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

              Sunday, August 25, 2024, Vol. 28, No. 237

                            Headlines

ABPCI DIRECT II: S&P Assigns BB- (sf) Rating on Class E-RR Notes
AG TRUST 2024-NLP: Moody's Assigns Ba1 Rating to Cl. HRR Certs
AGL CLO 21: Fitch Assigns 'BB+sf' Rating on Class E-R Notes
AGL CLO 33: Fitch Assigns 'BB+sf' Final Rating on Class E Notes
AGL CLO 33: Moody's Assigns B3 Rating to $250,000 Class F Notes

AIMCO CLO 11: S&P Assigns BB- (sf) Rating on Class E-R2 Notes
ANGEL OAK 2024-7: Fitch Assigns 'Bsf' Final Rating on Cl. B-2 Certs
ANTARES CLO 2018-3: S&P Assigns BB- (sf) Rating on Class E Notes
APIDOS CLO XXVI: Moody's Affirms Ba3 Rating on $20MM Class D Notes
ARBOR REALTY 2021-FL3: DBRS Confirms B(low) Rating on G Notes

BALLYROCK CLO 27: S&P Assigns Prelim BB-(sf) Rating on Cl. D Notes
BAMLL COMMERCIAL 2015-ASTR: S&P Cuts E Certs Rating to 'B- (sf)'
BANC OF AMERICA 2015-UBS7: DBRS Confirms C Rating on 2 Tranches
BANK 2019-BNK19: Fitch Lowers Rating on Cl. F Certs to CCsf
BANK5 2024-5YR9: Fitch Assigns 'B-(EXP)sf' Rating on Class G Debt

BENEFIT STREET XII-B: S&P Assigns BB- (sf) Rating on Class E Notes
BENEFIT STREET XXVII: S&P Assigns Prelim 'BB-' Rating on E-R Notes
BETONY CLO 2: Moody's Affirms Ba3 Rating on $25MM Class D Notes
BLACKROCK SHASTA XIV: S&P Assigns BB- (sf) Rating on Class E Notes
BOCA COMMERCIAL 2024-BOCA: DBRS Gives Prov. BB Rating on HRR Certs

BRAVO RESIDENTIAL 2024-NQM5: DBRS Assigns B(high) on B2 Notes
CEDAR FUNDING VII: S&P Affirms 'B- (sf)' Rating on Class F Notes
CHASE HOME 2024-DRT1: Fitch Assigns 'BB-(EXP)sf' Rating on B-5 Debt
CIFC FUNDING 2021-IV: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
COLT 2024-INV3: S&P Assigns B (sf) Rating on Class B-2 Certs

COMM 2016-667M: S&P Affirms B (sf) Rating on Class E Certs
CROCKETT PARTNERS IIA: DBRS Finalizes BB Rating on C Notes
CROTON PARK: S&P Assigns Prelim BB- (sf) Rating on Class E Debts
DRYDEN 76: S&P Assigs Prelim BB- (sf) Rating on Class E-R2 Notes
ELMWOOD CLO 18: S&P Assigns B- (sf) Rating on Class F-RR Notes

FALCON 2019-1: Fitch Affirms 'Bsf' Rating on Series B Notes
GENERATE CLO 2: S&P Assigns Prelim BB-(sf) Rating on Cl. ER2 Notes
GS MORTGAGE 2019-GC40: DBRS Cuts Class G-RR Certs Rating to C
GS MORTGAGE 2021-ARDN: DBRS Confirms B(low) Rating on G Certs
GS MORTGAGE 2024-A01: Fitch Gives 'Bsf' Rating on B-2 Certs

HOMEWARD OPPORTUNITIES 2024-RRTL2: DBRS Gives P B(low) on M2 Notes
IVY HILL VII: S&P Assigns BB- (sf) Rating on Class E-RRR Notes
KIND COMMERCIAL 2024-1: Moody's Assigns B2 Rating to Cl. HRR Certs
LHOME MORTGAGE 2024-RTL4: DBRS Finalizes B Rating on M2 Notes
LOANCORE 2022-CRE7: DBRS Confirms B(low) Rating on G Notes

M&T EQUIPMENT 2023-LEAF1: DBRS Confirms BB Rating on E Notes
MADISON PARK XXXII: Fitch Assigns 'BB+sf' Rating on Cl. E-R2 Notes
MARINER FINANCE 2024-A: DBRS Finalizes BB(low) Rating on E Notes
OAKTREE CLO 2019-2: S&P Assigns Prelim BB-(sf) Rating on D-R Notes
OAKTREE CLO 2024-27: S&P Assigns Prelim BB- (sf) Rating on E Notes

OCP CLO 2020-18: S&P Assigns BB- (sf) Rating on Class E-R2 Notes
OCP CLO 2022-24: S&P Assigns Prelim BB- (sf) Rating on E-R Notes
OCP CLO 2024-34: S&P Assigns BB- (sf) Rating on Class E Notes
OPORTUN ISSUANCE 2021-C: DBRS Confirms BB(high) Rating on D Notes
ORIGEN MANUFACTURED 2002-A:S&P Affirms CCC(sf) Rating on M-2 Notes

PIONEER AIRCRAFT: Fitch Hikes Rating on Series C Notes to 'CCC+sf'
PRET TRUST 2024-RPL2: Fitch Assigns 'B(EXP)sf' Rating on B-2 Notes
RATE MORTGAGE 2024-J2: DBRS Gives Prov. B(low) Rating on B5 Certs
RCKT MORTGAGE 2024-CES6: Fitch Gives B(EXP) Rating on 5 Tranches
RR 30: Moody's Assigns B3 Rating to $400,000 Class E Notes

SALUDA GRADE 2024-INV1: DBRS Finalizes B Rating on B-2 Certs
SIXTH STREET XXVI: S&P Assigns Prelim BB- (sf) Rating on E Loans
SYMPHONY CLO 41: Fitch Assigns 'BB-(EXP)sf' Rating on Class E Notes
TCI-FLATIRON 2017-1: Moody's Ups Rating on $22.5MM E Notes to Ba2
TVC MORTGAGE 2024-RRTL1: DBRS Finalizes B(low) Rating on M2 Notes

VELOCITY COMMERCIAL 2024-4: DBRS Gives Prov. B Rating on 3 Classes
VERUS SECURITIZATION 2024-INV2: S&P Assigns B- (sf) on B-2 Notes
VOYA CLO 2016-2: Moody's Affirms B1 Rating on $16.4MM D-R Notes
WELLINGTON MANAGEMENT 3: S&P Assigns Prelim 'BB-' Rating on E Notes
WELLS FARGO 2015-SG1: Fitch Lowers Rating on Cl. D Certs to 'B-sf'

WELLS FARGO 2017-C41: Fitch Affirms 'B+sf' Rating on Cl. F-RR Certs
WELLS FARGO 2024-C63: Fitch Gives B-(EXP) Rating on Cl. G-RR Certs
WELLS FARGO 2024-MGP: Moody's Assigns Ba3 Rating to HRR-11 Certs
[*] DBRS Confirms 12 Ratings From 3 Oportun Transactions
[*] DBRS Reviews 161 Classes From 24 US RMBS Transactions

[*] DBRS Reviews 683 Classes From 25 US RMBS Transactions
[*] DBRS Reviews 713 Classes From 17 US RMBS Transactions
[*] Moody's Upgrades Ratings on $325MM of US RMBS Issued 2017-2019
[*] Moody's Ups Ratings on $209MM of US RMBS Issued 2015-2019
[*] S&P Takes Various Actions on 31 Classes From 27 US RMBS Deals


                            *********

ABPCI DIRECT II: S&P Assigns BB- (sf) Rating on Class E-RR Notes
----------------------------------------------------------------
S&P Global Ratings assigned ratings to the class A-1-RR, A-1L,
A-2-RR, B-RR, C-RR, D-RR, and E-RR replacement debt from ABPCI
Direct Lending Fund CLO II Ltd./ABPCI Direct Lending Fund CLO II
LLC, a CLO that was originally issued in July 2017 and was first
refinanced in March 2021. The transaction is managed by AB Private
Credit Investors LLC. At the same time, S&P withdrew its ratings on
the class A-1-R, A-2-R, B-R, C-R, D-R, and E-R debt following
payment in full on the Aug. 22, 2024, second refinancing date.

The replacement debt was issued via a supplemental indenture, which
outlines the terms of the replacement debt. According to the
proposed supplemental indenture:

-- The replacement class A-1-RR, A-1L, A-2-RR, B-RR, C-RR, D-RR,
and E-RR debt was issued at a lower spread over three-month SOFR
than the previous debt.

-- The reinvestment period was extended through Aug. 22, 2029.

-- A non-call period was implemented and will be in effect through
Aug. 22, 2026.

-- The stated maturity of the secured debt was extended through
July 20, 2037.

-- The transaction has a unique feature that, at the direction of
a majority of the subordinate noteholders, a percentage of the
collateral and the capital structure (debt and equity) can be
partitioned off into separate entities on either the first or the
second static date.

Replacement And Previous Debt Issuances

Replacement debt

-- Class A-1-RR, $260.80 million: Three-month CME term SOFR +
1.65%

-- Class A-1L, $25.00 million: Three-month CME term SOFR + 1.65%

-- Class A-2-RR, $19.70 million: Three-month CME term SOFR +
1.85%

-- Class B-RR, $29.50 million: Three-month CME term SOFR + 1.95%

-- Class C-RR, $39.40 million: Three-month CME term SOFR + 2.40%

-- Class D-RR, $29.60 million: Three-month CME term SOFR + 4.15%

-- Class E-RR, $29.60 million: Three-month CME term SOFR + 7.50%

-- Subordinated notes, $53.57 million: Not applicable

Previous debt

-- Class A-1-R, $252.00 million: Three-month CME term SOFR +
1.86161%

-- Class A-2-R, $22.50 million: Three-month CME term SOFR +
2.16161%

-- Class B-R, $31.50 million: Three-month CME term SOFR +
2.41161%

-- Class C-R (deferrable), $36.00 million: Three-month CME term
SOFR + 3.41161%

-- Class D-R (deferrable), $22.50 million: Three-month CME term
SOFR + 4.76161%

-- Class E-R (deferrable), $13.50 million: Three-month CME term
SOFR + 7.86161%

-- Subordinated notes, $66.70 million: Not applicable

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults, and
recoveries upon default, under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Ratings Assigned

  ABPCI Direct Lending Fund CLO II Ltd./
  ABPCI Direct Lending Fund CLO II LLC

  Class A-1-RR, $260.80 million: AAA (sf)
  Class A-1L, $25.00 million: AAA (sf)
  Class A-2-RR, $19.70 million: AAA (sf)
  Class B-RR, $29.50 million: AA (sf)
  Class C-RR, $39.40 million: A (sf)
  Class D-RR, $29.60 million: BBB- (sf)
  Class E-RR, $29.60 million: BB- (sf)
  Subordinated notes, $53.57 million: NR

  Ratings Withdrawn

  ABPCI Direct Lending Fund CLO II Ltd./
  ABPCI Direct Lending Fund CLO II LLC

  Class A-1-R to NR from AAA (sf)
  Class A-2-R to NR from AAA (sf)
  Class B-R to NR from AA (sf)
  Class C-R to NR from A (sf)
  Class D-R to NR from BBB- (sf)
  Class E-R to NR from BB- (sf)

  NR--Not rated.



AG TRUST 2024-NLP: Moody's Assigns Ba1 Rating to Cl. HRR Certs
--------------------------------------------------------------
Moody's Ratings has assigned definitive ratings to seven classes of
CMBS securities issued by AG Trust 2024-NLP, Commercial Mortgage
Pass-Through Certificates, Series 2024-NLP:

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. X-CP*, Definitive Rating Assigned A2 (sf)

Cl. X-EXT*, Definitive Rating Assigned A2 (sf)

Cl. B, Definitive Rating Assigned Aa3 (sf)

Cl. C, Definitive Rating Assigned A3 (sf)

Cl. D, Definitive Rating Assigned Baa2 (sf)

Cl. HRR, Definitive Rating Assigned Ba1 (sf)

* Reflects Interest-Only Classes

RATINGS RATIONALE

The certificates are collateralized by a single loan backed by a
first lien commercial mortgage related to a portfolio of 41
properties covering a total of 4,641,301SF and located across 22
states. Moody's ratings are based on the credit quality of the
loans and the strength of the securitization structure.

The portfolio includes a diverse mix of 29 industrial properties,
10 retail properties, and 2 mixed use properties. The industrial
properties include 10 cold storage facilities, eight water bottling
and storage properties, and eleven food storage and processing
facilities. The retail properties are occupied by Lifetime Fitness
health and fitness centers. The mixed-use properties include an
office/data center and an office/research center.

The properties are leased to seven individual tenants, and under
triple net leases with a weighted average remaining term of 10.3
years. Each location is fully occupied by a single tenant. The
largest tenants include Lifetime Fitness (health and fitness clubs,
40.0% of UW base rent), Americold Realty Trust (cold storage
properties, 22.3% of UW base rent),and Raytheon Technologies Corp
(RTX Corporation, senior unsecured Baa1; office/data facility;
11.8% of UW base rent). No other property constitutes more than
5.8% of net rentable area or 11.8% of underwritten base rent.

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

The 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 Moody's first mortgage actual DSCR is 1.14x, compared with
1.17x at Moody's provisional ratings due to a higher interest rate
spread, and Moody's first mortgage actual stressed DSCR (at a 9.25%
constant) is 1.01x. Moody's DSCR is based on Moody's stabilized net
cash flow.

The loan first mortgage balance of $507,650,000 represents a
Moody's LTV ratio of 97.1% based on Moody's value. Moody's Adjusted
Moody's LTV ratio for the first mortgage balance is 88.2%, compared
with 88.0% at Moody's provisional ratings, based on Moody's value
using a cap rate adjusted for the current interest rate
environment.

With respect to diversity, the pool's property level Herfindahl
score is 23.69.

Moody's also grade properties on a scale of 0 to 5 (best to worst)
and consider those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The pool's quality
grade is 1.50.

Notable strengths of the transaction include: location in core
national markets, strong occupancy rate and tenancy, geographic
diversity, multiple property pooling, and experienced sponsorship.

Notable concerns of the transaction include: tenant concentration,
equity repatriation, property age, floating-rate interest-only loan
profile, non-sequential prepayment provision, and credit negative
legal features.

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

The principal methodology used in rating all classes except
interest-only classes was "Large Loan and Single Asset/Single
Borrower Commercial Mortgage-backed Securitizations" published in
July 2024.

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

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

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

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


AGL CLO 21: Fitch Assigns 'BB+sf' Rating on Class E-R Notes
-----------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to AGL CLO
21 Ltd. reset transaction.

   Entity/Debt         Rating               Prior
   -----------         ------               -----
AGL CLO 21 Ltd.

   A-1-R           LT  NRsf   New Rating
   A-2-R           LT  AAAsf  New Rating
   B 00119FAC8     LT  PIFsf  Paid In Full   AAsf
   B-R             LT  AA+sf  New Rating
   C 00119FAE4     LT  PIFsf  Paid In Full   Asf
   C-R             LT  A+sf   New Rating
   D 00119FAG9     LT  PIFsf  Paid In Full   BBB-sf
   D-1-R           LT  BBBsf  New Rating
   D-2-R           LT  BBB-sf New Rating
   E 00120GAA7     LT  PIFsf  Paid In Full   BBsf
   E-R             LT  BB+sf  New Rating
   F-R             LT  NRsf   New Rating

Transaction Summary

AGL CLO 21 Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) managed by AGL CLO Credit
Management LLC, which originally closed in August 2022. The secured
notes will be refinanced in whole on Aug. 9, 2024. Net proceeds
from the issuance of the secured and subordinated notes will
provide financing on a portfolio of approximately $400 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', which is in line with that of recent
CLOs. Issuers rated in the 'B' rating category denote a highly
speculative credit quality; however, the notes benefit from
appropriate credit enhancement and standard CLO structural
features.

Asset Security (Positive): The indicative portfolio consists of
99.63% first-lien senior secured loans and has a weighted average
recovery assumption of 75%. Fitch stressed the indicative portfolio
by assuming a higher portfolio concentration of assets with lower
recovery prospects and further reduced recovery assumptions for
higher rating stresses.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% 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
CLOs.

Portfolio Management (Neutral): The transaction has a 5.2-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting 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, the rated notes can
withstand default and recovery assumptions consistent with their
assigned ratings.

The WAL used for the transaction stress portfolio and matrices
analysis is 12 months less than the WAL covenant to account for
structural and reinvestment conditions after the reinvestment
period. In Fitch's opinion, these conditions would reduce the
effective risk horizon of the portfolio during stress periods.

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 as
severe as between 'BBB+sf' and 'AA+sf' for class A-2-R, between
'BB+sf' and 'AA-sf' for class B-R, between 'B+sf' and 'BBB+sf' for
class C-R, between less than 'B-sf' and 'BB+sf' for class D-1-R,
between less than 'B-sf' and 'BB+sf' for class D-2-R, and between
less than 'B-sf' and 'BB-sf' for class E-R.

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

Upgrade scenarios are not applicable to the class A-2-R notes as
these notes are in the highest rating category of 'AAAsf'.

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; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B-R, 'AA+sf' for class C-R, 'A+sf'
for class D-1-R, 'A-sf' for class D-2-R, and 'BBB+sf' for class
E-R.

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

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

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 its rating analysis according to its applicable rating
methodologies indicates that it is adequately reliable.

ESG Considerations

Fitch does not provide ESG relevance scores for AGL CLO 21 Ltd. In
cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, program,
instrument or issuer, Fitch will disclose in the key rating drivers
any ESG factor which has a significant impact on the rating on an
individual basis.


AGL CLO 33: Fitch Assigns 'BB+sf' Final Rating on Class E Notes
---------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to AGL
CLO 33 Ltd.

   Entity/Debt              Rating             Prior
   -----------              ------             -----
AGL CLO 33 Ltd.

   A-1                  LT NRsf   New Rating   NR(EXP)sf
   A-L                  LT NRsf   New Rating
   A-2                  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-1                  LT BBBsf  New Rating   BBB-(EXP)sf
   D-2                  LT BBB-sf New Rating   BBB-(EXP)sf
   E                    LT BB+sf  New Rating   BB+(EXP)sf
   F                    LT NRsf   New Rating   NR(EXP)sf
   Subordinated Notes   LT NRsf   New Rating   NR(EXP)sf

Transaction Summary

AGL CLO 33 Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by AGL
CLO Credit Management LLC. Net proceeds from the issuance of the
secured and subordinated notes will provide financing on a
portfolio of approximately $400 million of primarily first lien
senior secured leveraged loans.

The final ratings for class B and D-1 (AA+sf for class B and BBBsf
for class D-1) are higher than the expected ratings (AA(EXP)sf for
class B and BBB-(EXP)sf for class D-1). This change was due to
lower cost of funding and better-quality indicative and stressed
portfolios since the expected rating analysis.

KEY RATING DRIVERS

Asset Credit Quality (Negative): The average credit quality of the
indicative portfolio is 'B', which is in line with that of recent
CLOs. Issuers rated in the 'B' rating category denote a highly
speculative credit quality; however, the notes benefit from
appropriate credit enhancement and standard CLO structural
features.

Asset Security (Positive): The indicative portfolio consists of
99.75% first-lien senior secured loans and has a weighted average
recovery assumption of 74.37%. Fitch stressed the indicative
portfolio by assuming a higher portfolio concentration of assets
with lower recovery prospects and further reduced recovery
assumptions for higher rating stresses.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% 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
CLOs.

Portfolio Management (Neutral): The transaction has a 4.9-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting 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, the rated notes can
withstand default and recovery assumptions consistent with their
assigned ratings.

The WAL used for the transaction stress portfolio is 12 months less
than the WAL covenant to account for structural and reinvestment
conditions after the reinvestment period. In Fitch's opinion, these
conditions would reduce the effective risk horizon of the portfolio
during stress periods.

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 as
severe as between 'BBB+sf' and 'AA+sf' for class A-2, between
'BB+sf' and 'A+sf' for class B, between 'B+sf' and 'BBB+sf' for
class C, between less than 'B-sf' and 'BB+sf' for class D-1,
between less than 'B-sf' and 'BB+sf' for class D-2, and between
less than 'B-sf' and 'BB-sf' for class E.

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

Upgrade scenarios are not applicable to the class A-2 notes as
these notes are in the highest rating category of 'AAAsf'.

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; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B, 'AA+sf' for class C, 'A+sf' for
class D-1, 'A-sf' for class D-2, and 'BBB+sf' for class E.

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

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

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 its rating analysis according to its applicable rating
methodologies indicates that it is adequately reliable.

ESG Considerations

Fitch does not provide ESG relevance scores for AGL CLO 33 Ltd. In
cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, program,
instrument or issuer, Fitch will disclose in the key rating drivers
any ESG factor which has a significant impact on the rating on an
individual basis.


AGL CLO 33: Moody's Assigns B3 Rating to $250,000 Class F Notes
---------------------------------------------------------------
Moody's Ratings has assigned ratings to two classes of notes issued
and one class of loans incurred by AGL CLO 33 Ltd. (the "Issuer" or
"AGL CLO 33").

Moody's rating action is as follows:

US$216,000,000 Class A-1 Senior Secured Floating Rate Notes due
2037, Definitive Rating Assigned Aaa (sf)

US$40,000,000 Class A-L Loans maturing 2037, Assigned Aaa (sf)

US$250,000 Class F Junior Secured Deferrable Floating Rate Notes
due 2037, Definitive Rating Assigned B3 (sf)

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

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.

AGL CLO 33 is a managed cash flow CLO. The issued debt will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 90.0% of the portfolio must consist of
first lien senior secured loans, cash and eligible investments, and
up to 10.0% of the portfolio may consist of second lien loans,
unsecured loans, senior secured bonds or senior secured notes. The
portfolio is approximately 100% ramped as of the closing date.

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

In addition to the Rated Debt, the Issuer issued six other classes
of secured notes and one class of subordinated notes.

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2024.

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

Par amount: $400,000,000

Diversity Score: 80

Weighted Average Rating Factor (WARF): 3225

Weighted Average Spread (WAS): 3.50%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 46.5%

Weighted Average Life (WAL): 8.0 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
May 2024.

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

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


AIMCO CLO 11: S&P Assigns BB- (sf) Rating on Class E-R2 Notes
-------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1R2, A-2R2,
B-R2, C-R2, D-1R2, D-2R2, and E-R2 replacement debt from AIMCO CLO
11 Ltd./AIMCO CLO 11 LLC, a CLO managed by Allstate Investment
Management Co. that was originally issued in September 2020 and
previously refinanced in November 2021. At the same time, S&P
withdrew its ratings on the original class A-R, B-R, C-R, D-R, and
E-R debt following payment in full on the Aug. 20, 2024,
refinancing date.

The replacement debt was issued via a supplemental indenture, which
outlines the terms of the replacement debt. According to the
supplemental indenture:

-- The non-call period was extended to Aug. 20, 2026.

-- The reinvestment period was extended to July 17, 2029.

-- The legal final maturity dates (for the replacement debt and
the existing subordinated notes) were extended to July 17, 2037.

-- The required minimum overcollateralization coverage ratios were
amended.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis (and other qualitative factors, as applicable)
demonstrated, in our view, that the outstanding rated classes all
have adequate credit enhancement available at the rating levels
associated with the rating actions.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Ratings Assigned

  AIMCO CLO 11 Ltd./AIMCO CLO 11 LLC

  Class A-1R2, $384.0 million: AAA (sf)
  Class A-2R2, $18.0 million: AAA (sf)
  Class B-R2, $54.0 million: AA (sf)
  Class C-R2 (deferrable), $36.0 million: A (sf)
  Class D-1R2 (deferrable), $36.0 million: BBB (sf)
  Class D-2R2 (deferrable), $7.5 million: BBB- (sf)
  Class E-R2 (deferrable), $16.5 million: BB- (sf)
  Subordinated notes, $53.2 million: Not rated

  Ratings Withdrawn

  AIMCO CLO 11 Ltd./AIMCO CLO 11 LLC

  Class A-R to not rated from 'AAA (sf)'
  Class B-R to not rated from 'AA (sf)'
  Class C-R to not rated from 'A (sf)'
  Class D-R to not rated from 'BBB- (sf)'
  Class E-R to not rated from 'BB- (sf)'



ANGEL OAK 2024-7: Fitch Assigns 'Bsf' Final Rating on Cl. B-2 Certs
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings to Angel Oak Mortgage
Trust 2024-7 (AOMT 2024-7).

   Entity/Debt       Rating             Prior
   -----------       ------             -----
AOMT 2024-7

   A-1           LT  AAAsf  New Rating   AAA(EXP)sf
   A-2           LT  AAsf   New Rating   AA(EXP)sf
   A-3           LT  Asf    New Rating   A(EXP)sf
   M-1           LT  BBB-sf New Rating   BBB-(EXP)sf
   B-1           LT  BBsf   New Rating   BB(EXP)sf
   B-2           LT  Bsf    New Rating   B(EXP)sf
   B-3           LT  NRsf   New Rating   NR(EXP)sf
   A-IO-S        LT  NRsf   New Rating   NR(EXP)sf
   XS            LT  NRsf   New Rating   NR(EXP)sf

Transaction Summary

The AOMT 2024-7 certificates are supported by 843 loans with a
balance of $345.87 million as of the cutoff date. This represents
the 40th Fitch-rated AOMT transaction and the seventh Fitch-rated
AOMT transaction in 2024.

The certificates are secured by mortgage loans mainly originated
(76.0%) by Angel Oak Mortgage Solutions LLC (AOMS) and Angel Oak
Home Loans LLC (AOHL). The remaining 24.0% of the loans were
originated by various third-party originators (TPOs). Fitch
considers AOMS and AOHL to be average originators. The servicer of
the loans is Select Portfolio Servicing, Inc. (RPS1-/Negative).

Of the loans, 44.2% are designated as nonqualified mortgage
(non-QM) loans and 49.0% are exempted mortgage loans that were not
subject to the Ability to Repay (ATR) Rule. There are also 6.7%
safe harbor QM loans, and 0.1% QM rebuttable presumption loans in
the pool.

There are six ARM loans in the pool, none of which reference Libor.
The certificates do not have Libor exposure. Class A-1, A-2 and A-3
certificates are fixed rate, are capped at the net weighted average
coupon (WAC) and have a step-up feature. Class M-1 certificate is
based on the lower of a fixed rate and the net WAC rate for the
related distribution date and class B-1, B-2 and B-3 certificates
are based on the net WAC rate for the related distribution date.

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 10.1% above a long-term sustainable level (compared
with 11.1% on a national level as of 4Q23, down 0% qoq). Housing
affordability is at its worst levels in decades, driven by both
high interest rates and elevated home prices. Home prices have
increased 5.5% yoy nationally as of February 2024, notwithstanding
modest regional declines, but are still being supported by limited
inventory.

Non-QM Credit Quality (Mixed): The collateral consists of 843 loans
totaling $345.87 million and seasoned at about 11 months in
aggregate according to Fitch, and nine months per the transaction
documents. The borrowers have a relatively strong credit profile
with a 748 nonzero FICO and a 45.8% debt-to-income ratio (DTI), as
determined by Fitch. They have relatively moderate leverage with an
original combined loan-to-value (CLTV) ratio of 69.8% as determined
by Fitch, which translates to a Fitch-calculated sustainable LTV
(sLTV) of 76.3%.

Its analysis of the pool shows that 51.0% represents loans in which
the borrower maintains a primary or secondary residence, while the
remaining 49.0% comprises investor properties. Its analysis
considers the 26 loans to foreign nationals to be investor
occupied, which explains the discrepancy between the
Fitch-determined figures and those in the transaction documents for
investor and owner occupancy. Fitch determined that 12.6% of the
loans were originated via a retail channel.

In addition, 44.2% of the pool is designated as non-QM, while the
remaining 49.0% is exempt from QM status. There are also 6.7% Safe
Harbor QM loans and 0.1% QM Rebuttable Presumption loans in the
pool. The pool contains 56 loans over $1.00 million, with the
largest amounting to $3.19 million. Loans on investor properties
represent 49.0% of the pool, as determined by Fitch, including
13.2% underwritten to the borrower's credit profile and 35.9%
investor cash flow loans.

Fitch views only 1.7% of the borrowers as having a prior credit
event within the past seven years, and 0.5% of the loans have a
junior lien in addition to the first lien mortgage. There are no
second lien loans in the pool as 100% of the pool consists of first
lien mortgages. In Fitch's analysis, loans with deferred balances
are considered to have subordinate financing.

None of the loans in this transaction have a deferred balance;
therefore, Fitch views 0.5% of the loans in the pool as having
subordinate financing due to the borrower taking out additional
financing on the home that ranks subordinate to the mortgage in the
pool. Fitch views the limited subordinate financing as a positive
aspect of the transaction.

Fitch determined that 26 loans in the pool are to foreign
nationals. Fitch only considers a loan to be made to a foreign
national if both the borrower and co-borrower are both foreign
nationals. Fitch treats loans to foreign nationals as investor
occupied, coded as no documentation for employment and income
documentation, and remove the liquid reserves. If a credit score is
not available, Fitch uses a credit score of 650 for such
borrowers.

Although the borrowers' credit quality is higher than that of AOMT
transactions securitized in 2023 and 2022, the pool's
characteristics resemble those of nonprime collateral; therefore,
the pool was analyzed using Fitch's nonprime model.

The largest concentration of loans is in Florida (29.9%), followed
by California (19.6%) and Texas (11.0%). The largest MSA is Miami
(14.0%), followed by Los Angeles (10.4%) and New York (6.9%). The
top three MSAs account for 31.4% of the pool. There was no
geographical concentration risk in the pool; as such, Fitch did not
apply a penalty and losses were not impacted.

Loan Documentation (Negative): Fitch determined that 95.2% of the
loans in the pool were underwritten to borrowers with less than
full documentation. Fitch may consider a loan to be less than a
full documentation loan based on its review of the loan program and
the documentation details provided in the loan tape, which may
explain any discrepancy between Fitch's percentage and figures in
the transaction documents.

Of the loans underwritten to borrowers with less than full
documentation, Fitch determined that 55.6% were underwritten to a
12-month or 24-month business or personal bank statement program
for verifying income. That is not consistent with the previously
applicable Appendix Q standards and Fitch's view of a full
documentation program.

To reflect the added risk, Fitch increases the probability of
default (PD) by 1.5x on bank statement loans. In addition to loans
underwritten to a bank statement program, 35.9% constitute a debt
service coverage ratio (DSCR) product and 1.4% are an asset
qualifier product.

No loans in the pool are no-ratio DSCR loans.

Limited Advancing (Mixed): The deal is structured to six months of
servicer advances for delinquent principal and interest (P&I). 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 is the additional stress on the
structure, as liquidity is limited in the event of large and
extended delinquencies (DQs).

Modified Sequential-Payment Structure (Neutral): The structure
distributes collected principal pro rata among the class A
certificates while excluding the mezzanine and subordinate
certificates from principal until all three A classes are reduced
to zero. To the extent that either a cumulative loss trigger event
or a DQ 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. There is limited excess spread in
the transaction available to reimburse for losses or interest
shortfalls should they occur.

However, excess spread will be reduced on and after the
distribution date in August 2028, since the class A certificates
have a step-up coupon feature whereby the coupon rate will be the
lower of (i) the applicable fixed rate plus 1.000% and (ii) the net
WAC rate.

In addition, on any distribution date occurring on or after the
distribution date in August 2028 on which the aggregate unpaid cap
carryover amount for the class A certificates is greater than zero,
payments to the cap carryover reserve account will be prioritized
over the payment of interest and unpaid interest payable to class
B-3 certificates in both the interest and principal waterfalls.

This feature is supportive of the class A-1 certificate being paid
timely interest at the step-up coupon rate under Fitch's stresses
and classes A-2 and A-3 being paid ultimate interest at the step-up
coupon rate under Fitch's stresses. Fitch rates to timely interest
for 'AAAsf' rated classes and to ultimate interest for all other
rated classes.

On Aug. 1, Fitch revised its sustainable market value decline
assumptions in its US RMBS Loan Loss model to reflect updated home
prices and economic data. This change had no impact to Fitch's loss
expectations.

The transaction priced on Aug. 7 and as a result of the pricing and
current market conditions the balances, coupons and CE changed. The
transaction still has sufficient CE to pass Fitch's rating stresses
and there are no changes to the final ratings from the expected
ratings that were previously assigned. See below for the revised CE
and ratings for each Fitch rated class:

A-1: CE: 27.30%; 'AAAsf'

A-2: CE: 22.05%; 'AAsf'

A-3: CE: 13.05%; 'Asf'

M-1: CE: 8.15%; 'BBB-sf'

B-1: CE: 6.55%; 'BBsf'

B-2: CE: 4.45%; 'Bsf'

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 analyses was conducted at the
state and national levels to assess the effect of higher MVDs for
the subject pool as well as lower MVDs, illustrated by a gain in
home prices.

This defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10%, 20% and 30% in addition to the
model-projected 41.6% at 'AAAsf'. 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 analyses were conducted at the state and national
levels to assess the effect of higher MVDs for the subject pool as
well as lower MVDs, illustrated by a gain in home prices.

This 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 being assigned
ratings of 'AAAsf'.

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Canopy, Clarifii, Clayton, Consolidated Analytics,
Covius, Infinity, Inglet Blair, Recovco, and Selene. The
third-party due diligence described in Form 15E focused on three
areas: compliance review, credit review and valuation review. Fitch
considered this information in its analysis and, as a result, did
not make any negative adjustments to its analysis due to no
material due diligence findings. Based on the results of the 100%
due diligence performed on the pool with no material findings, the
overall expected loss was reduced by 0.48%.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the loans. The third-party due diligence was
consistent with Fitch's "U.S. RMBS Rating Criteria." The sponsor
engaged Canopy, Clarifii, Clayton, Consolidated Analytics, Covius,
Infinity, Inglet Blair, Recovco, and Selene to perform the review.
Loans reviewed under these engagements were given compliance,
credit and valuation grades and assigned initial grades for each
subcategory.

An exception and waiver report was provided to Fitch, indicating
the pool of reviewed loans has a number of exceptions and waivers.
Fitch determined that the exceptions and waivers do not materially
affect the overall credit risk of the loans due to the presence of
compensating factors such as having liquid reserves or FICO above
guideline requirements or LTV or DTI lower than the guideline
requirement. Therefore, no adjustments were needed to compensate
for these occurrences.

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 (ASF) data layout format.

The ASF data tape layout was established with input from various
industry participants, including rating agencies, issuers,
originators, investors and others, to produce an industry standard
for the pool-level data to support the U.S. RMBS securitization
market. The data contained in the data tape layout were populated
by the due diligence company and no material discrepancies were
noted.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


ANTARES CLO 2018-3: S&P Assigns BB- (sf) Rating on Class E Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1-R, A-2-R,
B-R, C-R, D-R, and E-R replacement debt from Antares CLO 2018-3
Ltd./Antares CLO 2018-3 LLC, a CLO originally issued in December
2018 that is managed by Antares Capital Advisers LLC, a wholly
owned subsidiary of Antares Holdings L.P. At the same time, S&P
withdrew its ratings on the original class A-1, B, C, D, and E debt
following payment in full on the Aug. 22, 2024, refinancing date.
S&P did not rate the original class A-2 debt.

The replacement debt was issued via a supplemental indenture, which
outlines the terms of the replacement debt. According to the
supplemental indenture:

-- The non-call period was extended to Aug. 22, 2026.

-- The reinvestment period was extended to July 20, 2028.

-- The legal final maturity dates (for the replacement debt and
the original subordinated notes) were extended to July 20, 2036.

-- The target initial par amount remains at $1.0 billion. The new
effective date is Dec. 20, 2024, and the first payment date
following the refinancing is Jan. 20, 2025.

-- The required minimum overcollateralization and interest
coverage ratios were amended.

-- The replacement class A-2-R debt is rated 'AAA (sf)', replacing
the previously unrated original class A-2 debt.

-- No additional subordinated notes were issued on the refinancing
date.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis (and other qualitative factors, as applicable)
demonstrated, in our view, that the outstanding rated classes all
have adequate credit enhancement available at the rating levels
associated with the rating actions

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Ratings Assigned

  Antares CLO 2018-3 Ltd./Antares CLO 2018-3 LLC

  Class A-1-R, $580.0 million: AAA (sf)
  Class A-2-R, $30.0 million: AAA (sf)
  Class B-R, $85.0 million: AA (sf)
  Class C-R (deferrable), $70.0 million: A (sf)
  Class D-R (deferrable), $55.0 million: BBB- (sf)
  Class E-R (deferrable), $60.0 million: BB- (sf)

  Ratings Withdrawn

  Antares CLO 2018-3 Ltd./Antares CLO 2018-3 LLC

  Class A-1 to NR from 'AAA (sf)'
  Class B to NR from 'AA (sf)'
  Class C to NR from 'A (sf)'
  Class D to NR from 'BBB- (sf)'
  Class E to NR from 'BB- (sf)'
  
  Other Debt

  Antares CLO 2018-3 Ltd./Antares CLO 2018-3 LLC

  Subordinated notes, $122.9 million: NR

  NR--Not rated.



APIDOS CLO XXVI: Moody's Affirms Ba3 Rating on $20MM Class D Notes
------------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by Apidos CLO XXVI:

US$37.5M Class B-R Mezzanine Deferrable Floating Rate Notes,
Upgraded to Aaa (sf); previously on Jan 26, 2024 Upgraded to Aa2
(sf)

US$0M Class C-R Mezzanine Deferrable Floating Rate Notes, Upgraded
to A3 (sf); previously on Jul 19, 2021 Assigned Baa3 (sf)

Moody's have also affirmed the ratings on the following notes:

US$295M (Current outstanding amount US$53,945,355) Class A-1AR
Senior Secured Floating Rate Notes, Affirmed Aaa (sf); previously
on Jul 19, 2021 Assigned Aaa (sf)

US$25M Class A-1BR Senior Secured Floating Rate Notes, Affirmed
Aaa (sf); previously on Jul 19, 2021 Assigned Aaa (sf)

US$52.5M Class A-2R Senior Secured Floating Rate Notes, Affirmed
Aaa (sf); previously on Jan 26, 2024 Upgraded to Aaa (sf)

US$20M Class D Mezzanine Deferrable Floating Rate Notes, Affirmed
Ba3 (sf); previously on May 31, 2017 Definitive Rating Assigned Ba3
(sf)

Apidos CLO XXVI, originally issued in May 2017 and partially
refinanced in July 2021, is a managed cashflow CLO. The notes are
collateralized primarily by a portfolio of broadly syndicated
senior secured corporate loans. The portfolio is managed by CVC
Credit Partners US CLO Management LLC. The transaction's
reinvestment period ended in July 2022.

RATINGS RATIONALE

The rating upgrades on the Class B-R and Class C-R notes are
primarily a result of the significant deleveraging of the Class
A-1AR notes following amortisation of the underlying portfolio
since the last rating action in January 2024.

The Class A-1AR notes have paid down by approximately US$124.4
million (42.2% of original balance) since the last rating action in
January 2024 and US$241.1 million (81.7% of original balance) since
closing. As a result of the deleveraging, over-collateralisation
(OC) has increased across the capital structure. According to the
trustee report dated July 2024 [1] the Class A, Class B, Class C,
and Class D OC ratios are reported at 152.7%, 129.0%, 114.7% and
106.9% compared to January 2024 [2] levels of 135.1%, 120.7%,
111.3% and 105.8%, respectively. Moody's note that the July 2024
principal payments are not reflected in the reported OC ratios.

The affirmations on the ratings on the Class A-1AR, Class A-1BR,
Class A-2R and Class D notes are primarily a result of the expected
losses on the notes remaining consistent with their current rating
levels, after taking into account the CLO's latest portfolio, its
relevant structural features and its actual over-collateralisation
ratios.

The key model inputs Moody's use in Moody's analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on Moody's published methodology
and could differ from the trustee's reported numbers.

In Moody's base case, Moody's used the following assumptions:

Performing par and principal proceeds balance: US$236.6 million

Defaulted Securities: US$5.4 million

Diversity Score: 53

Weighted Average Rating Factor (WARF): 2818

Weighted Average Life (WAL): 3.0 years

Weighted Average Spread (WAS): 2.9%

Weighted Average Coupon (WAC): 0.0%

Weighted Average Recovery Rate (WARR): 47.4%

Par haircut in OC tests and interest diversion test: None

The default probability derives from the credit quality of the
collateral pool and Moody's expectation of the remaining life of
the collateral pool. The estimated average recovery rate on future
defaults is based primarily on the seniority of the assets in the
collateral pool. In each case, historical and market performance
and a collateral manager's latitude to trade collateral are also
relevant factors. Moody's incorporate these default and recovery
characteristics of the collateral pool into Moody's cash flow model
analysis, subjecting them to stresses as a function of the target
rating of each CLO liability it is analysing.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2024.

Counterparty Exposure:

The rating action took into consideration the notes' exposure to
relevant counterparties using the methodology "Moody's Approach to
Assessing Counterparty Risks in Structured Finance methodology"
published in October 2023. Moody's concluded the ratings of the
notes are not constrained by these risks.

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

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

Additional uncertainty about performance is due to the following:

-- Portfolio amortisation: The main source of uncertainty in this
transaction is the pace of amortisation of the underlying
portfolio, which can vary significantly depending on market
conditions and have a significant impact on the notes' ratings.
Amortisation could accelerate as a consequence of high loan
prepayment levels or collateral sales by the collateral manager or
be delayed by an increase in loan amend-and-extend restructurings.
Fast amortisation would usually benefit the ratings of the notes
beginning with the notes having the highest prepayment priority.

-- Recovery of defaulted assets: Market value fluctuations in
trustee-reported defaulted assets and those Moody's assume have
defaulted can result in volatility in the deal's
over-collateralisation levels. Further, the timing of recoveries
and the manager's decision whether to work out or sell defaulted
assets can also result in additional uncertainty. Moody's analysed
defaulted recoveries assuming the lower of the market price or the
recovery rate to account for potential volatility in market prices.
Recoveries higher than Moody's expectations would have a positive
impact on the notes' ratings.

In addition to the quantitative factors that Moody's explicitly
modelled, qualitative factors are part of the rating committee's
considerations. These qualitative factors include the structural
protections in the transaction, its recent performance given the
market environment, the legal environment, specific documentation
features, the collateral manager's track record and the potential
for selection bias in the portfolio. All information available to
rating committees, including macroeconomic forecasts, input from
Moody's other analytical groups, market factors, and judgments
regarding the nature and severity of credit stress on the
transactions, can influence the final rating decision.


ARBOR REALTY 2021-FL3: DBRS Confirms B(low) Rating on G Notes
-------------------------------------------------------------
DBRS, Inc. confirmed its credit ratings on all classes of notes
issued by Arbor Realty Commercial Real Estate Notes 2021-FL3, Ltd.
as follows:

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

All trends are Stable.

The credit rating confirmations reflect the increased credit
support to the notes as there has been a collateral reduction of
22.0% since the transaction became static in March 2024 following
the post-closing 30-month Reinvestment Period. The transaction also
benefits from being composed solely of loans backed by multifamily
collateral, which has historically proven to better retain property
value and cash flow compared with other property types. In its
analysis for the review, Morningstar DBRS determined the majority
of individual borrowers are progressing with their business plans
to increase property cash flow and property value; however, some
borrowers' business plans and loan exit strategies have lagged for
a variety of factors, including increased construction costs,
slowed rent growth, and increased debt service costs, which has
increased the execution risk. The unrated, first-loss note of
$127.5 million provides significant cushion against realized losses
should the increased risks for those loans ultimately result in
defaults and dispositions. In conjunction with this press release,
Morningstar DBRS has published a Surveillance Performance Update
report with in-depth analysis and credit metrics for the
transaction as well as business plan updates on select loans. For
access to this report, please click on the link under Related
Documents below or contact us at info-DBRS@morningstar.com.

As of the July 2024 remittance, the transaction had an outstanding
balance of $1.17 billion with 39 loans secured by 52 properties
remaining in the trust. Of the original 36 loans from the
transaction closing in October 2021, 12 loans, representing 32.5%
of the current pool balance, remain in the trust. Since the
previous Morningstar DBRS credit rating action in September 2023,
seven loans, representing 16.6% of the current pool balance, have
been added to the trust. As referenced above, there has been
significant collateral reduction since the previous credit rating
action as 18 loans with a former cumulative trust balance of $464.1
million were successfully paid in full and another three loans with
a former cumulative trust balance of $66.9 million were deemed
credit-risk assets and were purchased out of the trust by the
issuer.

The pool collateral is concentrated in properties located in
suburban markets as 30 loans, representing 79.3% of the pool, are
secured by properties in suburban markets, as defined by
Morningstar DBRS, with a Morningstar DBRS Market Rank of 3, 4, or
5. An additional seven loans, representing 16.6% of the pool, are
secured by properties with Morningstar DBRS Market Ranks of 1 and
2, denoting rural and tertiary markets, while the remaining two
loans, representing 4.1% of the pool, are secured by properties
with Morningstar DBRS Market Ranks of 6 or 7, denoting urban
markets. This is in comparison with the pool at September 2023 when
properties in suburban markets represented 75.3% of the collateral,
properties in tertiary and rural markets represented 17.6% of the
collateral, and properties in urban markets represented 7.0% of the
collateral.

