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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, October 16, 2022, Vol. 26, No. 288

                            Headlines

BATTERY PARK II: S&P Assigns Prelim BB- (sf) Rating on Cl. E Notes
CHASE AUTO 2021-3: Moody's Upgrades Rating on Class F Notes to Ba3
CHL MORTGAGE 2003-49: Moody's Cuts Ratings on 2 Tranches to B2
COLT 2022-8: Fitch Assigns 'Bsf' Rating on Class B2 Certs
COMM 2013-CCRE7: Moody's Lowers Rating on Cl. E Certs to B3

COMM 2018-HCLV: S&P Lowers Class F Notes Rating to 'CCC (sf)'
CWABS 2007-13: Moody's Hikes Rating on Class 1-A Debt to 'B2'
EXETER AUTOMOBILE 2022-5: Fitch Gives 'BB(EXP)sf' Rating on E Debt
EXETER AUTOMOBILE 2022-5: S&P Assigns Prelim BB Rating on E Notes
GOODLEAP 2022-4: S&P Assigns Prelim BB+ (sf) Rating on Cl. C Notes

HALCYON LOAN 2013-2: Moody's Cuts Rating on Class D Notes to 'Caa3'
JP MORGAN 2018-PHH: Moody's Lowers Rating on Cl. E Certs to B3
JP MORGAN 2019-LTV3: Moody's Ups Rating on Cl. B-4 Bonds From Ba1
MARINER FINANCE 2022-A: S&P Assigns Prelim 'BB-' Rating on D Notes
MFA 2022-INV3: S&P Assigns B+ (sf) Rating on Class B-2 Certs

MONROE CAPITAL XIV: Moody's Gives (P)Ba3 Rating to $32.5MM E Notes
NEWSTAR FAIRFIELD: Fitch Affirms 'BB-sf' Rating on Cl. D-N Notes
OCEANVIEW MORTGAGE 2022-1: Moody's Gives (P)B3 Rating to B-5 Debt
PALISADES CENTER 2016-PLSD: S&P Cuts Class A Notes Rating to 'BB'
PENNANTPARK CLO V: S&P Assigns Prelim 'BB-' Rating on Cl. E Notes

PFP LTD 2022-9: Fitch Assigns 'B-sf' Rating on Class G Notes
PRESTIGE AUTO 2022-1: S&P Assigns Prelim BB-(sf) Rating on E Notes
RAD CLO 17: Fitch Assigns 'BB-(EXP)sf' Rating on Class E Notes
SANTANDER CONSUMER 2021-A: Fitch Affirms 'B' Rating on Cl. F Notes
SIERRA TIMESHARE 2022-3: Fitch Gives BB-(EXP) Rating on Cl. D Notes

SIERRA TIMESHARE 2022-3: S&P Assigns Prelim BB- Rating on D Notes
UBS COMMERCIAL 2017-C7: Fitch Affirms 'B-sf' Rating on G-RR Certs
UBS-BARCLAYS 2012-C2: Moody's Lowers Rating on Cl. EC Certs to B3
UBS-BARCLAYS 2013-C6: Moody's Lowers Rating on Cl. C Certs to B1
[*] Moody's Takes Action on $179MM of US RMBS Issued 2002-2007

[*] Moody's Takes Action on $36.7MM of US RMBS Issued 2003-2005
[*] S&P Takes Various Actions on 59 Classes From 34 U.S. RMBS Deals
[*] S&P Takes Various Actions on 76 Classes from 21 US RMBS Deals

                            *********

BATTERY PARK II: S&P Assigns Prelim BB- (sf) Rating on Cl. E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Battery Park
CLO II Ltd./Battery Park CLO II LLC's fixed- and floating-rate
notes.

The note issuance is a CLO securitization governed by investment
criteria and backed primarily by broadly syndicated
speculative-grade (rated 'BB+' or lower) senior secured term loans.
The transaction is managed by Goldman Sachs Asset Management L.P.

The preliminary ratings are based on information as of Oct. 6,
2022. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The diversification of the collateral pool;

-- The credit enhancement provided through subordination, excess
spread, and overcollateralization;

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

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

  Preliminary Ratings Assigned

  Battery Park CLO II Ltd./Battery Park CLO II LLC

  Class A-1, $244.00 million: AAA (sf)
  Class A-2, $10.00 million: AAA (sf)
  Class B-1, $40.00 million: AA (sf)
  Class B-2, $10.00 million: AA (sf)
  Class C (deferrable), $22.00 million: A (sf)
  Class D (deferrable), $20.00 million: BBB- (sf)
  Class E (deferrable), $15.00 million: BB- (sf)
  Subordinated notes, $40.66 million: Not rated



CHASE AUTO 2021-3: Moody's Upgrades Rating on Class F Notes to Ba3
------------------------------------------------------------------
Moody's Investors Service has upgraded 13 classes of notes issued
by seven prime auto securitizations. The notes are backed by pools
of retail automobile loan contracts originated and serviced by
multiple parties. Chase Auto Credit Linked Notes, Series 2021-3
(CACLN 2021-3) transfers credit risk to noteholders through a
hypothetical tranched credit default swap on a reference pool of
auto loans.

The complete rating actions are as follows:

Issuer: Ally Auto Receivables Trust 2019-4

Class D Notes, Upgraded to Aaa (sf); previously on Sep 14, 2021
Upgraded to Aa1 (sf)

Issuer: Canadian Pacer Auto Receivables Trust 2020-1

Class C Notes, Upgraded to Aa1 (sf); previously on May 6, 2022
Upgraded to Aa2 (sf)

Issuer: Capital One Prime Auto Receivables Trust 2021-1

Class B Notes, Upgraded to Aaa (sf); previously on May 16, 2022
Upgraded to Aa1 (sf)

Class C Notes, Upgraded to Aa2 (sf); previously on May 16, 2022
Upgraded to Aa3 (sf)

Class D Notes, Upgraded to A2 (sf); previously on May 16, 2022
Upgraded to A3 (sf)

Issuer: CarMax Auto Owner Trust 2021-3

Class C Asset-backed Notes, Upgraded to Aa2 (sf); previously on Apr
11, 2022 Upgraded to Aa3 (sf)

Issuer: CarMax Auto Owner Trust 2021-4

Class B Asset-backed Notes, Upgraded to Aaa (sf); previously on Apr
11, 2022 Upgraded to Aa1 (sf)

Issuer: CarMax Auto Owner Trust 2022-1

Class B Asset-backed Notes, Upgraded to Aa1 (sf); previously on Jan
26, 2022 Definitive Rating Assigned Aa2 (sf)

Class C Asset-backed Notes, Upgraded to A1 (sf); previously on Jan
26, 2022 Definitive Rating Assigned A2 (sf)

Issuer: Chase Auto Credit Linked Notes, Series 2021-3

Class C Notes, Upgraded to A1 (sf); previously on Sep 20, 2021
Definitive Rating Assigned A2 (sf)

Class D Notes, Upgraded to A3 (sf); previously on Sep 20, 2021
Definitive Rating Assigned Baa2 (sf)

Class E Notes, Upgraded to Baa3 (sf); previously on Sep 20, 2021
Definitive Rating Assigned Ba2 (sf)

Class F Notes, Upgraded to Ba3 (sf); previously on Sep 20, 2021
Definitive Rating Assigned B2 (sf)

RATINGS RATIONALE

The rating actions are primarily driven by the buildup of credit
enhancement due to structural features including a sequential pay
structure, non-declining reserve account and overcollateralization.
For CACLN 2021-3, the rating actions are primarily driven by
increasing subordination.

Moody's lifetime cumulative net loss expectations are noted below
for the transaction pools. The loss expectations reflect updated
performance trends on the underlying pools.

Ally Auto Receivables Trust 2019-4: 0.70%

Canadian Pacer Auto Receivables Trust 2020-1: 0.40%

Capital One Prime Auto Receivables Trust 2021-1: 0.35%

CarMax Auto Owner Trust 2021-3: 2.25%

CarMax Auto Owner Trust 2021-4: 2.25%

CarMax Auto Owner Trust 2022-1: 2.25%

Chase Auto Credit Linked Notes, Series 2021-3: 0.30%

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Auto Loan- and Lease-Backed ABS" published in
July 2022.

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

Up

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

Down

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


CHL MORTGAGE 2003-49: Moody's Cuts Ratings on 2 Tranches to B2
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of four bonds
from one US residential mortgage-backed transactions (RMBS), backed
by prime jumbo mortgages issued by CHL Mortgage Pass-Through Trust
2003-49.

A list of Affected Credit Ratings is available at
https://bit.ly/3etFNmw

Complete rating actions are as follows:

Issuer: CHL Mortgage Pass-Through Trust 2003-49

Cl. A-8-A, Downgraded to Ba3 (sf); previously on May 26, 2020
Downgraded to Ba1 (sf)

Cl. A-8-B, Downgraded to B2 (sf); previously on May 26, 2020
Downgraded to Ba3 (sf)

Cl. A-9, Downgraded to B1 (sf); previously on May 26, 2020
Downgraded to Ba2 (sf)

Cl. M, Downgraded to B2 (sf); previously on Mar 16, 2018 Downgraded
to Ba3 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance as well as
Moody's updated loss expectation on the underlying pool. The rating
downgrades are primarily due to a decline in credit enhancement
available to the bonds.

In light of the current macroeconomic environment, Moody's revised
loss expectations based on forecast uncertainties. Moody's rating
actions also take into consideration the buildup in credit
enhancement of the bonds, which has helped offset the impact of the
increase in expected losses.

Moody's estimated the proportion of loans granted payment relief in
a pool based on a review of loan level cashflows. In Moody's
analysis, Moody's considered a loan to be enrolled in a payment
relief program if (1) the loan was not liquidated but took a loss
in the reporting period (to account for loans with monthly
deferrals that were reported as current), or (2) the actual balance
of the loan increased in the reporting period, or (3) the actual
balance of the loan remained unchanged in the last and current
reporting period, excluding interest-only loans and pay ahead
loans. Based on Moody's analysis, the proportion of borrowers that
are currently enrolled in payment relief plans varied greatly,
ranging between approximately 2% and 11% among RMBS transactions
issued before 2009. In Moody's analysis, Moody's assume these loans
to experience lifetime default rates that are 50% higher than
default rates on the performing loans.

In addition, for borrowers unable to make up missed payments
through a short-term repayment plan, servicers will generally defer
the forborne amount as a non-interest-bearing balance, due at
maturity of the loan as a balloon payment. Moody's analysis
considered the impact of six months of scheduled principal payments
on the loans enrolled in payment relief programs being passed to
the trust as a loss. The magnitude of this loss will depend on the
proportion of the borrowers in the pool subject to principal
deferral and the number of months of such deferral. The treatment
of deferred principal as a loss is credit negative for junior
bonds, which could incur write-downs on bonds when missed payments
are deferred.

Principal Methodologies

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in July 2022.

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 of the subordinate bonds up. Losses could decline from
Moody's original expectations as a result of a lower number of
obligor defaults or appreciation in the value of the mortgaged
property securing an obligor's promise of payment. Transaction
performance also depends greatly on the US macro economy and
housing market.

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 expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions. In addition, improvements in
reporting formats and data availability across deals and trustees
may provide better insight into certain performance metrics such as
the level of collateral modifications.


COLT 2022-8: Fitch Assigns 'Bsf' Rating on Class B2 Certs
---------------------------------------------------------
Fitch Ratings has assigned final ratings to the residential
mortgage-backed certificates to be issued by COLT 2022-8 Mortgage
Loan Trust (COLT 2022-8).

   Debt            Rating             Prior
   ----            ------             -------

COLT 2022-8

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

TRANSACTION SUMMARY

The certificates are supported by 553 non-prime loans with a total
balance of approximately $298 million as of the cut-off date. Loans
in the pool were originated by multiple originators, including
Sprout Mortgage, Northpointe Bank and others. The loans were
aggregated by Hudson Americas L.P. The loans are currently serviced
by Select Portfolio Servicing, Inc. (SPS) or Northpointe Bank.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): Due to Fitch's updated
view on sustainable home prices, Fitch views the home price values
of this pool as 10.2% above a long-term sustainable level (versus
11.0% on a national level as of 1Q22, up 1.8% since last quarter).
Underlying fundamentals are not keeping pace with the growth in
prices, resulting from a supply/demand imbalance driven by low
inventory, favorable mortgage rates and new buyers entering the
market. These trends have led to significant home price increases
over the past year, with home prices rising 18.0% yoy nationally as
of June 2022.

Non-QM Credit Quality (Negative): The collateral consists of 553
loans, totaling $298 million and seasoned approximately three
months in aggregate. The borrowers have a moderate credit profile
— 731.2 model FICO and 43% model debt-to-income ratio (DTI) —
and leverage — 83.8% sustainable loan-to-value ratio (sLTV) and
75.5% combined LTV (cLTV). The pool consists of 59.5% of loans
where the borrower maintains a primary residence, while 36.7%
comprise an investor property. Additionally, 63.2% are nonqualified
mortgage (non-QM); the QM rule does not apply to the remainder.

Fitch's expected loss in the 'AAAsf' stress is 25%. This is mostly
driven by the non-QM collateral and the significant investor cash
flow product concentration.

Loan Documentation (Negative): Approximately 81.6% of the loans in
the pool were underwritten to less than full documentation and
50.7% were underwritten to a bank statement program for verifying
income, which is not consistent with Appendix Q standards and
Fitch's view of a full documentation program.

A key distinction between this pool and legacy Alt-A loans is that
these loans adhere to underwriting and documentation standards
required under the Consumer Financial Protections Bureau's (CFPB)
Ability to Repay (ATR) Rule (ATR Rule, or the Rule), which reduces
the risk of borrower default arising from lack of affordability,
misrepresentation or other operational quality risks due to rigor
of the Rule's mandates with respect to the underwriting and
documentation of the borrower's ATR.

Fitch's treatment of alternative loan documentation increased the
'AAAsf' expected loss by 625 bps relative to a fully documented
loan.

High Percentage of DSCR Loans (Negative): There are 215 debt
service coverage ratio (DSCR) products in the pool (39% by loan
count). These business purpose loans are available to real estate
investors that are qualified on a cash flow basis, rather than DTI,
and borrower income and employment are not verified. Compared with
standard investment properties for DSCR loans, Fitch converts the
DSCR values to a DTI and treats as low documentation.

Fitch's expected loss for these loans is 38.1% in the 'AAAsf'
stress, which is driving the higher pool expected losses due to the
27.5% WA concentration.

Modified Sequential-Payment Structure with Limited Advancing
(Mixed): The structure distributes principal pro rata among the
senior certificates while shutting out the subordinate bonds from
principal until all senior classes are reduced to zero. If a
cumulative loss trigger event, delinquency trigger event or credit
enhancement (CE) trigger event occurs in a given period, principal
will be distributed sequentially to class A-1, A-2 and A-3
certificates until they are reduced to zero.

Advances of delinquent principal and interest (P&I) will be made on
the mortgage loans for the first 180 days of delinquency, to the
extent such advances are deemed recoverable. If the P&I advancing
party fails to make a required advance, the master servicer and
then securities administrator will be obligated to make such
advance.

The limited advancing reduces loss severities, as a lower amount is
repaid to the servicer when a loan liquidates and liquidation
proceeds are prioritized to cover principal repayment over accrued
but unpaid interest. The downside to this is the additional stress
on the structure, as there is limited liquidity in the event of
large and extended delinquencies.

COLT 2022-8 has a step-up coupon for the senior classes (A-1, A-2
and A-3). After four years, the senior classes pay the lesser of a
100-bp increase to the fixed coupon or the net weighted average
coupon (WAC) rate. Fitch expects the senior classes to be capped by
the Net WAC. Additionally, after the step-up date, the unrated
class B-3 interest allocation goes toward the senior cap carryover
amount for as long as the senior classes are outstanding. This
increases the P&I allocation for the senior classes.

RATING SENSITIVITIES

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

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper market value declines (MVDs) than
assumed at the MSA level. Sensitivity analysis was conducted at the
state and national level to assess the effect of higher MVDs for
the subject pool as well as lower MVDs, illustrated by a gain in
home prices.

The 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 41.7% 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 positive
rating action/upgrade:

Fitch incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper MVDs than assumed at the MSA level.
Sensitivity analysis was conducted at the state and national level
to assess the effect of higher MVDs for the subject pool as well as
lower MVDs, illustrated by a gain in home prices.

The defined positive rating sensitivity analysis demonstrates how
the ratings would react to positive home price growth of 10% with
no assumed overvaluation. 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 assigned
'AAAsf' ratings.

SUMMARY OF FINANCIAL ADJUSTMENTS

International scale credit ratings for 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.

DATA ADEQUACY

Fitch also utilized data files that were made available by the
issuer on its SEC Rule 17g-5 designated website. The loan-level
information Fitch received was provided in the American
Securitization Forum's data layout format.

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 2013-CCRE7: Moody's Lowers Rating on Cl. E Certs to B3
-----------------------------------------------------------
Moody's Investors Service has affirmed the ratings on ten classes
and downgraded the ratings on two classes in COMM 2013-CCRE7
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2013-CCRE7, as follows:

Cl. A-4, Affirmed Aaa (sf); previously on Jul 8, 2020 Affirmed Aaa
(sf)

Cl. A-M, Affirmed Aaa (sf); previously on Jul 8, 2020 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Jul 8, 2020 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa3 (sf); previously on Jul 8, 2020 Affirmed Aa3
(sf)

Cl. C, Affirmed A3 (sf); previously on Jul 8, 2020 Affirmed A3
(sf)

Cl. D, Affirmed Ba2 (sf); previously on Jul 8, 2020 Affirmed Ba2
(sf)

Cl. E, Downgraded to B3 (sf); previously on Jul 8, 2020 Confirmed
at B1 (sf)

Cl. F, Downgraded to Caa2 (sf); previously on Jul 8, 2020 Confirmed
at B3 (sf)

Cl. G, Affirmed Caa3 (sf); previously on Jul 8, 2020 Confirmed at
Caa3 (sf)

Cl. PEZ, Affirmed Aa3 (sf); previously on Jul 8, 2020 Affirmed Aa3
(sf)

Cl. X-A*, Affirmed Aaa (sf); previously on Jul 8, 2020 Affirmed Aaa
(sf)

Cl. X-B*, Affirmed A2 (sf); previously on Jul 8, 2020 Affirmed A2
(sf)

*Reflects Interest-Only Classes

RATINGS RATIONALE

The ratings on six principal and interest (P&I) classes were
affirmed because of their credit support and the transaction's key
metrics, including Moody's loan-to-value (LTV) ratio and Moody's
stressed debt service coverage ratio (DSCR) are within acceptable
ranges. These classes will also benefit from principal paydowns as
the remaining loans approach their maturity dates and defeased
loans now represent 40% of the pool.

The ratings on two P&I classes were downgraded due to higher
anticipated losses and the potential refinance challenges for
certain poorly performing loans with upcoming maturity dates on or
before April 2023. The largest loan (Lakeland Square Mall - 13% of
the pool) is secured by a regional mall that has exhibited
declining performance in recent years and matures in April 2023.
Furthermore, one specially serviced loan (5.8% of the pool) is
undergoing the foreclosure process.  Additionally, if certain loans
are unable to pay off at their upcoming maturity dates, the
outstanding classes may face increased interest shortfall risk.

