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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, December 15, 2019, Vol. 23, No. 348

                            Headlines

ACAM LTD 2019-FL1: DBRS Assigns Prov. B(low) Rating on G Notes
AJAX MORTGAGE 2019-F: DBRS Gives Prov. B Rating on Class B-2 Notes
BAIN CAPITAL 2019-1: S&P Assigns B- (sf) Rating to Class F Notes
BAIN CAPITAL 2019-4: S&P Rates Class E Notes 'BB- (sf)'
BANK 2019-BNK23: Fitch Assigns B-sf Rating on Class G Certs

BANK 2019-BNK24: DBRS Assigns Prov. BB Rating on Class X-G Certs
BATTALION CLO XVI: S&P Assigns Prelim BB- Rating to Class E Notes
BENCHMARK MORTGAGE 2019-B15: DBRS Gives (P)BB Rating on X-F Certs
BRAVO RESIDENTIAL 2019-NQM2: DBRS Finalizes B Rating on B-2 Notes
BUNKER HILL 2019-3: DBRS Assigns Prov. B Rating on Class B-2 Notes

BUNKER HILL 2019-3: DBRS Finalizes B Rating on Class B-2 Notes
BX TRUST 2017-SLCT: S&P Raises Class F Certs Rating to 'B+ (sf)'
CBAM LTD 2018-6: Moody's Gives Ba3 Rating on $51.5MM Cl. E-R Notes
CD 2017-CD3: Fitch Affirms B-sf Rating on Class F Certs
CIM TRUST 2019-R5: Moody's Assigns B3 Rating on Class B2 Debt

CITIGROUP COMMERCIAL 2019-C7: DBRS Gives Prov. B(low) on J-RR Certs
COMM 2013-LC6: Moody's Affirms B2 Rating on Class F Certs
CREDIT SUISSE 2005-C5: Fitch Affirms CCsf Rating on Cl. G Certs
CSMC 2019-NQM1: S&P Assigns B (sf) Rating to Class B-2 Notes
CWHEQ REVOLVING 2006-RES: Moody's Hikes Rating on 2 Tranches to Ba1

FANNIE MAE 2019-HRP1: S&P Rates Nine Classes of Notes 'B (sf)'
FLAGSHIP CREDIT 2019-4: DBRS Finalizes BB Rating on Class E Notes
GS MORTGAGE 2006-GG8: Fitch Lowers Class A-J Certs to CCCsf
GSAMP TRUST 2004-OPT: Moody's Upgrades Class M-2 Debt to B3
GUGGENHEIM MM 2019-2: S&P Rates Class E Debt 'BB- (sf)'

HOMEWARD OPPORTUNITIES 2019-3: DBRS Finalizes B Rating on B2 Certs
HOMEWARD OPPORTUNITIES 2019-3: S&P Rates Class B-2 Certs 'B (sf)'
INTER PIPELINE 2019-B: DBRS Gives BB(high) to 2019-B Sub. Notes
JP MORGAN 2003-CIBC6: Fitch Affirms Bsf Rating on Class L Certs
MADISON PARK XXXVI: S&P Assigns Prelim 'BB-' Rating to Cl. E Notes

MARATHON CLO 14: S&P Assigns Prelim BB- (sf) Rating to Cl. D Notes
MERRILL LYNCH 2002-CANADA 8: Moody's Cuts Rating on 2 Classes to B3
MF1 LTD 2019-FL2: DBRS Finalizes B(low) Rating on Class G Notes
MF1 LTD 2019-FL2: DBRS Gives Prov. B(low) Rating on Class G Notes
ML-CFC COMMERCIAL 2006-4: S&P Lowers Cl. C Certs Rating to 'D (sf)'

MORGAN STANLEY 2006-TOP23: S&P Cuts Cl. F Certs Rating to 'D (sf)'
MORGAN STANLEY 2016-SNR: S&P Affirms BB+(sf) Rating on Cl. E Certs
MORGAN STANLEY 2016-UBS9: Fitch Affirms B-sf Rating on Cl. F Certs
MORGAN STANLEY 2019-NUGS: Moody's Rates Class E Certs '(P)Ba3'
MSC MORTGAGE 2011-C3: DBRS Confirms B(high) Rating on Cl. G Certs

NEUBERGER BERMAN 34: S&P Assigns BB- (sf) Rating to Class E Notes
NEUBERGER BERMAN 35: S&P Assigns Prelim BB- Rating to Cl. E Notes
NEW RESIDENTIAL 2019-6: DBRS Finalizes BB Rating on 10 Classes
NORTHWOODS CAPITAL 20: S&P Assigns Prelim BB- Rating to E Notes
OHA LOAN 2015-1: S&P Rates Class E-R2 Notes 'BB- (sf)'

PFP LTD 2019-6: DBRS Assigns Prov. B(low) Rating on Class G Notes
PFP LTD 2019-6: DBRS Finalizes B(low) Rating on Class G Notes
PREFERREDPLUS TRUST CZN-1: S&P Lowers 8.375% Trust Certs to 'CCC-'
PULSAR FUNDING: S&P Assigns BB- (sf) Rating to Class D Notes
RALI TRUST 2006-QO8: Moody's Hikes Rating on Class I-A4A Debt to Ca

RAMP TRUST 2005-RS3: Moody's Hikes Class M-6 Debt to Ba3
RASC TRUST 2004-KS6: Moody's Hikes Class M-I-1 Debt Rating to B2
READY CAPITAL 2019-6: DBRS Finalizes B(low) Rating on G Certs
RFC LTD 2006-1: Fitch Withdraws Ratings on 9 Tranches
SILVER HILL 2019-SBC1: DBRS Assigns Prov. B Rating on 2 Tranches

TAILWIND 2019-1: S&P Assigns BB(sf) Rating on $46MM Series C Notes
TRINITAS CLO III: Moody's Lowers $8MM Class F Notes to Caa3
VNDO TRUST 2016-350P: S&P Affirms BB- (sf) Rating to Cl. E Certs
VOYA CLO 2019-4: S&P Assigns BB- (sf) Rating to Class E Notes
[*] DBRS Puts 316 Classes on 12 GSE CRT Deals Under Review

[*] S&P Takes Various Actions on 61 Classes From 10 U.S. CLO Deals

                            *********

ACAM LTD 2019-FL1: DBRS Assigns Prov. B(low) Rating on G Notes
--------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage-Backed Notes to be issued by ACAM 2019-FL1,
Ltd. (the Issuer):

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

All trends are Stable. Classes F and G will be privately placed.

The initial collateral consists of 21 floating-rate mortgages
secured by 35 mostly transitional properties with a cut-off balance
totaling $400.3 million, excluding approximately $87.4 million of
future funding commitments. Most loans are in a period of
transition with plans to stabilize and improve asset value. During
the Reinvestment Period, the Issuer may acquire future funding
commitments and additional eligible loans subject to the
Eligibility Criteria. The transaction stipulates a $1.0 million
threshold on pari passu participation acquisitions before a rating
agency condition is required if the underlying loan is already
participating in the trust.

For the floating-rate loans, the index DBRS Morningstar used
(one-month LIBOR) was the lower of a DBRS Morningstar stressed rate
that corresponded with the remaining fully extended term of the
loans or the strike price of the interest-rate cap, with the
respective contractual loan spread added to determine a stressed
interest rate over the loan term. When the cut-off balances were
measured against the DBRS Morningstar As-Is Net Cash Flow, 18
loans, comprising 86.9% of the initial pool, had a DBRS Morningstar
As-Is Debt Service Coverage Ratio (DSCR) below 1.00 times (x), a
threshold indicative of elevated term default risk. Additionally,
the DBRS Morningstar Stabilized DSCR for six loans, comprising
29.8% of the initial pool balance, is below 1.00x, which is
indicative of elevated refinance risk. The majority of the
properties are transitioning with potential upside in cash flow;
however, DBRS Morningstar does not give full credit to the
stabilization if there are no holdbacks or if other loan structural
features in place are insufficient to support such treatment.
Furthermore, even with the structure provided, DBRS Morningstar
generally does not assume the assets to stabilize the above market
levels.

The transaction will have a sequential-pay structure.

The properties are primarily located in core markets with the
overall pool's weighted-average (WA) DBRS Morningstar Market Rank
at a very high 5.1. Eight loans, totaling 41.0% of the pool, are in
markets with a DBRS Morningstar Market Rank of 8, 7 and 6. These
higher DBRS Morningstar Market Ranks correspond with zip codes that
are more urbanized in nature.

Three loans in the pool, totaling 33.8% of the DBRS Morningstar
sample by cut-off date pool balance, are backed by a property whose
quality DBRS Morningstar deemed to be Average (+) or Above
Average.

The borrowers of all 21 floating-rate loans have purchased LIBOR
rate caps that range between 2.5% and 3.75% to protect against
rising interest rates over the term of the loan.

Thirteen loans, representing 51.8% of the initial pool balance,
represent acquisition financing. Acquisition financing generally
requires the respective sponsor(s) to contribute material cash
equity as a source of funding in conjunction with the mortgage
loan, resulting in a higher sponsor cost basis in the underlying
collateral.

The Class F Notes, Class G Notes, and Preferred Shares, which
represent 15.6% of the transaction balance, will be retained by
ACAM 2019-FL1 Retention Holder, LLC, an affiliate of the trust
asset seller.

The pool consists of mostly transitional assets. Given the nature
of the assets, DBRS Morningstar determined a sample size,
representing 77.7% of the pool cut-off date balance. This is higher
than the typical sample size for traditional conduit commercial
mortgage-backed security (CMBS) transactions. DBRS Morningstar also
performed physical site inspections, including management meetings.
When DBRS Morningstar visits these markets, it may actually visit
properties more than once to follow the progress (or lack thereof)
toward stabilization. The service is also in constant contact with
the borrowers to track progress.

Five loans, representing 27.7% of the pool, are secured by hotels,
including three of the largest ten loans. Hotels have the highest
cash flow volatility of all major property types as their income,
which is derived from daily contracts rather than multi-year
leases, and expenses, which are often mostly fixed, are quite high
as a percentage of revenue. These two factors cause revenue to fall
swiftly during a downturn and cash flow to fall even faster as a
result of high operating leverage. The loans in the pool secured by
hotel properties have a WA As-Is Loan-to-Value (LTV) ratio of 57.4%
based on their fully funded loan amount and as-is appraised value,
which compares favorably with the WA LTV of 89.7% for non-hotel
properties in the pool. Additionally, the WA market index for the
hotel properties in the pool is 6.3, with 61.5% of the hotel
properties located in markets ranked 7 and 8, indicating
concentration in urban locations.

Based on the weighted initial pool balances, the overall WA DBRS
Morningstar As-Is DSCR of 0.77x reflects high-leverage financing.
The assets are generally well-positioned to stabilize and any
realized cash flow growth would help to offset rising interest
rates and also improve the overall debt yield of the loans. DBRS
Morningstar associates its loss given default (LGD) with the
assets' As-Is LTV and does not assume that the stabilization plan
and cash flow growth will ever materialize. Additionally, including
all future funding in the calculation, the WA DBRS Morningstar
As-Stabilized LTV is low at 53.8%. The WA DBRS Morningstar
As-Stabilized LTV reflects downward stabilized value adjustments
that DBRS Morningstar made to two loans.

All loans in the pool have floating interest rates. Eighteen loans,
comprising 78.0% of the pool balance, are interest-only during the
original term and have original terms ranging from 24 months to 60
months, creating interest-rate risk. All loans are short-term loans
and, even with extension options, they have a fully extended
maximum loan term of five years. Additionally, for the
floating-rate loans, DBRS Morningstar used the one-month LIBOR
index, which is based on the lower of a DBRS Morningstar stressed
rate that corresponded with the remaining fully extended term of
the loans or the strike price of the interest-rate cap with the
respective contractual loan spread added to determine a stressed
interest rate over the loan term. Additionally, all loans have
extension options and, to qualify for these options, the loans must
meet minimum DSCR and LTV requirements.

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

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


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

-- $110.1 million Class A-1 at AAA (sf)
-- $12.5 million Class A-2 at A (high) (sf)
-- $5.1 million Class A-3 at A (low) (sf)
-- $6.1 million Class M-1 at BBB (sf)
-- $11.5 million Class B-1 at BB (sf)
-- $10.4 million Class B-2 at B (sf)

The AAA (sf) rating on the Notes reflects the 35.55% of credit
enhancement provided by subordinated Notes in the pool. The A
(high) (sf), A (low) (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 28.25%, 25.25%, 21.70 %, 14.95% and 8.85% of credit
enhancement, respectively.

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

The transaction is a securitization of a portfolio of seasoned
performing and re-performing first-lien residential mortgages
funded by the issuance of the Notes. The Notes are backed by 923
loans with a total principal balance of approximately $170,800,620
as of the Cut-Off Date (October 31, 2019).

The portfolio is approximately 150 months seasoned. As of the
Cut-Off Date, under the Mortgage Bankers Association delinquency
method, 72.9% of the pool is current, 19.0% is 30-59 days
delinquent, 4.7% is 60-89 days delinquent, 1.8% is 90+ days
delinquent and 1.5% is in bankruptcy.

Although the number of months clean (consecutively zero times 30
days delinquent) at issuance is weaker relative to other DBRS
Morningstar-rated seasoned transactions, the borrowers in this pool
demonstrate reasonable cash flow velocity (as measured by a number
of payments over time) in the past 24 months. Approximately 28.7%
of the pool has been clean for the past 24 months; however, 84.5%
of the pool has made 24 or more payments in the past 24 months.

Modified loans comprise 83.7% of the portfolio. The modifications
happened more than two years ago for 86.3% of the modified loans.
Within the pool, 247 mortgages (31.9% of the pool) have
non-interest-bearing deferred amounts, which equate to 4.4% of the
total principal balance. Included in the deferred amounts are the
Home Affordable Modification Program and proprietary principal
forgiveness amounts, which comprise less than 0.1% of the total
principal balance.

Prior to the Closing Date, Great Ajax Operating Partnership LP
(Ajax), in its capacity as the Sponsor, acquired some loans from
various unaffiliated third-party sellers between 2014 and 2019. On
the Closing Date, Ajax will also acquire other loans directly or
indirectly as a result of the redemption of all or certain classes
of notes that were previously issued by Ajax Mortgage Loan Trust
2017-A. To satisfy the credit risk retention requirements, the
Sponsor or a majority-owned affiliate of the Sponsor will retain at
least a 5% eligible horizontal interest in the securities.

Since 2013, Ajax and its affiliates have issued 29 securitizations
under the Ajax Mortgage Loan Trust shelf prior to AJAX 2019-F.
These issuances were backed by seasoned, re-performing or
non-performing loans. Two of the previously issued Ajax deals, Ajax
Mortgage Loan Trust 2017-B and Ajax Mortgage Loan Trust 2019-D,
were rated by DBRS Morningstar. DBRS Morningstar reviewed the
historical performance of the Ajax shelf; however, the non-rated
deals generally exhibit much worse collateral attributes than the
rated deals with regard to delinquencies at issuance. The prior
Ajax transactions currently exhibit high levels of delinquencies
and losses, which are expected given the nature of these severely
distressed assets.

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

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

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

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

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


BAIN CAPITAL 2019-1: S&P Assigns B- (sf) Rating to Class F Notes
----------------------------------------------------------------
S&P Global Ratings assigned credit ratings to the class A to F
European cash flow CLO notes issued by Bain Capital Euro CLO 2019-1
DAC. At closing, the issuer issued unrated subordinated notes.

The ratings reflect S&P's assessment of:

-- The diversified collateral pool, which consists primarily of
broadly syndicated speculative-grade senior secured term loans and
bonds that are governed by collateral quality tests.

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

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

-- The transaction's legal structure, which S&P expects to be
bankruptcy remote.

-- The transaction's counterparty risks, which S&P expects to be
in line with its counterparty rating framework.

Under the transaction documents, the rated notes pay quarterly
interest unless there is a frequency switch event. Following this,
the notes will permanently switch to semiannual payment.

"Our ratings reflect our assessment of the effective date
collateral portfolio's credit quality, which has a weighted-average
'B' rating. We consider that the portfolio on the effective date
will be well-diversified, primarily comprising broadly syndicated
speculative-grade senior secured term loans, and senior secured
bonds. Therefore, we have conducted our credit and cash flow
analysis by applying our criteria for corporate cash flow CDOs,"
S&P said.

"In our cash flow analysis, we used the EUR400 million target par
amount, the covenanted weighted-average spread (3.65%), the
covenanted weighted-average coupon (5.00%), and the covenanted
weighted-average recovery rates for all rating levels. As the
portfolio is being ramped, we have relied on its indicative spreads
and recovery rates," S&P said.

  Target Portfolio Metrics

  S&P Global Ratings weighted-average rating factor   2,629
  Default rate dispersion                               645
  Weighted-average life (years)                        5.51
  Obligor diversity measure                             132
  Industry diversity measure                             25
  Regional diversity measure                            1.3
  'CCC' assets (%)                                     1.00
  'AAA' WARR (%)                                      37.96
  WARR--Weighted-average recovery rate.

S&P's credit and cash flow analysis shows that the class B, C, D,
and E notes benefit from break-even default rate and scenario
default rate cushions that the rating agency would typically
consider to be in line with higher ratings than those assigned.
However until the end of the reinvestment period, the collateral
manager is allowed to substitute assets in the portfolio for so
long as S&P's CDO Monitor test is maintained or improved in
relation to the initial ratings on the notes. As a result, until
the end of the reinvestment period, the collateral manager can,
through trading, deteriorate the transaction's current risk
profile, as long as the initial ratings are maintained. S&P has
therefore capped its assigned ratings on the notes.

Prior to the purchase of any asset, the collateral manager will
request the collateral administrator to test compliance with the
reinvestment conditions. The collateral manager may proceed with
the purchase even if they have not received confirmation from the
collateral administrator. The collateral manager still has to
comply with the reinvestment conditions, in accordance with its
standard of care.

Under S&P's structured finance ratings above the sovereign
criteria, the transaction's exposure to country risk is
sufficiently mitigated at the assigned rating levels.

The Bank of New York Mellon, London Branch is the bank account
provider and custodian. The documented downgrade remedies are in
line with S&P's current counterparty criteria.

The issuer is bankruptcy remote, in accordance with S&P's legal
criteria.

Following S&P's analysis of the credit, cash flow, counterparty,
operational, and legal risks, it believes its ratings are
commensurate with the available credit enhancement for each class
of notes.

Transaction key dates

-- End of reinvestment period: April 15, 2024
-- End of non-call period: Jan. 15, 2022
-- Maximum weighted-average life: 8.5 years

  Ratings List

  Class           Rating      Amount (mil. EUR)
  A               AAA (sf)    250.00
  B               AA (sf)      40.00
  C               A (sf)       27.60
  D               BBB (sf)     23.40
  E               BB (sf)      21.00
  F               B- (sf)      10.40
  M-1 sub notes   NR           32.10
  M-2 sub notes   NR            0.50
  NR--Not rated.


BAIN CAPITAL 2019-4: S&P Rates Class E Notes 'BB- (sf)'
-------------------------------------------------------
S&P Global Ratings assigned its ratings to Bain Capital Credit CLO
2019-4 Ltd./Bain Capital Credit CLO 2019-4 LLC's floating-rate
notes.

The note issuance is a CLO transaction backed by a diversified
collateral pool, which consists primarily of broadly syndicated
speculative-grade (rated 'BB+' and lower) senior secured term loans
that are governed by collateral quality tests.

The ratings reflect:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  Bain Capital Credit CLO 2019-4 Ltd./Bain Capital Credit CLO
  2019-4 LLC

  Class             Rating        Amount (mil. $)

  A-1               AAA (sf)               360.00
  A-2               NR                      30.00
  B                 AA (sf)                 66.00
  C (deferrable)    A (sf)                  33.00
  D (deferrable)    BBB- (sf)               33.00
  E (deferrable)    BB- (sf)                30.00
  Sub notes         NR                      51.80

  NR--Not rated.


BANK 2019-BNK23: Fitch Assigns B-sf Rating on Class G Certs
-----------------------------------------------------------
Fitch Ratings assigned ratings and Rating Outlooks to BANK
2019-BNK23 commercial mortgage pass-through certificates, series
2019-BNK23.

Since Fitch published its expected ratings on Nov. 18, 2019, the
balances for classes A-2 and A-3 were finalized. At the time that
the expected ratings were published the initial certificate
balances of classes A-2 and A-3 were unknown and expected to be
approximately $814,369,000 in aggregate, subject to a 5% variance.
The final class balances for classes A-2 and A-3 are $325,000,000
and $489,369,000, respectively. Additionally, based on final
pricing of the certificates, class C is a WAC class hereby
providing no excess cash flow that would affect the payable
interests on the class X-B certificates. Fitch's rating on class
X-B has been updated to 'AA-', to reflect the rating of Class B,
the next lowest-referenced tranche whose payable interest has an
impact on the Class X-B's interest-only payments.

RATING ACTIONS

BANK 2019-BNK23

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

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

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

Class H;    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

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

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

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

TRANSACTION SUMMARY

The ratings are based on information provided by the issuer as of
Dec. 10, 2019.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 47 loans secured by 100
commercial properties having an aggregate principal balance of
$1,287,022,414 as of the cut-off date. The loans were contributed
to the trust by Wells Fargo Bank, National Association, Bank of
America, National Association and Morgan Stanley Mortgage Capital
Holdings LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 67.4% of the properties
by balance, cash flow analysis of 84.1% and asset summary reviews
on 100% of the pool.

KEY RATING DRIVERS

Lower Fitch Leverage than Recent Transactions: Overall, the pool's
Fitch debt service coverage ratio (DSCR) of 1.26x is better than
average when compared with the YTD 2019 and 2018 averages of 1.25x
and 1.22x, respectively. The pool's LTV of 99.7% is better than the
YTD 2019 and 2018 averages of 102.5% and 102.0%, respectively.
Excluding the credit opinion loans, the Fitch DSCR and LTV are
1.25x and 112.42%, respectively.

High Concentration of Interest-Only Loans with Limited
Amortization: The pool has 29 interest-only (IO) loans representing
77.4% of the pool and eight loans representing 12.2% of the pool
that are partial interest-only. From securitization to maturity,
the pool is scheduled to pay down by only 3.5%, which is well below
the YTD 2019 and 2018 averages of 6.0% and 7.2%, respectively.

Investment-Grade Credit Opinion Loans: Four loans representing
29.5% of the pool are credit assessed. This is significantly above
the 2019 YTD and 2018 concentrations of 13.9% and 13.6%,
respectively. Jackson Park received a credit opinion of 'A-sf' on a
stand-alone basis. Park Tower at Transbay, Century Plaza Tower and
ILPT Industrial Portfolio each received credit opinions of 'BBB-sf'
on a standalone basis.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 12.5% 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 BANK
2019-BNK23 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.

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.


BANK 2019-BNK24: DBRS Assigns Prov. BB Rating on Class X-G Certs
----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-BNK24 to
be issued by BANK 2019-BNK24 as follows:

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

All trends are Stable. Classes X-D, X-F, X-G, X-H, D, E, F, G, H,
and RR will be privately placed.

The collateral consists of 71 fixed-rate loans secured by 104
commercial and multifamily properties. The transaction is a
sequential-pay pass-through structure. DBRS Morningstar analyzed
the conduit pool to determine the provisional ratings, reflecting
the long-term probability of loan default within the term and its
liquidity at maturity. Four loans, representing 22.4% of the pool,
are shadow-rated investment grade by DBRS Morningstar. When DBRS
Morningstar measured the cut-off loan balances against the DBRS
Morningstar Stabilized Net Cash Flow (NCF) and their respective
actual constants, the initial DBRS Morningstar weighted-average
(WA) debt service coverage ratio (DSCR) for the pool was 2.94 times
(x). The WA DSCR is elevated because 22.4% of the pool is
shadow-rated investment grade and low-leverage residential
co-operative loans represent 8.9% of the pool. Residential
co-operative loans have very low loan-level credit enhancement at
the AAA level and near-zero loan-level credit enhancement at the
BBB (low) level. Only one loan, Totowa Shoppes, had a DBRS
Morningstar Term DSCR below 1.30x, a threshold indicative of a
higher likelihood of mid-term default. The WA loan-to-value (LTV)
ratio of the pool at issuance was 53.1%, and the pool is scheduled
to amortize down to a WA LTV of 51.2% at maturity. The pool
includes 17 loans, representing 24.6% of the pool by allocated loan
balance, with issuance LTVs equal to or higher than 65.0%, a
threshold historically indicative of above-average default
frequency.

The transaction includes four loans, representing 22.4% of the
total pool balance, which is shadow-rated investment grade by DBRS
Morningstar, including 55 Hudson Yards, Jackson Park, Park Tower at
Transbay, and ILPT Industrial Portfolio. Park Tower at Transbay
exhibits credit characteristics consistent with a AAA shadow
rating, Jackson Park exhibits credit characteristics consistent
with a AA (high) shadow rating, ILPT Industrial Portfolio exhibits
credit characteristics consistent with a AA (low) shadow rating,
and 55 Hudson Yards exhibit credit characteristics consistent with
a BBB shadow rating.

Thirty-two loans in the pool, representing 8.9% of the transaction,
are backed by residential co-operative loans. Residential
co-operatives tend to have minimal risk, given their low leverage
and a low risk to residents if the co-operative associations
default on their mortgages. The WA LTV for these loans is 12.5%.

Fifty loans, representing 69.7% of the pool, have collateral
located in Metropolitan Statistical Area (MSA) Group 3, which
represents the best-performing group in terms of historical
commercial mortgage-backed security (CMBS) default rates among the
top 25 MSAs. The MSA Group 3 has a historical default rate of
17.25%, which is 50.00% lower than the overall CMBS historical
default rate of approximately 28.00%.

Forty-seven loans, representing 67.8% of the pool by allocated loan
balance, exhibit issuance LTVs of equal to or less than 60.0%, a
threshold historically indicative of relatively low-leverage
financing and generally associated with below-average default
frequency.

Only one loan had property quality deemed to be Average (-) while
none had property quality deemed Below Average or Poor.
Additionally, nine loans, representing 46.6% of the pool balance,
exhibited Average (+), Above Average or Excellent property quality.
One of the top ten loans, Park Tower at Transbay, is secured by
collateral with Excellent property quality.

The pool has a relatively high concentration of loans secured by
office properties as ten loans, representing 33.7% of the pool by
allocated loan balance, are secured by this property type. DBRS
Morningstar considers office properties to be a riskier property
type with a generally above-average historical default frequency.
Two of the ten office loans (55 Hudson Yards and Park Tower at
Transbay), comprising 12.2% of the pool balance, are shadow-rated
investment grade by DBRS Morningstar. Five office properties,
totaling 18.9% of the pool balance, have DBRS Morningstar DSCRs
higher than 2.00x while the remaining five office loans, totaling
14.8% of the pool balance, have DBRS Morningstar DSCRs higher than
1.45x. Four office loans, representing 73.1% of the office
concentration, are secured by office properties in areas
characterized as extremely dense and desirable urban markets, which
have a DBRS Morningstar Market Rank of 8.

Thirty loans, representing 75.2% of the pool by allocated loan
balance, are structured with full-term interest-only (IO) periods.
Of these 30 loans, 12 loans, representing 42.5% of the pool by
allocated loan balance, are in areas with a DBRS Morningstar Market
Rank of 6, 7, or 8. These markets benefit from increased liquidity
even during times of economic stress. Four of the 30 identified
loans, representing 22.4% of the total pool balance, are
shadow-rated investment grade by DBRS Morningstar: Park Tower at
Transbay, Jackson Park, ILPT Industrial Portfolio, and 55 Hudson
Yards.

