetime
propensity to default assumptions and considered the historical
performance of seasoned loans with similar collateral
characteristics and payment histories. Moody's then adjusted this
base default propensity up for, if any, (1) adjustable-rate loans,
(2) loans that have the risk of coupon step-ups and (3) loans with
high updated loan to value ratios (LTVs). Moody's applied a higher
baseline lifetime default propensity for interest-only loans, using
the same adjustments. To calculate the final expected loss for the
pool, Moody's applied a loan-level loss severity assumption based
on the loans' updated estimated LTVs. Moody's further adjusted the
loss severity assumption upwards for loans in states that give
super-priority status to homeowner association (HOA) liens, to
account for potential risk of HOA liens trumping a mortgage.

The final expected loss for the collateral pool also reflects the
due diligence findings of three independent third-party review
(TPR) firms as well as its assessment of TPMT 2019-4's
representations & warranties (R&Ws) framework.

Unlike previous TPMT transactions Moody's has rated, FirstKey, as
seller, is not required to pay by the 18th month after the closing
date unpaid property taxes (or any resulting liens from such unpaid
taxes) or overdue payments for energy lien deficiency that exist at
closing and that may have priority over the lien of the related
mortgage, unless FirstKey, as asset manager, verifies, based on
information provided by the servicer, that all such unpaid property
taxes or energy lien deficiency either: (i) have been extinguished
by the related servicer or have otherwise been satisfied, (ii) have
been previously paid, (iii) are invalid, or (iv) constitute a lien
or charge that is subordinate to that of the related mortgage.
Consequently, the seller is no longer required to repurchase
mortgage loans for which it has not paid such delinquent taxes and
liens by the end of the 18th month after the closing date or for
which none of the conditions in clauses (i) to (iv) above have been
satisfied.

While Moody's considers this change to the roles of the asset
manager and seller to be credit negative, Moody's did not make an
adjustment to its loss levels because: (1) the amount of such
delinquent taxes and liens is small relative to the aggregate
unpaid principal balance of the pool at 0.10% and (2) the related
servicer will make a servicing advance for the payment of HOA
liens, energy lien deficiencies, real estate property taxes and
other municipal charges, but only to the extent necessary to
protect the lien of the related mortgage.

Collateral Description

TPMT 2019-4's collateral pool is primarily comprised of
re-performing first lien fixed-rate mortgage loans. Approximately
90% of the loans in the collateral pool have been previously
modified and approximately 99% are fixed-rate mortgage loans. The
majority of the loans underlying this transaction exhibit
collateral characteristics similar to that of seasoned Alt-A
mortgages.

As of the cut-off date of September 30, 2019, the collateral pool
is comprised of 21,631 first lien mortgage loans with a collateral
balance of $3,668,304,917. It is expected that approximately 23
mortgage loans (representing approximately 0.07% of the mortgage
loans) will be excluded from the pool of final mortgage loans
included in this transaction as a result of a failure to meet the
Sponsor's eligibility requirements. The expected final collateral
balance will be $3,665,760,775.

Moody's based its expected loss on 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 two factors
that most strongly influence a re-performing mortgage loan's
likelihood of re-default are the length of time that the loan has
performed since modification, and the amount of the reduction in
monthly mortgage payments as a result of modification. The longer a
borrower has been current on a re-performing loan, the less likely
they are to re-default. Approximately 69% of the borrowers of the
loans in the collateral pool have been current on their payments
for the past 24 months or more under the OTS method.

Transaction Structure

TPMT 2019-4 has a sequential priority of payments structure, in
which a given class of notes can only receive principal payments
when all the classes of notes above it have been paid off.
Similarly, losses will be applied in the reverse order of priority.
The Class A1, A2, M1, M2, B1, B2, B3, B4, and B5 notes carry a
fixed-rate coupon subject to the collateral adjusted net WAC and
applicable available funds cap. There are no performance triggers
in this transaction. Additionally, the servicer will not advance
any principal or interest on delinquent loans.

Moody's coded TPMT 2019-4's cashflows using its proprietary
cashflow tool. To assess the final rating on the notes, Moody's ran
96 different loss and prepayment scenarios. The scenarios encompass
six loss levels, four loss timing curves, and four prepayment
curves.