The rating on one P&I class was affirmed because the rating is
consistent with Moody's expected loss.

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

The rating on the exchangeable class was affirmed based on the
credit quality of its referenced exchangeable classes.

Moody's regard e-commerce competition as a social risk under
Moody's ESG framework. The rise in e-commerce and changing consumer
behavior presents challenges to brick-and-mortar discretionary
retailers.

Moody's rating action reflects a base expected loss of 7.8% of the
current pooled balance, compared to 6.0% at Moody's last review.
Moody's base expected loss plus realized losses is now 4.9% of the
original pooled balance, compared to 4.1% at the last review.


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

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range can
indicate that the collateral's credit quality is stronger or weaker
than Moody's had previously expected. Additionally, significant
changes in the 5-year rolling average of 10-year US Treasury rates
will impact the magnitude of the interest rate adjustment and may
lead to future rating actions.

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except interest-only
classes were "US and Canadian Conduit/Fusion Commercial
Mortgage-Backed Securitizations Methodology" published in July
2022.

DEAL PERFORMANCE

As of the September 12, 2022 distribution date, the transaction's
aggregate certificate balance has decreased by 53% to $438.3
million from $936.2 million at securitization. The certificates are
collateralized by 43 mortgage loans ranging in size from less than
1% to 13% of the pool, with the top ten loans (excluding
defeasance) constituting 44% of the pool. Eighteen loans,
constituting 40% of the pool, have defeased and are secured by US
government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 11, compared to 18 at Moody's last review.

As of the September remittance report, except the specially
serviced loan, all loans were current on their debt service
payments.

Seven loans, constituting 18% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $11.9 million (for an average loss
severity of 28%). There is currently one loan in special servicing,
the 20 Church Street Loan ($25.3 million – 5.8% of the pool),
which is secured by a 419,000 square feet (SF) Class A-/B+ office
tower located in the CBD of Hartford, Connecticut. The loan was
transferred to special servicing in March 2022 due to payment
default. As of March 2022, the property was 79% leased, compared to
87% as of December 2020, 94% as of December 2019, and 98% as of
September 2018. Special servicer commentary indicates a foreclosure
action has been filed on this loan.

Moody's has also assumed a high default probability for one poorly
performing loan, the Lakeland Square Mall Loan ($57.0 million –
13.0% of the pool), which is secured by a 535,937 SF component of
an 883,290 SF regional mall located in Lakeland, Florida,
approximately 35 miles east of Tampa. At securitization, the
property was anchored by Dillard's(non-collateral), J.C. Penney,
Macy's(non-collateral), and Sears(non-collateral). Macy's and Sears
closed their stores at this location in 2017 and 2018,
respectively. Junior anchors Sports Authority vacated its space in
late 2016, but was subsequently backfilled by a 42,000 SF Urban Air
Adventure Park. Another junior anchor Burlington Stores (formerly
known as Burlington Coat Factory) recently announced the relocation
of their current store at this location to a shopping center
nearby. As of June 2022, the collateral was 93% leased, however the
collateral will be only 78% leased excluding the Burlington Stores
lease. Additionally, the mall saw a decline in its inline occupancy
to 87% as of June 2022 from 92% as of March 2020. The mall also
faces direct competition from a lifestyle center built in 2006,
located in the affluent, southern section of the trade area,
approximately 10 miles from the subject property. The mall's
reported 2020 and 2021 NOIs saw a decrease of 6% and 14%,
respectively, from the 2019 NOI.  Due to the decline in its
performance in recent years and the vacant anchor and junior anchor
spaces, the loan faces heightened refinance risk at the loan's
April 2023 maturity date.

Moody's has estimated an aggregate loss of $30 million (a 37%
expected loss) from the specially serviced loan and troubled loan.

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
adjust the MLTV for each loan using a value that reflects
capitalization (cap) rates that are between Moody's 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.

Moody's received full year 2021 operating results for 100% of the
pool, and partial year 2022 operating results for 71% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 94%, compared to 101% at Moody's last
review. Moody's conduit component excludes loans with structured
credit assessments, defeased and CTL loans, and specially serviced
and troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 22% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 10.4%.

Moody's actual and stressed conduit DSCRs are 1.48X and 1.27X,
respectively, compared to 1.55X and 1.19X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 13% of the pool balance. The
largest loan is the PNC Center Loan ($26.7 million – 6.1% of the
pool), which is secured by a 22-story, Class A-/B+ office building
now known as 20 Stanwix, located in the "Golden Triangle" submarket
within the CBD of Pittsburgh, Pennsylvania. While the property had
experienced a low occupancy of around 60% between 2018 and 2020
primarily as a result of the departure of the largest tenant (32.5%
of the net rentable area (NRA)) at their lease expiration date in
December 2017, the property's occupancy bounced back to 84% as of
May 2022 because of several new leases that commenced in 2021.  The
property still faces near-term rollover risk as the 3rd and 4th
largest tenants that occupy a combined 16% of the NRA have their
scheduled lease expirations in 2023. The loan benefits from
amortization and has amortized nearly 17% since securitization.
Moody's LTV and stressed DSCR are 128% and 0.84X, respectively.

The second largest loan is the 171 & 175 Madison Avenue Loan ($16.0
million – 3.7% of the pool), which is secured by a pre-war
16-story plus penthouse class B office building (171 Madison) with
one ground floor retail space, and a 5-story residential apartment
building (175 Madison) with one ground floor retail space located
in Manhattan, New York. The property was 89% leased as of March
2022, compared to 87% as of December 2020 and 97% as of December
2019. The loan benefits from amortization and has amortized nearly
20% since securitization. Moody's LTV and stressed DSCR are 66% and
1.48X.

The third largest loan is the 6800 Hollywood Boulevard Loan ($14.8
million – 3.4% of the pool), which is secured by a 35,574 SF
mixed use property located in Los Angeles, California. The property
is located at one of the busiest intersections in Hollywood and in
the heart of one of the main tourist areas of Los Angeles. As of
June 2022, the property was 100% leased, unchanged from prior
reviews. The loan benefits from amortization and has amortized over
18% since securitization. Moody's LTV and stressed DSCR are 103%
and 1.02X, respectively.


COMM 2018-HCLV: S&P Lowers Class F Notes Rating to 'CCC (sf)'
-------------------------------------------------------------
S&P Global Ratings lowered its ratings on two classes of commercial
mortgage pass-through certificates from COMM 2018-HCLV Mortgage
Trust, a U.S. CMBS transaction. At the same time, S&P affirmed its
ratings on four other classes from the same transaction.

This U.S. CMBS transaction is backed by a floating-rate,
interest-only (IO) mortgage loan secured by Hughes Center, a
68-acre, mixed-use campus consisting of 10 class-A suburban office
buildings (1.4 million sq. ft.) and 10 unanchored retail buildings
(111,000 sq. ft.) located in Las Vegas.

Rating Actions

S&P said, "The downgrades on the class E and F certificates and
affirmations on the class A, B, C, and D certificates reflect our
re-evaluation of Hughes Center, which secures the sole loan in the
transaction. Our current analysis considers the property's
declining net cash flow (NCF) in the past three-plus years, as
reported by the servicer, driven primarily by escalating operating
expenses and relatively flat revenues.

"While the servicer-reported occupancy and revenues have remained
relatively stable and comparable to our assumed levels at issuance
(72.4% and $43.1 million, respectively): 74.0% and $41.6 million in
2019; 77.0% and $41.3 million in 2020; 74.0% and $40.8 million in
2021; and 74.0% and $42.5 million for the trailing-12-months (TTM)
ending June 30, 2022, increases in operating expenses exceeded our
expectations. Reported operating expenses were $20.8 million in
2019; $22.9 million in 2020; $23.5 million in 2021; and $24.3
million as of TTM ending June 30, 2022, compared with our assumed
expenses of $16.9 million at issuance. As a result, the
servicer-reported NCF of $18.6 million in 2019, $16.3 million in
2020, $15.2 million in 2021, and $16.0 million as of TTM ending
June 30, 2022, is below the $22.9 million NCF that we derived at
issuance.

"Our current property-level analysis considers these factors, as
well as the servicer-provided March 2022 rent roll and the
borrower's 2022 budget. Therefore, we revised and lowered our
long-term sustainable NCF to $20.2 million, which is 12.0% lower
than the NCF we derived at issuance and 25.9% above the
servicer-reported NCF as of the TTM ending June 30, 2022. Using an
8.00% S&P Global Ratings' capitalization rate (unchanged from
issuance), we arrived at an S&P Global Ratings' expected case value
of $253.8 million or $169 per sq. ft., down 12.2% from our issuance
value of $288.9 million. This yielded an S&P Global Ratings'
loan-to-value (LTV) ratio of 128.1% on the trust balance, compared
with 112.5% at issuance."

Although the model-indicated ratings were lower than the current
ratings for the class A, B, C, and D certificates, S&P affirmed its
ratings on these classes because S&P weighed certain qualitative
considerations, including:

-- The potential that the property's operating performance could
improve above our revised expectations;

-- The significant market value decline that would be needed
before these classes experiences principal losses;

-- The liquidity support provided in the form of servicer
advancing; and

-- The relative position of the classes in the payment waterfall.

S&P said, "In addition, the downgrade on the class F certificate to
'CCC (sf)' from 'B- (sf)' reflects our view that, based on an S&P
Global Ratings' LTV ratio over 100% on the loan, this class is more
susceptible to reduced liquidity support and exhibits an elevated
risk of default and loss due to current market conditions.

"If the property's performance does not improve or if there are
reported negative changes in the performance beyond what we have
already considered, we may revisit our analysis and adjust our
ratings further, as necessary."

Property-Level Analysis

Hughes Center is a 68-acre, mixed-use campus consisting of 10
class-A suburban office buildings (1.4 million sq. ft.) and 10
unanchored retail buildings (111,000 sq. ft.) located in the
Central East Las Vegas office submarket of Las Vegas. The property
was built in stages from 1986 to 2017 and is located near the Sands
Expo Center, the Las Vegas Convention Center, and the McCarran
Airport.

Eight of the 10 retail buildings totaling 92,690 sq. ft. are
subject to or partially subject to a ground lease with FC Income
Properties LLC, as ground lessor, and the borrower (loan sponsors
are affiliates of Blackstone Real Estate Group), as ground lessee.
The ground lease commenced on July 1, 1999, and expires on June 30,
2059, with three, five-year extension options for a fully extended
expiration date in June 2074. The current annual ground rent
expense per the transaction documents is $744,997 and increases
every five years based on a schedule, with the next increase
occurring in July 2024 to $838,122. In addition, certain signage at
the property is subject to a ground lease with the same ground
lessor and ground lessee that commenced on Nov. 13, 2017, and
expires on June 30, 2059, with three, five-year extension options.
The ground rent increases every five years based on a schedule. The
current annual ground rent expense is $7,853 and starting in July
2024, it will increase to $8,834 for the next five years. At
issuance, we assumed a ground rent expense of $1.1 million, which
is the scheduled amount that is 10 years beyond the fully extended
loan term, and added the net present value of the difference
between our assumed ground rent expense and the actual ground rent
expense over a 17-year period to our value. In our current
analysis, the add-to-value was reduced to $1.7 million from $2.5
million at issuance.

As previously discussed, the property's occupancy rate has remained
relatively flat since issuance. As of the March 31, 2022, rent
roll, the property was 73.3% occupied and 75.6% leased, considering
future executed leases. The five largest tenants comprise 18.2% of
collateral NRA and include:

-- Pinnacle Entertainment (5.8% of NRA; 8.0% of gross rent, as
calculated by S&P Global Ratings; July 2024 lease expiration);

-- NYU Grossman School of Medicine (3.9%; 4.9%; December 2030 and
April 2032. The tenant signed a lease for 2.6% of NRA in November
2020 and expanded 1.3% of NRA in May 2022);

-- Consumer Portfolio Services (3.0%; 4.1%; March 2023);

-- Cosmopolitan of Las Vegas (2.8%; 4.0%; and June 2027); and

-- Wells Fargo (2.8%; 3.7%; December 2027. The tenant extended its
lease in 2020 at a reduced sq. ft. from 3.7% of NRA at issuance).

The property faces elevated tenant rollover risk through 2024, with
13.6% of NRA and 17.8% of gross rent as calculated by S&P Global
Ratings expiring in 2022, 11.5% and 16.4% in 2023, and 12.5% and
17.0% in 2024, respectively.

The property is in a weak office submarket. While the current
submarket vacancy rate for four- and five-star properties has
declined from a high of between 23.4% and 29.2% from 2011 to 2016,
it remains elevated. According to CoStar, the four- and five-star
properties in the Central East Las Vegas office submarket had a
vacancy rate, availability rate, and asking rent of 21.0%, 17.1%,
and $26.19 per sq. ft., respectively, as of year-to-date September
2022. At issuance (in 2018), per CoStar, the reported office
submarket vacancy rate and asking rent for four- and five-star
properties were 19.5% and $23.90 per sq. ft., respectively. CoStar
projects the four- and five-star office properties submarket
vacancy rate and asking rent in 2023 to be 18.5% and $27.42 per sq.
ft., respectively. This compares with the subject property's 24.4%
vacancy rate and $39.01 per sq. ft. gross rent, as calculated by
S&P Global Ratings.

As previously noted, the reported NCF has steadily declined since
issuance. This decline is attributed primarily to increasing
expenses and relatively flat revenues. As a result, the operating
expense ratio increased to 57.2% as of the TTM ending June 30, 2022
from 57.5% in 2021; 55.3% in 2020; and 50.1% in 2019;. S&P said,
"We assumed a 39.2% operating expense ratio at issuance. Most of
the increase in expenses were in general and administrative, as
categorized by the master servicer. While we did not receive an
update from the master servicer, KeyBank Real Estate Capital
(KeyBank), on the nature of these expenses, the servicer-provided
borrower's 2022 budget estimated that the overall operating
expenses would be approximately $20.0 million, with an operating
expense ratio of 45.1%."

S&P said, "Our current property-level analysis reflects the
aforementioned factors. As a result, we revised our long-term
sustainable NCF to $20.2 million based on an assumed 75.6%
occupancy rate, $39.01-per-sq.-ft. average gross rent, as
calculated by S&P Global Ratings, and an operating expense ratio of
48.0%, which aligns to the borrower's 2022 budgets and is higher
than ratios we have observed in other Las Vegas office properties
(typically in the high-20s to low-30s range). Using an S&P Global
Ratings' capitalization rate of 8.00% and adding $1.7 million for
the aforementioned ground rent differential, we arrived at an
expected-case value of $253.8 million or $169 per sq. ft."

Transaction Summary

This is a U.S. stand-alone (single-borrower) transaction backed by
a two-year, floating-rate, IO mortgage loan with five, one-year
extension options. The loan is secured by the borrower's fee and
leasehold interests in Hughes Center, a mixed-use, office/retail
complex totaling 1.5 million sq. ft. in Las Vegas.

The IO mortgage loan has a current trust balance of $325.0 million
(as of the Sept. 15, 2022, trustee remittance report), the same as
at issuance. The loan pays an annual floating interest rate of
one-month LIBOR plus a weighted average component spread of 2.265%
(up from 2.165% at issuance). According to KeyBank, the borrower
recently exercised its third extension option, extending the loan's
maturity date to Sept. 9, 2023, and increasing the loan's spread by
10 basis points. Two extension options remain, and the loan has a
fully extended maturity date of Sept. 9, 2025.

To date, the trust has not experienced any principal losses. The
loan had a reported current payment status through its September
2022 debt service payment date. KeyBank reported a debt service
coverage of 2.03x for both the TTM ending June 30, 2022, and 2021,
and 1.76x in 2020.

The recent rapid spread of the omicron variant highlights the
inherent uncertainties of the COVID-19 pandemic, as well as the
importance and benefits of vaccines. S&P said, "While the risk of
new, more severe variants displacing omicron and evading existing
immunity cannot be ruled out, our current base case assumes that
existing vaccines can continue to provide significant protection
against severe illness. Furthermore, many governments, businesses,
and households around the world are tailoring policies to limit the
adverse economic impact of recurring COVID-19 virus waves.
Consequently, we do not expect a repeat of the sharp global
economic contraction of second-quarter 2020. Meanwhile, we continue
to assess how well each issuer adapts to new waves in its geography
or industry."

  Ratings Lowered

  COMM 2018-HCLV Mortgage Trust

  Class E to 'B- (sf)' from 'BB- (sf)'
  Class F to 'CCC (sf)' from 'B- (sf)'

  Ratings Affirmed

  COMM 2018-HCLV Mortgage Trust

  Class A: 'AAA (sf)'
  Class B: 'AA- (sf)'
  Class C: 'A- (sf)'
  Class D: 'BBB- (sf)'



CWABS 2007-13: Moody's Hikes Rating on Class 1-A Debt to 'B2'
-------------------------------------------------------------
Moody's Investors Service has upgraded the rating of one bond from
one US residential mortgage-backed transaction (RMBS), backed by
subprime mortgages issued by CWABS Asset-Backed Certificates Trust
2007-13.  

Issuer: CWABS Asset-Backed Certificates Trust 2007-13

Cl. 1-A, Upgraded to B2 (sf); previously on Mar 16, 2018 Upgraded
to Caa1 (sf)

RATINGS RATIONALE

The rating action reflects the recent performance as well as
Moody's updated loss expectation on the underlying pool. The rating
upgrade is the result of an increase in credit enhancement
available to the bond.

In light of the current macroeconomic environment, Moody's revised
loss expectations based on forecast uncertainties. Specifically,
Moody's have observed an increase in delinquencies, payment
forbearance, and payment, which could result in higher realized
losses. Moody's rating actions also take into consideration the
buildup in credit enhancement of the bonds, which has helped offset
the impact of the increase in expected losses.

Moody's estimated the proportion of loans granted payment relief in
a pool based on a review of loan level cashflows. In Moody's
analysis, Moody's considered a loan to be enrolled in a payment
relief program if (1) the loan was not liquidated but took a loss
in the reporting period (to account for loans with monthly
deferrals that were reported as current), or (2) the actual balance
of the loan increased in the reporting period, or (3) the actual
balance of the loan remained unchanged in the last and current
reporting period, excluding interest-only loans and pay ahead
loans. Based on Moody's analysis, the proportion of borrowers that
are currently enrolled in payment relief plans varied greatly,
ranging between approximately 2% and 11% among RMBS transactions
issued before 2009. In Moody's analysis, Moody's assume these loans
to experience lifetime default rates that are 50% higher than
default rates on the performing loans.

In addition, for borrowers unable to make up missed payments
through a short-term repayment plan, servicers will generally defer
the forborne amount as a non-interest-bearing balance, due at
maturity of the loan as a balloon payment. Moody's analysis
considered the impact of six months of scheduled principal payments
on the loans enrolled in payment relief programs being passed to
the trust as a loss. The magnitude of this loss will depend on the
proportion of the borrowers in the pool subject to principal
deferral and the number of months of such deferral. The treatment
of deferred principal as a loss is credit negative for junior
bonds, which could incur write-downs on bonds when missed payments
are deferred.

Principal Methodologies

The principal methodology used in this rating was "US RMBS
Surveillance Methodology" published in July 2022.

