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

              Sunday, October 13, 2024, Vol. 28, No. 286

                            Headlines

ACADEMIC LOAN 2013-1: Fitch Lowers Rating on Cl. A Notes to 'BBsf'
AGL CLO 20: Fitch Assigns 'BBsf' Rating on Class E-R Notes
AGL CLO 20: Moody's Assigns B3 Rating to $1.125MM Class F-R Notes
AIMCO CLO 19: S&P Assigns Prelim BB- (sf) Rating on Class E Notes
ANGEL OAK 2024-10: Fitch Assigns 'B(EXP)sf' Rating on Cl. B-2 Certs

ARES LOAN VII: Fitch Assigns 'BB-sf' Final Rating on Class E Notes
ARES TRUST 2024-IND2: Fitch Assigns 'B(EXP)sf' Rating on HRR Certs
BAIN CAPITAL 2024-5: Fitch Assigns 'BB-sf' Rating on Class E Notes
BALLYROCK CLO 20: S&P Assigns Prelim BB- (sf) Rating on D-R2 Notes
BAMLL 2016-SS1: S&P Lowers Class X-B Certs Rating to 'BB+ (sf)'

BBCMS MORTGAGE 2022-C15: Fitch Lowers Rating on 2 Tranches to B-sf
BBCMS MORTGAGE 2024-5C29: Fitch B-sf Final Rating on Cl. G-RR Certs
BEAR STEARNS 2006-EC2: Moody's Cuts Rating on Cl. M-2 Certs to Caa1
BENCHMARK 2024-V10: Fitch Assigns 'B-sf' Rating on Class G-RR Certs
BLUEMOUNTAIN 2018-1: S&P Places 'BB-' E Notes Rating on Watch Neg.

BRAVO RESIDENTIAL 2024-CES2: Fitch Gives B(EXP)sf on B2 Notes
BXP TRUST 2017-CC: S&P Lowers Class E Certs Rating to 'B (sf)'
CARLYLE US 2018-3: Moody's Affirms Ba3 Rating on $20.8MM D Notes
CASCADE MH 2024-MH1: Fitch Assigns B-(EXP)sf Rating on Cl. B2 Notes
CEDAR CREST 2022-1: Fitch Affirms B-sf Rating on Class F Notes

CIFC FUNDING 2018-II: Fitch Assigns BB-(EXP)sf Rating on E-R Notes
CIFC FUNDING 2022-VI: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
COMM 2014-UBS4: Fitch Lowers Rating on Two Tranches to 'BB-sf'
CSAIL 2015-C1: Fitch Lowers Rating on Cl. C Certificates to 'BBsf'
EATON VANCE 2020-2: S&P Assigns BB- (sf) Rating on Cl. E-R2 Debt

EFMT 2024-INV2: S&P Assigns B- (sf) Rating on Class B-2 Certs
ELMWOOD CLO VII: S&P Assigns 'B-(sf)' Rating on Class F-RR Notes
ELMWOOD CLO XII: S&P Assigns B- (sf) Rating on Class F-R Notes
EXETER AUTOMOBILE 2024-5: Fitch Assigns BB-sf Rating on Cl. E Notes
FORTRESS CREDIT XIX:S&P Assigns Prelim BB-(sf) Rating on E-R Notes

FS RIALTO 2024-FL9: Fitch Assigns 'B-(EXP)' Rating on Three Classes
GALAXY XXII CLO: S&P Assigns BB- (sf) Rating on Class E-RRR Notes
GENERATE CLO 6: S&P Assigns BB- (sf) Rating on Class E-R2 Notes
GOODLEAP SUSTAINABLE 2023-2: Fitch Rates Class C Debt 'BBsf'
GS MORTGAGE 2014-GC26: Fitch Lowers Rating on Two Tranches to BBsf

GS MORTGAGE 2018-RIVR: S&P Discontinues 'D (sf)' Rating on D Certs
GS MORTGAGE 2024-PJ8: Fitch Assigns 'Bsf' Rating on Class B-5 Certs
HALCYON LOAN 2015-3: Moody's Cuts Rating on $27.5MM D Notes to Ca
JP MORGAN 2018-PTC: S&P Lowers Class A Certs Rating to 'CCC(sf)'
JP MORGAN 2024-HE3: Fitch Assigns B(EXP)sf Rating on Cl. B-2 Certs

JP MORGAN 2024-HE3: Fitch Assigns Bsf Final Rating on Cl. B-2 Certs
JPMCC COMMERCIAL 2015-JP1: Fitch Cuts Rating on 2 Tranches to 'B-'
JPMDB COMMERCIAL 2016-C4: Fitch Lowers Rating on 2 Tranches to 'B'
LENDMARK FUNDING 2024-2: S&P Assigns BB-(sf) Rating on Cl. E Notes
MADISON PARK LIV: Fitch Assigns BB+(EXP)sf Rating on Cl. E-R Notes

MARINER FINANCE 2024-B: S&P Assigns Prelim 'BB-' Rating on E Notes
MCF CLO V: S&P Assigns Prelim BB- (sf) Rating on Class E-R2 Notes
MORGAN STANLEY 2013-C11: Moody's Lowers Rating on 2 Tranches to Ca
MORGAN STANLEY 2022-17A: Fitch Gives BB-(EXP) Rating on E-R Notes
MOUNTAIN VIEW CLO XVIII: S&P Assigns BB- (sf) Rating on E Notes

MSC 2024-NSTB: Fitch Assigns 'B-sf' Final Rating on Class G Certs
OZLM XXIII: S&P Assigns Prelim BB- (sf) Rating on Class E Notes
PIKES PEAK 5: Fitch Assigns 'B-sf' Rating on Class F-R Notes
RATE MORTGAGE 2024-J3: Moody's Assigns Ba3 Rating to Cl. B-5 Certs
RR 32: S&P Assigns Preliminary BB- (sf) Rating on Class D-R Debt

SEQUOIA MORTGAGE 2024-10: Fitch Assigns B+(EXP) Rating on B5 Certs
SIERRA TIMESHARE 2024-3: Fitch Gives BB-(EXP) Rating on D Notes
SIERRA TIMESHARE 2024-3: S&P Prelim BB (sf) Rating on Cl. D Notes
SIERRA TIMESHARE: Fitch Affirms Ratings on 10 Trusts
SIXTH STREET XV: S&P Assigns Prelim BB- (sf) Rating on E-R Notes

TCW CLO 2018-1: Fitch Assigns 'BB-sf' Rating on Class E-R3 Notes
TOWD POINT 2024-CES4: Fitch Assigns 'B-sf' Final Rating on B2 Notes
TOWD POINT 2024-CES5: Fitch Assigns 'B-(EXP)sf' Rating on B2 Notes
UBS COMMERCIAL 2018-C12: Fitch Lowers Rating on 2 Tranches to 'B+'
UBS COMMERCIAL 2019-C18: Fitch Affirms B-sf Rating on Two Tranches

VERUS SECURITIZATION 2024-8: S&P Assigns Prelim B (sf) on B-2 Notes
VIBRANT CLO IX: Moody's Cuts Rating on $24MM Class D Notes to B1
WESTLAKE AUTOMOBILE 2024-3: Fitch Gives BB(EXP) Rating on E Notes
WFRBS COMMERCIAL 2014-LC14: Fitch Affirms CCC Rating on Cl. F Certs
WIND RIVER 2014-1: Moody's Ups Rating on $36MM D-RR Notes From Ba1

[*] Moody's Cuts Eight Bonds From 6 US RMBS Deals Issued in 2005
[*] Moody's Cuts Ratings From 14 US RMBS Issued 2002-2006
[*] Moody's Takes Action on 11 Bonds From 6 US RMBS Deals
[*] Moody's Takes Action on Nine Bonds from 8 US RMBS Deals
[*] Moody's Takes Action on Seven Bonds From 7 US RMBS Deals

[] Moody's Takes Action on 13 Bonds from US RMBS Issued 2004-2007

                            *********

ACADEMIC LOAN 2013-1: Fitch Lowers Rating on Cl. A Notes to 'BBsf'
------------------------------------------------------------------
Fitch Ratings has affirmed the ratings to the outstanding notes of
Academic Loan Funding Trust 2011-1 and Academic Loan Funding Trust
2012-1. The Rating Outlooks for all classes of these two trusts
remain Stable. Fitch has downgraded the outstanding class A note of
Academic Loan Funding Trust 2013-1. The Rating Outlook is
Negative.

   Entity/Debt              Rating            Prior
   -----------              ------            -----
Academic Loan Funding
Trust 2011-1

   A 003895AA7          LT AA+sf  Affirmed    AA+sf

Academic Loan Funding
Trust 2012-1

   A-2 00400VAB3        LT AA+sf  Affirmed    AA+sf

Academic Loan Funding
Trust 2013-1

   Class A Notes
   00389VAA0            LT BBsf   Downgrade   BBBsf

Transaction Summary

Academic Loan Funding Trust 2011-1 (ALFT 2011-1): The class A notes
passed all of Fitch's credit and maturity rating stresses with
sufficient credit enhancement (CE). Fitch has affirmed the class A
notes at 'AA+sf'.

Academic Loan Funding Trust 2012-1 (ALFT 2012-1): The class A-2
notes passed all of Fitch's credit and maturity rating stresses
with sufficient CE. Fitch has affirmed the class A-2 notes at
'AA+sf'.

Academic Loan Funding Trust 2013-1 (ALFT 2013-1): The notes failed
credit stresses in the stable and increasing interest rate
scenarios in the 'AAAsf' through 'BBsf' rating stresses and failed
credit stresses in the stable scenario in the 'BBsf' rating stress.
These failures are due to higher interest rates eroding trust
excess spread in Fitch's cashflow modeling, leading to principal
and interest shortfalls in these scenarios. The notes passed 'BBsf'
stresses during the last review, however, for the current review
the shortfalls extended to the 'BBsf' rating stress scenario.

Fitch has downgraded the notes to 'BBsf' from 'BBBsf'. The rating
is within one rating category of the lowest rating implied by
Fitch's FFELP cashflow results, in line with Fitch's FFELP rating
criteria. Given the small size of the shortfall compared to the
outstanding note balance in the 'BBsf' scenario and the remaining
time to maturity of around 20 years, Fitch has downgraded the notes
to 'BBsf'. The Outlook for class A is Negative following the
downgrade. This reflect the possibility for future downgrades as
the trust remains sensitive to additional changes in excess
spread.

All three transactions expressed significant increases to
prepayments, which Fitch did not consider when reviewing the sCPR
assumptions across the three trusts. Recent prepayments reflected
benefits (under the Federal Direct Loan SAVE payment plan) FFELP
borrowers could receive by refinancing with a Federal Direct loan
prior to the end of June 2024. Fitch expects CPRs to decrease
quickly, a similar performance after the Public Service Loan
Forgiveness Program waiver ended in October 2022. That program also
drove short-term inflation of CPR and voluntary prepayments higher.
CPRs are expected to decrease closer to historical levels in line
with the updated sCPR assumptions by the end of the year.

KEY RATING DRIVERS

U.S. Sovereign Risk: The trusts' collateral comprises 100% Federal
Family Education Loan Program (FFELP) loans with guaranties
provided by eligible guarantors and reinsurance provided by the
U.S. Department of Education (ED) for at least 97% of principal and
accrued interest. The U.S. sovereign rating is currently
'AA+'/Stable Outlook by Fitch. The notes are capped at the U.S.
sovereign rating and will likely move in tandem with the U.S.
sovereign rating given the reinsurance and Special Allowance
Payment (SAP) provided by Department of Education (ED).

Collateral Performance

ALFT 2011-1: Based on transaction-specific performance to date,
Fitch assumes a cumulative default rate of 49.75% under the base
case scenario and a 100% default rate under the 'AA' credit stress,
with an effective default rate of 96.86% after applying the default
timing curve, as per criteria. Fitch maintained its sustainable
constant default rate (sCDR) at 8.0% and maintained its sustainable
constant prepayment rate (sCPR; voluntary and involuntary
prepayments) at 11.0% in cash flow modelling. Fitch applies the
standard default timing curve in its credit stress cash flow
analysis. The claim reject rate is assumed to be 0.25% in the base
case and 2.0% in the 'AA+' case based on historical servicer data.

The trailing twelve-month (TTM) levels of deferment, forbearance
and income-based repayment (IBR) are 3.52% (3.86% at July 2023),
12.69% (12.94%) and 24.24% (21.12%), respectively. These are used
as the starting point in cash flow modelling. Subsequent declines
or increases are modeled as per criteria. The 31-60 days past due
(DPD) decreased while and the 91-120 DPD increased since July 2023
and are currently 3.59% for 31 DPD and 1.24% for 91 DPD compared to
4.44% and 0.86% for 31 DPD and 91 DPD, respectively. The borrower
benefit is assumed to be 0.0%, based on information provided by the
sponsor.

ALFT 2012-1: Based on transaction-specific performance to date,
Fitch assumes a cumulative default rate of 38.25% under the base
case scenario and a 100.0% default rate under the 'AA' credit
stress, with an effective default rate of 98.33% after applying the
default timing curve, as per criteria. Fitch maintained its sCDR at
6.0% and its sustainable sCPR to 12.0% in cash flow modelling.
Fitch applies the standard default timing curve in its credit
stress cash flow analysis. The claim reject rate is assumed to be
0.25% in the base case and 2.0% in the 'AA+' case based on
historical servicer data.

The trailing twelve-month (TTM) levels of deferment, forbearance
and income-based repayment (IBR) are 4.67% (4.95% at July 2023),
12.75% (12.15%) and 35.37% (33.06%), respectively. These are used
as the starting point in cash flow modelling. Subsequent declines
or increases are modeled as per criteria. The 31-60 days past due
(DPD) increased and the 91-120 DPD decreased from July 2023 and are
currently 3.17% for 31 DPD and 1.14% for 91 DPD compared to 2.89%
and 1.18% for 31 DPD and 91 DPD, respectively. The borrower benefit
is assumed to be 0.22%, based on information provided by the
sponsor.

ALFT 2013-1: Based on transaction-specific performance to date,
Fitch assumes a cumulative default rate of 62.75% under the base
case scenario and a 100.0% default rate under the 'AA' credit
stress, with an effective default rate of 98.46% after applying the
default timing curve, as per criteria. Fitch maintained its sCDR at
10.0% and its sustainable sCPR at 13.0% in cash flow modelling.
Fitch applies the standard default timing curve in its credit
stress cash flow analysis. The claim reject rate is assumed to be
0.25% in the base case and 2.0% in the 'AA+' case based on
historical servicer data.

The trailing twelve-month (TTM) levels of deferment, forbearance
and income-based repayment (IBR) are 4.73% (5.14% at July 2023),
15.60% (16.04%) and 27.06% (25.67%), respectively. These are used
as the starting point in cash flow modelling. Subsequent declines
or increases are modeled as per criteria. The 31-60 days past due
(DPD) and the 91-120 DPD increased from July 2023 and are currently
4.44% for 31 DPD and 6.16% for 91 DPD compared to 4.24% and 6.16%
for 31 DPD and 91 DPD, respectively. The borrower benefit is
assumed to be 0.0%, based on information provided by the sponsor.

Basis and Interest Rate Risk: Basis risk for this transaction
arises from any rate and reset frequency mismatch between interest
rate indices for Special Allowance Payments (SAP) and the
securities. For transactions that were modeled for this review,
Fitch applies its standard basis and interest rate stresses as per
criteria.

Payment Structure

ALFT 2011-1: Credit enhancement (CE) is provided by excess spread
and overcollateralization (OC). As of the August 2024 distribution
date, the reported total parity ratio (including the reserve) is
110.34%. Liquidity support is provided by a reserve account sized
at its floor of $250,000.

ALFT 2012-1: CE is provided by excess spread and OC. As of the
August 2024 distribution date, the reported total parity ratio
(including the reserve) is 112.39%. Liquidity support is provided
by a reserve account sized at its floor of $1,250,000. The
transaction will release excess cash as long as 104.0% total parity
is maintained.

ALFT 2013-1: CE is provided by excess spread and OC. As of the
August 2023 distribution date, the reported total parity ratio
(including the reserve) is 104.0%. Liquidity support is provided by
a reserve account sized at its floor of $250,000.

Operational Capabilities: Day-to-day servicing is provided by
Navient Solutions, LLC for ALFT 2011-1 and Great Lakes Education
Loan Services Inc. (Nelnet subsidiary) and Pennsylvania Higher
Education Assistance Agency (PHEAA) for ALFT 2012-1 and 2013-1.
Fitch believes the servicers to be adequate, due to their extensive
track record as the largest servicers of FFELP loans.

RATING SENSITIVITIES

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

'AA+sf' rated tranches of most FFELP securitizations will likely
move in tandem with the U.S. sovereign rating given the strong
linkage to the U.S. sovereign, by nature of the reinsurance
provided by the Department of Education. Aside from the U.S.
sovereign rating, defaults, basis risk and loan extension risk
account for the majority of the risk embedded in FFELP student loan
transactions. This section provides insight into the model-implied
sensitivities the transaction faces when one assumption is
modified, while holding others equal.

Fitch conducts credit and maturity stress sensitivity analysis by
increasing or decreasing key assumptions by 25% and 50% over the
base case. The credit stress sensitivity is viewed by stressing
both the base case default rate and the basis spread. The maturity
stress sensitivity is viewed by stressing remaining term, IBR usage
and prepayments. The results below should only be considered as one
potential outcome, as the transaction is exposed to multiple
dynamic risk factors. It should not be used as an indicator of
possible future performance.

ALFT 2011-1

Credit Stress Sensitivity

- Default increase 25%: class A 'AA+sf';

- Default increase 50%: class A 'AA+sf';

- Basis Spread increase 0.25%: class A 'AA+sf';

- Basis Spread increase 0.50%: class A 'AA+sf'.

Maturity Stress Sensitivity

- CPR decrease 25%: class A 'AA+sf';

- CPR decrease 50%: class A 'AA+sf';

- IBR usage increase 25%: class A 'AAsf';

- IBR usage increase 50%: class A 'AAsf';

- Remaining term increase 25%: class A 'AAsf';

- Remaining term increase 50%: class A 'AAsf'.

ALFT 2012-1

Credit Stress Sensitivity

- Default increase 25%: class A 'AA+sf';

- Default increase 50%: class A 'AA+sf';

- Basis Spread increase 0.25%: class A 'AA+sf';

- Basis Spread increase 0.50%: class A 'AA+sf'.

Maturity Stress Sensitivity

- CPR decrease 25%: class A 'AA+sf';

- CPR decrease 50%: class A 'AA+sf';

- IBR usage increase 25%: class A 'AA+sf';

- IBR usage increase 50%: class A 'AA+sf';

- Remaining term increase 25%: class A 'AA+sf';

- Remaining term increase 50%: class A 'AAsf'.

ALFT 2013-1

Credit Stress Sensitivity

- Default increase 25%: class A 'Bsf';

- Default increase 50%: class A 'Bsf';

- Basis Spread increase 0.25%: class A 'Bsf';

- Basis Spread increase 0.50%: class A 'CCCsf'.

Maturity Stress Sensitivity

- CPR decrease 25%: class A 'AA+sf';

- CPR decrease 50%: class A 'AA+sf';

- IBR usage increase 25%: class A 'AA+sf';

- IBR usage increase 50%: class A 'AA+sf';

- Remaining term increase 25%: class A 'AAsf';

- Remaining term increase 50%: class A 'AAsf'.

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

ALFT 2011-1

No upgrade credit or maturity stress sensitivity is provided for
the notes, as the class A notes are at their highest achievable
ratings.

ALFT 2012-1

No upgrade credit or maturity stress sensitivity is provided for
the notes, as the class A-2 notes are at their highest achievable
ratings.

ALFT 2013-1

Credit Stress Sensitivity

- Default decrease 25%: class A 'BBsf';

- Basis Spread decrease 0.25%: class A 'BBsf'.

Maturity Stress Sensitivity

- CPR increase 25%: class A 'AA+sf';

- IBR usage decrease 25%: class A 'AA+sf';

- Remaining term decrease 25%: class A 'AA+sf'.

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.


AGL CLO 20: Fitch Assigns 'BBsf' Rating on Class E-R Notes
----------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to AGL CLO
20 Ltd. Reset Transaction.

   Entity/Debt        Rating               Prior
   -----------        ------               -----
AGL CLO 20 Ltd.

   X              LT  NRsf   New Rating
   A-1R           LT  NRsf   New Rating
   A-2R           LT  AAAsf  New Rating
   B              LT  PIFsf  Paid In Full   AAsf
   B-R            LT  AA+sf  New Rating
   C              LT  PIFsf  Paid In Full   Asf
   C-R            LT  A+sf   New Rating
   D              LT  PIFsf  Paid In Full   BBB-sf
   D-1R           LT  BBB+sf New Rating
   D-2R           LT  BBB-sf New Rating
   E              LT  PIFsf  Paid In Full   BB-sf
   E-R            LT  BBsf   New Rating
   F-R            LT  NRsf   New Rating

Transaction Summary

AGL CLO 20 Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by AGL
CLO Credit Management LLC originally closed in August 2022. The
CLO's secured notes will be refinanced on Oct. 4, 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 $450 million of primarily first lien
senior secured leverage 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. 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
99.49% first-lien senior secured loans and has a weighted average
recovery assumption of 74.96%. 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 (Negative): 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 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 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-2R, 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 'BBB-sf' for class D-1R,
between less than 'B-sf' and 'BB+sf' for class D-2R, 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 A-2R 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-1R, 'Asf' for class D-2R, 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 20 Ltd.
(Reset) 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.


AGL CLO 20: Moody's Assigns B3 Rating to $1.125MM Class F-R Notes
-----------------------------------------------------------------
Moody's Ratings has assigned ratings to three classes of CLO
refinancing notes (the Refinancing Notes) issued by AGL CLO 20 Ltd.
(the Issuer):  

US$2,500,000 Class X Senior Secured Floating Rate Notes due 2037,
Assigned Aaa (sf)

US$279,000,000 Class A-1R Senior Secured Floating Rate Notes due
2037, Assigned Aaa (sf)

US$1,125,000 Class F-R Junior Secured Deferrable Floating Rate
Notes due 2037, 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.

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

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

In addition to the issuance of the Refinancing Notes and six other
classes of secured notes, a variety of other changes to transaction
features will occur in connection with the refinancing. These
include: extension of the reinvestment period; extensions of the
stated maturity and non-call period; changes to certain collateral
quality tests; changes to the overcollateralization test levels;
and changes to the base matrix and modifiers.

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.

The key model inputs Moody's used in Moody's analysis, such as par,
weighted average rating factor, diversity score 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:

Portfolio par: $450,000,000

Diversity Score: 75

Weighted Average Rating Factor (WARF): 3195

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 6.00%

Weighted Average Recovery Rate (WARR): 46.00%

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 a Downgrade of the
Ratings:

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


AIMCO CLO 19: S&P Assigns Prelim BB- (sf) Rating on Class E Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to AIMCO CLO 19
Ltd./AIMCO CLO 19 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 Allstate Investment Management Co.

The preliminary ratings are based on information as of Oct. 9,
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

  AIMCO CLO 19 Ltd./AIMCO CLO 19 LLC

  Class A, $256.00 million: AAA (sf)
  Class B, $48.00 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, $37.50 million: Not rated



ANGEL OAK 2024-10: Fitch Assigns 'B(EXP)sf' Rating on Cl. B-2 Certs
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings to Angel Oak Mortgage
Trust 2024-10 (AOMT 2024-10).

   Entity/Debt       Rating           
   -----------       ------           
AOMT 2024-10

   A-1           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-IO-S        LT NR(EXP)sf   Expected Rating
   XS            LT NR(EXP)sf   Expected Rating
   R             LT NR(EXP)sf   Expected Rating

Transaction Summary

Fitch expects to rate the RMBS to be issued by Angel Oak Mortgage
Trust 2024-10, Series 2024-10 (AOMT 2024-10), as indicated above.
The certificates are supported by 661 loans with a balance of
$316.80 million as of the cutoff date. This represents the 43rd
Fitch-rated AOMT transaction and the tenth Fitch-rated AOMT
transaction in 2024.

The certificates are secured by mortgage loans mainly originated
(41.9%) by Angel Oak Mortgage Solutions LLC (AOMS). The remaining
58.1% of loans were originated by various third-party originators
(TPOs). Fitch considers AOMS to be an 'Acceptable' originator. The
servicer of the loans is Select Portfolio Servicing, Inc.
(RPS1-/Negative).

Of the loans, 57.6% are designated as non-qualified mortgage
(non-QM) loans and 42.4% are exempted mortgage loans that were not
subject to the Ability to Repay (ATR) Rule.

The pool includes 11 ARM loans, 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. The class M-1 certificate
is based on the lower of a fixed rate and the net WAC rate for the
related distribution date. The class B-1 coupon will be determined
at the time of pricing: it will be a per annum rate equal to either
(i) the lower of a fixed rate for such class to be determined at
the time of pricing and the net WAC or (ii) the net WAC. The B-2
and B-3 classes will have their coupons 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, it views the home price values of
this pool as 11.1% above a long-term sustainable level (versus
11.5% on a national level as of 1Q24, up 0.4% from 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.

Non-QM Credit Quality (Mixed): The collateral consists of 661 loans
totaling $316.80 million and seasoned at about six months in
aggregate, according to Fitch, and four months, per the transaction
documents. The borrowers have a relatively strong credit profile,
with a 753 nonzero FICO and a 43.3% debt-to-income (DTI) ratio, as
determined by Fitch. They have relatively moderate leverage, with
an original combined loan-to-value (CLTV) ratio of 70.3%, as
determined by Fitch, which translates to a Fitch-calculated
sustainable LTV (sLTV) of 79.0%.

Its analysis of the pool loans shows that 57.1% represent those of
a primary or secondary residence, while the remaining 42.9%
comprise investor properties. Its analysis considers the 17 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 15.1% of the loans were originated via a retail
channel.

Additionally, 57.6% of the pool loans are designated as non-QM,
while the remaining 42.4% are exempt from QM status, as this
comprises investor loans. The pool contains 71 loans over $1.00
million, with the largest amounting to $3.40 million. Loans on
investor properties represent 42.9% of the pool, as determined by
Fitch, including 8.2% underwritten to the borrower's credit profile
and 34.7% investor cash flow and no ratio loans.

Furthermore, only 0.3% of the borrowers were viewed by Fitch as
having a prior credit event within the past seven years. 0.1% of
the loans have a junior lien in addition to the first lien
mortgage. First lien mortgages constitute 100% of the pool (no
second lien loans are in the pool). 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 0.1% of the loans in the pool as having
subordinate financing; Fitch views limited subordinate financing as
a positive aspect of the transaction.

Fitch determined that 17 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 the co-borrower are 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.

Geographic Concentration (Negative): The largest concentration of
loans is in Florida (27.0%), followed by California (20.9%) and New
York (9.9%). The largest MSA is Miami (16.5%), followed by New York
(12.1%) and Los Angeles (10.2%). The top three MSAs account for
38.8% of the pool. The pool received a 1.01x penalty for
geographical concentration risk; this increased the 'AAAsf' losses
by 6bps.

Loan Documentation (Negative): Fitch determined that 93.1% 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 53.1% were underwritten to a
12-month or 24-month business or personal bank statement program
for verifying income, which 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, 34.2% constitute a debt
service coverage ratio (DSCR) product, 1.3% are an asset qualifier
product, and 0.5% are no-ratio DSCR loans.

Four loans in the pool are no-ratio DSCR loans. For no-ratio loans,
employment and income are considered to be "no documentation" in
Fitch's analysis, and Fitch assumes a DTI of 100%. This is in
addition to the loans being treated as investor occupied.

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 November 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.

Additionally, on any distribution date occurring on or after the
distribution date in November 2028 on which the aggregate unpaid
cap carryover amount for 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 certificates 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.

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 42.2% 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 SitusAMC, Clarifii, Clayton, Consolidated Analytics,
Infinity, Inglet Blair, Incenter, 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 0.51%.

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 SitusAMC, Clarifii, Clayton, Consolidated Analytics,
Infinity, Inglet Blair, Incenter, 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.


ARES LOAN VII: Fitch Assigns 'BB-sf' Final Rating on Class E Notes
------------------------------------------------------------------
Fitch Ratings has assigned final ratings to Ares Loan Funding VII,
Ltd.

   Entity/Debt              Rating           
   -----------              ------           
Ares Loan Funding VII,
Ltd.

   A-1                  LT AAAsf  New Rating
   A-2                  LT AAAsf  New Rating
   B-1                  LT AA+sf  New Rating
   B-2                  LT AAsf   New Rating
   C                    LT Asf    New Rating
   D-1                  LT BBBsf  New Rating
   D-2                  LT BBB-sf New Rating
   E                    LT BB-sf  New Rating
   Subordinated Notes   LT NRsf   New Rating

Transaction Summary

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

KEY RATING DRIVERS

Asset Credit Quality (Negative): The average credit quality of the
indicative portfolio is 'B'/'B-', which is in line with that of
recent CLOs. The weighted average rating factor (WARF) of the
indicative portfolio is 24.65, versus a maximum covenant, in
accordance with the initial expected matrix point of 25.0. issuers
rated in the 'B' rating category denote a highly speculative credit
quality; however, the notes benefit from appropriate credit
enhancement and standard U.S. CLO structural features.

Asset Security (Positive): The indicative portfolio consists of
97.48% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 74.59% versus a
minimum covenant, in accordance with the initial expected matrix
point of 69.30%.

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 5.0-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 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, between
'BBB+sf' and 'AA+sf' for class A-2, between 'BB+sf' and 'A+sf' for
class B-1, between 'BB+sf' and 'A+sf' for class B-2, 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-1 and 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-1, 'AAAsf' for class B-2, 'AAsf'
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 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 Ares Loan Funding
VII, 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 any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.



ARES TRUST 2024-IND2: Fitch Assigns 'B(EXP)sf' Rating on HRR Certs
------------------------------------------------------------------
Fitch Ratings has assigned the following expected ratings and
Ratings Outlooks to ARES Trust 2024-IND2, Commercial Mortgage Pass
Through Certificates, Series 2024-IND2:

- $261,000,000 class A 'AAA(EXP)sf'; Outlook Stable;

- $28,800,000 class B 'AA-(EXP)sf'; Outlook Stable;

- $31,000,000 class C 'A-(EXP)sf'; Outlook Stable;

- $43,700,000 class D 'BBB-(EXP)sf'; Outlook Stable;

- $66,900,000 class E 'BB-(EXP)sf'; Outlook Stable;

- $19,850,000 class F 'B+(EXP)sf'; Outlook Stable;

- $23,750,000 class HRR 'B(EXP)sf'; Outlook Stable.

HRR is a horizontal risk retention interest representing at least
5.0% of the estimated fair value of all classes.

Transaction Summary

The certificates represent the beneficial ownership interest in a
trust that will hold a $475.0 million, two-year, floating-rate,
interest-only mortgage loan with three one-year extension options.
The mortgage will be secured by the borrowers' fee simple interest
in a portfolio of 25 industrial facilities, comprising
approximately 4.8 million sf located across 12 states.

The borrower sponsor is AREIT Operating Partnership LP, which is
externally managed by Ares Commercial Real Estate Management LLC (a
subsidiary of Ares). The sponsorship acquired the properties
through a series of transactions over the past six years for a
total cost basis of approximately $716.2 million.

The mortgage loan is expected to be used to pay down the existing
corporate debt facility and fund estimated closing costs for a
total cost basis of $475.0 million.

The loan is expected to be co-originated by JPMorgan Chase Bank,
National Association, Morgan Stanley Mortgage Capital Holdings LLC
and Natixis Real Estate Capital LLC. Midland Loan Services, a
Division of PNC Bank National Association, is expected to be the
servicer, with Argentic Services Company LP as the special
servicer. Computershare Trust Company, N.A is expected to act as
the trustee and certificate administrator. Pentalpha Surveillance
LLC will act as operating advisor.

The certificates will follow a pro-rata paydown for the initial 25%
of the loan amount and a standard senior-sequential paydown
thereafter. To the extent no mortgage loan event of default
continues, voluntary prepayments will be applied pro rata between
the mortgage loan components. The transaction is scheduled to close
on Oct. 15, 2024.

KEY RATING DRIVERS

Net Cash Flow: Fitch estimates stressed net cash flow (NCF) for the
portfolio at $30.6 million. This is 9.7% lower than the issuer's
NCF and 5.6% higher than the trailing 12 months (TTM) ended May
2024 NCF. Fitch applied a 7.25% cap rate to derive a Fitch value of
approximately $442.5 million.

High Fitch Leverage: The $475.0 million whole loan equates to debt
of approximately $99psf with a Fitch stressed LTV ratio and debt
yield of 112.4% and 6.4%, respectively. The loan represents
approximately 61.5% of the appraised value of $772.6 million. Fitch
increased the LTV hurdles by 1.25% to reflect the higher in-place
leverage.

Geographic and Tenant Diversity: The portfolio exhibits strong
geographic diversity with 25 primarily industrial properties (4.8
million sf) located across 12 states and 17 metropolitan
statistical areas (MSAs). The three largest state concentrations
are California (862,988 sf; five properties), Nevada (750,594 sf;
three properties) and Texas (693,865 sf; five properties). The
three largest MSAs are Atlanta, GA (16.7% of NRA; 10.1% of ALA),
Reno NV (15.1% of NRA; 11.5% of ALA) and Houston, TX (14.5% of NRA;
11.0% of ALA). The portfolio also exhibits significant tenant
diversity, as it features 57 distinct tenants, with no tenant
occupying more than 16.7% of NRA.

Institutional Sponsorship: Ares is a global leader in alternative
investments, and its real estate division oversees both equity and
debt strategies. In 2021, Ares enhanced its offerings by acquiring
Black Creek Group which brought additional expertise, particularly
in core and core-plus real estate investments focusing on the
industrial sector. As of April 30, 2024, Ares' AREIT real estate
fund comprised 54.4 million sf of industrial space across 254
properties located in 29 markets with 428 distinct tenants.

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 list below indicates the model
implied rating sensitivity to changes in one variable, Fitch NCF:

- Original Rating:
'AAAsf'/'AA-sf'/'A-sf'/'BBB-sf'/'BB-sf'/'B+sf'/'Bsf'

- 10% NCF Decline:
'A+sf'/'BBB+sf'/'BBB-sf'/'BBsf'/'Bsf'/'B-sf'/'CCC+sf'

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 list below indicates the
model implied rating sensitivity to changes to the same one
variable, Fitch NCF:

- Original Rating:
'AAAsf'/'AA-sf'/'A-sf'/'BBB-sf'/'BB-sf'/'B+sf'/'Bsf'

- 10% NCF Increase:
'AAAsf'/'AA+sf'/'A+sf'/'BBB+sf'/'BBsf'/'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 certain attributes of the mortgage
data file. Fitch considered this information in its analysis and it
did not have an effect on its 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.


BAIN CAPITAL 2024-5: Fitch Assigns 'BB-sf' Rating on Class E Notes
------------------------------------------------------------------
Fitch has assigned final ratings and Rating Outlooks to Bain
Capital Credit CLO 2024-5, Limited.

   Entity/Debt           Rating             Prior
   -----------           ------             -----
Bain Capital Credit
CLO 2024-5, Limited

   A-1               LT NRsf   New Rating   NR(EXP)sf
   A-2               LT AAAsf  New Rating   AAA(EXP)sf
   B-1               LT AA+sf  New Rating   AA+(EXP)sf
   B-2               LT AAsf   New Rating   AA(EXP)sf
   C                 LT Asf    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
   Subordinated      LT NRsf   New Rating   NR(EXP)sf

Transaction Summary

Bain Capital Credit CLO 2024-5, Ltd. (the issuer) is an arbitrage
cash flow collateralized loan obligation (CLO) that will be managed
by Bain Capital Credit U.S. CLO Manager II, LP. 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. The weighted average rating factor (WARF) of the indicative
portfolio is 23.28 versus a maximum covenant, in accordance with
the initial expected matrix point of 24. 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
99.3% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.41% versus a
minimum covenant, in accordance with the initial expected matrix
point of 69.9%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 42.5% 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 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, between
'BBB-sf' and 'AA-sf' for class B-1, between 'BB+sf' and 'A+sf' for
class B-2, between 'B+sf' and 'BBB+sf' for class C, between less
than 'B-sf' and 'BBB-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-1, 'AAAsf' for class B-2, 'AAsf'
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, and together with any assumptions referred to above,
Fitch's assessment of the information relied upon for the agency's
rating analysis according to its applicable rating methodologies
indicates that it is adequately reliable.

ESG Considerations

Fitch does not provide ESG relevance scores for Bain Capital Credit
CLO 2024-5, Limited. 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.


BALLYROCK CLO 20: S&P Assigns Prelim BB- (sf) Rating on D-R2 Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the
replacement class A-1A2 (loan), A-1B2, A-2R2, B-R2, C-1R2, C-2R2,
and D-R2 debt from Ballyrock CLO 20 Ltd./Ballyrock CLO 20 LLC, a
CLO originally issued in July 2022 that is managed by Ballyrock
Investment Advisors LLC, an affiliate of Fidelity Management &
Research Co. LLC.

The preliminary ratings are based on information as of Oct. 1,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 15, 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 and 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 replacement class A-1A2 (loan), A-2R2, B-R2,C-1R2. and D-R2
debt is expected to be issued at a lower spread over three-month
CME term SOFR than the original debt over three-month LIBOR.

-- Classes A-2A, B-R, C-R, and D-R were reset in 2023.

-- The stated maturity and reinvestment and non-call periods will
be extended just over two years.

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

  Ballyrock CLO 20 Ltd./Ballyrock CLO 20 LLC

  Class A-1A2 (loan), $325.00 million: AAA (sf)
  Class A-1B2, $10.00 million: AAA (sf)
  Class A-2R2, $45.00 million: AA (sf)
  Class B-R2 (deferrable), $30.00 million: A (sf)
  Class C-1R2 (deferrable), $30.00 million: BBB (sf)
  Class C-2R2 (deferrable), $5.00 million: BBB- (sf)
  Class D-R2 (deferrable), $15.00 million: BB- (sf)
  Subordinated notes, $42.50 million: Not rated



BAMLL 2016-SS1: S&P Lowers Class X-B Certs Rating to 'BB+ (sf)'
---------------------------------------------------------------
S&P Global Ratings lowered its ratings on eight classes of
commercial mortgage pass-through certificates from BAMLL Commercial
Mortgage Securities Trust 2016-SS1, a U.S. CMBS transaction.

This U.S. stand-alone (single-borrower) CMBS transaction is backed
by a fixed-rate, interest-only (IO) mortgage loan secured by the
borrower's fee simple and leasehold interests in an 11-story, class
A, 501,650-sq.-ft. office building located at 1 Iron St. and an
adjacent 965-space freestanding parking garage at 116 West First
St. in the Seaport office submarket of Boston.

Rating Actions

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

-- While the property is currently 100% leased to a single tenant,
SSB Realty LLC, an affiliate of State Street Corp. (A/Stable/A-1),
with a lease that expires four years after the loan's December 2025
maturity date, the tenant has continued to market 36.4% of the net
rentable area (NRA) for sublease, which was first put on the market
in June 2023. Currently, the master servicer, Wells Fargo Bank N.A.
(Wells Fargo), and CoStar indicated that the spaces are still on
the market and available for sublease. In addition, Wells Fargo
stated that floors 9 and 10, totaling 18.2% of the NRA, are dark.

-- The property's office submarket continues to experience
elevated vacancy and availability rates. However, the average
submarket asking rent for 4- and 5-Star office properties is still
significantly above the in place gross rent that the sole tenant is
currently paying, according to the June 30, 2024, rent roll.

-- Given these factors, S&P revised its expected-case valuation
for the property, which, while marginally higher (1.4%) than the
value S&P derived in its last review in October 2023, is still
17.6% below its issuance value and a 55.4% decline from the
issuance appraised value.

-- S&P has concerns with the borrower's ability to refinance the
loan at its maturity in December 2025 due to concentrated tenancy
and rollover about four years after the loan matures, significant
subleasing activity in a weak office submarket, and uncertainty
surrounding State Street's intent at the subject property upon its
lease expiry in 2029.

The downgrades on class E to 'CCC (sf)' and class F to 'CCC- (sf)'
also reflect S&P's view that the classes are or remain at
heightened risk of default and losses and are susceptible to
liquidity interruptions, based on our analysis, the current market
conditions, and their positions in the payment waterfall.

S&P said, "The downgrades on the class X-A and class X-B IO
certificates reflect our criteria for ratings 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 class X-B references classes B
and C.

"We will continue to monitor the tenancy and performance of the
property and loan, as well as the borrower's ability to refinance
the loan by its December 2025 maturity date. 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 loan collateral consists of One Channel Center, an 11-story,
class A, 501,650-sq.-ft. LEED silver certified office tower,
located at 1 Iron St. in the Seaport office submarket of Boston,
and an adjacent 965-space freestanding parking garage at 116 West
First St. Amenities include a non-collateral 1.6-acre public park,
a cafeteria, a fitness center, and a 130-space bike storage. The
office property was built-to-suit for State Street in 2014. SSB
Realty LLC, an affiliate of State Street, signed a 15-year
triple-net lease through Dec. 31, 2029. The tenant has two
five-year renewal options with an 18-month notice. The subject
property supports State Street's global headquarters, which, until
2023, was located nearby at 1 Lincoln St. The tenant relocated its
global headquarters about 1.5 miles northwest in September 2023 to
1 Congress St. It is our understanding that State Street does not
have any termination options and that its lease has not changed
since issuance.

The office collateral is subject to a ground lease between
co-borrowers to satisfy statutory requirements to realize real
estate tax benefits for certain development projects in blighted
areas. S&P said, "We viewed the ground rent payments as effectively
an intra-transaction between co-borrowers, resulting in zero sum
gain. Consequently, we did not include the ground rent payments in
our current analysis, which is the same approach as in our past
reviews."

State Street has marketed a portion of its leased space (four
floors totaling 36.4% of NRA) for sublease since June 2023. S&P
said, "In our October 2023 review, we utilized an 18.0% vacancy
rate, which was on par with the office submarket fundamentals at
that time, an S&P Global Ratings' gross rent of $40.67 per sq. ft.,
and a 46.8% operating expense ratio to arrive at our long-term
sustainable net cash flow (NCF) of $10.1 million. Using a 7.25% S&P
Global Ratings' capitalization rate and adding $1.9 million for the
present value of State Street's future rent steps, we derived an
expected-case value of $141.5 million, or $282 per sq. ft."

As of the June 30, 2024, rent roll, the property was still 100.0%
leased to State Street through Dec. 31, 2029, at a
$42.32-per-sq.-ft. gross rent, as calculated by S&P Global
Ratings.

According to CoStar, the 4- and 5-Star properties in the Seaport
office submarket had a 15.6% vacancy rate, a 28.5% availability
rate, and a $66.46-per-sq.-ft. average asking rent as of October
2024. CoStar projects the vacancy for 4- and 5-Star office
properties to incrementally increase to 17.7% in 2027 and then
return to its current level (15.6%) in 2028. The average asking
rent is expected to slightly contract to $63.67 per sq. ft. in 2027
and $64.68 per sq. ft. in 2028.

The property's in-place gross rent is significantly below the 4-
and 5-Star office properties' average submarket rent. CoStar
expects the submarket vacancy rate to stabilize around the
mid-teens. S&P said, "As a result, in our current analysis, we
assumed a 15.0% vacancy rate (roughly in line with the current 4-
and 5-Star office properties' submarket vacancy rate), a
$42.32-per-sq.-ft. S&P Global Ratings in-place gross rent, a 44.9%
operating expense ratio, and higher tenant improvement costs to
arrive at an S&P Global Ratings' NCF of $10.3 million, 1.8% above
our last review NCF and 17.6% lower than the $12.1 million NCF that
we derived at issuance. We utilized an S&P Global Ratings
capitalization rate of 7.18%, which is a weighted average based on
the office revenue and percentage rent and parking income, to
arrive at an S&P Global Ratings expected-case value of $143.5
million, or $286 per sq. ft., which is 1.4% higher than our last
review, 17.6% below our issuance value of $174.2 million ($347 per
sq. ft.), and a 55.4% decline from the issuance appraised value of
$322.0 million. This yielded an S&P Global Ratings loan-to-value
ratio of 115.7%."