DBRS Morningstar completed a cash flow review and a cash flow
stability and structural review on 26 of the 71 loans, representing
83.5% of the pool by loan balance. For loans not subject to an NCF
review, DBRS Morningstar applied the average NCF variance of its
respective loan seller. DBRS Morningstar uses recent leasing to
determine leasing cost assumptions in loan-level NCF analysis,
which was the main driver for the sampled commercial properties in
the transaction. The sampled variance in the transaction reflects
an increasing leasing cost environment, particularly for suburban
office properties. The DBRS Morningstar sample had an average NCF
variance of -10.2% and ranged from -21.5% (Galleria 57) to +0.2%
(Park Tower at Transbay).

Classes X-A, X-B, X-D, X-F, X-G, and X-H are IO certificates that
reference a single rated tranche or multiple rated tranches. The IO
rating mirrors the lowest-rated applicable reference obligation
tranche adjusted upward by one notch if senior in the waterfall.

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


BATTALION CLO XVI: S&P Assigns Prelim BB- Rating to Class E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Battalion
CLO XVI Ltd.'s fixed- and floating-rate notes.

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

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

The preliminary ratings reflect:

-- The diversified collateral pool.

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Battalion CLO XVI Ltd./Battalion CLO XVI LLC  

  Class                   Rating       Amount (mil. $)
  A                       AAA (sf)              233.00
  AF                      AAA (sf)               19.00
  B                       AA (sf)                52.00
  C (deferrable)(i)       A (sf)                 20.00
  D (deferrable)          BBB- (sf)              24.00
  E (deferrable)          BB- (sf)               16.00
  Subordinated notes      NR                     38.50
  
  (i)Class C also contains a LIBOR floor of 1.5%.
  NR--Not rated.


BENCHMARK MORTGAGE 2019-B15: DBRS Gives (P)BB Rating on X-F Certs
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-B15 to
be issued by Benchmark 2019-B15 Mortgage Trust:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-5 at AAA (sf)
-- Class A-AB at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X-A AAA (sf)
-- Class B at AA (low) (sf)
-- Class X-B at A (sf)
-- Class C at A (low) (sf)
-- Class D at BBB (high) (sf)
-- Class X-D at BBB (sf)
-- Class E at BBB (low) (sf)
-- Class X-F at BB (sf)
-- Class F at BB (low) (sf)
-- Class G-RR at B (high) (sf)

All trends are Stable. Classes X-B, X-D, X-F, F, E, F, and G-RR
will be privately placed.

The collateral consists of 32 fixed-rate loans secured by 87
commercial and multifamily properties. The transaction is a
sequential-pay pass-through structure. The conduit pool was
analyzed to determine the provisional ratings, reflecting the
long-term probability of loan default within the term and its
liquidity at maturity. When the cut-off loan balances were measured
against the DBRS Morningstar Stabilized Net Cash Flow (NCF) and
their respective actual constants, the initial DBRS Morningstar
weighted average (WA) DSCR of the pool was 2.05 times (x). None of
the loans had a DBRS Morningstar Term DSCR below 1.32x, a threshold
indicative of a higher likelihood of mid-term default.
Additionally, excluding hospitality properties, 17 loans,
comprising 66.8% of the pool by allocated loan balance, exhibited a
favorable DSCR in excess of 1.69x, a threshold generally associated
with below-average default frequency. The pool additionally
includes five loans comprising a combined 37.5% of the pool balance
with a DBRS Morningstar loan-to-value (LTV) ratio in excess of
67.1%, a threshold generally indicative of above-average default
frequency. The WA DBRS Morningstar LTV of the pool at issuance was
61.6%, and the pool is scheduled to amortize down to a DBRS
Morningstar WA LTV of 58.0% at maturity.

The transaction includes three loans, representing a combined 12.7%
of the total pool balance, that is shadow-rated investment grade by
DBRS Morningstar, including Century Plaza Towers, The Essex and
Osborn Triangle. Century Plaza Towers exhibits credit
characteristics consistent with an "A" shadow rating; The Essex
exhibits credit characteristics consistent with a BBB (high) shadow
rating, and Osborn Triangle exhibits credit characteristics
consistent with a BBB (low) shadow rating.

There were 13 loans, representing 62.8% of the pool by allocated
loan amount, assigned with either Average (+), Above Average or
Excellent quality. Only two loans, representing a combined 5.3% of
the pool by allocated loan balance, were assigned Average (-)
property quality scores and there were no loans assigned Below
Average or Poor property scores. Properties with favorable property
quality tend to attract and retain tenancy and are more liquid in
the capital markets.

The pool has a high concentration of loans secured by office
properties, as evidenced by ten loans, representing a combined
44.0% of the pool by allocated loan balance, being secured by such
properties. DBRS Morningstar considers office properties to be a
riskier property type with above-average default frequency. Two of
the identified loans (comprising 22.1% of the pool's total office
composition), Century Plaza Towers and Osborn Triangle, are secured
by office properties that are shadow-rated investment grade by DBRS
Morningstar. Eight of the identified office loans (comprising 88.7%
of the pool's total office composition) are secured by properties
with either Average (+), Above Average or Excellent quality.

The pool features a relatively high concentration of loans secured
by properties located in less favorable suburban market areas, as
evidenced by 15 loans, representing 43.7% of the pool by allocated
loan balance, being secured by properties located in areas with a
DBRS Morningstar Market Rank of either 3 or 4. Twenty-two of the
identified loans, representing 56% of the pool balance that is
secured by properties located in areas with a DBRS Morningstar
Market Rank of either 3 or 4, will amortize over the loan term,
which can reduce risk over time. The WA expected amortization of
these loans is 7.3%, which is higher than the pool's total WA
expected amortization of 5.3%.

Thirteen loans, representing a combined 58.6% of the pool by
allocated loan balance, are structured with full-term interest-only
(IO) periods and an additional seven loans, accounting for 19.6% of
the pool by allocated loan balance, are structured with partial IO
terms ranging from 24 to 60 months. Expected amortization across
the pool is 5.3%. The loans structured with full-term IO periods
are, for the most part, pre-amortized, as is evidenced by a DBRS
Morningstar WA Issuance LTV of 56.3% for these loans.

The average DBRS Morningstar sampled NCF variance of -15.6% for
this transaction is higher than the straight-line average sampled
NCF variance of -11.1% for the last six conduits DBRS
Morningstar-rated transactions, ranging from -14.2% for GSMS
2019-GC42 to -8.0% for WFCM 2019-C53. If DBRS Morningstar were to
exclude the -30.6% variance for 8 West Centre, the average sampled
NCF variance for the transaction would fall to -14.1%, which is
within the range of the past six DBRS Morningstar-rated conduit
transactions. DBRS Morningstar uses recent leasing to determine
leasing cost assumptions in loan-level NCF analysis, which was the
predominant driver for the sampled commercial properties in the
transaction. The increasing leasing cost environment, particularly
for suburban office properties, is a macro-economic trend reflected
in the sampled variance for this transaction.

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

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


BRAVO RESIDENTIAL 2019-NQM2: DBRS Finalizes B Rating on B-2 Notes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage-Backed Notes, Series 2019-NQM2 (the Notes) issued by BRAVO
Residential Funding Trust 2019-NQM2 (the Trust):

-- $255.5 million Class A-1 Notes at AAA (sf)
-- $17.1 million Class A-2 Notes at AA (sf)
-- $26.4 million Class A-3 Notes at A (sf)
-- $13.3 million Class M-1 Notes at BBB (sf)
-- $9.6 million Class B-1 Notes at BB (sf)
-- $9.0 million Class B-2 Notes at B (sf)

The AAA (sf) rating on the Class A-1 Notes reflects 25.10% of
credit enhancement provided by subordinated Notes in the pool. The
AA (sf), A (sf), BBB (sf), BB (sf), and B (sf) ratings reflect
20.10%, 12.35%, 8.45%, 5.65%, and 3.00% of credit enhancement,
respectively.

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

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate prime and non-prime first-lien residential
mortgages funded by the issuance of the Notes. The Notes are backed
by 742 loans with a total principal balance of $341,102,250 as of
the Cut-Off Date (October 31, 2019). By balance, 40.5% of the loans
included in this pool were included in COLT 2017-2 Mortgage Loan
Trust, a DBRS Morningstar-rated securitization that was collapsed
and cleaned up after the August 2019 distribution. The remaining
59.5% of the loans were acquired by affiliates of the sponsor.

The mortgage loans were originated by Caliber Home Loans, Inc.
(41.3%); AmWest Funding Corp. (10.0%); Excelerate Capital (9.7%);
A&D Mortgage LLC (8.5%); LoanStream Mortgage (8.2%); Impac Mortgage
Holdings, Inc. (6.4%); and various other originators, each
comprising less than 5.0% of the mortgage loans.

Although a portion of the mortgage loans was originated to satisfy
the Consumer Financial Protection Bureau (CFPB) Ability-to-Repay
(ATR) rules, they were made to borrowers who generally do not
qualify for an agency, government, or private-label non-agency
prime jumbo products for various reasons. In accordance with the
CFPB Qualified Mortgage (QM) rules, 1.5% of the loans by balance
are designated as QM Safe Harbor, 11.7% as QM Rebuttable
Presumption, and 63.1% as non-QM. QM/ATR-exempt loans consist of
loans made to investors for business purposes (approximately 22.3%
of the loans by balance) and loans originated by Commerce Home
Mortgage, LLC, a community development financial institution (CDFI;
1.4% of the pool). While CDFI loans are not required to adhere to
the ATR rules, the CDFI loans included in this pool were documented
with at least 12 months of income documentation and were made to
mostly creditworthy borrowers with a weighted-average credit score
of 726.

Neither the servicers nor any other party to the transaction will
advance delinquent principal or interest on any mortgage loan;
however, the servicers are obligated to make advances in respect of
taxes and insurance, the cost of preservation, the restoration and
protection of mortgaged properties, and any enforcement or judicial
proceedings, including foreclosures and reasonable costs and
expenses incurred in the course of servicing and disposing of
properties.

On or after the date when the aggregate principal balance of the
mortgage loans and any real estate owned (REO) properties is
reduced to 30% of the Cut-Off Date balance, the holder of the Trust
Certificates has the option to purchase all of the outstanding
loans and REO properties at a price equal to the outstanding
balance plus accrued and unpaid interest, including any fees,
expenses, indemnification amounts, and unpaid extraordinary Trust
expenses.

This transaction employs a cash flow structure that is similar to
many non-QM securitizations. The transaction contains a
sequential-pay cash flow structure with a pro-rata principal
distribution among the senior tranches. Principal proceeds can be
used to cover interest shortfalls on the Notes as the outstanding
senior Certificates are paid in full. Furthermore, the excess
spread can be used to cover realized losses first before being
allocated to unpaid Cap Carryover Amounts.

The ratings reflect transactional strengths that include the
following:

-- Robust loan attributes and pool composition,
-- Satisfactory third-party due diligence review,
-- Compliance with the ATR rules, and
-- Current loans and faster prepayments.

The transaction also includes the following challenges:

-- No servicer advances of delinquent principal and interest,
-- Representations and warranties standard, and
-- Certain non-prime, non-QM, CDFI, and investor loans.

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


BUNKER HILL 2019-3: DBRS Assigns Prov. B Rating on Class B-2 Notes
------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following
Mortgage-Backed Notes, Series 2019-3 (the Notes) to be issued by
Bunker Hill Loan Depositary Trust 2019-3 (BHLD 2019-3 or the
Trust):

-- $189.8 million Class A-1 at AAA (sf)
-- $24.9 million Class A-2 at AA (low) (sf)
-- $35.9 million Class A-3 at A (sf)
-- $15.3 million Class M-1 at BBB (sf)
-- $19.9 million Class B-1 at BB (sf)
-- $10.7 million Class B-2 at B (sf)

The AAA (sf) rating on the Class A-1 Notes reflects 37.90% of
credit enhancement provided by subordinated Notes. The AA (low)
(sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect 29.75%,
18.00%, 13.00%, 6.50% and 3.00% of credit enhancement,
respectively.

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

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate prime and non-prime first-lien residential
mortgages funded by the issuance of the Notes. The Notes are backed
by 938 loans with a total principal balance of $305,587,629 as of
the Cut-Off Date (November 1, 2019).

The transaction structure and the Representations and Warranties
(R&W) framework and enforcement mechanism of BHLD 2019-3 are
similar to that of BHLD 2019-2 and BHLD 2019-1, deals that
Morningstar Credit Ratings, LLC rated earlier in 2019. Compared
with BHLD 2019-1 and BHLD 2019-2, the overall collateral
characteristics of the pool backing BHLD 2019-3 are weaker. To
further differentiate the pools, there are a few characteristics
unique to BHLD 2019-3: (1) 26.6% of loans by balance are originated
and serviced by A&D Mortgage LLC (A&D), an originator with limited
securitization history; (2) a notable share of the collateral
(17.3%) comprises loans originated to foreign national or
non-resident alien borrowers (foreign borrowers), most of which do
not have FICO scores provided by the U.S. credit bureaus; and (3)
overall, 17.8% of the collateral are loans to borrowers with no
FICO score.

NQM WH REDF2 Seller, LLC, NQM WH TSE Seller, LLC, and NQM WH
INVESTIN Seller, LLC (the Sellers) are investment funds advised by
Oaktree Capital Management, L.P. (Oaktree or the Aggregator) under
an indemnification agreement between the funds and Grand Avenue
Acquisition Company, LLC (the Sponsor). Oaktree has invested over
$4.0 billion of capital since 2008 as an aggregator of performing
and non-performing mortgage loans as well as an equity investor in
Selene Finance LP, as a residential mortgage servicer, and in
Genesis Capital LLC (Genesis), an originator of fix and flip loans.
Since launching the non-Qualified Mortgage (QM) platform in 2018,
Oaktree has acquired over $1.0 billion of residential mortgage
loans and issued two non-QM residential mortgage-backed security
deals in 2019. The Aggregator's platform includes several
investment funds and separate accounts which make investments in
the residential assets, including non-QM loans.

The funds include real estate debt (inception in 2010; $3.2 billion
in assets under management (AUM)), real estate income (inception in
2016; $1.2 billion in AUM) and real estate opportunities (inception
in 1994; $5.2 billion in AUM). The Aggregator does not use its own
underwriting guidelines and generally acquires loans from various
approved mortgage originators based on an investment criterion
which, among other factors, includes lower borrower loan-to-value
ratios and higher credit scores.

Through bulk purchases, Oaktree acquired the mortgage loans from
(1) Citadel Servicing Corporation (Citadel or CSC; 65.8%); (2) A&D
(26.6%); (3) AmWest Funding Corp. (AmWest; 2.5%); and other
originators (5.1%).

Citadel will service approximately 65.8% of the mortgage loans by
balance directly or through sub-servicers. A&D will be the servicer
of record for approximately 26.6% of the loans and will use
Specialized Loan Servicing LLC (SLS) as a sub-servicer to service
the loans. SLS will also service approximately 5.2% of the loans,
and AmWest will service approximately 2.5%.

DBRS Morningstar conducted an aggregator review of Oaktree, an
originator and servicer review of CSC, a servicer review of SLS and
an originator review of A&D, and deems them to be acceptable.

Wells Fargo Bank, N.A. (rated AA with a Stable trend by DBRS
Morningstar) will act as Master Servicer, Paying Agent, Certificate
Registrar, Note Registrar, REMIC Administrator, and Custodian. The
Bank of New York Mellon will serve as an Indenture Trustee.

Grand Avenue Acquisition Company, LLC will serve as the R&W
Provider for approximately 70.8% of the loans by balance. A&D
(26.6%) and AmWest (2.5%) will serve as the R&W providers for their
respective loans.

Although 49.9% of the mortgage loans by balance were originated to
satisfy the Consumer Financial Protection Bureau (CFPB)
Ability-to-Repay (ATR) rules, they were made to borrowers who
generally do not qualify for agency, government or private-label
non-agency prime jumbo products for various reasons, including but
not limited to income documentation requirements, limited credit
history, loan size and debt-to-income, a prior housing or credit
event or prior mortgage delinquency. Approximately 50.1% of the
loans were originated under the programs which are exempt from the
ATR rules. In accordance with the CFPB QM rules, 49.9% of the loans
are qualified as non-QM and approximately 50.1% of the loans are
made to investors for business purposes and are exempt from QM
categorization.

The Servicers, except for Citadel, will generally fund advances of
delinquent principal and interest (P&I) on any respective mortgage
until such loan becomes 180 days delinquent, and they are obligated
to make advances in respect of taxes, insurance premiums and
reasonable costs incurred in the course of servicing and disposing
of properties. Citadel will not be required to make any P&I
advances on the loans it services and the Master Servicer will have
no obligation to make any P&I Advances for any loans serviced by
Citadel. However, all Servicers will be required to pay customary,
reasonable and/or necessary expenses incurred in the performance of
the servicing obligations, including the mortgagor's escrow
payments.

On or after the earlier of (1) the three-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, Grand Avenue Depositor, LLC (the Depositor) may, at the
direction of the Class XS Noteholders, purchase all outstanding
Notes (call the deal) at a price equal to the greater of the sum of
(1) outstanding class balance plus accrued and unpaid interest,
including any cap carryover amounts, unreimbursed advances, any
fees, expenses and indemnification amounts of the transaction
parties; and (2) the sum of balance of the mortgage loans plus
accrued and unpaid interest thereon and the fair market value of
each real estate owned property, less estimated liquidation
expenses, unreimbursed advances and fees, expenses and
indemnification amounts of the transaction parties. The Depositor
may also purchase all of the Notes from the Noteholders (call the
deal) at a price equal to the aggregate outstanding Note balance of
all classes, accrued and unpaid interest thereon (including any Net
Weighted-Average Coupon (Net WAC) cap carryover amounts and step-up
interest payment amounts).

If the transaction is not called, on and after the fourth
anniversary of the Closing Date, the coupons on Class A and Class
M-1 Notes will step up by up to 100 basis points but will remain
subject to the Net WAC Cap. The portion of the interest due to the
step-up will be paid at the top of the excess cash flow waterfall.

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

The ratings reflect transactional strengths that include the
following:

-- Substantial borrower equity, robust loan attributes, and pool
     composition;
-- Compliance with the ATR rules;
-- Satisfactory third-party due diligence review;
-- Current loans; and
-- Satisfactory performance to date.

The transaction also includes the following challenges:

-- Foreign borrowers with no FICO scores;
-- R&W framework and provider;
-- Non-prime, QM-rebuttable presumption or non-QM loans;
-- Servicers' advances of delinquent P&I; and
-- Servicers' financial capability.

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


BUNKER HILL 2019-3: DBRS Finalizes B Rating on Class B-2 Notes
--------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage-Backed Notes, Series 2019-3 (the Notes) issued by Bunker
Hill Loan Depositary Trust 2019-3 (BHLD 2019-3 or the Trust):

-- $189.8 million Class A-1 at AAA (sf)
-- $24.9 million Class A-2 at AA (low) (sf)
-- $35.9 million Class A-3 at A (sf)
-- $15.3 million Class M-1 at BBB (sf)
-- $19.9 million Class B-1 at BB (sf)
-- $10.7 million Class B-2 at B (sf)

The AAA (sf) rating on the Class A-1 Notes reflects 37.90% of
credit enhancement provided by subordinated Notes. The AA (low)
(sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings reflect 29.75%,
18.00%, 13.00%, 6.50% and 3.00% of credit enhancement,
respectively.

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

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate prime and non-prime first-lien residential
mortgages funded by the issuance of the Notes. The Notes are backed
by 938 loans with a total principal balance of $305,587,629 as of
the Cut-Off Date (November 1, 2019).

The transaction structure and the Representations and Warranties
(R&W) framework and enforcement mechanism of BHLD 2019-3 are
similar to that of BHLD 2019-2 and BHLD 2019-1, deals that
Morningstar Credit Ratings, LLC rated earlier in 2019. Compared
with BHLD 2019-1 and BHLD 2019-2, the overall collateral
characteristics of the pool backing BHLD 2019-3 are weaker. To
further differentiate the pools, there are a few characteristics
unique to BHLD 2019-3: (1) 26.6% of loans by balance are originated
and serviced by A&D Mortgage LLC (A&D), an originator with limited
securitization history; (2) a notable share of the collateral
(17.3%) comprises loans originated to foreign national or
non-resident alien borrowers (foreign borrowers), most of which do
not have FICO scores provided by the U.S. credit bureaus; and (3)
overall, 17.8% of the collateral are loans to borrowers with no
FICO score.

NQM WH REDF2 Seller, LLC, NQM WH TSE Seller, LLC, and NQM WH
INVESTIN Seller, LLC (the Sellers) are investment funds advised by
Oaktree Capital Management, L.P. (Oaktree or the Aggregator) under
an indemnification agreement between the funds and Grand Avenue
Acquisition Company, LLC (the Sponsor). Oaktree has invested over
$4.0 billion of capital since 2008 as an aggregator of performing
and non-performing mortgage loans as well as an equity investor in
Selene Finance LP, as a residential mortgage servicer, and in
Genesis Capital LLC (Genesis), an originator of fix and flip loans.
Since launching the non-Qualified Mortgage (QM) platform in 2018,
Oaktree has acquired over $1.0 billion of residential mortgage
loans and issued two non-QM residential mortgage-backed security
deals in 2019. The Aggregator's platform includes several
investment funds and separate accounts which make investments in
the residential assets, including non-QM loans.

The funds include real estate debt (inception in 2010; $3.2 billion
in assets under management (AUM)), real estate income (inception in
2016; $1.2 billion in AUM) and real estate opportunities (inception
in 1994; $5.2 billion in AUM). The Aggregator does not use its own
underwriting guidelines and generally acquires loans from various
approved mortgage originators based on an investment criterion
which, among other factors, includes lower borrower loan-to-value
ratios and higher credit scores.

Through bulk purchases, Oaktree acquired the mortgage loans from
(1) Citadel Servicing Corporation (Citadel or CSC; 65.8%); (2) A&D
(26.6%); (3) AmWest Funding Corp. (AmWest; 2.5%); and other
originators (5.1%).

Citadel will service approximately 65.8% of the mortgage loans by
balance directly or through sub-servicers. A&D will be the servicer
of record for approximately 26.6% of the loans and will use
Specialized Loan Servicing LLC (SLS) as a sub-servicer to service
the loans. SLS will also service approximately 5.2% of the loans
and AmWest will service approximately 2.5%.

DBRS Morningstar conducted an aggregator review of Oaktree, an
originator and servicer review of CSC, a servicer review of SLS and
an originator review of A&D, and deems them to be acceptable.

Wells Fargo Bank, N.A. (rated AA with a Stable trend by DBRS
Morningstar) will act as Master Servicer, Paying Agent, Certificate
Registrar, Note Registrar, REMIC Administrator, and Custodian. The
Bank of New York Mellon will serve as an Indenture Trustee.

Grand Avenue Acquisition Company, LLC will serve as the R&W
Provider for approximately 70.8% of the loans by balance. A&D
(26.6%) and AmWest (2.5%) will serve as the R&W providers for their
respective loans.

Although 49.9% of the mortgage loans by balance were originated to
satisfy the Consumer Financial Protection Bureau (CFPB)
Ability-to-Repay (ATR) rules, they were made to borrowers who
generally do not qualify for agency, government or private-label
non-agency prime jumbo products for various reasons, including but
not limited to income documentation requirements, limited credit
history, loan size, and debt-to-income, a prior housing or credit
event or prior mortgage delinquency. Approximately 50.1% of the
loans were originated under the programs which are exempt from the
ATR rules. In accordance with the CFPB QM rules, 49.9% of the loans
are qualified as non-QM and approximately 50.1% of the loans are
made to investors for business purposes and are exempt from QM
categorization.

The Servicers, except for Citadel, will generally fund advances of
delinquent principal and interest (P&I) on any respective mortgage
until such loan becomes 180 days delinquent, and they are obligated
to make advances in respect of taxes, insurance premiums and
reasonable costs incurred in the course of servicing and disposing
of properties. Citadel will not be required to make any P&I advance
on the loans it services and the Master Servicer will have no
obligation to make any P&I Advances for any loans serviced by
Citadel. However, all Servicers will be required to pay customary,
reasonable and/or necessary expenses incurred in the performance of
the servicing obligations, including the mortgagor's escrow
payments.

On or after the earlier of (1) the three-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, Grand Avenue Depositor, LLC (the Depositor) may, at the
direction of the Class XS Noteholders, purchase all outstanding
Notes (call the deal) at a price equal to the greater of the sum of
(1) outstanding class balance plus accrued and unpaid interest,
including any cap carryover amounts, unreimbursed advances, any
fees, expenses and indemnification amounts of the transaction
parties; and (2) the sum of balance of the mortgage loans plus
accrued and unpaid interest thereon and the fair market value of
each real estate owned property, less estimated liquidation
expenses, unreimbursed advances and fees, expenses and
indemnification amounts of the transaction parties. The Depositor
may also purchase all of the Notes from the Noteholders (call the
deal) at a price equal to the aggregate outstanding Note balance of
all classes, accrued and unpaid interest thereon (including any Net
Weighted-Average Coupon (Net WAC) cap carryover amounts and step-up
interest payment amounts).

If the transaction is not called, on and after the fourth
anniversary of the Closing Date, the coupons on Class A and Class
M-1 Notes will step up by up to 100 basis points but will remain
subject to the Net WAC Cap. The portion of the interest due to the
step-up will be paid at the top of the excess cash flow waterfall.

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

The ratings reflect transactional strengths that include the
following:

-- Substantial borrower equity, robust loan attributes, and pool
     composition;
-- Compliance with the ATR rules;
-- Satisfactory third-party due diligence review;
-- Current loans; and
-- Satisfactory performance to date.

The transaction also includes the following challenges:

-- Foreign borrowers with no FICO scores;
-- R&W framework and provider;
-- Non-prime, QM-rebuttable presumption or non-QM loans;
-- Servicers' advances of delinquent P&I; and
-- Servicers' financial capability.

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


BX TRUST 2017-SLCT: S&P Raises Class F Certs Rating to 'B+ (sf)'
----------------------------------------------------------------
S&P Global Ratings raised its ratings on five classes of commercial
mortgage pass-through certificates from BX Trust 2017-SLCT, a U.S.
CMBS transaction. In addition, S&P discontinued its rating on one
other class.

For the upgrades, S&P's expectation of credit enhancement was
generally in line with the raised rating levels. The upgrades also
considered the 59 property releases to date, which were released at
105% to 110% of the allocated loan amount.

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

While available credit enhancement levels may suggest further
positive rating movements on classes D, E, and F, S&P's analysis
also considered the low release amounts required for property
releases and that the portfolio is comprised entirely of hotels,
which S&P deems to be one of the riskier property types.

This is a stand-alone (single borrower) transaction backed by a
floating-rate IO mortgage loan secured by 37 lodging properties
across 10 states, down from 96 properties in 24 states at issuance.
S&P's property-level analysis included a re-evaluation of the
lodging properties that secure the mortgage loan in the trust and
considered the stable servicer-reported net operating income and
occupancy for the past three years (2017 through the trailing 12
months ended June 30, 2019). The rating agency then derived its
sustainable in-place net cash flow, which it divided by a 9.58%
weighted average S&P Global Ratings capitalization rate to
determine its expected-case value. This yielded an overall S&P
Global Ratings loan-to-value ratio and debt service coverage (DSC)
of 69.4% and 1.94x, respectively, on the trust balance.