Leverage across the pool has declined since issuance as the current
weighted-average (WA) as-is appraised value loan-to-value ratio
(LTV) is 79.5% with a current WA stabilized LTV of 67.6%. In
comparison, these figures were 84.1% and 71.6%, respectively, at
issuance. Morningstar DBRS recognizes these appraised values may be
inflated as the individual property appraisals were completed in
2021 or 2022 and do not reflect the current higher interest rate or
widening capitalization rate environments. In the analysis for this
review, Morningstar DBRS applied LTV adjustments to 18 loans,
representing 62.8% of the current trust balance, generally
reflective of higher cap rate assumptions compared with the implied
cap rates based on the appraisals.

As of July 2024, two loans, representing 5.0% of the current pool
balance, are reported as 30 to 59 days delinquent. The Landings at
Brittany Acres loan (Prospectus ID#64; 2.8% of the current pool
balance) is secured by a multifamily property in Bridgeton,
Missouri. According to the collateral manager's Q1 2024 update, the
borrower has continually made debt service payments late as the
interest reserve is not sufficient to cover payments. The loan
matured in April 2024 and was subsequently modified to allow the
borrower to exercise the first 12-month extension without meeting
the performance threshold as the debt service coverage ratio (DSCR)
for the trailing 12 months (T-12) ended February 29, 2024, was 0.79
times (x). The collateral manager noted the borrower was also
working to refinance the loan by the end of June 2024, but as of
the July 2024 remittance the loans remains in the trust. The
borrower is in the midst of its business plan to renovate all 280
units of the property. As of Q1 2024, 135 units had been upgraded
and $0.5 million of the original $1.2 million of loan future
funding remained in an interest-bearing account controlled by the
collateral manager.

The collateral manager reported that two loans, representing 4.4%
of the current pool balance, are specially serviced. The Estrella
at Kiest loan (Prospectus ID#73; 2.2% of the current pool balance)
is secured by a multifamily property in Dallas. The loan
transferred to the special servicer in April 2024 for imminent
default. The loan was modified to extend the loan maturity to
September 2025 with the borrower purchasing a new interest rate cap
agreement with a 5.0% strike rate and depositing $250,000 into a
general reserve. The borrower will also be required to deposit
$500,000 into the interest reserve if the balance in the reserve
falls below $384,000. As of Q1 2024, the property was 78.9%
occupied and the borrower had used $4.1 million of loan future
funding to complete its renovation plan, including 120 of the 180
planned unit upgrades. There remains $1.1 million of available
renovation dollars in an interest bearing account controlled by the
collateral manager.

The other specially serviced loan, Casa Blanca & Casa Valencia
(Prospectus ID#28; 2.2% of the current pool balance), is also
secured by a multifamily property in Dallas. The loan transferred
to special servicing in January 2024 for imminent default. The loan
was modified in March 2024 whereby the borrower made a $1.0 million
deposit to be used to pay past-due debt service, fund the
renovation reserve, and fund the interest rate cap reserve. The
borrower is also required to make an additional $1.0 million
deposit to a newly created renovation and loan paydown reserve by
December 2024 with another $0.5 million due by June 2025. Lastly,
the borrower purchased a new 12-month interest rate cap agreement
with a 5.25% strike rate. In return, the loan was extended to March
2026 and the lender will provide monthly advances of $100,000 for
the borrower to complete its renovation program. As of Q1 2024, the
borrower had completed 179 of the planned 227 unit upgrades, having
used $3.8 million of loan future funding. The property was
appraised at $24.6 million in June 2024, down from the original
as-is appraised value of $27.6 million. The current LTV is elevated
at 103.7%, suggesting the credit risk of the loan has increased
materially from closing. The projected as-stabilized value of $30.2
million implies an elevated LTV of 84.4%, which may be aggressive
as the implied cap rate based on the issuer's stabilized cash flow
of $1.7 million is 5.6%. In its analysis for both specially
serviced loans, Morningstar DBRS applied upward LTV adjustments to
increase the loan level expected loss for each.

The servicer did not report any loans on the servicer's watchlist
as of the July 2024 reporting; however, using the most recent
available cash flow reports for a range of T-12s ended from
December 31, 2023, to May 31, 2024, for all loans in trust, only
nine loans, representing 22.0% of the current pool balance,
reported DSCRs above 1.0x, suggesting the remaining loans should be
on the servicer's watchlist for low DSCRs. In total, 20 loans,
representing 61.9% of the current pool balance, have been modified.
Terms for individual loan modifications vary; however, some common
terms have allowed borrowers to extend maturity dates without
meeting required property performance tests, extend renovation
completion dates, and waive or defer the requirement to purchase
new interest rate cap agreements with some borrowers securing
subordinate preferred equity financing to purchase new rate cap
agreements. In return, borrowers have made fresh equity deposits
into renovation or operating reserves.

Throughout 2024, 10 loans, representing 19.9% of the current pool
balance, have scheduled maturity dates. All 10 loans have extension
options and, if property performance does not qualify to exercise
the related options, Morningstar DBRS expects the borrowers and
lenders to negotiate mutually beneficial loan modifications to
extend loans, which would likely include fresh sponsor equity to
fund principal curtailments, fund carry reserves, or purchase new
interest rate cap agreements.

Through March 2024, the lender had advanced $113.0 million in
cumulative loan future funding to 26 of the outstanding individual
borrowers to aid in property stabilization efforts, including $64.4
million since the previous Morningstar DBRS rating action in
September 2023. The largest advance to a single borrower ($25.1
million) was made to the Diplomat Tower loan, which is secured by a
2022-vintage multifamily property in Hallandale Beach, Florida. The
borrower's business plan is to complete the initial lease-up phase
of the property. Future funding of up to $30.1 million was
available at loan closing to fund operating and debt service
shortfalls as well as an earnouts tied to the borrower achieving
multiple occupancy benchmarks. To date, $15.0 million of earnout
dollars and $10.5 million of operating shortfall dollars have been
released to the borrower. The remaining $5.0 million of future
funding was reallocated for debt service shortfalls from an
additional earnout and remains available to the borrower. According
to the April 2024 rent roll, the property was 76.4% occupied with
an average rental rate of $5,127 per unit. Property cash flow does
not currently cover debt service as the DSCR for the T-12 ended
April 30, 2024, was 0.28x.

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


BALLYROCK CLO 27: S&P Assigns Prelim BB-(sf) Rating on Cl. D Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Ballyrock
CLO 27 Ltd./Ballyrock CLO 27 LLC's floating-rate debt.

The debt 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 Ballyrock Investment Advisors LLC, an
affiliate of Fidelity Management & Research Co. LLC.

The preliminary ratings are based on information as of Aug. 20,
2024. 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

  Ballyrock CLO 27 Ltd./Ballyrock CLO 27 LLC

  Class A-1a, $320.00 million: AAA (sf)
  Class A-1b, $15.00 million: AAA (sf)
  Class A-2, $45.00 million: AA (sf)
  Class B (deferrable), $30.00 million: A (sf)
  Class C-1 (deferrable), $30.00 million: BBB- (sf)
  Class C-2 (deferrable), $5.00 million: BBB- (sf)
  Class D (deferrable), $15.00 million: BB- (sf)
  Subordinated notes, $50.52 million: Not rated



BAMLL COMMERCIAL 2015-ASTR: S&P Cuts E Certs Rating to 'B- (sf)'
----------------------------------------------------------------
S&P Global Ratings lowered its ratings on seven classes of
commercial mortgage pass-through certificates from BAMLL Commercial
Mortgage Securities Trust 2015-ASTR, a U.S. CMBS transaction.

This is a U.S. standalone (single-borrower) CMBS transaction that
is backed by a 12-year, fixed-rate, interest-only (IO) mortgage
loan secured by the borrower's leasehold interest in a class A
office building at 51 Astor Place in lower Manhattan's Greenwich
Village office submarket.

Rating Actions

The downgrades on classes A, B, C, D, and E primarily reflect
that:

-- While the property is currently 96.0% leased, the largest
tenant, IBM (37.3% of the net rentable area [NRA]), had announced
in March 2022 that it will vacate the subject property and relocate
to One Madison Avenue upon its lease expiration in December 2024.
According to the master servicer, Wells Fargo Bank N.A. (Wells
Fargo), the sponsor is currently in early negotiations with a
prospective tenant for about 75,000 sq. ft. of IBM's space. If the
sponsor can sign a lease for said space by the time IBM leaves, and
including known tenant movements, S&P expects the property's
occupancy to stabilize at around 82.0% by year-end, which is in
line with the current office submarket fundamentals. Otherwise, it
would fall to around 63.0% if IBM's space is not backfilled
timely.

-- S&P's expected-case valuation, while unchanged from its last
review in July 2023, is 10.3% lower than the valuation S&P derived
at issuance.

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

S&P said, "We will continue to monitor the tenancy and performance
of the property, including the sponsor's ability to stabilize the
property's occupancy timely following IBM's departure at the end of
2024, and the loan. If we receive information that differs
materially from our expectations, we may revisit our analysis and
take additional rating actions as we determine necessary."

Property-Level Analysis

The collateral property is a 12-story, class A, LEED Gold
certified, 385,831-sq.-ft. office tower with ground floor retail
space located at 51 Astor Place in the NoHo neighborhood of lower
Manhattan. The building, built in 2013 by the sponsor, a joint
venture between Edward J. Minskoff Equities and Rockwood Capital
(subsequently sold its position to Korean Teachers' Credit Union in
August 2015), for $313.6 million ($813 per sq. ft.), is located
between Third and Fourth Avenues on East Ninth Street and Astor
Place. Amenities include a conference center, a private green roof
on the fifth floor, a tenant-accessible green roof on the top
floor, and an urban plaza. The property is accessible via multiple
subway lines.

The property is subject to a ground lease between the borrower as
lessee and The Cooper Union for the Advancement of Science and Art
as lessor from Jan. 31, 2008, to July 9, 2108, with no renewal
options. The ground lease specifies fixed base ground rent payments
of $11.6 million annually for 20 years from July 15, 2015, through
July 14, 2035. There is no ground rent due thereafter. The borrower
paid in advance the full amount due under the ground lease
agreement in the form of a promissory note to the lessor.

Additionally, the site has a deed restriction requiring the
property to contain no less than 40,000 sq. ft. of space for
education purposes. The property currently consists of 287,672 sq.
ft. of office space, 26,844 sq. ft. of retail space, and 71,315 sq.
ft. of educational space leased to St. John's University until July
31, 2030. However, according to Wells Fargo, it plans to give back
6,000 sq. ft. later this year, reducing its footprint to 65,315 sq.
ft. The sponsor intends to use the 6,000 sq. ft. to build out
amenity space at the property.

S&P said, "In our July 2023 review, we noted that the property was
fully leased since 2018. However, we assessed that the property's
vacancy rate may move to a level in line with the deteriorated
office submarket fundamentals after IBM vacates in December 2024
and 1stdibs.com (10.9% of NRA), which was marketing its space for
sublease, decides to downsize or exercise its termination option
effective December 2024. We utilized a 15.0% vacancy rate (on par
with the office submarket vacancy at that time), S&P Global
Ratings' gross rent of $116.47 per sq. ft., 42.7% operating expense
ratio, and higher tenant improvement (TI) cost assumptions to
arrive at a revised long-term sustainable net cash flow (NCF) of
$19.0 million."

The servicer reported stable NCF of $26.6 million in 2023 and
corresponding debt service coverage of 2.25x. According to the July
31, 2024, rent roll, the property was 96.0% leased due primarily to
former tenant, CBAM Partners LLC (4.0% of NRA), terminating its
lease in early 2024. Wells Fargo stated that it paid a $3.75
million termination fee; and after disbursing $1.47 million to fund
the leasing cost of tenant, Tudor Investment Corp., which expanded
its footprint to 9.2% of NRA in 2024 from 6.6% of NRA as well as
renewed its lease through August 2031 from February 2026 at the
property, the remaining $2.28 million is currently deposited into a
lender-controlled general leasing reserve account.

Additionally, since IBM is not renewing its lease, approximately
$9.35 million ($65.00 per sq. ft. on IBM's space, as specified in
the transaction documents) was swept into a lender-controlled
reserve account. Wells Fargo indicated that $2.75 million was
recently used to pay leasing expenses related to tenant, Mail
Media, moving from the ninth floor (6.6% of NRA) and expanding into
a portion of IBM's space on the fourth floor (10.9% of NRA).

After including known tenant movements, the five largest tenants,
which currently comprise 52.6% of NRA, are:

-- St. John University (16.9% of NRA, 16.6% of S&P Global Ratings'
in-place gross rent, July 2030 lease expiration). As S&P previously
mentioned, the tenant currently leases 18.5% of NRA and is expected
to give back 6,000 sq. ft. (1.6% of NRA) in November 2024 for the
sponsor to build out amenity space at the property.

-- Mail Media (10.9%, 18.6%, October 2036). The tenant recently
signed a lease to move from its current unit on the ninth floor to
IBM's space on the fourth floor. It received 16 months of free rent
and over $150 per sq. ft. in TIs.

-- 1stdibs.com Inc. (10.9%, 18.5%, December 2029). The tenant has
a termination option effective December 2024. Wells Fargo stated
that it has not exercised its option and has subleased its space to
Intuit until March 2030.

-- Tudor Investment Corp. (9.2%, 17.6%, August 2031). The tenant
recently increased its footprint at the property and extended its
lease. It received $90.00 per sq. ft. on its new space and $30.00
per sq. ft. on its existing space and six months of free rent.

Prospective Advisors LLC (4.7%, 9.5%, June 2026).

The property has no tenant rollover until 2026 when leases
comprising 8.2% of the NRA (15.2% of S&P Global Ratings' in-place
gross rent) expire. S&P also considered the concentrated tenant
rollover between 2029 and 2031 when leases aggregating 41.6% of NRA
(63.4%) expire versus the loan's maturity in July 2027.

According to CoStar, the vacancy rate for 4- and 5-star properties
in the Greenwich Village office submarket, where the subject
property is located, has decreased significantly to 9.2% as of
year-to-date 2024 from over 15.0% a year ago. The availability rate
is still elevated at 17.7%, and the asking rent was $93.40 per sq.
ft. for the same period. CoStar projects vacancy to decrease to
8.1% and asking rent to increase modestly to $94.57 per sq. ft. by
2028.

S&P said, "In our current analysis, assuming an 18.0% vacancy rate
(reflecting our expected occupancy rate of the property by year
end, which is in line with the current submarket office
fundamentals), $118.17 per sq. ft. S&P Global Ratings' in-place
gross rent, 44.1% operating expense ratio, and higher TI costs, we
arrived at a NCF of $19.0 million, the same as in our last review
and 9.1% lower than our issuance NCF of $20.9 million. Utilizing a
S&P Global Ratings' capitalization rate of 6.25%, we derived an S&P
Global Ratings' expected-case value of $303.6 million, or $787 per
sq. ft., unchanged from our last review, and 10.3% and 48.5% below
our issuance value of $338.3 million and issuance appraised value
of $590.0 million, respectively. This yielded an S&P Global
Ratings' loan-to-value ratio of 90.1%."

  Table 1

  Servicer-reported collateral performance
                     
                                2023(I)  2022(I)  2021(I)

  Occupancy rate (%)            100.0    100.0    100.0

  Net cash flow (mil. $)         26.6     27.2     26.5

  Debt service coverage (x)      2.25     2.30     2.24

  Appraisal value (mil. $)      590.0    590.0    590.0

  (i)Reporting period.


  Table 2

  S&P Global Ratings' key assumptions

CURRENT LAST REVIEW ISSUANCE
                           (AUGUST 2024) (JULY 2023) (AUGUST 2015)
                                 (I)         (I)           (I)

  Occupancy rate (%)            82.0        85.0          95.0

  Net cash flow (mil. $)        19.0        19.0          20.9

  Capitalization rate (%)       6.25        6.25          6.25

  Value (mil. $)               303.6       303.6         338.3

  Value per sq. ft. ($)          787         787           877

  Loan-to-value ratio (%)       90.1        90.1          80.9

(i)Review period.


Transaction Summary

The 12-year, fixed-rate, IO mortgage loan had an initial and
current balance of $273.5 million (as of the Aug. 15, 2024, trustee
remittance report), pays an annual fixed interest rate of 4.26%,
and matures on July 10, 2027. According to the August 2024 trustee
remittance report, class E had accumulated interest shortfalls
outstanding totaling $477, which S&P deemed de minimis. To date,
the transaction has not experienced any principal losses.

In addition to the mortgage loan, there is a IO mezzanine loan
totaling $96.5 million. Including the mezzanine loan, the S&P
Global Ratings' LTV ratio increases to 121.9%.

  Ratings Lowered

  BAMLL Commercial Mortgage Securities Trust 2015-ASTR

  Class A to 'AA (sf)' from 'AAA (sf)'
  Class B to 'A- (sf)' from 'AA- (sf)'
  Class C to 'BBB- (sf)' from 'A- (sf)'
  Class D to 'BB (sf)' from 'BBB- (sf)'
  Class E to 'B- (sf)' from 'B+ (sf)'
  Class X-A to 'AA (sf)' from 'AAA (sf)'
  Class X-B to 'BBB- (sf)' from 'A- (sf)'



BANC OF AMERICA 2015-UBS7: DBRS Confirms C Rating on 2 Tranches
---------------------------------------------------------------
DBRS Limited confirmed the credit ratings on all classes of
Commercial Mortgage Pass-Through Certificates, Series 2015-UBS7
issued by Banc of America Merrill Lynch Commercial Mortgage Trust
2015-UBS7 as follows:

-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X-A at AAA (sf)
-- Class X-B at AAA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class X-D at BBB (low) (sf)
-- Class D at BB (high) (sf)
-- Class X-E at B (sf)
-- Class E at B (low) (sf)
-- Class F at C (sf)
-- Class G at C (sf)

Morningstar DBRS changed the trends on Classes C, D, E, X-D, and
X-E to Negative from Stable. The trends on all other classes are
Stable with the exception of Classes F and G, which are assigned
credit ratings that do not typically carry a trend in commercial
mortgage-backed securities (CMBS) credit ratings.
The credit rating confirmations reflect the overall stable
performance of the pool as exhibited by a healthy weighted-average
(WA) debt service coverage ratio (DSCR) of 2.10 times (x) based on
the most recent year-end financials. However, Morningstar DBRS
notes increased concerns related to loan level performance declines
and/or large tenant exposure as the pool enters its maturity year
in 2025. The primary loans of concern are further discussed below.
In addition, the pool is concentrated by property type with more
than 25.0% of the pool balance secured by office properties.
Morningstar DBRS has a cautious outlook on this asset type as
sustained upward pressure on vacancy rates in the broader office
market may challenge landlords' efforts to backfill vacant space
and, in certain instances, contribute to value declines,
particularly for assets in noncore markets and/or with
disadvantages in location, building quality, or amenities offered.
Where applicable, Morningstar DBRS increased the probability of
default (POD) penalties and, in certain cases, applied stressed
loan-to-value ratios (LTVs) for office-backed and other loans
exhibiting performance concerns. To date, $19.4 million of losses
have been realized in the trust, eroding the majority of the
nonrated Class H balance. In addition, $2.5 million of interest
shortfalls have accrued to date, a slight increase from the prior
year of $2.4 million. These factors all contributed to the Negative
trends.

As of the July 2024 remittance, 37 of the original 42 loans remain
in the pool, representing a collateral reduction of 24.4% since
issuance. Seven loans, representing 8.3% of the pool balance, are
fully defeased. Seven other loans, representing 15.5% of the pool
balance, are on the servicer's watchlist and one loan, representing
3.0% is in special servicing. The Holiday Inn - New York JFK
(Prospectus ID#8; 3.0% of the pool) loan is secured by a 201-key
full-service hotel, located close to JFK Airport. This loan
transferred to special servicing in March 2024 for nonmonetary
default as the borrower was noncompliant with the franchise
agreement. The hotel ultimately lost its flag and is currently
contracted by the NYC Department of Homeless Services to provide
temporary housing assistance for the homeless. However, it appears
the property has permanently closed. The loan was last paid in
April 2024 and the servicer is currently working toward appointing
a receiver and continues to hold discussions regarding forbearance
with the borrower. A new appraisal has not yet been ordered, but
Morningstar DBRS expects that the property value has likely
declined from the issuance appraised value of $51.6 million
considering the loss of the flag and the change in use of the
property. For this review, Morningstar DBRS liquidated this loan
from the pool based on a stressed haircut to the issuance value,
resulting in an implied loss of $3.6 million.

The pool's office exposure is concentrated in the top 10 loans,
with the largest loan, 261 Fifth Avenue, secured by a Class B
office building in Midtown Manhattan. The occupancy rate has
declined to 86% as of March 2024 from 100% at issuance. As a
result, cash flow and DSCR have also declined. The largest tenant
is Town and Country Holdings Inc. representing 7.5% of the net
rentable area (NRA) on a lease through September 2031. Despite some
positive leasing traction in the last year, Morningstar DBRS
expects cash flow will not stabilize to issuance levels. The
decline in cash flow, the property's age and condition, and the
upcoming loan maturity in September 2025 indicate refinance risk is
elevated. To reflect this, Morningstar DBRS analyzed the loan with
a stressed loan-to-value ratio (LTV) and increased POD, resulting
in an expected loss that was more than double the deal average.

Another large office loan is 651 Brannan Street, which is secured
by a Class B office building in San Francisco. Pinterest leases
nearly 90% of the NRA through May 2029, but the tenant has been
shedding its San Francisco footprint as the company implements its
flexible hybrid/remote work model where employees have the choice
to work in any of the 50 states within the U.S. or in a country of
an international Pinterest office. Employees are only required to
work from a Pinterest office once per year. According to media
sources, Pinterest has subleased its space at the nearby 505
Brannan Street and halted its development plans at 88 Bluxome, a
500,000 square foot (sf) office property in the Bay Area. Reis
reported the South of Market average office vacancy rate was 20.6%
as of Q1 2024. It doesn't appear that the subject property is
affected as it continues to serve as Pinterest's headquarters but,
given the general shift in the tenant's demand for office space,
high submarket vacancy rate, and scheduled loan maturity in
September 2025, the refinance risk is elevated. As such, the loan
was analyzed with a stressed LTV and POD, resulting in an expected
loss that was nearly double the pool average.

The largest loan on the servicer's watchlist, Mall of New
Hampshire, is the backed by a regional mall in Manchester, New
Hampshire. A cash trap was implemented following the loan's return
from special servicing in 2021, with $1.2 million of lockbox
receipts collected, in addition to $0.5 million in an outstanding
leasing reserve as of April 2024. A more updated figure was not
provided. While the loan continues to perform, most recently
reporting a healthy in-place DSCR of 1.74x as of YE2023, this is a
significant decline from the Issuer's underwritten figure of 2.50x,
representing about 30% in net cash flow since issuance. The loan
benefits from institutional sponsorship in Simon Property Group and
the Canadian Pension Plan Investment Board; however, given the
sustained decline in performance, Morningstar DBRS believes the
property's as-is value has declined significantly since issuance,
with a stressed value scenario indicating an LTV in excess of
150.0%, significantly elevating the refinance risk at maturity in
2025.

The collateral is 405,723 sf of in-line space in an 811,573-sf
Class B single-level enclosed regional mall, anchored by Macy's,
JCPenney, and Dick's Sporting Goods; none of which serve as
collateral for the loan. As of March 2024, the collateral was 84.0%
occupied, indicating moderate improvement from 82.0% at YE2022
following the departure of Olympia Sports (3.2% of NRA). The
largest collateral tenants include Best Buy (10.4% of NRA, lease
expires January 2024), Old Navy (4.6% of NRA, lease expires January
2027), and Ulta (2.9% of NRA, lease expires May 2025). Morningstar
DBRS has inquired about the status of Best Buy's lease and is
awaiting a response; however, according to the subject mall's
website, the tenant is still in occupancy. According to the most
recent tenant sales report provided for YE2022, the subject mall
reported in-line sales (excluding Apple) of $437 per square foot
(psf), an improvement from the in-line sales of $396 psf as of
August 2021. In the analysis for this loan, Morningstar DBRS
applied an elevated LTV and a stressed POD penalty, resulting in an
expected loss that was more than double the pool average.

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


BANK 2019-BNK19: Fitch Lowers Rating on Cl. F Certs to CCsf
-----------------------------------------------------------
Fitch Ratings has downgraded two and affirmed 15 classes BANK
2019-BNK18 commercial mortgage pass-through certificates, series
2019-BNK18. In addition, the Rating Outlook for classes A-S and B
were revised to Negative from Stable. The Outlook on classes C, D,
E, F, X-B, X-D, and X-F remain Negative.

Fitch has also downgraded eight and affirmed five classes of BANK
2019-BNK19 commercial mortgage pass-through certificates, series
2019-BNK19. Classes A-S, B, C, D, and X-B were assigned Negative
Rating Outlooks following their downgrades.

   Entity/Debt          Rating            Prior
   -----------          ------            -----
BANK 2019-BNK19

   A-1 06540WBA0    LT AAAsf  Affirmed    AAAsf
   A-2 06540WBC6    LT AAAsf  Affirmed    AAAsf
   A-3 06540WBD4    LT AAAsf  Affirmed    AAAsf
   A-S 06540WBE2    LT AAsf   Downgrade   AAAsf
   A-SB 06540WBB8   LT AAAsf  Affirmed    AAAsf
   B 06540WBF9      LT A-sf   Downgrade   AA-sf
   C 06540WBG7      LT BBB-sf Downgrade   BBBsf
   D 06540WAJ2      LT BB-sf  Downgrade   BB+sf
   E 06540WAL7      LT CCCsf  Downgrade   B+sf
   F 06540WAN3      LT CCsf   Downgrade   B-sf
   X-A 06540WBH5    LT AAAsf  Affirmed    AAAsf
   X-B 06540WBJ1    LT A-sf   Downgrade   AA-sf
   X-D 06540WAA1    LT CCCsf  Downgrade   B+sf

BANK 2019-BNK18

   A-1 065402AY5    LT AAAsf  Affirmed    AAAsf
   A-2 065402AZ2    LT AAAsf  Affirmed    AAAsf
   A-3 065402BB4    LT AAAsf  Affirmed    AAAsf
   A-4 065402BC2    LT AAAsf  Affirmed    AAAsf
   A-S 065402BF5    LT AAAsf  Affirmed    AAAsf
   A-SB 065402BA6   LT AAAsf  Affirmed    AAAsf
   B 065402BG3      LT AA-sf  Affirmed    AA-sf
   C 065402BH1      LT A-sf   Affirmed    A-sf
   D 065402AJ8      LT BBBsf  Affirmed    BBBsf
   E 065402AL3      LT BBsf   Affirmed    BBsf
   F 065402AN9      LT Bsf    Affirmed    Bsf
   G 065402AQ2      LT CCCsf  Downgrade   B-sf
   X-A 065402BD0    LT AAAsf  Affirmed    AAAsf
   X-B 065402BE8    LT A-sf   Affirmed    A-sf
   X-D 065402AA7    LT BBsf   Affirmed    BBsf
   X-F 065402AC3    LT Bsf    Affirmed    Bsf
   X-G 065402AE9    LT CCCsf  Downgrade   B-sf

KEY RATING DRIVERS

Increased 'Bsf' Loss Expectations: Deal-level 'Bsf' rating case
losses have increased since Fitch's prior rating action to 4.9% for
BANK 2019-BNK18 and 6.7% in BANK 2019-BNK19. The BANK 2019-BNK18
transaction includes six Fitch Loans of Concern (FLOCs; 17.9% of
the pool), one of which is specially serviced (3.4%). The BANK
2019-BNK19 transaction has seven FLOCs (18.7%), including one
specially serviced loan (3.2%).

BANK 2019-BNK18: The downgrades on classes G and X-G reflect
increased pool loss expectations since Fitch's prior rating action,
driven primarily by the specially serviced 801 Barton Springs
(3.4%) loan. Deal-level 'Bsf' rating case losses were 3.9% at the
prior rating action.

The Negative Outlooks in BANK 2019-BNK18 reflect continued
performance deterioration and lack of stabilization of the FLOCs,
particularly Central Tower (6.3%) and Marriott Hanover (5.9%). The
Negative Outlooks reflects possible future downgrades should
performance continue to deteriorate and submarket fundamentals for
the specially serviced office loan not stabilize. The Negative
Outlooks also reflect a sensitivity scenario which assumes a higher
loss on the specially serviced 801 Barton Springs. In addition, the
pool has a high exposure to loans secured by office properties
(56.2% of the pool).

BANK 2019-BNK19: The downgrades on classes A-S, B, C, D, E, F, X-B
and X-D reflect increased pool loss expectations since Fitch's
prior rating action, driven primarily by the specially serviced 29
West 35th Street (3.2%) office loan which has seen a significant
increase in Fitch expected losses since the last rating action due
to the expectation the asset will become REO in the near future and
persistent performance declines and low occupancy. Deal-level 'Bsf'
rating case losses were 5.4% at the prior rating action.

The Negative Outlooks in BANK 2019-BNK19 reflect possible further
downgrades if there is a continued degradation of value and a
prolonged workout for 29 West 35th Street loan, as well as other
FLOCs including One Financial Plaza (3.7%). In addition, the pool
has a high office concentration of 52.0%.

Largest Contributors to Loss: The largest contributor to overall
loss expectations in BANK 2019-BNK18 is the specially serviced 801
Barton Springs loan (3.4%), which is secured by an 89,577-sf office
property located in Austin, TX. The loan transferred to special
servicing in May 2024 due to a maturity default. The property is
100% leased to 801 Barton Springs Tenant LLC, a subsidiary of
WeWork Companies, Inc., which also controls the sponsorship entity.
The tenants lease is being rejected as part of WeWork's Chapter 11
bankruptcy restructuring. The loan reported $560,349 ($6.3 psf) in
total reserves as of the July 2024 loan level reserve report.

Per CoStar, the property lies within the South office submarket of
the Austin, TX market. As of 2Q24, submarket asking rents averaged
$43.12 psf and the submarket vacancy rate was 18.7%. Fitch's 'Bsf'
rating case loss of 36% (prior to a concentration adjustment) is
based on a 10% cap rate and 40% stress to the YE 2022 NOI. In
addition to its base case analysis, Fitch performed a sensitivity
analysis that assumed an outsized loss of 50% to reflect a possible
prolonged workout and weak submarket fundamentals.

The second largest contributor to expected losses in BANK
2019-BNK18 is the Central Tower loan (6.3%), which is secured by a
164,848-sf office property located in San Francisco, CA. The
property's major tenants include Unity Technologies (52% of NRA,
leased through August 2025), Glow Holding (3.2%, December 2026) and
Pivot Interiors Inc (3.2%, October 2028). Occupancy was 67.8% as of
March 2024, unchanged from YE 2023, 67.4% at YE 2022, down from
78.2% at YE 2021 and 98.0% at issuance. Near term lease rollover
includes, 61.0% of the NRA in 2025 and 3.2% in 2026.

Per CoStar, the property lies within the Yerba Buena office
submarket of the San Francisco, CA market. As of 2Q24, submarket
asking rents averaged $45.76 psf and the submarket vacancy rate was
42.3%. Fitch's 'Bsf' rating case loss of 14.2% (prior to a
concentration adjustment) is based on a 9.25% cap rate and 15%
stress to the YE 2023 NOI.

The largest contributor to overall loss expectations, and the
largest increase in expected losses in BANK 2019-BNK19 is the
specially serviced 29 West 35th Street loan (3.2%). The loan is
secured by a 94,737-sf office property located in Manhattan, NY.
The loan transferred to special servicing in August 2020 for
payment default, and a foreclosure complaint was filed in January
2022. The lender is dual tracking the foreclosure process, a
receiver has been appointed and a foreclose sale is scheduled for
August 2024. The loan is expected to become REO.

The property has seen a persistent decline in performance with
occupancy falling from 100% at issuance to a recent low of only 19%
as of the July 2024 rent roll. The decline in occupancy is
primarily due to the loss of major tenant Knotel after bankruptcy
filing in 2021 when occupancy declined to 40%.

Fitch's 'Bsf' rating case loss of 80.5% (prior to a concentration
adjustment) reflects a stressed value of $182 psf. Fitch's analysis
incorporates the deterioration in performance, expectations for the
loan to become REO and low recovery prospects upon liquidation
given the highly distressed nature of the office asset. Fitch's
'Bsf' rating case loss for this loan at the prior rating action was
38%.

The second largest contributor to expected losses in BANK
2019-BNK19 is the One Financial Plaza loan (3.7%), which is secured
by a 621,830-sf office property located in Hartford, CT. The
property's major tenants include; Travelers Indemnity Company
(11.0% of NRA, leased through December 2024), Virtus Investment
Partners (10.2%, April 2030), and Conning & Company (7.5%, July
2029). Occupancy was 71.9% as of the March 2024 rent roll, 70.1% at
YE 2023, down from 86.9% at YE 2022, 88.8% at YE 2021 and 94.1% as
issuance. Occupancy declined in 2023 due to Travelers Indemnity
Company (Previously 32.3% of NRA) downsizing its space in the
property by 131,736-sf to 11.0% of NRA in December 2022.

Recent leasing includes three leases totaling 49,714-sf (7.9% of
NRA) which have been signed in 2024, and would increase occupancy
to 79.8%. Near term lease rollover includes 11.0% of the NRA in
2024 and 1.8% in 2025.

Per CoStar, the property lies within the Hartford office submarket
of the Hartford, CT market. As of 2Q24, submarket asking rents
averaged $20.33 psf and the submarket vacancy rate was 10.7%.
Fitch's 'Bsf' rating case loss of 16.2% (prior to a concentration
adjustment) is based on a 10.50% cap rate and 10% stress to the YE
2023 NOI, and factors in an increased probability of default due to
the deterioration in performance.

Minimal Increase in Credit Enhancement (CE): As of the July 2024
distribution date, the aggregate pool balances of the BANK
2019-BNK18 and BANK 2019-BNK19 transactions have been reduced by
1.9% and 1.8%, respectively, since issuance. The BANK 2019-BNK18
transaction includes one loan (0.9% of the pool) that has been
fully defeased. Four loans (2.4%) are fully defeased in BANK
2019-BNK19.

Interest shortfalls totaling $145,830 are impacting the non-rated
class H and risk retention class RRI in the BANK 2019-BNK18
transaction, and interest shortfalls totaling $2.3 million are
impacting the non-rated classes G, H, J and risk retention class
RRI in the BANK 2019-BNK19 transaction.

RATING SENSITIVITIES

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

Downgrades to the senior 'AAAsf' rated classes are not expected due
to the position in the capital structure and expected continued
amortization and loan repayments, but may occur if deal-level
losses increase significantly or interest shortfalls occur or are
expected to occur.

Downgrades to the junior 'AAAsf' rated class with a Negative
Outlook in BANK 2019-BNK18 are possible with continued performance
deterioration of the FLOCs, increased expected losses and limited
to no improvement in class CE, or if interest shortfalls occur. In
BANK 2019-BNK18, downgrades may occur if property performance
and/or updated valuations for the specially serviced 801 Barton
Springs loan continue to deteriorate.

Downgrades to classes rated in the 'AAsf' and 'Asf' categories
could occur if deal-level losses increase significantly from
outsized losses on larger FLOCs and/or more loans than expected
experience performance deterioration and/or default at or prior to
maturity. This is most notable for the Fairway Center I and Eleven
Seventeen Perimeter office FLOCs in BANK 2019-BNK19.

Downgrades to classes with Negative Outlooks in the 'BBBsf', 'BBsf'
and 'Bsf' categories are possible with further loan performance
deterioration of FLOCs, additional transfers to special servicing,
and/or with greater certainty of losses on the specially serviced
loans and/or FLOC.

Downgrades to 'CCCsf', 'CCsf' and 'Csf' rated classes would occur
should additional loans transfer to special servicing or default,
or as losses become realized or more certain.

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

Upgrades to classes rated in the 'AAsf' and 'Asf' category may be
possible with significantly increased credit enhancement (CE),
coupled with stable-to-improved pool-level loss expectations and
improved performance on the FLOCs.

Upgrades to the 'BBBsf' and 'BBsf' category rated classes would be
limited based on sensitivity to concentrations or the potential for
future concentration. Classes would not be upgraded above 'AA+sf'
if there is likelihood for interest shortfalls.

Upgrades to 'BBsf' and 'Bsf' category rated classes could occur
only if the performance of the remaining pool is stable, recoveries
on the FLOCs are better than expected, and there is sufficient CE
to the classes.

Upgrades to distressed classes are not likely, but may be possible
with better than expected recoveries on specially serviced loans
and/or significantly higher values on FLOCs.

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

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

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


BANK5 2024-5YR9: Fitch Assigns 'B-(EXP)sf' Rating on Class G Debt
-----------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
BANK5 2024-5YR9 commercial mortgage pass-through certificates
series 2024-5YR9 as follows:

- $9,500,000 class A-1 'AAAsf'; Outlook Stable;

- $250,000,000a class A-2 'AAAsf'; Outlook Stable;

- $0b class A-2-1 'AAAsf'; Outlook Stable;

- $0bc class A-2-X1 'AAAsf'; Outlook Stable;

- $0b class A-2-2 'AAAsf'; Outlook Stable;

- $0bc class A-2-X2 'AAAsf'; Outlook Stable;

- $345,793,000a class A-3 'AAAsf'; Outlook Stable;

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

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

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

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

- $605,293,000c class X-A 'AAAsf'; Outlook Stable;

- $86,470,000 class A-S 'AAAsf'; Outlook Stable;

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

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

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

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

- $46,478,000 class B 'AA-sf'; Outlook Stable;

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

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

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

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

- $32,426,000 class C 'A-sf'; Outlook Stable;

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

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

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

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

- $165,374,000c class X-B 'A-sf'; Outlook Stable;

- $19,456,000d class D 'BBBsf'; Outlook Stable;

- $8,647,000d class E 'BBB-sf'; Outlook Stable;

- $28,103,000cd class X-D 'BBB-sf'; Outlook Stable;

- $19,456,000d class F 'BB-sf'; Outlook Stable;

- $19,456,000cd class X-F 'BB-sf'; Outlook Stable;

- $12,971,000d class G 'B-sf'; Outlook Stable.

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

- $33,507,453d class J 'NR'.

- $33,491,261de class RR Certificates 'NR'.

- $12,091,500de class RR Interest 'NR'.

a) The initial certificate balances of classes A-2 and A-3 are
unknown and expected to be $595,793,000 in aggregate, subject to a
5% variance. The certificate balances will be determined based on
the final pricing of those classes of certificates. The expected
class A-2 balance range is $0 to $250,000,000 (net of the vertical
risk retention interest), and the expected class A-3 balance range
is $345,793,000 to $595,793,000 (net of the vertical risk retention
interest). Fitch's certificate balances for classes A-2 and A-3
reflect the high and low point of each range, respectively.

b) Exchangeable Certificates. The class A2, class A3, class AS,
class B and class C are exchangeable certificates. Each class of
exchangeable certificates may be exchanged for the corresponding
classes of exchangeable certificates, and vice versa. The dollar
denomination of each of the received classes of certificates must
be equal to the dollar denomination of each of the surrendered
classes of certificates.

The class A2 may be surrendered (or received) for the received (or
surrendered) classes A-2-1, A-2-X1, A-2-2 and A-2-X2. The class A-3
may be surrendered (or received) for the received (or surrendered)
classes A-3-1, A-3-X1, A-3-2 and A-3-X2. The class AS may be
surrendered (or received) for the received (or surrendered) classes
A-S -1, AS -X1, A-S -2 and A-S -X2. The class B may be surrendered
(or received) for the received (or surrendered) classes B-1, B-X1,
B-2 and B-X2. The class C may be surrendered (or received) for the
received (or surrendered) classes C-1, C-X1, C-2 and C-X2. The
ratings of the exchangeable classes would reference the ratings of
the associate referenced or original classes.

c) Notional amount and interest only.

d) Privately placed and pursuant to Rule 144A.

e) Vertical-risk retention interest.

Transaction Summary

The certificates represent the beneficial ownership interest in the
trust, the primary assets of which are 33 fixed-rate, commercial
mortgage loans with an aggregate principal balance of $910,215,214
as of the cutoff date. The mortgage loans are secured by the
borrowers' fee and leasehold interests in 44 commercial properties.
The loans were contributed to the trust by JPMorgan Chase Bank,
National Association, Morgan Stanley Mortgage Capital Holdings LLC,
and Wells Fargo Bank, National Association.

The master servicer is expected to be Wells Fargo Bank, National
Association and the special servicer is expected to be Midland Loan
Services, a Division of PNC Bank, National Association. The trustee
and certificate administrator are expected to be Computershare
Trust Company, National Association. The certificates are expected
to follow a sequential paydown structure.

KEY RATING DRIVERS

Fitch Net Cash Flow: Fitch Ratings performed cash flow analyses on
21 loans totaling 90.8% of the pool by balance. Fitch's resulting
net cash flow (NCF) of $87.9 million represents a 14.4% decline
from the issuer's underwritten NCF of $102.7 million.

Higher Fitch Leverage: The transaction has higher Fitch leverage
compared to recent five-year multiborrower transactions. The pool's
Fitch weighted average (WA) trust loan-to-value ratio (LTV) of
95.1% is higher than the 2024 YTD and 2023 multiborrower five-Year
averages of 92.0% and 89.7%, respectively. The pool's Fitch NCF
debt yield (DY) of 9.7% is weaker than both the 2024 YTD and 2023
averages of 10.7% and 10.6%, respectively.

Investment-Grade Credit Opinion Loans: Three loans representing
20.7% of the pool balance received an investment grade credit
opinion. BioMed 2024 Portfolio 2 (8.8% of pool) received a
standalone credit opinion of 'BBB+sf*'. 640 5th Avenue (6.4%)
received a standalone credit opinion of 'BBB+sf*'. Bronx Terminal
Market (5.5%) received a standalone credit opinion of 'BBB-sf*'.
The pool's total credit opinion percentage of 20.7% is above the
YTD 2024 multiborrower five-year average of 13.4% and the 2023
multiborrower five-year average of 14.6%. The pool's Fitch LTV and
DY, excluding credit opinion loans, are 101.4% and 9.3%,
respectively.

Higher Office Concentration: In general, the pool has lower
property type diversity compared to recent Fitch transactions; the
pool's effective property type count of 3.4 is lower than the YTD
2024 and 2023 multiborrower five-year averages of 4.2 and 4.1,
respectively. The largest property type concentration is office
(36.6% of the pool), followed by retail (35.5%) and multifamily
(17.4%).

The pool's office loan concentration is higher than the YTD 2024
and 2023 office averages of 21.4% and 27.7%, respectively. In
particular, the office concentration includes five of the largest
10 loans (33.7% of the pool). Pools that have a greater
concentration by property type are at a greater risk of losses, all
else equal. Therefore, Fitch raises the overall losses for pools
with effective property type counts below five property types.

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: 'AA-sf' / 'A-sf' / 'BBBsf' / 'BB+sf' / 'BBsf' /
'Bsf' / less than 'CCCsf'.

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

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

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

- 10% NCF Increase: 'AAAsf' / 'AA+sf' / 'A+sf' / 'BBB+sf' / 'BBBsf'
/ 'BB+sf' / 'B-sf'.

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

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

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


BENEFIT STREET XII-B: S&P Assigns BB- (sf) Rating on Class E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A, B, C, D-1,
D-2, and E floating-rate debt from Benefit Street Partners CLO
XII-B Ltd./Benefit Street Partners CLO XII-B LLC, a reissue of a
transaction originally issued in 2017 that was not rated by S&P
Global Ratings.

The debt 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 Benefit Street Partners LLC, a
subsidiary of Franklin Templeton.

The ratings reflect:

-- S&P's view of the collateral pool's diversification;

-- 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.

  Ratings Assigned

  enefit Street Partners CLO XII-B Ltd./
  Benefit Street Partners CLO XII-B LLC

  Class A, $315.00 million: AAA (sf)
  Class B, $65.00 million: AA (sf)
  Class C (deferrable), $30.00 million: A (sf)
  Class D-1 (deferrable), $30.00 million: BBB- (sf)
  Class D-2 (deferrable), $3.75 million: BBB- (sf)
  Class E (deferrable), $16.25 million: BB- (sf)
  Subordinated notes, $43.69 million: Not rated



BENEFIT STREET XXVII: S&P Assigns Prelim 'BB-' Rating on E-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-R, B-R, C-R, D-1-R, D-2-R, and E-R replacement debt from Benefit
Street Partners CLO XXVII Ltd./Benefit Street Partners CLO XXVII
LLC, a CLO originally issued in August 2022 that is managed by BSP
CLO Management LLC, a subsidiary of Franklin Templeton Investments
LLC, and was not rated by S&P Global Ratings.

The preliminary ratings are based on information as of Aug. 20,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Aug. 28, 2024, refinancing date, the proceeds from the
replacement debt will be used to redeem the original debt. At that
time, S&P expects to assign ratings to the replacement debt.
However, if the refinancing doesn't occur, S&P may withdraw its
preliminary ratings on the replacement debt.