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 of the subordinate bonds up. Losses could decline from
Moody's original expectations as a result of a lower number of
obligor defaults or appreciation in the value of the mortgaged
property securing an obligor's promise of payment. Transaction
performance also depends greatly on the US macro economy and
housing market.

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 expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of this transaction. In addition, improvements in
reporting formats and data availability across deals and trustees
may provide better insight into certain performance metrics such as
the level of collateral modifications.


EXETER AUTOMOBILE 2022-5: Fitch Gives 'BB(EXP)sf' Rating on E Debt
------------------------------------------------------------------
Fitch Ratings expects to assign ratings and Rating Outlooks to
Exeter Automobile Receivables Trust (EART) 2022-5.

   Debt         Rating
   ----         ------
Exeter Automobile
Receivables Trust 2022-5

   A-1      ST   F1+(EXP)sf  Expected Rating
   A-2      LT   AAA(EXP)sf  Expected Rating
   A-3      LT   AAA(EXP)sf  Expected Rating
   B        LT   AA(EXP)sf   Expected Rating
   C        LT   A(EXP)sf    Expected Rating
   D        LT   BBB(EXP)sf  Expected Rating
   E        LT   BB(EXP)sf   Expected Rating

KEY RATING DRIVERS

Collateral Performance - Subprime Credit Quality: EART 2022-5 is
backed by collateral with subprime credit attributes, including a
weighted average (WA) FICO score of 586, a WA loan-to-value ratio
of 112.69%, and a WA Annual Percentage Rate (APR) of 20.94%.
Additionally, 97.92% of the loans are backed by used cars and the
WA payment-to-income ratio is 12.26%.

Forward-Looking Approach to Derive Base Case Proxy: Fitch
considered economic conditions and future expectations by assessing
key macroeconomic and wholesale market conditions when deriving the
series loss proxy. Although recessionary performance data from
Exeter is not available, the initial base case CNL proxy was
derived utilizing 2006-2010 data from Santander Consumer as proxy
recessionary static managed portfolio data and 2016-2017 vintage
data from Exeter to arrive at a forward-looking base case
cumulative net loss expectation of 18.75%.

Payment Structure - Sufficient Credit Enhancement: Initial hard
credit enhancement (CE) totals 56.10%, 42.25%, 29.90%, 17.70%, and
7.75% for classes A, B, C, D and E, respectively, slightly down
from 2022-4, but generally in range of recent transactions. Excess
spread is expected to be 10.98% per annum. Loss coverage for each
class of notes is sufficient to cover the respective multiples of
Fitch's base case credit net loss (CNL) proxy of 18.75%.

Seller/Servicer Operational Review - Adequate
Origination/Underwriting/Servicing: Exeter demonstrates adequate
abilities as the originator, underwriter and servicer, as evidenced
by historical portfolio and securitization performance. Fitch does
not rate Exeter Finance LLC. Fitch deems Exeter as capable to
service this transaction. In addition, Citibank, N.A., which Fitch
rates 'A+'/'F1'/Stable, has been contracted as backup servicer for
this transaction.

RATING SENSITIVITIES

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

Unanticipated increases in the frequency of defaults could produce
CNL levels that are higher than the base case and would likely
result in declines of CE and remaining net loss coverage levels
available to the notes. Additionally, unanticipated declines in
recoveries could also result in lower net loss coverage, which may
make certain note ratings susceptible to potential negative rating
actions depending on the extent of the decline in coverage.

Therefore, Fitch conducts sensitivity analyses by stressing both a
transaction's initial base case CNL and recovery rate assumptions,
as well as by examining the rating implications on all classes of
issued notes. The CNL sensitivity stresses the CNL proxy to the
level necessary to reduce each rating by one full category, to
non-investment grade (BBsf) and to 'CCCsf' based on the break-even
loss coverage provided by the CE structure.

Additionally, Fitch conducts 1.5x and 2.0x increases to the CNL
proxy, representing both moderate and severe stresses. Fitch also
evaluates the impact of stressed recovery rates on an auto loan ABS
structure and rating impact with a 50% haircut. These analyses are
intended to provide an indication of the rating sensitivity of the
notes to unexpected deterioration of a trust's performance.

Fitch has revised its global economic outlook forecasts as a result
of the war in Ukraine and related economic sanctions. Downside
risks have increased, and Fitch has published an assessment of the
potential rating and asset performance impact of a plausible,
albeit worse than expected, adverse stagflation scenario on Fitch's
major structured finance and covered bond subsectors ("What Global
Stagflation Would Mean for Structured Finance and Covered Bond
Ratings").

Fitch expects the North American subprime auto ABS sector in the
assumed adverse scenario to experience "Virtually No Impact" on
rating performance, indicating very few (less than 5%) rating or
Outlook changes. Fitch expects "Mild to Modest Impact" on asset
performance, indicating asset performance to be modestly negatively
affected relative to current expectations, and a 25% chance of
sector outlook revision by YE 2023. Fitch expects the asset
performance impact of the adverse case scenario to be more modest
than the most stressful scenario shown above that increases the
default expectation by 2.0x.

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

Stable to improved asset performance driven by stable delinquencies
and defaults would lead to rising CE levels and consideration for
potential upgrades. If CNL is 20% less than the projected proxy,
the expected subordinate note ratings could be upgraded by up to
one category.

ESG CONSIDERATIONS

The concentration of hybrid and electric vehicles of less than 1%
did not have an impact on Fitch's ratings analysis or conclusion on
this transaction and has no impact on Fitch's ESG Relevance Score.

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.


EXETER AUTOMOBILE 2022-5: S&P Assigns Prelim BB Rating on E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Exeter
Automobile Receivables Trust 2022-5's automobile receivables-backed
notes.

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

The preliminary ratings are based on information as of Oct. 6,
2022. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The availability of approximately 58.08%, 49.29%, 39.83%,
30.41%, and 24.80% credit support--hard credit enhancement and
haircut to excess spread--for the class A (collectively, classes
A-1, A-2, and A-3), B, C, D, and E notes, respectively, based on
stressed cash flow scenarios. These credit support levels provide
at least 3.05x, 2.60x, 2.10x, 1.60x, and 1.30x coverage of S&P's
expected net loss of 18.75%. These break-even scenarios withstand
cumulative gross losses of approximately 89.35%, 75.83%, 63.73%,
48.65%, and 39.68%, respectively.

-- The expectation that under a moderate ('BBB') stress scenario
(1.60x S&P's expected loss level), all else being equal, its
preliminary ratings will be within the credit stability limits
specified by section A.4 of the Appendix in "S&P Global Ratings
Definitions," published Nov. 10, 2021.

-- The expectation for timely interest and principal payments on
the notes, based on stressed cash flow modeling scenarios, which,
in S&P's view, are appropriate for the assigned preliminary
ratings.

-- The collateral characteristics of the subprime automobile loans
securitized in this transaction together with S&P's view of the
credit risk of the collateral, its updated macroeconomic forecast,
and forward-looking view of the auto finance sector.

-- S&P's assessment of the series' bank accounts at Citibank N.A.
(Citibank), which do not constrain the preliminary ratings.

-- S&P's operational risk assessment of Exeter Finance LLC as
servicer, along with its view of the company's underwriting and the
backup servicing arrangement with Citibank.

-- S&P's assessment of the transaction's potential exposure to
environmental, social, and governance credit factors, which are in
line with its sector benchmark.

-- The transaction's payment and legal structures.

S&P said, "Our ECNL of 18.75% for EART 2022-5, down from series
2022-4's 19.00% (18.50%-19.50%), incorporates our view that the
series 2022-5 collateral characteristics are slightly stronger than
those of series 2022-4, our observation of better-than-expected
performance of outstanding EART series relative to our initial
expectations, and our forward-looking view of the auto finance
sector. The reduction in initial hard credit enhancement reflects
our lower ECNL for this transaction compared with the same for
series 2022-4 and is captured in our stressed cash flow analysis,
which shows the notes are credit enhanced to the degree appropriate
for the assigned preliminary ratings."

  Preliminary Ratings Assigned

  Exeter Automobile Receivables Trust 2022-5

  Class A-1, $72.00 million: A-1+ (sf)
  Class A-2, $127.53 million: AAA (sf)
  Class A-3, $89.23 million: AAA (sf)
  Class B, $89.07 million: AA (sf)
  Class C, $79.43 million: A (sf)
  Class D, $78.46 million: BBB (sf)
  Class E, $63.99 million: BB (sf)



GOODLEAP 2022-4: S&P Assigns Prelim BB+ (sf) Rating on Cl. C Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to GoodLeap
Sustainable Home Solutions Trust 2022-4's sustainable home
improvement loan-backed series 2022-4 notes.

The note issuance is an ABS securitization backed by an underlying
trust certificate representing an ownership interest in the trust,
whose assets consist of more than 99% residential solar loans and
less than 1% other types of sustainable home improvement loans.

The preliminary ratings are based on information as of Oct. 6,
2022. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The credit enhancement available in the form of
overcollateralization, a yield supplement overcollateralization
amount, subordination for classes A and B, and a fully funded cash
reserve account;

-- The servicer's operational, management, and servicing
abilities;

-- The obligor base's initial credit quality;

-- The projected cash flows supporting the notes; and

-- The transaction's structure.

  Preliminary Ratings Assigned

  GoodLeap Sustainable Home Solutions Trust 2022-4

  Class A, $239.778 million: A (sf)
  Class B, $14.828 million: BBB (sf)
  Class C, $16.780 million: BB+ (sf)



HALCYON LOAN 2013-2: Moody's Cuts Rating on Class D Notes to 'Caa3'
-------------------------------------------------------------------
Moody's Investors Service has downgraded the rating on the
following notes issued by Halcyon Loan Advisors Funding 2013-2
Ltd.:

US$26,750,000 Class D Mezzanine Secured Deferrable Floating Rate
Notes (current outstanding balance of 15,583,629.76), Downgraded to
Caa3 (sf); previously on Jan 24, 2022 Downgraded to B3 (sf)

Halcyon Loan Advisors Funding 2013-2 Ltd., originally issued in
July 2013, is a managed cashflow CLO. The notes are collateralized
primarily by a portfolio of broadly syndicated senior secured
corporate loans. The transaction's reinvestment period ended in
August 2017.

RATINGS RATIONALE

The downgrade rating action on the Class D notes reflects the
deterioration in its over-collateralization (OC) ratio and interest
coverage. Based on the trustee's August 2022 report[1], the OC
ratio for the Class D notes is reported at 61.58% versus December
2021 level[2] of 93.74%.

The rating action is also due to deterioration of the credit
quality of the portfolio. Based on Moody's calculation, the
weighted average rating factor (WARF) of the portfolio is currently
4103 compared to 3868 in December 2021. Based on Moody's
calculation, the proportion of obligors in the portfolio with
Moody's corporate family or other equivalent ratings of Caa1 or
lower (after any adjustments for watchlist for possible downgrade)
is currently approximately 49% of the CLO par.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in "Moody's Global
Approach to Rating Collateralized Loan Obligations." In addition,
because of the collateral pool's low diversity, Moody's used
CDOROM(TM) to simulate a default distribution that it then used as
an input in the cash flow model.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score, weighted average
spread, 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: $9,535,817

Defaulted par: $4,746,300

Diversity Score: 4

Weighted Average Rating Factor (WARF): 4103

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 5.58%

Weighted Average Recovery Rate (WARR): 47.14%

Weighted Average Life (WAL): 2.2 years

Par haircut in OC tests and interest diversion test: 21.3%

In addition to base case analysis, Moody's considered additional
scenarios where outcomes could diverge from the base case. These
additional scenarios include, among others, deterioration in credit
quality of the underlying portfolio, decrease in overall WAS and
lower recoveries on defaulted assets.

Methodology Used for the Rating Action

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2021.

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

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


JP MORGAN 2018-PHH: Moody's Lowers Rating on Cl. E Certs to B3
--------------------------------------------------------------
Moody's Investors Service has affirmed the ratings on two classes
and downgraded the ratings on five classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust 2018-PHH, Commercial Mortgage
Pass-Through Certificates, Series 2018-PHH as follows:

Cl. A, Affirmed Aaa (sf); previously on Aug 25, 2020 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa3 (sf); previously on Aug 25, 2020 Affirmed Aa3
(sf)

Cl. C, Downgraded to Baa2 (sf); previously on Aug 25, 2020 Affirmed
A3 (sf)

Cl. D, Downgraded to Ba3 (sf); previously on Aug 25, 2020
Downgraded to Ba1 (sf)

Cl. E, Downgraded to B3 (sf); previously on Aug 25, 2020 Downgraded
to B1 (sf)

Cl. F, Downgraded to Caa3 (sf); previously on Aug 25, 2020
Downgraded to Caa1 (sf)

Cl. HRR, Downgraded to Ca (sf); previously on Aug 25, 2020
Downgraded to Caa2 (sf)

RATINGS RATIONALE

The ratings on Cl. A and Cl. B were affirmed because the
transaction key metrics, including Moody's loan-to-value (LTV)
ratio, are within acceptable ranges. These classes benefit from
credit support in the form of a significant equity cushion and as
part of Moody's analysis Moody's performed a stressed value
recovery analysis.

The ratings on five principal and interest (P&I) classes were
downgraded primarily due to the sustained loan underperformance and
the resulting increase in interest shortfalls to the trust and
outstanding loan advances. As of the September 2022 remittance
statement the borrower has been delinquent on debt service payments
since April 2020 and the loan has reported total advances
(inclusive of outstanding principal and interest (P&I), taxes and
insurance (T&I) and other advances) of $44.9 million. Furthermore,
the appraisal reduction amount has increased to $93.2 million. The
loan was transferred to the special servicer in April 2020 and the
loan's delinquency status is listed as foreclosure as of the
September 2022 remittance statement.

In this credit rating action, Moody's considered qualitative and
quantitative factors in relation to the senior-sequential structure
and trophy nature of the asset, and Moody's analyzed multiple
scenarios to reflect various levels of stress in property values
could impact loan proceeds at each rating level.  However, the
trust may be at increased risk of interest shortfalls if the
borrower is unable to reach a resolution with the special servicer
and continues to be delinquent on its debt service payments.

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

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range can
indicate that the collateral's credit quality is stronger or weaker
than Moody's had previously expected. Additionally, significant
changes in the 5-year rolling average of 10-year US Treasury rates
will impact the magnitude of the interest rate adjustment and may
lead to future rating actions.

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in these ratings was "Large Loan and
Single Asset/Single Borrower Commercial Mortgage-Backed
Securitizations Methodology" published in July 2022.


DEAL PERFORMANCE

As of the September 15, 2022 distribution date, the transaction's
aggregate certificate balance remains unchanged from Moody's prior
review at approximately $329 million. The decrease from
approximately $333 million at securitization had been due to 2019's
scheduled annual principal paydown from 25% of excess cash flow.
The securitization is backed by a single floating-rate loan
collateralized by the borrower's fee simple interest in the Palmer
House Hilton. The 24-story, 1,642 guestroom property is located in
the central business district of Chicago, Illinois, one block west
of Millennium Park and Michigan Avenue. The loan's final maturity
date (including three one-year extension options) is in June 2023.
There is an approximately $94 million of mezzanine debt held
outside of the trust.

The property's performance had deteriorated before the coronavirus
outbreak and its reported net cash flow (NCF) in 2019 was $25.9
million, representing a 22% decline from that of 2018. The
performance of the property was further negatively impacted by the
coronavirus pandemic and the hotel was temporarily closed between
April 2020 and June 2021. As a result of the temporarily closure
and travel restrictions the property's revenue was insufficient to
cover operating expenses in 2020 and 2021 and no debt service
payments have been made since April 2020. The special servicer
indicated they have filed for judicial foreclosure and a Receiver
has been appointed.

As of the September 2022 distribution date and the total
outstanding P&I, T&I and other advances had increased to $44.9
million. While the most recently reported appraised value in March
2022 reported a slight increase of 6% and 7%, respectively, from
its appraised value reported in August 2020 and July 2021, it still
represented a 41% decline from its appraised value at
securitization. As of the September 2022 remittance statement an
appraisal reduction of $93.2 million has been recognized on this
loan. There were outstanding interest shortfalls totaling $6.1
million affecting Cl. E, Cl. F., and Cl. HRR and no losses as of
the current distribution date.

The property's monthly profitability has increased since the second
quarter of 2022 and the hotel generated a positive $5.7 million
cash flow in July 2022. Furthermore, according to STR, LLC, the
Chicago market's Revenue per Available Room (RevPAR) was up 73.5%
during the first eight months of 2022 compared to the same period
in 2021; however, compared to the same period in 2019 it is still
down 7.9%.  The overall US RevPAR performance for the year to date
period ending August 2022 is up 36.3% over the same period in 2021
and up 5.3% over the same period in 2019, respectively. However,
the property's reliance on group segment (40% at securitization) is
delaying its recovery timing compared to those that cater to more
leisure and individual corporate traveler.  Moody's stabilized NCF
is $20.4 million, compared to $28.4 million at securitization.
Moody's A-note LTV and stressed A-note DSCR for the first mortgage
are 169% and 0.67X, respectively.


JP MORGAN 2019-LTV3: Moody's Ups Rating on Cl. B-4 Bonds From Ba1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 34 classes
from ten J.P. Morgan Mortgage Trust transactions issued in 2019.
These transactions are securitizations of fixed rate, first-lien
conforming and non-conforming prime jumbo mortgage loans.          
   