  Table 1

  Servicer-reported collateral performance

      SIX MONTHS ENDING JUNE 2024(I)  2023(I)  2022(I)  2021(I)

  Occupancy rate (%)         100      100      100      100

  Net cash flow (mil. $)     7.5      16.0     11.6     13.1

  Debt service coverage (x)  2.08     2.24     1.63     1.83

  Appraisal value (mil. $)   322.0    322.0    322.0    322.0

(i)Reporting period.


  Table 2

  S&P Global Ratings' key assumptions

                       CURRENT        LAST REVIEW    ISSUANCE
                      (OCT 2024)(I)  (OCT 2023)(I)  (FEB 2016)(I)

  Occupancy rate (%)       85.0           82.0           96.0

  Net cash flow (mil. $)   10.3           10.1           12.1

  Capitalization rate (%)  7.18(ii)       7.25           7.10

  Add to value ($)(iii)    0.0            1.9            3.8

  Value (mil. $)           143.5          141.5          174.2

  Value per sq. ft. ($)    286            282            347

  Loan-to-value ratio (%)  115.7          117.3          95.3

(i)Review period.
(ii)Weighted average based on 7.00% for the office revenue and
8.00% for percentage rent and parking income.
(iii)Present value of tenant rent steps.


Transaction Summary

The 10-year, fixed rate, IO mortgage loan had an initial and
current balance of $166.0 million (as of the Sept. 17, 2024,
trustee remittance report), pays an annual fixed rate of 4.24%, and
matures on Dec. 11, 2025. The loan has a reported current payment
status through its September 2024 payment period. To date, the
trust has not incurred any principal losses.

  Ratings Lowered

  BAMLL Commercial Mortgage Securities Trust 2016-SS1

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



BBCMS MORTGAGE 2022-C15: Fitch Lowers Rating on 2 Tranches to B-sf
------------------------------------------------------------------
Fitch Ratings has downgraded five and affirmed 12 classes of BBCMS
Mortgage Trust 2022-C15, commercial mortgage pass-through
certificates, series 2022-C15. Classes E, F, X-D and X-F were
assigned Negative Rating Outlooks following their downgrades. The
Outlook for class D was revised to Negative from Stable.

Fitch has also affirmed 16 classes of BBCMS Mortgage Trust
2022-C18, commercial mortgage pass-through certificates, series
2022-C18. The Outlook for class F-RR was revised to Negative from
Stable. The Outlook on classes G-RR and H-RR remains Negative.

   Entity/Debt          Rating           Prior
   -----------          ------           -----
BBCMS 2022-C18

   A-1 054975AA5    LT AAAsf  Affirmed   AAAsf
   A-2 054975AB3    LT AAAsf  Affirmed   AAAsf
   A-3 054975AC1    LT AAAsf  Affirmed   AAAsf
   A-4 054975AD9    LT AAAsf  Affirmed   AAAsf
   A-5 054975AE7    LT AAAsf  Affirmed   AAAsf
   A-S 054975AJ6    LT AAAsf  Affirmed   AAAsf
   A-SB 054975AF4   LT AAAsf  Affirmed   AAAsf
   B 054975AK3      LT AA-sf  Affirmed   AA-sf
   C 054975AL1      LT A-sf   Affirmed   A-sf
   D 054975AP2      LT BBBsf  Affirmed   BBBsf
   E-RR 054975AR8   LT BBB-sf Affirmed   BBB-sf
   F-RR 054975AT4   LT BB+sf  Affirmed   BB+sf
   G-RR 054975AV9   LT BB-sf  Affirmed   BB-sf
   H-RR 054975AX5   LT B-sf   Affirmed   B-sf
   X-A 054975AG2    LT AAAsf  Affirmed   AAAsf
   X-D 054975AM9    LT BBBsf  Affirmed   BBBsf

BBCMS 2022-C15

   A-1 05552FAW7    LT AAAsf  Affirmed   AAAsf
   A-2 05552FAX5    LT AAAsf  Affirmed   AAAsf
   A-3 05552FAY3    LT AAAsf  Affirmed   AAAsf
   A-4 05552FAZ0    LT AAAsf  Affirmed   AAAsf
   A-5 05552FBA4    LT AAAsf  Affirmed   AAAsf
   A-S 05552FBE6    LT AAAsf  Affirmed   AAAsf
   A-SB 05552FBB2   LT AAAsf  Affirmed   AAAsf
   B 05552FBF3      LT AA-sf  Affirmed   AA-sf
   C 05552FBG1      LT A-sf   Affirmed   A-sf
   D 05552FAE7      LT BBBsf  Affirmed   BBBsf
   E 05552FAG2      LT BB-sf  Downgrade  BBB-sf
   F 05552FAJ6      LT B-sf   Downgrade  BB-sf
   G-RR 05552FAL1   LT CCCsf  Downgrade  B-sf
   X-A 05552FBC0    LT AAAsf  Affirmed   AAAsf
   X-B 05552FBD8    LT AA-sf  Affirmed   AA-sf
   X-D 05552FAA5    LT BB-sf  Downgrade  BBB-sf
   X-F 05552FAC1    LT B-sf   Downgrade  BB-sf

KEY RATING DRIVERS

Updated 'Bsf' Loss Expectations: Deal-level 'Bsf' rating case
losses are 6.2% for BBCMS 2022-C15 which reflects an increase from
4.8% at Fitch's prior rating action, while BBCMS 2022-C18's losses
are 4.7% which is in line with Fitch's prior rating action. The
BBCMS 2022-C15 transaction includes four Fitch Loans of Concern
(FLOCs; 9.8% of the pool), two of which are specially serviced
(4.5%). The BBCMS 2022-C18 transaction has four FLOCs (8.6%),
including one specially serviced loan (2.7%).

BBCMS 2022-C15: The downgrades on classes E, F, G-RR, X-D and X-F
reflect increased pool loss expectations since Fitch's prior rating
action, driven primarily by higher expected losses on the specially
serviced loans: Salina Meadows Office Park (2.4%), which has an
updated appraisal valuation, and VVF (2.0%) loans.

The Negative Outlooks for BBCMS 2022-C15 reflect the potential for
further downgrades if expected losses increase on the specially
serviced loans and/or if there is continued performance
deterioration and lack of stabilization of the FLOCs, particularly
the Moonwater Office Portfolio (3.9%) and NYC MFRT Portfolio (1.5%)
loans. Downgrades are expected should performance and submarket
fundamentals for these loans not stabilize and/or with prolonged
workouts of the specially serviced loans. In addition, the pool has
an elevated office concentration of 40.9%.

BBCMS 2022-C18: The affirmations in BBCMS 2022-C18 reflect
generally stable performance since Fitch's prior rating action. The
Negative Outlooks on classes F-RR, G-RR and H-RR reflect the
potential for future downgrades should performance of the FLOCs
continue to deteriorate and/or there is a prolonged workout of the
specially serviced Wyndham National Hotel Portfolio (2.7%).

Largest Contributors to Loss: The largest contributor to overall
loss expectations in BBCMS 2022-C15 is the specially serviced
Salina Meadows Office Park (2.4%) loan, which is secured by a
240,475-sf suburban office property located in Syracuse, NY. The
loan transferred to special servicing in June 2023 due to a payment
default. A receiver was appointed in November 2023, and the special
servicer is currently pursuing a foreclosure strategy.

The property was 59.9% occupied as of the April 2024 rent roll;
major tenants include Parsons Engineering (8.3% of NRA, leased
through December 2024), CorVel Healthcare Corp. (6.1%, September
2028), and NCR Corporation (5.4%, December 2026).

Fitch's 'Bsf' rating case loss of 58.6% (prior to a concentration
adjustment) is based on the most recent December 2023 appraisal
valuation and reflects a stressed value of $51.2 psf. The updated
appraisal value is approximately 70% lower than the appraisal value
from issuance. Fitch's 'Bsf' rating case loss for this loan at the
prior rating action was 32.1%.

The second largest contributor to overall loss expectations in
BBCMS 2022-C15 is the specially serviced VVF (2.0%) loan, which is
secured by a 638,595-sf single-tenant, industrial warehouse and
manufacturing facility located in Saint Bernard, OH. The loan
transferred to special servicing in June 2024 due to a payment
default after the borrower failed to make the March 2024 debt
service payment. The special servicer has reached out to the
borrower and a pre-negotiation letter has been executed.

The property was 100% leased to VVF through March 2042. VVF is the
world's leading contract manufacturer of bar soaps and the leading
manufacturer of oleochemicals in India. VVF, which guarantees the
lease, defaulted on its lease and an eviction process is currently
ongoing. Per CoStar, the property lies within the Central/Midtown
industrial submarket of the Cincinnati, OH market. As of 2Q24,
submarket asking rents averaged $7.5 psf and the submarket vacancy
rate was 5.8%. The loan reported $5.0 million ($7.8 psf) as of the
August 2024 loan level reserve report.

Fitch's 'Bsf' rating case loss of 30.7% (prior to a concentration
adjustment) is based on a 9.25% cap rate and 10% stress to the YE
2023 NOI, and factors in an increased probability of default due to
the recent transfer to special servicing and potential for a
prolonged workout given the eviction process that's underway and
the nature of the tenant's use of the property.

The third largest contributor to overall loss expectations in BBCMS
2022-C15 is the Moonwater Office Portfolio (3.9%) loan, which is
secured by a 611,320-sf, six-property suburban office portfolio
located in Las Vegas, NV. The portfolio's major tenants include
Nevada Power Company, Inc. (47.8% of portfolio NRA, leased through
January 2029) and WeWork (16.7%, October 2034).

Former major tenant Coin Cloud (previously 12.4% of NRA) filed for
Chapter 11 bankruptcy and vacated the property. According to the
servicer commentary, a cash sweep equal to one-year's payable rent
by Coin Cloud has been collected.

The second largest tenant in occupancy at the property, WeWork
(16.7% of NRA), also filed for Chapter 11 bankruptcy. The WeWork
lease at the 6543 South Las Vegas Boulevard property is not
currently on the lease rejection list. The servicer-reported NOI
DSCR was reported to be 1.19x and 1.82x at YE 2023, down from 1.86x
at YE 2022. Fitch requested additional performance information
including a recent rent roll, but this was not provided.

Per CoStar, the portfolio properties are located within the West
Las Vegas office submarket of the Las Vegas, NV market. As of 2Q24,
submarket asking rents averaged $27.5 psf and the submarket vacancy
rate was 5.3%. The loan reported $2.6 million ($4.3 psf) as of the
September 2024 loan level reserve report.

Fitch's 'Bsf' case loss of 17.3% (prior to a concentration
adjustment) is based on a 10.0% cap rate and Fitch issuance NCF,
and factors in an increased probability of default due to the
deterioration in performance and limited information provided.

The largest contributor to overall loss expectations in BBCMS
2022-C18 is the Spartan Retail Portfolio (8.1%) loan, which is
secured by a 14-property, 844,888-sf anchored retail portfolio
located across the U.S. The largest geographic concentrations
include 47.2% of NRA in Spartanburg, SC, 18.1% in Columbia, SC, and
14.7% in Pensacola, FL. The servicer-reported NOI DSCR for the TTM
ended January 2024 was 1.11x and 1.15x at YE 2023.

Fitch's 'Bsf' case loss of 9.7% (prior to a concentration
adjustment) is based on a 9.25% cap rate and 7.5% stress to the TTM
ended January 2024 NOI.

The second largest contributor to overall loss expectations in
BBCMS 2022-C18 is the Wyndham National Hotel Portfolio (2.7%) loan,
which is secured by a 44-property portfolio totaling 3,729 keys
comprised of limited service hotels located across 23 states: 27
Travelodges, 14 Baymont Inn & Suites, two Super 8s, and one Days
Inn. The loan transferred to special servicing in April 2024 due to
various defaults, including but not limited to failure to comply
with cash management. The borrower, Vukota Capital Management Ltd.,
filed Chapter 11 bankruptcy in June 2024 and the case is ongoing.

Portfolio occupancy was 58.0% as of March 2024 and the
servicer-reported NOI DSCR was 1.87x for the same period compared
to 55% and 1.73x, respectively, at YE 2022. The loan reported a
total of $11.4 million ($3,069 per key) in reserves as of the
August 2024 loan level reserve report.

Fitch's 'Bsf' rating case loss of 26.7% (prior to a concentration
adjustment) is based on a 13.5% cap rate and Fitch issuance net
cash flow (NCF), and factors in an increased probability of default
due to the recent transfer to special servicing and borrower
bankruptcy.

The third largest contributor to overall loss expectations in BBCMS
2022-C18 is the Rialto Industrial (8.4%) loan, which is secured by
a 1.1 million-sf, single-tenant, industrial warehouse/distribution
facility located in Rialto, CA. The property is 100% leased to
Rialto Distribution through October 2042. The property was 100%
occupied as of YE 2023 and the servicer-reported NOI DSCR was 1.67x
for the same period.

Fitch's 'Bsf' case loss of 6.1% (prior to a concentration
adjustment) is based on an 8.75% cap rate to the Fitch issuance
NCF.

Minimal Increase in CE: As of the September 2024 distribution date,
the aggregate balances of the BBCMS 2022-C15 and BBCMS 2022-C18
transactions have been reduced by 0.5% and 0.4%, respectively,
since issuance. No loans have been defeased in the BBCMS 2022-C15
and BBCMS 2022-C18 transactions.

Interest Shortfalls: To date, the BBCMS 2022-C15 and BBCMS 2022-C18
transactions have not incurred any realized principal losses.
Interest shortfalls totaling $443,630 are impacting the non-rated
risk retention classes H-RR, RRC and RRI in the BBCMS 2015-C15
transaction, and interest shortfalls totaling $22,149 are impacting
the non-rated risk retention classes J-RR in the BBCMS 2022-C18
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 in BBCMS 2022-C15 are
possible with continued performance deterioration of the FLOCs,
particularly Moonwater Office Portfolio, Salina Meadows Office Park
and VVF loan in BBCMS 2022-C15, increased expected losses and
limited to no improvement in class CE, or if interest shortfalls
occur. In BBCMS 2022-C18, downgrades may occur if property
performance and/or updated valuations for the specially serviced
Wyndham National Portfolio indicate expected losses increase.

Downgrades to classes rated in the 'AAsf' and 'Asf' categories in
both transactions 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.

Downgrades to classes with Negative Outlooks in the '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 classes with distressed ratings 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.


BBCMS MORTGAGE 2024-5C29: Fitch B-sf Final Rating on Cl. G-RR Certs
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to
BBCMS Mortgage Trust 2024-5C29 Commercial Mortgage Pass-Through
Certificates, Series 2024-5C29 as follows:

- $5,185,000a class A-1 'AAAsf'; Outlook Stable;

- $205,825,000a class A-2 'AAAsf'; Outlook Stable;

- $534,775,000a class A-3 'AAAsf'; Outlook Stable;

- $745,785,000ab class X-A 'AAAsf'; Outlook Stable;

- $127,848,000a class A-S 'AAAsf'; Outlook Stable;

- $50,607,000a class B 'AA-sf'; Outlook Stable;

- $37,289,000a class C 'A-sf'; Outlook Stable;

- $215,744,000ab class X-B 'A-sf'; Outlook Stable;

- $18,645,000ac class D 'BBBsf'; Outlook Stable;

- $10,654,000ac class E 'BBB-sf'; Outlook Stable;

- $29,299,000abc class X-D 'BBB-sf'; Outlook Stable;

- $19,977,000ac class F 'BB-sf'; Outlook Stable;

- $19,977,000abc class X-F 'BB-sf'; Outlook Stable;

- $10,654,000acd class G-RR 'B-sf'; Outlook Stable.

The following class is not rated by Fitch:

- $43,948,151acd class H-RR.

(a) The certificate balances and notional amounts of these classes
include the vertical risk retention (VRR) interest, which is
approximately 2.83% of the certificate balance or notional amount,
as applicable, of each class of certificates as of the closing
date.

(b) Notional amount and interest only.

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

(d) Class G-RR and H-RR certificates, excluding the portion
included in the VRR interest, comprise the transaction's horizontal
risk retention interest.

Since Fitch published its expected ratings on Sept. 11, 2024, the
balances for classes A-2 and A-3 were finalized. At the time the
expected ratings were published, the expected class A-2 balance
range was $0 to $275,000,000 and the expected class A-3 balance
range was $465,600,000 to $740,600,000. Fitch's certificate
balances for classes A-2 and A-3 were assumed at the midpoint of
both classes (inclusive of the VRR interest). The final class
balances for classes A-2 and A-3 are $205,825,000 and $534,775,000,
respectively.

Transaction Summary

The certificates represent the beneficial ownership interest in the
trust, primary assets of which are 55 fixed-rate commercial
mortgage loans secured by 102 properties having an aggregate
principal balance of $1,065,407,151, as of the cut-off date. The
mortgage loans were contributed to the trust by Barclays Capital
Real Estate Inc., Argentic Real Estate Finance 2 LLC, Starwood
Mortgage Capital LLC, KeyBank National Association, Societe
Generale Financial Corporation, German American Capital
Corporation, LMF Commercial, LLC, UBS AG, BSPRT CMBS Finance, LLC,
Bank of Montreal and Citi Real Estate Funding Inc.

The master servicer is KeyBank National Association and the special
servicer is Argentic Services Company LP. The trustee is U.S. Bank
Trust Company, National Association. The certificate administrator
is Computershare Trust Company, National Association. The
certificates will follow a sequential paydown structure.

KEY RATING DRIVERS

Fitch Net Cash Flow: Fitch performed cash flow analyses on 32 loans
totaling 84.6% of the pool by balance. Fitch's resulting net cash
flow (NCF) of $102.0 million represents a 14.4% decline from the
issuer's underwritten NCF of $119.2 million.

Higher Fitch Leverage: The transaction has higher Fitch leverage
compared to recent five-year multiborrower transactions rated by
Fitch. The pool's Fitch weighted-average (WA) trust loan-to-value
ratio (LTV) of 97.1% is higher than the 2024 YTD and 2023 averages
of 93.2% and 89.7%, respectively. The pool's Fitch NCF debt yield
(DY) of 9.6% is worse than both the 2024 YTD and 2023 averages of
10.5% and 10.6%, respectively.

Investment Grade Credit Opinion Loans: Four loans representing
13.3% of the pool balance received an investment grade credit
opinion. 277 Park Avenue (6.6%) received a standalone credit
opinion of 'Asf*'. BioMed 2024 Portfolio 2 (2.8% of the pool)
received a standalone credit opinion of 'BBB+sf*'. Bronx Terminal
Market (2.3% of the pool) received a standalone credit opinion of
'BBB-sf*'. GNL-Industrial Portfolio (1.6% of the pool) received a
standalone credit opinion of 'BBB-sf*'.

The pool's total credit opinion percentage of 13.3% is above the
YTD 2024 average of 12.8% and the 2023 average of 14.6%. The pool's
Fitch LTV and DY, excluding credit opinion loans, are 101.4% and
9.3%, respectively.

Higher Multifamily Concentration: Multifamily properties represent
the largest concentration at 41.4% of the pool, which is materially
higher than the YTD 2024 and 2023 averages of 22.2% and 10.9%,
respectively. The second and third largest concentrations are
retail (18.3%) and office (15.4%). Multifamily properties have a
lower average likelihood of default than retail and office, all
else equal.

The pool's effective property type count of 4.0 is slightly worse
than the YTD 2024 and 2023 averages of 4.2 and 4.1. Pools with a
greater concentration by property type are at a greater risk of
losses, all else equal. Fitch therefore 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

A reduction in cash flow that decreases property value and capacity
to meet its debt service obligations.

The list below indicates the model implied rating sensitivity to
changes to the same one variable, Fitch NCF:

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

- 10% NCF Decline:
'AA-sf'/'A-sf'/'BBB-sf'/'BB+sf'/'BB-sf'/'CCC+sf'/less than
'CCCsf'.

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

Similarly, an improvement in cash flow that increases property
value and capacity to meet its debt service obligations.

The list 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 Increase:
'AAAsf'/'AA+sf'/'Asf'/'A-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 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.


BEAR STEARNS 2006-EC2: Moody's Cuts Rating on Cl. M-2 Certs to Caa1
-------------------------------------------------------------------
Moody's Ratings has upgraded the rating of one bond from one US
residential mortgage-backed (RMBS) transaction and downgraded the
ratings of eight bonds from six US RMBS transactions, backed by
Alt-A and subprime mortgages issued by multiple issuers.

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: Bear Stearns Asset Backed Securities I Trust 2006-EC2

Cl. M-2, Downgraded to Caa1 (sf); previously on Jan 11, 2019
Downgraded to B3 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2007-FS1

Cl. I-A-3, Upgraded to B2 (sf); previously on May 21, 2010
Downgraded to Ca (sf)

Issuer: MASTR Alternative Loan Trust 2004-9

Cl. M-1, Downgraded to Caa1 (sf); previously on Oct 31, 2018
Downgraded to B1 (sf)

Issuer: MASTR Asset Backed Securities Trust 2003-OPT1

Cl. M-3, Downgraded to Caa1 (sf); previously on Oct 1, 2015
Upgraded to B3 (sf)

Issuer: MASTR Asset Backed Securities Trust 2004-FRE1

Cl. M-6, Downgraded to Caa2 (sf); previously on Nov 8, 2018
Downgraded to Caa1 (sf)

Cl. M-7, Downgraded to Ca (sf); previously on Apr 1, 2013 Affirmed
Caa2 (sf)

Issuer: MASTR Asset Backed Securities Trust 2004-HE1

Cl. M-4, Downgraded to B2 (sf); previously on Aug 8, 2019
Downgraded to B1 (sf)

Cl. M-5, Downgraded to Caa1 (sf); previously on Aug 8, 2019
Downgraded to B1 (sf)

Issuer: MASTR Asset Securitization Trust 2002-NC1

Cl. M-3, Downgraded to Caa1 (sf); previously on Dec 4, 2012
Downgraded to B2 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance as well as
Moody's updated loss expectations on the underlying pools. The
rating upgrade is a result of the improving performance of the
related pool, and an increase in credit enhancement available to
the bond.  The credit enhancement for Class I-A-3 of Bear Sterns
Asset Backed Securities I Trust 2007-FS1, increased by 16% over the
last 12 months.

The rating downgrades are due to outstanding interest shortfalls

on the bonds that are not expected to be recouped. Some bonds in
this review have weak interest recoupment mechanisms where missed
interest payments will likely result in a permanent interest loss.
Unpaid interest owed to bonds with weak interest recoupment
mechanisms are reimbursed sequentially based on bond priority, from
excess interest, if available, and often only after the
overcollateralization has built to a pre-specified target amount.
In transactions where overcollateralization has already been
reduced or depleted due to poor performance, any such missed
interest payments to these bonds are unlikely to be repaid.

Certain bonds in this review are currently impaired or expected to
become impaired. Moody's ratings on those bonds reflect any losses
to date as well as Moody's expected future loss.

No actions were taken on the other 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 principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in July 2022.

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

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


BENCHMARK 2024-V10: Fitch Assigns 'B-sf' Rating on Class G-RR Certs
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to
Benchmark 2024-V10 Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series V10 as follows:

- $230,000 class A-1 'AAAsf'; Outlook Stable;

- $160,000,000 class A-2 'AAAsf'; Outlook Stable;

- $356,349,000 class A-3 'AAAsf'; Outlook Stable;

- $71,952,000 class A-S 'AAAsf'; Outlook Stable;

- $588,531,000a class X-A 'AAAsf'; Outlook Stable;

- $41,510,000 class B 'AA-sf'; Outlook Stable;

- $28,597,000 class C 'A-sf'; Outlook Stable;

- $70,107,000a class X-B 'A-sf'; Outlook Stable;

- $12,545,000b class D 'BBBsf'; Outlook Stable;

- $12,545,000a,b class X-D 'BBBsf'; Outlook Stable;

- $11,439,000b,c class E-RR 'BBB-sf'; Outlook Stable;

- $14,759,000b,c class F-RR 'BB-sf'; Outlook Stable;

- $11,070,000b,c class G-RR 'B-sf'; Outlook Stable.

Fitch does not expect to rate the following classes:

- $29,519,000b,c class J-RR.

- $0b,c class R

Notes:

(a) Notional amount and interest only.

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

(c) Classes E-RR, F-RR, G-RR and J-RR certificates comprise the
transaction's horizontal risk retention interest.

Since Fitch published its expected ratings on Sept. 16, 2024, the
balances for classes A-2 and A-3 were finalized. At the time the
expected ratings were published, the expected class A-2 balance
range was $0 to $250,000,000, and the expected class A-3 balance
range is $291,329,000 to $516,349,000. Fitch's certificate balances
for classes A-2 and A-3 reflected the highest and lowest respective
value of each range. The final class balance for class A-2 is
$160,000,000. The final class balance for class A-3 is
$356,349,000.

The expected ratings are based on information provided by the
issuer as of Sept. 30, 2024.

KEY RATING DRIVERS

Fitch Net Cash Flow (NCF): Fitch performed cash flow analyses on 22
loans totaling 91.1% of the pool by balance, including the largest
20 loans and all of the office loans in the pool. Fitch's resulting
NCF of $190.9 million represents a 16.0% decline from the issuer's
underwritten NCF of $227.4 million.

Higher Fitch Leverage: The transaction has higher Fitch leverage
than recent five-year multiborrower transactions. The pool's Fitch
weighted average (WA) trust loan-to-value ratio (LTV) of 97.8% is
higher than the 2024 YTD and 2023 multiborrower five-year averages
of 90.4% and 89.7%, respectively. The pool's Fitch NCF debt yield
(DY) of 9.5% is weaker than both the 2024 YTD and 2023 averages of
11.1% and 10.6%, respectively.

Investment Grade Credit Opinion Loans: Two loans totaling 18.1% of
the pool received an investment-grade credit opinion on a
standalone basis. BioMed 2024 Portfolio 2 (10.0% of pool) received
a standalone credit opinion of 'BBB+sf*'. Bronx Terminal Market
(8.1% of pool) received a standalone credit opinion of 'BBB-sf*'.
The pool's total credit opinion percentage is above the YTD 2024
multiborrower five-year average of 12.0% and the 2023 multiborrower
five-year average of 14.6%. The pool's Fitch LTV and DY, excluding
credit opinion loans, are 103.4% and 9.3%, respectively.

Higher Office Concentration: The largest property type
concentration is office (36.3% of the pool), followed by
multifamily (27.2%) and hotel (13.3%). The pool's office loan
concentration is higher than the YTD 2024 and 2023 office averages
of 22.0% and 27.7%, respectively. In particular, the office
concentration includes four of the largest 10 loans (30.8% of the
pool). Pools that have a greater concentration by property type are
at greater risk of losses, all else being equal.

Therefore, Fitch raises the overall losses for pools with effective
property type counts below five property types. In general, the
pool has an average property type diversity consistent with other
recent Fitch-rated transactions; the pool's effective property type
count is 4.1 comparable with the YTD 2024 and 2023 multiborrower
five-year averages of 4.3 and 4.1, respectively.

Pool Concentration: The top 10 loans in the pool make up 63.5% of
the pool, which is higher than the YTD 2024 average of 59.2% but
lower than the 2023 average of 65.3%. The pool's effective loan
count is 20.7, compared to the YTD 2024 and 2023 averages of 23.0
and 23.6, respectively. Fitch views diversity as a key mitigant to
idiosyncratic risk. Fitch raises the overall loss for pools with
effective loan counts below 40.

Subordinate Debt: The pool has a higher concentration of
subordinate debt with three loans (27.0%) having secured
subordinate debt in place. This higher than the YTD 2024 and 2023
average of 6.2% and 3.7%, respectively.

RATING SENSITIVITIES

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

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

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

- 10% NCF Decline:
'AA-sf'/'A-sf'/'BBB-sf'/'BB+sf'/'BBsf'/'B-sf'/'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 list 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 Increase: AAAsf/AA+sf/A+sf/A-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 Ernst & Young LLP. Fitch
considered this information in its analysis and it did not have an
effect on its 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.


BLUEMOUNTAIN 2018-1: S&P Places 'BB-' E Notes Rating on Watch Neg.
------------------------------------------------------------------
S&P Global Ratings placed 31 ratings from 13 CLO transactions on
CreditWatch: 22 with positive implications and nine with negative
implications. All of the transactions are in their amortization
phase except for Blackrock Baker CLO 2021-1 Ltd., which is in its
reinvestment phase until January 2026. The portfolios of 11 CLOs
backing notes are broadly syndicated loans, and two CLOs are backed
by middle market speculative-grade loans.

Most of the 22 classes placed on CreditWatch positive are in the
senior part of their respective capital structures. The continued
paydowns to the senior notes of the CLOs increased the
overcollateralization support to these tranches. In addition, we
also considered their indicative cash flow results when we placed
their ratings on CreditWatch positive.

While paydowns to senior notes are generally a positive for the
credit enhancement of the senior portion of the capital structure,
increased exposure to lower-quality assets and portfolio
concentration in such amortizing transactions can increase the
credit risk of the junior CLO notes.

This seems the case for most of these nine tranches whose ratings
that are being placed on CreditWatch with negative implications:
one in the 'A' category, one in the 'BBB' category, two in the 'BB'
category, two in the 'B' category, and three in the 'CCC' category.
The placement primarily reflects the decline in their
overcollateralization levels, which is likely due to a combination
of par losses, increases in defaults, and increases in haircuts due
to excess exposure to 'CCC' collateral. In addition, S&P considered
other factors, such as indicative cash flow runs, current exposure
to 'CCC' and lower collateral, and the pure O/C, which is its
estimate of the tranches' current overcollateralization ratios
without 'CCC' haircuts in relation to the overall market average.

S&P intends to resolve these CreditWatch placements within 90 days,
following a committee review.

S&P will continue to monitor the transactions it rates and take
rating actions, including CreditWatch placements, as S&P deems
appropriate.


  Ratings list

  RATING

  ISSUER            CLASS    CUSIP            TO            FROM

  Atlas Senior
  Loan Fund X Ltd.     B   04942JAE1    AA (sf)/Watch Pos    AA

  Atlas Senior
  Loan Fund X Ltd.     C   04942JAG6    A (sf)/Watch Pos     A

  BlueMountain
  CLO 2018-1 Ltd.      E   09629UAA3    BB- (sf)/Watch Neg   BB-

  BlueMountain  
  CLO 2018-1 Ltd.      F   09629UAC9    CCC+ (sf)/Watch Neg  CCC+

  OCP CLO 2014-5
  Ltd. 2014-5      A-2-R   67102SAN4    AA (sf)/Watch Pos    AA

  OCP CLO 2014-5
  Ltd. 2014-5        E-R   67103SAL7    B- (sf)/Watch Neg    B-

  Octagon Investment
  Partners
  18-R, Ltd.         A-2   67576FAE9    AA (sf)/Watch Pos    AA

  Octagon Investment
  Partners
  18-R, Ltd.           E   67576HAC9    B- (sf)/Watch Neg    B-

  Blackrock Baker
  CLO 2021-1 Ltd.      C   91734KAG2    A- (sf)/Watch Neg    A-

  Blackrock Baker  
  CLO 2021-1 Ltd.      D   91734KAJ6    BBB- (sf)/Watch Neg  BBB-

  Blackrock Baker
  CLO 2021-1 Ltd.      E   91734KAL1    BB- (sf)/Watch Neg   BB-

  Telos CLO
  2014-6 Ltd.          E   87970UAQ9    CCC- (sf)/Watch Neg  CCC-

  Fortress Credit
  BSL VI Ltd.      B-1-R   34955YAE9    AA (sf)/Watch Pos    AA

  Fortress Credit
  BSL VI Ltd.     B-2-R2   34955YAN9    AA (sf)/Watch Pos    AA

  Fortress Credit
  BSL VI Ltd.        C-R   34955YAG4    A (sf)/Watch Pos     A

  BlueMountain
  CLO 2013-2
  Ltd. 2013-2        B-R   09626YAS9    AA (sf)/Watch Pos    AA

  BlueMountain
  CLO 2013-2
  Ltd. 2013-2        C-R   09626YAU4    A (sf)/Watch Pos     A

  GoldenTree Loan
  Opportunities
  XII Ltd.         B-1-R   38137MAM9    AA (sf)/Watch Pos    AA

  GoldenTree Loan
  Opportunities
  XII Ltd.       B-2-R-2   38137MAV9    AA (sf)/Watch Pos    AA

  GoldenTree Loan
  Opportunities
  XII Ltd.           C-R   38137MAR8    A (sf)/Watch Pos     A

  LCM XIII L.P.      D-R   50184KAY4    BBB (sf)/Watch Pos   BBB

  Cent CLO
  21 Ltd.         A-2-R3   15137EBQ5    AA (sf)/Watch Pos    AA

  Cent CLO 21 Ltd.  B-R3   15137EBS1    A (sf)/Watch Pos     A

  Cent CLO 21 Ltd.  C-R2   15137EBJ1    BBB- (sf)/Watch Pos  BBB-

  Cent CLO 21 Ltd.  E-R2   15137FAJ9    CCC+ (sf)/Watch Neg  CCC+

  AUF Funding LLC    B-1   002223AD7    AA (sf)/Watch Pos    AA

  AUF Funding LLC    B-2   002223AE5    AA (sf)/Watch Pos    AA

  AUF Funding LLC      C   002223AF2    A (sf)/Watch Pos     A

  Nassau 2017-I Ltd. A-2   631707AC0    AA+ (sf)/Watch Pos   AA+

  Nassau 2017-I Ltd.   B   631707AE6    A+ (sf)/Watch Pos    A+

  Nassau 2017-I Ltd.   C   631707AG1    BBB- (sf)/Watch Pos  BBB-





BRAVO RESIDENTIAL 2024-CES2: Fitch Gives B(EXP)sf on B2 Notes
-------------------------------------------------------------
Fitch Ratings has assigned expected ratings to BRAVO Residential
Funding Trust 2024-CES2 (BRAVO 2024-CES2).

   Entity/Debt         Rating           
   -----------         ------           
BRAVO 2024-CES2

   A1A             LT AAA(EXP)sf Expected Rating
   A1X             LT AAA(EXP)sf Expected Rating
   A1              LT AAA(EXP)sf Expected Rating
   A2              LT AA(EXP)sf  Expected Rating
   A3              LT A(EXP)sf   Expected Rating
   M1              LT BBB(EXP)sf Expected Rating
   B1              LT BB(EXP)sf  Expected Rating
   B2              LT B(EXP)sf   Expected Rating
   B3              LT NR(EXP)sf  Expected Rating
   AIOS            LT NR(EXP)sf  Expected Rating
   XS              LT NR(EXP)sf  Expected Rating

Transaction Summary

Fitch expects to rate the residential mortgage-backed notes issued
by BRAVO Residential Funding Trust 2024-CES2 (BRAVO 2024-CES2) as
indicated above. The transaction is expected to close on Oct. 11,
2024. The notes are supported by one collateral group that consists
of 5,263 primarily newly originated, closed-end second lien (CES)
loans with a total balance of $379 million, as of the cutoff date.

NewRez LLC (NewRez), PennyMac Loan Services, LLC (PennyMac), and
Nationstar Mortgage LLC dba Mr. Cooper (Nationstar), originated
approximately 37.0%, 32.7%, and 29.4% of the loans, respectively.
PennyMac, Rushmore Loan Management Services, LLC (Rushmore), and
Shellpoint will service the loans. The servicers will not advance
delinquent monthly payments of principal and interest (P&I).

Distributions of P&I and loss allocations are based on a
traditional senior-subordinate, sequential structure with an
interest-only class A-1X, whose interest payments are made
pari-passu with class A-1A, based on their respective entitlements.
The sequential-pay structure locks out principal to the
subordinated notes until the most senior notes outstanding are paid
in full. In addition, excess cash flow can be used to repay losses
or net weighted average coupon shortfalls.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): Due to an updated view
on sustainable home prices, Fitch views the home price values of
this pool as 11.7% above a long-term sustainable level, compared
with 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 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.

Closed-End Second Liens (Negative): The entirety of the collateral
pool is composed of newly originated CES mortgages. Fitch assumed
no recovery and 100% loss severity (LS) on second lien loans 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.

Strong Credit Quality (Positive): The pool consists of
new-origination CES loans, seasoned approximately seven months (as
calculated by Fitch), with a relatively strong credit profile
—weighted average model credit score of 736, a 37% debt-to-income
ratio (DTI) and a moderate sustainable loan-to-value ratio (sLTV)
of 75%.

Roughly 100% of the loans were treated as full documentation in
Fitch's analysis. None of the loans have experienced any
modifications since origination.

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

Second lien loans that are DQ for 180 days or more under the MBA
method will be subject to an equity analysis and may be charged
off, and, therefore, will cause the most subordinated class to be
written down. Despite the 100% LS assumed for each defaulted second
lien loan, Fitch views the writedown feature positively, as there
will be more excess interest to repay and protect against losses if
writedowns occur earlier. In addition, subsequent recoveries
realized after the writedown (excluding active forbearance or loss
mitigation loans) will be passed on to bondholders as principal.

Unlike prior CES deals, excess interest is only available to repay
current or prior losses and not to turbo down the bonds. This has
resulted in a higher amount of credit enhancement compared to
structures with a partial turbo feature.

No Servicer P&I Advances (Neutral): The servicers will not advance
DQ monthly payments of P&I. Structural provisions and cash flow
priorities, together with increased subordination, provide for
timely payments of interest to the 'AAAsf' and 'AA-sf' rated
classes. Fitch is indifferent to the advancing framework, as given
its projected 100% LS, no credit would be given to advances on the
structure side and no additional adjustment would be made as it
relates to LS.

RATING SENSITIVITIES

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

This defined negative rating sensitivity analysis shows how ratings
would react to steeper market value declines (MVDs) at the national
level. The analysis assumes MVDs of 10.0%, 20.0% and 30.0%, in
addition to the model-projected 42.6%, at 'AAAsf'. The analysis
indicates there is some potential rating migration, with higher
MVDs for all rated classes compared with model projections.
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

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

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 multiple third-party review firms. The third-party due
diligence described in Form 15E focused on credit, compliance, and
property valuation review. Fitch considered this information in its
analysis and, as a result, Fitch made the following adjustments to
its analysis:

- A 5% PD credit was applied at the loan level for all loans graded
either 'A' or 'B';

- Fitch lowered its loss expectations by approximately 78bps as a
result of the diligence review.

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.


BXP TRUST 2017-CC: S&P Lowers Class E Certs Rating to 'B (sf)'
--------------------------------------------------------------
S&P Global Ratings lowered its ratings on six classes of commercial
mortgage pass-through certificates from BXP Trust 2017-CC, a U.S.
CMBS 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)
whole mortgage loan secured by the borrower's fee simple interest
in Colorado Center, a six-building urban office campus totaling 1.2
million-sq.-ft. in Santa Monica, Calif.

Rating Actions

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

-- While the property is currently 87.6% leased, which is
relatively unchanged from S&P's last published review in May 2022,
four tenants comprising 71.7% of the net rentable area (NRA) have
marketed portions of their spaces for sublease. In addition, two of
these tenants, Hulu (30.9% of NRA) and Roku (6.9%), have early
termination options effective in 2027, the same year as the loan's
maturity. There has been no new direct leasing activity since our
last published review.

-- The property's office submarket continues to experience high
vacancy (over 25.0%) and availability (over 30.0%) rates. S&P said,
"We assessed that the sponsor would need to offer substantial
tenant improvement (TI) costs and rent concessions to attract and
retain tenants at the property. Given these factors, we considered
that the property's performance may decline closer to that of the
still-weak office submarket fundamentals at or prior to the loan's
maturity and would likely not return to historical levels in the
near term."

S&P said, "We revised our expected-case valuation for the property,
which is now 6.2% lower than the value we derived in our last
published review and at issuance. To arrive at this value, we
assumed higher vacancy rate and TI costs for the property.

"We have concerns with the borrower's ability to refinance the
whole mortgage loan due to concentrated tenancy and rollover at or
shortly after the loan matures, significant subleasing activity,
and the property's weak office submarket.

"We lowered our rating on the class X-A IO certificates based on
our 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.

"We will continue to monitor the loan and the tenancy and
performance of the property, including the sponsor's ability to
refinance the loan by its August 2027 maturity date. 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 property, Colorado Center, is a six-building urban office
campus totaling 1.2 million sq. ft. in Santa Monica built between
1984 and 1991. Amenities at Colorado Center include a three-level
subterranean parking garage containing 3,105 parking stalls, a food
court, a 3.5-acre park with tennis and basketball courts, a
full-service gym, including racquetball courts, and an indoor lap
pool.

S&P said, "In our May 4, 2022, review, we noted that although the
reported occupancy fell to 80.0% as of September 2021 from 97.8% as
of September 2020, the December 2021 rent roll indicated that Hulu
expanded its footprint, and occupancy increased to 86.7%, a level
generally in line with the office submarket fundamentals at that
time. As a result, we maintained our sustainable net cash flow
(NCF) and expected-case value that we derived at issuance."

Since then, there has been no new direct leasing activity. The
master servicer reported relatively stable occupancy and NCF in
2022 through six months ended June 30, 2024. However, according to
the master servicer, Wells Fargo Bank N.A., and CoStar, four of the
largest tenants comprising 71.7% of NRA have marketed portions of
their spaces for sublease. Further, two of these tenants, Hulu
(30.9% of NRA) and Roku (6.9%) have early lease termination options
effective as of February 2027 and December 2027, respectively.

As of the June 30, 2024, rent roll, the property was 87.6% leased.
The five largest tenants comprised 85.8% of NRA and include:

-- Hulu (30.9% of NRA, 33.9% of gross rent as calculated by S&P
Global Ratings, February 2029 lease expiration). According to Wells
Fargo and CoStar, about 35.7% of its leased space, or 11.0% of the
property's NRA, has been marketed for sublease since June 2024. The
tenant has an early termination option effective Feb. 28, 2027,
with 12 months' prior notice and a prorated unamortized costs
payment.

-- Edmunds.com (17.3%, 22.5%, January 2028). According to the
master servicer and CoStar, the tenant has marketed 65.7% of its
leased space, or 11.4% of the entire NRA, for sublease since May
2022.

-- Rubin Postaer (16.5%, 16.4%, June 2033). Per Wells Fargo and
CoStar, the tenant has marketed 72.9% of its leased space, or 12.0%
of the property's NRA, for sublease. CoStar noted that Bo's House
of Visual Arts has subleased 2.7% of the NRA at a base rent that is
19.9% lower than the tenant's in-place base rent.
Kite Pharma (14.1%, 18.6%, July 2032).

-- Roku (6.9%, 7.9%, February 2032). Wells Fargo indicated that
82.7% of its leased space, or 5.7% of the entire NRA, is marketed
for sublease. The tenant has an early lease termination option
effective Dec. 1, 2027, with 12 months' notice by Dec. 1, 2026, and
a $6.5 million termination fee payment.

-- The property faces minimal (less than 0.5% of NRA) tenant
rollover each year until after the loan matures in 2027. After
that, 17.3% of NRA (22.5% of S&P Global Ratings' in-place gross
rent) roll in 2028, 30.9% (33.9%) in 2029, 21.0% (26.4%) in 2032,
and 16.5% (16.5%) in 2033. Additionally, Hulu and Roku can also
terminate their leases in 2027. According to the September 2024 CRE
Finance Council loan-level reserve report, there is about $5.3
million in the tenant reserve account.

According to CoStar, 4- and 5-star properties in the Santa Monica
office submarket, where the subject property is located, continued
to experience elevated vacancy (27.2%) and availability (35.2%)
levels and flat average asking rent ($68.99 per sq. ft.) as of
October 2024. The overall Santa Monica office submarket had a
reported 20.2% vacancy rate, 27.0% availability rate, and
$60.34-per-sq.-ft. asking rent. This compares with the property's
in-place vacancy of 12.4% and in-place gross rent, as calculated by
S&P Global Ratings, of $77.21 per sq. ft. CoStar projects for 4-
and 5-Star office properties the vacancy rate to remain elevated at
27.6% in 2027 and 2028 and average asking rent to be flat at $68.41
per sq. ft. in 2027 and $68.98 per sq. ft. in 2028.