According to the Nov. 15, 2019, trustee remittance report, the IO
mortgage loan has a trust and whole loan balance of $587.2 million
and pays an annual floating interest rate of LIBOR plus 2.053%. The
mortgage loan pays IO through its current maturity date of July 9,
2020, subject to four additional one-year extension options for a
fully extended maturity date of July 9, 2024. In addition, there is
mezzanine debt totaling $88.3 million. To date, the trust has not
incurred any principal losses.

The master servicer, KeyBank Real Estate Capital, reported a DSC of
2.66x on the trust balance for the 12 months ended June 30, 2019
(which includes subsequently released properties), and occupancy
was 80.7% for the properties remaining in the portfolio at that
time.

  RATINGS RAISED
  BX Trust 2017-SLCT
  Commercial mortgage pass-through certificates

                Rating
  Class     To          From
  C         AAA (sf)    A- (sf)
  D         AA- (sf)    BBB- (sf)
  E         BBB- (sf)   BB- (sf)
  F         B+ (sf)     B (sf)
  X-EXT     AA- (sf)    BBB- (sf)

  RATING DISCONTINUED
  BX Trust 2017-SLCT
  Commercial mortgage pass-through certificates

                Rating
  Class     To          From         
  B         NR          AA- (sf)    

  NR–-Not rated.


CBAM LTD 2018-6: Moody's Gives Ba3 Rating on $51.5MM Cl. E-R Notes
------------------------------------------------------------------
Moody's Investors Service assigned ratings to seven classes of CLO
refinancing notes issued by CBAM 2018-6, Ltd.

Moody's rating action is as follows:

US$610,000,000 Class A-1-R Floating Rate Notes Due 2031 (the "Class
A-1-R Notes"), Assigned Aaa (sf)

US$30,000,000 Class A-2-R Fixed Rate Notes Due 2031 (the "Class
A-2-R Notes"), Assigned Aaa (sf)

US$79,625,000 Class B-1-R Floating Rate Notes Due 2031 (the "Class
B-1-R Notes"), Assigned Aa2 (sf)

US$42,875,000 Class B-2-R Floating Rate Notes Due 2031 (the "Class
B-2-R Notes"), Assigned Aa2 (sf)

US$45,000,000 Class C-R Deferrable Floating Rate Notes Due 2031
(the "Class C-R Notes"), Assigned A2 (sf)

US$61,000,000 Class D-R Deferrable Floating Rate Notes Due 2031
(the "Class D-R Notes"), Assigned Baa3 (sf)

US$51,500,000 Class E-R Deferrable Floating Rate Notes Due 2031
(the "Class E-R Notes"), Assigned Ba3 (sf)

RATINGS RATIONALE

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

The Issuer is a managed cash flow collateralized loan obligation.
The issued notes are collateralized primarily by a portfolio of
broadly syndicated senior secured corporate loans. At least 90% of
the portfolio must consist of first lien senior secured loans, and
up to 10% of the portfolio may consist of second lien loans and
unsecured loans.

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

The Issuer issued the Refinancing Notes on December 6, 2019 in
connection with the refinancing of all classes of the secured notes
originally issued on June 15, 2018. On the Refinancing Date, the
Issuer used proceeds from the issuance of the Refinancing Notes,
along with the proceeds from the issuance of additional
subordinated notes, to redeem in full the Refinanced Original
Notes.

In addition to the issuance of the Refinancing Notes and additional
subordinated notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: shortening the notes' stated maturity from July 2031 to
January 2031; extension of the reinvestment period; extension of
the non-call period; changes to certain collateral quality tests;
and changes to the overcollateralization test levels.

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

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

Performing par and principal proceeds balance: $996,471,183

Defaulted par: $7,057,634

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2780

Weighted Average Spread (WAS): 3.35%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.25%

Weighted Average Life (WAL): 7.61 years

Methodology Underlying the Rating Action:

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

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

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


CD 2017-CD3: Fitch Affirms B-sf Rating on Class F Certs
-------------------------------------------------------
Fitch Ratings affirmed all classes of CD 2017-CD3 Mortgage Trust
Commercial Mortgage Pass-Through Certificates, Series 2017-CD3.

RATING ACTIONS

CD 2017-CD3 Mortgage Trust Series 2017-CD3

Class A-1 12515GAA5;  LT AAAsf Affirmed;  previously at AAAsf

Class A-2 12515GAB3;  LT AAAsf Affirmed;  previously at AAAsf

Class A-3 12515GAC1;  LT AAAsf Affirmed;  previously at AAAsf

Class A-4 12515GAD9;  LT AAAsf Affirmed;  previously at AAAsf

Class A-AB 12515GAE7; LT AAAsf Affirmed;  previously at AAAsf

Class A-S 12515GAF4;  LT AAAsf Affirmed;  previously at AAAsf

Class B 12515GAG2;    LT AA-sf Affirmed;  previously at AA-sf

Class C 12515GAH0;    LT A-sf Affirmed;   previously at A-sf

Class D 12515GAM9;    LT BBB-sf Affirmed; previously at BBB-sf

Class E 12515GAP2;    LT BB-sf Affirmed;  previously at BB-sf

Class F 12515GAR8;    LT B-sf Affirmed;   previously at B-sf

Class V-A 12515GAX5;  LT AAAsf Affirmed;  previously at AAAsf

Class V-B 12515GAZ0;  LT AA-sf Affirmed;  previously at AA-sf

Class V-C 12515GBB2;  LT A-sf Affirmed;   previously at A-sf

Class V-D 12515GBD8;  LT BBB-sf Affirmed; previously at BBB-sf

Class X-A 12515GAJ6;  LT AAAsf Affirmed;  previously at AAAsf

Class X-B 12515GAK3;  LT AA-sf Affirmed;  previously at AA-sf

Class X-D 12515GAV9;  LT BBB-sf Affirmed; previously at BBB-sf

KEY RATING DRIVERS

Stable Performance and Loss Expectations: The affirmations reflect
the overall stable performance and loss expectations with no
material changes to pool metrics since issuance. There were no
specially serviced loans since issuance.

The largest loan, 229 West 43rd Street Retail Condo (7.6% of pool),
which is secured by a 245,132-sf retail condominium located in New
York, NY was designated a Fitch Loan of Concern (FLOC). The loan
remains current; however, it was placed on the master servicer's
watchlist for the occurrence of multiple lease sweep periods
related to the National Geographic, Gulliver's Gate and OHM
tenants, which have triggered a cash flow sweep since December
2017. As of November 2019, the National Geographic (24.1% of NRA)
lease has been terminated and the tenant remains in occupancy and
operating, and the Gulliver's Gate (18.6%) lease has been
terminated and the tenant remains in occupancy and operating under
a Stipulation Agreement. In October 2019, Gulliver's Gate LLC filed
for bankruptcy; however, per the agreement, will pay $5.9 million
in fixed annual base rent for the period of April 1st 2019 through
March 2020, with $3.8 million, $3.6 million, $3.7 million and $3.8
million for each successive year, in addition to pro rata taxes and
operating expense reimbursements. Additionally, the vacant OHM
space (4.9% of NRA) and the National Geographic space, is currently
being marketed for lease as a combined space. As of June 2019
year-to-date (YTD), physical occupancy is 95.1% with a NOI DSCR of
0.94x. Fitch continues to monitor the stabilization of the
collateral property and tenancy operations and lease terms.

Minimal Change to Credit Enhancement: As of the November 2019
distribution date, the pool's aggregate balance has been reduced by
1.1% to $1.31 billion from $1.33 billion at issuance. All original
52 loans remain in the pool. One loan (1.1% of pool) is
fully-defeased. Sixteen loans (51.6%) are full term interest-only
and ten loans (17.8%) remain in their partial interest-only period.
Based on the scheduled balance at maturity, the pool will pay down
by 6.9%.

Pool Concentration: The top 10 loans represent 53% of the pool. The
largest property type in the transaction is office, representing
46.6% of the pool, followed by retail at 20.2%, hotel at 15.4% and
mixed-use at 10.4%.

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.


CIM TRUST 2019-R5: Moody's Assigns B3 Rating on Class B2 Debt
-------------------------------------------------------------
Moody's Investors Service assigned definitive ratings to eight
classes of notes issued by CIM Trust 2019-R5, which are backed by
one pool of primarily fixed-rate re-performing residential mortgage
loans. As of the cut-off date of October 31, 2019, the collateral
pool is comprised of 1,872 first lien mortgage loans with a
non-zero weighted average updated borrower FICO score of 661, a WA
current loan-to-value Ratio of 73.4% and a total unpaid balance of
$315,039,230. Approximately 78.5% of the collateral pool consists
of previously modified mortgage loans and about 11.7% consists of
adjustable-rate mortgage loans. Approximately 2.1% of the pool
balance is non-interest bearing, which consists of both principal
reduction alternative and non-PRA deferred principal balance.

Fay Servicing, LLC and Specialized Loan Servicing LLC will be the
primary servicers for 81.1% and 18.9% of the pool balance,
respectively. The servicers will not advance any principal or
interest on the delinquent loans, but they will be required to
advance costs and expenses incurred in connection with a default,
delinquency or other event in the performance of its servicing
obligations.

The complete rating actions are as follows:

Issuer: CIM Trust 2019-R5

Class A1, Definitive Rating Assigned Aaa (sf)

Class A1-A, Definitive Rating Assigned Aaa (sf)

Class A1-B, Definitive Rating Assigned Aaa (sf)

Class M1, Definitive Rating Assigned Aa2 (sf)

Class M2, Definitive Rating Assigned A3 (sf)

Class M3, Definitive Rating Assigned Baa3 (sf)

Class B1, Definitive Rating Assigned Ba2 (sf)

Class B2, Definitive Rating Assigned B3 (sf)

RATINGS RATIONALE

Summary Credit Analysis and Rating Rationale

Moody's expected loss on CIM 2019-R5's collateral pool is 12.00% in
its base case scenario and 36.00% at a stress level consistent with
the Aaa rating. Its loss estimates take into account the historical
performance of loans that have similar collateral characteristics
as the loans in the pool. Its credit opinion is the result of its
analysis of a wide array of quantitative and qualitative factors, a
review of the third-party review of the pool, servicing framework
and the representations and warranties framework.

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.

Collateral Description

CIM 2019-R5's collateral pool is primarily comprised of fixed-rate
re-performing mortgage loans. About 78.5% of mortgage loans in the
pool have been previously modified and about 11.7% of the mortgage
loans are adjustable-rate mortgage loans.

Moody's based its expected losses 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 a loan modification, and the amount of the
reduction in the monthly mortgage payment as a result of the
modification. The longer a borrower has been current on a
re-performing loan, the less likely the borrower is to re-default.
Approximately 40.5% of the borrowers have been current on their
payments for at least the past 24 months under the MBA method of
calculating delinquencies.

Moody's estimated expected losses for the pool using two approaches
-- (1) pool-level approach, and (2) re-performing loan level
analysis.

In the pool-level approach, Moody's estimates losses on the pool
using an approach similar to its surveillance approach whereby
Moody's applies assumptions of future delinquencies, default rates,
loss severities and prepayments based on observed performance of
similar collateral. Moody's projects future annual delinquencies
for eight years by applying an initial annual default rate and
delinquency burnout factors. Based on the loan characteristics of
the pool and the demonstrated pay histories, Moody's expects an
annual delinquency rate of 14.8% on the collateral pool for year
one. Moody's then calculated future delinquencies on the pool using
its default burnout and voluntary conditional prepayment rate (CPR)
assumptions. The delinquency burnout factors reflect its future
expectations of the economy and the U.S. housing market. Moody's
then aggregated the delinquencies and converted them to losses by
applying pool-specific lifetime default frequency and loss severity
assumptions. Its loss severity assumptions are based off observed
severities on liquidated seasoned loans and reflect the lack of
principal and interest advancing on the loans.

Moody's also conducted a loan level analysis on CIM 2019-R5'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 (1) loans that have the risk of
coupon step-ups and (2) 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 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.

As of the statistical cut-off date, approximately 2.1% of the pool
balance is non-interest bearing, which consists of both PRA and
non-PRA deferred principal balance. However, the PRA deferred
amount of $152,112 will be carved out as a separate Class PRA
note.

For non-PRA forborne amounts, the deferred balance is the full
obligation of the borrower and must be paid in full upon (i) sale
of property, (ii) voluntary payoff, or (iii) final scheduled
payment date. Upon sale of the property, the servicer therefore
could potentially recover some of the deferred amount. For loans
that default in future or get modified after the closing date, the
servicer may opt for partial or full principal forgiveness to the
extent permitted under the servicing agreement. Based on
performance and information from servicers, Moody's applied a
slightly higher default rate than what Moody's assumed for the
overall pool given that these borrowers have experienced past
credit events that required loan modification, as opposed to
borrowers who have been current and have never been modified. In
addition, Moody's assumed approximately 95% severity as the
servicer may recover a portion of the deferred balance. Its
expected loss does not consider the PRA deferred amount.

Transaction Structure

The securitization has a simple sequential priority of payments
structure without any cash flow triggers. The servicer will not
advance any principal or interest on delinquent loans. However, the
servicer will be required to advance costs and expenses incurred in
connection with a default, delinquency or other event in the
performance of its servicing obligations. Credit enhancement in
this transaction is comprised of subordination provided by
mezzanine and junior tranches. To the extent excess cashflow is
available, it will be used to pay down additional principal of the
bonds sequentially, building overcollateralization.

Moody's ran 96 different loss and prepayment scenarios through its
cash flow analysis. The scenarios encompass six loss levels, four
loss timing curves, and four prepayment curves.

Third Party Review

The sponsor engaged third-party diligence providers to conduct the
following due diligence reviews: (i) a title/lien review to confirm
the appropriate lien was recorded and the position of the lien and
to review for other outstanding liens and the position of those
liens; (ii) a state and federal regulatory compliance review on the
loans; (iii) a payment history review for the most recent two year
period (to the extent available) to confirm that the payment
strings matched the data supplied by or on behalf of the
third-party sellers; and (iv) a data comparison review on certain
characteristics of the loans.

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

The seller will prepare a schedule based upon the custodian's
exception report. The seller will have 90 days to cure any
exceptions related to missing mortgages or lost note affidavits. If
the seller is unable to cure, then it will repurchase such loans
within 90 days. Similarly, if the seller is unable to cure any
exceptions related to missing intervening assignments of mortgage
and/or missing intervening endorsements of the note within a year
from closing date, then the seller will be obligated to repurchase
such loans. The absence of an intervening assignment of mortgage,
original note or endorsement could delay or prevent the servicer
from foreclosing on the property or could reduce the value of the
loan. Similarly, other document exceptions can increase the
severity of a mortgage loan upon liquidation.

The diligence provider conducted a review of the title policies,
mortgages and lien searches (within twelve months of the cut-off
date) on all of the mortgage in the collateral pool to confirm the
first lien position of the mortgages and to identify other amounts
owed on the mortgage. Moody's did not increase losses for any
outstanding lien because the remedy provider will extinguish the
liens within 150 days of closing date. If the liens are not
extinguished, then remedy provider will be obligated to repurchase
the loans.

The review also consisted of validating 39 data fields for each
loan in the pool which resulted in 1,662 loans having one or more
data variances. It was determined that such data variances were
attributable to missing or defective source documentation,
non-material variances within acceptable tolerances, allocation
between documented and undocumented deferred principal balances,
timing and data formatting differences. Moody's did not make any
adjustments for these findings.

Representations & Warranties (R&W)

The R&W provider is Chimera Funding TRS LLC, wholly-owned
subsidiary of Chimera Investment Corporation (NYSE: CIM) and is not
an investment grade-rated entity. The creditworthiness of the R&W
provider determines the probability that the R&W provider will be
available and have the financial wherewithal to repurchase
defective loans upon identifying a breach. An investment
grade-rated R&W provider lends substantial strength to its R&Ws.
For financially weaker entities, Moody's looks for other offsetting
factors, such as a strong alignment of interest and enforcement
mechanisms, to derive the same level of protection. Moody's
analyzes the impact of less creditworthy R&W providers case by
case, in conjunction with other aspects of the transaction.

Mortgage loans will be reviewed for a breach of R&Ws only if one of
the following occurs (1) a loan becomes 120 days delinquent (MBA
method) or (2) a loan has been liquidated and upon such liquidation
has incurred a realized loss.

There are a few weaknesses in the enforcement mechanisms. First,
the independent reviewer is not identified at closing and, if the
owner trustee (on behalf of controlling holder) has difficulty
engaging one on acceptable terms, the controlling holder can direct
the trustee not to engage one. Furthermore, the review fees, which
the trust pays, are not agreed upon at closing and will be
determined in the future. Second, the remedies do not cover damages
owing to TILA under-disclosures. Moody's made adjustments to
account for such damages in its analysis. Finally, there will be no
remedy for an insurance-related R&W (i.e. any reduction in the
amount paid by a mortgage insurer or title insurer).

Overall, Moody's considers the R&W framework to be relatively
stronger compared to recent RPL securitizations rated by us because
every seriously delinquent loan is automatically reviewed, there is
a well-defined process in place to identify loans with defects on
an ongoing basis and the R&Ws do not sunset.

Trustee Indemnification

Moody's believes there is a very low likelihood that the rated
notes in CIM 2019-R5 will incur any loss from extraordinary
expenses or indemnification payments owing to potential future
lawsuits against key deal parties. First, majority of the loans are
seasoned with demonstrated payment history, reducing the likelihood
of a lawsuit on the basis that the loans have underwriting defects.
Second, the transaction has reasonably well-defined processes in
place to identify loans with defects on an ongoing basis. In this
transaction a well-defined breach discovery and enforcement
mechanism reduces the likelihood that parties will be sued for
inaction.

Servicing arrangement

Fay and SLS will be the primary servicers for 81.1% and 18.9% of
the collateral pool, respectively. In the event of a termination of
a servicer under the related Servicing Agreement, a successor
servicer that is reasonably acceptable to the Class C holder will
be appointed by the Depositor on behalf of the Issuer. In addition,
the servicers do not advance principal and interest on delinquent
loans in this transaction which would make servicing transfer
easier as the replacement servicer will not be obligated to make
P&I advances. Moody's considers the overall servicing arrangement
to be credit neutral.

Other Considerations

The servicers will not commence foreclosure proceedings on a
mortgage loan unless the related servicer has notified the Class C
holder (which, as of the closing date, will be the sponsor or one
of its affiliate) at least five (5) business days in advance of the
foreclosure and the Class C holder has not objected to such action.
If the Class C holder objects, the related servicer has to obtain
three appraisals from the appraisal firms as listed in the pooling
and servicing agreement. The cost of the appraisals is borne by the
Class C holder. The Class C 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 related servicer cannot obtain
three appraisals there are alternate methods for determining the
purchase price. If the Class C holder fails to purchase the
mortgage loan within the time frame, the Class C holder forfeits
any foreclosure rights thereafter. Moody's considers this credit
neutral because a) the appraiser is chosen by the related servicer
from the approved list of appraisers, b) the fair value of the
property is decided by the related servicer, based on third party
appraisals, and c) the Class C holder will pay the fair price and
accrued interest.

Other Transaction Parties

Wells Fargo Bank, N.A. will act as the custodian, trust
administrator and paying agent. Wilmington Savings Fund Society,
FSB will be the owner trustee and U.S. Bank National Association
will be the indenture trustee.

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

Factors that would lead to an upgrade of the ratings

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.

Factors that would lead to a downgrade of the ratings

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.


CITIGROUP COMMERCIAL 2019-C7: DBRS Gives Prov. B(low) on J-RR Certs
-------------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-C7 to be
issued by the Citigroup Commercial Mortgage Trust 2019-C7:

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-AB at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X-A AAA (sf)
-- Class B at AAA (sf)
-- Class C at A (high) (sf)
-- Class X-B at AA (low) (sf)
-- Class D at BBB (high) (sf)
-- Class E at BBB (low) (sf)
-- Class X-D at BBB (sf)
-- Class F at BB (high) (sf)
-- Class X-F at BBB (low) (sf)
-- Class G at BB (high) (sf)
-- Class X-G at BBB (low) (sf)
-- Class H at B (high) (sf)
-- Class X-H at BB (low) (sf)
-- Class J-RR at B (low) (sf)

All trends are Stable. Classes X-B, X-D, D, E, F, G, H, and J-RR
will be privately placed.

The collateral consists of 55 fixed-rate loans secured by 113
commercial and multifamily properties. The transaction is a
sequential-pay pass-through structure. DBRS Morningstar analyzed
the conduit pool to determine the provisional ratings, reflecting
the long-term probability of loan default within the term and its
liquidity at maturity. Two loans, representing approximately a
combined 8.8% of the pool, have investment-grade shadow ratings
from DBRS Morningstar. Based on the cutoff loan balances against
the DBRS Morningstar Stabilized Net Cash Flow and their respective
actual constants, five loans, representing a combined 5.1% of the
pool, had a DBRS Morningstar Term Debt Service Coverage Ratio
(DSCR) below 1.32 times (x), a threshold indicative of a higher
likelihood of midterm default. The pool additionally includes 16
loans (representing a combined 27.9% of the pool by allocated loan
balance) with issuance loan-to-value ratios (LTVs) exceeding 67.1%,
a threshold historically indicative of above-average default
frequency. The weighted-average (WA) LTV of the pool at issuance is
61.8%, and the pool will amortize down to a WA LTV of 57.6% at
maturity.

The collateral features two loans, representing a combined 8.8% of
the pool, that have investment-grade shadow ratings from DBRS
Morningstar: 650 Madison and 805 3rd Avenue. The 650 Madison loan
exhibits credit characteristics consistent with a BBB (low) shadow
rating, and 805 3rd Avenue exhibits credit characteristics
consistent with a BBB shadow rating.

Of the 55 loans in the pool, the DBRS Morningstar sample included
27 loans, representing a combined 73.6% of the pool by allocated
loan balance. Of the loans sampled, 12, representing 55.2% of the
sample, have either Average (+) or Above Average property quality.
Additionally, only four loans, representing 13.5% of the sampled
loans, have Average (-) or Below Average property quality. The
properties securing the three largest loans in the pool, all with
identical balances representing 4.4% of the pool balance each, are
Average (+).

The pool exhibits some leverage barbell. While the pool has six
loans, representing 13.1% of the pool balance, which have an
issuance LTV below 59.3%, a threshold historically indicative of
relatively low-leverage financing and generally associated with
below-average default frequency, there are also 16 loans,
representing 27.9% of the pool balance, which have an issuance LTV
above 67.1%, a threshold historically indicative of relatively
high-leverage financing and generally associated with above-average
default frequency. Only two of the identified high-leverage loans
exhibit a DBRS Morningstar DSCR of less than 1.32x. These loans
exhibited a WA expected loss of 6.8%, which is considerably higher
than the WA expected loss of the overall pool. As a result, DBRS
Morningstar reflects the risk of these loans in the credit
enhancement levels of the pool.

The pool features a relatively high concentration of loans secured
by properties in less favorable suburban market areas. Thirty
loans, representing 46.9% of the pooled cutoff balance, are secured
by properties predominately in areas with a DBRS Morningstar Market
Rank of either 3 or 4. The DBRS Morningstar WA DSCR of these loans
is still relatively high at 1.87x and the pool also has 13 loans,
representing 31.2% of the cutoff pool balance, that are in urban
areas with a DBRS Morningstar Market Rank of 7 or 8.

Classes X-A, X-B, X-D X-F, X-G, and X-H are interest-only (IO)
certificates that reference a single rated tranche or multiple
rated tranches. The IO rating mirrors the lowest-rated applicable
reference obligation tranche adjusted upward by one notch if senior
in the waterfall.

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


COMM 2013-LC6: Moody's Affirms B2 Rating on Class F Certs
---------------------------------------------------------
Moody's Investors Service upgraded the ratings on three classes and
affirmed the ratings on nine classes in COMM 2013-LC6 Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series
2013-LC6:

Cl. A-3, Affirmed Aaa (sf); previously on Aug 30, 2018 Affirmed Aaa
(sf)

Cl. A-4, Affirmed Aaa (sf); previously on Aug 30, 2018 Affirmed Aaa
(sf)

Cl. A-M, Affirmed Aaa (sf); previously on Aug 30, 2018 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Aug 30, 2018 Affirmed
Aaa (sf)

Cl. B, Upgraded to Aa2 (sf); previously on Aug 30, 2018 Affirmed
Aa3 (sf)

Cl. C, Upgraded to A2 (sf); previously on Aug 30, 2018 Affirmed A3
(sf)

Cl. D, Affirmed Baa3 (sf); previously on Aug 30, 2018 Affirmed Baa3
(sf)

Cl. E, Affirmed Ba2 (sf); previously on Aug 30, 2018 Affirmed Ba2
(sf)

Cl. F, Affirmed B2 (sf); previously on Aug 30, 2018 Affirmed B2
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Aug 30, 2018 Affirmed
Aaa (sf)

Cl. X-B*, Upgraded to A1 (sf); previously on Aug 30, 2018 Affirmed
A2 (sf)

Cl. X-C*, Affirmed Caa1 (sf); previously on Aug 30, 2018 Affirmed
Caa1 (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on seven principal and interest classes were affirmed
because the transaction's key metrics, including Moody's
loan-to-value ratio, Moody's stressed debt service coverage ratio
and the transaction's Herfindahl Index, are within acceptable
ranges.

The ratings on two P&I classes, Cl. B and Cl. C, were upgraded due
to increased credit support from paydowns and amortization as well
as an increase in the pool's share of defeasance. The deal has paid
down 32.5% since securitization and defeasance now represents 8.4%
of the pool.

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

The rating on the IO class, Cl. X-B, was upgraded due to the
improvement in the credit quality of its referenced classes.

Moody's rating action reflects a base expected loss of 3.5% of the
current pooled balance, compared to 3.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 2.4% of the
original pooled balance, compared to 2.2% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

DEAL PERFORMANCE

As of the November 13, 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 32.5% to $1.01
billion from $1.49 billion at securitization. The certificates are
collateralized by 57 mortgage loans ranging in size from less than
1% to 16.2% of the pool, with the top ten loans (excluding
defeasance) constituting 56.2% of the pool. Eight loans,
constituting 8.4% of the pool, have defeased and are secured by US
government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 15, compared to 17 at Moody's last review.

There are currently no loans on the master servicer's watchlist.
The watchlist includes loans that meet certain portfolio review
guidelines established as part of the CRE Finance Council (CREFC)
monthly reporting package. As part of Moody's ongoing monitoring of
a transaction, the agency reviews the watchlist to assess which
loans have material issues that could affect performance.

One loan has been liquidated from the pool, resulting in a minimal
realized loss of $170,049. There are currently two loans in special
servicing, constituting 2.0% of the pool. The largest specially
serviced loan is the Campus Pointe & Campus Manor Apartments Loan
($15.9 million -- 1.6% of the pool), which is secured by two
jointly owned and managed student housing properties located in
Macomb, Illinois. The properties serve the student population of
Western Illinois University and have a combined 356-units
containing 631 beds. The loan transferred to special servicing in
June 2017 for imminent maturity default due to a significant
decline in rental revenue. The property's occupancy had declined
from a high of 94% in 2014 to 67% at year-end 2017. The reported
occupancy as of June 2018 was 73%. The property became REO in June
2019 and the special servicer is working toward a disposition
during the second quarter of 2020.