Third-Party Review

Three independent third-party review (TPR) firms -- Clayton
Services, LLC, AMC Diligence, LLC and Westcor Land Title Insurance
Company -- conducted due diligence for the transaction. Due
diligence was performed on about 99.8% of the loans by unpaid
principal balance for regulatory compliance, 99.8% for data
integrity, 99.5% for pay string history, and 100.0% for title and
tax review. The TPR firms reviewed compliance, data integrity and
key documents to verify that loans were originated in accordance
with federal, state and local anti-predatory laws. The TPR firms
conducted audits of designated data fields to ensure the accuracy
of the collateral tape.

Based on its analysis of the third-party review reports, Moody's
determined that a portion of the loans had legal or compliance
exceptions that could cause future losses to the trust. Moody's
incorporated an additional increase to its expected losses for
these loans to account for this risk. FirstKey Mortgage, LLC
retained AMC and Westcor to review the title and tax reports for
the loans in the pool, and will oversee AMC and Westcor and monitor
the loan sellers in the completion of the assignment of mortgage
chains. In addition, FirstKey expects a significant number of the
assignment and endorsement exceptions to be cleared within the
first eighteen months following the closing date of the
transaction. Moody's took these loans into account in its loss
analysis.

Representations & Warranties

Its ratings reflect TPMT 2019-4's weak representations and
warranties (R&Ws) framework. The representation provider, FirstKey
Mortgage, LLC is unrated by Moody's. Moreover, FirstKey's
obligations will be in effect for only thirteen months after
transaction settlement. The R&Ws themselves are weak because they
contain many knowledge qualifiers and the regulatory compliance R&W
does not cover monetary damages that arise from TILA violations
whose right of rescission has expired. While the transaction
provides a breach reserve account to cover for any breaches of
R&Ws, the target size of the account (0.25% of the current balance
of the Class A1, A2, M1 and M2) is small relative to TPMT 2019-4's
aggregate collateral pool.

Similar to recent TPMT transactions, the sponsor will not be
funding the breach reserve account at closing. On each payment
date, the paying agent will fund the reserve account from the Class
XS2 each month up to the target balance which is based on the
outstanding principal balance of the Class A1, A2, M1 and M2 notes.
Since its loss analysis already takes into account the weak R&W
framework, Moody's did not apply an additional penalty.

Transaction Parties

The transaction benefits from a strong servicing arrangement. SPS
will service all of the mortgage loans in the collateral pool.
Moody's considers the overall servicing arrangement for this pool
to be better than average given the ability and experience of the
servicer, and the servicer oversight from an experienced asset
manager in FirstKey. This arrangement strengthens the overall
servicing framework in the transaction. U.S. Bank National
Association is the indenture trustee and a custodian for the
transaction. Wells Fargo Bank, N.A. will also act as custodian. The
Delaware Trustee is Wilmington Trust, National Association.

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 Moody's original expectations
as a result of a higher number of obligors defaulting 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.


WELLS FARGO 2011-C4: Fitch Lowers Class F Certs Rating to Bsf
-------------------------------------------------------------
Fitch Ratings affirmed eight classes and downgraded two classes of
Wells Fargo Bank, N.A. commercial mortgage pass-through
certificates series 2011-C4. Three of the affirmed classes have had
their Rating Outlooks revised to Negative from Stable.

RATING ACTIONS

WFRBS Commercial Mortgage Trust 2011-C4

Class A-4 92936CAJ8;  LT AAAsf Affirmed; previously at AAAsf

Class A-FL 92936CAG4; LT AAAsf Affirmed; previously at AAAsf

Class A-FX 92936CBG3; LT AAAsf Affirmed; previously at AAAsf

Class B 92936CAS8;    LT AAsf Affirmed;  previously at AAsf

Class C 92936CAU3;    LT A+sf Affirmed;  previously at A+sf

Class D 92936CAW9;    LT A-sf Affirmed;  previously at A-sf

Class E 92936CAY5;    LT BBsf Downgrade; previously at BBB-sf

Class F 92936CBA6;    LT Bsf Downgrade;  previously at BBsf

Class G 92936CBC2;    LT CCCsf Affirmed; previously at CCCsf

Class X-A 92936CAN9;  LT AAAsf Affirmed; previously at AAAsf

KEY RATING DRIVERS

Increased Loss Expectations: Overall loss expectations have
increased since Fitch Ratings' prior rating action in January,
2019. Fitch remains most concerned about the ability of two
regional malls, Fox River Mall (13.9% of the pool) and Eastgate
Mall (2.4%), to refinance at maturity. Fitch considers these two
loans, as well as four other loans (totaling 4.8% of the pool),
Fitch Loans of Concern (FLOC). Additionally, there are two
specially serviced assets (2.5%) that are also considered FLOCs.

