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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, January 31, 2021, Vol. 25, No. 30

                            Headlines

BANK 2021-BNK31: Fitch to Rate $8MM Class G Certificates 'B-'
CIRRUS FUNDING 2018-1: Moody's Rates $36M Class E Notes 'Ba2(sf)'
CITIGROUP COMMERCIAL 2016-C1: Fitch Affirms B- Rating on F Certs
COMM 2014-LC17: Fitch Affirms CC Rating on 2 Tranches
CSMC TRUST 2021-RPL2: Fitch to Rate Class C-2 Notes 'B(EXP)'

EATON VANCE 2013-1: Moody's Gives (P)Ba3 Rating to Cl. D-RRR Notes
GCT COMMERCIAL 2021-GCT: Moody's Gives (P)Ba3 to Class E Certs
JP MORGAN 2013-C15: Fitch Affirms B Rating on Class F Certs
LB-UBS COMMERCIAL 2007-C6: Fitch Affirms D Ratings on 8 Classes
MELLO WAREHOUSE 2021-1: Moody's Gives (P)B2 Rating to 2 Tranches

MILL CITY 2021-NMR1: Fitch to Rate 3 Note Classes 'B-'
OCTAGON INVESTMENT 49: S&P Assigns BB-(sf) Rating to Class E Notes
PALMER SQUARE 2018-2: Fitch Hikes Rating on Class E Debt to BB+
SLM FFELP: S&P Affirms 'B (sf)' Ratings on 26 Classes of Notes
WELLS FARGO 2018-C44: Fitch Affirms B- Rating on Cl. G-RR Certs

WELLS FARGO 2019-C49: Fitch Downgrades Class H-RR Certs to 'CCC'
WILLIS ENGINE V: Fitch Affirms BB Rating on Series C Notes

                            *********

BANK 2021-BNK31: Fitch to Rate $8MM Class G Certificates 'B-'
-------------------------------------------------------------
Fitch Ratings has issued a presale report on BANK 2021-BNK31,
commercial mortgage pass-through certificates, Series 2021-BNK31.

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

-- $24,155,000 Class A-1 'AAAsf'; Outlook Stable;

-- $27,859,000 Class A-SB 'AAAsf'; Outlook Stable;

-- $135,000,000ab Class A-3 'AAAsf'; Outlook Stable;

-- $0b Class A-3-1 'AAAsf'; Outlook Stable;

-- $0b Class A-3-2 'AAAsf'; Outlook Stable;

-- $0bc Class A-3-X1 'AAAsf'; Outlook Stable;

-- $0bc Class A-3-X2 'AAAsf'; Outlook Stable;

-- $414,934,000ab Class A-4 'AAAsf'; Outlook Stable;

-- $0b Class A-4-1 'AAAsf'; Outlook Stable;

-- $0b Class A-4-2 'AAAsf'; Outlook Stable;

-- $0bc Class A-4-X1 'AAAsf'; Outlook Stable;

-- $0bc Class A-4-X2 'AAAsf'; Outlook Stable;

-- $601,948,000c Class X-A 'AAAsf'; Outlook Stable;

-- $166,611,000c Class X-B 'A-sf'; Outlook Stable;

-- $94,592,000b Class A-S 'AAAsf'; Outlook Stable;

-- $0b Class A-S-1 'AAAsf'; Outlook Stable;

-- $0b Class A-S-2 'AAAsf'; Outlook Stable;

-- $0bc Class A-S-X1 'AAAsf'; Outlook Stable;

-- $0bc Class A-S-X2 'AAAsf'; Outlook Stable;

-- $37,622,000 Class B 'AA-sf'; Outlook Stable;

-- $0b Class B-1 'AA-sf'; Outlook Stable;

-- $0b Class B-2 'AA-sf'; Outlook Stable;

-- $0bc Class B-X1 'AA-sf'; Outlook Stable;

-- $0bc Class B-X2 'AA-sf'; Outlook Stable;

-- $34,397,000 Class C 'A-sf'; Outlook Stable;

-- $0b Class C-1 'A-sf'; Outlook Stable;

-- $0b Class C-2 'A-sf'; Outlook Stable;

-- $0bc Class C-X1 'A-sf'; Outlook Stable;

-- $0bc Class C-X2 'A-sf'; Outlook Stable;

-- $37,622,000cd Class X-D 'BBB-sf'; Outlook Stable;

-- $17,199,000cd Class X-F 'BB-sf'; Outlook Stable;

-- $8,599,000cd Class X-G 'B-sf'; Outlook Stable;

-- $21,499,000d Class D 'BBBsf'; Outlook Stable;

-- $16,123,000d Class E 'BBB-sf'; Outlook Stable;

-- $17,199,000d Class F 'BB-sf'; Outlook Stable;

-- $8,599,000d Class G 'B-sf'; Outlook Stable;

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

-- $27,948,084cd Class X-H;

-- $27,948,084d Class H;

-- $45,259,320e RR Interest.

(a) The initial certificate balances of class A-3 and A-4 are
unknown and expected to be $549,934,000 in the aggregate, subject
to a 5.0% variance. The certificate balances will be determined
based on the final pricing of those classes of certificates. The
expected class A-3 balance range is $0 to $270,000,000, and the
expected class A-4 balance range is $279,934,000 to $549,934,000.
Fitch's certificate balances for classes A-3 and A-4 are assumed at
the midpoint for each class.

(b) Exchangeable Certificates. The Class A-3, Class A-4, Class A-S,
Class B and Class C are exchangeable certificates. Each class of
exchangeable certificates may be exchanged for the corresponding
classes of exchangeable certificates, and vice versa. The dollar
denomination of each of the received classes of certificates must
be equal to the dollar denomination of each of the surrendered
classes of certificates. The Class A-3 may be surrendered (or
received) for the received (or surrendered) Classes A-3-1, A-3-2,
A-3-X1 and A-3-X2. The Class A-4 may be surrendered (or received)
for the received (or surrendered) Class A-4-1, A-4-2, A-4-X1 and
A-4-X2. The Class A-S may be surrendered (or received) for the
received (or surrendered) Class A-S-1, A-S-2, A-S-X1 and A-S-X2.
The Class B may be surrendered (or received) for the received (or
surrendered) Class B-1, B-2, B-X1 and B-X2. The Class C may be
surrendered (or received) for the received (or surrendered) Class
C-1, C-2, C-X1 and C-X2. The ratings of the exchangeable classes
would reference the ratings on the associated referenced or
original classes.

(c) Notional amount and IO

(d) Privately-placed and pursuant to Rule 144a

(e) Non-offered vertical credit risk retention interest

TRANSACTION SUMMARY

The expected ratings are based on information provided by the
issuer as of Jan. 22, 2021.

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 61 loans secured by 126
commercial properties having an aggregate principal balance of
$905,186,404 as of the cutoff date. The loans were contributed to
the trust by Wells Fargo Bank, National Association, Morgan Stanley
Mortgage Capital Holdings LLC, Bank of America, National
Association and National Cooperative Bank, N.A.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 35.3% of the properties
by balance, cash flow analyses of 89.1% of the pool and asset
summary reviews on 100% of the pool.

Coronavirus Impact: The ongoing containment effort related to the
coronavirus (which causes COVID-19) pandemic may have an adverse
impact on near-term revenue (i.e., bad debt expense, rent relief)
and operating expenses (i.e., sanitation costs) for some properties
in the pool. Delinquencies may occur in the coming months as
forbearance programs are put in place, although the ultimate impact
on credit losses will depend heavily on the severity and duration
of the negative economic impact of the coronavirus pandemic, and to
what degree fiscal interventions by the U.S. federal government can
mitigate the impact on consumers. Per the offering documents, all
of the loans are current and are not subject to any forbearance
requests.

KEY RATING DRIVERS

Better Than Average Fitch Leverage: Overall, the pool's Fitch debt
service coverage ratio (DSCR) of 1.53x is higher than the 2020 and
2019 averages of 1.32x and 1.26x, respectively. The pool's Fitch
LTV of 98.5% is below the 2020 and 2019 averages of 99.6% and
103.0%, respectively. Excluding the cooperative loans, the pool's
Fitch DSCR and LTV are 1.33x and 102.3%, respectively.

Investment Grade Credit Opinion Loans and Co-op Loans: Two loans
representing 12.7% of the pool by balance have credit
characteristics consistent with investment-grade obligations on a
stand-alone basis. 605 Third Avenue (8.8% of the pool) received a
stand-alone credit opinion of 'BBB-sf' and McDonald's Global HQ
(3.8% of the pool) received a stand-alone credit opinion of 'Asf'.
Additionally, the pool contains 17 loans, representing 6.6% of the
pool, that are secured by residential cooperatives and exhibit
leverage characteristics significantly lower than typical conduit
loans. The weighted average (WA) Fitch DSCR and LTV for the co-op
loans are 4.27 and 43.8%, respectively.

Below-Average Mortgage Coupons: The pool's weighted average (WA)
mortgage rate is 3.21%, which is well below historical levels. The
WA mortgage rate is below the 2020 average mortgage rate of 3.62%
and well below the 2019 average of 4.27%. Fitch accounted for
increased refinance risk in a higher interest rate environment by
incorporating an interest rate sensitivity that assumes an interest
rate floor of 5% for the term risk of most property types, 4.5% for
multifamily properties and 6.0% for hotel properties, in
conjunction with Fitch's stressed refinance constants, which were
9.76% on a WA basis.

RATING SENSITIVITIES

This section provides insight into the sensitivity of ratings when
one assumption is modified, while holding others equal. For U.S.
CMBS, the sensitivity reflects the impact of changes to property
net cash flow (NCF) in up- and down-environments. The results below
should only be considered as one potential outcome, as the
transaction is exposed to multiple dynamic risk factors. It should
not be used as an indicator of possible future performance.

Factors that Could, Individually or Collectively, Lead to a
Negative Rating Action/Downgrade:

-- Declining cash flow decreases property value and capacity to
    meet its debt service obligations. The table below indicates
    the model implied rating sensitivity to changes in one
    variable, Fitch NCF:

-- Original Rating: AAAsf/AA-sf/A-sf/BBBsf/BBB-sf/BB-sf/B-sf;

-- 10% NCF Decline: A+sf/BBB+sf/BBB-sf/BB+sf/Bsf/CCCsf/CCCsf;

-- 20% NCF Decline: BBB+sf/BBB-sf/BB-sf/CCCsf/CCCsf/CCCsf/CCCsf;

-- 30% NCF Decline: BBB-sf/BBsf/CCCsf/CCCsf/CCCsf/CCCsf/CCCsf.

Factors that Could, Individually or Collectively, Lead to a
Positive Rating Action/Upgrade:

-- Improvement in cash flow increases property value and capacity
    to meet its debt service obligations. The table below
    indicates the model implied rating sensitivity to changes to
    the same one variable, Fitch NCF:

-- Original Rating: AAAsf/AA-sf/A-sf/BBBsf/BBB-sf/BB-sf/B-sf;

-- 20% NCF Increase: AAAsf/AAAsf/AA+sf/A+sf/A-sf/BBBsf/BBB-sf.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Deloitte & Touche LLP. The third-party due diligence
described in Form 15E focused on a comparison and re-computation of
certain characteristics with respect to each of the mortgage loans.
Fitch considered this information in its analysis and it did not
have an effect on Fitch's analysis or conclusions.

ESG CONSIDERATIONS

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


CIRRUS FUNDING 2018-1: Moody's Rates $36M Class E Notes 'Ba2(sf)'
-----------------------------------------------------------------
Moody's Investors Service has assigned ratings to four classes of
CDO refinancing notes (the "Refinancing Notes") issued by Cirrus
Funding 2018-1, Ltd. (the "Issuer").

Moody's rating action is as follows:

US$78,000,000 Class B-R Senior Secured Fixed Rate Notes due 2037
(the "Class B-R Notes"), Assigned Aa1 (sf)

US$30,000,000 Class C-R Mezzanine Secured Deferrable Fixed Rate
Notes due 2037 (the "Class C-R Notes"), Assigned A1 (sf)

US$29,000,000 Class D-R Mezzanine Secured Deferrable Fixed Rate
Notes due 2037 (the "Class D-R Notes"), Assigned Baa1 (sf)

US$36,000,000 Class E Junior Secured Deferrable Fixed Rate Notes
due 2037 (the "Class E Notes"), Assigned Ba2 (sf)

RATINGS RATIONALE

The rationale for the ratings is based on our methodology and
considers all relevant risks particularly those associated with the
CDO's portfolio and structure.

The Issuer is a managed cash flow collateralized debt obligation
(CDO). The issued notes are collateralized primarily by a portfolio
of corporate bonds and loans. At least 30% of the portfolio must
consist of senior secured loans, senior secured notes, and eligible
investments, up to 70% of the portfolio may consist of second lien
loans, unsecured loans, bonds, subordinated bonds, and unsecured
bonds, and up to 5% of the portfolio may consist of letters of
credit.

Blackstone Liquid Credit Strategies LLC ((f/k/a GSO / Blackstone
Debt Funds Management LLC) (the "Manager") will continue to direct
the selection, acquisition and disposition of the assets on behalf
of the Issuer and may engage in trading activity, including
discretionary trading, during the transaction's three year
reinvestment period. Thereafter, subject to certain restrictions,
the Manager may reinvest unscheduled principal payments and
proceeds from sales of credit risk assets.

The Issuer has issued the Refinancing Notes on January 25, 2021
(the "Refinancing Date") in connection with the refinancing of
three classes of the secured notes (the "Refinanced Original
Notes") originally issued on November 28, 2018 (the "Original
Closing Date"). On the Refinancing Date, the Issuer used proceeds
from the issuance of the Refinancing Notes to redeem in full the
Refinanced Original Notes. On the Original Closing Date, the Issuer
also issued the Class A Notes and one class of subordinated notes
that remain outstanding.

In addition to the issuance of the Refinancing Notes, a variety of
other changes to transaction features will occur in connection with
the refinancing. These include extension of the non-call period for
the Refinancing Notes; additions to further the CLO's ability to
hold workout and restructured assets; and changes to the definition
of "Adjusted Weighted Average Moody's Rating Factor".

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 December 2020.

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: $597,327,785

Defaulted par: $1,191,531

Diversity Score: 69

Weighted Average Rating Factor (WARF): 3161

Weighted Average Coupon (WAC): 4.55%

Weighted Average Recovery Rate (WARR): 42.34%

Weighted Average Life (WAL): 9 years

In consideration of the current high uncertainties around the
global economy, and the ultimate performance of the CLO portfolio,
Moody's conducted a number of additional sensitivity analyses
representing a range of outcomes that could diverge, both to the
downside and the upside, from Moody's base case. Some of the
additional scenarios that Moody's considered in its analysis of the
transaction include, among others: additional near-term defaults of
companies facing liquidity pressure; and a lower recovery rate
assumption on defaulted assets to reflect declining loan recovery
rate expectations.

The coronavirus outbreak, the government measures put in place to
contain it, and the weak global economic outlook continue to
disrupt economies and credit markets across sectors and regions.
Moody's analysis has considered the effect on the performance of
corporate assets from the current weak U.S. economic activity and a
gradual recovery for the coming months. Although an economic
recovery is underway, it is tenuous and its continuation will be
closely tied to containment of the virus. As a result, the degree
of uncertainty around Moody's forecasts is unusually high. Moody's
regards the coronavirus outbreak as a social risk under its ESG
framework, given the substantial implications for public health and
safety.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2020.

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

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


CITIGROUP COMMERCIAL 2016-C1: Fitch Affirms B- Rating on F Certs
----------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of Citigroup Commercial
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
series 2016-C1 (CGCMT 2016-C1).

    DEBT                RATING              PRIOR
    ----                ------              -----
CGCMT 2016-C1

A-1 17290YAN8      LT  AAAsf  Affirmed      AAAsf
A-2 17290YAP3      LT  AAAsf  Affirmed      AAAsf
A-3 17290YAQ1      LT  AAAsf  Affirmed      AAAsf
A-4 17290YAR9      LT  AAAsf  Affirmed      AAAsf
A-AB 17290YAS7     LT  AAAsf  Affirmed      AAAsf
A-S 17290YAT5      LT  AAAsf  Affirmed      AAAsf
B 17290YAU2        LT  AA-sf  Affirmed      AA-sf
C 17290YAV0        LT  A-sf   Affirmed      A-sf
D 17290YAA6        LT  BBB-sf Affirmed      BBB-sf
E 17290YAC2        LT  BB-sf  Affirmed      BB-sf
EC 17290YAY4       LT  A-sf   Affirmed      A-sf
F 17290YAE8        LT  B-sf   Affirmed      B-sf
X-A 17290YAW8      LT  AAAsf  Affirmed      AAAsf
X-B 17290YAX6      LT  AA-sf  Affirmed      AA-sf

KEY RATING DRIVERS

Increased Loss Expectations: While the majority of the pool has
exhibited relatively stable performance since Fitch's prior rating
action, loss expectations have increased due to the slowdown in
economic activity related to the coronavirus pandemic and
performance concerns on the 15 Fitch Loans of Concern (FLOCs; 29.2%
of pool), including two specially serviced loans (9.3%). Fitch's
current ratings incorporate a base case loss of 5.25%. The Negative
Rating Outlooks on classes E and F factor in additional stresses
related to the coronavirus pandemic, which reflect losses could
reach 6.30%.