S&P said, "Given the limited leasing development, considerable
subleasing activity, early termination options, and concentrated
tenancy and rollover, we assessed that there is a strong
probability that the property's performance may decline to a level
closer to the still-weak office submarket fundamentals. We assumed
a 20.0% vacancy rate (between the property's in-place and current
office submarket vacancy levels), a $77.21-per-sq.-ft. S&P Global
Ratings' gross rent, a 31.5% operating expense ratio, and higher TI
costs to arrive at a revised long-term sustainable NCF of $45.2
million, a 9.0% decline from our last published review NCF of $49.6
million. Using a 7.25% S&P Global Ratings' capitalization rate,
unchanged from our last published review, and deducting $2.5
million for the Proposition 13 adjustment, we derived an S&P Global
Ratings expected-case value of $620.8 million, or $528 per sq. ft.,
6.2% below our last published review value of $661.8 million and a
48.8% decrease from the issuance appraised value of $1.2 billion.
This yielded an S&P Global Ratings' loan-to-value ratio of 88.6% on
the whole loan balance."

  Table 1

  Servicer-reported collateral performance

             YEAR TO DATE JUNE 2024(I)  2023(I)  2022(I)  2021(I)

  Occupancy rate (%)           87.8     87.8     87.1     80.0

  Net cash flow (mil. $)       27.4     54.9     52.0     50.9

  Debt service coverage (x)    2.75     2.76     2.62     2.56

  Appraisal value (mil. $)     1,212.5  1,212.5  1,212.5  1,212.5

(i)Reporting period.

  
  Table 2

  S&P Global Ratings' key assumptions
  
                             CURRENT   LAST REVIEW  ISSUANCE
                            (OCT 2024) (MAY 2022) (AUGUST 2017)
                              (I)        (I)          (I)
  Occupancy rate (%)           80.0        86.7       90.2

  Net cash flow (mil. $)       45.2        49.6       49.6

  Capitalization rate (%)      7.25        7.25       7.25

  Proposition 13 adjustment   (2.5)       (22.9)     (22.9)

  Value (mil. $)               620.8       661.8      661.8

  Value per sq. ft. ($)        528         563        563

  Loan-to-value ratio (%)(ii)  88.6        83.1       83.1

(i)Review period.
(ii)On the whole loan balance.


Transaction Summary

The IO whole mortgage loan had an initial and current balance of
$550.0 million, pays an annual fixed interest rate of 3.56%, and
matures on Aug. 9, 2027. The whole loan is split into nine senior A
notes totaling $298.0 million and three subordinate B notes
totaling $252.0 million. The trust balance totaling $350.0 million
(as of the Sept. 13, 2024, trustee remittance report) comprises
three of the senior A notes totaling $98.0 million and the three
subordinate B notes totaling $252.0 million. The remaining six
senior A notes, totaling $200.0 million, are in four U.S. CMBS
conduit transactions. The $298.0 million senior A notes are pari
passu to each other in right of payment and senior in right of
payment to the $252.0 million subordinate B notes.

To date, the transaction has not experienced any principal losses.

  Ratings Lowered

  BXP Trust 2017-CC

  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 'BB- (sf)'
  Class X-A to 'AA+ (sf)' from 'AAA (sf)'



CARLYLE US 2018-3: Moody's Affirms Ba3 Rating on $20.8MM D Notes
----------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by Carlyle US CLO 2018-3, Ltd.:

US$39.8M Class A-2 Senior Secured Floating Rate Notes, Upgraded to
Aaa (sf); previously on Sep 8, 2023 Upgraded to Aa1 (sf)

US$20M Class B Mezzanine Secured Deferrable Floating Rate Notes,
Upgraded to Aa2 (sf); previously on Sep 8, 2023 Upgraded to A1
(sf)

US$25.4M Class C Mezzanine Secured Deferrable Floating Rate Notes,
Upgraded to Baa2 (sf); previously on Sep 10, 2020 Confirmed at Baa3
(sf)

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

US$244M (current outstanding amount US$163,802,263) Class A-1a
Senior Secured Floating Rate Notes, Affirmed Aaa (sf); previously
on Oct 29, 2018 Definitive Rating Assigned Aaa (sf)

US$18M Class A-1b Senior Secured Floating Rate Notes, Affirmed Aaa
(sf); previously on Oct 29, 2018 Definitive Rating Assigned Aaa
(sf)

US$20.8M Class D Junior Secured Deferrable Floating Rate Notes,
Affirmed Ba3 (sf); previously on Sep 10, 2020 Confirmed at Ba3
(sf)

Carlyle US CLO 2018-3, Ltd., issued in October 2018, is a
collateralised loan obligation (CLO) backed by a portfolio of
mostly high-yield senior secured US loans. The portfolio is managed
by Carlyle CLO Management L.L.C. The transaction's reinvestment
period ended in October 2023.

RATINGS RATIONALE

The rating upgrades on the Class A-2, B and C notes are primarily a
result of the significant deleveraging of the Class A-1a notes
following amortisation of the underlying portfolio since the last
rating action in September 2023.

The affirmations on the ratings on the Class A-1a, A-1b and 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-1a notes have paid down by approximately USD 80.2
million (32.9%) since the last rating action in September 2023. As
a result of the deleveraging, over-collateralisation (OC) has
increased across the capital structure. According to the trustee
report dated September 2024 [1], the Class A, Class B, Class C and
Class D OC ratios are reported at 138.73%, 127.25%, 115.14% and
106.82% compared to August 2023 [2] levels, on which the last
rating action was based, of 129.59%, 121.53%, 112.64% and 106.28%,
respectively.

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: USD 307.0m

Defaulted Securities: USD 2.26m

Diversity Score: 69

Weighted Average Rating Factor (WARF): 2904

Weighted Average Life (WAL): 3.86 years

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 3.21%

Weighted Average Recovery Rate (WARR): 47.4%

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 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.


CASCADE MH 2024-MH1: Fitch Assigns B-(EXP)sf Rating on Cl. B2 Notes
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings to the
residential-mortgage backed notes to be issued by Cascade MH Asset
Trust 2024-MH1 (CMHAT 2024-MH1).

   Entity/Debt        Rating           
   -----------        ------           
CMHAT 2024-MH1

   A1             LT AAA(EXP)sf  Expected Rating
   A2             LT AA-(EXP)sf  Expected Rating
   M1             LT A-(EXP)sf   Expected Rating
   M2             LT BBB-(EXP)sf Expected Rating
   B1             LT BB-(EXP)sf  Expected Rating
   B2             LT B-(EXP)sf   Expected Rating
   B3             LT NR(EXP)sf   Expected Rating
   R              LT NR(EXP)sf   Expected Rating
   X              LT NR(EXP)sf   Expected Rating

Transaction Summary

Fitch expects to rate notes to be issued by Cascade MH Asset Trust
2024-MH1 (CMHAT 2024-MH1). This is Cascade's fourth transaction
(and second rated transaction) backed by loans secured by
manufactured homes (MH). While this is the fourth post-crisis MH
transaction to be rated by Fitch, it is also the second rated
post-crisis MH transaction to consist of new origination MH loans.

The transaction is expected to close on Oct. 11, 2024. The
collateral pool is backed by 1,020 MH contracts. The pool totals
$147.0 million.

Distributions of principal and interest (P&I) are based on a
traditional senior-subordinate, sequential pay structure. Losses
are allocated to the note overcollateralization (OC) amount and
excess spread and lastly applied in reverse sequential order
beginning with the most subordinated bond. The sequential pay
structure locks out principal to the subordinated notes until the
most senior notes outstanding are paid in full. The servicer will
not be advancing delinquent monthly payments of P&I.

KEY RATING DRIVERS

Manufactured Housing Collateral (Negative): The transaction is
backed by 98.6% new origination manufactured homes (MH) loans,
which are seasoned at approximately six months, as determined by
Fitch. Loans backed by chattel properties (secured with the
structure only) comprise 71.6% of the pool, and the remaining 28.4%
is comprised of land/home MH. Fitch applies a higher probability of
default (PD) for chattel homes than for land homes, given that the
borrower does not own the land the housing structure sits on. MH
loans typically experience higher default rates and lower
recoveries than site-built residential homes.

Fitch applied a loan-level loss model developed specifically for MH
loans based on historical observations of more than one million MH
loans originated from 1993 to 2002, with performance tracked
through 2018. The key PD drivers in Fitch's MH modeling include the
original CLTV, credit score, MH type (chattel vs. land home), pay
history, loan purpose, property type (single vs. multi-wide), loan
term and the representation and warranty framework.

The primary loss severity considerations are the loan balance,
years since manufacturing was completed and the property type.
Relative to standard RMBS pools, certain PD and LS variables such
as sustainable loan-to-value (sLTV), documentation scoring,
originator and servicer adjustments, number of borrowers, liquid
reserves, origination channel, occupancy, debt-to-income (DTI),
property value ratio (PVR), and qualified-mortgage (QM) status are
not applicable for pools backed by MH collateral.

MH Credit Attributes (Negative): All loans in the pool are fixed
rate, and the borrowers in the pool have a weighted average (WAVG)
model FICO of 685 and a combined loan-to-value ratio (CLTV) of
94.4%. Double or multi-wide MH units comprise 77.7% of the pool,
while 98.5% of the MH units were built within the last four years.
Double or multi-wide MH properties are viewed by Fitch as a more
favorable PD variable. In addition, Fitch views newer manufactured
years as more favorable. Some 97.5% of loans are now current based
on the OTS methodology over the past two years, while 2.3% have
experienced a delinquency within the past 24 months and 0.2% are
currently delinquent.

Fitch's expected loss in the 'AAAsf' stress is 43.25%, with a PD
and LS of 53.26% and 81.20%, respectively. Fitch's expected loss in
the 'Bsf' stress is 22.50%, with a PD and LS of 33.85% and 66.47%,
respectively.

Sequential Pay Structure (Positive): The transaction's cash flow is
based on a sequential pay structure. The subordinate classes do not
receive principal until the senior classes are repaid in full. Note
OC, calculated as 1.5% of the aggregate cutoff balance, will be
used as credit enhancement in addition to substantial excess
spread. Following note OC and excess, losses are allocated in
reverse-sequential order beginning with the class B-3.

Furthermore, the provision to reallocate principal to pay interest
on the 'AAAsf' rated notes prior to other principal distributions
is highly supportive of timely interest payments to that class in
the absence of servicer advancing. Excess spread will also be used
to pay down the notes on each payment date where a cumulative loss
trigger event is in effect.

Overcollateralization (Positive): The transaction benefits from OC,
which acts as a form of credit enhancement, along with
subordination and excess spread. The note OC amount represents the
amount by which the aggregate pool balance exceeds the aggregate
class principal balance of the notes. On the closing date, the
initial OC will be approximately $0.

Following the closing date, the note OC amount may increase to the
OC target amount, defined as 1.50% ($2,204,386) of the aggregate
pool balance as of the cutoff date. OC is replenished throughout
the life of the transaction. The introduction of an OC target
amount will provide increased support during varying loss timing
scenarios through the life of the transaction.

Excess Spread (Mixed): The structure has a notable amount of excess
spread (approximately 234 bps) due to the difference in coupon on
the underlying collateral and the weighted average coupon on the
notes. Due to the significant amount of excess spread and OC, the
deal CE is lower than Fitch's expected losses. Excess spread can be
a notable benefit to a transaction, based on the excess cash flow
waterfall.

When a cumulative loss trigger is not in effect, the monthly excess
cash flow waterfall is structured to pay any fees and expenses,
unpaid principal, cumulative realized losses, breach reserve
account, net WAC shortfalls and B-3 interest. Any remaining excess
will flow to the class X holder and would not be used later during
the life of the transaction to cover losses. Specifically, in
Fitch's backloaded scenarios, excess may not be available to cover
periodic losses. This risk is mitigated by the structure utilizing
the OC target amount which is replenished throughout the life of
the deal.

When a cumulative loss trigger is in effect, the monthly excess
cash flow waterfall will use principal to turbo down the bonds;
however, the trigger is considered weak and would require
substantial losses before excess is used to pay principal.

The structure of this transaction differs slightly from that of
other Fitch-rated MH transactions where excess may be used to turbo
down the bonds, and is more supportive through different loss
timing scenarios. Transactions with more supportive structures have
seen more significant rating upgrades.

No Servicer Principal and Interest (P&I) Advancing (Positive): 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.

RATING SENSITIVITIES

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

The defined stress sensitivity analysis demonstrates how the
ratings would react to additional losses. As shown in the presale
report, the analysis indicates some potential of rating migration
with an increase in loss.

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

The defined stress sensitivity analysis demonstrates that better
than expected performance could lead to rating upgrades.

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 Regulatory Solutions and Ernest Young LLP. The review
was bifurcated between land home and chattel loans.

Land home MH loans received a scope that consisted of credit,
compliance and data integrity. The land home MH loans which are
qualified mortgages do not require an appraisal per Cascade's
guidelines. As a result, no valuation review was performed for this
cohort. If required by applicable guidelines, Cascade employs an
automated valuation model or desk review in the appraisal review,
unless the loan meets certain specific criteria, to ensure the
value is reasonably supported.

Chattel loans received a credit, compliance and data integrity
check but did not receive a valuation review. Chattel properties
are valued solely on the housing unit, which excludes the land they
reside upon. Therefore, appraisals are not performed on chattel
units, which results in a valuation review not being applicable.

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.


CEDAR CREST 2022-1: Fitch Affirms B-sf Rating on Class F Notes
--------------------------------------------------------------
Fitch Ratings has affirmed the ratings on the class A-FL, A-FX, B,
C, D, E and F notes of Cedar Crest 2022-1 LLC (Cedar Crest 2022-1).
The Rating Outlooks have been revised to Negative from Stable on
class C, D, E, and F notes in Cedar Crest 2022-1. The Outlook
remains Stable for all other rated tranches.

   Entity/Debt              Rating           Prior
   -----------              ------           -----
Cedar Crest 2022-1 LLC

   A-FL 15018VAA7       LT AAAsf  Affirmed   AAAsf
   A-FX 15018VAC3       LT AAAsf  Affirmed   AAAsf
   B 15018VAE9          LT AAsf   Affirmed   AAsf
   C 15018VAG4          LT Asf    Affirmed   Asf
   D 15018VAJ8          LT BBB-sf Affirmed   BBB-sf
   E 15018VAL3          LT BB-sf  Affirmed   BB-sf
   F 15018VAN9          LT B-sf   Affirmed   B-sf

Transaction Summary

Cedar Crest 2022-1 is a middle market collateralized loan
obligation (CLO) managed by Panagram Structured Asset Management,
LLC. Cedar Crest 2022-1 closed in November 2022 and will exit its
reinvestment period in October 2026. This CLO is secured primarily
by first-lien, senior secured leveraged loans.

KEY RATING DRIVERS

Increased Portfolio Concentration and Material Change in Portfolio
composition, leading to lower portfolio recovery assumptions

Since last review in October 2023, the portfolio has experienced
approximately 45% turnover, resulting in a more concentrated
portfolio and a lower Weighted Average Recovery Rate (WARR). Based
on the portfolio reported in the August 1 trustee report, the
number of obligors fell to 57 from 72 since the last review. Each
obligor now represents 1.8% of the current portfolio, excluding
cash, compared to 1.4% at last review.

The weight of assets representing middle market collateral
increased by approximately 17% while the share of broadly
syndicated loans (BSL) declined by a corresponding magnitude. The
Fitch WARR decreased to 63.1% from 67.5%. The Fitch Weighted
Average Rating Factor (WARF) remains in the 'B-' rating level,
slightly increasing to 32.3 from 31.8 at the last review.

As a result of these key rating drivers, the model-implied ratings
(MIR) on class B, C, D, and E notes are a notch lower than their
respective current ratings. Fitch affirmed all of the notes due to
the modest magnitude of failures relative to the respective default
hurdles for the notes and considering the modelling shortfalls were
limited to the 'interest rate down 'scenarios. Additionally, the
portfolio is actively managed according to Fitch Collateral Quality
Tests (CQT) under the remaining two years of the reinvestment
period, and Fitch believes that future declines in WARF and WARR
are likely to be mitigated through managing the portfolio to Fitch
CQT.

Nevertheless, the Negative Outlook on Class C, D, and E notes
indicates rating vulnerability to modest portfolio deterioration.
In addition, Class F, while not experiencing modelling shortfalls,
is currently passing its current rating of 'B-sf' with 2.3% default
cushion at a 60.4% recovery assumption for the underlying assets.
Therefore, the class's rating is potentially susceptible to a
single default, given the concentration of the portfolio and
class's junior position in the capital structure.

The Stable Outlook for Class B notes, despite the modelling
shortfalls, is expected to benefit from its senior position when
deleveraging begins after the end of reinvestment period in October
2026.

RATING SENSITIVITIES

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

- Downgrades may occur if realized and projected losses of the
portfolio are higher than what was assumed at closing and the
notes' credit enhancement do not compensate for the higher loss
expectation than initially assumed.

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

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

- Upgrades may occur in the event of better-than-expected portfolio
credit quality and transaction performance.

- Except for the 'AAAsf' rated notes, which are at the highest
level on Fitch's scale and cannot be upgraded, a 25% reduction of
the mean default rate across all ratings, along with a 25% increase
of the recovery rate at all rating levels for the current
portfolio, would lead to upgrades of up to four notches, based on
the MIRs.

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

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

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

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

ESG Considerations

Fitch does not provide ESG relevance scores for Cedar Crest 2022-1
LLC.

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 any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.


CIFC FUNDING 2018-II: Fitch Assigns BB-(EXP)sf Rating on E-R Notes
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
CIFC Funding 2018-II, Ltd. Reset Transaction.

   Entity/Debt       Rating           
   -----------       ------           
CIFC Funding
2018-II, Ltd.

   A-1-R         LT AAA(EXP)sf  Expected Rating
   A-2-R         LT AAA(EXP)sf  Expected Rating
   B-R           LT AA(EXP)sf   Expected Rating
   C-R           LT A(EXP)sf    Expected Rating
   D-1-R         LT BBB-(EXP)sf Expected Rating
   D-2-R         LT BBB-(EXP)sf Expected Rating
   E-R           LT BB-(EXP)sf  Expected Rating

Transaction Summary

CIFC Funding 2018-II, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that is managed by CIFC CLO
Management II LLC that originally closed on May 31, 2018. The
secured notes will be refinanced in whole on Oct. 10, 2024. 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 24.2, 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
99.01% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 76% versus a
minimum covenant, in accordance with the initial expected matrix
point of 73.2%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 46.5% 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-1R, between
'BBB-sf' and 'AA+sf' for class A-2R, between 'BB+sf' and 'A+sf' for
class B-R, between 'Bsf' and 'BBB+sf' for class C-R, between less
than 'B-sf' and 'BB+sf' for class D-1R, between less than 'B-sf'
and 'BB+sf' for class D-2R, 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 A-1R and class
A-2R 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-1R, 'Asf' for class D-2R, 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
2018-II, 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.


CIFC FUNDING 2022-VI: Fitch Assigns 'BB-sf' Rating on Cl. E-R Notes
-------------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to CIFC
Funding 2022-VI, Ltd. reset transaction.

   Entity/Debt         Rating               Prior
   -----------         ------               -----
CIFC Funding
2022-VI, Ltd.

   A-R             LT AAAsf  New Rating
   B-1 12574HAC7   LT PIFsf  Paid In Full   AAsf
   B-2 12574HAJ2   LT PIFsf  Paid In Full   AAsf
   B-R             LT AAsf   New Rating
   C 12574HAE3     LT PIFsf  Paid In Full   Asf
   C-R             LT Asf    New Rating
   D 12574HAG8     LT PIFsf  Paid In Full   BBB-sf
   D-1-R           LT BBB-sf New Rating
   D-2-R           LT BBB-sf New Rating
   E 12569BAA1     LT PIFsf  Paid In Full   BB-sf
   E-R             LT BB-sf  New Rating

Transaction Summary

CIFC Funding 2022-VI, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by CIFC
Asset Management LLC. The transaction originally closed in
September 2022. The CLO's existing secured notes will be refinanced
in whole on Oct. 3, 2024 from proceeds of the new secured notes.
Net proceeds from the issuance of the secured notes, along with the
existing 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. The weighted average rating factor (WARF) of the indicative
portfolio is 23.93 versus a maximum covenant, in accordance with
the initial expected matrix point of 25.0. 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
95.78% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.15% versus a
minimum covenant, in accordance with the initial expected matrix
point of 73.80%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 46.5% 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 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 A1-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 D1-R,
between less than 'B-sf' and 'BB+sf' for class D2-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 A1-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, 'Asf'
for class D1-R, 'A-sf' for class D2-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
2022-VI, 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 any ESG factor
that is a key rating driver in the key rating drivers section of
the relevant rating action commentary.


COMM 2014-UBS4: Fitch Lowers Rating on Two Tranches to 'BB-sf'
--------------------------------------------------------------
Fitch Ratings has downgraded three and affirmed three classes of
Deutsche Bank Securities, Inc.'s COMM 2014-UBS4 Mortgage Trust
commercial pass-through certificates. Negative Rating Outlooks were
assigned to classes B, C and PEZ following their downgrades. The
Outlooks remain Negative for the affirmed classes (A-5, A-M and
X-A).

   Entity/Debt          Rating            Prior
   -----------          ------            -----
COMM 2014-UBS4

   A-5 12591QAR3    LT AAAsf  Affirmed    AAAsf
   A-M 12591QAT9    LT AAAsf  Affirmed    AAAsf
   B 12591QAU6      LT A-sf   Downgrade   AA-sf
   C 12591QAW2      LT BB-sf  Downgrade   A-sf
   PEZ 12591QAV4    LT BB-sf  Downgrade   A-sf
   X-A 12591QAS1    LT AAAsf  Affirmed    AAAsf

KEY RATING DRIVERS

Increased 'Bsf' Loss Expectations; Adverse Selection: The
downgrades reflect increased pool loss expectations since Fitch's
prior rating action, driven by continued performance deterioration
and/or updated lower appraisal valuations on the specially serviced
loans, particularly State Farm Portfolio and 597 Fifth Avenue.
Additionally, the pool is highly concentrated and adversely
selected, with 14 loans remaining, including 11 specially serviced
loans (92.4% of the pool balance). Fitch's current ratings
incorporate a 'Bsf' rating case loss of 43.0%.

The Negative Outlooks reflect the high concentration of specially
serviced loans and these classes' reliance on specially serviced
loan proceeds to repay; further downgrades are likely without
performance stabilization and/or should recovery prospects worsen
on the loans in special servicing, particularly State Farm
Portfolio, 597 Fifth Avenue, 30 Knightsbridge, North Pointe
Business Park, Fremont Moreno 3rd Street Promenade, The Mercantile
Building and Columbia Associates Portfolio.

Due to the increasing concentrated nature of the pool, Fitch
performed a sensitivity and liquidation analysis, which grouped the
remaining loans based on their current status and collateral
quality, and ranked them by perceived likelihood of repayment
and/or loss expectations. Higher probabilities of default were
assigned to loans anticipated to default at maturity along with
additional stresses to appraisal valuations of loans in special
servicing.

Largest Contributors to Loss Expectations: The largest overall
contributor to expected losses and largest increase in loss since
the prior rating action is the State Farm Portfolio loan (31.6% of
the pool), which is secured by 14 single-tenant suburban office
properties located in 11 cities across 11 states. The loan
transferred to special servicing in September 2023 at the
borrower's request for a loan modification to include a partial
release and paydown of the loan. State Farm, which already
announced its intention to vacate the properties, has various lease
expirations across the portfolio, including 4.2% of the portfolio
NRA in 2026 and 92.5% in 2028. One property (3.3% of NRA) had a
State Farm lease that expired in 2023.

The loan had an anticipated repayment date (ARD) in April 2024 with
a final maturity date in April 2029. Since the loan failed to repay
at the ARD, the interest rate was reset from the initial rate of
4.6266% to the higher of the five-year treasury note rate plus
3.50% and 7.6266% through April 2026, and a cash flow sweep was
triggered. The loan continues to amortize with excess cash flow. If
the loan still fails to repay by the end of April 2026, the
interest rate will again be reset to the higher of the five-year
treasury note rate plus 4.50% and 8.6266% from May 2026 through the
final April 2029 maturity.

Fitch's 'Bsf' rating case loss of 50.5% (prior to concentration
adjustments) reflects a 10.50% cap rate, 60% stress to the YE 2023
NOI and factors an increased probability of default to account for
the anticipated vacancy across the entire portfolio.

The next largest contributor to expected losses and the second
largest increase in loss since the prior rating action is the 597
Fifth Avenue loan (25.9%), which is secured by two retail and
office buildings located in Manhattan totaling 80,032-sf. The loan
transferred to special servicing in October 2020 due to payment
default cause by pandemic-related performance declines. Performance
has continued to decline, with occupancy falling to 42.3% as of
February 2024 from 49% at March 2023, and it remains below
occupancy levels of 71% in June 2022 and 95% at YE 2019. YE 2023
cash flow remains insufficient to cover debt service.

Fitch's 'Bsf' rating case loss of 51.4% (prior to concentration
adjustments) reflect a stress to the most recent appraised value
and equates to a stressed value of $712 psf.

The fourth largest contributor to losses is the North Pointe
Business Park (7.2%), which is secured by a 250,823-sf suburban
office complex located in American Fork, UT. The loan transferred
to special servicing in June 2024 for payment default and
subsequently failed to repay at maturity in July 2024. Occupancy
declined to 76% as of YE 2023 from 100% at June 2023 following the
downsize of the largest tenant, Henry Schein, to 29.0% of the NRA
from 38.5%. Additionally, major tenants, Worldwide Holdings (4.8%),
Fidelity Real Estates Company, LLC (20.7%) and Business
Promotion/DentalQuora (9.9%) vacated at their lease expirations in
2023. The loan maintained a NOI DSCR of 1.40x as of YE 2023.

Fitch's 'Bsf' rating case loss of 30.6% (prior to concentration
adjustments) reflects a 10% cap rate, 20% stress to the YE 2023 NOI
and the loan's defaulted status.

Changes to Credit Enhancement (CE): As of the September 2024
distribution date, the pool's aggregate balance has been reduced by
68.6% to $404.7 million from $1.29 billion at issuance. Of the
non-specially serviced loans, the Stanley Apartments loan is
scheduled to mature in December 2025, the Showcase at Indio loan in
July 2029, and the Jacksonville ICE loan in February 2027.

Interest shortfalls of $8.86 million are affecting classes C and
PEZ and the non-rated classes D, E, F and G. Realized losses of
$16.7 million are affecting class G.

RATING SENSITIVITIES

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

Given the significant pool concentration and adverse selection,
downgrades to the 'AAAsf' rated classes are possible should
performance or property valuations on the specially serviced loans,
particularly State Farm Portfolio and 597 Fifth Avenue, further
deteriorate beyond Fitch's expectations and/or interest shortfalls
affect these classes.

Downgrades to classes rated 'A-sf' and 'BB-sf' are likely with
lower recovery prospects on the two aforementioned specially
serviced loans, as well as 30 Knightsbridge, North Pointe Business
Park, Fremont Moreno 3rd Street Promenade, The Mercantile Building,
Columbia Associates Portfolio, Mattydale Commons, Macneal Medical
Office, Ari Fleet, and Richmond Gill Shopping, and/or should the
non-specially serviced loans, including The Showcase at Indio,
Jacksonville ICE, and Stanley Apartments, not refinance and/or
transfer to special servicing.

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

Upgrades to classes rated 'A-sf' and 'BB-sf' are not expected, but
may be possible with substantial improvements in CE coupled with
significantly better recovery prospects on the loans in special
servicing, including the State Farm Portfolio, 597 Fifth Avenue, 30
Knightsbridge, North Pointe Business Park, Fremont Moreno 3rd
Street Promenade, The Mercantile Building, Columbia Associates
Portfolio, Mattydale Commons, Macneal Medical Office, Ari Fleet,
and Richmond Gill Shopping.

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.


CSAIL 2015-C1: Fitch Lowers Rating on Cl. C Certificates to 'BBsf'
------------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed 12 classes of CSAIL
2015-C1 Commercial Mortgage Trust Pass-through Certificates, series
2015-C1. The Rating Outlooks on affirmed classes A-S and X-A have
been revised to Negative from Stable. Following the downgrade to
class C, the class was assigned a Negative Outlook.

   Entity/Debt          Rating               Prior
   -----------          ------               -----
CSAIL 2015-C1

   A-3 126281AY0    LT AAAsf  Affirmed       AAAsf
   A-4 126281AZ7    LT AAAsf  Affirmed       AAAsf
   A-S 126281BD5    LT AAAsf  Affirmed       AAAsf
   A-SB 126281BA1   LT PIFsf  Paid In Full   AAAsf
   B 126281BE3      LT Asf    Affirmed       Asf
   C 126281BF0      LT BBsf   Downgrade      BBBsf
   D 126281AL8      LT CCCsf  Affirmed       CCCsf
   E 126281AN4      LT Csf    Affirmed       Csf
   F 126281AQ7      LT Csf    Affirmed       Csf
   X-A 126281BB9    LT AAAsf  Affirmed       AAAsf
   X-B 126281BC7    LT Asf    Affirmed       Asf
   X-D 126281AC8    LT CCCsf  Affirmed       CCCsf
   X-E 126281AE4    LT Csf    Affirmed       Csf
   X-F 126281AG9    LT Csf    Affirmed       Csf

KEY RATING DRIVERS

Increased 'Bsf' Loss Expectations; Near-Term Maturity Concentration
and Refinancing Concerns: Fitch's current ratings incorporate a
'Bsf' rating case loss of 11.7%. Fourteen loans (40.7% of the pool)
are flagged as Fitch Loans of Concern (FLOCs), including two
specially serviced loans (16.4%). There are 62 loans remaining in
the pool as of the September 2024 remittance, all of which are
scheduled to mature between October 2024 and March 2025.

Due to the significant near-term loan maturities and increasing
pool concentrations, Fitch performed a sensitivity and liquidation
analysis, which grouped the remaining loans based on their current
status and collateral quality, and then ranked them by their
perceived likelihood of repayment and/or loss expectations.

The downgrade on class C reflects higher pool loss expectations
since Fitch's prior rating action driven by performance
deterioration and refinance concerns on the FLOCs, primarily those
secured by lower-tier regional malls and office properties,
including 500 Fifth Avenue (13.3%), Westfield Trumbull (10.2%),
Westfield Wheaton (5.7%), St. Louis Premium Outlets (3.1%) and
Bayshore Mall (2.7%).

The Negative Outlooks for classes A-S, X-A, B, X-B and C reflect
the elevated concentration of FLOCs and adverse selection concerns
in the pool and were assigned to classes with a reliance on FLOCs
to repay. Without performance stabilization, improved recovery
prospects and/or if more loans than expected fail to refinance at
maturity and/or expected losses increase, further downgrades are
possible.

In the sensitivity and liquidation analysis, Fitch assumed paydown
from the defeased loans (25 loans, 34.1%), as well as loans with a
high likelihood of refinanceability, including those with
sufficient cash flow to refinance into a higher interest rate
environment. Fitch assigned a higher probability of default to
these retail and office FLOCs, 500 Fifth Avenue, Westfield
Trumbull, Westfield Wheaton, St. Louis Premium Outlets, Bayshore
Mall, Overlake Office (0.9%), Six Columbus Center (0.5%) and Rogers
Alley (0.5%), which also contributed to the Negative Outlooks.

Largest Contributors to Loss Expectations: The largest contributor
to overall loss expectations is the Westfield Trumbull loan, which
is secured by a 1.1 million-sf regional mall located in Trumbull,
CT, now called Trumbull Mall. In January 2023, the mall was sold
and the loan assumed by Namdar Realty Group. Anchor tenants include
Target, JCPenney, Macy's and LA Fitness. Lord and Taylor closed in
early 2021 following the retailer's bankruptcy. Macy's extended its
lease through January 2026, from April 2023. Both Macy's and Target
are anchors at a competing mall located 9.5 miles away.

Occupancy has remained relatively stable, and was 91.3% as of July
2024. The servicer-reported NOI DSCR has increased to 2.36x at YE
2023 from 1.69x at YE 2022 and 1.56x at YE 2021. The improvement in
NOI between 2022 and 2023 was mainly due to a large drop in
operating expenses as revenues remained stable over that time
period. However, YE 2023 NOI remains 19.3% below the issuer's
underwritten NOI.

Fitch's 'Bsf' rating case loss (prior to concentration add-ons) is
approximately 45%, which reflects a 15% cap rate to the Fitch cash
flow based off a 15% stress to the YE 2021 NOI given the lack of
certainty regarding the sustainability of the expense decline in
2023. Fitch also increased the probability of default in its
analysis to reflect the heightened maturity default risk. The loan
matures in March 2025.

The second largest contributor to Fitch's overall loss expectations
is the Westfield Wheaton loan, which is secured by a 1.6 million-sf
regional mall sponsored by Unibail-Rodamco-Westfield and located in
Wheaton, MD. Anchor tenants include JCPenney, Target, Macy's and
Costco. There is also a nine-screen AMC Theater and two
ground-leased outparcels leased to Giant Food and American Freight.
There are five other large retail centers located within a 10-mile
radius, with another competing mall owned by the same sponsor,
Westfield Montgomery, located seven miles away with a similar
inline tenant profile.

Per the June 2024 rent roll, occupancy dropped to 91.5% from 96% at
YE 2022. The largest tenant, Target (13.8% of the NRA), extended
its lease that was set to expire in February 2025 through February
2030. YE 2023 NOI decreased 10.5% compared to YE 2022, and remains
15.8% below the issuer's underwritten NOI. The loan has remained
current since issuance, with NOI DSCR reporting at 2.21x as of YE
2023, a decline from 2.47x at YE 2022, 2.95x at YE 2019 and 2.62x
at issuance.

Total mall sales as of TTM September 2023 were $437 psf, which
compares to $389 psf at TTM March 2022, $317 psf at YE 2020, and
$353 psf at YE 2019. Excluding the major anchors and grocer, tenant
sales are approximately $355 psf, compared with $296 psf at TTM
March 2022, $189 psf at YE 2020, and $255 psf at YE 2019.

Fitch's 'Bsf' rating case loss (prior to concentration add-ons) is
approximately 40%, which reflects a 15% cap rate to the Fitch cash
flow based off a 20% stress to the YE 2023 NOI. Fitch increased the
probability of default in its analysis to reflect the elevated
increasing maturity default risks. The loan matures in March 2025.

The third largest contributor to Fitch's overall loss expectations
is the Bayshore Mall, which is secured by a 515,920-sf, one-story
enclosed regional mall in Eureka, CA. The loan was previously in
special servicing, transferring in October 2020 for payment default
and returning to the master servicer in August 2022. The property
continues to experience performance declines since issuance with
collateral occupancy falling to 54.8% as of June 2024 from 66.7% at
YE 2022 and 83% at issuance. The YE 2023 NOI is 17% below YE 2022
NOI and 36.4% below the issuer's NOI at underwriting.

Fitch's 'Bsf' rating case loss (prior to concentration add-ons) is
approximately 49%, which reflects a 25% cap rate given the tertiary
location and lower collateral quality, as well as a 7.5% stress to
the YE 2023 NOI.

The fourth largest contributor to Fitch's overall loss expectations
and largest specially serviced loan is 500 Fifth Avenue, which is
secured by a 727,976-sf urban office property located at the corner
of 42nd Street and Fifth Avenue in Midtown Manhattan, directly
across the street from the New York Public Library and Bryant Park.
The loan transferred to the special servicer in June 2024 for
imminent maturity default, ahead of its October 2024 maturity
date.

As of the June 2024 rent roll, occupancy declined to 81.1% from
85.5% at YE 2023, 89% at YE 2022, and 92.3% at issuance. Upcoming
tenant lease rollover includes 6.5% in 2024, 3.3% in 2025, and 6.5%
in 2026. NOI DSCR remains strong at 3.82x as of YE 2023, compared
with 3.97x as of YE 2022 and 4.16x as of YE 2021.

Fitch's 'Bsf' rating case loss (prior to concentration add-ons) is
9.6%, which reflects a 8.5% cap rate and 10% stress to the YE 2023
NOI. Fitch increased the probability of default in its analysis to
reflect the recent transfer to the special servicer.

Increased Credit Enhancement (CE): As of the September 2024
distribution date, the pool's aggregate balance has been reduced by
37.9%. There are 25 loans (34.1% of the pool) that are fully
defeased. There are 58 loans (70.1% of the pool) that are
amortizing and four loans (29.9%) that are full-term,
interest-only.

Cumulative interest shortfalls of $1.7 million are impacting
non-rated class NR. Realized losses of $32.4 million are impacting
class NR.

RATING SENSITIVITIES

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

Downgrades to classes A-3 and A-4 are unlikely due to the classes'
senior payment priority in the capital structure and expected
paydown from defeased loans and loans with a high likelihood of
refinancing, but could occur if a majority of the remaining
non-defeased loans fail to pay off at their maturity, deal-level
expected losses increase significantly and/or interest shortfalls
occur.

Downgrades to classes A-S and X-A could occur if a higher than
expected proportion of the pool defaults at or prior to maturity,
including larger FLOCs such as Westfield Trumbull, Westfield
Wheaton, and Bayshore Mall, and/or with lower recovery prospects on
the remaining loans in the pool with further performance
deterioration.

Further downgrades to classes B, C and X-B are likely with higher
than expected losses and/or if a greater number of loans fail to
pay off at loan maturity, including the aforementioned larger FLOCs
and other FLOCs within the pool.

Further downgrades to distressed classes would occur should
additional loans transfer to special servicing or as losses on
FLOCs and specially serviced loans are realized and/or become more
certain.

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

Given the pool's upcoming maturity concentration, upgrades are not
expected, but may occur with significant deleveraging due to loan
payoffs, better than expected recoveries on specially serviced
loans and/or higher recovery expectations on the aforementioned
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.


EATON VANCE 2020-2: S&P Assigns BB- (sf) Rating on Cl. E-R2 Debt
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R2, B-1R2,
B-2R2, C-R2, D-1R2, D-2R2, and E-R2 replacement debt from Eaton
Vance CLO 2020-2 Ltd./Eaton Vance CLO 2020-2 LLC, a CLO managed by
Morgan Stanley Eaton Vance CLO Manager LLC that was originally
issued in October 2020 and underwent a refinancing on Dec. 9, 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 following payment in full on the Oct. 3,
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 July 15, 2026.

-- The reinvestment period was extended to Oct. 15, 2029.

-- The legal final maturity dates (for the replacement debt and
the existing subordinated notes) was extended to Oct. 15, 2037.

-- Additional subordinated notes were issued on the Oct. 3, 2024,
refinancing date, bringing the total amount to $48.1 million

-- The required minimum overcollateralization and interest
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

  Eaton Vance CLO 2020-2 Ltd./Eaton Vance CLO 2020-2 LLC

  Class A-R2, $256.0 million: AAA (sf)
  Class B-1R2, $40.0 million: AA (sf)
  Class B-2R2, $8.0 million: AA (sf)
  Class C-R2 (deferrable), $24.0 million: A (sf)
  Class D-1R2 (deferrable), $20.0 million: BBB- (sf)
  Class D-2R2 (deferrable), $4.0 million: BBB- (sf)
  Class E-R2 (deferrable), $15.0 million: BB- (sf)

  Ratings Withdrawn

  Eaton Vance CLO 2020-2 Ltd./Eaton Vance CLO 2020-2 LLC

  Class A-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)'

  Other Debt

  Eaton Vance CLO 2020-2 Ltd./Eaton Vance CLO 2020-2 LLC

  Subordinated notes, $48.1 million: NR

  NR--Not rated.



EFMT 2024-INV2: S&P Assigns B- (sf) Rating on Class B-2 Certs
-------------------------------------------------------------
S&P Global Ratings assigned its ratings to EFMT 2024-INV2's
mortgage pass-through certificates.

The certificate issuance is an RMBS transaction backed by
first-lien, fixed- and adjustable-rate fully amortizing residential
mortgage loans (some with an interest-only period), secured
primarily by single-family residential properties, including
townhomes, planned-unit developments, condominiums, two- to
four-family units, condotels, five- to 10-unit multifamily
residential properties, and manufactured housing to prime and
nonprime borrowers. The pool consists of 962 ATR-exempt residential
mortgage loans backed by 1,148 properties, including 25
cross-collateralized loans backed by 211 properties.

The ratings reflect:

-- The pool's collateral composition;

-- The credit enhancement provided for this transaction;

-- The transaction's associated structural mechanics;

-- The transaction's representation and warranty framework;

-- The mortgage aggregator, Ellington Financial Inc., and the
originators;

-- The potential impact current and near-term macroeconomic
conditions may have on the performance of the mortgage borrowers in
the pool. S&P said, "We recently recalibrated our views on the
trajectory of interest rates in the U.S. and now expect 50 basis
points (bps) of rate cuts this year and another 100 bps next year,
with the balance of risks tilting toward more of those cuts
happening sooner rather than later. Our base-case forecast for U.S.
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 markets, as
demonstrated through general national level home price behavior,
unemployment rates, mortgage performance, and underwriting."

  Ratings Assigned(i)

  EFMT 2024-INV2

  Class A-1, $173,386,000: AAA (sf)
  Class A-2, $24,337,000: AA- (sf)
  Class A-3, $37,874,000: A- (sf)
  Class M-1, $20,737,000: BBB- (sf)
  Class B-1, $14,545,000: BB- (sf)
  Class B-2, $10,657,000: B- (sf)
  Class B-3, $6,480,807: NR
  Class A-IO-S, notional(ii): NR
  Class X, notional(ii): NR
  Class R, N/A: NR

(i)The ratings address the ultimate payment of interest and
principal.
(ii)Notional amount equals the loans' aggregate stated principal
balance as of the cutoff date.
NR--Not rated.
N/A--Not applicable.



ELMWOOD CLO VII: S&P Assigns 'B-(sf)' Rating on Class F-RR Notes
----------------------------------------------------------------
S&P Global Ratings assigned its ratings to the replacement class
A-1-RR, A-2-RR, B-RR, C-RR, D-1-RR, D-2-RR, E-RR, and F-RR debt
from Elmwood CLO VII Ltd./Elmwood CLO VII LLC, a CLO originally
issued in December 2020 and refinanced in October 2023 that is
managed by Elmwood Asset Management LLC.

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 B-RR, C-RR, E-RR, and F-RR debt was
issued at a lower spread over three-month SOFR than the original
debt.

-- The original class A-R debt was replaced by two new
floating-rate classes: A-1-RR and A-2-RR. The class A-1-RR debt
will be senior to the class A-2-RR debt.

-- The original class D-R debt was replaced by two new
floating-rate classes: D-1-RR and D-2-RR. The class D-1-RR debt
will be senior to the class D-2-RR debt.

-- The stated maturity and reinvestment period were extended three
years.

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 notes remain consistent with the credit enhancement
available to support them and take rating actions as we deem
necessary."

  Ratings Assigned

  Elmwood CLO VII Ltd./Elmwood CLO VII LLC

  Class A-1-RR, $310.00 million: AAA (sf)
  Class A-2-RR, $7.50 million: AAA (sf)
  Class B-RR, $62.50 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), $2.50 million: BBB- (sf)
  Class E-RR (deferrable), $16.25 million: BB- (sf)
  Class F-RR (deferrable), $8.75 million: B- (sf)

  Ratings Assigned

  Elmwood CLO VII Ltd./Elmwood CLO VII 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)'
  Class F-R to not rated from 'B- (sf)'

  Other Debt

  Elmwood CLO VII Ltd./Elmwood CLO VII LLC

  Subordinated notes, $39.00 million: Not rated


ELMWOOD CLO XII: S&P Assigns B- (sf) Rating on Class F-R Notes
--------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-L-R, A-R,
B-R, C-R, D-1-R, D-2-R, E-R, and F-R replacement debt from Elmwood
CLO XII Ltd./Elmwood CLO XII LLC, a CLO originally issued in
December 2021 that is managed by Elmwood Asset Management LLC. At
the same time, S&P withdrew their ratings on the original class
A-L, A, B, C, D, E, and F debt following payment in full on the
Oct. 3, 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-L-R, A-R, B-R, C-R, D-1-R, and E-R debt
was issued at a lower spread over three-month SOFR than the
original debt. Class D-2-R was be issued at 4.35% over three-month
SOFR.

-- The current class D debt was replaced by two new classes: D-1-R
and D-2-R.

-- The reinvestment period was extended to Oct. 15, 2029, from
Oct. 20, 2026.

-- The non-call period was extended to Oct. 3, 2026, from Oct. 20,
2023.