The replacement debt will be issued via a proposed supplemental
indenture, which outlines the terms of the replacement debt.
According to the proposed supplemental indenture:

-- The non-call period will be extended to Oct. 20, 2026.

-- The reinvestment period will be extended to Oct. 20, 2029.

-- The legal final maturity dates (for the replacement debt and
the existing subordinated notes) will be extended to Oct. 20,
2037.

-- The target initial par amount is being increased to $500
million.

The preliminary ratings reflect S&P's assessment 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.

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

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Preliminary Ratings Assigned

  Benefit Street Partners CLO XXVII Ltd./
  Benefit Street Partners CLO XXVII LLC

  Class A-R, $320.00 million: AAA (sf)
  Class B-R, $60.00 million: AA (sf)
  Class C-R (deferrable), $30.00 million: A (sf)
  Class D-1-R (deferrable), $30.00 million: BBB- (sf)
  Class D-2-R (deferrable), $5.00 million: BBB- (sf)
  Class E-R (deferrable), $15.00 million: BB- (sf)

  Other Debt

  Benefit Street Partners CLO XXVII Ltd./
  Benefit Street Partners CLO XXVII LLC

  Subordinated notes, $31.95 million: Not rated



BETONY CLO 2: Moody's Affirms Ba3 Rating on $25MM Class D Notes
---------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by Betony CLO 2, Ltd.:

US$55M Class A-2 Senior Secured Floating Rate Notes, Upgraded to
Aaa (sf); previously on Apr 11, 2023 Upgraded to Aa1 (sf)

US$25M Class B Deferrable Mezzanine Secured Floating Rate Notes,
Upgraded to Aa3 (sf); previously on Apr 11, 2023 Upgraded to A1
(sf)

Moody's have also affirmed the ratings on the following notes:

US$325M (Current outstanding amount US$219,504,150) Class A-1
Senior Secured Floating Rate Notes, Affirmed Aaa (sf); previously
on Jun 27, 2018 Definitive Rating Assigned Aaa (sf)

US$30M Class C Deferrable Mezzanine Secured Floating Rate Notes,
Affirmed Baa2 (sf); previously on Apr 11, 2023 Upgraded to Baa2
(sf)

US$25M Class D Deferrable Junior Secured Floating Rate Notes,
Affirmed Ba3 (sf); previously on Jun 27, 2018 Definitive Rating
Assigned Ba3 (sf)

Betony CLO 2, Ltd., issued in June 2018 is a managed cashflow CLO.
The notes are collateralized primarily by a portfolio of broadly
syndicated senior secured corporate loans. The portfolio is managed
by Invesco RR Fund L.P. The transaction's reinvestment period ended
in May 2023.

RATINGS RATIONALE

The rating upgrades on the Class A-2 and B notes are primarily a
result of the deleveraging of the senior notes following
amortisation of the underlying portfolio since the last rating
action in April 2023.

The affirmations on the ratings on the Class A-1, Class C and Class
D notes are primarily a result of the expected losses on the notes
remaining consistent with their current rating levels, after taking
into account the CLO's latest portfolio, its relevant structural
features and its actual over-collateralisation ratios.

The Class A-1 notes have paid down by approximately USD105.5
million (32.5%) since the last rating action in April 2023. As a
result of the deleveraging, over-collateralisation (OC) has
increased for Class A to B notes. According to the trustee report
dated July 2024 [1] the Class A and Class B OC ratios are reported
at 133.10% and 123.02% compared to March 2023 [2] levels of 129.93%
and 121.91% respectively. Moody's note that the July 2024 principal
payments are not reflected in the reported OC ratios.

The key model inputs Moody's use in Moody's analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on Moody's published methodology
and could differ from the trustee's reported numbers.

In Moody's base case, Moody's used the following assumptions:

Performing par and principal proceeds balance: USD376.8m

Defaulted Securities: USD3.4m

Diversity Score: 69

Weighted Average Rating Factor (WARF): 2920

Weighted Average Life (WAL): 3.76 years

Weighted Average Spread (WAS): 3.29%

Weighted Average Coupon (WAC): 8.0%

Weighted Average Recovery Rate (WARR): 47.21%

Par haircut in OC tests and interest diversion test: none

The default probability derives from the credit quality of the
collateral pool and Moody's expectation of the remaining life of
the collateral pool. The estimated average recovery rate on future
defaults is based primarily on the seniority of the assets in the
collateral pool. In each case, historical and market performance
and a collateral manager's latitude to trade collateral are also
relevant factors. Moody's incorporate these default and recovery
characteristics of the collateral pool into Moody's cash flow model
analysis, subjecting them to stresses as a function of the target
rating of each CLO liability it is analysing.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2024.

Counterparty Exposure:

The rating action took into consideration the notes' exposure to
relevant counterparties, using the methodology "Moody's Approach to
Assessing Counterparty Risks in Structured Finance methodology"
published in October 2023. Moody's concluded the ratings of the
notes are not constrained by these risks.

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

The rated notes' performance is subject to uncertainty. The notes'
performance is sensitive to the performance of the underlying
portfolio, which in turn depends on economic and credit conditions
that may change.

Additional uncertainty about performance is due to the following:

-- Portfolio amortisation: The main source of uncertainty in this
transaction is the pace of amortisation of the underlying
portfolio, which can vary significantly depending on market
conditions and have a significant impact on the notes' ratings.
Amortisation could accelerate as a consequence of high loan
prepayment levels or collateral sales by the collateral manager or
be delayed by an increase in loan amend-and-extend restructurings.
Fast amortisation would usually benefit the ratings of the notes
beginning with the notes having the highest prepayment priority.

-- Recovery of defaulted assets: Market value fluctuations in
trustee-reported defaulted assets and those Moody's assume have
defaulted can result in volatility in the deal's
over-collateralisation levels. Further, the timing of recoveries
and the manager's decision whether to work out or sell defaulted
assets can also result in additional uncertainty. Moody's Moody's
analysed defaulted recoveries assuming the lower of the market
price or the recovery rate to account for potential volatility in
market prices. Recoveries higher than Moody's expectations would
have a positive impact on the notes' ratings.

In addition to the quantitative factors that Moody's explicitly
modelled, qualitative factors are part of the rating committee's
considerations. These qualitative factors include the structural
protections in the transaction, its recent performance given the
market environment, the legal environment, specific documentation
features, the collateral manager's track record and the potential
for selection bias in the portfolio. All information available to
rating committees, including macroeconomic forecasts, input from
Moody's other analytical groups, market factors, and judgments
regarding the nature and severity of credit stress on the
transactions, can influence the final rating decision.


BLACKROCK SHASTA XIV: S&P Assigns BB- (sf) Rating on Class E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to BlackRock Shasta CLO XIV
LLC's 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 BlackRock Capital Investment Advisors LLC, a
subsidiary of BlackRock.

The ratings reflect:

-- S&P's view of the collateral pool's diversification;

-- 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.

  Ratings Assigned

  BlackRock Shasta CLO XIV LLC

  Class A-1, $158.00 million: AAA (sf)
  Class A-1L loans, $74.00 million: AAA (sf)
  Class A-2, $16.00 million: AAA (sf)
  Class B, $24.0 million: AA (sf)
  Class C (deferrable), $32.00 million: A (sf)
  Class D (deferrable), $24.00 million: BBB- (sf)
  Class E (deferrable), $24.00 million: BB- (sf)
  Subordinated notes, $45.35 million: Not rated



BOCA COMMERCIAL 2024-BOCA: DBRS Gives Prov. BB Rating on HRR Certs
------------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2024-BOCA (the Certificates) to be issued by BOCA Commercial
Mortgage Trust 2024-BOCA (the Trust):

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

All trends are Stable.

The Trust is secured by the borrower's fee-simple interest in a
1,047-key full-service resort and private, members-only Boca Raton
Club. Adjacent to the blue water of the Atlantic Ocean, the luxury
resort is well located in the coastline of Miami-Fort
Lauderdale-West Palm Beach, conceptualizing the allure of a premier
South Florida resort. The Boca Raton Club attracts wealthy family
who relocated to South Florida post pandemic, making the resort one
of the most renowned social occasions for wealthy locals and
individuals nationwide in South Florida. Morningstar DBRS expects
its competitive position to persist given the transformative
capital improvements at the property.

Originally opened as the Ritz-Carlton Cloister Inn in 1926 and
situated on approximately 165 acres, the resort features 1,047
total keys and approximately 120,000 sf of event space. The
property also hosts the Boca Raton Club, with approximately 4,000
active memberships as of May 2024 representing approximately 12,000
individual members. The Club features amenities such as a new Pool
Club along with several F&B venues providing a lazy river, three
pools, a splash pad, a FlowRider, waterslides, separate kids and
teen clubs, cabanas, an event lawn, a poolside F&B experience, and
a rooftop bar and sundeck. The Club's amenities are generally
available to club members and hotel guests, and guests of each. The
Property also features five additional pools, an approximately
50,000 SF spa, an 18-hole golf course, 16 tennis courts, four
pickleball courts, and several retail outlets. Since the sponsor's
acquisition in June 2019, the sponsor committed approximately $378
million (approximately $276 million spent with an additional
approximately $102 million anticipated) in capex to enhance guest
rooms and resort-wide amenities and services. The sponsor's
unwavering commitment to conceptualizing the luxurious South
Florida resort experience has earned the resort various five-star
ratings by the Forbes Travel Guide.

The subject mortgage loan of $1.0 billion will be used to retire
$900 million of existing debt, return $64.6 million of cash equity
to the sponsor, cover $35.2 million of closing costs, and fund an
upfront membership fee refund reserve of $166,000. The loan is a
two-year floating-rate IO mortgage loan, with three one-year
extension options. The floating rate will be based on the one-month
Secured Overnight Financing Rate (SOFR) plus the initial WA
component spread, which is assumed to be 2.90%. The borrower will
be required to enter into an interest rate cap agreement, with a
one-month Term SOFR strike price of 3.00% during the initial term,
and for each extension term, the strike price equal to the greater
of 4.50% and a strike rate that, when added to the spread of each
component, results in a minimum DSCR of 1.10x on the Mortgage Loan,
which as of the date of this report is less than the spot rate.

The sponsor for this transaction is an affiliate of BDT and MSD, a
merchant bank with an advisory and investment platform built to
serve the distinct needs of business owners and strategic,
long-term investors. BDT & MSD was established in 2023 through the
combination of BDT & Company, the merchant bank to the closely
held, founded in 2009 by Byron Trott, and MSD Partners, an
investment firm that since 2009 invested on behalf of Dell
Technologies Founder Michael Dell, his family, and other investors.
The resort is independently flagged and managed by an affiliate of
the sponsor.

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


BRAVO RESIDENTIAL 2024-NQM5: DBRS Assigns B(high) on B2 Notes
-------------------------------------------------------------
DBRS, Inc. finalized its provisional credit ratings on the
following Mortgage-Backed Notes, Series 2024-NQM5 (the Notes)
issued by BRAVO Residential Funding Trust 2024-NQM5 (the Trust) as
follows:

-- $287.3 million Class A-1 at AAA (sf)
-- $26.9 million Class A-2 at AA (high) (sf)
-- $30.6 million Class A-3 at A (high) (sf)
-- $21.9 million Class M-1 at BBB (high) (sf)
-- $12.6 million Class B-1 at BBB (low) (sf)
-- $10.7 million Class B-2 at B (high) (sf)

The AAA (sf) credit rating on the Class A-1 Notes reflects 30.45%
of credit enhancement provided by subordinated Notes. The AA (high)
(sf), A (high) (sf), BBB (high) (sf), BBB (low) (sf), and B (high)
(sf) credit ratings reflect 23.95%, 16.55%, 11.25%, 8.20%, and
5.60% of credit enhancement, respectively.
Other than the specified classes above, Morningstar DBRS does not
rate any other classes in this transaction.

This transaction is a securitization of a portfolio of fixed- and
adjustable-rate prime and non-prime first-lien residential
mortgages funded by the issuance of the Mortgage-Backed Notes. The
Notes are backed by 928 loans with a total principal balance of
approximately $413,084,868 as of the Cut-Off Date (June 30, 2024).
The pool is, on average, four months seasoned with loan ages
ranging from one to 13 months. The primary originators of the
mortgages are Citadel Servicing Corporation doing business as Acra
Lending (Citadel; 47.8%) and ClearEdge Lending LLC (13.7%). The
remaining originators each comprise less than 5% of the mortgage
loans. Citadel will service approximately 71.1% of the mortgage
loans. ServiceMac, LLC (ServiceMac) will subservice all but seven
of the Citadel serviced loans (on behalf of CSC). Morningstar DBRS
did not conduct an operational risk review of ServiceMac for this
transaction. Select Portfolio Servicing, Inc. will service
approximately 20.6% of the mortgage loans and NewRez LLC d/b/a
Shellpoint Mortgage Servicing will service approximately 8.3% of
the mortgage loans.

Nationstar Mortgage LLC (Nationstar) will act as Master Servicer.
Citibank, N.A. (rated AA (low) with a Stable trend by Morningstar
DBRS) will act as Indenture Trustee, Paying Agent, and Owner
Trustee. Computershare Trust Company, N.A. (rated BBB with a Stable
trend by Morningstar DBRS) will act as Custodian.
As of the Cut-Off Date, 98.8% of the loans in the pool are
contractually current according to the Mortgage Bankers Association
(MBA) delinquency calculation method.

In accordance with the Consumer Financial Protection Bureau (CFPB)
Qualified Mortgage (QM) rules, 57.4% of the loans by balance are
designated as non-QM. Approximately 41.5% of the loans in the pool
made to investors for business purposes are exempt from the CFPB
Ability-to-Repay (ATR) and QM rules. Remaining loans subject to the
ATR rules are designated as QM Safe Harbor (0.9%), and QM
Rebuttable Presumption (0.2%) by unpaid principal balance.
There will be no advancing of delinquent principal or interest on
any mortgage loan by the servicers or any other party to the
transaction; however, each servicer is obligated to make advances
in respect of taxes and insurance, the cost of preservation,
restoration, and protection of mortgaged properties and any
enforcement or judicial proceedings, including foreclosures and
reasonable costs and expenses incurred in the course of servicing
and disposing of properties.

The Sponsor or a majority-owned affiliate of the Sponsor will
acquire and intends to retain an eligible horizontal residual
interest consisting of a portion of the Class B-3 Notes and 100% of
the Class XS Notes, collectively representing at least 5.0% of the
aggregate fair value of the Notes (other than the Class SA and
Class R Notes) to satisfy the credit risk-retention requirements
under Section 15G of the Securities Exchange Act of 1934 and the
regulations promulgated thereunder.

The holder of the Trust Certificates may, at its option, on or
after the earlier of (1) the payment date in July 2027 or (2) the
date on which the balance of mortgage loans and real estate owned
properties falls to or below 30% of the loan balance as of the
Cut-Off Date (Optional Redemption Date), redeem the Notes at the
optional termination price described in the transaction documents.
The Depositor, at its option, may purchase any mortgage loan that
is 90 days or more delinquent under the MBA method at the
repurchase price (Optional Purchase) described in the transaction
documents. The total balance of such loans purchased by the
Depositor will not exceed 10% of the Cut-Off Date balance.
Issuer may require the Seller to repurchase loans that become
delinquent in the first three monthly payments following the date
of acquisition. Such loans will be repurchased at the related
repurchase price.

The transaction's cash flow structure is generally similar to that
of other non-QM securitizations. The transaction employs a
sequential-pay cash flow structure with a pro rata principal
distribution among the senior tranches subject to certain
performance triggers related to cumulative losses or delinquencies
exceeding a specified threshold (Credit Event). In the case of a
Credit Event, principal proceeds will be allocated to cover
interest shortfalls on the Class A-1 and then in reduction of the
Class A-1 note balance, before a similar allocation of funds to the
Class A-2 (IPIP). For the Class A-3 Notes (only after a Credit
Event) and for the mezzanine and subordinate classes of notes (both
before and after a Credit Event), principal proceeds will be
available to cover interest shortfalls only after the more senior
notes have been paid off in full. Also, the excess spread can be
used to cover realized losses first before being allocated to
unpaid Cap Carryover Amounts due to Classes A-1, A-2, A-3, M-1 and
B-1.

Of note, the Class A-1, A-2, and A-3 Notes coupon rates step up by
100 basis points on and after the payment date in August 2028.
Interest and principal otherwise payable to the Class B-3 Notes as
accrued and unpaid interest may be used to pay the Class A-1, A-2,
and A-3 Notes Cap Carryover Amounts after the Class A coupons step
up.

Morningstar DBRS' credit ratings on the Notes address the credit
risk associated with the identified financial obligations in
accordance with the relevant transaction documents. The associated
financial obligations for each of the rated Notes are the related
Current Interest, Interest Carryforward Amount, and the related
Note Amount.

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


CEDAR FUNDING VII: S&P Affirms 'B- (sf)' Rating on Class F Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R, B-R, C-R,
and D-R replacement debt from Cedar Funding VII CLO Ltd./Cedar
Funding VII CLO LLC, a CLO originally issued in March 2018 that is
managed by Aegon USA Investment Management LLC, an affiliate of
Aegon Asset Management. At the same time, S&P withdrew its ratings
on the original class A-1, B, C, and D debt following payment in
full on the Aug. 16, 2024, refinancing date. S&P also affirmed its
ratings on the class E and F debt, which were not refinanced.

The replacement debt was issued via a supplemental indenture, which
outlines the terms of the replacement debt. According to the
supplemental indenture:

-- The non-call period was extended to Feb. 16, 2025.

-- No additional assets were purchased on the Aug. 16, 2024
refinancing date, and the first payment date following the
refinancing is in Oct. 20, 2024.

-- No additional subordinated notes were issued on the refinancing
date.

-- The existing class A-1 A-2 notes were combined into the new
class A-R notes.

S&P said, "On a standalone basis, our cash flow analysis indicated
a lower rating on the class F debt (which was not refinanced) than
the rating action on the debt reflects. However, we affirmed our
'B- (sf)' rating on the class F debt after considering the margin
of failure, the relatively stable overcollateralization ratio since
our last rating action on the transaction, and that the transaction
is in its amortizing phase. Based on the latter, we expect the
credit support available to all rated classes to increase as
principal is collected and the senior debt is paid down. In
addition, we believe the payment of principal or interest on the
class F debt when due does not depend on favorable business,
financial, or economic conditions. Therefore, this class does not
fit our definition of 'CCC' risk in accordance with our guidance
criteria."

Replacement And Original Debt Issuances

Replacement debt

-- Class A-R, $231.85 million: Three-month CME term SOFR + 1.08%

-- Class B-R, $65.00 million: Three-month CME term SOFR + 1.55%

-- Class C-R (deferrable), $30.00 million: Three-month CME term
SOFR + 1.80%

-- Class D-R (deferrable), $25.00 million: Three-month CME term
SOFR + 2.75%

Original debt

-- Class A-1, $214.35 million: Three-month CME term SOFR + 1.00% +
CSA(i)

-- Class A-2, $17.50 million: Three-month CME term SOFR + 1.15% +
CSA(i)

-- Class B, $65.00 million: Three-month CME term SOFR + 1.40% +
CSA(i)

-- Class C (deferrable), $30.00 million: Three-month CME term SOFR
+ 1.75% + CSA(i)

-- Class D (deferrable), $25.00 million: Three-month CME term SOFR
+ 2.55% + CSA(i)

(i)The CSA is 0.26161%.
CSA--Credit spread adjustment.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis (and other qualitative factors, as applicable)
demonstrated, in our view, that the outstanding rated classes all
have adequate credit enhancement available at the rating levels
associated with the rating actions

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Ratings Assigned

  Cedar Funding VII CLO Ltd./Cedar Funding VII CLO LLC

  Class A-R, $231.85 million: AAA (sf)
  Class B-R, $65.00 million: AA (sf)
  Class C-R (deferrable), $30.00 million: A (sf)
  Class D-R (deferrable), $25.00 million: BBB- (sf)

  Ratings Withdrawn

  Cedar Funding VII CLO Ltd./Cedar Funding VII CLO LLC

  Class A-1 to NR from 'AAA (sf)'
  Class B to NR from 'AA (sf)'
  Class C to NR from 'A (sf)'
  Class D to NR from 'BBB- (sf)'

  Ratings Affirmed

  Cedar Funding VII CLO Ltd./Cedar Funding VII CLO LLC

  Class E: 'BB- (sf)'
  Class F: 'B- (sf)'

  Other Debt

  Cedar Funding VII CLO Ltd./Cedar Funding VII CLO LLC

  Subordinated notes, $41.75 million: NR

  NR--Not rated.



CHASE HOME 2024-DRT1: Fitch Assigns 'BB-(EXP)sf' Rating on B-5 Debt
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Chase Home Lending Mortgage Trust 2024-DRT1 (Chase 2024-DRT1).

   Entity/Debt        Rating           
   -----------        ------           
Chase 2024-DRT1

   A-1            LT NR(EXP)sf  Expected Rating
   A-2            LT AAA(EXP)sf Expected Rating
   A-2-A          LT AAA(EXP)sf Expected Rating
   A-2-X          LT AAA(EXP)sf Expected Rating
   B-1            LT AA(EXP)sf  Expected Rating
   B-2            LT A(EXP)sf   Expected Rating
   B-3            LT BBB(EXP)sf Expected Rating
   B-4            LT BB(EXP)sf  Expected Rating
   B-5            LT BB-(EXP)sf Expected Rating
   B-6            LT NR(EXP)sf  Expected Rating
   B-6-X          LT NR(EXP)sf  Expected Rating

Transaction Summary

The Chase 2024-DRT1 notes are supported by 455 loans with a total
balance of approximately $523.52 million as of the cutoff date.

The pool entirely consists of prime-quality hybrid adjustable-rate
mortgages (ARMs). All of the loans were originated by JPMorgan
Chase Bank, National Association (JPMCB). The loan-level
representations (reps) and warranties (R&Ws) are provided by the
main originator, JPMCB. All mortgage loans in the pool will be
serviced by JPMCB. The collateral quality of the pool is extremely
strong, with a large percentage of loans over $1.0 million.

Of the loans, 100.0% qualify as safe-harbor qualified mortgage
(SHQM) average prime offer rate (APOR) loans. There is no exposure
to Libor in this transaction. The collateral comprises 100%
adjustable-rate loans that are based on the SOFR index rate. The
notes are fixed rate and capped at the net weighted average coupon
(WAC), or are based on the net WAC; as a result, the notes have no
Libor exposure.

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 11.2% above a long-term sustainable level (vs.
11.5% on a national level as of 1Q24, up 0.4% since last quarter.
Housing affordability is the worst it has been in decades driven by
both high interest rates and elevated home prices. Home prices have
increased 5.9% YoY nationally as of May 2024 despite modest
regional declines, but are still being supported by limited
inventory.

High-Quality Prime Mortgage Pool (Positive): The pool consists of
455 high-quality, hybrid adjustable-rate, fully amortizing loans
with maturities of 30 years that total $523.52 million. In total,
100.0% of the loans qualify as SHQM APOR. The loans were made to
borrowers with strong credit profiles, relatively low leverage and
large liquid reserves.

The loans are seasoned at an average of 13.3 months, according to
Fitch. The pool has a weighted average (WA) FICO score of 776, as
determined by Fitch, and is based on the original FICO for newly
originated loans and the updated FICO for loans seasoned at 12
months or more, which is indicative of very high credit-quality
borrowers. A large percentage of the loans have a borrower with a
Fitch-derived FICO score equal to or above 750. Fitch determined
that 84.2% of the loans have a borrower with a Fitch-determined
FICO score equal to or above 750. Based on Fitch's analysis of the
pool, the original WA combined loan-to-value (CLTV) ratio is 75.4%,
which translates to a sustainable loan-to-value (sLTV) ratio of
78.9%. This represents moderate borrower equity in the property and
reduced default risk compared to a borrower with a CLTV over 80%.

Of the pool, 100.0% of the loans are designated as qualified
mortgage (QM) loans.

All the loans in the pool are adjustable-rate loans. To reflect the
additional risk that is present in adjustable-rate loans due to
payment shock, Fitch increased its probability of default (PD) by
1.11x.

The borrower maintains a primary or secondary residence for all the
pool loans. Single-family homes and planned unit developments
(PUDs) constitute 90.9% of the pool, while condominiums make up
8.2% and co-ops, 0.9%. Fitch viewed the fact that there are no
investor loans favorably.

The pool consists of loans with the following loan purposes, as
determined by Fitch: purchases (94.8%), cashout refinances (1.6%)
and rate-term refinances (3.6%). Fitch views favorably that no
loans are for investment properties and a majority of mortgages are
purchases.

Of the pool loans, 32.2% are concentrated in California, followed
by Washington and Colorado. The largest MSA concentration is in the
San Francisco MSA (7.9%), followed by the Seattle MSA (7.9%) and
the Los Angeles MSA (7.7%). The top three MSAs account for 23.5% of
the pool. As a result, no probability of default (PD) penalty was
applied for geographic concentration.

Pro-Rata Structure with Triggers and Subordination Floors (Mixed):
The mortgage cash flow allocations are based on available funds and
allocated to the senior classes first, and then to the subordinate
classes. The transaction is an IPIP structure where interest is
paid to the senior classes, and then principal; then the
subordinate classes are paid interest, and then principal
sequentially, starting with class B-1.

Principal is allocated among the senior and subordinate classes,
based on the senior/subordinate principal amounts (pro-rata
allocation). Performance triggers are in place to re-prioritize
unscheduled principal to the senior classes, as well as a lock-out
feature that re-allocates principal from a more junior class to pay
a more senior class until performance improves and the trigger is
no longer breached. The triggers are supportive of maintaining
credit enhancement and paying off more senior classes when the
transaction experiences performance issues.

The transaction will have a senior subordination floor of 0.90% and
a junior subordination floor of 0.55%.

Realized losses will be allocated reverse sequentially starting
with class B-6. Once all the subordinate classes are written off,
the senior classes will be allocated losses starting with the A-2-A
notes and then to the A-1 loans.

No Advancing of Delinquent P&I (Mixed): The servicer, JPMCB, will
not advance delinquent principal and interest (P&I) payments on
behalf of the loans. Not having full advancing will reduce the
loan-level loss severity (LS) compared to a similar transaction
with full advancing of delinquent (DQ) P&I payments, as the
servicer will not need to be reimbursed for DQ P&I advances from
liquidation proceeds (allowing more funds to flow to the notes).
However, the credit enhancement (CE) will be increased, as
principal will need to be used to pay interest to cover loans that
are DQ in an effort to provide liquidity to the transaction. The
transaction's structure prioritizes the payment of interest to the
'AAAsf' rated senior classes, which is supportive of these classes
receiving timely interest.

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 analyses was conducted at the
state and national levels to assess the effect of higher MVDs for
the subject pool as well as lower MVDs, illustrated by a gain in
home prices.

This defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10.0%, 20.0% and 30.0% in addition to the
model-projected 42.3% 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 analyses was conducted at the state and national levels
to assess the effect of higher MVDs for the subject pool as well as
lower MVDs, illustrated by a gain in home prices.

This 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 being assigned
ratings of 'AAAsf'.

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Digital Risk. The third-party due diligence described
in Form 15E focused on four areas: compliance review, credit
review, valuation review and data integrity. Fitch considered this
information in its analysis and, as a result, Fitch decreased its
loss expectations by 0.15% at the 'AAAsf' stress due to 100.0% due
diligence with no material findings.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100.0% of the pool. The third-party due diligence was
generally consistent with Fitch's "U.S. RMBS Rating Criteria."
Digital Risk was engaged to perform the review. Loans reviewed
under this engagement were given compliance, credit and valuation
grades and assigned initial grades for each subcategory. Minimal
exceptions and waivers were noted in the due diligence reports.
Refer to the "Third-Party Due Diligence" section for more detail.

Fitch also utilized data files provided by the issuer on its SEC
Rule 17g-5 designated website. Fitch received loan level
information based on the ResiPLS data layout format, and the data
provided was considered comprehensive. The data contained in the
ResiPLS layout data tape were reviewed by the due diligence
companies, and no material discrepancies were noted.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


CIFC FUNDING 2021-IV: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
-------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to CIFC
Funding 2021-IV, Ltd. reset transaction.

   Entity/Debt        Rating           
   -----------        ------           
CIFC Funding
2021-IV, Ltd.

   X-R            LT AAAsf  New Rating
   A-R            LT AAAsf  New Rating
   B-R            LT AAsf   New Rating
   C-R            LT Asf    New Rating
   D-R            LT BBB-sf New Rating
   E-R            LT BB-sf  New Rating
   Subordinated   LT NRsf   New Rating

Transaction Summary

CIFC Funding 2021-IV, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by CIFC
Asset Management LLC which originally closed in June 2021. The
CLO's secured notes will be refinanced on Aug. 9, 2024 from
proceeds of the new secured notes. Net proceeds from the issuance
of the secured and subordinated notes will provide financing on a
portfolio of approximately $600 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', which is in line with that of recent
CLOs. The weighted average rating factor (WARF) of the indicative
portfolio is 23.7, versus a maximum covenant, in accordance with
the initial expected matrix point of 26. 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
95.24% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 74.2% versus a
minimum covenant, in accordance with the initial expected matrix
point of 71.7%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 45% 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 resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

Portfolio Management (Neutral): The transaction has a five-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting 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, the rated notes can
withstand default and recovery assumptions consistent with their
assigned ratings.

The WAL used for the transaction stress portfolio and matrices
analysis is 12 months less than the WAL covenant to account for
structural and reinvestment conditions after the reinvestment
period. In Fitch's opinion, these conditions would reduce the
effective risk horizon of the portfolio during stress periods.

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 as
severe as between 'BBB+sf' and 'AA+sf' for class A-R, between
'BB+sf' and 'A+sf' for class B-R, between 'B+sf' and 'BBB+sf' for
class C-R, between less than 'B-sf' and 'BB+sf' for class D-R, and
between less than 'B-sf' and 'B+sf' for class E-R.

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

Upgrade scenarios are not applicable to the class X-R and class A-R
notes as these notes are in the highest rating category of
'AAAsf'.

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; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B-R, 'AAsf' for class C-R, 'Asf'
for class D-R, and 'BBB+sf' for class E-R.

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

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

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 its rating analysis according to its applicable rating
methodologies indicates that it is adequately reliable.

ESG Considerations

Fitch does not provide ESG relevance scores for CIFC Funding
2021-IV, Ltd. In cases where Fitch does not provide ESG relevance
scores in connection with the credit rating of a transaction,
program, instrument or issuer, Fitch will disclose in the key
rating drivers any ESG factor which has a significant impact on the
rating on an individual basis.


COLT 2024-INV3: S&P Assigns B (sf) Rating on Class B-2 Certs
------------------------------------------------------------
S&P Global Ratings assigned its ratings to COLT 2024-INV3 Mortgage
Loan Trust's mortgage-backed certificates.

The certificate issuance is an RMBS transaction backed by 865
first-lien, fixed- and adjustable-rate, fully amortizing,
ability-to-repay-exempt, business-purpose investment property
residential mortgage loans to prime and nonprime borrowers (some
with interest-only periods). The loans are secured by single-family
residential properties, planned-unit developments, condominiums,
townhomes, two- to four-family residential properties, and
condotels.

The ratings reflect S&P's view of:

-- The pool's collateral composition;

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

-- The mortgage aggregator and reviewed originators; and

-- The potential impact current and near-term macroeconomic
conditions may have on the performance of the mortgage borrowers in
the pool. S&P said, "Per our latest update ("A Cooling U.S. Labor
Market Sets Up A September Start For Rate Cuts," published Aug. 6,
2024) to our third-quarter macroeconomic outlook ("Economic Outlook
U.S. Q3 2024: Milder Growth Ahead," published June 24, 2024), we
have recalibrated our views on the trajectory of interest rates in
the U.S. We now expect 50 basis points (bps) of rate cuts coming
this year and another 100 bps of cuts coming next year, with the
balance of risks tilting toward more of those cuts happening sooner
rather than later. Our base-case forecast for GDP growth and
inflation have not changed, and we attribute the recent loosening
of the labor market to normalization, not to an economy that's
about to slip into a recession. A soft landing remains the most
likely scenario, at least into 2025. We therefore maintain our
current market outlook as it relates to the 'B' projected
archetypal foreclosure frequency of 2.50%, which reflects our
benign view of the mortgage and housing market as demonstrated
through general national-level home price behavior, unemployment
rates, mortgage performance, and underwriting.
Since issuing our preliminary ratings on Aug. 12, 2024, we
incorporated updated loan-level information into our analysis,
including two dropped loans, updated loan balances, as well as loan
status as of the cutoff date. Bond sizes were subsequently adjusted
to reflect the lower pool balance, with the credit enhancement
unchanged for each class. The loss coverage estimates and final
ratings assigned are unchanged from the preliminary ratings we
assigned for all classes."

  Ratings Assigned(i)

  COLT 2024-INV3 Mortgage Loan Trust

  Class A-1, $145,776,000: AAA (sf)
  Class A-2, $13,612,000: AA (sf)
  Class A-3, $24,369,000: A (sf)
  Class M-1, $13,721,000: BBB (sf)
  Class B-1, $9,660,000: BB (sf)
  Class B-2, $7,684,000: B (sf)
  Class B-3, $4,720,952: NR
  Class A-IO-S, notional(ii): NR
  Class X, notional(ii): NR
  Class R, not applicable: NR

(i)The ratings address the ultimate payment of interest and
principal. They do not address payment of the cap carryover
amounts.
(ii)The notional amount will equal the aggregate principal balance
of the mortgage loans as of the first day of the related due
period.
NR--Not rated.



COMM 2016-667M: S&P Affirms B (sf) Rating on Class E Certs
----------------------------------------------------------
S&P Global Ratings lowered its ratings on five classes of
commercial mortgage pass-through certificates from COMM 2016-667M
Mortgage Trust, a U.S. CMBS transaction. At the same time, we
affirmed our rating on the class E certificates from the
transaction.

This is a U.S. standalone (single-borrower) CMBS transaction that
is backed by a portion of a 10-year, fixed-rate, interest-only (IO)
mortgage whole loan secured by the borrower's fee simple interest
in a 1985-built, 25-story, 273,983-sq.-ft. class A boutique office
building with ground floor and basement retail space at 667 Madison
Avenue in Midtown Manhattan's Plaza District office submarket.

Rating Actions

The downgrades on classes A, B, C, and D, and the affirmation on
class E primarily reflect that:

-- S&P said, "While the sponsor was able to increase
occupancy--which we expect after adjusting the July 2024 rent roll
for known tenant movements--to 84.2% by year-end 2024, from 79.6%
in our last review in April 2024, we assessed that the property's
net cash flow (NCF) will likely not return to historical levels.
This is generally due to in-place gross rent per sq. ft. that are,
on average, below our expectations."

-- S&P said, "Our expected-case valuation, while unchanged from
our last review, is 15.0% lower than the value we derived at
issuance.

-- S&P lowered its rating on the class X-A IO certificates based
on its 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-A references class
A.

-- S&P will continue to monitor the tenancy and performance of the
property and the loan. If S&P receives information that differs
materially from its expectations, it may revisit its analysis and
take additional rating actions as S7 determine necessary.

Property-Level Analysis Updates

S&P said, "In our April 2024 review, we noted that the property's
occupancy dropped below 80.0%, primarily due to the departure of
Loews Corp. (15.5% of net rentable area [NRA]) in second-quarter
2023. At that time, based on CoStar's projected submarket vacancy
rates in 2025 through 2027, we assumed a 17.5% vacancy rate, a
$162.65 per sq. ft. S&P Global Ratings' gross rent, and a 45.8%
operating expense ratio, to arrive at an S&P Global Ratings'
long-term sustainable NCF of $17.6 million. Using a 6.25% S&P
Global Ratings' capitalization rate, we derived an S&P Global
Ratings' expected-case value of $281.9 million, or $1,029 per sq.
ft..

"After adjusting the July 11, 2024, rent roll for known tenant
movements, we expect the property's occupancy to increase to 84.2%
by year-end 2024, which is generally in line with our April 2024
review and CoStar's current office submarket vacancy (14.2%) and
availability (15.0%) rates as of year-to-date August 2024. While
the in-place gross rent of $156.63 per sq. ft., as calculated by
S&P Global Ratings, is significantly higher than the submarket
asking rent for 4- and 5-star office properties of $96.56 per sq.
ft. (according to CoStar, as of year-to-date August 2024), it has
declined from our assumed $162.65 per sq. ft. in our last review
and $179.85 per sq. ft. at issuance. Specifically, based on the
July 2024 rent roll, the assumed average gross rent for the retail
space fell 35.7% to $430.78 per sq. ft. from $670.36 per sq. ft. at
issuance, while for the occupied office space, it dropped modestly
to $140.92 per sq. ft. from $148.80 per sq. ft.

"The servicer reported a NCF for year-end 2023 of $8.2 million
(corresponding debt service coverage of 1.00x), which we expect
would increase once free rent periods burn off for new and renewing
tenants (totaling 31.6% of NRA)--including Redbird Capital Partners
Management LLC, which received six months of free rent, fully moves
in, and pays rent on its expanded space (totaling 15.7% of NRA) in
November 2024--and repairs and maintenance (R&M) expenses
normalize. According to the master servicer, KeyBank Real Estate
Capital, the $5.6 million R&M amount reported in 2023--versus, on
average, $2.6 million from 2019 to 2022--included
tenant-improvement costs for new and renewing tenants.

"In our current analysis, assuming a 15.8% vacancy rate, a $156.63
per sq. ft. S&P Global Ratings' in place gross rent, and a 46.5%
operating expense ratio, we arrived at a NCF of $17.6 million, the
same as in our last review and 8.8% lower than our issuance "as-is"
NCF of $19.3 million. Utilizing a S&P Global Ratings'
capitalization rate of 6.25%, we derived an S&P Global Ratings'
expected-case value of $281.9 million, or $1,029 per sq. ft.,
unchanged from our last review, and 15.0% and 61.9% below our
issuance value of $331.8 million, and issuance appraised value of
$740.0 million, respectively. This yielded an S&P Global Ratings'
loan-to-value ratio of 90.1% on the whole loan balance of $254.0
million."

  Ratings Lowered

  COMM 2016-667M Mortgage Trust

  Class A to 'AA- (sf)' from 'AAA (sf)'
  Class B to 'BBB+ (sf)' from 'A+ (sf)'
  Class C to 'BB+ (sf)' from 'BBB (sf)'
  Class D to 'B+ (sf)' from 'BB (sf)'
  Class X-A to 'AA- (sf)' from 'AAA (sf)'

  Rating Affirmed

  COMM 2016-667M Mortgage Trust

  Class E: B (sf)



CROCKETT PARTNERS IIA: DBRS Finalizes BB Rating on C Notes
----------------------------------------------------------
DBRS, Inc. finalized its provisional credit ratings on the
following classes of notes issued by Crockett Partners Equipment
Company IIA LLC (the Issuer):

-- $368,830,000 Class A Notes at A (sf)
-- $18,840,000 Class B Notes at BBB (sf)
-- $17,950,000 Class C Notes at BB (sf)

CREDIT RATING RATIONALE/DESCRIPTION

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

-- The issuance of the Notes represents the inaugural asset-backed
security (ABS) issuance of equipment managed by EQS. The ratings
address payment of timely interest and ultimate principal.

-- The transaction capital structure, credit ratings, and form and
sufficiency of available credit enhancement.

-- The Notes benefit from credit enhancement consisting of
overcollateralization, subordination, and cash reserves. A cash
reserve account established for the transaction and sized at four
months' of interest plus fees and expenses is meant to ensure that
an appropriate amount of senior expense and interest can be covered
during the assumed liquidation period.

-- The collateral quality and historical value volatility
performance.

-- Morningstar DBRS conducted an operational risk review of EQS
and, as a result, considers the company to be an acceptable
Equipment Manager and Servicer.

-- Borrowing Base Test: The Aggregate Portfolio Value (APV) will
be the lower of the equipment's aggregate net orderly liquidation
value (NOLV) and the its aggregate net book value (NBV), calculated
on a monthly basis. If the APV is less than the aggregate Note
balance divided by 82.78%, then one or more cures would need to be
applied to keep the borrowing base in compliance.

-- Consideration of increased depreciation rate (versus historical
experience) in the transaction that provides for accelerated
paydown of Notes in the context of the relationship between
decreasing note balances and aggregate NBV.

-- Consideration of the relatively young age of the equipment.
Generally, younger equipment would be expected to produce somewhat
higher sales proceeds, a credit positive with respect to the
subject portfolio.

-- Consideration of monthly dynamic adjustment provisions,
specifically (1) inclusion of updated disposition expense estimates
in monthly appraisals, (2) inclusion of updated expense estimates
in calculation of the reserve account requirement, and (3)
inclusion of updated equipment values vis-à-vis book value.

-- The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary "Baseline Macroeconomic Scenarios For Rated
Sovereigns June 2024 Update," published on June 28, 2024. These
baseline macroeconomic scenarios replace Morningstar DBRS' moderate
and adverse COVID-19 pandemic scenarios, which were first published
in April 2020.

-- Specific proceeds haircuts on equipment built by non-investment
grade manufacturers were not applied since (1) the historical data
used covered the industry as a whole and (2) construction equipment
brands are fairly well known and values are less driven by credit
quality of the manufacturer. Notwithstanding the foregoing, a large
proportion of the portfolio was built by investment grade
manufacturers.

-- Morningstar DBRS materially deviated from its principal
methodology when determining the ratings assigned to the Notes by
adjusting certain cash flow assumptions to better align them with
the rental equipment assets being securitized. These adjustments,
and the resulting material deviation are warranted given the unique
aspects of the transaction, the adequacy and analysis of historical
data from reliable sources specific to the industry, similarity of
the equipment rental space vis-à-vis the car rental space, and
comparable transaction legal structure.

-- The legal structure and its consistency with Morningstar DBRS'
Legal Criteria for U.S. Structured Finance methodology, the
provision of legal opinions that address the treatment of the
operating lease as a true lease, a true sale, the non-consolidation
of the special-purpose vehicles (SPVs) with Crockett Partners
Equipment Company II LLC and its affiliates, and that the Issuer
has a valid first-priority security interest in the assets.

Morningstar DBRS' credit ratings on the Class A Notes, Class B
Notes, and Class C Notes address the credit risk associated with
the identified financial obligations in accordance with the
relevant transaction documents. The associated financial
obligations are interest on the associated note balance of each of
the Class A Notes, Class B Notes, and Class C Notes, and the note
balance of the Class A Notes, Class B Notes, and Class C Notes.

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


CROTON PARK: S&P Assigns Prelim BB- (sf) Rating on Class E Debts
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Croton Park
CLO Ltd./Croton Park CLO LLC's floating-rate debt.

The debt 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 Blackstone Liquid Credit Strategies
LLC.

The preliminary ratings are based on information as of Aug. 20,
2024. 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

  Croton Park CLO Ltd./Croton Park CLO LLC

  Class A-1, $307.50 million: AAA (sf)
  Class A-2, $27.50 million: Not rated
  Class B, $45.00 million: AA (sf)
  Class C (deferrable), $30.00 million: A (sf)
  Class D-1 (deferrable), $30.00 million: BBB- (sf)
  Class D-2 (deferrable), $3.75 million: BBB- (sf)
  Class E (deferrable), $16.25 million: BB- (sf)
  Subordinated notes, $48.10 million: Not rated



DRYDEN 76: S&P Assigs Prelim BB- (sf) Rating on Class E-R2 Notes
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1-R2, A-2-R2, B-R2, C-R2, D-1-R2, D-2-R2 and E-R2 replacement
debt from Dryden 76 CLO Ltd./Dryden 76 CLO LLC, a CLO first
refinanced in November 2021 and originally issued in October 2019.
The transaction is managed by PGIM Inc.

The preliminary ratings are based on information as of Aug. 21,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Aug. 28, 2024, refinancing date, the proceeds from the
replacement debt will be used to redeem the existing debt. At that
time, S&P expects to withdraw its ratings on the existing debt and
assign ratings to the replacement debt. However, if the refinancing
doesn't occur, S&P may affirm its ratings on the existing debt and
withdraw its preliminary ratings on the replacement debt.

The replacement debt will be issued via a supplemental indenture,
which outlines the terms of the replacement debt. According to the
proposed supplemental indenture:

-- The replacement class A-1-R2, A-2-R2, B-R2, C-R2, D-1-R2,
D-2-R2 and E-R2 notes are expected to be issued at floating
spreads, replacing the current floating spreads.

-- The stated maturity will be extended to October 2037.

-- The reinvestment period will be extended to October 2029.

-- The non-call period will be extended to August 2026.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults, and
recoveries upon default, under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Preliminary Ratings Assigned

  Dryden 76 CLO Ltd./Dryden 76 CLO LLC

  Class A-1-R2, $256.00 million: AAA (sf)
  Class A-2-R2, $4.00 million: AAA (sf)
  Class B-R2, $44.00 million: AA (sf)
  Class C-R2 (deferrable), $24.00 million: A (sf)
  Class D-1-R2 (deferrable), $20.00 million: BBB (sf)
  Class D-2-R2 (deferrable), $8.00 million: BBB- (sf)
  Class E-R2 (deferrable), $12.00: BB- (sf)
  Subordinated notes, $64.80 million: Not rated



ELMWOOD CLO 18: S&P Assigns B- (sf) Rating on Class F-RR Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-RR, B-RR,
C-RR, D-1-RR, D-2-RR, E-RR, and F-RR replacement debt from Elmwood
CLO 18 Ltd./Elmwood CLO 18 LLC, a CLO managed by Elmwood Asset
Management LLC that was originally issued in July 2022 and
underwent a refinancing in August 2023. At that time, S&P withdrew
its ratings on the class A-R, B, C-R, D, E-R, and F-R following
payment in full on the Aug. 16, 2024, refinancing date.