The largest contributor to loss, and the largest change in loss
since the prior rating action, is The Strip loan (13.1%), which is
secured by a 786,928-sf anchored retail center located in North
Canton, OH. Leases totaling 73.6% of the NRA expire by loan
maturity, including 39.6% within the next 12 months, the majority
of which is concentrated in the two largest tenants, Walmart (19.0%
of NRA; through October 2021) and Lowes (16.6%; September 2021).
Other major tenants include Giant Eagle (11.5%; January 2022) and a
15-screen Cinemark Theatre (8.4%; December 2025). Tenants occupying
spaces larger than 10,000-sf comprise 90.5% of the NRA.

Property occupancy increased to 99.0% as of the September 2020 rent
roll from 94.0% at YE 2019 after Bob's Discount Furniture signed a
10-year lease for 5.4% of NRA in July 2020. As of January 2021, the
loan had replacement reserves totaling $2.2 million and tenant
reserves totaling $243,141. The servicer-reported NOI debt service
coverage ratio (DSCR) was 1.37x as of YE 2019.

The next largest change in loss since the prior rating action, is
the 46 Geary Street (1.8%) loan, which is secured by an 18,002-sf
mixed-use property located in downtown San Francisco, CA. Physical
occupancy fell to 72.9% from 100% after TapFWD Inc. (27.1% of NRA)
went dark in 2020, ahead of their January 2021 lease expiration.

The second largest tenant, Propeller Health (22.6%), also has a
lease expiration at the end of January 2021. Per the servicer, the
space is fully subleased to Haus Services. Fitch's inquiry
regarding whether Haus Services plans to directly lease the space
after Propeller Health's lease expiration remains outstanding. The
loan has been cash managed since 2016. The servicer-reported NOI
DSCR was 1.63x as of YE 2019.

The largest FLOC, the specially serviced Hyatt Regency Huntington
Beach Resort & Spa (7.4%), is secured by a 517-key full-service
hotel located in Huntington Beach, CA. The loan transferred to
special servicing in July 2020 after the borrower requested
coronavirus relief. The hotel closed in March 2020 but has since
reopened. Occupancy, ADR and RevPAR fell to 55.1%, $279 and $154,
respectively, as of the TTM August 2020 STR report from 77.5%, $298
and $231 as of YE 2019. RevPAR penetration remains strong at 139.2%
as of TTM August 2020 compared to 133% at issuance.

A loan modification closed in November 2020; terms included three
months of principal and interest deferment between July 2020 and
September 2020, a six-month interest-only period between October
2020 and March 2021, a deferral of monthly FF&E reserve payments
between March 2020 and March 2021 and allowing the borrower use of
existing FF&E reserves to pay for FF&E, operating expenses and/or
debt service, with repayment of deferred funds to occur within 30
months of April 2021.

Non-room revenue accounted for approximately 52% to 53% of total
revenue historically, primarily from food and beverage income. The
servicer-reported NOI DSCR was 2.80x as of YE 2019. The loan began
amortizing in June 2020.

The second largest FLOC, the Marriott Savannah Riverfront loan
(5.0%), is secured by a 387-key full-service hotel located in
downtown Savannah, GA. Occupancy, ADR and RevPAR fell to 52.3%,
$168 and $88, respectively, as of the TTM September 2020 STR report
from 80.0%, $176 and $141 as of YE 2019 due to performance decline
caused by the ongoing pandemic. RevPAR penetration was 139.2% as of
TTM August 2020, compared to 136% as of TTM November 2019 and 133%
at issuance.

New supply in the market includes the 120-key Courtyard by Marriott
Savannah Airport that opened in September 2018 and the 419-key JW
Marriott Hotel that opened in July 2020 as part of Richard
Kessler's 670,000-sf Plant Riverside District waterfront mixed-use
development. As of January 2021, the loan had a FF&E reserves
balance of $400,885 and seasonality reserve balance of $89,902. The
servicer-reported NOI DSCR was 2.55x as of YE 2019.

Minimal Changes in Credit Enhancement (CE): As of the January 2021
distribution date, the pool's aggregate principal balance has been
paid down by 4.7% to $720.3 million from $755.7 million at issuance
and 1.3% since Fitch's prior rating action. The pool is scheduled
to amortize by 13.3% of the initial pool balance prior to
maturity.

One loan (1.7%) is fully defeased. Six loans (17.4%) are full-term
interest-only and three loans (5.3%) remain in
partial-interest-only periods (compared with 20 loans (39.5%) at
issuance). Loan maturities are concentrated in 2026 (94.7%), with
1.8% in 2021 and 3.5% in 2025. The non-rated class H has been
impacted by $58,037 in cumulative interest shortfalls to date.

Coronavirus Exposure: Six loans (19.6%) are secured by hotel
properties. The weighted average (WA) NOI DSCR for the hotel loans
is 2.15x; these hotel loans could sustain a decline in NOI of 70.2%
before NOI DSCR falls below 1.0x. Twenty-two loans (34.8%) are
secured by retail properties. The WA NOI DSCR for the retail loans
is 1.47x; these retail loans could sustain a decline in NOI of
28.8% before DSCR falls below 1.0x. Eight loans (10.1%) are secured
by multifamily properties, including one student housing property
(2.7%). The WA NOI DSCR for the multifamily loans is 1.81x; these
multifamily loans could sustain a decline in NOI of 40.4% before
DSCR falls below 1.0x.

Fitch applied additional stresses to four hotel loans, 12 retail
loans and one student housing loan to account for potential cash
flow disruptions due to the coronavirus pandemic; this analysis
contributed to maintaining the Negative Rating Outlooks on classes
E and F.

Pool Concentrations: Retail is the largest property type
concentration at 34.8%, followed by hotel at 19.6%, office at 12.3%
and self-storage at 11.1%. The retail composition in the pool
consists of unanchored and anchored shopping centers; there are no
regional malls or outlet centers in the pool. The largest 10 and 15
loans represent 55.1% and 65.3% of the pool by balance,
respectively.

RATING SENSITIVITIES

The Negative Rating Outlooks on classes E and F reflect the
potential for downgrade due to concerns surrounding the ultimate
impact of the coronavirus pandemic and the performance concerns
associated with the FLOCs. The Stable Rating Outlooks on classes
A-1 through D reflect the increasing CE, continued expected
amortization and relatively stable performance of the majority of
the pool.

Factors that could, individually or collectively, lead to a
positive rating action/upgrade:

Sensitivity factors that lead to upgrades would include:

-- Stable to improved asset performance coupled with pay down
    and/or defeasance.

-- Upgrades of the 'Asf' and 'AAsf' categories would likely occur
    with significant improvement in CE and/or defeasance; however,
    adverse selection, increased concentrations and further
    underperformance of the FLOCs or loans expected to be
    negatively affected by the coronavirus pandemic could cause
    this trend to reverse.

-- Upgrades to the 'BBBsf' category would be limited based on
    sensitivity to concentrations or the potential for future
    concentration. Classes would not be upgraded above 'Asf' if
    there is likelihood for interest shortfalls.

-- Upgrades to the 'Bsf' and 'BBsf' categories are not likely
    until the later years in a transaction and only if the
    performance of the remaining pool is stable and/or properties
    vulnerable to the coronavirus return to pre-pandemic levels,
    and there is sufficient CE to the classes.

Factors that could, individually or collectively, lead to a
negative rating action/downgrade:

Sensitivity factors that lead to downgrades include:

-- An increase in pool level losses from underperforming or
    specially serviced loans.

-- Downgrades to the 'AAsf' and 'AAAsf' categories are not likely
    due to the position in the capital structure, but may occur
    should interest shortfalls impact the classes.

-- Downgrades to the 'BBBsf' and Asf' category would occur should
    overall pool losses increase significantly and/or one or more
    large loans have an outsized loss, which would erode CE.

-- Downgrades to the 'Bsf' and 'BBsf' categories would occur
    should loss expectations increase and if performance of the
    FLOCs or loans vulnerable to the coronavirus pandemic fail to
    stabilize or additional loans default and/or transfer to the
    special servicer.

In addition to its baseline scenario related to the coronavirus,
Fitch also envisions a downside scenario where the health crisis is
prolonged beyond 2021; should this scenario play out, Fitch expects
negative rating actions, including downgrades and/or further
Negative Rating Outlook revisions.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

ESG CONSIDERATIONS

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


COMM 2014-LC17: Fitch Affirms CC Rating on 2 Tranches
-----------------------------------------------------
Fitch Ratings has affirmed 17 classes of Deutsche Bank Securities,
Inc.'s COMM 2014-LC17 Mortgage Trust.

     DEBT                RATING           PRIOR
     ----                ------           -----
COMM 2014-LC17

A-2 12592MBF6     LT  AAAsf  Affirmed     AAAsf
A-3 12592MBH2     LT  AAAsf  Affirmed     AAAsf
A-4 12592MBJ8     LT  AAAsf  Affirmed     AAAsf
A-5 12592MBK5     LT  AAAsf  Affirmed     AAAsf
A-M 12592MBM1     LT  AAAsf  Affirmed     AAAsf
A-SB 12592MBG4    LT  AAAsf  Affirmed     AAAsf
B 12592MBN9       LT  AAsf   Affirmed     AAsf
C 12592MBQ2       LT  Asf    Affirmed     Asf
D 12592MAN0       LT  BBsf   Affirmed     BBsf
E 12592MAQ3       LT  CCCsf  Affirmed     CCCsf
F 12592MAS9       LT  CCsf   Affirmed     CCsf
PEZ 12592MBP4     LT  Asf    Affirmed     Asf
X-A 12592MBL3     LT  AAAsf  Affirmed     AAAsf
X-B 12592MAA8     LT  AAsf   Affirmed     AAsf
X-C 12592MAC4     LT  BBsf   Affirmed     BBsf
X-D 12592MAE0     LT  CCCsf  Affirmed     CCCsf
X-E 12592MAG5     LT  CCsf   Affirmed     CCsf

KEY RATING DRIVERS

Increased Loss Expectations: Loss expectations have increased due
to an increase in the number of Fitch Loans of Concern (FLOCs) and
specially serviced loans. Fitch's ratings assume a base case loss
is 6.50%. The Negative Outlooks reflect additional sensitivities
which reflect losses that could reach 8.2%. These additional
sensitivities include additional stresses applied to loans expected
to be impacted by the coronavirus pandemic.

Twelve loans (15.0% of pool), including five loans (5.3%) in
special servicing, were designated FLOCs. As of the January 2021
distribution period, there were 11 loans (28.6%) on the servicer's
watchlist for high vacancy, low DSCR, coronavirus relief requests,
fire damage and rolling tenants.

Specially Serviced Loans:

World Houston Plaza (1.8%) is an eight-story office building
located approximately 20 miles north of the Houston CBD. The loan
transferred to the special servicer in June 2017 for imminent
default. Weatherford U.S. was previously the largest tenant,
occupying 50.5% of the NRA on a lease that expired in May 2017, and
occupancy has fallen to 27% as of September 2020. The asset became
REO in January 2018. Per the special sevicer, the building is
listed for auction occurring in February 2021. Fitch expects
significant losses.

Paradise Valley (1.5%) is secured by a shopping center located in
Phoenix, AZ. This loan transferred to special servicing in August
2020 for imminent monetary default due to the largest tenant,
RoomStore of Phoenix (NRA 35.3%), and a number of smaller tenants
vacating the subject. June 2020 occupancy fell to 53% from 65% at
YE 2018 and underwritten occupancy of 95%. The loan has been
classified as 90+ Days delinquent since the November 2020 payment
date. As of January 2021, the resolution strategy was to pursue a
non-judicial foreclosure, and the lender was coordinating with the
borrower's legal counsel to complete the foreclosure process.

Georgia Multifamily Portfolio (1.1%) is a portfolio of five class C
multifamily properties in the Atlanta area (four in the south
Atlanta suburbs and one in a west Atlanta suburb). This loan
transferred to special servicing in December 2015 for imminent
default as the borrower reportedly refused or failed to provide
sufficient capital to operate, maintain and repair the properties.
A payment change modification was executed in April 2018. The
borrower failed to maintain the terms of the
Modification/Settlement agreement and the loan remains in special
servicing and is categorized as 90+ days delinquent. As of January
2021, the lender is dual tracking resolutions, and negotiations
continue with the borrower.

There are two loans that have transferred to special servicing that
individually account for less than 1.0% of aggregate principal
balance. Peru Retail Center (.6%) is an anchored, neighborhood
center located in Peru, IL., and transferred to special servicing
in December 2018 due to imminent monetary default resulting from
several large tenant departures. RSRT Properties (.3%) is a
portfolio comprised of two traditional multifamily properties
located in North Dakota, and transferred to special servicing in
November 2020 for imminent monetary default as a result of low
occupancy.

Increased Credit Enhancement (CE) to Senior Classes: As of the
January 2021 distribution date, the pool's aggregate principal
balance has paid down by 27.1% to $900.3 million from $1.235
billion at issuance. Two loans totaling $27.4 million have paid off
since Fitch's rating action in January 2020, including two FLOCs:
1401/1405/1621 Holdings and Smithfield Holdings which both prepaid
in July 2020. There are nine loans (8.3% of current pool) that are
fully defeased, including one loan in the top 15 (2.3%). Of the
remaining pool balance, 22.8% of the pool is classified as full IO
through the term of the loan.

Exposure to Coronavirus: There are three loans (22.4% of pool),
which have a weighted average (WA) NOI DSCR of 3.06x, and are
secured by hotel properties. Seventeen loans (25.4%), which have a
WA NOI DSCR of 1.84x, are secured by retail properties. Seven loans
(6.6%), which have a WA NOI DSCR of 1.44x, are secured by
multifamily properties. Fitch's base case analysis applied
additional stresses to two hotel loans, 10 retail loans and one
multifamily loan given the significant declines in property-level
cash flow expected in the short term as a result of the decrease in
consumer spending and property closures from the coronavirus
pandemic.

Alternative Loss Scenario: A sensitivity scenario was applied to
test the stability of the ratings and Outlooks. In this stress
scenario, Fitch applied 100 bps to the stressed cap rates as well
as a total 10% NOI haircut to all of the base case cap rates and
NOI stresses in the pool. This scenario also assumed a 30% loss
severity on the FLOC 50 Crosby Drive. In addition, the defeased
loans were assumed to pay in full. The Negative Rating Outlook on
class D partially reflects this sensitivity scenario as well as
ongoing concerns with the ultimate impact of the pandemic on
long-term performance.

FLOCs:

50 Crosby Drive (3.6%) is a four-story, office building located in
Bedford, MA. According to the master servicer Oracle (NRA 100%)
exercised its early termination option and vacated the subject in
March 2020. This loan transferred to special servicing in February
2020 for imminent monetary default, and then was returned to the
master servicer in December 2020 following the execution of a
forbearance. According to the master servicer, as of January 2021
the subject remains vacant. Fitch's 30% loss assumption in the
sensitivity scenario reflects a dark value assumption if the
property remains vacant.

Triangle Plaza (1.6%) is a retail center located in Raleigh, NC.
The center's anchor, Gander Mountain (53.4% NRA). has vacated in
October of 2017. Aldi (NRA 25.8%) has leased approximately half of
the former Gander Mountain space and opened for business in
November 2019. Spirit Halloween (NRA 27.6%) occupies the remaining
former Gander Mountain space on a seasonal lease. As of YE 2019,
NOI DSCR was .93x and occupancy was 72%. The loan may no longer be
considered a FLOC should YE financials stabilize.

1717 Route 208 North (1.6%) is a suburban office property located
Fair Lawn, NJ. Loan is on the servicer's watchlist for two upcoming
lease expirations. Paychex North America Inc. (NRA 33.2%) and Ultra
Logistics Inc. (NRA 9.8%) leases are scheduled to expire in May
2021 and January 2021, respectively. According to the most recent
servicer commentary, the master servicer has contacted the borrower
for a leasing update and is awaiting a response.