-- The stated maturity on the existing subordinated notes was
extended to Oct. 15, 2037, from Jan. 20, 2035, to match the stated
maturity on the replacement 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 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

  Elmwood CLO XII Ltd./Elmwood CLO XII LLC

  Class A-L-R loans(i), $279.0 million: AAA (sf)
  Class A-R, $99.0 million: AAA (sf)
  Class B-R, $78.0 million: AA (sf)
  Class C-R (deferrable), $36.0 million: A (sf)
  Class D-1-R (deferrable), $36.0 million: BBB- (sf)
  Class D-2-R (deferrable), $2.4 million: BBB- (sf)
  Class E-R (deferrable), $19.8 million: BB- (sf)
  Class F-R (deferrable), $10.8 million: B- (sf)

  Ratings Withdrawn

  Elmwood CLO XII Ltd./Elmwood CLO XII LLC

  Class A-L to NR from 'AAA (sf)'
  Class A 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)'
  Class F to NR from 'B- (sf)'

  Other Debt

  Elmwood CLO XII Ltd./Elmwood CLO XII LLC

  Subordinated notes, $47.0 million: NR

(i)All or a portion of the class A-L-R loans may be converted into
class A-R debt, subject to a maximum conversion of $279.0 million.
Upon a conversion, the balance on the class A-R debt may be
increased and the balance of the class A-L-R loans may be
decreased. No portion of the class A-R debt may be converted into
class A-L-R loans.
NR--Not rated.



EXETER AUTOMOBILE 2024-5: Fitch Assigns BB-sf Rating on Cl. E Notes
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to
Exeter Automobile Receivables Trust (EART) 2024-5.

   Entity/Debt          Rating             Prior
   -----------          ------             -----
Exeter Automobile
Receivables
Trust 2024-5

   A-1              ST  F1+sf   New Rating   F1+(EXP)sf
   A-2              LT  AAAsf   New Rating   AAA(EXP)sf
   A-3              LT  AAAsf   New Rating   AAA(EXP)sf
   B                LT  AAsf    New Rating   AA(EXP)sf
   C                LT  Asf     New Rating   A(EXP)sf
   D                LT  BBBsf   New Rating   BBB(EXP)sf
   E                LT  BB-sf   New Rating   BB-(EXP)sf

KEY RATING DRIVERS

Collateral Performance — Subprime Credit Quality: EART 2024-5 is
backed by collateral with subprime credit attributes; however, it
exhibits some improvements in credit attributes when compared to
the prior Fitch-rated series, 2024-2. The weighted average (WA)
FICO score is 582, up from 572 for 2024-2. Additionally, 8.85% of
the pool is backed by new vehicles, up from 2.41% in 2024-2. Other
credit metrics, such as the WA loan-to-value (LTV) ratio of 116.47%
and the WA annual percentage rate (APR) of 21.62%, are generally
consistent with prior Exeter transactions.

Forward-Looking Approach to Derive Rating Case Proxy: Fitch
considered economic conditions and future expectations by assessing
key macroeconomic and wholesale market conditions to derive the
series loss proxy. Fitch maintained the vintage ranges to derive
the rating case loss proxy for 2024-5 with those for 2024-2, in
recognition of continued weak performance for the 2022 and 2023
securitizations. Fitch utilized 2006-2008 data from Santander
Consumer — as proxy recessionary static-managed portfolio data
— and 2015-2017 vintage data from Exeter to arrive at a
forward-looking rating case cumulative net loss (CNL) proxy of
21.50% compared with 22.00% in 2024-2.

Payment Structure — Sufficient Credit Enhancement: Initial hard
credit enhancement (CE) levels are 60.95%, 45.00%, 31.35%, 17.65%,
and 6.65% for classes A, B, C, D and E, respectively. These CE
levels are lower than 2024-2 but in line with prior transactions.
Excess spread is expected to be 13.24%, up from 13.10% per annum in
2024-2. Loss coverage for each class of notes is sufficient to
cover the respective multiples of Fitch's rating case CNL proxy of
21.50%.

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

Fitch's base-case loss expectation, which does not include a margin
of safety and is not used in Fitch's quantitative analysis to
assign ratings, is 20.00%, based on its Global Economic Outlook and
transaction-based forecast loss projections.

RATING SENSITIVITIES

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

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

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

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

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

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

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 comparing or recomputing certain
information with respect to 150 loans from the statistical data
file Fitch considered this information in its analysis and it did
not have an effect on Fitch's analysis or conclusions.

ESG Considerations

The concentration of electric and hybrid vehicles in the pool is
low and did not have an impact on Fitch's ratings analysis or
conclusion on this transaction and has no impact on Fitch's ESG
Relevance Score.

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.


FORTRESS CREDIT XIX:S&P Assigns Prelim BB-(sf) Rating on E-R Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1R-R, A-L-1R, A-L-2R, A-1T-R, B-R, C-R, D-R, and E-R replacement
debt from Fortress Credit Opportunities XIX CLO LLC, a CLO managed
by FCOD CLO Management LLC that was originally issued in September
2022.

The preliminary ratings are based on information as of Oct. 9,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 15, 2024, refinancing date, the proceeds from the
replacement debt will be used to redeem the September 2022 debt.
S&P said, "At that time, we expect to withdraw our ratings on the
September 2022 debt and assign ratings to the replacement debt.
However, if the refinancing doesn't occur, we may affirm our
ratings on the September 2022 debt and 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 replacement class A-1R-R, A-L-1R, A-L-2R, A-1T-R, B-R, C-R,
D-R, and E-R debt is expected to be issued at lower spreads over
three-month CME term SOFR than the original debt.

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

-- The reinvestment period will be extended to Oct. 15, 2028.

-- The legal final maturity dates (for the replacement debt and
the existing subordinated notes) will be extended to Oct. 15,
2036.

-- The target initial par amount will remain $400 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.

-- No additional subordinated notes will be 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."

  Preliminary Ratings Assigned

  Fortress Credit Opportunities XIX CLO LLC

  Class A-1R-R, $65.00 million: AAA (sf)
  Class A-L-1R, $33.00 million: AAA (sf)
  Class A-L-2R, $68.00 million: AAA (sf)
  Class A-1T-R, $50.00 million: AAA (sf)
  Class B-R, $32.00 million: AA (sf)
  Class C-R (deferrable), $32.00 million: A (sf)
  Class D-R (deferrable), $28.00 million: BBB- (sf)
  Class E-R (deferrable), $24.00 million: BB- (sf)
  
  Other Debt

  Fortress Credit Opportunities XIX CLO LLC

  Subordinated notes, $64.78 million: Not rated



FS RIALTO 2024-FL9: Fitch Assigns 'B-(EXP)' Rating on Three Classes
-------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
FS Rialto 2024-FL9 Issuer, LLC as follows:

- $480,759,000c class A 'AAAsf'; Outlook Stable;

- $120,190,000c class A-S 'AAAsf'; Outlook Stable;

- $57,948,000c class B 'AA-sf'; Outlook Stable;

- $45,072,000c class C 'A-sf'; Outlook Stable;

- $28,974,000c class D 'BBBsf'; Outlook Stable;

- $13,951,000c class E 'BBB-sf'; Outlook Stable;

- $30,047,000ad class F 'BB-sf'; Outlook Stable;

- $0ad class F-E 'BB-sf'; Outlook Stable;

- $0abd class F-X 'BB-sf'; Outlook Stable;

- $20,389,000ad class G 'B-sf'; Outlook Stable;

- $0ad class G-E 'B-sf'; Outlook Stable;

- $0abd class G-X 'B-sf'; Outlook Stable.

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

- $61,169,007d class H.

(a) Exchangeable Notes. The class F and class G notes are
exchangeable notes. Each class of exchangeable notes may be
exchanged for the corresponding classes of exchangeable notes, 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.

(b) Notional amount and interest only (IO).

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

(d) Horizontal risk retention interest, estimated to be 13.000% of
the notional amount of the notes.

The approximate collateral interest balance as of the cutoff date
is $858,499,007 and does not include future funding.

The expected ratings are based on information provided by the
issuer as of Sept. 27, 2024.

Transaction Summary

The notes represent the beneficial ownership interest in the trust,
primary assets of which are 17 loans secured by 62 commercial
properties having an aggregate principal balance of $858,499,007 as
of the cut-off date. The loans were contributed to the trust by FS
CREIT Finance Holdings LLC, a wholly-owned subsidiary of FS Credit
REIT.

The servicer is expected to be Situs Asset Management LLC, and the
special servicer is expected to be Rialto Capital Advisors, LLC.
The trustee is expected to be Wilmington Trust, National
Association, and the note administrator is expected to be
Computershare Trust Company, N.A. The notes are expected to follow
a sequential paydown structure.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 65.4% of the loans by
balance, and cash flow analysis and asset summary reviews on 100%
of the pool.

KEY RATING DRIVERS

Fitch Net Cash Flow: Fitch performed a detailed cash flow analysis
on all loans in the pool. Fitch's resulting aggregate net cash flow
(NCF) of $57.6 million represents an 11.57% decline from the
issuer's aggregate underwritten NCF of $65.2 million, excluding
loans for which Fitch utilized an alternate value analysis.
Aggregate cash flows include only the pro-rated trust portion of
any pari passu loan.

Lower Leverage: The pool has lower leverage compared to recent CRE
CLO transactions rated by Fitch. The pool's Fitch loan-to-value
(LTV) ratio of 122.4% is better than both the 2024 YTD and 2023 CRE
CLO averages of 143.9% and 171.2%, respectively. The pool's Fitch
NCF debt yield (DY) of 7.6% is better than both the 2024 YTD and
2023 CRE CLO averages of 6.3% and 5.6%, respectively.

Average Pool Concentration: The pool concentration is in line with
recently rated Fitch CRE CLO transactions. The top 10 loans make up
73.7% of the pool, which is higher than both the 2024 YTD CRE CLO
average of 70.6%, and the 2023 CRE CLO average of 62.5%. 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 17.9. Fitch views diversity as a
key mitigant to idiosyncratic risk. Fitch raises the overall loss
for pools with effective loan counts below 40.

No Amortization: The pool 100% comprises IO loans. This is worse
than both the 2024 YTD and 2023 CRE CLO averages of 55.2% and
35.3%, respectively, based on fully extended loan terms. As a
result, the pool is expected to have zero principal paydown by
maturity of the loans. By comparison, the average scheduled
paydowns for Fitch-rated U.S. CRE CLO transactions during 2024 YTD
and 2023 were 0.6% and 1.7%, respectively.

Seasoned Loans: The pool contains more seasoned loans than recently
rated Fitch CRE CLO transactions. The pool's WA seasoning of 16.0
months is higher than both the 2024 YTD and 2023 CRE CLO averages
of 8.9 months and 9.8 months, respectively.

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

- 10% NCF Decline: 'AAAsf' / 'AAsf' / 'Asf' / 'BBBsf' / 'BB+sf' /
'BBsf' / 'Bsf' / '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' / AAAsf' / 'AA-sf' / 'A-sf' / 'BBBsf' /
'BBB-sf' / 'BB-sf' / 'B-sf';

- 10% NCF Increase: 'AAAsf' / 'AAAsf' / 'AAsf' / 'Asf' / 'BBB+sf' /
'BBBsf' / 'BBsf' / 'Bsf'.

SUMMARY OF FINANCIAL ADJUSTMENTS

Cash Flow Modeling

This transaction utilizes note protection tests to provide
additional credit enhancement (CE) to the investment-grade
noteholders, if needed. The note protection tests comprise an
interest coverage test and a par value test at the 'BBB-' level
(class E) in the capital structure. Should either of these metrics
fall below a minimum requirement then interest payments to the
retained notes are diverted to pay down the senior most notes. This
diversion of interest payments continues until the note protection
tests are back above their minimums.

As a result of this structural feature, Fitch's analysis of the
transaction included an evaluation of the liabilities structure
under different stress scenarios. To undertake this evaluation,
Fitch used the cash flow modeling referenced in the Fitch criteria
"U.S. and Canadian Multiborrower CMBS Rating Criteria". Different
scenarios were run where asset default timing distributions and
recovery timing assumptions were stressed.

Key inputs, including Rating Default Rate (RDR) and Rating Recovery
Rate (RRR), were based on the CMBS multiborrower model output in
combination with CMBS analytical insight. The cash flow modeling
results showed that the default rates in the stressed scenarios did
not exceed the available CE in any stressed scenario.

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 PricewaterhouseCoopers 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.


GALAXY XXII CLO: 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 from Galaxy XXII CLO
Ltd./Galaxy XXII CLO LLC, a CLO originally issued in July 2016 that
is managed by PineBridge Investments LLC. At the same time, S&P
withdrew its ratings on the class A-RR, B-RR, C-RR, D-RR and E-RR
debt following payment in full on the Oct. 3, 2024, refinancing
date. S&P also affirmed its rating on the class X-RR and F-RR
notes, 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, references to European risk retention were
removed; the non-call period for the replacement debt was set to
Oct. 3, 2025.

Replacement And Original Debt Issuances

Replacement debt

-- Class A-RRR, $243.80 million: Three-month CME term SOFR +
1.24%

-- Class B-RRR, $45.70 million: Three-month CME term SOFR + 1.65%

-- Class C-RRR (deferrable), $22.90 million: Three-month CME term
SOFR + 2.10%

-- Class D-RRR (deferrable), $22.90 million: Three-month CME term
SOFR + 3.25%

-- Class E-RRR (deferrable), $13.80 million: Three-month CME term
SOFR + 6.75%


Original debt

-- Class A-RR, $243.80 million: Three-month CME term SOFR + 1.20%
+ CSA(i)

-- Class B-RR, $45.70 million: Three-month CME term SOFR + 1.70% +
CSA(i)

-- Class C-RR (deferrable), $22.90 million: Three-month CME term
SOFR + 2.15% + CSA(i)

-- Class D-RR (deferrable), $22.90 million: Three-month CME term
SOFR + 3.35% + CSA(i)

-- Class E-RR (deferrable), $13.80 million: Three-month CME term
SOFR + 6.50% + 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

  Galaxy XXII CLO Ltd./Galaxy XXII CLO LLC

  Class A-RRR, $243.80 million: AAA (sf)
  Class B-RRR, $45.70 million: AA (sf)
  Class C-RRR (deferrable), $22.90 million: A (sf)
  Class D-RRR (deferrable), $22.90 million: BBB- (sf)
  Class E-RRR (deferrable), $13.80 million: BB- (sf)

  Ratings Withdrawn

  Galaxy XXII CLO Ltd./Galaxy XXII CLO LLC

  Class A-RR to not rated from 'AAA (sf)'
  Class B-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)'

  Rating Affirmed

  Galaxy XXII CLO Ltd./Galaxy XXII CLO LLC

  Class X-RR: AAA (sf)
  Class F-RR: B- (sf)

  Other Debt

  Galaxy XXII CLO Ltd./Galaxy XXII CLO LLC

  Subordinated notes, $28.00 million: Not rated



GENERATE CLO 6: S&P Assigns BB- (sf) Rating on Class E-R2 Notes
---------------------------------------------------------------
S&P Global Ratings assigned its ratings to the class A-R2, B-R2,
C-R2, D-1R2, D-2R2, and E-R2 replacement debt and new class X debt
from Generate CLO 6 Ltd./Generate CLO 6 LLC, a CLO originally
issued in 2019 that is managed by Generate Advisors LLC, a
subsidiary of Kennedy Lewis Investment Management LLC and was not
rated by S&P Global Ratings.

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

  Generate CLO 6 Ltd./Generate CLO 6 LLC

  Class X, $1.5 million: AAA (sf)
  Class A-R2, $252.0 million: AAA (sf)
  Class B-R2, $52.0 million: AA (sf)
  Class C-R2 (deferrable), $24.0 million: A (sf)
  Class D-1R2 (deferrable), $20.0 million: BBB (sf)
  Class D-2R2 (deferrable), $7.0 million: BBB- (sf)
  Class E-R2 (deferrable), $12.0 million: BB- (sf)

  Other Debt

  Generate CLO 6 Ltd./Generate CLO 6 LLC

  Subordinated notes, $37.0 million: Not rated



GOODLEAP SUSTAINABLE 2023-2: Fitch Rates Class C Debt 'BBsf'
------------------------------------------------------------
Fitch Ratings has affirmed the ratings on three classes of GoodLeap
Sustainable Home Solutions Trust 2023-2 (GoodLeap 2023-2) Solar ABS
transaction following a revised modelling of interest deferrals.
The Rating Outlooks for classes B and C remain Negative, reflecting
their vulnerability to the effects of lower prepayment rates and
increasing default rates.

   Entity/Debt             Rating           Prior
   -----------             ------           -----
GoodLeap Sustainable
Home Solutions
Trust 2023-2

   A 38237AAA0         LT A-sf  Affirmed    A-sf
   B 38237AAB8         LT BBBsf Affirmed    BBBsf
   C 38237AAC6         LT BBsf  Affirmed    BBsf

Transaction Summary

GoodLeap 2023-2 is a securitization of consumer loans backed by
residential solar equipment. Loans are originated by GoodLeap
(formerly known as Loanpal), a frequent securitization sponsor and
currently one of the largest specialized solar lenders by
originations in the U.S. They started advancing solar loans in
December 2017 (although the company already existed as a mortgage
lender).

KEY RATING DRIVERS

Error Correction: When last modelling the transaction, Fitch did
not assume that interest accrues on deferred interest. As a result
of the error, the Model-Implied Ratings (MIR) were overstated.
Modelling interest accrual on deferred interest negatively affected
the MIRs for all classes of notes. The impact was largest on the
class B notes and increased the MIR deviation by one notch.

While this error affects the MIRs, Negative Outlooks are still
appropriate for classes B and C. It adequately captures its view of
the transaction's current performance and expectations for future
performance as well as the notes' heightened vulnerability to
changing prepayment rates and increasing default rates. Fitch has
affirmed the ratings on all of the notes. The Rating Outlooks on
classes B and C remain Negative. The Rating Outlook on class A is
Stable.

Low Prepayments Exacerbate Negative Excess Spread: GoodLeap 2023-2
has had the lowest average prepayment levels when compared with
other GoodLeap transactions rated by Fitch and has underperformed
the assumptions Fitch set at closing. This exacerbates the effect
of the transaction's substantial negative excess spread (-2.00% of
stated principal balance, using Fitch's 0.7% Bsf servicing fee),
which is the most negative among Fitch-rated GoodLeap transactions.
Fitch anticipates prepayment rates will rise in the near term,
mostly due to housing turnover stimulated by monetary policy
easing. Given the portfolio's 2.54% weighted average interest
rates, monetary policy would need to be more aggressively eased
than Fitch views as likely to incentivize prepayments other than
from borrowers moving.

Prepayment Sensitivity, CE Drive Outlook: The Negative Outlook on
classes B and C reflect their vulnerability to the effects of lower
prepayment rates. Ratings on the B and C notes are sensitive to
changes in prepayments, as they extend or shorten the amortization
period and thus the amount required to cover the transaction's
negative excess spread. The B and C's subordination means negative
excess spread negatively affects them first. Defaults and
prepayments also increased the difference between target
overcollateralization (OC) and current OC on all notes, shutting
off B and C notes from principal distributions. Amortizing only the
A notes, which have the lowest coupon, increases the weighted
average coupon on the notes and further exacerbates the negative
excess spread.

Defaults, Recoveries Close to Expectations: Default and recovery
performance of the portfolio has been mostly in line with Fitch's
expectations. At last review, Fitch brought the assumptions in line
with FICO-based assumptions as set for the last Fitch-rated
GoodLeap transaction (GoodLeap 2024-1). As only one month has
passed since last review, Fitch did not change its assumptions. The
base case default rate assumption (9.1% weighted average) and
default rate multiples (3.0x weighted average at Asf) updated at
last review reflected additional FICO-based performance data. Low
recovery observations, as of September 2024, are consistent with
the low seasoning of the transaction and the typically long
recovery for solar loans and the additional month of data did not
change Fitch's view on the transaction's recovery performance.
Fitch therefore maintained a base case recovery assumption of 25%,
an 'Asf' recovery haircut of 36% and a recovery lag assumption of
48 months.

Trigger Breach Protects Senior and Junior Notes: The notes
initially amortize based on target OC percentages. Should the asset
performance deteriorate: first, additional principal will be paid
to cover any defaulted amounts; and, second, if the cumulative loss
trigger is breached, the payment waterfall will switch to "turbo"
sequential to the senior class, also subordinating interest on all
junior notes to the most senior note's principal. This mostly
protects the A notes, but curing the trigger can also negatively
affect the B and C notes. In the tail of some of Fitch's stress
scenarios, the CNL trigger is cured, maintaining C interest senior
to B principal. This can be negative for the B notes, as funds
could be used to pay C interest instead of B principal, but this
could be offset through quicker repayment of the notes from a
modest increase in prepayments.

No Further Investment-Tax Credit (ITC) Attainment Assumed: Since
note amortization relies on the adjusted principal balance, Fitch
calculated a vector for modelling representing the ratio between
stated and adjusted principal balances over time, accounting for
retained interest. Assuming no borrowers awaiting re-amortization
make the expected prepayment, all loans re-amortize. Yield
supplement OC is based on the next monthly installment, and so it
rises when a borrower misses the expected prepayment at
re-amortization, reducing OC calculated on the adjusted principal
balance. Fitch has factored this impact into the rating decisions
for each note.

RATING SENSITIVITIES

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

- Asset performance worsening, or sustained low prepayments without
expectation of future increases may put pressure on the ratings;

- Material changes in policy support, the economics of purchasing
and financing photovoltaic panels and batteries, and/or
ground-breaking technological advances that make the existing
equipment obsolete may also affect the ratings negatively.

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

Fitch currently caps this transaction's ratings in the 'Asf'
category due to limited performance history, while the assigned
'A-sf' rating is further constrained by the level of CE. As a
result, a positive rating action could result from an increase of
CE due to deleveraging, underpinned by low defaults.

CRITERIA VARIATION

This analysis includes a criteria variation due to MIR variations
in excess of the limit stated in the consumer ABS criteria report
for surveillance. According to the criteria, the committee can
decide to deviate from the MIRs but, if the MIR variation is
greater than three notches, this will be a criteria variation. The
MIR variation for class B is greater than three notches. The MIR is
materially sensitive to prepayment assumptions, meaning a limited
increase could materially increase the MIR. Given its expectation
of rising prepayments, Fitch deviated from the MIRs to affirm the
ratings and avoid ratings volatility.

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 historical information available for this originator was
limited in that originations began less than seven years ago, while
the loan tenure can be as long as 25 years. Fitch applied a rating
cap at the 'Asf' category to address this limitation. The
amortizing nature of the assets and the application of an annual
default rate to the static portfolio allowed us to determine
lifetime default assumptions.

Fitch also considered proxy data from other originators and
borrower characteristics (including demographics and relatively
high FICO scores) to derive asset assumptions, as envisaged under
the Consumer ABS Rating Criteria. Taking into account this
analytical approach, the rating committee considered the available
data sufficient to support a rating in the 'Asf' category.

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.


GS MORTGAGE 2014-GC26: Fitch Lowers Rating on Two Tranches to BBsf
------------------------------------------------------------------
Fitch Ratings has downgraded four classes and affirmed three
classes of GS Mortgage Securities Trust Series 2014-GC26 commercial
mortgage pass-through certificates (GSMS 2014-GC26). Following
their downgrades, Fitch has assigned Negative Rating Outlooks to
four classes. The Outlooks for two of the affirmed classes were
revised to Negative from Stable.

Fitch has also downgraded four classes and affirmed three classes
of Citigroup Commercial Mortgage Trust commercial mortgage
pass-through certificates series 2014-GC25 (CGCMT 2014-GC25).
Following their downgrades, Fitch has assigned Negative Outlooks to
four classes.

   Entity/Debt          Rating               Prior
   -----------          ------               -----
GSMS 2014-GC26

   A-4 36250HAD5    LT PIFsf  Paid In Full   AAAsf
   A-5 36250HAE3    LT AAAsf  Affirmed       AAAsf
   A-AB 36250HAF0   LT PIFsf  Paid In Full   AAAsf
   A-S 36250HAJ2    LT AAAsf  Affirmed       AAAsf
   B 36250HAK9      LT Asf    Downgrade      AA-sf
   C 36250HAM5      LT BBsf   Downgrade      Asf
   PEZ 36250HAL7    LT BBsf   Downgrade      Asf
   X-A 36250HAG8    LT AAAsf  Affirmed       AAAsf
   X-B 36250HAH6    LT Asf    Downgrade      AA-sf

CGCMT 2014-GC25

   A-3 17322YAC4    LT PIFsf  Paid In Full   AAAsf
   A-4 17322YAD2    LT AAAsf  Affirmed       AAAsf
   A-AB 17322YAE0   LT PIFsf  Paid In Full   AAAsf
   A-S 17322YAF7    LT AAAsf  Affirmed       AAAsf
   B 17322YAG5      LT Asf    Downgrade      AA-sf
   C 17322YAH3      LT BBsf   Downgrade      A-sf
   PEZ 17322YAL4    LT BBsf   Downgrade      A-sf
   X-A 17322YAJ9    LT AAAsf  Affirmed       AAAsf
   X-B 17322YAK6    LT Asf    Downgrade      AA-sf

KEY RATING DRIVERS

Increased 'Bsf' Loss Expectations; Adverse Selection: Deal-level
'Bsf' rating case loss has increased to 23.1% in GSMS 2014-GC26 and
26.1% in CGCMT 2014-GC25. The GSMS 2014-GC26 transaction has 12
Fitch Loans of Concern (FLOCs; 58.5% of the pool), including three
loans (20.0%) in special servicing. The CGCMT 2014-GC25 transaction
has nine FLOCs (73.8%), including four loans (53.9%) in special
servicing.

Due to the remaining loan maturities scheduled by YE24 and
increasing concentration and adverse selection in these pools,
Fitch conducted a look-through analysis that grouped the loans
based on their current status and collateral quality, and then
ranked them by their perceived likelihood of repayment and/or loss
expectation.

The downgrades in both transactions reflect adverse selection of
the remaining loans and increased pool loss expectations since
Fitch's prior rating action. In GSMS 2014-GC26, the increased
losses are primarily driven by continued performance deterioration
of the two largest office FLOCs, 1201 North Market Street (13.9% of
the pool) and 5599 San Felipe (13.6%), along with sustained high
loss expectations on the REO Queen Ka'ahumanu Center asset (15.1%).
In CGCMT 2014-GC23, they are primarily driven by the declining
performance and poor submarket fundamentals of the three largest
office FLOCs, Bank of America Plaza (38.3%), The Pinnacle at
Bishop's Woods (9.7%) and Stamford Plaza Portfolio (9.6%).

The Negative Outlooks in both transactions reflect the high
concentration of FLOCs and these classes' reliance on recoveries
from these FLOCs to repay. Further downgrades to classes with
Negative Outlooks are likely should performance of the
aforementioned office FLOCs deteriorate and/or recovery prospects
on the specially serviced loans/assets worsen. Additionally, office
concentration is high, comprising 43% of GSMS 2014-GC26 and 60% of
CGCMT 2014-GC23.

FLOCs and Largest Loss Contributors: The largest increase to loss
expectations since the prior rating action in GSMS 2014-GC26 is the
5599 San Felipe loan, secured by a 450,508-sf, 20-story office
building located in the Galleria District of Houston, TX.

The largest tenant, Schlumberger Technology Corporation (69.7% of
NRA through July 2027), is a creditworthy tenant and has been at
the property since 1994. The remainder of the rent roll is
granular, with the second largest tenant, Hibernia Resources IV
(lease expiry in January 2027), representing 2.4% of the NRA.

As of the March 2024 rent roll, the property was 94.0% occupied,
compared to 89.7% in June 2021 and 96.3% in March 2020. Upcoming
rollover includes 1.5% of the NRA in 2024 and 4.0% in 2025. The
servicer-reported NOI DSCR was 1.59x at YE 2023, compared to 1.43x
at YE 2022, 1.00x at YE 2021 and 1.11x at YE 2020. According to
Costar, the Galleria/Uptown office submarket reported a vacancy
rate of 32.5%.

Fitch's 'Bsf' rating case loss of 22.8% (prior to concentration
add-ons) reflects a 9.5% cap rate, 5% stress to the YE 2023 NOI,
and factors an elevated probability of default given the
deteriorating office sector outlook, weakened submarket
fundamentals and anticipated refinance concerns. The loan has an
upcoming November 2024 maturity date.

The second largest increase to loss expectations since the prior
rating action in GSMS 2014-GC26 is the 1201 North Market Street
loan, secured by a 23-story office tower and data colocation center
located in the Wilmington, DE CBD. The 447,439-sf building is the
tallest in Wilmington and home to a number of law firms, financial
services and technology companies.

Major tenants at the property include Morris Nichols Arsht &
Tunnell (18.5% of NRA through December 2028), DaSTOR Wilmington
(7.7%; December 2037), The Siegfried Group (6.7%; October 2028) and
Maron Marvel Bradley (4.6%; May 2033).

As of YE 2023, the property was 71% occupied, compared to 73% at YE
2022, 77% at YE 2021 and 78% at YE 2020. The servicer-reported NOI
DSCR was 1.15x at YE 2023, compared to 1.14x at YE 2022, 1.16x at
YE 2021 and 1.20x at YE 2020.

Per the servicer, the borrower is reportedly in early discussions
with a major tenant to potentially lease 100,000 sf (approximately
22% of NRA). Additionally, at the request of the borrower, the loan
has been transferred to the special servicer to discuss a potential
modification ahead of the November 2024 loan maturity.

Fitch's 'Bsf' rating case loss of 24.9% (prior to concentration
add-ons) reflects a 9.5% cap rate, 10% stress to the YE 2023 NOI,
and factors an elevated probability of default given the
deteriorating office sector outlook, sustained weak DSCR and lower
occupancy, as well as anticipated refinance concerns.

The largest contributor to overall loss expectations in GSMS
2014-GC26 is the REO Queen Ka'ahumanu Center asset, a 570,904-sf
open-air regional mall located in Kahului, HI. The loan transferred
to special servicing in June 2020 for imminent default and the
asset became REO in June 2022. According to the servicer, the
property is not listed for sale as discussions remain ongoing about
a potential redevelopment of the asset.

The subject mall is anchored by a Macy's Men's, Children's and Home
(14.5% of NRA through November 2034) and a Macy's (14.0%; October
2034). Sears (13.6%) closed in 2021. The mall had a six-screen
movie theater, Consolidated Theatres Ka'ahumanu 6, (4.9%), which
closed in July 2023. At YE 2023, the mall was 79% occupied, with
4.5% of the NRA listed as temporary or on a month-to-month lease,
and another 4.3% of the NRA having lease expirations prior to YE
2024.

Fitch's 'Bsf' rating case loss of 80.1% (prior to concentration
add-ons) considers a haircut to the most recent appraisal value,
reflecting a stressed value of approximately $53 psf. Fitch's loss
expectation also considers the higher exposure of $94.5 million,
compared to the outstanding loan amount of $81.3 million.

The largest contributor to overall loss expectations and largest
increase in loss since the prior rating action in CGCMT 2014-GC25
(and the fourth largest contributor to overall loss expectations in
GSMS 2014-GC26) is the Bank of America Plaza loan, secured by a 1.4
million-sf, LEED Gold certified, office building located in
downtown Los Angeles, CA. Major tenants include Capital Group
Companies (26.6% of the NRA through February 2033), Bank of America
(14.7%; June 2029) and Sheppard, Mullin & Richter (12.8%; December
2024). Prior tenant Alston & Bird (5.6%) vacated at lease
expiration in December 2023. The loan transferred to special
servicing in July 2024 for imminent maturity default ahead of its
scheduled September 2024 maturity date.

As of the YE 2023 rent roll, the property was 86.2% occupied with
an interest-only NOI DSCR of 2.42x. Upcoming rollover consists of
approximately 15% of the NRA in 2024, inclusive of Sheppard, Mullin
& Richter, which is expected to vacate at its December 2024
maturity. Following this tenant's departure, occupancy will drop to
an estimated 73%. According to CoStar, the subject is located in
the Downtown Los Angeles office submarket, which has a reported
vacancy rate of 20.8%.

Fitch's 'Bsf' rating case loss of 28.1% (prior to concentration
add-ons) is based on a 9.0% cap rate, 30% stress to the YE 2023 NOI
and factors in the loan's specially serviced status to reflect the
expected drop in occupancy and weakened submarket fundamentals.

The second largest contributor to overall loss expectations and
second largest increase in loss since the prior rating action in
CGCMT 2014-GC25 is The Pinnacle at Bishop's Woods loan, secured by
a three-building 247,433-sf suburban office portfolio located in
Brookfield, WI. The loan transferred to special servicing in March
2022 due to imminent monetary default after the borrower was no
longer willing to support the asset. An appointed receiver is
focused on marketing space for lease in order to stabilize
performance.

The largest tenants include Pentair Residential Filtration, LLC
(17.9% of the NRA through October 2024), Travelers Indemnity
Company (11.1%; October 2026), Dewitt Ross & Stevens (10.1%; July
2030), and Windstream (5.0%; May 2025). As of YE 2023, the property
was 59% occupied, down from 66% in May 2022, 67% at YE 2021, and
76% at YE 2020.

Fitch's expected loss of 52.4% considers a haircut to a recent
appraisal value, reflecting a stressed value of approximately $68
psf.

The third contributor to overall loss expectations in CGCMT
2014-GC25 is the Stamford Plaza Portfolio loan, secured by four
office properties totaling 982,483-sf located in Stamford, CT. The
loan transferred to special servicing in August 2024 for maturity
default.

Occupancy was 69% as of YE 2023, compared with 65.2% at YE 2022,
63% at YE 2021, 82% at YE 2018 and 90% at issuance. Major tenants
include Icon International (6.2% of NRA through December 2029),
Indeed (4.8%; expired July 2024 with no leasing update) and LOXO
(4.7%; February 2028). Due to the occupancy decline, the
servicer-reported NOI DSCR has remained below 1.0x since YE 2018.
According to CoStar, the subject is located in the Stamford office
submarket, which reported a vacancy rate of 26.1% and average
asking rents of approximately $40 psf.

Fitch's 'Bsf' rating case loss of 35.2% (prior to concentration
add-ons) reflects a 10.0% cap rate and 15% stress to the YE 2023
NOI given continued depressed performance, weak submarket
fundamentals and the defaulted loan status.

Increased Credit Enhancement (CE): As of the September 2024
distribution date, the pool's aggregate balance in GSMS 2014-GC26
has been reduced by 57.1% to $538.1 million from $1.26 billion at
issuance. Since issuance, 53 loans have been repaid or disposed,
with realized losses of $17.4 million affecting the non-rated class
H. Ten loans (12.1%) have been fully defeased. Three loans,
representing 18.2% of the pool, are full-term interest-only (IO)
and the remaining 81.8% of the pool is amortizing.

As of the September 2024 distribution date, the pool's aggregate
balance in CGCMT 2014-GC25 has been reduced by 65.9% to $287.0
million from $842.0 million at issuance. Since issuance, 45 loans
have been repaid or disposed, with realized losses of $12,994
affecting the non-rated class G. Seven loans (20.8%) have been
fully defeased. One loan, representing 38.3% of the pool, is
full-term IO and the remaining 61.7% of the pool is amortizing.

RATING SENSITIVITIES

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

- Downgrades to senior 'AAAsf' rated classes are not considered
likely due to the position in the capital structure, increasing CE
and continued paydown from expected loan payoffs, but may occur
should interest shortfalls affect these classes.

- Downgrades to the junior 'AAAsf' rated classes with a Negative
Outlook and 'Asf' rated classes could occur if deal-level losses
increase significantly from further declines in performance on the
large office and retail FLOCs, including Queen Ka'ahumanu Center,
1201 North Market Street and 5599 San Felipe in GSMS 2014-GC26, and
Bank of America Plaza, The Pinnacle at Bishop's Woods and Stamford
Plaza Portfolio in CGCMT 2014-GC25.

- Downgrades to the 'BBsf' rated classes are likely with lower
recovery prospects and higher certainty of losses on the FLOCs,
including loans/assets in special servicing.

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

- Upgrades to the 'Asf' rated classes are not anticipated given
pool adverse selection, but may be possible with significantly
increased CE from paydowns, coupled with stable to improved
pool-level loss expectations and performance stabilization of the
FLOCs, mainly the Queen Ka'ahumanu Center, 1201 North Market Street
and 5599 San Felipe in GSMS 2014-GC26, and Bank of America Plaza,
The Pinnacle at Bishop's Woods, and Stamford Plaza Portfolio in
CGCMT 2014-GC25.

- Upgrades to the 'BBsf' 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
were likelihood for interest shortfalls.

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.


GS MORTGAGE 2018-RIVR: S&P Discontinues 'D (sf)' Rating on D Certs
------------------------------------------------------------------
S&P Global Ratings discontinued its 'D (sf)' ratings on four
classes of commercial mortgage pass-through certificates from two
U.S. CMBS transactions, Morgan Stanley Capital I Trust 2006-TOP 21
and GS Mortgage Securities Corp. Trust 2018-RIVR.

We discontinued these ratings according to our surveillance and
withdrawal policies. We previously lowered the ratings on these
classes to 'D (sf)' because of accumulated interest shortfalls that
we believed would remain outstanding for an extended period of
time. We view a subsequent upgrade to a rating higher than 'D (sf)'
to be unlikely under the relevant criteria for the classes within
this review.

Related Research
Global Structured Finance 2024 Outlook, Jan. 10, 2024
Ratings Discontinued

  Morgan Stanley Capital I Trust 2006-TOP 21

  Class C to NR from 'D (sf)'

  GS Mortgage Securities Corp. Trust 2018-RIVR

  Class B to NR from 'D (sf)'
  Class C to NR from 'D (sf)'
  Class D to NR from 'D (sf)'



GS MORTGAGE 2024-PJ8: Fitch Assigns 'Bsf' Rating on Class B-5 Certs
-------------------------------------------------------------------
Fitch Ratings rates the residential mortgage-backed certificates
issued by GS Mortgage-Backed Securities Trust 2024-PJ8 (GSMBS
2024-PJ8).

   Entity/Debt       Rating             Prior
   -----------       ------             -----
GSMBS 2024-PJ8

   A-1           LT AAAsf  New Rating   AAA(EXP)sf
   A-1-X         LT AAAsf  New Rating   AAA(EXP)sf
   A-2           LT AAAsf  New Rating   AAA(EXP)sf
   A-3           LT AAAsf  New Rating   AAA(EXP)sf
   A-3A          LT AAAsf  New Rating   AAA(EXP)sf
   A-3L          LT WDsf   Withdrawn    AAA(EXP)sf
   A-3-X         LT AAAsf  New Rating   AAA(EXP)sf
   A-4           LT AAAsf  New Rating   AAA(EXP)sf
   A-4L          LT WDsf   Withdrawn    AAA(EXP)sf
   A-4A          LT AAAsf  New Rating   AAA(EXP)sf
   A-5           LT AAAsf  New Rating   AAA(EXP)sf
   A-5-X         LT AAAsf  New Rating   AAA(EXP)sf
   A-6           LT AAAsf  New Rating   AAA(EXP)sf
   A-7           LT AAAsf  New Rating   AAA(EXP)sf
   A-7-X         LT AAAsf  New Rating   AAA(EXP)sf
   A-8           LT AAAsf  New Rating   AAA(EXP)sf
   A-9           LT AAAsf  New Rating   AAA(EXP)sf
   A-9-X         LT AAAsf  New Rating   AAA(EXP)sf
   A-10          LT AAAsf  New Rating   AAA(EXP)sf
   A-11          LT AAAsf  New Rating   AAA(EXP)sf
   A-11-X        LT AAAsf  New Rating   AAA(EXP)sf
   A-12          LT AAAsf  New Rating   AAA(EXP)sf
   A-13          LT AAAsf  New Rating   AAA(EXP)sf
   A-13-X        LT AAAsf  New Rating   AAA(EXP)sf
   A-14          LT AAAsf  New Rating   AAA(EXP)sf
   A-15          LT AAAsf  New Rating   AAA(EXP)sf
   A-15-X        LT AAAsf  New Rating   AAA(EXP)sf
   A-16          LT AAAsf  New Rating   AAA(EXP)sf
   A-16L         LT WDsf   Withdrawn    AAA(EXP)sf
   A-17          LT AAAsf  New Rating   AAA(EXP)sf
   A-17-X        LT AAAsf  New Rating   AAA(EXP)sf
   A-18          LT AAAsf  New Rating   AAA(EXP)sf
   A-19          LT AAAsf  New Rating   AAA(EXP)sf
   A-19-X        LT AAAsf  New Rating   AAA(EXP)sf
   A-20          LT AAAsf  New Rating   AAA(EXP)sf
   A-21          LT AAAsf  New Rating   AAA(EXP)sf
   A-21-X        LT AAAsf  New Rating   AAA(EXP)sf
   A-22          LT AAAsf  New Rating   AAA(EXP)sf
   A-22L         LT WDsf   Withdrawn    AAA(EXP)sf
   A-23          LT AAAsf  New Rating   AAA(EXP)sf
   A-23-X        LT AAAsf  New Rating   AAA(EXP)sf
   A-24          LT AAAsf  New Rating   AAA(EXP)sf
   A-X           LT AAAsf  New Rating   AAA(EXP)sf
   B             LT BBB-sf New Rating   BBB-(EXP)sf
   B-1           LT AA-sf  New Rating   AA-(EXP)sf
   B-1-A         LT AA-sf  New Rating   AA-(EXP)sf
   B-1-X         LT AA-sf  New Rating   AA-(EXP)sf
   B-2           LT A-sf   New Rating   A-(EXP)sf
   B-2-A         LT A-sf   New Rating   A-(EXP)sf
   B-2-X         LT A-sf   New Rating   A-(EXP)sf
   B-3           LT BBB-sf New Rating   BBB-(EXP)sf
   B-3-A         LT BBB-sf New Rating   BBB-(EXP)sf
   B-3-X         LT BBB-sf New Rating   BBB-(EXP)sf
   B-4           LT BBsf   New Rating   BB(EXP)sf
   B-5           LT Bsf    New Rating   B(EXP)sf
   B-6           LT NRsf   New Rating   NR(EXP)sf
   B-X           LT BBB-sf New Rating   BBB-(EXP)sf
   A-IO-S        LT NRsf   New Rating   NR(EXP)sf
   A-R           LT NRsf   New Rating   NR(EXP)sf

Transaction Summary

The classes are supported by 283 prime loans with a total balance
of approximately $315 million as of the cut-off date. The
transaction is expected to close on Sept. 30, 2024.

Classes A-3L, A-4L, A-16L and A-22L have been cancelled by the
issuer as they are not being funded at close and will not be funded
at any point in the future. Therefore, Fitch has withdrawn the
ratings for those classes.

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 11.5% above a long-term sustainable level, which is
lower than the projected overvaluation of 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 Mortgage Pool (Positive): The collateral consists of
30-year, fixed-rate mortgage (FRM) fully amortizing loans seasoned
at approximately seven months in aggregate, calculated as the
difference between the cutoff date and origination date. The
average loan balance is $1,114,394. The collateral comprises
primarily prime-jumbo loans and 102 agency-conforming loans.

Borrowers in this pool have strong credit profiles (a 772 model
FICO). The sustainable loan to value ratio (sLTV) is 76%, and the
mark-to-market (MTM) combined loan to value (CLTV) ratio is 67.4%.
Fitch treated 100% of the loans as full documentation collateral,
and 100% of the loans are qualified mortgages (QMs).

Of the pool, 87.4% are loans for which the borrower maintains a
primary residence, while 12.6% are for second homes. In addition,
80.6% of the loans were originated through a retail channel.
Expected losses in the 'AAAsf' stress amount to 7.75%, similar to
those of prior issuances and other prime-jumbo shelves.

Shifting-Interest Deal Structure (Mixed): The mortgage cash flow
and loss allocation are based on a senior-subordinate,
shifting-interest structure, whereby the subordinate classes
receive only scheduled principal and are locked out from receiving
unscheduled principal or prepayments for five years. The lockout
feature helps maintain subordination for a longer period should
losses occur later in the life of the deal.

The applicable credit support percentage feature redirects
subordinate principal to classes of higher seniority if specified
credit enhancement (CE) levels are not maintained. Due to the
leakage to the subordinate bonds, the shifting-interest structure
requires more CE. While there is only minimal leakage to the
subordinate bonds early in the life of the transaction, the
structure is more vulnerable to defaults at a later stage compared
with a sequential or modified-sequential structure.