The replacement debt was issued via a supplemental indenture, which
outlines the terms of the replacement debt. According to the
supplemental indenture:

-- The replacement class A-RR, B-RR, C-RR, and E-RR debt was
issued at a lower spread over three-month CME term SOFR than the
existing debt.

-- The existing class D debt were replaced by two new classes:
D-1-RR and D-2-RR.

-- The replacement class F-RR debt was issued at a higher spread
over three-month CME term SOFR than the existing class F-R debt.

-- The reinvestment period was extended to July 17, 2029, from
July 17, 2025.

-- The non-call period was extended to July 17, 2026, from July
17, 2023.

-- The stated maturity on the existing subordinated notes was
extended to July 17, 2037, from July 17, 2033, to match the stated
maturity on the new refinancing debt.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults, and
recoveries upon default, under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Ratings Assigned

  Elmwood CLO 18 Ltd./Elmwood CLO 18 LLC

  Class A-RR, $320.00 million: AAA (sf)
  Class B-RR, $60.00 million: AA (sf)
  Class C-RR (deferrable), $30.00 million: A (sf)
  Class D-1-RR (deferrable), $30.00 million: BBB- (sf)
  Class D-2-RR (deferrable), $5.00 million: BBB- (sf)
  Class E-RR (deferrable), $15.00 million: BB- (sf)
  Class F-RR (deferrable), $7.50 million: B- (sf)

  Ratings Withdrawn

  Elmwood CLO 18 Ltd./Elmwood CLO 18 LLC

  Class A-R to NR from 'AAA (sf)'
  Class B to NR from 'AA (sf)'
  Class C-R to NR from 'A (sf)'
  Class D to NR from 'BBB- (sf)'
  Class E-R to NR from 'BB- (sf)'
  Class F-R to NR from 'B- (sf)'

  Other Debt

  Elmwood CLO 18 Ltd./Elmwood CLO 18 LLC
  Subordinated notes, $42.00 million: NR

  NR--Not rated.



FALCON 2019-1: Fitch Affirms 'Bsf' Rating on Series B Notes
-----------------------------------------------------------
Fitch Ratings has affirmed the ratings of Kestrel Aircraft Funding
Limited's A and B notes at 'BBBsf' and 'BBsf', respectively, with
Stable Rating Outlooks. Fitch also affirmed Falcon 2019-1 Aerospace
Limited's A, B, and C notes at 'BBBsf', 'Bsf', and 'CCCsf'
respectively, with Stable Outlooks for the A and B notes.

The ratings reflect current transaction performance, Fitch's cash
flow projections, and its expectation for the structures to
withstand rating-specific stresses under Fitch's criteria and
related asset model. Rating considerations include lease terms,
lessee credit quality and performance, updated aircraft values, and
Fitch's assumptions and stresses, which inform Fitch's modeled cash
flows and coverage levels.

   Entity/Debt              Rating           Prior
   -----------              ------           -----
Falcon 2019-1
Aerospace Limited

   Series A 30610GAA1   LT BBBsf  Affirmed   BBBsf
   Series B 30610GAB9   LT Bsf    Affirmed   Bsf
   Series C 30610GAC7   LT CCCsf  Affirmed   CCCsf

Kestrel Aircraft
Funding Limited

   A 49255PAA1          LT BBBsf  Affirmed   BBBsf
   B 49255PAB9          LT BBsf   Affirmed   BBsf

Transaction Summary

Portfolio performance has been stable for both Kestrel and Falcon.
The aircraft are 100% utilized and all lessees are current in both
transactions. Year-over-year rental collection trends in both
transactions have remained in line with Fitch's expectations.

Since the last review, Kestrel has made consistent principal
payments to the class A notes, supported by three asset sales and
stable rent collections. The class B notes have started receiving
principal with three payments over the past 12 months, driven by
asset sales and cure of the early amortization trigger. The class A
notes are 2% behind scheduled principal, and the class B notes are
40% behind. For Falcon 2019-1, the class A notes are ahead of
scheduled principal. The class B notes have not received principal
since September 2021, while the class C notes have not received
principal since August 2020 and continue to defer interest.

Overall market recovery: Demand for air travel remains robust.
Total passenger traffic is above 2019 levels with June revenue
passenger kilometers (RPKs) up 9.1% compared to June 2023, per the
International Air Transport Association (IATA). International
traffic led the way with 12.3% you RPK growth while domestic
traffic grew 4.3% yoy. Asia Pacific led overall growth in traffic.

Macro Risks: While the commercial aviation market has recovered
significantly over the past 12 months, it will continue to face
potential risks, including workforce shortages, supply chain
issues, geopolitical risks, and recessionary concerns that would
impact passenger demand. Most of these events would lead to greater
credit risk due to increased lessee delinquencies, lease
restructurings, defaults, and reductions in lease rates and asset
values, particularly for older aircraft, all of which would cause
downward pressure on future cash flows needed to meet debt
service.

KEY RATING DRIVERS

Asset Values:

The aircraft in the DAE transactions are generally late mid-life
with a weighted-average age (by value) of 14 and 16 years for
Kestrel and Falcon, respectively. Kestrel's maintenance reserve
account is funded at approximately 77% of target. Falcon's senior
maintenance reserve account is fully funded; the junior maintenance
reserve account is unfunded.

Using the Fitch Value, the loan-to-value for each of the notes has
changed since its August 2023 review as follows:

- Kestrel: A note 63% to 62%; B note 85% to 78%

- Falcon 2019-1: A note 72% to 66%; B note 92% to 88%; C note 106%
to 104%

In determining the Fitch Value of each pool, Fitch used the most
recent appraisals as of June 2024. Fitch employs a methodology
whereby Fitch varies the type of value per aircraft based on the
remaining leasable life:

- Less than three years of leasable life: Maintenance-adjusted
market value;

- More than three years of leasable life but more than 15 years
old: Maintenance-adjusted base value;

- Less than 15 years old: Half-life base value.

Fitch then uses an LMM (lesser of mean and median) of the given
value. The current Fitch Value for each of the transactions is as
follows:

- Kestrel: $239.7 million

- Falcon 2019-1: $223.1 million

Tiered Collateral Quality:

Fitch utilizes three tiers when assessing the desirability and
therefore the liquidity of aircraft collateral: Tier 1 which is the
most liquid and Tier 3 which is the least liquid. As aircraft in
the pool reach an age of 15 and then 20 years, pursuant to Fitch's
criteria, the aircraft tier will migrate one level lower.
Additional detail regarding Fitch's tiering methodology can be
found here.

The weighted average age and tier for each of the transactions is
as follows:

- Kestrel: Age: 14 years; Tier: 1.5

- Falcon 2019-1: Age: 16; Tier: 2.1

Pool Concentration:

The subject pools have a moderate concentration profile with
Kestrel having 14 aircraft on lease to 12 lessees and Falcon 2019-1
having 15 aircraft on lease to 13 lessees. As the pool ages and
Fitch models aircraft being sold at the end of their leasable lives
(generally 20 years), pool concentration will continue to increase.
Pursuant to Fitch's criteria, Fitch stresses cash flows based on
the effective aircraft count. Concentration haircuts which vary by
rating level are only applied at stresses higher than 'CCCsf'.

Lessee Credit Risk:

Fitch considers the credit risk posed by the pool of lessees as
moderate. Delinquencies have improved, with all lessees current in
both transactions.

Operation and Servicing Risk:

Fitch deems the servicer, Dubai Aerospace Enterprise (DAE) Ltd., to
be qualified based on its experience as a lessor, overall servicing
capabilities and ABS performance to date. Fitch rates DAE
'BBB'/Stable.

RATING SENSITIVITIES

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

An increase in delinquencies, lower lease rates, or sales of
aircraft below Fitch's projections could lead to a downgrade.

The aircraft ABS sector has a rating cap of 'Asf'. All subordinate
tranches carry ratings lower than the senior tranche and below the
ratings at close.

Fitch also considers jurisdictional concentrations per the
"Structured Finance and Covered Bonds Country Risk Rating
Criteria," which could result in rating caps lower than 'Asf'.

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

If contractual lease rates outperform modeled cash flows or lessee
credit quality improves materially, this may lead to an upgrade.
Similarly, if assets in the pool display higher values and stronger
rent generation than Fitch's stressed scenarios this may also lead
to an upgrade.

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

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

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


GENERATE CLO 2: S&P Assigns Prelim BB-(sf) Rating on Cl. ER2 Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Generate CLO
2 Ltd./Generate CLO 2 LLC's floating-rate debt.

The debt 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 Generate Advisors LLC, which serves
as the CLO management division of Kennedy Lewis Investment
Management LLC. This is a proposed refinancing of it's December
2017 transaction, which wasn't rated by S&P Global Ratings.

The preliminary ratings are based on information as of Aug. 20,
2024. 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 collateral pool's diversification;

-- 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

  Generate CLO 2 Ltd./Generate CLO 2 LLC

  Class X, $3.50 million: AAA (sf)
  Class AR2, $305.00 million: Not rated
  Class BR2, $75.00 million: AA (sf)
  Class CR2 (deferrable), $30.00 million: A (sf)
  Class D1R2 (deferrable), $25.00 million: BBB (sf)
  Class D2R2 (deferrable), $7.50 million: BBB- (sf)
  Class ER2 (deferrable), $17.50 million: BB- (sf)
  Subordinated notes, $63.65 million: Not rated



GS MORTGAGE 2019-GC40: DBRS Cuts Class G-RR Certs Rating to C
-------------------------------------------------------------
DBRS Limited downgraded the credit ratings on nine classes of
Commercial Mortgage Pass-Through Certificates, Series 2019-GC40
issued by GS Mortgage Securities Corporation Trust 2019-GC40 as
follows:

-- Class B to A (high) (sf) from AA (low) (sf)
-- Class X-B to BBB (high) (sf) from A (high) (sf)
-- Class C to BBB (sf) from A (sf)
-- Class D to BB (sf) from BBB (high) (sf)
-- Class X-D to B (sf) from BBB (sf)
-- Class E to B (low) (sf) from BBB (low) (sf)
-- Class X-F to CCC (sf) from BB (high) (sf)
-- Class F to CCC (sf) from BB (sf)
-- Class G-RR to C (sf) from B (sf)

In addition, Morningstar DBRS confirmed the following credit
ratings:

-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class A-AB at AAA (sf)
-- Class A-S at AAA (sf)
-- Class X-A at AAA (sf)

Morningstar DBRS also changed the trends on Classes A-S, B, C, D,
E, X-A, X-B, and X-D to Negative from Stable. Classes X-F, F, and
G-RR do not carry a trend, given the CCC (sf) or lower credit
rating. The trends on all remaining classes are Stable.
The credit rating downgrades reflect Morningstar DBRS' increased
loss expectations for the pool, primarily attributed to the 250
Livingston loan (Prospectus ID#2, 9.8% of the pool), a watch listed
loan where the largest tenant that occupies majority of the
property will be vacating the property. The loan is discussed
further below. Since the last credit rating action, three loans,
representing 5.7% of the pool balance, transferred to special
servicing. Morningstar DBRS' loss projections for 250 Livingston
and two of the three special serviced loans totaled $41.3 million,
which would wipe out the entire balance of Classes H-RR and G-RR
and nearly 30% of Class F. The Negative trends reflect the
potential for further value decline for these loans, given the
declining performance trends. In addition, the pool has a high
concentration of loans backed by office properties with a number of
those loans exhibiting performance declines from issuance coupled
with significant upcoming rollover risk.

The credit rating confirmations on the remaining classes are
reflective of the otherwise overall steady performance of the
remaining loans in the pool as exhibited by a healthy
weighted-average (WA) debt service coverage ratio (DSCR) of 2.29
times (x) and a WA debt yield of higher than 10.0% based on the
most recent year-end financials. As of the July 2024 remittance, 32
of the original 35 loans remain in the pool, with an aggregate
principal balance of $762.5 million, reflecting a 16.6% collateral
reduction since issuance. The concentration of loans on the
servicer's watchlist has materially increased to 31.4%. The pool is
most concentrated by loans that are secured by office properties,
representing 38.2% of the pool balance. Morningstar DBRS has a
cautious outlook on this asset type as sustained upward pressure on
vacancy rates in the broader office market may challenge landlords'
efforts to backfill vacant space, and, in certain instances,
contribute to value declines, particularly for assets in noncore
markets and/or with disadvantages in location, building quality, or
amenities offered. Where applicable, Morningstar DBRS increased the
probability of default penalties, and, in certain cases, applied
stressed loan-to-value ratios for loans exhibiting performance
concerns. The resulting WA expected loss for these loans is about
100 basis points higher than the pool average.

As noted above, a primary driver of Morningstar DBRS' loss
projections is 250 Livingston Street, a watchlisted loan that is
secured by a 370,305-square-foot (sf), mixed-use commercial and
residential building located in Downtown Brooklyn. The subject note
is pari passu with BMARK 2018-B12, which is also rated by
Morningstar DBRS. The New York City Human Resources Administration
occupies the entire office portion of the property (92.0% of the
property's net rentable area) on a lease through August 2030.
However, the tenant has exercised its termination option and plans
to vacate the building in August 2025. As a result, a cash flow
sweep was initiated where the funds will be used to re-lease the
space. The re-leasing efforts will likely be challenging given the
soft office submarket with CB Richard Ellis reporting a Q2 2024
vacancy rate vacancy rate of 19.1% with asking rents of $54.55 per
sf (psf) for downtown Brooklyn. While an updated appraisal has not
yet been made available, Morningstar DBRS believes the property
value has deteriorated significantly given potential of the
building going dark, as well as its age and property condition and
the current office landscape. Morningstar DBRS derived a dark value
based on the market rental rate, tenant improvement costs of $60
psf for new leases and $30 psf for renewal leases, a stabilization
period of two years, and a 9.0% stressed capitalization rate, which
is on the higher end of the range used by Morningstar DBRS for
office properties. The resulting dark value was approximately $60.0
million. Morningstar DBRS also gave credit to the cash flow sweep
reserves. Morningstar DBRS' liquidated the loan from the trust,
resulting in an implied loss severity in excess of 30.0%.

The second largest loan in special servicing, 57 East 11th Street
(Prospectus ID#15, 2.6% of the pool) is secured by a 64,460-sf
office property with ground floor retail within the Greenwich
Village submarket of New York. The property was built in 1903 and
was most recently renovated in 2018. The subject note is pari passu
with GSMS 2019-GC39 and BMARK 2019-B11 (rated by Morningstar
DBRS).The $55.0 million interest-only (IO) whole loan transferred
to special servicing in February 2024 because of payment default.
The property was previously fully leased to WeWork Inc. (WeWork) on
a lease through October 2034; however WeWork filed for bankruptcy
and rejected the lease at the subject property in November 2023. A
receiver was recently appointed while the special servicer
continues to pursue foreclosure. An updated appraisal as of March
2024 valued the property at $17.8 million, a -77.0% variance from
the issuance value of $76.0 million. Given the severe as-is value
decline, lack of leasing activity, and general lack of liquidity
for this property type, Morningstar DBRS analyzed this loan with a
liquidation scenario, resulting in a loss severity in excess of
80.0%.

Morningstar DBRS' credit ratings on the applicable classes address
the credit risk associated with the identified financial
obligations in accordance with the relevant transaction documents.
Where applicable, a description of these financial obligations can
be found in the transactions' respective press releases at
issuance.

Morningstar DBRS' long-term credit ratings provide opinions on risk
of default. Morningstar DBRS considers risk of default to be the
risk that an issuer will fail to satisfy the financial obligations
in accordance with the terms under which a long-term obligation has
been issued. The Morningstar DBRS short-term debt rating scale
provides an opinion on the risk that an issuer will not meet its
short-term financial obligations in a timely manner.

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


GS MORTGAGE 2021-ARDN: DBRS Confirms B(low) Rating on G Certs
-------------------------------------------------------------
DBRS, Inc. confirmed its credit ratings on all classes of the
Commercial Mortgage Pass-Through Certificates, Series 2021-ARDN
issued by GS Mortgage Securities Corporation Trust 2021-ARDN as
follows:

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

All trends are Stable.

The credit rating confirmations reflect the overall stable
performance of the transaction, as evidenced by the
servicer-reported YE2023 portfolio net cash flow (NCF) of $33.4
million, which is slightly improved compared the Morningstar DBRS
NCF of $29.0 million concluded at issuance. As of YE2023, the
portfolio was 91.7% occupied by an extremely granular tenant base.
Performance is expected to remain in line with expectations.

The floating-rate, interest-only loan is secured by the fee-simple
interest in a portfolio of 140 flex, industrial buildings
consisting of approximately 5.2 million square feet (sf) across 26
business parks and within the greater metro areas of eight cities:
Atlanta; Indianapolis; Philadelphia; Tampa, Florida; Columbus,
Ohio; Charlotte, North Carolina; Dallas; and San Antonio, Texas.
The collateral benefits from institutional-quality sponsorship
provided by a joint venture between Arden Group and Arcapita Group
(Arcapita).

The loan proceeds of $446.0 million, along with $155.0 million of
sponsor equity, were used to finance the recapitalization of the
underlying portfolio through a 49% acquisition by Arcapita. The
transaction is structured with pro rata paydowns associated with
property releases for the first 20% of the original principal
balance, proceeds applied sequentially thereafter. As a condition
of the property release provisions, the borrower is required to pay
a release price of 110% of the allocated loan amount (ALA) until
the outstanding pool balance is reduced to 90% of the original
balance, 115% of the ALA until the outstanding balance is further
reduced to 80%, and 125% of the ALA thereafter. In addition, the
portfolio debt yield following such release must be equal to the
greater of the debt yield at closing of 8.3% and the debt yield for
the trailing 12 months. As of the July 2024 remittance, there have
been no property releases since issuance. The mortgage loan is also
structured to comply with Sharia law, and each property is subject
to a master lease.

The mortgage loan represents a 81.7% loan-to-value ratio (LTV)
based on the issuance appraised value of $545.9 million. The
December 2023 reported occupancy rate of 91.7% is in line with the
portfolio's issuance occupancy rate of 91.6%. The tenant roster is
relatively granular with no single tenant occupying more than 2.0%
of the total net rentable area. The Morningstar DBRS NCF and debt
service coverage ratio (DSCR) at issuance were $29.0 million and
2.14 times (x), respectively. Based on the YE2023 reporting, the
NCF was at $33.4 million, but DSCR declined to 1.14x as a result of
increased debt service stemming from the floating-rate coupon.

The loan's initial two-year term ended in November 2023, following
which the borrower elected to extend the loan to November 2024.
There are two one-year extension options remaining for a fully
extended maturity date in November 2026. Per the loan terms, the
borrower may give notice of its intention to execute its extension
option no less than 30 days prior to maturity. The borrower is also
required to purchase an interest rate cap agreement with a strike
rate that will result in a DSCR of no less than 1.2x. Considering
the stable performance of the underlying collateral, the loan is
well positioned to be extended.

Morningstar DBRS maintained its analysis derived at issuance, which
is based on the Morningstar DBRS NCF of $29.0 million and a
capitalization rate of 7.5%. This results in a Morningstar DBRS
value of $386.7 million, which represents a -29.2% variance from
the issuance appraised value of $545.9 million. The implied LTV
based on the Morningstar DBRS value is 115.3%. Positive qualitative
adjustments totaling 4.5% were maintained to account for the low
cash flow volatility, good property quality and stable market
fundamentals.

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


GS MORTGAGE 2024-A01: Fitch Gives 'Bsf' Rating on B-2 Certs
-----------------------------------------------------------
Fitch Ratings rates the residential mortgage-backed certificates
issued by GS Mortgage-Backed Securities Trust 2024-AO1 (GSMBS
2024-AO1).

   Entity/Debt         Rating              Prior
   -----------         ------              -----
GSMBS 2024-AO1

   A-1             LT AAAsf  New Rating    AAA(EXP)sf
   A-2             LT AAsf   New Rating    AA(EXP)sf
   A-3             LT Asf    New Rating    A(EXP)sf
   M-1             LT BBB-sf New Rating    BBB-(EXP)sf
   B-1             LT BBsf   New Rating    BB(EXP)sf
   B-2             LT Bsf    New Rating    B(EXP)sf
   B-3             LT NRsf   New Rating    NR(EXP)sf
   A-IO-S          LT NRsf   New Rating    NR(EXP)sf
   R               LT NRsf   New Rating    NR(EXP)sf
   RiskRetention   LT NRsf   New Rating    NR(EXP)sf
   X               LT NRsf   New Rating    NR(EXP)sf

Transaction Summary

The certificates are supported by 609 seasoned nonprime loans with
a total balance of approximately $285 million as of the cutoff
date.

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 9% above a long-term sustainable level (vs. 11.5%
on a national level as of 1Q24, which remained unchanged since the
prior quarter). Housing affordability is the worst it has been in
decades driven by both high interest rates and elevated home
prices. Home prices increased 5.9% YoY nationally as of May 2024.

Nonprime Credit Quality (Mixed): The collateral consists of 609
loans totaling $285 million and seasoned at approximately 32 months
in aggregate (calculated as the difference between the origination
date and the cutoff date). The borrowers have a moderate credit
profile (Fitch FICO: 738) and a 42% debt-to-income ratio (DTI),
which factors converted debt service coverage ratio (DSCR)-to-DTI
values, and low leverage (a 67% sustainable loan-to-value ratio
[sLTV]). The pool consists of 54% of loans where the borrower
maintains a primary residence, while the remaining 46% represents
an investor property or second home. Additionally, 38% of the loans
were originated through a retail channel.

Modified Sequential Payment Structure (Mixed): The structure
distributes collected principal pro rata among the class A
certificates while excluding the mezzanine and subordinate
certificates from principal until all three A classes are reduced
to zero. To the extent that either a cumulative loss trigger event
or a delinquency 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. Excess spread is
available to reimburse for losses or interest shortfalls should
they occur as well as to pay coupon cap shortfalls on the senior
classes.

However, excess spread will be reduced on and after the
distribution date in August 2028, since the class A certificates
have a step-up coupon feature, whereby the coupon rate will be the
lower of (i) the applicable fixed rate plus 1.000% or (ii) the net
weighted average coupon (WAC) rate. Payments on the A classes at
the fully stepped up rate is supported by the structuring of
classes M-1, B-1, B-2 and B-3 as principal-only (PO) bonds. This
creates additional excess interest to support full payment of the
bonds and to protect against losses.

Limited Advancing (Mixed): The deal is structured to three months
of servicer advances for delinquent principal and interest (P&I).
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 is the additional stress on the
structure, as liquidity is limited in the event of large and
extended delinquencies.

Of the pool, 58% are nonqualified mortgage (non-QM) loans and less
than 0.5% are either Safe Harbor Qualified Mortgages (SHQM) or
Higher Priced Qualified Mortgages (HPQM); for the remainder, the
Consumer Financial Protection Bureau's Ability-to-Repay/Qualified
Mortgage Rule (ATR, or the Rule) does not apply.

Loan Documentation (Negative): Approximately 87% of the pool was
underwritten to less than full documentation. Of the pool, 40% was
underwritten to a 12-month or 24-month bank statement program for
verifying income, which is not consistent with 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 ATR, which reduces the risk of borrower default
arising from lack of affordability, misrepresentation or other
operational quality risks due to the rigor of the Rule's mandates
with respect to underwriting and documentation of the borrower's
ability to repay. Additionally, 2% is an asset depletion product,
33% is a DSCR product and the rest comprises a mix of alternative
documentation products.

RATING SENSITIVITIES

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

Fitch's incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper market value declines (MVDs) than
assumed at the metropolitan statistical area 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 40.8% at 'AAA'. The analysis indicates that there
is some potential rating migration with higher MVDs for all rated
classes, compared with the model projection. Specifically, a 10%
additional decline in home prices would lower all rated classes by
one full category.

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

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 being assigned
ratings of 'AAAsf'.

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by multiple third-party review firms. The third-party due
diligence described in Form 15E focused on credit, regulatory
compliance, and property valuation. Fitch considered this
information in its analysis and, as a result, Fitch made the
following adjustment to its analysis: a 5% PD credit to each loan
in the pool (due to the 100% diligence that was performed) This
adjustment resulted in a 33bps reduction to the 'AAAsf' expected
loss.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


HOMEWARD OPPORTUNITIES 2024-RRTL2: DBRS Gives P B(low) on M2 Notes
------------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the
Mortgage-Backed Notes, Series 2024-RRTL2 (the Notes) to be issued
by Homeward Opportunities Fund Trust 2024-RRTL2 (HOF 2024-RRTL2 or
the Issuer) as follows:

-- $206.6 million Class A1 at A (low) (sf)
-- $175.5 million Class A1A at A (low) (sf)
-- $31.1 million Class A1B at A (low) (sf)
-- $17.6 million Class A2 at BBB (low) (sf)
-- $18.2 million Class M1 at BB (low) (sf)
-- $14.2 million Class M2 at B (low) (sf)

The A (low) (sf) credit rating reflects 23.50% of credit
enhancement provided by the subordinated notes and
overcollateralization. The BBB (low) (sf), BB (low) (sf), and B
(low) (sf) credit ratings reflect 17.00%, 10.25%, and 5.00% of
credit enhancement, respectively.

Other than the specified classes above, Morningstar DBRS does not
rate any other classes in this transaction.
This transaction is a securitization of an 18-month revolving
portfolio of residential transition loans (RTLs) funded by the
issuance of the Notes. As of the Initial Cut-Off Date, the Notes
are backed by:

-- 468 mortgage loans with a total principal balance of
approximately $234,048,590,
-- Approximately $35,951,410 in the Accumulation Account, and
-- Approximately $2,000,000 in the Interest Reserve Account.

Additional RTLs may be added to the revolving portfolio on future
additional transfer dates, subject to the transaction's eligibility
criteria.

HOF 2024-RRTL2 represents the third RTL securitization issued by
the Sponsor, Homeward Opportunities Fund LP (HOF). Formed in 2019,
HOF is a fund managed by and affiliated with Neuberger Berman
Investment Advisers LLC (NBIA) whose investment objective is to
achieve an attractive risk-adjusted return on investment by
acquiring, managing, holding for investment, and disposing of U.S.
residential real estate-related investments, including but not
limited to residential, commercial, multifamily, residential
rental, mixed residential/commercial, bridge, and investment
mortgage loans.

The revolving portfolio generally consists of first-lien,
fixed-rate, interest-only (IO) balloon RTL with original terms to
maturity of 12 to 24 months. The loans may include extension
options, which can lengthen maturities beyond the original terms.
The characteristics of the revolving pool will be subject to
eligibility criteria specified in the transaction documents and
include, but are not limited to:

-- A minimum nonzero weighted-average (NZ WA) FICO score of 735.
-- A maximum WA Loan-to-Cost ratio (LTC) of 80.0%.
-- A maximum NZ WA as Repaired Loan-to-Value ratio (ARV LTV) of
70.0%.

RTL Features

RTLs, also known as fix-and-flip mortgage loans, are short-term
bridge, construction, or renovation loans designed to help real
estate investors purchase and renovate residential or small balance
commercial properties (the latter is limited to 5.0% of the
revolving portfolio), generally within 12 to 36 months. RTLs are
similar to traditional mortgages in many aspects but may differ
significantly in terms of initial property condition, construction
draws, and the timing and incentives by which borrowers repay
principal. For traditional residential mortgages, borrowers are
generally incentivized to pay principal monthly, so they can occupy
the properties while building equity in their homes. In the RTL
space, borrowers repay their entire loan amount when they (1) sell
the property with the goal to generate a profit or (2) refinance to
a term loan and rent out the property to earn income.

In general, RTLs are short-term IO balloon loans with the full
amount of principal (balloon payment) due at maturity. The
repayment of an RTL is mainly based on the ability to sell the
related mortgaged property or to convert it into a rental property.
In addition, many RTL lenders offer extension options, which
provide additional time for borrowers to repay their mortgage
beyond the original maturity date. For the loans in this
transaction, such extensions may be granted, subject to certain
conditions, at the direction of the Servicing Administrator.

In the HOF 2024-RRTL2 revolving portfolio, RTLs may be:

-- Fully funded, (1) with no obligation of further advances to the
borrower, or (2) with a portion of the loan proceeds allocated to a
rehabilitation (rehab) escrow account for future disbursement to
fund construction draw requests upon the satisfaction of certain
conditions; or

-- Partially funded, with a commitment to fund borrower-requested
draws for approved rehab, construction, or repairs of the property
(Rehabilitation Disbursement Requests) upon the satisfaction of
certain conditions.

After completing certain construction/repairs using their own
funds, the borrower usually seeks reimbursement by making draw
requests. Generally, construction draws are disbursed only upon the
completion of approved construction/repairs and after a
satisfactory construction progress inspection. Based on the HOF
2024-RRTL2 eligibility criteria, unfunded commitments are limited
to 50.0% of the assets of the issuer, which includes (1) the unpaid
principal balance (UPB) of the mortgage loans and (2) amounts in
the Accumulation Account.

Cash Flow Structure and Draw Funding

The transaction employs a sequential-pay cash flow structure.
During the reinvestment period, the Notes will generally be IO.
After the reinvestment period, principal will be applied to pay
down the Notes, sequentially. If the Issuer does not redeem the
Notes by the payment date in July 2026, the Class A1, A1A, A1B, and
A2 fixed rates listed in the Credit Ratings table will step up by
1.000% the following month.

There will be no advancing of delinquent (DQ) interest on any
mortgage by the Servicers or any other party to the transaction.
However, the Servicers are obligated to fund Servicing Advances
which include taxes, insurance premiums, and reasonable costs
incurred in the course of servicing and disposing properties. Each
Servicer will be entitled to reimburse itself for Servicing
Advances from available funds prior to any payments on the Notes.
The Servicers will satisfy Rehabilitation Disbursement Requests by,
(1) for loans with funded commitments, releasing funds from the
Rehab Escrow Account to the applicable borrower; or (2) for loans
with unfunded commitments, releasing funds from principal
collections on deposit in the related Servicer's Custodial Account
(Rehabilitation Advances). If amounts in the applicable Servicer's
Custodial Account are insufficient to fund a Rehabilitation
Advance, the Depositor may advance funds from the Accumulation
Account. The Depositor will be entitled to reimburse itself for
Rehabilitation Disbursement Requests from time to time from the
Accumulation Account.

The Accumulation Account is replenished from the transaction cash
flow waterfall, after payment of interest to the Notes, to maintain
a minimum required funding balance. During the reinvestment period,
amounts held in the Accumulation Account, along with the mortgage
collateral, must be sufficient to maintain a minimum credit
enhancement (CE) of approximately 5.00% to the most subordinate
rated class. The transaction incorporates a Minimum Credit
Enhancement Test during the reinvestment period, which if breached,
redirects available funds to pay down the Notes, sequentially,
prior to replenishing the Accumulation Account, to maintain the
minimum CE for the rated Notes.
The transaction also employs the Expense Reserve Account, which
will be available to cover fees and expenses. The Expense Reserve
Account is replenished from the transaction cash flow waterfall,
before payment of interest to the Notes, to maintain a minimum
reserve balance.

An Interest Reserve Account is in place to help cover the first
three months of interest payments to the Notes. Such account is
funded upfront in an amount equal to $2,000,000. On the payment
dates occurring in August, September, and October 2024, the Paying
Agent will withdraw a specified amount to be included in available
funds.

Historically, RTL originations reviewed by Morningstar DBRS have
generated robust mortgage repayments, which have been able to cover
unfunded commitments in securitizations. In the RTL space, because
of the lack of amortization and the short-term nature of the loans,
mortgage repayments (paydowns and payoffs) tend to occur closer to
or at the related maturity dates when compared with traditional
residential mortgages. Morningstar DBRS considers paydowns to be
unscheduled voluntary balance reductions (generally repayments in
full) that occur prior to the maturity date of the loans, while
payoffs are scheduled balance reductions that occur on the maturity
or extended maturity date of the loans. In its cash flow analysis,
Morningstar DBRS evaluated mortgage repayments relative to draw
commitments for NBIA's historical acquisitions and incorporated
several stress scenarios where paydowns may or may not sufficiently
cover draw commitments.

Other Transaction Features

Optional Redemption

On any date on or after the date on which the aggregate Note Amount
falls to less than 25% of the initial Closing Date Note Amount, the
Issuer, at its option, may purchase all of the outstanding Notes at
par plus interest and fees (the Redemption Price).

On any Payment Date following the termination of the Reinvestment
Period, the Depositor, at its option, may purchase all of the
mortgage loans at the Redemption Price.

Repurchase Option

The Sponsor will have the option to repurchase any DQ or defaulted
mortgage loan at the Repurchase Price, which is equal to par plus
interest and fees. However, such voluntary repurchases may not
exceed 10.0% of the cumulative UPB of the mortgage loans. During
the reinvestment period, if the Depositor repurchases DQ or
defaulted loans, this could potentially delay the natural
occurrence of an early amortization event based on the DQ or
default trigger. Morningstar DBRS' revolving structure analysis
assumes the repayment of Notes is reliant on the amortization of an
adverse pool regardless of whether it occurs early or not.

Repurchases

A mortgage loan may be repurchased under the following
circumstances:

-- There is a material R&W breach, a material document defect, or
a diligence defect that the Sponsor is unable to cure,

-- The Sponsor elects to exercise its Repurchase Option, or
-- An optional redemption occurs.

U.S. Credit Risk Retention

As the Sponsor, HOF, through a majority-owned affiliate, will
initially retain an eligible horizontal residual interest
comprising at least 5% of the aggregate fair value of the
securities (the Class XS Notes) to satisfy the credit risk
retention requirements.

Morningstar DBRS' credit ratings on the Notes address the credit
risk associated with the identified financial obligations in
accordance with the relevant transaction documents. The associated
financial obligations for each of the rated Notes are the related
Note Interest Payment Amount, the Interest Carryforward Amount, and
the Note Amount.

Morningstar DBRS' credit ratings on the Class A1, Class A1A, and
Class A1B also address the credit risk associated with the
increased rate of interest applicable Class A1, Class A1A, and
Class A1B if the Class A1, Class A1A, and Class A1B notes remain
outstanding on the step-up date (July 2027) in accordance with the
applicable transaction document(s).

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


IVY HILL VII: S&P Assigns BB- (sf) Rating on Class E-RRR Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-RRR, B-RRR,
C-RRR, D-RRR and E-RRR replacement debt and new class A-LRRR loans
and class A-LRRR notes from Ivy Hill Middle Market Credit Fund VII
Ltd./Ivy Hill Middle Market Credit Fund VII LLC, a CLO originally
issued in 2021 that is managed by Ivy Hill Asset Management L.P., a
subsidiary of Ares Capital Corp. At the same time, S&P withdrew its
ratings on the original class X-RR, A-RR, B-1-RR, B-2-RR, C-RR,
D-RR, and E-RR debt following payment in full on the Aug. 15, 2024,
refinancing date.

The replacement debt and new debt was issued via a supplemental
indenture, which outlines the terms of the replacement and new
debt. According to the supplemental indenture:

-- The replacement class A-RRR, B-RRR, C-RRR, D-RRR, and E-RRR
debt and new class A-LRRR loans and class A-LRRR notes were issued
at a floating spread.

-- The original class B-1-RR, issued at a floating spread, and
class B-2-RR, issued at a fixed coupon, were combined into a single
class B-RRR, which was issued at a floating spread.

-- The stated maturity and reinvestment period were extended by
2.99 years, and the non-call date was extended by 2.82 years.

-- The new class A-LRRR loans are convertible in whole or in part
into only the class A-LRRR notes. The new class A-LRRR notes are
not convertible into loans.

Replacement And Original Debt Issuances

Replacement debt

-- Class A-RRR, $177.00 million: Three-month CME term SOFR +
1.60%

-- Class A-LRRR loans, $55.00 million: Three-month CME term SOFR +
1.60%

-- Class A-LRRR, $0.00 million: Three-month CME term SOFR + 1.60%

-- Class B-RRR, $40.00 million: Three-month CME term SOFR + 1.90%

-- Class C-RRR (deferrable), $32.00 million: Three-month CME term
SOFR + 2.35%

-- Class D-RRR (deferrable), $24.00 million: Three-month CME term
SOFR + 3.90%

-- Class E-RRR (deferrable), $24.00 million: Three-month CME term
SOFR + 7.35%

-- Subordinated notes, $112.50 million: Not applicable

Original debt

-- Class X-RR, $4.20 million: Three-month CME term SOFR + 1.00% +
CSA(i)

-- Class A-RR, $237.30 million: Three-month CME term SOFR + 1.48%
+ CSA(i)

-- Class B-1-RR, $39.00 million: Three-month CME term SOFR + 1.90%
+ CSA(i)

-- Class B-2-RR, $15.60 million: 3.226%

-- Class C-RR (deferrable), $31.50 million: Three-month CME term
SOFR + 2.60% + CSA(i)

-- Class D-RR (deferrable), $18.90 million: Three-month CME term
SOFR + 3.80% + CSA(i)

-- Class E-RR (deferrable), $27.30 million: Three-month CME term
SOFR + 8.42% + CSA(i)

-- Subordinated notes, $65.08 million: Not applicable

(i)The CSA is 0.26161%.
CSA--Credit spread adjustment.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Ratings Assigned

  Ivy Hill Middle Market Credit Fund VII Ltd./
  Ivy Hill Middle Market Credit Fund VII LLC

  Class A-RRR, $177.0 million: AAA (sf)
  Class A-LRRR loans, $55.0 million: AAA (sf)
  Class A-LRRR, $0.0 million: AAA (sf)
  Class B-RRR, $40.0 million: AA (sf)
  Class C-RRR (deferrable), $32.0 million: A (sf)
  Class D-RRR (deferrable), $24.0 million: BBB- (sf)
  Class E-RRR (deferrable), $24.0 million: BB- (sf)

  Ratings Withdrawn

  Ivy Hill Middle Market Credit Fund VII Ltd./
  Ivy Hill Middle Market Credit Fund VII LLC

  Class X-RR to not rated from 'AAA (sf)'
  Class A-RR to not rated from 'AAA (sf)'
  Class B-1-RR to not rated from 'AA (sf)'
  Class B-2-RR to not rated from 'AA (sf)'
  Class C-RR to not rated from 'A- (sf)'
  Class D-RR to not rated from 'BBB- (sf)'
  Class E-RR to not rated from 'BB- (sf)'

  Other Debt

  Ivy Hill Middle Market Credit Fund VII Ltd./
  Ivy Hill Middle Market Credit Fund VII LLC

  Subordinated notes, $112.5 million: Not rated



KIND COMMERCIAL 2024-1: Moody's Assigns B2 Rating to Cl. HRR Certs
------------------------------------------------------------------
Moody's Ratings has assigned definitive ratings to seven classes of
CMBS securities, issued by KIND Commercial Mortgage Trust 2024-1,
Commercial Mortgage Pass-Through Certificates, Series 2024-1:

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa3 (sf)

Cl. C, Definitive Rating Assigned A3 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba2 (sf)

Cl. F, Definitive Rating Assigned Ba3 (sf)

Cl. HRR, Definitive Rating Assigned B2 (sf)

RATINGS RATIONALE

The certificates are collateralized by a single loan backed by
first lien mortgages on the borrowers' fee simple interests in a
portfolio of 43 primarily industrial properties encompassing
approximately 6,732,245 SF. Moody's ratings are based on the credit
quality of the loan and the strength of the securitization
structure.

The collateral portfolio consists of 42 industrial properties and
one office property located across seventeen states and two
Canadian provinces and leased across 29 markets. The largest
concentrations are in Pennsylvania (18.2% of base rent), Texas
(15.4% of base rent), Michigan (8.7% of base rent), Illinois(8.1%
of base rent) and Florida (7.0% of base rent). The portfolio's
property-level Herfindahl score is 17.4  based on allocated loan
amount (the "ALA").

The portfolio is 100% triple-net-leased to ten tenants with a
weighted average remaining lease term of 14.4 years. Four tenants
are subject to master leases, which include multiple properties.
The remaining six tenants are subject to single-property leases.
The top three tenants are Blue Triton (59.4% of NRA, 54.4% base
rent), Dessert Holdings 7.8% of NRA, 12.1% of base rent), and
Cadrex (8.3% of NRA, 7.8% of base rent).

The collateral properties contain a total of 6,732,245 SF of NRA
and includes Production & Distribution facilities (89.5% of NRA,
84.3% of base rent), Distribution facilities (9.7% of NRA, 9.1% of
base rent), and  one LEED Platinum class A office property (0.9% of
NRA, 6.6% of base rent). Property size ranges between  9,500 SF and
811,000 SF, and averages 184,668 SF.  Clear heights for properties
range between 11 feet and 40 feet, and average approximately 27.6
feet. The properties were built between 1923 and 2020 with an
average year built of 1996.

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

The 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 Moody's first mortgage actual DSCR is 0.90x, compared with
0.88x in place at Moody's provisional ratings, and Moody's first
mortgage actual stressed DSCR is 0.76x. Moody's DSCR is based on
Moody's stabilized net cash flow.

The loan first mortgage balance of $517,000,000 represents a
Moody's LTV ratio of 118.9% based on Moody's value. Adjusted
Moody's LTV ratio for the first mortgage balance is 108.0%,
compared with 107.7% in place at Moody's provisional ratings, based
on Moody's Value using a cap rate adjusted for the current interest
rate environment.

Moody's also grades properties on a scale of 0 to 5 (best to worst)
and considers those grades when assessing the likelihood of debt
payment. The factors considered include property age, quality of
construction, location, market, and tenancy. The pool's quality
grade is 1 for the industrial properties and 2 for the office
property.

Notable strengths of the transaction include: proximity to global
gateway markets, geographic diversity, strong occupancy rate with
minimal rollover, below-market rent,  multiple property pooling and
experienced sponsorship.

Notable concerns of the transaction include: tenant concentration,
property age, high Moody's LTV, floating-rate interest-only loan
profile, non-sequential prepayment provision, and credit negative
legal features.

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

The principal methodology used in these ratings was "Large Loan and
Single Asset/Single Borrower Commercial Mortgage-backed
Securitizations" published in July 2024.

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

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

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


LHOME MORTGAGE 2024-RTL4: DBRS Finalizes B Rating on M2 Notes
-------------------------------------------------------------
DBRS, Inc. finalized the following provisional credit ratings on
the Mortgage-Backed Notes, Series 2024-RTL4 (the Notes) issued by
LHOME Mortgage Trust 2024-RTL4 (LHOME 2024-RTL4 or the Issuer) as
follows:

-- $328.8 million Class A1 at A (low) (sf)
-- $23.4 million Class A2 at BBB (low) (sf)
-- $27.0 million Class M1 at BB (low) (sf)
-- $20.7 million Class M2 at B (sf)

The A (low) (sf) credit rating reflects 21.45% of credit
enhancement provided by the subordinated notes and
overcollateralization. The BBB (low) (sf), BB (low) (sf), and B
(sf) credit ratings reflect 15.85%, 9.40%, and 4.45% of credit
enhancement, respectively.

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

This transaction is a securitization of a two-year revolving
portfolio of residential transition loans (RTLs) funded by the
issuance of the Mortgage-Backed Notes, Series 2024-RTL4 (the
Notes). As of the Initial Cut-Off Date, the Notes are backed by:

-- 659 mortgage loans with a total principal balance of
approximately $168,067,114

-- Approximately $250,561,876 in the Accumulation Account

-- Approximately $4,000,000 in the Pre-funding Interest Account.

Additional RTLs may be added to the revolving portfolio on future
additional transfer dates, subject to the transaction's eligibility
criteria.

LHOME 2024-RTL4 represents the 19th RTL securitization issued by
the Sponsor, Kiavi Funding, Inc. (Kiavi). Founded in 2013 as
LendingHome Funding Corporation and re-branded as Kiavi in November
2021, Kiavi is a privately held technology-enabled lender that
provides business-purpose loans for real estate investors engaged
in acquiring, renovating and either reselling or holding for
investment purposes single-family residential properties.
The revolving portfolio generally consists of first-lien,
fixed-rate, interest-only (IO) balloon RTL with original terms to
maturity of 12 to 24 months. The loans may include extension
options, which can lengthen maturities beyond the original terms.
The characteristics of the revolving pool will be subject to
eligibility criteria specified in the transaction documents and
include:

-- A minimum non-zero weighted-average (NZ WA) FICO score of 735.
-- A maximum NZ WA Loan-to-Cost (LTC) ratio of 91.5%.
-- A maximum NZ WA As Repaired Loan-to-Value (ARV LTV) ratio of
73.0%.