The other specially serviced loan is the Candlewood Suites Kingwood
($4.6 million -- 0.5% of the pool), which is secured by a 75-room
extended stay hotel in Kingwood, Texas. The loan was transferred to
special servicing in August 2019 for imminent default. The property
has faced significant declines in revenue per available room
(RevPAR) since securitization. The loan is currently 90+ days
delinquent and is last paid through its July 2019 payment date.
Moody's has estimated an aggregate loss of $13.4 million (a 65%
expected loss on average) from the specially serviced loans.

Moody's received full year 2018 operating results for 100% of the
pool, and a partial year 2019 operating results for 89% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 89%, compared to 87% at Moody's last review.
Moody's conduit component excludes loans with structured credit
assessments, defeased and CTL loans, and specially serviced and
troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 17% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.6%.

Moody's actual and stressed conduit DSCRs are 1.72X and 1.23X,
respectively, compared to 1.79X and 1.25X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 33% of the pool balance. The
largest loan is the Moffett Towers Loan ($163.5 million -- 16.2% of
the pool), which is secured by three eight-story Class A office
buildings totaling approximately 950,000 SF and located in
Sunnyvale, California. The loan is componentized into three senior
notes in the aggregate principal amount of $312.9 million and the
asset is also encumbered by $50 million in mezzanine debt. All
three buildings are LEED Gold certified and have a combined 2,881
parking spaces as well as shared amenities. As of June 2019 the
property was 98% leased, the same as in December 2018 and compared
to 100% in December 2017. All tenants at the property are on triple
net leases. The third largest tenant, Rambus Inc.(16.5% of NRA,
lease expiration June 2020), has announced they will be relocating
from this location to a new 90,000 square-foot office space in
North San Jose. Overall, the property's performance has improved
significantly since securitization and the year-end 2018 NOI was
27% above the levels at securitization due to higher rental
revenues. The loan has amortized 7% since securitization and
Moody's A-note LTV and stressed DSCR are 97% and 1.01X,
respectively, compared to 99% and 0.98X at the last review.

The second largest loan is the Coastland Center Loan ($111.8
million -- 11.1% of the pool), which is secured by a 459,000 SF
portion of a 926,000 SF regional mall located in Naples, Florida.
The mall currently has two non-collateral anchors, Dillard's and
Macys and one collateral anchor, J.C. Penney. A former
non-collateral anchor, Sears, closed its store in November 2018.
The former Sears location is being demolished and there are plans
for a stand-alone luxury movie theater. As of December 2018 rent
roll, the total mall occupancy was 98% (however, excluding Sears
total occupancy would be 81%). Overall, the collateral performance
improved from securitization through year-end 2016, however, the
reported NOI in 2017 and 2018 declined below the levels at
securitization. The loan has amortized nearly 14% since
securitization and Moody's LTV and stressed DSCR are 108% and
0.97X, respectively, compared to 95% and 1.12X at the last review.

The third largest loan is the Innisfree Pensacola Beach Hotel
Portfolio Loan ($61.1 million -- 6.1% of the pool), which is
secured by two adjacent full-service hotel properties located
directly on the beach in Pensacola, Florida. The larger hotel, The
Hilton, is a 275-key, 17-story resort and conference center, built
in 2003 with an addition in 2007. The smaller hotel, The Holiday
Inn, is a 206-key, 11-story resort built in 2011. For the trailing
twelve month period ending June 2019, the combined occupancy and
revenue per available room (RevPAR) were 84% and $181, compared to
81% and $173, respectively, for the full year 2018. The portfolio's
NOI has increased since securitization primarily due to higher
RevPAR. The loan benefits from amortization and has amortized by
11% since securitization. Moody's LTV and stressed DSCR are 70% and
1.62X, respectively, compared to 72% and 1.58X at the last review.


CREDIT SUISSE 2005-C5: Fitch Affirms CCsf Rating on Cl. G Certs
---------------------------------------------------------------
Fitch Ratings affirmed 10 classes of Credit Suisse First Boston
Mortgage Securities Corp. series 2005-C5 (CSFB 2005-C5), commercial
mortgage pass-through certificates.

RATING ACTIONS

Credit Suisse First Boston Mortgage Securities Corp. 2005-C5

Class G 225470BA0; LT CCsf Affirmed; previously at CCsf

Class H 225470BC6; LT Csf Affirmed;  previously at Csf

Class J 225470BE2; LT Dsf Affirmed;  previously at Dsf

Class K 225470BG7; LT Dsf Affirmed;  previously at Dsf

Class L 225470BJ1; LT Dsf Affirmed;  previously at Dsf

Class M 225470BL6; LT Dsf Affirmed;  previously at Dsf

Class N 225470BN2; LT Dsf Affirmed;  previously at Dsf

Class O 225470BQ5; LT Dsf Affirmed;  previously at Dsf

Class P 225470BS1; LT Dsf Affirmed;  previously at Dsf

Class Q 225470DQ3; LT Dsf Affirmed;  previously at Dsf

KEY RATING DRIVERS

Fitch Loan of Concern; High Loss Expectations: The affirmations of
the distressed classes reflect their reliance on the repayment of
the Gallery at South Dekalb loan (61.6% of pool). The loan is
secured by a 444,393-sf portion of a 620,393-sf regional mall
located in Decatur, GA (seven miles southeast of Atlanta) and is
shadow-anchored by a non-collateral Macy's store. The original
$44.1 million interest-only loan was previously modified (December
2015) while in special servicing. Terms of the modification
included a borrower equity contribution, plus a bifurcation of the
remaining loan into a $29 million A-Note and a $14.4 million B-Note
(Hope Note). The loan maturity was also extended four years to July
2019. The loan was returned to the master servicer in April 2016.

Property performance has not recovered since being modified, with
occupancy remaining low at 57% as of August 2019. Satellite Cinemas
(8% of net rentable area) vacated in September 2017 after only
opening in January 2016; the former tenant is currently in
litigation with the sponsor. Property NOI continues to decline,
with YE 2018 NOI declining 17.6% from YE 2017 and 35.6% below YE
2015. Comparable tenant sales were $288 psf in 2018, compared with
$278 psf in 2017 and $312 psf in 2016. The property also faces
primary competition from Greenbriar Mall (12.6 miles away from the
subject) and The Mall at Stonecrest (10.4 miles), and secondary
competition from Southlake Mall (10.4 miles) and North DeKalb Mall
(6.8 miles).

Fitch's analysis assumes a full loss on the Hope note, which would
be absorbed by the current class J (rated 'Dsf') and class H (rated
'Csf') balances. Given the continued decline in performance since
the loan's modification, and retransferring to special servicing in
March 2019, the repayment of the A-note remains uncertain and loss
expectations remain high. The distressed classes incorporate this
analysis.

Defeasance and Fully Amortizing Loan: Two loans (38.3% of pool) are
fully defeased and one additional loan is fully amortizing (0.1%).
All three loans mature between July 2020 and September 2020. Based
on the current balances, the defeased loans would repay
approximately 71% of the current class G balance by July 2020.

As of the November 2019 distribution date, the transaction has been
reduced by 97.7% to $66.3 million from $2.94 billion at issuance.
There have been $146.6 million (5% of original pool balance) in
realized losses to date. Cumulative interest shortfalls of $7.3
million are currently affecting classes H through S and the
remaining pool balance is undercollateralized by $1.05 million.
Since Fitch's last rating action, the Garden Village Apartments
loan (4.1% of pool balance at last review), prepaid with yield
maintenance.

Concentrated Pool: The pool is highly concentrated with only four
loans remaining of the original 282. Due to the concentrated nature
of the pool, Fitch performed a sensitivity analysis that grouped
the remaining loans based on the likelihood of repayment and
expected losses from underperforming or overleveraged loans.

RATING SENSITIVITIES

Upgrades are not likely. A downgrade of the distressed classes to
'D' is expected as losses are realized.


CSMC 2019-NQM1: S&P Assigns B (sf) Rating to Class B-2 Notes
------------------------------------------------------------
S&P Global Ratings assigned its ratings to CSMC 2019-NQM1 Trust's
mortgage-backed notes.

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

The ratings reflect:

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

  RATINGS ASSIGNED
  CSMC 2019-NQM1 Trust

  Class      Rating(i)      Amount ($)
  A-1        AAA (sf)      228,714,000
  A-2        AA (sf)        21,589,000
  A-3        A (sf)         34,737,000
  M-1        BBB (sf)       16,232,000
  B-1        BB (sf)        11,363,000
  B-2        B (sf)          7,629,000
  B-3        NR              4,383,492
  A-IO-S     NR               Notional(ii)
  XS         NR               Notional(ii)
  PT(iii)    NR            324,647,492
  R          NR                    N/A

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


CWHEQ REVOLVING 2006-RES: Moody's Hikes Rating on 2 Tranches to Ba1
-------------------------------------------------------------------
Moody's Investors Service upgraded the ratings of eight notes and
downgraded the rating of one note backed by US RMBS tranches,
issued by CWHEQ Revolving Home Equity Loan Resecuritization Trust
2006-RES and Lehman Manufactured Housing Asset-Backed Trust
1998-1.

Complete rating actions are as follows:

Issuer: CWHEQ Revolving Home Equity Loan Resecuritization Trust
2006-RES

Cl. 04L-1a, Upgraded to Baa1 (sf); previously on Jun 4, 2019
Affirmed Baa3 (sf)

Cl. 04L-1b, Upgraded to Baa1 (sf); previously on Jun 4, 2019
Affirmed Baa3 (sf)

Cl. 04R-1a, Upgraded to Ba2 (sf); previously on Jun 4, 2019
Affirmed B2 (sf)

Cl. 04R-1b, Upgraded to Ba2 (sf); previously on Jun 4, 2019
Affirmed B2 (sf)

Cl. 05B-1a, Upgraded to B2 (sf); previously on Jun 4, 2019 Affirmed
B3 (sf)

Cl. 05B-1b, Upgraded to B2 (sf); previously on Jun 4, 2019 Affirmed
B3 (sf)

Cl. 05H-1a, Upgraded to Ba1 (sf); previously on Jun 4, 2019
Affirmed Ba3 (sf)

Cl. 05H-1b, Upgraded to Ba1 (sf); previously on Jun 4, 2019
Affirmed Ba3 (sf)

Issuer: Lehman Manufactured Housing Asset-Backed Trust 1998-1

II-IO1*, Downgraded to C (sf); previously on Jun 4, 2019 Affirmed
Caa3 (sf)

*Reflects Interest-Only Class

RATINGS RATIONALE:

The ratings upgrades of underlying bonds pledged to the related
resecuritizations have prompted the subsequent upgrades of tranches
in CWHEQ Revolving Home Equity Loan Resecuritization Trust
2006-RES.

The downgrade of the rating of the Class II-IO1 bond in Lehman
Manufactured Housing Asset-Backed Trust 1998-1 to C (sf) reflects
the nonpayment of interest for an extended period. The coupon rate
is subject to a calculation that has reduced the required interest
distribution to zero. Because the coupon on this bond is subject to
changes in interest rates and underlying tranche composition, there
is a remote possibility that they may receive interest in the
future.

The principal methodology used in rating all classes except
interest-only classes was "Moody's Approach to Rating Repackaged
Securities" published in March 2019. The methodologies used in
rating interest-only classes were "Moody's Approach to Rating
Repackaged Securities" published in March 2019 and "Moody's
Approach to Rating Structured Finance Interest-Only (IO)
Securities" published in February 2019.

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

For CWHEQ Revolving Home Equity Loan Resecuritization Trust
2006-RES, given the repack nature of the structure, note-holders
are mainly exposed to the credit risk of the underlying asset(s). A
downgrade or upgrade of the underlying asset(s) could trigger a
downgrade or upgrade on the related repack notes.

An IO bond may be upgraded or downgraded, within the constraints
and provisions of the IO methodology, based on lower or higher
realized and expected loss due to an overall improvement or decline
in the credit quality of the reference bonds and/or pools.


FANNIE MAE 2019-HRP1: S&P Rates Nine Classes of Notes 'B (sf)'
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to Fannie Mae Connecticut
Avenue Securities Trust 2019-HRP1's securities.

The issuance is an RMBS transaction in which the payments are
determined by a reference pool of residential mortgage loans, deeds
of trust, or similar security instruments encumbering mortgaged
properties acquired by Fannie Mae.

The ratings reflect S&P's view of:

-- The credit enhancement provided by the subordinated reference
tranches and the associated structural deal mechanics;

-- The credit quality of the collateral included in the reference
pool;

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

-- Fannie Mae's aggregation experience and the alignment of
interests between the issuer and the security holders in the deal's
performance, which, in S&P's view, enhances the securities'
strength; and

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

  RATINGS ASSIGNED

  Fannie Mae Connecticut Avenue Securities Trust 2019-HRP1

  Class        Rating              Amount ($)
  A-H(i)       NR             105,687,174,713
  M-2A(ii)     BB- (sf)           278,896,000
  M-AH(i)      NR                  14,679,485
  M-2B(ii)     B (sf)             278,896,000
  M-BH(i)      NR                  14,679,485
  B-1          NR                 405,667,000
  B-1H(i)      NR                  21,351,888
  B-2H(i)      NR                  53,377,361

  RCR exchangeable notes
  RCR note     Rating              Amount ($)
  M-2          B (sf)             557,792,000
  E-A1         BB- (sf)           278,896,000
  A-I1         BB- (sf)           278,896,000
  E-A2         BB- (sf)           278,896,000
  A-I2         BB- (sf)           278,896,000
  E-A3         BB- (sf)           278,896,000
  A-I3         BB- (sf)           278,896,000
  E-A4         BB- (sf)           278,896,000
  A-I4         BB- (sf)           278,896,000
  E-B1         B (sf)             278,896,000
  B-I1         B (sf)             278,896,000
  E-B2         B (sf)             278,896,000
  B-I2         B (sf)             278,896,000
  E-B3         B (sf)             278,896,000
  B-I3         B (sf)             278,896,000
  E-B4         B (sf)             278,896,000
  B-I4         B (sf)             278,896,000

(i)Reference tranche only and will not have corresponding
securities. Fannie Mae retains the risk of each of these tranches.
(ii)Class M-2 is offered at closing and may be exchanged for
classes M-2A and M-2B.
RCR--Related combinable and recombinable notes.
NR--Not rated.



FLAGSHIP CREDIT 2019-4: DBRS Finalizes BB Rating on Class E Notes
-----------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of notes issued by Flagship Credit Auto Trust 2019-4 (the
Issuer):

-- $262,450,000 Class A Notes at AAA (sf)
-- $35,060,000 Class B Notes at AA (sf)
-- $45,080,000 Class C Notes at A (sf)
-- $36,060,000 Class D Notes at BBB (sf)
-- $20,030,000 Class E Notes at BB (sf)

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

(1) Transaction capital structure, proposed ratings and form, and
sufficiency of available credit enhancement.

-- Credit enhancement is in the form of over-collateralization
(OC), subordination, amounts held in the reserve fund and excess
spread. Credit enhancement levels are sufficient to support the
DBRS Morningstar-projected cumulative net loss assumption under
various stress scenarios.

(2) The ability of the transaction to withstand stressed cash flow
assumptions and repay investors according to the terms under which
they have invested.

-- For this transaction, the ratings address the timely payment of
interest on a monthly basis and the payment of principal by the
legal final maturity date.

(3) The consistent operational history of Flagship Credit
Acceptance, LLC (Flagship or the Company) and the strength of the
overall Company and its management team.

-- Flagship's senior management team has considerable experience
and a successful track record in the auto finance industry.

(4) The capabilities of Flagship with regard to origination,
underwriting, and servicing.

-- DBRS Morningstar has performed an operational review of
Flagship and considers the entity an acceptable originator and
servicer of subprime automobile loan contracts with an acceptable
backup servicer.

(5) DBRS Morningstar exclusively used the static pool approach
because Flagship has enough data to generate a sufficient amount of
static pool projected losses.

-- DBRS Morningstar was conservative in the loss forecast analysis
that is performed on the static pool data and gave no seasoning to
this collateral.

(6) The Company has indicated that it may be subject to various
consumer claims and litigation seeking damages and statutory
penalties. Some litigation against the Company could take the form
of class action complaints by consumers. However, the Company has
indicated that there is no material pending or threatened
litigation.

(7) Robert Hurzeler joined the Company as Chief Executive Officer
(CEO) and joined the Company's board. Hurzeler previously served as
Executive Vice President and Chief Operating Officer of OneMain
Holdings, Inc. Michael Ritter, the prior CEO, will remain with the
Company as Chairman of the Board.

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

Flagship is an independent full-service automotive financing and
servicing company that provides (1) financing to borrowers who do
not typically have access to prime credit-lending terms for the
purchase of late-model vehicles and (2) refinancing of existing
automotive financing.

The rating on the Class A Notes reflects the 35.50% of initial hard
credit enhancement provided by the subordinated notes in the pool
(34.00%), the Reserve Account (1.00%) and OC (0.50%). The ratings
on Class B, C, D and E Notes reflect 26.75%, 15.50%, 6.50% and
1.50% of initial hard credit enhancement, respectively. Additional
credit support may be provided from excess spread available in the
structure.

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


GS MORTGAGE 2006-GG8: Fitch Lowers Class A-J Certs to CCCsf
-----------------------------------------------------------
Fitch Ratings downgraded one distressed class and has affirmed 15
classes of GS Mortgage Securities Corporation II commercial
mortgage pass-through certificates, series 2006-GG8.

RATING ACTIONS

GS Mortgage Securities Corp. II 2006-GG8

Class A-J 362332AH1; LT CCCsf Affirmed; previously at CCCsf

Class B 362332AJ7;   LT CCsf Affirmed;  previously at CCsf

Class C 362332AK4;   LT Csf Affirmed;   previously at Csf

Class D 362332AL2;   LT Dsf Downgrade;  previously at Csf

Class E 362332AM0;   LT Dsf Affirmed;   previously at Dsf

Class F 362332AN8;   LT Dsf Affirmed;   previously at Dsf

Class G 362332AT5;   LT Dsf Affirmed;   previously at Dsf

Class H 362332AV0;   LT Dsf Affirmed;   previously at Dsf

Class J 362332AX6;   LT Dsf Affirmed;   previously at Dsf

Class K 362332AZ1;   LT Dsf Affirmed;   previously at Dsf

Class L 362332BB3;   LT Dsf Affirmed;   previously at Dsf

Class M 362332BD9;   LT Dsf Affirmed;   previously at Dsf

Class N 362332BF4;   LT Dsf Affirmed;   previously at Dsf

Class O 362332BH0;   LT Dsf Affirmed;   previously at Dsf

Class P 362332BK3;   LT Dsf Affirmed;   previously at Dsf

Class Q 362332BM9;   LT Dsf Affirmed;   previously at Dsf

KEY RATING DRIVERS

Concentrated Pool, Significant Loss Expectations: The transaction
is very concentrated with only two loans/assets remaining. Due to
the concentrated nature of the pool, Fitch performed a look through
analysis to the underlying pool, which consists of one Fitch Loan
of Concern (FLOC, 67% of the pool), secured by a single tenant
office property located in Islandia, NY, and an REO office property
located in Fairfax, VA (33%). Overall loss expectations on the
loans/assets are high.

Fitch Loan of Concern, Single Tenant Risk: The largest loan in the
pool is secured by a single-tenant 778,370 sf suburban office
building located in Islandia, NY. The loan transferred to special
servicing in April 2016 for imminent maturity default and returned
back to the master servicer in May 2017 when the maturity date was
extended to October 2020 with an option to further extend to August
2021. The property is 100% leased to Computer Associates through
August 2021. The property has served as the company's headquarters.
In November 2018, Broadcom Inc. acquired Computer Associates, an
information technology management and solutions provider. Fitch has
requested additional information from the servicer on the leasing
status of the tenant and is awaiting response. A letter of credit
reserve was established with a cap of $1.15 million that is fully
funded. In addition, a hard lockbox is in place with excess cash
going into the general reserve account; which has a current balance
is $7.8 million, per the servicer. Given the binary risk associated
with the single tenant lease expiration, Fitch remains concerned
about the ability of this loan to refinance.

REO Asset: A 45% interest in an REO office property (33%) is
included in the pool. The property, which is 59% occupied per the
April 2019 rent roll, is located in Fairfax, VA. The original pari
passu loan was secured by nine suburban office buildings located in
Fairfax, VA. The loan transferred to special servicing in 2015 and
became REO in 2016; eight properties have since been sold.

Minimal Change to Credit Enhancement: Since Fitch's last rating
action two specially serviced loans have been disposed, resulting
in $23.8 million in realized losses. As of the November 2018
distribution, the pool has been reduced by 94.2% to $246.8 million
from $4.24 billion at issuance. The pool has incurred $429.6
million in realized losses to date.

RATING SENSITIVITIES

Further downgrades on the distressed classes are possible as losses
are realized on the REO asset or should the largest loan not
refinance at maturity.

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.


GSAMP TRUST 2004-OPT: Moody's Upgrades Class M-2 Debt to B3
-----------------------------------------------------------
Moody's Investors Service upgraded the rating of seven tranches
from five transactions backed Subprime loans.

Complete rating actions are as follows:

Issuer: GSAMP Trust 2004-OPT

Cl. M-2, Upgraded to B3 (sf); previously on Mar 17, 2011 Downgraded
to Caa3 (sf)

Issuer: GSAMP Trust 2007-HE1

Cl. A-1, Upgraded to Ba3 (sf); previously on Apr 30, 2017 Upgraded
to B1 (sf)

Cl. A-2C, Upgraded to Ba2 (sf); previously on Apr 30, 2017 Upgraded
to B1 (sf)

Cl. A-2D, Upgraded to Ba3 (sf); previously on Apr 30, 2017 Upgraded
to B1 (sf)

Issuer: GSAMP Trust 2007-HSBC1

Cl. M-6, Upgraded to B3 (sf); previously on Feb 26, 2018 Upgraded
to Caa2 (sf)

Issuer: New Century Home Equity Loan Trust 2005-4

Cl. M-5, Upgraded to Caa1 (sf); previously on Nov 27, 2018 Upgraded
to Ca (sf)

Issuer: New Century Home Equity Loan Trust, Series 2005-1

Cl. M-5, Upgraded to Caa2 (sf); previously on Jun 1, 2010
Downgraded to C (sf)

RATINGS RATIONALE

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

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.5% in November 2019 from 3.7% in
November 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.


GUGGENHEIM MM 2019-2: S&P Rates Class E Debt 'BB- (sf)'
-------------------------------------------------------
S&P Global Ratings assigned its ratings to Guggenheim MM CLO 2019-2
Ltd./Guggenheim MM CLO 2019-2 LLC's senior secured term debt.

The debt issuance is CLO transaction backed primarily by middle
market speculative-grade (rated 'BB+' and lower) senior secured
term loans that are governed by collateral quality tests.

The ratings reflect:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  Guggenheim MM CLO 2019-2 Ltd./Guggenheim MM CLO 2019-2 LLC

  Class                  Rating      Amount (mil. $)
  A-1a                   AAA (sf)             135.63
  A-1b                   AAA (sf)               8.50
  A-1a loan              AAA (sf)              75.00
  A-2                    AAA (sf)              27.40
  B                      AA (sf)               29.70
  C                      A (sf)                38.60
  D                      BBB- (sf)             26.10
  E                      BB- (sf)              24.00
  Subordinated ws     NR                    54.20
  NR--Not rated.



HOMEWARD OPPORTUNITIES 2019-3: DBRS Finalizes B Rating on B2 Certs
------------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage Pass-Through Certificates, Series 2019-3 (the
Certificates) issued by Homeward Opportunities Fund I Trust 2019-3
(HOF I 2019-3 or the Trust):

-- $263.5 million Class A-1 at AAA (sf)
-- $27.3 million Class A-2 at AA (sf)
-- $48.9 million Class A-3 at A (sf)
-- $24.9 million Class M-1 at BBB (sf)
-- $19.9 million Class B-1 at BB (sf)
-- $15.8 million Class B-2 at B (sf)

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

The AAA (sf) rating on the Class A-1 Certificates reflects 35.90%
of credit enhancement provided by subordinated Certificates in the
pool. The AA (sf), A (sf), BBB (sf), BB (sf) and B (sf) ratings
reflect 29.25%, 17.35%, 11.30%, 6.45% and 2.60% of credit
enhancement, respectively.

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate, prime, expanded prime and non-prime first-lien
residential mortgages funded by the issuance of the Certificates.
The Certificates are backed by 590 mortgage loans with a total
principal balance of $411,111,003 as of the Cut-Off Date (November
1, 2019).

The originators for the underlying mortgage pool are Sprout
Mortgage Corporation (Sprout; 67.2%); 5th Street Capital, Inc.
(30.3%); and various other originators, each comprising less than
2.0% of the mortgage loans. Specialized Loan Servicing LLC (53.8%)
and Fay Servicing, LLC (46.2%) will service all loans within the
pool.

The Sprout mortgages were originated under the following programs:

(1) Income Per Bank Statements (46.2%) — Generally made to
self-employed borrowers using bank statements to support
self-employed income for qualification purposes.

(2) Jumbo Special Feature (17.7%) — Generally made to borrowers
with loan amounts exceeding the government-sponsored enterprise
(GSE) loan limits who may fall outside the Qualified Mortgage (QM)
requirements based on debt-to-income or loans that have special
features that do not meet GSE guidelines.

(3) Asset Depletion (3.3%) — Generally made to borrowers with
significant assets equal to 110% or more of the original mortgage
balance.

Although the mortgage loans were originated to satisfy the Consumer
Financial Protection Bureau's QM and Ability-to-Repay (ATR) rules,
they were made to borrowers who generally do not qualify for an
agency, government or private-label non-agency prime jumbo products
for various reasons. In accordance with the QM/ATR rules, 1.3% of
the loans are designated as QM Safe Harbor and 90.5% as non-QM.
Approximately 8.2% of the loans are made to investors for business
purposes and, hence, are not subject to the QM/ATR rules.

The HOF I 2019-3 pool has no debt servicing coverage ratio loans
leading to a lower proportion of investor loans within the pool
when compared with previous Homeward Opportunities Fund deals. This
transaction also has loans that exhibit high balances. Loans with
original balance greater than $3 million accounts for 16.1% of the
pool balance.

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

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

The Sponsor, directly or indirectly through a majority-owned
affiliate, will retain an eligible horizontal residual interest in
at least 5% of the Certificates (Classes B-2, B-3, and X
Certificates) issued by the Trust, to satisfy the credit
risk-retention requirements under Section 15G of the Securities
Exchange Act of 1934 and the regulations promulgated thereunder.

On or after the earlier of (1) the three-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Cut-Off Date
balance, the Depositor has the option to purchase all outstanding
Certificates at a price equal to the outstanding class balance plus
accrued and unpaid interest, including any cap carryover amounts.
After such a purchase, the Depositor then has the option to
complete a qualified liquidation, which requires (1) a complete
liquidation of assets within the Trust and (2) proceeds to be
distributed to the appropriate holders of regular or residual
interests.

The Sponsor will have the option, but not the obligation, to
repurchase any mortgage loan that becomes 90 or more days
delinquent or are real estate owned at the repurchase price (par
plus interest), provided that such repurchases in aggregate do not
exceed 10% of the total principal balance as of the Cut-Off Date.