Broadmoor Towne Center (1.2%) is a community shopping center
located in Colorado Springs, CO. Subject September 2020 occupancy
fell to 53% from 88% at YE 2019 and underwritten occupancy at
issuance of 100%. This decline in occupancy is due to Specialty
Retailers (NRA 34%) vacating ahead of their lease expiration in
August 2024 following the Chapter 11 bankruptcy of their parent
company. As of the January 2021 payment date, the loan was
classified as 30 Days delinquent.

The remaining five FLOCs individually account for less than 1.00%
of total pool balance and collectively account for 2.6% of total
pool balance.

RATING SENSITIVITIES

The Stable Rating Outlooks on classes A-1 through C reflect the
overall stable performance of the majority of the pool and expected
continued amortization and increased credit enhancement. The
Negative Rating Outlook on class D reflect the potential for
downgrade due to concerns surrounding the ultimate impact of the
coronavirus pandemic and the performance concerns associated with
the FLOCs, which include five specially serviced loans.

Factors that could, individually or collectively, lead to a
positive rating action/upgrade:

Sensitivity factors that could lead to upgrades would include:

-- Stable to improved asset performance, coupled with additional
    paydown and/or defeasance.

-- Upgrades to the 'Asf' and 'AAsf' rated classes are not
    expected but would likely occur with significant improvement
    in CE and/or defeasance and/or the stabilization to the
    properties impacted from the coronavirus pandemic.

-- Upgrade of the 'BBsf' class is considered unlikely and would
    be limited based on the sensitivity to concentrations or the
    potential for future concentrations.

-- Classes would not be upgraded above 'Asf' if there is a
    likelihood of interest shortfalls.

-- An upgrade to the 'CCCsf' and 'CCsf' rated classes is not
    likely unless the performance of the remaining pool stabilizes
    and the senior classes pay off.

Factors that could, individually or collectively, lead to a
negative rating action/downgrade:

Sensitivity factors that lead to downgrades include:

-- An increase in pool-level losses from underperforming or
    specially serviced loans/assets.

-- Downgrades to classes A-1 through A-M and the IO classes X-A
    are not likely due to the position in the capital structure,
    but may occur should interest shortfalls occur.

-- Downgrades to classes B, C, X-B and X-C are possible should
    performance of the FLOCs continue to decline; should loans
    susceptible to the coronavirus pandemic not stabilize; and/or
    should further loans transfer to special servicing. Classes D
    and X-D could be downgraded should the specially serviced loan
    not return to the master servicer and/or as there is more
    certainty of loss expectations.

-- The Rating Outlooks on these classes may be revised back to
    Stable if performance of the FLOCs improves and/or properties
    vulnerable to the coronavirus stabilize once the pandemic is
    over. Downgrades classes E, F, X-D and X-E are possible as
    losses become more imminent.

In addition to its baseline scenario, Fitch also envisions a
downside scenario where the health crisis is prolonged beyond 2021;
should this scenario play out, classes with Negative Rating
Outlooks will be downgraded one or more categories.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

ESG CONSIDERATIONS

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


CSMC TRUST 2021-RPL2: Fitch to Rate Class C-2 Notes 'B(EXP)'
------------------------------------------------------------
Fitch Ratings expects to rate CSMC 2021-RPL2 Trust (CSMC
2021-RPL2)'s residential mortgage-backed notes.

DEBT             RATING           
----             ------           
CSMC 2021-RPL2

A-1     LT  AAA(EXP)sf  Expected Rating
A-1A    LT  AAA(EXP)sf  Expected Rating
A-1X    LT  AAA(EXP)sf  Expected Rating
M-1     LT  AA(EXP)sf   Expected Rating
M-2     LT  A(EXP)sf    Expected Rating
M-3     LT  BBB(EXP)sf  Expected Rating
B-1     LT  BB(EXP)sf   Expected Rating
B-2     LT  B(EXP)sf    Expected Rating
B-3     LT  NR(EXP)sf   Expected Rating
B-4     LT  NR(EXP)sf   Expected Rating
B-5     LT  NR(EXP)sf   Expected Rating
PT      LT  NR(EXP)sf   Expected Rating
A-IO-S  LT  NR(EXP)sf   Expected Rating
XS      LT  NR(EXP)sf   Expected Rating

TRANSACTION SUMMARY

Fitch expects to rate the residential mortgage-backed notes to be
issued by CSMC 2021-RPL2 Trust (CSMC 2021-RPL2) as indicated above.
The transaction is expected to close on Jan. 28, 2021. The notes
are supported by one collateral group that consists of 2,370
seasoned performing loans (SPLs) and re-performing loans (RPLs)
with a total balance of approximately $424 million.

Distributions of P&I and loss allocations are based on a
traditional senior-subordinate, sequential structure. The
sequential-pay structure locks out principal to the subordinated
notes until the most senior notes outstanding are paid in full.
Losses are allocated reverse sequentially. The servicers will not
be advancing delinquent monthly payments of P&I.

KEY RATING DRIVERS

Coronavirus Impact Addressed (Negative): Coronavirus and the
resulting containment efforts have resulted in revisions to
Fitch’s GDP estimates for 2020. Fitch’s current baseline
outlook for U.S. GDP growth is -3.5% for 2020, down from 2.2% for
2019. To account for declining macroeconomic conditions the
Economic Risk Factor (ERF) default variable for the 'Bsf' and
'BBsf' rating categories was increased from a floor of 1.0 and 1.5,
respectively to 2.0. The ERF floor of 2.0 best approximates
Fitch’s baseline GDP for 2020 and a recovery of 4.5% in 2021. If
conditions deteriorate further and recovery is longer or less than
current projections, the ERF floors may be further revised higher.

RPL/SPL Credit Quality (Positive): The collateral consists of 2,370
seasoned performing and re-performing first- and second-lien loans,
totaling $424 million, and seasoned approximately 171 months in
aggregate according to Fitch (168 months based on the collateral
tables in the transaction documents). The pool is 100% current and
0% delinquent. Fitch determined that over the last two years 74.2%
of loans have been clean current. Additionally, 76.5% of loans have
a prior modification. The borrowers have a weaker credit profile
(701 FICO and 42% DTI) and relatively low leverage (65% sustainable
Loan-to-Value (sLTV)). The pool consists of 91.1% of loans where
the borrower maintains a primary residence, while 8.9% are
investment properties or second home.

Geographic Concentration (Positive): Approximately 29.2% of the
pool is concentrated in California. The largest MSA concentration
is in the New York-Northern New Jersey-Long Island, NY-NJ-PA MSA
(14.6%), followed by the Los Angeles-Long Beach-Santa Ana, CA MSA
(11.6%) and the Miami-Fort Lauderdale-Miami Beach, FL MSA (7%). The
top three MSAs account for 33.1% of the pool. As a result, there
was no adjustment for geographic concentration.

Payment Forbearance (Neutral): As of the cut-off date, 232 loans
13.1% of the pool opted into a coronavirus relief plan. Of these,
six loans, or 0.37% of the pool are on an active coronavirus relief
plan, all are still making payments and contractually current as of
the cut-off date. The remaining 12.7% of the pool are no longer on
active coronavirus relief plans and all are contractually current
as of the cut-off date.

Fitch considers borrowers which are on the coronavirus relief plan
that are cash flowing as current, while the borrowers which are not
cash flowing were treated as delinquent. A total of 100% of the
pool is current.

Deferred Amounts (Negative): Non-interest-bearing principal
forbearance amounts totaling $21.9 million (4.7%) of the UPB is
outstanding on the loans. Fitch included the deferred amounts when
calculating the borrower's LTV and sLTV, despite the lower payment
and amounts not being owed during the term of the loan. The
inclusion resulted in a higher probability of default (PD) and loss
severity (LS) than if there were no deferrals. Fitch believes that
borrower default behavior for these loans will resemble that of the
higher LTVs, as exit strategies (i.e., sale or refinancing) will be
limited relative to those borrowers with more equity in the
property.

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

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

Well Controlled Operational Risk (Positive): Operational risk is
well controlled for in this transaction. Credit Suisse is assessed
by Fitch as an 'Average' aggregator specifically for acquiring
seasoned and distressed loans. Select Portfolio Servicing, Inc.
(SPS) is the named servicer for the transaction and is rated by
Fitch as RPS1- with an Outlook Stable. Fitch decreased its
adjustments to the 'AAAsf' rating category by 139 bps based
primarily on the strong rating for the servicer counterparty.
Issuer retention of at least 5% of the bonds also helps ensure an
alignment of interest between both the issuer and investor.

Representation and Warranty Framework (Negative): The
representation, warranty and enforcement (RW&E) framework for this
transaction generally contains all loan level representations
listed in Fitch criteria and is consistent with a Tier 2 framework.
Fitch increased its loss expectations by 125 bps at the 'AAAsf'
rating category to reflect the RW&E framework combined with the
noninvestment grade counterparty risk of the rep provider.

Third-Party Due Diligence (Negative): A third-party due diligence
review was performed on approximately 100% of the loans in the
transaction pool. The review scope included a compliance review
that tested for adherence to applicable federal, state and local
high-cost loan and/or anti-predatory laws. Due diligence was
performed by SitusAMC and Opus CMC, which are approved third-party
review (TPR) firm and is assessed by Fitch as an 'Acceptable - Tier
1' and 'Acceptable - Tier 2'.

The due diligence results indicate low compliance risk with 6.7% of
loans receiving a final grade of 'C' or 'D'. This concentration of
material exceptions is lower to other Fitch-rated RPL RMBS due to a
single aggregated purchase of the loans, adjustments were applied
only to loans missing of estimated final HUD-1 documents that are
subject to testing for compliance with predatory lending
regulations. These regulations are not subject to statute of
limitations like most compliance findings which ultimately exposes
the trust to added assignee liability risk. Fitch increased its
loss expectation at the 'AAAsf' rating category by approximately 25
bps to account for this added risk.

RATING SENSITIVITIES

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

Factors that could, individually or collectively, lead to a
negative rating action/downgrade:

-- This defined negative rating sensitivity analysis demonstrates
    how the ratings would react to steeper MVDs at the national
    level.

-- The analysis assumes MVDs of 10.0%, 20.0% and 30.0% in
    addition to the model-projected 38.8% at 'AAA'.

-- The analysis indicates that there is some potential rating
    migration with higher MVDs for all rated classes, compared
    with the model projection.

-- Specifically, a 10% additional decline in home prices would
    lower all rated classes by one full category.

Factors that could, individually or collectively, lead to a
positive rating action/upgrade:

-- This defined positive rating sensitivity analysis demonstrates
    how the ratings would react to negative MVDs at the national
    level, or in other words positive home price growth with no
    assumed overvaluation.

-- The analysis assumes positive home price growth of 10%.
    Excluding the senior class, which is already rated 'AAAsf',
    the analysis indicates there is potential positive rating
    migration for all of the rated classes.

-- Specifically, a 10% gain in home prices would result in a full
    category upgrade for the rated class excluding those being
    assigned ratings of 'AAAsf'.

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modeling process uses the modification of
these variables to reflect asset performance in up- and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Fitch has added a Coronavirus Sensitivity Analysis that includes a
prolonged health crisis resulting in depressed consumer demand and
a protracted period of below-trend economic activity that delays
any meaningful recovery to beyond 2021. Under this severe scenario,
Fitch expects the ratings to be impacted by changes in its
sustainable home price model due to updates to the model's
underlying economic data inputs. Any long-term impact arising from
coronavirus disruptions on these economic inputs will likely affect
both investment and speculative grade ratings.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

CRITERIA VARIATION

There is one variation to the U.S. RMBS Rating Criteria. The tax
and title search for one loan was performed outside of the
six-month timeframe during which Fitch looked at the criteria. This
is mitigated by the relatively small outstanding amounts at the
time the search was completed and the close proximity to the
six-month time frame during which Fitch looked at the criteria (the
one loan was outside the six-month time frame by one month). As a
result there was no rating impact.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by SitusAMC, Opus Capital Markets Consultants LLC (Opus)
and Residential Real Estate Review Management Inc.
(RRR). The third-party due diligence described in Form 15E focused
on these areas: compliance review data integrity, pay history, and
updated tax and title review. Fitch considered this information in
its analysis and, as a result, increased the overall expected loss
by 0.25% in the 'AAAsf' stress.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the pool by loan count. The third-party due
diligence was consistent with Fitch's "U.S. RMBS Rating Criteria."
SitusAMC and Opus were engaged to perform the compliance and data
integrity reviews. Loans reviewed under this engagement were given
compliance grades. Situs AMC and Residential Real Estate Review
Management Inc. (RRR) were engaged to perform tax and title reviews
on 100% of the loans. There was a custodian review on 100% of the
loans. Minimal exceptions and waivers were noted in the due
diligence reports. Refer to the Third-Party Due Diligence section
for more details.

Fitch also used data files that were made available by the issuer
on its SEC Rule 17g-5 designated website. Fitch received loan-level
information based on the American Securitization Forum's (ASF) data
layout format, and the data are considered to be comprehensive. The
ASF data tape layout was established with input from various
industry participants, including rating agencies, issuers,
originators, investors and others, to produce an industry standard
for the pool-level data in support of the U.S. RMBS securitization
market. The data contained in the ASF layout data tape were
reviewed by the due diligence companies, and no material
discrepancies were noted.

ESG CONSIDERATIONS

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


EATON VANCE 2013-1: Moody's Gives (P)Ba3 Rating to Cl. D-RRR Notes
------------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to six
classes of CLO refinancing notes (the "Refinancing Notes") to be
issued by Eaton Vance CLO 2013-1 Ltd. (the "Issuer").

Moody's rating action is as follows:

US$4,000,000 Class A-X-RRR Senior Secured Floating Rate Notes due
2034 (the "Class A-X-RRR Notes"), Assigned (P)Aaa (sf)

US$265,600,000 Class A-1-RRR Senior Secured Floating Rate Notes due
2034 (the "Class A-1-RRR Notes"), Assigned (P)Aaa (sf)

US$48,762,500 Class A-2-RRR Senior Secured Floating Rate Notes due
2034 (the "Class A-2-RRR Notes"), Assigned (P)Aa2 (sf)

US$19,712,500 Class B-RRR Senior Secured Deferrable Floating Rate
Notes due 2034 (the "Class B-RRR Notes"), Assigned (P)A2 (sf)

US$23,862,500 Class C-RRR Senior Secured Deferrable Floating Rate
Notes due 2034 (the "Class C-RRR Notes"), Assigned (P)Baa3 (sf)

US$19,920,000 Class D-RRR Secured Deferrable Floating Rate Notes
due 2034 (the "Class D-RRR Notes"), Assigned (P)Ba3 (sf)

RATINGS RATIONALE

The rationale for the ratings is based on our methodology and
considers all relevant risks particularly those associated with the
CLO's portfolio and structure.

The Issuer is a managed cash flow collateralized loan obligation
(CLO). The issued notes are collateralized primarily by a portfolio
of broadly syndicated senior secured corporate loans. At least
90.0% of the portfolio must consist of senior secured loans and
eligible investments, and up to 10.0% of the portfolio may consist
of second lien loans, unsecured loans and up to 5% may consist of
senior secured bonds.

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

The Issuer will issue the Refinancing Notes on February 10, 2021
(the "Refinancing Date") in connection with the refinancing of all
classes of the secured notes (the "Refinanced Original Notes")
previously refinanced on December 20, 2016 and August 9, 2019, and
originally issued on November 13, 2013 (the "Original Closing
Date") and will also issue additional subordinated notes. On the
Refinancing Date, the Issuer will use proceeds from the issuance of
the Refinancing Notes to redeem in full the Refinanced Original
Notes. On the Original Closing Date, the Issuer also issued one
class of subordinated notes that remains outstanding.

In addition to the issuance of the Refinancing Notes a variety of
other changes to transaction features will occur in connection with
the refinancing. These include: extension of the reinvestment
period; extensions of the stated maturity and non-call period;
changes to certain collateral quality tests; changes to the
overcollateralization test levels, the inclusion of alternative
benchmark replacement provisions; additions to the CLO's ability to
hold workout and restructured assets; changes to the definition of
"Adjusted Weighted Average Rating Factor".

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 December 2020.

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

Portfolio par including principal proceeds and recoveries:
$410,438,877

Defaulted par: $8,430,963

Diversity Score: 75

Weighted Average Rating Factor (WARF): 2915

Weighted Average Spread (WAS): 3.30%

Weighted Average Coupon (WAC): 6.00%

Weighted Average Recovery Rate (WARR): 48.16%

Weighted Average Life (WAL): 9.0 years

The coronavirus outbreak, the government measures put in place to
contain it, and the weak global economic outlook continue to
disrupt economies and credit markets across sectors and regions.
Moody's analysis has considered the effect on the performance of
corporate assets from the current weak U.S. economic activity and a
gradual recovery for the coming months. Although an economic
recovery is underway, it is tenuous and its continuation will be
closely tied to containment of the virus. As a result, the degree
of uncertainty around our forecasts is unusually high. Moody's
regards the coronavirus outbreak as a social risk under its ESG
framework, given the substantial implications for public health and
safety.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2020.