Fitch Loans of Concern: Six loans within the pool are considered
FLOCs and represent approximately 21% of the pool's balance. The
first FLOC is the largest loan in the pool, the Fox River Mall. The
subject is a 1.2 million sf (648,728 sf collateral) regional mall
located in Appleton, WI. The mall is anchored by JC Penney, Target,
Macy's, and Scheel's (collateral). As of year-end 2018, in-line
sales remain roughly in-line year-over-year at $375 per square foot
(PSF), but continue to remain below $385 PSF reported at issuance.
Fitch remains concerned about the ability of the loan to refinance
at the upcoming maturity date in June 2021.

The second FLOC is the tenth largest loan in the pool, the Eastgate
Mall. The mall is an 853,040 sf (561,250 sf collateral) regional
mall located in the suburbs of Cincinnati, OH. The mall is anchored
by Dillard's (clearance/outlet location), JC Penney, Sears
(expected to close in December 2019), and Kohl's. Since issuance,
sales PSF have decreased. As of 2018, total weighted-average mall
sales were $330 PSF compared to $365 PSF in 2017. Fitch is also
concerned about the ability of the loan to refinance at the
upcoming maturity date in April 2021.

The third FLOC is Quail Springs, the 12th largest loan in the pool
(2.14%). The loan is secured by a 298,610 sf suburban office
property located in Oklahoma City, OK. In 2015 and 2016, the two
largest tenants occupying approximately 50% of the net rentable
area (NRA) vacated. More recently, several new leases have been
signed, but, occupancy remains below issuance levels and there are
concerns with upcoming rollover.

The fourth FLOC is the specially serviced Wausau Center (1.6%). The
property became REO in August of 2017. As of July 2019, the mall
was 50% occupied with two of the three anchors remaining vacant.
The special servicer continues efforts to stabilize the rent roll
while preparing the property for sale. Per a local news article
dated Oct. 2, 2019, the city of Wausau agreed to lend $1 million to
two local non-profits to purchase the center. Both non-profit
groups are contributing an additional $1 million each for a total
offer price of $3 million. According to the special servicer, the
$3 million offer has been accepted and the transaction is expected
to close in 4Q19.

The fifth FLOC is the specially serviced Park Place Student Housing
(0.9%) loan. The loan is secured by a student housing property in
Fredonia, NY. The loan originally transferred to special servicing
in 2014 for imminent default and has remained with the servicer
since. The borrower remains in default but continues to make
non-default rate loan payments.

The final FLOC is the Trinet West loan (0.09%). The loan is secured
by a 27,305 sf flex industrial property located in Fresno, CA. The
property is 50% occupied, however, there are ongoing discussions
with several tenants to bring occupancy to 100%.

Increased Credit Enhancement: Credit enhancement continues to
increase, primarily due to the defeasance the pool has experienced.
Currently, there are 16 fully defeased loans totaling 36% of the
pool's balance. As of the October 2019 remittance date, the pool
had paid down approximately 32% since issuance.

Alternative Loss Considerations: In addition to modeling a base
case loss, Fitch performed an additional sensitivity scenario that
applied to the Fox River Mall and the Eastgate Mall. Due to
property type, location, declining performance and upcoming
maturity dates, a 50% loss severity was applied to the Fox River
Mall and a 100% loss severity was applied to the Eastgate Mall.
Fitch took the defeasance adjusted credit enhancement and the
liquidation of the Wassau Center into consideration in the
alternative loss scenario. The Negative Outlooks on classes B, C,
D, E, & F, reflect this scenario analysis.

Additional Considerations

Retail and Regional Mall Concentration: There is significant retail
exposure within the pool. Loans secured by retail properties
represent 47.5% of the pool, with several retail loans in the top
10. This includes the two aforementioned properties: Fox River Mall
(13.9%) and Eastgate Mall (2.4%). The transaction is also
concentrated in loan size, with the top 15 loans representing
68.55% of the pool's balance.