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

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

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


HOMEWARD OPPORTUNITIES 2019-3: S&P Rates Class B-2 Certs 'B (sf)'
-----------------------------------------------------------------
S&P Global Ratings assigned ratings to Homeward Opportunities Fund
I Trust 2019-3's mortgage pass-through certificates.

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

The ratings reflect S&P's view of:

-- The pool's collateral composition;
-- The transaction's credit enhancement;
-- The transaction's associated structural mechanics;
-- The transaction's representation and warranty (R&W) framework;
-- The transaction's geographic concentration; and
-- The mortgage aggregator, Neuberger Berman Investment Advisors
LLC (Neuberger Berman), as investment manager for HOF I Trust
2019-3.

  RATINGS ASSIGNED

  Homeward Opportunities Fund I Trust 2019-3
  Class       Rating(i)               Amount ($)

  A-1         AAA (sf)               263,522,000
  A-2         AA (sf)                 27,339,000
  A-3         A (sf)                  48,922,000
  M-1         BBB (sf)                24,872,000
  B-1         BB (sf)                 19,939,000
  B-2         B (sf)                  15,828,000
  B-3         NR                      10,689,002
  A-IO-S      NR                        Notional(ii)
  X           NR                        Notional(ii)
  R           NR                             N/A

(i)The ratings address S&P's view regarding the ultimate payment of
interest and principal. They do not address payment of the cap
carryover amounts.
(ii)The notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period.
NR--Not rated.
N/A--Not applicable.


INTER PIPELINE 2019-B: DBRS Gives BB(high) to 2019-B Sub. Notes
---------------------------------------------------------------
DBRS Limited assigned a rating of BB(high) with a Stable trend to
Inter Pipeline Ltd.'s (IPL or the Company; rated BBB with a Stable
trend by DBRS Morningstar) $700 million 6.625% Fixed-to-Floating
Rate Subordinated Notes Series 2019-B due November 19, 2079 (the
Hybrid Notes). The rating is based on the rating of an
already-outstanding series of the above-mentioned debt instrument.
DBRS Morningstar also assigned an equity weight of 50% to the
Hybrid Notes based on the current "DBRS Morningstar Criteria:
Preferred Share and Hybrid Security Criteria for Corporate Issuers"
released in November 2019.

DBRS Morningstar notes that the Hybrid Notes are direct unsecured
subordinated obligations of IPL and subordinated in right of
payment to the prior payment in full of all present and future
senior indebtedness. The Hybrid Notes will be effectively
subordinated to all indebtedness and obligations of the Company's
subsidiaries. IPL proposes to use the net proceeds from the sale of
the Hybrid Notes to fund capital projects, repay indebtedness under
its revolving credit facility and for other general corporate
purposes.

Notes: All figures are in Canadian dollars unless otherwise noted.



JP MORGAN 2003-CIBC6: Fitch Affirms Bsf Rating on Class L Certs
---------------------------------------------------------------
Fitch Ratings affirmed five classes of J.P. Morgan Chase Commercial
Mortgage Securities Corp. commercial mortgage pass through
certificates, series 2003-CIBC6.

RATING ACTIONS

J. P. Morgan Chase Commercial Mortgage Securities Corp. 2003-CIBC6

Class J 46625MXH7; LT AAAsf Affirmed; previously at AAAsf

Class K 46625MXJ3; LT AAAsf Affirmed; previously at AAAsf

Class L 46625MXK0; LT Bsf Affirmed; previously at Bsf

Class M 46625MXL8; LT Dsf Affirmed; previously at Dsf

Class N 46625MXM6; LT Dsf Affirmed; previously at Dsf

KEY RATING DRIVERS

Stable Loss Expectations: The pool remains highly concentrated,
with only seven of the original 129 loans remaining. The largest
loan in the pool (38.2% of pool) has fully defeased. The second
largest loan, Old Orchard Village East Shopping Center (32.2%), is
secured by a grocery anchored retail center located in Lewisville,
TX, north of Dallas. The property is anchored by WinCo foods (50%
NRA, expires May 2040). The loan previously transferred to special
servicing in 2010, was modified, and returned to the master
servicer in 2011. The modification included an extension of the
interest-only (IO) period and a shortening of the term by three
years. Performance at the property has improved since the
modification and occupancy has remained stable at approximately 85%
since 2016, up from 28% at YE 2014. NOI DSCR has increased over
that same period as well, improving to 2.47x at YE 2018 from 0.78x
at YE 2014. The loan is amortizing and has a scheduled maturity in
April 2020. Due to the concentrated nature of the pool, Fitch
performed a sensitivity analysis that grouped the remaining loans
based on collateral quality, performance and perceived likelihood
of repayment.

Improved Credit Enhancement: Credit enhancement has improved since
Fitch's last rating action due to continued amortization of the
remaining loans. Additionally, the pool benefits from four (61.4%
of pool) defeased loans. Of the remaining non-defeased loans, two
(6.4%) are fully amortizing and one (32.2%) is amortizing balloon.
The maturity schedule of the remaining loans is as follows: 32.2%
(2020), 42.9% (2022), and 24.9% (2023). The pool has been paid down
by 98.3%, down to $17.5 million from $1.04 billion at issuance. The
trust has realized $21.2 million in losses (2% of original pool
balance).

RATING SENSITIVITIES

The Positive Outlook for class L reflects the potential for
multiple category upgrades. Should the Old Orchard East Shopping
Center pay in full at its 2020 maturity date, the class would be
upgraded to 'AAAsf' as it would be fully covered by defeased
collateral. The current rating reflects the uncertainty of payoff.

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 only have a minimal credit impact on the transaction, either due
to their nature or the way in which they are being managed by the
transaction.


MADISON PARK XXXVI: S&P Assigns Prelim 'BB-' Rating to Cl. E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Madison Park
Funding XXXVI Ltd./Madison Park Funding XXXVI LLC's fixed- and
floating-rate notes.

The note issuance is a CLO transaction backed by a diversified
collateral pool, which consists primarily of broadly syndicated
speculative-grade (rated 'BB+' and lower) senior secured term loans
that are governed by collateral quality tests.

The preliminary ratings are based on information as of Dec. 10,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The diversified collateral pool;

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Madison Park Funding XXXVI Ltd./Madison Park Funding XXXVI LLC

  Class                 Rating          Amount
                                    (mil. $)
  A                     AAA (sf)        496.00
  B-1                   AA (sf)          66.95
  B-2                   AA (sf)          45.05
  C (deferrable)        A (sf)           48.00
  D (deferrable)        BBB- (sf)        48.00
  E (deferrable)        BB- (sf)         32.00
  Subordinated notes    NR               61.20
  
  NR--Not rated.


MARATHON CLO 14: S&P Assigns Prelim BB- (sf) Rating to Cl. D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Marathon CLO
14 Ltd.'s fixed- and floating-rate notes.

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

The preliminary ratings are based on information as of Dec. 4,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The diversified collateral pool.

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Marathon CLO 14 Ltd./Marathon CLO 14 LLC

  Class                     Rating       Amount (mil. $)
  A-1A                      AAA (sf)              236.00
  A-1B                      NR                     12.00
  A-2a                      AA (sf)                35.00
  A-2b                      AA (sf)                21.00
  B-a (deferrable)          A (sf)                 15.00
  B-b (deferrable)          A (sf)                  7.00
  C-1a (deferrable)         BBB+ (sf)              10.00
  C-1b (deferrable)         BBB+ (sf)              12.00
  C-2 (deferrable)          BBB- (sf)              10.00
  D (deferrable)            BB- (sf)                6.00
  Subordinated notes        NR                     41.80

  NR--Not rated.


MERRILL LYNCH 2002-CANADA 8: Moody's Cuts Rating on 2 Classes to B3
-------------------------------------------------------------------
Moody's Investors Service downgraded the ratings on two
interest-only in Merrill Lynch Financial Assets Inc. Commercial
Mortgage Pass-Through Certificates, Series 2002-Canada 8 as
follows:

Class X-1*, Downgraded to B3 (sf); previously on October 4, 2018
Downgraded to B2 (sf)

Class X-2*, Downgraded to B3 (sf); previously on October 4, 2018
Downgraded to B2 (sf)

* Reflects Interest Only Classes

RATINGS RATIONALE

The ratings on the interest only (IO) classes, Class X-1 and Class
X-2, were downgraded due to the decline in the credit quality of
its reference classes. The only outstanding P&I class (not rated by
Moody's) has experienced a 3.2% realized loss based on its original
balance.

Moody's does not anticipate losses from the remaining collateral in
the current environment. However, over the remaining life of the
transaction, losses may emerge from macro stresses to the
environment and changes in collateral performance. Its ratings
reflect the potential for future losses under varying levels of
stress. Moody's base expected loss plus realized losses is now 0.1%
of the original pooled balance, compared to 0.1% at the last
review.

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

An IO class may be subject to ratings upgrades if there is an
improvement in the credit quality of its referenced classes,
subject to the limits and provisions of the updated IO
methodology.

An IO class may be subject to ratings downgrades if there is (i) a
decline in the credit quality of the reference classes and/or (ii)
paydowns of higher quality reference classes, subject to the limits
and provisions of the updated IO methodology.

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in these ratings 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 November 2019 distribution date, the transaction's
aggregate certificate balance has decreased by 99.5% to $2.3
million from $468.3 million at securitization. The certificates are
collateralized by 8 mortgage loans ranging in size from 2% to 31%
of the pool. Two loans, constituting 19% of the pool, have defeased
and are secured by US government securities. All of the remaining
loans fully amortize over their loan terms.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 4, compared to 6 at Moody's last review.

There are no loans on the master servicer's watchlist and no loans
currently in special servicing.

Moody's received full year 2018 operating results for 19% of the
pool and/or full year 2017 financials for 100% of the pool
(excluding defeased loans). Moody's weighted average conduit LTV is
7.9%, compared to 10.8% at Moody's last review. Moody's conduit
component excludes loans with structured credit assessments,
defeased and CTL loans, and specially serviced and troubled loans.
Moody's net cash flow (NCF) reflects a weighted average haircut of
17.9% to the most recently available net operating income (NOI).
Moody's value reflects a weighted average capitalization rate of
9.5%.

Moody's actual and stressed conduit DSCRs are 1.73X and above
4.00X, respectively, compared to 1.79X and above 4.00X at the last
review. Moody's actual DSCR is based on Moody's NCF and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stress rate the agency applied to the loan balance.

The top three non-defeased loans represent 65.3% of the pool
balance. The largest loan is the CLA-MFAM-758861 Loan ($0.7 million
-- 30.9% of the pool), which is secured by a 88-unit multifamily
property located in Toronto, Ontario. As of December 2017, the
property was 100% leased, unchanged from the prior year. The loan
is fully recourse to the Borrower and the loan is fully amortizing.
The loan has paid down 82% since securitization. Moody's LTV and
stressed DSCR are 9.3% and greater than 4.00X, respectively.

The second largest loan is the CLA-MFAM-758862 Loan ($0.4 million
-- 18.5% of the pool), which is secured by 82-unit multifamily
property located in Toronto, Ontario. As of December 2017, the
property was 100% leased, unchanged from the prior year. The loan
is fully recourse to the Borrower and the loan is fully amortizing.
The loan has amortized 82% since securitization. Moody's LTV and
stressed DSCR are 9.5% and greater than 4.00X, respectively.

The third largest loan is the Edmonton Industrial Portfolio Loan
($0.4 million -- 15.9% of the pool), which is secured by two
cross-collateralized and cross-defaulted industrial properties
located in Edmonton, Alberta. The properties total over 183,000
square feet (SF) and are 100% leased to the sole tenant, Purolator.
The tenant's leases expire in March 2020, less than one month prior
to the loan's maturity date. The loan is fully amortizing and is
full recourse to the sponsor. The loan has amortized 96% since
securitization. Due to the single tenant exposure, Moody's value of
this property utilized a lit/dark analysis. Moody's LTV and
stressed DSCR are 3% and greater than 4.00X, respectively.


MF1 LTD 2019-FL2: DBRS Finalizes B(low) Rating on Class G Notes
---------------------------------------------------------------
DBRS, Inc. finalized provisional ratings to the following classes
of notes issued by MF1 2019-FL2, Ltd. (the Issuer):

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

All trends are Stable.

The initial collateral consists of 38 floating-rate mortgage loans
secured by 39 transitional multifamily properties totaling $654.6
million, representing 67.4% of the total fully funded balance,
excluding $68.4 million of remaining future funding commitments and
$248.2 million of pari passu debt. Of the 38 loans, there are two
unclosed, delayed-close loans as of November 20, 2019, representing
4.1% of the initial pool balance, including Bella Solano Apartments
(Prospectus ID#18) and Timberland Apartments (Prospectus ID#23). If
a delayed-close loan is not expected to close or fund prior to the
purchase termination date, then the Issuer can use unused proceeds
to acquire a replacement mortgage asset referred to as Haven Garden
& Hidden Chalet with a cut-off date balance of $6.5 million.
Additionally, during a 90-day period following the closing date,
the Issuer can bring an estimated $15.4 million of future funding
participation into the pool, resulting in a target deal balance of
$670.0 million. The loans are mostly secured by currently
cash-flowing assets, most of which are in a period of transition
with plans to stabilize and improve the asset value. Of these
loans, 32 have remaining future funding participations totaling
$68.4 million, which the Issuer may acquire in the future.

Given the floating-rate nature of the loans, the index DBRS
Morningstar used (one-month Libor) was the lower of a DBRS
Morningstar stressed rate that corresponded to the remaining fully
extended term of the loans or the strike price of the interest-rate
cap with the respective contractual loan spread added to determine
a stressed interest rate over the loan term. When the cut-off date
balances were measured against the DBRS Morningstar As-Is Net Cash
Flow, 26 loans, representing 76.5% of the mortgage loan cut-off
date balance, had a DBRS Morningstar As-Is Debt Service Coverage
Ratio (DSCR) below 1.00 times (x), a threshold indicative of
default risk. Additionally, the DBRS Morningstar Stabilized DSCRs
for 10 loans, comprising 39.7% of the initial pool balance, are
below 1.00x, which is indicative of elevated refinance risk. The
properties are often transitioning with potential upside in cash
flow; however, DBRS Morningstar does not give full credit to the
stabilization if there are no holdbacks or if other loan structural
features in place are insufficient to support such treatment.
Furthermore, even with the structure provided, DBRS Morningstar
generally does not assume that the assets will stabilize above
market levels.

The transaction will have a sequential-pay structure.

The loans were all sourced by an affiliate of the Issuer, which has
strong origination practices and substantial experience in the
multifamily industry. Classes F, G, and the Preferred Shares
(representing 14.0% of the initial pool balance) will be purchased
by a wholly-owned subsidiary of MF1 REIT LLC.

All loans in the pool are secured by multifamily properties located
across 15 states, including Texas, California, Colorado, and
Pennsylvania, among others. Multifamily properties benefit from
staggered lease rollover and generally low expense ratios compared
with other property types. While revenue is quick to decline in a
downturn because of the short-term nature of the leases, it is also
quick to respond when the market improves. Additionally, most loans
are secured by traditional multifamily properties, such as
garden-style communities or mid-/high-rise buildings, with only one
loan secured by an independent living/assisted living/memory care
facility (Prospectus ID#30, Brookside Seniors Portfolio) and a
second loan secured by student housing (Prospectus ID#37, The Lux
at Cornell). Independent living/assisted living/memory care
facilities and student-housing properties are modeled with an
elevated probability of default (POD) compared with traditional
multifamily properties.

Thirty loans, comprising 69.1% of the initial trust balance,
represent acquisition financing wherein sponsors contributed
material cash equity as a source of funding in conjunction with the
mortgage loan, resulting in a moderately high sponsor cost basis in
the underlying collateral.

The loans in the transaction benefit from experienced and
financially stable borrowers, several of which were securitized in
MF1 2019-Q009, a transaction sponsored by Freddie Mac. Only two
loans, representing 6.4% of the initial pool balance, have sponsors
with negative credit history and/or loan collateral associated with
a borrowing structure that DBRS Morningstar deemed to be Weak. Such
sponsors were associated with a prior DPO, loan default, limited
net worth and/or liquidity or a historical negative credit event.
DBRS Morningstar increased the POD for loans with identified
sponsorship concerns.

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

No loans are secured by properties located in markets ranked seven
or eight, which are considered dense urban in nature and benefit
from increased liquidity that is driven by consistently strong
investor demand, even during times of economic stress. Furthermore,
25 loans, representing 69.2% of the initial trust balance, are
secured by properties located in markets ranked three or four,
which have historically been found to have higher PODs. The pool's
weighted-average (WA) market rank of 3.8 is indicative of a high
concentration of properties located in less densely populated
suburban areas. Properties located in less densely populated
markets were analyzed with higher loss severities than those
located in more urban markets. Three loans totaling 12.8% of the
initial trust balance, including Lotus 315 (Prospectus ID#3), Wave
Lakeview (Prospectus ID#4) and Lure at Cedar Springs (Prospectus
ID#39), are secured by properties located in markets ranked six.
These markets include Chicago; East Orange, New Jersey; and
Dallas.

Loan collateral was built between 1949 and 2019 with a WA year
built of 1988. Given the older vintage of the assets, no loans are
secured by properties that DBRS Morningstar deemed to be Above
Average or Excellent in quality. Six loans, comprising 17.9% of the
initial trust balance, are secured by properties with Average (-)
quality, including Alvista Terrace (Prospectus ID#1) and Rancho
Verde Apartments (Prospectus ID#13). Lower-quality properties are
less likely to retain existing tenants, resulting in less than
stable performance. DBRS Morningstar increased the POD for loans
with Average (-) quality to account for the elevated risk.
Thirty-two loans have $68.4 million of remaining future funding
participations, ranging from $409,900 to $8.0 million. The sponsors
will use these funds to facilitate their respective capital
improvement plans, which should help to enhance the quality of the
properties and improve overall value.

All loans have floating interest rates and are interest-only (IO)
during the initial loan term, which ranges from 24 months to 36
months, creating interest-rate risk. The borrowers of all 38 loans
have purchased Libor rate caps, ranging between 2.50% and 3.50%, to
protect against rising interest rates over the term of the loan.
All loans are short term and, even with extension options, have a
fully extended loan term of five years maximum.

Additionally, all loans have extension options and, in order to
qualify for these options, the loans must meet minimum DSCR and LTV
requirements. Twenty-three loans, representing 66.9% of the total
pool, amortize on 30-year schedules during all or a portion of
their extension period.

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


MF1 LTD 2019-FL2: DBRS Gives Prov. B(low) Rating on Class G Notes
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
notes to be issued by MF1 2019-FL2, Ltd. (the Issuer):

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

All trends are Stable.

The initial collateral consists of 38 floating-rate mortgage loans
secured by 39 transitional multifamily properties totaling $654.6
million, representing 67.4% of the total fully funded balance,
excluding $68.4 million of remaining future funding commitments and
$248.2 million of pari passu debt. Of the 38 loans, there are two
unclosed, delayed-close loans as of November 20, 2019, representing
4.1% of the initial pool balance, including Bella Solano Apartments
(#18) and Timberland Apartments (#23). If a delayed-close loan is
not expected to close or fund prior to the purchase termination
date, then the Issuer can use unused proceeds to acquire a
replacement mortgage asset referred to as Haven Garden & Hidden
Chalet with a cut-off date balance of $6.5 million. Additionally,
during a 90-day period following the closing date, the Issuer can
bring an estimated $15.4 million of future funding participation
into the pool, resulting in a target deal balance of $670.0
million. The loans are mostly secured by currently cash-flowing
assets, most of which are in a period of transition with plans to
stabilize and improve the asset value. Of these loans, 32 have
remaining future funding participations totaling $68.4 million,
which the Issuer may acquire in the future.

Given the floating-rate nature of the loans, the index DBRS
Morningstar used (one-month LIBOR) was the lower of a DBRS
Morningstar stressed rate that corresponded to the remaining fully
extended term of the loans or the strike price of the interest-rate
cap with the respective contractual loan spread added to determine
a stressed interest rate over the loan term. When the cut-off date
balances were measured against the DBRS Morningstar As-Is Net Cash
Flow, 26 loans, representing 76.5% of the mortgage loan cut-off
date balance, had a DBRS Morningstar As-Is Debt Service Coverage
Ratio (DSCR) below 1.00 times (x), a threshold indicative of
default risk. Additionally, the DBRS Morningstar Stabilized DSCRs
for ten loans, comprising 39.7% of the initial pool balance, are
below 1.00x, which is indicative of elevated refinance risk. The
properties are often transitioning with potential upside in cash
flow; however, DBRS Morningstar does not give full credit to the
stabilization if there are no holdbacks or if other loan structural
features in place are insufficient to support such treatment.
Furthermore, even with the structure provided, DBRS Morningstar
generally does not assume that the assets will stabilize above
market levels.

The transaction will have a sequential-pay structure.

The loans were all sourced by an affiliate of the Issuer, which has
strong origination practices and substantial experience in the
multifamily industry. Classes F and G and the Preferred Shares
(representing 14.0% of the initial pool balance) will be purchased
by a wholly-owned subsidiary of MF1 REIT LLC.

All loans in the pool are secured by multifamily properties located
across 15 states, including Texas, California, Colorado, and
Pennsylvania, among others. Multifamily properties benefit from
staggered lease rollover and generally low expense ratios compared
with other property types. While revenue is quick to decline in a
downturn because of the short-term nature of the leases, it is also
quick to respond when the market improves. Additionally, most loans
are secured by traditional multifamily properties, such as
garden-style communities or mid-/high-rise buildings, with only one
loan secured by an independent living/assisted living/memory care
facility (#30, Brookside Seniors Portfolio) and a second loan
secured by student housing (#37, The Lux at Cornell). Independent
living/assisted living/memory care facilities and student-housing
properties are modeled with an elevated probability of default
(POD) compared with traditional multifamily properties.

Thirty loans, comprising 69.1% of the initial trust balance,
represent acquisition financing wherein sponsors contributed
material cash equity as a source of funding in conjunction with the
mortgage loan, resulting in a moderately high sponsor cost basis in
the underlying collateral.

The loans in the transaction benefit from experienced and
financially stable borrowers, several of which were securitized in
MF1 2019-Q009, a transaction sponsored by Freddie Mac. Only two
loans, representing 6.4% of the initial pool balance, have sponsors
with negative credit history and/or loan collateral associated with
a borrowing structure that DBRS Morningstar deemed to be Weak. Such
sponsors were associated with a prior DPO, loan default, limited
net worth and/or liquidity or a historical negative credit event.
DBRS Morningstar increased the POD for loans with identified
sponsorship concerns.

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

No loans are secured by properties located in markets ranked seven
or eight, which are considered dense urban in nature and benefit
from increased liquidity that is driven by consistently strong
investor demand, even during times of economic stress. Furthermore,
25 loans, representing 69.2% of the initial trust balance, are
secured by properties located in markets ranked three or four,
which have historically been found to have higher PODs. The pool's
weighted-average (WA) market rank of 3.8 is indicative of a high
concentration of properties located in less densely populated
suburban areas. Properties located in less densely populated
markets were analyzed with higher loss severities than those
located in more urban markets. Three loans totaling 12.8% of the
initial trust balance, including Lotus 315 (#3), Wave Lakeview (#4)
and Lure at Cedar Springs (#39), are secured by properties located
in markets ranked six. These markets include Chicago; East Orange,
New Jersey; and Dallas.

Loan collateral was built between 1949 and 2019 with a WA year
built of 1988. Given the older vintage of the assets, no loans are
secured by properties that DBRS Morningstar deemed to be Above
Average or Excellent in quality. Six loans, comprising 17.9% of the
initial trust balance, are secured by properties with Average (-)
quality, including Alvista Terrace (#1) and Rancho Verde Apartments
(#13). Lower-quality properties are less likely to retain existing
tenants, resulting in less than stable performance. DBRS
Morningstar increased the POD for loans with Average (-) quality to
account for the elevated risk. Thirty-two loans have $68.4 million
of remaining future funding participations, ranging from $409,900
to $8.0 million. The sponsors will use these funds to facilitate
their respective capital improvement plans, which should help to
enhance the quality of the properties and improve overall value.

All loans have floating interest rates and are interest-only during
the initial loan term, which ranges from 24 months to 36 months,
creating interest-rate risk. The borrowers of all 38 loans have
purchased LIBOR rate caps, ranging between 2.50% and 3.50%, to
protect against rising interest rates over the term of the loan.
All loans are short term and, even with extension options, have a
fully extended loan term of five years maximum. Additionally, all
loans have extension options and, in order to qualify for these
options, the loans must meet minimum DSCR and LTV requirements.
Twenty-three loans, representing 66.9% of the total pool, amortize
on 30-year schedules during all or a portion of their extension
period.

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


ML-CFC COMMERCIAL 2006-4: S&P Lowers Cl. C Certs Rating to 'D (sf)'
-------------------------------------------------------------------
S&P Global Ratings lowered its rating on the class C commercial
mortgage pass-through certificates from ML-CFC Commercial Mortgage
Trust 2006-4, a U.S. CMBS transaction, to 'D (sf)' from 'CCC
(sf)'.

The downgrade reflects accumulated interest shortfalls that S&P
expects to remain outstanding for the foreseeable future, as well
as credit support erosion that it anticipates will occur upon the
eventual resolution of the two real estate-owned (REO) assets
($42.2 million, 91.7%) with the special servicer.

According to the Nov. 12, 2019, trustee remittance report, the
current gross monthly interest shortfalls totaled $225,055 and
resulted primarily from interest not advanced due to nonrecoverable
determination totaling $212,337 and special servicing fees totaling
$12,718. The current shortfalls are offset by proceeds from
principal distribution and affected classes subordinate to and
including class C.

TRANSACTION SUMMARY

As of the Nov. 12, 2019, trustee remittance report, the collateral
pool balance was $46.0 million, which is 1.0% of the pool balance
at issuance. The pool currently includes three loans and two REO
assets that are with the special servicer, down from 279 loans at
issuance. No loans are defeased or on the master servicer's
watchlist.

Excluding the two specially serviced assets, the rating agency
calculated a 1.11x S&P Global Ratings' weighted average debt
service coverage (DSC) and 44.2% S&P Global Ratings' weighted
average loan-to-value ratio using a 7.20% S&P Global Ratings'
weighted average capitalization rate for the three performing
loans.

To date, the transaction has experienced $410.5 million in
principal losses, or 9.1% of the original pool trust balance. S&P
expects losses to reach approximately 9.6% of the original pool
trust balance in the near term, based on losses incurred to date
and additional losses that the rating agency expects upon the
eventual resolution of the two specially serviced assets.

CREDIT CONSIDERATIONS

As of the Nov. 12, 2019, trustee remittance report, two assets in
the pool were with the special servicer, C-III Asset Management LLC
(C-III). Details of these assets are as follows:

-- The Elm Ridge Center REO asset ($28.6 million, 62.2%) is the
largest asset in the pool and has a total reported exposure of
$28.6 million. The asset is a 481,010-sq.-ft. retail property in
Greece, N.Y. The loan was transferred to the special servicer on
June 25, 2015, due to imminent default and the property became REO
on Nov. 26, 2018. C-III stated that it is currently addressing
deferred maintenance items and working on leasing up the property.
The reported occupancy as of March 31, 2019, was 31.0%. The asset
has been deemed nonrecoverable and S&P expects a significant loss
(60.0% or greater) upon this asset's eventual resolution.