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.


GCT COMMERCIAL 2021-GCT: Moody's Gives (P)Ba3 to Class E Certs
--------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to six
classes of CMBS securities, issued by GCT Commercial Mortgage Trust
2021-GCT, Commercial Mortgage Pass-Through Certificates, Series
2021-GCT:

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

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

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

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

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

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

RATINGS RATIONALE

This securitization is collateralized by a first priority deed of
trust mortgage on the fee simple interests in (i) a 54-story, Class
A office building with grade level retail space and a 978 stall
subterranean parking garage located at 555 West 5th Street in Los
Angeles, California (the "Gas Company Tower") and (ii) a 1,166
stall parking garage located at 350 South Figueroa Street in Los
Angeles, California (the "World Trade Center Parking Garage" and,
together with the Gas Company Tower, the "Property"). Moody's
analysis is based on the quality of the collateral, the amount of
subordination supporting each rated class, among other structural
characteristics.

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

The Gas Company Tower is a 54-story, 1,377,053 SF, Class A office
building with grade level retail space and a 978 stall on-site
subterranean parking garage located at 555 West 5th Street in the
Bunker Hill district of downtown Los Angeles, California. The LEED
Gold certified tower sits on the east side of West 5th Street and
spans an entire city block between South Grand Avenue and South
Olive Street.

Building amenities include an on-site management team with 24-hour
building security, engineering, and maintenance services, valet
parking with electric vehicle charging stations and text-in valet
services, a banking center, a newsstand, a car wash, a dry cleaner,
self-service bike storage, and concierge services.

As of January 1, 2021, Gas Company Tower was 75.7% leased to 28
tenants (primarily office). The weighted average remaining lease
term of the tenant roster is 6.3 years and the average gross rent
is $44.59 PSF. Investment grade, "AM Law 100", government and "Big
4" accounting firm occupants account for approximately 54.4% of
total NRA (71.8% of occupied NRA) and 69.5% of base rent. The
largest revenue contributors at the Property include Southern
California Gas Co. (A2, senior unsecured; 26.0% of NRA; 29.3% of
base rent), Sidley Austin (AM Law 100 #6; 10.0% of NRA; 12.9% of
base rent), Deloitte LLP (Big 4 accounting firm; 8.1% of NRA; 10.4%
of base rent), WeWork (6.0% of NRA; 9.2% of base rent), Latham &
Watkins (AM Law 100 #2; 6.5% of NRA; 7.8% of base rent) and GSA
(Aaa, senior unsecured; 2.6% of NRA; 7.5% of base rent). The top 10
tenants by base rent represent approximately 68.3% of NRA,
approximately 90.0% of base rent and have a weighted average
remaining lease term of 6.5 years (weighted based on base rent).

The World Trade Center Parking Garage is a 1,166-stall off-site
parking garage situated on South Figueroa Street that provides
additional parking capacity for the tenants of the Gas Company
Tower (approximately an eight-minute walk) as well as nearby
transient parkers.

The Property has a total of 2,144 parking stalls (approximately
1.56 spaces per 1,000 SF of net rentable area, which includes the
parking stalls located at the Gas Company Tower and the World Trade
Center Parking Garage).

The credit risk of loans is determined primarily by two factors: 1)
Moody's assessment of the probability of default, which is largely
driven by each loan's DSCR, and 2) Moody's assessment of the
severity of loss upon a default, which is largely driven by each
loan's loan-to-value ratio, referred to as the Moody's LTV or MLTV.
As described in the CMBS methodology used to rate this transaction,
Moody's make various adjustments to the MLTV. Moody's adjusts the
MLTV for each loan using a value that reflects capitalization (cap)
rates that are between our sustainable cap rates and market cap
rates. Moody's also use an adjusted loan balance that reflects each
loan's amortization profile. The MLTV reported in this publication
reflects the MLTV before the adjustments described in the
methodology.

The Moody's first-mortgage DSCR is 2.77x and Moody's first-mortgage
stressed DSCR (at a 9.25% constant) is .82x. Moody's DSCR is based
on our assessment of the property's stabilized NCF.

The first mortgage loan balance of $350.0 million represents a
Moody's LTV of 109.3%. Taking into consideration the additional
subordinate mezzanine loan with a principal balance of $115.0
million, the total debt Moody's LTV would increase to 145.3%.

Moody's also grades properties on a scale of 0 to 5 (best to worst)
and considers those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The property's
weighted average property quality grade is 0.75.

Notable strengths of the transaction include: asset quality, tenant
roster, and institutional sponsorship.

Notable challenges of the transaction include: the effects of the
coronavirus, the lack of asset diversification, soft submarket,
subordinate debt, and certain credit negative loan structure and
legal features.

The principal methodology used in these ratings was "Moody's
Approach to Rating Large Loan and Single Asset/Single Borrower
CMBS" published in September 2020.

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

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.

The coronavirus outbreak, the government measures put in place to
contain it, and the weak global economic outlook continue to
disrupt economies and credit markets across sectors and regions.
Moody's analysis has considered the effect on the performance of
commercial real estate from the current weak US economic activity
and a gradual recovery for the coming months. Although an economic
recovery is underway, it is tenuous and its continuation will be
closely tied to containment of the virus. As a result, the degree
of uncertainty around our forecasts is unusually high.

Moody's regards the coronavirus outbreak as a social risk under its
ESG framework, given the substantial implications for public health
and safety.


JP MORGAN 2013-C15: Fitch Affirms B Rating on Class F Certs
-----------------------------------------------------------
Fitch Ratings has affirmed 11 classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust (JPMBB) Commercial Mortgage
Pass-Through Certificates series 2013-C15.

     DEBT               RATING             PRIOR
     ----               ------             -----
JPMBB 2013-C15

A-4 46640NAD0     LT  AAAsf  Affirmed      AAAsf
A-5 46640NAE8     LT  AAAsf  Affirmed      AAAsf
A-S 46640NAJ7     LT  AAAsf  Affirmed      AAAsf
A-SB 46640NAF5    LT  AAAsf  Affirmed      AAAsf
B 46640NAK4       LT  AAsf   Affirmed      AAsf
C 46640NAL2       LT  Asf    Affirmed      Asf
D 46640NAP3       LT  BBB-sf Affirmed      BBB-sf
E 46640NAR9       LT  BBsf   Affirmed      BBsf
F 46640NAT5       LT  Bsf    Affirmed      Bsf
X-A 46640NAG3     LT  AAAsf  Affirmed      AAAsf
X-B 46640NAH1     LT  AAsf   Affirmed      AAsf

KEY RATING DRIVERS

Increased Loss Expectations: Loss expectations have increased
primarily due to the declining performance of the 10 Fitch Loans of
Concern (FLOCS; 49.5%) including three specially serviced loans
(6.3%), as a result of the coronavirus pandemic and/or occupancy
declines and upcoming lease rollover concerns. Fitch's current
ratings incorporate a base case loss of 4.5%. The Negative Rating
Outlooks indicate losses may increase further to 7.9% if loans
impacted by the pandemic do not stabilize and reflect additional
stresses on these loans.

Fitch Loans of Concern/Specially Serviced Loans: The largest FLOC
and the largest loan in the pool, Miracle Mile Shops (15.8%), is
secured by an approximately 450,000-sf regional mall located on the
Las Vegas Strip adjacent to the Planet Hollywood Resort and Casino.
The mall was temporarily closed between mid-March and early June
2020 due to the ongoing coronavirus pandemic. The tenancy includes
a variety of retail shops, restaurants and entertainment venues;
the largest two tenants are both theaters and remain closed. The
mall had strong sales performance pre-pandemic, with comparable
in-line sales of $835 psf as of the TTM February 2020 sales
report.

Approximately 16.6% of the NRA is scheduled to expire in 2020 and
2021, including the second largest tenant Saxe Theater (5% of NRA),
whose lease expired in June 2020. According to the servicer, the
tenant has postponed renewal discussions due to the ongoing
pandemic. The loan transferred to the special servicer Aug. 5,
2020, when the borrower requested coronavirus relief and the loan
was modified, whereby the interest only period was extended until
Feb. 2021. The loan was returned to the master servicer on Aug. 20,
2020. As of January 2021, the mall has partially re-opened with
stores, restaurants and bars operating with limited hours. The
property was 94% occupied as of October 2020 compared to 97.8% a
YE2019. The TTM September 2020 NOI DSCR was 1.49x compared to 1.41x
at YE 2019.

The second largest FLOC, 1615 L Street (14.8% of the pool), is
secured by a 417,383-sf office building located in downtown
Washington, DC, four blocks from the White House. The property was
built in 1984 and renovated in 2009. The property's top tenant,
Cardinia Real Estate (21.8% of the NRA), has approximately 63,000
sf (15.1% of the NRA), which expired in September 2020. Per the
master servicer, the tenant did not renew approximately 43,000 sf
of their space. The departure causes property occupancy to decrease
to approximately 83% from 93.8% as of September 2020, 94.1% in
September 2019, 98.6% at YE 2018, and 96.1% at YE 2017. Fitch
applied a 15% total haircut to the NOI to adjust for the tenant
vacating and expected decline in performance.

The third largest FLOC, Briarcliff Office Portfolio (7.3% of the
NRA) is secured by a portfolio of four office buildings and one day
care center totaling 417,512-sf located in Kansas City, MO.
Occupancy is at 82.2% as of September 2020 compared to 80% at YE
2019 after consistently being near 95% since 2014. NOI DSCR is
1.18x at June 2020 compared to 1.13x at YE 2019 down from 1.36x at
YE2018 and 1.45 at YE 2017. Per the borrower, there was an ongoing
litigation related to a failed retaining wall, which had increased
expenses in 2019 along with a significant increase in taxes. Fitch
applied a 10% total haircut to the NOI for upcoming tenant
rollover.

The largest specially serviced loan, Marriott Portfolio (4.2%), is
secured by three full-service Marriott flagged hotels in Fullerton,
CA (48.1% of allocated loan balance), Norcross, GA (28.4%) and
Southfield, MI (23.4%). The loan transferred to the special
servicer in July 2020 for imminent monetary default but the loan
has remained current. A forbearance was approved and the loan will
be returned to the master servicer. Servicer reported YE 2019 NOI
DSCR was 3.54x compared to 3.21x at YE 2018. Fitch modeled a
minimal loss in its base case analysis for expected fees.

Alternative Loss Consideration: Fitch's analysis included an
additional sensitivity scenario that included additional pool-wide
stresses to cap rates (100 bps over Fitch standard stressed cap
rates) and NOI (10% additional stress) applied on the performing
loans in the pool. This additional sensitivity scenario contributed
to the Negative Outlooks on classes E and F.

Improved Credit Enhancement: Credit enhancement has increased since
issuance due to loan payoffs and scheduled amortization. As of the
January 2021 distribution date, the pool's aggregate principal
balance has been reduced by 43.2% to $677.5 million from $1.19
billion at issuance. Twenty loans have paid off since issuance,
including the large FLOC, Hulen Mall, formerly $82.2 million. Two
loans, approximately 16.4% of the pool, are full-term, interest
only, including the second largest loan, 1615 L Street (14.8%). All
of the partial-term interest only loans (36.1%) are now amortizing
with the exception of Miracle Mile Shops, which was modified,
extending the Interest only period. Ten loans (12.3%) are fully
defeased, up from nine loans (11.2%) at the prior review, including
the 8th, 9th, and 17th largest loans. All remaining loans mature
from July through October 2023. There have been no realized losses
to date.

Coronavirus Impact: Fitch expects significant economic impacts to
certain hotels, retail and multifamily properties from the
pandemic, due to the related reductions in travel and tourism,
temporary closures and capacity rules, and lack of clarity at this
time on the potential duration and/or impact of the pandemic.
Properties collateralized by retail, hotels, and multifamily total
33.0%, 7.9%, and 7.5%, respectively. Fitch's base case analysis
applied additional stresses to eleven retail loans and two hotel
loans due to their vulnerability to the pandemic; this analysis
contributed to the Negative Outlooks on classes E and F.

RATING SENSITIVITIES

The Negative Rating Outlook on classes E and F reflects the
potential for downgrade due to concerns surrounding the ultimate
impact of the pandemic, and the performance concerns associated
with the FLOCs. The Outlooks on classes E and F may be revised to
Stable with another year of stable collateral performance and
improved CE. The Stable Rating Outlooks on classes A-4 through D
reflect the increasing credit enhancement, continued expected
amortization and relatively stable performance of the majority of
the pool.

Factors that could, individually or collectively, lead to a
positive rating action/upgrade:

Sensitivity factors that lead to upgrades would include:

-- Stable to improved asset performance coupled with pay down
    and/or defeasance.

-- Upgrades of the 'Asf' and 'AAsf' categories would likely occur
    with significant improvement in credit enhancement and/or
    defeasance; however, adverse selection, increased
    concentrations and further underperformance of the FLOCs or
    loans expected to be negatively affected by the coronavirus
    pandemic could cause this trend to reverse.

-- Upgrades to the 'BBB-sf' category would be limited based on
    sensitivity to concentrations or the potential for future
    concentration. Classes would not be upgraded above 'Asf' if
    there were likelihood for interest shortfalls. Upgrades to the
    'Bsf' and 'BBsf' categories are not likely until the later
    years in a transaction, and only if the performance of the
    remaining pool is stable and/or properties vulnerable to the
    pandemic return to pre-pandemic levels, and there is
    sufficient credit enhancement to the classes.

Factors that could, individually or collectively, lead to a
negative rating action/downgrade:

-- Sensitivity factors that lead to downgrades include an
    increase in pool level losses from underperforming or
    specially serviced loans. Downgrades to the 'AAsf' and 'AAAsf'
    categories are not likely due to the high CE and amortization,
    but may occur should interest shortfalls impact the classes.

-- Downgrades to the 'BBB-sf' and Asf' category would occur
    should overall pool losses increase significantly and/or one
    or more large loans have an outsized loss, which would erode
    credit enhancement. Downgrades to the 'Bsf' and 'BBsf'
    categories would occur should loss expectations increase and
    if performance of the FLOCs or loans vulnerable to the
    pandemic fail to stabilize or additional loans default and/or
    transfer to the special servicer.

-- In addition to its baseline scenario related to the
    coronavirus pandemic, Fitch also envisions a downside scenario
    where the health crisis is prolonged beyond 2021; should this
    scenario play out, Fitch expects negative rating actions,
    including downgrades and/or further Negative Rating Outlook
    revisions.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

ESG CONSIDERATIONS

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


LB-UBS COMMERCIAL 2007-C6: Fitch Affirms D Ratings on 8 Classes
---------------------------------------------------------------
Fitch Ratings affirmed 16 classes of LB-UBS Commercial Mortgage
Trust commercial mortgage pass-through certificates series
2007-C6.

    DEBT              RATING             PRIOR
    ----              ------             -----
LB-UBS Commercial Mortgage Trust 2007-C6

A-J 52109PAH8   LT  CCCsf  Affirmed      CCCsf
B 52109PAJ4     LT  CCsf   Affirmed      CCsf
C 52109PAK1     LT  Csf    Affirmed      Csf
D 52109PAL9     LT  Csf    Affirmed      Csf
E 52109PAM7     LT  Csf    Affirmed      Csf
F 52109PAN5     LT  Csf    Affirmed      Csf
G 52109PAX3     LT  Csf    Affirmed      Csf
H 52109PAY1     LT  Csf    Affirmed      Csf
J 52109PAZ8     LT  Dsf    Affirmed      Dsf
K 52109PBA2     LT  Dsf    Affirmed      Dsf
L 52109PBB0     LT  Dsf    Affirmed      Dsf
M 52109PBC8     LT  Dsf    Affirmed      Dsf
N 52109PBD6     LT  Dsf    Affirmed      Dsf
P 52109PBE4     LT  Dsf    Affirmed      Dsf
Q 52109PBF1     LT  Dsf    Affirmed      Dsf
S 52109PBG9     LT  Dsf    Affirmed      Dsf

KEY RATING DRIVERS

High Concentration of Specially Serviced Loans/Assets: The
affirmations reflect the continued high certainty of losses from
specially serviced loans/assets impacting the outstanding classes.

The remaining pool is adversely selected, with only 10 individual
loans/assets and one cross-collateralized portfolio of 39 loans. As
of the January 2021 remittance reporting, 10 loans/assets (95.4% of
pool) are in special servicing, including seven REO assets (65.8%),
one loan (23.2%) previously modified into A/B notes which is 30
days delinquent, one loan (6.4%) classified as in foreclosure and
one non-performing matured balloon loan (0.01%).