RTL Features

RTLs, also known as fix-and-flip mortgage loans, are short-term
bridge, construction, or renovation loans designed to help real
estate investors purchase and renovate residential or multifamily
5+ properties (the latter is limited to 5.0% of the revolving
portfolio), generally within 12 to 36 months. RTLs are similar to
traditional mortgages in many aspects but may differ significantly
in terms of initial property condition, construction draws, and the
timing and incentives by which borrowers repay principal. For
traditional residential mortgages, borrowers are generally
incentivized to pay principal monthly, so they can occupy the
properties while building equity in their homes. In the RTL space,
borrowers repay their entire loan amount when they (1) sell the
property with the goal to generate a profit or (2) refinance to a
term loan and rent out the property to earn income.

In general, RTLs are short-term IO balloon loans with the full
amount of principal (balloon payment) due at maturity. The
repayment of an RTL is mainly based on the ability to sell the
related mortgaged property or to convert it into a rental property.
In addition, many RTL lenders offer extension options, which
provide additional time for borrowers to repay their mortgage
beyond the original maturity date. For the loans in this
transaction, such extensions may be granted, subject to certain
conditions, at the direction of the Asset Manager.
In the LHOME 2024-RTL4 revolving portfolio, RTLs may be:

Fully funded:

-- With no obligation of further advances to the borrower, or

-- With a portion of the loan proceeds allocated to a
rehabilitation (rehab) escrow account for future disbursement to
fund construction draw requests upon the satisfaction of certain
conditions.

Partially funded:

-- With a commitment to fund borrower-requested draws for approved
rehab, construction, or repairs of the property (Rehabilitation
Disbursement Requests) upon the satisfaction of certain
conditions.

After completing certain construction/repairs using their own
funds, the borrower usually seeks reimbursement by making draw
requests. Generally, construction draws are disbursed only upon the
completion of approved construction/repairs and after a
satisfactory construction progress inspection. Based on the LHOME
2024-RTL4 eligibility criteria, unfunded commitments are limited to
40.0% of the portfolio by aggregate principal limit.

Cash Flow Structure and Draw Funding

The transaction employs a sequential-pay cash flow structure.
During the reinvestment period, the Notes will generally be IO.
After the reinvestment period, principal will be applied to pay
down the Notes, sequentially. If the Issuer does not redeem the
Notes by the payment date in January 2027, the Class A1 and A2
fixed rates will step up by 1.000% the following month.
There will be no advancing of delinquent (DQ) interest on any
mortgage by the Servicer or any other party to the transaction.
However, the Servicer is obligated to fund Servicing Advances which
include taxes, insurance premiums, and reasonable costs incurred in
the course of servicing and disposing properties. The Servicer will
be entitled to reimburse itself for Servicing Advances from
available funds prior to any payments on the Notes.

The Servicer will satisfy Rehabilitation Disbursement Requests by
(1) directing release of funds from the Rehab Escrow Account to the
applicable borrower for loans with funded commitments; or (2) for
loans with unfunded commitments, (a) advancing funds on behalf of
the Issuer (Rehabilitation Advances) or (b) directing the release
of funds from the Accumulation Account. The Servicer will be
entitled to reimburse itself for Rehabilitation Disbursement
Requests from time to time from the Accumulation Account.

The Accumulation Account is replenished from the transaction cash
flow waterfall, after payment of interest to the Notes, to maintain
a minimum required funding balance. During the reinvestment period,
amounts held in the Accumulation Account, along with the mortgage
collateral, must be sufficient to maintain a minimum credit
enhancement (CE) of approximately 4.45% to the most subordinate
rated class. The transaction incorporates a Minimum Credit
Enhancement Test during the reinvestment period, which if breached,
redirects available funds to pay down the Notes, sequentially,
prior to replenishing the Accumulation Account, to maintain the
minimum CE for the rated Notes.

The transaction also employs the Expense Reserve Account, which
will be available to cover fees and expenses. The Expense Reserve
Account is replenished from the transaction cash flow waterfall,
before payment of interest to the Notes, to maintain a minimum
reserve balance.

A Pre-funding Interest Account is in place to help cover three
months of interest payments to the Notes. Such account is funded
upfront in an amount equal to $3,000,000. On the payment dates
occurring in August, September, and October 2024, the Paying Agent
will withdraw a specified amount to be included in the available
funds.

Historically, Kiavi RTL originations have generated robust mortgage
repayments, which have been able to cover unfunded commitments in
securitizations. In the RTL space, because of the lack of
amortization and the short term nature of the loans, mortgage
repayments (paydowns and payoffs) tend to occur closer to or at the
related maturity dates when compared with traditional residential
mortgages. Morningstar DBRS considers paydowns to be unscheduled
voluntary balance reductions (generally repayments in full) that
occur prior to the maturity date of the loans, while payoffs are
scheduled balance reductions that occur on the maturity or extended
maturity date of the loans. In its cash flow analysis, Morningstar
DBRS evaluated Kiavi's historical mortgage repayments relative to
draw commitments and incorporated several stress scenarios where
paydowns may or may not sufficiently cover draw commitments.

Other Transaction Features

Optional Redemption

On any date on or after the earlier of (1) the Payment Date
following the termination of the Reinvestment Period or (2) the
date on which the aggregate Note Amount falls to less than 25% of
the initial Closing Date Note Amount, the Issuer, at its option,
may purchase all of the outstanding Notes at the par plus interest
and fees.

Repurchase Option

The Depositor will have the option to repurchase any DQ or
defaulted mortgage loan at the Repurchase Price, which is equal to
par plus interest and fees. However, such voluntary repurchases may
not exceed 10.0% of the cumulative UPB of the mortgage loans.
During the reinvestment period, if the Depositor repurchases DQ or
defaulted loans, this could potentially delay the natural
occurrence of an early amortization event based on the DQ or
default trigger. Morningstar DBRS' revolving structure analysis
assumes the repayment of Notes is reliant on the amortization of an
adverse pool regardless of whether it occurs early or not.

Loan Sales

The Issuer may sell a mortgage loan under the following
circumstances:

-- The Seller is required to repurchase a loan because of a
material breach, a material document defect, or the loan is a non-

REMIC qualified mortgage

-- The Depositor elects to exercise its Repurchase Option

-- An automatic repurchase is triggered in connection with the
third-party due diligence review

-- An optional redemption occurs.

U.S. Credit Risk Retention

As the Sponsor, Kiavi, through a majority-owned affiliate, will
initially retain an eligible horizontal residual interest
comprising at least 5% of the aggregate fair value of the
securities (the Class XS Notes) to satisfy the credit risk
retention requirements.

Morningstar DBRS' credit rating on the Notes addresses the credit
risk associated with the identified financial obligations in
accordance with the relevant transaction documents. The associated
financial obligations for each of the rated Notes are the related
Note Interest Payment Amount, the Interest Carryforward Amount, and
the Note Amount

Morningstar DBRS' credit rating on the Class A1 and Class A2 Notes
also addresses the credit risk associated with the increased rate
of interest applicable to the Class A1 and Class A2 Notes if the
Class A1 and Class A2 Notes are not redeemed by the expected
Optional Redemption Date (January 2027) in accordance with the
applicable transaction document(s).

Notes: All figures are in US Dollars unless otherwise noted.


LOANCORE 2022-CRE7: DBRS Confirms B(low) Rating on G Notes
----------------------------------------------------------
DBRS Limited confirmed its credit ratings on all classes of notes
issued by LoanCore 2022-CRE7 Issuer Ltd. as follows:

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

All trends are Stable.

The credit rating confirmations reflect the favorable collateral
composition of the transaction as the trust continues to be
primarily secured by the multifamily collateral (29 loans,
representing 97.8% of the current pool balance). Historically,
loans secured by multifamily properties have exhibited lower
default rates and the ability to retain and increase asset value.
Additionally, the majority of individual borrowers are progressing
with the stated business plans to increase property cash flow asset
value. In conjunction with this press release, Morningstar DBRS has
published a Surveillance Performance Update report with in-depth
analysis and credit metrics for the transaction and with business
plan updates on select loans. For access to this report, please
click on the link under Related Documents below or contact us at
info-dbrs@morningstar.com.

The initial collateral consisted of 29 floating-rate mortgages,
secured by 29 transitional properties, with a cut-off balance of
$1.25 billion, excluding approximately $65.4 million of future
funding participations and $194.7 million of funded companion
participations. The transaction was structured with a two-year
Reinvestment Period that expired with the March 2024 Payment Date.

As of the July 2024 remittance, the pool comprised 30 loans,
secured by 30 properties, with a cumulative trust balance of $1.5
billion. Since Morningstar DBRS' previous credit rating action in
August 2023, three loans with a cumulative loan balance of $170.6
million have successfully been repaid from the trust while three
loans, with a cumulative trust loan balance of $122.9 million, were
added to the pool.

Leverage across the pool has marginally decreased since issuance as
the current weighted-average (WA) as-is appraised, loan-to-value
(LTV) ratio is 71.5%, with a current WA stabilized LTV ratio of
65.2%. In comparison, these figures were 76.2% and 67.4%,
respectively, since issuance. Morningstar DBRS recognizes that
select property values may be inflated as the majority of the
individual property appraisals were completed in 2022 and may not
reflect the current rising interest rate or widening capitalization
rate environments. In its analysis, Morningstar DBRS applied upward
LTV adjustments across 10 loans, representing 51.1% of the current
trust balance.

The remaining collateral in the transaction beyond the multifamily
concentration noted above includes one manufactured housing
property (2.2% of the current trust balance). The loans are
primarily secured by properties in suburban markets as 25 loans,
representing 79.4% of the pool, are secured by properties in
suburban markets, as defined by Morningstar DBRS with a Morningstar
DBRS Market Rank of 3, 4, or 5. An additional two loans,
representing 10.5% of the pool, are secured by properties with a
Morningstar DBRS Market Rank of 6 or 7, denoting an urban market
while three loans, representing 10.3% of the pool, is secured by
properties with a Morningstar DBRS Market Rank of 2, denoting a
tertiary urban market. In comparison, at issuance, properties in
suburban markets represented 84.1% of the collateral, properties in
tertiary and rural markets represented 12.1% of the collateral, and
properties in urban markets represented 3.9% of the collateral.

As of the July 2024 reporting, the lender had advanced cumulative
loan future funding of $65.2 million to 16 of 17 outstanding
individual borrowers to aid in property stabilization efforts. The
largest advance has been made to the borrower of the El Centro loan
($15.8 million), which is secured by the leasehold interest in a
507-unit Class A multifamily property in Hollywood, California.

The borrower's business plan focused on increasing occupancy on the
retail component by attracting new tenants with competitive tenant
improvement packages. There remains $9.4 million of future funding
available to the borrower. As of the March rent roll, the property
was 89.2% occupied, down slightly from 91.1% at closing. Based on
the T-12 financials ended February 29, 2024, the property generated
net class flow of $6.8 million equating to a debt service coverage
ratio of 0.50 times and debt yield of 4.3%. The borrower recently
exercised its final extension option, extending loan maturity to
June 2025.

An additional $25.1 million of loan future funding allocated to 12
of the outstanding individual borrowers remains available. The
largest portion of available funds is allocated to the borrowers of
the aforementioned El Centro loan ($9.4 million) and GVA Sunrise
Portfolio Pool C loan (GVA; $4.3 million), which is secured by a
portfolio of five cross collateralized, garden-style multifamily
properties, totaling 1,670 units located across five states. The
loan was recently modified in June 2024, extending loan maturity to
March 2025 and deferring a portion interest until maturity.
Additionally, Leste Group, which previously served as GVA's equity
partner, will replace GVA as loan sponsor and inject $13.1 million
of equity to fund various reserves as well as reducing the loan
balance by $6.5 million. In its analysis, Morningstar DBRS applied
upward as-is and as-stabilized LTV adjustments resulting in an
expected loss slightly above the pool average.

As of the July 2024 remittance, there are no delinquent loans or
loans in special servicing, and there are two loans (Parcland
Crossing and GVA) on the servicer's watchlist flagged for upcoming
maturities; however, the maturity date on both loans was recently
extended.

Six loans, representing 18.2% of the current cumulative trust loan
balance, have been modified. The modified loans include Elan
Heights, 1000 West Apartments, Elan Crockett Row, Parcland
Crossing, Skyline MHP, and Pillar at Westgate. In general, the
modifications resulted in the waivers of interest rate cap
requirements, prepayment penalties, and increasing renovation
budgets. In exchange, borrowers have been required to make
principal curtailment payments on loans or deposit additional
dollars into existing reserves.

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


M&T EQUIPMENT 2023-LEAF1: DBRS Confirms BB Rating on E Notes
------------------------------------------------------------
DBRS, Inc. confirmed five and upgraded two credit ratings from M&T
Equipment (2023-LEAF1), LLC.

  Debt                 Rating        Action
  ----                 ------        ------
  Class A-2 Notes      AAA(sf)       Confirmed
  Class A-3 Notes      AAA(sf)       Confirmed
  Class A-4 Notes      AAA(sf)       Confirmed
  Class B Notes        AA(high)sf    Upgraded
  Class C Notes        A(high)(sf)   Upgraded
  Class D Notes        BBB(sf)       Confirmed
  Class E Notes        BB(sf)        Confirmed

The credit rating actions are based on the following analytical
considerations:

-- Losses are tracking above Morningstar DBRS' initial base case
CNL expectation. However, due to the transaction structure, credit
enhancement has increased for all classes mitigating the weaker
than expected collateral performance. The current level of hard
credit enhancement is sufficient to support the Morningstar DBRS'
projected remaining cumulative net loss assumption at a multiple of
coverage commensurate with the credit ratings.

-- The currently available hard credit enhancement in the form of
overcollateralization, subordination (as applicable), and amounts
of deposit in the cash reserve account.

-- The relative benefit from obligor and geographic
diversification of collateral pools.

-- The transaction parties' capabilities with regard to
origination, underwriting, and servicing.

-- The transaction assumptions consider Morningstar DBRS's
baseline macroeconomic scenarios for rated sovereign economies,
available in its commentary Baseline Macroeconomic Scenarios For
Rated Sovereigns - June 2024 Update, published on June 28, 2024.
These baseline macroeconomic scenarios replace Morningstar DBRS's
moderate and adverse COVID-19 pandemic scenarios, which were first
published in April 2020.

Morningstar DBRS' credit rating on the securities referenced herein
addresses the credit risk associated with the identified financial
obligations in accordance with the relevant transaction documents.
The associated financial obligations for each of the rated notes
are the related Note Current Interest and the related Outstanding
Note Balance.

Morningstar DBRS' credit rating does not address non-payment risk
associated with contractual payment obligations contemplated in the
applicable transaction document(s) that are not financial
obligations. The associated contractual payment obligations that
are not financial obligations are interest on unpaid Note Interest
for each of the rated notes and the related Optional Redemption
Price.

Morningstar DBRS' long-term credit ratings provide opinions on risk
of default. Morningstar DBRS considers risk of default to be the
risk that an issuer will fail to satisfy the financial obligations
in accordance with the terms under which a long-term obligation has
been issued.


MADISON PARK XXXII: Fitch Assigns 'BB+sf' Rating on Cl. E-R2 Notes
------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to Madison
Park Funding XXXII, Ltd. reset transaction.

   Entity/Debt            Rating               Prior
   -----------            ------               -----
Madison Park
Funding XXXII, Ltd.

   A-1-R 55817AAN4    LT PIFsf  Paid In Ful    AAAsf
   A-1-R2             LT AAAsf  New Rating
   A-2-R 55817AAQ7    LT PIFsf  Paid In Full   AAAsf
   A-2-R2             LT AAAsf  New Rating
   B-R2               LT AA+sf  New Rating
   C-R2               LT A+sf   New Rating
   D-1                LT BBB+sf New Rating
   D-2                LT BBBsf  New Rating
   D-3                LT BBB-sf New Rating
   E-R2               LT BB+sf  New Rating
   F                  LT NRsf   New Rating

Transaction Summary

Madison Park Funding XXXII, Ltd. (the issuer) is an arbitrage cash
flow collateralized loan obligation (CLO) managed by UBS Asset
Management (Americas) LLC that originally closed in January 2019,
and refinanced on the first refinancing date in March 2021. The
secured notes will be refinanced in full on the second refinancing
date (Aug. 9, 2024). Net proceeds from the issuance of the secured
and subordinated notes will provide financing on a portfolio of
approximately $796 million of primarily first lien senior secured
leveraged loans, excluding defaults.

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. Issuers rated in the 'B' rating category denote a
highly speculative credit quality; however, the notes benefit from
appropriate credit enhancement and standard CLO structural
features.

Asset Security (Positive): The indicative portfolio consists of
96.65% first-lien senior secured loans and has a weighted average
recovery assumption of 74.36%. Fitch stressed the indicative
portfolio by assuming a higher portfolio concentration of assets
with lower recovery prospects and further reduced recovery
assumptions for higher rating stresses.

Portfolio Composition (Positive): The largest three industries may
comprise up to 41% 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
CLOs.

Portfolio Management (Neutral): The transaction has a five-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting 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, the rated notes can
withstand default and recovery assumptions consistent with their
assigned ratings.

The weighted average life (WAL) used for the transaction stress
portfolio is 12 months less than the WAL covenant to account for
structural and reinvestment conditions after the reinvestment
period. In Fitch's opinion, these conditions would reduce the
effective risk horizon of the portfolio during stress periods.

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 as
severe as between 'BBB+sf' and 'AA+sf' for class A-1-R2, between
'BBB+sf' and 'AA+sf' for class A-2-R2, between 'BB+sf' and 'AA-sf'
for class B-R2, between 'B+sf' and 'BBB+sf' for class C-R2, between
less than 'B-sf' and 'BBB-sf' for class D-1, between less than
'B-sf' and 'BB+sf' for class D-2, between less than 'B-sf' and
'BB+sf' for class D-3, and between less than 'B-sf' and 'BBsf' for
class E-R2.

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

Upgrade scenarios are not applicable to the class A-1-R2 and class
A-2-R2 notes as these notes are in the highest rating category of
'AAAsf'.

For the other Fitch-rated notes, 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; the
minimum rating results under these sensitivity scenarios are
'AAAsf' for class B-R2, 'AA+sf' for class C-R2, 'A+sf' for class
D-1, 'A+sf' for class D-2, 'A+sf' for class D-3, and 'BBB+sf' for
class E-R2.

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

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

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 its rating analysis according to its applicable rating
methodologies indicates that it is adequately reliable.

ESG Considerations

Fitch does not provide ESG relevance scores for Madison Park
Funding XXXII, Ltd. In cases where Fitch does not provide ESG
relevance scores in connection with the credit rating of a
transaction, programme, instrument or issuer, Fitch will disclose
in the key rating drivers any ESG factor which has a significant
impact on the rating on an individual basis.


MARINER FINANCE 2024-A: DBRS Finalizes BB(low) Rating on E Notes
----------------------------------------------------------------
DBRS, Inc. finalized its provisional credit rating on the following
classes of notes (collectively, the Notes) issued by Mariner
Finance Issuance trust 2024-A (MFIT 2024-A):

-- $270,670,000 Class A Notes at AAA (sf)
-- $52,230,000 Class B Notes at AA (low) (sf)
-- $28,490,000 Class C Notes at A (low) (sf)
-- $33,240,000 Class D Notes at BBB (low) (sf)
-- $40,370,000 Class E Notes at BB (low) (sf)

CREDIT RATING RATIONALE/DESCRIPTION

The credit ratings are based on Morningstar DBRS' review of the
following analytical considerations:

(1) The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary Baseline Macroeconomic Scenarios For Rated
Sovereigns: June 2024 Update, published on June 28, 2024. These
baseline macroeconomic scenarios replace Morningstar DBRS' moderate
and adverse COVID-19 pandemic scenarios, which were first published
in April 2020.

(2) Transaction capital structure and form and sufficiency of
available credit enhancement.

-- Credit enhancement is in the form of OC, subordination, amounts
held in the reserve fund, and excess spread. Credit enhancement
levels are sufficient to support Morningstar DBRS' stressed
assumptions under all stress scenarios.

(3) The ability of the transaction to withstand stressed cash flow
assumptions and repay investors according to the terms under which
they have invested. For this transaction, the credit ratings
address the timely payment of interest on a monthly basis and
principal by the legal final maturity date.

(4) Mariner's capabilities with regard to originations,
underwriting, and servicing.

-- Morningstar DBRS performed an operational review of Mariner
and, as a result, considers the entity to be an acceptable
originator and servicer of personal loans.

-- Mariner's senior management team has considerable experience
and a successful track record within the consumer loan industry.

(5) The credit quality of the collateral and performance of
Mariner's consumer loan portfolio. Morningstar DBRS used a hybrid
approach in analyzing Mariner's portfolio that incorporates
elements of static pool analysis, employed for assets such as
consumer loans, and revolving loan analysis to account for renewal
loans. As of the Statistical Cut-Off Date:

-- The weighted-average (WA) remaining term of the collateral pool
is approximately 39 months.

-- The WA coupon (WAC) of the pool is 26.43% and the transaction
includes a reinvestment criteria event that the WAC is less than
24.50%. All loans going into the pool will have an APR less than
36.00%.

-- CPR rates for Mariners' portfolio, as estimated by Morningstar
DBRS, have generally averaged between 8.0% and 14.0% since 2014
depending on product type.

-- The Morningstar DBRS base-case assumption for CPR is 6.0%.

-- Charge-off rates on the Mariner portfolio have generally ranged
between 9.00% and 15.00% over the past several years.

-- The Morningstar DBRS base-case assumption for the charge-off
rate is 12.81% which is based on the MFIT 2024-A reinvestment
criteria and recent credit performance.

-- For this transaction, Morningstar DBRS assumed an overall
recovery rate of 5.75% which based on historical recovery
performance which varies by product type, with assumptions ranging
from 5.00% to 7.50%.

(6) Mariner is currently subject to a complaint filed against it by
eleven attorneys generals. The complaint initially filed by the
Eastern District of Pennsylvania by the attorneys general for
Pennsylvania, the District of Columbia, New Jersey, Oregon, Utah,
and Washington alleges certain unfair and deceptive acts and
practices by Mariner. Specifically, in relation to its sale of
optional loan products, refinancing practices and LBM products. On
October 17, 2022, the state of Utah voluntarily withdrew from the
matter. On March 22, 2024 six additional states joined the lawsuit
and did not add any additional claims to the litigation. The
attorneys generals seek to enjoin Mariner's conduct, and seek
penalties, restitution to borrowers and rescission and/or
reformation of borrower agreements. On January 12, 2024, the court
denied Mariner's motion to dismiss. On January 26, 2024, Mariner
filed its answer to the complaint, denying any and all allegations
of unlawful or deceptive business practices, or that it engaged in
any of the wrongdoing alleged in the complaint. The ongoing
litigation remains in the discovery phase. To the extent it is
determined that the Loans were not originated in accordance with
all applicable laws, the relevant Sellers may be obligated to
repurchase from the Issuer.

(7) The legal structure and presence of legal opinions that address
the true sale of the assets from the Seller to the Depositor, the
non-consolidation of the special-purpose vehicle with the Seller,
that the Indenture Trustee has a valid first-priority security
interest in the assets, and the expected consistency with the
Morningstar DBRS Legal Criteria for U.S. Structured Finance.

Morningstar DBRS' credit ratings on the securities referenced
herein address the credit risk associated with the identified
financial obligations in accordance with the relevant transaction
documents. The associated financial obligations for each of the
rated Notes are the related Monthly Interest Amount and the related
Note Balance.

Notes: All figures are in US Dollars unless otherwise noted.


OAKTREE CLO 2019-2: S&P Assigns Prelim BB-(sf) Rating on D-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1aRR, A-2RR, B-RR, C-R, and D-R replacement debt from Oaktree CLO
2019-2 Ltd./Oaktree CLO 2019-2 LLC, a CLO which was first
refinanced in April 2021 and originally issued in May 2019. S&P
Global Ratings is not assigning a rating to the class A-1b-RR debt.
The transaction is managed by Oaktree Capital Management L.P.

The preliminary ratings are based on information as of Aug. 16,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 15, 2024, second refinancing date, the proceeds from
the replacement debt will be used to redeem the existing debt. S&P
said, "At that time, we expect to withdraw our ratings on the
existing debt and assign ratings to the replacement debt. However,
if the refinancing doesn't occur, we may affirm our ratings on the
existing debt and withdraw our preliminary ratings on the
replacement debt."

The replacement debt will be issued via a supplemental indenture,
which outlines the terms of the replacement debt. According to the
proposed supplemental indenture:

-- The non-call period will be extended to Oct. 15, 2026.

-- The reinvestment period will be extended to Oct. 15, 2029.

-- The legal final maturity dates (for the replacement debt and
the existing subordinated notes) will be extended to Oct. 15, 2037,
provided that the class A-1aRR note stated maturity is Oct 15,
2036.

-- No additional assets will be purchased on the Oct. 15, 2024,
refinancing date, and the target initial par amount will decrease
to $470 million.

-- There will be no additional effective date or ramp-up period,
and the first payment date following the refinancing is Jan. 15,
2025.

-- The required minimum overcollateralization ratios will be
amended.

-- On the refinancing date, $26 million in additional subordinated
notes will be issued.

Replacement And Existing Debt Issuances

Replacement debt

-- Class A-1aRR, $289.00 million: Three-month CME term SOFR +
1.40%

-- Class A-1bRR, $30.50 million: Three-month CME term SOFR +
1.65%

-- Class A-2RR, $37.75 million: Three-month CME term SOFR + 1.80%

-- Class B-RR (deferrable), $28.25 million: Three-month CME term
SOFR + 2.25%

-- Class C-R (deferrable), $28.25 million: Three-month CME term
SOFR + 3.25%

-- Class D-R (deferrable), $18.75 million: Three-month CME term
SOFR + 7.50%

-- Additional subordinated notes, $26.00 million: Not applicable

Existing debt

-- Class A-1aR, $280.38 million: Three-month CME term SOFR +
1.38%

-- Class A-1bR, $27.50 million: Three-month CME term SOFR + 1.71%

-- Class A-2R, $55.00 million: Three-month CME term SOFR + 1.96%

-- Class BR (deferrable), $30.00 million: Three-month CME term
SOFR + 2.96%

-- Class C (deferrable), $28.75 million: Three-month CME term SOFR
+ 4.22%

-- Class D (deferrable), $28.75 million: Three-month CME term SOFR
+ 7.03%

-- Subordinated notes, $47.20 million: Not applicable

The proposed refinancing will be the first refinancing of the class
C and D debt.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults, and
recoveries upon default, under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Preliminary Ratings Assigned

  Oaktree CLO 2019-2 Ltd./Oaktree CLO 2019-2 LLC

  Class A-1aRR, $289.00 million: AAA (sf)
  Class A-2RR, $37.75 million: AA (sf)
  Class B-RR (deferrable), $28.25 million: A (sf)
  Class C-R (deferrable), $28.25 million: BBB- (sf)
  Class D-R (deferrable), $18.75 million: BB- (sf)

  Other Debt

  Oaktree CLO 2019-2 Ltd./Oaktree CLO 2019-2 LLC

  Class A-1bRR, $30.50 million: Not Rated

  Subordinated notes, $73.20 million: Not rated



OAKTREE CLO 2024-27: S&P Assigns Prelim BB- (sf) Rating on E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Oaktree CLO
2024-27 Ltd./Oaktree CLO 2024-27 LLC's floating-rate debt.

The debt 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 Oaktree CLO Management Co. LLC.

The preliminary ratings are based on information as of Aug. 20,
2024. 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

  Oaktree CLO 2024-27 Ltd./Oaktree CLO 2024-27 LLC

  Class A-1, $240.00 million: AAA (sf)
  Class A-2, $32.00 million: AAA (sf)
  Class B, $32.00 million: AA (sf)
  Class C (deferrable), $24.00 million: A (sf)
  Class D-1 (deferrable), $24.00 million: BBB- (sf)
  Class D-2 (deferrable), $4.00 million: BBB- (sf)
  Class E (deferrable), $12.00 million: BB- (sf)
  Subordinated notes, $38.90 million: Not rated



OCP CLO 2020-18: S&P Assigns BB- (sf) Rating on Class E-R2 Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-1R2, A-2R2,
B-1R2, B-2R2, C-R2, D-1R2, D-2R2, and E-R2 replacement debt from
OCP CLO 2020-18 Ltd./OCP CLO 2020-18 LLC, a CLO managed by Onex
Credit Partners LLC that was originally issued in May 2020 and
underwent a previous refinancing in May 2021. At the same time, S&P
withdrew its ratings on the class A-R, B-R, C-R, D-R, and E-R debt
(May 2021 debt) following payment in full on the Aug. 20, 2024,
refinancing date.

The replacement debt was issued via a supplemental indenture, which
outlined the terms of the replacement debt. According to the
supplemental indenture:

-- The non-call period was extended to July 20, 2026.

-- The reinvestment period was extended to July 20, 2029.

-- The legal final maturity dates (for the replacement debt and
the existing preference shares) were extended to July 20, 2037.

-- The target initial par amount remained at $400.00 million.
There was no additional effective date or ramp-up period, and the
first payment date following the second refinancing is Jan. 20,
2025.

-- The required minimum overcollateralization and interest
coverage ratios were amended.

-- Additional preference shares with a notional balance of $25.11
million were issued on the second refinancing date.

-- The transaction has adopted benchmark replacement language and
was updated to conform to current rating agency methodology.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis (and other qualitative factors, as applicable)
demonstrated, in our view, that the outstanding rated classes all
have adequate credit enhancement available at the rating levels
associated with the rating actions.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Ratings Assigned

  OCP CLO 2020-18 Ltd./OCP CLO 2020-18 LLC

  Class A-1R2, $256.00 million: AAA (sf)
  Class A-2R2, $6.00 million: AAA (sf)
  Class B-1R2, $30.00 million: AA+ (sf)
  Class B-2R2, $12.00 million: AA+ (sf)
  Class C-R2 (deferrable), $24.00 million: A+ (sf)
  Class D-1R2 (deferrable), $24.00 million: BBB- (sf)
  Class D-2R2 (deferrable), $4.00 million: BBB- (sf)
  Class E-R2 (deferrable), $12.00 million: BB- (sf)

  Ratings Withdrawn

  OCP CLO 2020-18 Ltd./OCP CLO 2020-18 LLC

  Class A-R to NR from 'AAA (sf)'
  Class B-R to NR from 'AA (sf)'
  Class C-R (deferrable) to NR from 'A (sf)'
  Class D-R (deferrable) to NR from 'BBB- (sf)'
  Class E-R (deferrable) to NR from 'BB- (sf)'

  Other Debt

  OCP CLO 2020-18 Ltd./OCP CLO 2020-18 LLC

  Preference shares(i), $79.95 million: NR

(i)The notional amount of preference shares increased to $79.95
million from $54.84 in connection with this second refinancing.
NR--Not rated.



OCP CLO 2022-24: S&P Assigns Prelim BB- (sf) Rating on E-R Notes
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1R, A-2R, B-1R, B-2R, C-R, D-1R, D-2R, and E-R replacement debt
from OCP CLO 2022-24 Ltd./OCP CLO 2022-24 LLC, a CLO originally
issued in June 2022 that is managed by Onex Credit Partners LLC.

The preliminary ratings are based on information as of Aug. 20,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Aug. 27, 2024, refinancing date, the proceeds from the
replacement debt will be used to redeem the original debt. S&P
said, "At that time, we expect to withdraw our ratings on the
original debt and assign ratings to the replacement debt. However,
if the refinancing doesn't occur, we may affirm our ratings on the
original debt withdraw our preliminary ratings on the replacement
debt."

The replacement debt will be issued via a proposed supplemental
indenture, which outlines the terms of the replacement debt.
According to the proposed supplemental indenture:

-- The non-call period will be extended to Aug. 27, 2026.

-- The reinvestment period will be extended to Aug. 27, 2029.

-- The legal final maturity dates will be extended to Oct. 20,
2037.

-- The target initial par amount will remain at $400.00 million.
There will be no additional effective date or ramp-up period, and
the first payment date will be Oct. 21, 2024.

-- The required minimum overcollateralization ratios will be
amended.

S&P said, "Our review of this transaction included a cash flow
analysis, based on the portfolio and transaction data in the
trustee report, to estimate future performance. In line with our
criteria, our cash flow scenarios applied forward-looking
assumptions on the expected timing and pattern of defaults and the
recoveries upon default under various interest rate and
macroeconomic scenarios. Our analysis also considered the
transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis (and other qualitative factors, as applicable)
demonstrated, in our view, that the outstanding rated classes all
have adequate credit enhancement available at the rating levels
associated with the rating actions.

"We will continue to review whether, in our view, the ratings
assigned to the debt remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Preliminary Ratings Assigned

  OCP CLO 2022-24 Ltd./OCP CLO 2022-24 LLC

  Class A-1R, $256.00 million: AAA (sf)
  Class A-2R, $8.00 million: AAA (sf)
  Class B-1R, $30.00 million: AA (sf)
  Class B-2R, $10.00 million: AA (sf)
  Class C-R (deferrable), $24.00 million: A (sf)
  Class D-1R (deferrable), $24.00 million: BBB (sf)
  Class D-2R (deferrable), $4.00 million: BBB- (sf)
  Class E-R (deferrable), $12.00 million: BB- (sf)

  Other Debt

  OCP CLO 2022-24 Ltd./OCP CLO 2022-24 LLC
  
  Subordinated notes, $42.15 million: Not rated



OCP CLO 2024-34: S&P Assigns BB- (sf) Rating on Class E Notes
-------------------------------------------------------------
S&P Global Ratings assigned its ratings to OCP CLO 2024-34 Ltd./OCP
CLO 2024-34 LLC's floating-rate debt.

The debt 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 Onex Credit Partners LLC.

The ratings reflect S&P's view of:

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

-- 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.

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

  Ratings Assigned

  OCP CLO 2024-34 Ltd. /OCP CLO 2024-34 LLC

  Class A-1, $416.00 million: AAA (sf)
  Class A-2, $13.00 million: AAA (sf)
  Class B, $65.00 million: AA (sf)
  Class C (deferrable), $39.00 million: A (sf)
  Class D-1 (deferrable), $39.00 million: BBB- (sf)
  Class D-2 (deferrable), $6.50 million: BBB- (sf)
  Class E (deferrable), $22.75 million: BB- (sf)
  Preferred Shares, $6.04 million: Not rated
  Subordinated notes, $54.36 million: Not rated



OPORTUN ISSUANCE 2021-C: DBRS Confirms BB(high) Rating on D Notes
-----------------------------------------------------------------
DBRS, Inc. confirmed four credit ratings from Oportun Issuance
Trust 2021-C.

Debt            Rating          Action
----            ------          ------
Class A Notes   AA(low)(sf)     Confirmed
Class B Notes   A(low)(sf)      Confirmed  
Class C Notes   BBB(low)(sf)    Confirmed
Class D Notes   BB(high)(sf)    Confirmed

The credit rating actions are based on the following analytical
considerations:

-- The credit rating actions are the result of transaction
performance to date.

-- The transaction capital structure and form and sufficiency of
available credit enhancement.

-- The transaction parties' capabilities with regard to
originating, underwriting, and servicing.

-- The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary, "Baseline Macroeconomic Scenarios for Rated
Sovereigns June 2024 Update," published on June 28, 2024. These
baseline macroeconomic scenarios replace Morningstar DBRS' moderate
and adverse coronavirus pandemic scenarios, which were first
published in April 2020.


ORIGEN MANUFACTURED 2002-A:S&P Affirms CCC(sf) Rating on M-2 Notes
------------------------------------------------------------------
S&P Global Ratings raised its ratings on five classes from Green
Tree Financial Corp. Manufactured Housing Trust 1996-4, 1996-5,
1997-4, and 1997-6 and Origen Manufactured Housing Contract Trust
2007-B. At the same time, we affirmed our rating on one class from
Origen Manufactured Housing Contract Sr/Sub Asset-Backed Certs
Series 2002-A.

The transactions are backed by collateral pools of manufactured
housing loans that are currently serviced by Shellpoint Mortgage
Servicing (a division of Newrez LLC).

The rating actions reflect each transaction's collateral
performance to date, our expectations regarding future collateral
performance, the transactions' structures and credit enhancement
levels compared with our expected remaining losses, and other
credit factors, including our most recent macroeconomic outlook
that incorporates a baseline forecast for U.S. GDP and
unemployment.

  Table 1

  Collateral performance (%)

  As of the July 2024 distribution date

                              Pool   Current   60+ day
  Series              Mo.   factor       CNL   delinq.

  Green Tree 1996-4   339     0.64     17.18      7.32
  Green Tree 1996-5   338     0.68     17.43      5.50
  Green Tree 1997-4   326     1.25     17.98      2.38
  Green Tree 1997-6   323     1.35     17.56      4.48
  Origen 2002-A       269     4.73     29.54      1.99
  Origen 2007-B       202     3.76     16.83      1.88

Green Tree--Green Tree Financial Corp. Manufactured Housing Trust.
Origen
2002-A--Origen Manufactured Housing Contract Sr/Sub Asset-Backed
Certs Series 2002-A.
Origen 2007-B--Origen Manufactured Housing Contract Trust 2007-B.
Mo.--Month.
CNL--Cumulative net loss.
Delinq.--Delinquencies.

  Table 2

  CNL Expectations for Green Tree Financial Corp. Manufactured   
  Housing Trust transactions (%)

                  Prior revised   Revised lifetime
  Series      lifetime CNL exp.(i)        CNL exp.(ii)

  1996-4            17.50-18.00        17.40-17.60
  1996-5            17.75-18.25        17.65-17.85
  1997-4            18.75-19.25        18.40-18.60
  1997-6               N/A(iii)        17.75-18.25

(i)As of August 2023.
(ii)As of August 2024.
(iii)Losses were previously not
applicable, as there was no enhancement available to the rated
class.

  Table 3

  CNL Expectations for Origen Manufactured Housing transactions
(%)

                  Prior revised   Revised lifetime
  Series       lifetime CNL exp.(i)       CNL exp.(ii)

  2002-A                  31.25        31.00-31.50
  2007-B                  18.75        17.75-18.25

(i)As of November 2023.
(ii) As of August 2024.

The raised and affirmed ratings reflect our view that hard credit
support, as a percentage of the amortizing pool balance and
compared with our expected remaining losses, is commensurate with
the respective ratings.

As defined in our criteria, 'CCC+ (sf)', 'CCC (sf)', and 'CCC-
(sf)' ratings reflect our view that the related classes are
vulnerable to nonpayment and are dependent upon favorable business,
financial, and economic conditions in order to be paid interest
and/or principal according to the terms of each transaction.
Additionally, the 'CC (sf)' ratings reflect our view that the
related classes remain virtually certain to defaul.


  RATINGS RAISED

  Green Tree Financial Corp. Manufactured Housing Trust

                       Rating
  Series   Class   To          From

  1996-4   M-1     CCC (sf)    CCC- (sf)
  1996-5   M-1     CCC (sf)    CCC- (sf)
  1997-4   M-1     CCC (sf)    CCC- (sf)
  1997-6   M-1     CCC- (sf)   CC (sf)

  Origen Manufactured Housing Contract Trust 2007-B

  Class   To       From

  A       B (sf)   CCC (sf)

  RATING AFFIRMED

  Origen Manufactured Housing Contract Sr/Sub Asset-Backed Certs
Series 2002-A

  Class   Rating

  M-2     CCC (sf)




PIONEER AIRCRAFT: Fitch Hikes Rating on Series C Notes to 'CCC+sf'
------------------------------------------------------------------
Fitch Ratings has upgraded Pioneer Aircraft Finance Limited series
A, B and C notes to 'BBBsf', 'B+sf' and 'CCC+sf' from 'BBB-sf',
'Bsf' and 'CCCsf', respectively. The series A and B Rating Outlook
is Stable. Series C has been assigned a Stable Outlook.

   Entity/Debt              Rating           Prior
   -----------              ------           -----
Pioneer Aircraft
Finance Limited

   Series A 72353PAA4   LT BBBsf  Upgrade    BBB-sf
   Series B 72353PAB2   LT B+sf   Upgrade    Bsf
   Series C 72353PAC0   LT CCC+sf Upgrade    CCCsf

Transaction Summary

The ratings reflect current transaction performance, Fitch's cash
flow projections, and its expectation for the structure to
withstand stress scenarios commensurate with their respective
ratings within the framework of Fitch's criteria and modeling. The
rating actions also consider lease terms, lessee credit quality and
performance, updated aircraft values, and Fitch's assumptions and
stresses, which inform Fitch's modeled cash flows and coverage
levels. Fitch's updated airline rating assumptions are based on a
variety of performance metrics and airline characteristics.

Portfolio performance has improved and stabilized. While some
lessee delinquencies remain, they have improved since last review.
The series A and B notes continued to receive timely interest,
whereas series C interest is capitalizing. The series A principal
shortfall, relative to schedule, has improved marginally versus the
prior review. Proceeds from an aircraft sale in April 2024 were
used to pay down the series A notes. The series B and C notes have
fallen further behind their scheduled principal balances. The sale
of the aircraft along with the value ascribed to the remaining
aircraft in the pool has resulted in LTVs similar to the prior
review.

Overall Market Recovery: Demand for air travel remains robust.
Total passenger traffic is above 2019 levels with June revenue
passenger kilometers (RPKs) up 9.1% compared to June 2023, per the
International Air Transport Association (IATA). International
traffic led the way with 12.3% yoy RPK growth while domestic
traffic grew 4.3% yoy. Asia Pacific led overall growth in traffic.

Aircraft Collateral & Asset Value/Valuation: Aircraft ABS
transaction servicers are reporting strong demand and increased
lease rates for aircraft, particularly those with maintenance green
time remaining. Values of current generation narrowbodies (NEOs and
Maxs) have recovered. Demand for A320CEOs and 737-800s,
particularly those in good maintenance condition, has materially
strengthened. A320CEOs (10 aircraft) and 737-800s (four aircraft)
make up approximately 55% and 21% of the pool by value
respectively. The remainder of the pool consists of one 737-900ER
(7% of value) and one 2017 year of manufacture 787-8 (17% of
value).

Fitch is also seeing meaningful improvement in sales proceeds for
aircraft approaching the end of their leasable lives. Additionally,
appraiser market values are currently higher than base values for
many aircraft types, which previously had not occurred for several
years.

Macro Risks: While the commercial aviation market has recovered
significantly over the past 12 months, it will continue to face
risks, including workforce shortages, supply chain issues,
geopolitical risks, and recessionary concerns that would impact
passenger demand. In addition, there remains uncertainty regarding
inflationary pressures despite some improvements. Most of these
events would lead to greater credit risk due to increased lessee
delinquencies, lease restructurings, defaults, and reductions in
lease rates and asset values, particularly for older aircraft. All
of these factors would cause downward pressure on future cash flows
needed to meet debt service.

KEY RATING DRIVERS

Asset Values: The Fitch value for the pool is $384 million. Fitch
used the most recent appraisal as of December 2023 and applied
depreciation and market value decline assumptions pursuant to
Fitch's criteria. Fitch employs a methodology whereby Fitch varies
the type of value per aircraft based on the remaining leasable
life:

3 years of Leasable Life, but >15 years old --
Maintenance-adjusted base value;




PRET TRUST 2024-RPL2: Fitch Assigns 'B(EXP)sf' Rating on B-2 Notes
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
the residential mortgage-backed notes to be issued by PRET
2024-RPL2 Trust (PRET 2024-RPL2).

   Entity/Debt         Rating           
   -----------         ------           
PRET 2024-RPL2

   A-1             LT AAA(EXP)sf  Expected Rating
   A-2             LT  AA(EXP)sf  Expected Rating
   A-3             LT AA(EXP)sf   Expected Rating
   A-4             LT A(EXP)sf    Expected Rating
   A-5             LT BBB(EXP)sf  Expected Rating
   M-1             LT A(EXP)sf    Expected Rating
   M-2             LT BBB(EXP)sf  Expected Rating
   SA              LT NR(EXP)sf   Expected Rating
   B-1             LT BB(EXP)sf   Expected Rating
   B-2             LT B(EXP)sf    Expected Rating
   B-3             LT NR(EXP)sf   Expected Rating
   B-4             LT NR(EXP)sf   Expected Rating
   B-5             LT NR(EXP)sf   Expected Rating
   B               LT NR(EXP)sf   Expected Rating
   X               LT NR(EXP)sf   Expected Rating
   PT              LT NR(EXP)sf   Expected Rating
   R               LT NR(EXP)sf   Expected Rating
   CERT            LT NR(EXP)sf   Expected Rating
   RISKRETEN       LT NR(EXP)sf   Expected Rating

Transaction Summary

The PRET 2024-RPL2 notes are supported by 2,190 seasoned performing
and reperforming loans (RPLs) that had a balance of $409.73 million
as of the July 31, 2024 cutoff date.

The notes are secured by a pool of fixed, step-rate and
adjustable-rate mortgage (ARM) loans, some of which have an initial
interest-only (IO) period, that are primarily fully amortizing with
original terms to maturity of 30 years. The loans are secured by
first liens primarily on single-family residential properties,
townhouses, condominiums, co-ops, manufactured housing, multifamily
homes, and raw land.

In the pool, 100% of the loans are seasoned performing and
re-performing loans. Of the loans, 87.0% are exempt from the
qualified mortgage (QM) rule as they are investment properties or
were originated prior to the Ability to Repay (ATR) rule taking
effect in January 2014.

Selene Finance LP (Selene) will service 100.0% of the loans in the
pool; Fitch rates Selene 'RPS3+'.