-- The Prospect Square REO asset ($13.6 million, 29.5%) is the
second largest asset in the pool and has a total reported exposure
of $13.8 million. The asset is a mixed-use (office and retail)
property totaling 33,325 sq. ft. in San Diego, Calif. The loan was
transferred to the special servicer on Nov. 21, 2016, due to
imminent maturity default and the property became REO on Oct. 24,
2018. C-III stated that the property is being marketed for sale.
The reported DSC and occupancy as of March 31, 2019, were 0.17x and
69.0%, respectively. The asset has been deemed nonrecoverable and
S&P expects a moderate loss (26.0%-59.0%) upon this asset's
eventual resolution.


MORGAN STANLEY 2006-TOP23: S&P Cuts Cl. F Certs Rating to 'D (sf)'
------------------------------------------------------------------
S&P Global Ratings lowered its ratings on two classes of commercial
mortgage pass-through certificates from Morgan Stanley Capital I
Trust 2006-TOP23, a U.S. CMBS transaction. In addition, S&P
affirmed its rating on class D from the same transaction.

The downgrades on classes E and F reflect reduced liquidity support
available to these classes due to ongoing interest shortfalls. S&P
also anticipates credit support erosion will occur upon the
eventual resolution of the three assets ($29.3 million, 55.4%) with
the special servicer. Specifically, S&P lowered its rating on class
F to 'D (sf)' because it expects the accumulated interest
shortfalls to remain outstanding for the foreseeable future.

For the affirmation on class D, S&P's expectation of credit
enhancement was generally in line with the affirmed rating level.
While available credit enhancement levels may suggest positive
rating movement on class D, S&P's analysis also considered the
bond's susceptibility to reduced liquidity support from the three
specially serviced assets in the event the master servicer deems
any of these assets to be non-recoverable."

According to the Nov. 12, 2019, trustee remittance report, the
current monthly interest shortfalls totaled $90,134 and resulted
primarily from appraisal subordinate entitlement reduction amounts
totaling $83,865 and special servicing fees totaling $6,269.

The current interest shortfalls affected classes subordinate to,
and including, class F.

TRANSACTION SUMMARY

As of the Nov. 12, 2019, trustee remittance report, the collateral
pool balance was $52.9 million, which is 3.3% of the pool balance
at issuance. The pool currently includes eight loans and one real
estate-owned (REO) asset, down from 161 loans at issuance. Three of
these assets are with the special servicer, two ($4.5 million,
8.4%) are defeased, and none are on the master servicer's
watchlist.

S&P calculated a 1.38x S&P Global Ratings' weighted average debt
service coverage (DSC) and 72.8% S&P Global Ratings' weighted
average loan-to-value (LTV) ratio using a 7.36% S&P Global Ratings'
weighted average capitalization rate. The DSC, LTV, and
capitalization rate calculations exclude the three specially
serviced assets and two defeased loans.

To date, the transaction has experienced $47.8 million in principal
losses, or 3.0% of the original pool trust balance. S&P expects
losses to reach approximately 4.2% of the original pool trust
balance in the near term, based on losses incurred to date and
additional losses S&P expects upon the eventual resolution of the
three specially serviced assets.

CREDIT CONSIDERATIONS

As of the Nov. 12, 2019, trustee remittance report, three assets in
the pool were with the special servicer, C-III Asset Management LLC
(C-III). Details of the two largest specially serviced assets are
as follows:

-- The 150 Hillside Avenue loan ($19.8 million, 37.4%) is the
largest loan in the pool and has a total reported exposure of $21.3
million. The loan is secured by a 127,325-sq.-ft. office property
in White Plains, N.Y. The loan was transferred to the special
servicer on Sept. 12, 2017, because of imminent default. C-III
indicated that it has filed for foreclosure. A $9.8 million
appraisal reduction amount (ARA) is in effect against this loan.
S&P expects a significant loss (60% or greater) upon this loan's
eventual resolution.

-- The Lansing Shopping Center loan ($6.9 million, 13.1%) is the
third-largest loan in the pool and has a total reported exposure of
$7.5 million. The loan is secured by an 80,000-sq.-ft. retail
property in Lansing, Ill. The loan was transferred to the special
servicer on July 10, 2018, because of imminent monetary default.
C-III indicated that the foreclosure sale occurred on Nov. 18,
2019, with title expected to be transferred to the trust in early
December 2019. The reported occupancy as of March 31, 2018, was
43.8%. A $4.2 million ARA is in effect against this loan. S&P
expects a significant loss upon this loan's eventual resolution.  

The remaining asset with the special servicer has a balance that
represents less than 5.0% of the total pool trust balance. S&P
estimated losses for the three specially serviced assets, arriving
at a weighted-average loss severity of 70.3%.

  RATINGS LOWERED

  Morgan Stanley Capital I Trust 2006-TOP23
  Commercial mortgage pass-through certificates

                 Rating
  Class     To            From
  E         BB (sf)       BBB- (sf)
  F         D (sf)        CCC+ (sf)

  RATING AFFIRMED

  Morgan Stanley Capital I Trust 2006-TOP23
  Commercial mortgage pass-through certificates

  Class     Rating
  D         A+ (sf)


MORGAN STANLEY 2016-SNR: S&P Affirms BB+(sf) Rating on Cl. E Certs
------------------------------------------------------------------
S&P Global Ratings raised its ratings on three classes and affirmed
its ratings on two other classes of commercial mortgage
pass-through certificates from Morgan Stanley Capital Citigroup
Trust 2016-SNR, a U.S. CMBS transaction.

For the upgrades and affirmations, S&P's expectation of credit
enhancement was in line with the raised or affirmed rating levels.
The upgrades primarily reflect the significant reduction in trust
balance from property releases since issuance.

While available credit enhancement levels may suggest positive
rating movement on class E, S&P's analysis also considered the
subordinate nature of the class within the capital structure, as
well as the potential for adverse selection risk on the remaining
collateral pool.

This is a stand-alone transaction backed by a five-year,
fixed-rate, interest-only (IO) mortgage loan. At issuance, the
$555.0 million mortgage loan was secured by a portfolio of 64
skilled nursing facilities containing 7,786 licensed beds, located
in eight states. Since issuance, the sponsor of the mortgage loan,
a joint venture between Lindsay Goldberg IV and Omega Healthcare
Investors Inc., has released 27 facilities, resulting in the
paydown of the mortgage debt to $286.6 million currently. S&P's
property-level analysis included a re-evaluation of the 37
remaining skilled nursing facilities (4,387 licensed beds) that
secure the mortgage loan in the trust. S&P considered the stable
servicer-reported net operating income for the past three years
(2016 through 2018), including the six-month period ending June
2019. The rating agency then derived its sustainable in-place net
cash flow, which it divided by an 11.63% S&P Global Ratings'
weighted-average capitalization rate to determine its expected-case
value. This yielded an overall S&P Global Ratings' loan-to-value
(LTV) ratio and debt service coverage (DSC) of 50.2% and 4.30x,
respectively, on the trust balance. The decline in LTV from
issuance of 58.9% is primarily due to release premiums above the
allocated loan amount associated with the property releases.

According to the Nov. 15, 2019, trustee remittance report, the IO
mortgage loan has a trust balance of $286.6 million and pays an
annual fixed interest rate of 5.32% through its November 2021
maturity date. In addition, there is mezzanine debt totaling about
$125.1 million, down from $227.4 million at issuance. The paydown
of the mezzanine debt is also due to property releases. To date,
the trust has not incurred any principal losses.

The master servicer, KeyBank Real Estate Capital, reported a DSC of
4.88x on the trust balance for the full-year 2018.

  RATINGS RAISED

  Morgan Stanley Capital Citigroup Trust 2016-SNR
  Commercial mortgage pass-through certificates

  Class          Rating
            To            From
  B         AA+ (sf)      AA- (sf)
  C         AA (sf)       A- (sf)
  D         BBB+ (sf)     BBB- (sf)

  RATINGS AFFIRMED

  Morgan Stanley Capital Citigroup Trust 2016-SNR
  Commercial mortgage pass-through certificates

  Class     Rating
  A         AAA (sf)
  E         BB+ (sf)


MORGAN STANLEY 2016-UBS9: Fitch Affirms B-sf Rating on Cl. F Certs
------------------------------------------------------------------
Fitch Ratings affirmed 14 classes of Morgan Stanley Capital I Trust
Commercial Mortgage Pass-Through Certificates, series 2016-UBS9.

RATING ACTIONS

MSCI 2016-UBS9

Class A-2 61766CAB5; LT AAAsf Affirmed; previously at AAAsf

Class A-3 61766CAD1; LT AAAsf Affirmed; previously at AAAsf

Class A-4 61766CAE9; LT AAAsf Affirmed; previously at AAAsf

Class A-S 61766CAG4; LT AAAsf Affirmed; previously at AAAsf

Class A-SB 61766CAF6; LT AAAsf Affirmed; previously at AAAsf

Class B 61766CAK5; LT AA-sf Affirmed; previously at AA-sf

Class C 61766CAL3; LT A-sf Affirmed; previously at A-sf

Class D 61766CAV1; LT BBB-sf Affirmed; previously at BBB-sf

Class E 61766CAX7; LT BB-sf Affirmed; previously at BB-sf

Class F 61766CAZ2; LT B-sf Affirmed; previously at B-sf

Class X-A 61766CAH2; LT AAAsf Affirmed; previously at AAAsf

Class X-B 61766CAJ8; LT AA-sf Affirmed; previously at AA-sf

Class X-D 61766CAM1; LT BBB-sf Affirmed; previously at BBB-sf

Class X-E 61766CAP4; LT BB-sf Affirmed; previously at BB-sf

KEY RATING DRIVERS

Stable Loss Expectations: The rating affirmations reflect the
generally stable performance of the majority of the pool, which
remains in line with Fitch's issuance expectations. There have been
no realized losses or specially serviced loans to date. No loans
have been designated Fitch Loans of Concern (FLOCs).

Increased Credit Enhancement: As of the November 2019 distribution
date, the pool's aggregate principal balance has been reduced by
11.4% to $590.9 million from $666.6 million at issuance. Five loans
(19.9%) are full-term, interest-only and four loans (24.8%) remain
in partial interest-only periods. Two loans (9.6%) are fully
defeased. One loan, the GLP Industrial Portfolio B (8.4% of pool at
issuance), paid off in September 2019. Loan maturities are
concentrated in 2025 (44.0%) and 2026 (48.0%), with limited
maturities scheduled in 2023 (3.3%) and 2031 (4.7%). One loan, the
U Haul AREC RW Portfolio (9.6%), has an ARD in February 2026.

ADDITIONAL CONSIDERATIONS

Pool Concentrations: The top five and 10 loans in the transaction
represent 44.7% and 69.8% of the current pool balance,
respectively. The largest property type concentration is office
(36.6%), followed by retail (27.7%), industrial (12.2%) and
self-storage (9.6%).

Premium Outlet Concentration: Two of the top 15 loans (10.0% of the
pool) are secured by premium outlet centers from related sponsors.

Ellenton Premium Outlets (6.6% of the pool) is secured by a
476,481-sf outlet center located in Ellenton, FL, which is situated
between Bradenton/Sarasota to the south and Tampa/St. Petersburg to
the north. The servicer reported a YE 2018 NOI DSCR of 2.56x. As of
the June 2019 rent roll, the property was 86.9% leased, down from
91.8% at YE 2018, 94.4% at YE 2017 and 97.4% at YE 2016. The
largest tenants include VF Factory Outlet (4.9% of NRA; through
December 2021), Saks OFF Fifth (4.1%; October 2021) and the Nike
Factory Store (3.2%; January 2020). Leases totaling approximately
48% of NRA roll by YE 2022. Total outlet sales have decreased to
$419 psf for TTM June 2019, compared with $440 psf for 2018 and
$461 at issuance. Due to declining sales, occupancy costs increased
to approximately 13% as of June 2019 from 12.1% at YE 2015 and 9.4%
at YE 2012.

Grove City Premium Outlets (3.4% of the pool) is secured by a
531,200-sf outlet center located in Grove City, PA, approximately
50 miles north of Pittsburgh. The servicer reported a YE 2018 NOI
DSCR of 2.79x. As of the June 2019 rent roll, the property was
83.6% leased, down from 85.1% at YE 2018, 87.3% at YE 2017 and
92.6% at YE 2016. The largest tenants include VF Factory Outlet
(5.0%; renewed through November 2022), Old Navy (3.8%; January
2021) and the Nike Factory Store (3.1%; June 2023). Leases totaling
approximately 48% of NRA roll by YE 2022. Total outlet sales were
$363 psf for TTM November 2018, compared with $367 psf for 2017 and
$333 at issuance. Average occupancy costs have increased to
approximately 13% as of TTM November 2018 from 9.7% at YE 2012.

Fitch increased the cap rates and constants applied to these loans
from issuance levels due to the outlet centers' tertiary locations
and declining occupancy and/or performance. Both loans are
full-term, interest-only.

RATING SENSITIVITIES

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.

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.


MORGAN STANLEY 2019-NUGS: Moody's Rates Class E Certs '(P)Ba3'
--------------------------------------------------------------
Moody's Investors Service assigned provisional ratings to six
classes of CMBS securities, issued by Morgan Stanley Capital I
Trust 2019-NUGS, Commercial Mortgage Pass-Through Certificates,
Series 2019-NUGS:

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

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

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

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

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

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

* Reflects interest-only classes

RATINGS RATIONALE

The certificates are collateralized by a single loan backed by a
first lien commercial mortgage related to Wells Fargo Center
located in CBD Denver, CO. The property is a 1,195,149 SF, Class A,
office property comprised of 52-story tower and an adjoining
12-story garage containing 996 enclosed parking spaces. It was
developed in 1983 and is among the tallest buildings in the city.
The loan is a five-year (fully extended), floating rate
interest-only, first-lien mortgage loan with an original and
outstanding principal balance of $277,100,000. Its ratings are
based on the credit quality of the loan and the strength of the
securitization structure.

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

The credit risk of commercial real estate loans is determined
primarily by two factors: 1) the probability of default, which is
largely driven by the DSCR, and 2) and the severity of loss in the
event of default, which is largely driven by the LTV of the
underlying loan.

The trust loan balance of $217,100,000 represents a Moody's LTV of
106.0%. The Moody's loan trust actual DSCR is 2.08x and Moody's
loan trust stressed DSCR at a 9.25% stressed constant is 0.89x. The
Moody's LTV including the non-trust b-note of $50,600,000 and
mezzanine loan of $45,300,000 is 142.7%.

Notable strengths of the transaction include: Property's location,
quality, recent capital improvements, investment grade tenancy, and
strong sponsorship.

Notable concerns of the transaction include: Moody's LTV ratio,
floating-rate interest-only mortgage loan profile, lack of asset
diversification, and certain credit negative legal features.

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

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

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

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

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

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

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


MSC MORTGAGE 2011-C3: DBRS Confirms B(high) Rating on Cl. G Certs
-----------------------------------------------------------------
DBRS Limited confirmed the ratings on the Commercial Mortgage
Pass-Through Certificates, Series 2011-C3 issued by MSC 2011-C3
Mortgage Trust as follows:

-- Class A-4 at AAA (sf)
-- Class A-J at AAA (sf)
-- Class B at AAA (sf)
-- Class X-A at AAA (sf)
-- Class C at AA (sf)
-- Class D at A (sf)
-- Class E at BBB (sf)
-- Class F at BBB (low) (sf)
-- Class X-B at BB (low) (sf)
-- Class G at B (high) (sf)

All trends are Stable.

The rating confirmations reflect the overall stable performance of
the transaction. Per the November 2019 remittance, 39 of the
original 63 loans remain in the pool with an aggregate trust
balance of $651.9 million, representing a collateral reduction of
56.3% since issuance due to scheduled loan amortization and loan
repayment. There are ten loans, representing 15.2% of the pool,
that are fully defeased. Per the year-end (YE) 2018 financials, the
top 15 loans, representing 80.7% of the pool, reported a
weighted-average (WA) debt service coverage ratio (DSCR) of 1.70
times (x), compared to the WA DBRS Morningstar Term DSCR of 1.56x,
representing net cash flow (NCF) growth of 18.8% over DBRS
Morningstar NCF figures. At issuance, the pool had a WA
loan-to-value (LTV) ratio of 61.6%, compared with the WA LTV for
the pool of 64.3% as of the November 2019 remittance.

According to the November 2019 remittance, there are seven loans,
representing 20.6% of the pool, on the servicer's watchlist and no
loans in special servicing. The pool's watchlisted loans reported a
WA DSCR of 1.42x, representing NCF growth of 13.8% over the DBRS
Morningstar NCF figures according to the most recent YE financials.
The largest loan on the watchlist, Royal Ridge (Prospectus ID#7;
7.3% of the pool), is secured by an office property in Irving,
Texas, and was added to the servicer's watchlist in March 2019 as
the property's largest tenant, American Airlines (24.5% of net
rentable area (NRA)), exercised its lease termination option
effective December 2019. DBRS Morningstar notes that the implied
DSCR without American Airlines would be approximately 1.00x and the
loan is approaching its July 2021 maturity date. DBRS Morningstar
increased the probability of default for the loan as part of the
review.

The pool's two largest loans, representing 27.2% of the pool
balance, are secured by regional malls located in secondary markets
with no major markets in close proximity. Westfield Belden Village
(Prospectus ID#2; 14.6% of the pool) in Canton, Ohio, and Oxmoor
Center (Prospectus ID#3; 12.6% of the pool) in Louisville,
Kentucky, have been affected by the downsizing and departure of
anchor tenant Sears. The Sears at Westfield Belden Village
downsized to 8.9% of total NRA in 2018 after previously occupying
22.9% of total NRA and Sears recently announced the store will
close in January 2020. Dave & Buster's is backfilling a portion of
the Sears space (4.3% of total NRA) that is scheduled to begin
occupancy in November 2019. The servicer also noted leases were
being negotiated with two national big-box retailers to lease large
portions of the remaining Sears space. The Sears at Oxmoor Center,
representing 14.8% of NRA, permanently closed in 2018; however, the
sponsor executed a 20-year lease with Topgolf with an expected
occupancy date of June 2020. Despite space not being completely
backfilled, Topgolf's base rents are considerably higher than
Sears' previous base rents and will be an overall net positive for
the property. Despite the recent declining occupancy rates at both
malls, the loans reported strong cash flow growth since issuance as
they had an average NCF growth of 8.5% over the DBRS Morningstar
NCF figure.

At issuance, DBRS Morningstar shadow-rated Washington Tower
(Prospectus ID#13, 6.1% of the pool) investment grade. DBRS
Morningstar confirmed that the performance of this loan remains
consistent with investment-grade characteristics.

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

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


NEUBERGER BERMAN 34: S&P Assigns BB- (sf) Rating to Class E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Neuberger Berman Loan
Advisers CLO 34 Ltd.'s floating- and fixed-rate notes.

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

The ratings reflect:

-- The diversified collateral pool.

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

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

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

  RATINGS ASSIGNED
  Neuberger Berman Loan Advisers CLO 34 Ltd.

  Class                Rating          Amount (mil. $)
  A-1                  AAA (sf)                 160.00
  A-2                  AAA (sf)                 160.00
  B-1                  AA (sf)                   40.00
  B-2                  AA (sf)                   20.00
  C-1 (deferrable)     A (sf)                    10.00
  C-2 (deferrable)     A (sf)                    20.00
  D (deferrable)       BBB- (sf)                 30.00
  E (deferrable)       BB- (sf)                  20.00
  Subordinated notes   NR                        42.11

  NR--Not rated.


NEUBERGER BERMAN 35: S&P Assigns Prelim BB- Rating to Cl. E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Neuberger
Berman Loan Advisers CLO 35 Ltd.'s floating- and fixed-rate notes.

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

The preliminary ratings are based on information as of Dec. 10,
2019. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The diversified collateral pool.

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Neuberger Berman Loan Advisers CLO 35 Ltd.

  Class                  Rating       Amount (mil. $)
  A-1                    AAA (sf)              315.00
  A-2                    AAA (sf)               10.00
  B-I(i)                 AA (sf)                 0.00
  B-P(ii)                AAp (sf)               60.00
  C (deferrable)         A (sf)                 25.00
  D (deferrable)         BBB- (sf)              30.00
  E (deferrable)         BB- (sf)               20.00
  Subordinated-A notes   NR                     14.70
  Subordinated-B notes   NR                     25.80

(i)B-I is an interest-only rated note based off the principal
balance of B-P.
(ii)B-P is a principal-only rated note.
NR--Not rated.



NEW RESIDENTIAL 2019-6: DBRS Finalizes BB Rating on 10 Classes
--------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
Mortgage-Backed Notes, Series 2019-6 (the Notes) issued by New
Residential Mortgage Loan Trust 2019-6 (the Trust):

-- $326.2 million Class A-1 at AAA (sf)
-- $326.2 million Class A-IO at AAA (sf)
-- $326.2 million Class A-1A at AAA (sf)
-- $326.2 million Class A-1B at AAA (sf)
-- $326.2 million Class A-1C at AAA (sf)
-- $326.2 million Class A-1D at AAA (sf)
-- $326.2 million Class A1-IOA at AAA (sf)
-- $326.2 million Class A1-IOB at AAA (sf)
-- $326.2 million Class A1-IOC at AAA (sf)
-- $326.2 million Class A1-IOD at AAA (sf)
-- $365.5 million Class A-2 at AAA (sf)
-- $326.2 million Class A at AAA (sf)
-- $39.3 million Class B-1 at AAA (sf)
-- $39.3 million Class B1-IO at AAA (sf)
-- $39.3 million Class B-1A at AAA (sf)
-- $39.3 million Class B-1B at AAA (sf)
-- $39.3 million Class B-1C at AAA (sf)
-- $39.3 million Class B-1D at AAA (sf)
-- $39.3 million Class B1-IOA at AAA (sf)
-- $39.3 million Class B1-IOB at AAA (sf)
-- $39.3 million Class B1-IOC at AAA (sf)
-- $21.0 million Class B-2 at AA (sf)
-- $21.0 million Class B2-IO at AA (sf)
-- $21.0 million Class B-2A at AA (sf)
-- $21.0 million Class B-2B at AA (sf)
-- $21.0 million Class B-2C at AA (sf)
-- $21.0 million Class B-2D at AA (sf)
-- $21.0 million Class B2-IOA at AA (sf)
-- $21.0 million Class B2-IOB at AA (sf)
-- $21.0 million Class B2-IOC at AA (sf)
-- $32.9 million Class B-3 at A (sf)
-- $32.9 million Class B3-IO at A (sf)
-- $32.9 million Class B-3A at A (sf)
-- $32.9 million Class B-3B at A (sf)
-- $32.9 million Class B-3C at A (sf)
-- $32.9 million Class B-3D at A (sf)
-- $32.9 million Class B3-IOA at A (sf)
-- $32.9 million Class B3-IOB at A (sf)
-- $32.9 million Class B3-IOC at A (sf)
-- $22.5 million Class B-4 at BBB (sf)
-- $22.5 million Class B-4A at BBB (sf)
-- $22.5 million Class B-4B at BBB (sf)
-- $22.5 million Class B-4C at BBB (sf)
-- $22.5 million Class B4-IOA at BBB (sf)
-- $22.5 million Class B4-IOB at BBB (sf)
-- $22.5 million Class B4-IOC at BBB (sf)
-- $19.0 million Class B-5 at BB (sf)
-- $19.0 million Class B-5A at BB (sf)
-- $19.0 million Class B-5B at BB (sf)
-- $19.0 million Class B-5C at BB (sf)
-- $19.0 million Class B-5D at BB (sf)
-- $19.0 million Class B5-IOA at BB (sf)
-- $19.0 million Class B5-IOB at BB (sf)
-- $19.0 million Class B5-IOC at BB (sf)
-- $19.0 million Class B5-IOD at BB (sf)
-- $41.5 million Class B-7 at BB (sf)

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

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

The AAA (sf) ratings on the Notes reflect 27.85% of credit
enhancement provided by subordinated notes. The AA (sf), A (sf),
BBB (sf) and BB (sf) ratings reflect 23.70%, 17.20%, 12.75% and
9.00% of credit enhancement, respectively.

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

This transaction is a securitization of a seasoned portfolio of
performing and re-performing first-lien residential mortgages
funded by the issuance of the Notes. The Notes are backed by 4,681
loans with a total principal balance of $506,525,572 as of the
Cut-Off Date (November 1, 2019).

The loans are significantly seasoned with a weighted-average age of
188 months. As of the Cut-Off Date, 84.5% of the pool is current,
14.1% is 30 days delinquent under the Mortgage Bankers Association
(MBA) delinquency method and 1.4% is in bankruptcy (all bankruptcy
loans are performing or 30 days delinquent). Approximately 54.5%
and 61.6% of the mortgage loans have been zero times 30 days
delinquent for the past 24 months and 12 months, respectively,
under the MBA delinquency method.

The portfolio contains 61.9% modified loans. The modifications
happened more than two years ago for 83.9% of the modified loans.
The entire pool is exempt from the Consumer Financial Protection
Bureau's Ability-to-Repay/Qualified Mortgage rules because of
seasoning.

The Seller, NRZ Sponsor IX LLC (NRZ), acquired the loans prior to
the Closing Date in connection with the termination of various
securitization trusts and from a whole-loan purchase. Upon
acquiring the loans, NRZ, through an affiliate, New Residential
Funding 2019-6 LLC (the Depositor), will contribute the loans to
the Trust. As the Sponsor, New Residential Investment Corp.,
through a majority-owned affiliate, will acquire and retain a 5%
eligible vertical interest in each class of securities issued
(other than the residual notes) to satisfy the credit risk
retention requirements under Section 15G of the Securities Exchange
Act of 1934 and the regulations promulgated thereunder. These loans
were originated and previously serviced by various entities through
purchases in the secondary market.

As of the Cut-Off Date, 62.9% of the pool is serviced by PHH
Mortgage Corporation, 29.3% by Nationstar Mortgage LLC (Nationstar)
doing business as (d/b/a) Mr. Cooper, 5.7% by Select Portfolio
Servicing and 2.0% by NewRez LLC d/b/a Shellpoint Mortgage
Servicing (SMS). Nationstar will also act as the Master Servicer,
and SMS will act as the Special Servicer.

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

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

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

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

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

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

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

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


NORTHWOODS CAPITAL 20: S&P Assigns Prelim BB- Rating to E Notes
---------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Northwoods
Capital 20 Ltd.'s floating-rate notes.

The note issuance is a collateralized loan obligation transaction
backed by primarily broadly syndicated speculative-grade senior
secured term loans that are governed by collateral quality tests.

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

The preliminary ratings reflect:

-- The diversified collateral pool.

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

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

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

  PRELIMINARY RATINGS ASSIGNED
  Northwoods Capital 20 Ltd.

  Class                   Rating       Amount (mil. $)
  A-1                     AAA (sf)              270.00
  A-2                     NR                     22.50
  B                       AA (sf)                42.75
  C (deferrable)          A (sf)                 33.75
  D (deferrable)          BBB (sf)               22.50
  E (deferrable)          BB- (sf)               18.00
  Subordinated notes      NR                     40.68
  NR--Not rated.


OHA LOAN 2015-1: S&P Rates Class E-R2 Notes 'BB- (sf)'
------------------------------------------------------
S&P Global Ratings assigned its ratings to OHA Loan Funding 2015-1
Ltd.'s fixed- and floating-rate notes.