The only performing loan (4.6%), Town Square Retail, which is
secured by a 70,579 sf unanchored retail shopping center in Eden
Prairie, MN, was designated a Fitch Loan of Concern (FLOC) due to
declining occupancy and coronavirus performance concerns.

Due to the highly concentrated nature of the pool, Fitch performed
a sensitivity and liquidation analysis, which grouped the remaining
loans/assets based on their current status and collateral quality,
and ranked them by their perceived likelihood of repayment and/or
loss expectations. The ratings reflect this sensitivity analysis.

Largest Specially Serviced Assets: The largest asset in special
servicing is the PECO Portfolio (46.2%), which was originally
secured by 39 cross-collateralized and cross-defaulted properties
located across 13 states. The loan transferred to special servicing
in August 2012 when the borrower requested a modification. The
borrower later agreed to a deed-in-lieu of foreclosure and the
portfolio became REO in two stages between June 2014 and March
2015.

As of the January 2021 distribution date, 38 of the original 39
properties have been sold, 10 of which were since Fitch's last
rating action, and the proceeds were applied pro-rata across all
properties. Only one asset remains in the portfolio, Eastwood
Shopping Center, a retail center anchored by Save-a-Lot located in
Frankfort, KY. The property was only 49% occupied as of October
2020, with a vacant anchor box formerly occupied by Sears noted to
be in poor condition. The special servicer continues to work on
leasing up space and renewing expiring tenants. Several tenant rent
relief requests have been processed due to the coronavirus
pandemic.

The second largest specially serviced loan is the Islandia Shopping
Center - A and B notes (23.2%), which is secured by a 376,774 sf
grocery-anchored shopping center in Islandia, NY. The loan
transferred back again to the special servicer in January 2021 for
imminent default due to cash flow issues as a result of the
coronavirus pandemic. The loan has an upcoming maturity in July
2021.

The loan had previously transferred to special servicing in 2013,
was modified in 2014 and subsequently transferred back to the
master servicer in March 2015. Terms of the modification include a
four-year maturity extension to 2021, a change of the IO period and
interest rate, and the creation of a hope note. The property was
95% occupied as of September 2020. The largest tenants include
Wal-Mart (34.2% of NRA; through November 2027), Stop & Shop (18.2%;
May 2021) and Dave & Busters (12.6%; August 2027). Fitch's analysis
assumed the A-note to take a loss, and a full loss of the B-note.

Increased Credit Enhancement: Credit enhancement has increased
since Fitch's last rating action primarily due from REO
liquidations. As of the January 2021 distribution date, the pool's
aggregate principal balance has been reduced by 90.2% to $292.1
million from $2.98 billion at issuance. Realized losses since
issuance total $181.5 million (6.1% of original pool balance).
Cumulative interest shortfalls totaling $36.6 million are currently
affecting classes G through T.

RATING SENSITIVITIES

Factor that could, individually or collectively, lead to positive
rating action/upgrade:

-- All remaining classes are distressed and future upgrades are
    unlikely given the concentrated nature of the pool and large
    percentage of the pool in special servicing.

Factor that could, individually or collectively, lead to negative
rating action/downgrade:

-- All remaining classes are subject to further downgrades with
    greater certainty of losses and/or as losses are realized.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

ESG CONSIDERATIONS

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


MELLO WAREHOUSE 2021-1: Moody's Gives (P)B2 Rating to 2 Tranches
----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to seven
classes of notes issued by Mello Warehouse Securitization Trust
2021-1 (the transaction). The ratings range from (P)Aaa (sf) to
(P)B2 (sf). The securities in this transaction are backed by a
revolving pool of newly originated first-lien, fixed rate and
adjustable rate, residential mortgage loans which are eligible for
purchase by Fannie Mae, Freddie Mac or in accordance with the
criteria of Ginnie Mae for the guarantee of securities backed by
mortgage loans to be pooled in connection with the issuance of
Ginnie Mae securities. The pool may also include FHA Streamline
mortgage loans or VA-IRRR mortgage Loans, which may have limited
valuation and documentation. The revolving pool has a total size of
$300,000,000.

The complete rating action are as follows.

Issuer: Mello Warehouse Securitization Trust 2021-1

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

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

Cl. C, Provisional Rating Assigned (P)A2 (sf)

Cl. D, Provisional Rating Assigned (P)Baa2 (sf)

Cl. E, Provisional Rating Assigned (P)Baa3 (sf)

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

Cl. G, Provisional Rating Assigned (P)B2 (sf)

RATINGS RATIONALE

The transaction is based on a repurchase agreement between
loanDepot.com LLC ("loanDepot"), as repo seller, and Mello
Warehouse Securitization Trust 2021-1 as buyer. LD Holdings Group
LLC ("LD Holdings", senior unsecured rating B2) guarantees
loanDepot's payment obligations under the securitization's
repurchase agreement.

Moody's base our Aaa expected losses of 27.56% and base case
expected losses of 3.87% on a scenario in which loanDepot and the
guarantor LD Holdings does not pay the aggregate repurchase price
to pay off the notes at the end of the facility's three-year
revolving term, and the repayment of the notes will depend on the
credit performance of the remaining static pool of mortgage loans.
To assess the credit quality of the static pool, Moody's created a
hypothetical adverse pool based on the facility's eligibility
criteria, which includes no more than 5% (by unpaid balance)
adjustable-rate mortgage (ARM) loans. Loans which are subject to
payment forbearance, a trial modification, or delinquency are
ineligible to enter the facility. Moody's analyzed the pool using
our US MILAN model and made additional pool level adjustments to
account for risks related to (i) a weak representation and warranty
enforcement framework (ii) existence of compliance findings related
to the TILA-RESPA Integrated Disclosure (TRID) Rule in third-party
diligence reports from prior Mello Warehouse Securitization Trust
transactions, which have raised concerns about potential losses
owing to TRID for the loans in this transaction.

The ratings on the notes are be the higher of (i) the repo
guarantor's (LD Holdings Group LLC) rating and (ii) the rating of
the notes based on the credit quality of the mortgage loans backing
the notes (i.e., absent consideration of the repo guarantor). If
the repo guarantor does not satisfy its obligations under the
guaranty, then the ratings on the notes will only reflect the
credit quality of the mortgage loans backing the notes.

Collateral Description:

The mortgage loans will be newly originated, first-lien, fixed-rate
and adjustable rate mortgage loans that also comply with the
eligibility criteria set forth in the master repurchase agreement.
The aggregate principal balance of the purchased loans at closing
will be $300,000,000. Per the transaction documents, the mortgage
pool will have a minimum weighted average FICO of 730 and a maximum
weighted average LTV of 82%.

The ultimate composition of the pool of mortgage loans remaining in
the facility at the end of the three-year term upon default of
loanDepot is unknown. Moody's modeled this risk through evaluating
the credit risk of an adverse pool constructed using the
eligibility criteria. In generating the adverse pool: 1) Moody's
assumed the worst numerical value from the criteria range for each
loan characteristic. For example, the credit score of the loans is
not less than 660 and the weighted average credit score of the
purchased mortgage loans is not less than 730; the maximum
debt-to-income ratio is 50% in the adverse pool (per eligibility
criteria); 2) Moody's assumed risk layering for the loans in the
pool within the eligibility criteria. For example, loans with the
highest LTV also had the lowest FICO to the extent permitted by the
eligibility criteria; 3) Moody's took into account the specified
restrictions in the eligibility criteria such as the weighted
average LTV and FICO; 4) Since these loans are eligible for
purchase by the agencies, Moody's also took into account the
specified restrictions in the underwriting criteria. For example,
no more than 97% LTV for fixed rate purchased loans and 95% for
adjustable rate purchase loans.

The transaction allows the warehouse facility to include up to 50%
(consistent with the prior deal) of mortgage loans (by outstanding
principal balance) whose collateral documents have not yet been
delivered to the custodian (wet loans). This transaction is more
vulnerable to the risk of losses owing to fraud from wet loans
during the time it does not hold the collateral documents. There
are risks that a settlement agent will fail to deliver the mortgage
loan files after receipt of funds, or the sponsor of the
securitization, either by committing fraud or by mistake, will
pledge the same mortgage loan to multiple warehouse lenders.
However, Moody's analysis has considered several operational
mitigants to reduce such risks, including (i) collateral documents
must be delivered to the custodian within 10 business days
following a wet loan's funding or it becomes ineligible, (ii) the
transaction will only fund a wet loan if the closing of the
mortgage loan is handled by a settlement agent (covered by errors
and omissions insurance policy) who will provide a closing
protection letter to the repo seller (except for attorney closings
in the State of New York), (iii) the repo seller maintains a
fidelity bond in place, naming the issuer as an additional insured
party, in the event of fraud in connection with the closing of the
wet loans, (iv) the repo seller has acquired services of an
independent third party fraud detection and verification vendor,
PitchPoint Solutions Inc. (settlement agent vendor), to verify
credentials of settlement agents and the bank accounts for wires in
connection with the funding of such wet loans, and (v) Deutsche
Bank National Trust Company (Baa1), a highly rated independent
counterparty, act as the mortgage loan custodian. Moody's view
these mitigants as adequate measures to prevent the likelihood of
fraud by the settlement agent or the sponsor.

The loans will be originated and serviced by loanDepot.com, LLC
(loanDepot). U.S. Bank National Association will be the standby
servicer. Moody's consider the overall servicing arrangement for
this pool to be adequate. At the transaction closing date, the
servicer acknowledges that it is servicing the purchased loans for
the joint benefit of the issuer and the indenture trustee.

Transaction Structure:

Moody's analysis of the securitization structure includes reviewing
bankruptcy remoteness, assessing the ability of the indenture
trustee to take possession of the collateral in an event of
default, conformity of the collateral with the eligibility criteria
as well as allocation of funds to the notes.

The transaction is structured as a master repurchase agreement
between loanDepot (the repo seller) and the Mello Warehouse
Securitization Trust 2021-1 (the trust or issuer). The U.S.
Bankruptcy Code provides repurchase agreements, security contracts
and master netting agreements a "safe harbor" from the Bankruptcy
Code automatic stay. Due to this safe harbor, in the event of a
bankruptcy of loanDepot or the guarantor, the issuer will be exempt
from the automatic stay and thus, the issuer will be able to
exercise remedies under the master repurchase agreement, which
includes seizing the collateral.

During the revolving period, the repo seller's obligations will
include making timely payments of interest accrued on the notes as
well as the aggregate monthly fees. Failure to make such payments
will constitute a repo trigger event whereby the indenture trustee
will seize the collateral and terminate the repo agreement. It is
expected that the notes will not receive payments of principal
until the expected maturity date or after the occurrence and
continuance of an event of default under the indenture unless the
repo seller makes an optional prepayment. In an event of default,
principal will be distributed sequentially amongst the classes.
Realized losses will be allocated in a reverse sequential order.

In addition, since the pool may consist of both fixed rate and
adjustable rate mortgages, the transaction may be exposed to
potential risk from interest rate mismatch. To account for the
mismatch, Moody's assumed a stressed LIBOR curve by increasing the
one-month LIBOR rate incrementally for a certain period until it
reaches the maximum allowable interest rate as described in the
transaction documents.

Ongoing Due Diligence

During the revolving period, Clayton Services LLC (or a qualified
successor diligence provider appointed by the repo seller) will
conduct ongoing due diligence every 90 days on 100 randomly
selected loans (other than wet loans). The first review will be
performed 30 days following the closing date. The scope of the
review will include credit underwriting, regulatory compliance,
valuation and data integrity.

Because Moody's analysis is based on a scenario in which the
facility terms out, due diligence reviews provide some control on
the credit quality of the collateral. The due diligence framework
in this transaction combined with the collateral eligibility
controls help mitigate the risks of adverse selection in this
transaction.

While the due diligence review will provide some validation on the
quality of the loans, it may not be fully representative of the
collateral quality of the facility at all times. This is mainly due
to the frequency of the due diligence review, the revolving nature
of the collateral pool, and that the review will be conducted on a
sample basis. Also, by the time the due diligence review is
completed, some of the sampled loans may no longer be in the pool.

Representation and Warranties

For a mortgage loan to qualify as an eligible mortgage loan, the
loan must meet representations and warranties described in the
repurchase agreement. The substance of the representations and
warranties are consistent with those in our published criteria for
representations and warranties for U.S. RMBS transactions. After a
repo event of default, which includes the repo seller or buyer's
failure to purchase or repurchase mortgage loans from the facility,
the repo seller or buyer's failure to perform its obligations or
comply with stipulations in the master repurchase agreement,
bankruptcy or insolvency of the buyer or the repo seller, any
breach of covenant or agreement that is not cured within the
required period of time, as well as the repo seller's failure to
pay price differential when due and payable pursuant to the master
repurchase agreement, a delinquent loan reviewer will conduct a
review of loans that are more than 120 days delinquent to identify
any breaches of the representations and warranties provided by the
underlying sellers. Loans that breach the representations and
warranties will be put back to the repo seller for repurchase.

While the transaction has the described representation and
warranties enforcement mechanism, in the amortization period, after
an event of default where the repo seller did not pay the notes in
full, it is unlikely that the repo seller will repurchase the
loans. In addition, the noteholders (holding 100% of the aggregate
principal amount of all notes) may waive the requirement to appoint
such delinquent loan reviewer.

Elevated social risks associated with the coronavirus

The coronavirus outbreak, the government measures put in place to
contain it, and the weak global economic outlook continue to
disrupt economies and credit markets across sectors and regions.
Moody's analysis has considered the effect on the performance of
residential mortgage loans from the current weak US economic
activity and a gradual recovery for the coming months. Although an
economic recovery is underway, it is tenuous and its continuation
will be closely tied to containment of the virus. As a result, the
degree of uncertainty around our forecasts is unusually high.
Moody's regards the coronavirus outbreak as a social risk under its
ESG framework, given the substantial implications for public health
and safety.

Moody's have not made any adjustments related to coronavirus for
this transaction because (i) loans that are subject to payment
forbearance or a trial modification are ineligible to enter the
facility, and the repo seller must repurchase loans in the facility
that become subject to forbearance, (ii) delinquent loans are
ineligible to enter the facility, and (iii) loans are unlikely to
be modified while in the facility due to the seasoning constraint
specified in the eligibility criteria. The repo seller will be
required to repurchase any loans that do not meet the "eligible
loan" criteria.

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's original expectations
as a result of a weaker collateral composition than that in the
adverse pool, financial distress of any of the counterparties.
Transaction performance also depends greatly on the US macro
economy and housing market.

Methodology

The methodologies used in these ratings were "Moody's Approach to
Rating US RMBS Using the MILAN Framework" published in April 2020.


MILL CITY 2021-NMR1: Fitch to Rate 3 Note Classes 'B-'
------------------------------------------------------
Fitch Ratings expects to rate the residential mortgage-backed notes
to be issued by Mill City Mortgage Loan Trust 2021-NMR1 (MCMLT
2021-NMR1).

DEBT               RATING  
----               ------  
Mill City Mortgage Loan Trust 2021-NMR1

A1       LT  AAA(EXP)sf   Expected Rating
A1A      LT  AAA(EXP)sf   Expected Rating
A1B      LT  AAA(EXP)sf   Expected Rating
A2       LT  AA-(EXP)sf   Expected Rating
A3       LT  A-(EXP)sf    Expected Rating
A4       LT  BBB-(EXP)sf  Expected Rating
M1       LT  AA-(EXP)sf   Expected Rating
M2       LT  A-(EXP)sf    Expected Rating
M3       LT  BBB-(EXP)sf  Expected Rating
M3A      LT  BBB-(EXP)sf  Expected Rating
M3B      LT  BBB-(EXP)sf  Expected Rating
B1       LT  BB-(EXP)sf   Expected Rating
B1A      LT  BB-(EXP)sf   Expected Rating
B1B      LT  BB-(EXP)sf   Expected Rating
B2       LT  B-(EXP)sf    Expected Rating
B2A      LT  B-(EXP)sf    Expected Rating
B2B      LT  B-(EXP)sf    Expected Rating
B3       LT  NR(EXP)sf    Expected Rating
B3A      LT  NR(EXP)sf    Expected Rating
B3B      LT  NR(EXP)sf    Expected Rating

B4       LT  NR(EXP)sf    Expected Rating
B4A      LT  NR(EXP)sf    Expected Rating
B4B      LT  NR(EXP)sf    Expected Rating
B5       LT  NR(EXP)sf    Expected Rating
B5A      LT  NR(EXP)sf    Expected Rating
B5B      LT  NR(EXP)sf    Expected Rating
B6       LT  NR(EXP)sf    Expected Rating
B6A      LT  NR(EXP)sf    Expected Rating
B6B      LT  NR(EXP)sf    Expected Rating
PT       LT  NR(EXP)sf    Expected Rating
R        LT  NR(EXP)sf    Expected Rating
X        LT  NR(EXP)sf    Expected Rating
XS       LT  NR(EXP)sf    Expected Rating

TRANSACTION SUMMARY

The notes are supported by a collateral group consisting of 2,579
seasoned performing loans (SPLs), non-performing loans (NPLs) and
re-performing loans (RPLs) with a total balance of approximately
$313 million, including $19.9 million, or 6.4%, of the aggregate
pool balance in non-interest-bearing deferred principal amounts, as
of the cutoff date.