There is London Interbank Offered Rate (Libor) exposure in this
transaction. The majority of the loans in the collateral pool
comprise fixed-rate mortgages, though 9.9% of the pool comprises
step-rate loans or loans with an adjustable rate. Of the pool, 5.9%
consists of ARM loans that reference the six-month or one-year
Libor index.

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 12.1% above a long-term sustainable level (vs.
11.5% on a national level as of 1Q24, up 0.4% since the prior
quarter). Housing affordability is the worst it has been in decades
driven by both high interest rates and elevated home prices. Home
prices increased 5.9% YoY nationally as of May 2024 despite modest
regional declines but are still being supported by limited
inventory.

Seasoned and Reperforming Credit Quality (Mixed): The collateral
consists of 2,190 loans, totaling $409.73 million, which includes
deferred amounts. The loans are seasoned approximately 187 months
in aggregate, according to Fitch, as calculated from origination
date (182 months per the transaction documents). Specifically, the
pool comprises 90.1% fully amortizing fixed-rate loans, 6.9% fully
amortizing ARM loans, and 3.0% STEP loans that were treated as ARM
loans.

The borrowers have a moderate credit profile, with a 653 Fitch
model FICO score (655 FICO per the transaction documents). The
transaction has a weighted average (WA) sustainable loan to value
(sLTV) ratio of 56.8%, as determined by Fitch. The debt to income
ratio (DTI) was not provided for the loans in the transaction as a
result, Fitch applied a 45% DTI to all loans.

According to Fitch, the pool consists of 83.5% of loans where the
borrower maintains a primary residence, while 16.5% consists of
loans for investor properties or second homes. For loans with an
unknown occupancy, Fitch treated these loans as investor
properties. In Fitch's analysis, Fitch considered, 13.0% of the
loans to be non-QM loans and 0.03% to be safe-harbor QM loans,
while the remaining 87.0% were considered to be exempt from QM
status. In its analysis, Fitch considered loans originated after
January 2014 to be non-QM since they are no longer eligible to be
in government-sponsored enterprise (GSE) pools.

In Fitch's analysis, 82.6% of the loans are to single-family homes,
townhouses, and planned unit developments (PUDs), 7.5% are to
condos or coops, 9.9% are to manufactured housing or multifamily
homes, and less than 0.1% are for land. In the analysis, Fitch
treated manufactured properties as multifamily and the probability
of default (PD) was increased for these loans as a result.

The pool contains 22 loans over $1.0 million, with the largest loan
at $6.32 million. Based on the transaction documents 0.0% of the
loans have subordinate financing, however based on the due
diligence findings, Fitch considered 3.3% of the loans to have
subordinate financing. Specifically, Fitch treated PACE loan
amounts as subordinate financing since the borrower owes this
amount and it would need to be repaid in order to maintain the lien
status. In addition, for loans missing original appraised values,
Fitch assumed these loans had an LTV of 80% and a CLTV of 100%
which further explains the discrepancy in the subordinate financing
percentages per Fitch's analysis vs per the transaction documents.
Fitch viewed all the loans in the pool to be in the first lien
position based on data provided in the tape and confirmation from
the servicer on the lien position.

Of the pool, 95.2% of the loans were current as of July 31, 2024.
Overall, the pool characteristics resemble RPL collateral;
therefore, the pool was analyzed using Fitch's RPL model, and Fitch
extended liquidation timelines as it typically does for RPL pools.

Approximately 20.2% of the pool is concentrated in California. The
largest metropolitan statistical area (MSA) concentration is in the
New York MSA at 19.0%, followed by the Los Angeles MSA at 8.3% and
the Miami MSA at 4.8%. The top three MSAs account for 32.1% of the
pool. As a result, there was no penalty applied for geographic
concentration.

Sequential Deal Structure (Positive): The transaction utilizes a
sequential payment structure with no advancing of delinquent
principal and interest (P&I) payments. The transaction is
structured with subordination to protect more senior classes from
losses and has a minimal amount of excess interest, which can be
used to repay current or previously allocated realized losses and
cap carryover shortfall amounts.

The interest and principal waterfall prioritize the payment of
interest to the A-1 and A-2 classes, which is supportive of class
A-1 receiving timely interest and class A-2 receiving ultimate if
not timely interest. Fitch considers timely interest for 'AAAsf'
rated classes and to ultimate interest for 'AAsf' to 'Bsf' category
rated classes.

The class A-1 notes have a coupon based on a fixed rate that is
capped at the net weighted average coupon (WAC) and the class A-2,
M and B notes have a coupon based on the net WAC. All expenses are
coming out of the net WAC.

Losses are allocated to classes reverse sequentially starting with
class B-5. Classes will be written down if the transaction is
undercollateralized.

No Advancing (Mixed): The servicer will not be advancing delinquent
monthly payments of P&I. Because P&I advances made on behalf of
loans that become delinquent and eventually liquidate reduce
liquidation proceeds to the trust, the loan-level loss severities
(LS) are less for this transaction than for those where the
servicer is obligated to advance P&I.

To provide liquidity and ensure timely interest will be paid to the
'AAAsf' rated classes and ultimate interest on the remaining rated
classes, principal will need to be used to pay for interest accrued
on delinquent loans. This will result in stress on the structure
and the need for additional credit enhancement (CE) compared with a
pool with limited advancing. These Structural provisions and cash
flow priorities, together with increased subordination, provide for
timely payments of interest to the 'AAAsf' rated 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 levels to assess the effect of higher MVDs for
the subject pool as well as lower MVDs, illustrated by a gain in
home prices.

This defined negative rating sensitivity analysis demonstrates how
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 42.9%, at 'AAA'. The analysis indicates 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 levels
to assess the effect of higher MVDs for the subject pool as well as
lower MVDs, illustrated by a gain in home prices.

This 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 being assigned
ratings of 'AAAsf'.

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by ProTitle and AMC. The third-party due diligence
described in Form 15E focused on the following areas: compliance
review, data integrity, servicing review and title review. The
scope of the review was consistent with Fitch's criteria. Fitch
considered this information in its analysis. Based on the results
of the 100% due diligence performed on the pool, Fitch adjusted the
expected losses.

A large portion of the loans received 'C' and 'D' grades mainly due
to missing documentation that resulted in the ability to test for
certain compliance issues. As a result, Fitch applied negative loan
level adjustments, which increased the 'AAAsf' losses by 1.25% and
are further detailed in the Third-Party Due Diligence section of
the presale.

Fitch determined there were 21 loans with material TRID issues; a
$15,500 loss severity penalty was given to loans with material TRID
issues, though this did not have any impact on the rounded losses.

A ProTitle search found outstanding liens that pre-date the
mortgage. It was confirmed the majority of these liens are retired
and nothing is owed. There are 205 loans in the pool have a total
of approximately $2,408,018 (per the 15E) in potentially superior
post origination recorded liens/judgments. In addition, there are
48 loans that have a clean title search but there may be potential
liens that could claim priority over the mortgage in the pool that
total $105,580 (per the 15E). The trust will be responsible for
these amounts. As a result, Fitch increased the loss severity by
these amounts since the trust would be responsible for reimbursing
the servicer these amounts. This did not have any impact on the
rounded losses.

Fitch received confirmation from the servicer on the current lien
status of the loans in the pool. The servicer regularly orders
these searches as part of its normal business practice and resolves
issues as they arise. No additional adjustment was made as a
result. The title report did show loans in the pool to not be in a
first lien position, but the servicer confirmed that they are in a
first lien status and that they will follow standard servicing
practices to maintain the lien position disclosed in the tape. As a
result of the valid title policy and the servicer monitoring the
lien status, Fitch treated 100% of the pool as first liens.

The custodian is actively tracking down missing documents. In the
event a missing document materially delays or prevents a
foreclosure, the sponsor will have 90 days to find the document or
cure the issue. If the loan seller cannot cure the issue or find
the missing documents, they will repurchase the loan at the
repurchase price. Due to this, Fitch only extended timelines for
missing documents.

A pay history review was conducted on a sample set of loans by AMC.
The review confirmed the pay strings are accurate, and the servicer
confirmed the payment history was accurate for all the loans. As a
result, 100% of the pool's payment history was confirmed.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the loans. The third-party due diligence was
consistent with Fitch's "U.S. RMBS Rating Criteria." The sponsor
engaged ProTitle and AMC to perform the review. Loans reviewed
under this engagement were given initial and final compliance
grades. A portion of the loans in the pool received a credit or
valuation review.

An exception and waiver report was provided to Fitch, indicating
that the pool of reviewed loans has a number of exceptions and
waivers. Fitch determined that the exceptions and waivers do
materially affect the overall credit risk of the loans; refer to
the Third-Party Due Diligence section of the presale report for
more details.

Fitch also received confirmation from the servicer that the lien
status and payment history provided in the tape is accurate per its
records. Fitch took this information into consideration in its
analysis.

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 (ASF) data layout format. The ASF data tape
layout was established with input from various industry
participants, including rating agencies, issuers, originators,
investors and others, to produce an industry standard for the
pool-level data in support of the U.S. RMBS securitization market.
The data contained in the data tape layout was populated by the due
diligence company, and no material discrepancies were noted.

ESG Considerations

PRET 2024-RPL2 has an ESG Relevance Score of '4' for Transaction
Parties and Operational Risk due to elevated operational risk,
which resulted in an increase in expected losses. The Tier 2
representations and warranties (R&W) framework with an unrated
counterparty resulted in an increase in expected losses. This has a
negative impact on the credit profile and is relevant to the
ratings in conjunction with other factors.

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


RATE MORTGAGE 2024-J2: DBRS Gives Prov. B(low) Rating on B5 Certs
-----------------------------------------------------------------
DBRS, Inc. assigned provisional credit ratings to the Mortgage
Pass-Through Certificates, Series 2024-J2 (the Certificates) to be
issued by RATE Mortgage Trust 2024-J2 (RATE 2024-J2, or the Trust)
as follows:

-- $315.3 million Class A-1 at AAA (sf)
-- $315.3 million Class A-2 at AAA (sf)
-- $315.3 million Class A-3 at AAA (sf)
-- $236.5 million Class A-4 at AAA (sf)
-- $236.5 million Class A-5 at AAA (sf)
-- $236.5 million Class A-6 at AAA (sf)
-- $189.2 million Class A-7 at AAA (sf)
-- $189.2 million Class A-8 at AAA (sf)
-- $189.2 million Class A-9 at AAA (sf)
-- $47.3 million Class A-10 at AAA (sf)
-- $47.3 million Class A-11 at AAA (sf)
-- $47.3 million Class A-12 at AAA (sf)
-- $126.1 million Class A-13 at AAA (sf)
-- $126.1 million Class A-14 at AAA (sf)
-- $126.1 million Class A-15 at AAA (sf)
-- $78.8 million Class A-16 at AAA (sf)
-- $78.8 million Class A-17 at AAA (sf)
-- $78.8 million Class A-18 at AAA (sf)
-- $39.9 million Class A-19 at AAA (sf)
-- $39.9 million Class A-20 at AAA (sf)
-- $39.9 million Class A-21 at AAA (sf)
-- $355.2 million Class A-22 at AAA (sf)
-- $355.2 million Class A-23 at AAA (sf)
-- $355.2 million Class A-24 at AAA (sf)
-- $355.2 million Class A-25 at AAA (sf)
-- $355.2 million Class A-X-1 at AAA (sf)
-- $315.3 million Class A-X-2 at AAA (sf)
-- $315.3 million Class A-X-3 at AAA (sf)
-- $315.3 million Class A-X-4 at AAA (sf)
-- $236.5 million Class A-X-5 at AAA (sf)
-- $236.5 million Class A-X-6 at AAA (sf)
-- $236.5 million Class A-X-7 at AAA (sf)
-- $189.2 million Class A-X-8 at AAA (sf)
-- $189.2 million Class A-X-9 at AAA (sf)
-- $189.2 million Class A-X-10 at AAA (sf)
-- $47.3 million Class A-X-11 at AAA (sf)
-- $47.3 million Class A-X-12 at AAA (sf)
-- $47.3 million Class A-X-13 at AAA (sf)
-- $126.1 million Class A-X-14 at AAA (sf)
-- $126.1 million Class A-X-15 at AAA (sf)
-- $126.1 million Class A-X-16 at AAA (sf)
-- $78.8 million Class A-X-17 at AAA (sf)
-- $78.8 million Class A-X-18 at AAA (sf)
-- $78.8 million Class A-X-19 at AAA (sf)
-- $39.9 million Class A-X-20 at AAA (sf)
-- $39.9 million Class A-X-21 at AAA (sf)
-- $39.9 million Class A-X-22 at AAA (sf)
-- $355.2 million Class A-X-23 at AAA (sf)
-- $355.2 million Class A-X-24 at AAA (sf)
-- $355.2 million Class A-X-25 at AAA (sf)
-- $355.2 million Class A-X-26 at AAA (sf)
-- $5.0 million Class B-1 at AA (sf)
-- $5.0 million Class B-1A at AA (sf)
-- $5.0 million Class B-X-1 at AA (sf)
-- $5.7 million Class B2 at A (low) (sf)
-- $5.7 million Class B-2A at A (low) (sf)
-- $5.7 million Class B-X-2 at A (low) (sf)
-- $1.8 million Class B-3 at BBB (low) (sf)
-- $1.1 million Class B-4 at BB (low) (sf)
-- $.9 million Class B-5 at B (low) (sf)

Classes A-X-1, A-X-2, A-X-3, A-X-4, A-X-5, A-X-6, A-X-7, A-X-8,
A-X-9, A-X-10, A-X-11, A-X-12, A-X-13, A-X-14, A-X-15, A-X-16,
A-X-17, A-X-18, A-X-19, A-X-20, A-X-21, A-X-22, A-X-23, A-X-24,
A-X-25, A-X-26, B-X-1, and B-X-2 are interest-only (IO)
certificates. The class balances represent notional amounts.

Classes A-1, A-2, A-3, A-4, A-6, A-7, A-8, A-10, A-11, A-13, A-14,
A-15, A-16, A-17, A-19, A-20, A-22, A-23, A-24, A-25, A-X-2, A-X-3,
A-X-4, A-X-5, A-X-6, A-X-7, A-X-8, A-X-11, A-X-14, A-X-15, A-X-16,
A-X-17, A-X-20, A-X-23, A-X-24, A-X-25, A-X-26, B-1, B-X-1, and B-2
are exchangeable certificates. These classes can be exchanged for
combinations of initial exchangeable certificates as specified in
the offering documents.

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

The AAA (sf) credit ratings on the Certificates reflect 4.25% of
credit enhancement provided by subordinated certificates. The AA
(sf), A (low) (sf), BBB (low) (sf), BB (low) (sf), and B (low) (sf)
credit ratings reflect 2.90%, 1.35%, 0.85%, 0.55%, and 0.30% of
credit enhancement, respectively.

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

DBRS, Inc. (Morningstar DBRS) assigned provisional ratings to RATE
Mortgage Trust 2024-J2 (RATE 2024-J2 or the Trust), a
securitization of a portfolio of first-lien, fixed-rate prime
residential mortgages funded by the issuance of the Mortgage
Pass-Through Certificates (the Certificates). The Certificates are
backed by 336 loans with a total principal balance of $370,951,808
as of the Cut-Off Date (July 1, 2024).

Guaranteed Rate, Inc. (Guaranteed Rate or GRI), as the Sponsor,
began issuing prime jumbo securitizations from its RATE shelf in
early 2021 and this transaction represents the seventh prime jumbo
RATE deal. The pool consists of fully amortizing fixed-rate
mortgages with original terms to maturity of 30 years and a
weighted-average loan age of zero months. Almost all of the pool
consists of traditional, nonagency, prime jumbo mortgage loans,
which includes loans that were underwritten using an automated
underwriting system designated by Fannie Mae (99.8%), but may be
ineligible for purchase by such agencies because of loan size.

All of the mortgage loans were originated by Guaranteed Rate.
Guaranteed Rate is also the Servicing Administrator and Sponsor of
the transaction. The loans will be serviced by ServiceMac, LLC
(ServiceMac). Morningstar DBRS did not conduct an operational risk
review of ServiceMac for this transaction. Computershare Trust
Company, N.A. will act as the Master Servicer, Securities
Administrator, and Certificate Registrar. Deutsche Bank National
Trust Company will act as the Custodian. Wilmington Savings Fund
Society, FSB will serve as Trustee.

Similar to the prior RATE securitizations, the Servicing
Administrator will fund advances of delinquent principal and
interest (P&I) on any mortgage until such loan becomes 120 days
delinquent or such P&I advances are deemed to be unrecoverable by
the Servicer or the Master Servicer (Stop-Advance Loan). The
Servicing Administrator will also fund advances in respect of
taxes, insurance premiums, and reasonable costs incurred in the
course of servicing and disposing properties.

The interest entitlements for each class in this transaction are
reduced reverse sequentially by the delinquent interest that would
have accrued on the Stop-Advance Loans. In other words, investors
are not entitled to any interest on such severely delinquent
mortgages, unless such interest amounts are recovered. The
delinquent interest recovery amounts, if any, will be distributed
sequentially to the P&I certificates.

The pool consists of fully amortizing fixed-rate mortgages (FRMs)
with original terms to maturity of 30 years and a weighted-average
(WA) loan age of zero months. Almost all of the pool consists of
traditional, nonagency, prime jumbo mortgage loans, which includes
loans that were underwritten using an automated underwriting system
(AUS) designated by Fannie Mae (99.8%), but may be ineligible for
purchase by such agencies because of loan size.

All of the mortgage loans were originated by Guaranteed Rate. 100%
of the pool will be serviced by ServiceMac, LLC (Service Mac).

Computershare Trust Company (rated BBB with a Stable trend by
Morningstar DBRS) will act as Master Servicer, Securities
Administrator and Certificate Registrar. Wilmington Savings Fund
Society, N.A. will act as Trustee. Deutsche Bank National Trust
Company will act as the Custodian.

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

The Sponsor will have the option, but not the obligation, to
repurchase any mortgage loan that becomes 90 to 120 days delinquent
under the Mortgage Bankers Association method at a price equal to
par plus interest and unreimbursed servicing advance amounts,
provided that such repurchases in aggregate do not exceed 10% of
the total principal balance as of the Cut-Off Date.

Notes: All figures are in US Dollars unless otherwise noted.


RCKT MORTGAGE 2024-CES6: Fitch Gives B(EXP) Rating on 5 Tranches
----------------------------------------------------------------
Fitch Ratings expects to rate the residential mortgage-backed notes
issued by RCKT Mortgage Trust-CES6 (RCKT 2024-CES6)

   Entity/Debt       Rating  
   -----------       ------  
RCKT 2024-CES6

   A-1A          LT  AAA(EXP)sf  Expected Rating
   A-1B          LT  AAA(EXP)sf  Expected Rating
   A-2           LT  AA(EXP)sf   Expected Rating
   A-3           LT  A(EXP)sf    Expected Rating
   M-1           LT  BBB(EXP)sf  Expected Rating
   B-1           LT  BB(EXP)sf   Expected Rating
   B-2           LT  B(EXP)sf    Expected Rating
   B-3           LT  NR(EXP)sf   Expected Rating
   A-1           LT  AAA(EXP)sf  Expected Rating
   A-4           LT  AA(EXP)sf   Expected Rating
   A-5           LT  A(EXP)sf    Expected Rating
   A-6           LT  BBB(EXP)sf  Expected Rating
   B-1A          LT  BB(EXP)sf   Expected Rating
   B-X-1A        LT  BB(EXP)sf   Expected Rating
   B-1B          LT  BB(EXP)sf   Expected Rating
   B-X-1B        LT  BB(EXP)sf   Expected Rating
   B-2A          LT  B(EXP)sf    Expected Rating
   B-X-2A        LT  B(EXP)sf    Expected Rating
   B-2B          LT  B(EXP)sf    Expected Rating
   B-X-2B        LT  B(EXP)sf    Expected Rating
   XS            LT  NR(EXP)sf   Expected Rating
   A-1L          LT  AAA(EXP)sf  Expected Rating
   R             LT  NR(EXP)sf   Expected Rating

Transaction Summary

The notes are supported by 5,816 closed-end second-lien loans with
a total balance of approximately $424.5 million as of the cutoff
date. The pool consists of closed-end second-lien mortgages
acquired by Woodward Capital Management LLC from Rocket Mortgage
LLC. Distributions of P&I and loss allocations are based on a
traditional senior-subordinate, sequential structure in which
excess cash flow can be used to repay losses or net weighted
average coupon (WAC) shortfalls.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): As a result of its
updated view on sustainable home prices, Fitch views the home price
values of this pool as 12.1% above a long-term sustainable level
(versus 11.5% on a national level as of 1Q24). Housing
affordability is at its worst levels in decades, driven by both
high interest rates and elevated home prices. Home prices had
increased 5.9% yoy nationally as of May 2024, notwithstanding
modest regional declines, but are still being supported by limited
inventory.

Prime Credit Quality (Positive): The collateral consists of 5,816
loans totaling approximately $424.5 million and seasoned at
approximately three months in aggregate as calculated by Fitch (one
month per the transaction documents) — taken as the difference
between the origination date and the cutoff date. The borrowers
have a strong credit profile, including a weighted average (WA)
Fitch model FICO score of 744; a debt-to-income ratio (DTI) of
37.8%; and moderate leverage, with a sustainable loan-to-value
ratio (sLTV) of 74.4%.

Of the pool, 99.5% consist of loans where the borrower maintains a
primary residence and 0.5% represent second homes or investor
properties, while 95.8% of loans were originated through a retail
channel. Additionally, 67.8% of loans are designated as safe harbor
qualified mortgages (SHQM), 32.2% are higher-priced qualified
mortgages (HPQM). Given the 100% loss severity (LS) assumption, no
additional penalties were applied for the HPQM loan status.

Second-Lien Collateral (Negative): The entire collateral pool
comprises closed-end second-lien loans originated by Rocket
Mortgage. Fitch assumed no recovery and a 100% LS based on the
historical behavior of second-lien loans in economic stress
scenarios. Fitch assumes second-lien loans default at a rate
comparable to first-lien loans; after controlling for credit
attributes, no additional penalty was applied to Fitch's
probability of default (PD) assumption.

Sequential Structure (Positive): The transaction has a typical
sequential payment structure. Principal is used to pay down the
bonds sequentially and losses are allocated reverse sequentially.
Monthly excess cash flow is derived from remaining amounts after
allocation of the interest and principal priority of payments.
These amounts will be applied as principal, first to repay any
current and previously allocated cumulative applied realized loss
amounts and then to repay any potential net WAC shortfalls. The
senior classes incorporate a step-up coupon of 1.00% (to the extent
still outstanding) after the 48th payment date.

While Fitch has previously analyzed CES transactions using an
interest rate cut, this stress was not applied for this
transaction. Given the lack of evidence of interest rate
modifications being used as a loss mitigation tactic, applying the
stress would have been overly punitive. If interest rate
modifications re-emerge as a common form of loss mitigation or if
certain structures are overly dependent on excess interest, Fitch
may apply additional sensitivities to test the structure.

180-Day Chargeoff Feature (Positive): The class XS majority
noteholder has the ability, but not the obligation, to instruct the
servicer to write off the balance of a loan at 180 days delinquent
(DQ) based on the Mortgage Bankers Association (MBA) delinquency
method. To the extent the servicer expects meaningful recovery in
any liquidation scenario, the class XS majority noteholder may
direct the servicer to continue to monitor the loan and not charge
it off.

While the 180-day chargeoff feature will result in losses being
incurred sooner, there is a larger amount of excess interest to
protect against them. This compares favorably with a delayed
liquidation scenario, where losses occur later in the life of a
transaction and less excess is available to cover them. If a loan
is not charged off due to a presumed recovery, this will provide
added benefit to the transaction, above Fitch's expectations.

Additionally, recoveries realized after the writedown at 180 days
DQ (excluding forbearance mortgage or loss mitigation loans) will
be passed on to bondholders as principal.

RATING SENSITIVITIES

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

Fitch's incorporates a sensitivity analysis to demonstrate how the
ratings would react to steeper market value declines (MVDs) than
assumed at the metropolitan statistical area 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 42.9% 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

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 being assigned
ratings of 'AAAsf'.

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by AMC Diligence, LLC. The third-party due diligence
described in Form 15E focused on credit, regulatory compliance, and
property valuation. Fitch considered this information in its
analysis and, as a result, Fitch made the following adjustment to
its analysis: a 5% PD credit to the 20.2% of the pool by loan count
in which diligence was conducted. This adjustment resulted in a
12bps reduction to the 'AAAsf' expected loss.

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


RR 30: Moody's Assigns B3 Rating to $400,000 Class E Notes
----------------------------------------------------------
Moody's Ratings has assigned ratings to two classes of notes issued
by RR 30 LTD (the "Issuer" or "RR 30"):  

US$245,200,000 Class A-1a Senior Secured Floating Rate Notes due
2036, Definitive Rating Assigned Aaa (sf)

US$400,000 Class E Secured Deferrable Floating Rate Notes due 2036,
Definitive Rating Assigned B3 (sf)

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.

RR 30 is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated senior secured
corporate loans. At least 96% of the portfolio must consist of
first lien senior secured loans and up to 4% of the portfolio may
consist of second lien loans, unsecured loans and permitted
non-loan assets. The portfolio is approximately 100% ramped as of
the closing date.

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

In addition to the Rated Notes, the Issuer issued six other classes
of secured notes and one class of subordinated notes.

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2024.

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

Par amount: $400,000,000

Diversity Score: 45

Weighted Average Rating Factor (WARF): 3085

Weighted Average Spread (WAS): 3.30%

Weighted Average Coupon (WAC): 7.25%

Weighted Average Recovery Rate (WARR): 47.00%

Weighted Average Life (WAL): 8.2 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
May 2024.            

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

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


SALUDA GRADE 2024-INV1: DBRS Finalizes B Rating on B-2 Certs
------------------------------------------------------------
DBRS, Inc. finalized its provisional credit ratings on the Mortgage
Pass-Through Certificates, Series 2024-INV1 (the Certificates)
issued by Saluda Grade Alternative Mortgage Trust 2024-INV1 (GRADE
2024-INV1 or the Issuer) as follows:

-- $101.9 million Class A-1 at AAA (sf)
-- $10.3 million Class A-2 at AA (sf)
-- $9.4 million Class A-3 at A (sf)
-- $7.9 million Class M-1 at BBB(sf)
-- $6.5 million Class B-1 at BBB (sf)
-- $7.8 million Class B-2 at B (sf)

The AAA (sf) credit rating on the Class A-1 Certificate reflects
33.30% of credit enhancement provided by subordinated certificates.
The AA (sf), A (sf), BBB (sf), BB (sf), and B (sf) credit ratings
reflect 26.55%, 20.40%, 15.20%, 10.95%, and 5.85% of credit
enhancement, respectively.

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

GRADE 2024-INV1 represents the second securitization issued by the
Sponsor, Saluda Grade Opportunities Fund LLC (Saluda Grade), backed
by business purpose investment property loans underwritten using
DSCR. The top three originators for the mortgage pool are CV3 Alpha
Trust (40.9%), CIVIC Financial Services, LLC (27.1%), and Housemax
Funding LLC (13.7%). Fay Servicing, LLC (81.9%) and NewRez LLC
d/b/a Shellpoint Mortgage Servicing (18.1%) are the Servicers of
the loans in this transaction. U.S. Bank Trust Company, National
Association (rated AA with a Stable trend by Morningstar DBRS) will
act as the Trustee and Securities Administrator. U.S. Bank National
Association will act as the Custodian.

The mortgage loans were underwritten to program guidelines for
business-purpose loans that are designed to rely on property value,
the mortgagor's credit profile, and the DSCR, where applicable.
Because the loans were made to investors for business purposes,
they are exempt from the Consumer Financial Protection Bureau's
Ability-to-Repay (ATR) rules and TILA/RESPA Integrated Disclosure
rule.

The Sponsor, or an affiliate, will retain a portion of each class
of the Certificates (other than the Class R Certificates),
representing an eligible vertical interest of at least 5% of the
aggregate fair value of the Certificates to satisfy the credit
risk-retention requirements under Section 15G of the Securities
Exchange Act of 1934 and the regulations promulgated thereunder.
Such retention aligns Sponsor and investor interest in the capital
structure. Additionally, the Sponsor, or an affiliate, will
initially own the remainder of the Class B-3, A-IO-S, X, and P
Certificates on the Closing Date.

The Depositor will have the option on any date on or after the
earlier of (A) the three year anniversary of the Closing Date and
(B) the date on which the total loan balance is less than or equal
to 30% of the loan balance as of the Cut-Off Date, to purchase all
outstanding certificates at the redemption price specified in the
transaction documents, (optional redemption). An optional
redemption will be followed by a qualified liquidation of each
trust REMIC.

The Sponsor or the Depositor will have the option, but not the
obligation, to repurchase any mortgage loan that becomes 60 or more
days delinquent under the Mortgage Bankers Association Method at
the Repurchase Price (par plus interest), provided that such
repurchases in aggregate do not exceed 10% of the total principal
balance as of the Cut-Off Date.

For this transaction, neither Servicer nor any other transaction
party will fund advances on delinquent principal and interest (P&I)
on any mortgage. However, the Servicers are obligated to make
advances in respect of taxes, insurance premiums, and reasonable
costs incurred in the course of servicing and disposing of
properties (servicing advances).

The transaction employs a sequential-pay cash flow structure with a
pro rata principal distribution among the Class A-1, A-2, and A-3
Certificates (Senior Classes) subject to certain performance
triggers related to cumulative losses or delinquencies exceeding a
specified threshold (Trigger Event). However, in contrast to the
prior Morningstar DBRS-rated transaction from this shelf, in the
case of a Credit Event, principal proceeds will be allocated to
cover interest shortfalls on the Class A-1 and then in reduction of
the Class A-1 Certificate balance, before a similar allocation of
funds to the Class A-2 (IPIP). Prior issuance would typically
allocate principal (after a Credit Event) to cover interest
shortfalls on the Class A-1 and Class A-2 Certificates (IIPP)
before being applied sequentially to amortize the balances of the
senior and subordinated certificates. For all other classes,
principal proceeds can be used to cover interest shortfalls after
the more senior classes are paid in full (IPIP).

Excess spread can be used to cover realized losses before being
allocated to unpaid Cap Carryover

Amounts due to Class A-1 down to M-1. The Class A-1, A-2, and A-3
fixed rate coupons step up by 1.00% on and after the distribution
date in August 2028 (Step-Up Date). After the step-up date, on each
distribution date, interest and principal otherwise available to
pay the Class B-3 interest and interest shortfalls may be used to
pay any Class A Cap Carryover amounts.

Notes: All figures are in US Dollars unless otherwise noted.


SIXTH STREET XXVI: S&P Assigns Prelim BB- (sf) Rating on E Loans
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Sixth Street
CLO XXVI Ltd./Sixth Street CLO XXVI LLC's floating-rate debt (see
list).

The debt 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 Sixth Street CLO XXVI Management
LLC.

The preliminary ratings are based on information as of Aug. 19,
2024. 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

  Sixth Street CLO XXVI Ltd./Sixth Street CLO XXVI LLC

  Class A, $310.00 million: AAA (sf)
  Class B, $70.00 million: AA (sf)
  Class C (deferrable), $30.00 million: A (sf)
  Class D1 (deferrable), $30.00 million: BBB- (sf)
  Class D2 (deferrable), $5.00 million: BBB- (sf)
  Class E (deferrable), $15.00 million: BB- (sf)
  Subordinated notes, $50.00 million: Not rated



SYMPHONY CLO 41: Fitch Assigns 'BB-(EXP)sf' Rating on Class E Notes
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Symphony CLO 41, Ltd.

   Entity/Debt          Rating
   -----------          ------
Symphony CLO 41,
Ltd.

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

Transaction Summary

Symphony CLO 41, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by
Symphony Alternative Asset Management LLC. Net proceeds from the
issuance of the secured and subordinated notes will provide
financing on a portfolio of approximately $400 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 25.21, versus a maximum covenant, in
accordance with the initial expected matrix point of 27. 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
98.72% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 74.3% versus a
minimum covenant, in accordance with the initial expected matrix
point of 72.68%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 39% 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 resulting from the
industry, obligor and geographic concentrations is in line with
other recent CLOs.

Portfolio Management (Neutral): The transaction has a five-year
reinvestment period and reinvestment criteria similar to other
CLOs. Fitch's analysis was based on a stressed portfolio created by
adjusting 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, the rated notes can
withstand default and recovery assumptions consistent with their
assigned ratings.

The weighted average life (WAL) used for the transaction stress
portfolio and matrices analysis is 12 months less than the WAL
covenant to account for structural and reinvestment conditions
after the reinvestment period. In Fitch's opinion, these conditions
would reduce the effective risk horizon of the portfolio during
stress periods.

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 as
severe as between 'BBBsf' and 'AA+sf' for class A-2, between
'BB+sf' and 'A+sf' for class B, between 'B+sf' and 'BBB+sf' for
class C, between less than 'B-sf' and 'BB+sf' for class D-1,
between less than 'B-sf' and 'BB+sf' for class D-2, and between
less than 'B-sf' and 'B+sf' for class E.

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

Upgrade scenarios are not applicable to the class A-2 notes as
these notes are in the highest rating category of 'AAAsf'.

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; the minimum rating results under these sensitivity
scenarios are 'AAAsf' for class B, 'AA+sf' for class C, 'A+sf' for
class D-1, 'Asf' for class D-2, and 'BBB+sf' for class E.

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

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

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 assesses the asset portfolio
information.

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

ESG Considerations

Fitch does not provide ESG relevance scores for Symphony CLO 41,
Ltd. In cases where Fitch does not provide ESG relevance scores in
connection with the credit rating of a transaction, programme,
instrument or issuer, Fitch will disclose in the key rating drivers
any ESG factor which has a significant impact on the rating on an
individual basis.


TCI-FLATIRON 2017-1: Moody's Ups Rating on $22.5MM E Notes to Ba2
-----------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by TCI-Flatiron CLO 2017-1 Ltd.:

US$26,000,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2030 (the "Class C Notes"), Upgraded to Aaa (sf); previously on
October 30, 2023 Upgraded to Aa3 (sf)

US$31,500,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2030 (the "Class D Notes"), Upgraded to A3 (sf); previously on
October 30, 2023 Upgraded to Baa2 (sf)

US$22,500,000 Class E Senior Secured Deferrable Floating Rate Notes
due 2030 (the "Class E Notes"), Upgraded to Ba2 (sf); previously on
November 28, 2017 Assigned Ba3 (sf)

TCI-Flatiron CLO 2017-1 Ltd., originally issued in November 2017
and partially refinanced in April 2021, 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 November 2022.

A comprehensive review of all credit ratings for the respective
transaction has been conducted during a rating committee.

RATINGS RATIONALE

These rating actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's
over-collateralization (OC) ratios since October 2023. The Class
A-R notes have been paid down by approximately 39.5% or $99 million
since then. Based on Moody's calculation, the OC ratios for the
Class C, Class D and Class E notes are currently 134.73%, 119.01%
and 109.85%, respectively, versus October 2023 levels of 125.16%,
114.46% and 107.87% respectively.

Nevertheless, the credit quality of the portfolio has deteriorated
since October 2023. Based on Moody's calculation, the weighted
average rating factor (WARF) is currently 3027 compared to 2760 in
October 2023.

No actions were taken on the Class A-R and Class B Notes because
their expected losses remain commensurate with their current
ratings, after taking into account the CLO's latest portfolio
information, its relevant structural features and its actual
over-collateralization and interest coverage levels.

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

The key model inputs Moody's used in Moody's analysis, such as par,
weighted average rating factor, diversity score, weighted average
spread, and weighted average recovery rate, are based on Moody's
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: $319,857,459

Defaulted par: $5,484,858

Diversity Score: 64

Weighted Average Rating Factor (WARF): 3027

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 3.17%

Weighted Average Recovery Rate (WARR): 47.67%

Weighted Average Life (WAL): 3.69 years

In addition to base case analysis, Moody's ran additional scenarios
where outcomes could diverge from the base case. The additional
scenarios consider one or more factors individually or in
combination, and include: defaults by obligors whose low ratings or
debt prices suggest distress, defaults by obligors with potential
refinancing risk, deterioration in the credit quality of the
underlying portfolio, and lower recoveries on defaulted assets.

Methodology Used for the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2024.

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

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


TVC MORTGAGE 2024-RRTL1: DBRS Finalizes B(low) Rating on M2 Notes
-----------------------------------------------------------------
DBRS, Inc. finalized the following provisional credit ratings on
the Mortgage-Backed Notes, Series 2024-RRTL1 (the Notes) to be
issued by TVC Mortgage Trust 2024-RRTL1 (TVC 2024-RRTL1 or the
Issuer) as follows:

-- $187.6 million Class A1 at A (low) (sf)
-- $16.8 million Class A2 at BBB (low) (sf)
-- $16.8 million Class M1 at BB (low) (sf)
-- $19.5 million Class M2 at B (low) (sf)

The A (low) (sf) credit rating reflects 24.95% of credit
enhancement provided by the subordinated notes and
overcollateralization. The BBB (low) (sf), BB (low) (sf), and B
(low) (sf) credit ratings reflect 18.25%, 11.55%, and 3.75% of
credit enhancement, respectively.

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

This transaction is a securitization of a two-year revolving
portfolio of residential transition loans (RTLs) funded by the
issuance of the Notes. As of the Initial Cut-Off Date, the Notes
are backed by:

-- 324 mortgage loans with a total principal balance of
approximately $220,823,456

-- Approximately $29,176,544 in the Accumulation Account

-- Approximately $2,407,216 in the Pre-funding Interest Account

Additional RTLs may be added to the revolving portfolio on future
additional transfer dates, subject to the transaction's eligibility
criteria.

TVC 2024-RRTL1 represents the first rated RTL securitization (but
fourth overall) issued by the Sponsor, Temple View Capital Funding,
LP (TVC). TVC will own the mortgage servicing rights, and Temple
View Capital, LLC, an affiliate of the sponsor, will act as Loan
Administrator.

The revolving portfolio generally consists of first-lien,
fixed-rate, interest-only (IO) balloon RTL with original terms to
maturity of six to 24 months. The loans may also include extension
options, which can lengthen maturities beyond the original terms.
The characteristics of the revolving pool will be subject to
eligibility criteria specified in the transaction documents and
include:

-- A minimum non-zero weighted-average (NZ WA) FICO score of 725.

-- A maximum NZ WA Loan-to-Cost (LTC) ratio of 80.0%.

-- A maximum NZ WA As Repaired Loan-to-Value (ARV LTV) ratio of
69.0%.

RTL Features

RTLs, also known as fix-and-flip mortgage loans, are short-term
bridge, construction, or renovation loans designed to help real
estate investors purchase and renovate residential or small balance
commercial properties (the latter is ineligible for inclusion in
the TVC revolving portfolio), generally within 12 to 36 months.
RTLs are similar to traditional mortgages in many aspects but may
differ significantly in terms of initial property condition,
construction draws, and the timing and incentives by which
borrowers repay principal. For traditional residential mortgages,
borrowers are generally incentivized to pay principal monthly, so
they can occupy the properties while building equity in their
homes. In the RTL space, borrowers repay their entire loan amount
when they (1) sell the property with the goal to generate a profit
or (2) refinance to a term loan and rent out the property to earn
income.

In general, RTLs are short-term IO balloon loans with the full
amount of principal (balloon payment) due at maturity. The
repayment of an RTL is mainly based on the ability to sell the
related mortgaged property or to convert it into a rental property.
In addition, many RTL lenders offer extension options, which
provide additional time for borrowers to repay their mortgage
beyond the original maturity date. For the loans in this
transaction, such extensions may be granted, subject to certain
conditions, at the direction of the Loan Administrator.
In the TVC 2024-RRTL1 revolving portfolio, RTLs may be:
Fully funded:

-- With no obligation of further advances to the borrower, or

-- With a portion of the loan proceeds allocated to a
rehabilitation (rehab) escrow account for future disbursement to
fund construction draw requests upon the satisfaction of certain
conditions.

Partially funded:

-- With a commitment to fund borrower-requested draws for approved
construction, repairs, restoration, and protection of the property
(Rehabilitation Disbursement Requests) upon the satisfaction of
certain conditions.

After completing certain construction/repairs using their own
funds, the borrower usually seeks reimbursement by making draw
requests. Generally, construction draws are disbursed only upon the
completion of approved construction/repairs and after a
satisfactory construction progress inspection. Based on the TVC
Mortgage Trust 2024-RRTL1 eligibility criteria, unfunded
commitments are limited to 40% of the portfolio by the assets of
the issuer, which includes (1) the unpaid principal balance (UPB)
and (2) amounts in the Accumulation Account and Payment Account.

Cash Flow Structure and Draw Funding

The transaction employs a sequential-pay cash flow structure.
During the reinvestment period, the Notes will generally be IO.
After the reinvestment period, principal will be applied to pay
down the Notes, sequentially. If the Issuer does not redeem the
Notes by the payment date in February 2027, the Class A1 and A2
fixed rates will step up by 1.000% the following month.

There will be no advancing of delinquent (DQ) principal or interest
on any mortgage by the Servicer or any other party to the
transaction. However, the Servicer is obligated to fund Servicing
Advances which include taxes, insurance premiums, and reasonable
costs incurred in the course of servicing and disposing properties.
Such Servicing Advances will be reimbursable from collections and
other recoveries prior to any payments on the Notes.

The Loan Administrator, or the Servicer, will satisfy
Rehabilitation Disbursement Requests by, (1) for loans with funded
commitments, directing release of funds from the Rehab Escrow
Account to the applicable borrower; or (2) for loans with unfunded
commitments, (a) advancing funds on behalf of the Issuer
(Disbursement Request Advances) or (b) directing the release of
funds from the Accumulation Account. Amounts on deposit in the
Accumulation Account may be used to reimburse the Loan
Administrator or the Sponsor, as applicable, for such advances.

The Accumulation Account is replenished from the transaction cash
flow waterfall, after payment of interest to the Notes, to maintain
a minimum required funding balance. During the reinvestment period,
amounts held in the Accumulation Account, along with the mortgage
collateral, must be sufficient to maintain a minimum credit
enhancement (CE) of approximately 3.75% (the initial subordination)
to the most subordinate rated class. TVC 2024-RRTL1 incorporates
this via the Maximum Effective Advance Test during the reinvestment
period, which if breached, redirects available funds to pay down
the Notes, sequentially, prior to replenishing the Accumulation
Account, to maintain CE for all tranches.

A Pre-Funding Interest Account is in place to help cover two months
of interest payments to the Notes. Such account is funded upfront
in an amount equal to $2,407,216. On the payment dates occurring in
September and October 2024, the Paying Agent will withdraw a
specified amount to be included in the available funds.

The transaction also employs the Expense Reserve Account, which
will be available to cover fees and expenses. The Expense Reserve
Account is replenished from the transaction cash flow waterfall,
before payment of interest to the Notes, to maintain a minimum
reserve balance.

Albeit limited, TVC RTL originations have historically generated
robust mortgage repayments, which have been able to cover unfunded
commitments in securitizations. In the RTL space, because of the
lack of amortization and the short term nature of the loans,
mortgage repayments (paydowns and payoffs) tend to occur closer to
or at the related maturity dates when compared with traditional
residential mortgages. Morningstar DBRS considers paydowns to be
unscheduled voluntary balance reductions (generally repayments in
full) that occur prior to the maturity date of the loans, while
payoffs are scheduled balance reductions that occur on the maturity
or extended maturity date of the loans. In its cash flow analysis,
Morningstar DBRS evaluated TVC's historical mortgage repayments
relative to draw commitments and incorporated several stress
scenarios where paydowns may or may not sufficiently cover draw
commitments. Please see the Cash Flow Analysis section of the
related rating report for more details.

Other Transaction Features

Optional Redemption

On any date after the earlier of (1) the Payment Date following the
termination of the Reinvestment Period or (2) the date on which the
aggregate Note Amount falls to 25% or less of the initial Closing
Date Note Amount, the Issuer, at its option, may purchase all of
the outstanding Notes at the Redemption Price (par plus interest
and fees).

Repurchase Option

The Sponsor will have the option to repurchase any DQ or defaulted
mortgage loan at the Repurchase Price (par plus interest and fees).
During the reinvestment period, if the Sponsor repurchases DQ or
defaulted loans, this could potentially delay the natural
occurrence of an early amortization event based on the DQ or
default trigger. Morningstar DBRS' revolving structure analysis
assumes the repayment of Notes is reliant on the amortization of an
adverse pool regardless of whether it occurs early or not.

Sales of Mortgage Loans

The Issuer may sell a mortgage loan under the following
circumstances:

-- The Sponsor is required to repurchase a loan because of a
material breach, a diligence defect, or a material document defect

-- The Sponsor elects to exercise its Repurchase Option

-- An optional redemption occurs

-- The Issuer sells a mortgage loan in an arm's length transaction
at the Repurchase Price or sells an REO property at fair market
value (FMV)

-- The Issuer sells a mortgage loan to an affiliate at FMV but
such price must be at least par plus interest. Voluntary
repurchases and sales may not exceed 10.0% of the cumulative UPB of
the mortgage loans (Repurchase Limit).