A list of the Affected Ratings is available at
https://bit.ly/3Mlv21Z

Issuer: J.P. Morgan Mortgage Trust 2019-2

Cl. B-2, Upgraded to Aaa (sf); previously on Dec 13, 2021 Upgraded
to Aa1 (sf)

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

Cl. B-2, Upgraded to Aaa (sf); previously on Dec 13, 2021 Upgraded
to Aa2 (sf)

Cl. B-3, Upgraded to A1 (sf); previously on Dec 13, 2021 Upgraded
to A2 (sf)

Issuer: J.P. Morgan Mortgage Trust 2019-7

Cl. B-2, Upgraded to Aa2 (sf); previously on Dec 13, 2021 Upgraded
to Aa3 (sf)

Cl. B-2-A, Upgraded to Aa2 (sf); previously on Dec 13, 2021
Upgraded to Aa3 (sf)

Cl. B-3, Upgraded to A2 (sf); previously on Dec 13, 2021 Upgraded
to A3 (sf)

Cl. B-3-A, Upgraded to A2 (sf); previously on Dec 13, 2021 Upgraded
to A3 (sf)

Issuer: J.P. Morgan Mortgage Trust 2019-8

Cl. B-1, Upgraded to Aaa (sf); previously on Dec 13, 2021 Upgraded
to Aa1 (sf)

Cl. B-1-A, Upgraded to Aaa (sf); previously on Dec 13, 2021
Upgraded to Aa1 (sf)

Cl. B-2, Upgraded to Aa1 (sf); previously on Dec 13, 2021 Upgraded
to Aa3 (sf)

Cl. B-2-A, Upgraded to Aa1 (sf); previously on Dec 13, 2021
Upgraded to Aa3 (sf)

Cl. B-3, Upgraded to A2 (sf); previously on Dec 13, 2021 Upgraded
to A3 (sf)

Cl. B-3-A, Upgraded to A2 (sf); previously on Dec 13, 2021 Upgraded
to A3 (sf)

Issuer: J.P. Morgan Mortgage Trust 2019-9

Cl. B-2, Upgraded to Aa2 (sf); previously on Dec 13, 2021 Upgraded
to Aa3 (sf)

Cl. B-2-A, Upgraded to Aa2 (sf); previously on Dec 13, 2021
Upgraded to Aa3 (sf)

Cl. B-3, Upgraded to A2 (sf); previously on Dec 13, 2021 Upgraded
to A3 (sf)

Cl. B-3-A, Upgraded to A2 (sf); previously on Dec 13, 2021 Upgraded
to A3 (sf)

Issuer: J.P. Morgan Mortgage Trust 2019-INV1

Cl. B-3, Upgraded to Aa2 (sf); previously on Dec 13, 2021 Upgraded
to Aa3 (sf)

Issuer: J.P. Morgan Mortgage Trust 2019-INV3

Cl. B-2, Upgraded to Aa1 (sf); previously on Jan 13, 2022 Upgraded
to Aa2 (sf)

Cl. B-2-A, Upgraded to Aa1 (sf); previously on Jan 13, 2022
Upgraded to Aa2 (sf)

Cl. B-3, Upgraded to Aa3 (sf); previously on Jan 13, 2022 Upgraded
to A1 (sf)

Cl. B-3-A, Upgraded to Aa3 (sf); previously on Jan 13, 2022
Upgraded to A1 (sf)

Cl. B-4, Upgraded to Baa2 (sf); previously on Jan 13, 2022 Upgraded
to Baa3 (sf)

Issuer: J.P. Morgan Mortgage Trust 2019-LTV1

Cl. B-2, Upgraded to Aaa (sf); previously on Dec 13, 2021 Upgraded
to Aa1 (sf)

Cl. B-3, Upgraded to Aa2 (sf); previously on Dec 13, 2021 Upgraded
to A1 (sf)

Cl. B-4, Upgraded to Baa1 (sf); previously on Dec 13, 2021 Upgraded
to Baa3 (sf)

Issuer: J.P. Morgan Mortgage Trust 2019-LTV2

Cl. B-2, Upgraded to Aaa (sf); previously on Dec 13, 2021 Upgraded
to Aa2 (sf)

Cl. B-3, Upgraded to Aa3 (sf); previously on Dec 13, 2021 Upgraded
to A2 (sf)

Cl. B-4, Upgraded to Baa1 (sf); previously on Dec 13, 2021 Upgraded
to Baa3 (sf)

Issuer: J.P. Morgan Mortgage Trust 2019-LTV3

Cl. B-2, Upgraded to Aa1 (sf); previously on Dec 13, 2021 Upgraded
to Aa3 (sf)

Cl. B-2-A, Upgraded to Aa1 (sf); previously on Dec 13, 2021
Upgraded to Aa3 (sf)

Cl. B-3, Upgraded to A1 (sf); previously on Dec 13, 2021 Upgraded
to A3 (sf)

Cl. B-3-A, Upgraded to A1 (sf); previously on Dec 13, 2021 Upgraded
to A3 (sf)

Cl. B-4, Upgraded to Baa2 (sf); previously on Dec 13, 2021 Upgraded
to Ba1 (sf)

RATINGS RATIONALE

The rating upgrades reflect the increased levels of credit
enhancement available to the bonds, the recent performance, and
Moody's updated loss expectations on the underlying pool. In this
transaction, high prepayment rates, averaging 26%-47% over the last
six months, have benefited the bonds by increasing the paydown and
building credit enhancement.

In Moody's analysis Moody's considered the additional risk posed by
borrowers enrolled in payment relief programs. Moody's increased
Moody's MILAN model-derived median expected losses by 15% and
Moody's Aaa losses by 5% to reflect the performance deterioration
observed following the COVID-19 outbreak. For transactions where
more than 4% of the loans in pool have been enrolled in payment
relief programs for more than 3 months, Moody's further increased
the expected loss to account for the rising risk of potential
deferral losses to the subordinate bonds.

Moody's also considered higher adjustments for transactions where
more than 10% of the pool is either currently enrolled or was
previously enrolled in a payment relief program. Specifically,
Moody's account for the marginally increased probability of default
for borrowers that have either been enrolled in a payment relief
program for more than 3 months or have already received a loan
modification, including a deferral, since the start of the
pandemic.

Moody's estimated the proportion of loans granted payment relief in
a pool based on a review of loan level cashflows. In Moody's
analysis, Moody's considered a loan to be enrolled in a payment
relief program if (1) the loan was not liquidated but took a loss
in the reporting period (to account for loans with monthly
deferrals that were reported as current), or (2) the actual balance
of the loan increased in the reporting period, or (3) the actual
balance of the loan remained unchanged in the last and current
reporting period, excluding interest-only loans and pay ahead
loans. Based on Moody's analysis, the proportion of borrowers that
are enrolled in payment relief plans in the underlying pool ranged
between 0%-9% over the last six months.

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

Principal Methodology

The principal methodology used in these ratings was "Moody's
Approach to Rating US RMBS Using the MILAN Framework" published in
July 2022.

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 of the subordinate bonds up. Losses could decline from
Moody's original expectations as a result of a lower number of
obligor defaults or appreciation in the value of the mortgaged
property securing an obligor's promise of payment. Transaction
performance also depends greatly on the US macro economy and
housing market.

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 expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions. In addition, improvements in
reporting formats and data availability across deals and trustees
may provide better insight into certain performance metrics such as
the level of collateral modifications.


MARINER FINANCE 2022-A: S&P Assigns Prelim 'BB-' Rating on D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Mariner
Finance Issuance Trust 2022-A's asset-backed notes.

The note issuance is an ABS securitization backed by personal
consumer loan receivables.

The preliminary ratings are based on information as of Oct. 7,
2022. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The availability of approximately 60.27%, 52.18%, 47.13%,
41.30% and 34.76% credit support for the class A, B, C, D, and E
notes, respectively, in the form of subordination,
overcollateralization, a reserve account, and excess spread. These
credit support levels are sufficient to withstand stresses
commensurate with the preliminary ratings assigned to the notes
based on our stressed cash flow scenarios.

-- S&P's worst-case, weighted average, base-case loss assumption
for this transaction of 20.82%. Its loss assumption is a function
of the transaction-specific reinvestment criteria and historical
Mariner Finance LLC (Mariner) portfolio loan performance. Its loss
assumption also reflects year-over-year performance volatility
observed in Mariner annual loan vintages over time.

-- Mariner's long performance history as originator and servicer.
Mariner has been profitable every year since 2002.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal, the assigned preliminary ratings
will be consisted with the credit stability section of "S&P Global
Ratings Definitions," published Nov. 10, 2021.

-- The timely interest and full principal payments expected to be
made by the final maturity date under stressed cash flow modeling
scenarios appropriate to the assigned ratings.

-- The characteristics of the pool being securitized and
receivables expected to be purchased during the two-year revolving
period, which considers the worst-case pool according to the
transaction's concentration limits.

-- The transaction's payment and legal structures.

  Preliminary Ratings Assigned

  Mariner Finance Issuance Trust 2022-A(i)

  Class A, $187.277 million: AAA (sf)
  Class B, $35.671 million: AA- (sf)
  Class C, $20.333 million: A- (sf)
  Class D, $22.652 million: BBB- (sf)
  Class D, $34.067 million: BB- (sf)

(i)The actual size of the tranches and the respective interest
rates will be determined on the pricing date.



MFA 2022-INV3: S&P Assigns B+ (sf) Rating on Class B-2 Certs
------------------------------------------------------------
S&P Global Ratings assigned its ratings to MFA 2022-INV3 Trust's
mortgage pass-through certificates series 2022-INV3.

The certificate issuance is an RMBS transaction backed by
first-lien, fixed- and hybrid adjustable-rate, and fully amortizing
residential mortgage loans (some of which have an initial
interest-only period) secured by single-family residences,
condominiums, townhomes, and two- to four-family residential
properties to both prime and nonprime borrowers. The pool consists
of 1,005 business-purpose investor loans (including 249
cross-collateralized loans backed by 1,129 properties) that are
exempt from the qualified mortgage and ability-to-repay rules.

The ratings reflect S&P's view of:

-- The pool's collateral composition;

-- The transaction's credit enhancement, associated structural
mechanics, geographic concentration, and representation and
warranty framework;

-- The mortgage aggregator and primary mortgage originator; and

-- The current and near-term macroeconomic conditions and the
effect they may have on the performance of the mortgage borrowers
in the pool. S&P said, "On April 17, 2020, we updated our mortgage
outlook and corresponding archetypal foreclosure frequency levels
to account for the potential impact the COVID-19 pandemic may have
on the overall credit quality of collateralized pools. While
pandemic-related performance concerns have waned, we maintain our
updated 'B' foreclosure frequency (FF) for the archetypal pool at
3.25% given our current outlook for the U.S. economy, which
includes the Russia-Ukraine military conflict, supply-chain
disruptions, and rising inflation and interest rates."

Limited Exposure To Hurricane Ian

Eighty-nine properties (6.7% by balance) are located within Florida
counties that were declared disaster areas due to Hurricane Ian and
where Federal Emergency Management Agency individual assistance was
made available to homeowners. Property inspections have been
ordered for all 89 properties. As of the closing date, inspection
results were received for 79 of the properties, which showed that
none of the homes had any material damage and therefore will remain
in the pool, with no additional adjustments to our analysis. The
inspections for the remaining 10 properties (0.7% by balance) will
be completed post close. Per the issuer, if the results of the
inspections reveal that any of the remaining properties have
material damage, such loans will be repurchased from the pool. S&P
said, "Given the small concentration of properties yet to be
inspected and the issuer's intent to repurchase if applicable, we
believe exposure to Hurricane Ian in this pool is not a material
risk and, as such, we did not make any additional adjustments to
our analysis."

  Ratings Assigned

  MFA 2022-INV3 Trust

  Class A-1, $137,816,000: AAA (sf)
  Class A-2, $22,539,000: AA (sf)
  Class A-3, $27,470,000: A (sf)
  Class M-1, $13,735,000: BBB (sf)
  Class B-1, $11,152,000: BB (sf)
  Class B-2, $8,921,000: B+ (sf)
  Class B-3, $13,148,631: Not rated
  Class A-IO-S, notional(ii): Not rated
  Class XS, notional(ii): Not rated
  Class R: Not rated

(i)The ratings address S&P's view of the ultimate payment of
interest and principal and does not address payment of the cap
carryover amounts.
(ii)The notional amount equals the loans' aggregate unpaid
principal balance.



MONROE CAPITAL XIV: Moody's Gives (P)Ba3 Rating to $32.5MM E Notes
------------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to six
classes of notes to be issued and three class of loans to be
incurred by Monroe Capital MML CLO XIV, LLC (the "Issuer" or
"Monroe XIV").  

Moody's rating action is as follows:

US$55,000,000 Class A Senior Floating Rate Notes due 2034, Assigned
(P)Aaa (sf)

US$187,000,000 Class A-1 Senior Floating Rate Loans maturing 2034,
Assigned (P)Aaa (sf)

US$40,000,000 Class A-2 Senior Floating Rate Loans maturing 2034,
Assigned (P)Aaa (sf)

US$15,000,000 Class B-1 Floating Rate Notes due 2034, Assigned
(P)Aa2 (sf)

US$25,000,000 Class B Floating Rate Loans maturing 2034, Assigned
(P)Aa2 (sf)

US$10,000,000 Class B-2 Fixed Rate Notes due 2034, Assigned (P)Aa2
(sf)

US$41,000,000 Class C Deferrable Mezzanine Floating Rate Notes due
2034, Assigned (P)A2 (sf)

US$31,000,000 Class D Deferrable Mezzanine Floating Rate Notes due
2034, Assigned (P)Baa3 (sf)

US$32,500,000 Class E Deferrable Mezzanine Floating Rate Notes due
2034, Assigned (P)Ba3 (sf)

The notes and loans listed are referred to herein, collectively, as
the "Rated Debt."

The Class A-1 Loans and the Class A-2 Loans listed above are
referred to herein, collectively, as the "Class A Loans".

Upon written notice from one or more of the Class A Loans holders,
all or a portion of the Class A Loans may be converted into Class A
Notes subject to certain restrictions, thereby decreasing the
principal balance of the Class A Loans and increasing, by the
corresponding amount, the principal balance of the Class A Notes.
The amount converted is at least $250,000. Class A Notes may not be
converted into Class A Loans at any time. Class B Loans may not be
converted into Notes at any time.

RATINGS RATIONALE

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

Monroe XIV is a managed cash flow CLO. The issued debt will be
collateralized primarily by middle market loans. At least 95.0% of
the portfolio must consist of senior secured loans and eligible
investments, and up to 5.0% of the portfolio may consist of second
lien loans, senior unsecured loans and senior secured bonds.
Moody's expect the portfolio to be approximately 50% ramped as of
the closing date.

Monroe Capital CLO Manager II LLC (the "Manager") will direct the
selection, acquisition and disposition of the assets on behalf of
the Issuer and may engage in trading activity, including
discretionary trading, during the transaction's four year
reinvestment period. Thereafter, the manager may not reinvest in
new assets and all principal proceeds received will be used to
amortize the Rated Debt in sequential order.

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

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in December 2021.

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

Par amount: $500,000,000

Diversity Score: 50

Weighted Average Rating Factor (WARF): 3600

Weighted Average Spread (WAS): SOFR + 5.32%

Weighted Average Coupon (WAC): 7.5%

Weighted Average Recovery Rate (WARR): 46.0%

Weighted Average Life (WAL): 7.0 years

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
December 2021.

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


NEWSTAR FAIRFIELD: Fitch Affirms 'BB-sf' Rating on Cl. D-N Notes
----------------------------------------------------------------
Fitch Ratings has affirmed NewStar Fairfield Fund CLO, Ltd.'s class
A-1-N, A-2-N, B-1-N, B-2-N, C-N and D-N notes. The Rating Outlooks
on all tranches remain Stable.

   Debt                 Rating            Prior
   ----                 ------            -----
Newstar Fairfield Fund
CLO, Ltd. (F/K/A Fifth Street
SLF II, Ltd.)

   A-1-N 65252BAA1  LT  AAAsf   Affirmed   AAAsf
   A-2-N 65252BAC7  LT  AA+sf   Affirmed   AA+sf
   B-1-N 65252BAE3  LT  A+sf    Affirmed   A+sf
   B-2-N 65252BAJ2  LT  A+sf    Affirmed   A+sf
   C-N 65252BAG8    LT  BBB+sf  Affirmed   BBB+sf
   D-N 65252CAA9    LT  BB-sf   Affirmed   BB-sf

TRANSACTION SUMMARY

NewStar Fairfield Fund CLO, Ltd. (NewStar Fairfield) is a
middle-market (MM) collateralized loan obligation (CLO) that is
managed by First Eagle Alternative Credit, LLC. NewStar Fairfield
closed in September 2015, was reset in April 2018 and will exit its
reinvestment period in April 2023. The CLO is secured primarily by
first-lien, senior secured MM loans.

KEY RATING DRIVERS

Cash Flow Analysis

Fitch used a cash flow model to replicate the principal and
interest waterfalls and to assess the effectiveness of various
structural features of the transaction. The analysis included an
updated Fitch Stressed Portfolio (FSP), since the transaction is
still in its reinvestment period.

The FSP analysis adjusts the current portfolio from the latest
trustee report to create a stressed portfolio to account for
permissible concentration limits and collateral quality tests
(CQTs). Among these assumptions, the FSP weighted average life was
run at 4.75 (currently 3.7 years), industries were stressed to
their respective maximum concentration limitations, and considered
portfolios with 0% and 5% fixed-rate assets.

The stressed analysis also included the analysis of the Fitch test
matrix in transaction documentation. Fitch applied a haircut of
approximately 7.9% to the weighted average recovery rate (WARR) as
the calculation of the WARR in transaction documentation is not
line with the latest CLOs and Corporate CDOs Rating Criteria, based
on the difference between Fitch-calculated WARR and the current
test level.

The assigned ratings are in line with their model-implied ratings
(MIRs), which were based on the FSP analysis for classes A-2-N and
D-N notes and current portfolio analysis for the class A-1-N,
B-1-N, B-2-N and C-N notes.

The Stable Outlooks on all the rated notes reflect robust breakeven
cushions to withstand potential deterioration in the credit quality
of the portfolio in relevant rating stresses.

Asset Credit Quality, Asset Security, Portfolio Management and
Portfolio Composition

99.6% of the portfolio comprises senior secured obligations. The
Fitch-calculated WARR of the current portfolio is 66.5%. The
portfolio contains 131 obligors and the largest 10 obligors
represent 16.4% of the portfolio.

Fitch assesses the average credit quality of the obligors at the
'B-' rating level, with a Fitch-calculated WARF of 32.2.

All coverage tests and CQTs are in compliance. There are two
concentration limitations failing (limitation on permitted
deferrable obligations, 5.5% versus the test limit of 5.0%, and a
limitation on assets that are non-senior secured/first-lien
last-out loan where the obligor has an EBITDA of less than
$10,000,000 at the time of the loan origination, 1.7% versus the
test limit of 1.5%). Fitch-determined current defaults total
approximately 1.5% of the portfolio. Exposure to assets with a
Fitch-derived rating of 'CCC+' and below (including non-rated
assets) is at 20.5%.

RATING SENSITIVITIES

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

Downgrades may occur if the buildup of the notes' credit
enhancement following amortization does not compensate for a higher
loss expectation than initially assumed due to unexpected high
level of default and portfolio deterioration.

A 25% increase of the mean default rate across all ratings, along
with a 25% decrease of the recovery rate at all rating levels for
the current portfolio, would lead to downgrades (based on the MIR)
of up to three rating notches.

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

Except for the tranches already at the highest 'AAAsf' rating,
upgrades may occur in the event of better-than-expected portfolio
credit quality and deal performance.

A 25% reduction of the mean default rate across all ratings, along
with a 25% increase of the recovery rate at all rating levels for
the current portfolio, would lead to upgrades (based on the MIR) of
up to five rating notches.

DATA ADEQUACY

Fitch has checked the consistency and plausibility of the
information it has received about the performance of the asset pool
and the transaction. Fitch has not reviewed the results of any
third-party assessment of the asset portfolio information or
conducted a review of origination files as part of its ongoing
monitoring.

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other nationally
recognized statistical rating organizations and/or European
securities and markets authority-registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information or information on the risk-presenting entities.

Overall, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


OCEANVIEW MORTGAGE 2022-1: Moody's Gives (P)B3 Rating to B-5 Debt
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to 58
classes of residential mortgage-backed securities (RMBS) issued by
Oceanview Mortgage Trust 2022-1 and sponsored by Oceanview Asset
Selector, LLC.

The securities are backed by a pool of prime jumbo (100% by
balance) residential mortgages originated by multiple entities and
serviced by Nationstar Mortgage, LLC.