Distributions of principal and interest (P&I) and loss allocations
are based on a traditional senior-subordinate, sequential
structure. The sequential-pay structure locks out principal to the
subordinated notes until the most senior notes outstanding are paid
in full. The servicer will not advance delinquent monthly payments
of P&I.

KEY RATING DRIVERS

Distressed Performance History (Negative): The collateral pool
consists primarily of peak-vintage RPLs. After the adjustment for
COVID-19-related forbearance loans, 12.7% of the pool was 30 or
more days delinquent as of the cutoff date, and 46.6% of loans are
current but have had recent delinquencies or incomplete 24-month
pay strings. Of the loans, 39.3% have been paying on time for the
past 24 months. Roughly 75% (by unpaid principal balance [UPB])
have been modified. Fitch did not penalize loans for prior
delinquencies that were a result of a forbearance plan that have
since cured. Fitch increased its loss expectations to account for
the delinquent loans and the high percentage of "dirty current"
loans.

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

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

RATING SENSITIVITIES

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

This section provides insight into the model-implied sensitivities
the transaction faces when one assumption is modified, while
holding others equal. The modelling process uses the modification
of these variables to reflect asset performance in up and down
environments. The results should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- This defined positive rating sensitivity analysis demonstrates
    how the ratings would react to negative MVDs at the national
    level, or positive home price growth with no assumed
    overvaluation.

-- The analysis assumes positive home price growth of 10%.
    Excluding the senior class, which is already 'AAAsf', the
    analysis indicates there is potential positive rating
    migration for all of the rated classes.

-- Specifically, a 10% gain in home prices would result in a full
    category upgrade for the rated class excluding those assigned
    'AAAsf' ratings.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- This defined negative rating sensitivity analysis demonstrates
    how the ratings would react to steeper MVDs at the national
    level. The analysis assumes MVDs of 10%, 20% and 30% in
    addition to the model-projected 4.5%.

-- The analysis indicates that there is some potential rating
    migration with higher MVDs for all rated classes, compared
    with the model projection. Specifically, a 10% additional
    decline in home prices would lower all rated classes by one
    full category.

Fitch has added a coronavirus sensitivity analysis that includes a
prolonged health crisis resulting in depressed consumer demand and
a protracted period of below-trend economic activity that delays
any meaningful recovery to beyond 2021. Under this severe scenario,
Fitch expects the ratings to be affected by changes in its
sustainable home price model due to updates to the model's
underlying economic data inputs. Any long-term effects arising from
coronavirus-related disruptions on these economic inputs will
likely affect both investment and speculative-grade ratings.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

CRITERIA VARIATION

There are three variations to the U.S. RMBS ratings criteria that
relate to the tax/title review, the pay history sample size and the
compliance sample size.

Based on the title effective date, all the reviewed loans by loan
count were not reviewed within six months of the closing date.
However, all of lien searches were performed within at least 12
months of the transaction closing date. The servicer has a
responsibility in line with the transaction documents to advance
these payments to maintain the trust's interest and position in the
loans. There was no rating impact as a result of this variation.

In regards to the pay history review, 8% of the loans did not have
a review. No adjustments were made and Fitch did not view this as
material to the rating as there were no issues or discrepancies
noted on the portion completed; the 7% with no review have spotty
pay histories and are receiving material penalties.

On the compliance sample size variation, five first lien loans did
not receive a review and were penalized as high cost uncertain.
Also, the sample on the second lien portion was less than the 20%
Fitch looks for in its criteria. Given the 100% LS already applied
and the results of the diligence on the remaining portion, no
additional adjustments were made.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by situsAMC and Clayton Services. The third-party due
diligence described in Form 15E focused on a regulatory compliance
review that covered applicable federal, state and local high-cost
loan and/or anti-predatory laws, as well as the Truth in Lending
Act (TILA) and Real Estate Settlement Procedures Act (RESPA). Fitch
considered this information in its analysis and, as a result, Fitch
made the following adjustment(s) to its analysis:

-- Missing or indeterminate HUD- 1 files

-- Due Diligence Not Completed

-- Missing Modification Documents

-- Potential Ability to Repay Issues

These adjustment(s) resulted in an approximately 75bps increase to
the expected loss at 'AAAsf'.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on more than 90% of the pool. The third-party due
diligence was generally consistent with Fitch's "U.S. RMBS Rating
Criteria." SitusAMC, LLC and Clayton Services were engaged to
perform the review. Loans reviewed under this engagement were given
compliance grades. Minimal exceptions and waivers were noted in the
due diligence reports. Refer to the Third-Party Due Diligence
section for more details.

Fitch also utilized data files that were made available by the
issuer on its SEC Rule 17g-5 designated website. Fitch received
loan-level information based on the American Securitization Forum's
(ASF) data layout format, and the data are considered to be
comprehensive. The ASF data tape layout was established with input
from various industry participants, including rating agencies,
issuers, originators, investors and others, to produce an industry
standard for the pool-level data in support of the U.S. RMBS
securitization market. The data contained in the ASF layout data
tape were reviewed by the due diligence companies, and no material
discrepancies were noted.

ESG CONSIDERATIONS

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


OCTAGON INVESTMENT 49: S&P Assigns BB-(sf) Rating to Class E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Octagon Investment
Partners 49 Ltd./Octagon Investment Partners 49 LLC's floating- and
fixed-rate notes.

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

The ratings reflect S&P's view of:

-- The diversification of the collateral pool;

-- 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

  Octagon Investment Partners 49 Ltd./
  Octagon Investment Partners 49 LLC

  Class A-1, $279.93 mil.: AAA (sf)
  Class A-2, $15.00 mil.: AAA (sf)
  Class B, $62.28 mil.: AA (sf)
  Class C (deferrable), $28.20 mil.: A (sf)
  Class D (deferrable), $28.20 mil.: BBB- (sf)
  Class E (deferrable), $15.28 mil.: BB- (sf)
  Subordinated notes, $52.50 mil.: Not rated


PALMER SQUARE 2018-2: Fitch Hikes Rating on Class E Debt to BB+
---------------------------------------------------------------
Fitch Ratings has upgraded 23 and affirmed six tranches from five
static U.S. collateralized loan obligations (CLOs) serviced by
Palmer Square Capital Management LLC. Fitch has also revised its
Rating Outlooks on six tranches to Stable from Negative, with no
tranches retaining Negative Rating Outlooks. These rating actions
are based on updated cash flow analyses that include Fitch's
updated CLO coronavirus near-term stress scenario and key
analytical inputs and results are detailed in the accompanying
rating action report.

     DEBT              RATING            PRIOR
     ----              ------            -----
Palmer Square Loan Funding 2018-2, Ltd.

A-1 69700HAA8    LT  AAAsf   Affirmed     AAAsf
A-2 69700HAC4    LT  AAAsf   Upgrade      AA+sf
B 69700HAE0      LT  AAsf    Upgrade      Asf
C 69700HAG5      LT  A+sf    Upgrade      BBBsf
D 69700JAA4      LT  BBBsf   Upgrade      BBsf
E 69700JAC0      LT  BB+sf   Upgrade      B+sf

Palmer Square Loan Funding 2018-4, Ltd

A-1 69700KAA1    LT  AAAsf   Affirmed     AAAsf
A-2 69700KAC7    LT  AAAsf   Upgrade      AA+sf
B 69700KAE3      LT  A+sf    Upgrade      Asf
C 69700KAG8      LT  BBB+sf  Upgrade      BBBsf
D 69700NAA5      LT  BBsf    Affirmed     BBsf
E 69700NAC1      LT  BBsf    Upgrade      B+sf

Palmer Square Loan Funding 2018-5, Ltd.

A-1 69700PAA0    LT  AAAsf   Affirmed     AAAsf
A-2 69700PAC6    LT  AAAsf   Upgrade      AA+sf
B 69700PAE2      LT  A+sf    Upgrade      Asf
C 69700PAG7      LT  BBB+sf  Upgrade      BBBsf
D 69700QAA8      LT  BB+sf   Upgrade      BBsf

Palmer Square Loan Funding 2018-3 Ltd.

A-1 69700LAA9    LT  AAAsf   Affirmed     AAAsf
A-2 69700LAC5    LT  AAAsf   Upgrade      AA+sf
B 69700LAE1      LT  A+sf    Upgrade      Asf
C 69700LAG6      LT  BBB+sf  Upgrade      BBBsf
D 69700MAA7      LT  BB+sf   Upgrade      BBsf
E 69700MAC3      LT  BBsf    Upgrade      B+sf

Palmer Square Loan Funding 2018-1, Ltd.

A-1 69700EAA5    LT  AAAsf   Affirmed     AAAsf
A-2 69700EAC1    LT  AAAsf   Upgrade      AA+sf
B 69700EAE7      LT  AAsf    Upgrade      Asf
C 69700EAG2      LT  A+sf    Upgrade      BBBsf
D 69700FAA2      LT  BBBsf   Upgrade      BBsf
E 69700FAC8      LT  BB+sf   Upgrade      B+sf

TRANSACTION SUMMARY

Palmer Square Loan Funding (PSLF) 2018-1, Ltd., PSLF 2018-2, Ltd.,
PSLF 2018-3, Ltd., PSLF 2018-4, Ltd. and PSLF 2018-5, Ltd. are
arbitrage CLOs that are serviced by Palmer Square Capital
Management LLC. The CLOs were issued in 2018 and are securitized by
static pools of primarily first lien, senior secured leveraged
loans.

KEY RATING DRIVERS

The upgrades are due to the deleveraging of the capital structures
in each static CLO, primarily driven by loan prepayments and
resulting in elevated credit enhancement (CE) levels for all rated
tranches. As of the January 2021 trustee report, between 46.4% to
73.5% of the original class A-1 note balance for each transaction
has amortized since closing. Therefore, Fitch conducted updated
cash flow model (CFM) analyses for all five CLOs to support its
rating actions.

The analyses were based on the current portfolios and evaluated the
combined impact of deleveraging, rating migration and changes in
the portfolios' weighted average spreads and lives as compared with
initial metrics. The analyses used standard assumptions outlined in
Fitch's criteria and an additional stress scenario described
below.

UPDATED NEAR-TERM STRESS SCENARIO

Fitch ran an updated near-term stress scenario by applying the
average rating default rate (RDR) levels at each rating stress,
between standard (criteria) assumptions and a more severe downside
stress scenario, in which all corporate issuers with Negative
Rating Outlooks were notched down with a floor of 'CCC-',
regardless of sector. This near-term stress scenario was used to
inform the rating status for the CLO note ratings.

The Stable Rating Outlooks on the notes in this review reflect
Fitch's expectation that the classes have sufficient levels of
credit protection to withstand potential deterioration in the
credit quality of the portfolios in stress scenarios commensurate
with such class's rating.

CASH FLOW ANALYSIS

Fitch used a proprietary cash flow model to replicate the principal
and interest waterfalls and the various structural features of each
transaction. Each transaction was modeled under stable, down and
rising interest rate scenarios, as well as front-, mid- and
back-loaded default timing scenarios as outlined in Fitch's
criteria.

The rating actions were in line with the model-implied ratings
(MIRs) under standard assumptions, except for the following seven
classes of notes that had MIRs at least one notch higher than their
current ratings:

-- Class B, D notes in PSLF 2018-1, Ltd.

-- Class B, D notes in PSLF 2018-2, Ltd.

-- Class E notes in PSLF 2018-3, Ltd.

-- Class D, E notes in PSLF 2018-4, Ltd.

These notes were not upgraded to the MIRs in light of these notes'
performance in the near-term stress scenario and the comparable
performance of similar notes in other transactions in this review.
For example, the class D notes in PSLF 2018-4 were affirmed at one
notch below the MIR due to potential sensitivities to long-dated
asset exposure, which was the highest, at 4.7% of the portfolio, in
this review.

Credit Quality, Asset Security and Portfolio Composition

The portfolio credit quality of all transactions in this review is
rated 'B'/'B-', and there are currently no reported defaults. The
current portfolios, excluding principal cash amounts, consist of
97% to 99% of first lien senior secured loans. The Fitch weighted
average recovery rate (WARR) of the portfolios averaged 76%.
Portfolios remained diversified, with obligor counts ranging from
114 to 190 and the weight of top 10 obligors ranging from 9% to
16%.

Given the static nature of the pools, portfolio management was
confined to a limited number of credit risk sales since the prior
review, contributing to minimal par losses. All
overcollateralization and interest coverage tests have continued to
increase within the last year and are passing for each CLO.

Portfolio management is limited to credit risk sales and is not
considered a key rating driver.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- A 25% reduction of the mean default rate across all ratings,
    along with a 25% increase of the recovery rate at all rating
    levels, would lead to upgrades (based on model-implied
    ratings) of: two rating categories for the class E notes in
    PSLF 2018-1 and PSLF 2018-2 and for the class D notes in PSLF
    2018-3 and PSLF 2018-5; and one rating category for all other
    notes, except for the class A-1 and A-2 notes. The upgrade
    scenario is not applicable to the class A-1 and A-2 notes in
    the transactions, as their ratings are at the highest level on
    Fitch's scale and cannot be upgraded.

-- At closing, Fitch uses a stress portfolio (Fitch's Stressed
    Portfolio) that is customized to specific portfolio limits for
    the transaction as specified in the transaction documents.
    Upgrades may occur in the event of a better-than-expected
    portfolio credit quality and deal performance, leading to
    higher notes' CE and excess spread available to cover for
    losses on the remaining portfolio. For more information on
    Fitch's Stress Portfolio and the initial model-implied rating
    sensitivities, see the presale/new issue reports for each of
    the CLO transactions included in this review.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- A 25% increase of the mean default rate across all ratings,
    along with a 25% decrease of the recovery rate at all rating
    levels, would lead to downgrades (based on model-implied
    ratings) of: two rating categories for the class D notes in
    PSLF 2018-1, PSLF 2018-2 and PSLF 2018-4 and for the class E
    notes in PSLF 2018-3 and PSLF 2018-4; and one rating category
    for all other notes, except for the class A-2 notes in PSLF
    2018-1 and PSLF 2018-2 and all class A-1 notes, which would
    incur no rating impact.

-- Downgrades may occur if realized and projected losses of the
    portfolio are higher than what was assumed at closing in the
    Fitch Stressed Portfolio and the notes' CE does not compensate
    for the worse loss expectation than initially anticipated.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.


SLM FFELP: S&P Affirms 'B (sf)' Ratings on 26 Classes of Notes
--------------------------------------------------------------
S&P Global Ratings affirmed its 'B (sf)' ratings on 26 classes from
13 SLM Student Loan Trusts. These transactions are each backed by a
pool of student loans originated through the U.S. Department of
Education's (ED) Federal Family Education Loan Program (FFELP).

S&P said, "Our review considered the transactions' collateral
performance and fragile liquidity position, overall stable credit
enhancement, and capital and payment structures. We also considered
the evolving macroeconomic environment that has resulted from the
COVID-19 pandemic, which will likely present employment challenges
for student loan borrowers. Additionally, we considered secondary
credit factors, such as credit stability, peer comparisons, and
issuer-specific analyses."

As vaccine rollouts in several countries continue, S&P Global
Ratings believes there remains a high degree of uncertainty about
the evolution of the coronavirus pandemic and its economic effects.
Widespread immunization, which certain countries might achieve by
midyear, will help pave the way for a return to more normal levels
of social and economic activity. S&P said, "We use this assumption
about vaccine timing in assessing the economic and credit
implications associated with the pandemic. As the situation
evolves, we will update our assumptions and estimates
accordingly."