U.S. Credit Risk Retention

As the Sponsor, TVC, or one or more majority-owned affiliates will
initially retain an eligible horizontal residual interest
comprising at least 5% of the aggregate fair value of the
securities (in this case, the entirety of the Class XS Notes) to
satisfy the credit risk retention requirements.

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


VELOCITY COMMERCIAL 2024-4: DBRS Gives Prov. B Rating on 3 Classes
------------------------------------------------------------------
DBRS, Inc. assigned the following provisional credit ratings to the
Mortgage-Backed Certificates, Series 2024-4 (the Certificates) to
be issued by Velocity Commercial Capital Loan Trust 2024-4 (VCC
2024-4 or the Issuer) as follows:

-- $165.7 million Class A at AAA (sf)
-- $14.9 million Class M-1 at AA (low) (sf)
-- $14.9 million Class M-2 at A (low) (sf)
-- $16.6 million Class M-3 at BBB (sf)
-- $28.1 million Class M-4 at BB (sf)
-- $9.5 million Class M-5 at B (high) (sf)
-- $4.0 million Class M-6 at B (sf)
-- $165.7 million Class A-S at AAA (sf)
-- $165.7 million Class A-IO at AAA (sf)
-- $14.9 million Class M1-A at AA (low) (sf)
-- $14.9 million Class M1-IO at AA (low) (sf)
-- $14.9 million Class M2-A at A (low) (sf)
-- $14.9 million Class M2-IO at A (low) (sf)
-- $16.6 million Class M-3A at BBB (sf)
-- $16.6 million Class M3-IO at BBB (sf)
-- $28.1 million Class M4-A at BB (sf)
-- $28.1 million Class M4-IO at BB (sf)
-- $9.5 million Class M5-A at B (high) (sf)
-- $9.5 million Class M5-IO at B (high) (sf)
-- $4.0 million Class M6-A at B (sf)
-- $4.0 million Class M6-IO at B (sf)

Classes A-IO, M1-IO, M2-IO, M3-IO, M4-IO, M5-IO, and M6-IO are
interest-only (IO) certificates. The class balances represent
notional amounts.

Classes A, M-1, M-2, M-3, M-4, M-5, and M-6 are exchangeable
certificates. These classes can be exchanged for combinations of
initial exchangeable certificates as specified in the offering
documents.
The AAA (sf) credit ratings on the Certificates reflect 35.45% of
credit enhancement (CE) provided by subordinated certificates. The
AA (low) (sf), A (low) (sf), BBB (sf), BB (sf), B (high) (sf), and
B (sf) credit ratings reflect 29.65%, 23.85%, 17.40%, 6.45%, 2.75%,
and 1.20% of CE, respectively.

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

Morningstar DBRS assigned provisional credit ratings to VCC 2024-4,
a securitization of a portfolio of newly originated and seasoned
fixed and adjustable-rate, first-lien residential mortgages
collateralized by investor properties with one to four units
(residential investor loans) and small-balance commercial mortgages
(SBC) collateralized by various types of commercial, multifamily
rental, and mixed-use properties. Four of these loans were
originated through the U.S. SBA 504 loan program, and are backed by
first-lien, owner occupied, commercial real estate. The
securitization is funded by the issuance of the Certificates. The
Certificates are backed by 686 mortgage loans with a total
principal balance of $256,692,301 as of the Cut-Off Date (July 1,
2024).

Approximately 52.4% of the pool comprises residential investor
loans, about 46.1% of traditional SBC loans, and about 1.5% are the
SBA 504 loans mentioned above. Most of the loans in this
securitization (86.7%) were originated by Velocity Commercial
Capital, LLC (Velocity or VCC). Twenty-six loans (11.9%) were
originated by New Day Commercial Capital, LLC, which is a wholly
owned subsidiary of Velocity Commercial Capital, LLC, which is
wholly owned by Velocity Financial, Inc. Four of the loans (1.4%)
were originated by other parties and acquired in accordance with
Velocity's guidelines.

The loans were generally underwritten to program guidelines for
business-purpose loans where the lender generally expects the
property (or its value) to be the primary source of repayment (with
the exception being the four SBA 504 loans which, per SBA
guidelines, were underwritten to the small business cash flows,
rather than to the property value). For all of the New Day
Commercial Capital, LLC originated loans, underwriting was based on
business cash flows but loans were secured by real estate. For the
SBC and residential investor loans, the lender reviews the
mortgagor's credit profile, though it does not rely on the
borrower's income to make its credit decision. However, the lender
considers the property-level cash flows or minimum debt service
coverage ratio (DSCR) in underwriting SBC loans with balances more
than $750,000 for purchase transactions and more than $500,000 for
refinance transactions. Because the loans were made to investors
for business purposes, they are exempt from the Consumer Financial
Protection Bureau's Ability-to-Repay (ATR) rules and TILA-RESPA
Integrated Disclosure rule.

On January 5, 2024, a suit was filed in the U.S. District Court for
the Central District of California by Harvest Small Business
Finance, LLC and Harvest Commercial Capital, LLC against certain
employees of New Day Business Finance LLC and Velocity d/b/a New
Day Commercial Capital, LLC (New Day) alleging violations of the
Defend Trade Secrets Act, the California Uniform Trade Secrets Act
and the California Unfair Competition Law. New Day has indicated
that it does not believe that this suit is material.

PHH Mortgage Corporation (PMC) will service all loans within the
pool for a servicing fee of 0.30% per annum. New Day will act as
subservicer for the 26 New Day originated loans (including the 4
SBA 504 loans), and PHH will also act as the Backup Servicer for
these loans. In the event that New Day fails to service these loans
in accordance with the related subservicing agreement, PHH will
terminate the subservicing agreement and commence directly
servicing such mortgage loans within 30 days. In addition, Velocity
will act as a Special Servicer servicing the loans that defaulted
or became 60 or more days delinquent under Mortgage Bankers
Association (MBA) method and other loans, as defined in the
transaction documents (Specially Serviced Mortgage Loans). The
Special Servicer will be entitled to receive compensation based on
an annual fee of 0.75% and the balance of Specially Serviced
Loans.

Also, the Special Servicer is entitled to a liquidation fee equal
to 2.00% of the net proceeds from the liquidation of a Specially
Serviced Mortgage Loan, as described in the transaction documents.
The Servicer will fund advances of delinquent P&I until the
advances are deemed unrecoverable. Also, the Servicer is obligated
to make advances with respect to taxes, insurance premiums, and
reasonable costs incurred in the course of servicing and disposing
properties.

U.S. Bank National Association (U.S. Bank; rated AA with a Stable
trend by Morningstar DBRS) will act as the Custodian. U.S. Bank
Trust Company, National Association will act as the Trustee.
The Seller, directly or indirectly through a majority-owned
affiliate, is expected to retain an eligible horizontal residual
interest consisting of the Class XS Certificates, collectively
representing at least 5% of the fair value of all Certificates, to
satisfy the credit risk-retention requirements under Section 15G of
the Securities Exchange Act of 1934 and the regulations promulgated
thereunder. Such retention aligns Sponsor and investor interest in
the capital structure.

On or after the later of (1) the three-year anniversary of the
Closing Date or (2) the date when the aggregate stated principal
balance of the mortgage loans is reduced to 30% of the Closing Date
balance, the Depositor may purchase all outstanding Certificates
(Optional Purchase) at a price equal to the sum of the remaining
aggregate balance of the Certificates plus accrued and unpaid
interest, and any fees, expenses, and indemnity payments due and
unpaid to the transaction parties, including any unreimbursed P&I
and servicing advances, and other amounts due as applicable. The
Optional Purchase will be conducted concurrently with a qualified
liquidation of the Issuer.

Additionally, if on any date on which the unpaid mortgage loan
balance and the value of REO properties has declined to less than
10% of the initial mortgage loan balance as of the Cut-Off Date,
the Directing Holder, the Special Servicer, or the Servicer, in
that order of priority, may purchase all of the mortgages, REO
properties, and any other properties from the Issuer (Optional
Termination) at a price specified in the transaction documents. The
Optional Termination will be conducted as a qualified liquidation
of the Issuer. The Directing Holder (initially, the Seller) is the
representative selected by the holders of more than 50% of the
Class XS certificates (the Controlling Class).

The transaction uses a structure sometimes referred to as a
modified pro rata structure. Prior to the Class A CE falling below
10.0% of the loan balance as of the Cut-Off Date (Class A Minimum
CE Event), the principal distributions allow for amortization of
all senior and subordinate bonds based on CE targets set at
different levels for performing (same CE as at issuance) and
nonperforming (higher CE than at issuance) loans. Each class'
target principal balance is determined based on the CE targets and
the performing and nonperforming (those that are 90 or more days
MBA delinquent, in foreclosure and REO, and subject to a servicing
modification within the prior 12 months) loan amounts. As such, the
principal payments are paid on a pro rata basis, up to each class'
target principal balance, so long as no loans in the pool are
nonperforming. If the share of nonperforming loans grows, the
corresponding CE target increases. Thus, the principal payment
amount increases for the senior and senior subordinate classes and
falls for the more subordinate bonds. The goal is to distribute the
appropriate amount of principal to the senior and subordinate bonds
each month, to always maintain the desired level of CE, based on
the performing and nonperforming pool percentages. After the Class
A Minimum CE Event, the principal distributions are made
sequentially.

Relative to the sequential pay structure, the modified pro rata
structure is more sensitive to the timing of the projected defaults
and losses as the losses may be applied at a time when the amount
of credit support is reduced as the bonds' principal balances
amortize over the life of the transaction. That said, the excess
spread can be used to cover realized losses after being allocated
to the unpaid net weighted-average coupon shortfalls (Net WAC Rate
Carryover Amounts). Please see the Cash Flow Structure and Features
section of the related presale report for more details.

COMMERICAL MORTGAGE-BACKED SECURITIES (CMBS) METHODOLOGY - SMALL
BALANCE COMMERICAL (SBC) LOANS

The collateral for the SBC portion of the pool consists of 247
individual loans secured by 247 commercial and multifamily
properties with an average cut-off date loan balance of $479,139.
None of the mortgage loans are cross-collateralized or
cross-defaulted with each other. Given the complexity of the
structure and granularity of the pool, Morningstar DBRS applied its
North American CMBS Multi-Borrower Rating Methodology (the CMBS
Methodology).

The CMBS loans have a weighted-average (WA) fixed interest rate of
11.4%. This is approximately 30 basis points (bps) lower than the
VCC 2024-3 transaction, 20 bps lower than the VCC 2024-2
transaction, 20 bps lower than the VCC 2024-1 transaction, 50 bps
lower than the VCC 2023-4 transaction, 60 bps lower than the VCC
2023-3 transaction, the same WA interest rate as VCC 2023-2, and 90
bps higher than VCC 2023-1, highlighting the increase in interest
rates over the last few years. Most of the loans have original term
lengths of 30 years and fully amortize over 30-year schedules.
However, 14 loans, which represent 7.7% of the SBC pool, have an
initial interest-only (IO) period of 12, 24, 60, or 120 months.

All of the SBC loans were originated between December 2022 and June
2024 (100.0% of the cut-off pool balance), resulting in a WA
seasoning of 0.8 months. The SBC pool has a WA original term length
of 352 months, or approximately 30 years. Based on the current loan
amount, which reflects 30 bps of amortization, and the current
appraised values, the SBC pool has a WA loan-to-value ratio (LTV)
of 61.2%. However, Morningstar DBRS made LTV adjustments to 29
loans that had an implied capitalization rate of more than 200 bps
lower than a set of minimal capitalization rates established by the
Morningstar DBRS Market Rank. The Morningstar DBRS minimum
capitalization rates range from 5.0% for properties in Market Rank
8 to 8.0% for properties in Market Rank 1. This resulted in a
higher Morningstar DBRS LTV of 64.8%. Lastly, all loans fully
amortize over their respective remaining terms, resulting in 100%
expected amortization; this amount of amortization is greater than
what is typical for CMBS conduit pools. Morningstar DBRS' research
indicates that, for CMBS conduit transactions securitized between
2000 and 2021, average amortization by year has ranged between 6.5%
and 22.0%, with a median rate of 16.5%.

As contemplated and explained in Morningstar DBRS' Rating North
American CMBS Interest-Only Certificates methodology, the most
significant risk to an IO cash flow stream is term default risk.
As Morningstar DBRS noted in the methodology, for a pool of
approximately 63,000 CMBS loans that had fully cycled through to
their maturity defaults, the average total default rate across all
property types was approximately 17%, the refinance default rate
was 6% (approximately one third of the total default rate), and the
term default rate was approximately 11%. Morningstar DBRS
recognizes the muted impact of refinance risk on IO certificates by
notching the IO rating up by one notch from the Reference
Obligation rating. When using the 10-year Idealized Default Table
default probability to derive a probability of default (POD) for a
CMBS bond from its rating, Morningstar DBRS estimates that, in
general, a one-third reduction in the CMBS Reference Obligation POD
maps to a tranche rating that is approximately one notch higher
than the Reference Obligation or the Applicable Reference
Obligation, whichever is appropriate. Therefore, similar logic
regarding term default risk supported the rationale for Morningstar
DBRS to reduce the POD in the CMBS Insight Model by one notch
because refinance risk is largely absent for this SBC pool of
loans.

The Morningstar DBRS CMBS Insight Model does not contemplate the
ability to prepay loans, which is generally seen as credit positive
because a prepaid loan cannot default. The CMBS predictive model
was calibrated using loans that have prepayment lockout features.
Those loans' historical prepayment performance is close to a 0%
conditional prepayment rate (CPR). If the CMBS predictive model had
an expectation of prepayments, Morningstar DBRS would expect the
default levels to be reduced. Any loan that prepays is removed from
the pool and can no longer default. This collateral pool does not
have any prepayment lockout features, and Morningstar DBRS expects
this pool will have prepayments over the remainder of the
transaction. Morningstar DBRS applied a 5.0% reduction to the
cumulative default assumptions to provide credit for expected
payments. The assumption reflects Morningstar DBRS' opinion that,
in a rising-interest-rate environment, fewer borrowers may elect to
prepay their loan.

As a result of higher interest rate and lending spreads, the SBC
pool has a significant increase in interest rates compared with
prior VCC transactions. Consequently, approximately 68.7% of the
deal has an Issuer NOI DSCR of less than 1.0 times (x), which is in
line with the VCC 2023-4, VCC 2024-2, and VCC 2024-1 transactions
but a larger composition than previous VCC transactions in 2023 and
2022. Additionally, although the Morningstar DBRS CMBS Insight
Model does not contemplate FICO scores, it is important to point
out the WA FICO score of 713 for the SBC loans, which is relatively
similar to prior transactions. With regard to the aforementioned
concerns, Morningstar DBRS applied a 5.0% penalty to the fully
adjusted cumulative default assumptions to account for risks given
these factors.
The SBC pool is quite diverse based on loan count and size, with an
average cut-off date balance of $479,139, a concentration profile
equivalent to that of a transaction with 124 equal-size loans, and
a top 10 loan concentration of 20.0%. Increased pool diversity
helps insulate the higher-rated classes from event risk.
The loans are mostly secured by traditional property types (i.e.,
multifamily, retail, office, and industrial).

All loans in the SBC pool fully amortize over their respective
remaining loan terms, reducing refinance risk.

As classified by Morningstar DBRS for modeling purposes, the SBC
pool contains a significant exposure to retail (29.9% of the SBC
pool) and office (22.0% of the SBC pool), which are two of the
higher-volatility asset types. Loans counted as retail include
those identified as automotive and potentially commercial
condominium. Combined, retail and office properties represent 51.9%
of the SBC pool balance. Morningstar DBRS applied a 21.4% reduction
to the net cash flow (NCF) for retail properties and a 30.0%
reduction to the NCF for office assets in the SBC pool, which is
above the average NCF reduction applied for comparable property
types in CMBS analyzed deals.

Morningstar DBRS did not perform site inspections on loans within
its sample for this transaction. Instead, Morningstar DBRS relied
upon analysis of third-party reports and online searches to
determine property quality assessments. Of the 80 loans Morningstar
DBRS sampled, 16 were Average quality (25.3%), 43 were Average -
quality (52.4%), 18 were Below Average quality (18.6%), and three
were Poor quality (3.7%). Morningstar DBRS assumed unsampled loans
were Average - quality, which has a slightly increased POD level.
This is consistent with the assessments from sampled loans and
other SBC transactions rated by Morningstar DBRS.

Limited property-level information was available for Morningstar
DBRS to review. Asset summary reports, PCRs, Phase I/II
environmental site assessment (ESA) reports, and historical cash
flows were generally not available for review in conjunction with
this securitization.

Morningstar DBRS received and reviewed appraisals for sampled loans
for the top 30 of the pool, which represent 37.5% of the SBC pool
balance. These appraisals were issued between October 2023 and June
2024 when the respective loans were originated. Morningstar DBRS
was able to perform a loan-level cash flow analysis on the top 30
loans in the pool. The NCF haircuts for these loans ranged from
1.9% to 73.0%, with an average of 18.1%.
No ESA reports were required by the Issuer; however, all of the
loans have an environmental insurance policy that provides coverage
to the Issuer and the securitization trust in the event of a claim.
No probable maximum loss (PML) information or earthquake insurance
requirements are provided. Therefore, a loss given default (LGD)
penalty was applied to all properties in California to mitigate
this potential risk.

Morningstar DBRS received limited borrower information, net worth
or liquidity information, and credit history. Additionally, the WA
interest rate of the deal is 11.4%, which is indicative of the
broader increased interest rate environment and represents a large
increase over VCC deals in 2022 and early 2023.

Morningstar DBRS generally initially assumed loans had Weak
sponsorship scores, which increases the stress on the default rate.
The initial assumption of Weak reflects the generally less
sophisticated nature of small balance borrowers and assessments
from past small balance transactions rated by Morningstar DBRS.
Furthermore, Morningstar DBRS received a 12-month pay history on
each loan through July 9, 2024. If any loan had more than two late
pays within this period or was currently 30 days past due,
Morningstar DBRS applied an additional stress to the default rate.
This occurred for four loans, representing 2.9% of the SBC pool
balance.

SBA 504 LOANS

The transaction includes four SBA 504 loans, totaling approximately
$3.9 million or 1.5% of the aggregate 2024-4 collateral pool. These
are owner-occupied, first-lien commercial real estate (CRE)-backed
loans, originated via the U.S. Small Business Administration's 504
loan program (SBA 504) in conjunction with community development
companies (CDC), made to small businesses, with the stated goal of
community economic development.

The SBA 504 loans are fixed rate with 360-month original terms and
are fully amortizing. The loans were originated between May 20,
2024, and June 14, 2024, via New Day, which will also act as
subservicer of the loans. The total outstanding principal balance
as of the Cut-Off Date is approximately $3.9 million, with an
average balance of $990,767. The WA interest rate is 9.98%. The
loans are subject to prepayment penalties of 5%,4%, 3%, 2%, and 1%,
respectively, in the first five years from origination. These loans
are for properties that are owner-occupied by the small business
owner, with the exception of one loan that is investor-owned. WA
LTV is 42.22%. WA DSCR is 1.72x, and the WA FICO of this sub-pool
is 755.

For these loans, Morningstar DBRS applied its Rating U.S.
Structured Finance Transactions methodology, Small Business,
Appendix (XVIII). As there is limited historical information for
the originator, Morningstar DBRS used proxy data from the publicly
available SBA data set, which contains several decades of
performance data, stratified by industry categories of the small
business operators, to derive an expected default rate. Recovery
assumptions were derived from the Morningstar DBRS CMBS data set of
LGD stratified by property type, LTV, and market rank. These were
input into Morningstar DBRS' proprietary model, the Morningstar
DBRS CLO Insight Model, which uses a Monte Carlo process to
generate stressed loss rates corresponding to a specific rating
level.

RESIDENTIAL MORTGAGE-BACKED SECURITIES (RMBS) METHODOLOGY

The collateral pool consists of 435 mortgage loans with a total
balance of approximately $134.4 million collateralized by one- to
four-unit investment properties. Velocity underwrote the mortgage
loans to the No Ratio program guidelines for business-purpose
loans.
The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary Baseline Macroeconomic Scenarios for Rated
Sovereigns June 2024 Update, published on June 28, 2024. These
baseline macroeconomic scenarios replace Morningstar DBRS' moderate
and adverse COVID-19 pandemic scenarios, which were first published
in April 2020.

Morningstar DBRS incorporates a dynamic cash flow analysis in its
credit rating process. Morningstar DBRS applied a baseline of four
prepayment scenarios under the Standard Intex convention and two
default timing curves and two interest rate stresses to test the
resilience of the rated classes. Morningstar DBRS ran a total of 16
cash flow scenarios at each credit rating level for this
transaction. Additionally, WAC deterioration stresses were
incorporated in the runs.

Morningstar DBRS' credit ratings on Certificates address the credit
risk associated with the identified financial obligations in
accordance with the relevant transaction documents. The associated
financial obligations for each of the rated Certificates are the
related Interest Distribution Amount, Interest Carryforward Amount,
and Class Target Principal Distribution Amount.

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


VERUS SECURITIZATION 2024-INV2: S&P Assigns B- (sf) on B-2 Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to Verus Securitization
Trust 2024-INV2's mortgage-backed notes.

The note issuance is an RMBS securitization backed by first-lien,
fixed- and adjustable-rate (some with interest-only periods)
residential mortgage loans secured by single-family residences,
townhouses, planned-unit developments, two- to four-family
residential properties, condominiums, condotels, a cooperative,
five– to 10-unit multifamily properties, mixed-use properties,
and condotels to both prime and non-prime borrowers. The pool has
885 residential mortgage loans; five loans are cross-collateralized
loans backed by 21 properties for a total property count of 901.

The ratings reflect S&P's view of:

-- The pool's collateral composition;

-- The transaction's credit enhancement, associated structural
mechanics, representations and warranties (R&W) framework, and
geographic concentration;

-- The mortgage aggregator, Invictus Capital Partners (Invictus),
and any S&P Global Ratings reviewed originator; and
-- S&P said, "Per our latest update ("A Cooling U.S. Labor Market
Sets Up A September Start For Rate Cuts," Aug. 6, 2024) to our Q3
macroeconomic outlook ("Economic Outlook U.S. Q3 2024: Milder
Growth Ahead," June 24, 2024), we have recalibrated our views on
the trajectory of interest rates in the U.S. and now expect 50
basis points of rate cuts coming this year and another 100 basis
points of cuts coming next year, with the balance of risks tilting
toward more of those cuts happening sooner rather than later. Our
base-case forecast for GDP growth and inflation have not changed
and we attribute the recent loosening of the labor market to
normalization, not to an economy that's about to slip into a
recession. A soft landing remains the most likely scenario, at
least into 2025. We therefore maintain our current market outlook
as it relates to the 'B' projected archetypal foreclosure frequency
of 2.50% which reflects our benign view of the mortgage and housing
market as demonstrated through general national level home price
behavior, unemployment rates, mortgage performance, and
underwriting."

  Ratings Assigned

  Verus Securitization Trust 2024-INV2

  Class A-1, $215,921,000: AAA (sf)
  Class A-2, $24,525,000: AA (sf)
  Class A-3, $42,473,000: A (sf)
  Class M-1, $30,923,000: BBB- (sf)
  Class B-1, $18,837,000: BB- (sf)
  Class B-2, $12,618,000: B- (sf)
  Class B-3, $10,129,998: Not rated
  Class A-IO-S, $355,426,998(i): Not rated
  Class XS, $355,426,998(i): Not rated
  Class R, N/A: Not rated

(i)The notional amount equals the aggregate stated principal
balance of loans in the pool as of the cutoff date.
N/A—Not applicable.



VOYA CLO 2016-2: Moody's Affirms B1 Rating on $16.4MM D-R Notes
---------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by Voya CLO 2016-2, Ltd.:

US$25.6M Class B-R Deferrable Floating Rate Notes, Upgraded to Aaa
(sf); previously on Nov 16, 2023 Upgraded to Aa2 (sf)

US$21.2M Class C-R Deferrable Floating Rate Notes, Upgraded to
Baa1 (sf); previously on Nov 16, 2023 Upgraded to Baa3 (sf)

Moody's have also affirmed the ratings on the following notes:

US$259M (Current outstanding amount US$ 13,694,943) Class A-1-R
Floating Rate Notes, Affirmed Aaa (sf); previously on Aug 16, 2019
Assigned Aaa (sf)

US$45.9M Class A-2-R Floating Rate Notes, Affirmed Aaa (sf);
previously on Nov 16, 2023 Upgraded to Aaa (sf)

US$16.4M Class D-R Deferrable Floating Rate Notes, Affirmed B1
(sf); previously on Sep 15, 2020 Downgraded to B1 (sf)

Voya CLO 2016-2, Ltd., originally issued in July 2016 and
refinanced in August 2019, is a collateralised loan obligation
(CLO) backed by a portfolio of mostly high-yield senior secured US
loans. The portfolio is managed by Voya Alternative Asset
Management LLC. The transaction's reinvestment period ended in July
2021.

RATINGS RATIONALE

The rating upgrades on the Class B-R and C-R notes are primarily a
result of the significant deleveraging of the senior notes
following amortisation of the underlying portfolio since the last
rating action in November 2023.

The affirmations on the ratings on the Class A-1-R, A-2-R and D-R
notes are primarily a result of the expected losses on the notes
remaining consistent with their current rating levels, after taking
into account the CLO's latest portfolio, its relevant structural
features and its actual over-collateralisation ratios.

The Class A-1-R notes have paid down by approximately USD107.63
million (41.56%) since the last rating action in November 2023 and
USD245.31 million (94.71%) since closing. As a result of the
deleveraging, over-collateralisation (OC) for senior and mezzanine
rated notes has increased. According to the trustee report dated
July 2024 [1], the Class A, Class B and Class C OC ratios are
reported at 170.43%, 135.82% and 116.27% compared to October 2023
[2] levels of 139.73%, 123.46% and 112.59%, respectively. Moody's
note that the July 2024 principal payments are not reflected in the
reported OC ratios.

The key model inputs Moody's use in Moody's analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on Moody's published methodology
and could differ from the trustee's reported numbers.

In Moody's base case, Moody's used the following assumptions:

Performing par and principal proceeds balance: USD134.34m

Defaulted Securities: USD0.92m

Diversity Score: 59

Weighted Average Rating Factor (WARF): 3145

Weighted Average Life (WAL): 3.08 years

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 3.27%

Weighted Average Recovery Rate (WARR): 46.92%

Par haircut in OC tests and interest diversion test: 3.14%

The default probability derives from the credit quality of the
collateral pool and Moody's expectation of the remaining life of
the collateral pool. The estimated average recovery rate on future
defaults is based primarily on the seniority of the assets in the
collateral pool. In each case, historical and market performance
and a collateral manager's latitude to trade collateral are also
relevant factors. Moody's incorporate these default and recovery
characteristics of the collateral pool into Moody's cash flow model
analysis, subjecting them to stresses as a function of the target
rating of each CLO liability it is analysing.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2024.
Counterparty Exposure:

The rating action took into consideration the notes' exposure to
relevant counterparties, using the methodology "Moody's Approach to
Assessing Counterparty Risks in Structured Finance methodology"
published in October 2023. Moody's concluded the ratings of the
notes are not constrained by these risks.

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

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

Additional uncertainty about performance is due to the following:

-- Portfolio amortisation: The main source of uncertainty in this
transaction is the pace of amortisation of the underlying
portfolio, which can vary significantly depending on market
conditions and have a significant impact on the notes' ratings.
Amortisation could accelerate as a consequence of high loan
prepayment levels or collateral sales by the collateral manager or
be delayed by an increase in loan amend-and-extend restructurings.
Fast amortisation would usually benefit the ratings of the notes
beginning with the notes having the highest prepayment priority.

-- Recovery of defaulted assets: Market value fluctuations in
trustee-reported defaulted assets and those Moody's assume have
defaulted can result in volatility in the deal's
over-collateralisation levels. Further, the timing of recoveries
and the manager's decision whether to work out or sell defaulted
assets can also result in additional uncertainty. Moody's analysed
defaulted recoveries assuming the lower of the market price or the
recovery rate to account for potential volatility in market prices.
Recoveries higher than Moody's expectations would have a positive
impact on the notes' ratings.

-- Long-dated assets: The presence of USD7.3m of assets that
mature beyond the CLO's legal maturity date exposes the deal to
liquidation risk on those assets. Moody's assume that, at
transaction maturity, the liquidation value of such an asset will
depend on the nature of the asset as well as the extent to which
the asset's maturity lags that of the liabilities. Liquidation
values higher than Moody's expectations would have a positive
impact on the notes' ratings.

In addition to the quantitative factors that Moody's explicitly
modelled, qualitative factors are part of the rating committee's
considerations. These qualitative factors include the structural
protections in the transaction, its recent performance given the
market environment, the legal environment, specific documentation
features, the collateral manager's track record and the potential
for selection bias in the portfolio. All information available to
rating committees, including macroeconomic forecasts, input from
Moody's other analytical groups, market factors, and judgments
regarding the nature and severity of credit stress on the
transactions, can influence the final rating decision.


WELLINGTON MANAGEMENT 3: S&P Assigns Prelim 'BB-' Rating on E Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Wellington
Management CLO 3 Ltd./Wellington Management CLO 3 LLC's
floating-rate debt.

The debt 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 Wellington Management CLO Advisors
LLC, affiliated with Wellington Management Co. LLP and Wellington
Alternate Investments LLC.

The preliminary ratings are based on information as of Aug. 16,
2024. 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

  Wellington Management CLO 3 Ltd./Wellington Management CLO 3 LLC

  Class A-1, $181.00 million: AAA (sf)
  Class A loans, $75.00 million: AAA (sf)
  Class A-2, $6.00 million: AAA (sf)
  Class B, $42.00 million: AA (sf)
  Class C (deferrable), $24.00 million: A (sf)
  Class D-1 (deferrable), $24.00 million: BBB- (sf)
  Class D-2 (deferrable), $4.00 million: BBB- (sf)
  Class E (deferrable), $12.00 million: BB- (sf)
  Subordinated notes, $36.66 million: Not rated



WELLS FARGO 2015-SG1: Fitch Lowers Rating on Cl. D Certs to 'B-sf'
------------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed 11 classes of Wells
Fargo Commercial Mortgage Trust 2015-C30 (WFCM 2015-C30) commercial
pass-through certificates. Class D was assigned a Negative Outlook
following its downgrade. The Rating Outlooks for classes C and PEX
were revised to Negative from Stable. The Rating Outlooks remain
Negative on classes E and X-E.

Fitch has also downgraded one and affirmed 11 classes of Wells
Fargo Commercial Mortgage Trust 2015-SG1 (WFCM 2015-SG1). Class D
was assigned a Negative Outlook following its downgrade. The Rating
Outlooks for class A-S, X-A, B, C and PEX were revised to Negative
from Stable.

Fitch has affirmed 11 classes of Wells Fargo Commercial Mortgage
(WFCM) Trust 2015-C29 commercial mortgage pass-through
certificates. The Rating Outlooks for classes C, PEX, D and E have
been revised to Negative from Stable.

   Entity/Debt          Rating            Prior
   -----------          ------            -----
WFCM 2015-SG1

   A-4 94989QAV2    LT AAAsf  Affirmed    AAAsf
   A-S 94989QAX8    LT AAAsf  Affirmed    AAAsf
   A-SB 94989QAW0   LT AAAsf  Affirmed    AAAsf
   B 94989QBA7      LT Asf    Affirmed    Asf
   C 94989QBB5      LT BBBsf  Affirmed    BBBsf
   D 94989QBD1      LT B-sf   Downgrade   BB-sf
   E 94989QAL4      LT CCCsf  Affirmed    CCCsf
   F 94989QAN0      LT CCsf   Affirmed    CCsf
   PEX 94989QBC3    LT BBBsf  Affirmed    BBBsf
   X-A 94989QAY6    LT AAAsf  Affirmed    AAAsf
   X-E 94989QAA8    LT CCCsf  Affirmed    CCCsf
   X-F 94989QAC4    LT CCsf   Affirmed    CCsf

WFCM 2015-C30

   A-3 94989NBD8    LT AAAsf  Affirmed    AAAsf
   A-4 94989NBE6    LT AAAsf  Affirmed    AAAsf  
   A-S 94989NBG1    LT AAAsf  Affirmed    AAAsf
   A-SB 94989NBF3   LT AAAsf  Affirmed    AAAsf
   B 94989NBK2      LT AA+sf  Affirmed    AA+sf
   C 94989NBL0      LT A-sf   Affirmed    A-sf
   D 94989NAL1      LT BBsf   Downgrade   BBB-sf
   E 94989NAN7      LT B-sf   Affirmed    B-sf
   F 94989NAQ0      LT CCCsf  Affirmed    CCCsf
   PEX 94989NBM8    LT A-sf   Affirmed    A-sf
   X-A 94989NBH9    LT AAAsf  Affirmed    AAAsf
   X-E 94989NAA5    LT B-sf   Affirmed    B-sf

WFCM 2015-C29

   A-3 94989KAU7    LT AAAsf  Affirmed    AAAsf
   A-4 94989KAV5    LT AAAsf  Affirmed    AAAsf
   A-S 94989KAX1    LT AAAsf  Affirmed    AAAsf
   A-SB 94989KAW3   LT AAAsf  Affirmed    AAAsf
   B 94989KBA0      LT AA-sf  Affirmed    AA-sf
   C 94989KBB8      LT A-sf   Affirmed    A-sf
   D 94989KBC6      LT BBsf   Affirmed    BBsf
   E 94989KAE3      LT Bsf    Affirmed    Bsf
   F 94989KAG8      LT CCCsf  Affirmed    CCCsf
   PEX 94989KBD4    LT A-sf   Affirmed    A-sf
   X-A 94989KAY9    LT AAAsf  Affirmed    AAAsf

KEY RATING DRIVERS

Performance and 'B' Loss Expectations: Deal-level 'Bsf' rating case
losses are 6.4% in WFCM 2015-C30, 9.2% in WFCM 2015-SG1 and 7.3% in
WFCM 2015-C29. Fitch Loans of Concerns (FLOCs) comprise 17 loans
(34.7% of the pool) in WFCM 2015-C30, including six specially
serviced loans (3.9%); 19 loans (41.3%) in WFCM 2015-SG1, including
five specially serviced loans (22%); and 22 loans (37.9%) in WFCM
2015-C29. For each transaction, Fitch incorporated a higher
probability of default in its rating case and/or sensitivity on
certain FLOCs to account for their heightened maturity default
risk.

WFCM 2015-C30: The downgrade on class D reflects higher pool loss
expectations since Fitch's prior rating action driven by
performance and upcoming refinance concerns on the FLOCs, primarily
those secured by a lower-tier regional mall, student housing and
office properties, including Riverpark Square (8.3%), Pennbrook
Apartments (2.6%), Simmons Tower (5.5%) and Kent Office Portfolio
(3.7%). The Negative Outlook for classes C, PEX, D, E and X-E
reflect the elevated concentration of FLOCs in the pool and
possible downgrades should performance of these aforementioned
retail, multifamily and office FLOCs continue to deteriorate and
fail to refinance at maturity.

WFCM 2015-SG1: The downgrade on class D reflects higher pool loss
expectations since Fitch's prior rating action driven by
performance and upcoming refinance concerns on the FLOCs, including
Patrick Henry Mall (9.7%), DoubleTree DFW (2.8%), 580 Market (2.6%)
and The Fairfax Building (2.5%). The Negative Outlooks for classes
A-S, X-A, B, C, PEX and D reflect the elevated maturity default
risk of the FLOCs in the pool, including high concentration of
specially serviced loans, as well as these classes' reliance on
FLOCs to repay.

WFCM 2015-C29: The affirmations reflect the generally stable pool
performance and loss expectations since Fitch's prior rating
action. The Negative Outlook revision on classes C, PEX, D and E
reflect the elevated level of FLOCs, as well as refinance concerns
and heightened probability of default on the office FLOCs,
including Hutchinson Metro Center I (9.3%), 150 Royal Street
(3.7%), Cathedral Place (3.6%) and Hall Office Park (2.3%).

Largest Contributor to Losses: The largest contributor to pool loss
expectations in the WFCM 2015-C30 transaction is the Riverpark
Square FLOC (8.3%), secured by a 374,490-sf regional mall located
in Spokane, WA and anchored by collateral tenants Nordstrom and AMC
Theater. The servicer-reported occupancy and NOI DSCR were 96% and
1.55x, respectively, as of YTD March 2024, compared to 90% and
1.56x at YE 2022 and 96% and 2.05x at YE 2019. As of the April 2024
rent roll, Nordstrom's lease term has been extended to 2030.
Nordstrom's sales have been declining prior to the pandemic and
were historically below the retailer's national average. Fitch has
not received an updated sales report; the latest reported in-line
tenant sales, excluding Apple, were $289 psf at YE 2021 compared to
$173 psf at YE2020 and $332 psf at YE 2019. Upcoming rollover
includes 8.1% through the end of 2025.

Fitch's 'Bsf' rating case loss of 27.4% (prior to concentration
add-ons) reflects a 15% cap rate, 20% stress to the YE2023 NOI due
to rollover concerns and incorporates a higher probability of
default at maturity given that property cash flow has remained
below pre-pandemic performance. The loan matures in July 2025.

The second largest contributor to pool loss expectations in the
WFCM 2015-C30 transaction is Pennbrook Apartments loan (2.6% of the
pool), a multifamily property located in Philadelphia directly
across from St. Joseph's University. The servicer-reported YE 2023
financials reflected a NCF DSCR of 0.31x and a 36.5% occupancy,
compared with 1.18x and 100%, respectively, at YE 2022. The
property, which was primarily used as student housing for the
adjacent school, is being repositioned according to recent servicer
commentary.

Fitch's 'Bsf' rating case loss of 42.3% (prior to concentration
add-ons) reflects a 9.25% cap rate, 7.5% stress to the YE2023 NOI
and factors a high probability of default due to the loss of the
university master lease and limited time for the sponsor to
reposition and stabilize the asset before the loan's maturity in
July 2025.

The largest contributor to pool loss expectations in the WFCM
2015-SG1 transaction is the specially serviced Patrick Henry Mall
loan (9.7%), which is secured by a 432,401-sf portion of a
716,558-sf regional mall located in Newport News, VA. The loan
transferred to special servicing in January 2024 due to the
bankruptcy of the guarantor, Pennsylvania Real Estate Investment
Trust (PREIT). The loan remains current as of July 2024
remittance.

The largest tenant is JCPenney (19.7% total collateral, expiration
May 2025); the tenant renewed in 2020 for five years and has four
renewal options remaining. Other major tenants include Dick's
Sporting Goods (11.6% NRA, January 2027) and Forever 21 (4.9% NRA,
January 2025). Macy's and Dillard's are non-collateral anchors. The
mall's occupancy has remained steady and was reported at 96%
occupancy as of YE 2023.

Fitch's 'Bsf' rating case loss (prior to concentration adjustments)
of 35.5% reflects a discount to the most recent appraisal value,
equating to a stressed value of $119 psf, accounting for weaker
sponsorship and refinancing concerns at its upcoming July 2025
maturity.

The second largest contributor to pool loss expectations in the
WFCM 2015-SG1 transaction is the real estate owned (REO) Bella of
Baton Rouge asset (1.6% of the pool), a 220-unit apartment complex
located in Baton Rouge, LA. The loan initially transferred to
special servicing in May 2020 for imminent monetary default related
to the pandemic and units remaining offline from previous flooding
in the Baton Rouge area in August 2016. Fitch's 'Bsf' rating case
loss of 100% (prior to concentration add-ons) reflects a discount
to the most recent appraisal, which is down 64% from the issuance
appraisal value, and assumes limited-to-no recovery due to the
increasing total loan exposure.

The third largest contributor to pool loss expectations in the WFCM
2015-SG1 transaction is the 580 Market loan (2.6%), which is
secured by a 31,325-sf mixed-use (office and retail) property
located in downtown San Francisco, CA. The servicer-reported March
2024 NOI DSCR was 0.61x, with occupancy of 80%. The largest tenant,
Evolv (14.6% of the NRA), renewed to January 2026, but Rocket Money
(14.5%) did not renew at its 2024 lease expiration. Overall
occupancy at the property is anticipated to further decline as
other tenants with near-term lease maturities roll. Fitch
incorporated a higher probability of default on this loan to
account for refinancing concerns at its June 2025 maturity. Fitch's
'Bsf' rating case loss of 45% (prior to concentration add-ons)
reflects a 25% stress to reported YE 2023 NOI and a 10% cap rate.

The largest contributor to pool loss expectations in the WFCM
2015-C29 transaction is the 150 Royall Street loan (8.7% of the
pool), which is secured by a 259,341-sf office building located in
Canton, MA, approximately 15 miles southwest of the Boston CBD.
This FLOC was flagged due to declining occupancy, which was 65.8%
as of the March 2024 rent roll. A recent lease with Sick Inc was
signed for 31,569 sf through August 2031, which should boost
occupancy to approximately 77%. The near-term rollover consists of
5.4% in 2025 and 22.6% (from largest tenant Computershare) in
2026.

Fitch's 'Bsf' rating case loss (prior to concentration add-ons) is
28.7%, which reflects a 10% cap rate and a 15% stress to the YE
2023 NOI. Fitch's analysis factored an increased the probability of
default to reflect office sector concerns and heightened maturity
default risk. The loan matures in June 2025.

The second largest contributor to pool loss expectations in the
WFCM 2015-C29 transaction is the Hutchinson Metro Center I loan
(9.3%), which is secured by a four-story office building totaling
422,452-sf located in the Westchester Heights section of the Bronx,
New York. Occupancy has remained high, with a reported YE 2023
occupancy of 99%. The largest tenant, Mercy College (29.7% of the
NRA), renewed to 2034. The second and third largest tenants,
Administration of Children's Services (14.6%) and NYC Housing
Development (14.5%), have lease expirations in March 2027 and March
2026, respectively. Although financial performance has been strong,
Fitch's analysis factored an increased the probability of default
given the concerns with liquidity for the refinancing of large
office properties and concentrated lease rollover after loan
maturity. Fitch's 'Bsf' rating case loss (prior to concentration
add-ons) is 10.2%, which reflects a 9% cap rate and a 20% stress to
the YE 2023 NOI for high submarket availability and lease rollover
concerns. The loan matures in June 2025.

Increased Credit Enhancement (CE); Concentrated Loan Maturities: As
of the July 2024 distribution date, the pool's aggregate balance
for WFCM 2015-C30 has been reduced by 15.1% to $628.6 million from
$740.3 million at issuance. Twenty-two loans (31.2% of pool) have
been defeased. Ninety loans (96.5% of the pool) are scheduled to
mature in 2025. The pool has incurred $2.7 million in realized
losses to date and interest shortfalls of $1.2 million are
currently affecting non-rated class H.

As of the July 2024 distribution date, the pool's aggregate balance
for WFCM 2015-SG1 has been reduced by 17.1% to $594 million from
$716.3 million at issuance. Thirteen loans (12.1% of pool) have
been defeased. Sixty-five loans (99.3% of the pool) are scheduled
to mature in 2025. The pool has incurred $6.6 million in realized
losses to date and interest shortfalls of $2.8 million are
currently affecting the non-rated class H.

As of the July 2024 distribution date, the pool's aggregate balance
for WFCM 2015-C29 has been reduced by 19% to $953.4 million from
$1.2 billion at issuance. Twenty-five loans (22.1% of pool) have
been defeased. Of the remaining pool, 114 loans (99.5% of the pool)
are scheduled to mature in 2025; two loans are ARD. The pool has
incurred $361,011 in realized losses and interest shortfalls of
$94,338 are currently affecting the non-rated class G.

RATING SENSITIVITIES

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

Downgrades to 'AAAsf' rated classes with Stable Outlooks are not
expected due to the position in the capital structure and expected
continued amortization and loan repayments, but may occur if
deal-level losses increase significantly and/or interest shortfalls
occur or are expected to occur.

Downgrades to classes rated in the 'AAAsf', 'AAsf' and 'Asf'
categories, especially those which have Negative Outlooks, may
occur should performance of the FLOCs deteriorate further or if
more loans than expected default at or prior to maturity. These
FLOCs include Riverpark Square, Simmons Tower, Kent Office
Portfolio, Pennbrook Apartments, Sheraton Crescent Phoenix and
Bristol Retail Portfolio in WFCM 2015-C30; Patrick Henry Mall, Boca
Park Marketplace, DoubleTree DFW, 580 Market and The Fairfax
Building in WFCM 2015-SG1; Hutchinson Metro Center I, 150 Royall
Street, Cathedral Place, Hall Office Park and Parkway Crossing East
Shopping Center in WFCM 2015-C29.

Downgrades to classes rated in the 'BBBsf', 'BBsf' and 'Bsf'
categories may occur with higher than expected losses from
continued underperformance of the FLOCs (particularly the
aforementioned FLOCs), FLOCs fail to pay off at maturity, and with
greater certainty of losses on the specially serviced loans or
other FLOCs.

Downgrades to distressed ratings would occur should additional
loans transfer to special servicing or default and/or as losses are
realized or become more certain.

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

Upgrades to classes rated in the 'AAsf' and 'Asf' category may be
possible with significantly increased CE from loan payoffs at
maturity, coupled with stable-to-improved pool-level loss
expectations and/or improved performance on the FLOCs.