To help mitigate tail risk, which arises as the pool seasons and
fewer loans are outstanding, a subordination floor of 3.25% of the
original balance will be maintained for the senior notes and a
subordination floor of 2.25% of the original balance will be
maintained for the subordinate notes.

Loan Concentration (Negative): Fitch adjusted the expected losses
due concentration concerns due to small loan counts. Fitch
increased the losses at the 'AAAsf' level by 159 bps due to the low
loan count. The loan count is 283, with a weighted average number
(WAN) of 190. As a loan pool becomes more concentrated, there is a
greater vulnerability to idiosyncratic events impacting
performance.

RATING SENSITIVITIES

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

The defined negative rating sensitivity analysis demonstrates how
the ratings would react to steeper market value declines (MVDs) at
the national level. The analysis assumes MVDs of 10.0%, 20.0% and
30.0%, in addition to the model projected 41.8% 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 DILIGENCE PURSUANT TO SEC RULE 17G -10

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by SitusAMC and Opus. The third-party due diligence
described in Form 15E focused on a review of credit, regulatory
compliance and property valuation for each loan and is consistent
with Fitch criteria for RMBS loans.

Fitch considered this information in its analysis and, as a result,
made the following adjustment to its analysis:

- A 5% reduction to each loan's probability of default.

This adjustment resulted in a 351ps 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.


HALCYON LOAN 2015-3: Moody's Cuts Rating on $27.5MM D Notes to Ca
-----------------------------------------------------------------
Moody's Ratings has upgraded the rating on the following notes
issued by Halcyon Loan Advisors Funding 2015-3 Ltd.:

US$34,000,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2027 (current outstanding balance of $20,553,026.10), Upgraded
to A1 (sf); previously on February 8, 2022 Upgraded to Baa1 (sf)

Moody's have also downgraded the rating on the following notes:

US$27,500,000 Class D Senior Secured Deferrable Floating Rate Notes
due 2027 (current outstanding balance of $32,264,662.26),
Downgraded to Ca (sf); previously on November 1, 2022 Downgraded to
Caa3 (sf)

Halcyon Loan Advisors Funding 2015-3 Ltd., originally issued in
September 2015 and partially refinanced in December 2017, 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 October 2019.

A comprehensive review of all credit ratings for the respective
transaction has been conducted during a rating committee.

RATINGS RATIONALE

The upgrade rating action is primarily a result of deleveraging of
the senior notes and an increase in the transaction's
over-collateralization (OC) ratios since September 2023. The Class
A-2-R notes ($6.9 million), and Class B-R notes ($27.3 million)
have been fully repaid, and the Class C notes have been paid down
by approximately 39.6% or $13.4 million, since September 2023.
Based on the trustee's September 2024 report[1], the OC ratio for
the Class C notes is reported at 157.58% versus September 2023[2]
level of 124.78%.

The downgrade rating action on the Class D notes reflects the
specific risks to the junior notes posed by par loss and credit
deterioration observed in the underlying CLO portfolio. Based on
the trustee's September 2024 report[1], the OC ratio for the Class
D notes is reported at 61.32% versus the September 2023[2] level of
86.59%, and the September 2024[1] trustee-reported weighted average
rating factor (WARF) is 5165 compared to 4292 in September
2023[2].

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: $34,875,887

Defaulted par:  $1,764,824

Diversity Score: 12

Weighted Average Rating Factor (WARF): 4612

Weighted Average Spread (WAS) (before accounting for reference rate
floors): 3.96%

Weighted Average Recovery Rate (WARR): 45.3%

Weighted Average Life (WAL): 1.8 years

Par haircut in OC tests and interest diversion test: 11.9%

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.


JP MORGAN 2018-PTC: S&P Lowers Class A Certs Rating to 'CCC(sf)'
----------------------------------------------------------------
S&P Global Ratings lowered its ratings on five classes of
commercial mortgage pass-through 2018-PTC from J.P. Morgan Chase
Commercial Mortgage Securities Trust 2018-PTC, a U.S. CMBS
transaction.

This U.S. standalone (single-borrower) CMBS transaction was backed
by a pari-passu portion of a $115.3 million floating-rate,
interest-only mortgage loan secured by the fee simple and leasehold
interests in the Peachtree Center, an office and retail complex
totaling about 2.5 million sq. ft. in downtown Atlanta. The
properties became real estate-owned (REO) in late 2022.

Rating Actions

The downgrades on the class A, B, C, and D certificates reflect:

-- The lack of meaningful performance improvement at the REO
properties since S&P's last published review in November 2023.
Occupancy at the properties stood at 46.9% as of the June 2024
rent roll provided by the servicer, indicating minimal change from
the 42.6% occupancy rate we assumed in our last review.

-- The continued increase in servicer advances leading to a larger
exposure to the trust. According to the transaction's payment
waterfall, servicer advances are repaid to the servicer before any
distributions to the bondholders. Since S&P's published review in
November 2023, the reported exposure grew to $131.6 million. In
addition, due to the lack of clarity regarding the resolution of
the defaulted asset, we expect the servicer to potentially advance
an additional $10.6 million, or approximately 12-months in interest
payments, to the trust to pay bondholders interest due.

-- S&P said, "Our net recovery value of $59.92 million or $24 per
sq. ft., after reducing for the exposure build to date and
additional projected advances. This is 68.9% below the
servicer-reported appraisal value of $193.2 million as of July
2024, and indicates a risk of default and losses to the classes.
The value variance between our value against the appraisal value is
primarily due to the appraiser's valuation approach. To derive the
as-is valuation, the appraiser assumed a stabilization of the
office properties to an 80.0% occupancy rate, and then deducted the
lease-up costs, as well as capital expenditures required. Our
analysis assumed an in-place occupancy rate given the continued
downward trend in performance."

S&P said, "The downgrades on the class A, B, C, and D certificates
also reflect our view that, based on our current analysis, the
current market conditions, and their respective positions in the
payment waterfall, the risk of default and losses on these classes
has increased or remains elevated. Additionally, the classes are
susceptible to reduced liquidity support (in the event the servicer
implements an appraisal reduction amount [ARA] or deems the asset
nonrecoverable).

"The downgrade on the class X-EXT IO certificates reflects our
criteria for rating IO securities, which states that the rating on
the IO securities would not be higher than that of the lowest-rated
reference class. The notional amount of class X-EXT references
classes A, B, C, and D."

The loan transferred to the special servicer on March 22, 2022, due
to imminent monetary default and became REO in September 2022.

According to the September 2024 trustee remittance report, the
trust outstanding advances and accruals totaled $16.3 million, and
included the following:

-- Interest advances totaling $12.1 million;

-- Real estate tax and insurance advances totaling $1.6 million;

-- Other expense advances totaling $1.7 million;

-- Cumulative accrued unpaid advance interest totaling $757,422
million; and

-- Cumulative appraisal subordinate entitled reduction amount
totaling $207,493. This amount was the result of an ARA implemented
on the asset in March 2024 that was subsequently removed in July
2024 following the release of an updated appraisal value.

Although the servicer has not re-implemented an ARA on the trust
asset, given the lack of performance improvement at the properties,
S&P remains cautious of appraisal valuation declines in the future,
which could again trigger an ARA. Furthermore, the continued
increase in overall servicer advances may also result in a
nonrecoverable determination being made by the servicer.

According to the special servicer's comments, they have engaged
Transwestern to manage and lease the property, while efforts to
stabilize the property continue before determining the optimal
strategy to resolve the defaulted asset.

S&P said, "We will continue to monitor the tenancy and performance
of the properties. If we receive information that differs
materially from our expectations, including interest shortfalls
impacting the rated certificates, we may revisit our analysis and
take additional rating actions as we determine appropriate."

Updates To Property-Level Analysis

S&P said, "During our last review in November 2023, we revised our
S&P Global Ratings capitalization rate to 9.00% as a reflection of
the credit quality of the properties backing the trust's
certificates. At that time, our long-term sustainable net cash flow
of $7.7 million remained unchanged from our analysis derived in May
2023.

"Due to the lack of performance improvement at the property, as
well as the still weak office fundamentals, our current analysis
remains unchanged." Based on the June 2024 rent roll provided by
the special servicer, the overall occupancy rate averages 46.9%,
with individual occupancy rates at the seven properties ranging
from a low of 11.4% (South Tower) to a high of 76.2% (Marquis One).
At loan origination, the portfolio was approximately 70.0%
occupied, but soon declined to 61.0% occupancy in 2021, and
continued to decline to 50.0% in mid-2022, and now stands at 46.9%
as of June 2024.

According to CoStar, the downtown Atlanta submarket has a vacancy
rate of 17.5% as of September 2024, up from 10.0% in 2019. CoStar
projects the vacancy rate to increase to 19.0% in 2028.
Furthermore, CoStar peer properties that it deems are comparable in
quality to S&P's subject properties, have significantly weaker
credit matrices compared to the submarket and are performing
in-line with our subject properties. CoStar provided 17 peer
properties that in aggregate have a 68.1% vacancy rate with an
availability rate of 74.6%.

The September 2024 servicer reserve report does not indicate that
any funds are held by the special servicer. However, in a prior
communication with the special servicer, it was noted that $5.3
million of funds were held by the servicer as of May 2024. It is
unclear if any of the funds remain as collateral for the trust.

  Ratings Lowered

  J.P. Morgan Chase Commercial Mortgage Securities Trust 2018-PTC

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



JP MORGAN 2024-HE3: Fitch Assigns B(EXP)sf Rating on Cl. B-2 Certs
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings to J.P. Morgan Mortgage
Trust 2024-HE3 (JPMMT 2024-HE3).

   Entity/Debt        Rating           
   -----------        ------           
JPMMT 2024-HE3

   A-1            LT AAA(EXP)sf Expected Rating
   M-1            LT AA(EXP)sf  Expected Rating
   M-2            LT A(EXP)sf   Expected Rating
   M-3            LT BBB(EXP)sf Expected Rating
   B-1            LT BB(EXP)sf  Expected Rating
   B-2            LT B(EXP)sf   Expected Rating
   B-3            LT NR(EXP)sf  Expected Rating
   B-4            LT NR(EXP)sf  Expected Rating
   BX             LT NR(EXP)sf  Expected Rating
   A-IO-S         LT NR(EXP)sf  Expected Rating
   X              LT NR(EXP)sf  Expected Rating
   R              LT NR(EXP)sf  Expected Rating
   BX+AIOS        LT NR(EXP)sf  Expected Rating

Transaction Summary

Fitch expects to rate the residential mortgage-backed certificates
backed by first and second lien, prime, open home equity line of
credit (HELOC) on residential properties to be issued by J.P.
Morgan Mortgage Trust 2024-HE3 (JPMMT 2024-HE3), as indicated
above. This is the sixth transaction to be rated by Fitch that
includes prime-quality first and second lien HELOCs with open draws
off the JPMMT shelf and the sixth second lien HELOC transaction off
the JPMMT shelf.

The loans associated with the draws allocated to the participation
certificate are 5,433 non-seasoned, performing, prime-quality first
and second lien HELOC loans with a current outstanding balance (as
of the cutoff date) of $402.72 million. The collateral balance
based on the maximum draw amount is $599.82 million, as determined
by Fitch.

As of the cutoff date, 100% of the HELOC lines are open or on a
temporary freeze and may be opened in the future. The aggregate
available credit line amount, as of the cutoff date, is expected to
be $87.9 million, per transaction documents. As of the cutoff date,
weighted average (WA) utilization of the HELOCs is 90.9%, per the
transaction documents.

The main originators in the transaction are loanDepot.com, LLC
(35.3% per the transaction docs), United Wholesale Mortgage (39.8%
per the transaction docs), and Better Mortgage Corporation (20.0%
per the transaction docs). All other originators make up less than
10% of the pool. The loans are serviced by NewRez LLC d/b/a
Shellpoint Mortgage Servicing (Shellpoint [64.7% per the
transaction docs] and loanDepot.com LLC [35.3% per the transaction
docs]).

Distributions of principal are based on a modified sequential
structure, subject to the transaction's performance triggers.
Interest payments are made sequentially to all classes, except B-4,
which is a principal-only class, while losses are allocated reverse
sequentially once excess spread is depleted.

Draws will be funded by JPMorgan Mortgage Acquisitions Corp.
(JPMMAC). This transaction will not use a variable funding note
(VFN) structure; rather, it will use participation certificates.
JPMMT 2024-HE3 is only entitled to cash flows based on the amount
drawn as of the cutoff date. The remaining available draws will be
allocated to the JPMorgan participation certificate (JPM PC) if
they are drawn in the future.

In Fitch's analysis, Fitch assumes 100% of the HELOCs are 100%
drawn on day one. As a result, all Fitch-determined percentages are
based off the maximum HELOC draw amount.

The servicers, Shellpoint and loanDepot.com, LLC, will not be
advancing delinquent (DQ) monthly payments of principal and
interest (P&I).

The collateral comprises 100% adjustable-rate loans. These loans
are adjusted based on the prime rate, none of which reference
LIBOR. The class A-1, M-1, M-2, M-3 and B-1 certificates are
floating rate and use SOFR as the index; they are capped at the net
WA coupon (WAC). The annual rate on class B-2 and B-3 certificates
with respect to any distribution date (and the related accrual
period) will be equal to the net WAC for such distribution date.
The B-4 certificates are entitled to distributions of principal
only and will not receive any distributions of interest. There is
no exposure to LIBOR in this transaction.

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 11.0% 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 participation
interest is in a fixed pool of draws related to 5,433
prime-quality, performing, adjustable-rate open-ended HELOCs that
have up to 15-year interest-only (IO) periods and maturities of up
to 30 years. The open-ended HELOCs are secured by mainly second
liens on primarily one- to four-family residential properties
(including planned unit developments), condominiums and townhouses,
totaling $599.82 million (includes the maximum HELOC draw amount).
The loans were made to borrowers with strong credit profiles and
relatively low leverage.

The loans are seasoned at an average of eight months, according to
Fitch, and three months, per the transaction documents. The pool
has a WA original FICO score of 744, as determined by Fitch (745
per transaction documents), indicative of very high credit-quality
borrowers. About 44.8% of the loans, as determined by Fitch (43.9%
per transaction documents), have a borrower with an original FICO
score equal to or above 750. The original WA combined loan-to-value
(CLTV) ratio of 70.1%, as determined by Fitch, translates to a
sustainable loan-to-value (sLTV) ratio of 78.3%.

The transaction documents stated a WA drawn LTV of 18.4% and a WA
drawn CLTV of 65.0%. The LTVs represent moderate borrower equity in
the property and reduced default risk, compared with a borrower
CLTV of over 80%. Of the pool loans, 56.9% were originated by a
retail or correspondent channel with the remaining 43.1% originated
by a broker channel. Of the loans, 100% are underwritten to full
documentation. Based on Fitch's documentation review, it considered
95.6% of the loans to be fully documented.

Of the pool, 95.1% comprise loans where the borrower maintains a
primary or secondary residence, and the remaining 4.9% are investor
loans. Single-family homes, planned unit developments (PUDs), a
townhouse and single-family attached dwellings constitute 94.3% of
the pool (or 93.9%, per the transaction documents). Condominiums
make up 3.9% (4.1% per the transaction documents), while
multifamily homes make up 1.8% (2.0% per the transaction
documents).

According to Fitch, the pool consists of loans with the following
loan purposes: 99.3% cashout refinances (loans that have a cashout
amount greater than 2% of the original balance), 0.7% purchases and
less than 0.1% rate-term refinances (loans with a cashout amount
less than 2% of the original balance). The transaction documents
show 99.2% of the pool to be cashouts. Fitch considers a loan to be
a rate term refinance if the cashout amount is less than $5,000,
which explains the difference in the cashout amount percentages.

None of the loans in the pool are over $1.0 million, and the
maximum draw amount is $500,000.

Of the pool loans, 34.8% (34.2% per the transaction documents) are
concentrated in California. The largest MSA concentration is in the
Los Angeles MSA (12.7%), followed by the New York MSA (5.7%) and
the Miami MSA (4.8%). The top three MSAs account for 23% of the
pool. As a result, no probability of default (PD) penalty was
applied for geographic concentration.

Second Lien HELOC Collateral (Negative): The majority of the
collateral pool (98.6%) consists of second lien HELOC loans
originated by loanDepot.com, LLC, United Wholesale Mortgage, Better
Mortgage Corporation and other originators. Fitch assumed no
recovery and 100% loss severity (LS) on second lien loans, based on
the historical behavior of the 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.

Modified Sequential Structure with No Advancing of Delinquent P&I
(Mixed): The proposed structure is a modified-sequential structure
in which principal is distributed pro rata to classes A-1, M-1, M-2
and M-3 to the extent the performance triggers are passing. To the
extent the triggers are failing, principal is paid sequentially.
The transaction also benefits from excess spread that can be used
to reimburse for realized and cumulative losses, as well as cap
carryover amounts.

The transaction has a lockout feature benefiting more senior
classes if performance deteriorates. If the applicable credit
support percentage of classes M-1, M-2 or M-3 is less than the sum
of (i) 150% of the original applicable credit support percentage
for that class plus (ii) 50% of the NPL percentage plus (iii) the
charged off loan percentage, then that class is locked out of
receiving principal payments and the principal payments are
redirected toward the most senior class. To the extent any class of
certificates is a locked out class, each class of certificates
subordinate to such locked out class will also be a locked out
class. Due to this lockout feature, the class M will be locked out
starting on day one.

Classes A-1, M-1, M-2, M-3, and B-1 are floating-rate classes based
on the SOFR index and are capped at the net WAC. The annual rate on
the class B-2 and B-3 certificates with respect to any distribution
date (and the related accrual period) will be equal to the net WAC
for such distribution date. Class B-4 is a principal-only class and
is not entitled to receive interest. If no excess spread is
available to absorb losses, losses will be allocated to all classes
reverse sequentially, starting with class B-4. The servicer will
not advance delinquent monthly payments of P&I.

180-Day Chargeoff Feature (Positive): Loans that become 180 days
delinquent based on the Mortgage Bankers Association (MBA)
delinquency method, except for those in a forbearance plan, will be
charged off. The 180-day chargeoff feature will result in losses
being incurred sooner, while a larger amount of excess interest is
available to protect against losses. This compares favorably to a
delayed liquidation scenario, whereby the loss occurs later in the
life of the transaction and less excess is available.

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 42.2% 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.

CRITERIA VARIATION

Fitch rated the first JPMMT HELOC in 2023 and the shelf has been a
programmatic HELOC issuer. As such, Fitch now has 12 months of
performance data on post-crisis prime quality HELOC performance.
Based on this additional historical performance data, Fitch
reviewed its benchmark prepayment curves used for HELOCs and found
that revisions were needed in order to more accurately reflect when
prepayments occur and how fast prepayment speeds are based on this
additional data and HELOC borrower behavior.

For this transaction, Fitch applied a variation to Fitch's U.S.
RMBS Cash Flow Analysis Criteria in order to change the shape and
CPR speeds of the benchmark prepayment curves. Specifically, Fitch
used benchmark prepayment curves that have the shape as Fitch's
seven-year ARM prepayment curve and used benchmark prepayments
speeds that range from 15% to 37.5% CPR. These changes more
accurately reflect the historical prepayment behavior of HELOCs
that tend to prepay closer to the end of the IO period and prepay
slower than fixed rate second lien products and first lien
products. Applying the variation resulted in ratings that are one
rating category higher than existing criteria would suggest.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by SitusAMC and Consolidated Analytics. 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 1.01% at the
'AAAsf' stress due to 100% due diligence with no material
findings.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the pool. The third-party due diligence was
generally consistent with Fitch's "U.S. RMBS Rating Criteria."
SitusAMC and Consolidated Analytics were 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
are 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.


JP MORGAN 2024-HE3: Fitch Assigns Bsf Final Rating on Cl. B-2 Certs
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings to J.P. Morgan Mortgage
Trust 2024-HE3 (JPMMT 2024-HE3).

   Entity/Debt       Rating            Prior
   -----------       ------            -----
JPMMT 2024-HE3

   A-1           LT AAAsf New Rating   AAA(EXP)sf
   M-1           LT AAsf  New Rating   AA(EXP)sf
   M-2           LT Asf   New Rating   A(EXP)sf
   M-3           LT BBBsf 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
   B-4           LT NRsf  New Rating   NR(EXP)sf
   BX            LT NRsf  New Rating   NR(EXP)sf
   A-IO-S        LT NRsf  New Rating   NR(EXP)sf
   X             LT NRsf  New Rating   NR(EXP)sf
   R             LT NRsf  New Rating   NR(EXP)sf
   BX+AIOS       LT NRsf  New Rating   NR(EXP)sf

Transaction Summary

Fitch has assigned final ratings to the residential mortgage-backed
certificates backed by first and second lien, prime, open home
equity line of credit (HELOC) on residential properties to be
issued by J.P. Morgan Mortgage Trust 2024-HE3 (JPMMT 2024-HE3), as
indicated above. This is the sixth transaction to be rated by Fitch
that includes prime-quality first and second lien HELOCs with open
draws off the JPMMT shelf and the sixth second lien HELOC
transaction off the JPMMT shelf.

The loans associated with the draws allocated to the participation
certificate are 5,433 non-seasoned, performing, prime-quality first
and second lien HELOC loans with a current outstanding balance (as
of the cutoff date) of $402.72 million. The collateral balance
based on the maximum draw amount is $599.82 million, as determined
by Fitch.

As of the cutoff date, 100% of the HELOC lines are open or on a
temporary freeze and may be opened in the future. The aggregate
available credit line amount, as of the cutoff date, is expected to
be $87.9 million, per transaction documents. As of the cutoff date,
weighted average (WA) utilization of the HELOCs is 90.9%, per the
transaction documents.

The main originators in the transaction are loanDepot.com, LLC
(35.3% per the transaction docs), United Wholesale Mortgage (39.8%
per the transaction docs), and Better Mortgage Corporation (20.0%
per the transaction docs). All other originators make up less than
10% of the pool. The loans are serviced by NewRez LLC d/b/a
Shellpoint Mortgage Servicing (Shellpoint [64.7% per the
transaction docs] and loanDepot.com LLC [35.3% per the transaction
docs]).

Distributions of principal are based on a modified sequential
structure, subject to the transaction's performance triggers.
Interest payments are made sequentially to all classes, except B-4,
which is a principal-only class, while losses are allocated reverse
sequentially once excess spread is depleted.

Draws will be funded by JPMorgan Mortgage Acquisitions Corp.
(JPMMAC). This transaction will not use a variable funding note
(VFN) structure; rather, it will use participation certificates.
JPMMT 2024-HE3 is only entitled to cash flows based on the amount
drawn as of the cutoff date. The remaining available draws will be
allocated to the JPMorgan participation certificate (JPM PC) if
they are drawn in the future.

In Fitch's analysis, Fitch assumes 100% of the HELOCs are 100%
drawn on day one. As a result, all Fitch-determined percentages are
based off the maximum HELOC draw amount.

The servicers, Shellpoint and loanDepot.com, LLC, will not be
advancing delinquent (DQ) monthly payments of principal and
interest (P&I).

The collateral comprises 100% adjustable-rate loans. These loans
are adjusted based on the prime rate, none of which reference
LIBOR. The class A-1, M-1, M-2, M-3 and B-1 certificates are
floating rate and use SOFR as the index; they are capped at the net
WA coupon (WAC). The annual rate on class B-2 and B-3 certificates
with respect to any distribution date (and the related accrual
period) will be equal to the net WAC for such distribution date.
The B-4 certificates are entitled to distributions of principal
only and will not receive any distributions of interest. There is
no exposure to LIBOR in this transaction.

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 11.0% 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 participation
interest is in a fixed pool of draws related to 5,433
prime-quality, performing, adjustable-rate open-ended HELOCs that
have up to 15-year interest-only (IO) periods and maturities of up
to 30 years. The open-ended HELOCs are secured by mainly second
liens on primarily one- to four-family residential properties
(including planned unit developments), condominiums and townhouses,
totaling $599.82 million (includes the maximum HELOC draw amount).
The loans were made to borrowers with strong credit profiles and
relatively low leverage.

The loans are seasoned at an average of eight months, according to
Fitch, and three months, per the transaction documents. The pool
has a WA original FICO score of 744, as determined by Fitch (745
per transaction documents), indicative of very high credit-quality
borrowers. About 44.8% of the loans, as determined by Fitch (43.9%
per transaction documents), have a borrower with an original FICO
score equal to or above 750. The original WA combined loan-to-value
(CLTV) ratio of 70.1%, as determined by Fitch, translates to a
sustainable loan-to-value (sLTV) ratio of 78.3%.

The transaction documents stated a WA drawn LTV of 18.4% and a WA
drawn CLTV of 65.0%. The LTVs represent moderate borrower equity in
the property and reduced default risk, compared with a borrower
CLTV of over 80%. Of the pool loans, 56.9% were originated by a
retail or correspondent channel with the remaining 43.1% originated
by a broker channel. Of the loans, 100% are underwritten to full
documentation. Based on Fitch's documentation review, it considered
95.6% of the loans to be fully documented.

Of the pool, 95.1% comprise loans where the borrower maintains a
primary or secondary residence, and the remaining 4.9% are investor
loans. Single-family homes, planned unit developments (PUDs), a
townhouse and single-family attached dwellings constitute 94.3% of
the pool (or 93.9%, per the transaction documents). Condominiums
make up 3.9% (4.1% per the transaction documents), while
multifamily homes make up 1.8% (2.0% per the transaction
documents).

According to Fitch, the pool consists of loans with the following
loan purposes: 99.3% cashout refinances (loans that have a cashout
amount greater than 2% of the original balance), 0.7% purchases and
less than 0.1% rate-term refinances (loans with a cashout amount
less than 2% of the original balance). The transaction documents
show 99.2% of the pool to be cashouts. Fitch considers a loan to be
a rate term refinance if the cashout amount is less than $5,000,
which explains the difference in the cashout amount percentages.

None of the loans in the pool are over $1.0 million, and the
maximum draw amount is $500,000.

Of the pool loans, 34.8% (34.2% per the transaction documents) are
concentrated in California. The largest MSA concentration is in the
Los Angeles MSA (12.7%), followed by the New York MSA (5.7%) and
the Miami MSA (4.8%). The top three MSAs account for 23% of the
pool. As a result, no probability of default (PD) penalty was
applied for geographic concentration.

Second Lien HELOC Collateral (Negative): The majority of the
collateral pool (98.6%) consists of second lien HELOC loans
originated by loanDepot.com, LLC, United Wholesale Mortgage, Better
Mortgage Corporation and other originators. Fitch assumed no
recovery and 100% loss severity (LS) on second lien loans, based on
the historical behavior of the 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.

Modified Sequential Structure with No Advancing of Delinquent P&I
(Mixed): The proposed structure is a modified-sequential structure
in which principal is distributed pro rata to classes A-1, M-1, M-2
and M-3 to the extent the performance triggers are passing. To the
extent the triggers are failing, principal is paid sequentially.
The transaction also benefits from excess spread that can be used
to reimburse for realized and cumulative losses, as well as cap
carryover amounts.

The transaction has a lockout feature benefiting more senior
classes if performance deteriorates. If the applicable credit
support percentage of classes M-1, M-2 or M-3 is less than the sum
of (i) 150% of the original applicable credit support percentage
for that class plus (ii) 50% of the NPL percentage plus (iii) the
charged off loan percentage, then that class is locked out of
receiving principal payments and the principal payments are
redirected toward the most senior class. To the extent any class of
certificates is a locked out class, each class of certificates
subordinate to such locked out class will also be a locked out
class. Due to this lockout feature, the class M will be locked out
starting on day one.

Classes A-1, M-1, M-2, M-3, and B-1 are floating-rate classes based
on the SOFR index and are capped at the net WAC. The annual rate on
the class B-2 and B-3 certificates with respect to any distribution
date (and the related accrual period) will be equal to the net WAC
for such distribution date. Class B-4 is a principal-only class and
is not entitled to receive interest. If no excess spread is
available to absorb losses, losses will be allocated to all classes
reverse sequentially, starting with class B-4. The servicer will
not advance delinquent monthly payments of P&I.

180-Day Chargeoff Feature (Positive): Loans that become 180 days
delinquent based on the Mortgage Bankers Association (MBA)
delinquency method, except for those in a forbearance plan, will be
charged off. The 180-day chargeoff feature will result in losses
being incurred sooner, while a larger amount of excess interest is
available to protect against losses. This compares favorably to a
delayed liquidation scenario, whereby the loss occurs later in the
life of the transaction and less excess is available.

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 42.2% 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.

CRITERIA VARIATION

Fitch rated the first JPMMT HELOC in 2023 and the shelf has been a
programmatic HELOC issuer. As such, Fitch now has 12 months of
performance data on post-crisis prime quality HELOC performance.
Based on this additional historical performance data, Fitch
reviewed its benchmark prepayment curves used for HELOCs and found
that revisions were needed in order to more accurately reflect when
prepayments occur and how fast prepayment speeds are based on this
additional data and HELOC borrower behavior.

For this transaction, Fitch applied a variation to Fitch's U.S.
RMBS Cash Flow Analysis Criteria in order to change the shape and
CPR speeds of the benchmark prepayment curves. Specifically, Fitch
used benchmark prepayment curves that have the shape as Fitch's
seven-year ARM prepayment curve and used benchmark prepayments
speeds that range from 15% to 37.5% CPR. These changes more
accurately reflect the historical prepayment behavior of HELOCs
that tend to prepay closer to the end of the IO period and prepay
slower than fixed rate second lien products and first lien
products. Applying the variation resulted in ratings that are one
rating category higher than existing criteria would suggest.

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by SitusAMC and Consolidated Analytics. 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 1.01% at the
'AAAsf' stress due to 100% due diligence with no material
findings.

DATA ADEQUACY

Fitch relied on an independent third-party due diligence review
performed on 100% of the pool. The third-party due diligence was
generally consistent with Fitch's "U.S. RMBS Rating Criteria."
SitusAMC and Consolidated Analytics were 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
are 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.


JPMCC COMMERCIAL 2015-JP1: Fitch Cuts Rating on 2 Tranches to 'B-'
------------------------------------------------------------------
Fitch Ratings has downgraded seven and affirmed seven classes of
JPMCC Commercial Mortgage Securities Trust 2015-JP1 (JPMCC
2015-JP1) commercial mortgage pass-through certificates. Fitch has
also assigned Negative Rating Outlooks to seven classes following
the downgrades and has revised Outlooks on three classes to
Negative from Stable.

   Entity/Debt          Rating            Prior
   -----------          ------            -----
JPMCC 2015-JP1

   A-4 46590KAD6    LT AAAsf  Affirmed    AAAsf
   A-5 46590KAE4    LT AAAsf  Affirmed    AAAsf
   A-S 46590KAG9    LT AAAsf  Affirmed    AAAsf
   A-SB 46590KAF1   LT AAAsf  Affirmed    AAAsf
   B 46590KAH7      LT A-sf   Downgrade   AA-sf
   C 46590KAK0      LT BBB-sf Downgrade   A-sf
   D 46590KAL8      LT BB-sf  Downgrade   BBBsf
   E 46590KBA1      LT B-sf   Downgrade   BB-sf
   F 46590KAS3      LT CCCsf  Affirmed    CCCsf
   G 46590KAU8      LT CCsf   Affirmed    CCsf
   X-A 46590KAN4    LT AAAsf  Affirmed    AAAsf
   X-B 46590KAP9    LT A-sf   Downgrade   AA-sf
   X-D 46590KAR5    LT BB-sf  Downgrade   BBBsf
   X-E 46590KAY0    LT B-sf   Downgrade   BB-sf

KEY RATING DRIVERS

Increase in 'Bsf' Loss Expectations: The downgrades reflect
increased expected pool level losses since the prior rating action
driven by higher loss expectations and refinance concerns on Fitch
Loans of Concern (FLOCs), primarily 32 Avenue of the Americas and
Heinz 57 Center. Ten loans (62.5% of the pool) are flagged as
FLOCs, including the aforementioned loans and 7700 Parmer, The 9,
DoubleTree Anaheim - Orange County, Chattanooga & Greeley Retail
Portfolio, La Fontenay Apartments, Courtyard by Marriott McDonough,
Marketplace at Augusta - Townsend, and Hampton Inn College Park.

Due to the significant near-term loan maturities and increasing
pool concentrations, Fitch performed a sensitivity and liquidation
analysis. This grouped the remaining loans based on their current
status and collateral quality, and then ranked them by their
perceived likelihood of repayment and/or loss expectations.

Fitch's current ratings incorporate an increased 'Bsf' rating case
loss of 6.9% from 4.7% at Fitch's last rating action. The Negative
Outlooks reflect the elevated concentration of office loans
(50.8%), adverse selection concerns in the pool, and reliance on
proceeds from FLOCs to repay classes. Without performance
stabilization, improved recovery prospects and/or if more loans
than expected fail to refinance at maturity and/or expected losses
increase, further downgrades are possible.

The largest increase in loss expectations since the prior rating
action and largest overall contributor to loss is the 32 Avenue of
the Americas loan (19.6%), secured by a 1.2 million-sf office
property/data center in New York, NY. The property was identified
as a FLOC due to sustained performance declines. Occupancy has
declined further to 57.3% as of Q1 2024 from 60.5% at YE 2023, and
remains lower than 70% at YE 2022 and 89% at YE 2020. Due to the
occupancy declines, NOI DSCR remains slightly above a 1.00x
coverage for the Q1 2024 and YE 2023 reporting periods.

Per updates from the servicer, Dentsu (5.9% of the NRA) has been
gradually vacating their space ahead of their August 2025 lease
expiration. Cedar Cares (5.7% of the NRA) and Industrious (4.9% of
the NRA), which have previously shown interest in expanding at the
subject property, have also since retracted their plans.

In addition to the decline in occupancy, operating expenses have
increased at the subject. Compared to issuance levels, real estate
taxes have risen 41.8% and general and administrative expenses have
increased 170%, contributing to a 28.3% increase in total operating
expenses. Overall, YE 2023 NOI has declined 39.7% yoy and remains
42.7% below the originator's underwritten NOI at issuance.

Fitch's 'Bsf' rating case loss of 13.1% (prior to concentration
adjustments) reflects a 9% cap rate to the YE 2023 NOI and factors
an increased probability of default due to the loan's heightened
default concerns. The loan matures in November 2025.

The second largest increase in loss expectations since the prior
rating action and second largest overall contributor to loss is the
Heinz 57 Center loan (8.3%), secured by a 699,610-sf office
building in Pittsburgh, PA. The building is primarily occupied by
Heinz North America which represents 44.3% of the building NRA on a
lease through July 2026. As of June 2024, occupancy had declined to
74% due to ground floor retail tenant Burlington Coat Factory
(20.1% of NRA) vacating at lease expiration in March 2024. As of YE
2023, NOI DSCR was 1.54x in line with YE 2022. In addition, YE 2023
NOI had increased 6.7% above the originator's underwritten NOI from
issuance.

Fitch's 'Bsf' rating case loss (prior to concentration adjustments)
of 25% reflects a 10% stress to the YE 2023 NOI, elevated 10% cap
rate and factors a higher probability of default to account for the
decline in occupancy, near-term lease expiration and heightened
refinance risk.

The third largest increase in loss expectations since the prior
rating action and third largest overall contributor to loss is the
7700 Parmer loan (14.7%), secured by a 911,579 sf office property
in Austin, TX. The largest tenants at the property include Google
(33.3% of NRA) expiring in September 2027 and Electronic Arts
(19.2%) with lease expiration in August 2026. Occupancy declined to
81% in 2023 from 99% in 2022 due to the downsize of eBay from 24%
of the property down to 10% and the departure of Fair Isaac (2.7%
of NRA) and Deloitte (1.5%) in 2023 at their respective lease
expiration dates. YE 2023 NOI is down 38% year over year and is 11%
below the originator's underwritten NOI at issuance.

Fitch's 'Bsf' rating case loss (prior to concentration adjustments)
of 4% reflects the YE 2023 NOI with a cap rate of 9.5% which
equates to a stressed value of $187 psf.

Increase to Credit Enhancement: As of the September 2024
distribution date, the pool's aggregate principal balance has paid
down by 36.1% to $511.1 million from $799.2 million at issuance.
There are three full-term, IO loans (36.7% of pool) remaining,
while eight loans are defeased (15.8%). Cumulative interest
shortfalls totaling $2.2 million are affecting Class G.

RATING SENSITIVITIES

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

Downgrades to 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 junior 'AAAsf' rated classes with Negative Outlooks
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.

Downgrades to classes rated in the 'AAsf' and 'Asf' categories
could occur if deal-level losses increase significantly from
outsized losses on larger FLOCs or more loans than expected
experience performance deterioration or default at or before
maturity.

Downgrades to the 'BBBsf' and 'Bsf' categories are possible with
higher than expected losses from continued underperformance of the
FLOCs, in particular office loans with deteriorating performance or
with greater certainty of losses on FLOCs. Loans of particular
concern include 32 Avenue of the Americas, Heinz 57 Center, 7700
Parmer, The 9, DoubleTree Anaheim - Orange County, Chattanooga &
Greeley Retail Portfolio, La Fontenay Apartments, Courtyard by
Marriott McDonough, Marketplace at Augusta - Townsend, and Hampton
Inn College Park.

Downgrades to classes with distressed ratings would occur if
additional loans transfer to special servicing or default, 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 credit enhancement (CE) from
paydowns and/or defeasance, coupled with stable-to-improved
pool-level loss expectations and 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
were the likelihood of interest shortfalls.

Upgrades to the '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, recoveries on the FLOCs are better than
expected and there is sufficient CE to the classes.

Upgrades to distressed ratings are not expected but would be
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.


JPMDB COMMERCIAL 2016-C4: Fitch Lowers Rating on 2 Tranches to 'B'
------------------------------------------------------------------
Fitch Ratings has downgraded seven and affirmed five classes of
JPMDB Commercial Mortgage Securities Trust, series 2016-C4 (JPMDB
2016-C4). Fitch revised the Outlook to Negative from Stable for
affirmed classes, A-S and X-A. Fitch assigned Negative Outlooks to
classes B, C, D, X-B and X-C following the downgrades.

In addition, Fitch has downgraded six and affirmed six classes of
JPMCC Commercial Mortgage Securities Trust 2016-JP4 commercial
mortgage pass-through certificates (JPMCC 2016-JP4). Fitch revised
the Outlook to Negative from Stable for affirmed classes, A-S and
X-A. Fitch assigned Negative Outlooks to classes B, C, and X-B
following the downgrades.

   Entity/Debt          Rating            Prior
   -----------          ------            -----
JPMDB 2016-C4

   A-2 46646RAH6    LT AAAsf  Affirmed    AAAsf
   A-3 46646RAJ2    LT AAAsf  Affirmed    AAAsf
   A-S 46646RAN3    LT AAAsf  Affirmed    AAAsf
   A-SB 46646RAK9   LT AAAsf  Affirmed    AAAsf
   B 46646RAP8      LT A-sf   Downgrade   AA-sf
   C 46646RAQ6      LT BBB-sf Downgrade   A-sf
   D 46646RAB9      LT Bsf    Downgrade   BB+sf
   E 46646RAC7      LT CCCsf  Downgrade   Bsf
   F 46646RAD5      LT CCsf   Downgrade   CCCsf
   X-A 46646RAL7    LT AAAsf  Affirmed    AAAsf  
   X-B 46646RAM5    LT A-sf   Downgrade   AA-sf
   X-C 46646RAA1    LT Bsf    Downgrade   BB+sf

JPMCC 2016-JP4

   A-2 46645UAR8    LT AAAsf  Affirmed    AAAsf
   A-3 46645UAS6    LT AAAsf  Affirmed    AAAsf
   A-4 46645UAT4    LT AAAsf  Affirmed    AAAsf
   A-S 46645UAX5    LT AAAsf  Affirmed    AAAsf
   A-SB 46645UAU1   LT AAAsf  Affirmed    AAAsf
   B 46645UAY3      LT A-sf   Downgrade   AA-sf
   C 46645UAZ0      LT BBB-sf Downgrade   A-sf
   D 46645UAC1      LT CCCsf  Downgrade   BB-sf
   E 46645UAE7      LT CCsf   Downgrade   CCCsf
   X-A 46645UAV9    LT AAAsf  Affirmed    AAAsf
   X-B 46645UAW7    LT A-sf   Downgrade   AA-sf
   X-C 46645UAA5    LT CCCsf  Downgrade   BB-sf

KEY RATING DRIVERS

KEY RATING DRIVERS

Performance and Increase in 'B' Loss Expectations: The downgrades
in both transactions are the result of higher expected losses
compared to the last rating actions. JPMDB 2016-C4 deal-level 'Bsf'
ratings case losses are 6.8% compared to 5.0% at the prior rating
action; deal-level 'Bsf' rating case losses are 11.8% in JPMCC
2016-JP4 compared to 8.1% at the last rating action. Fitch Loans of
Concern (FLOCs) comprise nine loans (28.8% of the pool) in JPMDB
2016-C4 including two loans in special servicing (4.7%) and nine
loans (29.5%) in JPMCC 2016-JP4 with two loans (8.7%) in special
servicing.

The Negative Outlooks in the JPMDB 2016-C4 transaction reflect the
high office concentration of 56.2% and the potential for downgrades
should performance of the FLOCs, PNC Center, 60 Madison Avenue, 1
Kaiser Plaza, Riverside Center, 100 Oceangate, Shops at Avenue
North, Westfield San Francisco Centre, Riverwood Corporate Center I
& III, Beacon South Beach, fail to stabilize, and/or with prolonged
workouts of loans in special servicing.

Negative Outlooks in the JPMCC 2016-JP4 transaction reflect the
office concentration of 36.4% and the potential for downgrades with
sustained underperformance and lack of stabilization of the FLOCs,
Riverway, Summit Mall, International Plaza, 1140 Avenue of the
Americas, Everett Plaza, PGA Financial Plaza, 80 Park Plaza,
Franklin Marketplace, Timbergrove Heights.

Largest Contributors to Loss: The largest increase in loss
expectations since the prior rating action and the third largest
contributor to loss in the JPMDB 2016-C4 transaction is the 1
Kaiser Plaza loan (3.9% of the pool) secured by a 537,811 sf office
tower in downtown Oakland, CA. The building is primarily occupied
by Kaiser Foundation Health Plan which represents 69.4% of the
building NRA on a lease through February 2027. According to the
servicer, Kaiser has exercised an option to downsize by 130,085 sf
(24% of the total footage) in July 2024 which would result in a
decline of the building occupancy to 59%.

Fitch's 'Bsf' rating case loss (prior to concentration adjustments)
of 20% reflects a 20% stress to the YE 2023 NOI, elevated 10% cap
rate and factors a higher probability of default to account for the
downsize of the largest tenant and heightened refinance risk.

The largest overall contributor to loss expectations in the JPMDB
2016-C4 transaction is the specially serviced Riverwood Corporate
Center I & II (2.2%), secured by a 180,198 sf office property in
Pewaukee, WI. Performance of the property has deteriorated with
overall occupancy falling to 48% in 2021 due to the departure of
major tenants, Safway Services (36.3% of NRA) and MRA - The
Management Association (24.1%). Occupancy has since recovered to
63% as of Q1-2024, however, cash flow remains insufficient to
service debt service with Q1-2024 NOI DSCR of 0.73x which compares
with 0.58x as of YE 2022.

Fitch's 'Bsf' rating case loss (prior to concentration adjustments)
of 66% is based on a discount to a recent appraisal value, which
reflects a recovery of $39 psf.

The largest increase in loss expectations since the prior rating
action and second largest overall contributor to loss in the JPMCC
2016-JP4 transaction is the 1140 Avenue of the Americas loan (3.0%)
which is secured by a 242,466-sf Class A office building in
Midtown, Manhattan. The YE 2023 NOI has declined 48% below YE 2022
and remains 80% below the Fitch issuance NCF, reflecting lower
occupancy and rental rates at the property. Cash flow remains
insufficient to cover debt service with YE 2023 NOI DSCR of 0.40x;
however, the loan remains current as the sponsor continues to pay
debt service and works to stabilize occupancy. Per the June 2024
rent roll, the property was 79.3% occupied compared to 71% at YE
2022 and 91% at issuance.

Per the servicer, the largest tenant City National Bank (14.4% of
NRA; exp. June 2033) extended 10 years in 2023 but at a reduced
rent. Per the servicer, the tenant is now paying approximately $116
psf compared to their prior rental rate of $124 psf. The second
largest tenant is 1140 Office Suites LLC (10.3% of NRA; exp. March
20231), a coworking space. They signed a lease in December 2023,
filling the space of the former third largest tenant, Innovate
NYC's (6.8%). The coworking tenant received a rent abatement
through March 2024 and half abatement through the remainder of
2024.