The note issuance is a CLO transaction backed by broadly syndicated
speculative-grade (rated 'BB+' and lower) senior secured term loans
managed by Oak Hill Advisors L.P.

The ratings reflect:

The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  OHA Loan Funding 2015-1 Ltd./OHA Loan Funding 2015-1 LLC

  Class                     Rating       Amount (mil. $)
  A-1-R2                    AAA (sf)              409.00
  A-2-R2                    NR                      7.00
  B-1-R2                    AA (sf)                70.00
  B-2-R2                    AA (sf)                 4.40
  C-R2 (deferrable)         A (sf)                 38.50
  D-R2 (deferrable)         BBB- (sf)              39.00
  E-R2 (deferrable)         BB- (sf)               25.40
  Subordinated notes        NR                    89.157

  NR--Not rated.


PFP LTD 2019-6: DBRS Assigns Prov. B(low) Rating on Class G Notes
-----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
secured floating-rate notes to be issued by PFP 2019-6, Ltd. (the
Issuer):

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

All trends are Stable.

All classes will be privately placed.

The initial collateral consists of 36 floating-rate mortgages
secured by 37 transitional properties totaling $760.1 million
(90.4% of the total fully funded balance), excluding the $80.7
million of remaining future funding commitments. Of the 36 loans,
there are three unclosed loans as of November 18, 2019,
representing 8.5% of the initial pool balance (#9, Barrett
Pavilion; #13, 5 Wood Hollow Road; and #18, Tiffany Retro
Apartments). The loans are mostly secured by currently cash-flowing
assets, most of which are in a period of transition with plans to
stabilize and improve the asset value. Of these loans, 22 have
remaining future funding participation that may be acquired by the
Issuer in the future with principal repayment proceeds for a total
of $80.7 million. The initial future funding commitments totaled
$83.2 million, of which approximately $2.5 million has been funded
to date. If the acquisition by the Issuer of all or a portion of
future funding participation results in a downgrade of the ratings
by DBRS Morningstar, PFP Holding Company VI, LLC (PFP Holding) will
be required to promptly repurchase such related funded companion
participation at the same price as the Issuer paid to acquire it.

The loans were all sourced by an affiliate of the Issuer, which has
strong origination practices. Classes E, F, G and the Preferred
Shares (collectively, the retained securities) will be purchased by
a wholly-owned subsidiary of PFP, Inc. Classes F, G, and the
Preferred Shares represent 15.3% of the initial pool balance.

Given the floating-rate nature of the loans, the index DBRS
Morningstar used (one-month LIBOR) was the lower of (1) a DBRS
Morningstar stressed rate that corresponded to the remaining fully
extended term of the loans or (2) the strike price of the
interest-rate cap with the respective contractual loan spread added
to determine a stressed interest rate over the loan term. When the
cut-off balances were measured against the DBRS Morningstar As-Is
Net Cash Flow (NCF), 28 loans (74.0% of the mortgage loan cut-off
date balance) had a DBRS Morningstar As-Is Debt Service Coverage
Ratio (DSCR) below 1.00 times (x), a threshold indicative of
default risk. Additionally, the DBRS Morningstar Stabilized DSCR
for 20 loans, comprising 60.3% of the initial pool balance, is
below 1.00x, which is indicative of elevated refinance risk. The
properties are often transitioning with potential upside in the
cash flow; however, DBRS Morningstar does not give full credit to
the stabilization if there are no holdbacks or if other loan
structural features in place are insufficient to support such
treatment. Furthermore, even with the structure provided, DBRS
Morningstar generally does not assume the assets to stabilize the
above market levels. The transaction will have a sequential-pay
structure.

Ten loans, representing 23.9% of the pool, are in areas identified
as DBRS Morningstar Market Ranks 6, 7 and 8, which are generally
characterized as highly dense urbanized areas that benefit from
increased liquidity that is driven by consistently strong investor
demand, even during times of economic stress. Markets ranked six
through eight benefits from lower default frequencies than less
dense suburban, tertiary and rural markets. Urban markets
represented in the deal include New York; Philadelphia; Cleveland;
Seattle; Portland, Oregon; San Francisco; and Oakland, California.
Additionally, there are only three loans, representing 10.1% of the
pool, in markets ranked one or two, which are considered more rural
or tertiary in nature and often suffer from lower investor demand
and liquidity, particularly during times of economic stress.

Five loans, comprising 29.0% of the total pool balance, are secured
by properties deemed by DBRS Morningstar to be Above Average in
quality. Five additional loans, totaling 9.8% of the total pool
balance, are secured by properties identified as Average (+) in
quality. Equally important, only one loan, representing 1.2% of the
total pool balance, is secured by a property deemed by DBRS
Morningstar to be Below Average.

Only one loan, representing 2.2% of the initial pool balance, is
secured by hotel property. Hotels have the highest cash flow
volatility of all property types, as their income (which is derived
from daily contracts rather than multi-year leases) and their
expenses (which are often mostly fixed) account for a relatively
large proportion of revenue. As a result, cash revenue can decline
swiftly in the event of a downturn and cash flow may decline more
exponentially because of high operating leverage. In addition, the
one hospitality loan in the pool is in an area with a DBRS
Morningstar Market Rank of 7, which benefits from strong investor
demand and increased liquidity.

The deal is concentrated by property type with 14 loans,
representing 48.5% of the mortgage loan cut-off date balance,
secured by multifamily properties. One of these loans, comprising
1.1% of the trust balance, is backed by a student housing property,
which often exhibits higher cash flow volatility than traditional
multifamily properties. Additionally, 12 loans, representing 34.9%
of the mortgage loan cut-off balance, are secured by office
properties. Multifamily properties benefit from staggered lease
rollover and generally low expense ratios compared with other
property types. While revenue is quick to decline in a downturn
because of the short-term nature of the leases, it is also quick to
respond when the market improves. Furthermore, the average expected
loss of the loans secured by multifamily properties is roughly 30%
lower than the average expected loss of the overall pool. DBRS
Morningstar sampled 75.9% of the pool, representing 84.2% coverage
of the total multifamily loan cut-off balance and 77.5% of the
total office loan cut-off balance, thereby providing comfort for
the DBRS Morningstar NCF. Student housing properties are modeled
with an elevated probability of default compared with traditional
multifamily.

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

All loans have floating interest rates, and there are 34 loans,
representing 95.5% of the initial pool balance, which is IO during
the initial loan term, which ranges from 24 months to 48 months,
creating interest-rate risk. The borrowers of all 36 loans have
purchased LIBOR rate caps that have a range of 3.25% to 3.50% to
protect against a rise in interest rates over the term of the loan.
All loans are short term and, even with extension options, have a
fully extended maximum loan term of six years. Additionally, all
loans have extension options, and, in order to qualify for these
options, the loans must meet minimum DSCR and LTV requirements.
Twenty-six of the loans, representing 77.3% of the total pool,
amortize on fixed schedules during all or a portion of their
extension period.

The DBRS Morningstar sample included 21 loans, and DBRS Morningstar
performed site inspections on 16 of the 37 properties in the pool,
representing 67.8% of the pool by allocated cut-off loan balance.
DBRS Morningstar conducted meetings with the on-site property
manager, leasing agent or representative of the borrowing entity
for 11 properties, comprising 59.0% of the initial pool balance.

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


PFP LTD 2019-6: DBRS Finalizes B(low) Rating on Class G Notes
-------------------------------------------------------------
DBRS, Inc. finalized provisional ratings on the following classes
of secured floating-rate notes issued by PFP 2019-6, Ltd. (the
Issuer):

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

All trends are Stable.

All classes have been privately placed.

The initial collateral consists of 36 floating-rate mortgages
secured by 37 transitional properties totaling $760.1 million
(90.4% of the total fully funded balance), excluding the $80.7
million of remaining future funding commitments. Of the 36 loans,
there are three unclosed loans as of November 18, 2019,
representing 8.5% of the initial pool balance (#9, Barrett
Pavilion; #13, 5 Wood Hollow Road; and #18, Tiffany Retro
Apartments). The loans are mostly secured by currently cash-flowing
assets, most of which are in a period of transition with plans to
stabilize and improve the asset value. Of these loans, 22 have
remaining future funding participation that may be acquired by the
Issuer in the future with principal repayment proceeds for a total
of $80.7 million. The initial future funding commitments totaled
$83.2 million, of which approximately $2.5 million has been funded
to date. If the acquisition by the Issuer of all or a portion of
future funding participation results in a downgrade of the ratings
by DBRS Morningstar, PFP Holding Company VI, LLC (PFP Holding) will
be required to promptly repurchase such related funded companion
participation at the same price as the Issuer paid to acquire it.

The loans were all sourced by an affiliate of the Issuer, which has
strong origination practices. Classes F and G and the Preferred
Shares (collectively, the retained securities) were purchased by a
wholly-owned subsidiary of PFP, Inc. Classes F and G and the
Preferred Shares represent 15.3% of the initial pool balance.

Given the floating-rate nature of the loans, the index DBRS
Morningstar used (one-month LIBOR) was the lower of (1) a DBRS
Morningstar stressed rate that corresponded to the remaining fully
extended term of the loans or (2) the strike price of the
interest-rate cap with the respective contractual loan spread added
to determine a stressed interest rate over the loan term. When the
cut-off balances were measured against the DBRS Morningstar As-Is
Net Cash Flow (NCF), 28 loans (74.0% of the mortgage loan cut-off
date balance) had a DBRS Morningstar As-Is Debt Service Coverage
Ratio (DSCR) below 1.00 times (x), a threshold indicative of
default risk. Additionally, the DBRS Morningstar Stabilized DSCR
for 20 loans, comprising 60.3% of the initial pool balance, is
below 1.00x, which is indicative of elevated refinance risk. The
properties are often transitioning with potential upside in the
cash flow; however, DBRS Morningstar does not give full credit to
the stabilization if there are no holdbacks or if other loan
structural features in place are insufficient to support such
treatment. Furthermore, even with the structure provided, DBRS
Morningstar generally does not assume the assets to stabilize the
above market levels. The transaction has a sequential-pay
structure.

Ten loans, representing 23.9% of the pool, are in areas identified
as DBRS Morningstar Market Ranks 6, 7 and 8, which are generally
characterized as highly dense urbanized areas that benefit from
increased liquidity that is driven by consistently strong investor
demand, even during times of economic stress. Markets ranked six
through eight benefits from lower default frequencies than less
dense suburban, tertiary and rural markets. Urban markets
represented in the deal include New York; Philadelphia; Cleveland;
Seattle; Portland, Oregon; San Francisco; and Oakland, California.
Additionally, there are only three loans, representing 10.1% of the
pool, in markets ranked one or two, which are considered more rural
or tertiary in nature and often suffer from lower investor demand
and liquidity, particularly during times of economic stress.

Five loans, comprising 29.0% of the total pool balance, are secured
by properties deemed by DBRS Morningstar to be Above Average in
quality. Five additional loans, totaling 9.8% of the total pool
balance, are secured by properties identified as Average (+) in
quality. Equally important, only one loan, representing 1.2% of the
total pool balance, is secured by a property deemed by DBRS
Morningstar to be Below Average.

Only one loan, representing 2.2% of the initial pool balance, is
secured by hotel property. Hotels have the highest cash flow
volatility of all property types, as their income (which is derived
from daily contracts rather than multi-year leases) and their
expenses (which are often mostly fixed) account for a relatively
large proportion of revenue. As a result, cash revenue can decline
swiftly in the event of a downturn and cash flow may decline more
exponentially because of high operating leverage. In addition, the
one hospitality loan in the pool is in an area with a DBRS
Morningstar Market Rank of 7, which benefits from strong investor
demand and increased liquidity.

The deal is concentrated by property type with 14 loans,
representing 48.5% of the mortgage loan cut-off date balance,
secured by multifamily properties. One of these loans, comprising
1.1% of the trust balance, is backed by a student housing property,
which often exhibits higher cash flow volatility than traditional
multifamily properties. Additionally, 12 loans, representing 34.9%
of the mortgage loan cut-off balance, are secured by office
properties. Multifamily properties benefit from staggered lease
rollover and generally low expense ratios compared with other
property types. While revenue is quick to decline in a downturn
because of the short-term nature of the leases, it is also quick to
respond when the market improves. Furthermore, the average expected
loss of the loans secured by multifamily properties is roughly 30%
lower than the average expected loss of the overall pool. DBRS
Morningstar sampled 75.9% of the pool, representing 84.2% coverage
of the total multifamily loan cut-off balance and 77.5% of the
total office loan cut-off balance, thereby providing comfort for
the DBRS Morningstar NCF. Student housing properties are modeled
with an elevated probability of default compared with traditional
multifamily.

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

All loans have floating interest rates, and there are 34 loans,
representing 95.5% of the initial pool balance, that are
interest-only during the initial loan term, which ranges from 24
months to 48 months, creating interest-rate risk. The borrowers of
all 36 loans have purchased LIBOR rate caps that have a range of
3.25% to 3.50% to protect against a rise in interest rates over the
term of the loan. All loans are short term and, even with extension
options, have a fully extended maximum loan term of six years.
Additionally, all loans have extension options, and, in order to
qualify for these options, the loans must meet minimum DSCR and LTV
requirements. Twenty-six of the loans, representing 77.3% of the
total pool, amortize on fixed schedules during all or a portion of
their extension period.

The DBRS Morningstar sample included 21 loans, and DBRS Morningstar
performed site inspections on 16 of the 37 properties in the pool,
representing 67.8% of the pool by allocated cut-off loan balance.
DBRS Morningstar conducted meetings with the on-site property
manager, leasing agent or representative of the borrowing entity
for 11 properties, comprising 59.0% of the initial pool balance.

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


PREFERREDPLUS TRUST CZN-1: S&P Lowers 8.375% Trust Certs to 'CCC-'
------------------------------------------------------------------
S&P Global Ratings lowered its rating on PreferredPLUS Trust Series
CZN-1's preferred plus 8.375% trust certificates due Oct. 1, 2046,
to 'CCC-' from 'CCC'.

S&P's rating on the certificates depends solely on its rating on
the underlying security, Frontier Communications Corp.'s 7.05%
senior debentures due Oct. 1, 2046 ('CCC-').

The rating action reflects the Nov. 18, 2019, lowering of its
long-term rating on the underlying security to 'CCC-' from 'CCC'.

S&P may take subsequent rating actions on the certificates due to
the changes in its rating assigned to the underlying security.


PULSAR FUNDING: S&P Assigns BB- (sf) Rating to Class D Notes
------------------------------------------------------------
S&P Global Ratings assigned its ratings to Pulsar Funding I
Ltd./Pulsar Funding I LLC's floating-rate notes.

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

The ratings reflect:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  Pulsar Funding I Ltd./Pulsar Funding I LLC

  Class                Rating     Amount (mil. $)
  A loans              AA (sf)             302.00
  B (deferrable)       A (sf)               24.00
  C (deferrable)       BBB- (sf)            20.00
  D (deferrable)       BB- (sf)             18.00
  Subordinated notes   NR                   32.50

  NR--Not rated.


RALI TRUST 2006-QO8: Moody's Hikes Rating on Class I-A4A Debt to Ca
-------------------------------------------------------------------
Moody's Investors Service upgraded the ratings of three tranches
from RALI Series 2006-QO8 Trust. Moody's has also assigned a rating
to an additional class from the deal, the rating for which was
previously withdrawn in error.

The complete rating action is as follows:

Issuer: RALI Series 2006-QO8 Trust

Cl. I-A3A, Assigned Caa3 (sf) ; previously on April 6, 2017 rating
was Withdrawn

Cl. I-A4A, Upgraded to Ca (sf); previously on Dec 14, 2010
Downgraded to C (sf)

Cl. II-A, Upgraded to Caa3 (sf); previously on Dec 14, 2010
Downgraded to Ca (sf)

Cl. II-AX*, Upgraded to Caa3 (sf); previously on Dec 14, 2010
Downgraded to Ca (sf)

*Reflects Interest Only Classes

RATINGS RATIONALE

The rating upgrades on Cl. I-A4A, Cl. II-A and Cl. II-AX are
primarily due to improved performance of the underlying collateral
and increased credit enhancement available to the bonds.

Moody's also assigned a rating of Caa3 (sf) to Cl. I-A3A. Due to an
administrative error, the previous rating on this class was
mistakenly withdrawn on April 6th, 2017. Prior to the withdrawal,
Cl. I-A3A had a rating of Ca (sf).

The actions also reflect the recent performance as well as Moody's
updated loss expectations on the underlying pools.

The principal methodology used in rating all classes except
interest-only class was "US RMBS Surveillance Methodology"
published in February 2019. The methodologies used in rating
interest-only class were "US RMBS Surveillance Methodology"
published in February 2019 and "Moody's Approach to Rating
Structured Finance Interest-Only (IO) Securities" published in
February 2019.


RAMP TRUST 2005-RS3: Moody's Hikes Class M-6 Debt to Ba3
--------------------------------------------------------
Moody's Investors Service upgraded the ratings of three tranches
from RAMP Series 2005-RS3 Trust, which is backed by subprime
mortgage loans.

Complete rating actions are as follows:

Issuer: RAMP Series 2005-RS3 Trust

Cl. M-4, Upgraded to Aaa (sf); previously on Mar 27, 2018 Upgraded
to Aa3 (sf)

Cl. M-5, Upgraded to A1 (sf); previously on Mar 27, 2018 Upgraded
to Baa1 (sf)

Cl. M-6, Upgraded to Ba3 (sf); previously on Mar 27, 2018 Upgraded
to B2 (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to improvement in credit
enhancement available to the bonds, and also reflect a correction
to the cash-flow waterfall used by Moody's in rating this
transaction. In prior rating actions, losses were mistakenly
allocated to the certificates without first allocating losses to
the over-collateralization amount. This error has now been
corrected, and the rating actions reflect this change. The rating
actions also reflect the recent performance and Moody's updated
loss expectations on the underlying pools.

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

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

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


RASC TRUST 2004-KS6: Moody's Hikes Class M-I-1 Debt Rating to B2
----------------------------------------------------------------
Moody's Investors Service upgraded the rating of 10 tranches from
five transactions backed by Subprime RMBS, issued by multiple
issuers.

Complete rating actions are as follows:

Issuer: First Franklin Mortgage Loan Trust Series 2005-FF6

Cl. M-3, Upgraded to A2 (sf); previously on Jan 5, 2018 Upgraded to
Baa1 (sf)

Issuer: RASC Series 2004-KS6 Trust

Cl. A-I-5, Upgraded to A1 (sf); previously on Mar 27, 2018 Upgraded
to A3 (sf)

Cl. A-I-6, Upgraded to Aa3 (sf); previously on Mar 27, 2018
Upgraded to A2 (sf)

Cl. M-I-1, Upgraded to B2 (sf); previously on Apr 6, 2017 Upgraded
to Caa1 (sf)

Cl. M-II-1, Upgraded to Baa2 (sf); previously on Mar 27, 2018
Upgraded to Ba1 (sf)

Issuer: RASC Series 2005-AHL3 Trust

Cl. A-3, Upgraded to Aaa (sf); previously on Mar 28, 2017 Upgraded
to Aa3 (sf)

Cl. M-1, Upgraded to Ba2 (sf); previously on Mar 28, 2017 Upgraded
to B1 (sf)

Issuer: RASC Series 2005-EMX2 Trust

Cl. M-4, Upgraded to Aa2 (sf); previously on Dec 20, 2018 Upgraded
to A1 (sf)

Cl. M-5, Upgraded to Baa1 (sf); previously on Mar 6, 2018 Upgraded
to Ba1 (sf)

Issuer: RASC Series 2004-KS1 Trust

Cl. M-II-1, Upgraded to A2 (sf); previously on Dec 11, 2018
Upgraded to Baa1 (sf)

RATINGS RATIONALE

The rating upgrades are primarily due to an improvement in the
performance of the underlying pools and an increase in the credit
enhancement available to the bonds.

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

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

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment rate.
The unemployment rate fell to 3.5% in November 2019 from 3.7% in
November 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.


READY CAPITAL 2019-6: DBRS Finalizes B(low) Rating on G Certs
-------------------------------------------------------------
DBRS, Inc. finalized its provisional ratings on the following
classes of certificates (the Certificates) issued by Ready Capital
Mortgage Trust 2019-6 (the Issuer):

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

All trends are Stable.

The initial collateral consists of 89 fixed- and floating-rate
mortgages secured by 110 stabilized and transitional properties
with a cut-off balance totaling $430.7 million, excluding
approximately $5.6 million of future funding commitments attributed
to five loans. The pool contains a mix of stabilized properties
seeking short-term bridge financing, loans backing properties that
are in a period of transition with plans to stabilize and improve
the asset value and long term stabilized loans.

Although the majority of the loans are fixed-rate, the loans
backing transitional properties have a hybrid interest rate
structure wherein the loan amount within the trust is fixed rate
while the future funding component outside the trust is floating
rate. For these, DBRS Morningstar applied the floating rate across
the loans by using the one-month LIBOR index, which is based on the
lower of a DBRS Morningstar stressed rate that corresponded with
the remaining fully extended term of the loans or the strike price
of the interest rate cap with the respective contractual loan
spread added to determine a stressed interest rate over the loan
term. When the cut-off balances were measured against the DBRS
Morningstar As-Is Net Cash Flow (NCF), 12 loans comprising 28.5% of
the initial pool, had a DBRS Morningstar As-Is Debt Service
Coverage Ratio (DSCR) below 1.00 times (x), a threshold indicative
of default risk. Additionally, the DBRS Morningstar Stabilized DSCR
for seven loans, comprising 15.0% of the initial pool balance, is
below 1.00x, which is indicative of elevated refinance risk. Some
of the properties are transitioning with potential upside in cash
flow; however, DBRS Morningstar does not give full credit to the
stabilization if there are no holdbacks or if other loan structural
features in place are insufficient to support such treatment.
Furthermore, even with the structure provided, DBRS Morningstar
generally does not assume the assets to stabilize the above market
levels. The loans backing transitional properties are structured
with future funding, which will be conditionally released to the
sponsor but will not be brought into the trust.

The transaction will have a sequential-pay structure.

The loans are generally secured by traditional property types
(i.e., retail, multifamily, office and industrial); however, one
loan (Springhill Suites at The Rim; representing 3.5% of the pool)
is secured by hotel property. Additionally, two of the multifamily
loans (The Stilts on Springfield, representing 1.3% of the pool
balance, and Lincoln Park Townhomes, representing 1.2% of the pool
balance) in the pool are currently secured by a student-housing
property, which often exhibits higher cash flow volatility than
traditional multifamily properties.

Twenty-six loans, representing 45.1% of the initial pool balance,
are represented by properties primarily located in core markets
with a DBRS Morningstar Market Rank of 5 to 8. These higher DBRS
Morningstar Market Ranks correspond with zip codes that are more
urbanized or densely suburban in nature. Additionally, 30 loans,
representing 26.1% of the initial pool balance, are secured by
properties located in MSA Group 3. This group of MSAs has
relatively low historic commercial mortgage-backed security (CMBS)
default rates.

Three loans in the pool, totaling 13.4% of the DBRS Morningstar
sample by cut-off date pool balance, are backed by a property with
a quality deemed to be Average (+) by DBRS Morningstar.

Forty loans, representing 50.0% of the pool, represent acquisition
financing wherein sponsors contributed material cash equity as a
source of funding in conjunction with the mortgage loan, resulting
in a moderately high sponsor cost basis in the underlying
collateral.

Of the 28 loans DBRS Morningstar sampled, nine loans, representing
20.7% of the pool (34.9% of the DBRS Morningstar sample), were
modeled with Average (-) or Below Average property quality.
Lower-quality properties are less likely to retain existing
tenants, resulting in less stable performance. DBRS Morningstar
increased the probability of default (POD) for these loans to
account for the elevated risk.

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

The deal is concentrated by property type with 31 loans,
representing 41.7% of the mortgage loan cut-off date balance,
secured by multifamily properties. Two of these loans, comprising
2.6% of the trust balance, are backed by student-housing
properties, which often exhibit higher cash flow volatility than
traditional multifamily properties. Multifamily properties benefit
from staggered lease rollover and generally low expense ratios
compared with other property types. While revenue is quick to
decline in a downturn because of the short-term nature of the
leases, it is also quick to respond when the market improves. Two
loans, totaling 1.3% of the total multifamily cut-off balance, are
secured by properties located in a DBRS Morningstar Market Rank of
7. An additional two loans, representing 11.1% of the multifamily
concentration, are located in a DBRS Morningstar Market Rank of 6.
More importantly, DBRS Morningstar sampled 69.5% of the pool,
representing 80.2% coverage of the total multifamily loan cut-off
balance, thereby providing comfort for the DBRS Morningstar NCF.
Student-housing properties are modeled with an elevated POD
compared with traditional multifamily. No loans are secured by
military housing properties, which also often exhibit higher cash
flow volatility than traditional multifamily properties.

The pool is generally concentrated by geography with 21 properties,
representing 32.7% of the pool, located in Texas. Seven of these
properties are located in MSA Group 3, which has relatively low
historic CMBS default rates. Five of these are located in Market
Ranks that range between 5 and 7.

Classes IO-A and IO-B/C are interest-only (IO) certificates that
reference a single rated tranche or multiple rated tranches. The IO
rating mirrors the lowest-rated applicable reference obligation
tranche adjusted upward by one notch if senior in the waterfall.

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


RFC LTD 2006-1: Fitch Withdraws Ratings on 9 Tranches
-----------------------------------------------------
Fitch Ratings affirmed nine distressed classes of RFC CDO 2006-1,
Ltd. /LLC (RFC 2006-1). In addition, Fitch has withdrawn all
ratings as they are no relevant to the agency's coverage.

RATING ACTIONS

RFC CDO 2006-1, Ltd.

Class B 14986AAM8; LT Dsf Affirmed;   previously at Dsf

Class B 14986AAM8; LT WDsf Withdrawn; previously at Dsf

Class C 14986AAN6; LT Csf Affirmed;   previously at Csf

Class C 14986AAN6; LT WDsf Withdrawn; previously at Csf

Class D 14986AAP1; LT Csf Affirmed;   previously at Csf

Class D 14986AAP1; LT WDsf Withdrawn; previously at Csf

Class E 14986AAQ9; LT Csf Affirmed;   previously at Csf

Class E 14986AAQ9; LT WDsf Withdrawn; previously at Csf

Class F 14986AAR7; LT Csf Affirmed;   previously at Csf

Class F 14986AAR7; LT WDsf Withdrawn; previously at Csf

Class G 14986AAS5; LT Csf Affirmed;   previously at Csf

Class G 14986AAS5; LT WDsf Withdrawn; previously at Csf

Class H 14986AAT3; LT Csf Affirmed;   previously at Csf

Class H 14986AAT3; LT WDsf Withdrawn; previously at Csf

Class J 14986AAU0; LT Csf Affirmed;   previously at Csf

Class J 14986AAU0; LT WDsf Withdrawn; previously at Csf

Class K 14986AAV8; LT Csf Affirmed;   previously at Csf

Class K 14986AAV8; LT WDsf Withdrawn; previously at Csf

The ratings were withdrawn with the following reason: No longer
considered relevant to Fitch's coverage.

KEY RATING DRIVERS

The collateralized debt obligation (CDO) is undercollateralized by
over $140 million as of the November 2019 trustee reporting.
Further, the only remaining asset is not paying principal or
interest to the CDO. As of November 2018, proceeds were
insufficient to pay timely interest to the class B notes, resulting
in an event of default.