The complete rating actions are as follows:

Issuer: Oceanview Mortgage Trust 2022-1

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Cl. A-25, Assigned (P)Aaa (sf)

Cl. A-IO1*, Assigned (P)Aaa (sf)

Cl. A-IO2*, Assigned (P)Aaa (sf)

Cl. A-IO3*, Assigned (P)Aaa (sf)

Cl. A-IO4*, Assigned (P)Aaa (sf)

Cl. A-IO5*, Assigned (P)Aaa (sf)

Cl. A-IO6*, Assigned (P)Aaa (sf)

Cl. A-IO7*, Assigned (P)Aaa (sf)

Cl. A-IO8*, Assigned (P)Aaa (sf)

Cl. A-IO9*, Assigned (P)Aaa (sf)

Cl. A-IO10*, Assigned (P)Aaa (sf)

Cl. A-IO11*, Assigned (P)Aaa (sf)

Cl. A-IO12*, Assigned (P)Aaa (sf)

Cl. A-IO13*, Assigned (P)Aaa (sf)

Cl. A-IO14*, Assigned (P)Aaa (sf)

Cl. A-IO15*, Assigned (P)Aaa (sf)

Cl. A-IO16*, Assigned (P)Aaa (sf)

Cl. A-IO17*, Assigned (P)Aaa (sf)

Cl. A-IO18*, Assigned (P)Aaa (sf)

Cl. A-IO19*, Assigned (P)Aaa (sf)

Cl. A-IO20*, Assigned (P)Aa1 (sf)

Cl. A-IO21*, Assigned (P)Aa1 (sf)

Cl. A-IO22*, Assigned (P)Aa1 (sf)

Cl. A-IO23*, Assigned (P)Aaa (sf)

Cl. A-IO24*, Assigned (P)Aaa (sf)

Cl. A-IO25*, Assigned (P)Aaa (sf)

Cl. A-IO26*, Assigned (P)Aaa (sf)

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

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

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

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

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

*Reflects Interest-Only Classes

RATINGS RATIONALE

The ratings are based on the credit quality of the mortgage loans,
the structural features of the transaction, the origination quality
and the servicing arrangement, the third-party review, and the
representations and warranties framework.

Moody's expected loss for this pool in a baseline scenario-mean is
0.56%, in a baseline scenario-median is 0.34% and reaches 5.00% at
a stress level consistent with Moody's Aaa rating.

PRINCIPAL METHODOLOGY

The principal methodology used in rating all classes except
interest-only classes was "Moody's Approach to Rating US RMBS Using
the MILAN Framework" published in July 2022.

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 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 higher number of obligor defaults or deterioration
in the value of the mortgaged property securing an obligor's
promise of payment. Transaction performance also depends greatly on
the US macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions. In addition, improvements in
reporting formats and data availability across deals and trustees
may provide better insight into certain performance metrics such as
the level of collateral modifications.


PALISADES CENTER 2016-PLSD: S&P Cuts Class A Notes Rating to 'BB'
-----------------------------------------------------------------
S&P Global Ratings lowered its ratings on five classes of
commercial mortgage pass-through certificates from Palisades Center
Trust 2016-PLSD, a U.S. commercial mortgage-backed securities
(CMBS) transaction.

This U.S. CMBS transaction is backed by a portion of a fixed-rate,
interest-only (IO) mortgage whole loan secured by a portion of a
super-regional mall and entertainment center known as Palisades
Center in West Nyack, N.Y.

Rating Actions

S&P said, "The downgrades of the principal-and-interest paying
classes reflect our reevaluation of Palisades Center that secures
the sole loan in the transaction, based on our review of the
servicer-provided financial performance data for the year-to-date
(YTD) period ended June 30, 2022, and years ended Dec. 31, 2021,
2020, and 2019; our assessment of the accelerated decline in
reported operating performance at the property since the onset of
the COVID-19 pandemic; and the still vacant anchor space formerly
occupied by JC Penney. Our current analysis also considers that the
loan was recently transferred to special servicing because the
borrower was unable to obtain refinancing proceeds to pay off the
loan by its October 2022 maturity date.

"The servicer-reported occupancy rate fell during the pandemic to
75.4% in 2020, 76.3% in 2021, and 74.8% as of June 30, 2022, from
82.0% in 2019. In addition, the servicer-reported net cash flow
(NCF) decreased 56.1% to $16.2 million in 2020 from $36.9 million
in 2019. While the reported NCF improved 54.2% to $25.0 million in
2021, it is still 26.9% below our assumed NCF of $34.1 million that
we derived in our last review in December 2020. The reported NCF
was $11.1 million as of the six months ended June 30, 2022. We
attributed the decrease in NCF mainly to lower occupancy and base
rent, reflecting the continued challenges that the retail mall
sector faces.

"Therefore, we revised and lowered our long-term sustainable NCF by
27.5% to $24.8 million, which aligns to the 2021 servicer-reported
figures. Using a 9.00% S&P Global Ratings' capitalization rate (up
from 8.50% at our last review in December 2020), we arrived at an
expected-case valuation of $275.0 million--a decline of 31.5% from
our last review value of $401.7 million and 35.3% from the 2020
appraisal value of $425.0 million. This yielded an S&P Global
Ratings' loan-to-value (LTV) ratio of 152.2% on the whole loan
balance."

Although the model-indicated ratings on classes A and B were lower
than their current rating levels, S&P tempered its downgrades on
these classes because it weighed certain qualitative
considerations, including:

-- The potential that the property's operating performance could
increase above S&P's revised expectations;

-- The market value decline based on the 2020 appraisal value that
would be needed before these classes experience principal losses;

-- The liquidity support provided in the form of servicer
advancing; and

-- The relative position of these classes in the payment
waterfall.

In addition, the downgrades on classes C and D to 'CCC (sf)' and
'CCC- (sf)', respectively, reflect S&P's view that, based on an S&P
Global Ratings' LTV ratio over 100% on the loan, these classes are
more susceptible to reduced liquidity support and exhibit an
elevated risk of default and loss due to current market
conditions.

S&P said, "We lowered our rating on the class X-NCP IO certificates
based on our criteria for rating IO securities, in which the rating
on the IO securities would not be higher than that of the
lowest-rated reference class. The notional amount of class X-NCP
references classes A, B, C and D.

"We will continue to monitor for further development on the loan,
particularly, the resolution strategy and timing. If the property's
performance does not improve or if there are reported negative
changes in the performance or resolution strategy beyond what we
have already considered, we may revisit our analysis and adjust our
ratings further, as necessary."

Property-Level Analysis

-- Palisades Center is a 2.2-million-sq.-ft. (of which 1.9 million
sq. ft. serves as collateral) super-regional mall and entertainment
center in West Nyack, N.Y. The property is anchored by Macy's
(201,000 sq. ft., noncollateral), Home Depot (132,800 sq. ft.),
Target (1130,140 sq. ft.), and BJ's Wholesale Club (118,076 sq.
ft.). There are also two vacant anchor boxes (157,000 sq. ft.
[collateral] formerly occupied by JC Penney and 120,000 sq. ft.
[noncollateral] formerly occupied by Lord & Taylor) at the
property. According to the master servicer, Wells Fargo Bank N.A.,
there are currently no plans to backfill or redevelop these vacant
anchor spaces.

S&P's property-level analysis considers the decline in
servicer-reported NCF in the three years prior to the COVID-19
pandemic, as well as the further steeper decline in 2020, 2021, and
partial-2022, as discussed previously. According to the June 30,
2022, rent roll, the collateral property was 74.8% leased. The
five-largest tenants made up 29.0% of the collateral net rentable
area (NRA) and include:

-- Home Depot (7.0% of NRA, 4.6% of in place gross rent as
calculated by S&P Global Ratings, January 2029 lease expiration);
Target (6.9%, 3.8%, January 2024);

-- BJ's Wholesale Club (6.2%, 4.4%, February 2023);

-- Dick's Sporting Goods (5.0%, 2.6%, January 2028); and

-- AMC Palisades Center 21 (3.9%, 9.4%, December 2028).

The mall faces elevated tenant rollover risk in 2023 (15.5% of
in-place gross rent, as calculated by S&P Global Ratings), 2024
(16.8%), 2025 (10.4%), 2026 (10.1%), and 2028 (16.4%). The rollover
risk during this time is generally diversified with various
tenants; however, the major tenants noted above are among the
expiring tenants.

S&P said, "Due to the increasing trend of retail tenant
bankruptcies and store closures, where applicable, we increased our
lost rent assumptions and excluded income from those tenants no
longer listed on the respective mall directory websites or those
that have filed for bankruptcy protection or announced store
closures. As such, our current analysis assumed a collateral
occupancy rate of 73.5%, in-place gross rent of $27.69 per sq. ft.,
and operating expense ratio of 54.7% to derive a long-term
sustainable NCF of $24.8 million. Using a higher capitalization
rate of 9.00%, which reflects our view that this mall exhibits
class B to class B- qualities, we arrived at an expected-case value
of $275.0 million." The mall was last appraised at $425.0 million
in August 2020, which is a 51.8% decline from the issuance
appraisal value of $881.0 million.

Transaction Summary

This is a U.S. stand-alone (single borrower) transaction backed by
a portion of a fixed-rate, IO mortgage whole loan. The whole loan
is secured by the borrower's fee and leasehold interests in a
portion (1.9 million sq. ft.) of a 2.2 million-sq.-ft.
super-regional mall and entertainment center known as Palisades
Center in West Nyack, N.Y.

The IO mortgage whole loan had an initial and current balance of
$418.5 million, pays an annual fixed interest rate of 4.188%, and
currently matures on Oct. 9, 2022. The whole loan is split into
three senior A notes totaling $259.1 million and six subordinate
junior B, C, and D notes totaling $159.4 million. The $388.5
million trust balance (according to the Sept. 15, 2022, trustee
remittance report), comprises two senior A notes totaling $229.1
million and six subordinate junior notes totaling $159.4 million.
The other senior A note totaling $30.0 million is in JPMDB
Commercial Mortgage Securities Trust 2016-C2, a U.S. CMBS
transaction. The senior A notes are pari passu to each other and
senior to the subordinate junior B, C, and D notes. The master
servicer reported a 1.27x debt service coverage on the whole loan
balance for the six months ended June 30, 2022. To date, the trust
has not incurred any principal losses.

The loan originally transferred to special servicing on April 10,
2020, due to imminent monetary default because the borrower
requested COVID-19-related relief. The loan was modified and
returned to the master servicer on May 24, 2021. The final
modification terms included, among other items, deferring six
months of debt service payments (April to September 2020) and
extending the loan's original April 9, 2021, maturity date to Oct.
9, 2022. According to the September 2022 trustee remittance report,
$8.4 million of principal and interest advances remain outstanding.
Per the servicer's report, $8.3 million is currently held in
various reserve accounts.

S&P said, "It is our understanding from Wells Fargo that the loan
was transferred back to special servicing on Sept. 27, 2022, due to
imminent maturity default. The sponsor, Pyramid Management Group
LLC, also had three other retail loans in two U.S. CMBS
transactions (J.P. Morgan Chase Commercial Mortgage Securities
Trust 2014-DSTY and J.P. Morgan Chase Commercial Mortgage
Securities Trust 2012-WLDN) transferred to special servicing in
early 2022 due to maturity default. These loans have since been
modified and extended. We will continue to monitor the resolution
strategy and update our analysis, as necessary."

The recent rapid spread of the omicron variant highlights the
inherent uncertainties of the pandemic but also the importance and
benefits of vaccines. While the risk of new, more severe variants
displacing Omicron and evading existing immunity cannot be ruled
out, our current base case assumes that existing vaccines can
continue to provide significant protection against severe illness.
Furthermore, many governments, businesses, and households around
the world are tailoring policies to limit the adverse economic
impact of recurring COVID-19 waves. S&P said, "Consequently, we do
not expect a repeat of the sharp global economic contraction of
second-quarter 2020. Meanwhile, we continue to assess how well
individual issuers adapt to new waves in their geography or
industry."

  Ratings Lowered

  Palisades Center Trust 2016-PLSD

  Class A to 'BB (sf)' from 'BBB (sf)'
  Class B to 'B- (sf)' from 'BB- (sf)'
  Class C to 'CCC (sf)' from 'B- (sf)'
  Class D to 'CCC- (sf)' from 'CCC (sf)'
  Class X-NCP to 'CCC- (sf)' from 'CCC (sf)'



PENNANTPARK CLO V: S&P Assigns Prelim 'BB-' Rating on Cl. E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to PennantPark
CLO V LLC's fixed- and floating-rate debt.

The debt issuance is a CLO securitization governed by investment
criteria and backed primarily by middle market speculative-grade
(rated 'BB+' or lower) senior secured term loans. The transaction
is managed by PennantPark Investment Advisers LLC.

The preliminary ratings are based on information as of Oct. 10,
2022. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The diversification of the collateral pool;

-- The credit enhancement provided through subordination, excess
spread, and overcollateralization;

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

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

  Preliminary Ratings Assigned

  PennantPark CLO V LLC

  Class A-1A notes, $40.00 million: AAA (sf)
  Class A-1A loans, $85.00 million: AAA (sf)
  Class A-1F notes, $46.00 million: AAA (sf)
  Class A-2 notes, $12.00 million: AAA (sf)
  Class B notes, $21.00 million: AA (sf)
  Class C notes, $24.00 million: A (sf)
  Class D notes, $18.00 million: BBB- (sf)
  Class E notes, $18.00 million: BB- (sf)
  Subordinated notes, $34.70 million: Not rated



PFP LTD 2022-9: Fitch Assigns 'B-sf' Rating on Class G Notes
------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to PFP
2022-9, Ltd.:

   Debt                 Rating              Prior
   ----                 ------              -------
PFP 2022-9

   A                LT  AAAsf  New Rating   AAA(EXP)sf
   A-S              LT  AAAsf  New Rating   AAA(EXP)sf
   B                LT  AA-sf  New Rating   AA-(EXP)sf
   C                LT  A-sf   New Rating   A-(EXP)sf
   D                LT  BBBsf  New Rating   BBB(EXP)sf
   E                LT  BBB-sf New Rating   BBB-(EXP)sf
   F                LT  BB-sf  New Rating   BB-(EXP)sf
   G                LT  B-sf   New Rating   B-(EXP)sf
   Preferred Shares LT  NRsf   New Rating   NR(EXP)sf

- $509,597,000 class A 'AAAsf'; Outlook Stable;

- $89,067,000 class A-S 'AAAsf'; Outlook Stable;

- $59,754,000 class B 'AA-sf'; Outlook Stable;

- $52,989,000 class C 'A-sf'; Outlook Stable;

- $36,078,000 class D; 'BBBsf'; Outlook Stable;

- $14,656,000 class E; 'BBB-sf'; Outlook Stable;

- $32,696,000a class F; 'BB-sf'; Outlook Stable;

- $20,293,000a class G; 'B-sf'; Outlook Stable.

The following class is not rated by Fitch:

- $86,812,881a class Preferred Shares;

a. The horizontal credit risk retention interest is contained in
these classes, which are not being offered.

The approximate collateral interest balance as of the cutoff date
is $901,942,881 and does not include future fundings.

TRANSACTION SUMMARY

The notes represent the beneficial ownership interest in the
issuer, the primary assets of which are 29 loans secured by 33
commercial properties with an aggregate principal balance of
$901,942,881 as of the cut-off date. The loans were contributed to
the trust by PFP 2022-9 Depositor, LLC. The servicer is expected to
be Situs Asset Management LLC, and the special servicer is expected
to be Situs Holdings, LLC.

KEY RATING DRIVERS

Collateral Attributes: In general, the pool is secured by
properties that have not yet completely stabilized or will undergo
renovation. The associated risks, including cash flow interruption
during renovation, lease-up and completion, are mitigated by
experienced sponsorship, credible business plans and loan
structural features that include guaranties, reserves, cash
management and performance triggers, and additional funding
mechanisms.

Fitch Leverage: The pool's leverage statistics are higher than
those of recent Fitch-rated 'conduit' transactions. The pool's
Fitch DSCR is 0.65x; the pool's Fitch LTV is 175.6%; the
transaction's Fitch debt yield is 5.62%. Year-to-date Fitch-rated
'conduit' metrics are as follows: Fitch DSCR 1.34x; Fitch LTV
100.9%; Fitch debt yield 9.66%. Given the high Fitch Leverage and
pool concentration of 58.5% for the top 10 loans, Fitch's
Deterministic Stress influences credit enhancement.

Pool Concentration: The pool is more concentrated than recently
rated 'conduit' transactions. The top 10 loans represent 58.5%. The
2022 year-to-date average concentration for the top 10 loans is
55.5% and for 2021 51.2%. Given the concentration and the high
Fitch Leverage, Fitch's Deterministic Stress is influencing credit
enhancement.

Loan Structure: The loans in the pool are typically structured with
two-year initial terms with three one-year extension options. Fitch
historical loan performance analysis shows loans with terms less
than 10 years have modestly lower default risk, all else equal.
This is mainly attributed to the shorter window of exposure to
potential adverse economic conditions.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to 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:
'AAAsf'/'AA-sf'/BBB+sf'/'BB+sf'/'BBsf'/'CCCsf'/'CCCsf';

20% NCF Decline:
'AAAsf'/'AA-sf'/BBB-sf'/'BB-sf'/'CCCsf'/'CCCsf'/'CCCsf';

30% NCF Decline:
'AAAsf'/'AA-sf'/BB+sf'/'CCCsf'/'CCCsf'/'CCCsf'/'CCCsf'.

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

Similarly, 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'/'Asf'/'BBB+sf'/'BBB-sf'/'BBsf'.

CRITERIA VARIATION

An element of Fitch's analysis of the transaction involved cash
flow modeling. This is a variation from Fitch's CMBS criteria as
the criteria does not include cash flow modeling. The deal
structure proved robust under multiple stress scenarios.

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.


PRESTIGE AUTO 2022-1: S&P Assigns Prelim BB-(sf) Rating on E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Prestige
Auto Receivables Trust 2022-1's automobile receivables-backed notes
series 2022-1.

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

The preliminary ratings are based on information as of Oct. 6,
2022. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

-- The availability of approximately 53.8%, 47.0%, 37.7%, 28.8%,
and 22.8% credit support (hard credit enhancement and haircut to
excess spread) for the class A, B, C, D, and E notes, respectively,
based on stressed cash-flow scenarios. These credit support levels
provide at least 3.30x, 2.85x, 2.25x, 1.70x, and 1.37x coverage of
S&P's expected cumulative net loss of 16.00% for the class A, B, C,
D, and E notes, respectively.

-- The expectation that under a moderate ('BBB') stress scenario
(1.70x S&P's expected loss level), all else being equal, its
preliminary 'AAA (sf)', 'AA (sf)', 'A (sf)', 'BBB (sf)', and 'BB-
(sf)'ratings on the class A, B, C, D, and E notes, respectively,
are within its credit stability limits.

-- The timely payment of interest and principal by the designated
legal final maturity dates under our stressed cash flow modeling
scenarios, which S&P believes are appropriate for the assigned
preliminary ratings.

-- The collateral characteristics of the subprime automobile loans
securitized in this transaction, S&P's view of the credit risk of
the collateral, and our updated macroeconomic forecast and
forward-looking view of the auto finance sector.

-- S&P's assessment of the series' bank accounts at Citibank N.A.
(Citibank), which do not constrain the preliminary ratings.