Per the rent roll, upcoming lease rollover includes 8.6% of the NRA
in 2024 and 6.9% in 2025. Affiliated Managers Group Inc. (5.2% of
NRA, exp. September 2024) is expected to vacate. The tenant is
subleasing their space, and the subtenant is not expected to
execute a direct lease.

Fitch's 'Bsf' rating case loss of 84% (prior to concentration
add-ons) reflects a Fitch value of $16.1 million as well as a high
probability of default given a short-term ground lease and
declining performance. Fitch's value incorporates the YE 2023 NOI
with an adjustment for rent abatements ending in 2024. Fitch also
applied a cap rate of 12% reflecting the elevated risk associated
with the ground lease which expires in 2066. The current annual
ground lease payment is $4.75 million. Fitch's increased loss
expectation includes the potential for significant challenges in
refinancing the loan given the decline in performance and market
conditions since issuance, upcoming tenant rollover and potential
for further performance declines, as well as the high ground lease
payment and short remaining term.

The largest overall contributor to loss expectations in the JPMCC
2016-JP4 transaction is the Riverway loan (6.7%), which is secured
by a four-building suburban office property totaling 869,120-sf
located in Rosemont, IL, approximately 1.5 miles from O'Hare
International Airport. The property consists of three office
buildings and one 10,409-sf daycare center. The largest tenants
include U.S. Foods, Inc. (34.2% of NRA; expiring February 2029),
Culligan International Company (6.1%; December 2026), Appleton GRP
LLC (4.4%; December 2026) and Public Buildings Service (3.9%;
August 2037).

The loan transferred to special servicing in May 2023 for imminent
default due to occupancy/cash flow issues and the borrower stopped
funding shortfalls. According to the servicer, foreclosure has been
filed and the lender continues to discuss workout alternatives with
the borrower.

Occupancy was 68% as of March 2023, compared to 58% at YE 2022, 65%
at YE 2021, 67% at YE 2020 and 91% in June 2019; the steep decline
in occupancy between 2019 and 2020 was due to Central States
Pension Fund (21.9% NRA) vacating upon lease expiration in December
2019. Approximately 4% of the NRA is scheduled to roll in 2024. The
servicer-reported NOI debt service coverage ratio (DSCR) was 0.80x
as of March 2023, compared with 0.78x at YE 2022, 0.82x at YE 2021,
0.65x at YE 2020, and 1.60x at YE 2019. Cash management remains in
place after Central States Pension Fund's lease expiration
triggered a tenant cash flow sweep.

Fitch's 'Bsf' rating case loss of 53% (prior to concentration
add-ons) reflects a discount to a recent appraisal value which
equates to a recovery of $60 psf.

Changes in Credit Enhancement (CE): As of the September 2024
distribution date, the aggregate balances of the JPMDB 2016-C4 and
JPMCC 2016-JP4 transactions have been paid down by 15.6% and 18.4%,
respectively, since issuance.

The JPMDB 2016-C4 transaction includes five loans (11.2% of the
pool) that have fully defeased and JPMCC 2016-JP4 has four (5.41%)
fully defeased loans. Cumulative interest shortfalls of $318,419
are affecting the non-rated NR class in JPMDB 2016-C4 and $2.6
million is affecting the non-rated NR class in JPMCC 2016-JP4.

RATING SENSITIVITIES

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

Downgrades to 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 junior 'AAAsf' rated classes with Negative Outlooks
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.

Downgrades to classes rated in the 'AAsf' and 'Asf' categories,
which have Negative Outlooks, may occur should performance of the
FLOCs, which include PNC Center, 60 Madison Avenue, 1 Kaiser Plaza,
Riverside Center, 100 Oceangate, Shops at Avenue North, Westfield
San Francisco Centre, Riverwood Corporate Center I & III, Beacon
South Beach in JPMDB 2016-C4, and Riverway, Summit Mall,
International Plaza, 1140 Avenue of the Americas, Everett Plaza,
PGA Financial Plaza, 80 Park Plaza, Franklin Marketplace,
Timbergrove Heights in JPMCC 2016-JP4, deteriorate further or more
loans than expected default at or prior to maturity.

Downgrades to in the 'BBBsf', 'BBsf' and 'Bsf' categories are
likely 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 would occur should additional
loans transfer to special servicing or default, 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 paydowns and/or
defeasance, coupled with stable-to-improved pool-level loss
expectations and 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 until the later years in a transaction and 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 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.


LENDMARK FUNDING 2024-2: S&P Assigns BB-(sf) Rating on Cl. E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its ratings to Lendmark Funding Trust
2024-2's personal consumer loan-backed notes.

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

The ratings reflect S&P's view of:

-- The availability of approximately 55.3%, 48.3%, 41.9%, 35.7%,
and 29.2% credit support to the class A, B, C, D, and E notes,
respectively, in the form of subordination, overcollateralization,
a reserve account, and excess spread. These credit support levels
are sufficient to withstand stresses commensurate with the notes'
ratings, based on our stressed cash flow scenarios.

-- S&P's worst-case, weighted average base-case loss for this
transaction of approximately 13.09%, which is a function of the
transaction-specific reinvestment criteria and Lendmark Financial
Services LLC's (Lendmark) actual loan performance. Its base case
also accounts for historical volatility observed in Lendmark's
annual loan vintages over time.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal, the assigned ratings will be within
the limits specified in the credit stability section of "S&P Global
Ratings Definitions," published June 9, 2023.

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

-- The characteristics of the pool being securitized and the
receivables expected to be purchased during the revolving period.

-- Lendmark's performance history as originator and servicer.

-- The transaction's payment and legal structures.

  Ratings Assigned

  Lendmark Funding Trust 2024-2

  Class A, $200.02 million, 4.47% interest rate: AAA (sf)
  Class B, $28.91 million, 4.86% interest rate: AA (sf)
  Class C, $23.86 million, 5.25% interest rate: A (sf)
  Class D, $22.91 million, 5.69% interest rate: BBB (sf)
  Class E, $32.38 million, 8.47% interest rate: BB- (sf)



MADISON PARK LIV: Fitch Assigns BB+(EXP)sf Rating on Cl. E-R Notes
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
Madison Park Funding LIV, Ltd. reset transaction.

   Entity/Debt              Rating           
   -----------              ------            
Madison Park
Funding LIV, Ltd.

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

Transaction Summary

Madison Park Funding LIV, Ltd. (the issuer) is an arbitrage cash
flow collateralized loan obligation (CLO) that will be managed by
UBS Asset Management (Americas) LLC that originally closed in
November 2022 and is being refinanced on Oct. 29, 2024. Net
proceeds from the issuance of the secured and subordinated notes
will provide financing on a portfolio of approximately $500 million
of primarily first lien senior secured leveraged loans.

KEY RATING DRIVERS

Asset Credit Quality (Negative): The average credit quality of the
indicative portfolio is 'B'/'B-', which is in line with that of
recent CLOs. 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
98.12% first-lien senior secured loans and has a weighted average
recovery assumption of 75.50%. 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 37% 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 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 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:
'AAAsf' for class X, between 'BBB+sf' and 'AA+sf' for class A-1-R,
between 'BBB+sf' and 'AA+sf' for class A-2-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-1-R, between less
than 'B-sf' and 'BB+sf' for class D-2-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, class A-1-R
and 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, 'Asf' 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 Madison Park
Funding LIV, 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 any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.


MARINER FINANCE 2024-B: S&P Assigns Prelim 'BB-' Rating on E Notes
------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Mariner
Finance Issuance Trust 2024-B's asset-backed notes.

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

The preliminary ratings are based on information as of Oct. 7,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

-- The availability of credit support in the form of
subordination, overcollateralization, a reserve account, and excess
spread to absorb net losses of approximately 54.48%, 46.24%,
41.16%, 35.41%, and 28.87% in S&P's stressed cash flow scenarios,
commensurate with the preliminary ratings assigned to the notes.

-- S&P said, "Our worst-case, weighted average, base-case default
assumption of 18.45% for this transaction. Our default assumption
is a function of the transaction-specific reinvestment criteria and
the historical Mariner Finance LLC (Mariner) portfolio loan
performance."

-- Mariner's long performance history as originator and servicer.


-- The company has been profitable every year since 2002.

-- S&P's expectation that under a moderate ('BBB') stress
scenario, all else being equal, the assigned preliminary ratings
will be consistent with the credit stability section of "S&P Global
Ratings Definitions," published June 9, 2023.

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

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

-- The transaction's payment and legal structures.

  Preliminary Ratings Assigned

  Mariner Finance Issuance Trust 2024-B

  Class A, $199.56 million(i): AAA (sf)
  Class B, $31.18 million(i): AA- (sf)
  Class C, $21.33 million(i): A-(sf)
  Class D, $18.71 million(i): BBB- (sf)
  Class E, $29.22 million(i): BB- (sf)

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



MCF CLO V: S&P Assigns Prelim BB- (sf) Rating on Class E-R2 Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-R2, A-L1, A-L2, B-R2, C-R2, D-R2, and E-R2 replacement debt from
MCF CLO V LLC, a CLO managed by Apogem Capital LLC that was
originally issued in March 2017 and underwent a second refinancing
in March 2021.

The preliminary ratings are based on information as of Oct. 7,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 10, 2024, 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 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. 10, 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 weighted average life test will be extended to nine years
from the 2024 refinancing date.

-- No additional assets will be purchased on the Oct. 10, 2024,
refinancing date, and the target initial par amount will remain at
$300 million. There will be no additional effective date or ramp-up
period, and the first payment date following the refinancing is
Jan. 20, 2025.

-- The required minimum overcollateralization and interest
coverage ratios will be amended.

-- No additional subordinated notes will be issued on the
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."

  Preliminary Ratings Assigned

  MCF CLO V LLC

  Class A-R2, $36.00 million: AAA (sf)
  Class A-L1, $65.00 million: AAA (sf)
  Class A-L2, $73.00 million: AAA (sf)
  Class B-R2, $30.00 million: AA (sf)
  Class C-R2 (deferrable), $24.00 million: A (sf)
  Class D-R2 (deferrable), $18.00 million: BBB- (sf)
  Class E-R2 (deferrable), $16.50 million: BB- (sf)

  Other Debt

  MCF CLO V LLC

  Subordinated notes, $47.56 million: Not rated




MORGAN STANLEY 2013-C11: Moody's Lowers Rating on 2 Tranches to Ca
------------------------------------------------------------------
Moody's Ratings has affirmed the ratings on two classes and
downgraded the ratings on two classes in Morgan Stanley Bank of
America Merrill Lynch Trust 2013-C11 ("MSBAM 2013-C11"), Commercial
Mortgage Pass-Through Certificates, Series 2013-C11 as follows:

Cl. A-S, Affirmed B1 (sf); previously on Sep 29, 2023 Downgraded to
B1 (sf)

Cl. B, Downgraded to Ca (sf); previously on Sep 29, 2023 Downgraded
to Caa3 (sf)

Cl. C, Affirmed C (sf); previously on Sep 29, 2023 Downgraded to C
(sf)

Cl. PST, Downgraded to Ca (sf); previously on Sep 29, 2023
Downgraded to Caa3 (sf)

RATINGS RATIONALE

The rating on one P&I class, Cl. A-S, was affirmed due to its
credit support and the expected principal proceeds from the
remaining loans in the pool. While all the remaining loans are in
special servicing, the class has significant credit support and
will benefit from priority of payment from any loan liquidations or
pay downs. Furthermore, the class has already paid down 32% from
its original balance. The rating on Cl. C was affirmed because its
rating is consistent with Moody's expected loss plus realized
losses. Cl. C has already realized a 10% loss on its original
balance from previously liquidated loans.

The rating on class Cl. B was downgraded due to the potential for
higher losses given the significant exposure to specially serviced
loans.  All three remaining loans (100% of the pool) are in
specially servicing and the two largest include Westfield
Countryside (70% of the pool) which is secured by a regional mall
whose performance has remained significantly below securitization
levels and Bridgewater Commons (29% of pool) which is secured by a
mixed-use property with declining occupancy.

The rating on the exchangeable class, Cl. PST, was downgraded due
to the decline in the credit quality of its reference exchangeable
classes and from principal paydowns of higher quality reference
classes.

Moody's rating action reflects a base expected loss of 57.8% of the
current pooled balance, compared to 58.6% at Moody's last review.
Moody's base expected loss plus realized losses is now 22.0% of the
original pooled balance, compared to 23.2% at the last review.

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

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

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

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

METHODOLOGY UNDERLYING THE RATING ACTION

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

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

DEAL PERFORMANCE

As of the September 17, 2024 distribution date, the transaction's
aggregate certificate balance has decreased by 85% to $125.4
million from $856.3 million at securitization. The certificates are
collateralized by three mortgage loans, all of which are in special
servicing.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $115.8 million (for an average loss
severity of 83%).

The largest specially serviced loan is the Westfield Countryside
Loan ($88.0 million -- 70.2% of the pool), which represents a pari
passu portion of a $136.4 million mortgage loan. The loan is
secured by a 465,000 square foot (SF) component of an approximately
1.26 million square foot (SF) super-regional mall located in
Clearwater, Florida approximately 20 miles west of Tampa. The mall
is anchored by Dillard's, Macy's and JC Penney, all of which are
non-collateral. A former Sears space (non-collateral) was partially
backfilled by a Whole Food's and Nordstrom Rack. The largest
collateral tenant includes a 12-screen Cobb Theaters (lease
expiration in December 2026). As of April 2024, collateral and
inline occupancy were 82% and 82%, respectively, compared to 71%
and 63% in December 2023 and 93% and 88% in March 2020. The
property's NOI has generally declined since 2019, and the
property's 2023 NOI was 34% below securitization levels with an NOI
DSCR of 1.17X. The loan was originally sponsored by Westfield and
O'Connor Capital Partners, however, Westfield previously indicated
that they were no longer going to support the asset and cooperated
with a friendly foreclosure. All rents are currently being cash
trapped and JLL is the receiver and is currently managing the
property. The most recent appraisal value reported in October 2023
represented a 57% decline from its value at securitization and was
15% below the total outstanding loan amount. The loan has been in
special servicing since June 2020 and as of the September 2024
remittance statement was last paid through its May 2024 payment
date. A 28% appraisal reduction has been recognized (based on the
loan's outstanding balance) as of the September 2024 remittance
statement. Per the servicer's commentary, the property was listed
for sale and the special servicer is currently working with a
potential buyer to determine if they can get to acceptable terms to
close a sale after a prior offer was re-traded.

The second largest specially serviced loan is the Bridgewater
Campus Loan ($36.1 million -- 28.8% of the pool), which is secured
by eight Class B mixed-use buildings totaling 446,649 SF. The
property is located in Bridgewater, New Jersey, approximately 41
miles southwest of New York City. The buildings are leased to three
tenants who have been at the property since securitization,
however, one tenant has previously downsized causing the occupancy
to decline.  As of December 2023, the property was 80% leased,
compared to 88% in 2022 and 100% in 2019. The loan failed to pay
off at its scheduled maturity date in July 2023 and has been in
special servicing since June 2023. As of December 2023, the loan
had an NOI DSCR of 1.12X, has paid down 17% since securitization
and cash is being trapped from the lockbox account to paydown prior
advances. The loan is now classified as "performing maturity
balloon" and was current on monthly debt service payments as of the
September 2024 remittance date. The special servicer commentary
indicated foreclosure was filed in December 2023, a receiver was
appointed in June 2024 and the borrower previously requested an
extension but did not accept the extension terms.

The third special serviced loan is secured by a single tenant
retail property representing 1.1% of the pooled balance. Moody's
estimate an aggregate $72.5 million loss for the specially serviced
loans (57.8% expected loss on average).

As of the September 2024 remittance statement cumulative interest
shortfalls were $6.5 million. Moody's anticipate interest
shortfalls will continue because of the exposure to specially
serviced loans and/or modified loans. Interest shortfalls are
caused by special servicing fees, including workout and liquidation
fees, appraisal entitlement reductions (ASERs), loan modifications
and extraordinary trust expenses.


MORGAN STANLEY 2022-17A: Fitch Gives BB-(EXP) Rating on E-R Notes
-----------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
the Morgan Stanley Eaton Vance CLO 2022-17A, Ltd. reset
transaction.

   Entity/Debt           Rating           
   -----------           ------           
Morgan Stanley
Eaton Vance
CLO 2022-17A, Ltd.

   X-R               LT NR(EXP)sf   Expected Rating
   A-1-R             LT AAA(EXP)sf  Expected Rating
   A-2-R             LT AAA(EXP)sf  Expected Rating
   B-R               LT AA(EXP)sf   Expected Rating
   C-R               LT A(EXP)sf    Expected Rating
   D-1-R             LT BBB-(EXP)sf Expected Rating
   D-2-R             LT BBB-(EXP)sf Expected Rating
   E-R               LT BB-(EXP)sf  Expected Rating

Transaction Summary

Morgan Stanley Eaton Vance CLO 2022-17A, Ltd. (the issuer) is an
arbitrage cash flow collateralized loan obligation (CLO) managed by
Morgan Stanley Eaton Vance CLO Manager LLC that originally closed
in August 2022. On Nov. 1, 2024 (the reset date), the CLO's secured
notes will be redeemed in full with refinancing proceeds. 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. The weighted average rating factor (WARF) of the indicative
portfolio is 23.39, versus a maximum covenant, in accordance with
the initial expected matrix point of 25.35. 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
99.36% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 75.27% versus a
minimum covenant, in accordance with the initial expected matrix
point of 73.26%.

Portfolio Composition (Positive): The largest three industries may
comprise up to 42.5% 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 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
metrics. The results under these sensitivity scenarios are as
severe as between 'A-sf' and 'AAAsf' for class A-1-R, between
'BBB+sf' and 'AA+sf' for class A-2-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-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-1-R and 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, 'Asf' 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 Morgan Stanley
Eaton Vance CLO 2022-17A, 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 any ESG factor that is a
key rating driver in the key rating drivers section of the relevant
rating action commentary.


MOUNTAIN VIEW CLO XVIII: S&P Assigns BB- (sf) Rating on E Notes
---------------------------------------------------------------
S&P Global Ratings assigned its ratings to Mountain View CLO XVIII
Ltd./Mountain View CLO XVIII LLC's fixed- and 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 Seix Investment Advisors LLC, a
division of Virtus Fixed Income Advisers LLC.

The 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.

  Ratings Assigned

  Mountain View CLO XVIII Ltd./Mountain View CLO XVIII LLC

  Class X, $3.00 million: AAA (sf)
  Class A-1, $180.00 million: AAA (sf)
  Class A-2, $18.00 million: AAA (sf)
  Class B, $30.00 million: AA (sf)
  Class C (deferrable), $18.00 million: A (sf)
  Class D-1 (deferrable), $15.00 million: BBB (sf)
  Class D-2 (deferrable), $6.00 million: BBB- (sf)
  Class E (deferrable), $8.25 million: BB- (sf)
  Subordinated notes, $27.00 million: Not rated




MSC 2024-NSTB: Fitch Assigns 'B-sf' Final Rating on Class G Certs
-----------------------------------------------------------------
Fitch Ratings has assigned final ratings and Rating Outlooks to MSC
2024-NSTB, commercial mortgage pass-through certificates series
2024-NSTB, as follows:

- $325,780,000 class A 'AAAsf'; Outlook Stable;

- $57,012,000 class A-S 'AAAsf'; Outlook Stable;

- $382,792,000 class X-A 'AAAsf'; Outlook Stable;

- $22,688,000 class X-B 'AA-sf'; Outlook Stable;

- $22,688,000 class B 'AA-sf'; Outlook Stable;

- $16,871,000 class C 'A-sf'; Outlook Stable;

- $9,308,000 class X-F 'BB-sf'; Outlook Stable;

- $5,818,000 class X-G 'B-sf'; Outlook Stable;

- $9,308,000 class D 'BBBsf'; Outlook Stable;

- $4,654,000 class E 'BBB-sf'; Outlook Stable;

- $9,308,000 class F 'BB-sf'; Outlook Stable;

- $5,818,000 class G 'B-sf'; Outlook Stable.

Fitch does not rate the following classes:

- $13,962,416 class H;

- $13,962,416 class X-H;

- $24,494,811a,b Combined VRR Interest.

Notes:

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

(b) The VRR Interest certificates comprise the transaction's
vertical risk retention interest.

Transaction Summary

The certificates represent the beneficial ownership interest in the
trust, the primary assets of which are 149 loans secured by 146
commercial properties having an aggregate principal balance of
$489,896,228 as of the cutoff date. The loans were originated
between 2013 and 2023 by Signature Bank and contributed to the
trust by Morgan Stanley Mortgage Capital Holdings LLC.

The master servicer is Wells Fargo Bank, National Association, and
the special servicer is Rialto Capital Advisors, LLC. The trustee
and certificate administrator is Computershare Trust Company,
National Association. The certificates follow a sequential paydown
structure.

Since Fitch published its expected ratings on Sept. 18, 2024,
classes X-C, X-D and X-E were removed from the transaction
structure by the issuer. At the time the expected ratings were
published, class X-C had a balance of $16,871,000, class X-D had a
balance of $9,308,000 and class X-E had a balance of $4,654,000.
Fitch has withdrawn the expected rating of 'A-(EXP)sf' from class
X-C, 'BBB(EXP)sf' from class X-D and 'BBB-(EXP)sf' from class X-E
because the classes were removed from the final deal structure by
the issuer. The classes above reflect the final ratings and deal
structure.

KEY RATING DRIVERS

Fitch Net Cash Flow (NCF): Fitch Ratings performed cash flow
analyses on 35 loans totaling 55.4% of the pool by balance. Fitch's
resulting aggregate NCF of $40.6 million represents an 11.9%
decline from the issuer's aggregate underwritten NCF of $46.1
million.

Fitch Leverage: The pool has higher leverage compared to recent
multiborrower transactions rated by Fitch. The pool's Fitch
loan-to-value ratio (LTV) of 100.2% is greater than both the 2024
YTD and 2023 multiborrower pool averages of 95.1% and 88.3%,
respectively. The pool has lower leverage than Fitch-rated Freddie
Mac 10-year K-Series deals rated in 2024 YTD and 2023, which
averaged 107.5% and 120.1%, respectively. The pool's Fitch NCF debt
yield (DY) of 8.3% is worse than both the 2024 YTD and 2023
multiborrower averages of 10.5% and 10.9%, respectively, but is in
line with the 2024 YTD K-Series average of 8.2% and better than the
2023 K-Series average of 7.3%.

Adjustable Rate Loans: The pool includes 100 loans with loan
documents that specify an interest-rate reset or extension option
wherein the loan's interest rate will reset to the greater of the
in-place interest rate or the Five-Year Treasury Rate plus a spread
ranging from 250 to 300 basis points at a future date. An
additional 37 loans have passed their adjustment dates and have
already reset. Twelve loans in the pool do not have an interest
rate reset provision.

The largest concentration of future rate resets occurs in 2027,
during which 58 loans (54.9% of the pool) will reach their
adjustment date. The current weighted average (WA) interest rate
for the pool is 4.25%, Fitch assumed a WA constant of 8.74% for the
pool.

Loan Diversification: The pool is less concentrated than recently
rated Fitch transactions. The top 10 loans make up only 32.8% of
the pool, which is significantly lower than both the 2024 YTD
multiborrower pool average of 60.5% and the 2023 average of 63.7%.
The pool's concentration is also lower than Fitch-rated Freddie Mac
10-year K-Series deals rated in 2024 YTD and 2023, which averaged
52.4% and 56.6%, respectively.

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 59.5. 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

Declining cash flow decreases property value and capacity to meet
its debt service obligations. The list 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';

- 10% NCF Decline: 'AAsf'/'Asf'/'BBBsf'/'BB+sf'/'BBsf'/'B-sf'.

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 list 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';

- 10% NCF Increase: 'AAAsf'/'AAsf'/'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 Deloitte & Touche LLP. The third-party due diligence
described in Form 15E focused on a comparison and re-computation of
certain characteristics with respect to each of the mortgage loans.
Fitch considered this information in its analysis and it did not
have an effect on its 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.


OZLM XXIII: S&P Assigns Prelim BB- (sf) Rating on Class E Notes
---------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to OZLM XXIII
Ltd./OZLM XXIII LLC's fixed- and 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 Sculptor Loan Management L.P.

The preliminary ratings are based on information as of Oct. 3,
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

  OZLM XXIII Ltd./OZLM XXIII LLC

  Class X, $5.00 million: AAA (sf)
  Class A-1, $315.00 million: AAA (sf)
  Class A-2, $15.00 million: AAA (sf)
  Class B, $50.00 million: AA (sf)
  Class C-1 (deferrable), $20.00 million: A (sf)
  Class C-2 (deferrable), $10.00 million: A (sf)
  Class D-1 (deferrable), $20.00 million: BBB+ (sf)
  Class D-2 (deferrable), $15.00 million: BBB- (sf)
  Class E (deferrable), $15.00 million: BB- (sf)
  Subordinated notes, $52.925 million: Not rated



PIKES PEAK 5: Fitch Assigns 'B-sf' Rating on Class F-R Notes
------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to Pikes
Peak CLO 5 reset transaction.

   Entity/Debt          Rating             Prior
   -----------          ------             -----
Pikes Peak CLO 5

   A-1R             LT AAAsf  New Rating   AAA(EXP)sf
   A-2R             LT AAAsf  New Rating   AAA(EXP)sf
   B-R              LT AAsf   New Rating   AA(EXP)sf
   C-R              LT Asf    New Rating   A(EXP)sf
   D-1R             LT BBBsf  New Rating   BBB(EXP)sf
   D-2R             LT BBB-sf New Rating   BBB-(EXP)sf
   E-R              LT BB-sf  New Rating   BB-(EXP)sf
   F-R              LT B-sf   New Rating   B-(EXP)sf
   X                LT NRsf   New Rating   NR(EXP)sf

Transaction Summary

Pikes Peak CLO 5 (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by
Partners Group US Management CLO LLC. Net proceeds from the
issuance of the secured and subordinated notes will provide
financing on a portfolio of approximately $396 million of primarily
first lien senior secured leveraged loans (excluding defaulted
obligations).

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 24.52, versus a maximum covenant, in accordance with
the initial expected matrix point of 25. 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
98.53% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 73.28% versus a
minimum covenant, in accordance with the initial expected matrix
point of 71.6%.

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

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

Upgrade scenarios are not applicable to the class A-1R and class
A-2R 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-1R, 'Asf' for class D-2R, 'BBB+sf' for class E-R, and
'BBB-sf' for class F-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.

Date of Relevant Committee

24 September 2024

PUBLIC RATINGS WITH CREDIT LINKAGE TO OTHER RATINGS

ESG CONSIDERATIONS

Fitch does not provide ESG relevance scores for Pikes Peak CLO 5.
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.


RATE MORTGAGE 2024-J3: Moody's Assigns Ba3 Rating to Cl. B-5 Certs
------------------------------------------------------------------
Moody's Ratings has assigned definitive ratings to 61 classes of
residential mortgage-backed securities (RMBS) to be issued by RATE
Mortgage Trust 2024-J3, and sponsored by Guaranteed Rate, Inc.

The securities are backed by a pool of non GSE-eligible residential
mortgages originated by Guaranteed Rate, Inc. and serviced by
ServiceMac, LLC.

The complete rating actions are as follows:

Issuer: RATE Mortgage Trust 2024-J3

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

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

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-4, Definitive Rating Assigned Aaa (sf)

Cl. A-5, Definitive Rating Assigned Aaa (sf)

Cl. A-6, Definitive Rating Assigned Aaa (sf)

Cl. A-7, Definitive Rating Assigned Aaa (sf)

Cl. A-8, Definitive Rating Assigned Aaa (sf)

Cl. A-9, Definitive Rating Assigned Aaa (sf)

Cl. A-10, Definitive Rating Assigned Aaa (sf)

Cl. A-11, Definitive Rating Assigned Aaa (sf)

Cl. A-12, Definitive Rating Assigned Aaa (sf)

Cl. A-13, Definitive Rating Assigned Aaa (sf)

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

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

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

Cl. A-17, Definitive Rating Assigned Aaa (sf)

Cl. A-18, Definitive Rating Assigned Aaa (sf)

Cl. A-19, Definitive Rating Assigned Aa1 (sf)

Cl. A-20, Definitive Rating Assigned Aa1 (sf)

Cl. A-21, Definitive Rating Assigned Aa1 (sf)

Cl. A-22, Definitive Rating Assigned Aaa (sf)

Cl. A-23, Definitive Rating Assigned Aaa (sf)

Cl. A-24, Definitive Rating Assigned Aaa (sf)

Cl. A-25, Definitive Rating Assigned Aaa (sf)

Cl. A-X-1*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-2*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-3*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-4*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-5*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-6*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-7*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-8*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-9*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-10*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-11*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-12*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-13*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-14*, Definitive Rating Assigned Aaa (sf)

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

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

Cl. A-X-17*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-18*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-19*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-20*, Definitive Rating Assigned Aa1 (sf)

Cl. A-X-21*, Definitive Rating Assigned Aa1 (sf)

Cl. A-X-22*, Definitive Rating Assigned Aa1 (sf)

Cl. A-X-23*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-24*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-25*, Definitive Rating Assigned Aaa (sf)

Cl. A-X-26*, Definitive Rating Assigned Aaa (sf)

Cl. B-1A, Definitive Rating Assigned Aa3 (sf)

Cl. B-X-1*, Definitive Rating Assigned Aa3 (sf)

Cl. B-1, Definitive Rating Assigned Aa3 (sf)

Cl. B-2A, Definitive Rating Assigned A3 (sf)

Cl. B-X-2*, Definitive Rating Assigned A3 (sf)

Cl. B-2, Definitive Rating Assigned A3 (sf)

Cl. B-3, Definitive Rating Assigned Baa3 (sf)

Cl. B-4, Definitive Rating Assigned Ba1 (sf)

Cl. B-5, Definitive Rating Assigned Ba3 (sf)

Cl. A-2L Loans, Definitive Rating Assigned Aaa (sf)

*Reflects Interest-Only Classes

Moody's are withdrawing the provisional ratings for the Class A-1L
Loans and Class A-3L Loans, assigned on September 23, 2024, because
the issuer will not be issuing these classes.

RATINGS RATIONALE

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

Moody's expected loss for this pool in a baseline scenario-mean is
0.25%, in a baseline scenario-median is 0.08% and reaches 4.61% at
a stress level consistent with Moody's Aaa ratings.

PRINCIPAL METHODOLOGY

The principal methodology used in rating all classes except
interest-only classes was "Moody's Approach to Rating US RMBS Using
the MILAN Framework" published in July 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 up. Losses could decline from Moody's original
expectations as a result of a lower number of obligor defaults or
appreciation in the value of the mortgaged property securing an
obligor's promise of payment. Transaction performance also depends
greatly on the US macro economy and housing market.

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's original expectations
as a result of a higher number of obligor defaults or deterioration
in the value of the mortgaged property securing an obligor's
promise of payment. Transaction performance also depends greatly on
the US macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

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


RR 32: S&P Assigns Preliminary BB- (sf) Rating on Class D-R Debt
----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to the class
A-1-R, A-2-R, B-R, C-1A-R, C-1B-R, C-2-R, and D-R replacement debt
from RR 32 Ltd./RR 32 LLC, a CLO originally issued under the name
Gulf Stream Meridian 4 Ltd. in May 2021, then renamed to RRX 4 Ltd.
in October 2023, and being renamed now to RR 32 Ltd. The
transaction is managed by Redding Ridge Asset Management LLC, an
affiliate of Apollo Global Management LLC.

The preliminary ratings are based on information as of Oct. 8,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 15, 2024, refinancing date, the proceeds from the
replacement debt will be used to redeem the original class A-1,
A-2, B, C, and D debt. S&P said, "At that time, we expect to
withdraw our ratings on the original debt and assign ratings to the
class A-1-R, A-2-R, B-R, C-1A-R, C-1B-R, C-2-R, and D-R replacement
debt. However, if the refinancing doesn't occur, we may affirm our
ratings on the original debt and 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 replacement class A-1-R, A-2-R, B-R, C-1A-R, C-1B-R, and
D-R debt are expected to be issued at a floating spread.

-- The replacement class C-2-R debt is expected to be issued at a
fixed spread.

-- A new non-call period will be established, which will expire on
but exclude Oct. 15, 2026.

-- The stated maturity will be extended for 5.25 years to October
2039 and the reinvestment period will be extended for 3.25 years to
October 2029.

-- Additional subordinated notes are expected to be issued in
connection with this refinancing.

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

  RR 32 Ltd./RR 32 LLC

  Class A-1-R, $310.00 million: AAA (sf)
  Class A-2-R, $65.00 million: AA (sf)
  Class B-R (deferrable), $35.00 million: A (sf)
  Class C-1A-R (deferrable), $25.00 million: BBB (sf)
  Class C-1B-R (deferrable), $5.00 million: BBB- (sf)
  Class C-2-R (deferrable), $5.00 million: BBB- (sf)
  Class D-R (deferrable), $15.00 million: BB- (sf)

  Other Debt

  RR 32 Ltd./RR 32 LLC

  Subordinated notes(i), $65.42 million: Not rated

(i)Includes $40.75 million of subordinated notes issued on the May
27, 2021, original closing date.



SEQUOIA MORTGAGE 2024-10: Fitch Assigns B+(EXP) Rating on B5 Certs
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings to the residential
mortgage-backed certificates to be issued by Sequoia Mortgage Trust
2024-10 (SEMT 2024-10).

   Entity/Debt      Rating           
   -----------      ------           
SEMT 2024-10

   A1           LT AAA(EXP)sf  Expected Rating
   A2           LT AAA(EXP)sf  Expected Rating
   A3           LT AAA(EXP)sf  Expected Rating
   A4           LT AAA(EXP)sf  Expected Rating
   A5           LT AAA(EXP)sf  Expected Rating
   A6           LT AAA(EXP)sf  Expected Rating
   A7           LT AAA(EXP)sf  Expected Rating
   A8           LT AAA(EXP)sf  Expected Rating
   A9           LT AAA(EXP)sf  Expected Rating
   A10          LT AAA(EXP)sf  Expected Rating
   A11          LT AAA(EXP)sf  Expected Rating
   A12          LT AAA(EXP)sf  Expected Rating
   A13          LT AAA(EXP)sf  Expected Rating
   A14          LT AAA(EXP)sf  Expected Rating
   A15          LT AAA(EXP)sf  Expected Rating
   A16          LT AAA(EXP)sf  Expected Rating
   A17          LT AAA(EXP)sf  Expected Rating
   A18          LT AAA(EXP)sf  Expected Rating
   A19          LT AAA(EXP)sf  Expected Rating
   A20          LT AAA(EXP)sf  Expected Rating
   A21          LT AAA(EXP)sf  Expected Rating
   A22          LT AAA(EXP)sf  Expected Rating
   A23          LT AAA(EXP)sf  Expected Rating
   A24          LT AAA(EXP)sf  Expected Rating
   A25          LT AAA(EXP)sf  Expected Rating
   AIO1         LT AAA(EXP)sf  Expected Rating
   AIO2         LT AAA(EXP)sf  Expected Rating
   AIO3         LT AAA(EXP)sf  Expected Rating
   AIO4         LT AAA(EXP)sf  Expected Rating
   AIO5         LT AAA(EXP)sf  Expected Rating
   AIO6         LT AAA(EXP)sf  Expected Rating
   AIO7         LT AAA(EXP)sf  Expected Rating
   AIO8         LT AAA(EXP)sf  Expected Rating
   AIO9         LT AAA(EXP)sf  Expected Rating
   AIO10        LT AAA(EXP)sf  Expected Rating
   AIO11        LT AAA(EXP)sf  Expected Rating
   AIO12        LT AAA(EXP)sf  Expected Rating
   AIO13        LT AAA(EXP)sf  Expected Rating
   AIO14        LT AAA(EXP)sf  Expected Rating
   AIO15        LT AAA(EXP)sf  Expected Rating
   AIO16        LT AAA(EXP)sf  Expected Rating
   AIO17        LT AAA(EXP)sf  Expected Rating
   AIO18        LT AAA(EXP)sf  Expected Rating
   AIO19        LT AAA(EXP)sf  Expected Rating
   AIO20        LT AAA(EXP)sf  Expected Rating
   AIO21        LT AAA(EXP)sf  Expected Rating
   AIO22        LT AAA(EXP)sf  Expected Rating
   AIO23        LT AAA(EXP)sf  Expected Rating
   AIO24        LT AAA(EXP)sf  Expected Rating
   AIO25        LT AAA(EXP)sf  Expected Rating
   AIO26        LT AAA(EXP)sf  Expected Rating
   AIOS         LT NR(EXP)sf   Expected Rating
   B1           LT AA(EXP)sf   Expected Rating
   B1A          LT AA(EXP)sf   Expected Rating
   B1X          LT AA(EXP)sf   Expected Rating
   B2           LT A(EXP)sf    Expected Rating
   B2A          LT A(EXP)sf    Expected Rating
   B2X          LT A(EXP)sf    Expected Rating
   B3           LT BBB(EXP)sf  Expected Rating
   B4           LT BB(EXP)sf   Expected Rating
   B5           LT B+(EXP)sf   Expected Rating
   B6           LT NR(EXP)sf   Expected Rating

Transaction Summary

The certificates are supported by 313 loans with a total balance of
approximately $375.0 million as of the cutoff date. The pool
consists of prime jumbo fixed-rate mortgages acquired by Redwood
Residential Acquisition Corp. from various mortgage originators.
Distributions of principal and interest (P&I) and loss allocations
are based on a senior-subordinate, shifting-interest structure.

KEY RATING DRIVERS

High-Quality Mortgage (QM) Pool (Positive): The collateral consists
of 313 loans, totaling $375.0 million, and seasoned approximately
two months in aggregate. The borrowers have a strong credit profile
(775 FICO and 36.3% debt-to-income) and a moderate leverage (80.0%
sustainable loan-to-value). The pool consists of 93.9% of loans
where the borrower maintains a primary residence, while 6.1% is
second home. Additionally, 75.2% of the loans were originated
through a retail channel, and 99.1% are designated as QM loan.

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 9.6% 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 4.9% YoY nationally as of July 2024 despite modest
regional declines, but are still being supported by limited
inventory.

Shifting-Interest Structure with Full Advancing (Mixed): The
mortgage cash flow and loss allocation are based on a
senior-subordinate, shifting-interest structure, whereby the
subordinate classes receive only scheduled principal and are locked
out from receiving unscheduled principal or prepayments for five
years.

The lockout feature helps maintain subordination for a longer
period should losses occur later in the life of the transaction.
The applicable credit support percentage feature redirects
subordinate principal to classes of higher seniority if specified
credit enhancement (CE) levels are not maintained.

After the credit support depletion date, principal will be
distributed sequentially to the senior classes, which is more
beneficial for the super-senior classes (A-9, A-12 and A-18).

SEMT 2024-10 will feature the servicing administrator (RRAC),
following initial reductions in the class A-IO-S strip and
servicing administrator fees, obligated to advance delinquent P&I
to the trust until deemed non-recoverable. Full advancing of P&I is
a common structural feature across prime transactions in providing
liquidity to the certificates and absent the full advancing, bonds
can be vulnerable to missed payments during periods of adverse
performance.

CE Floor (Positive): A CE or senior subordination floor of 1.25%
has been considered to mitigate potential tail-end risk and loss
exposure for senior tranches as the pool size declines and
performance volatility increases due to adverse loan selection and
small loan count concentration.

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 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%, 20% and 30%, in addition to the
model-projected 41.2% at 'AAAsf'. The analysis indicates there is
some potential rating migration with higher MVDs compared to the
model projection. Specifically, a 10% additional decline in home
prices would lower all rated classes by one full category.

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

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

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'.

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 Clayton and SitusAMC. The third-party due diligence
described in Form 15E focused on credit, compliance, and property
valuation. Fitch considered this information in its analysis and,
as a result, Fitch made the following adjustment(s) to its
analysis: a 5% reduction in its loss analysis. This adjustment
resulted in a 24bp reduction to the 'AAAsf' expected loss.

ESG Considerations

SEMT 2024-10 has an ESG Relevance Score of '4' for Transaction
Parties & Operational Risk. Operational risk is well controlled for
in SEMT 2024-10 and includes strong R&W and transaction due
diligence as well as a strong aggregator, which resulted in a
reduction in the expected losses. This has a positive 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.


SIERRA TIMESHARE 2024-3: Fitch Gives BB-(EXP) Rating on D Notes
---------------------------------------------------------------
Fitch Ratings has assigned expected ratings and Rating Outlooks to
notes issued by Sierra Timeshare 2024-3 Receivables Funding LLC
(Sierra 2024-3).

The notes are backed by a pool of fixed-rate timeshare loans
originated by Wyndham Vacation Resorts, Inc. (WVRI) and the Wyndham
Resort Development Corporation (WRDC). Both entities are indirect,
wholly owned operating subsidiaries of Travel + Leisure Co. (T+L,
formerly Wyndham Destinations, Inc.). This is T+L's 50th public
Sierra transaction.

   Entity/Debt           Rating           
   -----------           ------           
Sierra Timeshare
2024-3 Receivables
Funding LLC

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

KEY RATING DRIVERS

Borrower Risk — Consistent Credit Quality: Approximately 66.8% of
Sierra 2024-3 consists of WVRI-originated loans. The remainder of
the pool comprises WRDC loans. Fitch has determined that, on a
like-for-like FICO basis, WRDC's receivables perform better than
WVRI's. The weighted average (WA) original FICO score of the pool
is 738, which is generally consistent with the prior transaction.
The collateral pool has nine months of seasoning and comprises
61.8% of upgraded loans.

Forward-Looking Approach on Rating Case CGD Proxy — Rising CGDs:
Similar to other timeshare originators, T+L's delinquency and
default performance exhibited notable increases in the 2007-2008
vintages before stabilizing in 2009 and thereafter. However, the
2017 through 2022 vintages show increasing gross defaults, tracking
outside of peak levels experienced in 2008. This is partially
driven by increased paid product exits (PPEs).

The 2022-2024 transactions are generally demonstrating weakening
default trends relative to improved performance in 2020-2021
transactions, though trending below the worst-performing 2019
transactions. Fitch's rating case cumulative gross default (CGD)
proxy for the pool is 22.00%, consistent with 2024-2. Given the
current economic environment, default vintages reflecting a
recessionary period were utilized along with more recent vintage
performance, specifically of the 2007-2009 and 2016-2019 vintages.

Structural Analysis — Lower CE: The initial hard credit
enhancement (CE) for the class A, B, C and D notes is 57.90%,
36.60%, 13.10% and 4.50%, respectively. CE is lower for all classes
relative to 2024-2, mainly due to lower overcollateralization (OC)
compared with the prior transaction. Hard CE comprises OC, a
reserve account and subordination. Soft CE is also provided by
excess spread and is expected to be 9.07% per annum. Loss coverage
for all notes is able to support CGD multiples of 3.00x, 2.25x,
1.50x and 1.17x for 'AAAsf', 'Asf', 'BBBsf' and 'BB-sf',
respectively.

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

RATING SENSITIVITIES

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

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

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

The CGD and prepayment sensitivities include 1.5x and 2.0x
increases to the prepayment assumptions, representing moderate and
severe stresses, respectively. These analyses are intended to
provide an indication of the rating sensitivity of the notes to
unexpected deterioration of a trust's performance.

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

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by Deloitte & Touche LLP. The third-party due diligence
described in Form 15E focused on a comparison and recomputation of
certain characteristics with respect to 155 sample loans. Fitch
considered this information in its analysis and it did not have an
effect on its 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.


SIERRA TIMESHARE 2024-3: S&P Prelim BB (sf) Rating on Cl. D Notes
-----------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Sierra
Timeshare 2024-3 Receivables Funding LLC's timeshare loan-backed
notes.

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

The preliminary ratings are based on information as of Oct. 3,
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 credit enhancement available in the form of subordination,
overcollateralization, a reserve account, and available excess
spread.

-- The transaction's ability on average to withstand breakeven
default levels of 73.38%, 57.80%, 40.71%, and 34.17% for the class
A, B, C, and D notes, respectively, based on S&P's various stressed
cash flow scenarios. These levels are higher than the 3.21x, 2.44x,
1.79x, and 1.45x multiples of its expected cumulative gross
defaults (ECGD) of 20.7% for the class A, B, C, and D notes,
respectively.