No recovery is anticipated on the sole remaining asset in the CDO;
and default of classes C through K is considered inevitable. The
$20 million JW Marriott mezzanine loan is backed by an interest in
a 575-room, full-service hotel located in Tucson, AZ. The senior
note, which was contributed to the CSFB 2006-TFL2 transaction, was
reportedly sold at par in April 2019; however, after related
expenses were factored in that transaction took a loss of $7.2
million. The mezzanine interest is expected to eventually be
written off.

RATING SENSITIVITIES

Ratings sensitivities are not applicable as the ratings on the
transaction are being withdrawn as they are no longer considered
relevant to the agency's coverage.

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
transaction.


SILVER HILL 2019-SBC1: DBRS Assigns Prov. B Rating on 2 Tranches
----------------------------------------------------------------
DBRS, Inc. assigned provisional ratings to the following classes of
secured floating-rate notes to be issued by Silver Hill Trust
2019-SBC1 (the Issuer):

-- Class A1 at AAA (sf)
-- Class A1-IO at AAA (sf)
-- Class A2 at AAA (sf)
-- Class A2-IO at AAA (sf)
-- Class M1 at AA (sf)
-- Class M1-IO at AA (sf)
-- Class M2 at A (sf)
-- Class M2-IO at A (sf)
-- Class M3 at BBB (sf)
-- Class M3-IO at BBB (sf)
-- Class B1 at BB (sf)
-- Class B1-IO at BB (sf)
-- Class B2 at B (sf)
-- Class B2-IO at B (sf)

All trends are Stable.

The collateral consists of 1,003 individual loans secured by 1,003
commercial, multifamily and single-family rental (SFR) properties
with an average loan balance of $450,008. DBRS Morningstar defines
properties as buildings located in non-contiguous addresses. The
transaction is configured with a sequential pay pass-through
structure. Given the complexity of the structure and granularity of
the pool, DBRS Morningstar applied its "North American CMBS
Multi-borrower Rating Methodology" (the CMBS Methodology) and its
"RMBS Insight 1.3: U.S. Residential Mortgage-Backed Securities
Model and Rating Methodology" (the RMBS Methodology).

Of the 1,003 individual loans, 205 loans, representing 18.0% of the
pool, have a fixed interest rate with a straight average of 7.6%.
The floating-rate loans are structured with interest-rate life
floors ranging from 6.0% to 11.0% with a straight average of 7.7%
and interest-rate margin ranging from 0.75% to 6.0% with a straight
average of 2.9%. To determine the probability of default (POD) and
loss given default inputs in the CMBS Insight Model for
floating-rate loans, DBRS Morningstar applied a stress to the
various indexes that corresponded with the remaining fully extended
term of the loans and added the respective contractual loan spread
to determine a stressed interest rate over the loan term. DBRS
Morningstar looked to the greater of the interest-rate floor or the
DBRS Morningstar stressed index rate when calculating stressed debt
service. The average DBRS Morningstar modeled coupon rate across
all loans was 7.7%. The loans have original terms of ten years to
30 years and amortize over periods of 15 years to 30 years. When
the cut-off loan balances were measured against the DBRS
Morningstar stressed net cash flow (NCF) and their respective
actual constants or stressed interest rates, there were 878 loans,
representing 87.8% of the pool, with term debt service coverage
ratios (DSCRs) below 1.15 times (x), a threshold indicative of a
higher likelihood of term default.

The pool has a weighted-average (WA) original term length of 347
months or 28.9 years with a WA remaining term of 335 months or 27.9
years. Based on the original loan balance and the appraisal at
origination, the pool had a WA loan-to-value (LTV) ratio of 65.2%.
DBRS Morningstar applied a pool WA LTV of 71.5%, which reflects
adjustments made to values based on implied cap rates by market
rank. Furthermore, all but 33 of 1,003 loans fully amortize over
their respective remaining loan terms, resulting in 97.5% expected
amortization; this is not representative of typical commercial
mortgage-backed security (CBMS) conduit pools, which have
substantial concentrations of interest-only (IO) and balloon loans.
DBRS Morningstar's research indicates that, for CMBS conduit
transactions securitized between 2000 and 2018, average
amortization by year has ranged between 7.5% and 22.0% with an
overall median of 12.5%.

Of the 1,003 loans, 45 loans, representing 1.6% of the trust
balance, are secured by SFR properties, defined as one to four
investor properties with one unit by the Issuer. The CMBS
Methodology does not currently contemplate ratings on SFR
properties. To address this, DBRS Morningstar severely increased
the expected loss on these loans by approximately 2.5x over the
average non-SFR expected loss.

The fully adjusted default assumption and model generated severity
figures from the DBRS Morningstar CMBS Insight Model were then
applied to the RMBS Cash Flow Model, which is adept at modeling
sequential and pro-rata structures on loan pools in excess of 1,000
loans. As part of the RMBS Cash Flow Model, DBRS Morningstar
incorporated four conditional prepayment rate stresses – 5.0%,
10.0%, 15.0% and 20.0%. Additional assumptions in the RMBS Cash
Flow Model include a 22-month recovery lag period, 100% servicer
advancing and four default curves (uniform, front, middle and
back). The shape and duration of the default curves were based on
the residential mortgage-backed security loss curves. Lastly, rates
were stressed, both upward and downward, based on their respective
loan indices.

The pool is relatively diverse based on loan size with an average
balance of $450,008, a concentration profile equivalent to that of
a pool with 617 equal-sized loans and a top-ten loan concentration
of only 4.7%. Increased pool diversity helps to insulate the
higher-rated classes from event risk. Furthermore, the loans are
mostly secured by traditional property types (i.e., retail,
multifamily, office and industrial) with no exposure to
higher-volatility property types, such as hotels, and minimal
exposure to self-storage or manufactured housing communities, which
represent 4.3% of the pool balance combined. Lastly, all but 33
loans in the pool fully amortize over their respective loan terms
between 120 months and 360 months, thus virtually eliminating
refinance risk.

The pool has high term risk as supported by the low WA DBRS
Morningstar DSCR of 0.89x. The DBRS Morningstar DSCR reflects a
conservatively stressed NCFs. Furthermore, the pool has a cut-off
WA LTV of 65.2% based on appraisal values at loan origination that
suggests overall moderate leverage.

The pool is heavily concentrated with multifamily, representing
35.8% of the pool, as modeled by DBRS Morningstar. Multifamily
properties included assets identified by the Issuer as multifamily,
bulk residential contiguous, bulk residential non-contiguous,
mixed-use assets that were predominately residential, and one to
four investor properties with two or more units. Based on DBRS
Morningstar research, multifamily properties securitized in conduit
transactions have had lower default rates than most other property
types. Of the pool balance, 30.0% of the multifamily loans are
located in strong suburban or urban markets, identified by market
ranks of five or greater, which typically have a more robust tenant
demand for multifamily properties.

Of the 548 loans on which DBRS Morningstar performed exterior
inspections, 34 loans, representing 4.4% of the pool (41.8% of the
DBRS Morningstar sample), were modeled with Average (-) to Poor
property quality and, on an overall basis, the mean DBRS
Morningstar property quality was Average (-). Lower-quality
properties are less likely to retain existing tenants, resulting in
less stable performance. DBRS Morningstar increased the POD for
these loans to account for the elevated risk. Furthermore, DBRS
Morningstar modeled any uninspected loans as Average (-), which has
a slightly increased POD level.

Limited property-level information was available for DBRS
Morningstar to review. Asset Summary Reports, Property Condition
Reports (PCRs), Phase I/II Environmental reports and historical
financial cash flows were not provided in conjunction with this
securitization. DBRS Morningstar received a long- or short-form
appraisal for loans in its sample, which DBRS Morningstar used in
the NCF analysis process. No environmental reports were provided;
however, only 11.1% of the pool consists of loans secured by
industrial properties, which would typically have an increased risk
of environmental concerns originating at the property. Furthermore,
as of the Cut-off Date, approximately 0.7% of the pool will be
covered by an individual environmental insurance policy and
approximately 33.9% of the Mortgage Loans will be covered by one or
more blanket environmental insurance policies. No PCRs were
provided; however, DBRS Morningstar used capital expense estimates
in excess of its guideline amounts and its assessment of the
sampled property quality to stress the NCF analysis. DBRS
Morningstar's NCF analysis resulted in a 27.8% reduction to the
Issuer's NCF, well above the median historical reduction of 8.0%
across CBMS conduit transactions, which provides meaningful stress
to the default levels.

DBRS Morningstar was provided limited borrower information, net
worth or liquidity information and credit history. DBRS Morningstar
modeled loans with Weak borrower strength, which increases the
stress on the default rate. Furthermore, DBRS Morningstar was
provided a 24-month pay history on each loan. Any loan with more
than two late pays within this period (or one late pay for loans
with less than 24 months of history) or two consecutive late pays
was modeled with additional stress to the default rate. This
assumption was applied to 17 loans, representing 2.2% of the pool
balance. Additionally, loans originated under the Lite Doc or Bank
Statement documentation programs were modeled with additional
stress to account for risk associated with borrowers that are
potentially less sophisticated or have negative credit histories.
Finally, a borrower FICO score as of October 2019 was provided on
739 of the 1,003 loans with an average FICO score of 722. While the
CMBS Methodology does not contemplate FICO scores, the RMBS
Methodology does and would characterize a FICO score of 721 as
near-prime, where prime is considered greater than 750. A borrower
with a FICO score of 721 could generally be described as
potentially having had previous credit events (foreclosure,
bankruptcy, etc.), but it is likely that these credit events were
cleared about two to five years ago.

Classes A1-IO, A2-IO, M1-IO, M2-IO, M3-IO, B1-IO, B2-IO are IO
certificates that reference a single rated tranche or multiple
rated tranches. The IO rating mirrors the lowest-rated applicable
reference obligation tranche in the waterfall.

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


TAILWIND 2019-1: S&P Assigns BB(sf) Rating on $46MM Series C Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Tailwind 2019-1
Ltd./Tailwind 2019-1 USA LLC's series 2019-1 notes:

-- $510 million series A: A (sf).
-- $81 million series B: BBB (sf).
-- $46 million series C: BB (sf).

The preliminary note issuance was an ABS transaction backed by 17
aircraft, and the related leases, shares, and beneficial interests
in an entity that directly and indirectly receives aircraft
portfolio lease rental and residual cash flows, among others.
However, an Airbus A330-300 wide-body aircraft bearing serial
number 1754 was removed from the portfolio after the lessee, South
African Airways SOC Ltd. (SAA), was placed into business rescue
(similar to bankruptcy protection) on Dec. 4, 2019. Although the
aircraft is part of the initial portfolio, the issuers/purchasers
have agreed under the asset purchase agreement that they will not
purchase this aircraft, and it will be removed on the special
redemption date, which is expected to occur no later than Dec. 17,
2019, and the note balances will be reduced accordingly on that
date.

As a result, S&P's analysis and ratings are based on a portfolio of
16 aircraft and the corresponding reduction in the note balances.
The current portfolio, which consists of 16 aircraft that are also
currently on lease to 14 lessees in 10 countries. Of the 16
aircraft, 15 are narrow-body passenger planes (10 Airbus A320-200s
[including three Airbus A320-200NEO], three Airbus A321-200s, and
two Boeing B737-800) and one is a B777-300ER wide-body plane. The
16 aircraft have a weighted average age of approximately 5.1 years
and remaining average lease term of approximately 5.6 years as of
the closing date. None of the aircraft are currently out of
production.

The ratings also reflect the following:

-- The likelihood of timely interest on the series A notes
(excluding step-up interest) on each payment date, the timely
interest on the series B notes (excluding step-up interest) when
series A notes are no longer outstanding on each payment date, and
the ultimate interest and principal payment on the series A, B, and
C notes on or prior to the legal final maturity at the respective
rating stress.

-- The 73% loan-to-value (LTV) ratio on the series A notes, the
84% LTV on the series B notes, and the 91% LTV on the series C
notes. The value used in these measures is based on the lower of
the median or mean of the appraised half-life base values and
half-life market values.

-- There are many lessees in the portfolio that are domiciled in
emerging markets, where the commercial aviation market is growing.
The series A and B notes' 12.5-year amortization profile and the
series C notes' seven-year amortization profile.

-- If a rapid amortization event has occurred and is continuing,
payment will be applied sequentially to the series A notes
outstanding principal balance, followed by the series B notes
outstanding principal balance.

-- The end-of-lease payment that will be paid to the series A, B,
and C notes according to a percentage equalling to each series'
then-current LTV ratio.

-- A liquidity facility of at least nine months of interest on the
series A and B notes.

-- The maintenance analysis provided by Alton Aviation Consultancy
LLC at closing and annually thereafter, projecting the expected
maintenance expenses for the following 29 months.

-- The maintenance reserve account, which is required to maintain
a balance to meet the higher of the lesser of $1,000,000 or the
outstanding balance of the class A and B notes, or the sum of
forward-looking maintenance expenses. The account will be funded
with $6,000,000 at closing.

-- The senior indemnification (capped at $10 million), which is
modelled to occur in the first 12 months.

-- The junior indemnification (uncapped), which is subordinated to
the rated series' principal payment.

-- The servicer for this transaction is Airborne Capital Ltd.,
which S&P believes is adequately capable of servicing this
transaction's aircraft portfolio.

The structural changes since S&P assigned preliminary ratings to
the notes on Nov. 7, 2019, are as follows:

-- The number of aircraft in the portfolio declined to 16 after an
Airbus A330-300 wide-body aircraft on lease with SAA was slated to
be removed from the portfolio on the special redemption date, which
will occur no later than Dec. 17, 2019. This will reduce the note
balances. The series A, B, and C notes are expected to have an
outstanding balance of $445.742 million, $70.794 million, and
$40.204 million, respectively, after the special redemption date.

-- The amortization schedule for the series A and B notes was
changed to 12.5 years straight-line from 13.5 years straight-line.

-- The loan facility agreement for maintenance payments due by few
airlines was removed, and S&P received updated maintenance cash
flows without giving effect to this agreement.

-- The senior and junior maintenance required amount schedules
were changed and the caps in steps five and 11 of the pre-default
waterfall replenishing the maintenance reserves were removed. Also,
the maintenance reserve will be replenished at step 11 (the junior
maintenance required amount) only on, or prior to, the expected
final payment date, after which point both the senior and the
junior required amounts will be the same.

-- Any excess in the maintenance reserve account over the senior
required maintenance amount will be released to the collections
account only on, or after, the expected final payment date, instead
of on, or after, 12 months from the closing date under S&P's
preliminary analysis.

-- Any excess in the maintenance reserve account over the junior
required maintenance amount will be released to the collections
account after 12 months from the closing date and prior to the
expected final payment date.

-- The class C reserve account is now replenished over time up to
the lower of six months' interest on the series C notes or 50% of
the available collections at step 18 of the pre-default waterfall
(right before paying step-up interest on the series A notes).


TRINITAS CLO III: Moody's Lowers $8MM Class F Notes to Caa3
-----------------------------------------------------------
Moody's Investors Service downgraded the rating on the following
notes issued by Trinitas CLO III, Ltd.:

US$8,000,000 Class F Deferrable Floating Rate Notes Due July 15,
2027, Downgraded to Caa3 (sf); previously on December 17, 2018
Downgraded to Caa1 (sf)

RATINGS RATIONALE

The downgrade rating action on the Class F notes reflects the
specific risks to the junior notes posed by par loss and credit
deterioration observed in the underlying CLO portfolio. Based on
Moody's calculation, the over-collateralization (OC) ratio for the
Class F notes has fallen to 102.14% versus the December 2018 level
of 104.40%. Furthermore, the Moody's calculated weighted average
rating factor (WARF) has been deteriorating and the current level
is 2783 compared to 2632 in December 2018.

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

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base case,
Moody's analyzed the collateral pool as having a performing par and
principal proceeds balance of $372.0 million, defaulted par of $1.9
million, a weighted average default probability of 18.82% (implying
a WARF of 2783), a weighted average recovery rate upon default of
48.75%, a diversity score of 54 and a weighted average spread of
3.13%.

Methodology Underlying the Rating Action:

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

Factors that Would Lead to an Upgrade or Downgrade of the Rating:

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


VNDO TRUST 2016-350P: S&P Affirms BB- (sf) Rating to Cl. E Certs
----------------------------------------------------------------
S&P Global Ratings affirmed its ratings on six classes of
commercial mortgage pass-through certificates from VNDO Trust
2016-350P, a U.S. CMBS transaction.

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

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

This is a stand-alone (single-borrower) transaction backed by
$233.3 million of a $400.0 million fixed-rate IO whole loan. The
whole loan is secured by a first lien on the borrower's fee
interest in 350 Park Avenue, a 30-story, 570,784-sq.-ft. class A
office building, including 17,144 sq. ft. of ground floor retail
space, in Manhattan's Park Avenue submarket. S&P said, "Our
property-level analysis included a reevaluation of the office
property that secures the whole loan and considered the relatively
stable servicer-reported net operating income and occupancy for the
past five years (2015 through the trailing 12 months ending June
30, 2019). We then derived our sustainable in-place net cash flow,
which we divided by a 6.50% S&P Global Ratings capitalization rate
to determine our expected-case value." This yielded an overall S&P
Global Ratings loan-to-value ratio and debt service coverage of
83.6% and 1.94x, respectively, on the whole loan balance.

The property is 97.7% economically occupied as of the June 2019
rent roll. S&P said, "However, at issuance, we noted that the
largest tenant, Ziff Brothers (Ziff; 287,030 sq. ft., 50.3% of net
rentable area [NRA]), reduced its footprint at the building and had
already subleased 53.3% of its total square footage at the
property. The master servicer recently confirmed that Ziff now
subleases 65.0% of its sq. ft., and the tenant does not intend to
renew its lease at its April 2021 expiration date. The master
servicer further confirmed that Ziff continues to pay rent under
the terms of its lease, and that a re-leasing reserve is now being
funded out of excess cash flow. In addition, as part of our
surveillance review, we considered the property's strong occupancy
history, as well as the higher vacancy assumption and cap rate used
in our analysis, which considers Ziff's rollover risk. We will
continue to monitor the sponsor's leasing efforts and, if actual
performance differs significantly from our expectations, we will
revisit our assumptions and consider the impact, if any, on the
transaction."

The IO whole mortgage loan had an initial and current $400.0
million balance, pays a per annum fixed rate of 3.91513%, and
matures on Jan. 6, 2027. The whole loan is split into four senior A
and two subordinate B notes. The $233.3 million trust balance
(according to the Nov. 13, 2019, trustee remittance report)
comprises the $77.6 million senior note A-1, the $51.7 million
senior note A-3, the $62.4 million subordinate note B-1, and the
$41.6 million subordinate note B-2. The $100.0 million senior note
A-2 is in GS Mortgage Securities Trust 2017-GS5 and the $66.7
million senior note A-4 is in JPMDB Commercial Mortgage Securities
Trust 2017-C5, both U.S. CMBS transactions. The A notes are pari
passu to each other and senior to the B notes. To date, the trust
has not incurred any principal losses.

Midland reported debt service coverage of 2.31x on the whole loan
balance for the trailing 12 months ending June 30, 2019. Based on
the July 1, 2019, rent roll, the five largest tenants make up 80.6%
of the total NRA. In addition, 54.9%, 7.1%, and 18.2% of the NRA
have leases that expire in 2021, 2022, and 2023, respectively. As
previously noted, 50.3% of the rollover in 2021 is attributable to
Ziff, which has already indicated that it will not renew upon
expiration.


  RATINGS AFFIRMED

  VNDO Trust 2016-350P

  Commercial mortgage pass-through certificates

  Class A: AAA (sf)

  Class B: AA- (sf)

  Class C: A- (sf)

  Class D: BBB- (sf)

  Class E: BB- (sf)

  Class X-A: AAA (sf)



VOYA CLO 2019-4: S&P Assigns BB- (sf) Rating to Class E Notes
-------------------------------------------------------------
S&P Global Ratings assigned its ratings to Voya CLO 2019-4
Ltd./Voya CLO 2019-4 LLC's floating-rate notes.

The note issuance is CLO transaction backed by a diversified
collateral pool, which consists primarily of broadly syndicated
speculative-grade (rated 'BB+' and lower) senior secured term loans
that are governed by collateral quality tests.

The ratings reflect:

-- The diversified collateral pool;

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

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

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

  RATINGS ASSIGNED
  Voya CLO 2019-4 Ltd./Voya CLO 2019-4 LLC

  Class                Rating       Amount (mil. $)
  A-1                  AAA (sf)              372.00
  A-2                  NR                     18.00
  B                    AA (sf)                66.00
  C                    A (sf)                 36.00
  D                    BBB- (sf)              36.00
  E                    BB- (sf)               21.00
  Subordinated notes   NR                     54.40

  NR--Not rated.


[*] DBRS Puts 316 Classes on 12 GSE CRT Deals Under Review
----------------------------------------------------------
DBRS, Inc. placed its ratings on 316 outstanding classes of the
following 12 government-sponsored enterprise credit risk transfer
(GSE CRT) transactions Under Review with Positive Implications:

-- Fannie Mae Connecticut Avenue Securities, Series 2017-C03

-- Fannie Mae Connecticut Avenue Securities, Series 2017-C05

-- Fannie Mae Connecticut Avenue Securities, Series 2018-C01

-- Fannie Mae Connecticut Avenue Securities, Series 2018-C03

-- Fannie Mae Connecticut Avenue Securities, Series 2018-C05

-- Freddie Mac Structured Agency Credit Risk Debt Notes, Series
     2015-DN1

-- Freddie Mac Structured Agency Credit Risk Debt Notes, Series
     2015-DNA3

-- Freddie Mac Structured Agency Credit Risk Debt Notes, Series
     2016-DNA3

-- Freddie Mac Structured Agency Credit Risk Debt Notes, Series
     2016-HQA1

-- Freddie Mac Structured Agency Credit Risk Debt Notes, Series
     2016-HQA4

-- Freddie Mac Structured Agency Credit Risk Debt Notes, Series
     2017-DNA3

-- Freddie Mac STACR Trust 2019-DNA1

The rating actions were taken in relation to the Request for
Comment on the proposed "Appendix 8: Expected Mortgage Insurance
Payments" to the "RMBS Insight 1.3: U.S. Residential
Mortgage-Backed Securities Model and Rating Methodology" on
November 22, 2019. In conjunction with the proposed expected
mortgage insurance payment appendix, DBRS Morningstar also
implements a minimum asset correlation in its RMBS Insight model
with respect to pools with very high loan counts.

In the RMBS Insight model, DBRS Morningstar's approach to rating
categories includes two components: one based on identifiable risks
and the other based on unidentifiable risks. Unidentifiable risk
refers to causes of variation that are not captured by the
independent variables in the model. For unidentifiable risks, the
variation is quantified by estimating an asset correlation.

The asset correlation model is a parametric function of geographic
concentration, loan size concentration, and credit quality. Asset
correlation increases with concentration and decreases with credit
quality. As a corollary, correlation decreases with loan size
concentration but remains positive because of broader economic
correlations at the regional and national levels. In pools with
very high loan counts, the loan diversity benefits can result in
low correlation calculations and gaps between any rating categories
can be compressed and potentially subject to rating volatility.

To mitigate this risk while maintaining appropriate rating
scalability for pools of different credit quality, DBRS Morningstar
implements minimum asset correlations in its RMBS Insight to
effectively capture pool risks. This represents a change from DBRS
Morningstar's previous approach of enforcing minimum spacing
between each rating category for pools with very high loan counts.

The implementation of minimum asset correlations is deemed to be a
material change to the existing "RMBS Insight 1.3: U.S. Residential
Mortgage-Backed Securities Model and Rating Methodology," the
impact of which is expected to be more significant for seasoned GSE
CRT transactions with strong credit attributes and collateral
performance.

A preliminary analysis indicated that the potential rating actions
on DBRS Morningstar-rated GSE CRT transactions are expected to be
confirmations or upgrades.

Notes: For more information related to these rating actions, please
refer to the following press release:

"DBRS Morningstar Requests Comments on Proposed Mortgage Insurance
Appendices to RMBS Insight 1.3: U.S. RMBS Model and Rating
Methodology and Operational Risk Assessment for U.S. RMBS
Originators"

The principal methodologies are U.S. RMBS Surveillance Methodology
and RMBS Insight 1.3: U.S. Residential Mortgage-Backed Securities
Model and Rating Methodology, which can be found on dbrs.com under
Methodologies & Criteria.

The rated entity or its related entities did not participate in the
rating process for this rating action. DBRS Morningstar did not
have access to the accounts and other relevant internal documents
of the rated entity or its related entities in connection with this
rating action.

The affected rating is available at https://bit.ly/2KSPqZO


[*] S&P Takes Various Actions on 61 Classes From 10 U.S. CLO Deals
------------------------------------------------------------------
S&P Global Ratings took various rating actions on 61 classes of
notes from 10 U.S. cash flow CLO transactions, resulting in eight
upgrades, seven downgrades, and 46 affirmations.

After publishing its updated global corporate CLO criteria, "Global
Methodology And Assumptions For CLOs And Corporate CDOs" on June
21, 2019, S&P placed certain ratings that could be affected under
criteria observation (UCO).

Following its review, S&P's ratings on these classes are no longer
under criteria observation and the UCO identifiers were removed.

The rating actions follow the application of S&P's global corporate
CLO criteria and its credit and cash flow analysis of each
transaction, based on their respective trustee reports. While S&P's
analysis of the transactions entailed a review of their
performance, in many cases the rating agency's rating decisions
also resulted from the application of its new criteria.

The majority of the transactions are in their amortization periods
and the senior note balances have declined as they received
paydowns. The notes' lower balances typically increased the
overcollateralization (O/C) levels, which is one of the primary
reasons for the upgrades.

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

-- Risk of imminent default;

-- Ability to withstand a steady state scenario or require a
favorable state scenario;

-- Exposure to assets in the 'CCC' rating category;

-- Existing subordination or O/C levels and recent trends;

-- Cushion available for coverage ratios and comparative analysis
with other CLO tranches with similar ratings;

-- Exposure to assets in stressed industries and/or with stressed
market values; and

-- Additional sensitivity runs to account for any of the above.

The affirmations indicate S&P's opinion that the current
enhancement available to those classes is commensurate with their
current ratings.

The downgrades are primarily due to a decline in each tranche's
credit support at the previous rating level. This decline typically
arises due to various reasons, such as par losses, deterioration of
the assets' credit quality, or pay-off of higher rated assets that
increase the transaction's exposure to lower quality assets,
haircuts to the O/C tests, or a combination of such factors. The
ratings lowered to or within the 'CCC (sf)' category reflect S&P's
view that the credit enhancement has deteriorated such that the
classes are vulnerable to and dependent on favorable market
conditions.

In line with its criteria, S&P's cash flow scenarios applied
forward-looking assumptions on the expected timing and pattern of
defaults, and recoveries upon default, under various interest rate
and macroeconomic scenarios. In addition, the rating agency's
analysis considered the transactions' ability to pay timely
interest and/or ultimate principal to each of the rated tranches.
The results of the cash flow analysis and other qualitative
factors, as applicable, demonstrated, in S&P's view, that all of
the rated outstanding classes have adequate credit enhancement
available at the rating levels associated with these rating
actions.

S&P will continue to review whether the ratings assigned to the
notes remain consistent with the credit enhancement available to
support them and take rating actions as it deems necessary.

A list on the Affected Ratings can be viewed at:

          https://bit.ly/2Yvz7rr


                            *********

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