-- S&P's operational risk assessment of Prestige Financial
Services Inc. as servicer, and its view of the company's
underwriting and the backup servicing with Citibank.

-- S&P's assessment of the transaction's potential exposure to
environmental, social, and governance credit factors, which are in
line with its sector benchmark.

-- The transaction's payment and legal structures.

  Preliminary Ratings Assigned

  Prestige Auto Receivables Trust 2022-1

  Class A-1, $48.00 million(i): A-1+ (sf)
  Class A-2, $112.23 million(i): AAA (sf)
  Class A-3, $47.61 million(i): AAA (sf)
  Class B, $40.53 million(i): AA (sf)
  Class C, $44.89 million(i): A (sf)
  Class D, $46.76 million(i): BBB (sf)
  Class E, $38.25 million(i): BB- (sf)

(i)The actual size of these tranches will be determined on the
pricing date.



RAD CLO 17: Fitch Assigns 'BB-(EXP)sf' Rating on Class E Notes
--------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Rad CLO 17, Ltd.

   Debt                  Rating           
   ----                  ------          
RAD CLO 17, Ltd.

   A                  LT NR(EXP)sf   Expected Rating
   B-1                LT AA(EXP)sf   Expected Rating
   B-2                LT AA(EXP)sf   Expected Rating
   C                  LT A(EXP)sf    Expected Rating
   D                  LT BBB-(EXP)sf Expected Rating
   E                  LT BB-(EXP)sf  Expected Rating
   Subordinated Notes LT NR(EXP)sf   Expected Rating

TRANSACTION SUMMARY

Rad CLO 17, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by
Irradiant Partners, LP. Net proceeds from the issuance of the
secured and subordinated notes will provide financing on a
portfolio of approximately $500 million of primarily first lien
senior secured leveraged loans.

KEY RATING DRIVERS

Asset Credit Quality (Negative): The average credit quality of the
indicative portfolio is 'B/B-', which is in line with that of
recent CLOs. The weighted average rating factor (WARF) of the
indicative portfolio is 24.9 versus a maximum covenant, in
accordance with the initial expected matrix point of 26.2. Issuers
rated in the 'B' rating category denote a highly speculative credit
quality; however, the notes benefit from appropriate credit
enhancement and standard U.S. CLO structural features.

Asset Security (Positive): The indicative portfolio consists of
97.3% first-lien senior secured loans. The weighted average
recovery assumption (WARR) of the indicative portfolio is 75.43%
versus a minimum covenant of 73.00%.

Portfolio Composition (Positive): The largest three industries may
constitute up to 39.0% of the portfolio balance in aggregate while
the top five obligors can represent up to 12.5% of the portfolio
balance in aggregate. The level of diversity required by industry,
obligor and geographic concentrations is in line with other recent
U.S. CLOs.

Portfolio Management (Neutral): The transaction has a 5.0-year
reinvestment period and reinvestment criteria similar to other U.S.
CLOs. Fitch's analysis was based on a stressed portfolio created by
making adjustments to the indicative portfolio to reflect
permissible concentration limits and collateral quality test
levels.

Cash Flow Analysis (Positive): Fitch used a customized proprietary
cash flow model to replicate the principal and interest waterfalls
and assess the effectiveness of various structural features of the
transaction. In Fitch's stress scenarios at the initial expected
matrix point, the rated notes can withstand default and recovery
assumptions for their assigned ratings.

RATING SENSITIVITIES

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

Variability in key model assumptions, such as decreases in recovery
rates and increases in default rates, could result in a downgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
a metric. The results under these sensitivity scenarios are between
'BB+sf' and 'AA+sf' for class B, between 'Bsf' and 'A+sf' for class
C, between less than 'B-sf' and 'BBB+sf' for class D, and between
less than 'B-sf' and 'BB-sf' for class E.

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

Variability in key model assumptions, such as increases in recovery
rates and decreases in default rates, could result in an upgrade.
Fitch evaluated the notes' sensitivity to potential changes in such
metrics; results under these sensitivity scenarios are 'AAAsf' for
class B notes, between 'A+sf' and 'AA+sf' for class C notes, 'A+sf'
for class D notes, and 'BBB+sf' for class E notes.

DATA ADEQUACY

The majority of the underlying assets or risk-presenting entities
have ratings or credit opinions from Fitch and/or other Nationally
Recognized Statistical Rating Organizations and/or European
Securities and Markets Authority registered rating agencies. Fitch
has relied on the practices of the relevant groups within Fitch
and/or other rating agencies to assess the asset portfolio
information.

Overall, Fitch's assessment of the asset pool information relied
upon for the agency's rating analysis according to its applicable
rating methodologies indicates that it is adequately reliable.


SANTANDER CONSUMER 2021-A: Fitch Affirms 'B' Rating on Cl. F Notes
------------------------------------------------------------------
Fitch Ratings has affirmed the class A-3, A-4, B and F notes and
upgraded the class C, D and E notes of Santander Consumer Auto
Receivables Trust (SCART) 2021-A. Fitch has also revised the Rating
Outlook on the class F notes to Positive from Stable.

   Debt              Rating          Prior
   ----              ------          -----
Santander Consumer Auto
Receivables Trust 2021-A

   A-3 80282YAC0  LT AAAsf Affirmed  AAAsf
   A-4 80282YAD8  LT AAAsf Affirmed  AAAsf
   B 80282YAE6    LT AAAsf Affirmed  AAAsf
   C 80282YAF3    LT AAAsf Upgrade   AAsf
   D 80282YAG1    LT Asf   Upgrade   BBBsf
   E 80282YAH9    LT BBBsf Upgrade   BBsf
   F 80282YAJ5    LT Bsf   Affirmed  Bsf

KEY RATING DRIVERS

The rating actions are based on available CE and CNL performance to
date. The collateral pool continues to perform within Fitch's
initial expectations, and hard CE is building for the notes. The
notes are able to withstand stress scenarios consistent with the
recommended ratings, and make full payments to investors in
accordance with the terms of the documents.

The Rating Outlooks of Stable on the class A-3, A-4, B and C notes
reflect Fitch's expectation that the notes have sufficient levels
of credit protection to withstand potential deterioration in credit
quality of the portfolio in stress scenarios and that loss coverage
will continue to increase as the transactions amortize. The
Positive Rating Outlooks on the class D, E and F notes reflect the
potential for subsequent upgrades in the next one to two years.

The lifetime CNL proxy considers the transaction's remaining pool
factor and pool composition. Further, the proxy considers current
and future macro-economic conditions which drive loss frequency,
along with the state of wholesale vehicle values, which impact
recovery rates and ultimately transaction losses.

As of the September 2022 servicer report, 61+ day delinquencies
total 0.63%, and CNLs are 0.39%, tracking well within Fitch's
initial CNL proxy at close of 3.25%. Hard CE (of the current pool
balance) has increased to 32.26%, 25.67% 19.61%, 13.56%, 9.24%, and
4.48% for the class A, B, C, D, E and F notes, respectively. Based
on transaction specific performance to date and future projections,
Fitch lowered the lifetime CNL loss proxy to 1.30% of the initial
pool from 2.00% in the last review and 3.25% at close.

Under the revised lifetime CNL loss proxy of 1.30%, cash flow
modelling continues to support multiples in excess of 5x for a
'AAAsf' rating for the class A-3, A-4 and B notes. For the class C,
D and E notes, cash flow modelling supported multiples of at least
one rating category higher than the current rating, in support of a
one category upgrade for the classes. For the class F notes, cash
flow modelling supported multiples at least at the current rating
category, in support of affirmation.

RATING SENSITIVITIES

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

Unanticipated increases in the frequency of defaults could produce
default levels higher than the current projected base case default
proxy, and impact available loss coverage and multiples levels for
the transaction. Weakening asset performance is strongly correlated
to increasing levels of delinquencies and defaults that could
negatively impact CE levels. Lower loss coverage could impact
ratings and Outlooks, depending on the extent of the decline in
coverage.

In Fitch's initial review, the notes were found to have some
sensitivity to a 1.5x and 2.0x increase of Fitch's base case loss
expectation. However, considering the growth in loss coverage,
downgrades are unlikely.

Fitch has revised global economic outlook forecasts as a result of
the Ukraine War and related economic sanctions. Downside risks have
increased, and Fitch has published an assessment of the potential
rating and asset performance impact of a plausible, but
worse-than-expected, adverse stagflation scenario on Fitch's major
SF and CVB sub-sectors.

Fitch expects the North American Prime Auto ABS sector in the
assumed adverse scenario to experience "Virtually No Impact" on
ratings performance, indicating very few (less than 5%) rating or
Outlook changes. Fitch also expects "Virtually No Impact" on asset
performance, indicating asset performance to remain broadly
unaffected, and less than a 10% likelihood of sector outlook
revision by YE 2023. Fitch expects the asset performance impact of
the adverse case scenario to be more modest than the scenarios
discussed above that increase the default expectations by 2.0x.

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

Stable to improved asset performance driven by stable delinquencies
and defaults would lead to increasing CE levels and consideration
for potential upgrades. If CNL is 20% less than projected CNL
proxy, the ratings could be upgraded by one or more rating
categories.

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.


SIERRA TIMESHARE 2022-3: Fitch Gives BB-(EXP) Rating on Cl. D Notes
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
notes issued by Sierra Timeshare 2022-3 Receivables Funding LLC
(2022-3).

   Entity/Debt       Rating
   -----------       ------
Sierra Timeshare 2022-3
Receivables Funding LLC

   A          LT   AAA(EXP)sf  Expected Rating
   B          LT   A(EXP)sf    Expected Rating
   C          LT   BBB(EXP)sf  Expected Rating
   D          LT   BB-(EXP)sf  Expected Rating

TRANSACTION SUMMARY

The notes are backed by a pool of fixed-rate timeshare loans
originated by Wyndham Vacation Resorts, Inc. (WVRI) and Wyndham
Resort Development Corporation (WRDC). Both entities are indirect,
wholly owned operating subsidiaries of Travel + Leisure Co. (T+L,
formerly Wyndham Destinations, Inc.) This is T+L's 44th public
Sierra transaction.

KEY RATING DRIVERS

Borrower Risk - Shifting Collateral Composition: Approximately
69.4% of Sierra 2022-3 consists of WVRI-originated loans; the
remainder of the pool comprises WRDC loans. Fitch has determined
that, on a like-for-like FICO basis, WRDC's receivables perform
better than WVRI's. The weighted average (WA) original FICO score
of the pool is 731, slightly lower than 733 in Sierra 2022-2.
Additionally, compared with the prior transaction, the 2022-3 pool
has overall weaker FICO segment concentrations, but with slightly
lower concentration in WVRI loans.

Forward-Looking Approach on Cumulative Gross Default (CGD) Proxy -
Increasing CGDs: Similar to other timeshare originators, T+L's
delinquency and default performance exhibited notable increases in
the 2007-2008 vintages, stabilizing in 2009 and thereafter.
However, more recent vintages, from 2014 through 2019, have begun
to show increasing gross defaults versus prior vintages dating back
to 2009, partially driven by increased paid product exits (PPE).
Fitch's CGD proxy for this pool is 23.00% (up from 22.50% for
2022-2). Given the current economic environment and consistent with
the prior transaction, Fitch used proxy vintages that reflect a
recessionary period along with recent vintage performance,
specifically 2007-2009 and 2016-2019 vintages.

Structural Analysis - Higher CE: Initial hard CE for the class A,
B, C and D notes is 68.65%, 46.50%, 24.25% and 15.00%,
respectively. CE is higher for the class A through D notes relative
to 2022-2, mainly due to higher overcollateralization (OC) as
compared with the prior transaction. Hard CE comprises OC, a
reserve account and subordination. Soft CE is also provided by
excess spread and is expected to be 7.45% per annum. Loss coverage
for all notes is able to support default multiples of 3.25x, 2.25x,
1.50x and 1.17x for 'AAAsf', 'Asf', 'BBBsf' and 'BB-sf',
respectively.

Originator/Seller/Servicer Operational Review — Quality of
Origination/Servicing: T+L has demonstrated sufficient capabilities
as an originator and servicer of timeshare loans. This is evidenced
by the historical delinquency and loss performance of securitized
trusts and of the managed portfolio.

RATING SENSITIVITIES

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

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

Therefore, Fitch conducts sensitivity analyses by stressing both a
transaction's initial base case CGD and prepayment assumptions and
examining the rating implications on all classes of issued notes.
The CGD sensitivity stresses the CGD proxy to the level necessary
to reduce each rating by one full category, to non-investment grade
(BBsf) and to 'CCCsf' based on the break-even loss coverage
provided by the CE structure. The CGD and prepayment sensitivities
include 1.5x and 2.0x increases to the prepayment assumptions,
representing moderate and severe stresses, respectively. These
analyses are intended to provide an indication of the rating
sensitivity of the notes to unexpected deterioration of a trust's
performance.

Fitch has revised its global economic outlook forecasts as a result
of the war in Ukraine and related economic sanctions. The downside
risks have increased; as such, Fitch has published an assessment of
the potential rating and asset performance impact of a plausible
but worse than expected adverse stagflation scenario on Fitch's
major structured finance and covered bonds subsectors.

Fitch expects the timeshare ABS sector in the assumed adverse
scenario to experience 'Virtually No Impact' on rating performance,
indicating very few (less than 5%) rating or Rating Outlook
changes. Fitch expects 'Mild to Modest Impact' on asset
performance, indicating asset performance will be modestly
negatively affected relative to current expectations, with a 25%
chance of a sector outlook revision by YE23.

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

Stable to improved asset performance driven by stable delinquencies
and defaults would lead to increasing CE levels and consideration
for potential upgrades. If CGD is 20% less than the projected
proxy, the expected ratings would be maintained for the class A
note at a stronger rating multiple. For class B, C and D notes, the
multiples would increase, resulting in potential upgrade of
approximately up to one rating category for each of the subordinate
classes.

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.


SIERRA TIMESHARE 2022-3: S&P Assigns Prelim BB- Rating on D Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Sierra
Timeshare 2022-3 Receivables Funding LLC's timeshare loan-backed,
fixed-rate notes.

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

The preliminary ratings are based on information as of Oct. 5,
2022. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

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

-- Wyndham Consumer Finance Inc.'s servicing ability and
experience in the timeshare market.

-- The transaction's ability to pay timely interest and ultimate
principal by the notes' legal maturity under our stressed cash flow
recovery rate, and credit stability sensitivity scenarios.

  Preliminary Ratings Assigned

  Sierra Timeshare 2022-3 Receivables Funding LLC

  Class A, $96.714 million: AAA (sf)
  Class B, $63.286 million: A (sf)
  Class C, $63.571 million: BBB (sf)
  Class D, $26.429 million: BB- (sf)



UBS COMMERCIAL 2017-C7: Fitch Affirms 'B-sf' Rating on G-RR Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed 13 classes of UBS Commercial Mortgage
Trust 2017-C7 commercial mortgage pass-through certificates series
2017-C7. The Rating Outlook for class G-RR has been revised to
Stable from Negative.

   Debt               Rating           Prior
   ----               ------           -------
UBS 2017-C7

   A-2 90276WAP2   LT AAAsf Affirmed   AAAsf
   A-3 90276WAR8   LT AAAsf Affirmed   AAAsf
   A-4 90276WAS6   LT AAAsf Affirmed   AAAsf
   A-S 90276WAV9   LT AAAsf Affirmed   AAAsf
   A-SB 90276WAQ0  LT AAAsf Affirmed   AAAsf
   B 90276WAW7     LT AA-sf Affirmed   AA-sf
   C 90276WAX5     LT A-sf  Affirmed   A-sf
   D-RR 90276WAA5  LT BBBsf Affirmed   BBBsf
   E-RR 90276WAC1  LT BBB-sf Affirmed  BBB-sf
   F-RR 90276WAE7  LT BB-sf Affirmed   BB-sf
   G-RR 90276WAG2  LT B-sf  Affirmed   B-sf
   X-A 90276WAT4   LT AAAsf Affirmed   AAAsf
   X-B 90276WAU1   LT AA-sf Affirmed   AA-sf

KEY RATING DRIVERS

Improved Loss Expectations: The Outlook revision to Stable from
Negative on class G-RR reflects improved loss expectations for the
pool since the prior rating action due to stabilizing performance
of loans affected by the pandemic. Fitch's current ratings
incorporate a base case loss of 3.00%. There are six Fitch Loans of
Concern (FLOCs; 14.7% of pool).

The largest increase in loss since the prior rating action is the
National Office Portfolio loan (6.2%), which is secured by a 2.6
million-sf suburban office portfolio consisting of 18 properties
across four states (TX, IL, GA, AZ). This FLOC was flagged due to
declining NOI and upcoming lease rollover concerns. YE 2021 NOI
fell 18.7% from 2020 due primarily to higher operating expenses
(mostly general and administrative expense) and lower rental
income. Upcoming rollover consists of 17.6% of the portfolio NRA in
2022 and 11.6% in 2023.

The portfolio was 76.6% occupied as of June 2022, compared with 74%
in December 2021, 73% at YE 2020, 79% at YE 2019 and 77.5% around
the time of issuance. The rent roll is granular; at issuance, Fitch
noted that the buildings were leased to more than 1,000 different
tenants and no tenant accounted for more than 4.5% NRA. The largest
tenants include American Intercontinental University (4.5% of
portfolio NRA; lease expiry in May 2028) and Trinity Universal
Insurance Co (3.3%; June 2025).

Fitch's base case loss of 5% reflects a 10% cap rate and 10% stress
to the YE 2021 NOI to address upcoming lease rollover.

The next largest increase in loss is the RPI Student Housing
Portfolio loan (0.9%), which is secured by a 35-property, 259-bed
multifamily student housing portfolio. The properties serve as
off-campus housing for students at the Rensselaer Polytechnic
Institute (RPI) in Troy, NY. Per the servicer, the pandemic has
negatively affected the property's performance as student numbers
returning to campus have been down significantly.

YE 2021 NOI was down 39% from YE 2020, and was 46% below the
pre-pandemic YE 2019 NOI. Portfolio occupancy was 54.9% at YE 2021,
compared with 53.7% at YE 2020 and 96.1% at YE 2019. Fitch's base
case loss of 17% reflects a 9.25% cap rate to the YE 2021 NOI.

The next largest increase in loss is the Plaza Del Sol loan (3.4%),
which is secured by a 165,528-sf mixed use retail/industrial
property located in Burbank, CA. Occupancy fell to 80.8% as of June
2022 from 98.7% at YE 2021 and 100% at YE 2020. This was due to the
third largest tenant Oakwood Worldwide (17% of NRA; 12% of total
base rents) vacating at expiration in February 2022.

The center is anchored by Vallarta Supermarkets (27% of NRA; 26% of
total base rents; leased through December 2023) and major tenants
include Planet Fitness (17.1%; December 2026), Wet Design (11.9%;
March 2027) and Diet to Go (10.4%; September 2024). Upcoming lease
rollover includes 1.5% of the NRA in 2022, 29.3% in 2023 and 13.4%
in 2024. The 2023 rollover is primarily concentrated in the
December 2023 expiration of largest tenant Vallarta Supermarkets.

Fitch's base case loss of 8% reflects a 25% stress to the YE 2020
NOI to reflect the declining occupancy and significant upcoming
lease rollover.