Rating Action Rationale

The rating actions primarily reflect the liquidity pressure certain
classes are experiencing. The pace of note principal payment has
remained slow, and the senior notes are at risk of being repaid
subsequent to their legal final maturity dates. As such, the
ratings on the class A notes reflect the risk that these notes may
be repaid after their respective maturity dates, and the ratings on
the class B notes reflect the risk that the subordinate notes will
not receive timely interest payments upon an event of default on
class A, since that default could trigger a reprioritization of the
class B interest. Thus, S&P's ratings on the class B notes are not
higher than the lowest-rated senior note. While the pace of bond
repayment is slow relative to the legal final maturity date of the
senior classes, in a base-case 'B' rating environment, it expects
Navient to exercise its option to support the maturing classes.

Current Capital Structure

All of the transactions in this review comprise one senior and one
subordinate note, with coupons based on a spread above a LIBOR
index.

Payment Structure And Credit Enhancement

These transactions utilize a payment mechanism that defines a
principal distribution amount to be distributed to the noteholders.
Generally, once the principal distribution amount is paid,
available funds can be used to pay subordinated amounts and
replenish the reserve account (if necessary and required), and then
release out of the trust. The amount of principal payment is
allocated sequentially between the class A and class B notes.
Credit enhancement includes overcollateralization (parity),
subordination (for certain classes), the reserve account, and
excess spread.

Parity is in excess of 114% for all of the senior classes. The
credit enhancement provided by the loan pool must convert from
loans into bond principal repayment at a pace that allows the bond
to be repaid by its legal final maturity date. The reserve account
may be used to make payment on a bond's legal final maturity date.
The reserve account, measured as greater of 0.25% of the pool
balance and a non-amortizing fixed amount, grows as the bonds
amortize.

Additional Agreements

While the haircuts indicate that the pace of principal payments
from the loans may result in repayment of the senior notes after
their legal final maturity dates, S&P believes that the trusts may
benefit from agreements the issuer has in place. The trusts were
previously amended to provide Navient Corp. with the option to
purchase collateral out of the trust or provide a subordinated loan
to the trust on the legal final maturity date, both of which may
allow the notes to be paid in full by their legal final maturity
dates.

Navient, an active issuer in the market and the current
certificate-holder for the trusts, has indicated that it intends to
exercise its option at the legal final maturity date through one of
these mechanisms. Navient has provided such liquidity in the past
by exercising its option to purchase collateral from some of its
trusts when certain classes faced liquidity constraints. As such,
S&P believes that in an expected case of a 'B' rating, Navient will
exercise its option to provide liquidity for the maturing class.

Collateral

These transactions primarily comprise seasoned Stafford loans that
are supported by a guarantee from the ED of at least 97% of a
defaulted loan's principal and interest. Loans that have been
serviced according to the FFELP guidelines are supported by this
guarantee; therefore, net losses are expected to be minimal.

Liquidity

S&P's rating addresses the receipt of timely interest payments and
the receipt of principal payments by the legal final maturity
dates.

Over the past year, the bond principal pay down has continued to
decline. S&P calculated a principal payment haircut using the
average bond principal payment over the past year, which indicates
the percentage decline a bond can immediately withstand and still
be repaid by its legal final maturity date. A lower haircut
indicates that a bond can withstand a smaller decline in bond
principal payment amount than a bond with a higher haircut. A
negative haircut implies that a bond will need to experience a
sustained increase in principal payments. Such an increase could
occur as a result of an increase in loan prepayments or defaults
(which act as a prepayment due to the government guarantee), or
from a decrease in loans in income-based repayment plans or loans
in other non-paying statuses, such as in-school/grace, deferment,
and forbearance. As of the most recent servicer report, all of the
senior class haircut calculations are negative. The calculated
haircuts for the subordinate classes are stronger than that of the
senior, as the subordinated classes have later maturity dates that
allow for the borrower to make more loan payments before these
classes' legal final maturity date.

These classes are not at immediate risk of missing timely interest
payments primarily because the structure allows borrower payments
of both interest and principal to be available for bond interest
payments. Due to the potential structural change in the waterfall,
if the senior classes do not receive their principal by their legal
final maturity date then repayment of their principal is
prioritized above the timely interest payment to the subordinate
classes. As such, the subordinate classes are at risk of receiving
timely interest once the senior class legal final maturity date
occurs.

S&P will continue to monitor the performance of the student loan
receivables backing the transactions relative to its ratings and
the available credit enhancement and liquidity for the classes.

  Ratings Affirmed

  SLM Student Loan Trust 2007-2

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2007-3

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2007-7

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-1

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-2

   Class A-3: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-3

   Class A-3: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-4

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-5

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-6

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-7

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-8

   Class A-4: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2008-9

   Class A: B (sf)
   Class B: B (sf)

  SLM Student Loan Trust 2010-1

   Class A: B (sf)
   Class B: B (sf)


WELLS FARGO 2018-C44: Fitch Affirms B- Rating on Cl. G-RR Certs
---------------------------------------------------------------
Fitch Ratings has affirmed the ratings for Wells Fargo Commercial
Mortgage Trust 2018-C44 commercial mortgage pass-through
certificates, series 2018-C44. Fitch has also revised the Rating
Outlook of one class to Negative from Stable.

     DEBT               RATING             PRIOR
     ----               ------             -----
WFCM 2018-C44

A-1 95001JAS6     LT  AAAsf   Affirmed     AAAsf
A-2 95001JAT4     LT  AAAsf   Affirmed     AAAsf
A-3 95001JAU1     LT  AAAsf   Affirmed     AAAsf
A-4 95001JAW7     LT  AAAsf   Affirmed     AAAsf
A-5 95001JAX5     LT  AAAsf   Affirmed     AAAsf
A-S 95001JBA4     LT  AAAsf   Affirmed     AAAsf
A-SB 95001JAV9    LT  AAAsf   Affirmed     AAAsf
B 95001JBB2       LT  AA-sf   Affirmed     AA-sf
C 95001JBC0       LT  A-sf    Affirmed     A-sf
D 95001JAC1       LT  BBB-sf  Affirmed     BBB-sf
E-RR 95001JAE7    LT  BBB-sf  Affirmed     BBB-sf
F-RR 95001JAG2    LT  BB-sf   Affirmed     BB-sf
G-RR 95001JAJ6    LT  B-sf    Affirmed     B-sf
X-A 95001JAY3     LT  AAAsf   Affirmed     AAAsf
X-B 95001JAZ0     LT  AA-sf   Affirmed     AA-sf
X-D 95001JAA5     LT  BBB-sf  Affirmed     BBB-sf

KEY RATING DRIVERS

Increased Loss Expectations: Loss expectations have increased since
issuance, primarily attributable to the social and market
disruption caused by the effects of the coronavirus pandemic and
related containment measures. Fitch has designated nine loans
(27.5% of the pool) as Fitch Loans of Concern (FLOC), including
four loans in the top 15. Three of the FLOCs are loans that have
recently transferred to special servicing.

Fitch's ratings are based on a base case loss expectation of 4.70%.
The Negative Outlook on class G-RR reflects additional stresses on
loans expected to be negatively impacted by the pandemic, which
assumes that losses could reach 6.40%.

Fitch Loans of Concern: The largest FLOC and the largest
contributor to Fitch's projected losses is the largest loan in the
pool, Village at Leesburg (8.7% of the pool). The collateral is a
large outdoor retail property anchored by Wegmans Food Market
located in Leesburg, VA. This loan has been flagged as a FLOC due
to the second largest tenant's April 2020 bankruptcy status.

Cinemex Holdings USA Inc., parent company to CMX/Cobb Theaters
(11.7% NRA through February 2029), filed for Chapter 11 in April
2020 shortly after having to close in response to the coronavirus
pandemic. The loan subsequently transferred to special servicing in
June 2020 at the borrower's request, but was returned to the master
servicer just a few months later with no forbearance or
modification and remains current. Cinemex Holdings USA Inc. has
since emerged from bankruptcy; however, media sources report that
modified lease terms for the company include revenue-sharing
arrangements with various landlords.

Fitch is awaiting clarification to better understand how the new
lease terms will impact cash flow. The theater has reopened after
working with the borrower to remain at the property. Fitch expects
there may be a lag in revenue recovery due re-negotiated lease
terms and potential co-tenancy clauses related to its temporary
closure, as well as other tenants that may have requested rent
relief as a result of reduced foot traffic due to the pandemic.

The second largest FLOC and contributor to Fitch's projected losses
is Northwest Hotel Portfolio (5.0% of the pool). The collateral
comprises seven limited service hotels totaling 818 rooms located
across Idaho (48.3% of allocated loan balance), Bend, Oregon
(34.9%) and Salt Lake City, Utah (16.8%). This loan has been
flagged as a FLOC due to recent missed payments and the borrower's
request for relief related to the coronavirus pandemic. Prior to
the onset of the pandemic, the loan was on the servicer's watchlist
for revenue decline, reportedly attributable to capital work being
done and rooms being temporarily offline. This PIP work was
considered at issuance, and a reserve was funded at closing to
cover most of these costs.

More recently, the loan has continued to exhibit revenue decline
and has been past-due on debt service payments. The first missed
payment occurred in June 2020, shortly after the borrower submitted
a request for relief stemming from challenges related to the
coronavirus pandemic. The loan was brought current with the
December 2020 remittance; however, the borrower continues to
negotiate with the servicer regarding further relief measures.

The third largest FLOC is Prince and Spring Street Portfolio (4.0%
of the pool). The collateral is a portfolio of three
retail/multifamily properties located in the NoLita neighborhood of
Manhattan, just east of SoHo. There are 48 multifamily units, six
of which are rent-stabilized and three of which are
rent-controlled. This loan has been flagged as a FLOC due missed
payments during various periods starting in April 2020. The
borrower previously notified the master servicer of
pandemic-related hardships, though there is little information
provided as to the current status of discussions.

As of the January 2021 distribution, the loan is 90 days delinquent
and has been transferred to the special servicer. At issuance,
retail leases comprised approximately 55% of base rent for the
portfolio. Two retail leases representing 37.5% of the portfolio's
retail space were scheduled to roll in 2020. Portfolio occupancy as
of September 2020 was down to 88% from 95% in June 2020 and 98% at
YE 2019.

The last remaining FLOC in the top15 is Aloft Hotel Raleigh (2.3%
of the pool). The subject is a 135-key Aloft Hotel built in 2015
and located two miles northwest of downtown Raleigh, adjacent to
the campus of North Carolina State University. The university was
the hotel's largest account at issuance. This loan has been flagged
as a FLOC given the property type and ongoing concerns with the
effects of the pandemic on the hospitality industry. The subject
was closed in April, May and June 2020. Since reopening in July,
occupancy has not broken above 30%; however, it is significantly
outperforming its competitive set in occupancy, ADR and RevPAR.

The borrower requested relief from the servicer in September 2020,
and a forbearance was subsequently approved. Terms of the
forbearance include allowing the borrower to use reserves for debt
service payments for the August, September and October 2020 payment
periods, to be repaid over a six-month period.

Coronavirus Exposure: Loans secured by retail properties comprise
24.4% of the pool, including the largest loan which is a FLOC. The
pool's retail component has a weighted-average debt service
coverage ratio (DSCR) of 1.78x. Loans secured by hotel properties
comprise 12.3% of the pool, including two loans in the top 15. The
pool's hotel component has a weighted-average DSCR of 2.10x.
Fitch's base case analysis included additional stresses to four
hotels (10.4% of the pool) and three retail loans (9.8% of the
pool) due to their vulnerability to the coronavirus pandemic. These
additional stresses contributed to the Negative Rating Outlook on
class G-RR.

Minimal Changes to Credit Enhancement: As of the January 2021
distribution, the pool's aggregate principal balance has been paid
down by 1.2% to $757.8 million from $766.7 million at issuance. All
44 of the originally securitized loans remain in the pool.
Seventeen loans representing 44.3% of the pool are interest only
for the full term. An additional 13 loans representing 35.1% of the
pool were structured with partial interest-only periods. Of these
loans, six (25.1% of the pool) have yet to begin amortizing.

Investment-Grade Credit Opinion Loan: At issuance, the seventh
largest loan, 181 Fremont Street (4.0% of the pool), received an
investment-grade credit opinion of 'BBB-sf' on a stand-alone
basis.

RATING SENSITIVITIES

The Negative Outlook on class G-RR reflects concerns for the FLOCs.
The Stable Outlooks on the remaining classes reflects the stable
performance of the remaining pool of loans and sufficient credit
enhancement (CE) relative to expected losses, and expected
continued amortization.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Sensitivity factors that lead to upgrades would include:

-- Stable to improved asset performance, particularly on the
    FLOCs, coupled with paydown and/or defeasance.

-- Upgrades of classes B and C could occur with significant
    improvement in CE and/or defeasance; however, adverse
    selection and increased concentrations or the underperformance
    of particular loan(s) could cause this trend to reverse.

-- Upgrades to classes D and E-RR would be limited based on
    sensitivity to concentrations or the potential for future
    concentration. Classes would not be upgraded above 'Asf' if
    there is likelihood for interest shortfalls.

-- Upgrades to classes F-RR and G-RR are unlikely absent
    significant performance improvement and stabilization of the
    FLOCs.

Factors that could, individually or collectively, lead to a
negative rating action/downgrade:

Sensitivity factors that lead to downgrades include:

-- An increase in pool-level losses from underperforming or
    specially serviced loans/assets.

-- Downgrades to the classes rated 'AAAsf' and 'AA-sf' are not
    likely due to the high CE relative to expected losses and
    amortization, but could occur if there are interest
    shortfalls.

-- Classes C, D and E-RR may be downgraded if additional loans
    transfer to special servicing or the loan currently in special
    servicing does not resolve in a timely manner.

-- Classes F-RR and G-RR may be downgraded if performance of the
    FLOCs continue to decline.

-- The Negative Rating Outlooks may be revised back to Stable if
    performance of the FLOCs improves and/or properties vulnerable
    to the coronavirus stabilize once the pandemic is over.

In addition to its baseline scenario, Fitch also envisions a
downside scenario where the health crisis is prolonged beyond 2021;
should this scenario play out, classes with Negative Rating
Outlooks will be downgraded one or more categories.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.


WELLS FARGO 2019-C49: Fitch Downgrades Class H-RR Certs to 'CCC'
----------------------------------------------------------------
Fitch Ratings has downgraded two classes, revised the Ratings
Outlooks on two classes to Negative from Stable, and affirmed 15
classes of Wells Fargo Commercial Mortgage Trust Pass-Through
Certificates, series 2019-C49 (WFCM 2019-C49).

     DEBT                RATING            PRIOR
     ----                ------            -----
WFCM 2019-C49

A-1 95001WAW8      LT  AAAsf  Affirmed     AAAsf
A-2 95001WAX6      LT  AAAsf  Affirmed     AAAsf
A-3 95001WAY4      LT  AAAsf  Affirmed     AAAsf
A-4 95001WBA5      LT  AAAsf  Affirmed     AAAsf
A-5 95001WBB3      LT  AAAsf  Affirmed     AAAsf
A-S 95001WBE7      LT  AAAsf  Affirmed     AAAsf
A-SB 95001WAZ1     LT  AAAsf  Affirmed     AAAsf
B 95001WBF4        LT  AA-sf  Affirmed     AA-sf
C 95001WBG2        LT  A-sf   Affirmed     A-sf
D 95001WAC2        LT  BBB-sf Affirmed     BBB-sf
E-RR 95001WAE8     LT  BBB-sf Affirmed     BBB-sf
F-RR 95001WAG3     LT  BB+sf  Affirmed     BB+sf
G-RR 95001WAJ7     LT  Bsf    Downgrade    BB-sf
H-RR 95001WAL2     LT  CCCsf  Downgrade    B-sf
X-A 95001WBC1      LT  AAAsf  Affirmed     AAAsf
X-B 95001WBD9      LT  A-sf   Affirmed     A-sf
X-D 95001WAA6      LT  BBB-sf Affirmed     BBB-sf

KEY RATING DRIVERS

Increased Loss Expectations: While the majority of the pool
continues to exhibit stable pool performance, loss expectations
have increased primarily due to the increased number of Fitch Loans
of Concern (FLOCs). Five loans (9.5% of the pool) are considered
FLOCs, including three specially serviced loans (3.1% of the pool),
which have transferred to special servicing. All three loans have
transferred due to hardships caused by the ongoing coronavirus
pandemic, and are either 90+ days delinquent and/or foreclosed.

Fitch's ratings are based on base case loss expectations of 6.90%.
The Negative Outlooks on classes E-RR, F-RR and G-RR reflect
additional stresses on loans expected to be negatively impacted by
the pandemic, which assumes that losses could reach 7.30%.

The largest specially serviced asset and second largest contributor
to losses, Florissant Marketplace (1.6% of the pool), is secured by
a 146,257-sf retail center located in Florissant, MO, approximately
one hour from St. Louis. The property is anchored by a local
grocery tenant, Schnucks Market (48.0% of the net rentable area
(NRA)). However, the second largest tenant, Gold's Gym (27.5% of
the NRA), vacated after filing for bankruptcy. The loan transferred
to the special servicer in July 2020 after falling 60 days
delinquent.