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

Upgrades to the 'BBsf' and 'Bsf' category rated classes are not
likely but could occur if the performance of the remaining pool is
stable, recoveries on the FLOCs are better than expected and there
is sufficient CE to the classes.

Upgrades to distressed ratings are not expected, but possible with
better than expected recoveries on specially serviced loans or
significantly higher values on FLOCs.

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

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

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


WELLS FARGO 2017-C41: Fitch Affirms 'B+sf' Rating on Cl. F-RR Certs
-------------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of Wells Fargo Commercial
Mortgage Trust 2017-C41 (WFCM 2017-C41) and 17 classes of Wells
Fargo Commercial Mortgage Trust 2017-C42 (WFCM 2017-C42). Fitch has
also revised the Rating Outlooks for classes C, D and X-D in WFCM
2017-C41 and C, X-B, D and X-D in WFCM 2017-C42 to Negative from
Stable. Fitch has also affirmed the MOA 2020-WC41 E-RR horizontal
risk retention pass through certificate (2017 C41 III).

   Entity/Debt           Rating             Prior
   -----------           ------             -----
WFCM 2017-C41

   A-2 95001ABA3     LT AAAsf   Affirmed    AAAsf
   A-3 95001ABC9     LT AAAsf   Affirmed    AAAsf
   A-4 95001ABD7     LT AAAsf   Affirmed    AAAsf
   A-S 95001ABG0     LT AAAsf   Affirmed    AAAsf
   A-SB 95001ABB1    LT AAAsf   Affirmed    AAAsf
   B 95001ABH8       LT AA-sf   Affirmed    AA-sf
   C 95001ABJ4       LT A-sf    Affirmed    A-sf
   D 95001AAD8       LT BBB+sf  Affirmed    BBB+sf
   E-RR 95001AAG1    LT BBB-sf  Affirmed    BBB-sf
   F-RR 95001AAK2    LT B+sf    Affirmed    B+sf
   G-RR 95001AAN6    LT CCCsf   Affirmed    CCCsf
   X-A 95001ABE5     LT AAAsf   Affirmed    AAAsf
   X-B 95001ABF2     LT AA-sf   Affirmed    AA-sf
   X-D 95001AAA4     LT BBB+sf  Affirmed    BBB+sf

WFCM 2017-C42

   A-2 95001GAB9     LT AAAsf   Affirmed    AAAsf
   A-3 95001GAD5     LT AAAsf   Affirmed    AAAsf  
   A-4 95001GAE3     LT AAAsf   Affirmed    AAAsf
   A-BP 95001GAF0    LT AAAsf   Affirmed    AAAsf
   A-S 95001GAK9     LT AAAsf   Affirmed    AAAsf
   A-SB 95001GAC7    LT AAAsf   Affirmed    AAAsf
   B 95001GAL7       LT AA-sf   Affirmed    AA-sf
   C 95001GAM5       LT A-sf    Affirmed    A-sf
   D 95001GAU7       LT BBB-sf  Affirmed    BBB-sf
   E 95001GAW3       LT B-sf    Affirmed    B-sf
   F 95001GAY9       LT CCCsf   Affirmed    CCCsf
   X-A 95001GAG8     LT AAAsf   Affirmed    AAAsf
   X-B 95001GAJ2     LT A-sf    Affirmed    A-sf
   X-BP 95001GAH6    LT AAAsf   Affirmed    AAAsf
   X-D 95001GAN3     LT BBB-sf  Affirmed    BBB-sf
   X-E 95001GAQ6     LT B-sf    Affirmed    B-sf
   X-F 95001GAS2     LT CCCsf   Affirmed    CCCsf

MOA 2020-WC41 E

   E-RR 90215VAA1    LT BBB-sf  Affirmed    BBB-sf

KEY RATING DRIVERS

Performance and 'B' Loss Expectations: Deal-level 'Bsf' rating case
losses are 4.3% in WFCM 2017-C41 and 5.4% in WFCM 2017-C42. Fitch
Loans of Concerns (FLOCs) comprise 15 loans (48.1% of the pool) in
WFCM 2017-C41 and 10 loans (32.9%) in WFCM 2017-C42, including two
specially serviced loans (1.3%).

The affirmations of all the transactions reflect generally stable
pool performance and loss expectations since Fitch's prior rating
action. The Negative Outlooks in each deal reflect refinancing
concerns for FLOCs secured by office properties (17.1% in WFCM
2017-C41 and 20.9% in WFCM 2017-C42). Additionally, Negative
Outlooks in WFCM 2017-C41 reflect a sensitivity analysis including
a heightened probability of default for National Office Portfolio.

The largest contributor to overall loss expectations WFCM 2017-C41
is the DoubleTree Berkeley Marina loan (2.6%), which is a FLOC due
to the significant decline in NOI since 2019. The property is a
378-key full-service hotel located on the waterfront in Berkeley,
CA. The YE 2023 NOI is depressed compared to pre-pandemic level and
is 23% below YE 2022, 61% below YE 2019 and 51% below the Fitch
issuance NCF. Overall revenues have grown 3% between 2023 and 2022
while total expenses have grown 7% YoY. YE 2023 revenues are down
19% compared to underwriting.

Occupancy improved to 68% for the TTM ending December 2023,
compared to 52% for the TTM ending January 2022 and 36% for the TTM
ending January 2021. The property is outperforming its competitive
set with pentation rates of 104%, 104% and 108% for occupancy, ADR,
and RevPAR, respectively. Fitch's 'Bsf' rating case loss of 20%
(prior to concentration add-ons) reflects a 11.25% cap rate and the
YE 2023 NOI with no stress.

The National Office Portfolio (3.7%) loan is a FLOC due to low
occupancy and lease rollover concerns in 2025. The portfolio
consists of 18 office properties totaling 2,572,700-sf located in
Dallas, Atlanta, Phoenix, and Chicago. The properties were
constructed between 1973 and 1987 and range in size from 46,769-sf
to 381,383-sf. The largest tenants include American
Intercontinental University (4.1% of portfolio NRA; exp. May 2028)
and Trinity Universal Insurance Co (3.9% of NRA; exp. June 2025).

As of YE 2023, occupancy was 76% compared to 74.8% at YE 2022 and
74% at YE 2021. The loan was underwritten to 78% occupancy.
Approximately 3.3% of portfolio NRA expires in 2024 and 11% in
2025. According to CoStar data, the properties generally have lower
asking rents compared with metro averages and higher vacancy rates
than submarket data, assumed to be due to the portfolio consisting
of older product. Fitch's 'Bsf' rating case loss of 2% (prior to
concentration add-ons) reflects a 10.5% cap rate and the YE 2022
NOI with a 10% stress. Fitch's heightened probability of default
sensitivity results in a 'Bsf' rating case loss of 21% (prior to
concentration add-ons).

The largest contributor to overall loss expectations WFCM 2017-C42
is the 16 Court Street loan (8.9%) which is a FLOC due to declining
occupancy and cashflow. The loan is secured by a 36-story,
325,510-sf, office building located in Brooklyn, New York. The YE
2023 NOI is 10% above YE 2022, 21% below YE 2021 and 26% below the
Fitch issuance NCF. Per the March 2024 rent roll, the property was
70.2% occupied compared 70.1% at YE 2022 and 93% at underwriting.
Rollover included 20.6% of NRA in 2024 (including the largest
tenant The City University of New York) and 2% in 2025. Per the
servicer commentary, the loan is currently being cash managed.

Per CoStar as of QTD 3Q2024, comparable properties in the Downtown
Brooklyn Office submarket had a 27.4% vacancy rate, 25%
availability rate and $52.75 market asking rent while the total
submarket had a 19.6% vacancy rate, 19% availability rate and
$50.96 market asking rent. Per the March 2024 rent roll, the
property had average in-place rent of $56.20 psf. Fitch's 'Bsf'
rating case loss of 19% (prior to concentration add-ons) reflects a
9.25% cap rate and the YE 2022 NOI with a 10% stress.

One Century Place (5.9%) is a FLOC due to occupancy declines,
subleasing and weak submarket. The property is a 538,792-sf
suburban office property located in Nashville, TN. Per the March
2024 rent roll, the property was 73.9% occupied and 26.1% vacant.
Occupancy decreased from 85% at YE 2022 and 100% at underwriting.
The largest tenant Willis North America (32.9% NRA, exp. April
2026) subleased approximately 80,000-sf (45% of their space, 15% of
total NRA) to Blue Cross Blue Shield in 2020 (expiring 2026).
Willis North America is 49% of annual base rent.

Per CoStar as of QTD 3Q2024, comparable properties in the Airport
North Office Submarket had a 16.2% vacancy rate, 25.3% availability
rate and $30.84 market asking rent while the total submarket had a
14.4% vacancy rate, 18.4% availability rate and $27.04 market
asking rent. Per the March 2024 rent roll, the property had average
in-place rent of $24.58 psf. Fitch's 'Bsf' rating case loss of 4%
(prior to concentration add-ons) reflects a 10% cap rate and the YE
2023 NOI with a 20% stress.

River Park I (2.4%) is a FLOC as the sole tenant, Reimbursement
Technologies (98.2% of NRA; exp. October 2029), has approximately
60% of its space on the sublease market. The loan is secured by a
167,663-sf suburban office property located in Conshohocken, PA.
Per CoStar as of QTD 3Q2024, comparable properties in the
Conshohocken Office Submarket had a 12.2% vacancy rate, 19.1%
availability rate and $38.58 market asking rent while the total
submarket had a 11.8% vacancy rate, 18.3% availability rate and
$35.32 market asking rent. Fitch's 'Bsf' rating case loss of 4%
(prior to concentration add-ons) reflects a 10% cap rate and the YE
2023 NOI with a 40% stress.

Defeasance: Respective defeasance percentages in the WFCM 2017-C41
and WFCM 2017-C42 transactions include 8.1% (four loans) and 2.5%
(three loans).

Increased Credit Enhancement (CE): As of the July 2024 remittance
report, the aggregate balances of the WFCM 2017-C41 and WFCM
2017-C42 transactions have been reduced by 8% and 4%, respectively,
since issuance. Loan maturities are concentrated in 2027 with 46
loans for 100% of the pool in WFCM 2017-C41 and 32 loans for 98.8%
of the pool in WFCM 2017-C42.

Cumulative interest shortfalls for the WFCM 2017-C41 and WFCM
2017-C42 transactions are $465,000 and $414,800 respectively; in
both transactions, they are affecting the non-rated class H-RR or
G.

RATING SENSITIVITIES

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

Classes with Negative Outlooks reflect possible future downgrades
should the FLOCs continue to exhibit performance declines or fail
to stabilize. If expected losses do increase, downgrades to these
classes are likely.

Downgrades to the senior 'AAAsf' rated classes are not expected due
to the position in the capital structure and expected continued
amortization and loan repayments, but may occur if deal-level
losses increase significantly and/or interest shortfalls occur or
are expected to occur.

Downgrades to the junior 'AAAsf' rated classes with Negative
Outlooks are expected with continued performance deterioration of
the FLOCs, increased expected losses and limited to no improvement
in class CE, or if interest shortfalls occur.

Downgrades to classes rated in the 'AAsf' and 'Asf' categories may
occur should performance of the FLOCs deteriorate further or if
more loans than expected default at or prior to maturity. These
FLOCs include National Office Portfolio in WFCM 2017-C41 and One
Century Place and River Park I in WFCM 2017-C42.

Downgrades to classes rated in the 'BBBsf' and 'Bsf' categories,
which have Negative Outlooks in each transaction, could occur with
higher than expected losses from continued underperformance of the
FLOCs, particularly the aforementioned loans with deteriorating
performance and with greater certainty of losses on the specially
serviced loans or other FLOCs.

Downgrades to distressed ratings of 'CCCsf' would occur as losses
become more certain and/or as losses are incurred.

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

Upgrades to 'AAsf' and 'Asf' category rated classes are possible
with significantly increased CE from paydowns, coupled with
stable-to-improved pool-level loss expectations and performance
stabilization of FLOCs. Upgrades of these classes to 'AAAsf' would
also consider the concentration of defeased loans in the
transaction.

Upgrades to the 'BBBsf' category rated classes would be limited
based on sensitivity to concentrations or the potential for future
concentration and would only occur with sustained performance
improvement of the FLOCs.

Upgrades to 'Bsf' category rated classes are not likely until the
later years in a transaction and only if the performance of the
remaining pool is stable and there is sufficient CE to the
classes.

Upgrades to distressed ratings are not expected but possible with
better than expected recoveries on specially serviced loans.

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

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

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


WELLS FARGO 2024-C63: Fitch Gives B-(EXP) Rating on Cl. G-RR Certs
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Wells Fargo Commercial Mortgage Trust 2024-C63 commercial mortgage
pass-through certificates series 2024-C63 as follows:

- $9,518,000 class A-1 'AAAsf'; Outlook Stable;

- $65,000,000 class A-3 'AAAsf'; Outlook Stable;

- $15,597,000 class A-SB 'AAAsf'; Outlook Stable;

- $100,000,000d class A-4 'AAAsf'; Outlook Stable;

- $309,657,000d class A-5 'AAAsf'; Outlook Stable;

- $499,772,000a class X-A 'AAAsf'; Outlook Stable;

- $101,739,000 class A-S 'AAAsf'; Outlook Stable;

- $32,128,000 class B 'AA-sf'; Outlook Stable;

- $18,742,000 class C 'A-sf'; Outlook Stable;

- $152,609,000a class X-B 'A-sf'; Outlook Stable;

- $11,601,000 class D 'BBBsf'; Outlook Stable;

- $7,140,000 class E 'BBB-sf'; Outlook Stable;

- $18,741,000a class X-D 'BBB-sf'; Outlook Stable;

- $13,387,000 class F 'BB-sf'; Outlook Stable;

- $13,387,000 class X-F 'BB-sf'; Outlook Stable;

- $8,924,000bc class G-RR 'B-sf'; Outlook Stable.

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

- $20,527,138bc class J-RR.

(a) Notional amount and interest-only.

(b) Privately placed pursuant to Rule 144A.

(c) Class G-RR and J-RR certificates comprise the transaction's
horizontal risk retention interest.

(d) The expected class A-4 balance range is $0-$200,000,000, and
the expected class A-5 balance range is $209,657,000-$409,657,000,
both net of their proportionate share of the Combined VRR Interest.
The balance for class A-4 reflects the top point of its range, and
the balance for class A-5 reflects the bottom point of its range,
net of their proportionate share of the Combined VRR Interest. In
the event the class A-5 certificates are issued at $409,657,000,
the class A-4 certificates will not be issued.

The expected ratings are based on information provided by the
issuer as of Aug. 12, 2024.

Transaction Summary

The certificates represent the beneficial ownership interest in the
trust, the primary assets of which are 30 loans secured by 30
commercial properties having an aggregate principal balance of
$713,960,139 as of the cutoff date. The loans were contributed to
the trust by Goldman Sachs Mortgage Company, Argentic Real Estate
Finance 2 LLC, Société Générale Financial Corporation, JPMorgan
Chase Bank, National Association, National Cooperative Bank, N.A.,
and Wells Fargo Bank, National Association.

The general master servicer is expected to be Wells Fargo Bank,
National Association, and the general special servicer is expected
to be Argentic Services Company LP. National Cooperative Bank, N.A.
is expected to serve as the master servicer and special servicer
for the loans that National Cooperative Bank, N.A. contributed to
the trust. The trustee and certificate administrator is excepted to
be Computershare Trust Company, National Association. The
certificates are expected to follow a sequential paydown
structure.

KEY RATING DRIVERS

Fitch Net Cash Flow: Fitch performed cash flow analyses on 20 loans
totaling 93.8% of the pool by balance. Fitch's resulting aggregate
net cash flow (NCF) of $274.2 million represents a 14.1% decline
from the issuer's aggregate underwritten NCF of $319.1 million.

Lower Fitch Leverage: The pool has lower leverage compared to
recent multiborrower transactions rated by Fitch. The pool's Fitch
loan-to-value ratio (LTV) of 77.0% is better than both the 2024 YTD
and 2023 averages of 89.47 and 88.3%, respectively. The pool's
Fitch NCF debt yield (DY) of 14.2% is better than both the 2024 YTD
and 2023 averages of 11.2% and 10.9%, respectively.

Investment Grade Credit Opinion Loans: Six loans representing 43.0%
of the pool by balance received an investment grade credit opinion.
Bridge Point Rancho Cucamonga (9.1%) received an investment grade
credit opinion of 'BBB+sf*' on a standalone basis. Marriott Myrtle
Beach Grande Dunes Resort (8.4%) received an investment grade
credit opinion of 'BBBsf*' on a standalone basis. 610 Newport
Center (7.7%) received an investment grade credit opinion of
'A-sf*' on a standalone basis. St. Johns Town Center (6.4%)
received an investment grade credit opinion of 'Asf*' on a
standalone basis. Mercer Square Owners Corp. (6.0%) received an
investment grade credit opinion of 'AAAsf*' on a standalone basis.
Arizona Grand Resort and Spa (5.3%) received an investment grade
credit opinion of 'A-sf*' on a standalone basis. The pool's total
credit opinion percentage is significantly greater than both the
2024 YTD average of 14.0% and the 2023 average of 17.8%. Excluding
the credit opinion loans, the pool's Fitch LTV and DY are 95.2% and
10.7%, respectively, compared to the equivalent conduit 2024 YTD
LTV and DY averages of 94.1% and 10.6%, respectively.

Higher Pool Concentration: The pool is more concentrated than
recently rated Fitch transactions. The top 10 loans make up 68.8%
of the pool, which is worse than both the 2024 YTD average of 59.3%
and the 2023 average of 63.7%. Fitch measures loan concentration
risk with an effective loan count, which accounts for both the
number and size of loans in the pool. The pool's effective loan
count is 17.6. Fitch views diversity as a key mitigant to
idiosyncratic risk. Fitch raises the overall loss for pools with
effective loan counts below 40.

RATING SENSITIVITIES

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

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

- 10% NCF Decline: 'AAAsf' / 'AA-sf' / 'A-sf' / 'BBBsf' / 'BB+sf' /
'BBsf' / 'Bsf'.

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

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

- 10% NCF Increase: 'AAAsf' / 'AAAsf' / 'AA+sf' / 'Asf' / 'BBB+sf'
/ 'BBBsf' / 'BBsf'.

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

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

ESG Considerations

The highest level of ESG credit relevance is a score of '3', unless
otherwise disclosed in this section. A score of '3' 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. Fitch's ESG Relevance Scores are not
inputs in the rating process; they are an observation on the
relevance and materiality of ESG factors in the rating decision.


WELLS FARGO 2024-MGP: Moody's Assigns Ba3 Rating to HRR-11 Certs
----------------------------------------------------------------
Moody's Ratings has assigned definitive ratings to ten classes of
CMBS securities, issued by Wells Fargo Commercial Mortgage Trust
2024-MGP, Commercial Mortgage Pass-Through Certificates, 2024-MGP.

Cl. A-11, Definitive Rating Assigned Aaa (sf)

Cl. B-11, Definitive Rating Assigned Aa3 (sf)

Cl. C-11, Definitive Rating Assigned A3 (sf)

Cl. D-11, Definitive Rating Assigned Baa3 (sf)

Cl. E-11, Definitive Rating Assigned Ba2 (sf)

Cl. HRR-11, Definitive Rating Assigned Ba3 (sf)

Cl. A-12, Definitive Rating Assigned Aaa (sf)

Cl. B-12, Definitive Rating Assigned Aa3 (sf)

Cl. C-12, Definitive Rating Assigned A3 (sf)

Cl. HRR-12, Definitive Rating Assigned Baa1 (sf)

RATINGS RATIONALE

The certificates are collateralized by two uncrossed commercial
mortgage loans:

i. A floating-rate and interest-only mortgage loan (the "Fund XI
Loan") secured by the related borrowers' fee simple interest(s) in
a seven-property portfolio comprised of six
grocery/pharmacy-anchored retail centers and one power center. The
properties total 1.3 million SF of rentable area and are located
across California and Washington (collectively, the "Fund XI
Properties" or the "Fund XI Portfolio").

ii. A floating-rate and interest-only mortgage loan (the "Fund XII
Loan") secured by the related borrowers' fee simple and leasehold
interest(s) in an 11-property portfolio comprised of 10
grocery/pharmacy-anchored retail centers and one retail center
containing a gym. The properties total 2.1 million SF of rentable
area and are located across California and Washington
(collectively, the "Fund XII Properties" or the "Fund XII
Portfolio").

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

The 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 Moody's first mortgage actual Fund XI DSCR is 1.17x and Moody's
first mortgage actual stressed Fund XI DSCR is 0.92x. Moody's DSCR
is based on Moody's stabilized net cash flow. The Fund XI loan
first mortgage balance of $238.0 million represents a Fund XI
Moody's LTV ratio of 102.5% based on Moody's Value. Adjusted Fund
XI Moody's LTV ratio for the first mortgage balance is 93.2%,
compared to 92.9% in place at Moody's provisional ratings, based on
Moody's Value using a cap rate adjusted for the current interest
rate environment.

With respect to Fund XI loan level diversity, the pool's loan level
Herfindahl score is 4.19. Moody's also grade properties on a scale
of 0 to 5 (best to worst) and consider those grades when assessing
the likelihood of debt payment. The factors considered include
property age, quality of construction, location, market, and
tenancy. The portfolio's property quality grade is 1.75.

The Moody's first mortgage actual Fund XII DSCR is 1.49x and
Moody's first mortgage actual stressed Fund XII DSCR is 1.05x.
Moody's DSCR is based on Moody's stabilized net cash flow. The Fund
XII loan first mortgage balance of $425.0 million represents a Fund
XII Moody's LTV ratio of 87.1% based on Moody's Value. Adjusted
Fund XII Moody's LTV ratio for the first mortgage balance is 79.2%,
compared to 79.0% in place at Moody's provisional ratings, based on
Moody's Value using a cap rate adjusted for the current interest
rate environment.

With respect to Fund XI loan level diversity, the pool's loan level
Herfindahl score is 6.29. Moody's also grade properties on a scale
of 0 to 5 (best to worst) and consider those grades when assessing
the likelihood of debt payment. The factors considered include
property age, quality of construction, location, market, and
tenancy. The portfolio's property quality grade is 1.50.

Notable strengths of the transaction include: i. the property's
strong anchor tenancy and tenant mix; ii. Locations; iii. tenant
sales; iv. multiple property pooling; and v. sponsorship. Notable
concerns of the transaction include: i. low percentage of tenants
reporting sales; ii. high share of discretionary retail offerings;
iii. a high MLTV ratio; iv. floating-rate interest-only loan
profile; and v. credit negative legal features.

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

The principal methodology used in these ratings was "Large Loan and
Single Asset/Single Borrower Commercial Mortgage-backed
Securitizations" published in July 2024.

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

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

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


[*] DBRS Confirms 12 Ratings From 3 Oportun Transactions
--------------------------------------------------------
DBRS, Inc. (i) confirmed eight credit ratings from two Oportun
Issuance Trust transactions and (ii) confirmed four credit ratings
from Oportun Funding XIV, LLC.

The Issuers are:

Oportun Issuance Trust 2022-A
Oportun Issuance Trust 2021-B
Oportun Funding XIV, LLC, Series 2021-A

The ratings are:

                 Debt Rated       Action
                 ----------       ------
Oportun Funding XIV, LLC, Series 2021-A

Class A         AA(low)(sf)      Confirmed
Class B         A(low)(sf)       Confirmed
Class C         BBB(low)(sf)     Confirmed
Class D         BB(high)(sf)     Confirmed

Oportun Issuance Trust 2021-B

Class A Notes   AA(low)sf        Confirmed
Class B Notes   A(low)sf         Confirmed
Class C Notes   BBB(low)(sf)     Confirmed
Class D Notes   BB(high)(sf)     Confirmed

Oportun Issuance Trust 2022-A

Class A Notes   AA(low)(sf)      Confirmed
Class B Notes   A(low)(sf)       Confirmed
Class C Notes   BBB(low)(sf)     Confirmed
Class D Notes   BB(high)(sf)     Confirmed

The credit rating actions are based on the following analytical
considerations:

Although losses are tracking above the Morningstar DBRS initial
base-case CNL expectations, the current level of hard CE and
estimated excess spread are sufficient to support the Morningstar
DBRS projected remaining CNL assumptions at a multiple of coverage
commensurate with the credit ratings.

The transaction capital structures and form and sufficiency of
available CE.

The transaction parties' capabilities with regard to originating,
underwriting, and servicing.

The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary, "Baseline Macroeconomic Scenarios for Rated
Sovereigns June 2024 Update," published on June 28, 2024. These
baseline macroeconomic scenarios replace Morningstar DBRS' moderate
and adverse coronavirus pandemic scenarios, which were first
published in April 2020.

Notes: The principal methodology applicable to the credit ratings
is Morningstar DBRS Master U.S. ABS Surveillance.


[*] DBRS Reviews 161 Classes From 24 US RMBS Transactions
---------------------------------------------------------
DBRS, Inc. reviewed 161 classes from 24 U.S. residential
mortgage-backed securities (RMBS) transactions. Out of the 24
transactions reviewed, 21 are classified as Non-QM and three as
reperforming mortgages. Of the 161 classes reviewed, Morningstar
DBRS upgraded its credit ratings on 58 classes and confirmed its
credit ratings on 103 classes.

The Affected Ratings are available at https://bit.ly/3XbCpQH

The Issuers are:

CTDL 2020-1 Trust
GCAT 2022-NQM4 Trust
CHNGE Mortgage Trust 2023-4
Towd Point Mortgage Trust 2022-2
CHNGE Mortgage Trust 2022-NQM1
J.P. Morgan Mortgage Trust 2023-DSC2
CHNGE Mortgage Trust 2023-1
CHNGE Mortgage Trust 2022-5
Angel Oak Mortgage Trust 2019-6
BRAVO Residential Funding Trust 2021-NQM3
BRAVO Residential Funding Trust 2022-NQM3
Angel Oak Mortgage Trust I 2019-2
Residential Mortgage Loan Trust 2019-3
Residential Mortgage Loan Trust 2019-2
Angel Oak Mortgage Trust I, LLC 2019-1
Homeward Opportunities Fund Trust 2022-1
Galton Funding Mortgage Trust 2020-H1
Angel Oak Mortgage Trust I, LLC 2018-3
Spruce Hill Mortgage Loan Trust 2020-SH1
Barclays Mortgage Loan Trust 2021-NQM1
BRAVO Residential Funding Trust 2022-NQM1
Angel Oak Mortgage Trust 2019-5
GS Mortgage-Backed Securities Trust 2022-RPL4
Freddie Mac Seasoned Credit Risk Transfer Trust, Series 2023-1

The credit rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new credit rating levels. The credit rating confirmations
reflect asset performance and credit-support levels that are
consistent with the current credit ratings.

Morningstar DBRS' credit ratings on the applicable classes address
the credit risk associated with the identified financial
obligations in accordance with the relevant transaction documents.
Where applicable, a description of these financial obligations can
be found in the transactions' respective press releases at
issuance.

Morningstar DBRS' long-term credit ratings provide opinions on risk
of default. Morningstar DBRS considers risk of default to be the
risk that an issuer will fail to satisfy the financial obligations
in accordance with the terms under which a long-term obligation has
been issued. The Morningstar DBRS short-term debt credit rating
scale provides an opinion on the risk that an issuer will not meet
its short-term financial obligations in a timely manner.

The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary "Baseline Macroeconomic Scenarios for Rated
Sovereigns June 2024 Update" published on June 28, 2024,
(https://dbrs.morningstar.com/research/435206) These baseline
macroeconomic scenarios replace Morningstar DBRS' moderate and
adverse coronavirus pandemic scenarios, which were first published
in April 2020.

The credit rating actions are the result of Morningstar DBRS'
application of its "U.S. RMBS Surveillance Methodology," published
on June 28, 2024.

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


[*] DBRS Reviews 683 Classes From 25 US RMBS Transactions
---------------------------------------------------------
DBRS, Inc. reviewed 683 classes from 25 U.S. residential
mortgage-backed securities (RMBS) transactions. This review
consists of 25 transactions generally-classified as Prime. Of the
683 classes reviewed, Morningstar DBRS upgraded 68 credit ratings
and confirmed 615 credit ratings.

The Affected Ratings are available at https://bit.ly/3AyEptB

The Issuers are:

J.P. Morgan Mortgage Trust 2013-3 Mortgage Pass-Through
Certificates, Series 2013-3
J.P. Morgan Mortgage Trust 2018-4
J.P. Morgan Mortgage Trust 2021-13
J.P. Morgan Mortgage Trust 2021-11
J.P. Morgan Mortgage Trust 2019-2
J.P. Morgan Mortgage Trust 2015-6
J.P. Morgan Mortgage Trust 2018-3
J.P. Morgan Mortgage Trust 2018-8
J.P. Morgan Mortgage Trust 2023-7
J.P. Morgan Mortgage Trust 2017-6
J.P. Morgan Mortgage Trust 2015-1
J.P. Morgan Mortgage Trust 2017-3
J.P. Morgan Mortgage Trust 2014-2
J.P. Morgan Mortgage Trust 2021-12
J.P. Morgan Mortgage Trust 2020-LTV1
J.P. Morgan Mortgage Trust 2020-LTV2
J.P. Morgan Mortgage Trust 2019-INV3
J.P. Morgan Mortgage Trust 2021-LTV2
J.P. Morgan Mortgage Trust 2020-INV1
J.P. Morgan Mortgage Trust 2018-7FRB
J.P. Morgan Mortgage Trust 2019-LTV1
J.P. Morgan Mortgage Trust 2014-IVR3
J.P. Morgan Mortgage Trust 2016-3
J.P. Morgan Mortgage Trust 2016-1
J.P. Morgan Mortgage Trust 2020-3

The credit rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new credit rating levels. The credit rating confirmations
reflect asset performance and credit-support levels that are
consistent with the current credit ratings.

Morningstar DBRS' credit ratings on the applicable classes address
the credit risk associated with the identified financial
obligations in accordance with the relevant transaction documents.
Where applicable, a description of these financial obligations can
be found in the transactions' respective press releases at
issuance.

The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary "Baseline Macroeconomic Scenarios for Rated
Sovereigns June 2024 Update" published on June 28, 2024,
(https://dbrs.morningstar.com/research/435206/baseline-macroeconomic-scenarios-for-rated-sovereigns-june-2024-update)
These baseline macroeconomic scenarios replace Morningstar DBRS'
moderate and adverse coronavirus pandemic scenarios, which were
first published in April 2020.

The credit rating actions are the result of Morningstar DBRS'
application of its "U.S. RMBS Surveillance Methodology," published
on June 28, 2024.

Morningstar DBRS' long-term credit ratings provide opinions on risk
of default. Morningstar DBRS considers risk of default to be the
risk that an issuer will fail to satisfy the financial obligations
in accordance with the terms under which a long-term obligation has
been issued. The Morningstar DBRS short-term debt credit rating
scale provides an opinion on the risk that an issuer will not meet
its short-term financial obligations in a timely manner.

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


[*] DBRS Reviews 713 Classes From 17 US RMBS Transactions
---------------------------------------------------------
DBRS, Inc. reviewed 713 classes from 17 U.S. residential
mortgage-backed securities (RMBS) transactions. Of the 17
transactions reviewed 14 are classified as prime jumbo
transactions, two are classified as agency credit risk-transfer
transactions and one is classified as a mortgage insurance
linked-note transaction. Of the 713 classes reviewed, Morningstar
DBRS upgraded 24 credit ratings and confirmed 689 credit ratings.

The Affected Ratings are available at https://bit.ly/3Md8PnD

The Issuers are:

OBX 2021-J3 Trust
Flagstar Mortgage Trust 2021-12
Radnor Re 2023-1 Ltd.
Flagstar Mortgage Trust 2021-7
Mello Mortgage Capital Acceptance 2021-INV2
Wells Fargo Mortgage Backed Securities 2021-2 Trust
Flagstar Mortgage Trust 2018-3INV
Citigroup Mortgage Loan Trust 2021-INV3
Citigroup Mortgage Loan Trust 2021-INV2
Freddie Mac STACR REMIC Trust 2022-HQA3
Flagstar Mortgage Trust 2017-2
GS Mortgage-Backed Securities Trust 2021-PJ9
GS Mortgage-Backed Securities Trust 2022-LTV2
WinWater Mortgage Loan Trust 2014-2
WinWater Mortgage Loan Trust 2015-1
FirstKey Mortgage Trust 2015-1, Mortgage Pass-Through Certificates
Connecticut Avenue Securities Trust 2022-R09

The credit rating upgrades reflect positive performance trends and
increases in credit support sufficient to withstand stresses at
their new credit rating levels. The credit rating confirmations
reflect asset performance and credit-support levels that are
consistent with the current credit ratings.

The transaction assumptions consider Morningstar DBRS' baseline
macroeconomic scenarios for rated sovereign economies, available in
its commentary "Baseline Macroeconomic Scenarios for Rated
Sovereigns June 2024 Update" published on June 28, 2024
(https://dbrs.morningstar.com/research/435206). These baseline
macroeconomic scenarios replace Morningstar DBRS' moderate and
adverse coronavirus pandemic scenarios, which were first published
in April 2020.

The credit rating actions are the result of Morningstar DBRS'
application of its "U.S. RMBS Surveillance Methodology," published
on June 28, 2024.

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


[*] Moody's Upgrades Ratings on $325MM of US RMBS Issued 2017-2019
------------------------------------------------------------------
Moody's Ratings has upgraded the ratings of 20 bonds from seven US
residential mortgage-backed transactions (RMBS). The transactions
are backed by seasoned performing and modified re-performing
residential mortgage loans (RPL). The collateral is serviced by
multiple servicers.

A comprehensive review of all credit ratings for the respective
transactions have been conducted during a rating committee.

The complete rating actions are as follows:

Issuer: CIM Trust 2019-R2

Cl. B1, Upgraded to A3 (sf); previously on Oct 6, 2023 Upgraded to
Ba1 (sf)

Cl. B2, Upgraded to Baa3 (sf); previously on Oct 6, 2023 Upgraded
to B1 (sf)

Cl. M2, Upgraded to Aaa (sf); previously on Oct 6, 2023 Upgraded to
Aa3 (sf)

Cl. M3, Upgraded to Aa3 (sf); previously on Oct 6, 2023 Upgraded to
Baa1 (sf)

Issuer: CIM Trust 2019-R5

Cl. B1, Upgraded to Aaa (sf); previously on Oct 6, 2023 Upgraded to
A2 (sf)

Cl. B2, Upgraded to Aa2 (sf); previously on Oct 6, 2023 Upgraded to
Baa3 (sf)

Cl. M3, Upgraded to Aaa (sf); previously on Oct 6, 2023 Upgraded to
Aa2 (sf)

Issuer: GCAT 2019-RPL1 Trust

Cl. B-1, Upgraded to Aa2 (sf); previously on Oct 6, 2023 Upgraded
to Baa1 (sf)

Cl. B-2, Upgraded to A3 (sf); previously on Oct 6, 2023 Upgraded to
Ba2 (sf)

Cl. B-3, Upgraded to B1 (sf); previously on Oct 6, 2023 Upgraded to
Caa3 (sf)

Cl. M-2, Upgraded to Aaa (sf); previously on Oct 6, 2023 Upgraded
to Aa1 (sf)

Cl. M-3, Upgraded to Aaa (sf); previously on Oct 6, 2023 Upgraded
to A1 (sf)

Issuer: Mill City Mortgage Loan Trust 2017-3

Cl. B1, Upgraded to Aaa (sf); previously on Oct 25, 2023 Upgraded
to Aa1 (sf)

Issuer: MILL CITY MORTGAGE LOAN TRUST 2018-3

Cl. M3, Upgraded to Aaa (sf); previously on Oct 25, 2023 Upgraded
to Aa1 (sf)

Issuer: MILL CITY MORTGAGE LOAN TRUST 2018-4

Cl. A4, Upgraded to Aaa (sf); previously on Oct 25, 2023 Upgraded
to Aa2 (sf)

Cl. M3, Upgraded to Aaa (sf); previously on Oct 25, 2023 Upgraded
to Aa3 (sf)

Issuer: Mill City Mortgage Loan Trust 2019-1

Cl. A4, Upgraded to Aaa (sf); previously on Oct 25, 2023 Upgraded
to Aa2 (sf)

Cl. B1, Upgraded to Aa2 (sf); previously on Oct 25, 2023 Upgraded
to Baa2 (sf)

Cl. B2, Upgraded to Baa2 (sf); previously on Oct 25, 2023 Upgraded
to B2 (sf)

Cl. M3, Upgraded to Aaa (sf); previously on Oct 25, 2023 Upgraded
to A1 (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 a one-year increase in credit enhancement of
2.9% on average, for the bonds Moody's upgraded. The loans
underlying most of the pools have fewer delinquencies and have
prepaid at a faster rate than originally anticipated, resulting in
an improvement of approximately 16.2%, on average, in Moody's loss
projections for the pools since Moody's last review (link above
provides Moody's current estimates).  

Moody's analysis also considered the existence of historical
interest shortfalls for some of the bonds. All the shortfalls have
since been recouped, the size and length of the past shortfalls, as
well as the potential for recurrence, were analyzed as part of the
upgrades.

The rating actions also reflect the further seasoning of the
collateral and increased clarity regarding the impact of borrower
relief programs on collateral performance. Information obtained
from loan servicers in recent years has shed light on their current
strategies regarding borrower relief programs and the impact those
programs may have on collateral performance. Moody's recent
analysis has found that in addition to robust home price
appreciation, many of these borrower relief programs have
contributed to stronger collateral performance than Moody's had
previously expected, thus supporting the upgrades.

No actions were taken on the other rated classes in these deals as
those classes are already at the highest achievable levels within
Moody's rating scale. Moody's analysis also considered the
relationship of exchangeable bonds to the bonds they could be
exchanged for.

Principal Methodologies

The methodologies used in these ratings were "Non-performing and
Re-performing Loan Securitizations" published in April 2024.

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 Ups Ratings on $209MM of US RMBS Issued 2015-2019
-------------------------------------------------------------
Moody's Ratings, in mid-August 2024, upgraded the ratings of 17
bonds from seven US residential mortgage-backed transactions
(RMBS). The transactions are backed by seasoned performing and
modified re-performing residential mortgage loans (RPL). The
collateral is serviced by multiple servicers.

A comprehensive review of all credit ratings for the respective
transactions has been conducted during a rating committee.

The complete rating actions are as follows:

Issuer: Citigroup Mortgage Loan Trust 2015-A

Cl. B-4, Upgraded to Aaa (sf); previously on Oct 30, 2023 Upgraded
to A1 (sf)

Issuer: Citigroup Mortgage Loan Trust 2015-PS1

Cl. B-3, Upgraded to Aaa (sf); previously on Jan 12, 2023 Upgraded
to Aa2 (sf)

Issuer: Citigroup Mortgage Loan Trust 2015-RP2

Cl. B-4, Upgraded to Aaa (sf); previously on Jan 12, 2023 Upgraded
to A1 (sf)

Issuer: Citigroup Mortgage Loan Trust 2018-RP2

Cl. B-1, Upgraded to Aa3 (sf); previously on Oct 30, 2023 Upgraded
to Baa1 (sf)

Cl. B-2, Upgraded to Baa1 (sf); previously on Oct 30, 2023 Upgraded
to Ba2 (sf)

Cl. B-3, Upgraded to B1 (sf); previously on May 7, 2019 Upgraded to
Ca (sf)

Cl. M-3, Upgraded to Aa1 (sf); previously on Oct 30, 2023 Upgraded
to A1 (sf)

Issuer: Citigroup Mortgage Loan Trust 2018-RP3

Cl. B-1, Upgraded to A1 (sf); previously on Oct 30, 2023 Upgraded
to Baa3 (sf)

Cl. B-2, Upgraded to Baa2 (sf); previously on Oct 30, 2023 Upgraded
to B1 (sf)

Cl. B-3, Upgraded to B2 (sf); previously on Jan 14, 2020 Upgraded
to Ca (sf)

Cl. M-3, Upgraded to Aa2 (sf); previously on Oct 30, 2023 Upgraded
to A3 (sf)

Issuer: Citigroup Mortgage Loan Trust 2019-RP1

Class B-1, Upgraded to A2 (sf); previously on Oct 30, 2023 Upgraded
to Baa3 (sf)

Class B-2, Upgraded to Baa3 (sf); previously on Oct 30, 2023
Upgraded to B1 (sf)

Class B-3, Upgraded to Caa1 (sf); previously on Apr 30, 2019
Definitive Rating Assigned C (sf)

Class M-2, Upgraded to Aaa (sf); previously on Oct 30, 2023
Upgraded to Aa2 (sf)

Class M-3, Upgraded to Aa1 (sf); previously on Oct 30, 2023
Upgraded to A2 (sf)

Issuer: Freddie Mac Seasoned Credit Risk Transfer Trust, Series
2017-2

Cl. M-1, Upgraded to A1 (sf); previously on Mar 9, 2022 Upgraded to
Baa3 (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 an increase in credit enhancement of 7.0%, on
average, for the bonds Moody's upgraded since last review. The
loans underlying the pools have fewer delinquencies and have
prepaid at a faster rate than originally anticipated, resulting in
an improvement of approximately 20.1%, on average, in Moody's loss
projections for the pools since Moody's last review (link above
provides Moody's current estimates).

The rating actions also reflect the further seasoning of the
collateral and increased clarity regarding the impact of borrower
relief programs on collateral performance. Information obtained
from loan servicers in recent years has shed light on their current
strategies regarding borrower relief programs and the impact those
programs may have on collateral performance and transaction
liquidity, through servicer advancing. Moody's recent analysis has
found that in addition to robust home price appreciation, many of
these borrower relief programs have contributed to stronger
collateral performance than Moody's had previously expected, thus
supporting the upgrades.

Moody's analysis also considered the existence of historical
interest shortfalls for some of the bonds. While most shortfalls
have since been recouped, the size and length of the past
shortfalls, as well as the potential for recurrence, were analyzed
as part of the upgrades.

Moody's analysis also reflects the potential for collateral
volatility given the number of deal-level and macro factors that
can impact collateral performance, the potential impact of any
collateral volatility on the model output, and the ultimate size or
any incurred and projected loss.

No actions were taken on remaining rated classes in these deals
because their expected losses on the bonds remain commensurate with
their current ratings, after taking into account the updated
performance information, structural features, credit enhancement
and other qualitative considerations.

Principal Methodology

The methodologies used in these ratings were "Non-performing and
Re-performing Loan Securitizations" published in April 2024.

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 31 Classes From 27 US RMBS Deals
-----------------------------------------------------------------
S&P Global Ratings completed its review of 31 classes from 27 U.S.
RMBS transactions issued between 2002 and 2007. The review yielded
12 downgrades and 19 discontinuances. At the same time, S&P removed
the lowered rating on class M-1 from CWABS Inc. series 2002-BC3
from CreditWatch, where S&P placed it with negative implications on
July 11, 2024.

A list of Affected Ratings can be viewed at:

          https://rb.gy/akzbnu

S&P said, "The rating actions reflect our analysis of the
transactions' interest shortfalls and/or missed interest payments
on the affected classes. We lowered our ratings in accordance with
our "S&P Global Ratings Definitions," published June 9, 2023, which
imposes a maximum rating threshold on classes that have incurred
missed interest payments resulting from credit or liquidity
erosion. In applying our ratings definitions, we looked to see if
the applicable class received additional compensation beyond the
imputed interest due as direct economic compensation for the delay
in interest payments (e.g., interest on interest) and if the missed
interest payments will be repaid by the maturity date.

"In instances where the class does receive additional compensation
for outstanding interest shortfalls, our analysis considers the
likelihood that the missed interest payments, including the
capitalized interest, would be reimbursed under our various rating
scenarios. In this review, 10 classes from 10 transactions (which
are listed as "Ultimate repayment of missed interest unlikely at
higher rating levels" in the ratings list) were affected.

"In instances where the class does not receive additional
compensation for outstanding interest shortfalls, our analysis
focuses on our expectations regarding the length of the interest
payment interruptions. We lowered our ratings on two classes from
two transactions (listed as "Interest shortfall" in the ratings
list) due to the interest shortfall."

Class M-1 from CWABS Inc. series 2002-BC3 was placed on CreditWatch
Negative on July 11, 2024, due to observed interest shortfalls. The
servicer confirmed that the interest shortfalls were primarily due
to recoupments from previous advances that were partially
reimbursed in recent months. S&P therefore downgraded the rating to
'B+ (sf)' from 'BBB- (sf)' and removed it from CreditWatch
Negative.

S&P said, "In accordance with our surveillance and withdrawal
policies, we discontinued 19 ratings from 15 transactions that had
observed interest shortfalls or missed interest payments during
recent remittance periods. We had previously lowered our rating on
these classes to 'D (sf)' because of principal losses, accumulated
interest shortfalls, missed interest payment, and/or credit-related
reductions in interest due to loan modifications. We view a
subsequent upgrade to a rating higher than 'D (sf)' unlikely under
the relevant criteria within this review.

"We will continue to monitor our ratings on securities that
experience interest shortfalls and/or missed interest payments, and
we will further adjust our ratings as we consider appropriate."



                            *********

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