Increasing Credit Enhancement (CE): As of the September 2022
distribution date, the pool's principal balance has been paid down
by 8.4% to $816 million from $891 million at issuance. Since the
prior rating action, one loan (Griffin Portfolio; $37.5 million)
was repaid ahead of its scheduled 2027 maturity. One loan, Eagle
Multifamily Portfolio (7.1% of pool), has been fully defeased since
the prior rating action.

Ten loans (32.4%) are full-term interest-only and six loans (10%)
still have a partial interest-only component during their remaining
loan term, compared with 31.7% of the original pool at issuance.
Four loans (5.9%) are scheduled to mature in prior to the end of
2022, 35 loans (72.2%) in 2027, six loans (17.3%) in 2028 and one
loan (4.6%) in 2033.

RATING SENSITIVITIES

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

Downgrades would occur with an increase in pool-level losses from
underperforming or specially serviced loans. Downgrades to classes
A-2, A-3, A-4, A-SB, A-S and X-A are not likely due to the
increasing CE, expected continued paydown and overall stable to
improving performance, but may occur should interest shortfalls
affect these classes. Downgrades to classes B, X-B and C may occur
should pool loss expectations increase significantly and should all
of the FLOCs suffer losses, which would erode CE.

Downgrades to classes D-RR, E-RR, F-RR and G-RR may occur with
further performance deterioration of the FLOCs and/or should
additional loans default or transfer to special servicing.

Fitch has identified both a baseline and a worse-than-expected,
adverse stagflation scenario based on fallout from the
Russia-Ukraine war whereby growth is sharply lower amid higher
inflation and interest rates; even if the adverse scenario should
play out, Fitch expects virtually no impact on ratings performance,
indicating very few rating or Outlook changes. However, for some
transactions with concentrations in underperforming retail
exposure, the ratings impact may be mild to modest, indicating some
changes on sub-investment grade notes.

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

Upgrades would occur with stable to improved asset performance,
particularly on the FLOCs, coupled with additional paydown and/or
defeasance. Upgrades to classes B, X-B and C would only occur with
significant improvement in CE, defeasance, and/or performance
stabilization of FLOCs and other properties affected by the
pandemic.

Upgrades to classes D-RR, E-RR, F-RR and G-RR are not likely until
the later years of the transaction and only if the performance of
the remaining pool is stable and/or properties vulnerable to the
pandemic return to pre-pandemic levels, the number of FLOCs is
reduced and there is sufficient CE to the classes. Classes would
not be upgraded above 'Asf' if there were likelihood of interest
shortfalls.

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.


UBS-BARCLAYS 2012-C2: Moody's Lowers Rating on Cl. EC Certs to B3
-----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings on five classes
and downgraded the ratings on six classes in UBS-Barclays
Commercial Mortgage Trust 2012-C2, Commercial Mortgage Pass-Through
Certificates, Series 2012-C2:

Cl. A-4, Affirmed Aaa (sf); previously on May 23, 2022 Affirmed Aaa
(sf)

Cl. A-S-EC, Downgraded to Baa3 (sf); previously on May 23, 2022
Downgraded to Baa1 (sf)

Cl. B-EC, Downgraded to Caa1 (sf); previously on May 23, 2022
Downgraded to B2 (sf)

Cl. C-EC, Downgraded to Caa3 (sf); previously on May 23, 2022
Downgraded to Caa2 (sf)

Cl. D, Downgraded to C (sf); previously on May 23, 2022 Downgraded
to Caa3 (sf)

Cl. E, Affirmed C (sf); previously on May 23, 2022 Downgraded to C
(sf)

Cl. F, Affirmed C (sf); previously on May 23, 2022 Affirmed C (sf)

Cl. G, Affirmed C (sf); previously on May 23, 2022 Affirmed C (sf)

Cl. X-A*, Downgraded to Baa3 (sf); previously on May 23, 2022
Downgraded to A2 (sf)

Cl. X-B*, Affirmed Ca (sf); previously on May 23, 2022 Affirmed Ca
(sf)

Cl. EC, Downgraded to B3 (sf); previously on May 23, 2022
Downgraded to B2 (sf)

*  Reflects Interest-Only Classes

RATINGS RATIONALE

The rating on one P&I class, Cl. A-4, was affirmed due to its
significant credit support and anticipated principal recovery from
the remaining loans in the pool.

The ratings on four P&I classes were downgraded due to potentially
higher losses and interest shortfall risks from the significant
exposure to specially serviced and delinquent loans. As of the
September 2022 remittance, all the remaining loans were in special
servicing and have passed their initial scheduled maturity dates.
Five of the special serviced loans (secured by four properties),
58% of the pool, have received an aggregate appraisal reduction
amount of approximately $132 million and were deemed
non-recoverable as of the September 2022 remittance date. While
interest shortfalls were repaid to classes A-S-EC, B-EC, and C-EC
due to a disposed loan, Moody's anticipates interest shortfalls
will likely increase due the performance of the remaining loans.

The ratings on three P&I classes, Cl. E. Cl. F and Cl. G, were
affirmed because the ratings are consistent with Moody's expected
loss.

The rating on one IO class, Cl. X-B, was affirmed based on the
credit quality of the referenced classes.

The rating on one IO class was, Cl. X-A, downgraded due to paydowns
of highly rated classes and a decline in the credit quality of the
referenced classes.

The rating on the exchangeable class, Cl. EC, was downgraded due to
the decline in credit quality of its referenced exchangeable
classes.

Moody's regard e-commerce competition as a social risk under
Moody's ESG framework. The rise in e-commerce and changing consumer
behavior presents challenges to brick-and-mortar discretionary
retailers.

Moody's rating action reflects a base expected loss of 49.6% of the
current pooled balance, compared to 38.2% at Moody's last review.
Moody's base expected loss plus realized losses is now 16.2% of the
original pooled balance, compared to 15.0% at the last review.

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

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

Factors that could lead to an upgrade of the ratings include a
significant amount of loan paydowns or amortization or an
significant improvement in pool performance.

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

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in rating all classes except the
interest-only classes was "Large Loan and Single Asset/Single
Borrower Commercial Mortgage-Backed Securitizations Methodology"
published in July 2022.

Moody's analysis incorporated a loss and recovery approach in
rating the P&I classes in this deal since 100% of the pool is in
special servicing. In this approach, Moody's determines a
probability of default for particular specially serviced loans that
it expects will generate a loss and estimates a loss given default
based on a review of broker's opinions of value (if available),
other information from the special servicer, available market data
and Moody's internal data. The loss given default for each loan
also takes into consideration repayment of servicer advances to
date, estimated future advances and closing costs. Translating the
probability of default and loss given default into an expected loss
estimate, Moody's then applies the aggregate loss from specially
serviced to the most junior classes and the recovery as a pay down
of principal to the most senior classes.

DEAL PERFORMANCE

As of the September 12, 2022 distribution date, the transaction's
aggregate certificate balance has decreased by 70% to $363 million
from $1.216 billion at securitization. The certificates are
collateralized by eight mortgage loans (including two
cross-collateralized loans) that are currently in special servicing
and have passed their initial scheduled maturity dates.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 5, compared to 8 at Moody's last review.

An aggregate realized loss of $16.7 million has been applied to the
pool. All eight loans are currently in special servicing and have
passed their initial scheduled maturity dates. The four specially
serviced exposures, 58% of the pool, that are already REO or
undergoing the foreclosure process have received an aggregate
appraisal reduction amount of approximately $132 million and were
deemed non-recoverable as of the September 2022 remittance date.

As of the September 2022 remittance statement cumulative interest
shortfalls were $10.1 million. Approximately $1.2 million in
interest shortfalls were repaid as of the September 2022 remittance
date due to the disposition of a previously specially serviced
loans and therefore Moody's anticipates interest shortfalls will
continue and likely increase due to the exposure to specially
serviced loans. Interest shortfalls are caused by special servicing
fees, including workout and liquidation fees, appraisal entitlement
reductions (ASERs), loan modifications and extraordinary trust
expenses. Recent interest distributions from the September 2022
remittance statement, repaid shortfalls to classes A-S-EC, B-EC,
and C-EC, however, classes B-EC and C-EC are likely to be impacted
by ongoing interest shortfalls due to the exposure to specially
serviced and non-recoverable loans.

The largest specially serviced exposure is the Louis Joliet Mall
Loan ($85.0 million – 23.4% of the pool), which is secured by a
359,000 square foot (SF) portion of a 975,000 SF regional mall
located in Joliet, Illinois. At securitization the mall was
anchored by Macy's, Sears, JC Penney and Carson Pirie Scott & Co
(all non-collateral). However, both Sears and Carson Pirie Scott &
Co. closed their stores at this location in 2018. Two major
collateral tenants, MC Sport and Toys R Us, also closed their
stores in 2017 and 2018, respectively. As of December 2021, the
total mall occupancy declined to approximately 56%, compared to 82%
at prior year and 93% at closing. The property performance has
declined significantly in recent years due to lower revenues and
the pandemic caused performance to further deteriorate. The 2020
NOI declined 25% year over year and was 48% lower than in 2012.
The loan transferred to special servicing in May 2020 due to
imminent monetary default and as of the September 2022 remittance
statement is last paid through its January 2021 payment date.  The
loan was interest-only for the entire term and had an original loan
maturity in July 2022. The property became REO in January 2022 and
the master servicer has recognized a $26.4 million appraisal
reduction as of the September 2022 remittance date. The loan has
been declared non-recoverable by the master servicer and Moody's
anticipates a significant loss on this loan.

The second largest specially serviced loan is the Crystal Mall Loan
($81.1 million – 22.3% of the pool), which is secured by a
518,500 SF portion of a 783,300 SF super-regional mall located in
Waterford, Connecticut. At securitization the mall contained three
anchors: Macy's, Sears, and JC Penney (Macy's and Sears were
non-collateral anchors). Sears closed its store at this location in
2018 and the space remains vacant. The subject is the only regional
mall within a 50-mile radius, but it faced significant competition
from other retail centers including Waterford Commons and Tanger
Outlets. Property performance has declined in recent years due to
lower rental revenue and is significantly below underwritten
levels. The 2020 NOI declined 30% year over year and was 60% below
the NOI in 2012. Additionally, 2021 NOI was 1% lower than the 2020
performance. For the full-year 2021, comparable in-line tenants
occupying less than 10,000 SF, generated sales of $336 PSF.  As of
July 2022, the collateral occupancy was 76% occupied, compared to
81% as of December 2020 and 87% as of December 2018. The property's
reported 2021 NOI DSCR was 0.80X, compared to 0.81X in December
2020 and 1.37X in December 2018. The loan transferred to special
servicing in July 2020 due to imminent default and as of September
2022 remittance statement was last paid through its September 2021
remittance date. The loan is reportedly in the foreclosure process.
The master servicer has already recognized $71.0 million appraisal
reduction, which represents 80% of the outstanding loan balance.
The loan has been declared non-recoverable by the master servicer
and Moody's anticipates a significant loss on this loan.

The third largest loan in special servicing the Southland Center
Mall Loan ($64.6 million – 17.8% of the pool), which is secured
by a 611,000 SF portion of a 903,500 SF super-regional mall located
in Taylor, Michigan. The mall is currently anchored by Macy's
(non-collateral) and JC Penney. Other major tenants include Best
Buy and a 12-screen, all-digital, Cinemark multiplex theater. As of
December 2021, total mall occupancy was 91%, compared to 94% in
December 2019 and 83% at securitization.  For the trailing twelve
month period ending September 2021 period, comparable in-line
tenants occupying less than 10,000 sf, generated sales of $526 PSF,
compared to $424 PSF for the FY 2019 and $374 PSF at
securitization. The property's net operating income (NOI) has
declined annually since 2019 but remains above levels at
securitization. The full-year 2021 NOI was 9% higher than 2012
performance and the 2021 NOI DSCR was 1.79X. The loan sponsor is
Brookfield Properties. The loan is on the servicer's watchlist due
to upcoming maturity in July 2022. The loan transferred to special
servicing in June 2022 and failed to payoff at its July 2022
maturity date. The loan has amortized 18% since securitization and
was last paid through July 2022. Potential resolutions discussions
between the special servicer and the borrower are ongoing.

The fourth largest specially serviced loan is the Trenton Office
Portfolio Loan ($60.0 million – 16.5% of the pool), which is
secured by two Class-A midrise office buildings containing an
aggregate 473,658 SF located in downtown Trenton, New Jersey. As of
June 2022, the buildings were approximately 96% leased, unchanged
since 2013. The largest tenant is the State of New Jersey, which
leases approximately 86% of the aggregate square footage on leases
through December 2022. The loan transferred to special servicing in
May and failed to payoff at its June 2022 maturity date. The loan
has amortized 18% since securitization and was last paid through
August 2022. The special servicer is reviewing the borrower's
extension request and awaiting updates in regard to any lease
extensions on the State of New Jersey tenant.

The fifth specially serviced loan is the Pierre Bossier Mall Loan
($39.7 million – 10.9% of the pool), which is secured by a
265,400 SF portion of a 612,300 SF regional mall located in Bossier
City, Louisiana. At securitization the mall contained four
non-collateral anchors: Dillard's, Sears, JC Penney, and Virginia
College. Both Sears and Virginia College closed at their locations
in 2018. The property's NOI has generally declined since 2015 due
to continued declines in rental revenues. The 2020 NOI was down 23%
year over year and was 55% lower than its 2012 NOI. The NOI DSCR
has been below 1.00X since 2019. Furthermore, the comparable inline
stores less than 10,000 SF reported sales of approximately $317 PSF
in 2021. As of September 2021, reported occupancy was 66%, compared
to 83% in December 2020 and 92% at closing. The loan transferred to
special servicing in June 2020 and is last paid through its May
2021 payment date. The loan is reportedly in the foreclosure
process. The master servicer has already recognized $34.5 million
appraisal reduction, which represents 87% of the current loan
balance. The loan has been declared non-recoverable by the master
servicer and Moody's anticipates a significant loss on this loan.

The sixth specially serviced loan is the Westgate Mall ($29.3
million – 8.1% of the pool), which is secured by a 453,544 SF
portion of a regional mall. The mall's anchors include
non-collateral Dillard's and Belk, as well as JC Penney. A former
anchor, Sears (193,000 SF), vacated in September 2018 and the space
remains vacant. Major collateral tenants include: Bed Bath & Beyond
(36,000 SF; lease expiration in January 2026) and Dick's Sporting
Goods (lease expiration January 2030). As of March 2022, total
occupancy was 85%, compared to 90% in December 2019, and 95% at
closing. The property's performance has declined since 2012 due
lower rental revenues, and 2021 NOI was 38% lower than in 2012. The
December 2021 NOI DSCR was 1.41X, compared to 2.21X in 2012. CBL &
Associates Properties, Inc. ("CBL"), which is the sponsor and
manages the property, declared Chapter 11 bankruptcy in late 2020
and subsequently emerged from bankruptcy in November 2021. The loan
has amortized nearly 27% since securitization and has continued to
make its monthly debt service payment. The loan transferred to
special servicing in July 2022 and failed to payoff at its July
2022 maturity date. Due to the recent declines in performance and
the current retail environment, Moody's anticipates a moderate loss
on this loan. An updated an appraisal has not yet been reported on
this loan and as of the September 2022 remittance statement no
appraisal reduction has been recognized on this loan.

The remaining specially serviced loan is the Neuro Care Medical
Office ($3.3 million - 0.9% of the pool). The loan is secured by a
two story medical building located in Canton, Ohio.  The property
is vacant due to a tenant bankruptcy and became REO earlier in
2022. The special servicer indicated a sale is anticipated within
the next 12-months.


UBS-BARCLAYS 2013-C6: Moody's Lowers Rating on Cl. C Certs to B1
----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings on eleven
classes and downgraded the ratings on two classes of UBS-Barclays
Commercial Mortgage Trust 2013-C6, Commercial Mortgage Pass-Through
Certificates, Series 2013-C6 ("UBS-BB 2013-C6"), as follows:

Cl. A-3, Affirmed Aaa (sf); previously on May 31, 2022 Affirmed Aaa
(sf)

Cl. A-3FL, Affirmed Aaa (sf); previously on May 31, 2022 Affirmed
Aaa (sf)

Cl. A-3FX, Affirmed Aaa (sf); previously on May 31, 2022 Affirmed
Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on May 31, 2022 Affirmed Aaa
(sf)

Cl. A-S, Affirmed Aaa (sf); previously on May 31, 2022 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on May 31, 2022 Affirmed
Aaa (sf)

Cl. B, Affirmed Baa2 (sf); previously on May 31, 2022 Downgraded to
Baa2 (sf)

Cl. C, Downgraded to B1 (sf); previously on May 31, 2022 Downgraded
to Ba3 (sf)

Cl. D, Downgraded to Caa1 (sf); previously on May 31, 2022
Downgraded to B3 (sf)

Cl. E, Affirmed Caa3 (sf); previously on May 31, 2022 Downgraded to
Caa3 (sf)

Cl. F, Affirmed C (sf); previously on May 31, 2022 Affirmed C (sf)

Cl. X-A*, Affirmed Aaa (sf); previously on May 31, 2022 Affirmed
Aaa (sf)

Cl. X-B*, Affirmed Ba1 (sf); previously on May 31, 2022 Downgraded
to Ba1 (sf)

*  Reflects Interest-Only Classes

RATINGS RATIONALE

The ratings on seven P&I classes were affirmed because of their
credit support and the transaction's key metrics, including Moody's
loan-to-value (LTV) ratio, Moody's stressed debt service coverage
ratio (DSCR) and the transaction's Herfindahl Index (Herf), are
within acceptable ranges. These classes will also benefit from
principal paydowns as the remaining loans approach their maturity
dates and defeased loans now represent 24% of the pool.

The ratings on two P&I classes were downgraded due to the potential
refinance challenges facing certain poorly performing loans with
upcoming maturity dates on or before April 2023 that have already
transferred to special servicing. The largest specially serviced
loans include the Broward Mall loan (9.8% of the pool) which is
secured by a poorly performing regional mall and the Bayview Plaza
loan (5.2%) which is secured by a retail property that has
exhibited significant declines in performance in recent years.
Furthermore, all the pool's loan balance matures by April 2023; if
particular loans are unable to pay off at their maturity date, the
outstanding classes may face increased interest shortfall risk.

The ratings on two P&I classes were affirmed because the ratings
are consistent with Moody's expected loss.

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

Moody's regard e-commerce competition as a social risk under
Moody's ESG framework. The rise in e-commerce and changing consumer
behavior presents challenges to brick-and-mortar discretionary
retailers.

Moody's rating action reflects a base expected loss of 10.7% of the
current pooled balance, compared to 9.2% at Moody's last review.
Moody's base expected loss plus realized losses is now 8.0% of the
original pooled balance, compared to 7.7% at the last review.


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

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range can
indicate that the collateral's credit quality is stronger or weaker
than Moody's had previously expected. Additionally, significant
changes in the 5-year rolling average of 10-year US Treasury rates
will impact the magnitude of the interest rate adjustment and may
lead to future rating actions.

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in rating all classes except interest-only
classes were "US and Canadian Conduit/Fusion Commercial
Mortgage-Backed Securitizations Methodology" published in July
2022.