-- The transaction's ability to make interest and principal
payments according to the terms of the transaction documents on or
before the legal final maturity date under S&P's rating stresses,
and performance under the credit stability and sensitivity
scenarios at their respective rating levels.

-- The collateral characteristics of the series' timeshare loans,
S&P's view of the credit risk of the collateral, and its updated
macroeconomic forecast and forward-looking view of the timeshare
sector.

-- The series' bank accounts at U.S. Bank Trust Co. N.A. and the
reserve account amount to be represented by a letter of credit to
be provided by The Bank of Nova Scotia, which do not constrain the
preliminary ratings.

-- S&P's operational risk assessment of Wyndham Consumer Finance
Inc. (WCF) as servicer, and its views of the company's servicing
ability and experience in the timeshare market.

-- S&P's assessment of the transaction's potential exposure to
environmental, social, and governance (ESG) credit factors.

-- The transaction's payment and legal structures.

  Preliminary Ratings Assigned

  Sierra Timeshare 2024-3 Receivables Funding LLC

  Class A, $147.908 million: AAA (sf)
  Class B, $70.638 million: A (sf)
  Class C, $77.934 million: BBB (sf)
  Class D, $28.520 million: BB (sf)



SIERRA TIMESHARE: Fitch Affirms Ratings on 10 Trusts
----------------------------------------------------
Fitch Ratings has affirmed the ratings of Sierra Timeshare
Receivables Funding Trust series 2020-2, 2021-1, 2021-2, 2022-1,
2022-2, 2022-3, 2023-1, 2023-2, 2023-3, and 2024-1. The Rating
Outlooks on all classes remain Stable.

   Entity/Debt           Rating           Prior
   -----------           ------           -----
Sierra Timeshare
2020-2 Receivables
Funding LLC

   A 826525AA5       LT AAAsf  Affirmed   AAAsf
   B 826525AB3       LT Asf    Affirmed   Asf
   C 826525AC1       LT BBBsf  Affirmed   BBBsf
   D 826525AD9       LT BBsf   Affirmed   BBsf

Sierra Timeshare
2021-1 Receivables
Funding LLC

   A 82652QAA9       LT AAAsf  Affirmed   AAAsf
   B 82652QAB7       LT Asf    Affirmed   Asf
   C 82652QAC5       LT BBBsf  Affirmed   BBBsf
   D 82652QAD3       LT BBsf   Affirmed   BBsf

Sierra Timeshare
2021-2 Receivables
Funding LLC

   A 82652RAA7       LT AAAsf  Affirmed   AAAsf
   B 82652RAB5       LT Asf    Affirmed   Asf
   C 82652RAC3       LT BBBsf  Affirmed   BBBsf
   D 82652RAD1       LT BBsf   Affirmed   BBsf

Sierra Timeshare
2023-2 Receivables
Funding LLC

   A 82650BAA4       LT AAAsf  Affirmed   AAAsf
   B 82650BAB2       LT Asf    Affirmed   Asf
   C 82650BAC0       LT BBBsf  Affirmed   BBBsf
   D 82650BAD8       LT BB-sf  Affirmed   BB-sf

Sierra Timeshare
2022-3 Receivables
Funding LLC

   A 826934AA9       LT AAAsf  Affirmed   AAAsf
   B 826934AB7       LT Asf    Affirmed   Asf
   C 826934AC5       LT BBBsf  Affirmed   BBBsf
   D 826934AD3       LT BB-sf  Affirmed   BB-sf

Sierra Timeshare
2024-1 Receivables
Funding LLC

   A 826935AA6       LT AAAsf  Affirmed   AAAsf
   B 826935AB4       LT Asf    Affirmed   Asf
   C 826935AC2       LT BBBsf  Affirmed   BBBsf
   D 826935AD0       LT BBsf   Affirmed   BBsf

Sierra Timeshare
2022-2 Receivables
Funding LLC

   A 82650TAA5       LT AAAsf  Affirmed   AAAsf
   B 82650TAB3       LT Asf    Affirmed   Asf
   C 82650TAC1       LT BBBsf  Affirmed   BBBsf
   D 82650TAD9       LT BBsf   Affirmed   BBsf

Sierra Timeshare
2023-1 Receivables
Funding LLC

   A 826943AA0       LT AAAsf  Affirmed   AAAsf
   B 826943AB8       LT Asf    Affirmed   Asf
   C 826943AC6       LT BBBsf  Affirmed   BBBsf
   D 826943AD4       LT BB-sf  Affirmed   BB-sf

Sierra Timeshare
2022-1 Receivables
Funding LLC

   A 82652TAA3       LT AAAsf  Affirmed   AAAsf  
   B 82652TAB1       LT Asf    Affirmed   Asf
   C 82652TAC9       LT BBBsf  Affirmed   BBBsf
   D 82652TAD7       LT BBsf   Affirmed   BBsf

Sierra Timeshare
2023-3 Receivables
Funding LLC

   A 826944AA8       LT AAAsf  Affirmed   AAAsf
   B 826944AB6       LT Asf    Affirmed   Asf
   C 826944AC4       LT BBBsf  Affirmed   BBBsf
   D 826944AD2       LT BBsf   Affirmed   BBsf

KEY RATING DRIVERS

The affirmation of the class A, B, C, and D notes, for each
transaction, reflects loss coverage levels consistent with their
current ratings. The Stable Outlooks for all classes of notes
reflect Fitch's expectation that loss coverage levels will remain
supportive of these ratings.

To date, more recent transactions have performed weaker than
Fitch's initial expectations, while transactions preceding 2023-1
are performing slightly better than or in line with initial
expectations. As of the August 2024 collection period, the 61+ day
delinquency rates for 2020-2, 2021-1, 2021-2, 2022-1. 2022-2,
2022-3, 2023-1, 2023-2, 2023-3, and 2024-1 are 1.88%, 1.92%, 2.55%,
2.68%, 3.24%, 2.80%, 2.48%, 2.53%, 2.97%, and 3.41%, respectively.

Cumulative gross defaults (CGD's) are currently at 18.37%, 17.56%,
16.11%, 16.93%, 15.41%, 15.35%, 14.07%, 10.71%, 8.60%, and 5.07%,
respectively. All transactions are currently tracking below their
initial base cases of 22.50%, 22.40%, 21.50%, 22.25%, 22.50%,
23.00%, 22.25%, 22.00%, 22.00%, and 22.00%, respectively. Due to
optional repurchases by the seller, none of the transactions have
experienced a net loss to date.

To account for recent performance, the CGD proxies for 2020-2,
2021-1, 2021-2, 2022-1, 2022-2, and 2022-3 were maintained at
20.00%, 20.00%, 20.00%, 22.00%, 22.00%, and 23.00%, respectively,
given the stable performance trends for these transactions. The CGD
proxy for 2023-1 was increased to 23.50% given its worse
performance. The lifetime proxies of 22.00%, 22.00%, and 22.00% for
2023-2, 2023-3 and 2024-1, respectively, were not changed due to
low seasoning of the pool.

Under Fitch's stressed cash flow assumptions, for the 2020-2,
2021-1, 2021-2, 2022-1, and 2022-2, loss coverages for the class A,
B, C, and D notes are able to support multiples in excess of 3.25x,
2.25x, 1.50x, and 1.25x for 'AAAsf', 'Asf', 'BBBsf', and 'BBsf'
respectively.

For 2022-3 and 2023-1, loss coverages for the class A, class B,
class C, and class D notes are able to support multiples in excess
of 3.25x, 2.25x, 1.50x, and 1.17x for 'AAAsf', 'Asf', 'BBBsf', and
'BB-sf' respectively.

For 2023-2, the class A loss coverage is slightly short of the
3.25x multiple for 'AAAsf' but still within the 3.00-4.50x range;
class B and class C loss coverage is able to support multiples in
excess of the 2.25x and 1.50x multiple for 'Asf' and 'BBBsf'
respectively; class D notes are short of the 1.17x multiple for
'BB-sf' but within the one category tolerance permitted by the
criteria.

For 2023-3, the class A loss coverage is slightly short of the
3.25x multiple for 'AAAsf' but still within the 3.00-4.50x range;
the class B loss coverage is slightly short of the 2.25x multiple
for 'Asf' but still within the 2.00-2.75x range; the class C loss
coverage is able to support multiples in excess of the 1.50x
multiple for 'BBBsf'; however, the current multiples for the class
D notes are short of the 1.25x multiple for 'BBsf', but within the
one category tolerance permitted by the criteria.

For 2024-1, the class A loss coverage is slightly short of the
3.25x multiple for 'AAAsf' but still within the 3.00-4.50x range;
the class B loss coverage is able to support multiple in excess of
the 2.25x multiple for 'Asf'; however, the current multiples for
the class C and class D notes are short of the 1.50x for 'BBBsf'
and 1.25x for 'BBsf' respectively, but within the one category
tolerance permitted by the criteria. The shortfalls are considered
marginal and are still within the range of the multiples for their
current ratings. Additionally, Fitch also accounted for the
seller's optional repurchase activities across all these
transactions, resulting in zero net losses to date.

The ratings also reflect the quality of Travel + Leisure Co.
timeshare receivable originations, the sound financial and legal
structure of the transactions, and the strength of the servicing
provided by Wyndham Consumer Finance, Inc. Fitch will continue to
monitor economic conditions and their impact as they relate to
timeshare asset-backed securities and trust level performance
variables and update the ratings accordingly.

RATING SENSITIVITIES

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

- Unanticipated increases in the frequency of defaults could
produce default levels higher than the current projected rating
case default proxy, and impact available loss coverage and
multiples levels for the transaction;

- Weakening asset performance is strongly correlated to increasing
levels of delinquencies and defaults that could negatively affect
credit enhancement (CE) levels. Lower loss coverage could impact
ratings and Outlooks, depending on the extent of the decline in
coverage.

- In Fitch's initial review of the transactions, the notes were
found to have limited sensitivity to a 1.5x and 2.0x increase of
Fitch's rating case loss expectation. For this review, Fitch
updated the analysis of the impact of a 2.0x increase of the rating
case loss expectation and the results suggest consistent ratings
for the outstanding notes and in the event of such a stress, these
notes could be downgraded by up to three rating categories.

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

- Stable to improved asset performance driven by stable
delinquencies and defaults would lead to increasing CE levels and
consideration for potential upgrades. Fitch applied an up
sensitivity, by reducing the rating case proxy by 20%. The impact
of reducing the proxies by 20% from the current proxies could
result in up to two categories of upgrades or affirmations of
ratings with stronger multiples.

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.


SIXTH STREET XV: S&P Assigns Prelim BB- (sf) 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 and new class
X debt from Sixth Street CLO XV Ltd./Sixth Street CLO XV LLC, a CLO
originally issued in 2020 as TICP CLO XV Ltd. that is managed by
Sixth Street CLO XV Management LLC.

The preliminary ratings are based on information as of Oct. 9,
2024. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

On the Oct. 10, 2024, refinancing date, the proceeds from the
replacement debt will be used to redeem the class A, B, C, D, and E
debt. S&P said, "At that time, we expect to withdraw our ratings on
the original debt assign ratings to the replacement debt. However,
if the refinancing doesn't occur, we may affirm our ratings on the
original debt and withdraw our preliminary ratings on the
replacement debt."

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

-- The stated maturity and reinvestment period will be extended
approximately 4.5 years.

-- The non-call period will be reestablished and is expected to
end in December 2026.

-- Class X notes will be issued in connection with this
refinancing. These notes are expected to be paid down using
interest proceeds during the first seven payment dates beginning
with the payment date in January 2025.

-- The class D notes are being replaced with the sequential class
D-1-R and D-2-R notes, which are both expected to be
floating-rate.

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

  Sixth Street CLO XV Ltd./Sixth Street CLO XV LLC

  Class X, $2.00 million: AAA (sf)
  Class A-R, $265.65 million: AAA (sf)
  Class B-R, $57.35 million: AA (sf)
  Class C-R (deferrable), $25.50 million: A (sf)
  Class D-1-R (deferrable), $25.50 million: BBB- (sf)
  Class D-2-R (deferrable), $2.75 million: BBB- (sf)
  Class E-R (deferrable), $13.85 million: BB- (sf)

  Other Debt

  Sixth Street CLO XV Ltd./Sixth Street CLO XV LLC

  Subordinated notes, $42.90 million: Not rated



TCW CLO 2018-1: Fitch Assigns 'BB-sf' Rating on Class E-R3 Notes
----------------------------------------------------------------
Fitch Ratings has assigned ratings and Rating Outlooks to TCW CLO
2018-1, Ltd.'s reset transaction.

   Entity/Debt             Rating               Prior
   -----------             ------               -----
TCW CLO 2018-1 Ltd.

   A-2a 87240UAB6      LT PIFsf  Paid In Full   AAAsf
   A-2b-RR 87240UAT7   LT PIFsf  Paid In Full   AAAsf
   A-R3                LT AAAsf  New Rating
   A1-R 87240UAR1      LT PIFsf  Paid In Full   AAAsf
   B-R3                LT AAsf  New Rating
   C-R3                LT Asf  New Rating
   D-1R3               LT BBB+sf  New Rating
   D-FR3               LT BBB+sf  New Rating
   D-JR3               LT BBB-sf  New Rating
   E-R3                LT BB-sf  New Rating
   X-R3                LT AAAsf  New Rating

Transaction Summary

TCW CLO 2018-1, Ltd. (the issuer) is an arbitrage cash flow
collateralized loan obligation (CLO) that will be managed by TCW
Asset Management Company LLC. that originally closed in May 2018.
This is the third refinancing and the first where the notes will be
refinanced in whole. Net proceeds from the issuance of the secured
and subordinated notes will provide financing on a portfolio of
approximately $399 million of primarily first lien senior secured
leveraged loans.

KEY RATING DRIVERS

Asset Credit Quality (Negative): The average credit quality of the
indicative portfolio is 'B'/'B-', which is in line with that of
recent CLOs. The weighted average rating factor (WARF) of the
indicative portfolio is 24.62, versus a maximum covenant, in
accordance with the initial expected matrix point of 25. Issuers
rated in the 'B' rating category denote a highly speculative credit
quality; however, the notes benefit from appropriate credit
enhancement and standard U.S. CLO structural features.

Asset Security (Positive): The indicative portfolio consists of
97.83% first-lien senior secured loans. The weighted average
recovery rate (WARR) of the indicative portfolio is 76.88% versus a
minimum covenant, in accordance with the initial expected matrix
point of 74%.

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 3.1-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 'AAAsf' for class X-R3, between 'BBB+sf' and 'AA+sf' for
class A-R3L, between 'BB+sf' and 'AA-sf' for class B-R3, between
'BB-sf' and 'A-sf' for class C-R3, between less than 'B-sf' and
'BBB+sf' for class D-1R3, between less than 'B-sf' and 'BBB-sf' for
class D-JR3, and between less than 'B-sf' and 'BBsf' for class
E-R3.

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

Upgrade scenarios are not applicable to the class X-R3 and class
A-R3L 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-R3, 'AA+sf' for class C-R3,
'A+sf' for class D-1R3, 'A+sf' for class D-JR3, 'BBB+sf' for class
E-R3.

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 TCW CLO 2018-1,
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.


TOWD POINT 2024-CES4: Fitch Assigns 'B-sf' Final Rating on B2 Notes
-------------------------------------------------------------------
Fitch Ratings has assigned final ratings to Towd Point Mortgage
Trust 2024-CES4 (TPMT 2024-CES4).

   Entity/Debt        Rating             Prior
   -----------        ------             -----
TPMT 2024-CES4

   A1             LT AAAsf  New Rating   AAA(EXP)sf
   A2             LT AA-sf  New Rating   AA-(EXP)sf
   M1             LT A-sf   New Rating   A-(EXP)sf
   M2             LT BBB-sf New Rating   BBB-(EXP)sf
   B1             LT BB-sf  New Rating   BB-(EXP)sf
   B2             LT B-sf   New Rating   B-(EXP)sf
   B3             LT NRsf   New Rating   NR(EXP)sf
   A2             LT AA-sf  New Rating   AA-(EXP)sf
   A2AX           LT AA-sf  New Rating   AA-(EXP)sf
   A2B            LT AA-sf  New Rating   AA-(EXP)sf
   A2BX           LT AA-sf  New Rating   AA-(EXP)sf
   A2C            LT AA-sf  New Rating   AA-(EXP)sf
   A2CX           LT AA-sf  New Rating   AA-(EXP)sf
   A2D            LT  AA-sf New Rating   AA-(EXP)sf
   A2DX           LT AA-sf  New Rating   AA-(EXP)sf
   M1A            LT A-sf   New Rating   A-(EXP)sf
   M1AX           LT A-sf   New Rating   A-(EXP)sf
   M1B            LT A-sf   New Rating   A-(EXP)sf
   M1BX           LT A-sf   New Rating   A-(EXP)sf
   M1C            LT A-sf   New Rating   A-(EXP)sf
   M1CX           LT A-sf   New Rating   A-(EXP)sf
   M1D            LT A-sf   New Rating   A-(EXP)sf
   M1DX           LT A-sf   New Rating   A-(EXP)sf
   M2A            LT BBB-sf New Rating   BBB-(EXP)sf
   M2AX           LT BBB-sf New Rating   BBB-(EXP)sf
   M2B            LT BBB-sf New Rating   BBB-(EXP)sf
   M2BX           LT BBB-sf New Rating   BBB-(EXP)sf
   M2C            LT BBB-sf New Rating   BBB-(EXP)sf
   M2CX           LT BBB-sf New Rating   BBB-(EXP)sf
   M2D            LT BBB-sf New Rating   BBB-(EXP)sf
   M2DX           LT BBB-sf New Rating   BBB-(EXP)sf
   B1A            LT BB-sf  New Rating   BB-(EXP)sf
   B1AX           LT BB-sf  New Rating   BB-(EXP)sf
   B1B            LT BB-sf  New Rating   BB-(EXP)sf
   B1BX           LT BB-sf  New Rating   BB-(EXP)sf
   AX             LT NRsf   New Rating   NR(EXP)sf
   XS1            LT NRsf   New Rating   NR(EXP)sf
   XS2            LT NRsf   New Rating   NR(EXP)sf
   X              LT NRsf   New Rating   NR(EXP)sf
   R              LT NRsf   New Rating   NR(EXP)sf

Transaction Summary

Following the publication of Fitch's presale and expected ratings,
the issuer provided a post-pricing structure with final bond
coupons and adjusted bond balances due to lower rates, resulting in
reduced credit enhancement. Fitch re-ran its cashflow analysis and
confirmed no changes from the expected to final ratings for each
tranche.

The bond sizes in this rating action commentary reflect the final,
closing bond sizes. The remainder of the commentary reflects the
data as of the statistical calculation date.

The TPMT 2024-CES4 transaction is expected to close on Sept. 27,
2024. The notes are supported by 5,188 newly originated, closed-end
second lien (CES) loans with a total balance of $404 million as of
the statistical calculation date.

Spring EQ, LLC (Spring EQ), Nationstar Mortgage LLC dba Mr. Cooper
(Nationstar) and PennyMac Loan Services, LLC (PennyMac) originated
approximately 55%, 24% and 21% of the loans, respectively.
Shellpoint Mortgage Servicing (SMS), PennyMac and Nationstar will
service the loans. The servicers will advance delinquency (DQ)
monthly payments of principal and interest (P&I) for up to 60 days
(under the Office of Thrift Supervision [OTS] methodology) or until
deemed nonrecoverable.

Distributions of P&I and loss allocations are based on a
traditional senior-subordinate, sequential structure. The
sequential-pay structure locks out principal to the subordinated
notes until the most senior notes outstanding are paid in full.
Excess cash flow can be used to repay losses or net weighted
average coupon (WAC) shortfalls. In addition, the structure
includes a senior interest only (IO) class, which represents a
senior interest strip of 1.50%, with such interest strip
entitlement being senior to the net interest amounts paid to the
P&I certificates.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): Due to an updated view
on sustainable home prices, Fitch views the home price values of
this pool as 11.7% above a long-term sustainable level, compared
with 11.5% on a national level as of 1Q24, up 0.4% qoq. Housing
affordability is at its worst levels in decades, driven by 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.

Closed-End Second Liens (Negative): The entirety of the collateral
pool comprises newly originated CES mortgages. Fitch assumed no
recovery and 100% loss severity (LS) on second lien loans 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.

Strong Credit Quality (Positive): The pool consists of
new-origination CES loans, seasoned at approximately six months (as
calculated by Fitch), with a relatively strong credit profile — a
weighted average (WA) model credit score of 732, a 39%
debt-to-income ratio (DTI) and a moderate sustainable loan-to-value
ratio (sLTV) of 81%.

Roughly 98% of the loans were treated as full documentation in
Fitch's analysis. Approximately 66% of the loans were originated
through a retail channel.

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

With respect to any loan that becomes DQ for 150 days or more under
the OTS methodology, the related servicer will review, and may
charge off, such loan with the approval of the asset manager, based
on an equity analysis review performed by the servicer, causing the
most subordinated class to be written down. Fitch views the
writedown feature positively, despite the 100% LS assumed for each
defaulted second lien loan, as cash flows will not be needed to pay
timely interest to the 'AAAsf' rated notes during loan resolution
by the servicers. In addition, subsequent recoveries realized after
the writedown at 150 days DQ (excluding forbearance mortgage or
loss mitigation loans) will be passed on to bondholders as
principal.

The structure does not allocate excess cashflow to turbo down the
bonds but includes a step-up coupon feature whereby the fixed
interest rate for classes A1, A2 and M1 will increase by 100 bps,
subject to the net WAC, after four years.

In addition, the structure includes a senior IO class certificate
(class AX), which represents a senior interest strip of 1.50% per
annum based off the related mortgage rate of each mortgage loan,
with such interest strip entitlement being senior to the net
interest amounts paid to the notes and paid at the top of the
waterfall. Given that it is a strip-off of the entire collateral
balance and accrual amounts will be reduced by any losses on the
collateral pool, class AX cannot be rated by Fitch.

Overall, in contrast to earlier TPMT CES transactions, this
transaction has less excess spread available and its application
offers diminished support to the rated classes, requiring a higher
level of credit enhancement (CE).

Separately, while Fitch has previously analyzed CES transactions
using an interest rate cut, this stress is not being applied for
this transaction. Given the lack of evidence of interest rate
modifications being used as a loss mitigation tactic, the
application of the stress was overly punitive. If this re-emerges
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.

Limited Servicer P&I Advances (Neutral): The transaction is
structured with three months of servicer advances for DQ P&I.
Structural provisions and cash flow priorities, together with
increased subordination, provide for timely payments of interest to
the 'AAAsf' rated classes. Fitch is indifferent to the advancing
framework since, given its projected 100% LS, no credit would be
given to advances on the structure side and no additional
adjustment would be made in relation to LS.

RATING SENSITIVITIES

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

This defined negative rating sensitivity analysis shows 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 42.6%, at 'AAAsf'. The analysis indicates there is
some potential rating migration, with higher MVDs for all rated
classes compared with model projections. 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

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by SitusAMC (AMC), Clayton, LLC (Clayton) and Consolidated
Analytics. A third-party due diligence review was completed on 100%
of the loans. The scope, as described in Form 15E, focused on
credit, regulatory compliance and property valuation reviews,
consistent with Fitch criteria for new originations. The results of
the reviews indicated low operational risk.

All except six loans received a final grade of 'A' or 'B'. These
six loans were graded 'C' for credit due to a lower FICO score or
combined loan-to-value (CLTV) ratio that was higher than the
guideline thresholds. Either these exceptions were subsequently
cleared or compensating factors were considered. The lower FICO
score and higher CLTV ratio were reported in the tape and
incorporated into Fitch's analysis. Fitch applied a credit for the
high percentage of loan-level due diligence, which reduced the
'AAAsf' loss expectation by 91bps.

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.


TOWD POINT 2024-CES5: Fitch Assigns 'B-(EXP)sf' Rating on B2 Notes
------------------------------------------------------------------
Fitch Ratings has assigned expected ratings to Towd Point Mortgage
Trust 2024-CES5 (TPMT 2024-CES5).

   Entity/Debt       Rating           
   -----------       ------           
TPMT 2024-CES5

   A1            LT AAA(EXP)sf  Expected Rating
   A2            LT AA-(EXP)sf  Expected Rating
   M1            LT A-(EXP)sf   Expected Rating
   M2            LT BBB-(EXP)sf Expected Rating
   B1            LT BB-(EXP)sf  Expected Rating
   B2            LT B-(EXP)sf   Expected Rating
   B3            LT NR(EXP)sf   Expected Rating
   A2A           LT AA-(EXP)sf  Expected Rating
   A2AX          LT AA-(EXP)sf  Expected Rating
   A2B           LT AA-(EXP)sf  Expected Rating
   A2BX          LT AA-(EXP)sf  Expected Rating
   A2C           LT AA-(EXP)sf  Expected Rating
   A2CX          LT AA-(EXP)sf  Expected Rating
   A2D           LT AA-(EXP)sf  Expected Rating
   A2DX          LT AA-(EXP)sf  Expected Rating
   M1A           LT A-(EXP)sf   Expected Rating
   M1AX          LT A-(EXP)sf   Expected Rating
   M1B           LT A-(EXP)sf   Expected Rating
   M1BX          LT A-(EXP)sf   Expected Rating
   M1C           LT A-(EXP)sf   Expected Rating
   M1CX          LT A-(EXP)sf   Expected Rating
   M1D           LT A-(EXP)sf   Expected Rating
   M1DX          LT A-(EXP)sf   Expected Rating
   M2A           LT BBB-(EXP)sf Expected Rating
   M2AX          LT BBB-(EXP)sf Expected Rating
   M2B           LT BBB-(EXP)sf Expected Rating
   M2BX          LT BBB-(EXP)sf Expected Rating
   M2C           LT BBB-(EXP)sf Expected Rating
   M2CX          LT BBB-(EXP)sf Expected Rating
   M2D           LT BBB-(EXP)sf Expected Rating
   M2DX          LT BBB-(EXP)sf Expected Rating
   B1A           LT BB-(EXP)sf  Expected Rating
   B1AX          LT BB-(EXP)sf  Expected Rating
   B1B           LT BB-(EXP)sf  Expected Rating
   B1BX          LT BB-(EXP)sf  Expected Rating
   AX            LT NR(EXP)sf   Expected Rating
   XS1           LT NR(EXP)sf   Expected Rating
   XS2           LT NR(EXP)sf   Expected Rating
   X             LT NR(EXP)sf   Expected Rating
   R             LT NR(EXP)sf   Expected Rating

Transaction Summary

Fitch expects to rate the residential mortgage-backed notes issued
by Towd Point Mortgage Trust 2024-CES5 (TPMT 2024-CES5), as
indicated above. The transaction is expected to close on Oct. 9,
2024. The notes are supported by 5,436 newly originated, closed-end
second lien (CES) loans with a total balance of $437 million as of
the cutoff date.

Spring EQ, LLC (Spring EQ), PennyMac Loan Services, LLC (PennyMac)
and Nationstar Mortgage LLC dba Mr. Cooper (Nationstar) originated
approximately 58%, 21% and 21% of the loans, respectively.
Shellpoint Mortgage Servicing (SMS), PennyMac and Nationstar will
service the loans. The servicers will advance delinquent (DQ)
monthly payments of P&I for up to 60 days (under the Office of
Thrift Supervision [OTS] methodology) or until deemed
nonrecoverable.

Distributions of P&I and loss allocations are based on a
traditional senior-subordinate, sequential structure. The
sequential-pay structure locks out principal to the subordinated
notes until the most senior notes outstanding are paid in full.
Excess cash flow can be used to repay losses or net weighted
average coupon (WAC) shortfalls. In addition, the structure
includes a senior interest-only (IO) class, which represents a
senior interest strip of 1.50%, with such interest strip
entitlement being senior to the net interest amounts paid to the
P&I certificates.

KEY RATING DRIVERS

Updated Sustainable Home Prices (Negative): Due to an updated view
on sustainable home prices, Fitch views the home price values of
this pool as 11.7% above a long-term sustainable level, compared
with 11.5% on a national level as of 1Q24, up 0.4% qoq. Housing
affordability is at its worst levels in decades, driven by 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.

Closed-End Second Liens (Negative): The entirety of the collateral
pool comprises newly originated CES mortgages. Fitch assumed no
recovery and 100% loss severity (LS) on second lien loans 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.

Strong Credit Quality (Positive): The pool consists of
new-origination CES loans, seasoned at approximately five months
(as calculated by Fitch), with a relatively strong credit profile
— a weighted average (WA) model credit score of 731, a 39%
debt-to-income ratio (DTI) and a moderate sustainable loan-to-value
ratio (sLTV) of 80%. Roughly 97% of the loans were treated as full
documentation in Fitch's analysis. Approximately 64% of the loans
were originated through a retail channel.

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

With respect to any loan that becomes DQ for 150 days or more under
the OTS methodology, the related servicer will review, and may
charge off, such loan with the approval of the asset manager, based
on an equity analysis review performed by the servicer, causing the
most subordinated class to be written down.

Fitch views the writedown feature positively, despite the 100% LS
assumed for each defaulted second lien loan, as cash flows will not
be needed to pay timely interest to the 'AAAsf' rated notes during
loan resolution by the servicers. In addition, subsequent
recoveries realized after the writedown at 150 days DQ (excluding
forbearance mortgage or loss mitigation loans) will be passed on to
bondholders as principal.

The structure does not allocate excess cashflow to turbo down the
bonds but includes a step-up coupon feature whereby the fixed
interest rate for classes A1, A2 and M1 will increase by 100 bps,
subject to the net WAC, after four years.

In addition, the structure includes a senior IO class certificate
(class AX), which represents a senior interest strip of 1.50% per
annum based off the related mortgage rate of each mortgage loan,
with such interest strip entitlement being senior to the net
interest amounts paid to the notes and paid at the top of the
waterfall. Notably, the inclusion of this senior IO class reduces
the collateral WAC and effectively diminishes the excess spread.
Given that it is a strip-off of the entire collateral balance and
accrual amounts will be reduced by any losses on the collateral
pool, class AX cannot be rated by Fitch.

Overall, in contrast to earlier TPMT CES transactions, this
transaction has less excess spread available and its application
offers diminished support to the rated classes, requiring a higher
level of credit enhancement (CE).

Separately, while Fitch has previously analyzed CES transactions
using an interest rate cut, this stress is not being applied for
this transaction. Given the lack of evidence of interest rate
modifications being used as a loss mitigation tactic, the
application of the stress was overly punitive. If this re-emerges
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.

Limited Servicer P&I Advances (Neutral): The transaction is
structured with three months of servicer advances for DQ P&I.
Structural provisions and cash flow priorities, together with
increased subordination, provide for timely payments of interest to
the 'AAAsf' rated classes. Fitch is indifferent to the advancing
framework since, given its projected 100% LS, no credit would be
given to advances on the structure side and no additional
adjustment would be made in relation to LS.

RATING SENSITIVITIES

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

This defined negative rating sensitivity analysis shows how ratings
would react to steeper market value declines (MVDs) at the national
level. The analysis assumes MVDs of 10.0%, 20.0% and 30.0%, in
addition to the model-projected 42.6%, at 'AAAsf'. The analysis
indicates there is some potential rating migration, with higher
MVDs for all rated classes compared with model projections.
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

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

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

Fitch was provided with Form ABS Due Diligence-15E (Form 15E) as
prepared by SitusAMC (AMC) and Clayton, LLC (Clayton). A
third-party due diligence review was completed on 100% of the
loans. The scope, as described in Form 15E, focused on credit,
regulatory compliance and property valuation reviews, consistent
with Fitch criteria for new originations. The results of the
reviews indicated low operational risk with no loans receiving a
final grade of C/D. Fitch applied a credit for the high percentage
of loan-level due diligence, which reduced the 'AAAsf' loss
expectation by 91bps.

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.


UBS COMMERCIAL 2018-C12: Fitch Lowers Rating on 2 Tranches to 'B+'
------------------------------------------------------------------
Fitch Ratings has downgraded six and affirmed 10 classes of UBS
Commercial Mortgage Trust 2018-C12 Commercial Mortgage Pass-Through
Certificates (UBS 2018-C12). Classes A-S B, X-B, C, D and X-D have
been assigned Negative Outlooks following their downgrades.

Fitch has also affirmed 15 classes of UBS Commercial Mortgage Trust
2018-C13 Commercial Mortgage Pass-Through Certificates (UBS
2018-C13). The Outlooks remain Negative on classes D-RR, E-RR, F-RR
and G-RR.

   Entity/Debt          Rating            Prior
   -----------          ------            -----
UBS 2018-C12

   A-2 90353DAV7    LT AAAsf  Affirmed    AAAsf
   A-3 90353DAX3    LT AAAsf  Affirmed    AAAsf
   A-4 90353DAY1    LT AAAsf  Affirmed    AAAsf
   A-5 90353DAZ8    LT AAAsf  Affirmed    AAAsf
   A-S 90353DBC8    LT AAsf   Downgrade   AAAsf
   A-SB 90353DAW5   LT AAAsf  Affirmed    AAAsf
   B 90353DBD6      LT A-sf   Downgrade   AA-sf
   C 90353DBE4      LT BBB-sf Downgrade   A-sf
   D 90353DAC9      LT B+sf   Downgrade   BBBsf
   D-RR 90353DAE5   LT CCCsf  Downgrade   BB-sf
   E-RR 90353DAG0   LT CCsf   Downgrade   B-sf
   F-RR 90353DAJ4   LT CCsf   Downgrade   CCCsf
   G-RR 90353DAL9   LT Csf    Downgrade   CCsf
   X-A 90353DBA2    LT AAAsf  Affirmed    AAAsf
   X-B 90353DBB0    LT A-sf   Downgrade   AA-sf
   X-D 90353DAA3    LT B+sf   Downgrade   BBBsf

UBS 2018-C13

   A-2 90353KAV1    LT AAAsf  Affirmed    AAAsf
   A-3 90353KAX7    LT AAAsf  Affirmed    AAAsf
   A-4 90353KAY5    LT AAAsf  Affirmed    AAAsf  
   A-S 90353KBB4    LT AAAsf  Affirmed    AAAsf
   A-SB 90353KAW9   LT AAAsf  Affirmed    AAAsf
   B 90353KBC2      LT AA-sf  Affirmed    AA-sf
   C 90353KBD0      LT A-sf   Affirmed    A-sf
   D 90353KAC3      LT BBBsf  Affirmed    BBBsf
   D-RR 90353KAE9   LT BBB-sf Affirmed    BBB-sf
   E-RR 90353KAG4   LT BB+sf  Affirmed    BB+sf
   F-RR 90353KAJ8   LT BB-sf  Affirmed    BB-sf
   G-RR 90353KAL3   LT B-sf   Affirmed    B-sf
   X-A 90353KAZ2    LT AAAsf  Affirmed    AAAsf
   X-B 90353KBA6    LT A-sf   Affirmed    A-sf
   X-D 90353KAA7    LT BBBsf  Affirmed    BBBsf

KEY RATING DRIVERS

Performance and 'B' Loss Expectations: UBS 2018-C12: deal-level
'Bsf' rating case losses increased to 9%, up from 7.8% at Fitch's
prior rating action. The transaction has a high concentration of
Fitch Loans of Concern (FLOCs), totaling 17 loans (42.5% of the
pool), including five loans (12.6%) in special servicing.

The downgrades in UBS 2018-C12 reflect higher pool loss
expectations, driven primarily by significantly lower updated
appraisal values since the last rating action for the following
specially serviced loans: Copeland Tower & Stadium Place (2.8%),
Holiday Inn Houston SW - Sugar Land Area (1%) and 24 Hour Fitness -
Cedar Hill (0.6%).

Additionally, credit enhancement (CE) has eroded since the last
rating action due to higher than expected realized losses after the
disposition of Holiday Inn - Matteson. Actual losses on the loan of
$19.5 million reflect a loss severity of 149.7%, $11.5 million
higher than Fitch's expected losses at the last rating action,
which were based on a haircut to an appraised value of $14.7
million.

The Negative Outlooks reflect the potential for downgrades if
expected losses on the specially serviced loans, including the
larger office FLOCs Riverfront Plaza I (6.7%) and Bank of America
Center (1.5%, increase or if additional loans experience
performance declines given the high office concentration in the
pool of 26.6%.

UBS 2018-C13: Deal-level 'Bsf' rating case loss is 5.3% up from
4.7% at Fitch's prior rating action. The transaction has a high
concentration of FLOCs, totaling 14 loans (37.9% of the pool),
including three loans (15.7%) in special servicing.

The affirmations reflect generally stable pool performance and loss
expectations since the prior rating action.

The Negative Outlooks reflect the potential for downgrades given
the high FLOC concentration including five loans in the top 10
(22.1%), including Medtronic Santa Rosa (3%) and Manor Parking
Garage (2.2%), experience further performance declines.

Largest Increases in Loss Expectations: The largest increase in
loss since the prior rating action and largest contributor to
overall pool loss expectations in UBS 2018-C12 is the Copeland
Tower & Stadium Place loan, which is secured by two office
buildings (210,955 sf) located in Arlington. The loan transferred
to special servicing in January 2021 due to payment default and has
been REO since 2022. As of the May 2023 rent roll, Copeland Tower
and Stadium Place were 79.9% and 82.7% occupied respectively.
Fitch's 'Bsf' rating case loss of 66.2% (prior to concentration
add-ons) reflects a stress to the most recent appraised value which
equates to approximately $52 psf. The updated appraisal value is
approximately 50% below the issuance appraisal value and 40% below
the updated appraisal value in 2022.

The second largest increase in loss since the prior rating action
is the 24 Hour Fitness - Cedar Hill loan, which is secured by a
32,880- sf retail property. The loan transferred to special
servicing in January 2021 due to payment default and has been REO
since 2022. The property has been vacant since the sole fitness
tenant vacated after filing for bankruptcy. The servicer has
reported a new lease has been executed to occupy the entire space.
Fitch's 'Bsf' rating case loss of 66.3% (prior to concentration
add-ons) reflect a stress to the most recent appraised value for
$98 psf.

The third largest increase in loss since the prior rating action
and second highest contributor to pool expected losses is the
Holiday Inn Houston SW - Sugar Land Area loan, which is secured by
a 206 key full-service Holiday Inn located in Houston, TX. The loan
transferred to special servicing in in May 2020 due to a franchise
agreement related default and a subsequent request for debt service
relief related to a COVID-related occupancy decline. It is
currently in foreclosure and losses exceeding the current loan
balance are expected due to continued increase in total loan
exposure from advances and fees. Fitch's 'Bsf' rating case loss of
approximately 109% reflects an updated appraisal value which is
less than the outstanding loan amount.

The largest increase in loss since the prior rating action and
largest contributor to overall pool loss expectations in UBS
2018-C13 is the Manor Parking Garage, which is secured by
198,000-sf parking garage, located in Pittsburgh, PA. The loan was
flagged as a FLOC as it is on the servicer's watchlist due to
performance decline as the most recent NCF DSCR Q1 2024 is 1.28x
and the loan was 30 days delinquent as of the August 2024
remittance. Fitch's 'Bsf' rating case loss of 37.9% (prior to
concentration add-ons) reflects a 7.5% stress to YE 2023 NOI, an
11% cap rate and higher probability of default given the past loan
delinquency.

The second largest increase in loss since the prior rating action
is the Medtronic Santa Rosa loan, which is secured by a 126,585-sf
sf suburban office property located in Santa Rosa, CA. The property
is 100% occupied by Medtronic Vascular, a subsidiary of Medtronic,
Inc. (NYSE: MDT), which is a global leader in medical technology,
solutions and services, and the largest medical device manufacturer
in the world. The loan was flagged as a FLOC due to the tenant
providing notice to vacate at its March 31, 2025 lease expiration.

The loan is structured with a full cash sweep 12-months prior to
lease expiration. As of September 2024, the rollover reserves
totaled approximately $726,000. Fitch submitted an inquiry
requesting an update on the leasing strategy but did not receive a
response. Fitch's 'Bsf' rating case loss of 14.8% (prior to
concentration add-ons) reflects a 50% stress to YE 2023 NOI and an
10.25% cap rate.

The third largest increase in loss since the prior rating action is
Fort Wayne Hotel Portfolio (2.6%), which is secured by a portfolio
consisting of two hotel properties located in Fort Wayne, ID.
Hilton Garden Inn is an 84 key select service hotel property and
Homewood Suites is a 74 key extended stay hotel property. The loan
was flagged as FLOC due to declining cashflow. As of TTM March
2024, occupancy and NOI DSCR were 73% and 1.09x respectively,
compared to 75% and 1.40x at YE 2023. Fitch's 'Bsf' rating case
loss of 13.3% (prior to concentration add-ons) reflects TTM March
2024 NOI and an 11.5% cap rate.

Updated CE: As of the August 2024 remittance report, the aggregate
balances of the UBS 2018-C12 and UBS 2018-C13 transactions have
been reduced by 15.8% and 18.6%, respectively, since issuance. Each
transaction has 9.1% in defeasance. Cumulative interest shortfalls
for the UBS 2018-C12 are $4.3 million and affect classes F-RR, G-RR
and NR-RR; realized losses total $19.7 million, the majority of
which are due to the aforementioned Holiday Inn - Matteson.
Cumulative interest shortfalls for the UBS 2018-C13 are $428,000,
affecting the non-rated class NR-RR; there have been no realized
losses to date.

RATING SENSITIVITIES

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

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

Downgrades to classes rated in 'AAsf', 'Asf' and 'BBBsf'
categories, especially those which have Negative Outlooks, are
likely with lack of performance stabilization of the FLOCs and/or
prolonged workouts and valuation declines of the loans in special
servicing. These FLOCs include Copeland Tower & Stadium Place,
Holiday Inn Houston SW - Sugar Land Area and 24 Hour Fitness -
Cedar Hill in UBS 2018-C12; and Medtronic Santa Rosa, Fort Wayne
Hotel Portfolio and Manor Parking Garage in UBS 2018-C13.

Downgrades to classes in the 'BBsf' and 'Bsf' rated categories are
likely with higher than expected losses from continued
underperformance of the FLOCs, particularly the aforementioned
office and mixed-use FLOCs with deteriorating performance and/or
with greater certainty of losses on the specially serviced loans or
other FLOCs.

Downgrades to distressed ratings would occur with a greater
certainty of losses and/or as losses are realized.

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 paydowns and/or
defeasance, coupled with improved deal-level loss expectations and
sustained performance improvement and stabilization on the FLOCs.
These FLOCs include Copeland Tower & Stadium Place, Holiday Inn
Houston SW - Sugar Land Area and 24 Hour Fitness - Cedar Hill in
UBS 2018-C12; and Medtronic Santa Rosa, Fort Wayne Hotel Portfolio
and Manor Parking Garage in UBS 2018- C13.

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', 'Bsf', 'CCCsf', 'CCsf' and 'Csf' category
rated classes are not likely, but would be possible in the later
years in a transaction if the performance of the remaining pool is
stable, recoveries and/or valuations on the FLOCs are better than
expected and there is sufficient CE to the classes.

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.


UBS COMMERCIAL 2019-C18: Fitch Affirms B-sf Rating on Two Tranches
------------------------------------------------------------------
Fitch Ratings has affirmed all ratings in UBS Commercial Mortgage
Trust 2019-C17 Commercial Mortgage Pass-Through Certificates,
Series 2019-C17 (UBS 2019-C17).

Fitch has also affirmed all classes in UBS Commercial Mortgage
Trust 2019-C18 Commercial Mortgage Pass-Through Certificates Series
2019-C18 (UBS 2019-C18). The Rating Outlooks for classes A-S, B, C,
D, E, X-B and X-D were revised to Negative from Stable.