Per the special servicer commentary, the borrower has not provided
a forbearance agreement, and the special servicer is working to put
a receiver in place and moving forward with foreclosure. Fitch's
loss expectations of 52% are based on an updated valuation provided
by the special servicer.

The second largest specially serviced loan, 599 Johnson Avenue
(0.8% of the pool), is secured by a 27,414-sf retail space located
in Brooklyn, NY. The property is anchored by a live music venue and
nightclub, which occupies 73% of the property and also includes
ground floor retail (Chinese food restaurant) and 2nd floor retail
(record shop). The loan transferred to special servicing due to
imminent monetary default in May 2020. The anchor tenant has been
closed during the pandemic, and the borrower expressed hardships
after multiple tenants failed to pay rent.

Per the special servicer commentary, the borrower has requested
payment relief, which includes nine months of debt service relief.
The borrower and special servicer are currently negotiating
potential payment relief plans; Fitch will continue to monitor the
loan for further updates. Fitch's loss expectations of 16% are
based on an updated valuation provided by the special servicer.

The last specially serviced loan, 659 Broadway (0.8% of the pool),
is secured by a 4,876-sf retail property located in Manhattan's
Greenwich Village. The property was single tenanted by Blades,
which closed this location in January 2020, prior to the pandemic.
The loan transferred to special servicing in August 2020 for
payment default. Per the special servicer, there are currently no
leasing prospects, and the borrower has suffered hardships due to
the ongoing pandemic. The special servicer and borrower are
currently negotiating the appropriate next steps; Fitch will
continue to monitor the loan for further updates.

Outside of the specially serviced loans, two loans (6.4% of the
pool) are considered FLOCs for declining performance and/or failing
to meet Fitch's property specific coronavirus net operating income
(NOI) debt service coverage ratio (DSCR) tolerance threshold. The
largest FLOC and largest contributor to losses, Grapevine Station
(4.4% of the pool), is secured by a 273-unit multifamily property
located in Grapevine, TX approximately 3.5 miles from the
Dallas-Fort Worth airport.

The property's occupancy as of September 2020 declined to 84.3%
from 92.7% at YE 2019. Although occupancy had declined, NOI DSCR as
of September 2020 improved to 1.24x from 1.14x at YE 2019. Per the
master servicer, the fluctuations are primarily driven by an
average declining vacancy loss for the 2020 year, despite the lower
occupancy as of September. Per the most recent Reis report, the
Grapevine submarket reported averaged asking rents of $1,214/unit
compared to $1,366/unit at the subject as of September 2020.
Fitch's analysis includes a 10% stress to the YE 2019 NOI due to
the declines in performance and above market rents.

The second largest non-specially serviced FLOC, Doubletree
Leominster (2.0% of the pool), is secured by a 187-key, full
service hotel located in Leominster, MA. The property was built in
1988 and renovated between 2013 and 2015. Renovations included
converting the property to a Doubletree, room upgrades, renovations
to the corridors, banquet space, restaurants and retail shop. Upon
the sponsor's acquisition in 2016, the sponsor signed a new license
agreement with Hilton Franchise Holding, which resulted in an
additional $1.6 million capital improvement plan.

Per the master servicer commentary, the borrower was experiencing
pandemic-related hardships and requested relief. The borrower and
special servicer agreed to a three-month forbearance, which expired
in December 2020. As of the TTM ended July 2020, occupancy at the
property declined to 55.2% from 75.2% at YE 2019. Per the most
recent Smith Travel Research (STR) report, as of TTM July 2020, the
property reported a revenue per available room (RevPAR) penetration
rate of 148.5%. Fitch's analysis includes a 26% stress to the YE
2019 NOI to reflect the expected declines in performance.

Increased Credit Enhancement: As of the January 2021 remittance,
the transaction's balance has been reduced by 0.7% to $769 million
from $774.2 million at issuance. Twenty-seven loans (52.1% of the
pool) have interest only payments for the full loan term, including
nine loans (37.5% of the pool) within the top 15. Twenty loans
(23.9% of the pool) have partial interest only payments, including
three loans (7.0% of the pool) in the top 15. Only two of the 20
partial interest only loans have begun amortizing. The remaining
loans are amortizing.

Four loans (5.7% of the pool) have received forbearance relief,
including Doubletree Leominster (2.1% of the pool). Of these loans,
only the Country Inn & Suites Orlando (1.2% of the pool) is
currently 60 days delinquent.

Coronavirus Exposure: Significant economic impact to certain
hotels, retail and multifamily properties is expected from the
pandemic, due to the recent and sudden reductions in travel and
tourism, temporary property closures and lack of clarity on the
potential length of the impact. The pandemic has prompted the
closure of several hotel properties in gateway cities, as well as
malls, entertainment venues and individual stores.

Eight loans (21.6% of the pool) are secured by hotel loans and
seventeen loans (29.9% of the pool) are secured by retail
properties. Fitch applied additional stresses to six hotel, four
retail and two multifamily loans to account for potential cash flow
disruptions due to the pandemic. This sensitivity analysis
contributed to the Negative Outlooks on classes E-RR, F-RR and G-RR
and downgrades of classes G-RR and H-RR.

Maturity Concentration: Three loans (2.5% of the pool) mature in
2024; one (6.2%) in 2026; fifteen (14.6%) in 2028 and forty-five
(76.7%) in 2029.

RATING SENSITIVITIES

-- The Negative Outlooks on classes E-RR, F-RR and G-RR and
    downgrades of classes G-RR and H-RR reflect increased loss
    expectations on the specially serviced loans and FLOCs, which
    are primarily secured by hotel and retail properties, given
    the decline in travel and commerce as a result of the
    pandemic.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Factors that could lead to upgrades would include:

-- Stable to improved asset performance, coupled with additional
    paydown and/or defeasance.

-- Upgrades to the 'A-sf' and 'AA-sf' rated classes are not
    expected but would likely occur with significant improvement
    in CE and/or defeasance in addition to the stabilization of
    properties impacted from the pandemic.

-- An upgrade to the 'Bs-f' and below rated classes is not likely
    unless the performance of the remaining pool stabilizes and
    the senior classes pay off.

-- The Negative Outlooks on classes E-RR, F-RR and G-RR may be
    revised back to Stable should the performance of the specially
    serviced loans and/or FLOCs improve, property valuations
    improve and recoveries are better than expected, or workout
    plans of the specially serviced loans and/or properties
    impacted by the pandemic stabilize once the pandemic is over.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- Downgrades to the senior classes, rated 'AAAsf' through 'A
    sf', are not likely given the high credit enhancement and
    scheduled amortization but are possible if a significant
    proportion of the pool defaults.

-- Downgrades to the classes rated 'Bsf' and below would occur if
    the performance of the FLOCs and/or specially serviced loans
    continues to decline or fails to stabilize.

-- Additionally, further Outlook revisions and downgrades to
    classes E-RR, F-RR and G-RR could occur.

-- In addition to its baseline scenario, Fitch also envisions a
    downside scenario where the health crisis is prolonged beyond
    2021. Should this scenario play out, downgrades to the senior
    classes could occur and classes with Negative Outlooks could
    be downgraded one or more categories.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

ESG CONSIDERATIONS

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


WILLIS ENGINE V: Fitch Affirms BB Rating on Series C Notes
----------------------------------------------------------
Fitch Ratings has affirmed the ratings on the outstanding series A
and B fixed rate notes issued by Willis Engine Structured Trust III
(WEST III) and Willis Engine Structured Trust IV (WEST IV), and
affirmed the series A, B and C fixed-rate notes issued by Willis
Engine Structured Trust V (WEST V). Fitch maintained the Negative
Rating Outlook on all series of notes.

       DEBT                         RATING            PRIOR
       ----                         ------            -----
Willis Engine Structured Trust III

Series A 2017-A 97063QAA0     LT  A-sf   Affirmed      A-sf
Series B 2017-A 97063QAB8     LT  BBB-sf Affirmed      BBB-sf

Willis Engine Structured Trust IV

Series A 97064EAA6            LT  Asf    Affirmed      Asf
Series B 97064EAC2            LT  BBBsf  Affirmed      BBBsf

Willis Engine Securitization Trust V

Series A 97064FAA3            LT  Asf    Affirmed      Asf
Series B 97064FAB1            LT  BBBsf  Affirmed      BBBsf
Series C 97064FAC9            LT  BBsf   Affirmed      BBsf

TRANSACTION SUMMARY

The rating actions reflect ongoing deterioration of all airline
lessee credits backing the leases in each transaction, downward
pressure on certain engine values, Fitch's updated assumptions and
stresses, and resulting impairments to modeled cash flows and
coverage levels.

The Negative Outlooks on all series of notes reflects Fitch's base
case expectation for the structures to withstand immediate and
near-term stresses at the updated assumptions and stressed
scenarios commensurate with their respective ratings. Furthermore,
additional global travel restrictions and recent regional spikes in
coronavirus cases, as currently seen in European countries and
across many U.S. states and other countries globally, could result
in additional delays in recovery of the airline industry.

This is a further credit negative for aircraft engine ABS and will
only place greater pressure on airlines globally and may lead to
additional near-term lease deferrals, airline defaults, lower
engine demand and value impairments. Ultimately, these negative
factors could manifest in the transactions, resulting in lower cash
flows and pressure on ratings.

Fitch updated rating assumptions for both rated and non-rated
airlines with a vast majority of ratings moving lower, which was a
key driver of these rating actions along with modeled cash flows.
This was driven by the current global recessionary environment,
ongoing sector stress with a slow recovery, and resulting impact on
airline lessees in each pool. Recessionary timing was assumed to
start immediately. This scenario stresses airline credits, asset
values and lease rates while incurring remarketing and repossession
costs and downtime at each relevant rating stress level.

Willis Lease Finance Corp. (WLFC, not rated [NR] by Fitch) acts as
sponsor, servicer and administrative agent to the aircraft engine
ABS transaction. Fitch believes WLFC is an adequate servicer to
service these transactions based on its experience as a lessor, and
overall servicing capabilities of its owned and managed portfolio
including prior ABS transactions.

KEY RATING DRIVERS

Deteriorating Airline Lessee Credit

The credit profiles of the airline lessees in the pools remain
under stress or have deteriorated further due to the
coronavirus-related impact on all global airlines, resulting in
lower rating assumptions for lessees utilized for this review. The
proportion of the WEST III pool assumed a 'CCC' Issuer Default
Rating (IDR) and below was relatively stable at 48.8% for this
review, versus 51.9% previously. For WEST IV, this concentration is
47.4% versus 59.4% in the prior review, and for WEST V is 33.7%
versus 28.8% in prior review. The concentration of off-lease
engines increased to 27.5%, 29.8% and 19.9% in each transaction,
respectively.

The assumptions are reflective of these airlines' ongoing credit
profiles and fleets in the current operating environment, due to
the continued coronavirus-related impact on the sector. Any
publicly rated airlines in the pool whose ratings have shifted have
been updated.

Asset Quality and Appraised Pool Value:

All three pools feature mostly in-demand engines that support
mostly narrowbody (NB) airframes.

The appraisers are AVITAS, Inc. (Avitas) and IBA Group Limited
(IBA). WEST III and IV also include BK Associates Inc. (BK), and
WEST V utilizes morten beyer & agnew Inc. (mba). All three
transactions' most recent appraisal date was in December 2019. The
transaction document values are $351.4 million for WEST III, $418.5
million for WEST IV and $421.5 million for WEST V.

Fitch utilized the minimum of half-life base values (HLBV) for WEST
III, and the average excluding highest value (AEH) HLBV for WEST IV
and V, with additional haircuts applied thereon. This resulted in
modeled values of $314.7 million for WEST III, $366.4 million for
WEST IV, and $336.6 million for WEST V, approximately 10.4%, 12.4%
and 20.1% lower, respectively, versus the transaction values.

Transaction Performance:

Lease collections have fluctuated since March 2020 trending notably
lower for all transactions. As of the most recent report, WEST III
received $2.2 million in basic rent compared with average monthly
collections of $1.8 million over the last six months; WEST IV
received $3.3 million in basic rent compared with an average
monthly receipt of $2.6 million over the last six months; and WEST
V received $2.8 million in basic rent compared with an average
monthly receipt of $2.5 million over the last six months. WEST III,
IV and V have received sizable excess proceeds payments from
lessees in recent payment periods. Loan-to-values (LTV) continue to
increase since closing, based on the updated Fitch LTVs.

All senior notes continue to receive interest payments through the
current period. For WEST III and IV, series A and series B
principal were paid according to schedule. For WEST V, series A, B
and C principal was also paid according to schedule. The
debt-service coverage ratios (DSCRs) remains above the respective
cash trap triggers.

Fitch Modeling Assumptions:

Nearly all servicer-driven assumptions are consistent from closing
for each transaction. These include costs and downtime assumptions
relating to engine repossessions and remarketing, terms of new
leases, and extension terms.

For any leases whose maturities are up in two years, or whose
lessee credit ratings are below 'CCC', Fitch assumed an additional
three-month downtime at lease end, on top of lessor-specific
remarketing downtime assumptions, to account for potential
remarketing challenges in placing assets with a new lessee in the
current distressed environment.

With the grounding of global fleets and significant reduction in
air travel, maintenance revenue and costs will be affected and are
expected to decline due to airline lessee credit issues and
grounded aircraft. Maintenance revenues were reduced by 50% over
the next immediate 12 months, and such missed payments were assumed
to be recouped in the following 12 months thereafter.

Maintenance costs over the immediate next six months were assumed
to be incurred as reported. Costs in the following month were
reduced by 50% and assumed to increase straight line to 100% over a
12-month period. Any deferred costs were incurred in the following
12 months.

RATING SENSITIVITIES

The Negative Outlooks on the WEST transactions reflect the
potential for further negative rating actions due to concerns over
the ultimate impact of the coronavirus pandemic, the resulting
concerns associated with airline performance and engine values, and
other assumptions across the aviation industry due to the severe
decline in travel and grounding of airlines.

At close, Fitch conducted multiple rating sensitivity analyses to
evaluate the impact of changes to a number of the variables in the
analysis. The performance of engine lease securitizations is
affected by various factors, which, in turn, could have an impact
on the assigned ratings. Due to the correlation between global
economic conditions and the airline industry, the ratings can be
affected by the strength of the macro-environment over the
remaining term of this transaction.

In the initial rating analysis, Fitch found the transactions to
exhibit sensitivity to the timing and severity of assumed
recessions. Fitch also found that greater default probability of
the leases has a material impact on the ratings. Furthermore, the
timing and degree of technological advancement in the commercial
aviation space, and the resulting impact on engine values, lease
rates and utilization would have a moderate impact on the ratings.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- The aviation ABS sector has a rating cap of 'Asf'. All
    subordinate tranches carry one category of ratings lower than
    the senior tranche, and remain at or below the initial
    ratings. At this point, future upgrades beyond current ratings
    would not be considered due to a combination of the sector
    rating cap, industry cyclicality, weaker lessee mix present in
    ABS pools and uncertainty around future lessee mix, along with
    the negative impact due to the coronavirus on the global
    travel.

-- Fitch explored a scenario in which the transactions received
    higher residual proceeds at the time of sale. For WEST III,
    strong residual values alone would not be sufficient to
    improve the ratings. However, if the transaction experiences
    stronger residual value realization than what was modeled by
    Fitch, coupled with stronger asset values, this results in
    improved modeling scenarios.

-- For this scenario in WEST IV and V, net cash flows improve
    across rating stress levels, but would not result in a rating
    impact.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- Softening in engine values could lead to downward rating
    action. Fitch explored the potential cash flow decline if all
    asset values declined further by 5% from Fitch's modeled
    values for this review across all three transactions.

-- Net cash flow declined by approximately $20-25 million across
    rating stress levels. Under this scenario, WEST III and IV
    could experience further category downgrades for each series
    of notes. For WEST V, this scenario does not suggest downward
    rating migration, but could result in negative rating action
    in conjunction with other factors in a weaker environment.

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Structured Finance
transactions have a best-case rating upgrade scenario (defined as
the 99th percentile of rating transitions, measured in a positive
direction) of seven notches over a three-year rating horizon; and a
worst-case rating downgrade scenario (defined as the 99th
percentile of rating transitions, measured in a negative direction)
of seven notches over three years. The complete span of best- and
worst-case scenario credit ratings for all rating categories ranges
from 'AAAsf' to 'Dsf'. Best- and worst-case scenario credit ratings
are based on historical performance.

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

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

ESG CONSIDERATIONS

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


                            *********

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