RATING SENSITIVITIES

Rating Outlooks on classes A-FL through A-4 remain Stable due to
increasing credit enhancement, continued paydown and expected
payoffs at maturity for the majority of the pool. The Negative
Rating Outlooks on classes B, C, D, E, and F reflect the potential
downgrade concerns as a result of the expected losses from the
specially serviced assets as well as potential refinance issues
surrounding the regional malls in the pool. Near-term upgrades are
unlikely but possible with significant paydown, defeasance, and
improved performance among the FLOCs. Downgrades to classes with
Negative Outlooks are likely should performance of the FLOC's
continue to deteriorate, if loans transfer to special servicing or
they fail to repay at the scheduled maturity date.

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

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

ESG CONSIDERATIONS

The transaction has an ESG Relevance Score of 4 for Exposure to
Social Impacts due to several malls that are underperforming as a
result of a sustained structural shift in consumer preference to
shopping, which has a negative impact on the credit profile, and is
highly relevant to the rating, resulting in downgrades to classes E
and F and the revision of the Rating Outlooks on classes B, C, and
D to Negative from Stable.


WELLS FARGO 2017-C42: Fitch Affirms B-sf Rating on Cl. X-F Certs
----------------------------------------------------------------
Fitch Ratings affirmed 18 classes of Wells Fargo Commercial
Mortgage Trust 2017-C42 commercial mortgage pass-through
certificates.

RATING ACTIONS

WFCM 2017-C42

Class A-1 95001GAA1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 95001GAB9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 95001GAD5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 95001GAE3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-BP 95001GAF0; LT AAAsf Affirmed;  previously at AAAsf

Class A-S 95001GAK9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-SB 95001GAC7; LT AAAsf Affirmed;  previously at AAAsf

Class B 95001GAL7;    LT AA-sf Affirmed;  previously at AA-sf

Class C 95001GAM5;    LT A-sf Affirmed;   previously at A-sf

Class D 95001GAU7;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 95001GAW3;    LT BB-sf Affirmed;  previously at BB-sf

Class F 95001GAY9;    LT B-sf Affirmed;   previously at B-sf

Class X-A 95001GAG8;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 95001GAJ2;  LT A-sf Affirmed;   previously at A-sf

Class X-BP 95001GAH6; LT AAAsf Affirmed;  previously at AAAsf

Class X-D 95001GAN3;  LT BBB-sf Affirmed; previously at BBB-sf

Class X-E 95001GAQ6;  LT BB-sf Affirmed;  previously at BB-sf

Class X-F 95001GAS2;  LT B-sf Affirmed;   previously at B-sf

KEY RATING DRIVERS

Stable Loss Expectations: The affirmations are based on the stable
performance of the underlying collateral. No loans have transferred
to special servicing since issuance, and Fitch has designated four
loans (5.3%) as Fitch Loans of Concern (FLOCs). There have been no
material changes to the pool since issuance, and therefore the
original rating analysis was considered in affirming the
transaction.

Minimal Change to Credit Enhancement: There has been minimal change
to credit enhancement since issuance. As of the October 2019
distribution date, the pool's aggregate balance has been paid down
by 0.55% to $740.7 million from $744.8 million at issuance. All 38
of the original loans remain in the pool. Eleven loans representing
28.9% of the pool are full-term interest-only loans, and 11 loans
representing 34% of the pool remain in their partial interest-only
period.

Fitch Loans of Concern: Four loans (5.3%) have been designated as
FLOCs. The largest FLOC is the Lennar Corporate Center loan (3.9%),
which is secured by a 289,986 sf office property located in Miami,
FL. The property has been designated a FLOC due to the largest
tenant Lennar Corporation (50% NRA) vacating prior to their lease
expiration in March 2022. Fitch has requested additional
information from the servicer and is still awaiting response. The
remaining FLOCs combine for 1.4% of the pool balance and are
designated as FLOCs due to performance related issues, such as low
DSCRS and occupancy declines. The loans are secured by a
self-storage property located in Napa, CA, unanchored convenience
center located in Plymouth Meeting, PA and a Manufactured Housing
community located in Plattsburgh, NY.

Additional Considerations

Investment-Grade Credit Opinion Loan: The fifth largest loan,
Moffett Towers II -- Building 2 (5.4%) received a credit opinion of
'BBB-sf' on a standalone basis at issuance. As of YE 2018, the
property was 100% occupied and reported a NOI DSCR of 1.75x.

RATING SENSITIVITIES

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

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

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

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. ESG issues are credit neutral
or have only a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by the
transaction.


                            *********

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