DEAL PERFORMANCE

As of the September 10, 2022 distribution date, the transaction's
aggregate certificate balance has decreased by 25% to $970 million
from $1.3 billion at securitization. The certificates are
collateralized by 61 mortgage loans ranging in size from less than
1% to 16.5% of the pool, with the top ten loans (excluding
defeasance) constituting 61.7% of the pool. One loan, constituting
13% of the pool, has an investment-grade structured credit
assessments. Twenty-one loans, constituting 23.6% of the pool, have
defeased and are secured by US government securities.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of nine, compared to 12 at Moody's last review.

Thirteen loans, constituting 27% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews the
watchlist to assess which loans have material issues that could
affect performance.

No loans have been liquidated from the pool. Five loans,
constituting 18% of the pool, are currently in special servicing.
The largest specially serviced loan is the Broward Mall loan ($95.0
million – 9.8% of the pool), which is secured by a 326,000 square
feet (SF) portion of a 1.042 million SF super-regional mall located
in Plantation, Florida. The mall is currently anchored by Macy's,
JC Penney and Dillard's, none of which are part of the collateral.
Seritage closed the fourth anchor, Sears, in 2018. As of March
2022, the property was 78% leased, while the collateral is 92%
occupied. The loan is interest-only throughout the term. The loan's
sponsor, Unibail-Rodamco-Westfield, plans to sell it US mall
properties by the end of 2023. The loan transferred to special
servicing in June 2020 due to imminent default as a result of the
coronavirus outbreak. The receiver is in control of the property.
The lender has filed foreclosure and is anticipating taking title.

The second largest specially serviced loan is the Bayview Plaza
loan ($50.3 million – 5.2% of the pool), which is secured by
leased fee and fee simple interests in a four phase mixed-use
property in Tuman, Guam. The property consists of four components,
a two-story and a three-story Class A retail building (69,700 SF
(Phases I and III)) and leased fee interests in two parcels
including the land at an adjacent retail property known as Bayview
Plaza II and portion of land at a nearby property known as DFS
Galleria. The borrower developed the Bayview Plaza Property from
1996 to 2002 at an estimated cost of $12.4 million. Japan is the
primary source of tourism for Guam, with Japan accounting for
approximately 70-85% of total arrivals at securitization. The
location caters to tourism. The property was 71% leased as of June
2022, compared to 72% in December 2021, and 80% in Dec 2019. The
loan transferred to special servicing in July 2022 as a result of
the borrower's failure to cooperate with the implementation of cash
management, which was enforced due a failure to achieve minimum
required threshold of 1.25X. 2021 NOI DSCR was only 0.40X, compared
to 1.52X in December 2019.

The remaining two specially serviced loans are secured by retail
and hospitality assets, the second of which has been included in
the conduit statistics. Moody's estimates an aggregate $90.4
million loss for the three largest specially serviced loans (53%
expected loss on average).

As of the September 2022 remittance statement, cumulative interest
shortfalls were $1.19 million. Moody's anticipates interest
shortfalls will continue because of the exposure to specially
serviced loans and/or modified loans. Interest shortfalls are
caused by special servicing fees, including workout and liquidation
fees, appraisal entitlement reductions (ASERs), loan modifications
and extraordinary trust expenses.

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
adjust the MLTV for each loan using a value that reflects
capitalization (cap) rates that are between Moody's 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.

Moody's received full year 2021 operating results for 100% of the
pool, and partial year 2022 operating results for 81% of the pool
(excluding specially serviced and defeased loans). Moody's weighted
average conduit LTV is 100%, compared to 105% at Moody's last
review. Moody's conduit component excludes loans with structured
credit assessments, defeased and CTL loans, and specially serviced
and troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 19% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.7%.

Moody's actual and stressed conduit DSCRs are 1.70X and 1.18X,
respectively, compared to 1.66X and 1.11X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The loan with a structured credit assessment is the 575 Broadway
Loan ($125.85 million – 13.0% of the pool), which is secured by
an approximately 170,000 SF mixed use retail and office building
located in the SoHo neighborhood of New York City, New York. The
property is encumbered by a ground lease through June 2060. As of
June 2022, the property was 88% leased. Moody's structured credit
assessment and stressed DSCR are a1 (sca.pd) and 1.26X,
respectively, unchanged from the prior review.

The top three conduit loans represent 26.9% of the pool balance.
The largest loan is the Gateway Center Loan ($160 million – 16.5%
of the pool), which is secured by three cross-collateralized and
cross-defaulted loans secured by a 355,000 SF portion of a 639,000
SF anchored retail center in Brooklyn, New York. The property was
constructed in 2002 by The Related Companies. The properties are
shadow anchored by Target and Home Depot. Collateral tenants
include BJ's Wholesale Club, Bed Bath & Beyond, Dave and Busters,
and Old Navy. As of June 2022, the property was 100% leased.
Moody's LTV and stressed DSCR are 122% and 0.73X, respectively,
unchanged from the last review.

The second largest loan is The Shoppes at River Crossing Loan
($70.7 million – 7.3% of the pool), which is secured by the
528,000 SF portion of a 728,000 SF lifestyle center located in
Macon, Georgia. Non-collateral anchors include Dillard's and Belk.
Collateral tenants include Dick's Sporting Goods, Barnes & Noble,
Jo-Ann Fabric, H&M, and DSW Shoe Warehouse. As of March 2022, the
collateral was 91% leased, compared to 96% in December 2019 and 98%
in 2018. The property benefits from amortization, having amortized
8.6% since securitization. Moody's LTV and stressed DSCR are 116%
and 0.96X, respectively, essentially unchanged since the last
review.

The third largest loan is the DoubleTree Hotel & Miami Airport
Convention Center loan ($30.1 million – 3.1% of the pool), which
is secured by the borrower's fee simple interest in a 334 room
full-service hotel, 198,000 SF convention center and 23,000 SF of
retail located in Miami, Florida. The total net rentable area (NRA)
of the property is approximately 521,000 SF. The hotel features an
open area atrium lobby incorporating the lobby lounge and bar,
20,000 SF of meeting space, banquet room, restaurants and pool
access. Previously, the loan transferred to special servicing in
June 2020 for monetary default. The special servicer was dual
tracking negotiations, however the loan was brought current in
November 2021 and was returned to the master servicer in June 2022.
Trailing-twelve month occupancy at the hotel was 66% in March 2022,
compared to 26% as of March 2021 and 72% as of March 2020. RevPAR
recovered similarly during the same period, reaching $83 in March
2022, compared to $23 in March 2021 and $90 in March 2020. Moody's
LTV and stressed DSCR are 99% and 1.23X, respectively.


[*] Moody's Takes Action on $179MM of US RMBS Issued 2002-2007
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 11 bonds and
downgraded the ratings of one bond from eight US residential
mortgage-backed transactions (RMBS), backed by option ARM and
subprime mortgages issued by multiple issuers.

A list of Affected Ratings is available at https://bit.ly/3MnOGKV

Complete rating actions are as follows:

Issuer: Bear Stearns Asset Backed Securities I Trust 2006-HE10

Cl. I-A-3, Upgraded to Aa3 (sf); previously on Dec 17, 2021
Upgraded to A3 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2006-HE6

Cl. I-A-3, Upgraded to Baa3 (sf); previously on Apr 9, 2018
Upgraded to B2 (sf)

Cl. II-A-3, Upgraded to Ba3 (sf); previously on Apr 9, 2018
Upgraded to B2 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2006-HE9

Cl. I-A-2, Upgraded to Ba1 (sf); previously on Dec 17, 2021
Upgraded to Ba3 (sf)

Cl. I-A-3, Upgraded to B1 (sf); previously on Dec 17, 2021 Upgraded
to B3 (sf)

Cl. II-A, Upgraded to Ba1 (sf); previously on Dec 17, 2021 Upgraded
to Ba3 (sf)

Cl. III-A, Upgraded to Ba1 (sf); previously on Dec 17, 2021
Upgraded to Ba3 (sf)

Issuer: Bear Stearns Mortgage Funding Trust 2007-AR2, Mortgage
Pass-Through Certificates, Series 2007-AR2

Cl. A-1, Upgraded to Ba2 (sf); previously on Dec 17, 2021 Upgraded
to B2 (sf)

Issuer: Carrington Mortgage Loan Trust, Series 2006-NC2

Cl. A-4, Upgraded to Aa2 (sf); previously on Dec 17, 2021 Upgraded
to A2 (sf)

Issuer: Centex Home Equity Company (CHEC) Loan Trust 2004-1

Cl. A-3, Upgraded to Aa3 (sf); previously on Jun 28, 2017 Upgraded
to A2 (sf)

Issuer: Centex Home Equity Loan Trust 2002-A

Cl. AV, Downgraded to Ba1 (sf); previously on Oct 9, 2013
Downgraded to Baa1 (sf)

Issuer: Chase Funding Trust, Series 2002-2

Cl. IA-5, Upgraded to Aa3 (sf); previously on Dec 16, 2021 Upgraded
to A2 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance as well as
Moody's updated loss expectations on the underlying pools. The
rating upgrades are a result of the improving performance of the
related pools and/or an increase in credit enhancement available to
the bonds. In addition, the improvement in credit enhancement
observed for bonds issued by Bear Stearns Asset Backed Securities I
Trust 2006-HE6 is also the reflection of a significant settlement
distribution received pursuant to JPMorgan Global RMBS Trust
Settlement Agreement. The rating downgrade is primarily due to a
deterioration in collateral performance and/or decline in credit
enhancement available to the bonds.

In light of the current macroeconomic environment, Moody's revised
loss expectations based on forecast uncertainties. Specifically,
Moody's have observed an increase in delinquencies, payment
forbearance, and payment, which could result in higher realized
losses. Moody's rating actions also take into consideration the
buildup in credit enhancement of the bonds, which has helped offset
the impact of the increase in expected losses.

Moody's estimated the proportion of loans granted payment relief in
a pool based on a review of loan level cashflows. In Moody's
analysis, Moody's considered a loan to be enrolled in a payment
relief program if (1) the loan was not liquidated but took a loss
in the reporting period (to account for loans with monthly
deferrals that were reported as current), or (2) the actual balance
of the loan increased in the reporting period, or (3) the actual
balance of the loan remained unchanged in the last and current
reporting period, excluding interest-only loans and pay ahead
loans. In cases where loan level data is not available, Moody's
assumed that the proportion of borrowers enrolled in payment relief
programs would be equal to levels observed in transactions of
comparable asset quality. Based on Moody's analysis, the proportion
of borrowers that are currently enrolled in payment relief plans
varied greatly, ranging between approximately 2% and 11% among RMBS
transactions issued before 2009. In Moody's analysis, Moody's
assume these loans to experience lifetime default rates that are
50% higher than default rates on the performing loans.

In addition, for borrowers unable to make up missed payments
through a short-term repayment plan, servicers will generally defer
the forborne amount as a non-interest-bearing balance, due at
maturity of the loan as a balloon payment. Moody's analysis
considered the impact of six months of scheduled principal payments
on the loans enrolled in payment relief programs being passed to
the trust as a loss. The magnitude of this loss will depend on the
proportion of the borrowers in the pool subject to principal
deferral and the number of months of such deferral. The treatment
of deferred principal as a loss is credit negative for junior
bonds, which could incur write-downs on bonds when missed payments
are deferred.

Principal Methodologies

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in July 2022.

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 of the subordinate bonds up. Losses could decline from
Moody's original expectations as a result of a lower number of
obligor defaults or appreciation in the value of the mortgaged
property securing an obligor's promise of payment. Transaction
performance also depends greatly on the US macro economy and
housing market.

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 expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions. In addition, improvements in
reporting formats and data availability across deals and trustees
may provide better insight into certain performance metrics such as
the level of collateral modifications.


[*] Moody's Takes Action on $36.7MM of US RMBS Issued 2003-2005
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of four bonds
and downgraded the ratings of four bonds from four US residential
mortgage-backed transactions (RMBS), backed prime jumbo, and
subprime mortgages issued by multiple issuers.

A list of the Affected Credit Ratings is available at
https://bit.ly/3TkJCcE

Complete rating actions are as follows:

Issuer: CSFB Home Equity Asset Trust 2005-6

Cl. M-4, Upgraded to Aa3 (sf); previously on Dec 16, 2021 Upgraded
to A2 (sf)

Cl. M-5, Upgraded to B3 (sf); previously on Dec 16, 2021 Upgraded
to Caa2 (sf)

Issuer: CSFB Home Equity Pass-Through Certificates, Series 2005-1

Cl. M-5, Upgraded to Aa2 (sf); previously on Dec 16, 2021 Upgraded
to A1 (sf)

Issuer: Merrill Lynch Mortgage Investors, Inc. 2003-WMC2

Cl. M-2, Upgraded to A1 (sf); previously on Jun 10, 2019 Upgraded
to A3 (sf)

Issuer: RESI Finance Limited Partnership 2003-CB1/RESI Finance DE
Corporation 2003-CB1

Cl. B3, Downgraded to B3 (sf); previously on Apr 7, 2020 Downgraded
to B1 (sf)

Cl. B4, Downgraded to Caa1 (sf); previously on Apr 7, 2020
Downgraded to B2 (sf)

Cl. B5, Downgraded to Caa2 (sf); previously on Apr 7, 2020
Downgraded to B3 (sf)

Cl. B6, Downgraded to Ca (sf); previously on Apr 7, 2020 Downgraded
to Caa3 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance as well as
Moody's updated loss expectations on the underlying pools. The
rating upgrades are a result of the improving performance of the
related pools and/or an increase in credit enhancement available to
the bonds. The rating downgrades are primarily due to a decline in
credit enhancement available to the bonds.

In light of the current macroeconomic environment, Moody's revised
loss expectations based on forecast uncertainties. Specifically,
Moody's have observed an increase in delinquencies, payment
forbearance, and payment, which could result in higher realized
losses. Moody's rating actions also take into consideration the
buildup in credit enhancement of the bonds, which has helped offset
the impact of the increase in expected losses.

Moody's estimated the proportion of loans granted payment relief in
a pool based on a review of loan level cashflows. In Moody's
analysis, Moody's considered a loan to be enrolled in a payment
relief program if (1) the loan was not liquidated but took a loss
in the reporting period (to account for loans with monthly
deferrals that were reported as current), or (2) the actual balance
of the loan increased in the reporting period, or (3) the actual
balance of the loan remained unchanged in the last and current
reporting period, excluding interest-only loans and pay ahead
loans. Based on Moody's analysis, the proportion of borrowers that
are currently enrolled in payment relief plans varied greatly,
ranging between approximately 2% and 11% among RMBS transactions
issued before 2009. In Moody's analysis, Moody's assume these loans
to experience lifetime default rates that are 50% higher than
default rates on the performing loans.

In addition, for borrowers unable to make up missed payments
through a short-term repayment plan, servicers will generally defer
the forborne amount as a non-interest-bearing balance, due at
maturity of the loan as a balloon payment. Moody's analysis
considered the impact of six months of scheduled principal payments
on the loans enrolled in payment relief programs being passed to
the trust as a loss. The magnitude of this loss will depend on the
proportion of the borrowers in the pool subject to principal
deferral and the number of months of such deferral. The treatment
of deferred principal as a loss is credit negative for junior
bonds, which could incur write-downs on bonds when missed payments
are deferred.

Principal Methodologies

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in July 2022.

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 of the subordinate bonds up. Losses could decline from
Moody's original expectations as a result of a lower number of
obligor defaults or appreciation in the value of the mortgaged
property securing an obligor's promise of payment. Transaction
performance also depends greatly on the US macro economy and
housing market.

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 expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions. In addition, improvements in
reporting formats and data availability across deals and trustees
may provide better insight into certain performance metrics such as
the level of collateral modifications.


[*] S&P Takes Various Actions on 59 Classes From 34 U.S. RMBS Deals
-------------------------------------------------------------------
S&P Global Ratings completed its review of 59 ratings from 34 U.S.
RMBS transactions issued between 1996 and 2003. The review yielded
six upgrades, 29 affirmations, and 24 withdrawals.

A list of Affected Ratings can be viewed at:

            https://bit.ly/3CFL43D

Analytical Considerations

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by our projected cash flows. These considerations
are based on transaction-specific performance and/or structural
characteristics and their potential effects on certain classes.
Some of these considerations may include:

-- Collateral performance or delinquency trends;
-- Increase or decrease in available credit support;
-- Expected short duration;
-- Small loan count;
-- Historical and/or outstanding missed interest payments/interest
shortfalls; and
-- Payment priority.

Rating Actions

S&P said, "The rating changes reflect our view regarding the
associated transaction-specific collateral performance, structural
characteristics, and/or the application of specific criteria
applicable to these classes. See the ratings list for the specific
rationales associated with each of the classes with rating
transitions.

"The rating affirmations reflect our view that our projected credit
support, collateral performance, and credit-related reductions in
interest on these classes have remained relatively consistent with
our prior projections.

"We withdrew our ratings on 23 classes from 13 transactions due to
the small number of loans remaining in the related group. Once a
pool has declined to a de minimis amount, its future performance
becomes more difficult to project. As such, we believe there is a
high degree of credit instability that is incompatible with any
rating level. Additionally, as a result, we applied our
principal-only criteria, "Criteria | Structured Finance | RMBS:
Methodology For Surveilling U. S. RMBS Principal-Only Strip
Securities For Pre-2009 Originations" published Oct. 11, 2016,
which resulted in withdrawing one rating from one transaction."



[*] S&P Takes Various Actions on 76 Classes from 21 US RMBS Deals
-----------------------------------------------------------------
S&P Global Ratings completed its review of 76 classes from 21 U.S.
RMBS transactions issued between 2002 and 2006. The review yielded
21 upgrades, four downgrades, 38 affirmations, 12 withdrawals, and
one discontinuance.


A list of Affected Ratings can be viewed at:

             https://bit.ly/3CPblwH

Analytical Considerations

S&P incorporates various considerations into its decisions to
raise, lower, or affirm ratings when reviewing the indicative
ratings suggested by its projected cash flows. These considerations
are based on transaction-specific performance and/or structural
characteristics and their potential effects on certain classes.
Some of these considerations may include:

-- Collateral performance or delinquency trends;

-- Available subordination and/or overcollateralization;

-- Increases or decreases in available credit support;

-- Historical and/or outstanding missed interest payments/interest
shortfalls;

-- Reduced interest payments due to loan modifications;

-- Expected duration;

-- Payment priority; and

-- A small loan count.

Rating Actions

S&P said, "The rating changes reflect our opinion regarding the
associated transaction-specific collateral performance and/or
structural characteristics, as well as the application of specific
criteria applicable to these classes. See the ratings list for the
specific rationales associated with each of the classes with rating
transitions.

"The rating affirmations reflect our opinion that our projected
credit support, collateral performance, and credit-related
reductions in interest on these classes has remained relatively
consistent with our prior projections."

The majority of today's upgrades are due to increased credit
support. As a result, the upgrades on these classes reflect their
ability to withstand a higher level of projected losses than
previously anticipated.

S&P said, "We withdrew our ratings on 12 classes from three
transactions due to the small number of loans remaining in the
related group. Once a pool has declined to a de minimis amount, its
future performance becomes more difficult to project. As such, we
believe there is a high degree of credit instability that is
incompatible with any rating level."



                            *********

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