   Entity/Debt          Rating               Prior
   -----------          ------               -----
UBS 2019-C18

   A-1 90278PAW0    LT AAAsf  Affirmed       AAAsf
   A-2 90278PAX8    LT AAAsf  Affirmed       AAAsf
   A-3 90278PAZ3    LT AAAsf  Affirmed       AAAsf
   A-4 90278PBA7    LT AAAsf  Affirmed       AAAsf
   A-S 90278PBD1    LT AAAsf  Affirmed       AAAsf
   A-SB 90278PAY6   LT AAAsf  Affirmed       AAAsf
   B 90278PBE9      LT AA-sf  Affirmed       AA-sf
   C 90278PBF6      LT A-sf   Affirmed       A-sf
   D 90278PAG5      LT BBBsf  Affirmed       BBBsf
   E 90278PAJ9      LT BBB-sf Affirmed       BBB-sf
   F 90278PAL4      LT BB-sf  Affirmed       BB-sf
   G 90278PAN0      LT B-sf   Affirmed       B-sf
   X-A 90278PBB5    LT AAAsf  Affirmed       AAAsf
   X-B 90278PBC3    LT AA-sf  Affirmed       AA-sf
   X-D 90278PAA8    LT BBB-sf Affirmed       BBB-sf
   X-F 90278PAC4    LT BB-sf  Affirmed       BB-sf
   X-G 90278PAE0    LT B-sf   Affirmed       B-sf

UBS 2019-C17

   A-1 90278MAW7    LT PIFsf  Paid In Full   AAAsf
   A-2 90278MAX5    LT PIFsf  Paid In Full   AAAsf
   A-3 90278MAZ0    LT AAAsf  Affirmed       AAAsf
   A-4 90278MBA4    LT AAAsf  Affirmed       AAAsf
   A-S 90278MBD8    LT AAAsf  Affirmed       AAAsf
   A-SB 90278MAY3   LT AAAsf  Affirmed       AAAsf
   B 90278MBE6      LT AA-sf  Affirmed       AA-sf
   C 90278MBF3      LT A-sf   Affirmed       A-sf
   D 90278MAG2      LT BBBsf  Affirmed       BBBsf
   E 90278MAJ6      LT BBB-sf Affirmed       BBB-sf
   F 90278MAL1      LT BBsf   Affirmed       BBsf
   G 90278MAN7      LT Bsf    Affirmed       Bsf
   X-A 90278MBB2    LT AAAsf  Affirmed       AAAsf
   X-B 90278MBC0    LT A-sf   Affirmed       A-sf
   X-D 90278MAA5    LT BBB-sf Affirmed       BBB-sf
   X-F 90278MAC1    LT BBsf   Affirmed       BBsf
   X-G 90278MAE7    LT Bsf    Affirmed       Bsf

KEY RATING DRIVERS

Performance and 'B' Loss Expectations: UBS 2019-C17: Deal-level
'Bsf' rating case loss is 5.1%, which is in line with the prior
rating action. 11 loans (22.6% of the pool), including three loans
(4.6%) in special servicing have been identified as Fitch Loans of
Concern (FLOCs).

The Negative Outlooks in UBS 2019-C17 reflect the potential for
downgrades with further performance deterioration and/or lack of
stabilization on the FLOCs particularly 600 & 620 National Avenue,
Gateway Tower and Meidinger Tower, all of which are secured by
office properties. Gateway Tower and Meidinger Tower are in special
servicing. Office loans comprise 14.1% of the pool.

UBS 2019-C18: Deal-level 'Bsf' rating case loss is 4.7%, an
increase from 3.8% at Fitch's prior rating action primarily due to
increased losses on the specially serviced Wyndham National Hotel
Portfolio 11 loans (22.3% of the pool), including two loans (6.3%)
in special servicing have been identified as FLOCs.

The Negative Outlooks in UBS 2019-C18 reflect the potential for
downgrades with further performance deterioration and/or lack of
stabilization on the FLOCs including the largest loan, 225 Bush,
and the potential for higher losses on the specially serviced
Wyndham National Hotel Portfolio loan and United Healthcare Office
loan. Office loans comprise 25.2% of the pool.

Largest Increases in Loss Expectations: The largest increase in
loss since the prior rating action and largest contributor to
overall pool loss expectations in UBS 2019-C17 is Meidinger Tower
(1.2%), which transferred to special servicing in August 2023 for
imminent monetary default. The loan is secured by a 26-story office
building totaling 331,054-sf located in Louisville, KY. Many of the
largest tenants at issuance vacated upon their respective lease
expirations in 2023 including Computershare (34% of NRA; October
2023), Mountjoy Chilton Medley (11.3%; May 2023) and River Road
Asset Management (6%; August 2023). As a result, property occupancy
has declined to 36% from 88% at issuance.

A pre-negotiation letter has been signed and the special servicer
is pursuing a consensual receivership/foreclosure action. Fitch
expects significant losses due to the deterioration in performance,
expectation for the loan to become real estate owned (REO) and low
recovery prospects upon liquidation given the lack of demand and
liquidity for office properties. Fitch's 'Bsf' rating case loss
(prior to concentration add-on) of 80.3% reflects a stressed value
of approximately $18 psf.

The second largest increase in loss since the prior rating action
and second largest contributor to overall pool loss expectations is
Gateway Tower (1.8%), which transferred to special servicing in
December 2023 for imminent monetary default. The loan is secured by
a 213,229-sf office property in St. Louis, MO. KMOV-TV Inc (23.6%)
vacated at its December 2023 lease expiration. As result, occupancy
declined to 53% from 86% at YE 2022. Servicer reported NOI DSCR was
1.36x at YE 2023 compared to 3.31x the prior year. Approximately
20% NRA is scheduled to expire within the next two years.

Fitch requested updated financial reports and rent rolls, as well
as a potential resolution strategy but did not receive a response.
Fitch's 'Bsf' rating case loss of 33.4% (prior to concentration
add-ons) reflects a 25% stress to YE 2023 NOI due to upcoming
rollover risk, a 10% cap rate and an increased probability of
default.

The largest increase in loss since the prior rating action and
largest contributor to overall pool loss expectations in UBS
2019-C18 is Wyndham National Hotel Portfolio (4.3%), which is
secured by a 44-property portfolio totaling 3,729 keys comprised of
limited service hotels located across 23 states: 27 Travelodges, 14
Baymont Inn & Suites, two Super 8s, and one Days Inn. The loan
transferred to special servicing in April 2024 due to various
defaults, including but not limited to failure to comply with cash
management. The borrower, Vukota Capital Management Ltd., filed
Chapter 11 bankruptcy in June 2024 and the case is ongoing.

Portfolio occupancy was 58.0% as of March 2024 and the
servicer-reported NOI DSCR was 1.87x for the same period compared
to 55% and 1.73x, respectively, at YE 2022. The loan reported a
total of $11.4 million ($3,069 per key) in reserves as of the
August 2024 loan level reserve report.

Fitch's 'Bsf' rating case loss of 25.3% (prior to a concentration
adjustment) is based on a 13.5% cap rate and Fitch issuance net
cash flow (NCF), and factors in an increased probability of default
due to the recent transfer to special servicing and borrower
bankruptcy.

Minimal Increase in Credit Enhancement (CE): As of the September
2024 distribution date, the aggregate balances of the UBS 2019-C17
and UBS 2019-C18 transactions have been reduced by 4.9% and 3.7%,
respectively, since issuance. Five loans (5.9%) have been defeased
in UBS 2019-C17 and two loans (1.9%) in UBS 2019-C18.

Interest Shortfalls: To date, the UBS 2019-C17 and UBS 2019-C18
transactions have not incurred any realized principal losses.
Interest shortfalls totaling $726,484 are impacting the risk
retention class, class VRRI and class NR-RR in the UBS 2019-C17
transaction, and interest shortfalls totaling $217,680 are
impacting the risk retention class VRR and class NR-RR in the UBS
2019-C18 transaction.

RATING SENSITIVITIES

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

Downgrades to the 'AAAsf' rated classes with Stable Outlooks are
not likely due to their position in the capital structure and
expected continued amortization and loan repayments. However,
downgrades could occur if deal-level losses increase significantly
and/or interest shortfalls occur or are expected to occur.
Downgrades to 'AAAsf' rated classes with Negative Outlooks are
possible with continued performance and/or valuation deterioration
of the FLOCs.

Downgrades to classes rated in 'AAsf', 'Asf' and 'BBBsf'
categories, especially those which have Negative Outlooks, are
likely with lack of performance stabilization of the FLOCs and/or
prolonged workouts and valuation declines of the loans in special
servicing. These FLOCs include 600 & 620 National Drive, Gateway
Tower and Meidinger Tower in UBS 2019-C17; and 225 Bush, United
Healthcare Office and Wyndham National Hotel Portfolio in UBS
2019-C18.

Downgrades to classes in the 'BBsf' and 'Bsf' rated categories are
likely with higher than expected losses from continued
underperformance of the FLOCs, particularly the aforementioned
office and FLOCs with deteriorating performance and/or with greater
certainty of losses on the specially serviced loans or other
FLOCs.

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 paydowns and/or
defeasance, coupled with improved deal-level loss expectations and
sustained performance improvement and stabilization on the FLOCs.
These FLOCs include 600 & 620 National Drive, Gateway Tower and
Meidinger Tower in UBS 2019-C17; and 225 Bush and Wyndham National
Hotel Portfolio in UBS 2019-C18.

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 would be possible in the later years in a transaction
if the performance of the remaining pool is stable, recoveries
and/or valuations on the FLOCs are better than expected and there
is sufficient CE to the classes.

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.


VERUS SECURITIZATION 2024-8: S&P Assigns Prelim B (sf) on B-2 Notes
-------------------------------------------------------------------
S&P Global Ratings assigned its preliminary ratings to Verus
Securitization Trust 2024-8's mortgage-backed notes.

The note issuance is an RMBS transaction backed primarily by newly
originated first- and second-lien, fixed- and adjustable-rate
residential mortgage loans, including mortgage loans with initial
interest-only periods, to both prime and non-prime borrowers. The
loans are secured by single-family residences, planned-unit
developments, two- to four-family residential properties,
condominiums, condotels, townhouses, mixed-use properties, and
five- to 10-unit multifamily residences. The pool has 1,229 loans
backed by 1,233 properties, which are QM/non-HPML (safe harbor), QM
rebuttable presumption, non-QM/ATR-compliant, and ATR-exempt loans.
Of the 1,229 loans, two loans are cross-collateralized loan backed
by six properties.

The preliminary ratings are based on information as of Oct. 7,
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 pool's collateral composition;

-- The transaction's credit enhancement, associated structural
mechanics, representations and warranties (R&W) framework, prior
credit events, and geographic concentration;

-- The mortgage aggregator, Invictus Capital Partners (Invictus);
and

-- S&P said, "One key change in our baseline forecast since June
is an acceleration in the pace of monetary policy easing. We
anticipate the Federal Reserve will deliver two more rate cuts of
25 basis points (bps) this year and a total of 225 bps of rate cuts
by year-end 2025--a 75 bps increase from our prior forecast. We
continue to expect real GDP growth to slow from above-trend growth
this year to below-trend growth in 2025, accompanied by a further
rise in the unemployment rate and lower inflation. However, our
probability of a recession starting over the next 12 months remains
unchanged at 25%. With personal consumption still healthy for now,
near-term recession fears appear overblown. Therefore, we maintain
our current market outlook as it relates to the 'B' projected
archetypal foreclosure frequency of 2.50%. This reflects our benign
view of the mortgage and housing markets, as demonstrated through
general national level home price behavior, unemployment rates,
mortgage performance, and underwriting."

  Preliminary Ratings Assigned

  Verus Securitization Trust 2024-8(i)

  Class A-1, $387,298,000: AAA (sf)
  Class A-2, $47,485,000: AA (sf)
  Class A-3, $72,415,000: A (sf)
  Class M-1, $39,769,000: BBB- (sf)
  Class B-1, $15,729,000: BB (sf)
  Class B-2, $19,884,000: B (sf)
  Class B-3, $10,981,598: Not rated
  Class A-IO-S, notional(ii): Not rated
  Class XS, notional(ii): Not rated
  Class R, Not applicable: Not rated

(i)The collateral and structural information reflect the term sheet
dated Oct. 1, 2024; the preliminary ratings address the ultimate
payment of interest and principal. They do not address the payment
of the cap carryover amounts.
(ii)The notional amount will equal the aggregate stated principal
balance of the mortgage loans as of the first day of the related
due period.



VIBRANT CLO IX: Moody's Cuts Rating on $24MM Class D Notes to B1
----------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by Vibrant CLO IX, Ltd.:

US$57,500,000 Class A-2 Senior Secured Floating Rate Notes due 2031
(the "Class A-2 Notes"), Upgraded to Aaa (sf); previously on
December 15, 2023 Upgraded to Aa1 (sf)

US$27,500,000 Class B Secured Deferrable Floating Rate Notes due
2031 (the "Class B Notes"), Upgraded to Aa2 (sf); previously on
August 8, 2018 Definitive Rating Assigned A2 (sf)

Moody's have also downgraded the rating on the following notes:

US$24,000,000 Class D Secured Deferrable Floating Rate Notes due
2031 (the "Class D Notes"), Downgraded to B1 (sf); previously on
September 11, 2020 Confirmed at Ba3 (sf)

Vibrant CLO IX, Ltd., issued in August 2018, 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 July 2023.

A comprehensive review of all credit ratings for the respective
transaction has been conducted during a rating committee.

RATINGS RATIONALE

The upgrade rating actions on the Class A-2 and Class B notes are
primarily a result of deleveraging of the senior notes and an
increase in the transaction's over-collateralization (OC) ratios
since December 2023. Since then, the Class A-1 notes have been paid
down by approximately 44.6% or $129.9 million. Based on Moody's
calculation, the OC ratios for the Class A-2 and Class B notes are
currently 145.19%, and 128.98%, respectively, versus December 2023
levels of 129.87% and 120.38%, respectively.

The downgrade rating action on the Class D notes reflects the
specific risks to the junior notes posed by credit and spread
deterioration observed in the underlying CLO portfolio. Based on
Moody's calculations, the weighted average rating factor (WARF) and
weighted average spread (WAS) have been deteriorating, and are
currently 2974 and 3.28%, respectively, compared to 2912 and 3.40%,
respectively, in December of 2023.

No actions were taken on the Class A-1 and Class C 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: $316,021,547

Defaulted par: $4,862,818

Diversity Score: 53

Weighted Average Rating Factor (WARF): 2974

Weighted Average Spread (WAS): 3.28%

Weighted Average Recovery Rate (WARR): 47.1%

Weighted Average Life (WAL): 3.7 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.


WESTLAKE AUTOMOBILE 2024-3: Fitch Gives BB(EXP) Rating on E Notes
-----------------------------------------------------------------
Fitch Ratings expects to assign ratings and Rating Outlooks to
Westlake Automobile Receivables Trust (WLAKE) 2024-3.

   Entity/Debt           Rating           
   -----------           ------           
Westlake Automobile
Receivables
Trust 2024-3

   A1                ST  F1+(EXP)sf   Expected Rating
   A2A               LT  AAA(EXP)sf   Expected Rating
   A2B               LT  AAA(EXP)sf   Expected Rating
   A3                LT  AAA(EXP)sf   Expected Rating
   B                 LT  AA+(EXP)sf   Expected Rating
   C                 LT  A(EXP)sf     Expected Rating
   D                 LT  BBB(EXP)sf   Expected Rating
   E                 LT  BB(EXP)sf    Expected Rating

KEY RATING DRIVERS

Collateral Performance - Stable Credit Quality: WLAKE 2024-3 is
backed by collateral with subprime credit attributes, with a
weighted average (WA) FICO score of 630, up three points from
2024-2, and an internal WA Westlake score of 4.18, up from 3.96 in
2024-2. WA seasoning is three months, down from six months in
2024-2, and new vehicles total just 2.1% of the pool, in line with
prior transactions. The pool is diverse in vehicle models and state
concentrations. The transaction's percentage of extended-term loans
(61+ months) is at 42.8%, generally in line with recent series.

Forward-Looking Approach to Derive Rating Case Proxy: Fitch
considered economic conditions and future expectations by assessing
key macroeconomic and wholesale market conditions when deriving the
series loss proxy. In recognition of weakening performance in 2022
and 2023 vintage originations, Fitch used the 2006-2009 and
2015-2018 vintage ranges to derive the loss proxy for 2024-3
instead of the 2007-2009 and 2015-2018 vintage range that was used
for 2023-4 to reflect a more conservative assessment of through the
cycle performance. Fitch's CNL rating case proxy for WLAKE 2024-3
is 13.00%, which is reflective of a higher credit quality pool than
2023-4.

Payment Structure — Sufficient Credit Enhancement: Initial hard
credit enhancement (CE) totals 41.55%, 34.05%, 23.40%, 13.90% and
9.50% for classes A, B, C, D and E, respectively. These percentages
are lower compared with both prior 2024 transactions. Excess spread
is expected to be 9.46% per annum. Loss coverage for each class of
notes is sufficient to cover the respective multiples of Fitch's
rating case credit net loss (CNL) proxy of 13.00%.

Operational and Servicing Risks — Consistent
Origination/Underwriting/Servicing: Westlake (not rated by Fitch)
has adequate abilities as the originator, underwriter and servicer,
as evident from historical portfolio and securitization
performance. Fitch deems Westlake as capable to service this
transaction.

Fitch's base-case loss expectation, which does not include a margin
of safety and is not used in Fitch's quantitative analysis to
assign ratings, is 12.00%, based on Fitch's September 2024 Global
Economic Outlook and transaction-based forecast loss projections.

RATING SENSITIVITIES

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

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

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

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

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

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

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 RSM US LLP. The third-party due diligence described in
Form 15E focused on comparing or recomputing certain information
with respect to 150 loans from the statistical data file. Fitch
considered this information in its analysis and it did not have an
effect on Fitch's analysis or conclusions.

ESG Considerations

The concentration of electric and hybrid vehicles in the pool, at
0.39%, did not have an impact on Fitch's ratings analysis or
conclusion for this transaction. As such, it has no impact on
Fitch's ESG Relevance Score.

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.


WFRBS COMMERCIAL 2014-LC14: Fitch Affirms CCC Rating on Cl. F Certs
-------------------------------------------------------------------
Fitch Ratings has affirmed four classes of WFRBS Commercial
Mortgage Trust 2014-LC14 commercial mortgage pass-through
certificates. The Rating Outlooks for classes D, X-B and E remain
Negative.

   Entity/Debt          Rating            Prior
   -----------          ------            -----
WFRBS 2014-LC14

   D 96221TAQ0      LT  BBB-sf  Affirmed   BBB-sf
   E 96221TAS6      LT  Bsf     Affirmed   Bsf
   F 96221TAU1      LT  CCCsf   Affirmed   CCCsf
   X-B 96221TAJ6    LT  BBB-sf  Affirmed   BBB-sf

KEY RATING DRIVERS

Concentrated Pool; Adverse Selection: Due to the concentrated
nature of the pool, Fitch performed a sensitivity and liquidation
analysis, which grouped the remaining six loans based on their
current status and collateral quality to determine the loans'
expected recoveries and losses to assess the outstanding classes'
ratings relative to credit enhancement (CE). A higher probability
of default was assumed for the Fitch Loan of Concern (FLOC)
Canadian Pacific Plaza (27.7% of the pool), which is the only
remaining loan in the pool not specially serviced as of the
September 2024 remittance.

The affirmations and Negative Outlooks reflect the liquidation
analysis and the potential for downgrade given the uncertainty and
timing of recovery of the remaining loans and potential for
prolonged workout timeframes, particularly for loans primarily
secured by office collateral.

Fitch Loans of Concern/Specially Serviced Loans: The largest
contributor to loss expectations is the Canadian Pacific Plaza
loan, which is secured by a 393,902-sf office building located in
the CBD of Minneapolis, MN. Occupancy has remained low since
February 2020 following the lease expiration and vacancy of a major
tenant representing 19.6% of the NRA. Occupancy was reported at 57%
as of YE 2023, down from 62% as of December 2022, 87% as of YE 2019
and 93% as of YE 2018. The only remaining large tenant is Soo Line
Railroad (23.4% NRA, August 2027 lease expiration) with no other
tenant occupying more than 3% of NRA.

The loan passed its anticipated repayment date (ARD) in November
2023. The loan's interest rate increased to 8.18% until the loans
November 2028 final maturity. Additionally, the ARD automatically
triggers a full cash flow sweep where all excess cash flow will be
used to pay down the principal balance of the loan. The property's
NOI declined 73.5% at YE 2023 from the prior year and the YE 2023
NOI DSCR was 0.17x, indicating no excess cashflow.

Fitch's 'Bsf' rating case loss is 52% and incorporates a 10.5% cap
rate and 10% stress to YE 2023 NOI in addition to an assumed higher
probability of default given the property's decline in occupancy
and cash flow.

The second largest contributor to loss expectations, Williams
Center Towers (32.7%), is secured by two office towers totaling
765,809 sf located within the CBD of Tulsa, OK. The loan
transferred to special servicing in April 2018 due to a low DSCR
and was unable to refinance at its February 2024 maturity date. Per
recent servicer commentary, a receiver is expected to be
appointed.

Occupancy as of March 2024 was reported at 70%, a slight increase
from 65% in December 2022 but well below the 91.6% occupancy at
issuance. The largest tenant at issuance, Samson Energy, first
downsized and then completely vacated the building in 2017 after
filing bankruptcy. The property suffered a further occupancy drop
in December 2019 when the Bank of Oklahoma terminated its lease.
The current largest tenants include Community Care HMO (17.1% NRA,
2033 lease expiration), Doerner, Saunders, Daniel and Anderson, LLP
(5.4% NRA, 2027 lease expiration), Southwest Power Administration
(5.4% NRA, 2033 lease expiration) and McAfee and Taft, PC (5.0%
NRA, 2027 lease expiration).

The reported Q1 2024 NOI DSCR is 1.10x compared to 1.06x at YE
2021, 1.15x at YE 2020 and 1.53x at September 2019. Fitch's 'Bsf'
rating case loss of 28% assumed a discount to the most recent
appraisal value and a stressed value of $40 psf.

The third largest loan and the third largest contributor to
expected loss is the 465 Park Avenue Retail Condominium (14.3% of
the pool). The loan is secured by a 39,153 sf commercial
condominium located at the northeast corner of E 57th Street and
Park Avenue in midtown Manhattan. The property was reportedly 47%
leased at YE 2023. The sponsor, Charles Cohen, entered into a
12-year master lease to cover the vacant space as the property was
initially vacant. Fitch's 'Bsf' rating case loss of 15% assumed a
discount to the most recent appraisal value and a stressed value of
$425 psf.

Increased CE; Interest Shortfalls and Realized Losses: As of the
September 2024 remittance report, the pool's aggregate balance has
been reduced by 90% to $123.1 million from $1.26 billion at
issuance. As noted above, there are only six loans remaining with
one loan past its ARD. Cumulative interest shortfalls of $3.02
million are impacting classes E and F and non-rated class G.
Realized losses of $9.4 million are impacting class G.

RATING SENSITIVITIES

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

Downgrades to the classes D and, X-B and E would likely occur if
Fitch's projected losses on the remaining loans increase, including
loans secured by office assets (Williams Center Towers and Canadian
Pacific Plaza) given the uncertainty and timing of recovery of the
remaining loans and potential for prolonged workout timeframes and
increased trust expenses.

A downgrade to class F class would occur with greater certainty of
loss or as losses are realized.

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

Given the significant pool concentration and adverse selection of
these transactions, upgrades are not expected, but may occur with
paydown from dispositions, better than expected recoveries on
specially serviced loans and/or significantly higher values or
recovery expectations on the remaining FLOC, Canadian Pacific
Plaza.

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.


WIND RIVER 2014-1: Moody's Ups Rating on $36MM D-RR Notes From Ba1
------------------------------------------------------------------
Moody's Ratings has upgraded the ratings on the following notes
issued by Wind River 2014-1 CLO Ltd.:

US$65,400,000 Class B-RR Senior Secured Floating Rate Notes due
2031 (the "Class B-RR Notes"), Upgraded to Aaa (sf); previously on
May 25, 2023 Upgraded to Aa1 (sf)

US$29,500,000 Class C-RR Secured Deferrable Floating Rate Notes due
2031 (the "Class C-RR Notes"), Upgraded to Aa1 (sf); previously on
May 31, 2018 Assigned A2 (sf)

US$36,500,000 Class D-RR Secured Deferrable Floating Rate Notes due
2031 (the "Class D-RR Notes"), Upgraded to Baa3 (sf); previously on
July 21, 2020 Downgraded to Ba1 (sf)

Wind River 2014-1 CLO Ltd., originally issued in May 2014,
partially refinanced in March 2017, and full refinanced in May
2018, 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
July 2023.

A comprehensive review of all credit ratings for the respective
transaction has been conducted during a rating committee.

RATINGS RATIONALE

The rating actions are primarily a result of deleveraging of the
senior notes and an increase in transaction's
Over-Collateralization (OC) ratios since September 2023. The Class
A-RR notes have been paid down by approximately 54.83% or $210.1
million since that time. Based on the trustee's September 2024
report[1], the Class A/B, Class C, and Class D Par Value Ratios are
reported at 141.72%, 126.12% and 111.00%, respectively, versus
September 2023[2] levels of 125.69%, 117.94%, and 109.57%,
respectively.

Nevertheless, the credit quality of the portfolio has deteriorated
since the September 2023. Based on the trustee's September 2024
report[1], the weighted average rating factor (WARF) is currently
3033 compared to 2835 in September 2023[2].

No actions were taken on the Class A-RR, Class E-R, and Class F
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: $347,214,110

Defaulted par:  $2,869,913

Diversity Score: 59

Weighted Average Rating Factor (WARF): 3044

Weighted Average Spread (WAS): 3.40%

Weighted Average Coupon (WAC): 2.00%

Weighted Average Recovery Rate (WARR): 46.76%

Weighted Average Life (WAL): 3.74 years

Par haircut in OC tests: 3.39%

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.


[*] Moody's Cuts Eight Bonds From 6 US RMBS Deals Issued in 2005
----------------------------------------------------------------
Moody's Ratings has downgraded the ratings of eight bonds from six
US residential mortgage-backed transactions (RMBS), backed by Alt-A
and Option ARM mortgages issued by multiple issuers.

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: IndyMac INDX Mortgage Loan Trust 2005-AR10

Cl. A-1, Downgraded to Caa1 (sf); previously on Dec 1, 2010
Downgraded to B3 (sf)

Issuer: IndyMac INDX Mortgage Loan Trust 2005-AR12

Cl. 2-A-1A, Downgraded to Caa1 (sf); previously on Mar 2, 2015
Upgraded to B3 (sf)

Issuer: IndyMac INDX Mortgage Loan Trust 2005-AR14

Cl. 2-A-1A, Downgraded to Caa1 (sf); previously on Dec 10, 2010
Downgraded to B3 (sf)

Issuer: IndyMac INDX Mortgage Loan Trust 2005-AR16IP

Cl. A-1, Downgraded to Caa1 (sf); previously on Aug 29, 2012
Confirmed at B1 (sf)

Issuer: Residential Asset Securitization Trust 2005-A11CB

Cl. 1-A-1, Downgraded to Caa1 (sf); previously on Sep 25, 2015
Upgraded to B3 (sf)

Cl. 1-A-2*, Downgraded to Caa1 (sf); previously on Sep 25, 2015
Upgraded to B3 (sf)

Cl. 2-A-5, Downgraded to C (sf); previously on Aug 30, 2012
Downgraded to Ca (sf)

Issuer: Residential Asset Securitization Trust 2005-A5

Cl. A-7, Downgraded to Ca (sf); previously on Apr 1, 2010
Downgraded to Caa2 (sf)

* Reflects Interest-Only Classes

RATINGS RATIONALE

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

The deals Moody's reviewed experienced credit enhancement decline
of approximately 20.0% on average over the past 12 months. This is
a result from the shifting interest nature of the transaction
structure, whereby the supporting bonds have been amortizing and
there is no credit enhancement floor in place. Moody's analysis
also reflected 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 the other rated classes in these deals
because their expected losses remain commensurate with their
current ratings, after taking into account the updated performance
information, structural features, credit enhancement and other
qualitative considerations.

Principal Methodologies

The principal methodology used in rating all classes except
interest-only classes was "US RMBS Surveillance Methodology"
published in July 2022.

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

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

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 Cuts Ratings From 14 US RMBS Issued 2002-2006
---------------------------------------------------------
Moody's Ratings has downgraded the ratings of 16 bonds from 14 US
residential mortgage-backed transactions (RMBS), backed by Alt-A
and subprime mortgages issued by multiple issuers.

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: Ace Securities Corp. Home Equity Loan Trust, Series
2002-HE1

Cl. M-1, Downgraded to Caa1 (sf); previously on Jul 28, 2014
Upgraded to B1 (sf)

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series
2005-HE4

Cl. M-5, Downgraded to Caa1 (sf); previously on Aug 3, 2016
Upgraded to B1 (sf)

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series
2005-HE5

Cl. M-4, Downgraded to Caa1 (sf); previously on Mar 31, 2017
Upgraded to B3 (sf)

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series
2006-NC1

Cl. M-1, Downgraded to Caa1 (sf); previously on Feb 27, 2018
Upgraded to B1 (sf)

Issuer: Ameriquest Mortgage Securities Inc., Series 2005-R7

Cl. M-4, Downgraded to Caa1 (sf); previously on Aug 26, 2016
Upgraded to B2 (sf)

Issuer: Bear Stearns ALT-A Trust 2004-4

Cl. M-1, Downgraded to B2 (sf); previously on Jan 25, 2017 Upgraded
to B1 (sf)

Cl. M-2, Downgraded to B3 (sf); previously on Oct 25, 2018 Upgraded
to B2 (sf)

Issuer: Bear Stearns ALT-A Trust 2005-5

Cl. I-M-1, Downgraded to Caa1 (sf); previously on Apr 13, 2017
Upgraded to B1 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2005-HE12

Cl. M-3, Downgraded to Caa1 (sf); previously on Apr 20, 2018
Upgraded to B1 (sf)

Issuer: Fremont Home Loan Trust 2005-2

Cl. M-4, Downgraded to Caa1 (sf); previously on Jul 5, 2017
Upgraded to B1 (sf)

Issuer: HSI Asset Securitization Corporation Trust 2005-NC1

Cl. M-3, Downgraded to Caa1 (sf); previously on Apr 27, 2017
Upgraded to B1 (sf)

Issuer: IndyMac Home Equity Mortgage Loan Asset-Backed Trust, INABS
2005-B

Cl. M-5, Downgraded to B3 (sf); previously on Mar 31, 2017 Upgraded
to B1 (sf)

Cl. M-6, Downgraded to Caa1 (sf); previously on Jan 13, 2020
Upgraded to B3 (sf)

Issuer: People's Choice Home Loan Securities Trust 2005-1

Cl. M4, Downgraded to Caa1 (sf); previously on Mar 10, 2016
Upgraded to B2 (sf)

Issuer: People's Choice Home Loan Securities Trust 2005-3

Cl. M3, Downgraded to Caa2 (sf); previously on Mar 26, 2019
Downgraded to B3 (sf)

Issuer: Popular ABS Mortgage Pass-Through Trust 2006-B

Cl. M-1, Downgraded to Caa1 (sf); previously on Mar 19, 2018
Upgraded to B1 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance as well as
Moody's updated loss expectations on the underlying pools. The
rating downgrades of the bonds are primarily due to outstanding
interest shortfalls on the bonds that are not expected to be
recouped. These bonds have weak interest recoupment mechanism where
missed interest payments will likely result in a permanent interest
loss. Unpaid interest owed to bonds with weak interest recoupment
mechanisms are reimbursed sequentially based on bond priority, from
excess interest, if available, and often only after the
overcollateralization has built to a pre-specified target amount.
In transactions where overcollateralization has already been
reduced or depleted due to poor performance, any such missed
interest payments to these bonds is unlikely to be repaid.

No actions were taken on the other rated classes in these deals
because their expected losses 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 principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in July 2022.

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

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


[*] Moody's Takes Action on 11 Bonds From 6 US RMBS Deals
---------------------------------------------------------
Moody's Ratings, on Oct. 3, 2024, upgraded the ratings of nine
bonds from five RMBS transactions and downgraded the ratings of two
bonds from one transaction. The bonds are backed by Subprime,
Option ARM and Alt-A mortgages issued by multiple issuers.

A list of the Affected Credit Ratings is available at
https://urlcurt.com/u?l=FFUwzs

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: DSLA Mortgage Loan Trust 2005-AR6

Cl. 2A-1A, Upgraded to Baa3 (sf); previously on May 28, 2021
Downgraded to Ba1 (sf)

Issuer: FBR Securitization Trust 2005-4, Mortgage-Backed Notes,
Series 2005-4

Cl. M-1, Upgraded to Aaa (sf); previously on Jun 29, 2023 Upgraded
to A1 (sf)

Issuer: Fremont Home Loan Trust 2005-C

Cl. M3, Upgraded to Aa1 (sf); previously on Jun 6, 2023 Upgraded to
Aa2 (sf)

Issuer: Impac CMB Trust Series 2005-4 Collateralized Asset-Backed
Bonds, Series 2005-4

Cl. 1-M-1, Upgraded to Ba3 (sf); previously on Dec 4, 2023 Upgraded
to Caa1 (sf)

Cl. 1-M-2, Upgraded to Caa1 (sf); previously on Dec 4, 2023
Upgraded to Caa3 (sf)

Cl. 1-M-3, Upgraded to Caa1 (sf); previously on Feb 20, 2009
Downgraded to C (sf)

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2003-3

Cl. B, Upgraded to Baa2 (sf); previously on Jun 5, 2023 Upgraded to
B3 (sf)

Cl. M-1, Upgraded to Baa2 (sf); previously on Jun 5, 2023 Upgraded
to Baa3 (sf)

Cl. M-2, Upgraded to Baa2 (sf); previously on Jun 5, 2023 Upgraded
to B1 (sf)

Issuer: Renaissance Home Equity Loan Trust 2004-1

AV-1, Downgraded to Ba1 (sf); previously on Dec 4, 2023 Downgraded
to Baa2 (sf)

AV-3, Downgraded to Ba1 (sf); previously on Dec 4, 2023 Downgraded
to Baa2 (sf)

RATINGS RATIONALE

The rating actions reflect the recent performance, the level of
credit enhancement available, as well as Moody's updated loss
expectations on the underlying pools.

The rating upgrades are primarily a result of an increase in credit
enhancement available to the bonds and/or an update to Moody's
expected losses. This has improved the loss coverage levels for
each of the upgraded tranches.

The downgrades of class AV-1 and AV-3 from Renaissance Home Equity
Loan Trust 2004-1 reflect the impact of performance triggers on the
amortization of the outstanding classes. More specifically, the
delinquency trigger in this transaction has toggled between passing
and failing for the past few years. When the delinquency trigger is
failing, the class AV-1 and AV-3 are receiving principal and the
balances are amortizing. However, when the delinquency trigger is
passing, the subordinate bonds are receiving principal payments,
thus slowing amortization of the class AV-1 and AV-3 and slowing
any credit enhancement growth provided by the subordinate classes.
This, combined with a higher loss expectation than in previous
reviews, has resulted in a reduction in loss coverage levels for
the deals.

Moody's analysis also considered the existence of historical
interest shortfalls for some of the bonds. While all 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 upgrades 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.

No actions were taken on the other rated classes in these deals
because their expected losses 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 principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in July 2022.

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

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


[*] Moody's Takes Action on Nine Bonds from 8 US RMBS Deals
-----------------------------------------------------------
Moody's Ratings, on Oct. 3, 2024, upgraded the ratings of six bonds
and downgraded the ratings of three bonds from eight RMBS
transactions, backed by Subprime and Option ARM mortgages issued by
multiple issuers.

A list of Affected Credit Ratings is available at
https://urlcurt.com/u?l=In0kyc

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: Aames Mortgage Investment Trust 2004-1

Cl. M6, Downgraded to Caa3 (sf); previously on Feb 7, 2019
Downgraded to Caa1 (sf)

Issuer: Aegis Asset Backed Securities Trust 2003-2

Cl. M1, Downgraded to Baa1 (sf); previously on Feb 22, 2023
Downgraded to A3 (sf)

Issuer: Aegis Asset Backed Securities Trust 2004-1

Cl. M1, Downgraded to Caa1 (sf); previously on May 23, 2023
Downgraded to B2 (sf)

Issuer: Aegis Asset Backed Securities Trust 2005-5

Cl. M1, Upgraded to Aaa (sf); previously on May 12, 2023 Upgraded
to A3 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2007-HE6

Cl. I-A-1, Upgraded to Baa1 (sf); previously on Apr 20, 2018
Upgraded to Baa3 (sf)

Issuer: First Franklin Mortgage Loan Trust 2006-FF17

Cl. A1, Upgraded to A3 (sf); previously on Sep 30, 2022 Upgraded to
B2 (sf)

Issuer: Fremont Home Loan Trust 2006-2

Cl. II-A-3, Upgraded to A1 (sf); previously on May 12, 2023
Upgraded to Baa2 (sf)

Cl. II-A-4, Upgraded to Baa1 (sf); previously on May 12, 2023
Upgraded to Baa3 (sf)

Issuer: GreenPoint Mortgage Funding Trust 2006-AR4

Cl. A6-A, Upgraded to B1 (sf); previously on Dec 9, 2010 Downgraded
to Caa1 (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 an increase in credit enhancement
available to the bonds. The rating downgrades are results of
outstanding credit interest shortfall that is unlikely to be
recouped or the bond is expected to be impaired.

The transactions with upgrades continue to display strong
collateral performance. Credit enhancement levels, over the last 12
months, have grown on average 3.0% for the tranches upgraded.

The rating upgrades 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 considered the existence of current and historical
interest shortfalls for some of the bonds. The size and length of
the past shortfalls, as well as the potential for recurrence, were
analyzed as part of the upgrades and downgrades.

Certain bonds in this review are currently impaired or expected to
become impaired. Moody's downgrades also reflect any losses to date
as well as Moody's expected future loss.

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 the other rated classes in these deals
because their expected losses remain commensurate with their
current ratings, after taking into account the updated performance
information, structural features and credit enhancement.

Principal Methodology

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

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

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


[*] Moody's Takes Action on Seven Bonds From 7 US RMBS Deals
------------------------------------------------------------
Moody's Ratings has upgraded the ratings of two bonds and
downgraded the ratings of five bonds from seven US residential
mortgage-backed transactions (RMBS), backed by Alt-A and subprime
mortgages issued by multiple issuers.

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: ACE Securities Corp. Home Equity Loan Trust, Series
2006-ASAP1

Cl. M-1, Downgraded to Caa1 (sf); previously on Feb 3, 2017
Upgraded to B1 (sf)

Issuer: Bear Stearns ALT-A Trust 2004-11

Cl. I-M-1, Downgraded to B3 (sf); previously on Feb 14, 2017
Upgraded to B1 (sf)

Issuer: BNC Mortgage Loan Trust 2007-1

Cl. A4, Downgraded to B1 (sf); previously on Jun 1, 2022 Upgraded
to Baa3 (sf)

Issuer: First Franklin Mortgage Loan Trust 2006-FF14

Cl. A5, Downgraded to B1 (sf); previously on Oct 16, 2018 Upgraded
to Baa2 (sf)

Issuer: Fremont Home Loan Trust 2005-B

Cl. M5, Upgraded to Aaa (sf); previously on Dec 20, 2022 Upgraded
to A2 (sf)

Issuer: J.P. Morgan Alternative Loan Trust 2005-A2

Cl. 1-M-1, Downgraded to Caa1 (sf); previously on Jul 19, 2018
Upgraded to B1 (sf)

Issuer: Structured Asset Securities Corp Trust 2006-WF3

Cl. M2, Upgraded to B3 (sf); previously on May 9, 2018 Upgraded to
Caa3 (sf)

RATINGS RATIONALE

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

The rating downgrades are due to outstanding interest shortfalls on
these bonds that are either not expected to be recouped or there's
uncertainty of whether they can be recouped. Some of these bonds
have weak interest recoupment mechanisms where missed interest
payments will likely result in a permanent interest loss. Unpaid
interest owed to bonds with weak interest recoupment mechanisms are
reimbursed sequentially based on bond priority, from excess
interest, if available, and often only after the
overcollateralization has built to a pre-specified target amount.
In transactions where overcollateralization has already been
reduced or depleted due to poor performance, any such missed
interest payments to these bonds is unlikely to be repaid.

Principal Methodology

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

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

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


[] Moody's Takes Action on 13 Bonds from US RMBS Issued 2004-2007
-----------------------------------------------------------------
Moody's Ratings, on Oct. 3, 2024, upgraded the ratings of 12 bonds
and downgraded the rating of one bond from six US residential
mortgage-backed securities (RMBS) transactions backed by scratch
and dent mortgages.

A list of Affected Credit Ratings is available at
https://urlcurt.com/u?l=TH0zJb

A comprehensive review of all credit ratings for the respective
transaction has been conducted during a rating committee.

The complete rating actions are as follows:

Issuer: Bear Stearns Asset Backed Securities Trust 2007-1

Cl. A-3, Upgraded to Aa1 (sf); previously on Dec 12, 2023 Upgraded
to A3 (sf)

Issuer: RAAC Series 2007-SP1 Trust

Cl. M-2, Upgraded to Baa1 (sf); previously on Dec 12, 2023 Upgraded
to B1 (sf)

Issuer: RAMP Series 2004-SL1 Trust

Cl. A-I-2, Upgraded to Aaa (sf); previously on Jul 17, 2012
Downgraded to Aa2 (sf)

Cl. M-I-1, Upgraded to Aa1 (sf); previously on Jul 17, 2012
Downgraded to A2 (sf)

Cl. M-I-2, Upgraded to Baa1 (sf); previously on Jul 1, 2015
Downgraded to Baa3 (sf)

Cl. M-I-4, Downgraded to Caa1 (sf); previously on Jul 1, 2015
Downgraded to B2 (sf)

Issuer: Structured Asset Securities Corp Trust 2007-TC1

Cl. M-2, Upgraded to Aaa (sf); previously on Dec 12, 2023 Upgraded
to Aa2 (sf)

Cl. M-3, Upgraded to Aaa (sf); previously on Dec 12, 2023 Upgraded
to Baa1 (sf)

Cl. M-4, Upgraded to A1 (sf); previously on Dec 12, 2023 Upgraded
to Ba2 (sf)

Cl. M-5, Upgraded to Ba1 (sf); previously on Dec 12, 2023 Upgraded
to Caa2 (sf)

Issuer: Structured Asset Securities Corporation 2005-GEL4

Cl. M3, Upgraded to A1 (sf); previously on Dec 12, 2023 Upgraded to
Ba1 (sf)

Issuer: Terwin Mortgage Trust 2007-QHL1

Cl. A-1, Upgraded to Aaa (sf); previously on Dec 12, 2023 Upgraded
to Aa3 (sf)

Cl. M-1, Upgraded to Ba3 (sf); previously on Dec 12, 2023 Upgraded
to Caa3 (sf)

RATINGS RATIONALE

The rating actions reflect the current levels of credit enhancement
available to the bonds, recent performances, analysis of the
transaction structures, and Moody's updated loss expectations on
the underlying pools.

The credit enhancement for the upgraded bonds has grown by an
average of 8% since the last review. Class M-I-4 of RAMP 2004-SL1
was downgraded as the bond is expected to become impaired. Moody's
rating on this bond reflects any losses to date as well as Moody's
expected future loss.  

Moody's analysis also considered the existence of historical
interest shortfalls for some of the bonds. While all 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, and the
potential impact of any collateral volatility on the model output.

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.

No actions were taken on the other rated classes in these deals
because their expected losses remain commensurate with their
current ratings, after taking into account the updated performance
information, structural features, credit enhancement and other
qualitative considerations.

Principal Methodologies

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

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

Up

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

Down

Levels of credit protection that are insufficient to protect
investors against current expectations of loss could drive the
ratings down. Losses could rise above Moody's expectations as a
result of a higher number of obligor defaults or deterioration in
the value of the mortgaged property securing an obligor's promise
of payment. Transaction performance also depends greatly on the US
macro economy and housing market. Other reasons for
worse-than-expected performance include poor servicing, error on
the part of transaction parties, inadequate transaction governance
and fraud.

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


                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

TCR subscribers have free access to our on-line news archive.
Point your Web browser to http://TCRresources.bankrupt.com/and use
the e-mail address to which your TCR is delivered to login.

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S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Philadelphia, Pa., USA.
Randy Antoni, Jhonas Dampog, Marites Claro, Joy Agravante,
Rousel Elaine Tumanda, Joel Anthony G. Lopez, Psyche A. Castillon,
Ivy B. Magdadaro, Carlo Fernandez, Christopher G. Patalinghug, and
Peter A. Chapman, Editors.

Copyright 2024.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $975 for 6 months delivered via
e-mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Peter A.
Chapman at 215-945-7000.

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